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Annual Report 2023 | LINK in short
3
LINK
IN
SHORT
900
600
300
0
2020
391
2021 2022
486
491
2023
613
+16%
6000
8000
4000
2000
0
2020
3,539
2021 2022
4,914
4,291
2023
6,282
+21%
Revenue NOKm
Adjusted EBITDA NOKm
LINK has 686 employees in 29 oces across
17 countries in Europe
2023 revenue NOK 6.3 billion.
Adjusted EBITDA NOK 613 million
=> EBITDA margin 10%
LINK’s 50 000 customers worldwide last year sent
17 billion messages, averaging more than 300 000
messages per customer
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Annual Report 2023 | LINK in short
4
LINK was founded more than
20 years ago and relisted on
the Oslo Stock Exchange in
2020 following its privatization
in 2018. Since returning to
the stock market, LINK has
completed 6 new acquisitions
in Europe.
2021
2020
WebSMS (Austria)
Altiria (Spain)
Chatbot Xenioo
AMM (Italy)
MarketingPlatform (Denmark)
Tismi (Netherlands)
DEC
NOV
APR
APR
FEB
2022
2019
2018
2017
2016
2023
2024
NOV
LINK has offices in most European countries
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Annual Report 2023 | LINK in short
5
Message from the CEO
LINK made significant commercial progress throughout 2023. The
refocusing of sales and streamlining of costs resulted in an organic
adjusted EBITDA growth of 15% in fixed FX. High leverage at the
beginning of the year was transformed into a solid financial position,
providing significant room for value creation through M&A. Our US
subsidiary was divested for an enterprise value of USD 260 million
at a highly attractive valuation.
Organically, new, more advanced solutions with a significant
potential for increased Return On Investment (ROI) for our customers
continued to gain traction from a low base. Organic volume growth
for the year was 11% and LINK advanced commercially despite the
ongoing challenging macroeconomic situation in Europe. Upon
entering 2024, LINK had a record contract backlog and a rightsized
cost level to generate organic growth and solid financials to pursue
additional inorganic growth.
Last year, after an extensive strategic review and following a bid,
LINK’s board of directors concluded that a divestment of the US
subsidiary Message Broadcast was an attractive path to maximize
shareholder value. The divestiture enhanced earnings predictability
for LINK and provided a new capital structure to fast-track accretive
M&A, leveraging our proven track record for inorganic growth during
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Annual Report 2023 | LINK in short
6
the last decade. LINK’s now divested US subsidiary performed
well in 2023, with several new contract signings supporting the
attractive valuation. LINK is to gain an earnout based on Message
Broadcast’s 2024 performance.
In 2023, LINK completed the implementation of new revenue
enhancing and cost reducing initiatives which commenced the
previous year. Commercial priority was placed into the development
plans and the sale of products on preferred customer channels like
SMS, RCS and WhatsApp and selected CPaaS solutions. All with
proven market demand for our chatbot Xenioo and email marketing
product MarketingPlatform. The result was a quarterly forecasted
gross profit contribution from new contract wins, close to doubling
in 2023.
LINK’s Environmental, Social and Governance (ESG) strategy set in
2021 was followed in 2023 by integrating a sustainability statement
based in principle on the ESRS in the annual report, and by including
extended collection of carbon data not only from Scope 1 and 2, as
in 2022, but also- for the first time- from Scope 3. The results are
visible in this report, with further information in the sustainability
section on our webpage.
LINK is now positioned for value generation in 2024 and beyond,
with a transparent and highly cash generative European business
and a significant excess cash position. Organically, substantial
upsell and new sale potential exists for new multi-channel and two-
way messaging solutions, whilst a strong M&A pipeline provides
material scope for inorganic EBITDA growth through acquisitions
at attractive multiples. The M&A approach is to be disciplined,
accretive and opportunistic within the framework of a conservative
financial policy. The remaining EUR bond, maturing in December
2025, is to be refinanced with net debt in the 2 - 2.5x adjusted
EBITDA range, well below the current incurrence test at 3.5x
adjusted EBITDA.
As our dedicated employees continue their relentless work together
with our numerous customers, partners, and business prospects.
LINK’s global ambitions remain undeterred.
Thomas Berge, CEO
Oslo, 25 April 2024
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Annual Report 2023 | LINK strategy
8
LINK strategy
Because every communication matters, LINK constantly enhances
how messages are delivered and conversations are created for our
customers.
At the heart of LINK’s strategy is our continuous
effort to offer businesses, public sectors and
organizations communication solutions that
increase customer engagement, satisfaction, and
loyalty. By implementing our solutions, LINK’s
customers can greatly improve their customer
satisfaction.
All communication services, from a simple one-
way SMS to a rich omnichannel conversation,
must bring real value, both to LINK’s customer
and to the end user. The communication needs
to be carried and delivered by the most
appropriate channel, depending on the type of
message, profile and preference of the customer,
location or device.
From our longstanding legacy as the leading
enterprise business A2P provider in Europe,
focusing on one-way ubiquitous communication,
LINK has evolved its strategy to become a
worldwide Communication Platform as a
Service (CPaaS) provider.
LINK has maintained and strengthened its enterprise customer focus. We cover the requirements
and needs of large corporations and multinationals, typically offering our solutions for worldwide
deployment. Our larger enterprise clients and government customers are served through dedicated
local sales teams speaking the local language, situated in 29 offices across Europe. This local business
model is, in our view, exceptional in the industry and very difficult to copy or replicate. LINK has spent
more than a decade building up a strong local presence by winning and supporting thousands of
enterprise clients with our bespoke solutions. The needs of smaller enterprises, or Small and Midsize
Enterprises (SMEs) are covered through Self-Sign Up (SSU) portals, where onboarding can be done in
minutes with off the shelf product offerings.
LINK’s Go-to-Market (GTM) approach includes an extensive partner strategy, enabling our partners to
embed LINK solutions into their own product offerings. From independent software vendors to large-
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Annual Report 2023 | LINK strategy
9
scale software integration providers, resellers and telecommunication operators, the LINK Partner
Community has grown to hundreds of partners.
M&A is an important part of LINK ’s growth history and continues to be a key part of our strategy.
Acquisitions help us achieve scale in existing markets and expand into new geographies. The
divestment of LINK’s US subsidiary last year provides ample financing for several potential level-up
cases in Europe and beyond. Smaller bolt-ons in Europe are however a priority.
LINK observes increased market adoption of more advanced and higher margin CPaaS products, like
marketing automation and conversational solutions, and channels with a richer feature set, like RCS
Q4 2022 Q1 2023 Q2 2023 Q3 2023 Q4 2023
+120%
5
7
6
8
11
CPaaS GP - Closed won contracts (NOKm)
and WhatsApp, particularly within the mobile marketing and customer service areas. We are therefore
further strengthening our development efforts and product portfolio in these areas, preparing for future
growth, both from upselling to our fifty thousand existing customers and from new clients.
The dedicated, enthusiastic and united employees who make up our organization are instrumental
in delivering industry leading products and services to our customers. We strive to be an attractive
employer for passionate and driven individuals who want to take part in our journey as a top global
CPaaS player. In our strategic and operational work and in our attitudes and behaviours towards
colleagues, customers and suppliers, we regard diversity, equity and inclusion as levers for innovation,
development and profitability. Our ESG criteria form an integral part of LINK ’s strategy. For more,
please refer to the Sustainability Statement in this report.
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Annual Report 2023 | LINK strategy
10
LINK’s recurring and
growing business model
LINK derives revenue from three main use cases: notifications,
mobile marketing and customer service, with a solid footprint in a
growing European market.
LINK’s largest share of traffic comes from notification use cases, with around 70% of group revenue.
Notifications are linked to essential activities such as healthcare, utilities and critical supplies and
include reminders, alerts, updates and mission critical communications. The market for essential
communication tends to be stable with a growth momentum in the high single-digits.
LINK is less exposed to mobile marketing use cases, contributing around a fifth of revenue. Digital
messaging for marketing has for years been an important channel for large retailers. With higher
engagement scores and click-through rates for RCS and WhatsApp, we are now also seeing accelerated
interest from smaller retailers across Europe. Mobile marketing use cases are more sensitive to
changes in consumer confidence as compared to essential notifications.
Customer service or Contact Center as a Service (CCaaS) is an area with significant value creation
potential from CPaaS solutions. As an example, a business may wish to introduce chatbots to resolve
most of their inbound customer enquiries, bringing large cost savings and increasing end user
satisfaction with its ease and timeliness. Customer service, still to a large extent, is based on Interactive
Voice Response (IVR) or automated telephone systems. This is a huge and potentially counter cyclical
growth area for CPaaS players due to the large cost savings possible for clients.
70% 22% 8%
Revenue by use case*
*Estimated from industry classification of customer data
Notifications Mobile marketing Customer service
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Annual Report 2023 | LINK strategy
11
Customers stay with LINK and increase their usage
To reach beyond local enterprise markets, LINK serves global enterprise clients directly through
dedicated Global Sales representatives, with several new multinationals acquired as customers in
2023. LINK endeavours to evolve initial contract wins, which may be just simple OTP messaging, into
deep software integrations and long-term client relations.
Self Sign-Up portals with
strong local SME brands
in several markets
Self Sign-up
LINK’s GTM approach results in increased usage,
new customers and very low churn
LINK focuses on three main GTM approaches to scale revenue through customer acquisitions. Most
valuable is LINK’s enterprise business model that presents a localized salesforce. LINK employs more
than 100 salespeople in local markets across Europe, providing superior service and value by being
present, speaking the local language and appreciating customer journeys over the years.
Q3 2022 Q4 2022 Q1 2023 Q2 2023 Q3 2023 Q4 2023
113
104 104
117
114
110
1.1
1.3
1.5
2.1 2.1
1.3
Net retention rate (NRR) and customer churn (%)
NRR Churn %
Dedicated partner
managers following up tier
based program
Partners
More than 100 local
salespeople speaking the
language and knowing the
customers. Global Sales
team reaching beyond
local markets
Enterprise
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Annual Report 2023 | LINK strategy
12
Our partnership program is LINK’s second GTM strategy with dedicated partner managers built around
LINK’s success in the Nordics, where partners have been instrumental for growth and scalability.
The program has in recent years been expanded throughout Europe and is divided into three tiers,
depending on the level of integration and commercial cooperation.
LINK’s third GTM approach sees the presence of SSU portals with strong local brands in several
markets. SSUs form the central part of the business with high margin local SME customers. LINK’s top
three SSU portals and brands are SMSAPI, Spot-Hit and WebSMS.
Official
Platinum Partner
Official
Gold Partner
Official
Certified Partner
SMSAPI, offered in a number of European languages,
operates out of Poland and has successfully been expanded
into Sweden and Bulgaria
Spot-Hit, a multi-channel CPaaS brand with a strong retail
position. Based in France, it is also offered to the Spanish
market and selected UK customers as a white-label solution
WebSMS, easy-to-use online portal for SMS messaging in the
DACH region. The portal allows for numerous SMS messages
to and from multiple contacts simultaneously
powered by
Q1 22 Q2 22 Q3 22 Q4 22 Q1 23 Q2 23 Q3 23 Q4 23
27
23
22
47
40
36
24
42
Gross profit contribution from new contract wins
NOKm
A2P CPaaS
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Annual Report 2023 | LINK strategy
13
LINK to execute on M&A
following US divestment
LINK has a proven M&A track record in creating value beyond organic growth. In less than 10 years,
LINK has completed more than 30 acquisitions to become the clear market leader for enterprise
messaging solutions in Europe. Since the IPO in October 2020, LINK has completed 6 acquisitions in
Europe; WebSMS in Austria, Tismi in the Netherlands, MarketingPlatform in Demark, AMM and chatbot
Xenioo in Italy, and Alteria in Spain.
LINK market leader in Europe through acquisitions
01
02
03
04
05
06
07
08
09
10
12
13
14
15
16
17
18
19
20
21
24
22
23
25
26
27
28
30
31
29
11
01
04
07
10
13
16
19
22
25
28
02
05
08
11
14
17
20
23
26
29
31
03
06
09
12
15
18
21
24
27
30
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Annual Report 2023 | LINK strategy
14
Value is driven by acquiring companies
that advance LINK’s core business. Add-on
acquisitions aim to increase our customer base
and grow market share in local markets, whilst
level-up cases refer to acquisitions of larger
companies to gain access to new markets.
The M&A process follows a clear path from
target identification through to integration and
realization of synergies. Suitable targets must
be established and profitable with a documented
low customer churn. Valuation must be accretive.
Strong local market
position and strong
telecom operator
relationship
Cash EBITDA
positive and
accretive to LINK
from day one
Solid, well-
diversified
customer portfolios
with low churn
~80% overlapping
technology, strong
commercial
enterprise focus
Synergy potential
to create further
value
Smaller bolt-ons to further strenghten
market position and realize synergies
Acquire platform companies in new
territories to gain and build market
position
Add-on
Level-up
M&A
playbook
guidelines
01
02
03
04
05
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Annual Report 2023 | LINK strategy
15
In April 2021, LINK acquired AMM in Italy. AMM operates within mobile-marketing
and web-advertising and the product offering includes SMS A2P, email services
and chatbots. The company served close to 3 500 enterprise and SME customers
throughout Italy by direct sales and a self-sign-up (SSU) platform. The acquisition
consolidated LINK’s position as a leading CPaaS player in the Italian market.
LINK acquired Altiria in December 2021. The company is headquartered in Madrid
and active in the A2P market in Spain in addition to some activity in other Spanish-
speaking countries through its web-based, go-to-market business model. Altiria
is the market leader within nongovernmental organizations (NGOs) in the Spanish
market. The acquisition enabled LINK to consolidate and further expand its position
in Spain through upselling opportunities and a strengthening of its SSU offering.
LINK entered the French market in 2019 by acquiring Netsize, a leading enterprise
focused A2P player. At the time, Netsize had struggled with flat or declining
revenue and gross profits for years. The LINK integration rekindled growth through
implementation of best practices and streamlining of operations. The efficiency gains
improved the cost position and revenue synergies were realized through increased
commercial effectiveness.
M&A track record
Bolt-ons in Italy
M&A track record
Bolt-ons in Spain
M&A track record
Level-up into the French market
Large and diverse M&A pipeline with bolt-ons in
Europe as priority
LINK seeks potential targets from an extensive and largely exclusive M&A pipeline including local
players with strong market positions and level-up cases into new regions. The digital messaging
industry is still fragmented, and LINK’s ambitions remain with several potential level-up cases in Europe
and beyond. Smaller bolt-ons in Europe however also remain a priority to provide further scale through
cost synergies and quicker upselling potential. The M&A pipeline holds an additional near-term EBITDA
potential of more than NOK 200 million in Europe alone.
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Annual Report 2023 | Product portfolio and the digital messaging industry
17
LINK product portfolio
and the digital
messaging industry
In 2023, the trend for Application-to-Person (A2P) messaging was moving towards Communication
Platform as a Service (CPaaS) solutions, with the emergence of new technologies that enable more
advanced applications. LINK is committed to being a leader in digitalization by providing products and
solutions that exceed customer expectations and anticipate market developments.
LINK Mobility’s product portfolio is shifting from basic one-way A2P messaging to conversational
CPaaS solutions. It currently consists of messaging channels and software solutions. The move
towards conversational interfaces is primarily driven by utilizing more advanced channels with greater
capabilities than the basic ones. To adapt to this transition, LINK creates products that allow customers
to choose their preferred communication channels with end-users. When identifying the best solution,
the focus is on customer objectives and required system interactions to streamline or digitize the
communication process. Once a successful solution has been designed, LINK achieves scalability by
marketing the product to other industries and markets.
Notifications
Alerts
Promotions
Payments
Invoices
Updates
Chat
TWO WAYS COMMUNICATIONS
Enhanced interaction
through digital
solutions
Companies can easily create, automate, and send communications through multiple channels by
combining LINK’s Messaging APIs with Software Solutions.
Uniquely targeted
messaging on preferred
channels
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Annual Report 2023 | Product portfolio and the digital messaging industry
18
LINK Mobility Product Offering
A one-stop-shop for communication needs
MyLINK Portal: Centralizing Customer Engagement and Management
In 2023, LINK Mobility continued to innovate in customer engagement through the MyLINK Portal. The
Portal empowers customers by providing a single access point to the full suite of LINK offerings.
Product Management and Accessibility: Customers can effortlessly manage their product portfolio,
access services, and explore additional offerings within the portal. The intuitive interface ensures
seamless navigation and management, enhancing the user experience.
Administrative Control: Administrators have robust tools to assign user permissions, ensuring precise
product management, accurate invoicing, and streamlined account settings. This level of control is
pivotal for maintaining organizational efficiency and governance.
User Empowerment: The MyLINK Portal is designed to foster autonomy among users, allowing them
to utilize each LINK product’s features to their full potential. This direct access is crucial for leveraging
the capabilities that our solutions offer.
Expansion and Discovery: We encourage exploration within the MyLINK Portal, guiding users to
discover and acquire additional LINK products that can further their business objectives.
Products
MyLINK Connect
MyLINK Marketing Platform
MyLINK Engage
MyLINK Payment
MyLINK CDP
MyLINK Messaging APIs
LINK
my
CDP
Engage
Payment
Marketin Platform
Messaging APIs
Automate conversations between companies
and people across a wide range of different text
and voice channels.
Gather all your channels in one place, so you can reach
the customer at the right time, on the right platform,
with the right channel.
Maximize your global reach by leveraging our
enterprise platform to effortlessly send and receive
SMS text messages on a massive scale.
Enable payment checkouts via our versatile API across
a range of channels, with a strong focus on our chat
functionality.
Aggregate customer data from various sources,
including websites, mobile apps and CRM systems,
creating a unified view for personalized expiriences.
Send and receive personal, secure messaging on
customers' preferred channels. Go omnichannel and
transition from one channel to another with ease.
Purchase
Lean more
Purchase
Lean more
Purchase
Lean more
Purchase
Lean more
Purchase
Lean more
Purchase
Lean more
LINK’s all-in-one solution
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Annual Report 2023 | Product portfolio and the digital messaging industry
19
Messaging channels
Any industry, any channel.
LINK provides businesses access to different messaging channels, such as SMS, WhatsApp, RCS,
Viber, Instagram, Messenger, and Email, and helps them effectively combine these channels to hone
an effective omnichannel strategy.
It is vital to select a channel that aligns with business and end-user preferences. LINK’s selection
of channels provides brands with the flexibility to experiment, target, and yield desired results. Our
solutions allow brands to maximize KPIs through value-driven and engaging user experiences.
LINK provides a guided process to help its customers identify a channel that best suits their needs
and the needs of their customers. The available channels are suitable for various industries and users,
ranging from public healthcare alerts via SMS through to influencers on WhatsApp. Regardless of the
chosen route, the flexibility of choice allows businesses to create a value-driven campaign to engage
their users and generate a return on investment.
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Annual Report 2023 | Product portfolio and the digital messaging industry
20
Notifications.
MyLINK Engage offers traditional A2P notification messages that enable customers to communicate
with individuals and large groups both internally and externally. The primary communication channel
provided is SMS, which has global reach and high recipient attention. Additionally, customers can use
channels such as RCS or WhatsApp. The solutions include various features such as opt-in and opt-
outs, automated responses and actions, two-way capabilities, forwarding, voting, and competitions to
ensure efficient communication and user satisfaction for both sender and recipient.
Marketing automation.
The MyLINK MarketingPlatform solution efficiently engages and converts leads with the help of social
media and search engine optimization. Advanced segmentation helps in accurate targeting, ensuring
high returns on investment. The key to marketing success is sending automated campaigns with
personalized content at the right time and through the right channel. The solution provides a visual
builder accessible from the web browser to create templates and customer journeys across various
channels. It is easily integrated with all data sources and provides an array of standard connectors
to market leading systems. The customer data platform predicts customer preferences, sentiment,
brand loyalty, and frustrations, enabling organizations to create personalized marketing campaigns,
customer journeys and product recommendations.
Chatbot
MyLINK Connect is a solution that handles one-to-one interactions between customers and chatbots,
live agents, or a combination of both to provide an excellent experience for both parties. It can be
operated from a web browser or an existing application like CRM or CCaaS via standard integrations
or APIs. MyLINKConnect is an omnichannel solution that supports popular channels like web,
SMS, WhatsApp, RCS, Messenger, and Telegram. It can initiate customer interaction for automated
conversational journeys such as surveys and payment journeys. The visual builder in the proprietary
user interface helps build customer journeys. MyLINK Connect streamlines processes and interactions
to improve efficiency and customer experience.
Payment
MyLINK Payment offers an integrated payment solution that consolidates multiple payment channels.
This service supports various payments, including event payments, reminder fees, digital services,
and content charges. It is convenient for customers and easy, efficient, and secure. By using this cost-
effective, dynamic and flexible payment services, customers can eliminate the need for paper invoices.
Software Solutions
True Customer Engagement
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Annual Report 2023 | Product portfolio and the digital messaging industry
21
Multi-Factor Authentication (MFA).
LINK delivers MFA solutions through one-time passwords to a range of customers globally, with the
usage of MFA solutions increasing substantially in recent years. OTP through MFA limits account
theft and the creation of fake accounts. LINK offers standard integrations with market-leading MFA
platforms, primarily using SMS to transport one-time passwords due to its encrypted traffic, 100%
mobile device reach, high attention, and no app download requirement. Other channels like Voice and
WhatsApp are also available for OTP delivery, combining the best SMS and native apps.
Connectivity.
LINK offers global connectivity through local mobile network operators, providing customers with two-
way communication worldwide. We also provide voice services such as masked calls, SIP (Session
Initiation Protocol) trunking, virtual numbers and offer look-up services to validate numbers and
formats, retrieve customer information, and improve user experience.
Timely communications
ONE-WAY
Accessible & automated communications
TWO-WAYS
No manual appointment
confirmation calls required.
His time is now spent on more
value-driven tasks.
Tom
Employee in the local office
Tom
Brand employee in the local office
Does not need to worry about
admin on the test-drive.
He can focus on selling the
perfect experience to his
customers.
Hello, Mrs. Miller.
Thank you for choosing us.
Your test drive is booked for
DD/MM/YY at 11:30. Location:
https://maps.goo.gl/6yBgP
Great!
Selectdate and time
that suits you!
Thank you! Your
appointment has
been scheduled.
DD/MM/YY
11:30
DD/MM/YY
13:30
I want to book a test drive.
DD/MM/YY 13:30
IT GETS BETTER
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Annual Report 2023 | Product portfolio and the digital messaging industry
22
Customer Data Platform (CDP) enables predictive intelligence for personalization. LINK’s proprietary
CDP is primarily utilized within marketing automation. The CDP can predict customer preferences,
value, brand loyalty, sentiment, unmet needs, and frustrations, resulting in a dynamic layer of consumer
intelligence that enables organizations to create personalized marketing campaigns, customer
journeys and product recommendations. With the phasing out of third-party cookie tracking due to
privacy concerns, CDP has become an increasingly important component of omnichannel messaging
within the CPaaS space.
Orchestration. Intelligent orchestration is important for optimal communication across different
channels and customer systems. LINK offers channel orchestration for advanced messaging, where
channels are selected based on user preferences or performance. Application orchestration is also
provided, with integrations and partnerships to optimize communication with other systems. This
ensures that customers can target the right customers and have a full overview of communication
across all channels and systems.
Product focus adapted to market trends
Speaking the customer’s language
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Annual Report 2023 | Product portfolio and the digital messaging industry
23
The digital messaging
industry
Transforming Communication: Customer-Centric Approach with
a Multi-Channel Conversational Software
In today’s ever-changing digital landscape, it is crucial to prioritize our customers’ ability to communicate
with end-users and help them achieve their objectives effectively. To accomplish this, we must
continue expanding customers’ use of A2P SMS Transactions to a more comprehensive SaaS model
combining OTT and Social Media Channels. We are thrilled to offer our customers a more extensive
range of communication services to connect with their clients. This includes notifications, marketing,
and customer care.
Our customers have faced challenges in adopting new communication channels and providing
seamless communication with their end customers over the past few years. This is mainly due to the
added complexity of integrating these solutions with their core systems. We are excited to provide our
software solutions to assist all our customers in bridging this gap.
Know your end-user
Our cutting-edge solutions are crafted to unveil clients’ unique preferences. This knowledge equips
LINK customers to create highly targeted campaign segments and offer bespoke experiences that
truly connect. By personalizing communication, we help brands position as innovative, ensuring each
end-user feels uniquely valued, boosting satisfaction and fostering loyalty.
We are thrilled to offer our support for a broad spectrum of communication channels, including SMS,
WhatsApp, RCS, Email, and popular social media platforms like Instagram, Snapchat, and Facebook
Messenger. Our software solutions are designed to help our customers adopt a multi-channel
approach, making it easier for end-users to interact with different brands and making communication
more convenient and practical.
Best of both worlds: global and local
Customers require adequate assistance to succeed with complex communication. We are dedicated
to maintaining solid local connections in today’s increasingly globalized world. Our goal is to connect
continents with a network of local contacts, offering our customers the best of both worlds. We strongly
believe in the power of relationships and realize that successful business is closely tied to the unique
needs of each community we serve. That’s why we ensure a local representative is always available to
provide personalized support and build meaningful connections.
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Annual Report 2023 | Product portfolio and the digital messaging industry
24
Our solutions are designed to meet the needs of local markets, thanks to the expertise of our local
contacts. With an in-depth understanding of the nuances that drive their respective markets, our
contacts ensure our solutions are tailored to the local ethos.
Predictable business model
Monthly Recurring Revenue (MRR) is a strategic approach in business that offers multiple benefits.
MRR provides a continuous income stream, creating a stable foundation for the business. The steady
flow of monthly revenue allows businesses to plan and innovate confidently. MRR fosters long-term
relationships with customers, transforming them into valued partners. Unlike transactional revenue,
MRR enables businesses to adapt quickly in a dynamic market. The subscription-based model, inherent
in MRR, motivates businesses to continually enhance their offerings, fostering innovation.
Excited about the future
Adopting this customer-centric approach redefines the communication landscape and builds stronger
ties between brands and customers. This strategic shift is more than just a change in direction- it’s an
investment in our future. It will bolster our position in the market and generate sustainable value for
our stakeholders, laying the groundwork for a future where communication is effortless, personalized,
and impactful.
1800s
Industrial Revolution
Telephone created in 1878
1970s
Computing Revolution
Email began its launch in 1971
1990s
Mobile Revolution
The first text message was sent in 1992
2010s
Smart Phone Revolution
Smartphones launched in 2010 introducing
social media apps on-the-go
Present day
We aim to revolutionize communication by extending
our A2P SMS transactions to a SaaS model combining
OTT and social media channels.
We aim to assist our valued customers in embracing
new communication channels and providing seamless
integration with their core systems.
MyLINK Solutions
2000
Joins the Revolution
LINK Mobility provides easy-to-use services
for companies that want to deliver relevant
and personalised customer communication.
CDP
Add-ons
Marketing
Engage
Payment
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Annual Report 2023 | Sustainability statement
26
Introductory note
1.
General information
1.1.
[ESRS 2]
1.1.1.
[BP-1] General basis for preparation of the sustainability statements
1.1.2.
[BP-2] Disclosures in relation to specific circumstances
1.1.3.
[GOV-1] The role of the administrative, management and supervisory bodies
1.1.4.
[GOV-2] Information provided to and sustainability matters addressed by the
undertaking’s administrative, management and supervisory bodies
1.1.5.
[GOV-3] Integration of sustainability-related performance in incentive schemes
1.1.6.
[GOV-4] Statement on due diligence
1.1.7.
[GOV-5] Risk management and internal controls over sustainability reporting
1.1.8.
[SBM-1] Strategy, business model and value chain
1.1.9.
[SBM-2] Interests and views of stakeholders
1.1.10.
[SBM-3] Material impacts, risks and opportunities and their interaction with strategy
and business model
1.1.11.
[IRO-1] Description of the process to identify and assess material impacts, risks and
opportunities
1.1.12.
[IRO-2] Disclosure Requirements in ESRS covered by LINK’s sustainability statement
2.
Environmental information
2.1.
Disclosures pursuant to Article 8 of Regulation (EU) 2020/852 (Taxonomy Regulation)
2.1.1.
Assessment of LINK’s compliance with the EU Taxonomy
2.1.2.
Disclosures under EU Taxonomy
2.2.
[ESRS 2 MDR] Minimum Disclosure Requirements (MDR) related to the material
sustainability matter “Climate change – Energy”
2.2.1.
[MDR-P] Policies adopted to manage material sustainability matter
2.2.2.
[MDR-A] Actions and resources in relation to material sustainability matters
2.2.3.
[MDR-M] Metrics in relation to material sustainability matters
2.2.4.
[MDR-T] Tracking effectiveness of policies and actions through targets
2.3.
[ESRS E1]
2.3.1.
[ESRS 2 GOV-3] Integration of sustainability-related performance in incentive schemes
2.3.2.
[ESRS 2 SBM-3] Material impacts, risks and opportunities and their interaction with
strategy and business model
2.3.3.
[ESRS 2 IRO-1] Description of the processes to identify and assess material climate-
related impacts, risks and opportunities
2.3.4.
[E1-2] Policies related to climate change mitigation and adaptation
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27
2.3.5.
[E1-3] Actions and resources in relation to climate change policies
101
2.3.6.
[E1-4] Targets related to climate change mitigation and adaptation
101
2.3.7.
[E1-5] Energy consumption and mix
102
2.3.8.
[E1-6] Gross Scopes 1, 2, 3 and total GHG emissions
102
3.
Social information
103
4.
Governance information
104
4.1.
[ESRS 2 MDR] Minimum Disclosure Requirements (MDR) related to the material
sustainability matter: “Business conduct – Corporate culture”
104
4.1.1.
[MDR-P] Policies adopted to manage material sustainability matters
104
4.1.2.
[MDR-A] Actions and resources in relation to material sustainability matters
106
4.1.3.
[MDR-M] Metrics in relation to material sustainability matters
108
4.1.4.
[MDR-T] Tracking effectiveness of policies and actions through targets
109
4.2.
[ESRS 2 MDR] Minimum Disclosure Requirements (MDR) related to the material
sustainability matter: “Business conduct – Protection of whistle-blowers”
111
4.2.1.
[MDR-P] Policies adopted to manage material sustainability matters
111
4.2.2.
[MDR-A] Actions and resources in relation to material sustainability matters
112
4.2.3.
[MDR-M] Metrics in relation to material sustainability matters
113
4.2.4.
[MDR-T] Tracking effectiveness of policies and actions through targets
114
4.3.
[ESRS 2 MDR] Minimum Disclosure Requirements (MDR) related to the material
sustainability matter: “Business conduct – Management of relationships with
suppliers”
115
4.3.1.
[MDR-P] Policies adopted to manage material sustainability matter
115
4.3.2.
[MDR-A] Actions and resources in relation to material sustainability matter
115
4.3.3.
[MDR-M] Metrics in relation to material sustainability matters
117
4.3.4.
[MDR-T] Tracking effectiveness of policies and actions through targets
117
4.4.
[ESRS 2 MDR] Minimum Disclosure Requirements (MDR) related to the material
sustainability matter: “Business conduct – Corruption and bribery”
119
4.4.1.
[MDR-P] Policies adopted to manage material sustainability matter
119
4.4.2.
[MDR-A] Actions and resources in relation to material sustainability matters
119
4.4.3.
[MDR-M] Metrics in relation to material sustainability matters
119
4.4.4.
[MDR-T] Tracking effectiveness of policies and actions through targets
120
4.5.
[ESRS G1]
122
4.5.1.
[GOV-1] The role of the administrative, management and supervisory bodies
122
4.5.2.
[G1-1] Business conduct policies and corporate culture
122
4.5.3.
[G1-2] Management of relationships with suppliers
124
4.5.4.
[G1-3] Prevention and detection of corruption and bribery
127
4.5.5.
[G1-4] Incidents of corruption or bribery
128
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28
Introductory note
LINK is subject to social responsibility reporting requirements according to the Norwegian Accounting
Act, § 3-3c, hereunder its section 10 regarding applicability of the EU Taxonomy. The regulations are
openly available on www.lovdata.no.
The structure of LINK’s sustainability statement differs significantly from previous years, as the
statement is for the first time based on the European Sustainability Reporting Standards (ESRS), as
provided by the European Financial Reporting Advisory Group (EFRAG), see https://www.efrag.org/,
and adopted by the Commission Delegated Regulation as regards sustainability reporting standards.
The Norwegian Accounting Act § 3-3c section 6 allows the structure of statement to follow framework
set out by another body, which is the case with the use of ESRS.
As it is based on the ESRS, the sustainability statement for 2023 constitutes LINK’s first step to reaching
compliance with the sustainability reporting requirements included in the Corporate Sustainability
Reporting Directive (CSRD), effective for LINK from the financial year 2024. This first step makes it
possible to follow the structure of the ESRS for future years, and to provide insight into all areas that
will be covered in the years to come. For 2023, LINK’s goal is to follow the ESRS in principle. Full
compliance with CSRD will, however, not be a goal for 2023.
As far as the structure of the statement is concerned, it in principle follows the ESRS, and more specifically
the implementation guidance “[Draft] EFRAG IG 3: List of ESRS datapoints”, as released by EFRAG
on December 22nd 2023, with minor deviations. First of all, the minimum disclosure requirements,
relevant for each material matter, as specified under the ESRS 2 MDR, have been disclosed in the
beginning of each relevant section “E”, “S” and “G”, whereas in the future it is expected to embed them
within the relevant topical standards. Moreover, since a digital taxonomy for the Union sustainability
reporting standards is necessary to allow the reported information to be tagged in accordance with the
ESRS, and it has not been released yet, the statement for the financial year 2023 has been prepared in
a human-readable format only. The machine-readable format is expected in the future.
LINK has adopted and implemented an ESG policy to safeguard the interests of the company’s
shareholders, employees, customers, and other stakeholders. The main ESG figures are also available
on the Euronext pages: https://live.euronext.com/en/product/equities/NO0010894231-XOSL/esg
Sustainability statement
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29
1. General information
1.1. [ESRS 2]
1.1.1. [BP-1] General basis for preparation of the sustainability statement
1.1.1.1. General basis for preparation of sustainability statement
The below presented disclosures constitute the general basis for preparation of LINK’s sustainability
statement.
1.1.1.2. Basis for preparation, scope of consolidation and information on subsidiaries’
exemption from sustainability reporting
The sustainability statement has been prepared on a consolidated basis. The scope of consolidation
is the same as for the financial statements.
LINK Mobility Group Holding ASA (the “Holding Company”) is the parent company of LINK Mobility
Group AS. LINK Mobility Group Holding ASA owns 100% of LINK Mobility Group AS, which in turn owns
100% of 37 LINK subsidiaries located across 13 EU countries, as well as in Norway, the United Kingdom,
the United States of America, Switzerland, and the Republic of North Macedonia (the “Group”, the
“Company”). On November 7th, 2023 LINK has entered into definitive agreement to divest its US-based
subsidiary- Message Broadcast, LLC. The transaction was closed on January 3rd, 2024. Furthermore,
compared to the previous reporting period, AMM S.p.A., located in Arezzo, Italy and Matelab Srl, located
in Lecco, Italy, were merged with LINK Mobility Italia Srl.
All LINK’s subsidiaries included in the consolidation, as listed in a table below, are covered by this
sustainability statement and therefore shall be exempted from the sustainability reporting pursuant to
Articles 19a(9) or 29a(8) of Directive 2013/34/EU.
No. LINK entity Place of business/ country of registration
1 LINK Mobility Group Holding ASA Oslo, Norway
2 LINK Mobility Group AS Oslo, Norway
3 Link Mobility AS Oslo, Norway
4 LINK Mobility USA AS Oslo, Norway
5 Tismi AS Oslo, Norway
6 BK Invest GmbH Vienna, Austria
7 LINK Mobility Austria GmbH Graz, Austria
8 Simple SMS GmbH Wels, Austria
9 Allterpay EOOD Sofia, Bulgaria
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No. LINK entity Place of business/ country of registration
10 LINK Mobility Bulgaria EAD Sofia, Bulgaria
11 LINK Mobility Holding Aps Copenhagen, Denmark
12 LINK Mobility A/S Copenhagen, Denmark
13 Tismi A/S Copenhagen, Denmark
14 Marketing Platform Aps Vejen, Denmark
15 LINK Mobility Oy Tampere, Finland
16 Labyrintti International Oy Tampere, Finland
17 LINK Mobility SAS Boulogne- Billancourt, France
18 Netzise SAS Boulogne- Billancourt, France
19 LINK Mobility Holding SAS Boulogne- Billancourt, France
20 LINK Mobility GmbH Hamburg, Germany
21 GfMB Gesellschaft für Mobiles Bezahlen Hamburg, Germany
22 LINK Mobility Hungary Kft. Budapest, Hungary
23 LINK Mobility Italia Srl Milan, Italy
24 Tismi B.V. Bunnik, Netherlands
25 Tismi Mobile B.V. Bunnik, Netherlands
26 LINK Mobility Poland Sp.z.o.o. Gliwice, Poland
27 Razvoen Centar na eMailPlatfor DOOEL Kumanovo, Republic of North Macedonia
28 Tera Communications DOOEL Skopje, Republic of North Macedonia
29 LINK Mobility SRL Bucharest, Romania
30 Teracomm RO SRL Bucharest, Romania
31 LINK Mobility Spain S.L.U. Madrid, Spain
32 Altiria TIC Sociedad Limitada Madrid, Spain
33 LINK Mobility AB Stockholm, Sweden
34 LINK Messaging AG Rorschach, Switzerland
35 LINK Mobility UK Limited Edinburgh, Scotland
36 Netsize UK Ltd. London, United Kingdom
37 Message Broadcast LLC* Newport Beach, USA
* Under divestiture, as explained above.
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31
1.1.1.3. Extent to which sustainability statement covers upstream and downstream
value chain
The sustainability statement covers LINK’s own operations, as well as direct business relationships in
its upstream and downstream value chain where it has been indicated or when it clearly results from
the context. The value chain information has been included based on its materiality, identified in the
process described under disclosure ESRS 2 IRO-1 (chapter 1.1.11). Description of how LINK understands
its value chain is included under disclosure ESRS 2 SBM-1 (chapter 1.1.8).
1.1.1.4. Information on certain omissions
No specific piece of information corresponding to intellectual property, know-how or results of
innovation has been omitted. No further omissions allowed by Member State have been used.
1.1.2. [BP-2] Disclosures in relation to specific circumstances
1.1.2.1. Disclosures in relation to specific circumstances
The below presented disclosures have been provided in relation to specific circumstances.
1.1.2.2. Time horizons
The sustainability statement complies with time horizons defined in ESRS 1 section 6.4:
•
(a) short-term: one year (the period adopted as the reporting period in LINK’s financial statements);
•
(b) medium-term: from the end of the short-term reporting period (one year) above to five years;
•
(c) long-term: more than five years.
1.1.2.3. Disclosures related to metrics that include value chain data estimated using
indirect sources
No metrics disclosed directly in this sustainability statement include value chain data estimated with
the use of indirect sources. As far as the environmental part is concerned, however, the methodology
on collecting the energy and GHG emissions data is included in the GHG report, available on LINK’s
webpage.
