Diversity in the Management of Danish Credit Institutions

May 2026

Diversity in the Management of Danish Commercial Banks 2 Diversity Strengthens Management – But Progress Is Slow Diversity in the management of financial companies has recently received increased attention at both the EU and Danish levels. A management composed of a broad range of skills, experiences, ages, genders, and backgrounds can contribute to better decision-making processes, increased innovation, and more robust risk management. The European Banking Authority (EBA), the European banking supervisory authority, produces a benchmarking report every three years on the development of diversity in the management of credit institutions and fund management companies in the EU. The latest report shows that there is still a long way to go to achieve a more balanced gender distribution and general diversity in the boards and management boards of European credit institutions and fund management companies. The report points out that nearly half of the investigated institutions do not have female leaders at the board and management board levels, and progress towards greater diversity is slow. The purpose of this report is to shed light on the status of diversity in the management of Danish credit institutions. The first part reviews the Danish data from the EBA’s analysis with a focus on the boards and management boards of credit institutions. Credit institutions include both commercial banks and mortgage credit institutions. The data analysis shows that the development of diversity at the board and management board levels in Danish credit institutions since the last measurement has been limited, and diversity at these levels is growing slowly. The second part reviews an investigation into how selected commercial banks work on diversity. The investigation supplements the data analysis and includes, in addition to the board and management board, the management level below the management board that reports directly to a management board member. The investigation shows that four factors are particularly important for strengthening diversity efforts: Management anchoring and clear prioritization, systematic target setting and follow-up, succession planning and recruitment with a focus on diversity, and continuous learning and adaptation.

Diversity in the Management of Danish Commercial Banks 3 Table of Contents Diversity Strengthens Management – But Progress Is Slow ................................................................................. 2 Legal Framework ........................................................................................................................................................... 4 Status and Trends for Diversity in Boards and Management Boards of Danish Credit Institutions..... 4 Gender Representation ................................................................................................................................................ 5 Age Representation ....................................................................................................................................................... 6 Educational and Professional Background ................................................................................................................ 7 Summary ........................................................................................................................................................................ 9 Strengthening Diversity Efforts .............................................................................................................................. 9 Management Anchoring and Clear Prioritization .................................................................................................. 9 Systematic Target Setting and Follow-up ............................................................................................................... 11 Succession Planning and Recruitment with a Focus on Diversity ...................................................................... 11 Continuous Learning and Adaptation...................................................................................................................... 12 Appendix List ......................................................................................................................................................... 14 Appendix 1: List of Institutions in EBA Benchmarking ................................................................................... 14

Diversity in the Management of Danish Commercial Banks 4 Legal Framework The work on diversity in the management of financial companies rests on both EU and national regulations. At the EU level, the central legal basis is Article 91 of Directive 2013/36/EU (CRD IV), which requires credit institutions to establish a policy that promotes diversity in the management body. The institutions must ensure a broad range of qualifications and competencies in management, pursuant to Article 91(10), while Article 91(11) obliges competent authorities to collect and benchmark information on diversity policies and their implementation. On this basis, the EBA has been mandated to conduct benchmarking exercises every three years and publish reports on developments in the area. In Denmark, the rules on diversity are implemented in the Financial Business Act (FiL). The board must establish a diversity policy that promotes sufficient diversity in qualifications and competencies among board members, pursuant to Section 70(1), no. 4. Additionally, Section 79a contains requirements for targets and policies for the underrepresented gender in the board and at other management levels in certain companies. Furthermore, explicit requirements for targets and policies for the underrepresented gender in management have been introduced, which also cover a large number of Danish listed credit institutions. These requirements are set out in Act No. 1602 of 17 December 2024 on gender distribution among management members in certain large listed joint-stock companies (the Gender Balance Act). Overall, the regulations ensure that credit institutions actively work to promote diversity in their board, management board, and management layers immediately below the management board. The regulations form the framework for this thematic investigation into diversity in management. Status and Trends for Diversity in Boards and Management Boards of Danish Credit Institutions Diversity concerns the presence of differences among management members and covers several different dimensions. The differences can be both visible and invisible and include, for example, gender, age, education, ethnicity, and geographical background. This section illustrates the status and development trends for diversity at the board and management board levels in Danish credit institutions. The EBA conducts a benchmarking exercise every three years among all EU member states based on data on diversity collected from selected institutions in the member states. The purpose is to measure trends and development and identify challenges. The EBA presents the results in a benchmarking report. The latest report was published in April 2026. Selected Danish institutions are included in the EBA’s benchmarking. The Danish Financial Supervisory Authority has reviewed the data for the Danish credit institutions included in the EBA’s latest benchmarking to shed light on developments in Denmark. The following sections focus on developments in Denmark, and the EBA’s benchmarking is used to compare trends at the EU level.

