Annual Report 2024 |
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LINK in short
Message from the CEO
LINK strategy
LINK’s offering within the messaging industry industry
The future of LINK Mobility
Sustainability statement*
Report from the Board of Directors
Financial statements
03
05
08
11
18
26
146
172
*Sustainability statement is a part of the report from the Board of Directors
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0
100
200
300
400
500
600
700
800
0
1000
2000
3000
4000
5000
6000
7000
8000
LINK in short
4,291
491
486
613
718
4,914
6,282
6,994
2021
2022 2023 2024
2024202320222021
Revenue NOKm
Adjusted EBITDA NOKm
+17%
+13%
7.0 billion
718 million
margin of 10.3%
LINK is a leading provider of mobile
communications, specializing in CpaaS
solutions and mobile messaging solutions.
LINK has more than 600 employees in
29 offices, across 18 countries in Europe with
an additional presence in, Colombia and Mexico.
LINK has more than fifty thousand
customers worldwide and last year sent
20.3 billion messages, averaging more
than 370k messages per customer.
2024 revenue of NOK
Adjusted EBITDA of NOK
Adjusted EBITDA
Annual Report 2024 | LINK in short
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LINK was founded more than 24 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 nine new acquisitions
in Europe, three of which occurred in 2024.
These are:
Reach-Data Ltd.
Net Real Solutions S.L. with subsidiaries
Curiosity Layer - Investigacao e Comunicacao, Unipessoal, LDA, (EZ4U hereafter),
2021
2020
WebSMS
(Austria)
Altiria
(Spain)
Chatbot Xenioo
(Italy)
AMM
(Italy)
MarketingPlatform
(Denmark)
Tismi
(Netherlands)
DEC
NOV
APR
APR
FEB
Reach Interactive
(UK)
Net Real Solutions S.L.
(Spain)
EZ4U
(Portugal)
OCT
SEP
MAY
2022
NOV
2024
2023
1
2
3
LINK’s recent acquisition history
Annual Report 2024 | Message from the CEO
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A message from the CEO
LINK Mobility delivered strong operational
performance in 2024 in the high end of
expectations with 10% organic gross profit
growth and 13% organic adjusted EBITDA
growth, both in fixed currency. Free cash
flow generation reached NOK 400 million.
Following the successful recapitalization
after the divestment of Message Broadcast
in early 2024, the company was once again
well-positioned to execute its accretive M&A
strategy and acquired three companies in the
second half of the year.
We believe that the greatest shareholder
value in LINK Mobility is generated through a
combination of organic and inorganic growth.
In terms of organic growth, we achieved higher
gross profit growth than revenue growth in
2024, primarily driven by the termination of
contracts with low gross profit contributions.
Looking ahead, we observe two key trends
shaping the market. First, there is significant
growth potential in the increased adoption of
digital messaging per capita across Europe.
Notably, Europe (excluding the Nordics) trails behind the Nordics
by 134% in messages per inhabitant, highlighting a substantial
opportunity for growth as more enterprises in these markets see
the benefit and adopt digital messaging to support their business.
Second, the rise of CPaaS solutions, such as RCS, are unlocking
enhanced value for clients by enabling more effective customer
interactions, which is expected to drive additional growth for LINK.
Gross profit contribution from new contract wins within CPaaS grew
by 78% from 2023 to 2024, and CPaaS contracts wins now account
for nearly 40% of all new signed agreements. We are also proud to
have been recognized for our achievements in this space, having
been awarded “Best RCS Business Messaging Solution in Europe”
by Juniper Research.
Annual Report 2024 | Message from the CEO
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In Q1 2024, LINK Mobility was recapitalized following the
divestment of Message Broadcast, bringing leverage down from 4x
to approximately 1x adjusted EBITDA. This strengthened financial
position allowed LINK to reignite its accretive M&A strategy,
building on a decade-long track record of 35 acquisitions across
Europe. During 2024, we acquired three companies: EZ4U, Net Real
Solutions, and Reach-Data, expanding our geographical footprint in
Portugal, Spain, Latin America, and the UK, respectively.
In 2025, acquisition activity is expected to continue, with a current
pipeline of 11 actionable targets, including four currently in due
diligence. Collectively, these targets represent an estimated Cash
EBITDA potential of EUR 30–40 million. We will continue to follow
our disciplined M&A playbook and adhere to our leverage policy of
max 2.0x–2.5x adjusted EBITDA.
After a strong 2024, LINK Mobility is looking ahead, well-positioned
to drive long-term value creation for shareholders. The company
aims to deliver sustainable earnings growth through both organic
expansion and strategic acquisitions. Organically, LINK’s medium-
term goal is to achieve high-single-digit gross profit growth, with
adjusted EBITDA growth outpacing gross profit due to increased
scale efficiencies. Growth opportunities are significant, driven
by rising end-user messaging penetration across Europe and the
gradual rollout of more advanced solutions. On the M&A front, we
continue to see compelling opportunities at attractive, accretive
valuations.Our approach remains both strategic and opportunistic,
while maintaining a conservative financial policy, keeping net debt
within 2.0x–2.5x adjusted EBITDA.
Lastly, I would like to extend my sincere gratitude to our dedicated
employees for their unwavering commitment across various areas
of the business. Their hard work and dedication are instrumental in
driving LINK Mobility’s strong, sustainable growth and success.
Thomas Berge, CEO
Oslo, April 28, 2025
Annual Report 2024 | LINK strategy
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LINK strategy
Annual Report 2024
Because
every
communication
matters
Annual Report 2024 | LINK strategy
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LINK’s strategy
LINK is committed to creating value for our customers by delivering innovative communication
solutions. Through the implementation of LINK’s technology, our customers can significantly enhance
their customer experience by ensuring the timely and effective delivery of important information. From
simple one-way SMS messaging to advanced, feature-rich communication solutions, LINK is dedicated
to providing value to both our customers and their end-users.
Evolving from a leading provider of one-way communication services, LINK has strategically expanded
its vision to become a global leader in Communication Platform as a Service (CPaaS) industry,
delivering seamless and scalable communication solutions worldwide. At the core of our strategy
is a commitment to creating value for our customers. We believe CPaaS solutions offer significant
benefits, making this a key focus area for LINK’s future growth. As a result, the company continues to
invest in developing and enhancing its CPaaS offerings to drive innovation and deliver superior value to
our customers.
A key priority for the company is to leverage new technology, and AI is becoming an integral part of
enhancing the value we deliver to our clients. Our solutions, such as MyLINK Connect, can integrate
with various AI platforms based on customer preferences, allowing for more tailored and automated
communication. We see significant potential in utilizing AI for automated segmentation and
personalized messaging based on company data, customer preferences, and historical interactions.
Additionally, AI will play a crucial role in enabling efficient content generation, which is essential for
scaling RCS and OTT messaging as a complement to SMS.
LINK’s strategy of maintaining a strong local presence in all our markets is a key differentiator from
our peers. With local sales teams operating from close to 30 offices across Europe and with additional
presence in Latin America, we serve enterprise clients and government customers in their native
language, ensuring tailored support and deep market understanding.
0
5
10
15
20
0
10
20
30
40
50
CPaaS Share of Total Closed Won Contracts
by Gross Profit (%)
5
10%
17%
33%
26%
38%
33%
40%
36%
16%
Q4 22
NOKm
Q4 22Q1 23 Q1 23Q2 23 Q2 23Q3 23 Q3 23Q4 23 Q4 23Q1 24 Q1 24Q2 24 Q2 24Q3 24 Q3 24Q4 24 Q4 24
7
6
8
11
14
16
11
14
GP from Closed Won Contracts
Annual Report 2024 | LINK strategy
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This localized approach not only sets us apart, but is also difficult to replicate, as it has been built over
more than a decade through strong customer relationships and deep-rooted market expertise. As a
result, this strategy is a contributor to our low churn rates.
In addition to a team of approximately 90 dedicated sales professionals and self-signups, LINK’s Go-
to-Market (GTM) strategy includes a comprehensive partner network, where partners integrate LINK’s
solutions into their own product offerings. These partners range from independent software vendors to
large-scale software integration providers. Over the years, the LINK partner ecosystem has expanded to
include hundreds of partners, playing a crucial role in our overall GTM approach.
Inorganic growth through M&A has historically been a key driver of LINK’s growth and market expansion
and remains an integral part of our strategy. Acquisitions enable LINK to scale efficiently in existing and
new geographies where strong synergy potential enhances our market position, operational capabilities,
and financial results.
At the core of LINK’s strategy is a commitment to deliver increasing value to our customers. In a
rapidly evolving market, we believe that maintaining a strong local presence is essential, enabling our
customers to adapt quickly to changing conditions. Additionally, we see significant opportunities to
enhance customer value through CPaaS solutions and by leveraging AI technology to drive greater
efficiency and satisfaction. Our ESG criteria form an integral part of LINK ’s strategy.
LINK’s Environmental, Social and Governance (ESG) strategy was initially concluded in 2021. In
2024, an updated strategy was adopted, with a commitment for LINK to reduce emissions based on
Science Based Targets during the term 2025-2027. The commitment to integrate in the annual report a
sustainability statement fully compliant with the ESRS, and to include carbon data from Scope 1, 2 and
3, remains in the updated strategy. The results are visible in this report, with further information in the
sustainability section on our webpage.
The dedicated, enthusiastic and united employees who make up our organization are instrumental in
delivering industry-leading products and services to our customers; LINK employees are deemed to be
key intangible assets. 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 behaviors towards colleagues, customers and suppliers, we regard diversity, equity
and inclusion as levers for innovation, development and profitability.
Please refer to the Sustainability Statement in this report for further information.
Annual Report 2024 | LINK’s offering within the messaging industry
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LINK’s offering within the
messaging industry
How LINK Mobility Is Shaping
Tomorrow’s Communications
The Evolution of Communication
The CPaaS (Communications Platform as a Service) industry has experienced transformative growth in
2024, and 2025 promises to push the boundaries even further. At the core of this evolution is AI-driven
innovations, the rise of RCS Business Messaging, the dominance of Over-The-Top (OTT) messaging
platforms like WhatsApp, and the increasing demand for automation and short-form, rich media content.
Businesses are shifting their focus from traditional, broadcast communications to hyper-personalized,
data-driven interactions. Artificial Intelligence is no longer just a tool - it is the engine powering 24/7
customer support, predictive analytics, and real-time engagement. At the same time, segmentation
and relevance have become essential, with consumers expecting brands to understand and
anticipate their needs.
In this adaptive industry, LINK will remain among the top companies that adapt to the necessary
changes and reap the rewards of doing so.
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Why Brands Must Keep Up
Staying competitive means more than just adopting new technologies, it is about embracing a
customer-first mindset. Consumers now expect interactions that are:
Today’s consumers are influenced by the trends and technologies they encounter in their personal
lives. They expect brands to keep pace, offering the same seamless, intuitive, and dynamic experiences
they get from the apps and platforms they use daily. LINK Mobility is committed to meeting these
expectations. We are continuously investing in advanced technologies and innovative solutions that
help brands deliver instant, relevant, and secure customer interactions across all channels.
LINK Mobility is committed to meeting these expectations. We are continuously investing in advanced
technologies and innovative solutions that help brands deliver instant, relevant, and secure customer
interactions across all channels.
Failure to meet these expectations results in lost engagement, diminished trust, and weakened brand
loyalty. The pace of change is relentless, and innovation is not optional - it is essential.
Instant
Real-time responses across their preferred channels.
Personalized
Tailored content based on their preferences and behaviors.
Relevant
Communications that align with their current needs and
interests.
Engaging
Experiences that capture attention and foster meaningful
connections.
Secure
Trusted communications that protect their data.
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Retail and E-commerce Need Speed, Personalization,
and 1:1 Engagement
In retail and e-commerce, speed and accessibility are everything. Tighter margins and
fierce competition are driving brands to move beyond traditional advertising, shifting
towards direct, permission-based communication via SMS, RCS, Chat apps, email,
and social media. Consumers expect real-time updates, personalized offers, and
seamless shopping experiences.
Finance Demands Trust, Compliance, and Secure
Messaging
Regulations are becoming stricter, and financial institutions face growing pressure
to ensure secure, compliant, and transparent communications. From One-Time
Passwords (OTPs) and Two-Factor Authentication (2FA) to automated alerts and
educational messages. Not only this but greater security layers add authenticity and
integrity whilst also reducing distrust and fosters confidence in interactions between
end-users and organizations.
Leisure Thrives on Creativity and Customer Experience
The leisure industry thrives on engagement and excitement. High interaction rates
demand innovative communication strategies, with brands leveraging AI-powered
chatbots, rich media, and dynamic content to create memorable experiences.
Logistics Requires Proactive Communication for
Eciency
For logistics companies, timely and automated communications are crucial. Real-time
updates, proactive delivery notifications, and AI-driven customer support improve
both operational efficiency and customer satisfaction.
Technology Providers Rely on Simplicity and
Transparency
In the tech sector, customers expect easy access to information and seamless
integrations - transparent, reliable, and automated communications, reinforcing trust
while simplifying complex processes.
How Communication Needs Are
Changing in LINK Target Industries,
and How LINK Responds
Annual Report 2024 | LINK’s offering within the messaging industry
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LINK’s Vision and Approach
At LINK Mobility, we are more than just a CPaaS provider, we are a strategic partner helping businesses
navigate the future of communication. In 2024, we deepened our focus on product marketing, refining how
we connect with our customers’ needs. As we move into 2025, our mission is clear:
•
Empower businesses with intuitive platforms for customer interaction.
•
Drive growth through customer data, AI, automation, and omnichannel solutions.
•
Be the link between business and customer, helping brands engage
and operate seamlessly across every channel with ease.
Our recognition as Europe’s Best RCS Business Messaging Solution by Juniper Research for 2025 validates
our leadership and commitment to innovation.
Rich
Communication
Services
Platinum Award
Best RCS Business Messaging Solution:
Europe
Telco Innovation Awards 2025
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How LINK Mobility Meets
the Ever-Changing Needs of its
Target Industries
LINK Mobility meets ever-changing needs from
customers with new technology
LINK Mobility helps businesses connect with their customers in meaningful, efficient, and secure ways,
tailored to the unique needs of different industries.
AI-Driven Customer Care That Is
Always on and Always Relevant
AI is transforming customer interactions.
MyLINK Connect, our AI-powered chatbot,
delivers 24/7 support, personalized experiences,
and proactive service. In retail and leisure, this
means instant answers, faster resolutions, and
happier customers; driving loyalty and growth.
RCS and OTT Messaging
That Is Secure, Engaging, and
Interactive
RCS and OTT platforms like WhatsApp are
redefining customer engagement. For logistics,
they offer real-time delivery updates, interactive
tracking, and seamless rescheduling options.
In finance, they provide secure, encrypted
communications with verified senders
for sensitive transactions like OTPs.
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Logistics Sector Uses LINK’s
RCS Messaging to Deliver
Timely, Interactive Updates
A major global logistics firm leverages
LINK’s RCS messaging to enhance customer
satisfaction and operational efficiency through
real-time, interactive updates that keep
customers informed every step of the way.
Automation Creates Proactive
Communications That Drive
Results
Automation is not just about efficiency, it is
about creating meaningful, timely connections.
LINK’s MyLINK MarketingPlatform enables
businesses to automate multi-channel
campaigns (SMS, email, RCS) based on
customer behavior and segmentation,
enhancing both engagement and retention.
Logistics Companies Automate Customer Interactions with LINK
Automation is driving proactive and reactive communication strategies in logistics, helping businesses
enhance operational efficiency. In retail, personalized automation fosters customer loyalty and
retention. LINK’s product portfolio offers products such as MyLINK MarketingPlatform, which is primed
to support the automation of multi-channel campaigns such as SMS and Emails based on customer
segmentation from within its Customer Data Platform (CDP).
Short-Form Content and Rich Media Capture Attention
and Drive Action
Consumers crave content that is quick, dynamic, and actionable. In retail and leisure, brands use rich
media to boost engagement, while financial services rely on automated payment reminders and secure
debt collection notifications to streamline transactions.
M T W T F S S
Annual Report 2024 | The future of LINK Mobilty
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The Future
of LINK Mobility
As we look ahead to 2025, LINK Mobility is evolving beyond
traditional CPaaS. We are becoming a leader in Automation as a
Service (AaaS), offering a suite of tools designed to:
Automate
processes for efficiency and
scalability.
Enhance
engagement through AI and
data-driven insights.
Simplify
digital transformation for
businesses of all sizes.
Notifications Mobile marketing
Revenue by use case
Customer service
LINK’s recurring and growing business model
LINK’s business model is inherently recurring, as most customers require ongoing communication
solutions to interact with end-users. Once engaged in LINK’s services, customers recognize the value
of seamless and timely communications, contributing to consistently low churn rates. Instead of
churning, customers typically expand their usage over time. As richer communication channels such as
RCS continue to gain traction in the market, we believe this trend will persist in the years ahead.
70%
22%
8%
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A significant portion of LINK’s revenue—approximately 70% —derives from notification-based
communication. These notifications play a crucial role in industries such as healthcare, utilities, and
logistics, ensuring timely reminders, alerts, updates, and other mission-critical communications. Given
their essential nature, this segment remains stable with consistent growth in the high single digits.
Mobile marketing, on the other hand, represents a smaller share of LINK’s revenue, accounting for
around 20%. While digital messaging has long been a key tool for major retailers, the rise of richer
messaging channels like RCS and WhatsApp ”offering higher engagement and click-through rates”
is now driving increased adoption among smaller retailers across Europe. However, unlike essential
notifications, mobile marketing is more sensitive to shifts in consumer confidence.
Another key growth area is Contact Center as a Service (CCaaS), where CPaaS solutions can drive
significant efficiencies. Many businesses are looking to integrate AI-powered chatbots to automate
customer interactions, reducing costs while improving response times and customer satisfaction.
Despite these advancements, traditional Interactive Voice Response (IVR) systems and automated
phone services still dominate the customer service landscape. As companies seek to modernize and
streamline operations, CCaaS presents a substantial growth opportunity—one that is not only scalable
but also resilient during economic downturns due to its cost-saving potential.
LINK’s Go-To-Market strategy
LINK employs a three-pronged Go-to-Market (GTM) strategy to drive customer acquisition and revenue
growth. This approach includes:
Partner Network
Collaborating with partners
who integrate LINK’s solutions
into their offerings.
Enterprise Sales Model
Leveraging a localized
salesforce to serve businesses
with tailored solutions.
Self-Service Portals
Enabling seamless customer
onboarding through digital
sign-up channels.
This diversified GTM strategy ensures both a strong local market presence and accessibility for
global enterprise clients. Additionally, by providing a seamless and customer-centric experience, LINK
strengthens customer satisfaction, which in turn contributes to low churn.
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Customers stay with LINK over time
The most valuable GTM approach is LINK’s enterprise business model that presents a localized
salesforce. LINK employs a team of approximately 90 sales professionals across local markets in
Europe, ensuring exceptional service and value through direct presence, native-language support, and a
deep understanding of long-term customer relationships. To reach beyond the local enterprise market,
LINK serves global enterprise clients directly through dedicated Global Sales representatives.
The second GTM approach is driven by dedicated partner managers, which builds on our success
experienced in the Nordics, where partners have played a crucial role in driving growth and scalability.
In recent years, we have expanded this program across Europe, structuring it into three distinct tiers
based on the depth of integration and commercial collaboration:
0.0
0.5
1.0
1.5
2.0
2.5
1.7
1.4
1.6
1.5
1.3
2.5
2.2
Q2 23 Q3 23 Q4 23 Q1 24 Q2 24 Q3 24 Q4 24
Enterprise churn (%)
Official
Platinum Partner
Official
Gold Partner
Official
Certified Partner
This tiered approach ensures a structured and scalable partnership model, fostering strong
collaboration and sustained market expansion.
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LINK’s third GTM approach involves Self-Sign Up (SSU) portals that operate under strong local brands
in several markets. These portals are central to LINK’s business model, particularly for serving high-
margin small and medium-sized enterprise (SME) customers. LINK’s top three SSU portals and brands
are SMSAPI, Spot-Hit and WebSMS.
LINK’s three GTM approaches have led to strong gross profit contribution from new contract wins.
SMSAPI, based in Poland, operates in multiple
European languages and has international reach
through its global smsapi.com webpage.
Spot-Hit, a multi-channel CPaaS brand with a strong
foothold in the retail sector, headquartered in France. It
is also available in the Spanish market and offered as
a white-label solution to select customers in the UK.
WebSMS, A user-friendly online platform for SMS
messaging in the DACH region, enabling seamless
communication by allowing users to send and receive
messages with multiple contacts simultaneously.
0
10
20
30
40
50
47
40
36
24
42
36
48
27
38
Q4 22 Q1 23 Q2 23 Q3 23 Q4 23 Q1 24 Q2 24 Q3 24 Q4 24
Gross Profit contribution from new contract wins
A2P CPaaS
powered by
NOKm
Annual Report 2024 | Mergers and acquisitions
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M&A - an integral part of
LINK’s strategy
M&A have played a pivotal role in shaping LINK’s growth and market presence. As a leading player in the
European A2P (Application to Person) messaging industry, LINK has leveraged strategic acquisitions to
drive accretive growth. With over 35 successful acquisitions completed in the past decade, we remain
confident that M&A will continue to be a key driver of LINK’s expansion in the future.
01
02
04
05
06
07
08
09
35
10
12
13
14
15
16
17
18
19
20
21
24
22
23
25
26
32
30
31
11
03
33
34
27
28
29
M&A
Previous acquisitions
Recent acquisitions
RECENT ACQUISITIONS
01
07
13
19
25
31
02
08
14
20
26
32
03
09
15
21
27
33
04
10
16
22
28
34 35
05
11
17
23
29
06
12
18
24
30
Annual Report 2024 | Mergers and acquisitions
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After a slowdown in acquisition activity throughout 2022 and 2023 and following the divestment of
Message Broadcast in Q1 2024, LINK’s balance sheet was strengthened and once again positioning the
company for growth through accretive acquisitions. Since the divestment, and throughout 2024, LINK
has completed three acquisitions: 1) EZ4U, 2) Net Real Solutions, and 3) Reach-Data.
Acquisition of
EZ4U
Acquisition of
Net Real Solutions
Acquisition of
Reach-Data
On May 28, 2024, LINK Mobility Spain SLU acquired the Portuguese
company EZ4U. The acquisition expands LINK’s geographical reach
in Europe to Portugal and offers numerous upselling opportunities
through superior local customer success services in Portuguese.
EZ4U, established in 2010 and headquartered in Porto, specializes
in enterprise messaging solutions. The company focuses on
SMS, RCS, WhatsApp, email, IVR, and chatbots. Through its
advanced software platform and APIs, EZ4U enables seamless
communication between businesses and customers. With a client
base of over 500 companies, it serves diverse industries such as
healthcare, transportation, and retail.
On September 24, 2024, LINK Mobility Spain SLU acquired Net
Real Solutions, headquartered in Castellon, Spain. This acquisition
expands LINK’s geographical reach in Europe and unlocks
opportunities in Latin America, where Net Real Solutions has a
significant market share.
Net Real Solutions, founded in 2001, specializes in SMS marketing,
email marketing, and voice services, catering to sectors such
as finance, retail, technology, and services, among others. Last
year, Net Real Solutions sent over 2 billion SMS messages
globally. In addition to offering operational and automated
multi-channel communications, the company advises B2C, B2B
companies, and startups on designing marketing and omnichannel
communication strategies.
On October 30, 2024, LINK Mobility UK Limited acquired Reach-
Data, headquartered in Doncaster, United Kingdom. This acquisition
strengthens LINK’s foothold in the UK market.
Reach-Data was founded in 2002 and provides businesses with
direct global communication routes. The company specializes in
cost-effective SMS marketing solutions by leveraging their user-
friendly, bulk SMS messaging platform.
Annual Report 2024 | Mergers and acquisitions
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Going forward
Into 2025, LINK expects to maintain an active acquisition strategy. With a pro-forma NIBD/LTM
adjusted EBITDA of 1.35x, the company is well-positioned to pursue accretive M&A opportunities. LINK
continues to evaluate potential targets from a robust and largely exclusive M&A pipeline, focusing on
local market leaders and strategic expansion into new geographies.
The digital messaging industry remains fragmented, and LINK sees significant opportunities for
consolidation both within Europe and beyond. Smaller bolt-on acquisitions in Europe remain a key
priority, offering synergies through cost efficiencies and accelerated upselling potential. As of the end
of 2024, the M&A pipeline includes 11 actionable opportunities with a near-term EBITDA potential of
EUR 30–40 million.
Leveraging its extensive M&A experience, LINK has developed a structured M&A playbook outlining key
criteria for evaluating potential acquisition targets:
We remain committed to executing our disciplined M&A strategy while adhering to our leverage policy,
maintaining a maximum leverage ratio of max 2.0x–2.5x adjusted EBITDA.
M&A Play-book guidelines:
01.
02.
03.
04.
05.
06.
Strong local market position and strong telecom
operator relationships.
Cash EBITDA positive and cash accretive to LINK
from day one.
Solid, well-diversied customer portfolios with
consistently low churn.
~80% overlapping technology strong commercial
enterprise focus.
Synergy potential to create additional value and drive
further growth.
Target valuations between 6-9x cash EBITDA before
synergies pending growth momentum.