1.1.2.4. Disclosures related to measurement uncertainty
No quantitative metrics or monetary amounts disclosed directly in this sustainability statement are
subject to a high level of measurement uncertainty. As far as the environmental part is concerned,
however, the methodology on collecting the data as well as calculating the energy and GHG emissions
is included in the GHG report, available on LINK’s webpage linked under disclosure 1.1.2.3.
1.1.2.5. Changes in preparation or presentation of sustainability information comparing to
previous reporting periods
The structure of LINK’s sustainability statement is for the first time based- in principle- on the
requirements provided in the ESRS. Therefore, no previous reporting period including metrics, targets, or
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Annual Report 2023 | Sustainability statement
32
estimated figures covered by this statement is available. As a consequence, no changes in preparation
and presentation of sustainability information (other than explained in the introductory note) and no
revisions of figures are disclosed.
1.1.2.6. Errors and corrections for previous reporting periods
The structure of LINK’s sustainability statement is for the first time based- in principle- on the
requirements provided in the ESRS. Since no prior reporting period is available, no errors or corrections
are disclosed. As far as the environmental part is concerned, however, please see the GHG report,
available on LINK’s webpage, linked under disclosure 1.1.2.3.
1.1.2.7. Disclosure of other legislation or generally accepted sustainability reporting
standards and frameworks based on which information has been included in
sustainability statement (including European standards approved by European
Standardisation System- ISO/IEC or CEN/CENELEC standards)
The sustainability statement covers information prescribed by the ESRS, including- in chapter 2.1- the
disclosures pursuant to Article 8 of Regulation 2020/852 of the European Parliament and the Council (EU
Taxonomy) and to the relevant Commission Delegated Regulations. No further information stemming
from other legislation or generally accepted sustainability reporting standards or frameworks have
been included. Hence, no verification by an external assurance provider has been performed in order
to confirm compliance with any ISO/IEC or CEN/CEMELEC standard.
1.1.2.8. Incorporation by reference (list of DRs or DPs mandated by a DR)
No information has been incorporated by reference.
1.1.2.9. Materiality assessment of topics (E4, S1, S2, S3, S4)
LINK has assessed certain topics included in ESRS S1 and ESRS S4 as material, which is specified in
sec. a) below. No matters covered by ESRS E4, ESRS S2, or ESRS S3 have been assessed as material.
Since LINK does not exceed on its balance sheet date the average number of 750 employees during the
financial year, it has decided to omit the information required by ESRS S1 and ESRS S4 respectively, as
allowed by provisions of Appendix C of ESRS 1 (phase-in). Nevertheless, for each such material topic,
LINK discloses below information on relevant policies, actions, metrics and targets.
a. List of sustainability matters (E4, S1, S2, S3, S4) assessed to be material (phase-in)
The following sustainability matters, covered respectively by ESRS S1 and ESRS S4, have been
assessed as material:
•
ESRS S1: Topic “Own workforce” – Sub-topic “Equal treatment and opportunities for all” – Sub-sub-
topic “Training and skills development”
•
ESRS S4: Topic “Consumers and end users” – Sub-topic “Information-related impacts for
consumers and/or end-users” – Sub-sub-topic “Privacy”
No sustainability matters covered by ESRS E4, ESRS S2, or ESRS S3 have been assessed as material.
The results of the materiality assessment are described in detail under disclosure ESRS 2 SBM-3
(chapter 1.1.10).
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33
b. Disclosures relevant for the material sustainability matter “Own workforce –
Equal treatment and opportunities for all – Training and skills development”
>
Disclosure of how business model and strategy take account of impacts related to the
material sustainability matter (phase-in)
LINK strives to be an attractive employer for passionate and driven individuals who wish to take part
in a journey towards being a top global CPaaS player. It regards diversity, equity and inclusion as
levers for innovation, development and profitability. Dedicated, enthusiastic and united employees are
recognized as one of LINK’s most valuable assets, which is reflected in LINK’s strategy and business
model.
> Policies related to the material sustainability matter (phase-in)
The material sustainability matter: “Own workforce – Equal treatment and opportunities for all –
Training and skills development” is managed under LINK’s ESG policy, which includes chapters on
“Engagement, training and development”. The ESG policy is described in this sustainability statement
under minimum disclosure requirements related to the material sustainability matter “Business
conduct – Corporate culture” (chapter 4.1).
> Actions taken to identify, monitor, prevent, mitigate, remediate or bring end to actual or
potential adverse impacts related to the material sustainability matter (phase-in) and
result of such actions
The following actions related to the material sustainability matter “Own workforce – Equal treatment
and opportunities for all – Training and skills development” were taken in 2023:
•
Employees’ training – described in this sustainability statement under minimum disclosure
requirements related to the material sustainability matter “Business conduct – Corporate culture”
(chapter 4.1).
•
Employee Code of Conduct – described in this sustainability statement under minimum disclosure
requirements related to the material sustainability matter “Business conduct – Corporate culture”
(chapter 4.1).
•
Link Voice – described in this sustainability statement under minimum disclosure requirements
related to the material sustainability matter “Business conduct – Corporate culture” (chapter 4.1).
•
myLINKjourney – implemented with an aim to provide a comprehensive framework of employees’
development; available for all LINK employees in the internal online system; initially introduced in
2023 with plans for further implementation in 2024; the results will be monitored on a rolling basis.
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34
> Metrics related to the material sustainability matter (phase-in)
To evaluate performance and effectiveness in relation to material impacts, risks and opportunities
relevant to the material matter “Own workforce – Equal treatment and opportunities for all – Training
and skills development”, LINK uses the following metrics:
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec);
•
LINK Voice participation rate;
•
Employee engagement score.
The metrics are described in this sustainability statement under minimum disclosure requirements
related to the material sustainability matter “Business conduct – Corporate culture” (chapter 4.1).
> Time-bound targets set related to the material sustainability matter (phase-in) and
progress made towards achieving those targets
Targets relevant to each action/ metric and progress towards achieving them is described in
this sustainability statement under minimum disclosure requirements related to the material
sustainability matter “Business conduct – Corporate culture” (chapter 4.1).
c. Disclosures relevant for the material sustainability matter “Consumers and end
users – Information-related impacts for consumers and/or end-users – Privacy”
>
Disclosure of how business model and strategy take account of impacts related to the
material sustainability matter (phase-in)
LINK’s ambition is to provide to its customers state-of-the art electronic communication solutions
that enable them to reach end users globally. Ensuring adequate level of privacy with regard to the
transmitted data, including end users’ personal data, is embedded in LINK’s core values and reflected
in LINK’s strategy and business model.
> Policies related to the material sustainability matter (phase-in)
The material sustainability matter: “Consumers and end users – Information related impacts for
consumers and/or end-users – Privacy” is managed, at a general level, under LINK’s ESG policy, which
includes chapters on data privacy and on information security. The ESG policy is described in this
sustainability statement under minimum disclosure requirements related to the material sustainability
matter “Business conduct – Corporate culture” (chapter 4.1). Moreover, detailed notions relating to
consumers and/or end-users privacy are extensively described in LINK’s Personal Data Protection
Policy, and Information Security Policy. Both policies are described below.
+ Personal Data Protection Policy
1. Key contents of policy
LINK’s Personal Data Protection Policy (PDPP) aims to ensure that any information containing personal
data is processed by LINK in line with the principles expressed in the relevant laws and regulations,
including primarily the EU General Data Protection Regulation (GDPR). Such principles concern
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35
compliance with law, reliability and transparency, purpose limitation, data minimization, regularity,
storage restriction, integrity and confidentiality, as well as accountability. Furthermore, the privacy and
security by design and default principles are taken into account. The policy regulates LINK’s governance
and conduct related to the personal data, covering description of mandates of Data Protection Officer
and Local Privacy Board, as well as matters such as how to ensure compliance with relevant laws and
protection of the rights of relevant stakeholders, security of data processing, the principles of privacy
and security by design and by default, data retention principles, issues related to breach reporting etc.
The policy is complemented with several specific policies, procedures and guidelines relevant to the
detailed topics.
2. Scope of policy or of its exclusions
LINK’s Personal Data Protection Policy has been adopted by the Board of Directors of LINK Mobility
Group Holding ASA. The policy applies to the Holding Company as well as to all its subsidiaries. It
covers all personal data processed by LINK irrespective of whether the Company acts as a Controller
or as a Processor, and regardless if the data is processed in paper or in an electronic form. The policy
is therefore relevant to own operations of the Group, as well as- to a limited extent- its value chain. It
applies to all users who have access to personal data collected, processed or stored by LINK, regardless
of the position held and place of employment, as well as the nature of employment or cooperation with
LINK.
3. Most senior level in organisation that is accountable for implementation of policy
The Global Leadership Team (GLT) has overall responsibility for the implementation of the Personal
Data Protection Policy.
4. Third-party standards or initiatives that are respected through implementation of policy
The following documents and frameworks form basis of LINK’s Personal Data Protection Policy:
•
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on
the protection of natural persons with regard to the processing of personal data and on the free
movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);
•
other relevant EU and national laws and regulations on the protection of personal data.
5. Description of consideration given to interests of key stakeholders in setting policy
Key stakeholders’ interests are taken into consideration during LINK’s materiality assessment and due
diligence processes that form basis for setting out and updating all LINK’s policies.
6. Explanation of how policy is made available to potentially affected stakeholders and
stakeholders who need to help implement it
Full version of the Personal Data Protection Policy is available to all LINK employees through an internal
system. A whistleblowing channel is available to report any suspected, potential or actual breaches.
All employees must complete a GDPR training annually. The privacy statement is publicly available on
LINK’s webpage.
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+ Information Security Policy
1. Key contents of policy
LINK’s Information Security (InfoSec) Policy aims to ensure the Company’s compliance with the
principles expressed in the laws and regulations relevant to the security of information, including
primarily Directive NIS2 and GDPR, as well as industry standards, best practices, and other guidelines.
It sets out rules on how to secure information and ensure that relevant systems preserve their
confidentiality, integrity, availability, and authenticity. The policy regulates LINK’s governance and
conduct related to the security of data, covering notions such as the classification of information,
access control, incident management, network security, physical and environmental security etc. It
includes topics relevant to specific LINK’s departments, as well as to third parties.
2. Scope of policy or of its exclusions
LINK’s Information Security Policy has been adopted by the Board of Directors of LINK Mobility Group
Holding ASA. The policy applies to the Holding Company as well as to all its subsidiaries and is relevant
to own operations of the Group, as well as- to a limited extent- its value chain. The policy aims to ensure
confidentiality, integrity, availability, and authenticity of information by providing organizational and
technical security measures to be used within LINK. Among others, the following topics are described:
•
definition of information security and information security management systems;
•
information security objectives or the framework for setting information security objectives;
•
principles to guide all activities relating to information security;
•
commitment to satisfy applicable requirements related to information security;
•
commitment to continual improvement of the information security management system;
•
assignment of responsibilities for information security management to defined roles;
•
procedures for handling exemptions and exceptions.
3. Most senior level in organisation that is accountable for implementation of policy
The Global Leadership Team (GLT) has overall responsibility for the implementation of the Information
Security Policy.
4. Third-party standards or initiatives that are respected through implementation of policy
The following documents and frameworks form basis of LINK’s Information Security Policy:
•
Directive (EU) 2022/2555 of the European Parliament and the Council of 14. December 2022 on
measures for a high common level of cybersecurity across the Union (NIS2);
•
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on
the protection of natural persons with regard to the processing of personal data and on the free
movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
•
other relevant EU and national laws and regulations on the protection of personal data;
•
best practices and guidelines described in ISO 27001:2022.
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37
5.Description of consideration given to interests of key stakeholders in setting policy
Key stakeholders’ interests are taken into consideration during LINK’s materiality assessment and due
diligence processes that form basis for setting out and updating all LINK’s policies.
6. Explanation of how policy is made available to potentially affected stakeholders and
stakeholders who need to help implement it
Full version of the Information Security Policy is available to all LINK employees through an internal
system. A whistleblowing channel is available to report any suspected, potential or actual breaches.
All employees must complete an InfoSec training annually. The public version of the policy is available
on LINK’s webpage.
+ Actions taken to identify, monitor, prevent, mitigate, remediate or bring end to actual or
potential adverse impacts related to the material sustainability matter (phase-in) and result
of such actions
The following actions related to the material sustainability matter “Consumers and end users –
Information related impacts for consumers and/or end-users – Privacy” were taken in 2023:
•
GDPR audit – internal audit conducted annually in all LINK geographical areas (countries) and
concluded with a set of recommendations; implemented with an aim to ensure that privacy and
information security matters are adequately managed and relevant processes are documented; has
been conducted in all LINK subsidiaries for several years now.
•
InfoSec audit – internal audit that will be conducted in certain LINK entities and concluded with a
set of recommendations; implemented with an aim to ensure that information security matters are
adequately managed and relevant processes are documented; the process was prepared in 2023
and first audits will commence in 2024.
•
Appointing DPO – implemented with an aim to ensure that privacy and information security matters
are adequately managed and relevant processes are documented; each LINK entity has a person
dedicated to handle privacy issues- either a formal DPO appointed in case of the GDPR requirements,
or an internal person with in principle the same function as the formally appointed DPO; the action
has been present for several years now.
•
Employees’ training – described in this sustainability statement under minimum disclosure
requirements related to the material sustainability matter “Business conduct – Corporate culture”
(chapter 4.1).
•
Employee Code of Conduct – described in this sustainability statement under minimum disclosure
requirements related to the material sustainability matter “Business conduct – Corporate culture”
(chapter 4.1).
•
Supplier Code of Conduct – described in this sustainability statement under minimum disclosure
requirements related to the material sustainability matter “Business conduct – Management of
relationships with suppliers” (chapter 4.3).
•
Supplier Due Diligence process – described in this sustainability statement under minimum
disclosure requirements related to the material sustainability matter “Business conduct –
Management of relationships with suppliers” (chapter 4.3).
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+ Metrics related to the material sustainability matter (phase-in)
To evaluate performance and effectiveness in relation to material impacts, risks and opportunities
relevant to the material matter “Consumers and end users – Information related impacts for consumers
and/or end-users – Privacy”, LINK uses the following metrics:
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec)
– the metric is described in this sustainability statement under minimum disclosure requirements
related to the material sustainability matter “Business conduct – Corporate culture” (chapter 4.1).
•
Percentage of LINK geographical regions (countries) subjected to the internal GDPR audit (% of
total revenues) – the metric reflects LINK’s progress towards ensuring that privacy and information
security matters are adequately managed and relevant processes documented. It is calculated as
a percent of revenues generated by LINK’s entities located in geographical regions (countries) that
have been subject to the internal GDPR audit, in relation to LINK’s total revenue. All geographical
regions (countries) are subject to annual GDPR audit. The metric shall be monitored on annual bases.
+ Time-bound targets set related to the material sustainability matter (phase-in) and progress
made towards achieving those targets
LINK tracks the effectiveness of the action “Employees’ training” that addresses each of the identified
material matters. The action is tracked with the use of the metric “Percentage of employees to complete
employees’ training (general compliance, GDPR, InfoSec)”. Relevant targets and progress towards
achieving them is described in this sustainability statement under minimum disclosure requirements
related to the material sustainability matter “Business conduct – Corporate culture” (chapter 4.1).
LINK tracks the effectiveness of the action “GDPR audits” that addresses the material matter
“Consumers and end users – Information related impacts for consumers and/or end-users – Privacy”.
The action is tracked with the use of the metric “Percentage of LINK geographical regions (countries)
subjected to the internal GDPR audit (% of total revenues)”. The metric includes all LINK geographical
areas (countries). The target of this metric is set to 100% as of 31st December each year, which is
monitored on annual bases by group DPO. 2023 is the first reporting year and therefore constitutes
a baseline. The target applies to the period, for which LINK’s strategy is set, that is until 2025. As of
December 31st 2023 the metric amounted to 100%, which fulfills the target in 100 %.
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1.1.3. [GOV-1] The role of the administrative, management and
supervisory bodies
1.1.3.1. Information about composition and diversity of members of administrative,
management and supervisory bodies
The below presented disclosures constitute an information about composition and diversity of members
of administrative, management and supervisory bodies. The following bodies have been included:
•
Board of Directors – as of 31st December 2023 composed of 6 members, all of whom are
non-executive personnel; 3 members are male (50%) and 3 are female (50%); 3 members are
independent (50%).
The following committees are formed within the Board of Directors:
•
Audit Committee – consists of 3 members of the Board of Directors, all independent;
•
Remuneration committee – consists of 2 members of the Board of Directors, including 1
independent;
•
M&A committee – consists of 3 members of the Board of Directors, including 1 independent, as
well as certain members of LINK’s management;
•
Nomination Committee – as of 31st December 2023 composed of 2 members, all of whom are non-
executive personnel; 1 member is female (50%) and 1 male(50%) and both are independent (100%);
•
Chief Executive Officer (CEO);
•
Global Leadership Team (GLT) – as of 31st December 2023 composed of 8 members (including
CEO), all of whom are executive personnel; 6 members are male (75%) and 2 are female (25%); no
member is independent (0%).
The numerical indicators take into account that CEO is at the same time part of the GLT. Adequate
corrections have been made to avoid double-counting.
Apart from the above listed bodies, LINK ensures the operational management on the local level through
relevant bodies appointed in its subsidiaries. Such bodies report to the Group bodies, mostly to the
GLT, and have not been included separately in deliberations covered by this sustainability statement.
Overview of the composition and diversity of members of the above listed bodies is presented in a
table below. Detailed information on LINK’s corporate governance is included in the Report from the
Board of Directors, section “Board statement on corporate governance”.
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40
No. Name Position
Executive/ Non-
executive [E/ nE]
Independence
Gender [M/F]
Audit committee
Remuneration
committee
M&A committee
1 André Christensen
Chairman of
the Board
nE X M X X X
2 Jens Rugseth Board member nE M X
3 Robert Joseph Nicewicz Jr Board member nE M X X
4 Sabrina Gosman Board member nE F
5 Grethe Viksaas Board member nE X F X
6 Sara Murby Forste Board member nE X F X
7 Tor Malmo
Chair of the
Nomination
Committee
nE X M
8 Oddny Svergja
Member of the
Nomination
Committee
nE X F
9 Thomas Martin Berge
CEO / GLT
member
E M
10 Morten Løken Edvardsen GLT member E M
11 Rune Eivind Strandli GLT member E M
12 Pål Marius Brun GLT member E M
13 Lin Austbø (Prev. Ackema) GLT member E F
14 Benoit Bole GLT member E M
15 Ina Rasmussen GLT member E F
16 Riccardo Dragoni* GLT member E M
17 Hendrik Faasch** GLT member E M
18 Bill Joiner*** GLT member E M
* since mid-11.2023
** until mid-11.2023
*** until early 12.2023
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a. Number of executive members
As of December 31st 2023, the number of executive members of the above listed administrative,
management and supervisory bodies accounted to 8.
b. Number of non-executive members
As of December 31st 2023, the number of non-executive members of the above listed administrative,
management and supervisory bodies accounted to 8.
c. Information about representation of employees and other workers
None of the above listed administrative, management and supervisory bodies includes representatives
of employees and other workers.
d. Information about member’s experience relevant to LINK sectors, products and
geographic locations
All members of the above listed administrative, management and supervisory bodies have experience
relevant to sectors, products and geographic locations of the Group.
e. Board’s gender diversity ratio
As of December 31st 2023, the gender diversity ratio in the Board of Directors amounted to 50%
[females as a percentage of total]. The gender diversity ratio within all of the above listed administrative,
management and supervisory bodies amounted to 37,50% [females as a percentage of total].
f. Percentage of independent board members
As of December 31st 2023, the percentage of independent members in the Board of Directors
amounted to 50% (all non-executive). The percentage of independent members within all of the above
listed administrative, management and supervisory bodies amounted to 31,25% (executive and non-
executive).
1.1.3.2. Roles and responsibilities of administrative, management and supervisory bodies
The below presented disclosures constitute an information about roles and responsibilities of
administrative, management and supervisory bodies. The following bodies have been included:
•
Board of Directors – has the ultimate responsibility for the management and control of the Group
and its operations, as well as for the oversight of impacts, risks and opportunities. The Board
of Directors’ responsibility is defined in the Norwegian Public Limited Liability Companies Act
(Allmennaksjeloven), chapter 6. In addition, the Norwegian Code of Practice for Corporate Governance,
issued by the Norwegian Corporate Governance Board (NUES) provides important guidelines for
LINK as a Norwegian listed company, and is implemented into LINK’s Corporate Governance. The
Board of Directors defines objectives, strategies, and risk profiles for LINK’s business through deep
dives into the strategy and business throughout the year, to ensure that the Group creates value
for shareholders in a sustainable manner. Financial, social, and environmental considerations are
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42
taken into account when performing such deep dives. The objectives, strategies, and risk profiles
are evaluated annually.
•
Audit Committee – a preparatory and advisory body for the Board to support the Board in the
exercise of its responsibility for financial reporting, internal control, risk management, and
choice of the statutory auditor.
•
Remuneration committee – prepares remuneration guidelines for executive personnel, including
main principles of LINK’s remuneration policy.
•
M&A committee – preparatory and advisory body to support the Board in the process of mergers
and acquisitions.
•
Nomination Committee – proposes candidates for election to the Board of Directors, makes
assessments of proposed candidates, and proposes remuneration to be paid to such members. It is
in contact with shareholders, the Board and the Group’s executive personnel as part of its work on
proposing candidates for the election to the Board.
•
Chief Executive Officer – is in charge of the day-to-day management of the business and shall
follow the orders and guidelines given by the General Meeting or the Board. The CEO shall provide
necessary information and recommendations for the Board’s required deliberations and decisions,
and is responsible for carrying out and implementing the direction, goals and policies, which have
been approved and/or defined by the Board, and then reporting on operational outcomes. It is also
the responsibility of the CEO to ensure that everyone within the Group is aware of the agreed strategic
direction, goals and policies.
•
Global Leadership Team – supports CEO in day-to-day management of the business and other tasks.
a.Identity of administrative, management and supervisory bodies or individual(s)
within body responsible for oversight of impacts, risks and opportunities
The ultimate responsibility for the oversight of impacts, risks and opportunities lies within the
Board of Directors, which sets out the strategic ESG principles and reviews them in case of need.
On the operational level, all GLT members are responsible for the management of impacts, risks and
opportunities within their functional areas. Furthermore, a function dedicated to the general oversight
and support on the operational level, who reports directly to CEO, has been appointed.
b.Disclosure of how body’s or individuals within body responsibilities for impacts,
risks and opportunities are reflected in undertaking’s terms of reference, board
mandates and other related policies
LINK’s ESG policy, adopted by the Board of Directors, sets out general principles regarding responsibility
for its implementation. The policy includes notions of materiality assessment based on double
materiality rule. It specifies that the policy applies to the Holding Company as well as to all subsidiaries,
and that GLT has overall responsibility for its implementation in LINK’s processes.
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43
c. Management’s role in governance processes, controls and procedures used to
monitor, manage and oversee impacts, risks and opportunities
Principles associated with the governance of sustainability-related impacts, risks and opportunities
are covered by LINK’s ESG policy, adopted by the Board of Directors. The policy is regularly reviewed in
order to monitor its effectiveness and to introduce updates when needed. The control and monitoring
procedures include a regular update of the Board of Directors on relevant sustainability issues, either
by the CEO or by the function dedicated to the general oversight and support of sustainability and
risk-related issues. On the operational level, the GLT members are responsible for the implementation,
monitoring and control of the ESG policy, and it is the responsibility of every LINK manager to implement
the policy within their functional area, to lead by example, and to provide guidance to employees
reporting to them. They shall also collect ESG best practices from key stakeholders. Oversight over
management-level positions is exercised through direct meetings (including online), whereas the
general reporting lines are kept. Furthermore, anonymous whistleblowing channel enables to report
any misconduct, where the cases are handled by the Integrity Audit Committee, set out in accordance
with the whistleblowing policy.
d. Disclosure of how administrative, management and supervisory bodies and
senior executive management oversee setting of targets related to material
impacts, risks and opportunities and how progress towards them is monitored
So far, LINK has set out targets related to material impacts, risks and opportunities to a limited extent.
These include providing regulatory updates on the sustainability issues and adjusting relevant internal
processes accordingly, as well as a set of targets described in this sustainability statement under
minimum disclosure requirements relevant to each of the material sustainability matters (chapters
1.1.2.9.b, 1.1.2.9.c, 2.2, 4.1, 4.2, 4.3, 4.4). The general oversight and progress monitoring is exercised by
the CEO, to whom a dedicated sustainability and risk-related function reports.
1.1.3.3. Disclosure of how administrative, management and supervisory bodies determine
whether appropriate skills and expertise are available or will be developed to
oversee sustainability matters
As the body responsible for defining clear objectives, strategies and risk profiles for the company’s
business activities, such that the company creates value for shareholders in a sustainable manner
(Cf. the Norwegian Code of Practice for Corporate Governance, section 2), it is the responsibility of the
Board of Directors to ensure that appropriate skills and expertise are available to oversee sustainability
matters, based on the information provided by the GLT members or other functions in accordance with
general reporting lines.
a.Sustainability-related expertise that bodies either directly possess or can leverage
The existing compliance function in LINK, reporting directly to CEO, has been tasked with managing
and overseeing the sustainability area, hereunder development of expertise to the extent reasonable
and required. The function provides support on the sustainability area group-wide.
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b.Disclosure of how sustainability-related skills and expertise relate to LINK’s
material impacts, risks and opportunities
A person dedicated to provide support in sustainability-related issues has been part of the Company’s
workforce for several years, with a cross-functional experience and a group-level perspective, which
ensures necessary expertise relevant to LINK-s specific impacts, risks and opportunities.
1.1.4. [GOV-2] Information provided to and sustainability matters
addressed by the undertaking’s administrative, management and
supervisory bodies
1.1.4.1. Disclosure of whether, by whom and how frequently administrative, management
and supervisory bodies are informed about material impacts, risks and
opportunities, implementation of due diligence, and results and effectiveness of
policies, actions, metrics and targets adopted to address them
The Board of Directors is informed through the year on material sustainability issues, including
materiality assessment and due diligence results, either by the CEO or by the function dedicated to the
general oversight and support of sustainability and risk-related issues. GLT members shall be informed
on the ESG issues resulting from LINK’s own operations and its value chain by LINK managers in their
respective areas of responsibility. Information is provided through direct meetings (including online),
whereas the general reporting lines are kept.
1.1.4.2. Disclosure of how administrative, management and supervisory bodies consider
impacts, risks and opportunities when overseeing strategy, decisions on major
transactions and risk management process
In accordance with LINK’s ESG policy, the ESG factors shall be taken into consideration upon making
business decisions- in procurement, in daily operations and in strategic decisions. LINK managers, with
Human Resources function’s support, shall also seek to structure incentives and conduct performance
assessments accordingly.
1.1.4.3. List of material impacts, risks and opportunities addressed by administrative,
management and supervisory bodies or their relevant committees
The material impacts, risks and opportunities that were identified during 2023, with the purpose to
address them since 2023 and through 2024, are listed in this sustainability statement under disclosure
ESRS 2 SBM-3 (chapter 1.1.10). The GLT has overall responsibility to address material impacts, risks
and opportunities on the operational level- each member within their functional area. No further
disaggregation of responsibility has been introduced so far.
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1.1.5. [GOV-3] Integration of sustainability-related performance in
incentive schemes
1.1.5.1. Incentive schemes and remuneration policies linked to sustainability matters for
members of administrative, management and supervisory bodies exist
LINK has not introduced specific sustainability-related incentive schemes or remuneration policies for
members of administrative, management and supervisory bodies. The detailed datapoints included
under this disclosure requirement are therefore not material.
1.1.6. [GOV-4] Statement on due diligence
1.1.6.1. Disclosure of mapping of information provided in sustainability statement about
due diligence process
In its ESG policy LINK has committed to conduct due diligence with regard to sustainability matters,
as required by the relevant laws, guidelines and standards. In principle, LINK follows due diligence
framework proposed in the OECD Due Diligence Guidance for Responsible Business Conduct
1
. The
scope of such a process reflects the double materiality rule and includes assessing LINK’s impacts
on sustainability matters, and how sustainability matters affect LINK’s development, performance and
position. LINK’s due diligence is inter-connected with both the materiality assessment process and the
risk management framework in the following way:
•
the results of the materiality assessment set out basis for the reviews and updates of the
sustainability due diligence process; at the same time, impacts, risks and opportunities identified
within the due diligence process are taken into consideration within the materiality assessment;
•
deliberations derived from the risk management framework, within which LINK identifies,
assesses, manages and reports risk in a wide sense, form basis and shall be taken into
consideration during the detailed risk assessment performed within the due diligence process.
LINK’s long-term goal is that due diligence covers LINK’s own operations as well as its value chain,
including its products and services, its business relationships and its supply chain. In the first step,
LINK has introduced due diligence of its upstream value chain (supply-side). The next step shall include
LINK’s own operations. In the future, due diligence shall also cover LINK’s downstream value chain
(demand-side). LINK’s due diligence process shall include short- and long- term analyses, understood
in line with how these terms are defined for the purposes of the sustainability reporting.
The public communication on due diligence includes primarily the Norwegian Transparency Act report,
as well as the sustainability statement forming part of the annual report, as required by the CSRD.
The parts of the sustainability statement relevant for the core elements of LINK’s sustainability due
diligence processes are listed in a table below.
1
OECD (2018), OECD Due Diligence Guidance for Responsible Business Conduct, OECD Publishing.
mneguidelines.oecd.org/OECD-Due-Diligence-Guidance-for-Responsible-Business-Conduct.pdf, p. 21
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No
Core elements of the sustainability
due diligence
Paragraph in the sustainability statement
1
Embedding due diligence in
governance, strategy and business
model
•ESRS 2 GOV-2 (chapter 1.1.4)
•ESRS 2 GOV-3 (chapter 1.1.5)
•ESRS 2 SBM-3 (chapter 1.1.10)
2
Engaging with affected stakeholders
in all key steps of the due diligence
•ESRS 2 GOV-2 (chapter 1.1.4)
•ESRS 2 SBM-2 (chapter 1.1.9)
•ESRS 2 IRO-1 (chapter 1.1.11)
•ESRS 2 MDR-P (chapters 1.1.2.9.b indent 2,
1.1.2.9.c indent 2, 2.2.1, 4.1.1, 4.2.1, 4.3.1, 4.4.1)
3
Identifying and assessing adverse
impacts
•ESRS 2 IRO-1 (chapter 1.1.11)
•ESRS 2 SBM-3 (chapter 1.1.10)
4
Taking actions to address those
adverse impacts
•ESRS 2 MDR-A (chapters 1.1.2.9.b indent 3,
1.1.2.9.c indent 3, 2.2.2, 4.1.2, 4.2.2, 4.3.2, 4.4.2)
5
Tracking the effectiveness of these
efforts and communicating
•ESRS 2 MDR-M (chapters 1.1.2.9.b indent 4,
1.1.2.9.c indent 4, 2.2.3, 4.1.3, 4.2.3, 4.3.3, 4.4.3)
•ESRS 2 MDR-T (chapters 1.1.2.9.b indent 5,
1.1.2.9.c indent 5, 2.2.4, 4.1.4, 4.2.4, 4.3.4, 4.4.4)
1.1.7. [GOV-5] Risk management and internal controls over
sustainability reporting
1.1.7.1. Description of scope, main features and components of risk management and
internal control processes and systems in relation to sustainability reporting
Within its risk management framework LINK has defined 10 risk areas: market risk, financial risk,
acquisition risk, IT risk, information security risk, legal risk, HR risk, ESG/ sustainability risk, privacy risk
and operational risk. Risk related to sustainability reporting is managed within the ESG/sustainability
risk area, which covers the same scope as this sustainability statement. Identification and assessment
of risk is performed regularly, within the framework and schedule applied group-wide.
1.1.7.2. Description of risk assessment approach followed
LINK’s risk assessment processes are based on a top-down approach, where the Holding Company
defines policies and procedures for subsidiaries to implement locally. The group function provides
support and counselling to local entities depending on requirements in the covered areas, including
sustainability reporting. ESG/ sustainability risk, including the one related to sustainability reporting, is
managed by a group function under the direct authority of the CEO.
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1.1.7.3. Description of main risks identified and their mitigation strategies
LINK has identified a high-level risk related to ensuring compliance with laws and regulations on the
sustainability reporting, and financial or reputational damage that can result from non-compliance. In
order to mitigate such a risk, in H2 2023 LINK commenced a project “LINK’s road to CSRD compliance”,
as described below.
1.1.7.4. Description of how findings of risk assessment and internal controls as regards
sustainability reporting process have been integrated into relevant internal
functions and processes
After identifying risk related to sustainability reporting, LINK assigned to a group function under the
direct authority of the CEO a task to follow relevant regulatory changes and to disseminate necessary
knowledge across the organization. Following that, in H2 2023 a project “LINK’s road to CSRD
compliance” was commenced, including people from a variety of LINK’s departments. First meetings
related to new requirements on sustainability reporting were held in 2023 and actions were taken to
commence relevant processes to be implemented across the organization. One of such processes
include preparation of the sustainability statement for 2023 (this statement) that- in principle- follows
the structure specified in the CSRD/ESRS, based on the materials that have been released so far. Such
a statement may form basis for gap analyses that are planned for 2024 and is an important step
towards ensuring compliance in the first reporting period when LINK falls under the formal obligations
resulting from the CSRD/ESRS.
1.1.7.5. Description of periodic reporting of findings of risk assessment and internal
controls to administrative, management and supervisory bodies
Administrative, management and supervisory bodies are regularly informed about the sustainability
issues, including sustainability reporting, by a group function under the direct authority of the CEO.
Such an information is provided through regular formal and informal meetings.
1.1.8. [SBM-1] Strategy, business model and value chain
1.1.8.1. Information about key elements of general strategy that relate to or affect
sustainability matters
The below presented disclosures constitute an information about the key elements of LINK’s general
strategy that relate to or affect sustainability matters.
a. Significant groups of products and (or) services offered
LINK is part of a broadly understood information and telecommunications (ICT) industry, and more
specifically a digital messaging industry. Services rendered by LINK are split into the following groups
(also referred to as business lines):
•
mobile messaging transactions;
•
payment services;
•
licences;
•
consulting services.
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LINK recognizes one of the above groups of products (services) as significant:
•
“Mobile messaging transactions” – the group is recognized as significant based on the fact that
in 2023 it accounted for 96 % of LINK’s revenue (which is more than the 10% required by ESRS 2
SBM 1 AR 13 (a)); it is also connected with material impacts, related mostly to material topics of
“Energy”, “Management of relationships with suppliers”, as well as “Consumers’ and/or end-users’
privacy” (ESRS 2 SBM 1 AR 13 (b)).
Significant products’ group “Mobile messaging transactions” covers a variety of electronic
communication services provided via telecom networks, including channels such as SMS, MMS, VoIP
or rich communication services (RCS), as well as communication services provided by OTT channels
like WhatsApp, Facebook Messenger, WeChat, Viber and others. While rendering mobile messaging
services, LINK usually acts as an aggregator that connects private (business) and public customers
with operators (carriers), RCS providers, over-the-top (OTT) providers or others. In certain cases LINK
may act as a mobile network operator (MNO), mobile virtual network operator (MVNO), or provide
its services in several other roles. To the certain extent, the significant product group also covers
provision of access to LINK’s platforms and other software solutions. Such solutions include chatbots,
conversational services, notifications, marketing automation and others.
LINK’s product portfolio, focused on the significant group of products described above, has been
transitioning from basic one-way A2P messaging to conversational CPaaS solutions. The shift towards
conversational interfaces is primarily based on utilization of more advanced messaging channels
and implementation of state-of-the art software solutions. LINK strives to create products that allow
customers to choose their preferred communication with end users. Customer Data Platform (CDP)
enables predictive intelligence for personalisation and is primarily used within marketing automation.
Intelligent orchestration, where channels are selected based on user’s preferences or performance, is
used for advanced messaging. Application orchestration, on the other hand, is used with integrations
and partnerships, and allows to optimize communication with other systems. CDP and orchestration
ensure that customers are able to target the right customers and to have a wide overview of
communication across all channels and systems.
More information on LINK’s product portfolio is included in the Annual Report, section “LINK product
portfolio and the digital messaging industry”.
No major changes to the significant group of products offered in 2023 in comparison with the previous
reporting period are recognized. Notwithstanding the above, the structure of LINK’s sustainability
statement is based- in principle- on the requirements provided in the ESRS for the first time, so no prior
reporting period is available.
b. Significant markets and (or) customer groups served
LINK Mobility Group Holding ASA is based in Oslo, Norway, and operates through its subsidiaries
located in 13 EU countries, Norway, the United Kingdom, Switzerland, the Republic of North Macedonia,
and- until late 2023- the US. On November 7th, 2023 LINK has entered into definitive agreement to
divest its US-based subsidiary- Message Broadcast, LLC. The transaction was closed on January 3rd,
2024.
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In 2023 LINK has identified the same five operating segments as in the previous reporting period,
based on market maturity and product development, as well as on geography:
•
Northern Europe is comprised of enterprise traffic in Norway, Sweden, Denmark, Finland;
•
Central Europe is comprised of enterprise traffic in Bulgaria, Romania, North Macedonia, Poland,
Hungary, Germany, Austria, and the Netherlands;
•
Western Europe is comprised of enterprise traffic in Spain, France, the United Kingdom, and Italy;
•
North America was comprised of enterprise traffic in the US market, and was active until
divestment of Message Broadcast, LLC;
•
Global Messaging is comprised of non-enterprise traffic and is representative of either stand-
alone business or as a component of revenues in countries included above; if a business is
comprised of both enterprise and wholesale/aggregator transactions, the latter is segregated here;
the Swiss operations are included here.
For the purposes of this statement LINK defines “market” as an area and/or a sector where it
belongs, which should not be automatically regarded as equal to a notion of a “relevant market” as
understood e.g. under the competition law. On a general level, LINK is part of the information and
telecommunication (ICT) industry and provides services with a global reach. LINK determines that the
operating segments described above represent market “clusters” and therefore may constitute basis
for identifying significant markets on a more specific level. Having in mind the divestment of the US-
based subsidiary, and the fact that it accounted for 6 % of LINK’s revenue in 2023 (which is less than
the 10% required by ESRS 2 SBM 1 AR 13 (a)), as of December 31st 2023, LINK recognizes four of the
above operating segments as significant. Hence, four significant markets are identified:
•
Northern Europe is recognized as significant based on the fact that in 2023 it accounted for 22 % of
LINK’s revenue (which is more than the 10% required by ESRS 2 SBM 1 AR 13 (a));
•
Central Europe is recognized as significant based on the fact that in 2023 it accounted for 22 % of
LINK’s revenue (which is more than the 10% required by ESRS 2 SBM 1 AR 13 (a));
•
Western Europe is recognized as significant based on the fact that in 2023 it accounted for 26 % of
LINK’s revenue (which is more than the 10% required by ESRS 2 SBM 1 AR 13 (a));
•
Global Messaging is recognized as significant based on the fact that in 2023 it accounted for 24 %
of LINK’s revenue (which is more than the 10% required by ESRS 2 SBM 1 AR 13 (a)).
The significant markets are identified based on two criterions: (1) the geographical location and (2) the
group of customers served/ type of products delivered.
