OPENINACROBATREADER
FORBETTERNAVIGATION
ANNUAL REPORT 2024
THIS IS KOMPLETT GROUP
Komplett Group at a glance.............................................................4
Key figures ......................................................................................5
Letter from the CEO ........................................................................7
Our business segments ...................................................................9
Consumer trends .......................................................................... 13
Strategic and financial roadmap .................................................. 14
Value chain .................................................................................... 15
Community engagements ............................................................. 16
Share information ..........................................................................17
DIRECTORS’ REPORT
Board and management presentation ......................................... 20
Board of directors’ statement ......................................................24
Risk and risk management ............................................................33
Sustainability statement ..............................................................38
General information ..............................................................................39
Environmental information ...................................................................70
Social information .............................................................................. 100
Governance information ...................................................................... 116
Corporate governance report ...................................................... 118
Other reporting ........................................................................... 125
FINANCIAL STATEMENTS
Overview of the financial statements ......................................... 128
Consolidated financial statements ............................................. 129
Consolidated notes ..................................................................... 133
Komplett ASA financial statements ........................................... 162
Komplett ASA notes .................................................................... 166
Independent auditor’s report ...................................................... 173
CONTENTS
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CONTENTS
ABOUT KOMPLETT GROUP
THIS IS KOMPLETT GROUP
Komplett Group at a glance.............................................................4
Key figures ......................................................................................5
Letter from the CEO ........................................................................7
Our business segments ...................................................................9
Consumer trends .......................................................................... 13
Strategic and financial roadmap .................................................. 14
Value chain .................................................................................... 15
Community engagements ............................................................. 16
Share information ..........................................................................17
DIRECTORS’ REPORT
Board and management presentation ......................................... 20
Board of directors’ statement ......................................................24
Risk and risk management ............................................................33
Sustainability statement ..............................................................38
General information ..............................................................................39
Environmental information ...................................................................70
Social information .............................................................................. 100
Governance information ...................................................................... 116
Corporate governance report ...................................................... 118
Other reporting ........................................................................... 125
FINANCIAL STATEMENTS
Overview of the financial statements ......................................... 128
Consolidated financial statements ............................................. 129
Consolidated notes ..................................................................... 133
Komplett ASA financial statements ........................................... 162
Komplett ASA notes .................................................................... 166
Independent auditor’s report ...................................................... 173
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ABOUTKOMPLETTGROUP
Logistics centres
and shops:
● Webhallen
● NetOnNet
● Logistics centres
5
12
Komplett Group was founded in Sandefjord, Norway, in 1991 and introduced e-commerce to
the Norwegian market in 1996.
Today, Komplett Group is the leading online-first player in
the consumer electronics market in the Nordics. The group
operates five well-known brands that cater to customers
across the B2C, B2B, and Distribution segments.
These brands deliver seamless shopping experiences
through excellent customer services, efficient deliveries,
and top-tier last-mile solutions. They are all supported by
strategically located warehouses in Sandefjord, Norway,
Stockholm, and Borås, Sweden.
Komplett Group's scalable and efficient business model
enables cost leadership. As laid out by its strategy,
the group is committed to maintaining a portfolio of
strong Nordic retail brands that serve distinct segments
while leveraging commercial cost efficiencies through
centralised operations. Komplett ASA is listed on the Oslo
Stock Exchange (KOMPL).
REVENUESBYCOUNTRY
DENMARK
2.0%
NORWAY
47.3%
SWEDEN
50.3%
Revenues 2024
NOK 15.3
billion
REVENUESBYSEGMENT
DISTRIBUTION
19.0%
B2C
71.0%
B2B
10.0%
Revenues 2024
NOK 15.3
billion
PORTFOLIO OF STRONG B2C AND B2B BRANDS PREFERRED BY CUSTOMERS:
The pure play online
electronics specialist
with expert authority
The low-price challenger
with convenient
omnichannel offering
The gaming destination
with an engaged and loyal
community
The simple and secure
IT service partner
for B2B
The B2B online
electronics
specialist
✔
High customer
satisfaction
✔
Fast and convenient
delivery
✔
Loyal and engaged
customers
✔
Knowledgable
customer service
THE LARGEST NORDIC ONLINE-FIRST
ELECTRONICS RETAILER
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ABOUTKOMPLETTGROUP
KEY FINANCIAL FIGURES 2024
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HIGHLIGHTSANDKEYFIGURES
Operating revenue:
NOK 15.3 billion
2023: NOK 15.9 billion
Revenue growth:
(3.5)%
2023: 8.5%
1)
Operating free cash flow:
NOK 1 078 million
2023: NOK 795 million
Gross profit:
NOK 2.1 billion
2023: NOK 2.1 billion
Gross margin:
13.7%
2023: 13.9%
Capex:
NOK 168 million
2023: NOK 212 million
Operating expenses (adj.):
NOK 2.1 billion
2023: NOK 2.1 billion
Operating cost percentage:
14.0%
2023: 13.1%
Equity ratio:
34.3%
2023: 37.2%
EBIT (adjusted):
NOK (47) million
2023: NOK 139 million
EBIT (adjusted) margin:
(0.30)%
2023: 0.90%
NIBD/EBITDA:
2.5x
2023: 2.4x
1) Year-over-year growth rates from 2023 were impacted by the consolidation of NetOnNet from 1 April 2022.
Note: See APM overview on page 172.
KEY ESG FIGURES 2024
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HIGHLIGHTSANDKEYFIGURES
1) The total CO
2
e emissions are location-based and includes Scope 1, 2 and 3. In 2024, we have improved our Scope 3 reporting by including all
significant categories. This explains the major difference between the reported figures.
Total GHG emissions
1)
413 473 tonnes CO
2
e
2023: 6 443 tonnes CO
2
e
Share of renewable energy use
66% renewable energy
2023: 71% renewable energy
Employees (headcount)
1 482 employees
2023: 1 561 employees
Gender balance
Female: 31.7% Male: 68.2% Other: 0.1%
2023: Female 32.0% Male: 67.9% Other: 0.1%
Factory audits
112 factory audits
2023: 67 factory audits
Audits resulting in contract termination
11 failed our standards
2023: 7 failed our standards
LETTER FROM THE CEO
Over the past few years, the retail industry has faced numerous
challenges and operated in an uncertain market. In 2024, Komplett
Group laid the groundwork to ensure we are equipped to handle them
well.
UPDATED STRATEGIC ROADMAP
Early in 2024, the group presented an updated strategic roadmap laying the
foundation for future growth, and throughout the year, we have remained
committed to our commercial initiatives and cost measures as laid out by our
stated strategic priorities.
Central to our strategic platform are our independent, differentiated brands,
with concepts, product offerings and sales strategies tailored to specific
customer segments and needs. We combine the benefits of brand autonomy
with shared functions and capabilities, including the establishment of a
central commercial team, a shared supply chain network and common tech,
analytics and data-infrastructure.
CONTROLLED EXPANSION
By the end of the year, we had strengthened our brand recognition amongst
customers, increased our presence in adjacent categories, such as the
home category, while expanding our private label portfolio. The popularity
of our private label products, such as the Komplett-PC, has proven that we
are on the right path in providing our customers with unique retail brands.
NetOnNet has also gained momentum during the year, particularly in
Norway. By the end of 2024, we had successfully opened three stores across
Norway and Sweden. The next NetOnNet store will open in Trondheim
in March 2025, and NetOnNet is therefore well covered in Oslo, Bergen,
Stavanger and Trondheim for 2025.
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LETTER FROM THE CEO
Our commercial initiatives have been accompanied by accelerated actions
throughout the group to adapt our cost base to the market environment.
During the year, a process was initiated to consolidate the group’s logistics
set-up in Sweden, and further actions to improve cost efficiency have been
introduced after year-end.
RESPONSIBLE BUSINESS OPERATIONS
One of the strategic priorities that saw growth this year was our commitment
to sustainable development. Technology plays a significant role in people’s
lives, and we want to make sure that shopping at Komplett means shopping
at a responsible business. In 2024, we revised our materiality assessment to
reevaluate which sustainability topics matter the most, both to us and to our
stakeholders. We upheld our three strategic focus areas – circular business
model, climate neutral and attractive and inclusive employer, with measurable
KPIs for each.
CHALLENGING MARKET CONDITIONS
During the year, weak demand has impacted both our main markets and has
been particularly evident in some of our core categories, such as gaming and
IT. The weak demand development has been accompanied by high competition
from both established and disruptive players. In this competitive environment,
we have made price investments and increased campaign activity to defend
our market positions.
As expected during Black Week and peak season in the fourth quarter, we did
see improved sales throughout the period. However, it remains too early to
state that there is a clear shift in consumer demand. Until we can be confident
that the market is improving and that there will be less uncertainty, we will
continue adhering to our cost agenda. That, combined with a healthy inventory
position, will maintain our industry-leading cost position and ensure we stay
top of mind among customers.
STRATEGIC DIRECTION MAINTAINED
As communicated in January, I will be transitioning from my role as President
and CEO of Komplett Group in August 2025, and the board has initiated a
process to find my successor. To ensure continuity and maintain the strategic
direction and targets communicated at last year's capital markets day, the
group’s main shareholders have indicated that they will recommend to the
annual general meeting that I be elected as the chair of the board. This is a role
I would be highly motivated to assume, and my commitment to Komplett Group
remains.
Komplett Group has a strong foundation, and our scalable business model
provides a competitive advantage. Even through challenging times, the
business has been able to adapt, and we are entering 2025 with a solid
strategic platform for further growth. I would like to express my gratitude
to our customers, colleagues, partners and suppliers for their support and
cooperation.
As we look ahead to 2025, we anticipate that an improved consumer
environment and the introduction of new products will gradually lead to
increased demand. The group continues to see positive effects from its
strategic initiatives, while the impact from new cost-saving measures is
expected to gain importance gradually into 2025.
Yours sincerely
Jaan Ivar Semlitsch
President and CEO
| TECHNOLOGY PLAYS A SIGNIFICANT
ROLE IN PEOPLE’S LIVES, AND WE
WANT TO MAKE SURE THAT SHOPPING
AT KOMPLETT MEANS SHOPPING AT A
RESPONSIBLE BUSINESS
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LETTER FROM THE CEO
OUR BUSINESS SEGMENTS
Our brands are organised into three business segments.
BUSINESS TO CONSUMER (B2C)
33 self-service warehouse shops
addressing needs of value-oriented
customers in the mass market
seeking quality at affordable prices.
The obvious choice for tech savvy
and gamers seeking the latest tech.
Approachable expert for customers
less familiar with technology.
12 small-box stores targeting
hardcore gaming enthusiasts and
casual gamers through playfulness
and shared passion for gaming.
BUSINESS TO BUSINESS (B2B)
The simple and secure IT service
partner for B2B.
The B2B online electronics
specialist in Norway.
The B2B online electronics
specialist in Sweden.
DISTRIBUTION
The group’s distribution activities are operated
under the Itegra brand and specialises in large-scale
distribution contracts for resellers and big entities.
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BUSINESSSEGMENTS
BUSINESS SEGMENT:
BUSINESS TO CONSUMER (B2C)
The group's B2C operations focus on serving private consumers across Norway, Sweden, and Denmark through
its NetOnNet, Komplett, and Webhallen brands. The group caters to the electronics, technology, and consumer
goods market via six online stores, offering products from third-party brands alongside its own private label.
NetOnNet is positioned as a low-cost, value-driven challenger, providing price-
conscious mass-market consumers with a wide range of products, including
private label options. Its omnichannel model includes two online stores,
NetOnNet.se and NetOnNet.no, complemented by 33 self-service logistics and
warehouse stores across Norway and Sweden.