Annual Report 2024 | Sustainability statement
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Sustainability statement
Introductory note 27
1. General information 28
1.1. [ESRS 2] 28
1.1.1. [BP-1] General basis for preparation of the sustainability statements 28
1.1.2. [BP-2] Disclosures in relation to specific circumstances 30
1.1.3. [GOV-1] The role of the administrative, management and supervisory bodies 38
1.1.4. [GOV-2] Information provided to and sustainability matters addressed by the
undertaking’s administrative, management and supervisory bodies
44
1.1.5. [GOV-3] Integration of sustainability-related performance in incentive schemes 44
1.1.6. [GOV-4] Statement on due diligence 46
1.1.7. [GOV-5] Risk management and internal controls over sustainability reporting 47
1.1.8. [SBM-1] Strategy, business model and value chain 48
1.1.9. [SBM-2] Interests and views of stakeholders 60
1.1.10. [SBM-3] Material impacts, risks and opportunities and their interaction with strategy and
business model
63
1.1.11. [IRO-1] Description of the process to identify and assess material impacts, risks and
opportunities
71
1.1.12. [IRO-2] Disclosure Requirements in ESRS covered by LINK’s sustainability statement 85
2. Environmental information 94
2.1. Disclosures pursuant to Article 8 of Regulation (EU) 2020/852 (Taxonomy Regulation) 94
2.1.1. Assessment of LINK’s compliance with the EU Taxonomy 95
2.1.2. Disclosures under EU Taxonomy 99
2.2. [ESRS E1] 105
2.2.1. [E1-1] Transition plan for climate change mitigation 105
2.2.2. [E1.SBM-3] Material impacts, risks and opportunities and their interaction with strategy
and business model
105
2.2.3. [E1-2] Policies related to climate change mitigation and adaptation 109
2.2.4. [E1-3] Actions and resources in relation to climate change policies 109
2.2.5. [E1-4] Targets related to climate change mitigation and adaptation 111
2.2.6. [E1-5] Energy consumption and mix 113
2.2.7. [E1-6] Gross Scopes 1, 2, 3 and total GHG emissions 115
2.2.8. [E1-9] Anticipated financial effects from material physical and transition risks and
potential climate-related opportunities
127
3. Social information 128
4. Governance information 129
4.1. [ESRS G1] 129
4.1.1. [G1-1] Business conduct policies and corporate culture 129
4.1.2. [G1-2] Management of relationships with suppliers 139
4.1.3. [G1-3] Prevention and detection of corruption and bribery 142
4.1.4. [G1-4] Incidents of corruption or bribery 144
’
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Sustainability statement
Introductory note
LINK is subject to social responsibility reporting requirements according to the Norwegian Accounting
Act, including its chapter 2 on the annual report, where sustainability reporting is specified in §§ 2-3 to
2-8. The regulations are openly available on www.lovdata.no.
LINK’s sustainability statement is for the first time based obligatorily 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 statement shall be regarded as the first year of reporting
compliant with the CSRD and the ESRS, see also implementation in §§ 2-3 to 2-8 in the Norwegian
Accounting Act.
As far as the structure is concerned, it follows the ESRS, and more specifically the implementation
guidance “EFRAG IG 3: List of ESRS datapoints”, as released by EFRAG on May 2024 (and its technical
adjustments from December 2024). It must be noted, however, that 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 yet been adopted by the EC by way of a relevant delegated act
(DA), the statement for the financial year 2024 has been prepared in a human-readable format only; the
machine-readable format is expected in the future.
The structure of LINK’s sustainability statement is in principle the same as last year, with the
following exceptions:
•
the minimum disclosure requirements, relevant to each material matter, as specified under the ESRS 2
MDR, have been disclosed not in the beginning of each relevant section “E”, “S” and “G”, but alongside
relevant topical standards;
•
some disclosure requirements relevant to topical standards, such as GOV-1, GOV-3 and IRO-1, that
are applied in conjunction with the disclosures required by ESRS 2, have been included under ESRS 2;
•
the environmental part has been vastly developed, which results from identifying one additional
material topic, namely “Climate change mitigation”, and from LINK’s intention to include environmental
data directly in this statement rather than in an external GHG report.
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
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1. General information
1.1. [ESRS 2]
1.1.1. [BP-1] General basis for preparation of the sustainability statements
1.1.1.1. 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,
directly or indirectly, 100% of 37 LINK subsidiaries located across 14 EU countries, as well as in Norway,
the United Kingdom, Switzerland, the Republic of North Macedonia, Colombia and Mexico (the “Group”,
the “Company”). Comparing to the previous reporting period:
•
Marketing Platform Aps, located in Denmark, was merged with LINK Mobility A/S, located in Denmark
(effective January 1st 2025);
•
LINK Mobility SAS, located in France, was merged with Netsize SAS, located in France, and it was
renamed to LINK Mobility SAS;
•
Curiosity Layer - Investigacao e Comunicacao, Unipessoal, LDA, located in Portugal, was acquired;
•
Altiria TIC Sociedad Limitada, located in Spain, was merged with LINK Mobility Spain S.L.U., located
in Spain;
•
Net Real Solutions SL, located in Spain, was acquired together with its 3 subsidiaries: Atenea Mobile
SAS located in Colombia, Kronos Mobile SAS, located in Colombia, and Pandora Mobile Group S de
R.L. de C.V., located in Mexico;
•
Reach-Data Ltd., located in the United Kingdom, was acquired;
•
Netsize UK Ltd, located in the United Kingdom, was renamed to LINK Mobility UK Ltd;
•
LINK Mobility UK Ltd, located in the United Kingdom, was renamed to HSL Messaging UK Ltd;
•
Razvoen Centar na eMailPlatform DOOEL, located in the Republic of North Macedonia, was renamed
to Link Mobility Development Center DOOEL.
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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 Vienna, Austria
9 Allterpay EOOD Sofia, Bulgaria
10 LINK Mobility Bulgaria EAD Sofia, Bulgaria
11 Atenea Mobile SAS Medellin, Antioquia, Colombia
12 Kronos Mobile SAS Medellin, Antioquia, Colombia
13 LINK Mobility Holding Aps Copenhagen, Denmark
14 LINK Mobility A/S Copenhagen, Denmark
15 Tismi A/S Copenhagen, Denmark
16 LINK Mobility Oy Tampere, Finland
17 Labyrintti International Oy Tampere, Finland
18 LINK Mobility 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 Pandora Mobile Group S de R.L. de C.V. Mexico City, Mexico
25 Tismi B.V. Bunnik, Netherlands
26 Tismi Mobile B.V. Bunnik, Netherlands
27 LINK Mobility Poland Sp.z.o.o. Gliwice, Poland
28
Curiosity Layer - Investigacao e
Comunicacao, Unipessoal, LDA
Matosinhos, Portugal
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.
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No. LINK entity Place of business/ country of registration
29 Link Mobility Development Center DOOEL Kumanovo, Republic of North Macedonia
30 Tera Communications DOOEL Skopje, Republic of North Macedonia
31 LINK Mobility SRL Bucharest, Romania
32 Teracomm RO SRL Bucharest, Romania
33 LINK Mobility Spain S.L.U. Madrid, Spain
34 Net Real Solutions S.L. Castelló, Spain
35 LINK Mobility AB Stockholm, Sweden
36 LINK Messaging AG Rorschach, Switzerland
37 LINK Mobility UK Ltd London, United Kingdom
38 HSL Messaging Limited Edinburgh, United Kingdom
39 Reach-Data Ltd Doncaster, United Kingdom
1.1.1.2. 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).
1.1.1.3. 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. 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.
1.1.2.2. Disclosures related to metrics that include value chain data estimated
using indirect sources
The energy and GHG emissions data included in the environmental part of the statement is partly based
on indirect sources, such as emission factors. The details regarding scope, sources and accuracy of
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such data, are described under disclosures E1-5 and E1-6 (chapters 2.2.6 and 2.2.7). LINK has been
working on improving the methodology of energy and GHG emissions’ data collection and relevant
calculations, and aims to continue to implement incremental improvements within this area. No other
metrics disclosed directly in this sustainability statement include value chain data estimated with the
use of indirect sources.
1.1.2.3. Disclosures related to measurement uncertainty
The energy and GHG emissions data included in the environmental part of the statement is subject to
some level of uncertainty. The details regarding scope and sources of measurement uncertainty, as
well as related assumptions, approximations and judgements, are described under disclosures E1-5
and E1-6 (chapters 2.2.6 and 2.2.7). No other quantitative metrics or monetary amounts disclosed
directly in this sustainability statement are subject to a high level of measurement uncertainty.
1.1.2.4. Changes in preparation or presentation of sustainability information comparing to
previous reporting periods
The structure of LINK’s sustainability statement is- in principle- the same as in the previous year, with
some exceptions:
•
the minimum disclosure requirements, relevant to each material matter, as specified under the ESRS 2
MDR, have been disclosed not in the beginning of each relevant section “E”, “S” and “G”, but alongside
relevant topical standards;
•
some disclosure requirements relevant to topical standards, such as GOV-1, GOV-3 and IRO-1, that
are applied in conjunction with the disclosures required by ESRS 2, have been included under ESRS 2;
•
the “E” part has been vastly developed, which results from identifying one additional material topic,
namely “Climate change mitigation”, and from LINK’s intention to include the environmental data
directly in this statement, rather than in the external GHG report- these have lead to including more
disclosure requirements covered by the ESRS E1.
As far as the content of this sustainability statement is concerned, changes to the EU Taxonomy part
are described in chapter 2.1.2.c. Furthermore, one qualitative metric, namely “Setting targets within the
SBT initiative” (as described in chapter 2.2.5.1.a), as well as one quantitative metric, namely “Percentage
of employees who had performance review under myLINKjourney” (as described in chapter 1.1.2.8.b),
have been added. No metric or target has been significantly redefined or replaced and no need for
further revisions of figures disclosed last year have been identified.
1.1.2.5. Errors and corrections for previous reporting periods
This statement constitutes the first reporting period under the ESRS, therefore no corrections have
been made. Changes in the Taxonomy part have been described in chapter 2.1.
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1.1.2.6. 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 external assurance provider has been performed in order
to confirm compliance with any ISO/IEC or CEN/CEMELEC standard.
1.1.2.7. Incorporation by reference (list of DRs or DPs mandated by a DR)
No information has been incorporated by reference.
1.1.2.8. Materiality assessment of topics (among 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 (among 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).
b.Disclosures relevant to the material sustainability matter “Employees’ 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
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recognized as one of LINK’s most valuable assets, which is reflected in LINK’s strategy and business
model. At LINK, people are at the heart of everything we do. By cultivating the culture of engagement,
collaboration, and continuous development, LINK ensures that the Group remains a great place to work,
where talented individuals thrive and drive innovation.
> Policies related to the material sustainability matter (phase-in)
The material sustainability matter: “Employees’ 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 chapter 4.1.1.1.
> 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 “Employees’ training and skills
development” were taken in 2024:
•
Employees’ training – described in chapter 4.1.1.2.
•
Employee Code of Conduct – described in chapter 4.1.1.2.
•
Link Voice – described chapter 4.1.1.2.
•
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 and further developed in 2024; the results have been monitored on a rolling bases. Introducing
“myLINKjourney” reflects LINK’s commitment to take professional development seriously and ensure
that all LINKers have the opportunity to grow within the company. Through development conversations,
which are part of myLINKjourney, LINK focuses on goal setting, feedback, and continuous learning.
> 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 “Employees’ training and skills development”, LINK uses the
following metrics:
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec) –
described in chapter 4.1.1.2;
•
LINK Voice participation rate – described in chapter 4.1.1.2;
•
Employee engagement score – described in chapter 4.1.1.2;
•
Percentage of employees who had performance review under myLINKjourney – the metric reflects
LINK’s progress in ensuring development of its workforce. It is calculated as a percentage of employees
that had performance review within the framework of myLINKjourney in relation to all employees. All
employees are required to complete such a review once a year. The metric is monitored in an internal
electronic system on a rolling bases, with an end-year number as a reference point.
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> Time-bound targets set related to the material sustainability matter (phase-in) and
progress made towards achieving those targets
Targets relevant to actions: “Employees’ training”, “Employee Code of Conduct”, and “Link Voice”, as
well as their respective metrics and progress towards achieving them is described in chapter 4.1.1.2.
LINK tracks the effectiveness of the action “myLINKjourney” that addresses the material matter
“Employees’ training and skills development”. The action is tracked with the use of the metric
“Percentage of employees who had performance review under myLINKjourney)”. The metric includes
all LINK employees. The target of this metric is set to 90% as of December 31st each year, which is
monitored on annual bases by group CPO. 2024 is the first reporting year fully compliant with CSRD 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 2024 the metric amounted to 93%, which exceeds the target.
c. Disclosures relevant to the material sustainability matter “Consumers and 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’ 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 chapter 4.1.1.1. 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
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.
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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 April 27, 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: https://www.linkmobility.com/legal/privacy.
+ 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.
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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 December 14, 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 April 27, 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.
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: https://www.linkmobility.com/legal/privacy/information-security.
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> 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’ privacy”
were taken in 2024:
•
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 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; conducted for the first time 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, after being fully
integrated in the Group’s operations, 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 chapter 4.1.1.2.
•
Employee Code of Conduct – described in chapter 4.1.1.2.
•
Supplier Code of Conduct – described in chapter 4.1.1.2.
•
Supplier Due Diligence process – described in chapter 4.1.1.2.
> 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’ privacy”, LINK uses the following metrics:
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec)
–described in chapter 4.1.1.2.
•
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 chapter 4.1.1.2.
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LINK tracks the effectiveness of the action “GDPR audits” that addresses the material matter
“Consumers and 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 December 31st each year, which is monitored on annual bases by the group DPO. 2024 is the first
reporting year fully compliant with CSRD 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 2024 the metric
accounted to 99,71%, which fulfills the target in almost 100 % (the audit was not performed in some of
the newly acquired entities).
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.
a. Number of executive and non-executive members
The numbers regarding respective members of administrative, management and supervisory
bodies include:
•
Board of Directors – as of December 31st, 2024 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 December 31st, 2024 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 December 31st, 2024 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.
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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.
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 M
2 Jens Rugseth Board member nE M
3 Robert Joseph Nicewicz Jr Board member nE M
4 Sabrina Gosman Board member nE F
5 Grethe Viksaas Board member nE F
6 Sara Murby Forste Board member nE F
7 Tor Malmo
Chair of the
Nomination
Committee
nE M
8 Oddny Svergja
Member of the
Nomination
Committee
nE 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 Arnhild Sivertsen** GLT member E F
* until July 25th, 2024
** since June 25th, 2024
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b. 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.
c. 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. Such experience includes, among
others, several years of serving as members of the respective LINK’s bodies, or holding other functions
across the Group, or- in the case of a new member- extensive experience in HR matters, adequate to the
position held.
d. Board’s gender diversity ratio
As of December 31st, 2024, 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].
e. Percentage of independent board members
As of December 31st, 2024, 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 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.
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•
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. The Audit
Committee has a control function. 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, inter alia, notions of materiality assessment based on
double materiality rule, as well as notions related to risk management. 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. Moreover, the ESG Policy includes a diagram specifying the
division of responsibilities regarding sustainability issues, as presented below.
c. Management’s role in governance processes, controls and procedures used to
monitor, manage and oversee impacts, risks and opportunities; reporting lines
Principles associated with the governance of the 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
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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.
The below included diagram, derived from LINK’s ESG Policy, presents the division of responsibilities
regarding sustainability issues, namely:
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 under minimum disclosure requirements
relevant to each of the material sustainability matters (chapters 1.1.2.8, 2.2.5.1, 4.1.1.2). The general
oversight and progress monitoring is exercised by the CEO, to whom a dedicated sustainability and risk-
related function reports.
Board of Directors
Audit Commitee
Decision making
Control
Consultation
Recommendation,
coordination, supervision,
analyses, control
Decision making
and implementation
Decision making
and implementation
Global
Leadership Team
Legal and
Compliance
Chief Executive Officer
Senior management responsible for
vrious functional areas/regions
•
non-financial reporting;
•
risk management;
•
materiality assessment;
•
other sustainability issues.
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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. The function has both
formal legal education and solid experience in the legal and compliance area, including, but not limited
to sustainability regulations’ compliance and risk management. The described expertise is leveraged
to LINK governing bodies by regular updates on the developments in the regulatory framework, by
providing recommendations, and by advising on various sustainability-related issues.
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. Moreover,
the function has many years of experience in the ICT sector, which LINK operates in, and hence,
demonstrates broad knowledge in the IROs specific to that sector. Both company-level and sector-
specific skills and knowledge ensure expertise relevant to LINK-s specific material impacts, risks and
opportunities.
1.1.3.4. [G1.GOV-1] The role and expertise of the 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. All members of the bodies responsible
for the business conduct matters have relevant expertise.
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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 are provided with
quarterly status. They shall also 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 2024, with the purpose to
address them since 2024 and through 2025, are listed 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.
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.
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1.1.5.2. [E1.GOV-3] Integration of sustainability-related performance in incentive schemes-
climate-related considerations
a. 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. No GHG emission reduction targets
have been set.
b. Percentage of remuneration recognised that is linked to climate related
considerations
No remuneration is recognized as linked to climate-related considerations (0%).
c. Explanation of climate-related considerations that are factored into remuneration
of members of administrative, management and supervisory bodies
No climate-related considerations are factored into remuneration of members of administrative,
management and supervisory bodies.
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 Conduct¹. 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
¹OECD (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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(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 Transparency Act Report is available on LINK’s corporate website: https://www.linkmobility.com/
legal/sustainability/transparency-report.
The parts of the sustainability statement relevant to the core elements of LINK’s sustainability due
diligence processes are listed in a table below.
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, E1.GOV-3 (chapter 1.1.5)
• ESRS 2 SBM-3, E1.SBM-3 (chapter 1.1.10, 2.2.2)
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, E1-E5.IRO-1 (chapter 1.1.11)
• ESRS 2 MDR-P (chapters 1.1.2.8.b indent 2,
1.1.2.8.c indent 2, 4.1.1.1, 4.1.1.3.c (see also
references in 2.2.3, 4.1.2, 4.1.3, 4.1.4))
3
Identifying and assessing adverse
impacts
• ESRS 2 IRO-1, E1-E5.IRO-1 (chapter 1.1.11)
• ESRS 2 SBM-3 (chapter 1.1.10), E1.SBM-3
(chapter 2.2.2)
4
Taking actions to address those
adverse impacts
• ESRS 2 MDR-A (chapters 1.1.2.8.b indent 3,
1.1.2.8.c indent 3, 2.2.4.1, 4.1.1.2.a (see also
references in 4.1.2, 4.1.3, 4.1.4))
5
Tracking the effectiveness of these
efforts and communicating
• ESRS 2 MDR-M (chapters 1.1.2.8.b indent 4,
1.1.2.8.c indent 4, 2.2.5.1.a, 4.1.1.2.b (see also
references in 4.1.2, 4.1.3, 4.1.4))
• ESRS 2 MDR-T (chapters 1.1.2.8.b indent 5,
1.1.2.8.c indent 5, 1.1.2.8.c indent 5, 2.2.5.1.b,
4.1.1.2.c (see also references in 4.1.2, 4.1.3, 4.1.4))
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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: commercial risk, financial
market risk, acquisition risk, IT risk, information security risk, legal risk, HR risk, ESG/ sustainability risk,
privacy risk and operational risk. Risk related to the 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.
The division of responsibilities is presented in the diagram included in chapter 1.1.3.2 above.
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 the 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.
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. On a
detailed level, it encompasses risk related to the completeness and consistency of LINK’s sustainability
reporting, risk associated with the accuracy of the consolidated data, especially related to data
stemming from multiple systems and sources, as well as risk resulting from potential errors in manual
data input processes. In order to mitigate such risks, in H2 2023 LINK commenced a project “LINK’s
road to CSRD compliance”, which was continued in 2024, as described below, and which resulted in the
preparation of this statement.
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 risks related to the 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
included preparation of the sustainability statement for 2023 that- in principle- followed the structure
specified in the CSRD/ESRS. The statement for FY 2023 formed basis for gap analyses performed in
2024, and was an important step towards ensuring compliance in the first reporting period when LINK
falls under the formal obligations resulting from the CSRD/ESRS, that is FY 2024.
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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.
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
2024 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 “Climate
change mitigation”, “Energy”, “Management of relationships with suppliers”, as well as “Consumers’
and 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 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.
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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.
No major changes to the significant group of products offered in 2024 in comparison with the previous
reporting period are recognized. Notwithstanding the above, the structure of LINK’s sustainability
statement is fully compliant with 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 14 EU countries, Norway, the United Kingdom, Switzerland, the Republic of North Macedonia,
Colombia and Mexico.
In 2024 LINK has identified four operating segments, which can be differentiated based on market
maturity and product development, as well as on geography (comparing to the previous reporting
period, North America segment is no longer present):
•
Northern Europe is comprised of enterprise traffic in Norway, Sweden, Denmark, and Finland;
•
Central Europe is comprised of enterprise traffic in Bulgaria, Romania, North Macedonia, Poland,
Hungary, Germany, and Austria;
•
Western Europe is comprised of enterprise traffic in Spain (including subsidiaries in Colombia and
Mexico), France, the United Kingdom, Italy, Portugal, and the Netherlands;
•
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. As of December 31st, 2024, LINK recognizes all 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 2024 it accounted for 22 % of
LINK’s revenue (which is more than the 10% required by ESRS 2 SBM 1 AR 13 (a));
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•
Central Europe is recognized as significant based on the fact that in 2024 it accounted for 24 % 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 2024 it accounted for 30 % 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 2024 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 20 countries. The European market, including Northern, Central and Western Europe, together with
Global Messaging that is also based in Europe- as described above- accounted for 100 % of LINK’s
revenue in 2024. 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 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 2024 in comparison with the
previous reporting period (the North American market that is no longer present was not recognized
as significant last year). Notwithstanding the above, the structure of LINK’s sustainability statement
is fully compliant with the requirements provided in the ESRS for the first time, so no prior reporting
period is available.
In 2024 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:
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•
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 more than 30 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 2024 in comparison
with the previous reporting period. Notwithstanding the above, the structure of LINK’s sustainability
statement is fully compliant with the requirements provided in the ESRS for the first time, so no prior
reporting period is available.
c. Headcount of employees
The number of LINK’s employees (headcount) as of December 31st, 2024, 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 14 15 0 29
2 Bulgaria 33 55 0 88
3 Colombia 3 2 0 5
4 Denmark 7 16 0 23
5 Finland 3 8 0 11
6 France 30 47 0 77
7 Germany 12 17 0 29
8 Hungary 0 4 0 4
9 Italy 16 26 0 42
10 Mexico 0 0 0 0
11 Netherlands 1 7 0 8
12 North Macedonia 10 28 0 38
13 Norway 31 68 0 99
14 Poland 26 47 0 73
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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 sectors², 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 Country Female Male Other Total number of employees
15 Portugal 0 4 0 4
16 Romania 2 4 0 6
17 Spain 23 42 0 65
18 Sweden 10 25 0 35
19 Switzerland 2 0 0 2
20 United Kingdom 5 19 0 24
Total 228 434 0 662
[%] 34.44% 65.56% 0 100%
No
Operating
segment (ISRS 8) Revenue 2024r
ESRS sector group
(initial proposal)
ESRS sector
(initial proposal)
1 Northern Europe 1 535 959
Technology
Media and
Communication
(TMC)
/
Information
technology (TIT)
2 Central Europe 1 689 181
3 Western Europe 2 105 343
4 Global messaging 1 663 324
Total [NOK 1000] 6 993 807
² In accordance with a paper from EFRAG SRB meeting of September 17, 2024 “European Sustainability Reporting Standards – SEC 1. Sector
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No
Group of products
(business line)
Revenue 2024r
ESRS sector group
(initial proposal)
ESRS sector
(initial proposal)
1
Mobile messaging
transactions
6 708 374
Technology
Media and
Communication
(TMC)
/
Information
technology (TIT)
2 Payment services 22 958
3 Licences 229 026
4
Consulting
services
33 449
Total [NOK 1000] 6 993 807
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)³, 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 chapter 4.1.1.1. Furthermore, the sustainability-related targets are described in chapters
1.1.2.8.b indent 5, 1.1.2.8.c indent 5, 2.2.5.1.b and 4.1.1.2.c.
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;
³https://sdgs.un.org/
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•
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;
•
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);
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•
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:
•
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).
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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
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 motivated 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” is a platform for collecting anonymous feedback from LINK employees twice per year, to
give management and the employees themselves a tool for following the development in engagement
statistics and a variety of other topics.
“myLINKjourney” constitutes a framework for employee development, with aligned processes for
annual goal setting, annual performance reviews, and regular follow-up through the year.
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.
In accordance with a paper from EFRAG SRB meeting of September 17, 2024 “European Sustainability Reporting Standards – SEC 1. Sector
Classification, General Requirements and Disclosure – Exposure Draft
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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 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.
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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.).
Customers
(private/business/ &
public)
(brand/ content providers
etc.)
LINK
(electronic communication
services’ provider)
End users
(subscribers/ consumers)
„TELCO” providers
•
operators (MNO/MVNO)
•
aggregators
•
OTT vproviders
•
RCS providers
•
other telco providers
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)
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•
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;
•
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.
https://lovdata.no/dokument/NLE/lov/2021-06-18-99
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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 (described in 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 (described in chapter 1.1.8.3.c);
•
Suppliers and supply-side business partners – the group includes “telco” providers, IT providers, and
other providers (described in 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 (described in 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
(described in 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 bonds;
•
Employees – the group includes LINK’s workforce.
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;
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•
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 electronic
communication industry, identification of the “simply understood” supply chain in its entirety is not
practically feasible. Electronic communication 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, electronic communication 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 electronic communication
market and are therefore subject to regulations that require each entity to fulfil 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 electronic communication 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;
•
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.
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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 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
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.
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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.
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 2024, as well as a description of impacts, risks, and opportunities
related to them, are listed in a table below. The information of where the identified IROs are concentrated
(own operations/ value chain), is included in the next chapter (1.1.10.2).