•
Geographical markets: LINK provides services with a global reach, operating through entities
located in 19 countries, including Europe and- until late 2023- the US. The European market, including
Northern, Central and Western Europe, together with Global Messaging that is also based in Europe-
as described above- accounted for 94 % of LINK’s revenue in 2023 and is therefore of highest focus.
However, LINK aims to reach beyond markets where it has its offices, by offering global connectivity
through local MNOs and other entities, and by ensuring that its customers get communication
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solutions with a worldwide range. Moreover, with the Global Sales Team, LINK targets to gain traction
on global clients and to benefit from the increased usage of mobile messaging solutions globally.
•
Product markets: LINK provides one significant group of products, namely messaging services
(“Mobile messaging transactions”), to private (business) and public customers. Two significant
markets are identified based on the group of customers served/ type of products delivered:
•
Enterprise market includes business where LINK renders services to private (business) and
public customers other than LINK’s competitors from the electronic communication industry;
LINK’s role is to provide communication services via telecom networks or OTT channels and/
or to provide access to LINK’s platforms and other software solutions; within the described
market LINK acts as a quasi intermediary between MNOs and LINK’s customers, enabling the
customers to effectively communicate with end-users;
•
Non-enterprise (wholesale/ aggregator) market includes business where services are provided
by LINK to entities active in the electronic communications industry- in fact LINK’s competitors-
with the purpose of ensuring connections with MNOs, mainly in locations where such entities do
not have connections themselves
LINK recognizes no major changes to the significant markets identified in 2023 in comparison with the
previous reporting period (the US market accounted for less than 10 % of the revenue also in 2022).
Notwithstanding the above, the structure of LINK’s sustainability statement is based- in principle- on
the requirements provided in the ESRS for the first time, so no prior reporting period is available.
In 2023 LINK has served more than 50 000 customers globally, meeting needs of both private (business)
and public sectors, including public entities, large corporations, as well as small and medium-sized
enterprises. LINK does not disaggregate the Group’s revenues depending on the specific customers’
group. It therefore recognizes one significant customer group:
•
Private (business) and public customers, including:
•
large corporations and multinationals, which are handled by the Global Sales Team, typically
offering LINK’s solutions for a worldwide deployment;
•
large and medium enterprises as well as public entities, which are served locally by dedicated
sales teams situated across 29 offices, sometimes through various partnership programmes;
•
smaller enterprises or SMEs, which are targeted through Self-Sign Up (SSU) portals, with top-
three including brands such as SMSAPI, Spot-Hit and WebSMS.
LINK recognizes no major changes to the significant groups of customers served in 2023 in comparison
with the previous reporting period. Notwithstanding the above, the structure of LINK’s sustainability
statement is based- in principle- on the requirements provided in the ESRS for the first time, so no prior
reporting period is available.
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51
c. Headcount of employees
The number of LINK’s employees (headcount) as of December 31st, 2023, disaggregated according to
gender and to the geographical areas, is presented in a table below. The headcount includes persons
with the employment contracts. It does not cover neither consultants nor self-employed.
No Country Female Male Other Total number of employees
1 Austria 15 15 0 31
2 Bulgaria 32 51 0 83
3 Denmark 6 17 0 23
4 Finland 2 10 0 12
5 France 32 47 0 79
6 Germany 14 18 0 32
7 Hungary 0 4 0 4
8 Italy 14 23 0 37
9 Netherlands 1 7 0 8
10 North Macedonia 9 29 0 38
11 Norway 29 67 0 96
12 Poland 25 45 0 70
13 Romania 2 3 0 5
14 Spain 15 27 0 42
15 Sweden 10 27 0 37
16 Switzerland 1 1 0 2
17 United Kingdom 4 11 0 15
18 United States* 23 48 1 72
Total 234 451 1 686
[%] 34.11% 65.47% 0.15% 100%
* The US subsidiary is under divestiture at year-end. It is included in the scope of consolidation for 2023, as
explained in this sustainability statement under the disclosure ESRS 2 BP-1 (chapter 1.1.1.2). The headcount reflects
the number of persons with the employment contract as of December 31st 2023.
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52
d. Description of products and services that are banned in certain markets
Within LINK’s product portfolio, no products or services have been recognized that are banned in the
markets the Group operates on.
e. Total revenue and revenue by ESRS Sectors
LINK’s total revenue, as well as its disaggregation by operating segments and business lines, and the
preliminary proposal of its relation to the ESRS sectors
2
, is presented in the tables below. Based on
Appendix C to ESRS 1, breakdown of total revenue by significant ESRS sectors has not been applicable
so far (datapoint subject to phase-in). Beyond the ESRS sectors reflected below, no additional significant
ESRS sectors have been identified, in which LINK develops significant activities or in which LINK is or
may be connected to material impacts (datapoint subject to phase-in).
No
Operating
segment (ISRS 8) Revenue 2023r
ESRS sector group
(initial proposal)
ESRS sector
(initial proposal)
1 Northern Europe 1 489 934
Technology
Media and
Communication
(TMC)
/
Information
technology (TIT)
2 Central Europe 1 461 521
3 Western Europe 1 750 286
4 North America 398 683
5 Global messaging 1 580 386
Total [NOK 1000] 6 680 809
No
Group of products
(business line)
Revenue 2023r
ESRS sector group
(initial proposal)
ESRS sector
(initial proposal)
1
Mobile messaging
transactions
6 010 031
Technology
Media and
Communication
(TMC)
/
Information
technology (TIT)
2 Payment services 26 224
3 Licences 214 994
4
Consulting
services
30 877
Total [NOK 1000] 6 282 126
2
In accordance with a [Draft] ESRS SEC 1 Sector Classification (Exposure Draft, December 2022)
* This table is exclusive of North America (Message Broadcast LLC)
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53
f. Statement on activity within certain sectors
LINK is not active in fossil fuel (coal, oil and gas), chemicals production, controversial weapons, or
cultivation and production of tobacco sectors. Hence, LINK generates no revenue from this sectors
(neither from coal, oil, gas, Taxonomy-aligned economic activities related to fossil gas, nor from
chemicals production, controversial weapons, or cultivation and production of tobacco).
g. Sustainability-related goals in terms of significant groups of products and
services, customer categories, geographical areas and relationships with
stakeholders
The 17 Sustainable Development Goals (SDGs), developed within the United Nations, are recognized in
LINK’s ESG policy as a general guide on its road to the responsible business conduct and sustainable
value creation. LINK has identified certain SDGs as the most relevant to its own operations and to
its value chain. All of them are found to be to a certain degree relevant to LINK’s significant group of
products, four significant markets, and the significant group of customers as described above, as well
as to a variety of stakeholders within LINK’s value chain. More specific objectives are distinguished
based on various environmental, social and governance factors and are included in LINK’s ESG policy,
as described in this sustainability statement under minimum disclosure requirements MDR-P (chapter
4.1.1.). Furthermore, the sustainability-related targets are described under minimum disclosure
requirements MDR-T (chapters 1.1.2.9.b indent 5, 1.1.2.9.c indent 5, 2.2.4, 4.1.4, 4.2.4, 4.3.4, 4.4.4).
High-level sustainability-related goals relevant to LINK’s significant groups of products, geographical
markets, customers and other stakeholders include:
•
SDG 5: achieve gender equality and empower all women and girls;
•
SDG 7: ensure access to affordable, reliable, sustainable and modern energy for all;
•
SDG 7.2: by 2030, increase substantially the share of renewable energy in the global energy mix;
•
SDG 7.3: by 2030, double the global rate of improvement in energy efficiency;
•
SDG 8: promote sustained, inclusive and sustainable economic growth, full and productive
employment and decent work for all;
•
SDG 8.2: achieve higher levels of economic productivity through diversification, technological
upgrading and innovation, including through a focus on high value added and labour-intensive
sectors;
•
SDG 8.7: take immediate and effective measures to eradicate forced labour, end modern slavery
and human trafficking and secure the prohibition and elimination of the worst forms of child
labour, including recruitment and use of child soldiers, and by 2025 end child labour in all its
forms;
•
SDG 8.8: protect labour rights and promote safe and secure working environments for all
workers, including migrant workers, in particular women migrants, and those in precarious
employment;
3
https://sdgs.un.org/
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54
•
SDG 9: build resilient infrastructure, promote sustainable industrialization, and foster innovation;
•
SDG 9.c: significantly increase access to information and communications technology and
strive to provide universal and affordable access to the Internet in least developed countries by
2020;
•
SDG 13: take urgent action to combat climate change and its impacts;
•
SDG 16: promote peaceful and inclusive societies for sustainable development, provide access to
justice for all and build effective, accountable and inclusive institutions at all levels;
•
SDG 16.5: substantially reduce corruption and bribery in all their forms;
•
SDG 16.10: ensure public access to information and protect fundamental freedoms, in accordance
with national legislation and international agreements.
Apart from the SDGs listed above, LINK aims to adhere to the Ten Principles of the United Nations
Global Compact. LINK Mobility Group Holding ASA joined the UN Global Compact in 2021 as part of an
increased focus on sustainability. It annually provides the “Communication on Progress” which reflects
the development in the implementation of the Ten Principles within LINK’s operations and value chain.
The report is available on the UN Global Compact homepage: https://unglobalcompact.org/what-is-
gc/participants/145208-LINK-Mobility-Group-Holding-ASA. LINK’s commitment to adhere to the Ten
Principles is reflected in its ESG policy.
h. Assessment of current significant products and (or) services, and significant
markets and customer groups, in relation to sustainability-related goals
The assessment of the identified significant groups of products, markets and customers in relation to
the most relevant of the above specified high-level sustainability-related goals, is as follows:
•
significant group of products: “Mobile messaging transactions” – most relevant SDGs:
•
SDG 5: LINK aims to take ESG criterions under consideration when developing its services; the
significant group of LINK products include provision of effective electronic communication
solutions, which play an important role in the digital transformation processes and in the
process of dissemination of free and unbiased information; such processes- on a more general
level- may positively contribute to achieve gender equality;
•
SDG 7: LINK is part of the global ICT sector, which is heavily dependent on the energy
consumption, but may also trigger digitalization processes that foster dissemination of the
energy-efficient solutions across multiple other sectors; as a result LINK may play a role in the
global rate of improvement in energy efficiency (SDG 7.3);
•
SDG 8: LINK strives to develop conversational CPaaS solutions, based on utilization of more
advanced messaging channels and implementation of state-of-the art software solutions;
through the development and implementation of innovative solutions, LINK contributes to the
increase in the levels of economic productivity (SDG 8.2);
•
significant markets: “Northern Europe”, “Central Europe”, “Western Europe” and “Global
Messaging” – most relevant SDGs:
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55
•
SDG 7: LINK operates through its European- based subsidiaries that are subject to strict
environmental legalisation aimed at promoting increase in the share of renewable energy in the
global energy mix; as a consequence, LINK may positively contribute to such an increase (SDG
7.2);
•
SDG 8: LINK operates through its European- based subsidiaries that are subject to strict human
rights and labour legislation, including laws on value chain due diligence; as a consequence
LINK may play a role in global efforts to eradicate forced labour, end modern slavery and human
trafficking and eliminate worst forms of child labour (SDG 8.7), as well as in global efforts to
protect labour rights and promote safe and secure working environments for all workers (SDG
8.8);
•
SDG 9: by offering global connectivity through local MNOs and other entities, LINK achieves a
global reach, beyond markets where it has its offices; as a consequence, it may contribute to the
increased usage of mobile messaging solutions globally and therefore positively affect access
to information and communications technology worldwide (SDG 9.c)
•
SDG 13: LINK operates through its European- based subsidiaries that are subject to strict
environmental legislation aimed at taking action to combat climate change and its impacts; as a
consequence, LINK may positively contribute to such action;
•
SDG 16: a global reach of LINK’s services may positively affect the dissemination of information in
a free and unbiased way; at the same time, LINK operates through its European- based subsidiaries
that are subject to strict anti-corruption and anti-bribery legalisation; as a consequence, LINK
may positively contribute to reducing corruption and bribery in all their forms (SDG 16.5);
•
significant customer group: “Private (business) and public customers” – most relevant SDGs:
•
SDG 16: LINK’s largest share of traffic comes from notification use cases, which are linked
to its customers’ essential activities like healthcare, utilities and critical supplies, and include
reminders, alerts, updates and mission critical communication; by serving such customers LINK
may positively contribute to ensuring public access to information and protection of fundamental
freedoms (SDG 16.10).
i. Elements of strategy that relate to or impact sustainability matters
LINK’s ambition, directly expressed in its ESG policy, is to integrate environmental, social, and
governance factors (ESG) into its strategy of offering to private businesses and public entities state-of-
the-art communication solutions that increase customer engagement, satisfaction and loyalty, while
using sustainable and innovative technologies that support processes of digital transformation. The
following elements of strategy relate to or impact sustainability matters:
•
Innovative and sustainable product portfolio.
LINK strives to develop and bring to the market innovative solutions in a responsible manner. On the
one hand, LINK aims to consider environmental factors while developing its own technology. On the
other hand, while introducing advanced communication solutions to the market, LINK takes part in
triggering digitalization processes that foster dissemination of the environment-friendly solutions
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56
across multiple other sectors. Main challenge ahead includes developing innovative solutions that will
be competitive on the market, while embedding energy-related factors into the product development
and procurement processes.
•
Responding to customers’ needs. Global reach with local markets’ adaptation.
By setting a goal to become a worldwide CPaaS provider, with a global reach and products adapted
to local markets’ requirements, LINK recognizes its role in the social and economic change that is
driven by the digital transformation. Identifying and anticipating customers’ and end-users’ needs, and
creating an offer that meets or exceeds market expectations, forms a backbone of LINK’s business
strategy, and a at the same time- one of main challenges ahead.
•
Responsible business conduct.
LINK’s goal is to conduct business in a responsible manner. It expects that ESG factors are taken into
consideration upon making business decisions, both in daily operations and on a strategic level. LINK
strives to be an attractive employer for passionate and driven individuals who wish to take part in a
journey towards being a top global CpaaS player. It regards diversity, equality and inclusion as levers for
innovation, development and profitability. Dedicated, enthusiastic and united employees are recognized
as one of LINK’s most valuable assets. Main projects that are relevant to this strategic element include
“LINK Voice” and “myLINKjourney”. “LINK Voice” aims to anonymously collect employees’ feedback in
a variety of topics, while “myLINKjourney” constitutes a framework for employees’ development.
1.1.8.2. List of ESRS sectors that are significant for LINK
LINK operates in the ESRS sector group “Technology”. It renders services that may be classified
under both ESRS sectors covered by the “Technology” group, namely “Information Technology” (TIT)
and “Media and Communication” (TMC). Further explanation with regard to ESRS sector groups are
included in chapter 1.1.8.1.e.
1.1.8.3. Business model and value chain
The below presented disclosures constitute a description of LINK’s business model and value chain.
a.Description of inputs and approach to gathering, developing and securing inputs
Main input factors that are required for LINK’s delivery of services include:
•
skilled workforce, which is reflected in LINK’s approach to create an attractive workplace;
•
connectivity, which is secured by contracts with electronic communication sector entities around
the world, such as mobile operators, aggregators, OTT providers etc.; additionally, in several
markets LINK is registered as an electronic communication sector provider, sometimes including a
status of MNO/MVNO;
•
data storage solutions that are ensured by contracts with hosting, server & storage solutions’
providers, and- to a very limited extent- by LINK’s own data storage units;
•
software solutions that are developed internally or secured through contracts with external
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57
developers and providers of a standardized or customized software, using a variety of licensing
models
b. Description of outputs and outcomes in terms of current and expected benefits
for customers, investors and other stakeholders
Main outputs and outcomes of LINK’s activity include delivering to its customers state-of-the-art
solutions that enable them to effectively communicate with their customers and ultimately to reach
end users worldwide by the most suitable communication channel. By implementing LINK’s solutions,
private business and public entities can greatly improve their customer satisfaction. In a wider scale,
LINK products may contribute to a global digital transformation, dissemination of innovation and
technological progress. LINK is in a position to further scale up the business and to strengthen its
leading position within the CPaaS industry, with the aim of bringing a significant value creation for the
benefit of not only its customers, but also investors and other stakeholders.
c. Description of main features of upstream and downstream value chain and
LINK’s position in value chain
LINK recognizes itself as a part of the global electronic communication value chain. In general, the
significant group of LINK’s products enable sending, receiving and/or circulating any electronic
message (i.e. exchanging information/ content) between LINK’s customer and an end-user, as shown
on the figure below. This is achieved either by rendering a variety of electronic communication services
via telecom networks and OTT channels, or by provisioning an access to LINK’s platforms and other
software solutions. In order to provide its services, LINK relies on electronic communication sector
providers (“telco” providers) such as mobile operators, aggregators, OTT providers etc. These are
entities that enable connectivity and the transmission of content to recipients- mostly holders of
mobile handsets. Furthermore, LINK’s services require data storage. This means that IT providers who
offer hosting, server & storage solutions are of relevance. Other providers are most notably in the IT
area, but also other sectors. The high-level overview of the described value chain and LINK’s position
within it is presented on the figure below.
„TELCO” providers
•
operators (MNO/MVNO)
•
aggregators
•
OTT vproviders
•
RCS providers
•
other telco providers
Customers
(private/business/ & public)
(brand/ content providers
etc.)
LINK
(electronic communication
services’ provider)
End users
(subscribers/ consumers)
IT providers
•
hosting, server &
storage solutions’
providers
•
software solution/
development providers
Other providers
•
non-minor (finance, legal,
HR support, lessors,
electronic equipment etc.)
•
minor (office, postage,
food, events etc)
4
In accordance with a [Draft] ESRS SEC 1 Sector Classification (Exposure Draft, December 2022)
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58
Main business actors within the relevant value chain, and their relative contribution to LINK’s
performance and position, include:
•
Upstream value chain actors – suppliers and business partners, including three main groups:
•
electronic communication (“telco”) providers – within the value chain of delivering a message
from a customer to an end user, LINK acts primarily as an aggregator that connects private
(business) and public customers with operators (MNO/MVNO), RCS providers, over-the-top
(OTT) providers, or other electronic communication services’ providers. In some cases, LINK
cooperates with other aggregators that directly or indirectly ensure connection to certain
operators. In certain cases LINK may also act as an operator itself. Electronic communication
sector providers, including MNOs, MVNOs, aggregators, OTT, RCS and other “telco” providers,
have therefore been identified as “suppliers”.
•
IT providers – in order to be able to act effectively and to provide its services, LINK must
ensure it has access to necessary infrastructure, equipment and software. LINK therefore
cooperates- firstly- with entities that provide hosting, server and other storage solutions,
making it possible to store, secure, manage and access digital data. Secondly, LINK purchases
standardized or customized software, using a variety of licensing models- ranging from “On-
Premises”, through “IaaS”, “PaaS” to “SaaS”. Furthermore, LINK develops certain software,
relying only on its own capacities or on external providers. Hence, IT sector providers form
a vital part of LINK’s value chain as they are necessary for both enabling LINK’s delivery of
services, as well as ensuring LINK’s operational excellence in managing its own organization.
IT sector entities LINK cooperates with, that provide input factors included in LINK’s delivery of
services, shall be regarded as “suppliers”, while the ones that do not deliver such input factors
shall be regarded as “business partners” (these may include e.g. providers of a software that is
used for payroll purposes, accountancy, office suites etc.).
•
other providers – in its daily activity, LINK cooperates with a variety of other providers, such as
property landlords, providers of electronic equipment for office use, office-related products/
services providers financial and legal advisors, HR support, postage services providers, event
organizers etc. They shall be considered as “business partners” rather than “suppliers”, as none
of these entities provide input factors necessary for LINK’s delivery of services.
The division of upstream value chain actors into “suppliers” and “business partners” is derived from the
Norwegian Transparency Act. “Suppliers” are understood as entities that deliver input factors included
LINK’s delivery of services, while “business partners” are entities that do not deliver such input factors.
•
downstream value chain actors – customers and end users:
•
private (business) and public customers – LINK’s customers form part of both public and
private sectors, and include public entities, large corporations, as well as small and medium-
sized enterprises;
•
end users – LINK solutions typically enable its customers to communicate with their end users,
namely the recipients of a message;
5
https://lovdata.no/dokument/NLE/lov/2021-06-18-99
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59
•
distribution channels, including three go-to-market (GTM) approaches:
•
enterprise – large and medium enterprises as well as public clients are served by local sales
people who are able to provide superior service and value by being present, speaking the
language, and knowing LINK’s customers; global clients that typically use LINK’s solutions
worldwide are served by the Global Sales Team;
•
SSU – the needs of smaller enterprises or SMEs are covered through the Self-Sign Up (SSU)
portals, where onboarding can be done in minutes with off the shelf product offerings; LINK’s top
three SSU brands are SMSAPI, Spot-Hit and WebSMS;
•
partners – the partner network, consisting of partners ranging from independent software
vendors to large-scale software integration providers, resellers, telecommunication operators
and other entities, enable to embed LINK solutions into their own product offerings and to scale
the business.
1.1.9. [SBM-2] Interests and views of stakeholders
1.1.9.1. Description of stakeholder engagement
The below presented disclosures constitute a description of LINK’s stakeholder engagement.
a. Key stakeholders
LINK has identified the following key stakeholder groups, including external and internal ones:
•
Customers – the group includes private (business) and public customers (as described under
disclosure SBM -1, chapter 1.1.8.1.b);
•
End users – the group includes ultimate recipients of messages transmitted through LINK’s services,
typically customers of LINK’s customers (as described under disclosure SBM -1, chapter 1.1.8.3.c);
•
Suppliers and supply-side business partners – the group includes “telco” providers, IT providers,
and other providers (as described under disclosure SBM -1, chapter 1.1.8.3.c);
•
Partners – the group includes LINK’s partner network, consisting of business entities ranging
from independent software vendors to large-scale software integration providers, resellers,
telecommunication operators and others (as described under disclosure SBM -1, chapter 1.1.8.3.c),
partners may be either downstream or upstream value chain actors;
•
Competitors – the group includes other entities present on the global CPaaS market, mainly other
aggregators, but also MNOs/ MVNOs, OTT/ RCS providers, IT solutions’ providers etc.; competitors
may in certain cases be simultaneously LINK’s customers- mostly on a wholesale/ aggregator
market (as described under disclosure SBM -1, chapter 1.1.8.1.b);
•
Public bodies – the group includes administrative bodies such as electronic communication offices,
data protection offices, business registers, tax offices etc., in countries where LINK operates;
•
Investors – the group includes institutional and retail investors with ownership stakes in the
company’s stock exchange listed equity and bond;
•
Employees – the group includes LINK’s workforce.
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b. Categories of stakeholders for which engagement occurs
LINK aims to engage most of the above identified stakeholder groups. The description of how such
engagement is organised is included below.
c. Description of how stakeholder engagement is organised
Stakeholder engagement is organised differently for each of LINK’s key stakeholders’ group:
•
Customers – LINK has a direct contact with its customers, either through local salesforce and
customer service people, or through the Global Salesforce Team, with an aim to collect customer
feedback in order to better understand market requirements and to be able to adjust product
portfolio accordingly;
•
End users – typically LINK does not engage end users in its operations, as they are most often not
even aware of LINK’s participation in the process of message transmission; LINK however conducts
market analyses aimed at understanding the end users’ behaviour and preferences, and takes their
results into consideration in product development and offering;
•
Suppliers and supply-side business partners – LINK mostly has a direct contact with its 1st tier
suppliers and supply-side business partners, typically during contract negotiation and execution
phases; LINK is open to collect feedback it gets through this direct contacts and to adjust its
operations when relevant.
As far as the sub-suppliers are concerned, it must be noted that in case of the telecommunication
industry, identification of the “simply understood” supply chain in its entirety is not practically
feasible. Telecommunication is a highly regulated sector that enables world-wide communication
via a variety of channels. In order to ensure that systems and devices located in different countries
are able to connect and work together, telecommunication laws are based on the principles of
“interconnection” and “interoperability”. As the termination of a message is in practice controlled
by the recipient’s subscription and location, LINK has no influence on where (in which network)
the message is in fact terminated. Furthermore, all entities through which the message ultimately
reaches an end-user operate on a highly regulated telecommunication market and are therefore
subject to regulations that require each entity to fulfill certain requirements. It should therefore be
expected that such entities adhere to at least basic standards of the responsible business conduct.
LINK recognizes that, even though a variety of telecommunication sector entities (Tier 1 and further
one) form part of its supply chain, numerous factors related to these entities are imposed on LINK,
which means LINK cannot in fact contribute to them or influence them. At the same time LINK strives
to establish as many direct business relations with respected and well-recognized companies as
practically and commercially possible.
•
Partners – LINK has a direct contact with its partner network through dedicated partner managers,
with an aim to collect partners’ feedback in order to better understand market requirements and to
be able to adjust product portfolio accordingly;
•
Competitors – being aware of the fair competition rules embedded in the competition law, LINK is
cautious in relations with its competitors and therefore their engagement is limited; LINK however
conducts market analyses aimed at understanding the market on which it operates, and takes their
results into consideration in product development and offering;
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61
•
Public bodies – LINK aims to ensure full compliance with relevant laws and regulations and seek
relevant public authority opinion when necessary; moreover, LINK actively follows the development
of relevant laws and regulations, analyses how they can influence LINK’s operations, and includes
results of such analyses in the decision making processes on a strategic and operational level;
•
Investors – LINK, in association with various investment banks, hosts quarterly result
presentations for investors; in between quarters, function dedicated to investor relations is
available on a daily basis for enquiries, and also facilitates management meetings on request;
•
Employees – LINK regularly conducts a company-wide survey for all employees to express
satisfaction or areas for improvement across a spectrum of issues; “LINK Voice” is a survey to
measure employee engagement, which provides action plans for managers to improve employee
engagement within their departments.
d. Purpose of stakeholder engagement
LINK recognizes stakeholder engagement as a vital part of its corporate social responsibility (CSR) that
allows the organisation to better understand how its activity may affect people and the planet in the
short- medium- and long term, to adjust to the ever changing market requirements, and to strengthen
its market position in a responsible and sustainable manner.
e. Description of how outcome of stakeholder engagement is taken into account
Crucial element of stakeholder engagement is an ability to hear the voice of relevant stakeholder groups
and to take their opinions into consideration when making business decisions. LINK takes actions to
disseminate feedback it gets from various stakeholder groups across the organisation. Such actions
include regular group-wide meetings of all employees (“All-hands”), as well as various meetings
in smaller teams. Views of LINK stakeholders are taken into consideration in annual materiality
assessment, product development, sales and customer care activities, peoples’ management, as well
as in the strategic decision making, including M&A processes.
1.1.9.2. LINK’s understanding of interests and views of key stakeholders as they relate to
LINK’s strategy and business model
Interests and views of key stakeholders’ groups are taken into consideration when making strategic
decisions in LINK, as external and internal feedback is recognized as an important factor in identifying
impacts, risks and opportunities that are ahead of the company. Both the materiality assessment
and due diligence processes include, to a certain extent, stakeholder engagement. Details have been
described in this sustainability statement under disclosure requirements ESRS 2 GOV-4 (chapter 1.1.6)
and ESRS 2 IRO-1 (chapter 1.1.11).
1.1.9.3. Amendments to strategy and (or) business model
The below presented disclosures constitute a description of amendments to LINK’s strategy and (or)
business model.
a.Description of how strategy and (or) business model have been amended or are
expected to be amended to address interests and views of stakeholders
LINK takes stakeholder voice into consideration when making business decision on both strategic and
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62
operational level on a rolling bases. Any changes in LINK’s strategy or business model result however
from a wide variety of factors. LINK recognizes no specific amendments that address solely interests
and views of stakeholders.
b.Description of any further steps that are being planned, in what timeline, and if
they are likely to modify relationship with and views of stakeholders?
At the moment LINK has no specific plans to take further steps to amend its strategy and (or) business
model to address interests and views of stakeholders. No modification of relationship with stakeholders
is therefore expected.
1.1.9.4. Description of how administrative, management and supervisory bodies are
informed about views and interests of affected stakeholders with regard to
sustainability-related impacts
LINK’s administrative, management and supervisory bodies are informed about sustainability-related
impacts, including views and interests of affected stakeholders, by relevant LINK managers responsible
for specific operational areas. Such information is provided in the framework of both formal and
informal meetings.
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No ESG matter Impact Ricks/Opportunity
1
Climate
change –
Energy
• LINK may contribute to the
increase in energy consumption,
because of the greater need for
infrastructure (cooling systems,
backup power solutions),
resulting from the climate
warming or extreme weather
conditions.
• LINK may contribute to the
reductions in energy consumption
by participating in a trend towards
shared infrastructure.
• Risk of increased operating
costs resulting from higher
energy consumption.
• Risk to business continuity, and
consequently financial loss, due
to the disruptions in the energy
supply.
• Risk of productivity loses due
to the reduced infrastructure
redundancy, resulting from
a trend towards shared
infrastructure.
• Opportunity to build resilience
and gain competitive advantage
by raising employees’ awareness
on environmental issues.
• Opportunity to build resilience
and gain competitive advantage
by introducing innovative
environment-friendly solutions.
• Opportunity of cost savings,
resulting from the introduction
of the solutions with improved
energy-efficiency.
• Opportunity to gain competitive
advantage, resulting from
the reduction in the energy
consumption and carbon
footprint, due to the use of shared
infrastructure.
1.1.10. [SBM-3] Material impacts, risks and opportunities and their
interaction with strategy and business model
1.1.10.1. Material impacts, risks, and opportunities resulting from materiality assessment
ESG matters assessed as material in 2023, as well as a description of impacts, risks, and opportunities
related to them, are listed in a table below.
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64
No ESG matter Impact Ricks/Opportunity
2
Own workforce
– Equal
treatment and
opportunities
for all –
Training
and skills
development
• LINK may act as a role model
and therefore positively impact its
internal and external stakeholders
by providing adequate training
and development opportunities
for its employees.
• Risk of productivity loses due to
not sufficient training of LINK’s
employees.
• Opportunity to attract skilled
people and to boost LINK’s
productivity by offering attractive
training and development
opportunities.
3
Consumers
and end users
– Information-
related
impacts for
consumers
and/or
end-users –
Privacy
• LINK may positively impact the
secure exchange of consumers/
end-users’ data by ensuring high
level of privacy of information
disseminated via LINK’s services.
• LINK may negatively impact
consumers/ end-users’ privacy
rights by any irregularities
concerning the security of data
within LINK’s services.
• Risk of non-compliance,
resulting from insufficient
protection of consumers/ end-
users’ privacy.
• Opportunity to gain competitive
advantage by ensuring high level
of the protection of consumers/
end-users’ privacy.
4
Business
conduct –
Corporate
culture
• LINK may act as a role model
and therefore positively impact its
internal and external stakeholders
by setting high corporate culture
standards.
• Risk of productivity loses due to
poor corporate culture.
• Opportunity to ensure LINK’s
smooth operation (achieving
higher level of internal integration,
gaining new customers,
effectively managing the value
chain) by setting up clear
corporate standards and adhering
to corporate culture.
5
Business
conduct –
Protection
of whistle-
blowers
• LINK may act as a role model
and therefore positively impact its
internal and external stakeholders
by setting high standards in
the area of whistleblowers’
protection.
• Risk of ignoring information
provided by a whistleblower,
leading to a disruption in LINK’s
operation, higher costs and/or
reputational damages.
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No ESG matter Impact Ricks/Opportunity
6
Business
conduct –
Management
of
relationships
with suppliers
• LINK may have a positive
impact on its supply chain, and
in a broader sense- on people
and the environment, by offering
its suppliers fair business and
financial conditions, and by
applying certain ESG criteria
in the process of the suppliers’
selection.
• Risk of cooperation with an
unreliable supplier, leading to
a potential disruption in LINK’s
operation, higher costs and/or
reputational damages.
• Risk of insufficient insight
into supply chain, leading to
unvoluntary relationship with
unfavourable entity in the chain.
• Opportunity to boost LINK’s
reliability and productivity by the
effective supplier management.
7
Business
conduct –
Corruption and
bribery
• LINK may positively impact its
internal and external stakeholders
by introducing a policy with a
zero-tolerance approach towards
corruption and bribery, and by
training its employees.
• LINK may positively impact its
internal and external stakeholders
by introducing an incident
management process.
• Risk of being involuntarily
engaged in a corruption/ bribery
scandal, resulting in reputational
damages.
• Risk of not detecting any
corruption/ bribery behaviour,
leading to higher costs and/or
disruption in LINK’s operation.
• Risk of poor incident
management, leading to higher
costs and/or a disruption in
LINK’s operation.
• Opportunity to gain competitive
advantage by providing
compliance training to LINK’s
employees.
• Opportunity to boost LINK’s
reliability by effective corruption/
bribery incident management.
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66
1.1.10.2. Current and anticipated effects of material impacts, risks and opportunities on
business model, value chain, strategy and decision-making, and how LINK has
responded or plans to respond to these effects
The identified current or anticipated effects of the material impacts, risks and opportunities on LINK’s
business model, value chain, strategy and decision-making, as well as steps taken to respond to them,
are described in a table below. Moreover, adequate policies and actions taken to address material
matters are described in this sustainability statement under minimum disclosure requirements relevant
to each of the material sustainability matters (chapters 1.1.2.9.b, 1.1.2.9.c, 2.2, 4.1, 4.2, 4.3, 4.4).
No
Impact/ Risk/
Opportunity
(IRO)
Effects on LINK’s business
model/ value chain/ strategy/
decision-making LINK’s response
1
IROs related to
the ESG matter
“Climate change
– Energy”
• Need of taking energy
consumption into consideration
in own operations.
• Need of taking energy
consumption into consideration
in procurement.
• Need of having business
continuity plans.
• Need of taking energy
consumption into consideration
in own operations.
• Need of taking energy
consumption into consideration
in procurement.
• Need of having business
continuity plans.
2
IROs related
to the ESG
matter “Own
workforce –
Equal treatment
and opportunities
for all – Training
and skills
development”
• Need of ensuring relevant
training and development
programs for LINK’s workforce.
• LINK has included
“Engagement, training and
development” matters in the
ESG Policy.
• LINK has developed and
implemented basic training
for all its employees (general
compliance, privacy, InfoSec).
• LINK has implemented
phishing training for its
employees.
• LINK provides additional
training corresponding
with particular needs of its
employees.
• LINK has developed and
started to implement training
and development programme
“myLINKjourney”.
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No
Impact/ Risk/
Opportunity
(IRO)
Effects on LINK’s business
model/ value chain/ strategy/
decision-making LINK’s response
3
IROs related to
the ESG matter
“Consumers
and end users
– Information-
related impacts
for consumers
and/or end-users
– Privacy
• Need of taking privacy and
information security matters
into consideration in own
operations.
• Need of taking privacy
and information security
matters into consideration in
procurement.
• Need to adequately manage
privacy and information security
matters.
• Need to document certain
processes related to privacy and
information security.
• Need of appointing Data
Protection Officer.
• LINK has included privacy and
information security matters in
the ESG Policy.
• LINK has developed the
Personal Data Protection Policy.
• LINK has developed the
Information Security Policy.
• LINK has included privacy and
information security topics in
employees’ training.
• LINK has appointed the Data
Protection Officer.
• LINK takes privacy and
information security topics into
consideration in procurement
(Supplier Due Diligence
process).
• LINK takes privacy and
information security topics
into consideration in its own
operations (GDPR audits).
• LINK has developed and
documented a variety of specific
processes related to adequate
management of privacy and
information security issues.
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No
Impact/ Risk/
Opportunity
(IRO)
Effects on LINK’s business
model/ value chain/ strategy/
decision-making LINK’s response
4
IROs related to
the ESG matter
“Business
conduct –
Corporate
culture”
• Need to introduce policies
and processes aimed at
the development of LINK’s
corporate culture.
• LINK has included business
culture matters in the ESG
Policy.
• LINK has defined its core
values and has embedded them
in its strategy.
• LINK has introduced the
Employee’ Code of Conduct.
• LINK has conducted “LINK
Voice” survey.
• LINK has included certain ESG
topics in employees’ training.
• LINK provides training on
the “Social Styles” model to
employees and managers with
communication to a wider
group.
5
IROs related to
the ESG matter
“Business
conduct –
Protection of
whistle-blowers”
• Need to ensure adequate
policies and processes on
whistleblowing.
• LINK has included
whistleblowing matters in the
ESG Policy.
• LINK has developed the
Whistleblowing Policy.
• LINK has introduced adequate
whistleblowing channel.
• LINK has included
whistleblowing topics in
employees’ training.
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69
No
Impact/ Risk/
Opportunity
(IRO)
Effects on LINK’s business
model/ value chain/ strategy/
decision-making LINK’s response
6
IROs related to
the ESG matter
“Business
conduct –
Management of
relationships with
suppliers
• Need to adequately manage
supply chain.
• Need to document certain
processes related to the supplier
management.
• LINK has included due
diligence matters in the ESG
Policy.
• LINK has prepared its first
Transparency Act report.
• LINK has included certain
supplier-related topics in
employees’ training.
• LINK has introduced the
Supplier Code of Conduct.
• LINK has developed and
introduced the Supplier Due
Diligence process.
7
IIROs related to
the ESG matter
“Business
conduct –
Corruption and
bribery”
• Need to ensure adequate
policies and processes on anti-
corruption and anti-bribery..
• LINK has included anti-
corruption and anti-bribery
matters in the ESG Policy.
• LINK has introduced the
Employee’ Code of Conduct.
• LINK has included anti-
corruption and anti-bribery
topics in employees’ training.
• LINK has adopted a zero-
tolerance approach to
corruption and bribery.
1.1.10.3. Information on LINK’s material impacts
a. Disclosure of how material negative and positive impacts affect (or are likely to
affect) people or environment
The short description of how material impacts affect or may affect people or environment is included
in a table in chapter 1.1.10.1 above. No further analysis have been conducted.
b. Disclosure of how impacts originate from or are connected to strategy and
business model
LINK’s strategy and business model are taken into account in the materiality assessment process,
during which each potentially material ESG matter is analysed and described in LINK’s specific
context. Moreover, the materiality assessment process includes involvement of certain stakeholders’
groups, among which the Group’s senior management is represented. In case any impact is identified
as material, it therefore originates inter alia from LINK’s strategic position, and/ or is connected to
LINK’s strategy and business model.
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On the other hand, material impacts, risks and opportunities are taken into consideration in the annual
review and update of LINK’s policies, which ensures they are embedded in the decision making on both
strategic and operational level.
c. Reasonably expected time horizons of impacts
The identified material impacts may be expected in short-, medium- and long-time horizons, as
understood for the purposes of this sustainability reporting (chapter 1.1.2). No detailed analysis
regarding time horizons of impacts have been conducted.
d. Nature of activities or business relationships through which LINK is involved
with material impacts
The identified impacts are relevant to LINK’s own operations as well as to its value chain. Having in
mind the relatively homogenous nature of LINK’s operations and its position in the value chain, as
described under disclosure requirement ESRS 2 SBM 1 (chapter 1.1.8), any more detailed description
has been found not necessary for a proper understanding of LINK’s involvement with material impacts.