Komplett operates a pure online brand, specialising in electronics with a strong
focus on tech, computing, and gaming. B2C customers are served through
Komplett.no, Komplett.se, and Komplett.dk while two pick-up points are
maintained in Oslo and at the Sandefjord warehouse in Norway.
Webhallen is the group's Swedish brand,
targeting gaming enthusiasts. As an
omnichannel provider, it offers consumer
electronics through its online platform, Webhallen.com, and 12 strategically
located retail stores in Stockholm and other major cities in Sweden.
SHAREOFTOTAL GROUPREVENUES
DISTRIBUTION
19%
B2B
10%
71%
NOK 10.9 billion
Note: Reported numbers are impacted by NetOnNet, which was consolidated into Komplett Group's financial statements as of 1 April 2022.
20242023202220212020
EBIT
NOK million
194
230
4
150
12
20242023202220212020
OPERATINGCOST
Per cent of revenue
11.9%
11.8%
13.5%
14.4%
15.4%
20242023202220212020
REVENUES
NOK million
6 142
6 382
9 785
11 195
10 877
20242023202220212020
GROSS MARGIN
Per cent
15.1%
15.4%
15.7%
15.4%
13.6%
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BUSINESSSEGMENTS
BUSINESS SEGMENT:
BUSINESS TO BUSINESS (B2B)
Komplett Group began its B2B operations in Norway in 2002. Today, the B2B segment has become a leading online
market player in the Nordic region, catering to corporate customers, particularly small and medium sized enterprises
(SMEs) and small office/home office segments (SOHO). It provides a fully digital customer experience through its web
shops, Komplettbedrift.no and Komplettforetag.se, which serve the Norwegian and Swedish markets.
With a wide range of attractively priced in-stock products, Komplett B2B
tailors its solutions to meet individual customer needs, ensuring a seamless
online shopping journey. This is further enhanced by highly skilled customer
support and fast, reliable delivery services.
In 2021, the group expanded its B2B operations by acquiring Ironstone,
a provider of simple and securely managed cloud-based IT services and
solutions. With the addition of Ironstone, the group's B2B offering reflects a
broader product selection, digital accessibility, customer SME solutions and
advanced IT services.
SHAREOFTOTAL GROUPREVENUES
DISTRIBUTION
19%
B2C
71%
10%
NOK 1.6 billion
20242023202220212020
EBIT
NOK million
109
146
116
74
100
20242023202220212020
OPERATINGCOST
Per cent of revenue
8.6%
8.4%
9.9%
11.4%
12.2%
20242023202220212020
REVENUES
NOK million
1 286
1 528
1 615
1 583
1 519
20242023202220212020
GROSS MARGIN
Per cent
17.0%
18.0%
17.7%
17.1%
17.1%
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BUSINESSSEGMENTS
BUSINESS SEGMENT:
DISTRIBUTION
The group’s distribution activities are operated under the Itegra brand and has been a central part of
Komplett Group's operations since 1999. Today, Itegra is a central player in Norway and Sweden specialising
in large-scale distribution contracts for resellers and big entities.
The Distribution segment focuses on large-scale contracts for selling
mobile and IT products to retailers, and B2B customers. Specialising in bulk
distribution and serving resellers, Itegra is uniquely positioned to meet the
needs of resellers and large entities, providing a reliable source for high-
volume orders. This specialisation sets it apart from the group's broader retail
and B2B operations.
Itegra's operations are supported by a world-class setup in Sandefjord,
Norway, which ensures cost efficiency and fast delivery at scale. The customer
base includes prominent consumer electronics brands and retail chains. Itegra
serves its customers through its websites, Itegra.no and Itegra.se.
SHAREOFTOTAL GROUPREVENUES
B2B
10%
B2C
71%
19%
NOK 2.4 billion
20242023202220212020
EBIT
NOK million
51
79
63
26
50
20242023202220212020
OPERATINGCOST
Per cent of revenue
4.8%
3.7%
3.4%
3.9%
4.4%
20242023202220212020
REVENUES
NOK million
2 426
3 124
3 207
3 078
2 907
20242023202220212020
GROSS MARGIN
Per cent
6.8%
6.2%
5.5%
5.3%
5.4%
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BUSINESSSEGMENTS
CONSUMER TRENDS
Komplett Group’s markets are shaped by the ongoing digitalisation trend, product development and lifestyle trends.
The key to succeed for Komplett Group is the ability to understand how these trends translate into consumer preferences.
RISE IN ONLINE SHOPPING
Convenience remains a key factor driving the growth of online shopping.
While the rapid expansion seen during the COVID-19 pandemic has slowed,
the shift toward e-commerce is expected to persist as consumers embrace
more convenient shopping habits. Younger generations, who already favour
online shopping over traditional methods, will play a significant role in
sustaining this trend.
DIGITAL ENTERTAINMENT AND GAMING
The rapid growth of streaming services, gaming, and new technologies
like virtual and interactive experiences is a key trend driving demand for
electronics. Devices such as smart TVs, gaming consoles, VR headsets, and
high-performance PCs are becoming more popular as users seek enhanced
entertainment experiences. The rise of e-sports and cloud gaming has
further increased the demand for advanced hardware capable of delivering
seamless and high-quality content.
SMART AND CONNECTED DEVICES
The expansion of the Internet of Things (IoT) is fuelling demand for smart
electronics, including wearables, smart home devices, and connected
appliances. Consumers value convenience, efficiency, and automation,
leading to the popularity of products like smart speakers, fitness trackers,
and home security systems. The integration of AI and voice assistants has
made these devices more intuitive and desirable.
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ABOUTKOMPLETTGROUP
KOMPLETT GROUP’S STRATEGIC PLATFORM
Komplett Group’s strategic platform is rooted in its vision to be the
preferred choice of its customers, suppliers and employees. The group
has a clear organic revenue growth plan targeting NOK 20 billion in
revenue by 2028 while improving profitability.
AMBITIONS AND OBJECTIVES
At its 2024 Capital Markets Day, Komplett Group updated its mid-term financial
targets. For the 2026-2028 period, the group aims to exceed market growth,
achieve industry-leading profitability, and maintain high cash conversion.
STRATEGIC GROWTH AREAS
Komplett Group is exposed to growth opportunities arising from the
digitalisation trend, product development and lifestyle trends. The group
continues to drive growth in core categories, such as computing and gaming,
while also expanding into adjacent categories, such as home appliances
and telecom, as well as expanding the store network in line with NetOnNet’s
omnichannel concept.
PROFITABILITY AND EFFICIENCY
Key priorities to improve profitability include active cost management as well
as utilising the group’s shared functions to achieve improved sourcing terms.
Moreover, growth in private label and services, as well as increased exposure
in higher-margin categories, such as home appliances and telecom, will have a
positive impact on margins.
SUSTAINABILITY AS A CORNERSTONE
Sustainability is integrated into Komplett Group’s strategy. The group has set
ambitious goals, including expanding circular product offerings, reducing
emissions, and fostering an inclusive, attractive workplace.
FINANCIAL
TARGETS
REVENUEGROWTH:
X The group has a clear
organic revenue growth
plan targeting NOK 20
billion in revenue by
2028
MARGINDEVELOPMENT:
X The group aims to be
an industry leader in
profitability and seeks to
improve its EBIT margin
from 2024 levels.
CASH CONVERSION:
X Cash conversion above
70 per cent
FIVE PILLARS LAY THE FOUNDATION FOR OUR
CORPORATE STRATEGY
OUR OPERATING MODEL LOGIC
SUSTAINABILITY
GOALS
CLEAR BUSINESS
MODEL:
X 15 per cent of group
revenues from circular
products and services
by 2028
CLIMATE NEUTRAL:
X Scope 1 & 2 GHG
reduction of 42 per cent
by 2030
X Net zero by 2040
ATTRACTIVE &
INCLUSIVE EMPLOYER:
X Industry leading
employee temperature
X Gender balance in
leadership positions
EFFECTIVE PLATFORM FOR EXPANSION
COMMERCIAL AND COST ADVANTAGES THROUGH SHARED FUNCTIONS AND CAPABILITIES
Komplett Group
The leading online-
first champion
with retail brands
loved by
customers
Driving force
for sustainable
development
Online-first
with speed,
convenience
and leading
tech
Unique retail
brands loved
by customers
Leading
efficiency and
OPEX cost position
Integrated
back-end and
shared capabilities
across commercial,
digital and suppply
chain functions
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ABOUTKOMPLETTGROUP
KOMPLETT GROUP'S VALUE CHAIN
STRONG SUPPLIER RELATIONS
Komplett Group offers a wide product
assortment sourced from a broad network of
high-quality suppliers of leading brands. The
supplier code of conduct outlines the legal
obligations and the integrity standards Komplett
Group expects its suppliers and business
partners to uphold. The group has a central
commercial team which negotiates supplier
agreements across the group.
EFFICIENT LOGISTICS SET-UP
Efficient logistics and inventory management is
key to Komplett Group’s operations. The group’s
brands offer seamless shopping experiences,
convenient delivery and best in class last mile
solutions. This is facilitated by strategically
positioned warehouses in Sandefjord, Norway,
and Stockholm and Borås, Sweden. Komplett in
Sandefjord is known for having one of Europe's
most efficient warehouse systems.
ONLINE-FIRST BUSINESS MODEL
The group’s five distinct brands are widely
recognised by customers within the B2C, B2B
and Distribution segments. The group serves
its customers through a combination of
online stores, self-service warehouse shops
(NetOnNet) and small-box stores (Webhallen).
Across its key markets, 90 per cent of the orders
are delivered on the same or next day.
COMMITTED TO CIRCULARITY
The group collaborates with suppliers and
recycling partners to maximise waste recycling.
Products that cannot be repaired are sent to
recycling partners, while an efficient paper
recycling system is in place at the Sandefjord
warehouse. We also have concepts that offer
customers the opportunity to buy used and
remanufactured products, along with buyback
options.
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ABOUTKOMPLETTGROUP
GAMERS AGAINST CHILDHOOD CANCER
Initiated during Komplett's Black Week in 2020, the
"Gamers against Childhood Cancer" charity event was held
for the fifth time in 2024. The initiative is dedicated to
raising funds for the Childhood Cancer Society in Norway,
an organisation that plays a central role in supporting
affected families and fighting childhood cancer.
Building on the success of previous years, “Gamers
against Childhood Cancer” brought together Norway’s top
streamers and gaming influencers for a livestream session
at Komplett’s studios in Sandefjord during Black Week. It
was with great pride that we could announce that, through
five years of collaboration and effort, we have raised over
NOK 10 million for the Norwegian Childhood Cancer Society.
STREAMHJÄLPEN
Streamhjälpen is a similar initiative in Sweden, where
streamers and gamers collaborate to raise money for
various charitable causes. Through live streaming
marathons, gaming events, and community engagement,
Streamhjälpen has successfully mobilised the gaming
community to support important social issues and
provide aid to those in need.
Streamhjälpen has brought in close to SEK 5.3 million over
the past eight years.
Both initiatives highlight the positive impact of the
gaming community in supporting charitable causes and
making a difference in people’s lives.
MIND
NetOnNet chooses each year, to give a substantial
donation to MIND, a non-profit organisation that works for
promoting mental well-being by offering compassionate
support, spreading knowledge, and advocating for
change. A society where people with mental health
problems and psychiatric conditions are respected,
receive the support they need and where no one should
have to end up in a situation where the only way out
is perceived to be to take their own life. MIND works
intensively with initiatives such as the Suicide Line, the
Elderly Line, the Life Line, and the Parent Line.