Diversity in the Management of Danish Commercial Banks 5 Gender Representation The figure below provides an overview of the gender composition in the management layers of Danish credit institutions. The figure also illustrates the development during the period between the last two benchmarking exercises. The institutions' reports show a general continued tendency towards an unbalanced gender distribution at the top management levels. Men are significantly overrepresented at all management levels, with the exception of employee-elected board members, where the distribution is more balanced. Women are therefore still underrepresented at the top management levels in Danish credit institutions. A closer analysis of the distribution across the different levels shows that the share of women decreases the higher one moves up the management hierarchy. Particularly in positions such as Managing Director and Chairman of the Board, the share of women is very low. The European benchmarking shows a higher share of women at the management board level and for chairmen of the board than in Denmark. The most balanced gender distribution is seen among employee-elected board members, where the distribution is just under 60 percent men and 40 percent women. This greater balance may be due to the fact that this group is elected among and by the company's employees, where the gender distribution is often more equal. At the European level, the same trends apply with a skewed distribution between women and men in the two management bodies. The general development shows an improvement, but also that it is happening slowly. Managing Directors are not included in the category "Management Board", and chairmen of the board as well as employee-elected board members are not included in the category "Board of Directors".

Diversity in the Management of Danish Commercial Banks 6 Age Representation The following section provides an overview of the age distribution in the management board and board of directors and highlights how the composition of younger and older leaders has developed over time. The age distribution across the different management levels shows a significant overrepresentation of directors in the 51-60 age group. Both in 2021 and 2024, the majority of directors were placed in this age group. The figures also show that the share of younger management members (under 50 years) is very low – and furthermore declining. The same trend applies at the board level, with an overrepresentation of board members in the older age categories. In both 2021 and 2024, the dominant age group was 51-60 years. The share of younger board members remained stable at around 20 percent. Among employee-elected board members, there is greater variation in age distribution, and they are generally younger than the other members of the board of directors and management board. At the EU level, similar trends are observed. Here, persons over 60 years old make up 31 percent of board members in smaller institutions, and in larger institutions the share is 39 percent. At the same time, the share of management members under 40 years old is low – and declining. The management levels in Danish credit institutions show no signs of a declining average age or increased age diversity. Compared to 2021, it appears that board and management board members in 2024 are older, for example, 8.7 percent of chairmen of the board are over 70 years old. The increasing average age increases the need for institutions to focus on succession planning, just as it remains important for boards to ensure continuity in the management of credit institutions. Managing Directors are not included in the category "Management Board", and chairmen of the board as well as employee-elected board members are not included in the category "Board of Directors".

Diversity in the Management of Danish Commercial Banks 7 Educational and Professional Background Diversity is not only a question of gender and age. It is also relevant to include educational and professional backgrounds to ensure a broad range of competencies in management. This section provides an overview of the educational and professional backgrounds of board and management board members and highlights how the composition of competencies and experiences has developed over time. Both in 2021 and 2024, management members with an educational background in business economics or economics constituted the largest single group in the management board and board of directors. The boards show greater educational spread than the categories "Business Economics or Economics" and "Advanced education in banking or finance", as a larger share of board members are placed in the "Other" category than what applies to members in the other management categories. The same trends are present at the EU level. The majority – 53 percent – of management board members have an educational background in "Business Economics or Economics". The same applies to 31 percent of board members. Employee-elected board members are not included in the category "Board of Directors".