1.1.10.4. Information on LINK’s material risks and opportunities
a. Current financial effects of material risks and opportunities on financial position,
financial performance and cash flows and material risks and opportunities for
which there is significant risk of material adjustment within next annual reporting
period to carrying amounts of assets and liabilities reported in related financial
statements
LINK has not identified significant current financial effects of any of the material risk or opportunity,
listed in the table provided in chapter 1.1.10.1 above, on the Company’s financial position, financial
performance, or cash flows. LINK has not identified any material risk or opportunity, among the ones
listed in the table provided in chapter 1.1.10.1 above, for which there is significant risk of material
adjustment within next annual reporting period to carrying amounts of assets and liabilities reported
in related financial statements.
b. Anticipated financial effects of material risks and opportunities on financial
position, financial performance and cash flows over short-, medium- and long-term
In 2023, LINK assessed the financial materiality on a general level, as described in this sustainability
statement under disclosure IRO -1 (chapter 1.1.11) and has not conducted more detailed analysis
regarding anticipated financial effects of material risks and opportunities on the Company’s financial
position, financial performance and cash flows over short-, medium- and long-term. LINK will consider
including such analysis as part of the materiality assessment process in the future.
1.1.10.5. Information about resilience of strategy and business model regarding capacity to
address material impacts and risks and to take advantage of material opportunities
The material impacts, risks and opportunities have been addressed by embedding them in certain
internal processes, among which the risk management framework and the compliance management
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71
framework are of key importance. This ensures that impacts and risks are timely identified and assessed,
and relevant processes are developed in order to mitigate them and to take advantage of material
opportunities. Such processes are then monitored as part of the compliance management framework.
Regular review is conducted under both frameworks, and relevant administrative, management and
supervisory bodies are provided with information necessary to update LINK’s strategy and business
model if needed, which ensures adequate level of resilience regarding LINK’s capacity to address
material impacts and risks and to take advantage of material opportunities. Further details regarding
LINK’s strategy and business model are described in this sustainability statement under disclosure
SBM-1 (chapter 1.1.8). No further analysis regarding LINK’s resilience have been conducted.
1.1.10.6. Changes to material impacts, risks and opportunities compared to previous
reporting period
In 2022 the following ESG topics were identified as material:
•
Diversity, inclusion and belonging;
•
Employee engagement;
•
Privacy and Security;
•
Energy consumption, monitoring, and efficiency;
•
Establishing and operationalizing ethical business practices;
•
Compliance with laws.
The structure of LINK’s sustainability statement is for the first time based- in principle- on the
requirements provided in the ESRS. Therefore, the material topics are formulated differently- as specified
in the list derived from AR.16, included in Appendix A to ESRS 2. In principle, the chosen materiality
matters are found to be to a great extent overlapping with the previous reporting period, as presented
in a table below. Main difference is that the topic “Compliance with laws” is not included in 2023, while
a new topic “Management of relationships with suppliers” is covered. The topic “Compliance with laws”
has a very general nature. LINK still aims to ensure full compliance with applicable law. However, the
topic is assessed as too general to constitute specific material matter. The material topics identified in
2023 have constituted a focus points since their identification and will be followed up in the financial
year 2024
No Material topics 2022 Material topics 2023
1 Diversity, inclusion and belonging
Own workforce – Equal treatment and opportunities
for all – Training and skills development
2 Employee engagement
3 Privacy and security
Consumers and end users – Information-related
impacts for consumers and/or end-users – Privacy
4
Energy consumption, monitoring
and efficiency
Climate change – Energy
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1.1.10.7. Specification of impacts, risks and opportunities that are covered by ESRS
Disclosure Requirements as opposed to those covered by additional entity-specific
disclosures
LINK has not identified material impacts, risks and opportunities related to ESG matters not covered
by the list derived from AR.16, included in Appendix A to ESRS 2, and therefore does not include any
entity-specific disclosures in this sustainability statement.
1.1.11. [IRO-1] Description of the process to identify and assess
material impacts, risks and opportunities
1.1.11.1. Methodologies and assumptions applied in process to identify impacts, risks and
opportunities
In 2023 LINK conducted its materiality assessment following a double materiality principle, covering
both impact and financial perspective. The top-bottom approach was applied, with an assessment
performed at a group level, while engaging internal stakeholders from all geographic regions, in which
LINK operates, as well as the ones relevant for various departments and for the Company as a whole. To a
very limited extent, external stakeholders were also invited to take part in the process. The assessment
considered all entities included in the scope of consolidation, as well as value chain related matters.
LINK recognizes that materiality assessment and due diligence processes are interconnected. On the
one hand, the materiality of impacts, risks and opportunities identified within the due diligence process
shall be taken into consideration within the materiality assessment. On the other hand, the results of
the materiality assessment are seen as basis for the sustainability due diligence. Since LINK operates
within one sector, with a fairly homogenous groups of significant products, markets and customers
(see chapter 1.1.8), the materiality assessment has not been disaggregated, as that was found not
needed for a proper understanding of material impacts, risks and opportunities.
During the process, short-, medium- and long- term time horizons, understood in line with how these
terms are defined for the purposes of the sustainability reporting (see chapter 1.1.2), were taken into
account. The process consisted of the following phases and steps:
•
Phase 1: Preliminary assessment
•
Step 1: Identification of stakeholder groups – with an aim to identify affected stakeholders as
well as users of sustainability statements and other users, whose views should be taken into
consideration;
No Material topics 2022 Material topics 2023
5
Establishing and operationalizing
ethical business practices
Business conduct – Corporate culture
Business conduct – Protection of whistle-blowers
Business conduct – Corruption and bribery
6 Compliance with laws -
7 -
Business conduct – Management of relationships
with suppliers
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•
Step 2: Description of ESG matters and their context to LINK – with an aim to understand LINK’s
specific context of the topics included in the list of ESG matters derived from AR.16, included in
Appendix A to ESRS 2 (a possibility to add further matters existed during Step 6);
•
Step 3: Defining a short-list of potentially material ESG matters – screening the list of ESG
matters derived from AR.16 included in Appendix A to ESRS 2 with an aim to identify ESG matters
that may potentially be material in LINK’s specific context (a possibility to add further matters
existed during Step 6).
•
Phase 2: Defining impacts, risk and opportunities
•
Step 4: Identification and description of impacts, risk, opportunities related to the short-listed
ESG matters – specifying impacts, risks and opportunities connected with the short-listed
ESG matters that may be material to LINK’s own operations and its value chain in a short-,
medium- and/or long- term, with an aim to further assess and analyse them in subsequent steps;
identification of risks and opportunities was proceeded by deliberations on dependencies on
natural and social resources from which certain risks and opportunities may be derived.
•
Phase 3: Impact and financial assessment
•
Step 5: Preparation of a template for collecting data from stakeholders – stakeholders were
provided with an extensive template covering short-listed ESG matters and corresponding
impacts, risks and opportunities, together with a dedicated space for adding next entries;
assessment criteria were defined and included; training was provided on how to fill in the
template; the aim of this step was to streamline the data collection process;
•
Step 6: Stakeholders’ assessment – with an aim to collect data from stakeholders, including:
a) Initial assessment – short-listed material matters were assessed by the stakeholders by
answering the question if they are/may be important to LINK, with an aim to choose matters
for further assessment; there was a possibility to add further matters;
b) Impact assessment – impacts related to the topics chosen during initial assessment were
assessed against the given criteria and on a provided scale; there was a possibility to add
further impacts;
c) Financial assessment – risks and opportunities related to the topics chosen during initial
assessment were assessed against the given criteria and on a provided scale; there was a
possibility to add further risks and opportunities.
•
Phase 4: Identifying results and their implications
•
Step 7: Summary of the stakeholders’ assessment in the form of a materiality matrix – data
collected from stakeholders was extensively analysed; impact and financial materiality was
calculated; materiality matrix was prepared, which was followed by specification of qualitative
and quantitative thresholds for the identification of material matters;
•
Step 8: Identification of LINK’s material matters – the choice of material matters was made
based on the pre-defined criterions and adapted thresholds;
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•
Step 9: Identification of strategic implications of the materiality assessment – materiality
assessment results were included in LINK’s risk management framework and formed basis
for the process of annual review and update of LINK’s policies; initial scope of sustainability
reporting was identified and communicated to the chosen internal stakeholders within the scope
of the project “LINK’s road to CSRD compliance” (described in chapters 1.1.7.3 and 1.1.7.4 of this
sustainability statement).
1.1.11.2. Process to identify, assess, prioritise and monitor potential and actual impacts on
people and environment, informed by due diligence process
Impact materiality assessment was performed as part of steps 4, 6b, 7 and 8 of the above outlined
materiality assessment process, as deliberated below.
a. Description of how process focuses on specific activities, business
relationships, geographies or other factors that give rise to heightened risk of
adverse impacts
LINK’s materiality assessment included specification of a short-list of potentially material ESG matters
in step 3 of the above described process. For the short-listed matters, actual and potential impacts on
people and environment were identified during step 4. The ESG matters and corresponding impacts
were described in LINK’s specific context, which took into consideration the market, on which the
company operates, its product portfolio, and key stakeholder groups. Focus was than put on the short
listed matters and corresponding impacts, which were assessed by the involved stakeholders during
step 6a-b. Having in mind relatively homogenous nature of LINK’s operations and its position in the
value chain, as described under disclosure requirement ESRS 2 SBM 1 (chapter 1.1.8), the top-bottom
approach was applied, with no disaggregation.
b. Description of how process considers impacts with which LINK is involved
through own operations or as result of business relationships
Impact assessment process involved identification and assessment of ESG matters and corresponding
impacts in the context specific for LINK’s own operations and its position in the relevant value chain,
as described above.
c. Description of how process includes consultation with affected stakeholders to
understand how they may be impacted and with external experts
Both internal and external stakeholders were invited to take part in the impact assessment. Since there’s
been no response from the external stakeholders so far, the choice of internal participants took into
consideration representation of various geographical regions and functional areas. Involving voices
from product, sales, investor relations, data protection, information security, and other departments,
representing different seniority levels, enabled to understand and take into consideration perspectives
of key internal and external stakeholder groups. Internal review of the specificity of LINK’s business,
and the corresponding desk research was carried out as well, with considerations including potential
silent stakeholders (e.g. nature).
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d. Description of how process prioritises negative impacts based on their relative
severity and likelihood and positive impacts based on their relative scale, scope and
likelihood and determines which sustainability matters are material for reporting
purposes
During step 6b of the above outlined process, stakeholders were assigned to assess against the given
criteria positive and negative impacts related to the ESG matters chosen as potentially material in step
6a. The assessment was on a scale [1] to [4] and the criteria included:
•
(1) scale, (2) scope and (3) likelihood of positive impacts;
•
(1) scale, (2) scope, (3) likelihood and (4) irremediable character of negative impacts.
Furthermore, (1) scale, (2) scope, (3) likelihood and (4) irremediable character of each impact was
calculated as an average note given by relevant stakeholder groups (including executives and senior
management, as well as other employees from various departments and geographical regions). Impact
materiality was calculated as an average of the notes (1), (2), (3) and (4) (for positive impacts without
(4)), and impacts were assigned with notes according to the following quantitative thresholds:
•
0,0 ≥ x ≤ 0,5 › impact materiality = 0;
•
0,5 > x ≤ 1,5 › impact materiality = 1;
•
1,5 > x ≤ 2,5 › impact materiality = 2;
•
2,5 > x ≤ 3,5 › impact materiality = 3;
•
3,5 > x ≤ 4,0 › impact materiality = 4.
The average impact materiality for each of the ESG short-listed matters was than calculated as an
average impact materiality of its related impacts. The matter has been chosen as material if either its
impact or financial materiality accounted to more than 2,5, or if the average of it’s impact and financial
materiality accounted to more than 2,0.
1.1.11.3. Process used to identify, assess, prioritise and monitor risks and opportunities
that have or may have financial effects
Financial materiality assessment was performed as part of steps 4, 6c, 7 and 8 of the above outlined
materiality assessment process, as deliberated below.
a. Description of how connections of impacts and dependencies with risks and
opportunities that may arise from those impacts and dependencies have been
considered
LINK’s materiality assessment included specification of a short-list of potentially material ESG matters
in step 3 of the above described process. For the short-listed matters, deliberations concerning
dependencies on natural and social resources, from which certain risks ad opportunities may be
derived, were carried out. The corresponding risks and opportunities were than identified during step
4. The ESG matters, dependencies, as well as corresponding risks and opportunities were described
in LINK’s specific context, which took into consideration the market, on which the company operates,
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its product portfolio, and key stakeholder groups. Focus was than put on the short listed matters and
corresponding risks and opportunities, which were assessed by the involved stakeholders during step
6a and c. Having in mind relatively homogenous nature of LINK’s operations and its position in the
value chain, as described under disclosure requirement ESRS 2 SBM 1 (chapter 1.1.8), the top-bottom
approach was applied, with no disaggregation.
b.Description of how likelihood, magnitude, and nature of effects of identified risks
and opportunities have been assessed
During step 6c of the above outlined process, stakeholders were assigned to assess against the given
criteria risks and opportunities related to the ESG matters chosen as potentially material in step 6a.
The assessment was on a scale [1] to [4] and the criteria included:
•
(1) size and (2) likelihood of risks and opportunities.
Furthermore, (1) size and (2) likelihood of each risk and opportunity was calculated as an average note
given by relevant stakeholder groups (including executives and senior management, as well as other
employees from various departments and geographical regions). Financial materiality was calculated
as an average of the notes (1) and (2), and risks and opportunities were assigned notes in according to
the following quantitative thresholds:
•
0,0 ≥ x ≤ 0,5 › financial materiality = 0;
•
0,5 > x ≤ 1,5 › financial materiality = 1;
•
1,5 > x ≤ 2,5 › financial materiality = 2;
•
2,5 > x ≤ 3,5 › financial materiality = 3;
•
3,5 > x ≤ 4,0 › financial materiality = 4.
The average financial materiality for each of the ESG short-listed matters was than calculated as an
average financial materiality of its related risks and opportunities. The matter has been chosen as
material if either its impact or financial materiality accounted to more than 2,5, or if the average of it’s
impact and financial materiality accounted to more than 2,0.
c. Description of how sustainability-related risks relative to other types of risks
have been prioritised
Sustainability-related risks identified inter alia during the materiality assessment are included in LINK’s
general framework for risk management, mainly under the group consisting of “ESG/ sustainability
risk” (see chapter 1.1.7.1). Such risks are therefore prioritised depending on their assessment in line
with how this is done for other risk areas.
1.1.11.4. Decision-making process and related internal control procedures
The materiality assessment process is supervised by a designated function that reports to the group
CEO (see chapters 1.1.3.2, 1.1.3.3). The process is inter-related with risk management framework, and
its results are embedded in LINK’s policies forming basis for decision making (see chapter 1.1.6). The
materiality process is regularly reviewed.
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1.1.11.5. Extent to which and how process to identify, assess and manage impacts and risks
is integrated into overall risk management process and used to evaluate overall
risk profile and risk management processes
LINK recognizes that materiality assessment process and LINK’s general framework for risk
management are inter-related (see chapter 1.1.6). On the one hand, general risks are taken into
consideration when creating a short-list of ESG matters that need materiality assessment. On the other
hand, the results of the materiality assessment are included in LINK’s risk management framework.
1.1.11.6. Extent to which and how process to identify, assess and manage opportunities is
integrated into overall management process
The results of the materiality assessment are included in LINK’s risk management framework and form
basis for the process of annual review and update of LINK’s policies (see chapter 1.1.6). Such policies
constitute than guidance in making decisions on both strategic and operational levels.
1.1.11.7. Input parameters used in process to identify, assess and manage material impacts,
risks and opportunities
CSRD and ESRS set out a general framework of LINK’s materiality assessment process and are seen
as a main input factor in designing the process. As far as the scope of topics covered is concerned, the
list of ESG matters derived from AR.16, included in Appendix A to ESRS 2 constitutes basis, with the
possibility to add further matters. Moreover, desk research is carried out based on online sources, and
internal expertise is extensively utilized.
1.1.11.8. Description of how process to identify, assess and manage impacts, risks and
opportunities has changed compared to prior reporting period
In 2023 LINK conducted the materiality assessment process based on the CSRD for the first time, and
aimed at ensuring compliance with ESRS. The process was significantly more structured than in the
previous reporting period, and it included a wider group of stakeholders. As far as the scope of topics
covered is concerned, the list of ESG matters derived from AR.16, included in Appendix A to ESRS 2
constituted basis, with the possibility to add further matters. Moreover, quantitative thresholds were
applied when assessing impact and financial materiality.
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78
1.1.12. [IRO-2] Disclosure Requirements in ESRS covered by LINK’s
sustainability statement
1.1.12.1. List of data points that derive from other EU legislation and information on their
location in sustainability statement
The list of datapoints derived from Appendix B to ESRS 2 and information on their location in this
sustainability statement is specified in a table below.
No
Disclosure Requirement
and related datapoint
Where the datapoint can be found
in this sustainability statement
/or “not material”/
1
ESRS 2 GOV-1 Board's gender diversity; paragraph
21 (d)
ESRS 2 GOV-1 (chapter 1.1.3.1.e)
2
ESRS 2 GOV-1 Percentage of board members who
are independent; paragraph 21 (e)
ESRS 2 GOV-1 (chapter 1.1.3.1.f)
3
ESRS 2 GOV-4 Statement on due diligence;
paragraph 30
ESRS 2 GOV-4 (chapter 1.1.6)
4
ESRS 2 SBM-1 Involvement in activities related to
fossil fuel activities; paragraph 40 (d) i
ESRS 2 SBM-1 (chapter 1.1.8.1.f)
5
ESRS 2 SBM-1 Involvement in activities related to
chemical production; paragraph 40 (d) ii
ESRS 2 SBM-1 (chapter 1.1.8.1.f)
6
ESRS 2 SBM-1 Involvement in activities related to
controversial weapons; paragraph 40 (d) iii
ESRS 2 SBM-1 (chapter 1.1.8.1.f)
7
ESRS 2 SBM-1 Involvement in activities related to
cultivation and production of tobacco; paragraph
40 (d) iv
ESRS 2 SBM-1 (chapter 1.1.8.1.f)
8
ESRS E1-1 Transition plan to reach climate
neutrality by 2050; paragraph 14
Not material
9
ESRS E1-1 Undertakings excluded from Paris-
aligned Benchmarks; paragraph 16 (g)
Not material
10
ESRS E1-4 GHG emission reduction targets;
paragraph 34
Not material
11
ESRS E1-5 Energy consumption from fossil
sources disaggregated by sources (only high
climate impact sectors); paragraph 38
Not material
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79
No
Disclosure Requirement
and related datapoint
Where the datapoint can be found
in this sustainability statement
/or “not material”/
12
ESRS E1-5 Energy consumption and mix; paragraph
37
ESRS E1-5 (chapter 2.3.7)
13
ESRS E1-5 Energy intensity associated with
activities in high climate impact sectors;
paragraphs 40 to 43
Not material
14
ESRS E1-6 Gross Scope 1, 2, 3 and Total GHG
emissions; paragraph 44
ESRS E1-6 (chapter 2.3.8)
15
ESRS E1-6 Gross GHG emissions intensity;
paragraphs 53 to 55
Not material
16
ESRS E1-7 GHG removals and carbon credits;
paragraph 56
Not material
17
ESRS E1-9 Exposure of the benchmark portfolio to
climate-related physical risks; paragraph 66
Not material
18
ESRS E1-9 Disaggregation of monetary amounts by
acute and chronic physical risk; paragraph 66 (a)
ESRS E1-9 Location of significant assets at
material physical risk; paragraph 66 (c).
Not material
19
ESRS E1-9 Breakdown of the carrying value of its
real estate assets by energy-efficiency classes;
paragraph 67 (c).
Not material
20
ESRS E1-9 Degree of exposure of the portfolio to
climate- related opportunities; paragraph 69
Not material
21
ESRS E2-4 Amount of each pollutant listed in
Annex II of the E-PRTR Regulation (European
Pollutant Release and Transfer Register) emitted to
air, water and soil; paragraph 28
Not material
22
ESRS E3-1 Water and marine resources; paragraph
9
Not material
23 ESRS E3-1 Dedicated policy; paragraph 13 Not material
24
ESRS E3-1 Sustainable oceans and seas;
paragraph 14
Not material
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80
No
Disclosure Requirement
and related datapoint
Where the datapoint can be found
in this sustainability statement
/or “not material”/
25
ESRS E3-4 Total water recycled and reused;
paragraph 28 (c)
Not material
26
ESRS E3-4 Total water consumption in m3 per net
revenue on own operations; paragraph 29
Not material
27 ESRS 2- IRO 1 - E4; paragraph 16 (a) i Not material
28 ESRS 2- IRO 1 - E4; paragraph 16 (b) Not material
29 ESRS 2- IRO 1 - E4; paragraph 16 (c) Not material
30
ESRS E4-2 Sustainable land / agriculture practices
or policies; paragraph 24 (b)
Not material
31
ESRS E4-2 Sustainable oceans / seas practices or
policies; paragraph 24 (c)
Not material
32
ESRS E4-2 Policies to address deforestation;
paragraph 24 (d)
Not material
33 ESRS E5-5 Non-recycled waste; paragraph 37 (d) Not material
34
ESRS E5-5 Hazardous waste and radioactive
waste; paragraph 39
Not material
35
ESRS 2- SBM3 - S1 Risk of incidents of forced
labour; paragraph 14 (f)
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.9)
36
ESRS 2- SBM3 - S1 Risk of incidents of child labour;
paragraph 14 (g)
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.9)
37
ESRS S1-1 Human rights policy commitments;
paragraph 20
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.9)
38
ESRS S1-1 Due diligence policies on issues
addressed by the fundamental International Labor
Organisation Conventions 1 to 8; paragraph 21
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.9)
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81
No
Disclosure Requirement
and related datapoint
Where the datapoint can be found
in this sustainability statement
/or “not material”/
39
ESRS S1-1 processes and measures for preventing
trafficking in human beings; paragraph 22
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.9)
40
ESRS S1-1 workplace accident prevention policy or
management system; paragraph 23
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.9)
41
ESRS S1-3 grievance/complaints handling
mechanisms; paragraph 32 (c)
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.9)
42
ESRS S1-14 Number of fatalities and number and
rate of work-related accidents; paragraph 88 (b)
and (c)
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.9)
43
ESRS S1-14 Number of days lost to injuries,
accidents, fatalities or illness; paragraph 88 (e)
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.9)
44
ESRS S1-16 Unadjusted gender pay gap; paragraph
97 (a)
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.9)
45
ESRS S1-16 Excessive CEO pay ratio; paragraph 97
(b)
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.9)
46
ESRS S1-17 Incidents of discrimination; paragraph
103 (a)
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.9)
47
ESRS S1-17 Non-respect of UNGPs on Business
and Human Rights and OECD; paragraph 104 (a)
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.9)
48
ESRS 2- SBM3 – S2 Significant risk of child labour
or forced labour in the value chain; paragraph 11
(b)
Not material
49
ESRS S2-1 Human rights policy commitments;
paragraph 17
Not material
50
ESRS S2-1 Policies related to value chain workers;
paragraph 18
Not material
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No
Disclosure Requirement
and related datapoint
Where the datapoint can be found
in this sustainability statement
/or “not material”/
51
ESRS S2-1 Non-respect of UNGPs on Business
and Human Rights principles and OECD guidelines;
paragraph 19
Not material
52
ESRS S2-1 Due diligence policies on issues
addressed by the fundamental International Labor
Organisation Conventions 1 to 8; paragraph 19
Not material
53
ESRS S2-4 Human rights issues and incidents
connected to its upstream and downstream value
chain; paragraph 36
Not material
54
ESRS S3-1 Human rights policy commitments;
paragraph 16
Not material
55
ESRS S3-1 non-respect of UNGPs on Business
and Human Rights, ILO principles or and OECD
guidelines; paragraph 17
Not material
56
ESRS S3-4 Human rights issues and incidents;
paragraph 36
Not material
57
ESRS S4-1 Policies related to consumers and end-
users; paragraph 16
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.9)
58
ESRS S4-1 Non-respect of UNGPs on Business and
Human Rights and OECD guidelines; paragraph 17
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.9)
59
ESRS S4-4 Human rights issues and incidents;
paragraph 35
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.9)
60
ESRS G1-1 United Nations Convention against
Corruption; paragraph 10 (b)
ESRS G1 G1-1 (chapter 4.5.2.3.a)
61
ESRS G1-1 Protection of whistle- blowers;
paragraph 10 (d)
ESRS G1 G1-1 (chapter 4.5.2.3.c)
62
ESRS G1-4 Fines for violation of anti-corruption and
anti-bribery laws; paragraph 24 (a)
ESRS G1 G1-4 (chapter 4.5.5)
63
ESRS G1-4 Standards of anti- corruption and anti-
bribery; paragraph 24 (b)
ESRS G1 G1-4 (chapter 4.5.5)
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1.1.12.2. List of ESRS Disclosure Requirements complied with in preparing sustainability
statement following outcome of materiality assessment
Based on the results of the materiality assessment, the following ESRS Disclosure Requirements have
been complied with in preparing this sustainability statement:
No ESRS Disclosure Requirement (DR) complied with
Where the DR can be found in
this sustainability statement
1
[ESRS 2] [BP-1] General basis for preparation of the
sustainability statements
chapter 1.1.1
2
[ESRS 2] [BP-2] Disclosures in relation to specific
circumstances
chapter 1.1.2
3
[ESRS 2] [GOV-1] The role of the administrative,
management and supervisory bodies
chapter 1.1.3
chapter 4.5.1
4
[ESRS 2] [GOV-2] Information provided to
and sustainability matters addressed by the
undertaking’s administrative, management and
supervisory bodies
chapter 1.1.4
5
[ESRS 2] [GOV-3] Integration of sustainability-related
performance in incentive schemes
chapter 1.1.5
chapter 2.3.1
6 [ESRS 2] [GOV-4] Statement on due diligence chapter 1.1.6
7
[ESRS 2] [GOV-5] Risk management and internal
controls over sustainability reporting
chapter 1.1.7
8
[ESRS 2] [SBM-1] Strategy, business model and value
chain
chapter 1.1.8
9 [ESRS 2] [SBM-2] Interests and views of stakeholders chapter 1.1.9
10
[ESRS 2] [SBM-3] Material impacts, risks and
opportunities and their interaction with strategy and
business model
chapter 1.1.10
chapter 2.3.2
11
[ESRS 2] [IRO-1] Description of the process to identify
and assess material impacts, risks and opportunities
chapter 1.1.11
chapter 2.3.3
12
[ESRS 2] [IRO-2] Disclosure Requirements in ESRS
covered by LINK’s sustainability statement
chapter 1.1.12
13
[ESRS 2] [MDR-P] Policies adopted to manage
material sustainability matters
chapters 1.1.2.9.b indent 2,
1.1.2.9.c indent 2, 2.2.1, 4.1.1,
4.2.1, 4.3.1, 4.4.1
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84
14
[ESRS 2] [MDR-A] Actions and resources in relation
to material sustainability matters
chapters 1.1.2.9.b indent 3,
1.1.2.9.c indent 3, 2.2.2, 4.1.2,
4.2.2, 4.3.2, 4.4.2
15
[ESRS 2] [MDR-M] Metrics in relation to material
sustainability matters
chapters 1.1.2.9.b indent 4,
1.1.2.9.c indent 4, 2.2.3, 4.1.3,
4.2.3, 4.3.3, 4.4.3
16
[ESRS 2] [MDR-T] Tracking effectiveness of policies
and actions through targets
chapters 1.1.2.9.b indent 5,
1.1.2.9.c indent 5, 2.2.4, 4.1.4,
4.2.4, 4.3.4, 4.4.4
17
Disclosures pursuant to Article 8 of Regulation (EU)
2020/852 (Taxonomy Regulation)
chapter 2.1
18
[ESRS E1] [E1-2] Policies related to climate change
mitigation and adaptation
chapter 2.3.4
19
[ESRS E1] [E1-3] Actions and resources in relation to
climate change policies
chapter 2.3.5
20
[ESRS E1] [E1-4] Targets related to climate change
mitigation and adaptation
chapter 2.3.6
21 [ESRS E1] [E1-5] Energy consumption and mix chapter 2.3.7
22
[ESRS E1] [E1-6] Gross Scopes 1, 2, 3 and Total GHG
emissions
chapter 2.3.8
23 [ESRS S1] all DR
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.9)
24 [ESRS S4] all DR
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.9)
25
[ESRS G1] [G1-1] Business conduct policies and
corporate culture
chapter 4.5.2
26
[ESRS G1] [G1-2] Management of relationships with
suppliers
chapter 4.5.3
27
[ESRS G1] [G1-3] Prevention and detection of
corruption and bribery
chapter 4.5.4
28 [ESRS G1] [G1-4] Incidents of corruption or bribery chapter 4.5.5
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85
1.1.12.3. Explanation of negative materiality assessment for certain ESRS
Based on the results of the materiality assessment, the following ESRS have been identified as not
material:
No ESRS Explanation of the negative materiality assessment
1 ESRS E2 Pollution
LINK operates in the ICT industry, providing mostly
messaging services on a B2B basis. The topic of “pollution”
has been assessed as not material because LINK takes part
in creating a digital rather than a physical world.
2
ESRS E3 Water and
marine resources
LINK operates in the ICT industry, providing mostly
messaging services on a B2B basis. The topic of “water
and marine resources” has been assessed as not material
because LINK takes part in creating a digital rather than a
physical world.
3
ESRS E4 Biodiversity
and ecosystems
LINK operates in the ICT industry, providing mostly
messaging services on a B2B basis. The topic of
“biodiversity and ecosystems” has been assessed as not
material because LINK takes part in creating a digital rather
than a physical world.
4
ESRS E5 Circular
economy
LINK operates in the ICT industry, providing mostly
messaging services on a B2B basis. The topic of “circular
economy” has been assessed as not material because LINK
takes part in creating a digital rather than a physical world.
5
ESRS S2 Workers in
value chain
LINK acts mainly as an electronic communication
aggregator, being a link between mobile telecommunication
operators (MNO)/ OTT providers, and the customers. In
provision of its services LINK relies on certain suppliers,
including IT, “telco” and others. As far as IT suppliers are
concerned, LINK mainly cooperates with global players, and
the cooperation is often based on adhesive-like contracts.
When it comes to telco suppliers, the industry is highly
regulated and therefore, it is expected that basic labour
standards should be respected. At the same time, LINK
often has no or little influence on its suppliers, as they are
either large MNOs or other entities falling under the telco
regulations. For that reasons LINK usually has little impact
on workforce in its value chain. As a consequence, the topic
“workers in value chain” has been assessed as not material.
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86
6
ESRS S3 Affected
communities
LINK operates in the ICT industry, providing mostly
messaging services on a B2B basis. The topic of “affected
communities” has been assessed as not material because
LINK takes part in creating a digital rather than a physical
world.
1.1.12.4 Explanation of how material information to be disclosed in relation to material
impacts, risks and opportunities has been determined
Based on the results of the materiality assessment, certain disclosure requirements included in the
ESRS, listed in a table below, have been identified as material. The explanation of how LINK decided on
the materiality topics, including the applied criterions and thresholds, is included in this sustainability
statement under disclosure requirement ESRS 2 IRO-1 (chapter 1.1.11).
No ESRS Explanation of how the scope of the disclosure was determined
1
ESRS E1
Climate
change
The topic “Climate change” – sub-topic “Energy” has been assessed as
material, whereas the topics of “Climate change adaptation” and “Climate
change mitigation” have been assessed as not material. LINK is not active
in any of the high climate impact sectors. Being part of the ICT industry,
LINK is however, heavily dependent on the energy consumption. Hence, the
disclosures include basic datapoints related to the energy mix. Moreover,
since LINK has already prepared its first GHG report in 2022, with an
intention to update it regularly, it will continue its work to disclose general
datapoints related to GHG emissions.
Having in mind the above, certain disclosures covered by ESRS E1 (E1-2,
E1-3, E1-4, E1-5, E1-6) are included in this sustainability statement in chapter
2. It must be noted that for 2023 they are included on a general level only,
mainly by a cross-reference to LINK’s GHG report. In the future LINK intends
to work on translating data from its GHG report into certain datapoints
specified in the ESRS.
The disclosures under E1-1, E1-7, E1-8, E1-9 have been assessed as not
material.
2
ESRS
S1 Own
workforce
The topic “Own workforce” – sub-topic “Equal treatment and opportunities
for all” – Sub-sub-topic “Training and skills development” has been
assessed as material. However, as LINK does not exceed on its balance sheet
date the average number of 750 employees during the financial year 2023, it omits
information required by ESRS S1. For the identified material topic covered
by ESRS S1, the required disclosures are included in this sustainability
statement in chapter 1.1.2.9.
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87
No ESRS Explanation of how the scope of the disclosure was determined
3
ESRS S4
Consumers
and end-
users
The topic “Consumers and end users” – sub-topic “Information-related
impacts for consumers and/or end-users” – sub-sub-topic “Privacy” has
been assessed as material. However, as LINK does not exceed on its balance
sheet date the average number of 750 employees during the financial year 2023, it
omits information required by ESRS S4. For the identified material topic covered
by ESRS S4, the required disclosures are included in this sustainability
statement in chapter 1.1.2.9.
4
ESRS G1
Business
conduct
The following sub-topics covered by topic “Business conduct” have been
assessed as material: “Corporate culture”; “Protection of whistle-blowers”;
“Management of relationships with suppliers”; “Corruption and bribery”.
Therefore, corresponding disclosures covered by ESRS G1 (G1-1, G1-2, G1-3,
G1-5) are included in this sustainability statement in chapter 4.
The disclosures [G1-4] „Political engagement and lobbying activities” and
[G1-6] “Payment practices” are omitted, as the related impacts, risks, and
opportunities have been assessed as not material.
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88
2. Environmental information
This chapter includes:
•
disclosures pursuant to Article 8 of Regulation (EU) 2020/852 (Taxonomy Regulation);
•
certain disclosures resulting from the materiality assessment.
As far as the materiality assessment is concerned, LINK has assessed the following topics included in
ESRS E1 as material:
•
ESRS E1: Topic “Climate change” – Sub-topic “Energy”
Hence, LINK reports in this chapter the minimum disclosure requirements covered by ESRS 2 MDR,
relevant for the above listed material topic (chapter 2.2). Moreover, the relevant disclosure requirements
covered by ESRS 2 GOV-3, ESRS 2 SBM-3, and ESRS 2 IRO-1 have been included. The disclosure
requirements covered by E1-2, E1-3, E1-4, E1-5 and E1-6 have been included on a general level, with
some cross-references to LINK’s GHG report (chapter 2.3). Since no sustainability matters covered
by the E1-1, E1-7, E1-8 and E1-9 have been assessed as material, the related disclosure requirements
have not been included. In the future LINK intends to work on translating data from its GHG report into
certain datapoints specified in the ESRS
.
No sustainability matters covered by ESRS E2, ESRS E3, ESRS E4, ESRS E5 have been assessed as
material. Hence, these topical standards have not been included.
The description of how LINK identified the scope of the sustainability reporting is provided in this
statement under disclosure requirements ESRS 2 IRO-2 (chapters 1.1.12.3 and 1.1.12.4).
2.1 Disclosures pursuant to Article 8 of Regulation (EU) 2020/852
(Taxonomy Regulation)
EU Taxonomy establishes the criteria for determining whether an economic activity qualifies as
environmentally sustainable for the purposes of establishing the degree to which an investment is
environmentally sustainable. Any undertaking that is obliged to publish non-financial information
pursuant to CSRD shall include, in its (consolidated) non-financial statement, information on how and
to what extent the undertaking’s activities are associated with ‘environmentally sustainable activities’.
Since the EU Taxonomy is applicable in Norway for annual reports published in 2024 (covering FY
2023), LINK reports relevant Key Performance Indicators for the first time. The scope of consolidation
is the same as for the financial statements.
The reported KPIs include proportion of eligible and aligned turnover, capital expenditure (CaPex) and
operating expenditure (OpEx) derived from products (services) associated with economic activities
qualifying as sustainable under the EU Taxonomy. The low level of the disclosed indicators (amounting
to 0) results from the assessment that majority of LINK activities is not covered by the EU Taxonomy.
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89
Activities contributing to environmental objectives covered by the Climate Delegated Act and the
Environmental Delegated Act are included. It must be however noted that the delegated acts published
so far do not include activities in the field of the electronic communication, which constitute a vast
majority of LINK’s operations. In principle, activities within the information and communication
sector are included to a very limited extent. As such, non-eligible activities are not synonymous with
unsustainable activities. LINK believes that majority of its activities may positively contribute to the
environmental objectives, and it expects they may be included in the EU Taxonomy in the future,
following regulatory changes. So far, few areas of LINK’s operations have been included in the EU
Taxonomy, which results in the low level of the key indicators (amounting to 0) disclosed by LINK.
2.1.1 Assessment of LINK’s compliance with the EU Taxonomy
Assessment of LINK’s operations under the EU Taxonomy has been performed in line with a four-steps
process, included in “A User Guide to navigate the EU Taxonomy for sustainable activities,”
6
published
by the EU Commission. These steps include:
Step 1. Identify the activities that are covered by the EU Taxonomy (Taxonomy-eligible activities)
Step 2. Assess whether the activities meet the technical screening criteria (Taxonomy-aligned
activities)
Step 3. Check compliance of the activities with minimum safeguards
Step 4. Apply the relevant reporting rules
The assessment process that was carried out in LINK in 2023 is described below.
a. Step 1: Identify the activities that are covered by the EU Taxonomy (Taxonomy-
eligible activities)
In the first step, the assessment was made concerning which, if any, LINK’s operation can be considered
as “taxonomy-eligible”. The aim of this step was to answer the question: “Which of activities performed
by LINK are covered by the EU Taxonomy?“
Two LINK’s activities were found as falling under the ones described in the Climate Delegated Act.
These activities have been identified as “taxonomy-eligible”. No activity was found as falling under the
ones described in the Environmental Delegated Act. For details see the table below.
6
https://ec.europa.eu/sustainable-finance-taxonomy/assets/documents/Taxonomy%20User%20
Guide.pdf
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90
Choice of the Taxonomy-eligible activities
Basis
No. of the
activity
Description of the activity
Description of
LINK’s activity
Climate
Delegated
Act,
Annex I &
Annex II
8.1. Data
processing,
hosting
and related
activities
Storage, manipulation, management,
movement, control, display,
switching, interchange, transmission
or reception of diversity of data
through data centers, including edge
computing.
The economic activities in this
category could be associated with
NACE code J63.1.1 in accordance
with the statistical classification of
economic activities established by
Regulation (EC) No 1893/2006.
Annex I: An economic activity in this
category is a transitional activity
as referred to in Article 10(2) of
Regulation (EU) 2020/852 where it
complies with the technical screening
criteria set out in this Section.
LINK stores,
manages and
transmits data
through its servers
(that may be
regarded as a data
centre).
Climate
Delegated
Act,
Annex II
8.2. Computer
programming,
consultancy
and related
activities
Providing expertise in the field of
information technologies: writing,
modifying, testing and supporting
software; planning and designing
computer systems that integrate
computer hardware, software and
communication technologies; on-site
management and operation of clients’
computer systems or data processing
facilities; and other professional and
technical computer-related activities.
The economic activities In this
category could be associated with
NACE code J62 in accordance
with the statistical classification of
economic activities established by
Regulation (EC) No 1893/2006.