PROMOTING EQUALITY WITH CARE
Komplett Group collaborates with CARE Norway to
support initiatives aimed at promoting gender equality
and empowering women and girls. This partnership
involves various activities, including fundraising
campaigns and awareness programs. Through these
efforts, Komplett Group helps CARE Norway provide
resources and support to women and girls, enabling them
to improve their economic conditions, access education,
and protect their rights. The cooperation between
Komplett Group and CARE Norway highlights their shared
commitment to creating a more equitable and inclusive
society.
COMMUNITY ENGAGEMENTS
Komplett Group is dedicated to supporting the communities in which they operate. Through various initiatives, the company collaborates with
charitable organisations, promotes sustainability, and fosters inclusivity. Komplett Group aims to contribute positively to society, and below
are a few examples of how the group partners with organisations to drive meaningful change.
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ABOUTKOMPLETTGROUP
SHARE INFORMATION
Komplett ASA is a public limited liability company organised pursuant to the Norwegian Public Limited Companies Act, which is
part of the laws of Norway. The company was listed on the Oslo Stock Exchange on 21 June 2021 under the ticker code KOMPL.
Komplett has one class of shares, and in accordance with the Norwegian Public
Limited Companies Act, all shares have equal rights and are freely transferable.
The total number of shares issued at 31 December 2024 were 175 341 161. The
nominal value per share is NOK 0.40.
TRADING IN THE KOMPLETT SHARE
The average daily volume of Komplett shares traded on the Oslo Stock Exchange
in 2024 was 0.07 million, equivalent to 0.04 per cent of the total number
of Komplett shares issued at year-end. The share closed at NOK 8.56 on 31
December 2024. The highest closing price was NOK 12.98, and the lowest closing
price was NOK 7.58. Komplett’s market capitalisation was NOK 1.5 billion at 31
December 2024.
OUR DIVIDEND POLICY
The group has a policy of distributing 60-80 per cent of net profit as annual
dividend adjusted for one-offs and special items but expects no dividend to be
paid for the financial year 2024.
AUTHORISATION TO ACQUIRE TREASURY SHARES
At the annual general meeting in 2024, the board of directors was granted an
authorisation, on behalf of the company, to acquire Komplett shares with a total
nominal value equal to 10 per cent of the company’s share capital at the time the
authorisation was granted.
The authorisation is valid until the company’s annual general meeting in 2025,
but no longer than 30 June 2025.
The authorisation was not used in 2024, and the company owns no treasury
shares at year-end 2024.
AUTHORISATION TO INCREASE SHARE CAPITAL
At the annual general meeting in 2024, the board of directors was granted an
authorisation to increase the company's share capital by up to NOK 7000000,
in one or more rounds. The authorisation may be utilised to issue consideration
shares to strengthen the company's capital structure for example in connection
with acquisitions of other companies or businesses.
The authorisation is valid until the company’s annual general meeting in 2025,
but no longer than 30 June 2025.
VOTING RIGHTS
Komplett has one class of share, and each share carries one vote. Shareholders
are entitled to vote for the number of shares they own. It follows from the
Norwegian public limited liability companies act that only those who are
shareholders five working days before the general meeting (registration date)
have the right to participate and vote at the general meeting.
SHAREHOLDERS
At 31 December 2024, Komplett had 3005 shareholders. The top 20
shareholders own 94 per cent of the shares.
FINANCIAL CALENDAR
Date Event
30 April 2025 First quarter 2025 reporting
7 May 2025 Annual general meeting
17 July 2025 Second quarter 2025 reporting
24 October 2025 Third quarter 2025 reporting
SHARE PRICE DEVELOPMENT
Click or scan the QR-code for access to
the share price development.
17 KOMPLETT ASA
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ANNUAL REPORT 2024
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ABOUTKOMPLETTGROUP
ANALYST COVERAGE
Firm Contact Phone Email
ABG Sundal Collier Petter Nystrøm +47 22 01 61 35 petter.nystrom@abgsc.no
DNB Ole Martin Westgaard +47 24 16 92 98 ole.martin.westgaard@dnb.no
Nordea Herman Aleksander Dahl +47 24 01 37 73 herman.aleksander.dahl@nordea.com
Pareto Phillihp Bjerke +47 22 87 88 46 phillihp.bjerke@paretosec.com
SEB Håkon Fuglu +47 21 00 85 49 hakon.fuglu@seb.no
TOP 20 SHAREHOLDERS AT 31 DECEMBER 2024
The 20 largest shareholders at 31 December 2024 Holding Stake Type of account
1 Canica Invest AS 74376317 42.42% Ordinary
2 SIBA Invest AB 55581404 31.70% Ordinary
3 Sole Active AS 6165112 3.52% Ordinary
4 Verdipapirfondet Alfred Berg Gambak 5832206 3.33% Ordinary
5 The Bank of New York Mellon SA/NV 5425413 3.09% Nominee
6 The Northern Trust Comp, London Branch 3899116 2.22% Nominee
7 Verdipapirfondet Holberg Norge 2400000 1.37% Ordinary
8 Verdipapirfondet Holberg Norden 2200000 1.25% Ordinary
8 Verdipapirfondet Storebrand Norge 1607937 0.92% Ordinary
10 Skandinaviska Enskilda Banken AB 1365500 0.78% Nominee
11 Verdipapirfondet Alfred Berg Norge 1142323 0.65% Ordinary
12 Wenaasgruppen AS 823499 0.47% Ordinary
13 Verdipapirfondet Alfred Berg Norge 501511 0.29% Ordinary
14 UBS AG 500423 0.29% Nominee
15 Gulbrand Gråstein AS 469805 0.27% Ordinary
16 Verdipapirfondet Storebrand Norge 404120 0.23% Ordinary
17 Nian AS 393335 0.22% Ordinary
18 Cigalep AS 391777 0.22% Ordinary
19 LT Invest AS 378646 0.22% Ordinary
20 Nordnet Livsforsikring AS 374957 0.21% Ordinary
Total top 20 164233401 93.67%
Other 11107760 6.33%
Total number of shares 175341161 100.00%
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ABOUTKOMPLETTGROUP
DIRECTORS’ REPORT
FINANCIAL STATEMENTS
Overview of the financial statements ......................................... 128
Consolidated financial statements ............................................. 129
Consolidated notes ..................................................................... 133
Komplett ASA financial statements ........................................... 162
Komplett ASA notes .................................................................... 166
Independent auditor’s report ...................................................... 173
THIS IS KOMPLETT GROUP
Komplett Group at a glance.............................................................4
Key figures ......................................................................................5
Letter from the CEO ........................................................................7
Our business segments ...................................................................9
Consumer trends .......................................................................... 13
Strategic and financial roadmap .................................................. 14
Value chain .................................................................................... 15
Community engagements ............................................................. 16
Share information ..........................................................................17
DIRECTORS’ REPORT
Board and management presentation ......................................... 20
Board of directors’ statement ......................................................24
Risk and risk management ............................................................33
Sustainability statement ..............................................................38
General information ..............................................................................39
Environmental information ...................................................................70
Social information .............................................................................. 100
Governance information ...................................................................... 116
Corporate governance report ...................................................... 118
Other reporting ........................................................................... 125
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BOARDOFDIRECTORS'REPORT
BOARD OF DIRECTORS
JO OLAV LUNDER
Chair of the board, non-independent (b 1961)
FABIAN BENGTSSON
Director, non-independent (b 1972)
SUSANNE EHNBÅGE
Director, independent (b 1979)
Professional experience:Over 25 years’ experience from
the telecom, IT, business solutions and e-commerce
sectors. Prior CEO of Ementor, Vimpelcom, John
Fredriksen Group, President of Ferd Capital and COO of
Telenor Mobile.
Professional experience:CEO of SIBA Fastigheter. Prior CEO
SIBA and several positions and directorships within the SIBA
Invest Group. Former chair and director of the board NetonNet.
Former chair of the Swedish Federation of Business Owners.
Former director of Svensk Fastighetsförmedling, Ordna Bolån,
Tipser, Strawbees and Irootfor.
Professional experience:CEO of Lindex Group and
AB Lindex. Former CEO of SIBA and NetOnNet Group,
and board member at Resurs Bank, HiQ International
and Mio.
Other assignments:Chair of Canica Holding, Axxelerator
Capital and Deepocean Group Holding. Director of
Stenshagen Invest, Hallo and Element Logic Holding.
Other assignments:Chair of SIBA Invest. Member of the
board Axfood.
Other assignments:Board member of Ahlsell Group.
Education:MBA from Henley Business School,
Bachelor’s degree from Oslo Business School.
Education:Bachelor’s degree in business economics from
Lund University.
Education:Master’s degree in industrial and financial econom-
ics from the School of Economics and Commercial Law in Goth-
enburg and additional board work education from Ahrens.
Number of Komplett ASA shares:391 777 shares. Number of Komplett ASA shares:55 581 404 shares through
his ownership of approximately one third of the votes and
shares in SIBA Invest.
Number of Komplett ASA shares:0 shares.
The board of directors has overall
responsibility for the group's organisation
and the administration of the operations.
The board of directors establishes strategies
and goals, and makes decisions concerning
major investments and operational changes.
20 KOMPLETT ASA
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ANNUAL REPORT 2024
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THEBOARDOFDIRECTORS
INGVILD NÆSS
Director, independent (b 1979)
JAN OLE STANGELAND
Director, non-independent (b 1967)
ANDERS ODDEN
Worker director, employee (b 1972)
EMELIE VICTORIN
Worker director, employee (b 1983)
Professional experience:CIO at Kahoot!. Former CEO of
E-Tech and CIO at Schibsted, where she also served as
Chief Privacy & Data Trends Officer. Previously a business
lawyer at Thommessen.
Professional experience:CEO of Canica. Former CFO
of Canica, and several prior board positions from listed
companies and from the Canica Group of companies.
Professional experience:Former sales manager and key
account manager across several companies within the
electronics industry.
Professional experience:Previous experience
from project management, management consulting,
accounting and digitalisation from Gislaved
municipality, PWC and EY.
Other assignments:Chair of the board FeltGiS, board
member of Clever Inc and Polyteknisk forening.
Other assignments:Several board assignments, including
board member of Jernia.
Other assignments:Sales director for Komplett Services. Other assignments:Product owner at NetOnNet.
Education:Cand. jur. from the University of Oslo. Courses
from Harvard Business School and executive program at
Standford Graduate School.
Education:Business administration degree from BI
Norwegian Business School.
Education:Bachelor’s degree from the BI Norwegian
Business School.
Education:Master’s degree in business economics
and specialisation in accounting and risk management
from Gothenburg University School of Economics.
Number of Komplett ASA shares:0 shares. Number of Komplett ASA shares: 76 296 shares through
Stangeland Invest AS (owned 50/50 with related parties).
Number of Komplett ASA shares:0 shares and 11 411 options
in Komplett ASA.
Number of Komplett ASA shares:0 shares.
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THEBOARDOFDIRECTORS
GROUP MANAGEMENT
JAAN IVAR SEMLITSCH
President and chief executive officer, (b 1971)
THOMAS RØKKE
Chief financial officer, (b 1968)
ANDREAS WESTGAARD
Commercial director, (b 1974)
JOSEFIN DALUM
Managing director NetOnNet, (b 1983)
Joined Komplett Group in:2023 Joined Komplett Group in:2023 Joined Komplett Group in:2023 Joined Komplett ASA in:2022
Professional experience:Former CEO at Orkla,
Elkjøp Nordic and REMA Industrier, and consultant at
McKinsey & Company.