Diversity in the Management of Danish Commercial Banks 8 The same tendency with great spread applies to the professional background of board members. Within the specific categories, the most board members placed themselves in "Banking" in both 2021 and 2024 with just under 30 percent both years – but the largest category was "Other" with just under 40 percent. Board members with professional experience from "Consulting" and "Legal Services" also fill board seats. It looks different in the management boards, where members with a professional background in the category "Banking" are most prevalent with approx. 76 percent. A smaller share of management board members have a professional background in the category "Other". There is thus greater diversity in professional and occupational background among board members than among directors. Part of the explanation may be that boards do not have an operational role and can therefore draw more heavily on competencies from other industries. The financial sector is characterized by extensive and complex regulation. This requires institutions to have identified relevant risk areas. It is therefore expected that there is an overrepresentation of knowledge and experience from the financial sector. Professional experience at the EU level stems primarily from the banking sector. Just under 83 percent of management board members have experience from here, while the same applies to approx. 55 percent of board members. At the EU level, a smaller share of board members also have experience from consulting and auditing, the public sector, information and communication, and other areas. Also at the EU level, diversity in professional background is generally greater among board members than among directors. Employee-elected board members are not included in the category "Board of Directors".

Diversity in the Management of Danish Commercial Banks 9 Summary The development of diversity at the board and management board levels in Danish credit institutions since the last measurement has been limited. The gender distribution remains skewed, with a low share of women at both the board and management board levels. The only exception is the group of employee-elected board members, where the gender distribution is more balanced. The gender distribution in Danish credit institutions is more skewed than in the EU, where there is a higher share of women at the management board level and for chairmen of the board. Age-wise, the picture is that both board and management board members have generally become older compared to previous measurements, and the majority are now in the 51-60 age group. The share of younger management members is low and still declining. Regarding professional experience, management board members and employee representatives primarily have a background in the banking sector, while board members have a more varied professional background. Here, competencies also include, for example, consulting, legal services, and other industries, such as information and communication technology. Both board and management board members continue to have predominantly economic or business economic educational backgrounds. The educational profiles of employee representatives, however, are more mixed. Overall, the status is that diversity at the board and management board levels is growing slowly. Strengthening Diversity Efforts As a supplement to the results from the diversity benchmarking, the Danish Financial Supervisory Authority investigated how seven selected commercial banks work in the area. Both large and smaller institutions were included in the investigation, where they, based on a number of questions, reported on their work on diversity supplemented with relevant documentation. The Danish Financial Supervisory Authority also conducted interviews with three of the institutions to gain even deeper insight into their experiences in the area. The following reviews the most important experiences and points from the institutions. Management Anchoring and Clear Prioritization All the investigated institutions have established policies on diversity for the board and for the underrepresented gender. Most institutions have established two policies. For some institutions, the work on diversity is also an explicit part of the strategy. The work on diversity is generally anchored in the board, which sets the overall frameworks, approves policies and targets, and follows up on targets and initiatives. In four of the surveyed

