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140 A.P. Møller-Mærsk A/S Annual Report 2020 Financials Independent Auditor's Report Report on compliance with the ESEF Regulation As part of our audit of the financial statements we performed procedures to express an opinion on whether the annual report of A.P. Møller-Mærsk A/S for the financial year 1 January to 31 December 2020 with the filename APMM-2020-12-31.zip is prepared, in all material respects, in compliance with the Commission Delegated Regulation (EU) 2019/815 on the European Single Electronic For- mat (ESEF Regulation) which includes require- ments related to the preparation of the annual report in XHTML format and iXBRL tagging of the consolidated financial statements. Management is responsible for preparing an annual report that complies with the ESEF Regulation. This responsibility includes: The preparing of the annual report in XHTML format; The selection and application of appropriate iXBRL tags, including extensions to the ESEF taxonomy and the anchoring thereof to ele- ments in the taxonomy, for all financial infor- mation required to be tagged using judgement where necessary; Ensuring consistency between iXBRL tagged data and the consolidated financial statements presented in human-readable format; and For such internal control as Management determines necessary to enable the preparation of an annual report that is compliant with the ESEF Regulation. Our responsibility is to obtain reasonable assur- ance on whether the annual report is prepared, in all material respects, in compliance with the ESEF Regulation based on the evidence we have obtained, and to issue a report that includes our opinion. The nature, timing and extent of proce- dures selected depend on the auditor's judgement, including the assessment of the risks of material departures from the requirements set out in the ESEF Regulation, whether due to fraud or error. The procedures include: Testing whether the annual report is prepared in XHTML format; Obtaining an understanding of the company's iXBRL tagging process and of internal control over the tagging process; Evaluating the completeness of the iXBRL tag- ging of the consolidated financial statements; Evaluating the appropriateness of the com- pany's use of iXBRL elements selected from the ESEF taxonomy and the creation of exten- sion elements where no suitable element in the ESEF taxonomy has been identified; Evaluating the use of anchoring of extension elements to elements in the ESEF taxonomy; and Reconciling the iXBRL tagged data with the audited consolidated financial statements. In our opinion, the annual report of A.P. Møller-Mærsk A/S for the financial year 1 January to 31 December 2020 with the file name APMM-2020-12-31.zip is prepared, in all material respects, in compliance with the ESEF Regulation. Copenhagen, 10 February 2021 PricewaterhouseCoopers Statsautoriseret Revisionspartnerselskab CVR no. 33 77 12 31 Mogens Nørgaard Mogensen State Authorised Public Accountant mne21404 Lars Baungaard State Authorised Public Accountant mne23331 =1

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