Governance

We are setting the bar high
The core of Comwell's entire value chain is to operate and develop responsible business, which is why we approach every work process with a focus on integrity and transparency, working with measurable data and ethical standards.
That is why we also set high standards - not only for ourselves, but also for our suppliers and business partners.
Running a transparent and responsible business
Comwell Hotels is continuously working to provide new data and make it available to the outside world. We believe that an increased insight helps to create the best conditions for us as a company and enables us to move in a positive direction. A continued focus for us is therefore to uncover our CO2 emissions, which we do by securing a range of data from our business partners:
We have identified the source of an estimated 90% of our emissions. We continue to focus on identifying the remaining emissions, and we are working to ensure that as much as possible is 'activity based'. Our suppliers are also on hand to help ensure that the correct data is obtained.
We are always aware of choosing responsible suppliers who, like us, live up to human rights in the areas of health and safety, everyone's right not to experience discrimination, violation of the right to privacy and data security, and the right to decent working conditions. We require this in all our co-operation agreements, and we always hold the right to control the suppliers whose employees work at the hotels on a daily basis.
We work with suppliers and have operations in Denmark and Sweden, and although the risk of corruption and bribery is considered low, it is an important parameter to focus on. Therefore, we have developed an anti-corruption policy that covers both permanent and temporary employees - all to ensure that it is clear to all employees what guidelines apply.
Keeping our word is a part of Comwell's core values - and this applies to all aspects of our business. Therefore, we naturally follow the legislation that exists in relation to running a business in Denmark. Just as we naturally also comply with the following collective agreements we have joined, but also in relation to the statutory whistleblower scheme, which is of course also important to us. The whistleblower scheme should be seen as a supplement to the mechanisms we already have in place at Comwell, where a confidential forum has been established with both the managers in the organisation and the HR department.
Furthermore, our ESG report and Communication Progress are also part of the way we ensure compliance around the things we work with. Therefore, the reporting is also done in accordance with the applicable regulations, as well as our sustainability objectives.
Trust and responsibility
Creating a feeling of security for guests and employees has been a cornerstone of Comwell Hotels for over 50 years. Safety is therefore also in focus when it comes to data ethics and our digital responsibility.

In order to maintain the trust that guests, employees and business partners have in Comwell, we have drawn up a number of data ethical principles that support our desire to create openness about Comwell's data use and supplement our principles of transparency and data minimisation in the data protection rules.
Therefore, we only collect personal data that is relevant and in accordance with applicable legislation. Among other things in connection with contact information and purchase history with guests and business partners and in connection with Comwell Club enrolment. Comwell Club enrolment, but also many other important parameters.
Our data ethics principles are based on recommendations from the Data Ethics Council.
The processing and use of data at Comwell must create security, trust and safety, which is why it is processed in a responsible, transparent and reliable manner - always with a focus on non-discrimination and respect for privacy. We believe that safety must be prioritised above all else, which is why the storage and sharing of data is secured so that data is not inadvertently accessible to unauthorised parties. Of course, employees, guests and business partners always have the opportunity to gain insight into their own data.
Everyone at Comwell Hotels must process personal data in accordance with Comwell's privacy policy, the rules of the General Data Protection Regulation and the rules on secrecy and confidentiality - and Comwell does not sell personal data to third parties.
Critical factors
Like all other hotel chains in Scandinavia, we face several risks and uncertainties that could potentially threaten our ability to conduct business. Therefore, we take a number of precautions in the form of our risk assessment to assess and mitigate risks as well as accommodate possible negative consequences of internal as well as external influences.
Therefore, we always look at the possible impacts on our business, but at the same time make sure to take preventive actions to actively mitigate impacts as much as possible. Both parameters can be read about below.
Possible impacts are assessed to arise, among other things, in connection with requirements and legislation in relation to reducing climate change from our operations and in connection with the new climate law with requirements for fractionalised waste sorting. There is also a general focus on the green agenda in the kitchen, but also in terms of responsible purchasing with a focus on sustainable solutions and minimising waste in both the production and disposal phases.
The most important resource at Comwell is our employees, and changes in the labour supply therefore also have a major impact on our business and the industry in general. A declining student enrolment, which also makes it harder to find qualified labour, and the fact that we are in an industry characterised by changing working hours and hard physical work affects the way we do business. The last one, hard physical labour, can also influence employees to take early career breaks. In addition, diversity is also a prerequisite for developing our business now and in the future.
We always monitor developments closely so that we can stay ahead of any necessary adjustments regarding green energy, consumption, recycling and waste, whilst our strategy includes ambitious climate targets to significantly reduce our carbon footprint across the entire value chain by 2040.
Our participation in the Science Based Targets initiative also works to reduce our CO2 emissions now and in the long term.
Our raw materials policy is designed to be a tool for reducing our CO2 emissions – alongside our standard operating procedures (SOPs), which focus on more plant-based options and less meat. We hold the Organic Food Label in bronze, and wherever possible, we use seasonal Danish ingredients.
All of this is supported by our staff training programmes, including the Green Chef training, as well as our high standards and the ability to conduct quality checks at our suppliers’ premises.
Staff development and well-being are a constant and, not least, crucial focus of Comwell’s business strategy. We have room for everyone who wants to join us, wherever they are in their careers or life stages, and offering our staff training through Comwell College or our Trainee Academy gives everyone the opportunity to develop both professionally and personally, regardless of gender, ethnicity or age.
We maintain a focus on well-being through well-being surveys and other initiatives, whilst doing everything we can to ensure that everyone thrives in a positive, diverse working environment that is open and inclusive, with opportunities for flexible working arrangements – including a focus on gender balance on the board and in senior management, as well as on the need for special consideration and age. That is why we have also drawn up a late-career policy.