No ESG matter Impact Risk/ Opportunity
1
Climate
change
mitigation
• Negative impact: LINK may
contribute to the increase in
the global carbon footprint,
because of the greater need
for infrastructure (cooling
systems, backup power
solutions), resulting from the
climate warming or extreme
weather conditions.
• Transition risk: legal and policy risk resulting from the
introduction of regulatory changes that impose strict
requirements related to reducing emissions and energy
consumption, and achieving “greener” energy mix
(identified transition event: enhanced emissions- and
energy-related regulatory obligations). It may lead to the
increased operating costs related to the necessity to
ensure compliance.
• Transition risk: technology risk resulting from the
necessity to catch up with a transition to lower-carbon,
energy efficient solutions, including the ones affecting
ICT infrastructure, and an increase in the use of shared
infrastructure (identified transition event: costs of
transition to lower emissions technology). It may lead
to efficiency loses related to the implementation of
new uncertain solutions and the reduced infrastructure
redundancy.
• Transition risk: market risk related to the increase in the
prices of energy from fossil sources and necessity to
lower energy consumption and achieve “greener” energy
mix (identified transition event: increased energy prices).
It may lead to the increased operating costs related to
higher energy prices and changes in the energy mix.
2 Energy
• Negative impact: LINK
may contribute to the
increase in the global energy
consumption, because
of the greater need for
infrastructure (cooling
systems, backup power
solutions), resulting from the
climate warming or extreme
weather conditions.
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No ESG matter Impact Risk/ Opportunity
2
• Transition risk: reputation risk related to the growing
awareness of climate related issues and uncertain
stakeholders’ perception of the company’s attitude to
the environmental issues (identified transition event:
negative stakeholder feedback). It may lead to the
increased operating costs related to the necessity to
ensure relevant training and marketing activities.
• Physical risk: acute risk resulting from heatwaves
(identified climate hazard: heatwaves/ extreme weather)
or other extreme weather conditions that may lead
to disruptions in energy supply and data centres’
operations. It may lead to problems with business
continuity, and consequently financial loss, due to the
disruptions in the energy supply.
• Physical risk: chronic risk resulting from the climate
warming (identified climate hazard: increased air
temperature), posing challenges to the operation of data
centres. It may lead to the increased operating costs
related to higher energy consumption and necessity to
ensure cooling and power backup solutions.
• 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.
3
Employees’
training
and skills
development
• Negative impact: LINK
may negatively impact
the society by applying
unfavourable HR practices
or lowering people
management standards.
• 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.
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No ESG matter Impact Risk/ Opportunity
4
Consumers
and end users’
privacy
• Negative impact: LINK
may negatively impact
consumers/ end-users’
privacy rights by any
irregularities concerning
the security of data within
LINK’s systems or privacy
of information disseminated
via 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.
5
Corporate
culture
• Negative impact: LINK
may negatively impact
the society by lowering
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.
6
Protection
of whistle-
blowers
• Negative impact: LINK may
negatively impact its internal
and external stakeholders-
and in a broader sense-
society, by neglecting 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.
• Opportunity to effectively handle information provided
by a whistleblower, leading to a prevention and/or a
detection of any irregularity, and consequently to savings
in costs and/or preserving LINK’s reputation.
7
Management
of
relationships
with suppliers
• Negative impact: LINK may
have a negative impact on
its supply chain, and in a
broader sense- on people
and the environment, by
applying unfair or anti-
competitive practices.
• 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.
8
Corruption
and bribery
• Negative impact: LINK
may negatively impact the
society by being involved in
an incident of corruption or
bribery.
• 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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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 under minimum disclosure requirements relevant for each of the material
sustainability matters (chapters 1.1.2.8, 2.2.4.1, 4.1.1.1., 4.1.1.2, 4.1.1.3).
No
Impact/ Risk/
Opportunity
(IRO)
[current/ anticipated]
Effects on LINK’s busi-
ness model/ value chain/
strategy/ deci-sion-
making
Reasonably
expected
time hori-
zons
Nature of
LINK’s involve-
ment (where
IROs concen-
trated?) LINK’s response
1
IROs related to
the ESG matter
“Climate
change
mitigation”
• Need of taking energy
consumption, energy
mix and carbon footprint
into consideration in
own operations and
procurement.
• Need of having business
continuity plans.
• Need of ensuring
regulatory compliance.
• Need of engaging in
relevant training and
marketing activities.
• Need of participating
in various climate-
related initiatives and
benchmarks.
• medium-
term
• long-term
• own
operations
• value chain
• LINK has included energy matters
in the ESG Policy.
• LINK has prepared the GHG
reports.
• LINK has been part of the United
Nations Global Compact (UNGC).
• LINK has submitted a
commitment letter to the Science
Based Targets Initiative (SBTi),
has been accepted, and will
work towards developing its
environmental goals within this
framework.
• LINK has included certain
environment-related topics in
employees’ training.
• LINK aims to take energy
consumption/ energy mix/ carbon
footprint into consideration in
procurement (certain IT suppliers)
and has taken first steps towards it
(Supplier Due Diligence process).
• LINK aims to take energy
consumption/ energy mix/ carbon
footprint into consideration in
own operations, including product
development and data storage/
infrastructure.
• LINK has developed business
continuity plans in certain areas.
2
IROs related to
the ESG matter
“Energy”
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No
Impact/ Risk/
Opportunity
(IRO)
[current/ anticipated]
Effects on LINK’s busi-
ness model/ value chain/
strategy/ deci-sion-
making
Reasonably
expected
time hori-
zons
Nature of
LINK’s involve-
ment (where
IROs concen-
trated?) LINK’s response
3
IROs related to
the ESG matter
“Employees’
training
and skills
development
• Need of ensuring
relevant training and
development programs for
LINK’s workforce.
• short-term
• medium-
term
• long-term
• own
operations
• 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”.
4
IROs related to
the ESG matter
“Consumers
and 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.
• short-term
• medium-
term
• long-term
• own
operations
• value chain
• LINK has included privacy and
information security matters in the
ESG Policy.
• LINK has developed the Personal
Data Protection Policy.
• LINK has developed the Infor-
mation Security Policy.
• LINK has included privacy and
information security topics in
employees’ training.
• LINK has appointed the Data Pro-
tection Officer.
• LINK takes privacy and infor-
mation security topics into con-
sideration in procurement (Sup-
plier Due Diligence process).
• LINK takes privacy and infor-
mation security topics into
con-sideration in own operations
(GDPR audits).
• LINK has developed and docu-
mented a variety of specific
pro-cesses related to adequate
man-agement of privacy and infor-
mation security issues.
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No
Impact/ Risk/
Opportunity
(IRO)
[current/ anticipated]
Effects on LINK’s busi-
ness model/ value chain/
strategy/ deci-sion-
making
Reasonably
expected
time hori-
zons
Nature of
LINK’s involve-
ment (where
IROs concen-
trated?) LINK’s response
5
IROs related to
the ESG matter
“Corporate
culture”
• Need to introduce
policies and processes
aimed at the development
of LINK’s corporate
culture.
• short-term
• medium-
term
• long-term
• own
operations
• LINK has included business cul-
ture matters in the ESG Policy.
• LINK has defined its core values
and has embedded them in its
strategy.
• LINK has introduced the Employ-
ee’ Code of Conduct.
• LINK has conducted “LINK Voice”
survey.
• LINK has included certain ESG
topics in employees’ training.
• LINK provides training on the “So-
cial Styles” model to employees
and managers with communica-
tion to a wider group.
6
IROs related to
the ESG matter
“Protection
of whistle-
blowers”
• Need to ensure adequate
policies and processes on
whistleblowing.
• short-term
• medium-
term
• long-term
• own
operations
• 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.
7
IROs related to
the ESG matter
“Management
of
relationships
with suppliers
• Need to adequately
manage supply chain.
• Need to document
certain processes
related to the supplier
management.
• short-term
• medium-
term
• long-term
• own
operations
• value chain
• 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.
8
IROs related to
the ESG matter
“Corruption
and bribery”
• Need to ensure adequate
policies and processes on
anti-corruption and anti-
bribery.
• short-term
• medium-
term
• long-term
• own
operations
• value chain
• 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.
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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. 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 indication of time horizons relevant to identified IROs is included in the table in chapter 1.1.10.2
above. The short-, medium- and long-time horizons shall be as understood for the purposes of this
sustainability reporting (chapter 1.1.2.1 and climate-related particularities in chapter 1.1.11.9.a).
d. Nature of activities or business relationships through which LINK is involved with
material impacts
The indication of the nature of LINK’s involvement relevant to the identified IROs is included in the
table in chapter 1.1.10.2 above. 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), any more detailed analyses have 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.
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b. Anticipated financial effects of material risks and opportunities on financial
position, financial performance and cash flows over short-, medium- and long-term
In 2024, LINK assessed the financial materiality on a general level, as described under disclosure IRO-
1 (chapter 1.1.11) and has not conducted more detailed, quantitative 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
System (CMS) are of key importance. The risk management framework includes processes that
allow to identify and assess impacts and risks annually, to develop measures to mitigate them, and
to take advantage of material opportunities. The processes are monitored as part of the CMS and
risk management framework. Regular review is conducted 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 under disclosure SBM-1 (chapter 1.1.8).
The description of climate-related scenario and resilience analyses are described under disclosure
E1.SBM-3 (chapter 2.2.2) and E1.IRO-1 (chapter 1.1.11.9). 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 2023 the following ESG topics were identified as material:
•
Climate change – Energy
•
Own workforce – Equal treatment and opportunities for all – Training and skills development
•
Consumers and end users – Information-related impacts for consumers and/or end-users – Privacy
•
Business conduct – Corporate culture
•
Business conduct – Protection of whistle-blowers
•
Business conduct – Management of relationships with suppliers
•
Business conduct – Corruption and bribery
In 2024 one new material topic was identified, namely “Climate change mitigation”. The material topics
identified in 2024 have constituted focus points since their identification and will be followed up in the
financial year 2025.
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No Material topics 2023 Material topics 2024
1 Climate change mitigation
2 Climate change – Energy Climate change – Energy
3
Own workforce – Equal treatment and
opportunities for all – Training and
skills development
Own workforce – Equal treatment and
opportunities for all – Training and skills
development
4
Consumers and end users –
Information-related impacts for
consumers and/or end-users –
Privacy
Consumers and end users – Information-related
impacts for consumers and/or end-users –
Privacy
5 Business conduct – Corporate culture Business conduct – Corporate culture
6
Business conduct – Protection of
whistle-blowers
Business conduct – Protection of whistle-blowers
7
Business conduct – Management of
relationships with suppliers
Business conduct – Management of relationships
with suppliers
8
Business conduct – Corruption and
bribery
Business conduct – Corruption and bribery
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
LINK’s materiality assessment process follows a double materiality principle, covering both impact
and financial perspective. The top-bottom approach is 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 to various departments and for the Company as a whole. To a very limited
extent, external stakeholders have also been invited to take part in the process (no external responses,
however, have been obtained so far). The assessment considers 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 inter-connected. On the one hand, the materiality of impacts, risks and
opportunities identified within the due diligence process shall be taken into consideration within the
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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
(carried out in 2023 and reviewed or repeated in 2024):
•
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;
•
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 (both
actual and potential, positive and negative impacts have been considered); 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 – in 2023 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. It
was prepared as a comprehensive .xls file, covering the short-listed materiality matters, with
an embedded assessment criteria. The description of the matters and IROs was provided, and
the possibility was given to add further matters and IROs. Stakeholders were provided with
instructions on how to fill in the template, and one-to-one help was provided when needed.
Since in 2024 the short-list of material matters with their corresponding IROs was the same
as in 2023, it was decided that a simplified survey will be conducted among stakeholders to
get their insight into any potential changes they may identify. The extent of further steps was
dependent on the results of this simplified survey. The survey was prepared in a user-friendly
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format. Stakeholders were provided instructions on how to fill in the survey, and were advised to
familiarize themselves with the results of the 2023 assessment. One-to-one help was provided
when needed, in particular to the persons that were new to the process.
•
Step 6: Stakeholders’ assessment – with an aim to collect data from stakeholders, including:
•
a) Initial assessment – in 2023 short-listed material matters were assessed by 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; in 2024 the
initial assessment was provided in a user-friendly survey, as described in Step 5 above;
•
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; since initial assessment performed in 2024 showed no major changes to the
previous year, impact assessment has relied on the data collected in 2023;
•
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; since initial assessment performed in 2024
showed no major changes to the previous year, financial assessment has relied on the data
collected in 2023.
•
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; the results relied to a certain
extent on the data collected in 2023, since no major changes were identified in 2024; the changes
in the final formulation of impacts is based on the internal and external expertise and results from
the intention to focus on the negative impacts;
•
Step 8: Identification of LINK’s material matters – the choice of material matters was made
based on the pre-defined criterions; adapted thresholds, and their critical analyses;
•
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 (as described in chapters
1.1.7.3 and 1.1.7.4).
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 the above outlined materiality assessment
process, as deliberated below.
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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
In 2024 the same stakeholder groups have been identified as in the previous year, with one adjustment-
an identification of “nature” as a silent stakeholder (which in 2023 was analysed to a minor degree).
The stakeholder groups include:
•
internal stakeholders – the choice of internal participants took into consideration representation of
various seniority, geographical regions and functional areas;
•
external stakeholders – representatives from the upstream and downstream value chain have been
invited to participate in the assessment already in 2023, but no responses have been obtained; to
compensate on that:
•
involvement of voices from a variety of internal stakeholders, including product, sales, investor
relations, data protection, information security, and other departments, representing different
seniority levels, enabled to understand and take into consideration perspectives of not only
internal, but also key external stakeholder groups;
•
the desk research was carried out by the L&C team to include perspective of the external
stakeholders;
•
silent stakeholders – “nature” has been identified as a silent stakeholder and analysed in 2024 more
broadly than in 2023; it resulted from the internal review of the specificity of LINK’s business, the
corresponding desk research, and the remarks of the performed gap analyses; it was further taken
into consideration during climate-related scenario and resilience analyses (see disclosure E1.SBM-3-
chapter 2.2.2, and E1.IRO-1- chapter 1.1.11.9).
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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 within a range of [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:
•
•
•
•
•
The matter has been chosen as material if either its impact or financial materiality accounted to more
than 2,5. Additionally, analyses were performed in cases for which the average of impact and financial
materiality for a given matter accounted to more than 2,0, and decision was made based on qualitative
analyses if such a matter is supposed to be deemed material. The final formulation of impacts is based
on the internal and external expertise and results from the intention to focus on the negative impacts.
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 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, LINK’s specific context was
described and impacts identified, followed by deliberations concerning dependencies on natural and
social resources, from which certain risks and opportunities may be derived. The corresponding risks
and opportunities were than identified during step 4, having in mind LINK’s context, identified impacts,
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and dependencies. The ESG matters, dependencies, as well as corresponding impacts, risks and
opportunities 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, risks and opportunities, which were assessed
by the involved stakeholders during step 6. 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 within a range of [1] to [4] and the criteria included:
•
(1) magnitude and (2) likelihood of risks and opportunities.
Furthermore, (1) magnitude 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:
•
•
•
•
•
The matter has been chosen as material if either its impact or financial materiality accounted to more
than 2,5. Additionally, analyses were performed in cases for which the average of impact and financial
materiality for a given matter accounted to more than 2,0, and decision was made based on qualitative
analyses if such a matter is supposed to be deemed material.
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. Since “Climate change mitigation” was identified as a material
topic in the materiality assessment performed in 2024, the climate-related scenario and resilience
analyses followed materiality assessment (see disclosure E1-SBM-3- chapter 2.2.2, and E1.IRO-1-
chapter 1.1.11.9).
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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 performed within the Legal & Compliance Team, with
the involvement of various stakeholders’ groups. Internal expertise is extensively utilized. 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.
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 the CSRD/ ESRS/
relevant guidelines, as well as various 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
LINK has conducted the materiality assessment for several years now, starting from a very simple
process in 2020, up to the introduction of the extensive, ESRS-compliant process in 2023.
As the non-financial reporting is performed on annual basis, the company shall revise its materiality
assessment each year. It is however allowed to use the outcomes of the prior reporting period if
the undertaking concludes that there have been no internal or external material changes that could
generate new or modify existing impacts, risks and opportunities.
Having this in mind, in 2024 LINK completed the simplified materiality assessment process, which
to a great extent uses the outcomes of the prior reporting period. During the process, following
desk research made within the Legal & Compliance Team, and a survey conducted among various
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stakeholders’ groups, it has been decided that there have been no material changes that could generate
new or modify existing impacts, risks and opportunities. Nevertheless, minor adjustments have been
made that resulted in the identification of one additional material topic i.e. “Climate change mitigation”
and in the introduction of changes in the final formulation of impacts with the intention to focus on
the negative ones. Following this, climate-related scenario and resilience analyses were performed, as
described under disclosure E1-SBM-3 (chapter 2.2.2) and E1.IRO-1 (chapter 1.1.11.9).
1.1.11.9. [E1.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 (materiality assessment), covering
also the ones related to climate, is included above. Following the materiality assessment, a simplified
climate-related scenario and resilience analyses were carried out in order to understand how LINK
might perform under different hypothetical future climate states, and how its strategy resilience to
climate change might be improved. This resulted in expanding and supplementing IROs’ analyses made
during the materiality assessment.
The climate-focused analyses were aimed at better understanding how the climate-related risks and
opportunities might plausibly develop in the future and how they may impact LINK in short-, medium-
and long- term horizons. It must be noted that 2024 was the first year when such scenario analyses
were carried out, which resulted in their limited scope and only qualitative nature. The process took into
consideration recommendations and guidelines developed by the Task Force for Climate Disclosures,
namely 2017 “Recommendations of the Task Force on Climate related Financial Disclosures”, 2017
“Technical Supplement on The Use of Scenario Analysis in Disclosure of Climate-Related Risks
and Opportunities”, and 2020 “Guidance on Scenario Analysis for Non-Financial Companies”. As
recommended by the TCFD, organization in the initial stage of implementation of scenario analyses
or with limited exposure to climate-related issues, may limit its discloses to qualitative information
on how the company’s strategy and financial position may differ in various climate scenarios.
LINK’s materiality assessment demonstrates that although climate change matters may be of
importance to the company, as to almost each entity operating in today’s world, its exposure is not
critical. The company operates mainly in the digital world, with no production facilities, and its relation
to the environment results mainly from usual office operations, as well as from its dependence on
data storage, and consequently energy supply. Having this in mind, considering also initial stage of
implementing scenario analyses at LINK, and limited resources available, LINK’s simplified scenario
analyses shall be viewed as just a starting point in framing potential environmental issues that are
worth addressing. Performing more in-depth analyses will be considered in the future.
The climate-specific analyses consisted of the following steps:
1. Describing LINK’s context in relation to climate change (above)
2. Deliberation on climate-related impacts, risks, and opportunities outlined during materiality
assessment (sec. b) below)
3. Climate-related scenario and resilience analyses
a. Defining purpose and scope of the analyses (above, and sec. a), c) below)
https://www.fsb-tcfd.org/publications/
TCFD’s 2017 Recommendations of the Task Force on Climate related Financial Disclosures, p.28
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b. Choice of relevant scenarios, formulating their main assumptions and objectives (sec. c) below)
c. Defining focal questions and driving forces (sec. c) below)
d. Identification of major climate factors and their impact on LINK-specific IROs (sec. c) below)
e. Resilience analyses and LINK’s response (chapter 2.2.2.2.)
a. Time horizons
The time horizons applied to climate analyses are the same as time horizons defined in ESRS 1 section
6.4 (see chapter 1.1.2.1). It must be noted however, that climate-related impacts, risks and opportunities
have implications mostly in a longer period of time. Therefore the climate analyses focused on medium-
and long- term, with long term spanning to as long as 2050 which is consistent with the 2050 net zero-
emission target specified in the European Green Deal.
b. Disclosures related to the identification of climate-related hazards and transition
events, and how LINK’s assets and business activities may be exposed to them and
are sensitive to them
The climate-related hazards and transition events identified during climate-specific analyses, and how
LINK is exposed to them, are described in a table below. Having in mind current regulatory environment,
and LINK’s type of business, no assets or activities have been identified that are incompatible with
or need significant efforts to be compatible with transition to climate-neutral economy. No further
quantitative assessments were performed.
Climate-
related hazard/
transition
event
Related risk Potential effects on LINK
LINK assets/
activity
potentially
affected
Transition
event:
enhanced
emissions- and
energy-related
regulatory
obligations
Transition risk: legal and policy
risk resulting from the introduction
of regulatory changes that impose
strict requirements related to
reducing emissions and energy
consumption, and achieving
“greener” energy mix.
It may lead to the increased
operating costs related to
the necessity to ensure
compliance.
Overall
(increased
operating
costs)
Transition
event:
costs of
transition
to lower
emissions
technology
Transition risk: technology risk
resulting from the necessity to catch
up with a transition to lower-carbon,
energy efficient solutions, including
the ones affecting ICT infrastructure,
and an increase in the use of shared
infrastructure.
It may lead to efficiency
loses related to the
implementation of new
uncertain solutions and
the reduced infrastructure
redundancy.
Data centres
https://climate.ec.europa.eu/eu-action/climate-strategies-targets/2050-long-term-strategy_en
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Climate-
related hazard/
transition
event
Related risk Potential effects on LINK
LINK assets/
activity
potentially
affected
Transition
event:
increased
energy prices
Transition risk: market risk related to
the increase in the prices of energy
from fossil sources and necessity
to lower energy consumption and
achieve “greener” energy mix.
It may lead to the increased
operating costs related to
higher energy prices and
changes in the energy mix.
Overall
(increased
operating
costs)
Transition
event:
negative
stakeholder
feedback
Transition risk: reputation risk
related to the growing awareness
of climate related issues and
uncertain stakeholders’ perception
of the company’s attitude to the
environmental issues.
It may lead to the increased
operating costs related to
the necessity to ensure
relevant training and
marketing activities.
Overall
(increased
operating
costs)
Climate-
related hazard:
heatwaves/
extreme
weather
Physical risk: acute risk resulting
from heatwaves or other extreme
weather conditions that may lead
to disruptions in energy supply and
data centres’ operations.
It may lead to problems with
business continuity, and
consequently financial loss,
due to the disruptions in the
energy supply.
Data centres
Climate-
related hazard:
increase in the
air temperature
Physical risk: chronic risk resulting
from the climate warming, posing
challenges to the operation of data
centres.
It may lead to the increased
operating costs related to
higher energy consumption
and necessity to ensure
cooling and power backup
solutions.
Data centres
c. Disclosures related to the climate-related scenario analyses
LINK’s scenario analyses involve three simple scenarios that are inspired by the publicly available
scenarios developed by International Energy Agency (IEA). IEA’s scenarios have been chosen because
they focus on issues most relevant to LINK, namely energy and emissions. The IEA’s Global Energy and
Climate (GEC) Model is designed to analyse various aspects of the energy system and how it might
evolve over time. It allows to analyse and compare the chosen scenarios build on different assumptions
on the energy system’s development, in order to understand how different factors might impact the
company and to which outcomes they may lead. These scenarios are:
•
the Stated Policies Scenario (STEPS),
•
the Announced Pledges Scenario (APS),
•
the Net Zero Emissions by 2050 Scenario (NZE Scenario) – aligned with limiting global warming to
1.5°C with no or limited overshoot.
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Scenario Scenario 1
-inspired by the
IEA’s Stated Policies
Scenario (STEPS)
Scenario 2
-inspired by the IEA’s
Announced Pledges
Scenario (APS)
Scenario 3
-inspired by the IEA’s Net Zero
Emissions by 2050 Scenario (NZE
Scenario)
Type of scenario
Exploratory scenario
that defines starting
conditions (policies/
targets etc), and see
where they lead.
Exploratory scenario
that defines starting
conditions (policies/
targets etc), and see
where they lead.
Normative scenario that defines
outcomes (net zero emissions
from the energy sector by 2050,
emissions trajectory consistent
with keeping the temperature rise
in 2100 below 1.5 °C), and shows
a pathway to reach them.
Assumptions
• No strengthening or
weakening of policies
and regulations – the
EU energy policies
and regulatory
requirements will
remain at their current
state.
• The energy sector
will go without a major
additional steer from
policy makers.
• Strengthening
of policies and
regulations – new
EU energy policies
and regulations will
be implemented that
reflect the announced
ambitions and targets
(net zero or carbon
neutrality pledges
achieved in the long-
term).
• The energy sector
will be affected by the
policies and regulations
requiring emissions
reductions aimed at
achieving net zero
emissions by 2050.
• The energy sector will achieve
net zero emissions by 2050.
• The global temperature rise will
be limited to 1.5 °C.
• Key energy-related Sustainable
Development Goals (SDGs)
will be achieved (universal
energy access by 2030, major
improvements in air quality,
action to tackle climate change).
• A pathway to achieve these
goals will include:
- deployment of clean energy
technologies,
- incentives supporting larger
share of renewable energy in the
energy mix,
- penalties for to large share of
energy from fossil sources in the
energy mix,
- strict requirements to lower GHG
emissions.
LINK’s scenario analyses are of qualitative nature, and constitute just a starting point to potential
future more in-depth analyses. Therefore, IEA’s scenarios have formed just an inspiration for the three
scenarios analysed on a company level. The description of these scenarios, their assumptions and
objectives, is provided in a table below.
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Scenario Scenario 1
-inspired by the
IEA’s Stated Policies
Scenario (STEPS)
Scenario 2
-inspired by the IEA’s
Announced Pledges
Scenario (APS)
Scenario 3
-inspired by the IEA’s Net Zero
Emissions by 2050 Scenario (NZE
Scenario)
Geographical
scope
• European Economic
Area (EEA)
• European Economic
Area (EEA)
• European Economic Area (EEA)
Time horizons
(defined above)
• Medium term
• Long term
• Medium term
• Long term
• Medium term
• Long term
Objectives
The scenario is aimed
to understand how
LINK’ s business will
be affected by climate
change in current
regulatory conditions.