LINK provides
expertise in the
field of information
technologies
through writing,
testing and
supporting
software that is
used for rendering
LINK’s services.
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91
b. Step 2: Assess whether the activities meet the technical screening criteria
(Taxonomy-aligned activities)
In the second step, assessment was made if LINK’s activities identified as the “taxonomy-eligible”,
meet the “technical screening criteria” set out in the Climate Delegated Act, and can therefore be
recognized as “taxonomy-aligned”. For that reason, the following was performed:
•
Assessment of the “substantial contribution” criterion – LINK’s taxonomy-eligible activities were
assessed against the “substantial contribution” criterions, specified in point 8.1. of Appendix I, and
points 8.1.-8.2. of Appendix II of the Climate Delegated Act, respectively. None of LINK’s activities
were found to fulfil this criterion. Hence, none of LINK’s activities shall be recognized as the
“taxonomy-aligned”.
•
Substantial contribution to climate change mitigation: LINK’s activity does not fulfil the criterion,
as it has not implemented the relevant practices listed in the Climate Delegated Act, nor has it
assessed the global warming potential (GWP) of refrigerants used in the data centre cooling
system, as specified in Annex I, point 8.1.
•
Substantial contribution to climate change adaptation: LINK’s activity does not fulfil the criterion,
as it has not implemented adaptation solutions, nor performed specific risk and vulnerability
assessment related to this activity, as specified in Annex II, point 8.1 and 8.2.
•
Assessment of the “do no significant harm” criterion – the “DNSH” criterion was not assessed, as
none of LINK’s activities were found to fulfil the first criterion. None of these activities may therefore
be recognized as the “taxonomy-aligned” ones.
c. Step 3: Check compliance of the activities with minimum safeguards
The third step includes assessment of compliance with the minimum safeguards as set out in art. 18(1)
and (2) of the EU Taxonomy. However, since step 2 showed that no LINK’s activity may be recognized
as “taxonomy-aligned”, performing step 3 was not necessary.
d. Step 4: Apply the relevant reporting rules
The reporting requirements under the EU Taxonomy are specified in the Disclosures Delegated Act,
which- for non-financial companies- defines key performance indicators (KPIs) related to turnover,
capital expenditure (CapEx), and operational expenditure (OpEx). As LINK identified two activities as
“taxonomy-eligible”, it discloses the following KPIs:
•
the proportion of a turnover derived from products or services associated with environmentally
sustainable activities;
•
the proportion of a capital expenditure related to assets or processes associated with
environmentally sustainable activities;
•
the proportion of an operating expenditure related to assets or processes associated with
environmentally sustainable activities.
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92
2.1.2 Disclosures under EU Taxonomy
Following the assessment described above, the below presented conclusions have been made and
relevant KPIs calculated.
a. Taxonomy- eligible activities
Two activities listed in the Climate Delegated Act have been identified in LINK as “taxonomy-eligible”:
•
8.1. Data processing, hosting and related activities – LINK stores, manages and transmits data
through its servers (that may be regarded as a data centre).
•
8.2. Computer programming, consultancy and related activities – LINK provides expertise in the
field of information technologies through writing, testing and supporting software that is used for
rendering LINK’s messaging services.
No activity listed in the Environmental Delegated Act has been identified in LINK.
b. Taxonomy- aligned activities
No LINK’s activity has been recognized as “taxonomy-aligned”, as the identified “taxonomy-eligible”
activities do not meet the “technical screening criteria” (“substantial contribution” criterion and “do
no significant harm” criterion) set out in the Climate Delegated Act. However, LINK complies with
minimum safeguards.
c. Key Performance Indicators (KPIs)
KPIs related to turnover, CapEx and Opex, are presented in the tables below.
Since LINK reports under the EU Taxonomy for the first time, no changes are reported in relation to the
previous reporting period.
Accounting methodology note:
For disclosure in compliance with Article 8 of the Taxonomy, turnover, CapEx, and OpEx are defined
below. These definitions differ from how CapEx and OpEx are defined in LINK’s financial reports.
•
Turnover corresponds to revenue in the consolidated income statement in the annual report. Further
information is provided in notes 3 and 6 of the financial statements.
•
CapEx, or capital expenditure, are cumulative costs recognized as intangible assets and property,
plant, and equipment during the year. These include assets arising from business combinations
(there are none in 2023), and they exclude goodwill. Further information is provided in notes 3, 13,
and 14 of the financial statements.
•
OpEx, or operating expenses, refer to direct costs arising from expenditures associated with
maintaining assets, costs related to research and development, short-term leases, repairs and
maintenance, and other expenditures related to the day-to-day operation of LINK’s business. Further
information is provided in notes 8 and 9 of the financial statements.
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93
* 2023 is for LINK a first reporting period under EU Taxonomy. Therefore, no data for 2022 is available.
** Activities under “8.1. Data processing, hosting and related activities” have been recognized as not bringing an external turnover to LINK.
***Activities under “8.2. Computer programming, consultancy and related activities” have been recognized as not bringing an external turnover to LINK.
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Financial year: 2023
Substantial
contribution criteria
DNSH criteria (“Does
Not Significant Harm”)
Minimum safeguards
Proportion of taxonomy-aligned (A.1) or-eligible
(A.2) turnover, year 2022*
Category enabling activity
Category transitional activity
Economic activities
Code(s)
Absolute turnover
Proportion of turnover,, year 2023
Climate change mitigation
Climate change adaptation
Water
Pollution
Circular economy
Biodiversity
Climate change mitigation
Climate change adaptation
Water
Pollution
Circular economy
Biodiversity
Text
NOK
%
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y/ N
Y/ N
Y/ N
Y/ N
Y/ N
Y/ N
Y/ N
%
E
T
A. TAXONOMY-ELIGIBLE ACTIVITIES
A.1. Environmentally sustainable activities (Taxonomy-aligned)
none
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Turnover of environmentally sustainable
activities (Taxonomy-aligned) (A.1)
0
0%
0%
0%
0%
0%
0%
0%
0%
-
-
-
-
-
-
-
-
of which enabling
0
0%
0%
0%
0%
0%
0%
0%
0%
-
-
-
-
-
-
-
-
E
of which transitional
0
0%
0%
0%
T
A.2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)
E; N/EL
E; N/EL
E; N/EL
E; N/EL
E; N/EL
E; N/EL
8.1. Data processing, hosting and related
activities**
CCM 8.1/
CCA 8.1
0
0%
EL
EL
N/EL
N/EL
N/EL
N/EL
-
-
8.2. Computer programming, consultancy
and related activities*** CCA 8.2
0
0%
N/EL
EL
N/EL
N/EL
N/EL
N/EL
-
-
Turnover of Taxonomy-eligible but not
environmentally sustainable activities (not
Taxonomy-aligned activities) (A.2)
0
0%
0%
0%
0%
0%
0%
0%
-
Turnover of Taxonomy-eligible activities
(A.1 + A.2)
0
0%
0%
0%
0%
0%
0%
0%
-
B. TAXONOMY NON-ELIGIBLE ACTIVITIES
Turnover of Taxonomy-non-eligible
activities
6 282 126 100%
TOTAL 100%
Proportion of turnover from products or services associated with Taxonomy-aligned economic activities –
disclosure covering year 2023 (NOK 1000)
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Annual Report 2023 | Sustainability statement
94
* Activities under “8.1. Data processing, hosting and related activities” and “8.2. Computer programming, consultancy and related activities” have been
recognized as not associated with any CapEx dedicated separately to them.
Proportion of CapEx from products or services associated with Taxonomy-aligned economic activities – disclosure
covering year 2023 (NOK 1000)
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Financial year: 2023
Substantial
contribution criteria
DNSH criteria (“Does
Not Significant Harm”)
Minimum safeguards
Proportion of taxonomy -aligned (A.1) or -eligible
(A.2) CapEx, year 2022*
Category enabling activity
Category transitional activity
Economic activities
Code(s)
CapEx
Proportion of turnover,, year 2023
Climate change mitigation
Climate change adaptation
Water
Pollution
Circular economy
Biodiversity
Climate change mitigation
Climate change adaptation
Water
Pollution
Circular economy
Biodiversity
Text
NOK
%
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y/ N
Y/ N
Y/ N
Y/ N
Y/ N
Y/ N
Y/ N
%
E
T
A. TAXONOMY-ELIGIBLE ACTIVITIES
A.1. Environmentally sustainable activities (Taxonomy-aligned)
none
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
CapEx of environmentally sustainable
activities (Taxonomy-aligned) (A.1)
0
0%
0%
0%
0%
0%
0%
0%
0%
-
-
-
-
-
-
-
-
of which enabling
0
0%
0%
0%
0%
0%
0%
0%
0%
-
-
-
-
-
-
-
-
E
of which transitional
0
0%
0%
0%
T
A.2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)
E; N/EL
E; N/EL
E; N/EL
E; N/EL
E; N/EL
E; N/EL
8.1. Data processing, hosting and related
activities**
CCM 8.1/
CCA 8.1
0
0%
EL
EL
N/EL
N/EL
N/EL
N/EL
-
-
8.2. Computer programming, consultancy
and related activities*** CCA 8.2
0
0%
N/EL
EL
N/EL
N/EL
N/EL
N/EL
-
-
CapEx of Taxonomy-eligible but not
environmentally sustainable activities (not
Taxonomy-aligned activities) (A.2)
0
0%
0%
0%
0%
0%
0%
0%
-
CapEx of Taxonomy-eligible activities
(A.1 + A.2)
0
0%
0%
0%
0%
0%
0%
0%
-
B. TAXONOMY NON-ELIGIBLE ACTIVITIES
CapEx of Taxonomy-non-eligible activities 121 845 100%
TOTAL 100%
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Annual Report 2023 | Sustainability statement
95
* Activities under “8.1. Data processing, hosting and related activities” and “8.2. Computer programming, consultancy and related activities” have been
recognized as not associated with any CapEx dedicated separately to them.
Proportion of OpEx from products or services associated with Taxonomy-aligned economic activities – disclosure
covering year 2023 (NOK 1000)
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 18 19 20
Financial year: 2023
Substantial
contribution criteria
DNSH criteria (“Does
Not Significant Harm”)
Proportion of taxonomy -aligned (A.1) or -eligible
(A.2) OpEx, year 2022*
Category enabling activity
Category transitional activity
Economic activities
Code(s)
OpEx
Proportion of turnover,, year 2023
Climate change mitigation
Climate change adaptation
Water
Pollution
Circular economy
Biodiversity
Climate change mitigation
Climate change adaptation
Water
Pollution
Circular economy
Biodiversity
Minimum safeguards
Text
NOK
%
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y/ N
Y/ N
Y/ N
Y/ N
Y/ N
Y/ N
%
E
T
A. TAXONOMY-ELIGIBLE ACTIVITIES
A.1. Environmentally sustainable activities (Taxonomy-aligned)
none
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
OpEx of environmentally sustainable
activities (Taxonomy-aligned) (A.1)
0
0%
0%
0%
0%
0%
0%
0%
0%
-
-
-
-
-
-
-
-
of which enabling
0
0%
0%
0%
0%
0%
0%
0%
0%
-
-
-
-
-
-
-
-
E
of which transitional
0
0%
0%
0%
T
A.2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)
E; N/EL
E; N/EL
E; N/EL
E; N/EL
E; N/EL
E; N/EL
8.1. Data processing, hosting and related
activities**
CCM 8.1/
CCA 8.1
0
0%
EL
EL
N/EL
N/EL
N/EL
N/EL
-
-
8.2. Computer programming, consultancy
and related activities*** CCA 8.2
0
0%
N/EL
EL
N/EL
N/EL
N/EL
N/EL
-
-
OpEx of Taxonomy-eligible but not
environmentally sustainable activities (not
Taxonomy-aligned activities) (A.2)
0
0%
0%
0%
0%
0%
0%
0%
-
OpEx of Taxonomy-eligible activities
0
0%
0%
0%
0%
0%
0%
0%
-
(A.1 + A.2)
OpEx of Taxonomy-non-eligible activities 4 934 441 100%
TOTAL 100%
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96
2.2. [ESRS 2 MDR] Minimum Disclosure Requirements (MDR)
related to the material sustainability matter “Climate change –
Energy”
2.2.1. [MDR-P] Policies adopted to manage material sustainability
matter
The material sustainability matter: “Climate change – Energy” is managed under LINK’s ESG policy,
which includes chapters on climate change and on energy. The ESG policy is described in this
sustainability statement under minimum disclosure requirements related to the material sustainability
matter “Business conduct – Corporate culture” (chapter 4.1).
2.2.2. [MDR-A] Actions and resources in relation to material
sustainability matters
2.2.2.1. Disclosure of key actions
The following actions related to the material sustainability matter “Climate change – Energy” were
taken in 2023:
•
GHG report – created with an aim to calculate LINK’s climate impact, based on the principles
included in the Greenhouse Gas Protocol (GHGP).
•
Supplier Code of Conduct – described in this sustainability statement under minimum disclosure
requirements related to the material sustainability matter “Business conduct – Management of
relationships with suppliers” (chapter 4.3).
•
Supplier Due Diligence process – described in this sustainability statement under minimum
disclosure requirements related to the material sustainability matter “Business conduct –
Management of relationships with suppliers” (chapter 4.3).
•
Employees’ training – described in this sustainability statement under minimum disclosure
requirements related to the material sustainability matter “Business conduct – Corporate culture”
(chapter 4.1).
•
Employee Code of Conduct – described in this sustainability statement under minimum disclosure
requirements related to the material sustainability matter “Business conduct – Corporate culture”
(chapter 4.1).
2.2.2.2. Description of scope of key actions
The scope of the relevant actions is as follows:
•
GHG report – in 2023 LINK aimed at including emissions from Scope 1 and Scope 2 sources, as
well as- to a limited extent- from Scope 3.
The remaining actions are described in this sustainability statement under minimum disclosure
requirements as specified in sec. 2.2.2.1. above.
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97
2.2.2.3. Time horizon under which key action is to be completed
Time horizon under which relevant actions are to be completed is as follows:
•
GHG report – the first report was published in 2023; it will be regularly revised and updated.
The remaining actions are described in this sustainability statement under minimum disclosure
requirements as specified in sec. 2.2.2.1. above.
2.2.2.4. Description of key action taken, and its results, to provide for and cooperate in or
support provision of remedy for those harmed by actual material impacts
No such actions have been taken, as no harmed by actual material impacts have been identified.
2.2.2.5. Disclosure of quantitative and qualitative information regarding progress of
actions or action plans disclosed in prior periods
Not relevant in the first reporting period.
2.2.2.6. Disclosure of the type of current and future financial and other resources allocated
to the action plan
No separate resources have been allocated to the described actions. The actions have been
implemented in the course of a day-to-day business.
2.2.3. [MDR-M] Metrics in relation to material sustainability
matters
2.2.3.1. Description of metric used to evaluate performance and effectiveness, in relation
to material impact, risk or opportunity
LINK uses the following metrics to evaluate performance and effectiveness in relation to material
impacts, risks and opportunities related to the material sustainability matter “Climate change- Energy”:
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec)
– described in this sustainability statement under minimum disclosure requirements related to the
material sustainability matter “Business conduct – Corporate culture” (chapter 4.1).
•
Including Scope 1 and Scope 2 in the GHG report – the metric reflects LINK’s progress towards
calculating climate impact from own activities, based on the principles included in the Greenhouse
Gas protocol (GHGP).
•
Including Scope 3 in the GHG report – the metric reflects LINK’s progress towards calculating
climate impact from its value chain, based on the principles included in the Greenhouse Gas
Protocol (GHGP).
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2.2.3.2. Disclosure of methodologies and significant assumptions behind metric
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec)
– described in this sustainability statement under minimum disclosure requirements related to the
material sustainability matter “Business conduct – Corporate culture” (chapter 4.1).
•
Including Scope 1 and Scope 2 in the GHG report – the metric of a qualitative nature, with [yes/no]
values. The metric is monitored on annual bases.
•
Including Scope 3 in the GHG report – the metric of a qualitative nature, with [yes/no] values. The
metric is monitored on annual bases.
2.2.3.3. Type of external body other than assurance provider that provides validation
All metrics are monitored internally. They have not been validated by an external body so far.
2.2.4. [MDR-T] Tracking effectiveness of policies and actions
through targets
LINK tracks the effectiveness of the action “Employees’ training” that addresses each of the identified
material matters. The action is tracked with the use of the metric “Percentage of employees to complete
employees’ training (general compliance, GDPR, InfoSec)”. Relevant targets are described in this
sustainability statement under minimum disclosure requirements related to the material sustainability
matter “Business conduct – Corporate culture” (chapter 4.1).
LINK tracks the effectiveness of the action “GHG report” that addresses the material matter “Climate
change – Energy”. The action is tracked with the use of two metrics: “Including Scope 1 and Scope 2 in
the GHG report” and “Including Scope 3 in the GHG report”, as described below.
2.2.4.1. Relationship with policy objectives
GHG report is prepared annually in order to calculate LINK’s climate impact, based on the principles
included in the Greenhouse Gas Protocol (GHGP). It is related to certain objectives set out in the ESG
Policy.
2.2.4.2. Measurable target, its nature and scope
The targets are set to “YES” as of 31st December each year. They are monitored on annual bases.
2.2.4.3. Baseline value an year 2023 /2024/
•
Including Scope 1 and Scope 2 in the GHG report – 2023 is the first reporting year and therefore
constitutes a baseline. The baseline value is specified below.
•
Including Scope 3 in the GHG report – 2024 is the first reporting year and therefore constitutes a
baseline. The value will be available next year (the first report covering 2023 will be published in 2024).
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2.2.4.4. Period to which target applies and indication of milestones or interim targets
The target applies to the period, for which LINK’s strategy is set, that is until 2025. The baseline for
the disclosures relevant for the sustainability reporting purposes is specified in sec. 2.2.4.3 above No
milestones or interim targets have been set.
2.2.4.5. Description of methodologies and significant assumptions used to define target
Not material for the described target.
2.2.4.6. Target related to environmental matters is based on conclusive scientific evidence
Not material for the described target.
2.2.4.7. Disclosure of how stakeholders have been involved in target setting
The target was set out based on the internal expertise. Stakeholders were not directly involved.
2.2.4.8. Description of any changes in target and corresponding metrics or underlying
measurement methodologies, significant assumptions, limitations, sources and
adopted processes to collect data
Not material, as the target is reported for the first time.
2.2.4.9. Description of performance against disclosed target
As of December 31st 2023 the metric amounted to, and the performance against the targets were as
follows:
•
Including Scope 1 and Scope 2 in the GHG report – YES, which fulfills the target.
•
Including Scope 3 in the GHG report – NO (“no” as of Dec. 31st 2023, but the target is set from
2024, and the report was made available in 2024).
2.3. [ESRS E1]
2.3.1. [ESRS 2 GOV-3] Integration of sustainability-related
performance in incentive schemes
1.3.1.1. Disclosure of how climate-related considerations are factored into remuneration of
members of administrative, management and supervisory bodies
LINK has not introduced specific climate-related incentive schemes or remuneration policies for
members of administrative, management and supervisory bodies. The detailed datapoints included
under this disclosure requirement are therefore not material.
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2.3.2. [ESRS 2 SBM-3] Material impacts, risks and opportunities
and their interaction with strategy and business model
2.3.2.1. Type of climate-related risk
Description of climate-related risks has been included in this sustainability statement under disclosure
ESRS SBM-3 (chapter 1.1.10.1). All of the identified material risks are related to the sustainability matter
“Climate change-Energy” and include:
•
Risk of increased operating costs resulting from higher energy consumption.
•
Risk to business continuity, and consequently financial loss, due to the disruptions in the energy
supply.
•
Risk of productivity loss due to the reduced infrastructure redundancy, resulting from a trend
towards shared infrastructure.
All of the above risks shall be classified as the transition risk, as they result from the market-related
factors, driven by economic and social changes that impact supply and demand, rather than from
physical shocks or stresses of climate change.
2.3.2.2. Resilience analysis
The general description on the resilience of LINK’s strategy and business model regarding material
IROs has been included in this sustainability statement under disclosure ESRS SBM-3 (chapter
1.1.10.5). No further resilience analysis have been conducted. The detailed datapoints included under
this disclosure requirement are therefore not material
.
2.3.3. [ESRS 2 IRO-1] Description of the processes to identify and
assess material climate-related impacts, risks and opportunities
Description of the process to identify and assess material IROs, covering also the ones related to
climate, is included in this sustainability statement in chapter 1.1.11. No separate process related
climate-related IROs has been conducted. The detailed datapoints, included under this disclosure
requirement, have therefore been assessed as not material.
2.3.4. [E1-2] Policies related to climate change mitigation and
adaptation
2.3.4.1. Policies in place to manage its material impacts, risks and opportunities related to
climate change mitigation and adaptation [see ESRS 2 MDR-P]
Impacts, risks and opportunities related to climate change are managed under LINK’s ESG policy, which
includes chapters on climate change and on energy. The ESG policy is described in this sustainability
statement under minimum disclosure requirements related to the material sustainability matter
“Business conduct – Corporate culture” (chapter 4.1).
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2.3.4.2. Sustainability matters addressed by policy for climate change
LINK’s ESG policy includes a section regarding the Company’s approach to the environmental factors,
which consists of sub-chapters on the EU Taxonomy, climate change and energy. The sustainability
matter “Climate change- Energy” has been assessed as material.
2.3.5. [E1-3] Actions and resources in relation to climate change
policies
2.3.5.1. Actions and Resources related to climate change mitigation and adaptation [ESRS
2 MDR-A]
Actions and resources relevant to climate change issues assessed as material to LINK are described
in this sustainability statement under minimum disclosure requirements related to the material
sustainability matter “Climate change- Energy” (chapter 2.2.2).
Issues related to LINK’s GHG-emission are presented in the GHG report, available on LINK’s webpage.
No further, detailed analyses regarding decarbonisation and GHG emission reductions have been
conducted so far. The related datapoints, included under this disclosure requirement, have been
assessed as not material.
2.3.5.2. Explanation of extent to which ability to implement action depends on availability
and allocation of resources
Resources necessary to implement the actions relevant to climate change issues assessed as material
to LINK are described in this sustainability statement under minimum disclosure requirements related
to the material sustainability matter “Climate change- Energy” (chapter 2.2.2).
No further analyses regarding significant CapEx and OpEx have been conducted so far. The related
data points, included under this disclosure requirement, have been assessed as not material.
2.3.6. [E1-4] Targets related to climate change mitigation and
adaptation
2.3.6.1. Tracking effectiveness of policies and actions through targets [see ESRS 2 MDR-T ]
Targets relevant to climate change issues assessed as material to LINK are described in this
sustainability statement under minimum disclosure requirements related to the material sustainability
matter “Climate change- Energy” (chapter 2.2.4).
No GHG emissions reduction targets have been set. LINK is not active in any of the high climate impact
sectors. The detailed datapoints, included under this disclosure requirement, have been assessed as
not material.
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102
2.3.7. [E1-5] Energy consumption and mix
2.3.7.1. Total energy consumption related to own operations
LINK’s GHG report for 2023 has been published on LINK’s webpage (as linked under chapter 2.3.5.1
above). The report includes calculations regarding the energy mix, and the description of the relevant
methodology. No further analyses regarding the energy consumption and production, including
matters related to fossil sources, nuclear sources and renewable energy, have been conducted. LINK
is not active in any of the high climate impact sectors. The detailed data points, included under this
disclosure requirement, have been assessed as not material. In the future LINK intends to work on
translating data from its GHG report into certain data points specified in the ESRS.
2.3.8. [E1-6] Gross Scopes 1, 2, 3 and total GHG emissions
2.3.8.1. Gross Scopes 1, 2, 3 and total GHG emissions
LINK’s GHG report for 2023 has been published on LINK’s webpage (as linked under chapter 2.3.5.1
above). The report includes certain data on Scope 1, 2 and 3, as well as the description of the relevant
methodology. No further analyses regarding the GHG emissions have been conducted. The detailed
datapoints, included under this disclosure requirement, have been assessed as not material. In the
future LINK intends to work on translating data from its GHG report into certain data points specified
in the ESRS.
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3. Social information
LINK has assessed the following topics included in ESRS S1 and ESRS S4 as material:
•
ESRS S1: Topic “Own workforce” – Sub-topic “Equal treatment and opportunities for all” – Sub-sub-
topic “Training and skills development”
•
ESRS S4: Topic “Consumers and end users” – Sub-topic “Information-related impacts for
consumers and/or end-users” – Sub-sub-topic “Privacy”
No sustainability matters covered by ESRS S2, or ESRS S3 have been assessed as material.
Since LINK does not exceed on its balance sheet date the average number of 750 employees during
the financial year, it has decided to omit the information required by ESRS S1 and ESRS S4 respectively,
in accordance with Appendix C of ESRS 1 (phase-in). Nevertheless, for each such material topic
LINK discloses the required information on relevant policies, actions, metrics and targets. Such an
information is reported in this sustainability statement under disclosure requirement ESRS 2 BP-2
(chapter 1.1.2.9).
The description of how LINK identified the scope of the sustainability reporting is provided in this
statement under disclosure requirements ESRS 2 IRO-2 (chapters 1.1.12.3 and 1.1.12.4).
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4. Governance information
LINK has assessed the following topics included in ESRS G1 as material:
•
ESRS G1: Topic “Business conduct” – Sub-topic “Corporate culture”
•
ESRS G1: Topic “Business conduct” – Sub-topic “Protection of whistle-blowers”
•
ESRS G1: Topic “Business conduct” – Sub-topic “Management of relationships with suppliers”
•
ESRS G1: Topic “Business conduct” – Sub-topic “Corruption and bribery”
Hence, LINK reports in this chapter the minimum disclosure requirements covered by ESRS 2 MDR,
relevant for each of the above listed material topics (chapters 4.1-4.4). Moreover, the relevant disclosure
requirements covered by ESRS 2 GOV-1, as well as by G1-1, G1-2, G1-3 and G1-4 have been included
(chapter 4.5).
Since no sustainability matters covered by ESRS G1-5 “Political influence and lobbying activities” and
G1-6 “Payment practices” have been assessed as material, the disclosure requirements G1-5 and G1-6
are not included.
The description of how LINK identified the scope of the sustainability reporting is provided in this
statement under disclosure requirements ESRS 2 IRO-2 (chapters 1.1.12.3 and 1.1.12.4).
4.1. [ESRS 2 MDR] Minimum Disclosure Requirements (MDR)
related to the material sustainability matter: “Business conduct –
Corporate culture”
4.1.1. [MDR-P] Policies adopted to manage material sustainability
matters
The material sustainability matter: “Business conduct – Corporate culture” is managed under LINK’s
ESG policy, which includes a chapter on corporate culture.
4.1.1.1. Key contents of policy
LINK ESG policy reflects its approach to environmental, social and governance factors and covers
a wide range of topics that have been identified as the most relevant to the company. The choice
of the focus areas that are included in the policy, is based on the materiality assessment and due
diligence processes, as well as on the risk and opportunities identified within LINK’s risk management
framework. The policy describes general principles of materiality assessment and due diligence
processes, as well as sets out- to a different extent and with certain exclusions- high-level objectives
covering the following sustainability matters:
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•
Environmental factors: EU Taxonomy, Energy, Climate change;
•
Social factors: Decent working conditions; Respect for Human Rights; Diversity, inclusion and
belonging; Engagement, training and development; Corporate culture; Data privacy; Information
security; Consumer interests; Science, technology and innovation;
•
Governance Factors: Anti-corruption; Fair competition; Sanctions against certain countries,
industries, companies or individuals; Accounting, taxation and financial reporting; Compliance with
laws; Corporate governance; Whistleblowing.
Moreover, the policy includes a separate chapter on a variety of issues related to its enforcement.
4.1.1.2. Scope of policy or of its exclusions
LINK ESG policy has been adopted by the Board of Directors of LINK Mobility Group Holding ASA.
The policy applies to the Holding Company as well as to all its subsidiaries. It applies to all directors,
officers, managers, employees, as well as to consultants and contractors to the extent applicable. It
covers own operations of the Group, as well as- to a limited extent- its value chain.
The policy covers a wide range of environmental, social and governance topics. Among others, the
following policies, statements and principles are incorporated as part of the ESG policy:
•
Due Diligence Policy;
•
Fundamental human rights and decent working conditions principles;
•
Anti-slavery and human trafficking statement;
•
Diversity Policy;
•
Anti-Corruption and Anti-Bribery Policy;
•
Antitrust Policy;
•
Sanctions Policy.
The ESG policy has its limitations- separate policies cover certain other areas, such as:
•
personal data protection/ privacy;
•
information security;
•
accounting, taxation and financial reporting;
•
corporate governance;
•
whistleblowing.
4.1.1.3. Most senior level in organisation that is accountable for implementation of policy
The Global Leadership Team (GLT) has overall responsibility for the implementation of the ESG policy.
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4.1.1.4. Third-party standards or initiatives that are respected through implementation of
policy
The following documents and frameworks form basis of LINK’s ESG policy (the extent to which the
policy is aligned with them is explained in the policy itself):
•
UN Goals for Sustainable Development (“SDGs”);
•
UN Guiding Principles on Business and Human Rights (“UN Guiding Principles”);
•
UN Global Compact;
•
OECD Guidelines for Multinational Enterprises (“OECD Guidelines”);
•
OECD Due Diligence Guidance for Responsible Business Conduct (“OECD DD Guidance”);
•
European Sustainability Reporting Standards (“ESRS”);
•
ISO 37301:2021.
4.1.1.5. Description of consideration given to interests of key stakeholders in setting policy
Key stakeholders’ interests are taken into consideration during LINK’s materiality assessment and due
diligence processes that form basis for setting out and updating the ESG policy.
4.1.1.6. Explanation of how policy is made available to potentially affected stakeholders
and stakeholders who need to help implement it
Full version of the ESG policy is available to all LINK employees through an internal system. A
whistleblowing channel is available to report any suspected, potential or actual breaches. All employees
must complete a compliance training annually that covers inter alia notions related to the ESG policy.
The public version of the policy is available on LINK’s webpage.
4.1.2. [MDR-A] Actions and resources in relation to material
sustainability matters
4.1.2.1. Disclosure of key actions
The following actions related to the material sustainability matter “Business conduct – Corporate
culture” were taken in 2023:
•
Employees’ training – implemented with the aim to raise employees’ awareness of various
compliance issues, including the required conduct towards third parties; covers privacy training
(GDPR and InfoSec) and general compliance training (covering inter alia ESG and whistleblowing
policy).
•
Employee Code of Conduct – implemented with an aim to raise employees’ awareness on compliance
issues, to embed LINK’s core values and to build ethical foundation for LINK’s daily operation.
•
LINK Voice – implemented with an aim to measure employees’ engagement and collect employees’
opinions and feedback on engagement related matters.
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•
Transparency Act Report – described in this sustainability statement under minimum disclosure
requirements related to the material sustainability matter “Business conduct – Management of
relationships with suppliers” (chapter 4.3).
4.1.2.2. Description of scope of key actions
The scope of the relevant actions is as follows:
•
Employees’ training – in 2023 LINK aimed at including all employees in its compliance and GDPR/
InfoSec training programs;
•
Employee Code of Conduct – the document is available for all LINK employees in the internal
system; all LINK’s workforce is obliged to adhere by it;
•
LINK Voice – all LINK employees are regularly invited to take part in the Employee Engagement
survey delivered by an external provider.
The remaining actions are described in this sustainability statement under minimum disclosure
requirements as specified in sec. 4.1.2.1. above.
4.1.2.3. Time horizon under which key action is to be completed
Time horizon under which relevant actions are to be completed is as follows:
•
Employees’ training – privacy training (GDPR and InfoSec) has been obligatory for all LINK employees
for several years; general compliance training was launched in 2021; both training programs are
regularly revised and implemented on a rolling bases (including repetition);
•
Employee Code of Conduct – has been part of the LINK’s DNA for multiple years, implemented on
a rolling bases.
•
LINK Voice – has been conducted regularly for several years. The first survey was held in 2020.
The remaining actions are described in this sustainability statement under minimum disclosure
requirements as specified in sec. 4.1.2.1. above.
4.1.2.4. Description of key action taken, and its results, to provide for and cooperate in or
support provision of remedy for those harmed by actual material impacts
No such actions have been taken, as no harmed by actual material impacts have been identified.
4.1.2.5. Disclosure of quantitative and qualitative information regarding progress of actions
or action plans disclosed in prior periods
Not relevant in the first reporting period.
4.1.2.6. Disclosure of the type of current and future financial and other resources allocated
to the action plan
No separate resources have been allocated to the described actions. The actions have been
implemented in the course of a day-to-day business.
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4.1.3. [MDR-M] Metrics in relation to material sustainability matters
4.1.3.1. Description of metric used to evaluate performance and effectiveness, in relation
to material impact, risk or opportunity
LINK uses the following metrics to evaluate performance and effectiveness in relation to material
impacts, risks and opportunities related to the material sustainability matter “Business conduct-
Corporate culture”:
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec) –
the metric reflects LINK’s progress in disseminating knowledge, raising awareness and promoting
a variety of ESG matters among its workforce. It reflects the general progress in relation to each of
the identified material matters.
•
LINK Voice participation rate – the metric reflects the reliability of the results of “LINK Voice” survey.
•
Employee engagement score – the metric reflects LINK’s employees’ engagement in a workplace.
Engagement is a measure of people’s connection and commitment to the company and its goals.
By lifting it, LINK can positively impact company performance, innovation, retention and attraction
of talent.
•
Annual review of the Transparency Report – described in this sustainability statement under
minimum disclosure requirements related to the material sustainability matter “Business conduct –
Management of relationships with suppliers” (chapter 4.3).
4.1.3.2. Disclosure of methodologies and significant assumptions behind metric
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec)
– the metric is calculated as a percentage of employees that completed the required training in
relation to all employees. All employees are required to complete the training once a year. The
metric is monitored in an internal electronic system on a rolling bases, with an October-November
number as a reference point.
•
LINK Voice participation rate – the metric is calculated as a percentage of employees that took
part in LINK Voice in relation to all employees. It reflects participation in the year-end survey, which
is the main survey conducted among all employees annually.
•
Employee engagement score – the metric is calculated as an average of three statements which
the employee rates from 1 “strongly disagree” to 5 “strongly agree”. The statements that are being
rated are: (1) “I would recommend LINK Mobility as a great place to work”, (2) “LINK Mobility
motivates me to go beyond what I would in a similar role elsewhere”, (3) “I rarely think about
looking for a job at another company”, or similar. The metric is calculated for the year-end-edition
of LINK Voice each year, which is the main survey conducted among all employees annually.
•
Annual review of the Transparency Report – described in this sustainability statement under
minimum disclosure requirements related to the material sustainability matter “Business conduct
– Management of relationships with suppliers” (chapter 4.3).
4.1.3.3. Type of external body other than assurance provider that provides validation
All metrics are monitored internally. They have not been validated by an external body so far.
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4.1.4.[MDR-T] Tracking effectiveness of policies and actions
through targets
LINK tracks the effectiveness of the action “Employees’ training” that addresses each of the identified
material matters. The action is tracked with the use of the metric “Percentage of employees to complete
employees’ training (general compliance, GDPR, InfoSec)”.
LINK tracks the effectiveness of the action “LINK Voice” that addresses the material matter “Business
conduct – Corporate culture”, and “Own workforce – Equal treatment and opportunities for all – Training
and skills development”. The action is tracked with the use of two metrics: “LINK Voice participation
rate” and “Employee engagement score”.
4.1.4.1. Relationship with policy objectives
Requiring all LINK’s employees to annually complete relevant training on general compliance and
privacy (GDPR, InfoSec) is seen a tool to disseminate knowledge, raise awareness and promote a
variety of ESG matters among LINK’s workforce. Moreover, it supports the implementation of the
Employee code of conduct. Employees’ training includes notions from, and is related to, objectives
set out in the Company’s ESG Policy, Personal Data Protection Policy, Information Security Policy and
Whistleblowing Policy.
Involving all LINK’s employees in a LINK Voice survey is seen as a tool to collect employees’ opinions
and feedback in a variety of matters relevant to LINK. It is related to objectives set out in the Company’s
ESG Policy.
4.1.4.2. Measurable target, its nature and scope
The following targets are relevant to the metrics specified above:
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec)
– the target is set to 100% as of October-November each year. It is monitored in an internal
electronic system on a rolling bases. It includes all LINK employees group-wide.
•
LINK Voice participation rate – the target is set to 75% as of 31st December each year, which in
principle follows the general recommendation of the external provider of the survey (for companies
with 500 to 1000 employees). It is monitored in an internal electronic system on annual bases. It
includes all LINK employees group-wide according to policy.
•
Employee engagement score – the target is set to 75 as of 31st December each year. It is
monitored in an internal electronic system on annual bases. It includes all LINK employees group-
wide according to policy.
•
Annual review of the Transparency Report – described in this sustainability statement under
minimum disclosure requirements related to the material sustainability matter “Business conduct
– Management of relationships with suppliers” (chapter 4.3).
4.1.4.3. Baseline value an year 2023
2023 is the first reporting year and therefore constitutes a baseline. The baseline values are specified below.
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4.1.4.4. Period to which target applies and indication of milestones or interim targets
The target applies to the period, for which LINK’s strategy is set, that is until 2025. The baseline for
the disclosures relevant for the sustainability reporting purposes is specified in sec. 4.1.4.3 above No
milestones or interim targets have been set.
4.1.4.5. Description of methodologies and significant assumptions used to define target
Not material for the described target.
4.1.4.6. Target related to environmental matters is based on conclusive scientific evidence
Not material for the described target.
4.1.4.7. Disclosure of how stakeholders have been involved in target setting
The target was set out based on the internal expertise. Stakeholders were not directly involved.
4.1.4.8. Description of any changes in target and corresponding metrics or underlying
measurement methodologies, significant assumptions, limitations, sources and
adopted processes to collect data
Not material, as the target is reported for the first time.
4.1.4.9. Description of performance against disclosed target
As of December 31st 2023 the metrics amounted to, and the performance against the targets was as
follows:
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec)
– 90%, which fulfills the target of 100% in 90%.
•
LINK Voice participation rate – 88%, which exceeds the target of 75%.
•
Employee engagement score – 68, which fulfills the target of 75 in 90,67%.
•
Annual review of the Transparency Report – described in this sustainability statement under
minimum disclosure requirements related to the material sustainability matter “Business conduct
– Management of relationships with suppliers” (chapter 4.3).
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4.2. [ESRS 2 MDR] Minimum Disclosure Requirements (MDR)
related to the material sustainability matter: “Business conduct –
Protection of whistle-blowers”
4.2.1. [MDR-P] Policies adopted to manage material sustainability
matters
The material sustainability matter: “Business conduct – Protection of whistle-blowers” is managed, at
a general level, under LINK’s ESG policy, which includes chapters on whistleblowers. The ESG policy
is described in this sustainability statement under minimum disclosure requirements related to the
material sustainability matter “Business conduct – Corporate culture” (chapter 4.1). Moreover, detailed
notions relating to whistleblowers are described in LINK’s Whistleblowing Policy, as described below.
4.2.1.1. Key contents of policy
LINK’s Whistleblowing Policy constitutes an implementation of the principles included in LINK’s ESG
policy and aims to provide a channel for all employees to safely and anonymously raise their concerns
by reporting any suspected, potential or actual breach of applicable law, any of LINK’s policies, codes
of conduct or LINK’s values.