Professional experience:Former CFO at Saferoad
Holding, Løgismose Meyers and Kwintet Group. He
further holds broad international experience in
operational management positions and strategy
consulting.
Professional experience:CCO and other
managerial positions at Elkjøp Nordic. Former
country manager and European account manager
at LG Electronics, and sales manager Nordic at
Sony Corp.
Professional experience:Former CFO and
acting CEO of Moment Group. Prior experience as
consultant at Polestar Automotive and auditor at
EY.
Education:Master’s degree in business economics
from the Norwegian School of Economics, and an
Exchange MBA in marketing from Northwestern
University, J.L. Kellogg.
Education:Master’s degree in business economics
(lic. Oec. HSG) and PhD (Dr. oec. HSG) in finance and
accounting from the University of St. Gallen,
Switzerland.
Education:Educated at the Officers’ Training
School at the Norwegian Army and management
training from BI Norwegian Business School.
Education:Master’s degree in business
economics from Lund University School
of Economics and Management, with a
specialisation in business economics and
accounting.
Number of Komplett ASA shares and options:
180 000 shares and 1 672 279 options.
Number of Komplett ASA shares and options:
0 shares and 1 031 988 options.
Number of Komplett ASA shares and options:
158 147 shares and 1 101 113 options.
Number of Komplett ASA shares and options:
0 shares and 281 209 options.
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ANNUAL REPORT 2024
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GROUP MANAGEMENT
MORTEN JOHNSEN
Managing director Komplett Services, (b 1973)
TRYGVE HILLESLAND
Managing director Webhallen, (b 1980)
KRISTIN HØDAL TORGERSEN
Chief HR officer, (b 1961)
MARKUS SOLVIK
Chief strategy officer, (b 1986)
Joined Komplett Group in:2024 Joined Komplett Group in:2023 Joined Komplett Group in:2021 Joined Komplett Group in:2022
Professional experience:Former CFO
of Komplett Services and CFO at PetXL
Group. Prior experience from 14 years at
Elkjøp Nordic, most recently as commercial
director.
Professional experience:More than 20
years’ experience from the electronics retail
industry. Former managing director of Elkjøp
Norway and Gigantti.
Professional experience:Has held various
management positions with Danske bank and
the position as CEO at Huseby Kjøkken and
CEO at Neas.
Professional experience:Former CFO and
CSO at Løvenskiold Handel, and several
years as management consultant within
retail and consumer goods at Boston
Consulting Group.
Education:Bachelor’s degree in investment
analysis and a Master degree in corporate
governance & risk management from BI
Norwegian Business School.
Education:Degree from IT Academy Education:Master’s degree in economics and
business administration from Copenhagen
Business School.
Education:Master’s degree in economics
and business administration from the
Norwegian School of Economics and
Cornell University, with a specialisation in
financial economics.
Number of Komplett ASA shares and options:
0 shares and 0 options.
Number of Komplett ASA shares and options:
45 000 shares and 258 059 options.
Number of Komplett ASA shares and options:
11 835 shares and 775 583 options.
Number of Komplett ASA shares and options:
0 shares and 478 348 options.
23 KOMPLETT ASA
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ANNUAL REPORT 2024
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GROUP MANAGEMENT
BOARD OF DIRETORS’ STATEMENT 2024:
PROGRESS IN A CHALLENGING YEAR
In 2024, Komplett Group has navigated challenging market conditions,
which is reflected in the group’s financial performance. Throughout
the year, the group has progressed with its strategic initiatives to
expand into selected categories and segments, optimise the cost
base, and leverage economies of scale, while maintaining a controlled
financial position. Despite intense competition, the group has
maintained high levels of customer satisfaction and retained a strong
market position.
The year 2024 was a year characterised by weak demand, adverse impact from
product related demand cycles and intense competition across the group’s
key markets. This resulted in a 3.5 per cent decline in operating revenues, from
NOK 15 861 million in 2023 to NOK 15 301 million in 2024. Still, the final quarter
of 2024 ended on a more positive note, yielding revenue growth on the back of
receding headwinds in critical categories as well as a strong black week and
peak execution.
In line with its stated strategic priorities, the group has established a central
commercial team, who has negotiated new, group-wide supplier agreements
with improved commercial terms, as well as refining the product assortments
and extending the supplier base. While the group’s commercial and sourcing
efforts have generated positive results, the gross margin came in at 13.7 per
cent in 2024, corresponding to a decline from 13.9 per cent in the prior-year
period, reflecting required price investments and campaign activity to meet
strong competition in key geographies.
During the year, measures to improve cost efficiency were intensified across
the group in order to offset cost increases resulting from inflation, expansion
initiatives, as well as a required higher marketing spending. Operating
expenses totalled NOK 2 138 million in 2024, corresponding to a 3.1 per
24 KOMPLETT ASA
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ANNUAL REPORT 2024
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BOARDOFDIRECTORS'REPORT
cent increase from 2023, mainly driven by higher depreciation from IT and
expansion investments. In sum, the revenue decline coupled with margin
pressure and higher operating expenses resulted in an adjusted EBIT of
negative NOK 47 million in 2024, compared to a profit of NOK 139 million in 2023.
Improved supplier payment terms coupled by disciplined inventory management
have contributed to reduced working capital levels. Throughout the year, the
group has monitored the leverage ratio and financial position closely.
Looking into 2025, an improved consumer environment and new product
launches are anticipated to gradually lead to increased demand. At the same
time, continued market and competitive uncertainties still require active cost
management. During 2024, the group has accelerated measures to reduce cost
and to leverage the group’s efficient and scalable platform, and further actions
to improve cost efficiency have been introduced after year-end.
OVERVIEW OF THE BUSINESS
The board of directors’ statement covers Komplett ASA (“the parent company”
or “the company”), its Norwegian subsidiaries collectively referred to as
Komplett Group (“the group”).
The group is headquartered in Sandefjord, Norway , and has offices at Lysaker,
Norway, and in Borås, Stockholm and Gothenburg, Sweden. NetOnNet also has
a purchase office in Dongguan, China.
At the end of 2024, the group had a total of 1 172 employees (FTE).
Business segments
STRATEGY
Komplett Group presented its refined strategic direction at the Capital Market
Day on 29 February 2024. The group's operating model is based on independent,
differentiated brands, with websites, shops and product offerings tailored
to specific customer segments and needs. The strength of brand autonomy
will increasingly be combined with selected shared functions and capabilities
that provide scale benefits, in particular a central commercial team, a shared
supply chain network and common tech, analytics and data platform.
An overview of Komplett Group’s strategic and financial roadmap can be found
on page 14 of this report.
MARKET POSITION
The group operates in a global competitive market and is the leading online-
first player in the e-commerce segment for electronics and IT-products in the
Nordic region.
The business is attractively positioned in the large and structurally growing
Nordic electronics and IT-products market and benefit from the growth impact
of continued online migration.
The online-first concept implies that products are sold mainly through online
channels. While Komplett is a pure online brand, Webhallen and NetOnNet both
offer an omnichannel concept, with 12 physical stores in Sweden under the
Webhallen brand and 33 physical warehouse shops under the NetOnNet brand,
of which four in Norway and 29 in Sweden.
The aggregated market share in the Nordic area is estimated to be in the level
of 10 per cent.
The group holds varying market shares across segments and markets, with a
particularly strong position in the B2C segment. The group is additionally well
positioned in the B2B segment through Komplett B2B and Ironstone, and in
long-term distribution contracts through the Itegra brand. The group enjoys a
strong competitive position from leveraging superior customer satisfaction,
efficient logistics across segments and distinct brands with lower cost levels
than typical for the industry.
NetOnNet also contributes with an extensive portfolio of own brands enabled
by a local purchasing presence in China since 2005.
RESEARCH AND DEVELOPMENT
The group does not perform research and development activities beyond
development activities connected to technical solutions and functionality on
the group’s webstores.
FINANCIAL REVIEW
The following financial review is based on the consolidated financial
statements of Komplett ASA and its subsidiaries. The statements have been
prepared in accordance with International Financial Reporting Standards
(IFRS) as adopted by the EU as well as the Norwegian accounting legislation.
Statement of profit and loss
Total operating revenue was NOK 15 301 million in 2024, corresponding to a
decrease of 3.5 per cent compared with NOK 15 861 million in 2023. The decline
was mainly driven by weak demand in the group’s core categories, gaming and
IT, as a result of phasing of product cycles and innovations as well as general
market weakness.
Cost of goods sold was NOK 13 211 million in the full year, compared with NOK 13
650 million in 2023. The group’s central commercial team continues to work on
improved commercial terms as part of the centralisation and consolidation of
group sourcing and category management.
The gross margin decreased from 13.9 per cent in 2023 to 13.7 per cent in
2024. The margin development was affected by required price investments
to maintain market positions, in light of the competitive situation, while the
impact was partly offset by positive mix effects and commercial initiatives.
Employee benefit expenses were NOK 1013 million in 2024, compared to
NOK 1014 million in 2023, as cost measures and less exception charges
compensated for expansion activities and continued salary inflation across
markets.
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BOARDOFDIRECTORS'REPORT
Other operating expenses totalled NOK 760 million in 2024, compared with
NOK 765 million in 2023. The decline was driven by efficiency measures and a
reduction in the level of one-off costs, which offset increases from inflation
and growth initiatives.
Depreciation and amortisation totalled NOK 384 million in 2024, of which
NOK 52 million was related to amortisation of acquired customer value. This
compares to NOK 335 million in 2023. The year-over-year increase was mainly
related to upgraded IT infrastructures and new store openings.
No non-cash impairments were recognised in 2024. In 2023, non-cash
impairments charges of NOK 983 million were recognised in accordance
with IFRS recommendations, and in line with generally accepted accounting
principles in Norway.
The operating result (EBIT) for 2024 amounted to a negative NOK 67 million,
representing an improvement from negative NOK 885 million in 2023, including
non-cash impairments.
Net financial items for the full year totalled NOK 169 million, compared with a
NOK 164 million in the same period last year. Interest on the group’s credit and
factoring facilities were the main components of the financial expenses.
Tax expenses totalled a positive NOK 44 million in the full year, compared with a
positive NOK 11 million in 2023.
Loss for the period was NOK 192 million, compared to a loss of NOK 1 038
million in 2023.
Statement of cash flows
Cash flow from operating activities amounted to NOK 1 078 million, compared to
NOK 866 million in 2023. The cash flow from operations was positively impacted
by an increase in trade payables of NOK 510 million, a build-down of inventory of
NOK 146 million. The latter items were partly affected by seasonal shifts.
Cash flow used in investing activities in 2024 was mainly related to property,
plant and equipment for new stores and improvements of the IT infrastructure.
In 2024, cash flow used in investing activities totalled NOK 163 million,
compared to NOK 208 million in 2023.
| IN 2024, KOMPLETT GROUP HAS NAVIGATED CHALLENGING
MARKET CONDITIONS, WHICH IS REFLECTED IN THE GROUP’S
FINANCIAL PERFORMANCE.
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BOARDOFDIRECTORS'REPORT
Cash flow used in financing activities amounted to NOK 419 million in 2024,
compared to NOK 578 million in 2023. Financing activities mainly consisted
of principal and interest paid on lease liabilities and net interest paid on loans,
as well as NOK 41 million in repayment in accordance with the Swedish tax
deferred payment rules, including currency adjustments.
Statement of financial position and liquidity
Non-current assets amounted to NOK 3 872 million at the end of the full year of
2024, compared with NOK 3 899 million at the end of last year.