The scenario is aimed
to understand how
LINK’ s business
will be affected by
climate change in
case the regulatory
requirements are
stricter than currently.
The scenario is aimed to
understand how LINK’ s business
will be affected by climate change
in conditions where the targets of
net zero emissions by 2050 and
are achieved in due time.
Having in mind the context in which LINK operates, climate analyses have been focused on answering
the following questions:
1. How the conditions in a given scenario might affect LINK’s requirements to reduce its energy
consumption and emissions?
2. How the conditions in a given scenario might affect LINK’s requirements to achieve
“greener” energy mix?
Following the choice of scenarios, most important climate factors that may affect LINK, depending on
the given scenario, were identified. The search for these factors was focused on the focal questions as
described above. The analyses took into consideration LINK’s own operations as well as its value chain,
in the medium and long term time horizons. The goal was to answer the question “What major climate
factors might affect LINK in a given scenario?”.
Following the identification of main climate factors that may affect LINK in each scenario, they were
related to the identified risks specific to LINK’s business. The goal was to answer the question “How
climate factors may impact identified risks?”.
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The analyses are presented in a table below.
Scenario Scenario 1
inspired by the IEA’s
Stated Policies Scenario
(STEPS)
Scenario 2
inspired by the IEA’s
Announced Pledges Scenario
(APS)
Scenario 3
inspired by the IEA’s Net Zero
Emissions by 2050 Scenario
(NZE Scenario)
Main climate
factors that may
affect LINK
• In the long term, the
price of energy from
fossil sources will
slightly increase.
• In the medium term, ensuring
regulatory compliance will
require significant resources.
• In the medium term, energy
mix will have to be “greener”
• In the medium term,
emissions will need to be
reduced.
• In the long term, the price of
energy from fossil sources will
significantly increase.
• In the long term, some
penalties for non reducing GHG
emissions will be introduced.
• In the medium term, energy
mix will have to be “greener”
(even more than in Scenario 2).
• In the medium term,
emissions will need to be
reduced (even more than in
Scenario 2).
• In the long term, the price of
energy from fossil sources will
significantly increase (even
more than in Scenario 2).
• In the medium term, some
penalties for non reducing GHG
emissions will be introduced.
• In the long term, significant
penalties for non reducing GHG
emissions will be introduced.
How climate factors may impact identified risks?
• Legal and policy
risk (regulatory
changes)
No changes comparing
to the current state.
LINK will have to ensure
compliance with existing
climate-related laws and
regulations.
LINK will have to bear
significant cost related to
ensuring compliance with
stricter climate-related laws
and regulations.
LINK may need to bear
significant cost related to
ensuring compliance with
stricter climate-related laws
and regulations.
• Technology
risk (transition
to low carbon,
energy efficient
solutions)
LINK will have to
consider implementing
energy-efficient
solutions leading to
decrease in energy
consumption and
“greener” energy mix,
resulting in some
reductions in GHG
emissions.
LINK will need to implement
energy-efficient solutions
leading to significant decrease
in energy consumption and
“greener” energy mix, leading
to considerable reductions in
GHG emissions.
LINK will need to implement
state-of-the-art energy-
efficient solutions leading to
fast and significant decrease
in energy consumption and
“greener” energy mix, leading
to major reductions in GHG
emissions.
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Scenario Scenario 1
inspired by the IEA’s
Stated Policies Scenario
(STEPS)
Scenario 2
inspired by the IEA’s
Announced Pledges Scenario
(APS)
Scenario 3
inspired by the IEA’s Net Zero
Emissions by 2050 Scenario
(NZE Scenario)
How climate factors may impact identified risks?
• Market risk
(energy prices)
LINK will face some
increases in operating
costs, resulting from
higher energy prices
coming from fossil
sources.
LINK will face major increases
in operating costs, resulting
from higher energy prices
coming from fossil sources.
LINK will face critical increases
in operating costs, resulting
from higher energy prices
coming from fossil sources.
• Reputation
risk (growing
awareness and
demands)
LINK will need to
continue its current
training and marketing
schemes.
LINK will need to continue its
current training and marketing
schemes.
LINK will need to continue its
current training and marketing
schemes.
• Physical risks
(acute and
chronic)
LINK will have to ensure
business continuity and
resilience related to
physical risks.
LINK will have to ensure
business continuity and
resilience related to physical
risks.
LINK will have to ensure
business continuity and
resilience related to physical
risks.
d. Explanation of how climate scenarios used are compatible with critical climate-
related assumptions made in financial statements
No climate-related assumptions have been made in financial statements.
1.1.11.10. [E2-E5.IRO-1] Description of the processes to identify and assess material impacts,
risks and opportunities that are related to pollution, water and marine resources,
diversity and ecosystem, as well as resource use and circular economy.
LINK operates in the ICT industry, providing mostly messaging services as an electronic communication
services’ provider, on a B2B basis. As the Group takes part in creating a digital rather than a physical
world, no material pollution, water and marine resources, diversity and ecosystem, or resource use and
circular economy related impacts, risks or opportunities have been identified.
The process to identify and assess material IROs (materiality assessment) is described in chapters
1.1.11.1-1.1.11.8 above. No separate process focused on the above mentioned environment topics has
been performed, and no further screening performed, as this is not material to the homogenous nature
of LINK’s operation in its respective sector, with presence mainly in the digital world. No site locations
relevant to the assessment of biodiversity sensitive areas, or relevant to other mentioned environmental
topics, have been identified.
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Description of how stakeholders have been included in the materiality assessment process is described
in chapter 1.1.11.2.c above. No specific consultations related to the above mentioned environment
topics, including the ones with affected communities, have been conducted.
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.d)
2
ESRS 2 GOV-1 Percentage of board members who are
independent; paragraph 21 (e)
ESRS 2 GOV-1 (chapter 1.1.3.1.e)
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
ESRS E1-1 (chapter 2.2.1)
9
ESRS E1-1 Undertakings excluded from Paris-aligned
Benchmarks; paragraph 16 (g)
Not material (no transition plan, as
explained in chapter 2.2.1)
10 ESRS E1-4 GHG emission reduction targets; paragraph 34
ESRS E1-4 (no GHG emissions
reduction targets set, as explained in
chapter 2.2.5)
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No
Disclosure Requirement
and related datapoint
Where the datapoint can be found in
this sustainability statement
/or “not material”/
11
ESRS E1-5 Energy consumption from fossil sources
disaggregated by sources (only high climate impact
sectors); paragraph 38
Not material (no operation in high
climate impact sectors, as explained
in chapter 2.2.6.2)
12 ESRS E1-5 Energy consumption and mix; paragraph 37 ESRS E1-5 (chapter 2.2.6.1)
13
ESRS E1-5 Energy intensity associated with activities in high
climate impact sectors; paragraphs 40 to 43
Not material (no operation in high
climate impact sectors, as explained
in chapter 2.2.6.2)
14
ESRS E1-6 Gross Scope 1, 2, 3 and Total GHG emissions;
paragraph 44
ESRS E1-6 (chapter 2.2.7.1)
15
ESRS E1-6 Gross GHG emissions intensity; paragraphs 53
to 55
ESRS E1-6 (chapter 2.2.7.6)
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
Phased-in in accordance with ESRS
1 Appendix C (see chapter 2.2.8)
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).
Phased-in in accordance with ESRS
1 Appendix C (see chapter 2.2.8)
19
ESRS E1-9 Breakdown of the carrying value of its real estate
assets by energy-efficiency classes; paragraph 67 (c).
Phased-in in accordance with ESRS
1 Appendix C (see chapter 2.2.8)
20
ESRS E1-9 Degree of exposure of the portfolio to climate-
related opportunities; paragraph 69
Phased-in in accordance with ESRS
1 Appendix C (see chapter 2.2.8)
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
25 ESRS E3-4 Total water recycled and reused; paragraph 28 (c) 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”/
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
ESRS 2 E2-E5.IRO-1 (chapter
1.1.11.10)
28 ESRS 2- IRO 1 - E4; paragraph 16 (b)
ESRS 2 E2-E5.IRO-1 (chapter
1.1.11.10)
29 ESRS 2- IRO 1 - E4; paragraph 16 (c)
ESRS 2 E2-E5.IRO-1 (chapter
1.1.11.10)
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 1.1.2.8)
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 1.1.2.8)
37 ESRS S1-1 Human rights policy commitments; paragraph 20
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
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 1.1.2.8)
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 1.1.2.8)
40
ESRS S1-1 workplace accident prevention policy or
management system; paragraph 23
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
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No
Disclosure Requirement
and related datapoint
Where the datapoint can be found in
this sustainability statement
/or “not material”/
41
ESRS S1-3 grievance/complaints handling mechanisms;
paragraph 32 (c)
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
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 1.1.2.8)
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 1.1.2.8)
44 ESRS S1-16 Unadjusted gender pay gap; paragraph 97 (a)
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
45 ESRS S1-16 Excessive CEO pay ratio; paragraph 97 (b)
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
46 ESRS S1-17 Incidents of discrimination; paragraph 103 (a)
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
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 1.1.2.8)
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
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
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No
Disclosure Requirement
and related datapoint
Where the datapoint can be found in
this sustainability statement
/or “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 1.1.2.8)
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 1.1.2.8)
59 ESRS S4-4 Human rights issues and incidents; paragraph 35
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
60
ESRS G1-1 United Nations Convention against Corruption;
paragraph 10 (b)
ESRS G1 G1-1 (chapter 4.1.1.3.a)
61 ESRS G1-1 Protection of whistle- blowers; paragraph 10 (d) ESRS G1 G1-1 (chapter 4.1.1.3.c)
62
ESRS G1-4 Fines for violation of anti-corruption and anti-
bribery laws; paragraph 24 (a)
ESRS G1 G1-4 (chapter 4.1.4)
63
ESRS G1-4 Standards of anti- corruption and anti- bribery;
paragraph 24 (b)
ESRS G1 G1-4 (chapter 4.1.4)
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
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
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No ESRS Disclosure Requirement (DR) complied with
Where the DR can be found in
this sustainability statement
5
[ESRS 2] [GOV-3] Integration of sustainability-related
performance in incentive schemes
chapter 1.1.5
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
11
[ESRS 2] [IRO-1] Description of the process to identify and
assess material impacts, risks and opportunities
chapter 1.1.11
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 1.1.2.8.b indent
2, 1.1.2.8.c indent 2, 4.1.1.1,
4.1.1.3.c (see also references in
2.2.3, 4.1.2 , 4.1.3, 4.1.4)
14
[ESRS 2] [MDR-A] Actions and resources in relation to material
sustainability matters
chapters 1.1.2.8.b indent 3,
1.1.2.8.c indent 3, 2.2.4.1,
4.1.1.2.a (see also references in
4.1.2, 4.1.3, 4.1.4)
15
[ESRS 2] [MDR-M] Metrics in relation to material sustainability
matters
chapters 1.1.2.8.b indent 4,
1.1.2.8.c indent 4, 2.2.5.1.a,
4.1.1.2.b (see also references in
4.1.2, 4.1.3, 4.1.4)
16
[ESRS 2] [MDR-T] Tracking effectiveness of policies and actions
through targets
chapters 1.1.2.8.b indent 5,
1.1.2.8.c indent 5, 2.2.5.1.b,
4.1.1.2.c (see also references in
4.1.2, 4.1.3, 4.1.4)
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 2.2.3
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No ESRS Disclosure Requirement (DR) complied with
Where the DR can be found in
this sustainability statement
19
[ESRS E1] [E1-3] Actions and resources in relation to climate
change policies
chapter 2.2.4
20
[ESRS E1] [E1-4] Targets related to climate change mitigation
and adaptation
chapter 2.2.5
21 [ESRS E1] [E1-5] Energy consumption and mix chapter 2.2.6
22 [ESRS E1] [E1-6] Gross Scopes 1, 2, 3 and Total GHG emissions chapter 2.2.7
23 [ESRS S1] all DR
Phased-in in accordance
with ESRS 1 Appendix C (see
chapter 1.1.2.8)
24 [ESRS S4] all DR
Phased-in in accordance
with ESRS 1 Appendix C (see
chapter 1.1.2.8)
25
[ESRS G1] [G1-1] Business conduct policies and corporate
culture
chapter 4.1.1
26 [ESRS G1] [G1-2] Management of relationships with suppliers chapter 4.1.2
27
[ESRS G1] [G1-3] Prevention and detection of corruption and
bribery
chapter 4.1.3
28 [ESRS G1] [G1-4] Incidents of corruption or bribery chapter 4.1.4
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 egative 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.
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No ESRS Explanation of the egative materiality assessment
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.
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.
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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 described 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 following sub-topics covered by topic “Climate change” have been
assessed as material: “Climate change mitigation”, “Energy”. 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,
and leaves certain carbon footprint. Hence, the disclosures include basic
datapoints related to the energy mix and GHG emissions. Having in mind the
above, certain disclosures covered by ESRS E1 (E1-1, E1-2, E1-3, E1-4, E1-5,
E1-6) are included in chapter 2. The disclosures under E1-7, E1-8 have been
assessed as not material. The disclosures under E1-9 have been phased-in,
as 2025 is the first year of preparation of LINK’s sustainability statement fully
compliant with CSRD.
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 2024, it omits
information required by ESRS S1. For the identified material topic covered by
ESRS S1, the required disclosures are included in chapter 1.1.2.8.
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
2024, it omits information required by ESRS S4. For the identified material
topic covered by ESRS S4, the required disclosures are included in chapter
1.1.2.8.
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,
G1-4) are included in chapter 4.
The disclosures [G1-5] „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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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 mitigation”
•
ESRS E1: Topic “Climate change” – Sub-topic “Energy”
Hence, LINK reports in this chapter the disclosure requirements covered by E-1 (including, E1-2, E1-3,
E1-4, E1-5 and E1-6), alongside the minimum disclosure requirements covered by ESRS 2 MDR, relevant
to each of the above listed material topics. The disclosures under E1-9 have been phased-in. The
disclosures under E1-7 and E1-8 have been assessed as not material.
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 disclosures E1.SBM-3 are included in this chapter. The disclosures E1.GOV-3 are included under
ESRS 2 GOV-3. The disclosures E1-E5.IRO-1 are included under ESRS 2 IRO-1.
The description of how LINK identified the scope of the sustainability reporting is provided 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’.
The EU Taxonomy is applicable in Norway for annual reports published since 2024 (covering FY
2023). Hence, LINK reports relevant Key Performance Indicators for the second time. The scope of
consolidation is the same as for the financial statements.
The reported KPIs include proportion of the EU Taxonomy- eligible and aligned turnover, capital
expenditure (CaPex) and operating expenditure (OpEx) derived from products (services) associated
with relevant economic activities, as well as disclosures as specified in Annex XII to the Disclosures
Delegated Act. The low level of the disclosed indicators results from the assessment that majority of
LINK activities is not covered by the EU Taxonomy.
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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
un sustainable 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 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 ¹,” 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 was carried out in LINK in 2023 for the first time, and it has been updated in
the beginning of 2025. The results are 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?“
Four 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.
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Basis
No. of the
activity
Description of the activity
Description of
LINK’s activity
Climate
Delegated
Act,
Annex I &
Annex II
6.5. Transport
by motorbikes,
passenger cars
and commercial
vehicles
Purchase, financing, renting, leasing and
operation of vehicles (categories: M1, N1, L).
The economic activities in this category could be
associated with several NACE codes, in particular
H49.32, H49.39 and N77.11 in accordance with the
statistical classification of economic activities
established by Regulation (EC) No 1893/2006.
Annex I: Where an economic activity in this category
does not fulfil the substantial contribution criterion
specified in point (a)(ii) and (b) of this Section, the
activity is a transitional activity as referred to in
Article 10(2) of Regulation (EU) 2020/852, provided
it complies with the remaining technical screening
criteria.
LINK leases
company cars
(category M1).
Climate
Delegated
Act,
Annex I &
Annex II
7.7. Acquisition
and ownership of
buildings
Buying real estate and exercising ownership
of that real estate.
The economic activities in this category could be
associated with NACE code L68 in accordance with
the statistical classification of economic activities
established by Regulation (EC) No 1893/2006.
LINK leases its
offices.
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 centres,
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.
LINK stores,
manages and
transmits data
through its servers
(that may be
regarded as a data
centre).
Choice of the Taxonomy-eligible activities
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Basis
No. of the
activity
Description of the activity
Description of
LINK’s activity
Climate
Delegated
Act,
Annex II
8.2. Computer
programming,
consultancy and
related activities
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.
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 recognised
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 points 6.5., 7.7., and 8.1. of
Annex I, as well as points 6.5, 7.7, 8.1. and 8.2. of Annex 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 (1) it does not have sufficient data to demonstrate the energy performance criterions of its
leased offices, as specified in Annex I, point 7.7.; (2) it does not collect detailed environmental
data on company cars and therefore may not assures to fulfil criterion relevant to emission, as
specified in Annex I, point 6.5.; and furthermore, (3) it has neither implemented 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 neither implemented adaptation solutions, nor has it performed specific risk and
vulnerability assessment related to this activity, as specified in Annex II, points 6.5, 7.7, 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.
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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. It was only performed voluntarily, in order
to demonstrate extent to which LINK aligns with minimum safeguards i.e. with:
•
the OECD Guidelines for Multinational Enterprises (OECD Guidelines) and
•
the UN Guiding Principles on Business and Human Rights (UNGPs), including the principles and rights
set out in the eight fundamental conventions identified in the Declaration of the International Labour
Organisation on Fundamental Principles and Rights at Work and
•
the International Bill of Human Rights.
The assessment was carried out in accordance with the recommendations included in the “Final Report
on Minimum Safeguards”¹¹.
Topic LINK’s compliance
Human
rights
LINK has established and implemented a human rights-focused due diligence process
within its process to ensure compliance with the Norwegian Transparency Act. The Act
obliges companies to perform a due diligence process on fundamental human rights
and decent labour conditions, and is in principle aligned with major requirements of the
UNGPs and OECD Guidelines. LINK published its first report under the Transparency
Act in 2023, where it explained its relevant due diligence processes. Furthermore, LINK
implemented Employee Code of Conduct and provides a whistleblowing channel to
report any misconduct.
In 2024 LINK was not found to be in breach of labour law or human rights.
Corruption
LINK has a zero-tolerance principle to corruption, which is reflected in its anti-corruption
and anti-bribery policy, being part of the ESG policy. The principle is also reflected in the
Employees’ Code of Conduct, which shall be observed by all its employees. Moreover,
anti-corruption is part of a regular training that is obligatory for all employees.
In 2024 LINK was not convicted in court on corruption.
Taxation
LINK acts in accordance with its internal policies and procedures on accounting,
taxation and financial reporting. It aims to observe all relevant international and local tax
laws.
Fair
competition
LINK acts in accordance with its antitrust policy, being part of the ESG policy. The fair
competition principle is also reflected in the Employees’ Code of Conduct, which shall be
observed by all its employees. Moreover, antitrust is also part of a regular training that is
obligatory for all employees.
In 2024 LINK was not convicted in court on violating competition laws.
LINK’s compliance with minimum safeguards
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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 four activities as
“taxonomy-eligible”, it discloses the following KPIs:
•
the proportion of a turnover derived from products or services associated with “taxonomy-eligible”
and “taxonomy non-eligible” activities;
•
the proportion of a capital expenditure related to assets or processes associated with “taxonomy-
eligible” and “taxonomy non-eligible” activities;
•
the proportion of an operating expenditure related to assets or processes associated with “taxonomy-
eligible” and “taxonomy non-eligible” activities.
Since LINK has not identified any of activities listed in sections 4.26- 4.31 of Annexes I and II to Climate
Delegated Act, nor does it engage in any nuclear energy related activities, the templates set out in
Annex XII of the Disclosures Delegated Act shall be reported with “0”/ “NO” answers.
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
Four activities listed in the Climate Delegated Act have been identified in LINK as “taxonomy-eligible”:
•
6.5. Transport by motorbikes, passenger cars and commercial vehicles – LINK leases company cars
(category M1).
•
7.7. Acquisition and ownership of buildings – LINK leases its office space.
•
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.
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c. Key Performance Indicators (KPIs)
KPIs related to turnover, CapEx and Opex, are presented in the tables below. Comparing to the previous
reporting period, two new “taxonomy-eligible” activities have been added (6.5., 7.7.), which resulted in
disclosure of relevant KPIs related to these activities. Moreover, disclosures as specified in templates
set out in Annex XII of the Disclosures Delegated Act have been added.
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 7 of the financial statements.
•
CapEx, or capital expenditure, are cumulative costs recognised as intangible assets and property,
plant, and equipment during the year. These include assets arising from business combinations
(there are none in 2024), and they exclude goodwill. Further information is provided in notes 3, 8, 14,
and 15 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.
•
The double counting in the allocation in the numerator of turnover, CapEx and OpEx was avoided by
the fact that they refer to different activities, which are independent. Moreover, the double counting
was avoided by eliminating the intra-group transactions where needed (as in the financial reporting).
No Taxonomy-aligned activities were identified.
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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Financial year: 2024
Substantial
contribution criteria
DNSH criteria (“Does
Not Significant Harm”)
Minimum safeguards
Proportion of taxonomy-aligned (A.1) or-eligible
(A.2) turnover, year 2023*
Category enabling activity
Category transitional activity
Economic activities
Code(s)
Absolute turnover
Proportion of turnover,, year 2024
Climate change mitigation
Climate change adaptation
Water
Pollution
Circular economy
Biodiversity
Climate change mitigation
Climate change adaptation
Water
Pollution
Circular economy
Biodiversity
Tex t
NOK 1000
%
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
6.5. Transport by motorbikes, passenger cars
and commercial vehicles *
CCM
6.5/ CCA
6.5
0
0%
EL
EL
N/EL
N/EL
N/EL
N/EL
-
0%
7.7. Acquisition and ownership of buildings**
CCM 7.7/
CCA 7.7
0
0%
EL
EL
N/EL
N/EL
N/EL
N/EL
-
0%
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
0%
8.2. Computer programming, consultancy
and related activities*
CCA 8.2
0
0%
N/EL
EL
N/EL
N/EL
N/EL
N/EL
0%
Turnover of Taxonomy-eligible activities (A.1 + A.2)
0
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%
0%
B. TAXONOMY NON-ELIGIBLE ACTIVITIES
Turnover of Taxonomy-non-eligible activities 6 993 807
100%
TOTAL 6 993 807
100%
Proportion of turnover from products or services associated with Taxonomy-aligned economic activities –
disclosure covering year 2024 (NOK 1000)
* Activities under “6.5. Transport by motorbikes, passenger cars and commercial vehicles “, “7.7 Acquisition and ownership of buildings”, “8.1. Data processing,
hosting and related activities” and “8.2. Computer programming, consultancy and related activities” have been recognized as not bringing an external
turnover to LINK.
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Proportion of CapEx from products or services associated with Taxonomy-aligned economic activities – disclosure
covering year 2024 (NOK 1000)
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Financial year: 2024
Substantial
contribution criteria
DNSH criteria (“Does
Not Significant Harm”)
Minimum safeguards
Proportion of taxonomy -aligned (A.1) or
-eligible (A.2) CapEx, year 2023
Category enabling activity
Category transitional activity
Economic activities
Code(s)
CapEx
Proportion of CapEx, year 2024
Climate change mitigation
Climate change adaptation
Water
Pollution
Circular economy
Biodiversity
Climate change mitigation
Climate change adaptation
Water
Pollution
Circular economy
Biodiversity
Tex t
NOK 1000
%
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
6.5. Transport by motorbikes, passenger cars
and commercial vehicles
CCM
6.5/ CCA
6.5
0
0.0%
EL
EL
N/EL
N/EL
N/EL
N/EL
-
0.9% * *
7.7. Acquisition and ownership of buildings
CCM 7.7/
CCA 7.7
7 710
2.9%
EL
EL
N/EL
N/EL
N/EL
N/EL
-
10.5%**
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
0%
8.2. Computer programming, consultancy
and related activities* CCA 8.2
0
0 %
N/EL
EL
N/EL
N/EL
N/EL
N/EL
0%
CapEx of Taxonomy-eligible but not environmentally
sustainable activities (not Taxonomy-aligned activities)
(A.2)
0
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%
0%
B. TAXONOMY NON-ELIGIBLE ACTIVITIES
CapEx of Taxonomy-non-eligible activities 261 419
97.1%
TOTAL 269 129
100%
* 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.
** The adjusted numbers reflect identification of additional “Taxonomy-eligible” activities, namely lease of company cars and offices (present in 2023 already).
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* Activities under “6.5. Transport by motorbikes, passenger cars and commercial vehicles“, “7.7 Acquisition and ownership of buildings”, “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 OpEx
dedicated separately to them.
** The adjusted numbers reflect identification of additional “Taxonomy-eligible” activities, namely lease of company cars and offices (present in 2023 already).