4.2.1.2. Scope of policy or of its exclusions
LINK’s Whistleblowing Policy applies to the Holding Company as well as to all its subsidiaries. It applies
to all LINK’s workforce, who can report incidents related to the Company’s own operations, as well
as to its value chain. The whistleblowing channel may be utilized for reporting of any misconduct,
covering also ESG matters.
4.2.1.3. Most senior level in organization that is accountable for implementation of policy
The Whistleblowing Policy was set up by the Chief People and Strategy Officer, who is part of the GLT, in
cooperation with the VP for Legal & Compliance, who reports directly to the CEO. It is the responsibility
of LINK’s HR team and Legal & Compliance team to make the whistleblowing channel available to all
employees through LINK’s internal communication channels.
4.2.1.4. Third-party standards or initiatives that are respected through implementation of
policy
The following documents and frameworks form basis of LINK’s Whistleblowing Policy:
•
Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the
protection of persons who report breaches of Union law (the “Whistleblower Directive”);
•
the Norwegian Work Environment Act (its Chapter 2A regarding Whistleblowing, added 16th June
2017).
4.2.1.5. Description of consideration given to interests of key stakeholders in setting policy
Key stakeholders’ interests are taken into consideration during LINK’s materiality assessment and due
diligence processes that form basis for setting out and updating all LINK’s policies.
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4.2.1.6. Explanation of how policy is made available to potentially affected stakeholders
and stakeholders who need to help implement it
Full version of the Whistleblowing Policy is available to all LINK employees through an internal system.
A whistleblowing channel is available through the online system delivered by an external provider.
All employees must complete a compliance training annually that covers inter alia notions related to
whistleblowers.
4.2.2. [MDR-A] Actions and resources in relation to material
sustainability matters
4.2.2.1. Disclosure of key actions
The following actions related to the material sustainability matter “Business conduct – Protection of
whistle-blowers” were taken in 2023:
•
Whistleblowing channel – implemented with an aim to provide LINK’s workforce with a secure
and anonymous channel to raise their concerns by reporting any suspected, potential or actual
breach of applicable law, any of LINK’s policies, codes of conduct or LINK’s values.
•
Employees’ training – described in this sustainability statement under minimum disclosure
requirements related to the material sustainability matter “Business conduct – Corporate culture”
(chapter 4.1).
•
Employee Code of Conduct – described in this sustainability statement under minimum disclosure
requirements related to the material sustainability matter “Business conduct – Corporate culture”
(chapter 4.1).
4.2.2.2. Description of scope of key actions
The scope of the relevant actions is as follows:
•
Whistleblowing channel – the channel is available for all LINK employees in an online system
delivered by an external provider.
The remaining actions are described in this sustainability statement under minimum disclosure
requirements as specified in sec. 4.2.2.1. above.
4.2.2.3. Time horizon under which key action is to be completed
Time horizon under which relevant actions are to be completed is as follows:
•
Whistleblowing channel – has been available for LINK’s employees for several years, implemented
on a rolling bases.
The remaining actions are described in this sustainability statement under minimum disclosure
requirements as specified in sec. 4.2.2.1. above.
4.2.2.4. Description of key action taken, and its results, to provide for and cooperate in or
support provision of remedy for those harmed by actual material impacts
No such actions have been taken, as no harmed by actual material impacts have been identified.
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4.2.2.5. Disclosure of quantitative and qualitative information regarding progress of
actions or action plans disclosed in prior periods
Not relevant in the first reporting period.
4.2.2.6. Disclosure of the type of current and future financial and other resources allocated
to the action plan
No separate resources have been allocated to the described actions. The actions have been
implemented in the course of a day-to-day business.
4.2.3. [MDR-M] Metrics in relation to material sustainability matters
4.2.3.1. Description of metric used to evaluate performance and effectiveness, in relation
to material impact, risk or opportunity
LINK uses the following metrics to evaluate performance and effectiveness in relation to material
impacts, risks and opportunities related to the material sustainability matter “Business conduct-
Protection of whistle-blowers”:
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec)
– described in this sustainability statement under minimum disclosure requirements related to the
material sustainability matter “Business conduct – Corporate culture” (chapter 4.1).
•
Percentage of non-handled whistleblowers’ notifications – the metric reflects LINK’s progress in
handling whistleblowers’ reports.
4.2.3.2. Disclosure of methodologies and significant assumptions behind metric
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec)
– described in this sustainability statement under minimum disclosure requirements related to the
material sustainability matter “Business conduct – Corporate culture” (chapter 4.1).
•
Percentage of non-handled whistleblowers’ notifications – the metric is calculated as
a percentage of whistleblowers’ reports that have not been addressed, in relation to all
whistleblowers’ reports. Addressing a whistleblower’s report means taking up an action to
investigate it in line with LINK’s whistleblowing policy, and implementing adequate measures to
resolve it in accordance with relevant laws and regulations, LINK’s codes of conduct and LINK’s
values. All whistleblowers’ reports’ shall be adequately addressed. The metric is monitored on
annual bases.
4.2.3.3. Type of external body other than assurance provider that provides validation
All metrics are monitored internally. They have not been validated by an external body so far.
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4.2.4. [MDR-T] Tracking effectiveness of policies and actions
through targets
LINK tracks the effectiveness of the action “Employees’ training” that addresses each of the identified
material matters. The action is tracked with the use of the metric “Percentage of employees to complete
employees’ training (general compliance, GDPR, InfoSec)”. Relevant targets are described in this
sustainability statement under minimum disclosure requirements related to the material sustainability
matter “Business conduct – Corporate culture” (chapter 4.1).
LINK tracks the effectiveness of the action “Whistleblowing channel” that addresses the material
matter “Business conduct – Protection of whistle-blowers”. The action is tracked with the use of the
metric “Percentage of non-handled whistleblowers’ notifications”, as described below.
4.2.4.1. Relationship with policy objectives
LINK has developed a whistleblowing channel to provide its workforce with a secure and anonymous
channel to raise their concerns regarding breach of applicable law, any of LINK’s policies, codes of
conduct or LINK’s values. No report may remain unaddressed. It is related to certain objectives set out
in the ESG Policy and Whistleblowing Policy.
4.2.4.2. Measurable target, its nature and scope
The following target is relevant to the metrics specified above:
•
Percentage of non-handled whistleblowers’ notifications – the target is set to 0% as of
31st December each year. It is monitored on annual bases. It includes all whistleblower’s reports
group-wide.
4.2.4.3. Baseline value on year 2023
2023 is the first reporting year and therefore constitutes a baseline. The baseline values are specified
below.
4.2.4.4. Period to which target applies and indication of milestones or interim targets
The target applies to the period, for which LINK’s strategy is set, that is until 2025. The baseline for the
disclosures relevant for the sustainability reporting purposes is specified in sec. 4.2.4.3 above.
No milestones or interim targets have been set.
4.2.4.5. Description of methodologies and significant assumptions used to define target
Not material for the described target.
4.2.4.6. Target related to environmental matters is based on conclusive scientific evidence
Not material for the described target.
4.2.4.7. Disclosure of how stakeholders have been involved in target setting
The target was set out based on the internal expertise. Stakeholders were not directly involved.
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4.2.4.8. Description of any changes in target and corresponding metrics or underlying
measurement methodologies, significant assumptions, limitations, sources and
adopted processes to collect data
Not material, as the target is reported for the first time.
4.2.4.9. Description of performance against disclosed target
As of December 31st 2023 the metric amounted to, and the performance against the target was as
follows:
•
Percentage of non-handled whistleblowers’ notifications – 0%, which fulfills the target in 100 %.
4.3. [ESRS 2 MDR] Minimum Disclosure Requirements (MDR)
related to the material sustainability matter:“Businessconduct –
Management of relationships with suppliers”
4.3.1. [MDR-P] Policies adopted to manage material sustainability
matter
The sustainability matter: “Business conduct – Management of relationships with suppliers” is managed
under LINK’s ESG policy, which includes a chapter on due diligence, covering supplier due diligence.
The ESG policy is described in this sustainability statement under minimum disclosure requirements
related to the material sustainability matter “Business conduct – Corporate culture” (chapter 4.1).
4.3.2. [MDR-A] Actions and resources in relation to material
sustainability matter
4.3.2.1. Disclosure of key actions
The following actions related to the material sustainability matter “Business conduct – Management
of relationships with suppliers” were taken in 2023:
•
Supplier Code of Conduct – implemented with the aim to raise stakeholders’ awareness;
introduced firstly in 2021, and applied ever since, it conveys a clear message of LINK’s
expectations within areas covered by the ESG policy, and hence, it contributes to improving
sustainability through LINK’s value chain.
•
Supplier Due Diligence process – implemented with an aim to integrate the principles of
responsible business conduct into the company’s relation to various third parties, by raising
employees’ awareness and by collecting relevant knowledge on third parties; the main tool used
during this process is an internal SDD questionnaire, where an employee that onboards a provider
gets a checklist of tasks that need to be performed before the contract is signed, depending
on the associated risk that is assessed based on the embedded indicators (e.g. if a provider is
assessed as «high risk with red flags» the commitment must be deliberated and approved on a
higher authority level). Further information on the SDD process is included under disclosure G1-2
(chapters 4.5.3.2, 4.5.3.3).
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•
Transparency Act Report – constitutes LINK’s account for the third party due diligence with
regard to fundamental human rights and decent working conditions, as required by the Norwegian
Transparency Act.
•
Employees’ training – described in this sustainability statement under minimum disclosure
requirements related to the material sustainability matter “Business conduct – Corporate culture”
(chapter 4.1).
•
Employee Code of Conduct – described in this sustainability statement under minimum disclosure
requirements related to the material sustainability matter “Business conduct – Corporate culture”
(chapter 4.1).
4.3.2.2. Description of scope of key actions
The scope of the relevant actions is as follows:
•
Supplier Code of Conduct – the document is available on LINK’s webpage, and aims at covering all
supply-side entities.
•
Supplier Due Diligence process – in 2023 LINK aimed at including all new supply-side entities in
the SDD process; the scope of the process varies depending on the risk associated with specific
entities, based on the chosen risk indicators.
•
Transparency Act Report – the report describes how LINK fulfils its duties to carry out, account
for and provide information on its due diligence practices.
The remaining actions are described in this sustainability statement under minimum disclosure
requirements as specified in sec. 4.3.2.1. above.
4.3.2.3. Time horizon under which key action is to be completed
Time horizon under which relevant actions are to be completed is as follows:
•
Supplier Code of Conduct – implemented on a rolling bases.
•
Supplier Due Diligence process – the process was designed in 2021 and has been implemented
since 2022; it is regularly revised and implemented on a rolling bases.
•
Transparency Act Report – the first report was published in 2023; it will be regularly revised and
updated.
The remaining actions are described in this sustainability statement under minimum disclosure
requirements as specified in sec. 4.3.2.1. above.
4.3.2.4. Description of key action taken, and its results, to provide for and cooperate in or
support provision of remedy for those harmed by actual material impacts
No such actions have been taken, as no harmed by actual material impacts have been identified.
4.3.2.5. Disclosure of quantitative and qualitative information regarding progress of
actions or action plans disclosed in prior periods
Not relevant in the first reporting period.
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4.3.2.6. Disclosure of the type of current and future financial and other resources allocated
to the action plan
No separate resources have been allocated to the described actions. The actions have been
implemented in the course of a day-to-day business.
4.3.3. [MDR-M] Metrics in relation to material sustainability
matters
4.3.3.1. Description of metric used to evaluate performance and effectiveness, in relation
to material impact, risk or opportunity
LINK uses the following metrics to evaluate performance and effectiveness in relation to material
impacts, risks and opportunities related to the material sustainability matter “Business conduct-
Management of relationships with suppliers”:
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec)
– described in this sustainability statement under minimum disclosure requirements related to the
material sustainability matter “Business conduct – Corporate culture” (chapter 4.1).
•
Annual review of the Transparency Report – the metric reflects LINK’s progress towards ensuring
its compliance with the Norwegian Transparency Act.
4.3.3.2. Disclosure of methodologies and significant assumptions behind metric
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec)
– described in this sustainability statement under minimum disclosure requirements related to the
material sustainability matter “Business conduct – Corporate culture” (chapter 4.1).
•
Annual review of the Transparency Report – the metric of a qualitative nature, with [yes/no]
values. The metric is monitored on annual bases.
4.3.3.3. Type of external body other than assurance provider that provides validation
All metrics are monitored internally. They have not been validated by an external body so far.
4.3.4. [MDR-T] Tracking effectiveness of policies and actions
through targets
LINK tracks the effectiveness of the action “Employees’ training” that addresses each of the identified
material matters. The action is tracked with the use of the metric “Percentage of employees to complete
employees’ training (general compliance, GDPR, InfoSec)”. Relevant targets are described in this
sustainability statement under minimum disclosure requirements related to the material sustainability
matter “Business conduct – Corporate culture” (chapter 4.1).
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LINK tracks the effectiveness of the actions “Transparency Report”, “Supplier Due Diligence, “Supplier
code of conduct” that address the material matters “Business conduct – Management of relationships
with suppliers”, “Consumers and end users – Information related impacts for consumers and/or end-
users – Privacy”, and “Climate change – Energy”, and “Business conduct- corruption and bribery”. The
action is tracked with the use of the metric “Annual review of the Transparency Report”, as described below.
4.3.4.1. Relationship with policy objectives
Transparency Report is prepared annually in order to fulfil LINK’s obligations resulting from the
Norwegian Transparency Act. It is seen as a tool to enhance transparency within LINK’s supply chain
and therefore addresses certain objectives set out in the ESG Policy.
4.3.4.2. Measurable target, its nature and scope
The following target is relevant to the metrics specified above:
•
Annual review of the Transparency Report – the target is set to “YES” as of 31st December each
year. It is monitored on annual bases.
4.3.4.3. Baseline value an year 2023
2023 is the first reporting year and therefore constitutes a baseline. The baseline values are specified below.
4.3.4.4. Period to which target applies and indication of milestones or interim targets
The target applies to the period, for which LINK’s strategy is set, that is until 2025. The baseline for
the disclosures relevant for the sustainability reporting purposes is specified in sec. 4.3.4.3 above No
milestones or interim targets have been set.
4.3.4.5. Description of methodologies and significant assumptions used to define target
Not material for the described target.
4.3.4.6. Target related to environmental matters is based on conclusive scientific evidence
Not material for the described target.
4.3.4.7. Disclosure of how stakeholders have been involved in target setting
The target was set out based on the internal expertise. Stakeholders were not directly involved.
4.3.4.8. Description of any changes in target and corresponding metrics or underlying
measurement methodologies, significant assumptions, limitations, sources and
adopted processes to collect data
Not material, as the target is reported for the first time.
4.3.4.9. Description of performance against disclosed target
As of December 31st 2023 the metric amounted to, and the performance against the target was as follows:
•
Annual review of the Transparency Report – YES, which fulfills the target.
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4.4. [ESRS 2 MDR] Minimum Disclosure Requirements (MDR)
related to the material sustainability matter: “Business conduct –
Corruption and bribery”
4.4.1. [MDR-P] Policies adopted to manage material sustainability
matter
The material sustainability matter: “Business conduct – Corruption and bribery” is managed under
LINK’s ESG policy, which includes a chapter on anti-corruption. The ESG policy is described in this
sustainability statement under minimum disclosure requirements related to the material sustainability
matter “Business conduct – Corporate culture” (chapter 4.1).
4.4.2. [MDR-A] Actions and resources in relation to material
sustainability matters
The following actions related to the material sustainability matter “Business conduct – Corruption and
bribery” were taken in 2023:
•
Employees’ training – described in this sustainability statement under minimum disclosure
requirements related to the material sustainability matter “Business conduct – Corporate culture”
(chapter 4.1).
•
Employee Code of Conduct – described in this sustainability statement under minimum
disclosure requirements related to the material sustainability matter “Business conduct –
Corporate culture” (chapter 4.1).
•
Supplier Code of Conduct – described in this sustainability statement under minimum disclosure
requirements related to the material sustainability matter “Business conduct – Management of
relationships with suppliers” (chapter 4.3).
4.4.3. [MDR-M] Metrics in relation to material sustainability
matters
4.4.3.1. Description of metric used to evaluate performance and effectiveness, in relation
to material impact, risk or opportunity
LINK uses the following metrics to evaluate performance and effectiveness in relation to material
impacts, risks and opportunities related to the material sustainability matter “Business conduct-
Corruption and bribery”:
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec)
– described in this sustainability statement under minimum disclosure requirements related to the
material sustainability matter “Business conduct – Corporate culture” (chapter 4.1).
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•
Percentage of non-handled incidents of corruption/ bribery – the metric reflects LINK’s progress
in ensuring the implementation of a zero-tolerance approach to corruption and bribery.
•
Annual review of the Transparency Report – described in this sustainability statement under
minimum disclosure requirements related to the material sustainability matter “Business conduct
– Management of relationships with suppliers” (chapter 4.3).
4.4.3.2. Disclosure of methodologies and significant assumptions behind metric
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec)
– described in this sustainability statement under minimum disclosure requirements related to the
material sustainability matter “Business conduct – Corporate culture” (chapter 4.1).
•
Percentage of non-handled incidents of corruption/ bribery – the metric is calculated as a
percent of incidents of corruption/ bribery that have been reported/ discovered and not addressed,
in relation to all incidents of corruption/ bribery that have been reported/ discovered. Addressing
an incident means taking up an action to investigate it, and implementing adequate measures to
resolve it in accordance with relevant laws and regulations, LINK’s codes of conduct and LINK’s
values. All incidents of corruption/ bribery shall be adequately addressed. The metric is monitored
on annual bases.
•
Annual review of the Transparency Report – described in this sustainability statement under
minimum disclosure requirements related to the material sustainability matter “Business conduct
– Management of relationships with suppliers” (chapter 4.3).
4.4.3.3. Type of external body other than assurance provider that provides validation
All metrics are monitored internally. They have not been validated by an external body so far.
4.4.4. [MDR-T] Tracking effectiveness of policies and actions
through targets
LINK tracks the effectiveness of the action “Employees’ training” that addresses each of the identified
material matters. The action is tracked with the use of the metric “Percentage of employees to complete
employees’ training (general compliance, GDPR, InfoSec)”. Relevant targets are described in this
sustainability statement under minimum disclosure requirements related to the material sustainability
matter “Business conduct – Corporate culture” (chapter 4.1).
LINK tracks the effectiveness of inter alia the action “Supplier Code of Conduct” that address inter
alia the material matter “Business conduct- corruption and bribery”. The action is tracked with the
use of the metric “Annual review of the Transparency Report”. Relevant targets are described in this
sustainability statement under minimum disclosure requirements related to the material sustainability
matter “Business conduct – Management of relationships with suppliers” (chapter 4.3).
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LINK tracks the effectiveness of the action “Employee Code of Conduct” that addresses each of the
identified material matters, including in particular the material matter “Business conduct – corruption
and bribery”. The action is tracked with the use of the metric “Percentage of non-handled incidents of
corruption/ bribery”, as described below.
4.4.4.1. Relationship with policy objectives
LINK follows a zero-tolerance to corruption and bribery approach. No incident of corruption and bribery
may therefore remain unaddressed. It is related to certain objectives set out in the ESG Policy.
4.4.4.2. Measurable target, its nature and scope
The following target is relevant to the metrics specified above:
•
Percentage of non-handled incidents of corruption/ bribery – the target is set to 0% as of 31st
December each year. It is monitored on annual bases. It includes all incidents reported/discovered
group-wide.
4.4.4.3. Baseline value an year 2023
2023 is the first reporting year and therefore constitutes a baseline. The baseline values are therefore
specified below.
4.4.4.4. Period to which target applies and indication of milestones or interim targets
The target applies to the period, for which LINK’s strategy is set, that is until 2025. The baseline for
the disclosures relevant for the sustainability reporting purposes is specified in sec. 4.4.4.3 above No
milestones or interim targets have been set.
4.4.4.5. Description of methodologies and significant assumptions used to define target
Not material for the described target.
4.4.4.6. Target related to environmental matters is based on conclusive scientific evidence
Not material for the described target.
4.4.4.7. Disclosure of how stakeholders have been involved in target setting
The target was set out based on the internal expertise. Stakeholders were not directly involved.
4.4.4.8. Description of any changes in target and corresponding metrics or underlying
measurement methodologies, significant assumptions, limitations, sources and adopted
processes to collect data
Not material, as the target is reported for the first time.
4.4.4.9. Description of performance against disclosed target
As of December 31st 2023 the metric amounted to, and the performance against the target was as
follows:
•
Percentage of non-handled incidents of corruption/ bribery – 0%, which fulfills the target in 100 %.
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4.5. [ESRS G1]
4.5.1. [GOV-1] The role of the administrative, management and
supervisory bodies
4.5.1.1. Role of administrative, management and supervisory bodies related to business
conduct
The ultimate responsibility for the oversight of business conduct matters lies within the Board of
Directors, which sets out the strategic ESG principles and reviews them in case of need. Business
conduct matters are managed by the Human Resources department on a group level, supervised by
one of the GLT members, as well as by local human resources units. The role of LINK’s administrative,
management and supervisory bodies is described in this sustainability statement under disclosure
ESRS 2 GOV-1 (chapter 1.1.3).
4.5.1.2. Expertise of administrative, management and supervisory bodies on business
conduct matters
All members of the bodies responsible for the business conduct matters, as mentioned in chapter
4.5.1.1. above have relevant experience.
4.5.2. [G1-1] Business conduct policies and corporate culture
4.5.2.1. Policies in place to manage material impacts, risks and opportunities related to
business conduct matters and how LINK fosters its corporate culture. [see ESRS
MDR-P]
Policies relevant to LINK’s business conduct, including the corporate culture, are described in this
statement under minimum disclosure requirements related to material sustainability matters (chapters
4.1.1, 4.1.2, 4.1.3, 4.1.4).
4.5.2.2. Description of how LINK establishes, develops, promotes and evaluates its
corporate culture
LINK has taken the following actions related to the establishment, development and promotion of its
corporate culture:
•
conducting LINK Voice,
•
providing employees’ training,
•
establishing Employee Code of Conduct and
•
preparing the Transparency Act Report.
The actions are described in this statement under minimum disclosure requirements related to material
sustainability matter “Business conduct- Corporate culture” (chapter 4.1.2). The metrics and targets
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related to the evaluation of such actions are described in chapters 4.1.3 and 4.1.4.
The principal themes that are promoted and communicated as part of LINK’s corporate culture- mostly
through the Employee Code of Conduct- include notions related to the people (e.g. human rights,
equality, diversity etc.), LINK’s business (e.g. anti-corruption, conflict of interest, privacy, intellectual
property, environment etc.), as well as LINK’s business partners (e.g. gifts, hospitality etc.). The Code
reflects LINK’s values: United, Dedicated and Enthusiastic, and is based on the ten principles provided
by the United Nations (UN) Global Compact.
4.5.2.3. Mechanisms for identifying, reporting and investigating concerns about unlawful
behavior or behavior in contradiction of its code of conduct or similar internal rules
LINK has implemented the Whistleblowing Policy and has provided the whistleblowing channel available
for all its workforce. The whistleblowing-related policies and actions are seen as a mechanism for
identifying, reporting and investigating concerns about the behavior that contradicts or may contradict
the law, ethical standards, LINK’s codes or any LINK’s values. Detailed information on relevant policies,
actions, metrics and targets are described in this sustainability statement in chapter 4.2.
a. Policies on anti-corruption or anti-bribery consistent with United Nations
Convention against Corruption (or timetable for their implementation)
LINK ESG Policy incorporates anti-corruption and anti-bribery policy and aims at ensuring consistency
with UN Convention against Corruption. In the future LINK plans to audit relevant chapters of its ESG
policy to ensure the Convention is respected.
b. Safeguards for reporting irregularities including whistleblowing protection
LINK has implemented the Whistleblowing Policy and has provided the whistleblowing channel
available for all its workforce. Detailed information on relevant policies, actions, metrics and targets
are described in this sustainability statement in chapter 4.2.
c. Policies on protection of whistle-blowers (or timetable for their implementation)
LINK has implemented the Whistleblowing Policy. It is regularly reviewed and updated if needed. It is
described in this sustainability statement in chapter 4.2.
d. Information on commitment to investigate business conduct incidents promptly,
independently and objectively
LINK is committed to investigate business conduct incidents promptly, independently and objectively.
The relevant mechanisms are described in LINK’s ESG policy and Whistleblowing Policy, as described
in this sustainability statement in chapters 4.1.1 and 4.2.1.
e. Policies with respect to animal welfare are in place
LINK has not implemented policies with respect to animal welfare as it has assessed this as not
material (LINK operates in a digital rather than physical world).
f. Information about policy for training within organisation on business conduct
LINK provides its employees’ with a training on a variety of ESG matters, including notions covered by
the Employee Code of Conduct. Detailed information on relevant policies, actions, metrics and targets
are described in this sustainability statement in chapter 1.1.2.9.b.
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g. Disclosure of the functions that are most at risk in respect of corruption and bribery
LINK has not conducted detailed analysis regarding specifically the identification of functions that are
most at risk in respect of corruption and bribery.
4.5.2.4. Entity is subject to legal requirements with regard to protection of whistleblowers
LINK is subject to the following legal acts concerning protection of whistleblowers:
•
Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the
protection of persons who report breaches of Union law (the “Whistleblower Directive”);
•
the Norwegian Work Environment Act (its Chapter 2A regarding Whistleblowing, added 16th June
2017).
Detailed information on relevant policies, actions, metrics and targets are described in this sustainability
statement in chapter 4.2.
4.5.3. [G1-2] Management of relationships with suppliers
4.5.3.1. Policy to prevent late payments, especially to SMEs
LINK has not adopted a policy to prevent late payments. LINK endeavours to remunerate suppliers per
the terms of the supplier contract. Baring any dispute, payments are made on time.
a. Reasons for not having adopted policies
LINK has not identified a high risk related to late payments. Late payments have not constituted a
major problem so far.
b. Timeframe in which LINK aims to adopt policies
At the moment, LINK has no concrete plan to adopt policy to prevent late payments.
4.5.3.2. Description of approaches in regard to relationships with suppliers, taking account
risks related to supply chain and impacts on sustainability matters
LINK is committed to avoid causing adverse impacts on people, the environment and society in its daily
operations, as well as to avoid contribution to such adverse impacts in its relations with stakeholders,
including suppliers and business partners.
Within the process of providing its services, LINK depends on several groups of supply-side actors,
as described under disclosure ESRS 2 SBM 1 (chapter 1.1.8.3). Since 2021, certain actions have been
taken up, aimed at identifying and organizing LINK’s relations with suppliers, enabling the Company to
act responsibly and to create added value throughout its value chain. The Supplier Due Diligence (SDD)
process that reflects an outward-facing approach to risk management was designed in 2021 and has
been implemented since 2022, with an aim to integrate the principles of responsible business conduct
into the company’s relation to various stakeholders. The focus areas of the process include a variety of
sustainability matters, covering inter alia fundamental human rights and decent working conditions, as
well as other areas such as data privacy, anti-corruption and antitrust.
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The process follows in principle the methodology proposed by the OECD Due Diligence Guidance
for Responsible Business Conduct
7
, which reflects standards set up in the OCED Guidelines for
Multinational Enterprises
8
. It also fulfills LINK’s obligation to carry out due diligence in accordance
with the Transparency Act that came into force in 2022. The framework is available to all LINK affiliates,
with a stepwise approach to ensure that categorization of risk level is performed before commitment.
General risk assessment within the SDD process
The actual and potential adverse impacts within LINK’s relations with suppliers and business partners
have been identified as part of the general risk assessment performed within the SDD process. The
assessed suppliers and business partner groups include the categories identified during the suppliers’
mapping (as described under disclosure ESRS 2 SBM 1, chapter 1.1.8.3). For all categories, apart from
minor providers, the risk has been assessed as “medium”. The general risk assessment process that
was performed is shown on the figure below.
During the general risk assessment performed within the SDD process, certain risk indicators were
chosen, that are later used for the assessment of individual providers. Such indicators cover the
following areas:
•
type of a provider (suppliers’/ business partners’ group);
•
geographical location of a provider;
•
characteristics of personal data processing;
•
total value of all contracts with a provider in the financial year.
Identification
of risks
within supply chain/
business partners
• based on
deliberations
from LINK’s risk
management
framework
• considers
corporate policies
• in accordance
with LINK’s risk
assessment
template
• separately for
each providers’
group (category)
• relevant for each
identified and
assessed risk
• used later for
the individual
providers’
assessment
• depending on
the value of risk
indicators
• used later for
the individual
providers’
assessment
Assessment
of each
identified risk
Formulation
of
risk indicators
Formulation
of
risk categories
7
OECD (2018), OECD Due Diligence Guidance for Responsible Business Conduct, OECD Publishing. mneguidelines.oecd.org/OECD-
Due-Diligence-Guidance-for-Responsible-Business-Conduct.pdf
8
OECD (2018), OECD Due Diligence Guidance for Responsible Business Conduct, OECD Publishing. mneguidelines.oecd.org/OECD-
Due-Diligence-Guidance-for-Responsible-Business-Conduct.pdf
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Individual risk assessment within the SDD process
The scope of the SDD process depends on the individual provider’s risk assessment, during which
certain indicators are taken into account, as mentioned above. Depending on a type of vendor, its
characteristics, and the scope of cooperation, questionnaires are set out in order to identify and
address potential risk for the assessed suppliers/business partners.
4.5.3.3. Disclosure of how social and environmental criteria are taken into account for
selection of supply-side contractual partners
Depending on the risk category the individual provider is assigned to during the individual risk
assessment performed within framework of the Supplier Due Diligence process, different actions
need to be performed. The risk categories are based on criterions that include social (data processing,
location in a high risk country regarding corruption/ social indexes etc) and environmental (type of
provider- hosting/ data storage) aspects, as outlined in chapter 4.5.3.2 above. The main tool used
during the process is an internal SDD questionnaire, where an employee that onboards a provider
gets a checklist of tasks that need to be performed before the contract is signed. The implemented
measures include:
•
Supplier Code of Conduct – implemented with the aim to raise stakeholders’ awareness; introduced
firstly in 2021, and applied ever since, it conveys a clear message of LINK’s expectations within
areas covered by ESG policy, and hence, it contributes to improving sustainability through LINK’s
value chain;
•
Employee Code of Conduct – implemented with the aim to raise employees’ awareness; has been
a part of the LINK DNA for multiple years, embedding LINK’s core values and building ethical
foundation for LINK’s daily operation;
•
Employees training – implemented with the aim to raise employees’ awareness of various compliance
issues, including the required conduct towards third parties; privacy training (GDPR and InfoSec
training) has been obligatory for all LINK employees for several years now, and in 2021 the company
additionally launched a general compliance training, covering sustainability, anti-corruption, and
competition policies;
•
SDD questionnaire – implemented with the aim to raise employees’ awareness of compliance
issues, and to collect relevant knowledge on third parties; acts as a primary guidance tool in the
SDD process, by instructing an employee on steps that should be performed when onboarding
an individual provider, depending on the associated risk that is assessed based on the embedded
indicators (e.g. if a provider is assessed as «high risk with red flags» the commitment must be
deliberated and approved on a higher authority level);
•
Contract measures – implemented with the aim to ensure a binding commitment of third parties to
adhere to standards set out in the Supplier Code of Conduct; application depends on the specificity
of particular contractual relationship;
•
Privacy/ InfoSec questionnaires – implemented with the aim to mitigate risks related to the
processing of personal data in vendors’ systems; used for several years already.
The relevant actions, metrics and targets are also described under relevant minimum disclosure
requirements (chapters 4.3.2, 4.3.3, 4.3.4).
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4.5.4. [G1-3] Prevention and detection of corruption and bribery
4.5.4.1. Information about procedures in place to prevent, detect, and address allegations
or incidents of corruption or bribery
Issues related to corruption and bribery are addressed in LINK’s ESG policy, which includes a separate
chapter on anti-corruption and anti-bribery rules. Main actions in place include employees’ training
program as well as relevant codes of conduct (Employee Code of Conduct and Supplier Code of
Conduct). The description of the policy, as well as information on corresponding actions, are provided
under minimum disclosure requirements (chapters 4.4.1, 4.4.2). The whistleblowing channel may be
used for reporting any incidents, as described in chapter 4.2.
a. Investigators or investigating committee are separate from chain of
management involved in prevention and detection of corruption or bribery
Prevention and detection of corruption and bribery lies under the responsibility of LINK managers in
their respective functional areas. A whistleblowing channel is provided to enable anonymous reporting
of any non-compliance. The incidents detected through the whistleblowing channel are managed by
the Integrity Audit Committee that is composed of persons not involved in the daily operations of
commercial areas in which corruption and bribery incidents may arise.
b. Information about process to report outcomes to administrative, management
and supervisory bodies
If corruption or bribery is reported through the Whistleblowing channel, reporting to administrative,
management and supervisory bodies will be managed depending on each case. There is no automatic
procedure for reporting to specific management bodies. However, if the case at hand does not include
elements that might prevent such information, the Integrity Audit Committee will inform CEO about
incidents of corruption or bribery as part of the investigation process, and the Board of Directors will
be informed on any incidents of corruption or bribery by the CEO.
If the corruption or bribery is discovered through other means than the whistleblowing channel, the
LINK Employee Code of Conduct encourages all employees to report to their direct manager, HR or
Managing Director. A manager who receives such report will inform the CEO or GLT members, as
applicable.
4.5.4.2. Information about how policies are communicated to those for whom they are
relevant (prevention and detection of corruption or bribery)
LINK’s ESG policy, that incorporates inter alia the anti-corruption and anti-bribery policy, is adopted by
the Board of Directors and communicated to all LINK’s workforce through internal electronic systems.
The compliance training relevant to the policy is provided, and must be completed annually by all
employees. The policy is described in chapter 4.4.1.
4.5.4.3. Information about nature, scope and depth of anti-corruption or anti-bribery
training programmes offered or required
The general compliance training that covers notions of LINK’s ESG policy, including a part on anti-
corruption and anti-bribery, is provided to all employees and is revised annually. The action is described
in chapter 4.4.2.
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a. Percentage of functions-at-risk covered by training programmes
All LINK employees (100%) must complete the general compliance training and revise it annually.
b. Information about members of administrative, supervisory and management
bodies relating to anti-corruption or anti-bribery training
All GLT members, including CEO, must complete the general compliance training and revise it annually.
4.5.4.4. Analysis of LINK’s training activities related to anti-corruption and anti-bribery
The general compliance training, covering part on anti-corruption and anti-bribery, is provided via a
dedicated electronic system to all LINK employees. Participants are able to rate the training and give
feedback. The content of the training is revised annually and it is annually repeated by all employees.
The Company monitors the completion rate for the training by country and in total through an electronic
system, in which the training is provided. In case the training is not completed by a particular employee,
they get adequate reminders electronically, and later their supervisors are informed. The action and
relevant metrics and targets are described in chapter 4.4.2, 4.4.3, and 4.4.4.
4.5.5. [G1-4] Incidents of corruption or bribery
4.5.5.1. Action plans and resources to manage material impacts, risks, and opportunities
related to corruption and bribery [see ESRS 2 - MDR-A]
LINK has implemented the ESG Policy with a dedicated chapter on anti-corruption and anti-bribery. The
actions taken to manage material IROs related to corruption and bribery are described in chapter 4.4.2.
4.5.5.2. Numerical indicators related to incidents related of corruption and bribery
In 2023 LINK did not detect any cases related to corruption or bribery.
•
Number of convictions for violation of anti-corruption and anti- bribery laws: 0
•
Amount of fines for violation of anti-corruption and anti- bribery laws: 0
•
Number of confirmed incidents of corruption or bribery: 0
•
Information about nature of confirmed incidents of corruption or bribery: no incidents
•
Number of confirmed incidents in which own workers were dismissed or disciplined for corruption
or bribery-related incidents: 0
•
Number of confirmed incidents relating to contracts with business partners that were terminated
or not renewed due to violations related to corruption or bribery: 0
•
Information about details of public legal cases regarding corruption or bribery brought against
undertaking and own workers and about outcomes of such cases: no such public legal cases
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Report from the
Board of Directors
LINK Mobility Group Holding ASA (LINK) is headquartered in Oslo and listed on the Oslo Stock Exchange
(OSE). The group has 686 employees across Europe with 29 offices located in 17 countries.
LINK has more than 20 years of experience in providing mobile messaging services and mobile solutions
for businesses, public sectors and organizations. LINK has for decades operated in the Nordics, the
world’s most innovative market for digital mobile solutions, and has over the recent years leveraged
its knowledge and capabilities to become the clear market leader within enterprise mobile messaging
solutions in Europe. Given its experience and reach, LINK is uniquely positioned to benefit from the
increased usage of mobile messaging solutions globally.
Market position and development
Market growth and the trend towards more advanced digital messaging solutions continued in 2023.
The new channels complementing SMS with richer content and conversational features, RCS (SMS 2.0)
and OTT (internet streaming) in CPaaS solutions are a requirement to win new customer contracts.
More advanced CPaaS solutions have slower adoption rates and longer revenue lead times as clients
need to adapt their value chains. Market growth is however expected to accelerate as digital messaging
solutions increasingly become the preferred end user communication for businesses, public sectors
and organizations.
In 2023, LINK sent 17.2 billion messages on behalf of its fifty thousand customers. The market for
mobile messaging solutions is expected to continue to expand with the vast opportunities presented
by new CPaaS solutions.
LINK had a low customer churn of below 2% in 2023, securing recurring and potential for growing
revenue from existing clients. Most customers increase their use of LINK’s digital messaging and
include more advanced solutions over time as they realize high Returns on Investment (ROI). ROI
is driven by higher revenue from more satisfied customers and lower costs through more efficient
internal processes.
LINK drives organic growth with increased usage from existing customers and through new customer
wins. In addition, market share is increased, and new markets entered through acquisitions.
Organic growth is supported by LINK’s Go-to-Market (GTM) strategy. Larger enterprise customers
are approached directly by dedicated salespeople, Small and Medium-sized Enterprises (SMEs) are
acquired through Self-Sign Up (SSU) portals and the partner model further expands the reach. LINK’s
tailored and innovative enterprise solutions are later standardized to SaaS solutions and offered to
SMEs. The partner network scales the business as LINK solutions are offered partner customers and
partner applications are made available to LINK customers.
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LINK’s extensive use case library, from a large innovative customer base in advanced markets for
digital messaging, give the group a clear competitive advantage.
Comments related to the financial statements
In accordance with the Norwegian Accounting Act §3-3a the board confirms that the company fulfils
the requirements necessary to operate as a going concern and the 2023 financial statements have
been prepared based on that assumption. As a listed company, LINK Mobility Group Holding ASA
prepared the consolidated financial statements for the financial year 2023 in accordance with the
International Financial Reporting Standards (IFRS) as adopted by the European Union.
Discontinued operations
LINK entered an SPA for the disposal of Message Broadcast LLC on 07 November 2023 and completed
the divestment on 3 January 2024.
Figures presented in the financial statements and the accompanying notes include amounts as either
held of sale or as discontinued operations depending on whether the figures relate to the statement of
financial position or to the income statement, respectively.