Current assets amounted to NOK 3 663 million at the end of the year, compared
with NOK 3 408 million in the same period last year. Inventories represented NOK
2 048 million at year-end, compared with 2 194 million one year earlier. A total of
NOK 1 573 million of receivables have been sold under the factoring agreement.
Cash and cash equivalents totalled NOK 726 million at the end of the full year
2024, reflecting the temporary phasing effects at year-end, versus NOK 230
million at year-end 2023.
Equity amounted to NOK 2 581 million at the end of the full year 2024, compared
with NOK 2 721 million in the same period last year. The difference is attributed
to the impact from changes in retained earnings.
The equity ratio was 34.3 per cent at the end of the year compared with 37.2 per
cent at the end of 2023.
Total liabilities amounted to NOK 4 954 million at the end of the full year 2024,
compared with NOK 4 586 million in the same period last year. Trade payables
totalled NOK 2 073 million, representing an increase of NOK 510 million from
the prior-year period. The late phasing of black week temporarily shifted
supplier payments from the peak-months into 2025, which along with improved
commercial payment terms, contributed a significant increase in trade payable
in the period.
Since Q2 2023, the Swedish subsidiaries have partly utilised the extension of
the Swedish tax deferred payment rules. The total outstanding amount at 31
December 2024 was NOK 413 million, of which NOK 263 million is included in the
group’s long-term liabilities. The remaining NOK 150 million, which matures in
less than 12 months, is shown as part of other current liabilities.
Total equity and liabilities amounted to NOK 7 535 million at the end of the full
year 2023, compared with NOK 7 307 million in the same period last year.
Financing and capital structure
The group’s total credit facilities include a revolving credit facility in the amount
of NOK 1 300 million and an overdraft facility in the amount of 400 million. The
latter increased to NOK 500 million in the fourth quarter in accordance with
normal practice.
At 31 December 2024, NOK 800 million of the revolving credit facility was utilised.
Including available cash of NOK 726 million, the liquidity reserve was NOK 1 726
million at the end of 2024, compared with NOK 1 230 million one year earlier.
Net interest-bearing debt at 31 December 2024 was NOK 337 million, excluding
IFRS 16 liabilities, and NOK 854 million including IFRS 16 liabilities.
The leverage ratio, defined as NIBD / LTM EBITDA (adjusted for certain exceptional
items), was 2.5x at the close of the fourth quarter of 2024, with the net debt level
positively affected by the temporarily high liquidity position that is expected to
seasonally adjust during Q1. These shifts have been catered for in the group’s
underlying covenant trajectory, which additionally has been temporarily raised to
allow for a leverage ratio of 4.5x and 4.0x in Q1 and Q2 2025 respectively.
27 KOMPLETT ASA
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BOARDOFDIRECTORS'REPORT
FINANCIAL REVIEW BY SEGMENT
B2C
The B2C segment represented 71.1 per cent of group revenues in 2024.
B2C Key figures:
NOK million 2024 2023
Operating revenues 10 877 11 195
Gross profit 1 678 1 757
Gross margin 15.4% 15.7%
Opex (ex dep) (1 571) (1 529)
D&A (103) (78)
Total opex (1 673) (1 607)
Opex share (15.4%) (14.4%)
Operating profit (EBIT) 4 150
Operating margin (EBIT) 0.0% 1.3%
In 2024, B2C had operating revenues of NOK 10 877 million, representing a 2.8
per cent decrease from 2023. The decrease was mainly due to a challenging
demand environment and the timing of new product launches.
In local currency, the operations in Norway had a revenue increase of 2.0
per cent and a revenue decrease of 6.8 per cent in Sweden. In Denmark, the
B2C had a revenue increase of 1.9 per cent in Denmark, which represents
approximately 2.8 per cent of the B2C sales volume.
Gross profit was NOK 1 678 million, an increase from NOK 1 757 million in 2023.
Gross margin decreased to 15.4 per cent in 2024, compared to 15.7 per cent
in 2023, reflecting intense campaign activity in a highly competitive market,
partly offset by positive mix effects and the group’s commercial efforts.
Total operating expenses were NOK 1 673 million in 2024, compared with NOK
1 757 million in 2023. Operating expenses increased by 4.2 per cent in 2024,
mainly due to increased depreciation costs related to system upgrades of the
SAP ERP and eCommerce solutions.
Operating profit (EBIT) declined to NOK 4 million in 2024, down from NOK 150 million
in 2023. The EBIT margin was 0.0 per cent in 2024, compared to 1.3 per cent in 2023.
B2B
The B2B segment accounted for 9.9 per cent of group revenues in 2024.
B2B Key figures:
NOK million 2024 2023
Operating revenues 1 519 1 583
Gross profit 260 281
Gross margin 17.1% 17.7%
Opex (ex dep) (172) (172)
D&A (14) (9)
Total opex (186) (180)
Opex share (12.2%) (11.4%)
Operating profit (EBIT) 74 100
Operating margin (EBIT) 4.9% 6.3%
The B2B segment had operating revenues of NOK 1 519 million in 2024,
compared to NOK 1 583 million in 2023.
In local currency, the operation in Norway had a revenue decrease of 4.1 per
cent, compared to 2023. In Sweden the decrease in revenue was 5.0 per cent.
Total operating expenses were NOK 186 million in 2024, up from NOK 180
million in 2023, the increase is mainly due to increased depreciation cost and
investment in marketing activities.
Operating profit (EBIT) decreased to NOK 74 million in 2024, down from NOK 100
million in 2023. This gave an EBIT margin of 4.9 per cent in 2024 compared to
6.3 per cent in 2023.
Distribution
The Distribution segment accounted for 19.0 per cent of group revenues in 2024.
Distribution key figures:
NOK million 2024 2023
Operating revenues 2 907 3 078
Gross profit 154 169
Gross margin 5.3% 5.5%
Opex (ex dep) (118) (112)
D&A (10) (7)
Total opex (128) (119)
Opex share (4.4%) (3.9%)
Operating profit (EBIT) 26 49
Operating margin (EBIT) 0.9% 1.6%
Distribution had operating revenues of NOK 2 907 million in 2024, compared to
NOK 3 078 million in 2023, representing a decrease of 5.6 per cent.
In local currency, the operation in Norway had a decrease in revenue of 5.2 per
cent. In Sweden the revenue decreased by 13.1 per cent.
Gross profit amounted to NOK 154 million in 2024, down 8.4 per cent from 2023.
Gross margin was 5.3 per cent in 2024, compared with 5.5 per cent in 2023.
Total operating expenses were NOK 128 million in 2024, compared with NOK 119
million in 2023. Operating expenses increased by 7.8 per cent in 2024, mainly
due to general inflation and higher depreciation costs.
Distribution recorded operating profit (EBIT) of NOK 26 million in 2024, down
from NOK 50 million in 2023. This gave an EBIT margin of 0.9 per cent in 2024
compared with 1.6 per cent in 2023.
Other / IFRS
“Other / IFRS” represents group costs not allocated to the operating segments:
B2C, B2B, and Distribution. This applies when costs are difficult to allocate
fairly between the segments.
28 KOMPLETT ASA
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ANNUAL REPORT 2024
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BOARDOFDIRECTORS'REPORT
Typical cost elements under this segment include management costs and
group strategic initiatives as well as the different effects of IFRS (International
Financial Reporting Standards), especially IFRS 16, as the operating segments
are reported excluding IFRS effects. For additional explanation, please refer to
note 5 to the financial statements.
RISK FACTORS AND RISK MANAGEMENT
Komplett Group is exposed to various forms of risk, overseen by the board. The
board believes there is a healthy balance between the group’s overall risk and
risk-bearing capacity, and targets a long-term leverage ratio, defined as NIBD /
LTM EBITDA (adjusted for certain exceptional items), of 2-3x.
In accordance with section 2-2 (6) of the Norwegian Accounting Act, a summary
of the group’s key financial risks is included below and in note 4 to the financial
statements.
Financial risks
The group is exposed to financial risk through different sources, including
currency risk, credit risk and liquidity risk.
The objective is to reduce the financial risk from financial instruments and thus
improve predictability in the group.
Currency risks
The group is exposed to fluctuations in foreign currency which imposes
currency risk. Efforts are made to reduce the currency risk through the use
of financial instruments in the business in Sweden. The currency risk for the
business in Norway is primarily mitigated by continuously matching the selling
price of the products against developments in purchase for goods measured in
NOK, as well as buying currency at the same time placed for goods in a foreign
currency. The currency is then used for supplier payments.
Komplett Group exercises currency hedging by closely monitoring and
adjusting selling prices while ensuring a high turnover rate for goods exposed
to currency risks.
Credit risks
Komplett Group is exposed to credit risk when a counterparty fails to fulfil
its financial obligations to the group. New suppliers and business customers
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BOARDOFDIRECTORS'REPORT
are hence credit evaluated by the group’s own credit department. The risk on
sales to end-consumers is mitigated by limiting the average order size and by
customer prepayment.
Liquidity risks
Komplett Group is exposed to the risk that it may not be able to meet its
financial obligations. Therefore, the group continuously strives to improve
working capital. Improved working capital and profitability shall contribute to
strengthening the group’s liquidity.
At the end of 2024, the liquidity reserve was NOK 1 726 million. The liquidity
position has benefited from new, group-wide supplier agreements
renegotiated with improved credit and payment conditions. In addition, the
liquidity position was temporarily elevated because of the timing of the black
week season combined with fewer payment days over year-end.
Interest rate risk
Komplett Group is exposed to interest risk through its various sources of
funding. A high proportion of the facilities have floating interest rates, while
the utilisation differs throughout the year.
Market risks
Komplett Group focuses primarily on the Nordic markets but operates in
a global competitive market within e-commerce. The group is therefore
vulnerable to factors affecting international trade, foreign exchange, and the
world economy in general.
The demand situation in its main Nordic markets is correlated with the general
economic development of each country. The market risk may therefore vary
within the different countries.
In 2024, the group continued to witness an elevated level of market risks in
all the Nordic countries, both in terms of macro-economic challenges, and
reduced purchasing power among consumers. However, towards the end of
the year, market conditions showed more positive signals.
Geopolitical risk has risen following the outbreak of wars, political unrest, and
trade sanctions. Risks from regulatory changes, trade barriers, tariffs, and
restrictive government actions could impact the group’s operations and results.
Higher energy prices, inflation and interest rates may continue to influence
consumer preferences and have an adverse impact on consumer spending,
which could negatively impact demand for Komplett Group’s products.
INTANGIBLE RESOURCES
The group is fundamentally dependent on intangible resources such as
consumer satisfaction, reputation and brand strength in order to remain its
market position.
Furthermore, its operations depend on a well-functioning IT infrastructure in
order to fulfil customer expectations with regards to service and delivery, and
to ensure an efficient business model in line with the group’s commitment of
maintaining its industry-leading cost position.
GOING CONCERN
In accordance with section 2-2 (8) of the Norwegian Accounting Act, it is
confirmed that the going concern assumptions continue to apply. The board
of directors firmly believes that Komplett Group has the ability to continue its
operations in the foreseeable future and hence confirms that the accounts
have been prepared on a going concern basis and that this assumption
is appropriate at the date for the accounts, and that the group, after the
proposed dividend, has sufficient equity and liquidity to fulfil its obligations.
PARENT COMPANY RESULTS AND ALLOCATION OF NET PROFIT
The parent company Komplett ASA has had limited commercial operations
in 2024 but has during the year continued to build up certain group functions,
including a central commercial team.
Komplett ASA recorded a loss before taxes of NOK 115 million in 2024,
compared to a loss before taxes of NOK 757 million in 2023. The loss included
group contributions from subsidiaries of negative NOK 84 million in 2024,
compared with negative NOK 131 million in 2023.