Proportion of OpEx from products or services associated with Taxonomy-aligned economic activities – disclosure
covering year 2024 (NOK 1000)
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 18 19 20
Financial year: 2024
Substantial
contribution criteria
DNSH criteria (“Does
Not Significant Harm”)
Proportion of taxonomy -aligned (A.1) or
-eligible (A.2) OpEx, year 2023**
Category enabling activity
Category transitional activity
Economic activities
Code(s)
OpEx
Proportion of OpEx, year 2024
Climate change mitigation
Climate change adaptation
Water
Pollution
Circular economy
Biodiversity
Climate change mitigation
Climate change adaptation
Water
Pollution
Circular economy
Biodiversity
Minimum safeguards
Tex t
NOK 1000
%
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
6.5. Transport by motorbikes, passenger cars
and commercial vehicles*
CCM 6.5/
CCA 6.5
0
0%
EL
EL
N/EL
N/EL
N/EL
N/EL
-
0 %
7.7. Acquisition and ownership of buildings*
CCM 7.7/
CCA 7.7
7.1
0.1%
EL
EL
N/EL
N/EL
N/EL
N/EL
-
0.1 %
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
0 %
8.2. Computer programming, consultancy
and related activities* CCA 8.2
0
0 %
N/EL
EL
N/EL
N/EL
N/EL
N/EL
0 %
OpEx of Taxonomy-eligible but not
environmentally sustainable activities (not
Taxonomy-aligned activities) (A.2)
0
0%
0%
0%
0%
0%
0%
0%
0 %
OpEx of Taxonomy-eligible activities (A.1 +
A.2)
0
0%
0%
0%
0%
0%
0%
0%
0 %
OpEx of Taxonomy-non-eligible activities 7 618
99.9%
TOTAL 7 625
100%
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Row Nuclear energy related activities LINK’s answer
1
The undertaking carries out, funds or has exposures to research, development,
demonstration and deployment of innovative electricity generation facilities
that produce energy from nuclear processes with minimal waste from the fuel
cycle.
NO
2
The undertaking carries out, funds or has exposures to construction and safe
operation of new nuclear installations to produce electricity or process heat,
including for the purposes of district heating or industrial processes such as
hydrogen production, as well as their safety upgrades, using best available
technologies.
NO
3
The undertaking carries out, funds or has exposures to safe operation of
existing nuclear installations that produce electricity or process heat, including
for the purposes of district heating or industrial processes such as hydrogen
production from nuclear energy, as well as their safety upgrades.
NO
Fossil gas related activities LINK’s answer
4
The undertaking carries out, funds or has exposures to construction or
operation of electricity generation facilities that produce electricity using fossil
gaseous fuels.
NO
5
The undertaking carries out, funds or has exposures to construction,
refurbishment, and operation of combined heat/cool and power generation
facilities using fossil gaseous fuels.
NO
6
The undertaking carries out, funds or has exposures to construction,
refurbishment and operation of heat generation facilities that produce heat/
cool using fossil gaseous fuels.
NO
Nuclear and fossil gas related activities
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2.2. [ESRS E1]
2.2.1. [E1-1] Transition plan for climate change mitigation
2.2.1.1. Disclosure of transition plan for climate change mitigation
LINK has so far not adopted a transition plan for climate change mitigation. Material topic “Climate
change mitigation” has been identified during the materiality assessment performed in 2025, and will
be followed in the forthcoming years. Hence, detailed datapoints related to the transition plan have
been omitted.
2.2.1.2. Date of adoption of transition plan for undertakings not having adopted transition
plan yet
LINK will consider adopting a transition plan by 2026, which corresponds with its plans to adopt Science
Based Targets by that time.
2.2.2. [E1.SBM-3] Material impacts, risks and opportunities and their
interaction with strategy and business model
2.2.2.1. Type of climate-related risk
Description of climate-related risks has been included in chapter 1.1.10.1. The climate-related material
risks that have been identified are related to the sustainability matters “Climate change-mitigation” and
“Energy”, and include both transition and physical risks.
2.2.2.2. Resilience analysis and the ability to adjust or adapt strategy and business model to
climate change
The general description on the resilience of LINK’s strategy and business model regarding material
IROs has been included in chapter 1.1.10.5. Moreover, the climate-related resilience analyses and
deliberation on potential LINK’s response, formed last step of the scenario analyses, as described in
chapter 1.1.11.9. The scope and time horizons were the same for all steps of the scenario analyses.
During the process, the potential effects of different conditions in the three scenarios, LINK’s resilience
and potential response to them, were briefly analysed. The goal was to answer the question “What
might be the consequences of climate change to LINK, how is LINK resilient to them, and how it could
respond to them?”. The analyses are presented in a table below.
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Scenario Scenario 1
-inspired by the IEA’s Stated
Policies Scenario (STEPS)
Scenario 2
-inspired by the IEA’s
Announced Pledges
Scenario (APS)
Scenario 3
-inspired
by the IEA’s
Net Zero
Emissions
by 2050
Scenario
(NZE
Scenario)
What may
be most
considerable
consequences
for LINK?
• Need of ensuring regula-
tory compliance with cur-rent
requirements.
• Need of taking energy
consumption, energy mix
and carbon footprint into
consideration in own op-erations
and procurement.
• Need of having business
continuity plans.
• Need of engaging in rele-
vant training and mar-keting
activities.
• Need of participating in various
climate-related in-itiatives and
benchmarks.
• Need of ensuring
regulatory compliance
with strengthened
requirements.
• Need of meeting
energy and emissions’
targets.
• Need of
implementing energy
consumption, energy
mix and carbon
footprint targets into
own operations and
procurement.
• Need of having
business continuity
plans.
• Need of engaging in
relevant training and
marketing activities.
• Need of participating
in various climate-
related initiatives and
benchmarks.
The same as
in Scenario 2
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Scenario Scenario 1
-inspired by the IEA’s Stated
Policies Scenario (STEPS)
Scenario 2
-inspired by the IEA’s
Announced Pledges
Scenario (APS)
Scenario 3
-inspired
by the IEA’s
Net Zero
Emissions
by 2050
Scenario
(NZE
Scenario)
How is LINK
resilient to such
consequences?
•LINK has taken steps to ensure
adequate response to the
current regulatory requirements
(implementing policies, GHG
reporting, participation in the
UNGC, SBTi etc.).
• LINK would need
to ensure additional
resources to
adequately respond
to strengthened
regulatory
requirements.
• LINK’s resilience
also depends on
effective management
of its value chain.
• LINK
would need
to ensure
additional
resources
to meet
ambitious
emission
and energy
related
targets.
• LINK’s
resilience
also depends
on effective
management
of its value
chain.
What may be
LINK’s strategy
response
to such
consequences?
• Developing current strategy,
following ESG maturity path.
• Continuous work on the GHG
report.
• Developing Science Based
Targets.
• Changing the
strategy in order
to meet ambitious
emissions- and energy
related targets.
• Allocating additional
resources to climate-
related issues.
• Continuous work on
the GHG report.
• Developing Science
Based Targets.
The same as
in Scenario 2
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Scenario Scenario 1
-inspired by the IEA’s Stated
Policies Scenario (STEPS)
Scenario 2
-inspired by the IEA’s
Announced Pledges
Scenario (APS)
Scenario 3
-inspired
by the IEA’s
Net Zero
Emissions
by 2050
Scenario
(NZE
Scenario)
Actions
/potential or
actual/
• Including energy and car-bon
related matters in the ESG Policy.
• Preparing GHG report.
• Participation in the United
Nations Global Compact (UNGC).
• Developing environmental
goals within the Science Based
Targets Initiative (SBTi).
• Employees’ training on the
environmental issues.
• Energy consumption/ en-ergy
mix/ carbon foot-print taken into
consider-ation in procurement
(Supplier Due Diligence).
• Energy consumption/ en-ergy
mix/ carbon foot-print taken into
consider-ation in own operations
(product development, data
storage).
• Business continuity plans.
The same as in
Scenario 1 +
• Implementing
technologies allowing
reductions in energy
consumption.
• Purchase of larger
share of energy from
renewable sources
(“greener” energy
mix).
• Allocating additional
resources to climate
issues.
The same as
in Scenario 2
Targets
/potential or
actual/
• GHG report in place.
• Targets developed within
Science Based Targets initiative.
• GHG report in place.
• “Greener” energy
mix.
• Reduction in energy
consumption.
• Reduction in GHG
emissions.
• Targets developed
within Science Based
Targets initiative.
The same as
in Scenario 2
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2.2.3. [E1-2] Policies related to climate change mitigation and adaptation
2.2.3.1. Policies in place to manage its material impacts, risks and opportunities related to
climate change mitigation and adaptation
Impacts, risks and opportunities related to climate change are managed under LINK’s ESG policy, which
includes chapters “LINK Mobility’s approach to Environmental Factors”. The ESG policy is described in
chapter 4.1.1.1. The public version of the policy is available online: https://www.linkmobility.com/legal/
sustainability/esg-policy
2.2.3.2. 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 (1) EU Taxonomy, (2) energy. (3) climate change, and (4) waste
management. During the materiality assessment conducted in 2024, two sustainability matters related
to the environment have been assessed as material i.e.: “Climate change mitigation” and “Energy”.
2.2.4. [E1-3] Actions and resources in relation to climate change policies
2.2.4.1. 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
below. The described actions are of a basic, initial character. No further, detailed analyses regarding
decarbonisation and GHG emission reductions have been conducted so far. Hence, the related
datapoints, included under this disclosure requirement, have been assessed as not material.
> Disclosure of key actions
The following actions related to the material sustainability matters “Climate change mitigation” and
“Energy” were taken in 2024:
•
GHG report – created with an aim to calculate LINK’s climate impact, based on the principles included
in the Greenhouse Gas Protocol (GHGP).
•
Science Based Targets initiative – initiated with an aim to set quantitative climate-related targets in
the future.
•
Supplier Code of Conduct – described in chapter 4.1.1.2.a.
•
Supplier Due Diligence process – described in chapter 4.1.1.2.a .
•
Employees’ training – described in chapter 4.1.1.2.a .
•
Employee Code of Conduct – described in chapter 4.1.1.2.a.
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> Description of scope of key actions
The scope of the relevant actions is as follows:
•
GHG report – in 2024 LINK aimed at including emissions from Scope 1 and Scope 2 sources, as well
as- to a limited extent- from Scope 3.
•
Science Based Targets initiative – in 2024 LINK submitted the commitment letter to the SBTi, was
accepted, and aims towards developing quantitative climate-related targets in line with the schedule
required by the SBTi.
The remaining actions are described in chapter 4.1.1.2.a.
> Time horizon under which key actions are to be completed
Time horizon under which relevant actions are to be completed is as follows:
•
GHG report –in 2024 LINK published a report including Scope 1, Scope 2 and Scope 3; it will be
regularly revised and updated.
•
Science Based Targets initiative – in 2024 LINK submitted the commitment letter to the SBTi and
was accepted; the quantitative climate-related targets are planned to be defined by the end of 2026.
The remaining actions are described in chapter 4.1.1.2.a.
> Description of key actions 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.
> Disclosure of quantitative and qualitative information regarding progress of actions or
action plans disclosed in prior periods
Not relevant in the first reporting period.
> 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.
2.2.4.2. Explanation of extent to which ability to implement action depends on availability
and allocation of resources
The actions relevant to climate change issues have been implemented in the course of a day-to-day
business with no separate resources allocated to them. The described actions are of a basic, initial
character, and no further analyses regarding significant CapEx and OpEx have been conducted. No
significant CapEx or OpEx necessary to implement the proposed actions is recognized at the moment.
Hence, the related datapoints, included under this disclosure requirement, have been assessed as
not material.
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2.2.5. [E1-4] Targets related to climate change mitigation and adaptation
2.2.5.1. Tracking effectiveness of policies and actions through targets
LINK tracks effectiveness of its climate-related policies and actions by assessing them against the
targets, with the use of relevant metrics. These metrics and targets are described below.
a. Metrics
>
Description of metrics used to evaluate performance and effectiveness, in relation to
material IROs
LINK uses the following metrics to evaluate performance and effectiveness in relation to material
impacts, risks and opportunities connected with the material sustainability matters “Climate change
mitigation” and “Energy”:
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec) –
described in chapter 4.1.1.2.b.
•
Including Scope 1 and Scope 2 in the GHG report – the metric used to track the effectiveness of
the action “GHG report”; it 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 used to track the effectiveness of the action “GHG
report”; it reflects LINK’s progress towards calculating climate impact from its value chain, based on
the principles included in the Greenhouse Gas Protocol (GHGP).
•
Setting targets within the SBT initiative – the metric used to track the effectiveness of the action
“Science Based Targets initiative”; it reflects LINK’s progress towards defining quantitative climate-
related targets.
> Disclosure of methodologies and significant assumptions behind metrics
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec) –
described in chapter 4.1.1.2.b.
•
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.
•
Setting targets within the SBT initiative – the metric of a qualitative nature, with [yes/no] values. The
metric is monitored on annual bases.
> 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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b. Targets
>
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). Participation in the SBTi results from the intention to
set quantitative climate-related targets. Both targets are related to certain objectives described in the
“E” part of its ESG Policy.
> Measurable targets, its nature and scope
The targets are set to “YES” as of December 31st each year. They are monitored on annual bases.
> Baseline value and year
Since 2024 is the first year when LINK prepares its sustainability statement fully compliant with the
CSRD, it has decided to set its baseline year for all targets to 2024, unless expressly specified otherwise.
The baseline values are therefore the same as the ones specified below.
> Period to which targets apply and indication of milestones or interim targets
The targets apply to the period, for which LINK’s strategy is set, that is until 2025. No milestones or
interim targets have been set.
> Description of methodologies and significant assumptions used to define targets
Not material for the described targets.
> Targets related to environmental matters is based on conclusive scientific evidence
Not material for the described targets.
> Disclosure of how stakeholders have been involved in targets setting
The targets were set out based on the internal expertise. Stakeholders were not directly involved.
> Description of any changes in targets and corresponding metrics or underlying
measurement methodologies, significant assumptions, limitations, sources and adopted
processes to collect data
Not material, as the targets are reported for the first time.
> Description of performance against disclosed targets
As of December 31st, 2024 the metrics 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 – “YES”, which fulfills the target.
•
Setting targets within the SBT initiative – “NO”, which does not fulfill the target (target however
should be achieved by 2026).
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2.2.5.2. Disclosure of whether and how GHG emissions reduction targets and (or) any
other targets have been set to manage material climate-related impacts, risks and
opportunities
LINK is not active in any of the high climate impact sectors and it has not yet set GHG emissions
reduction targets. Other targets to manage material climate-related IROs, are described in chapter
2.2.5.1.b. above. The detailed datapoints, included under this disclosure requirement, have been
assessed as not material.
2.2.5.3. Disclosure to be reported if the undertaking has not set any measurable outcome-
oriented targets
LINK intends to set its climate-related targets in line with its schedule for participation in the Science
Based Targets initiative, for which it submitted the commitment letter in 2024. More information is
provided in chapter 2.2.4.1.
2.2.6. [E1-5] Energy consumption and mix
2.2.6.1. Datapoints on the energy consumption related to own operations
LINK is active in the “Information and Communication” sector, as listed in NACE Section J. Its energy
consumption results mainly from the office operations, the use of data centres/ servers, the use of
company cars, and- to a minor degree- from stationary combustion. The energy consumption and mix
is presented in a table below, where 2024 constitutes a base year. The scope of data collection is the
same as for data on emissions, as explained in chapter 2.2.7 below.
The total energy consumption is the sum of the following: Scope 1 data, covering (1) stationary
combustion and (2) transportation, including diesel and petrol, as well as Scope 2 data (location-
based method), covering (1) electricity, steaming from offices, datacentres/ servers, and BEVs, and
(2) district heating /cooling. The total energy use has been disaggregated into the energy coming from
the renewable sources, nuclear sources and fossil fuels. Since LINK has no operations in high climate
impact sectors, the use of energy from fossil fuels has not been further disaggregated.
The calculation of the energy mix uses indirect data derived from two main sources, namely AIB
(Association of Issuing Bodies) and IEA (International Energy Agency). Due to the lack of certain data
covering district heating/ cooling, it was impossible to categorize the source of approximately 5 %
of the total energy use. In cases where such categorization was not possible, it was assumed that
such energy comes from fossil fuels. It must however be noted that the use of indirect sources, and
further assumptions regarding 5 % of the energy coming from unknown sources as the fossil energy,
is associated with some level of uncertainty. It should also be noted that estimation of energy mix
of district heating is based on several sources making the estimated share of renewables uncertain,
since such sources may have different approaches on how energy shares are calculated. Percentage of
renewable energy associated with Guarantees of Origin, is however disclosed in chapter 2.2.7.5 below.
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LINK’s GHG report has been published on its corporate webpage: https://www.linkmobility.com/legal/
sustainability/ghg-report. The calculations are based on the principles, requirements and guidance
provided by the Green House Gas protocol, as prescribed by the ESRS.
Energy consumption and mix Comparative* 2024
(1) Fuel consumption from coal and coal products (MWh)
n/a
omitted
(no operations
in high climate
impact sectors)
(2) Fuel consumption from crude oil and petroleum products (MWh)
(3) Fuel consumption from natural gas (MWh)
(4) Fuel consumption from other fossil sources (MWh)
(5) Consumption of purchased or acquired electricity, heat, steam,
and cooling from fossil sources (MWh)
(6) Total fossil energy consumption (MWh)
(calculated as the sum of lines 1 to 5)
n/a 612,3
Share of fossil sources in total energy consumption (%) n/a 50%
(7) Consumption from nuclear sources (MWh) n/a 122,0
Share of consumption from nuclear sources in total energy
consump-tion (%)
n/a 10%
(8) Fuel consumption for renewable sources, including biomass
(also comprising industrial and municipal waste of biologic origin,
biogas, renewable hydrogen, etc.) (MWh)
n/a 17,2
(9) Consumption of purchased or acquired electricity, heat, steam,
and cooling from renewable sources (MWh)
n/a 474,6
(10) The consumption of self-generated non-fuel renewable energy
(MWh)
n/a 0
(11) Total renewable energy consumption (MWh)
(calculated as the sum of lines 8 to 10)
n/a 491,8
Share of renewable sources in total energy consumption (%) n/a 40%
Total energy consumption (MWh)
(calculated as the sum of lines 6, and 11)
n/a 1 226,1
* The comparative is not available, as 2024 constitutes a first reporting year
2.2.6.2. Datapoints relevant to undertakings with operations in high climate impact sectors
LINK has no operations in any of the high climate impact sectors, as listed in NACE Sections A to H and
Section L (as defined in Commission Delegated Regulation (EU) 2022/1288). LINK does not produce
energy. The detailed datapoints related to such operations/ energy production have therefore been
assessed as not material and consequently- omitted.
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2.2.7. [E1-6] Gross Scopes 1, 2, 3 and total GHG emissions
2.2.7.1. Gross Scopes 1, 2, 3 and total GHG emissions
LINK’s GHG reporting includes Scope 1, 2 and Scope 3 emissions. The data on LINK’s GHG emissions,
and how each scope was included, is presented in a table below. The scope of the data and its
limitations have been explained in chapters 2.2.7.2 and 2.2.7.4 below.
Scope 1 data covers direct emissions related to (1) Stationary combustion and (2) Transportation.
Since LINK does not operate any installations that are subject to regulated Emission Trading Schemes
(ETS), no GHG emissions from regulated emission trading schemes have been identified.
Scope 2 data covers indirect emissions related to (1) Power consumption- office, (1) Power
consumption- data centres/ servers, (3) District heating /cooling, and (4) EV Vehicle. Both location-
based and market-based emissions have been calculated.
Scope 3 data covers activities LINK believes are the most significant sources of indirect emissions
from its value chain, namely: (1) Upstream emissions related to fuel consumption, (2) Business (air)
travel, (3) Employee commuting, (4) Purchased goods and services, which includes (a) IT equipment
and (b) SaaS/ cloud services, as well as (5) Waste generated in operations.
LINK’s GHG report has been published on its corporate webpage:
https://www.linkmobility.com/legal/sustainability/ghg-report. The calculations are based on the
principles, requirements and guidance provided by the Green House Gas protocol, as prescribed
by the ESRS.
Gross location-based Scope 2 GHG
emissions (tCO2eq)
n/a n/a 184,1 n/a n/a n/a n/a n/a
Gross market-based Scope 2 GHG
emissions (tCO2eq)
n/a n/a 234,8 n/a n/a n/a n/a n/a
Retrospective Milestones and target years**
Base
year*
Com
para
tive
N =
2024
% N/
N-1
2025 2030 (2050)
Annual %
target /
Base year
Scope 1 GHG emissions
Gross Scope 1 GHG emissions (tCO2eq) n/a n/a 67,1 n/a n/a n/a n/a n/a
Percentage of Scope 1 GHG emissions from
regulated emission trading schemes (%)
n/a n/a 0% n/a n/a n/a n/a n/a
Scope 2 GHG emissions
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Retrospective Milestones and target years**
Base
year*
Com
para
tive
N =
2024
% N/
N-1
2025 2030 (2050)
Annual %
target /
Base year
Significant scope 3 GHG emissions
Total Gross indirect (Scope 3) GHG
emissions (tCO2eq)
n/a n/a 638,1 n/a n/a n/a n/a n/a
1) Purchased goods and services n/a n/a 153,7 n/a n/a n/a n/a n/a
[optional]
incl. cloud computing and data centre
services
n/a n/a 65.7 n/a n/a n/a n/a n/a
2) Capital goods -
3) Fuel and energy-related activities (not
includ-ed in Scope 1 or Scope 2)
-
4) Upstream transportation and distribution n/a n/a 14,4 n/a n/a n/a n/a n/a
5) Waste generated in operations n/a n/a 0,1 n/a n/a n/a n/a n/a
6) Business traveling n/a n/a 257,0 n/a n/a n/a n/a n/a
7) Employee commuting n/a n/a 212,9 n/a n/a n/a n/a n/a
8) Upstream leased assets -
9) Downstream transportation -
10) Processing of sold products -
11) Use of sold products -
12) End-of-life treatment of sold products -
13) Downstream leased assets -
14) Franchises -
15) Investments -
Total GHG emissions
Total GHG emissions (location-based)
(tCO2eq)
n/a n/a 889,3 n/a n/a n/a n/a n/a
Total GHG emissions (market-based)
(tCO2eq)
n/a n/a 940,0 n/a n/a n/a n/a n/a
* Base year will be defined by 2026 as the latest, within the framework of the Science Based Targets initiative.
** Targets will be defined by 2026 as the latest, within the framework of the Science Based Targets initiative.
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2.2.7.2. Scope of the GHG emissions’ data and its disaggregation
Emissions were allocated using operational control as the consolidation approach. The GHG
numbers are based on data collected from entities that are covered by the scope of consolidation.
The calculations are based on material climate and energy data from LINK’s offices and activities, as
described in detail in a table below. Certain limitations result from the availability and materiality of
the data. To some extent, estimations have been made to address the missing data. 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 information has not been further
disaggregated by country, segment, activity, subsidiary or GHG category, as that was found not needed
for a proper understanding of LINK’s GHG emissions and its impact on climate change. Similarly, the
total GHG emissions have not been further disaggregated showing their split across the value chain
(Upstream, Own operations, Transport, Downstream), as that was found not necessary for a proper
understanding of LINK’s GHG emissions and its impact on climate change.
Country Location LINK entity Inclusion Comments
Austria
Graz LINK Mobility Austria GmbH Included
Vienna BK Invest GmbH not mate-rial
No office, therefore
not material in total
emission profile
Vienna Simple SMS GMbH not mate-rial
No office, therefore
not material in total
emission profile
Bulgaria
Sofia LINK Mobility Bulgaria EAD Included
Sofia Allterpay EOOD not material
No office, therefore
not material in total
emission profile
Colombia
Medellin Atenea Mobile SAS Included
New company / office
with Kronos
Medellin Kronos Mobile SAS Included
New company / office
with Atenea
Denmark
Copenhagen All Danish entities Included
Kolding All Danish entities Included
Vejen All Danish entities not mate-rial
No office, therefore
not material in total
emission profile
Finland Helsinki All Finnish entities Included
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Country Location LINK entity Inclusion Comments
France
Boulogne-
Billancourt
All French entities Included
Roanne All French entities Included
Rennes All French entities not mate-rial
No office, therefore
not material in total
emission profile
Germany
Hamburg LINK Mobility GmbH Included
Hamburg
GfMB Gesellschaft für
Mobiles Bezahlen
not mate-rial
No office, therefore
not material in total
emission profile
Hungary Budapest LINK Mobility Hungary Kft. Included
Italy
Arezzo LINK Mobility Italia Srl Included
Belluno LINK Mobility Italia Srl Included
Bologna LINK Mobility Italia Srl Included
Milan LINK Mobility Italia Srl not mate-rial
Co-working space
leased, few staff,
therefore not material in
total emis-sion profile
Rome LINK Mobility Italia Srl not mate-rial
Co-working space
leased, few staff,
therefore not material in
total emis-sion profile
Turin LINK Mobility Italia Srl not mate-rial
No office, therefore
not material in total
emission profile
Mexico Mexico City
Pandora Mobile Group S de
R.L. de C.V.
Included
No office- only Scope
3 /Air Travel, IT
Equipment, and SaaS/
Netherlands Breukelen All Dutch entities Included
No office- only scope 2 /
electricty usage for data
centers/
Norway
Bergen All Norwegian entities Included
Oslo All Norwegian entities Included
Operations
team
N/A LINK Mobility Group ASA Included
Group level Saas/Cloud
services
Poland Gliwice LINK Mobility Sp.z.o.o Included
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Country Location LINK entity Inclusion Comments
Portugal Porto
Curiosity Layer
- Investigacao e
Comunicacao, Unipessoal,
LDA
Included New company
North
Macedonia
Kumanovo
Link Mobility Development
Center DOOEL
Included
Kumanovo
Link Mobility Development
Center DOOEL
Included
Skopje
Tera Communications
DOOEL
Included
Romania Bucharest All Romanian entities Included
Spain
Madrid LINK Mobility Spain S.L.U. Included
Castellon Net Real Solutions S.L. Included New company
Sweden Stockholm LINK Mobility AB Included
Switzerland Rorschach LINK Messaging AG Included No permanent office
UK
London LINK Mobility UK Limited Included
No permanent office -
only Scope 3 /Air Travel
and IT Equipment/
Doncaster Reach-Data Ltd. Included New company
Edinburgh HSL Messaging Limited not mate-rial
No office, therefore
not material in total
emission profile
2.2.7.3. Disclosure of significant changes in definition of what constitutes reporting
undertaking and its value chain and explanation of their effect on year-to-year
comparability of reported GHG emissions
The scope of the data included in the reported GHG emissions is explained in chapter 2.2.7.2 above.