Discontinued operations are excluded from the figures commented on below.
Revenue, costs, and profits
LINK reported revenue of NOK 6 282 million in 2023, an increase of 28% from NOK 4 913 million in
2022. LINK’s gross profit was NOK 1 348 million (NOK 1 138 million).
Operating costs (including payroll and related services and other operating expenses) were NOK 870
million (NOK 800 million) and include non-recurring costs of NOK 135 million. The non-recurring costs
include a share-based compensation program of NOK 98 million, restructuring costs of NOK 29 million,
and expenses related to acquisitions of NOK 8 million. Depreciation and amortization were NOK 338
million (NOK 297 million). There was an impairment of intangible assets and goodwill of NOK 180
million related to the Spanish footprint in the prior year.
Net financial items amounted to negative NOK 89 million (negative NOK 36 million) and constituted a
net interest expense of NOK 140 million linked to an outstanding bond, net other financial expenses
of NOK 6 million and a positive currency effect of NOK 44 million. LINK’s outstanding EUR 370 million
bond carries a fixed coupon of 3.375% and matures in December 2025.
Income tax expense is NOK 13 million (NOK 19 million), resulting in a net profit from continuing
operations of NOK 38 million (negative NOK 193 million) in 2023.
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Annual result and allocation
The board proposes that the 2023 net profit will be transferred to accumulated losses.
Financial position, cash flow, and liquidity
As of 31 December 2023, LINK’s total assets amounted to NOK 11 680 million (NOK 10 994 million),
of which intangible assets were NOK 6 162 million (NOK 8 718 million). Intangible assets are mainly
comprised of goodwill equal to NOK 4 389 million (NOK 5 788 million). Trade receivables and other
receivables amounted to NOK 1 380 million (NOK 1 244 million) and cash and cash equivalents to
NOK 1 097 million (NOK 827 million). Total equity was NOK 5 514 (NOK 5 226 million) and constituted
of NOK 1.5 million in share capital, a share premium of NOK 5 938 million, and negative NOK 425
million in accumulated losses and translation differences.
Long-term liabilities were NOK 4 321 million (NOK 4 416 million) and consisted mainly of a EUR 370
million bond. LINK’s cash flow from operating activities during 2023 was NOK 532 million (NOK 307
million). Cash flow from investing activities was negative NOK 116 million (negative NOK 131 million).
Cash flows from financing activities amounted to a negative NOK 281 million (negative NOK 230
million), mainly reflecting interest payments of NOK 150 million and repayment of borrowings (bond
re-purchase) of NOK 117 million.
Comments in relation to the Sustainability statement
LINK’s Sustainability statement is available as a separate section in this annual report, and is for the
first time based in principle on the European Sustainability reporting Standards (ESRS), as provided by
the European Financial Reporting Advisory Group (EFRAG), see https://www.efrag.org/ , and adopted
by the Commission Delegated Regulation as regards sustainability reporting standards.
The Sustainability statement for 2023 constitutes LINK’s first step to reaching compliance with the
sustainability reporting requirements included in the Corporate Sustainability Reporting Directive
(CSRD), effective for LINK from the financial year 2024. Furthermore, using ESRS as basis is in alignment
with the Norwegian Accounting Act §3-3c section 6, opening for reporting social responsibility by use
of an international standard.
Sustainability in LINK
LINK’s board of directors has adopted a policy to reflect the company’s commitment to integrate ESG
factors into its daily operations and as a part of its strategic processes. The ESG policy is available
at [Legal section in LINK’s homepage]. The board has considered these topics in relation to LINK’s
business operations and reviewed factors based on the UN Sustainable Development Goals (SDGs),
the Ten Principles of the UN Global Compact, and the OECD Guidelines for Multinational Enterprises.
In 2021, LINK confirmed it committed to integrating the Ten Principles of the UN Global Compact in its
operations by becoming a signatory. The participation in the UN Global Compact continued in 2022
and 2023, which reflects constant efforts to incorporate sustainability factors into our operations. In
line with the UN Global Compact, LINK is committed to continuous progress in the four focus areas:
Anti-Corruption, Human Rights, Environment and Labor.
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LINK’s reports under UN Global Compact can be found here: https://www.unglobalcompact.org/what-
is-gc/participants/145208-LINK-Mobility-Group-Holding-ASA .
Materiality assessment
Since the global understanding of ESG as an important factor affecting business across markets
and industries gains ground, it is crucial for LINK, as any other business, to understand and manage
impacts, risks and opportunities related to these topics, not only when making strategic decisions but
also in its daily operations.
In a context that is constantly evolving, LINK recognizes that the areas affected by ESG factors may vary
over time and it therefore performs an annual materiality assessment. The first materiality assessment
was performed in 2020. For 2023, the materiality assessment was performed in accordance with the
ESRS requirements. The detailed methodology and results are visible in the Sustainability Statement.
Diversity
The rules regarding composition, included in the Code of Conduct for the Nomination Committee of
LINK Mobility Group Holding ASA and the Norwegian Public Limited Liability Companies Act (PLLCA)
§ 6-11 a, are applied by the Nomination Committee, thus ensuring that the board has a composition
appropriate to the company’s operations, phase of development, gender balance, independence and
other elements of relevance to board composition.
The ESG policy’s statements regarding diversity, inclusion and belonging form the policy for
recruitment. The considerations for diversity with regard to gender, disabilities and ethnicity are basis
for recruitment on all levels, including group management.
Further disclosures regarding diversity are available in the Sustainability Statement.
Greenhouse Gas (GHG) emissions
To get a better picture of energy consumption and greenhouse gas emissions related to LINK’s activities,
detailed information from European entities are collected each year. LINK will continue to expand our
data collection methodology with improvements to the data quality and availability. Collection of Scope
3 emissions has started this year, in accordance with the ambition stated in previous years’ report. It is
not a complete account of scope 3 emissions, but we have included activities we believe to be the most
significant sources of indirect scope 3 emissions. The calculations have been made according to the
Greenhouse Gas Protocol (GHGP).
The table below summarizes the GHG-account for Link Mobility in 2023. For 2023, we report on direct
emissions (SCOPE 1) and indirect emissions from SCOPE 2 and SCOPE 3. It is the indirect emissions
linked to the energy use (electricity and district heating) and the purchase of goods and services that
characterize the emissions. When we use location-based calculation method for emissions related
to the energy use (SCOPE 2), approximately 66 % of Link’s total footprint comes from other indirect
emissions (SCOPE 3). Approximately 65 % of estimated SCOPE 3 emissions comes from air travel and
commuting.
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A more detailed breakdown of the GHG-account and a comparison of 2022 and 2023 is described in
the GHG-report for 2023, available at LINK’s webpage.
Scope
Emissions in tCO2
2022*
Emissions in tCO2
2023
Share of emissions
(2023)
Scope 1 46.1 50.4 6 %
Scope 2 - location based 271.6 224.7 28 %
Scope 2 – market based 335.3 293.3
Sum Scope 1 + 2 location based 317.7 275.0
Sum scope 1 + 2 market based 381.4 343.7
Scope 3 n/a 538.8 66 %
Total (Scope 1 to 3) location based n/a 813.8 100 %
Total (scope 1 to 3) market based n/a 882.5
Table GHG- emissions LINK MOBILITY Group 2023 and 2022. *Scope 1 emissions is adjusted up
from 40,9 to 46,1 tCO2 due to incorrectly reported natural gas consumption in 2022.
LINK MOBILITY GHG-emissions (tCO2e)
Management of Risks
Awareness of the exposure to risks that may potentially impact LINK is necessary to identify such risks
and implement necessary and adequate management. The objective for LINK’s Risk Management
Framework is to make it possible to align risk management for LINK Mobility as a group of companies,
by identifying and managing risk under defined risk areas and allowing separate processes in each
team, while ensuring overview through a single framework, facilitating each team’s risk management
work, maintaining oversight of Risks facing LINK as a group. The Risk Management Framework assists
LINK as a group in its process to meet its objectives, monitoring, reporting and providing advice on
risk exposure to top management in LINK Mobility and continuously reviewing and improving risk
identification, management and treatment.
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LINK’s Risk Management Framework is not limited to specific risks but recognizes both risks to
enterprise (inward-facing approach, also referred to as Financial Materiality) and risks of adverse
impacts on people, the environment and society (outward- facing approach, also referred to as Impact
Materiality). The Risk Management Framework thus reflects the concept of Double Materiality.
LINK Mobility’s Risk Management Framework is set out in alignment with the Due Diligence Process
defined in the OECD Due Diligence Guidance for Responsible Business Conduct.
1
5
2
4 3
EMBED
RESPONSIBLE
BUSINESS CONDUCT
INTO POLICIES &
MANAGEMENT
SYSTEMS
COMMUNICATE
HOW IMPACTS ARE
ADDRESSED
TRACK
IMPLEMENTATION
AND RESULT
IDENTIFY & ASSESS
ADVERSE IPACTS
IN OPERATIONS, SUPPLY CHAINS
& BUSINESS RELATIONSHIPS
CASE, PREVENT OR ITIGATE
ADVERTISE IMPACTS
PROVIDE FOR OR
COOPERATE
IN REMEDIATION
WHEM APPROPRIATE
6
Source: OECD Due Diligence Guidance for Responsible Business Conduct,
ref. https://mneguidelines.oecd.org/due-diligence-guidance-for-responsible-business-conduct.htm
The Risk Management framework defines ten risk areas under which risks are identified. Management
of risks is vital to ensure that potential threats to LINK’s objectives are identified and managed.
-Successful implementation of LINK’s business strategy and effective management of growth rely on
management of potential risks affecting LINK’s objectives.
The section below describes how the Global Leadership Team (GLT) evaluates and mitigates risks for
each of the ten risk areas.
Market risk
LINK risks related to its customers and competition, hereunder loss of contracts and opportunities, are
managed under the headline of market risk. Risks under the area are mainly inward-facing (Financial
Materiality).
LINK’s revenue, costs and profits are subject to the risk of changes in customer and supplier prices.
Certain simple use cases like One-Time Passwords (OTP) or Two-Factor Authentications (2FA),
wholesale SMS trading and basic mobile payment services are exposed to margin pressure, and
therefore particularly vulnerable to such risk. LINK is however only exposed to simple use cases to a
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limited degree as the group’s strategy is long term customer relationships through enterprise CPaaS
solutions. This strategy has resulted in a very low customer churn and growing recurring revenue. LINK
did not experience any material margin pressure for enterprise solutions in 2023 and expect increased
adoption of more advanced CPaaS solutions to be supportive to margins in coming years.
The A2P SMS market grows in the high single digits annually as adoption increases throughout
markets and industries. LINK is operating in a market with one-way mass communication through A2P
SMS transitioning to conversational communication on multi-channel CPaaS solutions. The evolution
of SMS to RCS and the addition of new OTT channels like WhatsApp and Viber enables brands to
communicate with their customers on their preferred format. These new channel technologies offer
vast value creation opportunities and the market growth for CPaaS is thus expected to be higher
when adoption of advanced solutions reach critical mass. Currently, the CPaaS market remains small
compared to the more penetrated A2P SMS market.
The timeline to reach critical mass is uncertain and a risk for growth in the CPaaS industry. LINK
however believes its channel-agnostic approach limits this risk as the company is versatile to adopt to
channels and solutions as they mature and gain traction in the market.
Financial risk
LINK’s business activities expose the group to financial risks related to prices, currencies, interest
rates, credit and liquidity. Overall, these risks are regarded as low and manageable.
As a leading provider, LINK have the leverage to obtain competitive SMS pricing from Mobile Network
Operators (MNOs) and provide high quality deliverability for its customers as a trusted MNO partner.
Over time the growth in new OTT channels competing with MNOs could be beneficial for channel
agnostic CPaaS companies in terms of leverage on pricing from channel owners.
The group undertakes business in foreign currencies and is consequently exposed to fluctuations
in exchange rates. Foreign exchange risk arises from transactions related to operations conducted,
and assets and liabilities arising in foreign currencies. LINK’s subsidiaries operate using their local
currencies with revenue and costs for transactions usually carried out in the same currency. This
natural hedge reduces the currency risk and protects margins. There is, however, a translation effect
to LINK’s reporting currency NOK as changes in NOK to underlying currencies will impact reported
figures.
Macroeconomic uncertainty and sentiment of the credit market may affect LINK’s ability to refinance
its 5-year EUR 370 million outstanding bond maturing in December 2025. The bond is listed on the Oslo
Stock Exchange and carries a fixed coupon of 3.375% per year, exposing LINK to interest rate risk upon
refinancing. The EUR bond also exposes LINK to additional exchange rate risk. This currency risk is
however mitigated by LINK’s significant cash flow exposure to EUR. Following the divestment of the US
entity Message Broadcast on 3 January 2024, LINK increased its cash balance to NOK 3.4 billion which
significantly reduced the refinancing risk. Through its operations, LINK expects to continue to generate
free cash flows which will further improve its financing capacity. The remaining EUR bond maturing is
to be refinanced with net debt in the 2 - 2.5x adjusted EBITDA range, well below the current incurrence
test at 3.5x adjusted EBITDA.
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LINK’s credit risk is limited to trade and other receivables and mitigated by the group’s guidelines to
ensure that credit sales are limited only to customers with a positive credit history. Customers with a
poor payment history are required to prepay for services rendered by the group.
LINK considers its liquidity risk to be limited and has more than sufficient liquidity available on bank
accounts to fund its operations and strategy for growth. LINK has established efficient routines to
monitor and handle overdue trade receivables across its footprint and only saw marginal losses in
2023.
LINK manages financial risk with an emphasis to minimize its exposure and holds no financial assets
or liabilities for speculative purposes.
Acquisition risk
Acquisition risk refers to the risks related to not achieving the planned value creation from performed
acquisitions. Risk of insufficient value creation may come from elements in the acquisition process
itself, meaning the time leading up to closing date. Risk may also come from elements in the integration
of the acquired company, meaning the time after closing. Risks under the area are mainly inward-facing
(Financial Materiality).
Management of risks involve successful purchase of suitable companies at sound multiples and
well-managed integrations to realize synergies and scale advantages. Failure to realize synergies or
winner’s curse through overpayment for acquired companies may lead to significant value destruction.
The results of the prior year’s acquisitions confirm that LINK has such expertise.
The board has established routines and procedures regarding possible takeovers. This procedure does
not include any content regarding countermeasures like poison pills or other defence measures to
hinder a possible takeover of the group.
IT risk
IT risk includes risks of higher cost, lower profitability or loss due to issues related to LINK’s architecture,
data management, software development, internal infrastructure and IT Services, and business IT and
processes. Risks under the area are mainly inward-facing (Financial Materiality).
IT risk is managed by central IT functions under the authority of LINK’s Chief Technology Officer.
LINK’s central IT function cooperates closely with local IT teams and defines policies and procedures
for subsidiaries to implement locally.
LINK is taking steps to enhance and increase focus on the efforts to minimize the potential loss caused
by inadequate or failed internal processes, or from external or internal incidents. Processes to manage
the causes or mitigating the impacts of risks in these areas are therefore continuously implemented.
In 2023, the following actions should be noticed:
1. Increased redundancy in our data centers
2. Improved processes and IT-team structures to reduce dependencies between IT-capacities
3. Improved operational processes and extended our internal IT-audits on major IT-platforms
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Information security risk
Information security risk includes inward-facing risks related to potential loss, cost, and loss of income
due to the threats and vulnerabilities associated with the operation and use of information systems
and the internal and external environments in which those systems operate, hereunder cyber incidents.
Non-compliance with regulatory requirements and contractual requirements regarding Information
security will also be relevant for inward-facing risks. The introduction of new regulatory frameworks
effective in 2024 affects the risk area, hereunder the EU NIS2 Directive has particular relevance.
Furthermore, the risk area includes outward-facing risks related to negative effects on individuals
and society following from LINK’s operation and use of information systems or non-compliance with
regulatory requirements regarding Information security.
Information security risk is managed under LINK’s Compliance Function In 2023, the Information
Security organization in LINK was redefined and moved to a function under the authority of the CEO
(??). LINK’s Information Security Policy, available on the LINK Mobility page was redrafted in 2023, in
order to align with the EU NIS2 directive and the IEC/ISO 27001:2022.
LINK’s processes are based on a top-down approach, where LINK defines policies and procedures
for subsidiaries to implement locally. The central Information Security function provides support and
counseling to local entities depending on requirements in the covered areas.To ensure compliance
with the LINK Mobility Information Security Policy subsidiaries are subject to yearly internal audits to
identify and manage any non-compliances, or potentials for improvement. Results of those audits are
presented to the relevant stakeholders and are considered while identifying and assessing risks for
information security in LINK Mobility.
Legal risk
Legal risk includes inward-facing risk of financial loss, reputational damage or loss of right to operate,
incurred by unintentional or negligent failure to meet obligations in laws, regulations and commitments
that apply to LINK. Regulatory changes on several areas in recent years add to such risk. Furthermore,
the risk area may include outward-facing risks related to negative effects on individuals and society
following from LINK’s failure to meet obligations.
Legal risk at LINK is managed by a group function under the authority of the CEO. LINK’s processes
are based on a top-down approach, where policies, templates and procedures are defined to the extent
possible, taking local jurisdictions into account. The group function provides support and counselling
to group management and local entities depending on requirements.
HR risk
The area includes the inward-facing risk of financial loss, inability to operate and lower profitability
incurred by lack of sufficient personnel on all levels, key competencies and industry knowledge.
LINK’s success depends on the development of a skilled organization with regards to leadership
and key area competencies required in the industry. Ensuring recruitment and retention, and a safe
and attractive workplace is therefore a key priority throughout LINK from headquarters to every local
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subsidiary. Risks related to employee well-being and ability to ensure recruitment and retention are
consequently managed across LINK.
Recruitment, training, succession planning and people management, as well as dedication to equality
and diversity, are areas that are continuously developed to ensure growth and robustness in the
organization.
ESG risk / Sustainability risk
Risks related to environmental, social, and corporate governance factors (ESG) cover risks in the market
where LINK operates (inward-facing approach / Financial Materiality), and risks related to LINKs impact
on environment and society through its operations (outward-facing approach / Impact Materiality).
ESG risks include any identified threat to LINK’s ability to reach its objectives in the ESG area. The main
objectives within the ESG area are defined annually through Materiality Assessment as described in the
Sustainability Statement. Further information about LINK’s management of ESG matters is included in
the Sustainability Statement.
Macroeconomic uncertainty (Financial Materiality)
Increased global tensions and financial uncertainty could be negative for world economic growth
and indirectly affect LINK’s global operations. LINK is however well-diversified with fifty thousand
customers of all sizes in numerous industries and geographies. As these various industries and
markets are likely to be impacted differently from global shifts, the effect for LINK should be mitigated.
Privacy risk
LINK processes different scopes of personal data as part of its business, and therefore manages risks
in relation to the processing of the personal data in question. LINK manages risks in privacy and data
protection areas that may pose a direct or indirect loss for LINK itself (inward-facing) or risks that may
cause emotional distress, physical, financial, professional or other harm to individuals (outward-facing)
Data protection and privacy risks in LINK are documented by a Data Protection Officer, managed
by LINK group departments and local units, under the authority of the LINK Group CEO. LINK’s
processes are based on a top-down approach, where policies, templates and procedures are defined,
and implemented group-wide. The group function performs annual audits and provides support and
counselling to group management and local entities depending on requirements.
Operational risk
Operational risks include risks related to human rights, health and safety, security, leadership and
organization. The area thus covers organization, buildings, assets, internal structures, and external
events.
The safety of all employees is a key priority throughout LINK from headquarters to every local subsidiary.
The development of a skilled organization with regards to leadership and key area competence is
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crucial for LINK’s competitiveness, and therefore a top priority. Recruitment, training, and people
management, as well as dedication to equality and diversity, are areas that are continuously developed
to ensure growth and robustness in the organization.
LINK is taking steps to enhance and increase focus on its efforts to minimize potential losses from
inadequate or failed internal processes or from external events. Processes to manage the causes or
mitigate the impacts of risks in these areas are continuously implemented.
Shareholders and shares
LINK issued new shares in 2023 in connection with the Employee Share Purchase Program (ESPP) and
the Restricted Stock Units (RSUs) program. Throughout the year, the number of shares in the company
increased from 295,890,306 shares to 297,059,271 shares.
On 8th November 2023, 909,110 new RSU shares were issued, which completed the program.
New ESPP shares, totaling 259,855 shares through 2023, were issued on 11th July and on 12th
December. At the Annual General Meeting (AGM) on May 31st, the board was given the authorization
to issue shares amounting to up to 20% of the share capital of the company to strengthen the equity
position in relation to acquisitions. The board was also granted the option to acquire treasury shares of
up to 10% of the share capital and in addition provided the right to issue shares amounting to up to 10%
of the share capital in relation to the Employee Share Purchase Program (ESPP). The authorizations are
valid until the annual general meeting in 2024.
A LINK share represents one vote at the company’s general meeting. LINK does not have multiple share
classes. The shares are freely tradable and to the knowledge of the board, there are no shareholders’
agreements in the company regarding the exercise of voting power or limiting trading in the shares in
general. However, in connection with company acquisitions, major shareholders and shares issued
to majority sellers can be subject to customary 12 – 18 months lockups from the time of completion.
LINK at year-end 2023 had close to 4,000 shareholders, of which the largest 10 shareholders combined
controlled almost 2/3 of the company. Abry Partners, represented by Citibank as nominee, was the
largest single controlling shareholder with a 28.8% stake through subsidiary holdings.
The LINK Mobility Group Holding ASA share closed at NOK 18.16 on the Oslo Stock Exchange at year-
end 2023, appreciating 141% with better operational performance, an improved financial position and
a general repricing of technology stocks.
Organization, workforce, and management
LINK’s workforce, coupled with its technology, is the most important asset both in terms of serving
LINK’s customers of today and for the future development of the company. LINK continues to strengthen
and focus on strategic functions with reorganizing internal competencies and with emphasis on the
sales departments through streamlined sales skills development and measurements.
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Regional segments have also been restructured to maximize synergies. By the end of 2023, LINK had
686 permanent employees. 34% of the total LINK workforce was women, compared to 34% in 2022.
The GLT consists of 8 people, 2 women and 6 men. The working environment is regarded as positive.
None of LINK’s subsidiaries or the parent company recorded work-related accidents that resulted in
personal injury or property damage.
Board statement on corporate governance
This statement forms part of the board of directors’ report and describes the foundation and principles
for LINK’s corporate governance structure. Further information can be found at LINK ’s website (https://
www.linkmobility.com/investors/sustainablilty) and in the Sustainability statement” in this report.
LINK believes in transparent corporate governance processes, and that good corporate governance
will strengthen confidence, and help to ensure sustainable value creation in the best interests of
shareholders, employees, and other stakeholders.
1. Applicable legislation and principles
LINK is subject to corporate governance reporting requirements according to the Norwegian Accounting
Act, section 3-3b, Issuer Rules by the Oslo Stock Exchange (Oslo Rulebook II – Issuer Rules, Chapter
4.4), and the Norwegian Code of Practice for Corporate Governance (“Code”). The regulations are
openly available on www.lovdata.no, www.oslobors.no, and www.nues.no, respectively.
The structure of this statement shall follow the structure of the Code and will specify under each
section either how the board of LINK adheres to the Code or provide explanations in areas where it
does not fully comply.
LINK has adopted and implemented a corporate governance policy to safeguard the interests of
the company’s shareholders, employees, customers, and other stakeholders. These policies and
associated rules and practices are intended to create increased predictability and transparency and
thus reduce uncertainty related to the business. LINK’s Corporate Governance Policy as adopted by
the board on September 7th, 2020, with latest revisions made on December 7th 2022, and the Code of
Conduct for the Nomination Committee is presented in the annual report.
2. Business
As described in its Articles of Association, LINK itself or through its group of subsidiaries, develop
and operate software for mobile telephone services to private and public businesses. Please refer to
“Market position and development” in the board of directors’ report above for more on LINK’s business.
LINK’s Articles of Association are published in full on the company’s website (linkmobility.com).
The board of directors defines objectives, strategies, and risk profiles for LINK’s business through
deep dives into the strategy and business throughout the year, to ensure that the company creates
value for shareholders in a sustainable manner. The board takes financial, social, and environmental
considerations into account when performing such deep dives.
The board of directors evaluates objectives, strategies, and risk profiles annually.
LINK fully complies with the Code.
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3. Equity and dividends
LINK has a capital structure appropriate to the company’s objective, strategy, and risk profile.
Dividend Policy is published on LINK’s homepage under corporate governance, key documents.
LINK fully complies with the Code.
4. Equal treatment of shareholders
All LINK shareholders are treated equally. If the board of directors was to carry out an increase in
share capital and waive the pre-emption rights of existing shareholders, the reasoning would be fully
transparent and publicly disclosed in a stock exchange announcement. Any transactions the company
carries out in its own shares will be carried out either through the stock exchange or at prevailing stock
exchange prices. In the case of limited liquidity in the company’s shares, LINK will consider other ways
to ensure equal treatment of all shareholders.
LINK fully complies with the Code.
5. Shares and negotiability
LINK does not limit any party’s ability to own, trade, or vote for shares in the company. In the unlikely
event that this was not to be the case, LINK will provide an account of any restrictions on owning,
trading or voting for shares in the company.
LINK fully complies with the Code.
6. General meetings
In accordance with LINK’s Articles of Association, all shareholders with shares acquired before the
fifth business day ahead of the general meeting have a right to attend. The annual general meeting
shall resolve the annual accounts and other matters that the general meeting is required by law or
the articles of association to resolve. All shareholders are invited to the general meeting within the
deadlines that follow from law and regulations, and all documentation required for the shareholders
to sufficiently prepare for the general meeting is shared in the invitation and/or by reference to the
documents publicly available at LINK’s website. Deadlines for shareholders to give notice of their
intention to attend the meeting are set as close to the date of the meeting as possible.
Members of the board of directors attend the general meeting to the extent it is practically possible
and in accordance with the goal of minimizing travel. The chairman of the board of directors, or a board
member who represents the chairman, shall in all cases attend the general meeting. The chairman of
the nomination committee shall attend the general meeting in person or by representative.
The general meeting elects a chairman for the general meeting and shall be able to elect an
independent chairman. Shareholders can vote on each individual matter, including on each individual
candidate nominated for election. Shareholders who cannot attend the meeting in person are given
the opportunity to vote beforehand or give proxy to do so, through a form provided with the invitation,
where each individual matter can be voted over separately.
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LINK has not adopted any special procedures regarding the general meeting that deviates from
provisions applicable for Norwegian public limited liability companies that are listed on the Oslo
Stock Exchange. LINK fully complies with the Code except for the board of directors and nomination
committee attendance. As LINK has a goal of reducing all its travel to the largest extent possible, board
members shall attend the general meeting only to the extent necessary.
7. Nomination committee
LINK’s Articles of Association provides that LINK shall have a nomination committee comprising of two
to three members elected for two years by the general meeting of LINK, which shall be independent
of the board and executive management to ensure that all shareholders’ interests are considered. The
current members of the nomination committee are Tor Malmo (Chairman) and Oddny Svergja. The
members are not part of LINK’s board or personnel.
The general meeting sets guidelines for the duties of the nomination committee, as well as its
remuneration. A code of conduct for the nomination committee was defined by an EGM in LINK on
September 7th, 2020, and revised by the AGM on May 31st, 2022. The nomination committee’s duties
are to propose candidates for election to the board, to make assessments of proposed candidates, and
to propose remuneration to be paid to such members. The justification for the committee’s proposal
is provided separately.
The nomination committee is in contact with shareholders, the board of directors and the company’s
executive personnel as part of its work on proposing candidates for election to the board.
LINK fully complies with the Code.
8. Board of directors’ composition and independence
The composition of the board of directors shall ensure that the board can attend to the common
interests of all shareholders and meet the company’s need for expertise, capacity, and diversity.
LINK’s Articles of Association stipulate that the company shall have a board consisting of 5 to
9 members elected by the general meeting. The Articles of Association further determine that the
chairman of the board shall be elected for two years by the general meeting.
The composition of the board of directors shall ensure that it can operate independently of any special
interests. The majority of the shareholder-elected members of the board of directors shall thus be
independent of the company’s executive personnel and material business connections. In addition, at
least two of the members of the board must be independent of the company’s major shareholders. For
the purposes of the LINK Corporate Governance Policy, a major shareholder shall mean a shareholder
that controls 10% or more of the company’s shares or votes. Members of the board are, however,
encouraged to own shares in the company.
The board of directors does not include executive personnel.
There were 6 members on the board after the annual general meeting 2023, 3 women and 3 men.
The chairman was elected for two years in 2022, and each board member was elected for one year in
general meeting 2023.
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Overview of the Board of Directors
The names and positions of the Board members are set out in the table below
Name Position Served since Term expires Independent
André Christensen Chairman 2022 2024 Yes
Jens Rugseth Board member 2005 2024 -
Robert Joseph Nicewicz Jr Board member 2018 2024 -
Sabrina Gosman Board member 2022 2024 -
Grethe Viksaas Board member 2020 2024 Yes
Sara Murby Forste Board member 2020 2024 Yes
9. The work of the board of directors
The board of directors has issued instructions for its own work and the CEO’s work, the current version
is dated December 7th, 2022. The board and CEO instructions have a particular emphasis on clear
internal allocation of responsibilities and duties.
The instructions state how the board of directors and executive management handle agreements
with related parties, including whether an independent valuation must be obtained, and that any such
agreement will be presented in the annual report.
The board of directors considers any material interests held by board members or executive personnel.
If the chairman should be personally involved in a matter, another board member would chair the
consideration of such matter. No such matters have been managed in 2023.
The board of directors evaluates its performance and expertise annually.
The board held twenty-five (25) meetings in 2023 and arranged one general meeting. The average
board meeting attendance by members was 93%.
LINK fully complies with the Code.
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No Name Position
Audit
committee
Remuneration
committee
M&A
committee
1 André Christensen Chairman
2 Jens Rugseth Board member
3 Robert Joseph Nicewicz Jr Board member
4 Sabrina Gosman Board member
5 Grethe Viksaas Board member
6 Sara Murby Forste Board member
Audit committee
In accordance with the Public Companies Act, LINK has established an audit committee consisting
of board members who are independent of management, and who are appointed for a two-year term.
The audit committee’s obligations are defined in instructions defined by the board. The current version
of the audit committee’s instructions is from December 7th, 2022. The committee is a preparatory
and advisory body for the Board and support the Board in the exercise of its responsibility for financial
reporting, internal control and risk management. Furthermore, the committee is a preparatory body for
the Board in relation to LINK’s election of statutory auditor and make recommendations to the Board
in accordance with requirements in law, regarding the appointment or removal of statutory auditor and
the statutory auditor’s remuneration and other terms of engagement.
Remuneration committee
LINK has a remuneration committee that consists of board members who are independent of
management, and who are appointed for a two-year term. The remuneration committee’s obligations
are defined in instructions defined by the board. The current version of the remuneration committee’s
instructions is from December 7th, 2022. The remuneration committee prepares remuneration
guidelines for executive personnel including the main principles for the company’s remuneration policy.
The guidelines are communicated to the AGM. The remuneration committee may liaise with external
compensation consultants. The remuneration of senior executives is currently threefold. An individual
fixed salary, variable salary elements based on a group-wide set of KPIs, and incentives linked to share
price performance.
The Board of directors has set out three sub-committees, as described below. The table shows the
board members’ memberships in the committees per December 31st, 2023.
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M&A committee
LINK has an M&A committee that consists of board members and members of the company’s
management. The M&A Committee’s obligations are defined in instructions defined by the board.
The current version of the remuneration committee’s instructions is from February 16th 2021. The
committee acts as a preparatory and advisory body to support the board in the process of mergers
and acquisitions.
LINK fully complies with the Code.
10. Risk management and internal control
LINK’s risk management and internal control activities are integrated with its corporate strategy and
part of the business planning processes in all areas. GLT is responsible for risk management at LINK,
subject to directions and approval from the board of directors.
Risk management is an integral part of LINK’s business, and it is therefore performed in cooperation
with operative teams in all parts of the organization. The daily management activities that form part of,
and follow, the risk management processes are held by the operative teams in LINK.
LINK’s audit committee and board are informed on the process throughout the year, and the board
annually supervises the risk management process output and approves the risk profile for each of
the six risk areas defined by LINK. LINK’s risk profile defines the level acceptable in order to reach its
objectives. The definition forms the basis for management execution, controls, and resource allocation
within each risk area.
LINK’s operative processes for risk management are based on an approach where the group
organization defines policies and procedures enabling entities to implement locally or within a specific
area. Internal controls are implemented by the functional areas, and each area provides support and
information from group level to local entities or specific areas depending on requirements. Internal
annual audits are performed for some areas. Policies are accessible to employees at the LINK Intranet,
and training is provided by area.
Please refer to “Risks” above for an overview of the risk areas.
LINK fully complies with the Code.
11. Remuneration of the board of directors
The remuneration of the board of directors reflects the board’s responsibility, expertise, time
commitment, and the complexity of the company’s activities. The specific remuneration is listed in
note 8 payroll.
The remuneration of the board members is not linked to the company’s performance, and share options
are not granted.
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The chairman of the board was in an EGM on July 12th, 2022, granted a right to 2,000,000 share options,
where 1 option shall give the right to subscribe for 1 share in LINK. The share option agreement was
entered into in accordance with the decision, and the grant of shares was made public on the Oslo
Stock Exchange on September 1st, 2022.
LINK deviates from the Code regarding grant of share option to chairman.
12. Salary and other remuneration for executive personnel
The current guidelines for remuneration of executive management were approved by the general
meeting on May 31st 2023. The guidelines are published and available on LINK’s website General
Meetings (linkmobility.com)
Remuneration report following the guidelines will be made available on LINK’s website https://www.
linkmobility.com/investors/related-documents
LINK’s performance-related remuneration is defined annually by the board and is subject to an absolute
limit.
LINK fully complies with the Code.
13. Information and communication
The board of directors has established guidelines for LINK’s reporting of financial and other information
based on openness and equal treatment of all stakeholders. The board has established guidelines for
LINK’s contact with shareholders beyond general meetings, including a dedicated investor relations
professional and management meetings in relation to quarterly reporting.
LINK fully complies with the Code.
14. Takeovers
The board of directors has established guidelines for the event of a take-over bid. In the case of a bid,
the board has an independent responsibility to ensure that shareholders are treated equally and that
business activities are not disrupted unnecessarily. If an offer were to be made for LINK’s shares,
the board would issue a statement making a recommendation as to whether shareholders should or
should not accept the offer. The board will ensure shareholders are given sufficient information and
time to form a view of the offer. The board’s statement on the offer will make it clear whether the views
expressed are unanimous or specify the basis on which specific members excluded themselves. Any
final decision to go ahead with a potential offer will be made by the shareholders in an extraordinary
general meeting (EGM).
LINK fully complies with the Code.
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15. Auditor
The auditor submits the main features of the plan for the audit of the company to the audit committee
annually, in time for the committee to review before processing by the board.
The auditor is invited to board meetings where the annual accounts are dealt with. At these meetings,
the auditor reports on any material changes in the company’s accounting principles and key aspects
of the audit, comment on any material estimated accounting figures, and report all material matters
on which there has been disagreement between the auditor and the executive management of the
company.
The board of directors reviews the company’s internal control procedures with the auditor annually,
including weaknesses identified by the auditor and proposals for improvement.
The board of directors has guidelines in respect of the use of the auditor by the company’s executive
management for services other than the audit.
PWC has been the auditor of LINK since 2019. In the last decade, the group has had 2 auditors.
LINK fully complies with the Code.
Insurance
LINK has a Directors and Officers Liability Insurance in place. The insurance covers the members
of the Board of Directors, the CEO and group management, in addition to any employee acting in a
managerial capacity. The insurance includes LINK’s subsidiaries.
The insurance policy is issued by a reputable, specialized insurer with appropriate rating, and protects
LINK’s directors, officers and any employees that can incur personal liability from claims made against
them in respect of actual or alleged acts in their capacity as directors and officers.
Forward looking statement
LINK’s European business has delivered a historical organic gross profit growth in the high single
digits. As the business is highly scalable, organic adjusted EBITDA growth is expected to be higher than
organic gross profit growth.
LINK’s M&A ambitions remain with several potential level-up cases in both Europe and beyond. Smaller
bolt-ons in Europe is however a priority to realize further scale. The M&A pipeline holds an additional
EBITDA potential of more than NOK 200 million in Europe alone.
The board of directors appreciates and emphasizes uncertainty in relation to assessments of expected
future development.
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Thomas Berge
Chief Executive Officer
Andre Alexander Christensen
Chairman of the board
Grethe Helene Viksaas
Board member
Jens Rugseth
Board member
Sara Murby Forste
Board member
Robert Joseph Nicewicz Jr
Board member
Sabrina Gosman
Board member
Oslo, 25 April 2024
The Board of Directors at LINK Mobility Group Holding ASA
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Responsibility Statement
We confirm that, to the best of our knowledge, the consolidated financial statements for the year ended
31 December 2023 have been prepared in accordance with IFRS as adopted by the EU, that the financial
statements for the parent company for the year ended 31 December 2023 have been prepared in accordance
with IFRS as adopted by the EU, that they give a true and fair view of the Company’s and Group’s assets,
liabilities, financial position and results of operations, and that the Report of the Board of Directors gives a true
and fair review of the development, performance, and financial position of the Company and the Group and
includes a description of the principal risks and uncertainties that they face.
Thomas Berge
Chief Executive Officer
Andre Alexander Christensen
Chairman of the board
Grethe Helene Viksaas
Board member
Jens Rugseth
Board member
Sara Murby Forste
Board member
Robert Joseph Nicewicz Jr
Board member
Sabrina Gosman
Board member
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Consolidated income statement
For the period ended 31 December
(Amounts in NOK 1000)
Note 2023 2022
Revenue 6 6,282,126 4,913,740
Total operating revenue 6,282,126 4,913,740
Direct cost of services rendered -4,934,441 -3,775,466
Payroll and related expenses 8 -585,383 -498,247
Other operating expenses 9 -284,450 -301,253
Depreciation and amortization 7, 13, 14 -337,535 -296,985
Impairment of intangible assets and goodwill 13 - -180,360
Total operating expenses -6,141,809 -5,052,311
Operating profit (loss) 140,317 -138,571
Finance income and finance expenses
Net currency exchange gains (losses) 10 44,319 94,227
Net interest expense 10 -139,667 -148,353
Net other financial income (expenses) 10 6,002 17,705
Total finance income (expense) -89,345 -36,421
Profit (loss) before income tax 50,972 -174,992
Income tax 22 -12,616 -18,570
Profit (loss) from continuing operations 38,356 -193,563
Profit from discontinued operations 5 28,926 42,457
Profit (loss) for the period 67,282 -151,106
Loss attributable to:
Owners of the company 67,282 -151,106
Earnings per share (NOK/share):
Basic earnings (loss) per share from total operations 11 0.23 -0.51
Diluted earnings (loss) per share from total operations 11 0.22 -0.51
Basic earnings (loss) per share from continuing operations 11 0.13 -0.65
Diluted earnings (loss) per share from continuing operations 11 0.13 -0.65
The accompanying notes are an integral part of these financial statements.
