We have performed certain control procedures on the Novo Nordisk Environment & Bioethics Report 1998 (the "Report"). The Report is the responsibility of and has been approved by the management of the Company. The scope of the Report and the environmental and bioethical aspects reported on have been decided by Company management and are described in the introduction. The Report has been prepared on the basis described in the introduction.

The scope of our work and the procedures that we performed, which were agreed with the Company's management, were as stated below. Our work has been performed according to Professional Standards applied to State Authorized Public Accountants in Denmark. We visited the Company's corporate office and the sites in Kalundborg, Bagsværd and Chartres. Our procedures included interviews with corporate environmental management and those employees at the three sites who have been responsible for compiling data for the Report, as well as analytical procedures and testing samples of supporting documentation.

¥ We ascertained whether the data collection procedures as described in the introduction were used at corporate level (Environmental Affairs) to collect data from reporting units.

¥ We studied the Report and compared the figures reported for 1997 and 1998 with the aggregated information that was consolidated as a result of the procedures noted above. We have assessed whether the figures reported for 1997 and 1998 are appropriately reflected in the Report.

¥ We reviewed the internal control procedures established at a corporate level to verify data submitted from reporting units for inclusion in the Report. On a test basis, we compared the 1998 data reported from a sample of three reporting units (Kalundborg, Bagsværd and Chartres) to the source documentation supporting the submitted data.

¥ We compared the information in the Report on environmentally related investments and costs to the source documentation presented to us and assessed whether the information is appropriately presented in the Report.

The foregoing procedures do not constitute an audit. The scope of work and the procedures performed preclude us from providing an opinion as to whether all figures and other disclosures in the Report are complete and accurate.

Based upon the procedures performed it is our opinion that the Company has applied detailed data collection procedures for the purpose of collecting data from reporting units for inclusion in the Report; and that the figures reported for 1997 and 1998, according to these data collection procedures, are appropriately reflected in the Report. Further, we find that the company has made reasonable endeavours at corporate level to verify the data collected from reporting units for the Report; and for the three units identified above, submitted data is consistent with the source documentation presented to us. In addition, the information on environmentally related investments and costs is consistent with the source documentation presented to us and is appropriately presented.

Copenhagen, April 8, 1999
DELOITTE & TOUCHE
Statsautoriseret Revisionsaktieselskab

Preben J. Sørensen
State Authorized Public Accountant
Global Environmental Services

SustainAbility was commissioned by Novo Nordisk to verify the company's sixth annual environmental report. The objectives were to validate the collation of the data, to verify the statements made in the 1998 Environment and Bioethics Report, and to comment on the company's performance during 1998.

The benchmarks for the verification were:
¥ Novo Nordisk's own policies.
¥ SustainAbility's revised fifty-point checklist of reporting ingredients (Engaging Stakeholders 1996, and The Benchmark Survey 1997, UNEP/SustainAbility).
¥ The ICC Business Charter for Sustainable Development (to which Novo Nordisk is a signatory).
¥ Emerging best practice in corporate environmental and social performance reporting.

The verification process, carried out during January, February and March 1999, involved:
¥ A series of interviews with key personnel at Novo Nordisk in Denmark, and at Novo Nordisk's production plant at Araucária, Brazil. The latter included interviews with the regulatory authorities in the area.
¥ Examination of Novo Nordisk's policies, objectives, monitoring and reporting procedures, background documentation, the data to be included in the report and how they were compiled, the performance indicators used, and the drafts of the report.

SustainAbility is satisfied that:
1) The written statements in this report present a fair and honest reflection of Novo Nordisk's policies, management systems and practices.
2) The description of progress achieved during 1998 is valid and is substantiated by the company's performance data and the internal interviews undertaken by SustainAbility.

SustainAbility's comments and recommendations are:
¥ Novo Nordisk continues to be a leader in the field of voluntary corporate reporting. Its open and proactive approach is exemplary. Over the past 12 months considerable attention has been paid to the ethical aspects of the company's activities and also to social reporting. SustainAbility in conjunction with Professor Svend Andersen of the Centre for Bioethics at the University of Aarhus conducted an in-depth review of bioethics at Novo Nordisk during 1998.

¥ This report addresses not only the traditional environment, health and safety aspects of the company's operations but also a number of other important issues, reflecting the range of activities within the company and the wider interests of stakeholders.

¥ Novo Nordisk is now in the process of integrating sustainable development thinking into its corporate strategy and within the various business activities. In our opinion, the globalization of its various initiatives will be one of the key challenges facing the company in the future.

¥ 1998 has been a year of consolidation within the environmental programme and notable improvements in performance have been achieved in several areas. On the environmental management side, the Copenhagen site gained ISO 14001 certification during 1998 - this was a first in the company. The further development of the eco-productivity indices (EPIs) described in this report is welcomed and will help in the definition of sound performance targets.

¥ The International Network has been effective in increasing awareness and sharing knowledge on best practice throughout the company's operations. We recommend that this body continues to address global standards to help ensure that there is greater consistency worldwide.

¥ Sound progress has also been made in the areas of transport and distribution and supply management in Europe. We recommend that Novo Nordisk now considers the development of environmental auditing practices for key suppliers and a harmonized approach to purchasing worldwide. Likewise, we recommend that the transport and distribution initiative is expanded and extended to cover all production plants worldwide.

¥ Although the company's Health and Safety policy is global, the international coordination of Health and Safety remains, in our view, a major challenge for implementation.

¥ Despite the difficulties in implementing fully the Convention on Biological Diversity, very significant progress has been made in formulating a set of corporate requirements for the use of and access to genetic resources.

¥ As in previous years, we recommend that Novo Nordisk puts into place a more formal environmental auditing procedure at all production sites. Other priorities, in our view, include: the achievement of full compliance worldwide; environmental accounting; the formulation of a coherent strategy for environmental and bioethics education and training; and the continued publication of information on the biosafety aspects of the company's production organisms.

Dr. Vernon Jennings, Director, SustainAbility,
London, April 8, 1999