Since LINK reports the GHG data in line with the ESRS- as part of its sustainability statement- for the
first time, no significant changes are disclosed, as no prior reporting period is available.
2.2.7.4. Disclosure of methodologies, significant assumptions and emissions factors used
to calculate or measure GHG emissions
a. Methodology and significant assumptions
LINK’s emissions are calculated based on the international standard known as the Greenhouse Gas
Protocol (GHGP). The standard has been developed for measuring and reporting greenhouse gases
and is based on private initiatives through the World Resource Institute (WRI) and the World Business
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Council for Sustainable Development (WBCSD). The GHG protocol consists of an accounting modelling
that explains how the company can quantify its direct and indirect greenhouse gas emissions, and
distinguishes between direct and indirect emissions within three scopes:
•
Scope 1: direct sources of GHG emissions that are owned or controlled by the company, such as fuel
for cars or heating energy from combustion processes.
•
Scope 2: indirect emissions from purchased energy such as electricity and district heating/cooling,
as well as energy used in electric vehicles.
•
Scope 3: other indirect emissions that lie along the value chain and therefore also within the
responsibility of the company, such as emissions from purchased goods and services. Emissions
related to the company’s activities, but which occur from sources not owned or controlled by the
business. This includes, among other things, data equipment, office furniture, business flights,
waste, and goods transport. According to the GHG protocol, it is voluntary to report this category
of emissions, and there is usually large uncertainty associated with this data. Scope 3 is for most
companies the most significant emission source, according to Science Based Targets initiative¹².
LINK has calculated its climate impact from scope 1, scope 2 and scope 3 emissions. The emission
factors and sources used for calculating emission from electricity, district heating and combustion of
natural gas (for heat at office), use of other fossil energy sources and scope 3 related activities are
described below, in section b. “Emission factors and sources”.
Scope 1
•
Transportation: emissions from ICE cars leased by LINK are calculated on either the amount of fuel
used, or distance travelled. For distance travelled average WLTP emission factors (gCO2/km) for cars
sold in the EU (published by the European Environment Agency) have been used. Emission related to
EV cars is calculated based on total energy use times electricity emission factor in respective country.
Total energy use is calculated based on average energy use per km, and total distance travelled.
Scope 2
•
Electricity consumption: GHG emissions from electricity consumption in each affiliate/country are
calculated based on country-specific emission factors, gathered and published by AIB (Association
of issuing bodies)¹³ and other sources (see table about emission factors for details). Emission
from the use of electricity is calculated with both location-based and market based approach, in
accordance with the GHG-protocol. AIB also provides information on the split between the various
energy sources for the given countries. This information have been used to split energy into three
categories: renewable (wind, sun, hydro etc.), nuclear and fossil (gas, oil, coal etc.), to estimate
respective shares of energy sources under scope 2, with both the location-based and marked-based
approach.
•
Location-based method reflects the average emissions intensity of grids on which energy
consumption occurs (using mostly grid-average emission factor data).
¹²https://sciencebasedtargets.org/blog/scope-3-stepping-up-science-based-action
¹³https://www.aib-net.org/
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•
Market-based method reflects emissions based on the electricity that organizations have chosen
to purchase, often spelled out in contracts or instruments like Guarantees of Origin (GOs) or
Renewable Energy Certificates (RECs). For some countries market-based emission factors for
electricity are not available- in such cases the same emission factor is used in both methods.
•
District heating and cooling: the emission factors for district heating and cooling are based on specific
data provided by each energy supplier and reported by different offices using this type of energy. In
one country specific emission factors for district heating are missing, and therefore the electricity
emission factor as a proxy to calculate emissions from district heat without specific emission factors
from energy providers or other national emission factors for district heating have been used. The
energy source from district heating/cooling is either renewable or fossil fuel.
Scope 3
•
For indirect emissions from activities classified under scope 3, different methods and sources have
been used, depending on respective activity and data availability. The below table disclose the full list
of the categories included and excluded from the inventory. Categories included are assumed to be
the most significant sources of scope 3 GHG-emissions from LINK. The remaining categories have
been assessed as not bringing any material emissions. Factors used to estimate scope 3 emissions
are presented below, in section b. “Emission factors and sources”.
It must be noted that estimated scope 3 emissions are generally uncertain, because of large variations
and uncertainties in emission factors used, which are usually based on several assumptions and
approximations.
Scope 3
category
Included
Type of data
/primary data?/
Emissions
primary data
Emissions
estimated
(tCO2)
In total
(tCO2)
13,1 625,0 638
1
Purchased
goods and
services
YES- IT
equipment
Units
/No, emissions estimated
based on EPDs/
88 88
Cloud
computing
and data
centre
services
Yes
Primary data and estima-
tions based on activity data
/Yes, some values are pri-
mary data from supplier./
13,1 52,6 65,7
2 Capital goods
No - no new
ma-chinery/
buildings/
vehicles (offices
are leased)
Disclosure of scope 3 data included/excluded and type of data used to estimate scope 3 emissions.
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Scope 3
category
Included
Type of data
/primary data?/
Emissions
primary data
Emissions
estimated
(tCO2)
In total
(tCO2)
13,1 625,0 638
3
Fuel and
energy-related
activities not
included in
scope 1 and
2 (upstream
emis-sions)
Yes, partly
upstream
emissions for
scope 1 activities
included
Estimated based on
consumption numbers
/No, estimates based on
consumption numbers/
14,4 14,4
4
Upstream
trans-portation
and distribution
Transportation
of IT equipment
included in
calculation in
category 1
Activity data: units of IT
equipment bought.
/No, see category 1/
5
Waste
generated in
operations
Yes
Estimated numbers
/No, values based on
reported waste numbers in
kg/
0,1 0,1
6
Business
traveling
Yes
Estimated numbers based
on travel activity
/No, use of ICEC emission
calculator and trip data./
257 257,0
7
Employee com-
muting
Yes
Estimated based on survey
data
/No, survey data/
212,9 212,9
8
Upstream
leased assets
not relevant
Emission related to use of
vehicles, data centers and
offices (leased) is included
in scope 1 and 2
9
Downstream
transportation
Not relevant -
10
Processing of
sold products
Not relevant -
11
Use of sold
prod-ucts
Not relevant -
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Scope 3
category
Included
Type of data
/primary data?/
Emissions
primary data
Emissions
estimated
(tCO2)
In total
(tCO2)
13,1 625,0 638
12
End-of-life
treat-ment of
sold products
Not relevant -
13
Downstream
leased assets
No assets leased
to others
-
14 Franchises Not relevant -
15 Investments Not included -
Share of primary Scope 3 emissions 2 %
•
For the waste disposal emission factors from Department for Energy Security and Net Zero (UK)
are used. When estimating emissions from procurement of IT equipment, the reported emissions
from suppliers/producers of IT equipment are used, together with the EPDs (Environmental Product
Declaration) where they exist. Air travel is calculated using ICAO (International Civil Aviation
Organization) emissions calculator (ICEC)¹ for specified trips. Emissions from commuting are
based on survey of travel/commuting habits and average emission factors for different modes of
transportation. Emissions related to server/data center services are either based on emissions
provided by service provider (i.e. primary data) or calculated based on reported energy use for data
center/server services purchased and used. Emission or energy data are reported by each affiliate/
office and used to give an estimate of emissions from this type of services. When energy use is
reported the same electricity factor (location based) is used as when calculating emissions from
electricity use at the office.
¹A detailed description of the methodology used in ICEC can be found her:
Methodology ICAO Carbon Emissions Calculator_v13_Final.pdf
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b. Emissions factors and sources
Emission factors and sources have been mostly derived from:
Scope 1 emissions:
•
Norwegian Environment Agency
•
European Environment Agency
•
Transport and Environment initiative
Scope 2 emissions:
•
AIB (Association of Issuing Bodies)
•
JRC EU
•
IRENA
•
Fjernkontrollen.no
•
Energiföretagen.se
Scope 3 sources:
•
Department for Energy Security and Net Zero (UK)
•
European Environment Agency
•
ICEC calculator- ICAO
•
Product information of various devices (laptops, workstations, monitors, docking stations, handheld
devices, accessories and peripheral devices)
Energy mix:
•
AIB
•
IEA
•
IEA DHC (see figure 6 - in linked report)
•
Finnish Energy
•
Norsk Fjernvarme
•
Energiföretagen
•
ePURE
•
miljodirektoratet.no
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1 Scope 1
a
Biogenic emissions of CO2 from
combustion or bio-degradation of biomass
not included in Scope 1 GHG emissions
Not relevant (no data on biogenic emissions
availa-ble).
2 Scope 2
b
% of contractual instruments, Scope 2
emissions
10 out of 24 LINK’s offices that are
included in ener-gy calculations reported
purchase of electricity with Guarantees
of Origin, which results in 12% share of
such renewable energy in the total scope 2
energy use (including office, datacentres/
server, DH/DC, but excluding EV).
c
Type of contractual instruments, Scope 2
emis-sions
Guarantees of Origin
d
% of market-based Scope 2 GHG emissions
linked to purchased electricity bundled with
instruments
Not included (voluntary disclosure).
e
% of contractual instruments used for
sale and purchase of energy bundled with
attributes about energy generation in
relation to Scope 2 GHG emissions
Not included (no data regarding the
energy attributes of energy bundeled with
GoO; energy mix under disclosure E1-5 is
calculated based on AIB numbers.
f
% of contractual instruments used for
sale and purchase of unbundled energy
attribute claims in relation to Scope 2 GHG
emissions
See point b. above.
g
Types of contractual instruments used for
sale and purchase of energy bundled with
attributes about energy generation or for
unbundled en-ergy attribute claims
Not relevant.
h
Biogenic emissions of CO2 from
combustion or bio-degradation of biomass
not included in Scope 2 GHG emissions
Not relevant (no data on biogenic emissions
availa-ble).
2.2.7.5. Specific disclosures related to Scope 1, Scope 2 and Scope 3
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3 Scope 3
% of GHG Scope 3 calculated using
primary data
Approximately 2%
i
Disclosure if why Scope 3 GHG emissions
cate-gory has been excluded
Scope 3 data covers activities LINK
believes are the most significant sources of
indirect emissions from its value chain. The
remaining categories have been excluded
based on this assumption, and the lack of
available data.
j
List of Scope 3 GHG emissions categories
in-cluded in inventory
(1) Business (air) travel, (2) Employee
commuting, (3) Purchased goods and
services, which includes (a) IT equipment
and (b) SaaS/ cloud services, (4) Waste
generated in operations, and (5) Upstream
transpor-tation and distribution.
k
Biogenic emissions of CO2 from
combustion or bio-degradation of biomass
that occur in value chain not included in
Scope 3 GHG emissions
Not relevant (no data on biogenic emissions
availa-ble).
l
Disclosure of reporting boundaries
considered and calculation methods for
estimating Scope 3 GHG emissions
Described in chapter 2.2.7.4
2.2.7.6. Disclosures related to the GHG emissions intensity
a. GHG emissions intensity, location-based and market-based
GHG intensity per net revenue Comparative* N = 2024 (base year) N – 1*
Total GHG emissions (location-
based) per net revenue
(tCO2eq/1000 NOK)
n/a
0,00013 tCO2eq/1000 NOK
n/a
Total GHG emissions (market-
based) per net revenue
(tCO2eq/1000 NOK)
n/a
0,00013 tCO2eq/1000 NOK
n/a
* The comparative is not available, as 2024 constitutes a base year
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b. Disclosure of reconciliation to financial statements of net revenue used for
calculation of GHG emissions intensity
Net revenue
Amount
[1000 NOK]
Line in the financial statement
(reference)
Net revenue used to calculate GHG intensity
6,993,807 Consolidated income statement
2.2.8. [E1-9] Anticipated financial effects from material physical and
transition risks and potential climate-related opportunities
Since 2024 is the first year of preparation of LINK’s sustainability statement that is fully compliant with
ESRS, all the datapoints under the disclosure requirement E1-9 has been phased-in, in accordance with
Appendix C of ESRS1.
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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 under disclosure requirement ESRS 2 BP-2 (chapter 1.1.2.8).
The description of how LINK identified the scope of the sustainability reporting is provided 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 disclosure requirements covered by G1-1, G1-2, G1-3 and G1-4,
alongside the minimum disclosure requirements covered by ESRS 2 MDR, relevant to each of the above
listed material topics. The disclosures E1.GOV-1 are included under ESRS 2 GOV-1.
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 under
disclosure requirements ESRS 2 IRO-2 (chapters 1.1.12.3 and 1.1.12.4).
4.1. [ESRS G1]
4.1.1. [G1-1] Business conduct policies and corporate culture
4.1.1.1. Policies in place to manage material impacts, risks and opportunities related to
business conduct matters and how LINK fosters its corporate culture.
Business conduct matters, including- among others- notions related to corporate culture, are managed
under LINK’s ESG policy. It encompasses issues related to all material sustainability matters. Some
notions related to business conduct are also included in other LINK’s policies, as described in chapters
4.1.1.3.c and 1.1.2.8.c.
> Key contents of the ESG 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 the 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:
•
Environmental factors: EU Taxonomy, Energy, Climate change, Waste management;
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•
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.
> Scope of the ESG 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.
> Most senior level in organisation that is accountable for implementation of the ESG Policy
The Global Leadership Team (GLT) has overall responsibility for the implementation of the ESG policy.
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> Third-party standards or initiatives that are respected through implementation of the ESG
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.
> Description of consideration given to interests of key stakeholders in
setting theESG 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.
> Explanation of how the ESG 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:
https://www.linkmobility.com/legal/sustainability/esg-policy.
4.1.1.2. Description of how LINK establishes, develops, promotes and evaluates its corporate
culture
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.
LINK establishes, promotes, and evaluates its corporate culture by implementing relevant policies, as
described above, and furthermore, by taking actions that are assessed against the targets with the use
of relevant metrics. These actions, metrics and targets are described below.
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a. Actions
>
Disclosure of key actions
LINK has taken the following actions related to its corporate culture (including, among others, notions
of whistleblowers’ protection and anti-corruption/ anti-bribery):
•
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.
•
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.
•
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 4.1.2.2, 4.1.2.3).
•
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.
> Description of scope of key actions
The scope of the relevant actions is as follows:
•
Employees’ training – in 2024 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.
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•
Whistleblowing channel – the channel is available for all LINK employees in an online system
delivered by an external provider.
•
Supplier Code of Conduct – the document is available on LINK’s webpage: https://www.linkmobility.
com/legal/value-chain/supplier-code-of-conduct, and aims at covering all supply-side entities.
•
Supplier Due Diligence process – in 2024 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.
> Time horizon under which key actions are 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.
•
Whistleblowing channel – has been available for LINK’s employees for several years, implemented
on a rolling bases.
•
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.
> Description of key actions 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.
> Disclosure of quantitative and qualitative information regarding progress of actions or
action plans disclosed in prior periods
Not relevant in the first reporting period.
> 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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b. Metrics
>
Description of metrics used to evaluate performance and effectiveness, in relation to
material IROs
LINK uses the following metrics to evaluate performance and effectiveness in relation to material
impacts, risks and opportunities connected with the material sustainability matters “Corporate culture”,
“Protection of whistleblowers” and “Corruption and bribery”:
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec)
– the metric used to track the effectiveness of the action “Employees’ training”; it 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 used to track the effectiveness of the action “LINK Voice”;
it reflects the reliability of the results of “LINK Voice” survey.
•
Employee engagement score – the metric used to track the effectiveness of the action “LINK Voice”;
it 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.
•
Percentage of non-handled whistleblowers’ notifications – the metric used to track the effectiveness
of the action “Whistleblowing channel”; it reflects LINK’s progress in handling whistleblowers’ reports.
•
Percentage of non-handled incidents of corruption/ bribery – the metric used to track the
effectiveness of the action “Employee Code of Conduct”; it reflects LINK’s progress in ensuring the
implementation of a zero-tolerance approach to corruption and bribery.
•
Annual review of the Transparency Report – the metric used to track the effectiveness of the actions
“Transparency Act Report”, “Supplier Due Diligence process”, and “Supplier Code of Conduct”; it
reflects LINK’s progress towards ensuring its compliance with the Norwegian Transparency Act.
> Disclosure of methodologies and significant assumptions behind metrics
•
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
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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.
•
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.
•
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 – the metric of a qualitative nature, with [yes/no] values.
The metric is monitored on annual bases.
> 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.
c.Targets
>
Relationship of targes with policy objectives
•
Targets related to the action “Employees’ training” – 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.
•
Targets related to the action “Employee Code of Conduct” – 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.
•
Targets related to the action “LINK Voice” – 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.
•
Targets related to the action “Whistleblowing channel” – 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.
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•
Targets related to the action “Transparency Act Report” – 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.
> Measurable targets, their nature and scope
The following targets are relevant to the metrics specified in point b) 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 December 31st 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 December 31st each year. It is monitored
in an internal electronic system on annual bases. It includes all LINK employees group-wide according
to policy.
•
Percentage of non-handled whistleblowers’ notifications – the target is set to 0% as of December
31st each year. It is monitored on annual bases. It includes all whistleblower’s reports group-wide.
•
Percentage of non-handled incidents of corruption/ bribery – the target is set to 0% as of December
31st each year. It is monitored on annual bases. It includes all incidents reported/discovered group-
wide.
•
Annual review of the Transparency Report – the target is set to “YES” as of 31st December each year.
It is monitored on annual bases.
> Baseline value in year 2024
Since 2024 is the first year when LINK prepares its sustainability statement fully compliant with the
CSRD, it has decided to set its baseline year for all targets to 2024, unless expressly specified otherwise.
The baseline values are therefore the same as the ones specified in below.
> Period to which targets apply and indication of milestones or interim targets
The targets apply to the period, for which LINK’s strategy is set, that is until 2025. The baseline for
the disclosures relevant to the sustainability reporting purposes is specified above No milestones or
interim targets have been set.
> Description of methodologies and significant assumptions used to define targets
Not material for the described target.
> Target related to environmental matters is based on conclusive scientific evidence
Not material for the described targets.
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> Disclosure of how stakeholders have been involved in targets setting
The targets were set out based on the internal expertise. Stakeholders were not directly involved.
> Description of any changes in targets and corresponding metrics or underlying
measurement methodologies, significant assumptions, limitations, sources and adopted
processes to collect data
Not material, as the targets are reported for the first time.
> Description of performance against disclosed targets
As of December 31st 2024 the metrics amounted to, and the performance against the targets
was as follows:
•
Percentage of employees to complete employees’ training (general compliance, GDPR, InfoSec) –
83,8%, which fulfills the target of 100% in ~84%.
•
LINK Voice participation rate – 95%, which exceeds the target of ~75%.
•
Employee engagement score – 70, which fulfills the target of 75 in ~93%.
•
Percentage of non-handled whistleblowers’ notifications – 0%, which fulfills the target in 100 %.
•
Percentage of non-handled incidents of corruption/ bribery – 0%, which fulfills the target in 100 %.
•
Annual review of the Transparency Report – “YES”, which fulfills the target.
4.1.1.3. Mechanisms for identifying, reporting and investigating concerns about
unlawful behaviour or behaviour in contradiction of its code of conduct orsimilar
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 behaviour 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 chapters 4.1.1.1, 4.1.1.2, and 4.1.1.3.c.
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 will consider auditing 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 chapters 4.1.1.1, 4.1.1.2, and 4.1.1.3.c.
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c. Policies on protection of whistle-blowers (or timetable for their implementation)
As mentioned above, LINK has implemented the Whistleblowing Policy, which is regularly reviewed and
updated if needed. The policy is described below.
> Key contents of the Whistleblowing 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.
> Scope of the Whistleblowing 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 utilised for reporting of any misconduct, covering
also ESG matters.
> Most senior level in organisation that is accountable for implementation of the
Whistleblowing 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.
> Third-party standards or initiatives that are respected through implementation of the
Whistleblowing 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 October 23, 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).
> Description of consideration given to interests of key stakeholders in setting the
Whistleblowing 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.
> Explanation of how the Whistleblowing 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.
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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, in chapters
4.1.1.1 and 4.1.1.3.c.
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 chapter 1.1.2.8.b.
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.
4.1.1.4. Entity is subject to legal requirements with regard to protection of whistleblowers
LINK is subject to the following legal acts concerning protection of whistleblowers:
•
regulations that result from the Directive (EU) 2019/1937 of the European Parliament and of the
Council of October 23, 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 chapters 4.1.1.1,
4.1.1.2 and 4.1.1.3.
4.1.2. [G1-2] Management of relationships with suppliers
4.1.2.1. Policy to prevent late payments, especially to SMEs
On a general level, the sustainability matter: “Management of relationships with suppliers” is managed
under LINK’s ESG policy, which includes a chapter on due diligence, covering the supplier due diligence.
The ESG policy is described in chapter 4.1.1.1.
LINK has not adopted a specific 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.
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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.
4.1.2.2. 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 in 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.
The process follows in principle the methodology proposed by the OECD Due Diligence Guidance
for Responsible Business Conduct³, which reflects standards set up in the OCED Guidelines for
Multinational Enterprises³. It also fulfils 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 in 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.
³OECD (2018), OECD Due Diligence Guidance for Responsible Business Conduct, OECD Publishing.
mneguidelines.oecd.org/OECD-Due-Diligence-Guidance-for-Responsible-Business-Conduct.pdf
³OECD (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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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
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.
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.
4.1.2.3. 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 4.1.2.2 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;
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•
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 in chapters 4.1.1.2.
4.1.3. [G1-3] Prevention and detection of corruption and bribery
4.1.3.1. 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
programme as well as relevant codes of conduct (Employee Code of Conduct and Supplier Code of
Conduct). The whistleblowing channel may be used for reporting any incidents. The description of the
policy, as well as information on corresponding actions, are provided in chapters 4.1.1.1, 4.1.1.2, 4.1.1.3.
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. 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.
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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. Manager who receives such report will inform CEO or GLT members, as applicable.
4.1.3.2. 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 4.1.1.1.
4.1.3.3. 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 4.1.1.2.
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.
4.1.3.4. 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 4.1.1.2.
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4.1.4. [G1-4] Incidents of corruption or bribery
4.1.4.1. Action plans and resources to manage material impacts, risks, and opportunities
related to corruption and bribery
LINK has implemented the ESG Policy with a dedicated chapter on anti-corruption and anti-bribery. The
ESG policy is described in chapter 4.1.1.1. The following actions have been taken to manage material
IROs related to corruption and bribery:
•
Employees’ training
•
Employee Code of Conduct
•
Supplier Code of Conduct
These actions are assessed against the targets with the use of relevant metrics, as described in
chapter 4.1.1.2.
4.1.4.2. Numerical indicators related to incidents related of corruption and bribery
In 2024 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 662 employees across Europe with more than 20 offices located in 18 European
countries and 2 countries in LATAM.
LINK has more than 20 years of experience in providing mobile messaging services and mobile
solutions for businesses, public sectors and organizations. For decades, LINK has operated in the
Nordics, the world’s most innovative market for digital mobile solutions, and has, over 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
In 2024, LINK Mobility further strengthened its position as the market leading provider of digital
messaging in Europe. The company maintained its strong market presence, with a dominant share
in key regions, including a 53% market share in Norway. LINK also retained its top three positions in
several European markets. LINK operates in 18 European countries and has presence in Latin-America
(Mexico and Colombia) as part of the acquisition of Net Real Solutions in Spain. It expanded its
presence into Portugal in 2024 through the acquisition of EZ4U, one of the three strategic acquisitions
completed during the year.
The digital mobile messaging market is experiencing strong growth, driven by the significant adoption
potential of digital messaging across Europe and the development of more advanced products.
Compared to the more mature Nordic market, adoption rates in other European countries still have
considerable room for expansion. In 2024, the Nordics saw an average of 436 A2P SMS messages sent
per inhabitant, while the corresponding figure in other European countries was just 186.
Market adoption of select Communications Platform as a Service (CPaaS) products is accelerating,
as demonstrated by LINK’s new contract wins in the area, which grew 78% year-over-year. Additionally,
progress in enabling RCS support on Apple devices is expanding both the reach and demand for
advanced messaging solutions within LINK’s footprint. As RCS and OTT support continues to develop,
new opportunities are emerging across various use cases.
The company’s focus on innovation, scalability, and customer-centric solutions positions it for further
growth, securing new enterprise clients while strengthening relationships with partners to scale
sales faster.
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As businesses, public institutions, and organizations increasingly prioritize digital messaging as their
primary communication channel, LINK is well-positioned to capture future growth opportunities and
reinforce its market leadership in Europe.
Comments related to the nancial 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 2024 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 2024 in accordance with the International
Financial Reporting Standards (IFRS) as adopted by the European Union.
Revenue, costs, and profits
In 2024, LINK reported revenue of NOK 6 994 million, an increase of 11% from NOK 6 282 million in
2023. LINK’s gross profit was NOK 1 528 million (NOK 1 348 million).
Operating costs (including payroll and related services and other operating expenses) were NOK 929
million (NOK 870 million) and include non-recurring costs of NOK 119 million. The non-recurring costs
include a share-based compensation program of NOK 42 million, restructuring costs of NOK 39 million,
and expenses related to acquisitions of NOK 39 million. Depreciation and amortization were NOK 334
million (NOK 338 million).