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Consolidated statement of Comprehensive Income
for the period ended 31 December
(Amounts in NOK 1000)
2023 2022
Profit (loss) for the period 67,282 -151,106
Other comprehensive income
Items that may be reclassified to profit or loss
Translation differences of foreign operations 195,641 271,850
Gains and losses net investment hedge -69,037 -49,875
Tax on OCI that may be reclassified to P&L 15,188 10,973
OCI that may be reclassified to P&L 141,793 232,947
Actuarial gains and losses -1,757 -
OCI that will not be reclassified to P&L -1,757 -
Other comprehensive income for the period 140,036 232,947
Total comprehensive income for the period 207,318 81,841
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Consolidated statement of financial position
(Amounts in NOK 1000)
Note 2023 2022
ASSETS
Goodwill 13 4,388,870 5,788,277
Other intangible assets 13 1,773,601 2,929,503
Deferred tax asset 22 142,934 133,145
Equipment and fixtures 14 20,432 22,143
Right-of-use assets 7 43,988 47,865
Other non-current assets 2,523 2,876
Total non-current assets 6,372,348 8,923,810
Trade and other receivables 15, 18 1,380,412 1,243,758
Cash and cash equivalents 16, 18 1,096,596 826,851
Current assets held as available for sale 5, 24 2,831,510 -
Total current assets 5,308,518 2,070,609
TOTAL ASSETS 11,680,866 10,994,419
EQUITY AND LIABILITIES
Share capital 1,485 1,479
Share premium and other reserves 5,937,788 5,856,471
Accumulated translation differences 553,220 414,942
Retained earnings (accumulated losses) -978,401 -1,047,370
Total equity 17 5,514,093 5,225,521
Liabilities
Long-term borrowings 18, 19 4,008,320 3,837,096
Lease liabilities 7, 18, 19 31,421 34,381
Deferred tax liabilities 22 274,431 533,064
Other long-term liabilities 6,834 11,006
Total non-current liabilities 4,321,006 4,415,547
Short-term borrowings 18, 19 2,741 5,470
Lease liabilities 7, 18, 19 14,549 14,217
Trade and other payables 18, 21 1,493,639 1,331,086
Income tax payable 22 38,014 2,578
Short-term liabilities held as available for sale 5 296,825 -
Total current liabilities 1,845,768 1,353,351
Total liabilities 6,166,773 5,768,898
TOTAL EQUITY AND LIABILITIES 11,680,866 10,994,419
The accompanying notes are an integral part of these financial statements.
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Thomas Berge
Chief Executive Officer
Andre Alexander Christensen
Chairman of the board
Grethe Helene Viksaas
Board member
Jens Rugseth
Board member
Sara Murby Forste
Board member
Robert Joseph Nicewicz Jr
Board member
Sabrina Gosman
Board member
Consolidated statement of financial position
Oslo, 26 April 2024
The Board of Directors of LINK Mobility Group Holding ASA
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Consolidated statement of Changes in Equity
for the period ended 31 December
(Amounts in NOK 1000)
Note Share
capital
Share
premium
Currency
translation
reserve
Retained
earnings
(accumulated
losses)
Total
equity
equit
Balance at 01 January 2022 1,471 5,802,356 181,994 -896,264 5,089,557
Profit (loss) for the period - - - -151,106 -151,106
Other comprehensive income (loss)
for the period, net of income tax
Total comprehensive income for the
period
Issue of ordinary shares 8 6,282 - - 6,289
Redemption of preference shares - - - - -
Share based payment - 47,833 - - 47,833
Other adjustments - - - - -
Balance at 31 December 2022 17 1,479 5,856,471 414,942 -1,047,370 5,225,521
Balance at 01 January 2023 1,479 5,856,471 414,942 -1,047,370 5,225,521
Profit (loss) for the period - - - 67,282 67,282
Other comprehensive income (loss)
for the period, net of income tax
- - 138,278 1,757 140,036
Total comprehensive income for the
period
Issue of ordinary shares 6 2,752 - - 2,759
Redemption of preference shares - - - - -
Share based payment - 78,565 - - 78,565
Other adjustments - - -70 -70
Balance at 31 December 2023 17 1,485 5,937,788 553,220 -978,401 5,514,093
The accompanying notes are an integral part of these financial statements.
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Consolidated statement of cash flows
for the period ended 31 December
(Amounts in NOK 1000)
Note 2023 2022
Cash flows from operating activities
Profit (loss) before income tax from continuing operations 50,972 -174,992
Adjustments for:
Taxes paid -41,635 -58,091
Finance expense (income) 10 89,345 36,421
Depreciation and amortization 7, 13, 14 337,535 477,345
Share based payment expense 78,565 47,833
Net gain from disposals -248 32
Change in trade and other receivables -201,025 -204,601
Change in trade and other payables 198,402 144,645
Change in other provisions 20,384 38,852
Net cash flows from operating activities from continuing operations 532,296 307,444
Net cash flows from operating activities from discontinued operations 190,902 113,301
Cash flows from investing activities
Payment for equipment and fixtures 14 -5,857 -6,693
Payment for intangible assets 13 -110,270 -125,647
Payment for acquisition of subsidiary, net of cash acquired - 1,522
Disposal of subsidiary - -
Purchase price adjustment acquisition of subsidiary 10 - -
Net cash flows from investing activities from continuing operations -116,127 -130,819
Net cash flows from investing activities from discontinued operations -63,986 -109,437
Cash flows from financing activities
Proceeds on issue of shares 2,759 6,289
Repayment of equity - -
Other financial items 19 - 450
Proceeds from borrowings 19 - -
Repayment of borrowings 19 -117,038 -78,927
Interest paid -150,264 -141,967
Principal elements of lease payments 7 -16,583 -15,931
Dividends received - -
Net cash flows from financing activities from continuing operations -281,127 -230,085
Net cash flows from financing activities from discontinued operations
-2,506
-2,952
Effect of foreign exchange rate changes
21,928
37,204
Net change in bank deposits, cash and equivalents 281,381 -15,344
Cash and equivalents at beginning of period 826,851 842,195
Less: Cash and equivalents at end of the period (held for sale) -11,636 -
Cash and equivalents at end of the period from continuing operations 1,096,596 826,851
The accompanying notes are an integral part of these financial statements.
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Notes to the financial statements for the period ended
31 December 2023
1 Subsidiaries
2 Adoption of new and revised International Financial Reporting Standards (IFRS)
3 Summary of significant accounting policies
4 Critical accounting judgments and key sources of estimation variances
5 Discontinued operations
6 Segment reporting
7 Leases
8 Payroll and related expenses
9 Other operating expenses
10 Net finance and income expenses
11 Earnings per share
12 Transactions with related parties
13 Intangible assets
14 Equipment and fixtures
15 Trade and other receivables
16 Cash and cash equivalents
17 Share capital and shareholder information
18 Classes and categories of financial instruments
19 Interest-bearing liabilities
20 Financial instruments, risk management objectives, and policies
21 Trade and other payables
22 Income tax
23 Contingencies and legal claims
24 Events after the reporting date
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Income Statement
For the period ended 31 December
(Amounts in NOK 1000)
Note 2023 2022
Other operating expenses 6 -7, 220 -5,106
Total operating expenses -7,220 -5,106
Operating loss -7,220 -5,106
Finance income and finance expenses
Net currency exchange gains (losses) 1,773 44,385
Net interest expense -27,565 -24,943
Net other financial income (expenses) -29,723 -16,138
Total finance expense 7 -55,515 3,304
Loss before income tax -62,735 -1,802
Income tax 14 13,698 -1,143
Loss for the period -49,037 -2,945
The accompanying notes are an integral part of these financial statements.
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Statement of financial position
(Amounts in NOK 1000) 31 December 31 December
ASSETS Note 2023 2022
Investment in LINK Mobility Group AS 5 8,116,803 8,026,174
Long-term receivables - intercompany 7 3,236,134 3,181,121
Total non-current assets 11,352,937 11,207,295
Prepaid expenses 680 -
Cash and cash equivalents 8, 10 68,417 14,794
Total current assets 69,098 14,794
Total assets 11,422,035 11,222,089
EQUITY AND LIABILITIES
Share capital 1,485 1,479
Share premium and other reserves 5,961,948 5,880,630
Retained earnings (accumulated losses) 1,430,585 1,479,622
Total equity 9 7,394,018 7,361,731
LIABILITIES
Long-term borrowings 11 4,008,320 3,837,096
Deferred tax 14 -152 16,948
Loans and borrowings - intercompany 15,892 425
Total non-current liabilities 4,024,059 3,854,470
Short-term borrowings 10, 11 2,741 5,470
Trade payables and other payables 10, 13 1,216 418
Current tax liabilities 14 - -
Total current liabilities 3,957 5,888
Total liabilities 4,028,017 3,860,358
Total equity and liabilities 11,422,035 11,222,089
The accompanying notes are an integral part of these financial statements.
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Statement of Comprehensive Income
for the period ended 31 December
(Amounts in NOK 1000) 2023 2022
Profit (loss) for the period -49,037 -2,945
Other comprehensive income
Items that may be reclassified to profit or loss
Translation differences of foreign operations - -
Other comprehensive income for the period - -
Total comprehensive income for the period -49,037 -2,945
Statement of financial position
Oslo, 26 April 2024
The Board of Directors of LINK Mobility Group Holding ASA
Andre Alexander Christensen
Chairman of the board
Grethe Helene Viksaas
Board member
Jens Rugseth
Board member
Sara Murby Forste
Board member
Thomas Berge
Chief Executive Officer
Robert Joseph Nicewicz Jr
Board member
Sabrina Gosman
Board member
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Statement of Changes in Equity
For the period ended 31 December 2023
(Amounts in NOK 1000) Note
Share
capital
Share
premium
Retained earnings
(accumulated
losses)
Total
equity
Balance at 01 January 2022 1,471 5,826,515 1,482,567 7,310,554
Profit for the period - - -2,945 -2,945
Other comprehensive income (loss) for
the year, net of income tax
- - - -
Total comprehensive income for the year - - -2,945 -2,945
Issue of ordinary shares 8 6,282 - 6,289
Share based payment - 47,833 - 47,833
Balance at 31 December 2022 9 1,479 5,880,630 1,479,622 7,361,731
Balance at 01 January 2023 1,479 5,880,630 1,479,622 7,361,731
Profit for the year - - -49,037 -49,037
Other comprehensive income (loss) for
the year, net of income tax
- - - -
Total comprehensive income for the year - - -49,037 -49,037
Issue of ordinary shares 6 2,752 - 2,759
Share based payment - 78,565 - 78,565
Balance at 31 December 2023 9 1,485 5,961,948 1,430,585 7,394,018
The accompanying notes are an integral part of these financial statements.
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Statement of cash flows
for the period ended 31 December
(Amounts in NOK 1000) Note 2023 2022
Cash flows from operating activities
Profit before income tax -62,735 -1,802
Adjustments for:
Finance income (expense) 160,662 -3,304
Change in trade and other payables 10, 13 799 8
Change in other provisions -5,268 262
Net cash flows from operating activities 93,458 -4,836
Cash flows from investing activities
Net cash inflow, loan repayments from subsidiaries 5,654,133 111,719
Net cash (outflow), loan to subsidiaries -5,438,307 -52,290
Net cash inflow, intercompany loan interest 5,213 -
Net cash flows from investing activities 5 221,040 59,429
Cash flows from financing activities
Proceeds on issue of shares 9 2,759 6,289
Repayment of borrowings -117,960 -70,501
Interest paid -145,731 -133,960
Net cash flows from financing activities -260,932 -198,172
Net change in bank deposits, cash and equivalents 53,565 -143,579
Effect of foreign exchange rate changes 59 18,728
Cash and equivalents at beginning of period 14,833 139,684
Cash and equivalents at end of the period 68,456 14,833
The accompanying notes are an integral part of these financial statements.
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Notes to the financial statements for the period
ended 31 December 2023
Contents notes
1 General information
2 Adoption of new and revised International Financial Reporting Standards (IFRSs)
3 Summary of signicant accounting policies
4 Critical accounting judgments and key sources of estimation variances
5 Investment in subsidiaries
6 Other operating expenses
7 Net nance income and expenses
8 Cash and cash equivalents
9 Share capital and shareholder information
10 Classes and categories of nancial instruments
11 Interest-bearing liabilities
12 Financial instruments, risk management objectives, and policies
13 Trade and other payables
14 Income tax
15 Contingencies and legal claims
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Note 1 General information
LINK Mobility Group Holding ASA owns 100% of LINK Mobility Group AS, which in turn owns 100% the
LINK subsidiaries. The Group’s subsidiaries as at 31 December 2023 are listed below.
Name of entity Date of
acquisition
Place of business / country of
registration
Ownership
interest
LINK Mobility Group AS 12/6/2021 Oslo, Norway 100%
Note 2 Adoption of new and revised
International Financial Reporting Standards (IFRS)
A number of amended IFRS standards issued by the International Accounting Standards Board (IASB)
and IFRS interpretations issued by the IFRS Interpretations Committee (IFRS IC) are effective for
accounting periods commencing on or after 01 January 2023. The requirements arising from revised
IFRSs or IFRIC interpretations are embedded in the recognition, measurement and disclosures relevant
to the consolidated financial statements of the Group from the date of establishment. The accounting
policies adopted are described in Note 3 Summary of significant accounting policies.
Standards and interpretations affecting amounts reported in the current period
The accounting policies adopted, and methods of computation followed are consistent with those of
the previous financial year, except for items disclosed below. The adoption of the following standards
and interpretations has not had any material impact on the disclosures or on the amounts reported in
these financial statements:
Amendment to IFRS 7 and IAS 7 regarding supplier finance arrangements
Amendments to IAS 12 to provide a temporary exception to the requirements regarding deferred tax
assets and liabilities related to pillar two income taxes
As at the date of authorisation of these financial statements, Standards and Interpretations had been
issued by the IASB but were not effective for the financial year ended 31 December 2023. At the date
of these financial statements, it is not foreseable that these changes will not have a material impact on
the financial reporting for the Group.
New or amended standards that have effective date on 01 January 2025 or later have not been
assessed if these will have any impact on LINK Mobility Groups financial statements in the period of
initial application. Management will continue to follow the development of changes to Standards and
Interpretations issued by the IASB throughout 2024.
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Note 3 Summary of significant accounting policies
3.1 General information
LINK Mobility Group Holding ASA is the parent company of LINK Mobility Group AS, and is
headhquartered in Oslo, Norway. LINK is Europe’s leading provider of mobile and CPaaS solutions
specializing in messaging, digital services, and intelligent data usage.
LINK Mobility Group Holding ASA (“the Company”) is a limited liability Company incorporated and
domiciled in Norway. The address of the registered office is Universitetsgata 2, 0164 Oslo, Norway.
LINK Mobility Group Holding ASA is the parent company of the LINK Mobility Group AS. LINK Mobility
Group AS provides services in mobile communication and specialises in mobile messaging services,
mobile solutions, and mobile intelligence. LINK Mobility Group Holding ASA and its subsidiaries are
regarded as “the Group”.
These financial statements were approved for issue by the Board of Directors on date 26 April 2024.
Minor rounding differences may be present, and the total may deviate from the total of the individual
amounts. This is due to the rounding of whole figures to thousands for presentation purposes.
3.2 Basis for preparation
The financial statements of the Company have been prepared in accordance with IFRS® Accounting
Standards as adopted by the EU and the Norwegian Accounting Act. The financial statements have
been prepared on the historical cost basis.
The preparation of financial statements in conformity with IFRSs requires the use of certain critical
accounting estimates. It also requires management to exercise its judgments in applying the Group’s
accounting policies. Areas involving a high degree of judgment or complexity, and areas in which
assumptions and estimates are significant to the financial statements are disclosed in Note 4 Critical
accounting judgments and key sources of estimation variances. The financial statements have been
prepared on a going-concern basis.
The presentation currency of the financial statement is Norwegian kroner (NOK). Amounts are rounded
to nearest thousand, unless otherwise stated.
3.3 Current/non-current classification
An asset is classified as current when it is expected to be realised, or is intended for sale or consumption,
in the Company’s normal operating cycle, it is expected/due to be realised or settled within next twelve
month after the reporting date. The normal operating cycle for trade receivables is between 30 - 90
days. Other assets are classified as non-current. A liability is classified as current when it is expected
to be settled in the Company’s normal operating cycle, the liability is due to be settled within twelve
months after the reporting period or if the Company does not have an unconditional right to defer
settlement of the liability for at least twelve months after the reporting period. The normal operating
cycle for trade payables is between 30 - 45 days. All other liabilities are classified as non-current.
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3.4 Foreign currency translation
The consolidated financial statements are presented in NOK, which is the Company’s functional
currency. In preparing the financial statements of the individual companies, transactions in currencies
other than the entity’s functional currency are recognized at the rate of exchange on the date of the
transaction. At each reporting date, monetary assets and liabilities that are denominated in foreign
currencies are retranslated at the balance sheet date. Non-monetary items carried at fair value in foreign
currencies are translated using the exchange rate at the date when the fair value was measured. Non-
monetary items that are measured in terms of historical cost in a foreign currency are not retranslated
after the transaction date.
Foreign exchange gains and losses that relate to borrowings and cash and cash equivalents are
presented in the income statement as financial items. All other foreign exchange gains and losses are
presented on a net basis in the income statement as other operating expenses. Exchange differences
are recognized in the income statement in the period in which they arise.
For the purposes of presenting consolidated financial statements, the assets and liabilities of the
Company’s foreign operations are translated to NOK at exchange rates on the reporting date. Income
and expense items are translated to NOK at the average exchange rates for the period, unless
exchange rates fluctuate significantly during that period, in which case the exchange rates at the date
of transactions are used. Exchange differences arising, if any, are recognized in other comprehensive
income and accumulated in a separate component of equity.
3.5 Impairment of non-financial assets
At each reporting date, the Company reviews if there are any indicators that the carrying amounts
of its tangible and intangible assets may be impaired. If any such indication exists, the recoverable
amount of the asset is estimated to determine the extent of the impairment loss (if any). Where the
asset does not generate cash flows that are independent from other assets, the Company estimates
the recoverable amount of the cash-generating unit to which the asset belongs. When a reasonable
and consistent basis of allocation can be identified, corporate assets are also allocated to individual
cash-generating units, or otherwise they are allocated to the smallest group of cash-generating units
for which a reasonable and consistent allocation basis can be identified.
Recoverable amount is the higher of fair value less costs of disposal and value in use. In assessing value
in use, the estimated future cash flows are discounted to their present value using a pre-tax discount
rate that reflects current market assessments of the time value of money and the risks specific to the
asset for which the estimates of future cash flows have not been adjusted.
If the recoverable amount of an asset (or cash-generating unit) is estimated to be less than its carrying
amount, the carrying amount of the asset (or cash-generating unit) is reduced to its recoverable
amount. An impairment loss is recognized immediately in the income statement.
Where an impairment loss subsequently reverses, the carrying amount of the asset (or cash-generating
unit) is increased to the revised estimate of its recoverable amount, but so that the increased carrying
amount does not exceed the carrying amount that would have been determined had no impairment loss
been recognized for the asset (or cash-generating unit) in prior years. A reversal of an impairment loss
is recognized immediately in profit or loss, unless the relevant asset is carried at a revalued amount, in
which case the reversal of the impairment loss is treated as a revaluation increase.
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3.6 Financial Instruments
Financial assets and financial liabilities are initially measured at fair value. Transaction costs that are
directly attributable to the acquisition or issue of financial assets and financial liabilities (other than
financial assets and financial liabilities at fair value through profit or loss) are added to or deducted
from the fair value of the financial assets or financial liabilities, as appropriate, on initial recognition.
The Company has classified the financial instruments into the following categories of financial assets
and liabilities: Financial assets and liabilities at fair value through profit and loss (FVTPL), financial
assets at amortized cost (FAAC), financial assets at fair value through other comprehensive income
(FVTOCI) and Financial liability at cost (FLAC). Currently the Company does not have any assets in the
classification of FVTOCI.
The categorisation of financial instruments (financial assets and liabilities) for measurement
purposes is based on the nature and purpose of the financial instrument and is determined on initial
recognition. The Company presents financial assets and liabilities in the following classes: trade and
other receivables (FAAC), cash and cash equivalents, trade and other payables (FLAC), and borrowings
(FLAC).
Trade receivables and other current and non-current financial assets
The financial assets held by the Company, primarily trade and other receivables, are held within a
business model whose objective is to hold financial assets in order to collect contractual cash flows
and are thus measured subsequently at amortized cost less loss allowances. The impairment model in
IFRS 9 Financial Instruments requires the recognition of impairment provisions based on expected credit
losses (ECL). The Company recognises an allowance for expected credit losses on trade receivables.
The amount of expected credit losses is updated at each reporting date to reflect changes in credit
risk since initial recognition. The impairment is calculated by taking into account the historic evidence
of the level of credit losses experienced and the ageing profile of the trade receivables. Individual trade
receivables are impaired when management assesses them not to be wholly or partially collectible.
Cash and cash equivalents
Cash and cash equivalents include cash, bank deposits and commercial papers with original maturities
of three months or less.
Financial liabilities
Trade and other payables include trade payables and other current and non-current, non-interest-
bearing financial liabilities. Borrowings (non-current and current) include bank loans and overdrafts.
These liabilities are initially recognized in the statement of financial position at fair value (net of any
transaction costs), and subsequently measured at amortized cost using the effective interest rate
method.
3.7 Cash flow
The Company presents the statement of cash flows using the indirect method. Cash inflows and
outflows are shown separately for investing and financing activities, while operating activities include
both cash and non-cash line items. Interest received and paid, and dividends received, are reported as
a part of operating activities. Dividends distributed are included as a part of financing activities. Value
Added Tax and other similar taxes are regarded as collection of tax on behalf of authorities.
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3.8 Taxation
Income tax in the income statement includes both taxes payable for the period and the change in
deferred taxes. The change in deferred taxes reflects future taxes payable resulting from the year’s
activities. Deferred taxes are determined based on the accumulated result, which falls due for payment
in future periods. Deferred taxes are calculated on net positive timing differences between accounting
and tax balance sheet values, after offsetting negative timing differences and losses carried forward
under the liability method.
A deferred tax asset is recognized only to the extent that it is probable that future taxable profits will be
available against which the asset can be utilized. Deferred tax assets are reduced to the extent that it
is no longer probable that the related tax benefit will be realized.
Deferred tax assets and liabilities
Deferred tax assets and liabilities are presented net of their respective tax effect using tax rate of the
applicable jurisdiction applied to amounts representing future tax deductions or taxes payable and
consist of the following as of 31 December.
Negative and positive timing differences, which reverse or may reverse in the same period, are offset.
Deferred taxes are calculated on the basis of timing differences and losses carried forward that are
offset. Timing differences between different subsidiaries have not been offset. During the period that
these differences reverse, the companies will have a taxable net income that is sufficient to realize the
deferred tax allowance. The losses carried forward are all in countries where future taxable profits are
expected.
Note 4 Critical accounting judgments and key sources
of estimation variances
In the application of the Company’s accounting policies, as described in note 3 (summary of significant
accounting policies), management is required to make judgments, estimates and assumptions that
affect the reported amounts of assets and liabilities, income and expenses. Estimates and judgments
are evaluated on an ongoing basis and are based on historical experience and other factors, including
expectations of future events that are considered to be relevant. Future events may cause these
estimates to change and actual results may differ from these estimates. Estimates and underlying
assumptions are reviewed on an ongoing basis.
Changes in accounting estimates are recognized in the period when the changes occurred, if they
apply to that period. If the changes also apply to future periods, the effect will be distributed between
the current period and future periods.
Investment in subsidiaries
Subsidiaries are valued at cost. If actual value is below cost value and this continues over time, the
investment in subsidiaries will be impaired. Dividends, group contributions and other distributions
from subsidiaries are recognized in the same year as they are recognized in the financial statement of
the provider. If dividends or group contribution exceed withheld profits after the acquisition date, the
excess amount represents repayment of invested capital, and is recognized as a reduction in carrying
value of the investment.
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Note 5 Investment in subsidiaries
On 06 December 2021, LINK Mobility Pecunia AS was officially merged with LINK Mobility Group AS. As a
result of this merger, LINK Mobility Group AS is the immediate subsidiary of LINK Mobility Group Holding ASA.
The Company has the following investment in a subsidiary:
Entity Country Industry Date of acquisition
Proportion of
voting equity
acquired
LINK Mobility Group AS Norway Mobile messaging
services and solutions
06 December 2021 100%
The total amortized cost as of 31 December 2023:
(Amounts in NOK 1 000) LINK Mobility Group AS
Total amoritzed cost (01.01) 8,026,174
Employee share options in subsidiary 78,565
Total amoritzed cost (31.12) 8,104,739
LINK Mobility Group AS provides mobile communication services and specializes in messaging,
digital services and data intelligence. 100% of the voting equity interest of the company was acquired
on 06 December 2021 when LINK Mobility Pecunia AS was merged with LINK Mobility Group AS.
Note 6 Other operating expenses
(Amounts in NOK 1000) 2023 2022
Advisors and consultants 1,762 952
Stock exchange listing expenses1 1,993 2,590
Insurance premiums2 2,990 1,422
Travel expenses 230 -
Other expenses3 246 143
Total other operating expenses 7, 220 5,106
1
These costs are representative of stock exchange listing fees, registration fees for increases in share capital,
management of insider logs, and share register analysis.
2
Insurance premiums includes the cost of insurance brokerage services in addition to insurance policy
covers.
3
Other expenses are representative of license fees, insurance related to merger and acquisition activities, and
external accounting services.
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224
Auditor’s fees
The table below summarises audit fees for 2023 (2022) and fees for audit related services, tax
services and other services incurred by the Company during the period. These expenses are included
in advisors and consultants expenses above.
2023 2022
Audit fee 503 710
Other attestation services 397 -
Tax consulting services - -
Other services - -
Total fee to auditor 900 710
Note 7 Net finance income and expenses
(Amounts in NOK 1000)
The Company’s finance income and expense is comprised of gains (losses) from foreign exchange and
from exposure to interest expenses related to loans from financial institutions. Interest amounts are
presented as a sum of interest on borrowings offset by amortized cost recognized in the profit and loss.
All categories of financial income and expense are presented on a net basis.
Net financial income and expenses 2023 2022
Net currency exchange gains (losses)1 1,773 44,385
Net interest expense -27,565 -24,943
Net other financial expense -29,723 -16,138
Total finance income -55,515 3,304
Net interest expense 2023 2022
Interest expense financial institutions -144,184 -128,466
Interest expense - seller’s credit - -1,944
Other interest income (expense) 5,004 467
Interest income from related parties 111,615 105,000
Total net interest expense -27,565 -24,943
Net other financial expenses 2023 2022
Amortized loan set-up costs -16,840 -16,180
Currency option premium -12,573 -
Other financial (expenses) income -310 42
Total net other financial expenses -29,723 -16,138
1
Foreign currency gain/loss is presented on a net basis here and in the Statement of Profit and Loss.
Exposure to fluctuations in foreign currency comes from external lending denominated in EUR. Refer to note
11 (interest-bearing liabilities) and note 12 (financial instruments, risk management objectives, and policies)
for further details.
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Note 8 Cash and cash equivalents
(Amounts in NOK 1000)
2023 2022
Cash and cash equivalents 68,417 14,794
Total cash and cash equivalents 68,417 14,794
Restricted cash 2023 2022
Restricted cash - -
Bank balance in escrow account - -
Total cash and cash equivalents 68,417 14,794
If applicable, cash and cash equivalents include amounts classified as restricted cash. There are no
restricted amounts as at 31 December 2023.
Note 9 Share capital and shareholder information
Share capital as at 31 December 2023 is KNOK 1 485 (2022: KNOK 1 479), being 295 890 306 ordinary shares
(2022: 295 890 306 ordinary shares) at a nominal value of NOK 0.005/share (2022: NOK 0.005/share). There
are no preference shares in FY2023 (FY2022: nil).
All shares were fully paid; each ordinary share carries one vote at any general meeting.
The movement in the number of shares during the year was as follows:
2023 2022
Ordinary shares opening balance 2023/2022 295,890,306 294,252,254
Issue of ordinary shares (07 July 2022) 588,127
Issue of ordinary shares (14 November 2022) 929,457
Issue of ordinary shares (24 November 2022) 120,468
Issue of ordinary shares (05 June 2023) 174,692
Issue of ordinary shares (08 November 2023) 909,110
Issue of ordinary shares (22 December 2023) 85,163
Ordinary shares at the end of the period 297,059,271 295,890,306
Total number of shares at the end of the period 297,059,271 295,890,306
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LINK Mobility Group Holding ASA has the following major shareholders as at 31 December 2023:
Name of shareholder Type of account Ownership interest
Citibank, N.A. Nominee 28.80%
KARBON INVEST AS Ordinary 5.37%
Citibank, N.A. Nominee 4.51%
FOLKETRYGDFONDET Ordinary 4.14%
The Bank of New York Mellon SA/NV Nominee 3.77%
VERDIPAPIRFONDET DNB SMB Ordinary 2.73%
SUNDT AS Ordinary 2.36%
J.P. Morgan SE Nominee 1.80%
BARCLAYS CAPITAL SEC. LTD FIRM Ordinary 1.71%
SKANDINAVISKA ENSKILDA BANKEN AB Ordinary 1.70%
DANSKE BANK Ordinary 1.61%
VERDIPAPIRFONDET FIRST GENERATOR Ordinary 1.50%
The Bank of New York Mellon SA/NV Nominee 1.41%
J.P. MORGAN SECURITIES PLC Ordinary 1.34%
VERDIPAPIRFONDET DNB NORGE Ordinary 1.18%
DEFA ENDEAVOUR AS Ordinary 1.16%
Citibank, N.A. Nominee 1.13%
CLEARSTREAM BANKING S.A. Nominee 1.11%
VERDIPAPIRFONDET DELPHI NORDIC Ordinary 1.06%
Em Kapital As Ordinary 1.02%
69.41%
The company’s trustees (Board Members, management) hold ownership interests and
rights to shares:
Name of shareholder Total number of shares
Victory Partners VIII Limited via a nominee account in Citibank
(controlled by Abry who have 2 Board members)
85,540,774
Karbon Invest AS (controlled by Jens Rugseth) 15,945,105
HDR Srl (controlled by Riccardo Dragoni) 664,215
Rugz AS (controlled by Jens Rugseth) 500,000
Thomas Berge 455,030
Ina Rasmussen 67,166
Lin Austbø 40,504
Morten Løken Edvardsen 29,298
Pål Marius Brun 16,251
Sara Murby Forste 15,957
Riccardo Dragoni
8,612
Grethe Helene Viksaas (Board member) 6,382
Benoit Bole 5,000
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Note 10 Classes and categories of financial instruments
(Amounts in NOK 1000)
Carrying value
2023 2022
Current financial assets
Cash and cash equivalents 68,417 14,794
Non-current financial liabilities
Borrowings 4,008 3,837,096
Current liabilities
Borrowings 2,741 5,470
Trade payables 741 378
The financial assets held by the Company are held within a business model with the objective to hold
financial assets in order to collect contractual cash flows and are thus measured subsequently at
amortized cost less loss allowances.
All financial liabilities are measured at amortized cost.
The carrying amounts of financial assets and liabilities approximate their fair value as at 31 December
2023. Arrangements with financial institutions are entered into on market terms, and the carrying
value at the reporting date has been assessed as approximating fair value.
The recognized amounts consitute a reasonable approximation of fair value.
Note 11 Interest-bearing liabilities
(Amounts in NOK 1000)
Interest bearing liabilities are measured at amortized cost.
Non-current financial liabilities 2023 2022
Bond loan 4,008,320 3,837,096
Holdback - -
Total 4,008,320 3,837,096
Current liabilities 2023 2022
Bond loan* 2,741 5,470
Total 2,741 5,470
*Instalments falling due within a 12 month period, including non-capitalised interest, are classified as current.
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Contractual maturities of
financial liabilities at 31
December 2023
< 3 months 3 months - 1
year
1 - 2 years 2 - 5 years Total
Bond loan (tap issue 15.12.2020) - 75,873 2,323,973 - 2,399,847
Bond loan (tap issue 23.06.2021) - 64,492 1,975,377 - 2,039,870
Total - 140,366 4,299,351 - 4,439,716
Contractual maturities of financial
liabilities at 31 December 2022
< 3 months 3 months - 1
year
1 - 2 years 2 - 5 years Total
Bond loan (tap issue 15.12.2020) - 70,968 70,968 2,173,728 2,315,664
Bond loan (tap issue 23.06.2021) 60,323 60,323 1,847,669 1,968,315
Total - 131,291 131,291 4,021,397 4,283,979
The book value of borrowings is estimated to approximate their fair value.
2023 2022
Principal amount (tap issue 15.12.2020) 2,247,583 2,102,883
Principal amount (tap issue 23.06.2021) 1,908,130 1,786,041
Bond loan repurchase (06.12.2023) -112,405 -
Transaction costs (tap issue 15.12.2020)
1
-21,228 -21,228
Transaction costs (tap issue 23.06.2021)
1
-56,127 -56,127
Amortization (tap issue 15.12.2020) 12,462 8,215
Amortization (tap issue 23.06.2021) 29,906 17,313
Long-term borrowings 4,008,320 3,837,096
Accrued interest and fees 2,741 5,470
Carrying amount 4,011,061 3,842,567
1
The bond loan is initially measured at fair value net of transaction costs and it is subsequently measured at
amortized cost using the effective interest rate method. Consequently, the transaction cost will be amortized
over the life of the bond loan. The carrying value of the bond loan will be equal to the principal amount of EUR
370 million at maturity in FY2025.
Collateral and guarantees
On 15 December 2020, LINK Mobility Group Holding ASA (LINK) successfully completed the
issuance of EUR 200 million senior unsecured bonds, with a EUR 350 million borrowing limit. Part
of the proceeds from the bond issue were used to repay the remaining outstanding senior facility
agreement (SFA).
On 23 June 2021, LINK issued EUR 170 million new bonds in LINK’s outstanding 5-year senior
unsecured 3.375% fixed rate bond issue, raising the total outstanding amount to EUR 370 million.
The bonds were issued at par.
The bonds have a 5-year tenor and a fixed coupon of 3.375% p.a.; any outstanding bonds are to be
repaid in full at the maturity date.
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Note 12 Financial instruments, risk management objectives,
and policies
Through its operations LINK Mobility Group Holding ASA is exposed to the the following financial risks;
• Interest rate risk
• Foreign exchange risk
• Credit risk
• Liquidity risk
Interest rate risk
Interest rate risk arises as a consequence of long-term debt. In December 2020 the Company
successfully completed the issuance of EUR 200 million senior unsecured bonds, with a EUR 350
million borrowing limit.
On 23 June 2021, LINK issued EUR 170 million new bonds in LINK’s outstanding 5-year senior
unsecured 3.375% fixed rate bond issue, raising the total outstanding amount to EUR 370 million.
The bonds were issued at par; refer to note 11 for further details.
The sensitivity analysis below is based on the exposure to changes in interest rates for non-derivative
instruments at the reporting date. For floating rate liabilities, the analysis is prepared assuming the
amount outstanding at reporting date was outstanding for the whole year. A one percent increase
or decrease represents management’s assessment of reasonable and possible changes in interest
rates.
If interest rates had been one percent higher/lower and all other variables were held constant,
the Company’s profit (and corresponding equity) for the period ended 31 December 2023 would
decrease/increase by KNOK 41 590 (FY2022 KNOK 38 901). This is mainly attributable to the
Company’s exposure to interest rates on its variable rate borrowings.
Foreign exchange risk
The Company is a holding company and does not actively undertake business in foreign currencies;
as a consequence, exposure to fluctuations in exchange rates is limited. Foreign exchange risk
arises from transactions related to operations conducted, and assets and liabilities arising in foreign
currencies.
31 December 2023
(amounts in NOK 1000) NOK/EUR impact
NOK/SEK
impact NOK/CHF impact
Borrowings 41,590 - -
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Annual Report 2023 | Financial statements
230
Credit Risk
The Company is a holding company and owns all shares in LINK Mobility Group AS; credit risk is
deemed to be low.
Liquidity risk
Liquidity risk is the risk that the Company is unable to meet its financial obligations when they mature,
resulting in default.
The Company considers its liquidity risk to be limited, and has sufficient liquidity available on bank
accounts as of year-end. Obligations are covered by transfer of cash from subisidiaries.
The Company has financial debt covenants related to the senior unsecured bonds. Refer to note 11
for information about the bond convenants.
The Company does not have any credit facilities.
Note 13 Trade and other payables
(Amounts in NOK 1000)
Trade and other payables 2023 2022
Trade payables 741 378
VAT payable 41 40
Other accruals - legal fees 434 -
Total trade and other payables 1,216 418
Trade payables and accruals principally comprise amounts outstanding for trade purchases and ongoing costs.
Trade and other payables are due within three months.
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231
Note 14 Income tax
(Amounts in NOK 1000)
Specification of income tax expense
The tax benefit/(expense) is calculated based on profit before income tax and consists of current tax
and deferred tax.
2023 2022
Deferred tax expense (income) -17,101 1,143
Current tax expense 3,403 -
Income tax (income) -13,698 1,143
Income tax payable (balance sheet) 2023 2022
Income tax payable - -
Current tax liabilities (balance sheet) - -
Effective Tax Rate
The difference between income tax calculated at the applicable income tax rate and the income tax
exepense attributable to loss before income tax was as follows:
2023 2022
Profit/(loss) before income tax -62,735 -1,802
Statutory income tax rate* 22% 22%
Expected income tax benefit -13,802 -396
Tax effect on non-taxable income/expenses 95
Effect of changes in tax rules and rates*
Prior year adjustment
Non deductible interest, interest cap rules 8 1,539
Current tax expense, interest cap rules
Change in deferred tax asset not recognized
Income tax expense/income (-) for the year -13,698 1,143
Effective tax rate 22% -63%
* The statutory income tax rate based on the currently enacted tax rate in Norway.
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Annual Report 2023 | Financial statements
232
Specification of the tax effect of temporary differences and losses carried forward
Tax losses carried forward
2023 2022
Unused tax loss carry forward - 127,357
Interest cap 69,441 69,441
Potential tax benefit unused tax losses @ 22 % - 28,019
Potential tax benefit interest cap @ 22 % 15,277 15,277
The benefit from the interest cap carried forward is uncertain and the tax asset is not recognized. The amount
can be carried forward for 10 years.
Tax effect of temporary differences and tax losses carried forward
as of 31 December
Deferred tax liabilities: 2023 2022
Long term receivables and debt in foreign currency - 41,415
Other provisions -152 3,553
Tax loss to carry forward (-) - -28,019
Deferred tax liabilities -152 16,948
Unrecognized temporary differences
2023 2022
Temporary differences for which deferred tax liabilities
have not been recognized
- -
Unrecognized tax liabilities relating to the above
temporary differences @ 22 %
- -
The temporary differences are related to unrealized gains from currency translation. Deferred tax
liability has not been recognized as it is deemed unlikely that the company will generate taxable
income in the foreseeable future.
Note 15 Contingencies and legal claims
The Company is not involved in any disputes or litigation as at the balance sheet date or as at the date
these financial statements are approved, that would lead to the recognition of a liability or require
additional disclosure. Management and the Board of Directors are not aware of any such incidents that
may have a negative impact on the Company.