The company’s loss after taxes in 2024 was NOK 90 million compared with a net
loss of NOK 748 million in 2023. The board proposes the following allocation of
the net loss of NOK 90 million for the parent company:
Transferred from other equity: NOK 90 million.
The board proposes that no dividend is to be paid for 2024.
| IMPROVED WORKING CAPITAL AND
PROFITABILITY SHALL CONTRIBUTE TO
STRENGTHENING THE GROUP’S LIQUIDITY
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WORKING ENVIRONMENT
The working environment is considered to be healthy. Komplett has since the
end of 2019 introduced a tool to follow the working environment on a weekly
basis. The tool is based on input from employees and is evaluated on an
ongoing basis both by employees and managers in addition to the executive
management. Further, the tool is based on a broader system for following up on
health, safety, and environment.
Average sick leave in 2024 was 4.9 per cent compared with 5.3 per cent in 2023.
During 2024, 16 work related injuries were reported.
For further information about working conditions, please refer to the
Sustainability section on page 100 of this report.
CLIMATE AND ENVIRONMENT
The group is subject to climate and environment reporting requirements
under section 2-3 and 2-4 of the Norwegian Accounting Act. See page 70 in the
Sustainability section of this directors’ report for details.
DIRECTORS’ AND OFFICERS’ INSURANCE
Komplett ASA has a board liability insurance for the group, including the parent
company and its subsidiaries. The insurance covers the board members, CEO
and members of the management team. The insurance comprises personal
legal liabilities, including defence- and legal costs.
SHARE INFORMATION
Komplett ASA is a Norwegian public limited liability with shares listed on Oslo
Børs under the ticker KOMPL.
Komplett ASA has one class of shares, all shares carry the same rights, and no
restrictions on ownership, voting, or limitations on transactions are stated in
its articles of association.
The board of directors has the authorisation to increase the company’s share
capital or to purchase treasury shares for potential employee share programs
and other defined purposes.
Details on shares, equal treatment of shareholders, and potential takeovers,
pursuant to section 2-2 (13) of the Norwegian Accounting Act, are included in
the corporate governance statement in this report.
CORPORATE GOVERNANCE
The board of directors recognises the importance of good corporate
governance. The goal to ensure the protection of all shareholders’ interests and
to ensure that the company complies with high ethical and social standards.
Komplett ASA has established a corporate governance policy in order to
ensure a clear division of roles between the board of directors, the executive
management and the shareholders. The policy is based on the Norwegian Code
of Practice for Corporate Governance. The corporate governance policy is
published on the Komplett Group website, together with other relevant policy
documents such as the investor relation policy, guidelines for remuneration of
executives and instructions for handling inside information.
Komplett ASA is subject to corporate governance reporting requirements under
section 2-9 of the Norwegian Accounting Act and the Norwegian Code of Practice
for Corporate Governance, cf. section 4-4 on the continuing obligations of stock
exchange listed companies. The Accounting Act may be found (in Norwegian)
at www.lovdata.no. The Norwegian Code of Practice for Corporate Governance,
which was last revised on 14 October 2021, may be found at www.nues.no.
The annual statement on corporate governance for 2024 has been approved by
the board of directors and can be found on page 118 of this annual report.
The group conducted a comprehensive risk assessment during 2024, to
identify and assess risk factors of highest importance. Read more about this
risk assessment on page 33 of this report.
Activities on gender equality and non-discrimination
Komplett is required to provide an annual equality statement describing the
company’s efforts to secure equal opportunities under section 26-a in the
Norwegian Equality and Anti-Discrimination Act. The annual statement on
equality is available on www.komplettgroup.com.
| THE BOARD OF DIRECTORS RECOGNISES
THE IMPORTANCE OF GOOD CORPORATE
GOVERNANCE
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EVENTS AFTER 31 DECEMBER 2024
In January, Jaan Ivar Semlitsch informed the board of directors of Komplett ASA
that he will step down as President & CEO to take over as CEO of Apotek1 Gruppen.
He will continue in the position until 1 August 2025. To ensure continuity, the
group's main shareholders have signalled that they will recommend the annual
general meeting to elect Semlitsch as the new chair of the board.
Morten Johnsen took over as CEO of Komplett Services in Sandefjord effective
from 15 January, succeeding Erlend Stefansson. Johnsen comes from the
position of CFO of Komplett Services.
In January, a process to reduce the number of employees at Komplett Services
in Sandefjord by 65 full-time equivalents was announced. Consultation
meetings with the employees started 24 January and are expected to be
completed during the first half of 2025.
On 1 February 2025, Webhallen successfully transitioned to a new ERP system
(IFS) without material disruption and upgraded parts of its other commercial
IT-backbone, enabling improved functionality as well as future synergies with
NetOnNet through a more aligned technical platform.
SUMMARY AND OUTLOOK
Komplett Group remains committed to maintaining its industry-leading cost
position, and to leverage the group’s efficient and scalable platform for growth
as laid out by its strategic priorities.
During the year, a process was initiated to consolidate the group’s logistics
set-up in Sweden. Further, efforts to reduce cost have been accelerated, also
involving reductions at Komplett Services, Sandefjord.
Looking ahead, the economic projections both in Norway and in Sweden as well
as the development of the innovation cycles remain positive. More supportive
market conditions will be coupled by the group’s commercial initiatives to grow
in core and adjacent categories.
Despite these positive signs, it is still difficult to determine the timing of a
definite shift in demand as market conditions and consumer behaviour remain
unpredictable. The competitive environment is likely to remain strong, and new
generations of components have attracted competition from larger players
who are increasing their presence in the computing and gaming categories.
The group’s brands will continue to adapt their pricing strategies to the trading
environment. The group continues to see positive effects from its strategic
initiatives, while the impact from new cost-saving measures are expected to
gain importance gradually into 2025.
Komplett Group remains confident in the longer-term potential for the group,
and firmly believes in the strong underlying market fundamentals for consumer
electronics and appliances as well as the long-term growth trajectory for
online retail.
| KOMPLETT GROUP REMAINS COMMITTED TO
MAINTAINING ITS INDUSTRY-LEADING COST
POSITION, AND TO LEVERAGE THE GROUP’S
EFFICIENT AND SCALABLE PLATFORM
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RISK AND RISK MANAGEMENT
Komplett Group recognises that risk is an inherent part of doing
business and sees effective risk management as a competitive
advantage. The group’s risk management process ensures systematic,
cost-efficient control of risks and opportunities across the group’s
operations. This makes the group better equipped to achieve its
strategic, financial and operational targets while complying with
relevant laws and regulations.
OBJECTIVES
The group’s ongoing commitment to risk assessment and management aims to
achieve the following:
X Develop a systematic overview of key risk factors
X Prioritise identified risks and assess the effectiveness of existing controls
X Develop controls and mitigating actions for identified key risk exposures
X Integrate risk management into an annual wheel and management
processes
RISK MANAGEMENT PROCESS
The group’s risk management process involves the board of directors, audit
committee, group management and business units. The purpose of the
process is to minimise risk by identifying, analysing, and effectively mitigating
significant risks.
Group management annually revises the framework and policies for risk
management, which are then reviewed by the board and the audit committee.
The board, with support from the audit committee, conducts regular reviews
of key risk areas and internal control routines. Each business unit reports to
group management on the follow-up of key risks and the adherence to internal
control routines.
RISK ASSESSMENT PROCESS
For 2024, Komplett Group has identified the most material risk factors through
a structured assessment, considering both likelihood and consequence. The
assessment process involved company representatives from all subsidiaries
and group management, resulting in ten material risk factors.
GROUP MANAGEMENT
AUDIT COMMITTEE
BOARD OF DIRECTORS
Reporting
Governance
RISK ASSESSMENT PROCESS
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RISK ASSESSMENT
STRATEGIC
RISKS
OPERATIONAL
RISKS
FINANCIAL
RISK
COMPLIANCE
RISK
Regulatory
compliance
Market
conditions
Financial
position
People dependency
and resource allocation
Global supply
disruptions
Supply
planning
Brand awareness
and customer
loyalty
Collaboration
across organisations
Digital
development
Cyber-attack
and IT security
STRATEGIC RISKS
Strategic risks include both internal and external events
that pose challenges to Komplett Group’s strategic goals,
market position and competitive advantages. These risks are
primarily associated with changes in the business environment,
stakeholder dynamics and global events.
OPERATIONAL RISKS
Operational risks include internal and external events that may
disrupt day-to-day operations, potentially impacting earnings
and financial position. These risks can normally be influenced
and are often linked to organisational processes, working
methods and skills.
COMPLIANCE RISK
Compliance risk involves the potential negative impact on
a business from the many ongoing and rapid changes in
framework conditions, regulations, and laws, for instance within
material areas such as ESG and GDPR. This category captures
the legal, reputational, and financial penalties for failing to
comply with both internal and external regulations.
FINANCIAL RISK
Risks of a financial nature consist primarily of risks associated
with changes in the macroeconomic conditions, credit situation
for suppliers and customers, currency exposure, and liquidity
changes.
THE FOUR RISK CATEGORIES
The most material risk factors for 2024 have been grouped into four categories:
strategic, operational, financial and compliance risks. Each of these risks impacts
the group’s opportunities to achieve its vision and long-term goals.
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RISK ASSESSMENT
1. Market conditions
Responsible: CEO
Description Mitigation
Changes in
market conditions
affecting
operational
environment,
consumer
demand and/
or competition,
could impact the
group’s financial
results, product
availability,
market share,
and/or customer
agreements.
The group monitors market trends
closely and continuously works
to adapt its product range and
services to consumer demand.
In order to meet competition,
the group has maintained high
campaign activity and invested in
marketing.
The group has also established
a central commercial team to
refine core assortments, extend
the supplier base and improve
commercial terms.
Moreover, measures to increase
supply chain efficiency have been
launched.
The group’s cost base is actively
managed to align it with the
prevailing market conditions.
Cost-saving measures have been
introduced across the group to
offset cost inflation.
For 2025, the group continues its
efforts to strengthen its long-term
competitive position.
2. Digital development and new business models
Responsible: CEO
Description Mitigation
Changes in
technology and a
digital innovation,
evolving at an
increasing pace
(e.g. AI, IoT), could
lead to shifts
in consumer
behaviours,
changing market
conditions, and
competitive
dynamics.
The group leverages its online-
first position with leading
digital platforms and actively
invests in in-house competence
development.
Komplett Services has adopted
an automated warehousesystem,
and was one of Autostore's first
customers.
Komplett Services has also
implemented a new SAP ERP
solution and eCommerce
infrastructure.
In February 2025, Webhallen
transitioned to a new ERP
system (IFS), enabling improved
functionality and future synergies
with NetOnNet through a more
aligned technical platform.
For 2025, the group will
continue its efforts on in-house
competence development.
3. Brand awareness and customer loyalty
Responsible: CSO
Description Mitigation
The group’s
distinct brands
are central to
its competitive
position.
Maintaining and
strengthening
brand awareness
and customer
loyalty is essential
to sustain
Komplett Group’s
market position
and long-term
growth.
Maintaining a strong portfolio of
retail brands that target distinct
customer segments remains
central to the group’s strategy.
Marketing tools are being
deployed across the group in order
to remain top of mind amongst
consumers.
The group is also offering
personalised services, and
customer loyalty clubs. In 2024,
Komplett Services successfully
launched a new loyalty programme
targeting B2B.
4. Collaboration across organisations
Responsible: CHRO
Description Mitigation
Effective
collaboration
between business
units is a central
element to ensure
efficient use
of resources,
sharing of best
practice and
alignment with
overall business
goals.