Net financial items amounted to a negative NOK 43 million (negative NOK 89 million) and constituted
a net interest expense of NOK 64 million linked to an outstanding bond, net other financial expenses
of NOK 16 million and a positive currency effect of NOK 37 million. LINK’s outstanding EUR 171 million
bond (LINK01) carries a fixed coupon of 3.375% and matures in December 2025; the outstanding EUR
125 million bond (LINK02) carries a coupon of 3-month EURIBOR + 2.35% per annum and matures in
October 2029.
Income tax expense is NOK 50 million (NOK 13 million), resulting in a net profit from continuing
operations of NOK 172 million (negative NOK 38 million).
Annual result and allocation
The board proposes that the 2024 net profit will be transferred to accumulated losses.
Financial position, cash flow, and liquidity
As of December 31, 2024, LINK’s total assets amounted to NOK 10 722 million (NOK 11 680 million),
of which intangible assets were NOK 6 435 million (NOK 6 162 million). Intangible assets are mainly
comprised of goodwill equal to NOK 4 673 million (NOK 4 389 million). Trade receivables and other
receivables amounted to NOK 1 610 million (NOK 1 380 million) and cash and cash equivalents to NOK 2
479 million (NOK 1 097 million). Total equity was NOK 5 378 (NOK 5 514 million) and constituted of NOK
1.5 million in share capital, a share premium of NOK 5 977 million, and NOK 465 million in accumulated
losses and translation differences. NOK 345 million (negative) is representative of own shares.
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Long-term liabilities were NOK 1 744 million (NOK 4 321 million) and consisted mainly of the EUR 125
million LINK02 bond; LINK01 is classified as a current liability.
LINK’s cash flow from operating activities was NOK 622 million (NOK 532 million). Cash flow from
investing activities was negative NOK 333 million (negative NOK 116 million). Cash flows from
financing activities amounted to a negative NOK 1 234 million (negative NOK 281 million), mainly
reflecting purchase of LINK shares (negative NOK 345 million), proceeds from the LINK02 bond (NOK
1 464 million), repayment of borrowings (negative NOK 2 212 million), and interest payments (negative
NOK 125 million).
Comments related to the Sustainability statement
The requirement to provide a Sustainability Report based on the ESRS is implemented into Norwegian
law through “Lov om endringer i regnskapsloven mv. (bærekraftsrapportering)” effective November 1st
2024. The law implements the EU Corporate Sustainability Reporting Directive (CSRD), and provides
changes to multiple laws, including the Accounting Act (Regnskapsloven).
The Sustainability statement for 2024 shows the steps taken in LINK Mobility to reach compliance with
the sustainability reporting requirements included in the Accounting Act Chapter 2. In particular, the
requirement to provide reporting following ESRS in the Accounting Act §2-8.
Sustainability in LINK
LINK’s board of directors have 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. LINK’s Environmental,
Social and Governance (ESG) strategy was initially concluded in 2021. In 2024, an updated strategy
was adopted by the Board of Directors, with a commitment for LINK to reduce emissions based on
Science Based Targets during the term 2025-2027. The commitment to integrate in the annual report
a sustainability statement fully based on the ESRS, and to include carbon data from Scope 1, 2 and 3,
remains in the updated strategy. LINK’s ESG policy is available at
https://www.linkmobility.com/legal/sustainability/esg-policy.
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The board has considered the ESG factors 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 is 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.
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 .
In 2024, LINK Committed to developing targets for reducing its emissions under the Science Based
Targets initiative (SBTi). SBTi provides companies with a clearly defined path to reduce emissions in
line with the Paris Agreement goals.
LINK’s commitment to Science-Based Targets can be found here:
https://sciencebasedtargets.org/target-dashboard#dashboard
Materiality assessment
Since the stated global understanding of ESG as an important factors affecting businesses 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 2024, the materiality assessment was performed for the second time
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.
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Greenhouse Gas (GHG) emissions
To get a better picture of energy consumption and greenhouse gas emissions related to LINK’s
activities, detailed information information from LINK’s 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 been done for the second year in LINK in 2024, where
the activities considered to be the most significant sources of indirect scope 3 emissions are included.
The calculations have been made according to the Greenhouse Gas Protocol (GHGP).
The table below summarizes the GHG-account for LINK Mobility in 2023 and 2024. Since 2023, we
have reported 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 come
from air travel and commuting.
A more detailed breakdown of the GHG-account and a comparison of 2022, 2023 and 2024 is described
in the GHG-report for 2024, available at Greenhouse Gas Protocol Report .
2024 2023
Scope Activity
Activitity
data
Unit of
measure
Tonnes
CO2e
Activitity
data
Unit of
measure
Tonnes
CO2e
Scope 1
Stationary combustion
Natural gas consumption 26 205 kWh ICV/year 5.4 43 825 kWh ICV/year 9.0
Transportation
Gasoline 1 428 liters/year 3.3 638 liters/year 1.5
Diesel 11 847 liters/year 31.5 5 114 liters/year 13.6
Diesel car (distance
travelled)
107 238 km/year 15.5 113 794 km/year 16.5
Gasoline car(distance
trav-elled)
85 772 km/year 11.4 73 667 km/year 9.8
Scope 1 In total 67.1 50.4
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2024 2023
Scope Activity
Activitity
data
Unit of
measure
Tonnes
CO2e
Activitity
data
Unit of
measure
Tonnes
CO2e
Scope 2
Power consumption -
office
495 434 kWh/year 120.1 546 599 kWh/year 142.0
Power consumption -
data cen-ter/servers
173 700 kWh/year 26.3 173 700 kWh/year 33.1
District Heating /cooling 284 340 kWh/year 36.9 339 948 kWh/year 48.2
EV Veichle 60 720 km/year 0.8 49 172 km/year 1.4
Scope 2 (location based) 184.1 224.7
Scope 2
Power consumption -
office
495 434 kWh/year 148.1 546 599 kWh/year 194.0
Power consumption -
data center/servers
173 700 kWh/year 43.7 173 700 kWh/year 49.7
District Heating /cooling 284 340 kWh/year 36.9 339 948 kWh/year 48.2
EV Veichle 60 720 km/year 6.2
Scope 2 (market based) 234.8 291.9
Scope 1 and 2 (location based) 251.2 275.0
Scope 1 and 2 (market based) 302.0 342.3
Scope 3
Upstream emissions fuel
Scope 1
acitivties
14.4
Air travel 742 t 25 7.0 501 t 143.5
Commuting
(incl. walk/bike)
2 556 518
passenger
km
212.9 2 284 608
passenger
km
204.6
IT equipment 569 units* 88.0 391 units* 46.1
SaaS/cloud-services n/a n/a 65.7 n/a n/a 143.6
Waste 17 749 kg 0.1 47 853 kg 1.0
Scope 3 In total 638.1 538.8
In total
Scope 1+ 2 (location based) + 3
889.3 813.8
Scope 1+ 2 (market based) + 3
940 881.1
Table [number] Detailed GHG account LINK Mobility 2024 and 2023.
*Commuting km includes private transport (car etc.), public transport (train, bus etc.) and walking/biking.
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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.
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 relies on
the management of potential risks affecting LINK’s objectives.
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Key steps in the Risk Management Process
Definition of objectives and risk profile
Clear objectives and a defined risk profile are an essential basis for the risk management process.
Annual assessment of objectives is therefore performed, to ensure alignment with the risk management
process. Objectives in LINK are set out by the Board of Directors based on LINK Strategy and market
situation. Furthermore, LINK’s Material Topics, as defined in the annual Materiality Assessment,
constitute objectives for LINK.
The Board of Directors of LINK Mobility furthermore defines the risk profile for LINK Mobility, to ensure
acceptable risk levels.
Risk Identification and assessment
Identification and assessment of risks is performed in each risk area and aggregated to a group-wide
overview for review by management.
Assessment is performed by considering Probability and Consequence for each risk over four defined
levels, and calculating the final level of risk as High, Medium or Low.
Risk Management
Specification of management for each identified risk is performed in alignment with the risk profile set
for each risk area. The goal is to reduce the exposure to an acceptable level. The management types
in LINK 2024 are to avoid, mitigate, transfer or accept. Risk level and risk focus of each risk defines
thechosen management.
Measures for managing risk are defined and followed up for all risk areas annually.
Risk reporting and aggregation
The risk and mitigation actions are defined per risk area and reported to centralized function for
aggregation and creation of a group-wide risk picture.
The aggregated risk picture is prepared annually and presented to management in LINK Mobility.
The Audit Committee in LINK Mobility is presented with the status of the risk management process
through the year, and the board is provided with an annual overview of the risk picture.
The section below describes the ten risk areas and provides a general overview of risks and
management for each of these areas.
Commercial risk
LINK risks related to products, customers and competitors, hereunder loss of contracts and
opportunities, are managed under the headline of commercial risk (in previous reports referred to as
“Market risk”). Risks under the area of Commercial Risk are mainly inward facing (Financial Materiality).
LINK’s revenue, costs and profits are subject to the risk of changes in customer requirements, changes
in technology, competitor products and market expectations, and ability to adapt to market changes
resulting from technology, climate or other factors. Certain simple use cases like One-Time Passwords
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(OTP) or Two-Factor Authentications (2FA), wholesale SMS trading and basic mobile payment services
are exposed to margin pressure, and therefore particularly vulnerable. LINK is however only exposed to
simple use cases to a 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
2024 and expect increased adoption of more advanced CPaaS solutions to be supportive to margins in
coming years.
The A2P SMS market grows in high single digits annually as adoption increases throughout markets
and industries. LINK operates 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 in 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 remain 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 adapt to
channels and solutions as they mature and gain traction in the market.
Financial Market Risk
LINK’s business activities expose the group to financial market risks related to equity, interest rates,
currency, tax, liquidity and changes in cost. Cost is mainly related to prices set by Mobile Network
Operators and OTT channels. Overall, these risks are regarded as low and manageable.
As a leading provider, LINK has 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.
In October 2024, LINK refinanced parts of its outstanding LINK01 bond and changed the maturity
profile of its debt to EUR 171 million LINK01 maturing in December 2025 and EUR 125 million LINK02
maturing October 2029. The significant cash position at the end of 2024 of NOK 2.5 billion with solid
headroom beyond the working capital need reduces the refinancing risk of the debt maturity in 2025
to a minimum. The bond issuance in October 2024 was placed at a very low interest spread of 235bps
compared to similar transactions and with high investor interest, demonstrating LINK’s ability to
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manage its debt maturity either through cash pay-down or partial or full refinancing ahead of maturity.
The EUR bond exposes LINK to additional exchange rate risks. This currency risk is, however, mitigated
by LINK’s significant cash flow exposure to EUR. Through its operations, LINK expects to continue to
generate free cash flows which will further improve its financing capacity. LINK has a financial policy to
maintain net debt in the 2 - 2.5x adjusted EBITDA range, well below the current incurrence test level of
3.5x adjusted EBITDA.
LINK’s credit risk is limited to trade and other receivables and mitigated by the group’s guidelines to
ensure that credit sales are only made to customers with a sufficient credit rating. Customers with a
low credit rating 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. Losses in 2024 increased from the
previous year and were mainly driven by isolated cases in the Global Messaging, related to a long-term
client, and Western Europe related to bankruptcy of a large retail client.
LINK manages financial market 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. The 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 involves 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 defense 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.
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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 mitigate the impacts of risks in these areas are therefore continuously implemented. In
2024, the following actions should be noticed:
1. Consolidation, optimization, and harmonization of data centers, including improved redundancy
2. Implemented and operationalized new software development
lifecycle to improve software development quality
3. Strengthened governance and control on operational- and office-IT platforms
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, such as EU NIS2, are seen as relevant on the risk area.
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 2024 was managed by a centralized function under the authority of the
CEO. Starting 2025, a CISO has been appointed under the same authority. LINK’s Information Security
Policy, available on LINK Mobility homepage, is revised annually, and has since 2023 been aligned
with the EU NIS2 directive and the IEC/ISO 27001:2022. Compliance with both internal LINK Mobility
Information Security Policy and external regulations is critical to maintaining the integrity and security
of LINK’s systems. LINK’s subsidiaries are subject to annual internal audits of their information security
compliance. Results of those audits are presented to the relevant stakeholders and are considered
while identifying and assessing risks for information security in LINK Mobility.
LINK’s processes are based on a top-down approach, where LINK defines policies and procedures for
subsidiaries to implement locally. The centralized Information Security function provides support and
counselling to local entities depending on requirements in the covered areas. To ensure compliance
with the LINK Mobility Information Security Policy subsidiaries are subject to annual internal audits
where non-compliance and potential for improvement is identified. Results of audits are communicated
to the relevant stakeholders in each entity and implemented locally as part of the Information
Security process.
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 in several areas in recent years add to such risk. Furthermore,
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the risk area may include outward-facing risks related to negative effects on individuals and society
following 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 ability to operate effectively, sustain profitability, and drive growth depends on having the
right people with the right skills in the right roles. Risks such as workforce shortages, gaps in
critical competencies, and loss of industry expertise can lead to financial setbacks and operational
inefficiencies. To mitigate these risks, LINK prioritizes building a skilled, resilient organization with
strong leadership and expertise in key areas.
Recruitment, retention, and fostering a safe, inclusive, and engaging workplace is fundamental to
our strategy—ensuring alignment from headquarters to every local subsidiary. We actively address
risks related to corporate culture, employee engagement, and talent management by continuously
strengthening our hiring, training, succession planning, and people development capabilities. A firm
commitment to diversity, equity, and inclusion further enhances our ability to attract and retain top
talent, reinforcing LINK’s long-term growth and success.
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.
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).
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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, leadership, organization,
security and the geopolitical situation. The area thus covers organization, buildings, assets, internal
structures, and external events.
LINK is taking steps to enhance and increase its 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 implemented as necessary. Adequate insurance on
group level to mitigate risks is an important measure.
Increased global tensions and financial uncertainty could pose a risk to global economic growth
and indirectly impact LINK’s global operations. However, LINK benefits from a strong diversification
effect, with a broad customer base of over fifty thousand companies across numerous industries and
geographies. Given that different industries and markets are likely to be affected in different ways by
global shifts, this diversification helps mitigate overall risk exposure. While LINK may still experience
some effects, its diversified revenue streams and market presence should provide resilience against
broader economic volatility.
Shareholders and shares
Throughout the year, the number of shares in the company increased from 297,059,271 shares to
298,706,434 shares. And the increase was related to an issuance of ordinary shares in April 2024. On
March 11, 2024, the company announced a share repurchase program, authorizing the buyback of up
to 17 million outstanding shares, representing 5.72% of total shares at the beginning of the year. The
repurchase was conducted in two tranches: the first, totaling 8.31 million shares, occurred between
March 11 and May 30, 2024, while the second, comprising 8.69 million shares, was executed from June
12 to October 16, 2024. Together, these tranches amounted to a total repurchase of 17 million shares.
By the end of the program and the end of the year, the company held 16,202,629 or 5.42% of its own
shares following release of bonus shares as part of ESPP programs and limited exercise of options.
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.
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LINK at year-end 2024 had close to 4400 shareholders, of which the largest 10 shareholders combined
controlled over 60% of the company. Abry Partners, represented by Citibank as nominee, was the largest
single controlling shareholder with a 28.64% stake through subsidiary holdings.
The LINK Mobility Group Holding ASA share closed at NOK 23.00 on the Oslo Stock Exchange at
year end 2024, appreciating 26.7% with strong operational performance and a strong market for
technology stocks.
Organization, workforce, and management
LINK’s workforce (key intangible resources), 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 by reorganizing
internal competencies and with emphasis on the sales departments through streamlined sales skills
development and measurements.
Regional segments have also been restructured to maximize synergies. By the end of 2024, LINK
had more than 600 permanent employees. 34,4% of the total LINK workforce was women,
compared to 34,1% in 2023. 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.
Applicable legislation and principles
LINK is subject to Corporate Governance reporting requirements under the Norwegian
Accounting Act §2-9, Issuer Rules by the Oslo Stock Exchange in Oslo Rulebook II – Issuer Rules
2. May 2024 (“RulebookII”) Chapter 4.4, and the Norwegian Code of Practice for Corporate
Governance from October 14th 2021 (“Code”). The regulations are openly available on
www.lovdata.no, www.oslobors.no, and www.nues.no, respectively.
The structure of this statement shall, as instructed in RulebookII, 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.
The Board has accounted for how LINK adheres to the Code in this Annual report. An index of the Code
requirements and references to where in this report the information can be found is shown below.
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Code reference Reference to chapters in this Annual report
1. Implementation and reporting
on corporate governance
Section 1 in this Board Statement on Corpo-rate Governance
Disclosures [GOV-1], [GOV-2], [GOV-3], [GOV-4 and [GOV-5] in
the sustainability statement
2. Business
Section 2 in this Board Statement on Corporate Governance
Information on LINK’s strategy, business model and
value chain is included under disclosure [SBM-1] of the
sustainability statement.
3. Equity and dividends Section 3 in this Board Statement on Corporate Governance
4. Equal treatment of
shareholders
Section 4 in this Board Statement on Corporate Governance
5. Shares and negotiability Section 5 in this Board Statement on Corpo-rate Governance
6. General meetings Section 6 in this Board Statement on Corpo-rate Governance
7. Nomination Committee
Section 7 in this Board Statement on Corporate Governance
Disclosure [GOV-1] in the sustainability statement
8. Board of Directors
composition and independ-
ence
Section 8 in this Board Statement on Corporate Governance
Disclosure [GOV-1] in the sustainability statement
9. The work of the board of
directors
Section 9 in this Board Statement on Corporate Governance
Disclosure [GOV-1] in the sustainability statement
10. Risk management and
internal control
Section 10 in this Board Statement on Corporate Governance
“Management of Risks” section in this report
Information on the risk management and internal controls
over sustainability reporting is included under disclosure
[GOV-5] of the sustainability statement.
Information on the material impacts, risks and opportunities
and their interaction with strategy and business model,
as well as process to identify and assess material IROs, is
included under disclosures [SBM-3] and [IRO-1].
11. Compensation to the
Corporate Assembly and the
Board of Directors
Section 11 in this Board Statement on Corpo-rate Governance
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Code reference Reference to chapters in this Annual report
12. Compensation to the Group
Leadership Team
Section 12 in this Board Statement on Corpo-rate Governance
13. Information and
communications
Section 13 in this Board Statement on Corpo-rate Governance
14. Take - overs Section 14 in this Board Statement on Corpo-rate Governance
15. Auditor Section 15 in this Board Statement on Corpo-rate Governance
1. Implementation and reporting on corporate governance
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.
Key governing documents
LINK Mobility’s articles of association were last updated by the General Meeting on 29. May 2024. The
articles are available on linkmobility.com
LINK has adopted and implemented a corporate governance policy to safeguard the interests of the
company’s shareholders, employees, customers, and other stakeholders. The policy and associated
rules and practices are intended to create increased predictability and transparency and thus reduce
uncertainty related to the business. The latest version of LINK’s Corporate Governance Policy is dated
December 7th 2022.
LINK has developed group policies that set out mandatory requirements all LINK entities must adhere
to, for a number of areas. Hereunder sustainability, information security, diversity, fundamental human
rights and decent working conditions, anti-slavery and human trafficking, anti-corruption and anti-
bribery, antitrust, sanctions, accounting, taxation, financial reporting and processing of personal data.
LINK has implemented a group-wide framework for managing risk, and a group-wide compliance
management framework
Code of Conduct and Whistleblowing channel
LINK Mobility’s Employee Code of Conduct helps ensure that all employees carry out their activities in
an ethical manner and in accordance with current legislation and LINK standards. All employees are
required to complete a training program covering the Code of Conduct at least once per year.
All employees are encouraged to report any discovered breach with the Code of Conduct through the
Whistleblowing channel, allowing anonymous reporting of concerns.
Further information about LINK Mobility’s governance structure can be found at LINK mobility’s website
(https://www.linkmobility.com/legal/sustainability/esg-report) and in the Sustainability statement
in this report.
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2. Business
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’s Articles of Association provides a description of the business activities LINK Mobility is engaged
in and are published in full on the company’s website (linkmobility.com).
“The Company’s business is to own shares in other companies, and either itself or through
other companies, develop and operate software for mobile telephone services to private and
public businesses.”
LINK fully complies with the Code.
3. Equity and dividends
LINK has a capital structure appropriate to the company’s objective, strategy, and risk profile.
LINK Mobility’s 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.
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6. General meetings
In accordance with the Public Limited Liability Companies Act (Allmennaksjeloven), all shareholders
with shares acquired before the fifth business day ahead of the general meeting have a right to attend
the general meeting. 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 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 CEO and the Chairman of the board of directors
shall attend the general meeting, unless represented in alignment with the Public Limited Liability
Companies Act §5-5. 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.
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.
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, with latest revision made by the Annual General Meeting on May 29th 2024.
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.
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Information on the role of the administrative, management and supervisory bodies is also included
under disclosure [GOV-1] of the sustainability statement.
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 do not include deviations from
the requirement in the Public Limited Liability Companies act with regard to duration, so the chairman
and the board members are elected for a term of 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 2024, 3 women and 3 men.
The chairman was elected for two years in 2024, and each board member was elected for one year in
general meeting 2024.
Overview of the Board of Directors
The names and positions of the Board members are set out in the table below.
Name Position Ser ved since Term expi res Independence
André Christensen Chairman 2022 2026 Yes
Jens Rugseth Board m embe r 2005 2026 -
Robert Joseph Nicewicz Jr Board me mber 2018 2026 -
Sabrina Gosman Board me mber 2022 2026 -
Grethe Viksaas Board me mber 2020 2026 Yes
Sara Murby Forste B oard me mber 2020 2026 Yes
LINK fully complies with the Code.
Information on the role of the administrative, management and supervisory bodies is also included
under disclosure [GOV-1] of the sustainability statement.
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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 2024.
The board of directors evaluates its performance and expertise annually.
The board held twenty-three (23) meetings in 2024, of which 18 had 100% attendance by board
members. The average board meeting attendance by members was 96%.
The board called one general meeting in 2024, the annual general meeting held on May 29th.
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, 2024.
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
Information on the role of the administrative, management and supervisory bodies is also included
under disclosure [GOV-1] of the sustainability statement.
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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 instructions
have been updated in 2025, but the version of the audit committee’s instructions relevant for 2024
is from December 7th, 2022. The committee is a preparatory and advisory body for the Board and
supports the Board in the exercise of its responsibility for financial reporting, sustainability 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 makes 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.
Information on the role of the administrative, management and supervisory bodies is also included
under disclosure [GOV-1] of the sustainability statement.
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. This includes
an individual fixed salary, variable salary elements based on a group-wide set of KPIs, and incentives
linked to share price performance.
Information on the role of the administrative, management and supervisory bodies is also included
under disclosure [GOV-1] of the sustainability statement.
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 M&A 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.
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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.
For further details regarding LINK Mobility’s Risk Management process, please refer to [refer to the
“Management of Risks” section]
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 9 payroll.
The remuneration of the board members is not linked to the company’s performance, and share options
are not granted.
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/governance
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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 monthly newsletter, and a
dedicated investor relations professional and management meeting 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 takeover 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.
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, comments 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.
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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 all LINK’s subsidiaries, including acquisitions.
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 historically achieved high single-digit organic gross profit growth, a trend
that remains a key objective for the medium term. Given the company’s highly scalable model, organic
adjusted EBITDA growth is expected to outpace organic gross profit growth.
Capital allocation remains focused on accretive M&A as the top priority, with multiple promising
opportunities both within Europe and beyond. The current M&A pipeline presents an additional EBITDA
potential of up to EUR 30-40 million. Over the medium term, the goal is to drive at least 10% inorganic
growth in adjusted EBITDA annually through bolt-on acquisitions, all while maintaining LINK’s leverage
policy within a disciplined range of 2.0-2.5x adjusted EBITDA.
The board of directors appreciates and emphasizes uncertainty in relation to assessments of
expected future development. The Report from the Board of Directors is inclusive of the sustainability
statement.
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
Thomas Berge
Chief Executive Officer
Oslo, April 28, 2025
The Board of Directors at
LINK Mobility Group
Holding ASA
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Responsibility
Statement
Board of Directors rep
ort
We confirm that, to the best of our knowledge, the Board of Directors report has been prepared in
accordance with the Norwegian Accounting Act and that it gives a true and fair view of the development,
performance and financial position of the Company and the Group including a description of the
principle risks and uncertainties that they face.
Sustainability statements
We confirm that, to the best of our knowledge, the sustainability statements are prepared in compliance
with the Norwegian Accounting Act including compliance with European Sustainability Reporting
Standards (ESRS) and Article 8 of EU Regulation 2020/852 (the EU Taxonomy Regulation). In our
opinion, the Sustainability Statements give a true and fair view of the Group’s sustainability performance
in accordance with the stated reporting requirements.
Financial statements
We confirm that, to the best of our knowledge, the consolidated financial statements for the year ended
December 31 2024 have been prepared in accordance with IFRS® Accounting Standards as adopted
by the EU and the additional requirements of the Norwegian Accounting Act, and that the financial
statements for the parent company for the year ended December 31 2024 have been prepared in
accordance with IFRS® Accounting Standards 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.
ESEF regulation
We confirm that, to the best of our knowledge, the annual report of LINK Mobility Group Holding
ASA for the financial year January 01 – December 31 2024 with the file name:
2549006RH08XJGKC2Y14-2024-12-31-0-en.zip has been prepared in compliance with the ESEF
Regulation.