Diversity in the Management of Danish Commercial Banks 10 institutions, discussions take place in the nomination committee¹ and are subsequently presented to the board, which also gives final approval. The management board has daily responsibility and helps set the direction for the institutions' work on diversity. The area is typically professionally anchored in HR, which also primarily handles the practical execution of the work. Some institutions have established forums where both employees and leaders participate in implementing or spreading the diversity agenda in the organization. A larger number of institutions have forums where leaders beyond the management board participate in the work, e.g., via consultation and discussions in, for example, ESG committees. One institution has an independent unit that works on diversity, while another institution has decided to allocate dedicated resources to the area in the future. In most institutions, the work on diversity is treated on par with HR's other development tasks. Several of the investigated institutions have management board members with a strong interest in the area, who play an active and visible role in spreading the diversity agenda in the organization. Institutions where management actively participates in the work to promote diversity in the institution are generally further ahead with concrete initiatives and processes. It is crucial that diversity is anchored both in the board and the management board, such that the board follows up and asks questions, and the management board actively and visibly participates in promoting diversity in the institutions. This is best achieved when institutions focus on and actively work with diversity at all management levels. Institutions get the best concrete and operational starting point for the work on diversity by appointing responsible persons or units with a mandate to drive the work and report to management. This is especially true when this mandate is supported by a clear and explicit prioritization from top management. By incorporating diversity into strategies, policies, and action plans, it becomes clear that the area is a priority for the institution. This prioritization is a prerequisite for strengthening development and achieving greater diversity in management. When a person or unit is responsible for and has a mandate for the concrete work on diversity, it sharpens the attention on the development and reporting of the institution's diversity parameters. The responsible unit can be tasked with disseminating and ensuring compliance with the goals in the individual departments in the organization. The overall responsibility is, however, best placed at the top management level. Therefore, reporting on the ongoing development – and on any regression – is necessary to continuously adjust the set targets. Institutions generally define diversity more broadly than just gender and age diversity. This allows institutions to also include other parameters they consider relevant for their specific organization and its employees. ¹ A board committee that, among other things, is tasked with identifying, assessing, and proposing candidates for the board and senior positions. The committee works to ensure that the financial company has the right competencies and a suitable composition in management and the board.

Diversity in the Management of Danish Commercial Banks 11 Systematic Target Setting and Follow-up The institutions' work on diversity consists of several elements. The boards of all investigated institutions have reviewed their policies within the last year, which set the frameworks for diversity in the board and for the underrepresented gender. Generally, this review has resulted in minor adjustments to the policies. In institutions where the underrepresented gender makes up less than 40 percent, targets are set for the board and for the rest of the management, i.e., the management board and the management layer below the management board. Several institutions supplement the two legally required targets with additional targets, e.g., for gender distribution among leaders in general or for the share of men and women among employees in general. One institution has not set targets for the rest of the management. Concrete and objectively measurable targets and indicators are useful tools to support the development towards a higher degree of diversity in management layers. Institutions that communicate openly about objectives, results, and challenges internally create greater room for idea development among employees. It is important for progress that the targets are realistic. If the institution does not meet its targets, further efforts or new initiatives may be necessary, e.g., targeted recruitment efforts, changes in talent programs, or new development courses. It is also important to communicate openly about the reason if the institution adjusts its targets. Regardless of whether the targets are met or not, it is important that the institution's top management continuously follows up on development and results at an appropriate frequency, so that the effort to meet the targets can be adjusted continuously. Succession Planning and Recruitment with a Focus on Diversity Several institutions' work on diversity is closely linked to their succession planning. This helps make the work on diversity more operational, and together with continuous reporting it ensures progress. By integrating diversity as a central criterion in succession planning, institutions ensure that candidates are ready who both meet the necessary competence requirements and expectations for the positions and represent different genders, ages, and backgrounds. The work and frameworks in the individual institutions vary. In some institutions, the work is formalized with fixed and annually recurring activities, while in others it is less formalized, just as some activities are carried out ad hoc rather than systematically. There can be good reasons for the differences, e.g., large organizations often need more structure than smaller organizations. However, formalized succession planning helps ensure focus on diversity – this also applies to smaller institutions. The investigation shows that the area has greater attention now than before, and in some institutions there is a greater professionalization of the area. Several institutions have carried out various initiatives to support and spread diversity in their management layers, and several have, for example, worked on bias, talent development, and leadership clarification processes.

Diversity in the Management of Danish Commercial Banks 12 Several institutions have also carried out recruitment initiatives to ensure more leaders of the underrepresented gender and reduce bias in the recruitment process, e.g., by working on the language in their job advertisements. Furthermore, several institutions focus on inviting candidates of both genders to the vacant leadership positions. The majority of institutions in the investigation focus on talent identification in the organization. Talent identification, however, looks different depending on the institution's size and business model. What they have in common, however, is that it is considered an advantage to have a systematic approach across the organization to identify and develop talent. The system ensures a broader and more diverse talent pool for future leaders. Institution