The group’s business model
is based on selected shared
functions, with a central
commercial team, a unified supply
chain network, and common tech,
analytics, and data structures.
The group encourages
collaboration by promoting a
strong culture-driven environment
with value-driven leadership.
This is supported by clear
communication policies during
change processes, alignment on
business plans, strategies, and
priorities across all business
units, and setting clear goals for
all units and employees. Employee
satisfaction is monitored via
Winningtemp.
STRATEGIC RISKS
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RISK ASSESSMENT
5. Supply planning
Responsible: CCO
Description Mitigation
Komplett Group
works and
collaborates with
different suppliers
in all parts of the
value chain.
Effective supply
planning and strong
supplier relations
are key to optimise
inventory levels,
ensure product
availability, and
maintaining high
service levels for its
customers.
The group monitors its suppliers
closely and foster close
relationships to ensure a stable
supply of goods and reduce the risk
of disruptions.
Ongoing efforts are focused
on professionalis ing sales and
operation planning across all
business units.
Regular supply chain analyses
and audits in the value chain help
maintain proactive dialogue and
identify potential risks early.
The decision to consolidate the
group’s warehouse operations in
Sweden will enhance the utilisation
of the logistics facilities across the
group while continuing to
uphold an industry-leading delivery
service.
OPERATIONAL RISKS
6. Cyber-attack and IT security
Responsible: CFO
Description Mitigation
Komplett Group's
operations rely on
efficient IT and data
systems.
The threat of
external cyber-
attacks, fraud,
and IT security
challenges
involves risks
such as business
disruption, loss
of sensitive data,
and reputational
damage.
Komplett Group regularly updates
its IT platforms to ensure a strong
level of IT security and data
protection.
Cyber security efforts are
increasingly aligned and
coordinated across the group,
which involves continuous work to
reduce risks by implementing more
comprehensive security measures
and collaborating with strategic
partners.
The efforts are supported by the
continued efforts to upgrade the
IT infrastructure including major
upgrades at Komplett Services
in 2023, and at Webhallen in early
2025.
7. People dependency and resource allocation
Responsible: CHRO
Description Mitigation
Komplett Group
values its skilled
workforce and
acknowledges
the importance
of documenting
key processes
and fostering
cross-functional
competence in
order to
minimise people
dependency.
This approach
ensures the ability
to solve critical
tasks or address
operational
problems when
key individuals are
unavailable.
The group mitigates the risk
by standardising knowledge,
increasing training through
Learnifier and on-site sessions, and
optimising the organisational
structure with less silo-based
workflows.
Additionally, it regularly evaluates
resource allocation to ensure
effective use of capabilities.
8. Global supply disruptions
Responsible: CCO
Description Mitigation
Global supply
disruptions, such
as those caused
by sanctions,
pandemic, regional
conflicts, raw
material shortages,
can affect the
availability of
components and
commodities,
potentially
impacting the
group’s ability to
deliver goods to its
customers.
The group proactively monitor
its supply chain and employs a
diversified sourcing strategy.
The group’s central commercial
team ensures a coordinated and
systematic
contact with multiple suppliers.
This approach increases the group’s
ability to adapt to unforeseen
disruption and minimise potential
delays and shortages for the group.
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RISK ASSESSMENT
9. Financial position
Responsible: CFO
Description Mitigation
Access to
competitive
external financing
and adequate
short- and long-
term liquidity
is important
for business
efficiency and to
minimise finance
costs.
Financial risks are monitored and
managed in accordance with the
group’s financial policies, and
closely monitored by the financial
departments and internal control
mechanisms.
10. Regulatory compliance
Responsible: CFO
Description Mitigation
Regulatory
changes across
markets require
ongoing adaption
to ensure
compliance and
avoid potential
impacts on
operations,
customer
relationships and
market position.
Maintaining
regulatory
compliance is
essential for
Komplett Group’s
reputation and
future growth.
The group actively ensures com-
pliance with applicable legislation
and regulation through structured
compliance management.
Key mitigation initiatives include
monitoring and implementing reg-
ulatory updates, such as CSRD,
conducting data protection matu-
rity assessments, improving GDPR
processes, adding ESG resources,
implementing system support for
sustainability reporting, and roll-
ing out new group policies across
subsidiaries.
FINANCIAL RISK COMPLIANCE RISK
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RISK ASSESSMENT
SUSTAINABILITY STATEMENT
CONTENTS
General information ......................................................................39
How we report....................................................................................... 39
How we work ......................................................................................... 42
How we integrate sustainability ...........................................................46
Business model and value chain ...........................................................49
How we engage and prioritise ............................................................... 52
Disclosure requirements ...................................................................... 64
Environmental information ........................................................... 70
Climate change ..................................................................................... 70
EU taxonomy ......................................................................................... 85
Pollution ............................................................................................... 92
Resource use and circular economy ..................................................... 93
Social information ...................................................................... 100
Own workforce.................................................................................... 100
Workers in the value chain .................................................................... 111
Consumers and end-users .................................................................. 114
Governance information .............................................................. 116
Business conduct ................................................................................ 116
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SUSTAINABILITY STATEMENT
GENERAL INFORMATION
This sustainability statement provides an overview of Komplett Group’s efforts on matters
related to the environment, social issues and governance (ESG).
HOW WE REPORT
ABOUT THE REPORT (
ESRS
2)
Basis for reporting
(BP-1)
As required by the EU regulation on sustainability reporting, the Corporate
Sustainability Reporting Directive (CSRD), which came into force under
Norwegian law on November 1st, 2024, and the applicable European
Sustainability Reporting Standards (ESRS), as well as the Norwegian
Accounting Act Section 2-3, Komplett Group is disclosing sustainability
information for the fiscal year 2024.
This sustainability statement covers the entire Komplett Group, including the
subsidiaries; Komplett Services AS, Komplett Distribusjon AS, NetOnNet AB,
Webhallen Sverige AB, Komplett Services Sweden AB, Komplett Distribution
Sverige AB and Ironstone AS. The scope of consolidation is the same as for the
financial statement. Where data and sustainability efforts pertain to a specific
subsidiary, it will be specified accordingly. The sustainability statement
is published annually and covers the fiscal year from 1 January 2024 to 31
December 2024.
In 2024, we conducted a double materiality assessment (DMA) based on
the requirements in ESRS, and our sustainability statement is structured
according to the material topics. The statement includes information on the
identified material impacts, risks and opportunities (IROs) connected with
Komplett Group through our direct and indirect business relationships in the
upstream and downstream value chain as well as in our own operations. We
have not used the option provided by the ESRS regulations to omit information
related to intellectual property, know-how or the results of innovation.
The ESRS index in this sustainability statement provides an overview of
the disclosures made according to the ESRS. In addition, we have included
a chapter for other reporting requirements. This is Komplett Group's first
year with sustainability disclosures in accordance with CSRD set to satisfy
mandatory reporting requirements. We will continue to align our sustainability
disclosures with the applicable reporting requirements as they evolve.
>> For an overview of disclosures in the ESRS index, see ESRS 2 IRO-2
Komplett Group has defined a set of sustainability metrics in line with the ESRS
to ensure a streamlined reporting across the entire Komplett Group with all our
subsidiaries. Employees in the relevant functions report to a group function,
where the data is consolidated and validated.
>> For more value chain information, see Komplett Group’s material impacts,
risks and opportunities in ESRS 2 SBM-3
Report details
(BP-2)
When preparing this sustainability statement, Komplett Group has adopted the
time intervals defined in ESRS, which are applied consistently throughout all
assumptions and estimations:
X Short-term time horizon: the next annual reporting period in our financial
statements;
X Medium-term time horizon: from the end of the short-term reporting period
up to five years; and
X Long-term time horizon: more than five years.
Komplett Group has measured greenhouse gas (GHG) emissions since 2022.
Emissions from Ironstone have been reported since 2023. We are in the
process of improving our methods through inclusion of new emission sources
and refinement of calculations. In 2024, we have put particular emphasis
on expanding Scope 3 reporting to further enhance the quality of our GHG
accounts.
Komplett Group recognises several necessary areas for improvement. In 2023
and 2024, efforts were initiated to align ESG data with ESRS requirements, with
plans to further implement processes and routines in 2025 to enhance our data
quality.
For our value chain, estimations are necessary for Komplett Group to align
our sustainability statement with the disclosure requirements, given the lack
of maturity and accuracy of the data for certain parts of the group’s business
model. To meet these requirements under the ESRS, we therefore provide
estimates for key sustainability metrics based on indirect sources, recognising
the inherent limitations in data collection and accuracy across our upstream
and downstream value chains.
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SUSTAINABILITY STATEMENT
In compliance with ESRS requirements, we disclose metrics that rely on
upstream and downstream value chain data estimated using sector averages
or proxies. These include metrics such as Scope 3 GHG emissions and waste
generation across product life cycles. As mentioned, data from indirect
sources is necessary due to the complexity of gathering precise, primary
information from the full value chain. This is due to our highly complex and
extensive network of global suppliers, sourcing of private label products,
diverse product categories, and reliance on various distribution channels
across multiple markets.
Our basis for preparation of our sustainability statement is data from industry
benchmarks, sector averages and third-party reports. This approach is
necessary due to limited availability of direct data from suppliers and the
challenges inherent in tracing the entirety of our value chain activities. While
our methodology aligns with industry standards, the use of these sources
introduces approximation and hence a level of uncertainty into the estimates.
The overall accuracy of these estimates is considered moderate, as they are
based on assumptions and sector-wide averages rather than primary data
from all value chain participants. Furthermore, certain quantitative metrics
and financial impacts disclosed in this report are subject to a high degree of
measurement uncertainty. These uncertainties arise from factors beyond our
immediate control. For instance, regional variations in supplier data that can
affect the precision of our Scope 3 GHG emissions reporting.
To improve accuracy in future disclosures, Komplett Group is actively working
to enhance our data collection processes. This includes efforts to gather more
granular and reliable data from our value chain, enabling a gradual reduction in
reliance on indirect sources, such as sector averages.
All relevant information required for disclosure according to the ESRS is found
in this sustainability statement, and there is no information incorporated by
reference, cf. ESRS 1 section 9.1 Incorporation by reference. Furthermore, we
have not included disclosures stemming from other legislation or generally
accepted sustainability reporting pronouncements in our sustainability
statement.
As we have chosen to report assumptions influencing the accuracy of metrics
in the value chain alongside the disclosures to which they refer, we provide
a summary of these assuptions in the table "Our reported metrics that are
subject to estimations and assumptions". Detailed descriptions can be found in
the environmental section of our sustainability statement. We have identified
two prior reporting errors that are adjusted in this year’s sustainability
statement. One was related to disclosures of GHG emissions per subsidiary
which through discrepancies between the final table design and working
tables resulted in incorrect figures attributed to the different subsidiaries.
Overall emissions reporting was however not influenced by this. Furthermore,
an extra zero was added to the organic waste fraction from Komplett Services
resulting in 182 tonnes being reported instead of 18.2 tonnes, thus skewing the
overall reported emission value from waste. Specific considerations related
to these errors are reported alongside the disclosure of which they refer to.
Moreover, we have made significant improvements on data collection and
calculations resulting in necessary corrections when reporting comparative
figures. The difference between figures disclosed in previous reporting
periods, and the resulting revision of comparative figures, is reported
alongside the disclosure of which they refer to.