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April 28, 2024
Thomas Berge
Chief Executive Officer
Grethe Helene Viksaas
Board member
Jens Rugseth
Board member
Robert Joseph Nicewicz Jr
Board member
Sabrina Gosman
Board member
Sara Murby Forste
Board member
Andre Alexander Christensen
Chairman of the board
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Consolidated income statement
For the period ended December 31
(Amounts in NOK 1000)
Note 2024 2023
Revenue
7 6,993,807 6,282,126
Total operating revenue
Direct cost of services rendered
-5,466,166 -4,934,441
Payroll and related expenses
9 -555,051 -585,383
Other operating expenses
10 -373,932 -284,450
Depreciation and amortization
8, 14, 15 -334,103 -337,535
Total operating expenses
-6,729,253 -6,141,809
Operating profit (loss)
Finance income and finance expenses
Net currency exchange gains (losses)
11 36,678 44,319
Net interest expense
11 -64,097 -139,667
Net other financial income (expenses)
11 -15,951 6,002
Total finance income (expense)
-43,370 -89,345
Profit (loss) before income tax
Income tax
23 -49,641 -12,616
Profit (loss) from continuing operations
Profit from discontinued operations
5 84,025 28,926
Profit (loss) for the period
Profit attributable to:
Owners of the company
Earnings per share (NOK/share):
Basic earnings (loss) per share from total operations
12 0.86 0.23
Diluted earnings (loss) per share from total operations
12 0.83 0.22
Basic earnings (loss) per share from continuing operations
12 0.58 0.13
Diluted earnings (loss) per share from continuing operations
12 0.56 0.13
The accompanying notes are an integral part of these financial statements.
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Consolidated statement of Comprehensive Income
For the period ended December 31
(Amounts in NOK 1000)
Note 2024 2023
Profit (loss) for the period 255,569 67,282
Other comprehensive income
Items that may be reclassified to profit or loss
Translation differences of foreign operations 154,040 195,641
Reclassification of foreign currency translation reserve (US
subsidiary)
5 -197,071 -
Gains and losses net investment hedge -52,678 -69,037
Tax on OCI that may be reclassified to P&L 11,589 15,188
OCI that may be reclassified to P&L -84,120 141,793
Actuarial gains and losses -1,821 -1,757
OCI that will not be reclassified to P&L -1,821 -1,757
Other comprehensive income for the period -85,941 140,036
Total comprehensive income for the period 169,628 207,318
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Consolidated statement of financial position
(Amounts in NOK 1000)
Note 2024 2023
ASSETS
Goodwill 14 4,673,114 4,388,870
Other intangible assets 14 1,762,119 1,773,601
Deferred tax asset 23 139,072 142,934
Equipment and fixtures 15 22,339 20,432
Right-of-use assets 8 29,924 43,988
Other non-current assets 6,870 2,523
Total non-current assets 6,633,438 6,372,348
Trade and other receivables 16, 19 1,610,024 1,380,412
Cash and cash equivalents 17, 19 2,478,701 1,096,596
Current assets held as available for sale 5 - 2,831,510
Total current assets 4,088,725 5,308,518
TOTAL ASSETS 10,722,163 11,680,866
EQUITY AND LIABILITIES
Share capital 1,494 1,485
Share premium and other reserves 5,976,894 5,937,788
Accumulated translation differences 465,458 553,220
Own shares -344,574 -
Retained earnings (accumulated losses) -721,011 -978,401
Total equity 18 5,378,260 5,514,093
Liabilities
Long-term borrowings 19, 20 1,457,520 4,008,320
Lease liabilities 8, 19, 20 19,608 31,421
Deferred tax liabilities 23 256,480 274,431
Other long-term liabilities 10,037 6,834
Total non-current liabilities 1,743,645 4,321,006
Short-term borrowings 19, 20 2,019,655 2,741
Lease liabilities 8, 19, 20 11,948 14,549
Trade and other payables 19, 22 1,475,100 1,493,639
Income tax payable 23 93,554 38,014
Short-term liabilities held as available for sale 5 - 296,825
Total current liabilities 3,600,257 1,845,768
Total liabilities 5,343,903 6,166,773
TOTAL EQUITY AND LIABILITIES 10,722,163 11,680,866
The accompanying notes are an integral part of these financial statements.
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Thomas Berge
Chief Executive Officer
Grethe Helene Viksaas
Board member
Jens Rugseth
Board member
Robert Joseph Nicewicz Jr
Board member
Sabrina Gosman
Board member
Sara Murby Forste
Board member
Andre Alexander Christensen
Chairman of the board
Oslo, April 28, 2024
The Board of Directors of LINK Mobility Group Holding ASA
LINK Mobility Group Holding ASA
Consolidated statement of
financial position
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Consolidated statement of Changes in Equity
For the period ended December 31
(Amounts in NOK 1000)
Note
Share capital
Own shares
Share premium
Currency
translation
reserve
Retained
earnings
(accumulated
losses)
Total equity
equity
Balance at January 01 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
Total comprehensive income
for the period
Issue of ordinary shares 6 - 2,752 - - 2,759
Share based payment 9 - - 78,565 - - 78,565
Other adjustments - - - - -70 -70
Balance at December 31 2023 18 1,485 - 5,937,788 553,220 -978,401 5,514,093
Balance at January 01 2024 1,485 - 5,937,788 553,220 -978,401 5,514,093
Profit (loss) for the period - - - - 255,569 255,569
Other comprehensive income
(loss) for the period, net of
income tax
Total comprehensive income
for the period
Issue of ordinary shares 8 - 14,415 - - 14,423
Acquisition of treasury shares - -344,574 - - - -344,574
Share based payment 9 - - 24,691 - - 24,691
Balance at December 31 2024 18 1,494 -344,574 5,976,894 465,458 -721,011 5,378,260
The accompanying notes are an integral part of these financial statements.
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Consolidated statement of cash flows
For the period ended December 31
(Amounts in NOK 1000)
Note 2024 2023
Cash flows from operating activities
Profit (loss) before income tax from continuing operations 221,185 50,972
Adjustments for:
Taxes paid -95,260 -41,635
Finance expense (income) 11 43,480 89,345
Depreciation and amortization 8, 14, 15 334,983 337,535
Share based payment expense 24,691 78,565
Net gain from disposals -205 -248
Change in trade and other receivables 110,419 -201,025
Change in trade and other payables -127,286 198,402
Change in other provisions 110,156 20,384
Net cash flows from operating activities from continuing operations 622,163 532,296
Net cash flows from operating activities from discontinued operations - 190,902
Cash flows from investing activities
Payment for equipment and fixtures 15 -9,083 -5,857
Payment for intangible assets 14 -141,349 -110,270
Payment for acquisition of subsidiary, net of cash acquired 6 -182,894 -
Proceeds from sale of equipment and fixtures 170 -
Purchase price adjustment acquisition of subsidiary 6 - -
Net cash flows from investing activities from continuing operations -333,156 -116,127
Net cash flows from investing activities from discontinued operations 2,211,993 -63,986
Cash flows from financing activities
Proceeds on issue of shares 14,423 2,759
Repayment of equity -344,574 -
Other financial items 20 -15,008 -
Proceeds from borrowings 20 1,463,856 -
Repayment of borrowings 20 -2,212,376 -117,038
Interest paid 20 -125,582 -150,264
Principal elements of lease payments 8 -14,734 -16,583
Dividends received - -
Net cash flows from financing activities from continuing operations -1,233,995 -281,127
Net cash flows from financing activities from discontinued operations - -2,506
Effect of foreign exchange rate changes 103,464 21,928
Net change in bank deposits, cash and equivalents 1,370,470 281,381
Cash and equivalents at beginning of period 1,096,596 826,851
Cash and equivalents at beginning of the period (held for sale) 11,636 -
Cash and equivalents at end of the period (held for sale) - -11,636
Cash and equivalents at end of the period from continuing operations 2,478,701 1,096,596
The accompanying notes are an integral part of these financial statements.
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Notes to the financial statements for the period ended
December 31, 2024
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 Business combinations
7 Segment reporting
8 Leases
9 Payroll and related expenses
10 Other operating expenses
11 Net finance and income expenses
12 Earnings per share
13 Transactions with related parties
14 Intangible assets
15 Equipment and fixtures
16 Trade and other receivables
17 Cash and cash equivalents
18 Share capital and shareholder information
19 Classes and categories of financial instruments
20 Interest-bearing liabilities
21 Financial instruments, risk management objectives, and policies
22 Trade and other payables
23 Income tax
24 Contingencies and legal claims
25 Events after the reporting date
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Income Statement
For the period ended December 31
(Amounts in NOK 1000)
Note 2024 2023
Other operating expenses 6 -10,564 -7,220
Total operating expenses -10,564 -7,220
Operating loss -10,564 -7,220
Finance income and finance expenses
Net currency exchange gains (losses) -16,550 1,773
Net interest expense -40,540 -27,565
Net other financial income (expenses) -38,391 -29,723
Total finance income 7 -95,481 -55,515
Profit before income tax -106,046 -62,735
Income tax 14 23,293 13,698
Profit for the period -82,753 -49,037
The accompanying notes are an integral part of these financial statements.
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Statement of financial position
(Amounts in NOK 1000)
December 31 December 31
ASSETS Note 2024 2023
Investment in LINK Mobility Group AS 5 8,141,494 8,116,803
Long-term receivables - intercompany 5 1,919,812 3,236,134
Total non-current assets 10,061,306 11,352,937
Prepaid expenses 1,553 680
Other short-term receivables 619 -
Deferred tax 14 23,445 152
Cash and cash equivalents 8, 10 1,203,718 68,417
Total current assets 1,229,336 69,250
TOTAL ASSETS 11,290,642 11,422,187
EQUITY AND LIABILITIES
Share capital 1,494 1,485
Share premium and other reserves 6,001,053 5,961,948
Own shares -344,574 -
Retained earnings (accumulated losses) 1,347,832 1,430,585
Total equity 9 7,005,805 7,394,018
Liabilities
Long-term borrowings 11 1,457,521 4,008,320
Loans and borrowings - intercompany 805,193 15,892
Total non-current liabilities 2,262,714 4,024,212
Short-term borrowings 10, 11 2,019,655 2,741
Trade payables and other payables 10, 13 2,468 1,216
Current tax liabilities 14 - -
Total current liabilities 2,022,123 3,957
Total liabilities 4,284,837 4,028,169
TOTAL EQUITY AND LIABILITIES 11,290,642 11,422,187
The accompanying notes are an integral part of these financial statements.
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Statement of Comprehensive Income
for the period ended December 31
(Amounts in NOK 1000) 2024 2023
Profit (loss) for the period -82,753 -49,037
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 -82,753 -49,037
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
Statement of financial position
Oslo, April 28, 2025
The Board of Directors of LINK Mobility Group Holding ASA
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Statement of Changes in Equity
for the period ended December 31, 2024
(Amounts in NOK 1000) Note Share capital
Own
shares
Share
premium
Retained
earnings
(accumulated
losses) Total equity
Balance at January 01, 2023 1,479 - 5,880,630 1,479,622 7,361,731
Profit for the period - - - -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 December 31, 2023 9 1,485 - 5,961,948 1,430,585 7,394,018
Balance at January 01, 2024 1,485 - 5,961,948 1,430,585 7,394,018
Profit for the year - - - -82,753 -82,753
Other comprehensive income (loss)
for the year, net of income tax
- - - - -
Total comprehensive income
for the year
- - -82,753 -82,753
Issue of ordinary shares 8 - 14,415 - 14,423
Treasury shares - -344,574 - - -344,574
Share based payment - - 24,691 - 24,691
Balance at December 31, 2024 9 1,494 -344,574 6,001,053 1,347,832 7,005,805
The accompanying notes are an integral part of these financial statements.
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Statement of cash flows
for the period ended December 31
(Amounts in NOK 1000)
Note 2024 2023
Cash flows from operating activities
Profit before income tax -106,046 -62,735
Adjustments for:
Finance income (expense) 95,481 160,662
Changes in trade and other receivables -619 -
Change in trade and other payables 10, 13 1,252 799
Change in other provisions 181,547 -5,268
Net cash flows from operating activities 171,615 93,458
Cash flows from investing activities
Net cash inflow, loan repayments from subsidiaries 4,295,965 5,638,666
Net cash (outflow), loan to subsidiaries -2,847,405 -5,426,243
Net cash (outflow) inflow, intercompany loan interest 24,071 5,213
Net cash flows from investing activities 5 1,472,632 217,637
Cash flows from financing activities
Proceeds on issue of shares 9 14,423 2,759
Repayment of equity -344,574 -
Other financial items -15,008 -
Proceeds from borrowings 1,463,856 -
Intercompany debt, inflow 775,615 15,467
Repayment of borrowings -2,212,376 -117,960
Intercompany debt, outflow -11,589 -12,064
Interest paid -120,692 -145,731
Intercompany interest paid -58,600 -
Net cash flows from financing activities -508,945 -257,530
Net change in bank deposits, cash and equivalents 1,135,301 53,565
Effect of foreign exchange rate changes -40 59
Cash and equivalents at beginning of period 68,456 14,833
Cash and equivalents at end of the period 1,203,718 68,456
The accompanying notes are an integral part of these financial statements.
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Notes to the financial statements for the period
ended December 31, 2024
Contents notes
1 General information
2 Adoption of new and revised International Financial Reporting Standards (IFRSs)
3 Summary of significant accounting policies
4 Critical accounting judgments and key sources of estimation variances
5 Investment in subsidiaries
6 Other operating expenses
7 Net finance income and expenses
8 Cash and cash equivalents
9 Share capital and shareholder information
10 Classes and categories of financial 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 December 31, 2024 are listed below.
Name of entity Date of acquisition Place of business / country of
registration
Ownership
interest
LINK Mobility Group AS 6.12.2021 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 January 01, 2024. 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
and interpretations has not had any material impact on the disclosures or on the amounts reported in
- Amendment to IFRS 7 regarding classification and measurement of financial instruments
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 December 31, 2024. 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 January 01, 2026 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 2025.
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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 Gullhaug Torg 5, 0484 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 28 April 2025.
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 and the Group 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 judgements 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 classication
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 theCompany’s functional
currency. In preparing the financial statements of the individual companies, transactions in currencies
other than the entity’s functional currency are recognised 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 recognised 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 recognised in other comprehensive
income and accumulated in a separate component of equity.
3.5 Impairment of non-nancial 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 recognised 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
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been recognised for the asset (or cash-generating unit) in prior years. A reversal of an impairment loss
is recognised 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.
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 amortised 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 amortised 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 recognised in the statement of financial position at fair value (net of any transaction
costs), and subsequently measured at amortised cost using the effective interest rate method.
The effective interest method calculates the amortised cost of a financial liability and the allocation of
interest expense over the relevant period. The effective interest rate is the rate that discounts estimated
future cash payments, including all fees and points paid or received that form an integral part of the
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effective interest rate, transaction costs and other premiums or discounts, through the expected life of
the financial liability, or (where appropriate) a shorter period, to the amortised cost of a financial liability.
The Company derecognises financial liabilities when, and only when, the Company’s obligations are
discharged, cancelled, or have expired. The difference between the carrying amount of the financial
liability derecognised, and the consideration paid and payable is recognised in profit or loss.
3.7 Cash ow
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.
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 utilised. 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 December 31.
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.
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Note 4 Critical accounting judgements 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 recognised 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. 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
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
December 06, 2021 100%
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 December 06, 2021 when LINK Mobility Pecunia AS was merged with LINK Mobility Group AS.
The total amortized cost as of December 31, 2024:
(Amounts in NOK 1 000)
LINK Mobility
Group AS
Total amoritzed cost (01.01) 8,141,494
Total amoritzed cost (31.12) 8,141,494
As at year-end, the Company has outstanding long-term intercompany loans with its subsidiaries
totaling NOK 1 919 812 thousand. These loans are unsecured and interest bearing.
Management has assessed the recoverability of these amounts and has determined that there is no
credit risk or impairment associated with these intercompany loans.
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Note 6 Other operating expenses
(Amounts in NOK 1000)
2024 2023
Advisors and consultants 2,368 1,762
Stock exchange listing expenses¹ 4,432 1,993
Insurance premiums² 3,351 2,990
Travel expenses - 230
Other expenses³ 413 246
Total other operating expenses 10,564 7,220
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.
Auditor’s fees
The table below summarises audit fees for 2024 (2023) 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.
2024 2023
Audit fee 1,126 503
Other attestation services 300 397
Tax consulting services - -
Other services 43 -
Total fee to auditor 1,468 900
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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 amortised cost recognised in the profit
and loss.
All categories of financial income and expense are presented on a net basis.
Net financial income and expenses 2024 2023
Net currency exchange gains (losses)¹ -16,550 1,773
Net interest expense -40,540 -27,565
Net other financial expense -38,391 -29,723
Total finance income -95,481 -55,515
Net interest expense 2024 2023
Interest expense financial institutions -138,194 -144,184
Interest expense - seller’s credit - -
Other interest income (expense) 62,992 5,004
Interest income from related parties 58,718 111,615
Total net interest expense -16,483 -27,565
Net other financial expenses 2024 2023
Amortized loan set-up costs -22,663 -16,840
Currency option premium -15,008 -12,573
Other financial (expenses) income -721 -310
Total net other financial expenses -38,391 -29,723
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)
2024 2023
Cash and cash equivalents 1,203,718 68,417
Total cash and cash equivalents 1,203,718 68,417
Restricted cash 2024 2023
Restricted cash - -
Bank balance in escrow account - -
Total cash and cash equivalents 1,203,718 68,417
If applicable, cash and cash equivalents include amounts classified as restricted cash. There are no
restricted amounts as at December 31, 2024.
Note 9 Share capital and shareholder information
Share capital as at December 31, 2024 is KNOK 1 494 (2023: KNOK 1 485), being 298 706 434
ordinary shares (2023: 297 059 271 ordinary shares) at a nominal value of NOK 0.005/share (2023:
NOK 0.005/share). There are no preference shares in FY2024 (FY2023: 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:
2024 2023
Ordinary shares opening balance 2023/2022 297,059,271 295,890,306
Issue of ordinary shares (June 05, 2023) 174,692
Issue of ordinary shares (November 08, 2023) 909,110
Issue of ordinary shares (December 22, 2023) 85,163
Effect of shares issued (April 04, 2024) 1,647,163
Ordinary shares at the end of the period 298,706,434 297,059,271
Total number of shares at the end of the period 298,706,434 297,059, 271
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LINK Mobility Group Holding ASA has the following major shareholders as at December 31, 2024:
Name of shareholder Type of account Ownership interest
Citibank, N.A. Nominee 28.64%
LINK MOBILITY GROUP HOLDING ASA Ordinary 5.42%
KARBON INVEST AS Ordinary 5.34%
The Bank of New York Mellon SA/NV Nominee 4.56%
SUNDT AS Ordinary 4.02%
FOLKETRYGDFONDET Ordinary 3.39%
J.P. Morgan SE Nominee 2.69%
VERDIPAPIRFONDET DNB NORGE Ordinary 2.61%
SKANDINAVISKA ENSKILDA BANKEN AB Ordinary 2.27%
VERDIPAPIRFONDET DNB SMB Ordinary 1.65%
VPF DNB NORGE SELEKTIV Ordinary 1.51%
VERDIPAPIRFONDET ALFRED BERG GAMBA Ordinary 1.27%
J.P. Morgan SE Nominee 1.18%
Merrill Lynch, Pierce, Fenner & Sm Nominee 1.12%
BARCLAYS CAPITAL SEC. LTD FIRM Ordinary 1.11%
The Bank of New York Mellon SA/NV Nominee 0.98%
Em Kapital As Ordinary 0.86%
The Bank of New York Mellon SA/NV Nominee 0.75%
The Bank of New York Mellon SA/NV Nominee 0.71%
J.P. Morgan SE Nominee 0.69%
70.75%
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
LINK Mobility Group Holding ASA 16,202,629
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 457,900
Ina Rasmussen 74,817
Morten Løken Edvardsen 37,913
Pål Marius Brun 11,155
Sara Murby Forste 15,957
Riccardo Dragoni 8,612
Grethe Helene Viksaas (Board member) 6,382
Benoit Bole 1,217
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Note 10 Classes and categories of financial instruments
(Amounts in NOK 1000)
Carrying value
2024 2023
Current financial assets
Cash and cash equivalents 1,203,718 68,417
Non-current financial liabilities
Borrowings 1,458 4,008
Current liabilities
Borrowings and interest 2,019,655 2,741
Trade payables 2,050 741
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
amortised 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 December
31, 2024. 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 recognised amounts consitute a reasonable approximation of fair value.
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Note 11 Interest-bearing liabilities
(Amounts in NOK 1000)
Interest bearing liabilities are measured at amortised cost.
Non-current financial liabilities 2024 2023
Bond loan 1,457,521 4,008,320
Holdback - -
Total 1,457,521 4,008,320
Current liabilities 2024 2023
Bond loan/debt to financial institutions* 2,019,655 2,741
Total 2,019,655 2,741
*Bond principal and instalments falling due within a 12 month period, including non-capitalised interest,
are classified as current.
Contractual maturities of financial liabilities at
December 31, 2024 < 3 months
3 months
-1 year 1 - 2 years 2 - 5 years Total
Bond loan (tap issue 12.15.2020) - 12,193 - - 12,193
Bond loan (tap issue 06.23.2021) - 2,072,824 - - 2,072,824
Bond loan (tap issue 10.23.2024) - 80,914 161,827 1,636,202 1,878,944
Total - 2,165,931 161,827 1,636,202 3,963,960
Contractual maturities of financial liabilities at
December 31, 2023 < 3 months
3 months
- 1 year 1 - 2 years 2 - 5 years Total
Bond loan (tap issue 12.15.2020) - 75,873 2,323,973 - 2,399,847
Bond loan (tap issue 06.23.2021) - 64,492 1,975,377 - 2,039,870
Total - 140,366 4,299,351 - 4,439,716
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The book value of borrowings is estimated to approximate their fair value.
2024 2023
Principal amount (tap issue 12.15.2020) 11,795 2,247,583
Principal amount (tap issue 06.23.2021) 2,003,060 1,908,130
Principal amount (tap issue 10.23.2024) 1,474,457 -
Transaction costs (tap issue 12.15.2020)¹ -21,228 -21,228
Transaction costs (tap issue 06.23.2021)¹ -56,127 -56,127
Transaction costs (tap issue 10.23.2024)¹ -17,707 -
Amortization (tap issue 12.15.2020) 21,228 12,462
Amortization (tap issue 06.23.2021) 43,032 29,906
Amortisation (tap issue 10.23.2024) 770 -
Long-term borrowings 3,459,281 4,120,725
Accrued interest and fees 17,895 2,741
Carrying amount 3,477,176 4,123,466
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
171 million at maturity in FY2025 and EUR 125 million in FY2029.
Collateral and guarantees
On December 15, 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 June 23, 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.
On October 29, 2024, LINK successfully placed a EUR 125 million senior unsecured bond due October
29, 2029 (“LINK02”). The bond will have a coupon of 3-month EURIBOR + 2.35% per annum. Listing will
be on the Oslo Stock Exchange and the Frankfurt Open Market.
With the new bond issue, the company has bought back EUR 125 million of LINK01 (ISIN:
NO0010911506) (“LINK01”) due December 2025 which was cancelled. The EUR 74 million of LINK01
bonds held by LINK were also cancelled. Cancellations were executed on October 23, 2024.
The nominal outstanding amount in LINK01 is EUR 171 million; this is classified as a current liability.
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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 June 23, 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.
On October 29, 2024, LINK successfully placed a EUR 125 million senior unsecured bond due October
29, 2029 (“LINK02”). The bond will have a coupon of 3-month EURIBOR + 2.35% per annum.
With the new bond issue, the company has bought back EUR 125 million of LINK01 (ISIN:
NO0010911506) (“LINK01”) due December 2025 which was cancelled. The EUR 74 million of LINK01
bonds held by LINK were also cancelled. Cancellations were executed on October 23, 2024.
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 December 31, 2024 would decrease/
increase by KNOK 34 900 (FY2023 KNOK 41 590). 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.
December 31, 2024
(amounts in NOK 1000) NOK/EUR
impact
NOK/SEK
impact
NOK/CHF
impact
Borrowings 34,900 - -
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Note 13 Trade and other payables
(Amounts in NOK 1000)
Trade and other payables 2024 2023
Trade payables 2,050 741
VAT payable 188 41
Other accruals - legal fees 230 434
Total trade and other payables 2,468 1,216
Trade payables and accruals principally comprise amounts outstanding for trade purchases and
ongoing costs.
Trade and other payables are due within three months.
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.
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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.
2024 2023
Deferred tax expense (income) -23,293 -17,101
Current tax expense - 3,403
Income tax (income) -23,293 -13,698
Income tax payable (balance sheet) 2024 2023
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:
2024 2023
Profit/(loss) before income tax -106,046 -62,735
Statutory income tax rate* 22% 22%
Expected income tax benefit -23,330 -13,802
Tax effect on non-taxable income/expenses 37 95
Effect of changes in tax rules and rates* - -
Prior year adjustment - -
Non deductible interest, interest cap rules - 8
Current tax expense, interest cap rules - -
Change in deferred tax asset not recognized - -
Income tax expense/income (-) for the year -23,293 -13,698
Effective tax rate 22% 22%
*
The statutory income tax rate based on the currently enacted tax rate in Norway.
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Specication of the tax effect of temporary differences and losses carried forward
Tax losses carried forward
2024 2023
Unused tax loss carry forward 100,921 -
Interest cap 69,441 69,441
Potential tax benefit unused tax losses @ 22 % 22,203 -
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 recognised. The amount
can be carried forward for 10 years.
Tax effect of temporary differences and tax losses carried forward as of December 31
Deferred tax liabilities: 2024 2023
Long term receivables and debt in foreign currency - -
Other provisions -1,242 -152
Tax loss to carry forward (-) -22,203 -
Deferred tax liabilities -23,445 -152
Unrecognised temporary differences
2024 2023
Temporary differences for which deferred tax liabilities have not been recognised - -
Unrecognised 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 recognised 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.