>> For more information about concrete measures related to improving accuracy
for datapoints, in addition to changes and corrections from prior reporting
periods in the methodology descriptions, see E1-6, E5-4 and E5-5
>> For more information about the assumptions influencing the accuracy of
metrics, see E1-6, E5-4 and E5-5
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Our reported metrics that are subject to estimations and assumptions
Standard Datapoint (metric) KPI
reference
Description
Accuracy
1)
ESRS E1
E1-6 Gross
Scopes 1, 2, 3
and Total GHG
emissions
Gross Scopes 1, 2, 3 and Total GHG emissions - Scope 3 GHG emissions
(GHG Protocol)
§44 Scope 3 emissions are estimated using a combination of activity-based and spend-based methodologies, with data gaps
filled by external averages and industry standards.
Moderate
Gross Scopes 1, 2, 3 and Total GHG emissions - total GHG emissions - value
chain
§52 Emissions data for the value chain involves aggregating Scope 1, 2, and 3 emissions. Variability in Scope 3 data, especially
emissions from activities out of control of Komplett Group, contributes to overall uncertainty.
Moderate
Gross Scope 3 greenhouse gas §51 Emission data from activities out of direct control of Komplett Group, such as production of products for sale, and end-of-
life treatment is particularly uncertain.
Moderate
Gross Scope 3 greenhouse gas emissions §51 Emission data from activities out of direct control of Komplett Group. Category 4 and 11, are uncertain due to lack of either
precise data or explicit how products are used by customers.
Low
Total GHG emissions location-based §44, 52a Location-based Scope 2 emissions are calculated using grid-average emission factors, which can vary regionally and
annually. While relatively consistent, regional differences in grid data may introduce minor inaccuracies.
High
Total GHG emissions market-based §44, 52b Market-based emissions are derived using supplier-specific and contractual data, where available. Missing data is
substituted with grid-average factors, leading to potential inaccuracies.
High
ESRS E5
E5-4 Resource
inflow
Overall total weight of products and technical and biological materials used
during the reporting period (mass)
§31a Uncertainty arises from the reliance on supplier data and assumptions about the material composition of products where
direct information is unavailable.
Moderate
Percentage of biological materials (and biofuels used for non-energy
purposes) (per cent)
§31b This percentage is estimated using assumptions about product composition due to incomplete or missing supplier data
regarding the biological and technical content of materials.
High
The absolute weight of secondary reused or recycled components,
secondary intermediary products, and secondary materials used to
manufacture the undertaking’s products and services, including packaging
(mass)
§31c Uncertainty exists because recycled content data was not provided by most suppliers, and assumptions were made about
the absence of recycled materials in several product categories.
Low
Percentage of secondary reused or recycled components, secondary
intermediary products, and secondary materials (percent)
§31c Estimations are subject to significant uncertainty due to the same lack of supplier engagement, requiring reliance on
assumptions or external data where available.
Low
ESRS E5
E5-5 Resource
outflow
Expected durability of the products placed on the market, in relation to the
industry average for each product group (table/per cent)
§36a Durability is estimated using warranty periods for private label products and external deadlines as a proxy for industry
averages, which may not fully capture product lifespan.
Low
Rates of recyclable content in products (per cent) §36c Estimates rely on external data from waste management partners about recycling potential, and assumptions about
economic feasibility of recycling, rather than direct measurements.
Moderate
Rates of recyclable content in product packaging (per cent) §36c Uncertainty exists due to reliance on supplier input for packaging recyclability and the absence of comprehensive data for
certain product lines.
High
Non-recycled waste (mass) §37d Non-recycled waste data relies on estimates of treatment outcomes from waste management companies, with varying
levels of detail and accuracy across regions.
High
1) Accuracy refers to the quality of our data and the
precision of the methods used in calculating ESG
metrics.
High accuracy: This indicates that the data is of high quality,
and the methods applied yield results with minimal bias and
deviation from the true metric.
Moderate accuracy: This level suggests that the data is of
moderate quality, with methods that produce results showing
medium bias and deviation from the true metric.
Low accuracy: This reflects data of low quality, where the
methods result in larger biases and greater deviation from
the true metric.
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HOW WE WORK
SUSTAINABILITY GOVERNANCE
Sound governance is the foundation for oversight and responsible decision-
making. Our sustainability governance structure ensures progress on our
strategic focus areas.
Governing bodies
(GOV-1)
Sustainability and ESG matters are integrated into Komplett Group’s governance
structure. The board of directors oversees all material sustainability topics,
while the group CEO and group management are responsible for our daily
operations. Financial and sustainability performance are managed under the
group CFO, who oversees governance processes, controls, and procedures for
monitoring and managing impacts, risks, and opportunities.
The director legal & compliance and the newly appointed sustainability
manager have a joint responsibility for systematically embedding ESG topics
into our core business processes. This is done in cooperation with human
resources and procurement, as well as other functions.
Roles and responsibilities related to sustainability impacts, risks and opportunities
are reflected in our sustainability policy, including the ones of board of directors,
the audit committee, group CEO and group management, group CFO, director
legal & compliance, sustainability manger, subsidiaries as well as the managing
directors. These roles and their responsibilities are described in a dedicated
chapter of the policy. We will continue to update policies, mandates, roles and
responsibilities to further embed and integrate sustainability management, target
setting and activities into our culture. This includes applying dedicated controls
and procedures to the management of impacts, risks and opportunities. The
controls will be integrated with internal controls over financial reporting.
The composition and diversity of the board of directors and group
management
Diversity in all aspects of our business, including in leadership, is key to our
success. The board of directors consists of seven non-executive members,
including two worker directors. The group management consists of eight
members, with a wide variety of expertise, skills, and background. The board
of directors and group management hold specific expertise from the retail,
electronics and e-commerce sectors. With extensive experience from these
sectors, they also hold specific knowledge about the products we provide to
our customers. The board of directors and group management are based in
both Sweden and Norway, where Komplett Group operates, and in addition they
hold extensive knowledge about our operations in China.
Group management’s
gender diversity ratio
25%
Two females
and six males
BOARD OF DIRECTORS'
GENDER DIVERSITY RATIO
43%
Three females and
four males.
GROUP MANAGEMENT’S
GENDER DIVERSITY RATIO
25%
Two females and
six males.
GROUP MANAGEMENT
Day-to-day management of the company, including material sustainability matters.
Approve the materiality assessment and materiality threshold.
CFO
Financial and sustainability performance.
BOARD OF DIRECTORS
Strategic direction, oversight of material important topics.
Sign the annual, integrated report. Endorse the double materiality assessment.
THE REMUNERATION COMMITTEE
Review the remuneration
and benefits strategy for the
members and executive
management.
LEGAL &
COMPLIANCE
PROCUREMENT
SUSTAINABILITY
QUALITY
HUMAN
RESOURCES
OTHER
THE AUDIT COMMITTEE
Monitor the financial and sustainability
reporting processes and effectiveness of
the company’s internal quality control and
risk management systems.
NOMINATION COMMITTEE
Recommend candidates for the board of directors based on
competence and diversity considerations.
GOVERNANCE MODEL
Roles and responsibilities related to sustainability impacts,
risks and opportunities:
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INDEPENDENCE OF THE
BOARD OF DIRECTORS
57%
Four independent and
three non-independent.
To ensure informed decisions when overseeing sustainability matters, relevant
and satisfactory skills and expertise are available for our group management
and board of directors. An ESG-training specifically designed to address our
material impacts, risks and opportunities was initiated by the board in 2024,
to ensure updated knowledge about our material sustainability matters and
regulations. Further, the board and group management leverage expertise
from internal resources such as the sustainability manager and director legal
and compliance, as well as external expertise hired by the group to secure
progress and compliance related to sustainability reporting.
>> For additional information related to the board of directors and group
management, see the board and management presentation
Sustainability matters addressed
(GOV-2)
The group CFO informs the group management, audit committee and board
of directors about material impacts, risks, and opportunities, at least twice a
year during the endorsement of the double materiality assessment, and the
annual integrated report. This information includes the implementation of due
diligence processes, as well as the results and effectiveness of policies, actions,
metrics, and targets adopted to address them. The audit committee is updated
on material sustainability matters more frequently, with regular meetings on
sustainability, approximately every second month.
The group management is responsible for the oversight and governance of
Komplett Group’s overall risk management, including sustainability risks.
Material impacts, risks and opportunities are included in assessments and
updates on the group strategy. In particular, the material topics have been
essential as a basis for the group’s strategic focus areas and ambitions related
to sustainability. These strategic focus areas and ambitions are supported by
the group CEO and board of directors.
Sustainability impacts, risks and opportunities are integrated into the group’s
risk management process and the group’s Enterprise Risk Management (ERM)
policy ensuring that sustainability matters are systematically evaluated and
managed in the enterprise risk assessment process. This approach promotes
long-term resilience by identifying and mitigating sustainability risks, with the
objective of aligning operations with Komplett Group’s ethical standards and
positively contribute to society.
When overseeing strategy, major transactions, and risk management, Komplett
Group must navigate various trade-offs between financial performance,
sustainability goals, and regulatory compliance. Balancing short-term
profitability with long-term resilience requires weighing investments in circular
economy initiatives, supply chain sustainability, and climate risk preparedness.
While no formal process has been established to assess these trade-offs in
particular, the group management and board of directors are aware and actively
working to integrate sustainability into our business model and strategy while
maintaining financial stability and competitiveness.
All material impacts, risks and opportunities resulting from the materiality
assessment are addressed by the board of directors and group management.
>> For more information about material impacts, risks and opportunities
resulting from our materiality assessment, see SBM-3
Integration of sustainability-related performance in incentive schemes
(GOV-3)
The remuneration performance criteria in incentive schemes at the time of
writing do not cover sustainability goals explicitly, but Komplett Group will
consider whether such criteria should be incorporated to further enhance the
strategic sustainability focus areas. Further, climate related considerations
are not factored into the remuneration for members of administrative,
management and supervisory bodies.
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Statement on due diligence
(GOV-4)
Due diligence is the process whereby we identify, prevent, reduce, and take
responsibility for how we manage actual and potential adverse impacts on the
environment and people associated with our operations.
We are committed to conducting due diligence in accordance with the
concepts and principles set forth in the UN Guiding Principles for Business
and Human rights and OECD Guidelines for Responsible Business Conduct,
including the Norwegian Transparency Act.
Core elements of due diligence Paragraphs in the sustainability statement Page
Embedding due diligence in governance,
strategy and business model
ESRS 2 GOV-2 Sustainability matters addressed 43
ESRS 2 GOV-3 Integration of sustainability-related performance in incentive schemes 43
ESRS 2 SBM-3 Komplett Group's material impacts, risks and opportunities 55-59
Engaging with affected stakeholders
in all key steps of the due diligence
ESRS 2 GOV-2 Sustainability matters addressed 43
ESRS 2 SBM-2 Stakeholder engagement in 2024 52-54
ESRS 2 IRO-1 Komplett Group’s materiality process 59-63
ESRS 2 MDR-P Embedding sustainability in our policies and processes 68-69
ESRS S1-2 Processes for engaging with own workforce and workers' representatives 102
ESRS S2-2 Approach for engaging with value chain workers 112
ESRS S4-2 Processes for engaging with customers 114
Identifying and assessing adverse impacts ESRS 2 IRO-1 Komplett Group’s materiality process 59-63
ESRS 2 SBM-3 Komplett Group's material impacts, risks and opportunities 55-59
ESRS G1-1 Whistleblowing 117
ESRS 2 MDR-P Whistleblower policy 69
Taking actions to address identified
adverse impacts
ESRS E1 MDR-A Taking action 75
ESRS E2 MDR-A Actions and targets related to pollution of soil 92
ESRS E5 MDR-A Actions and efforts to increase circularity in Komplett Group 93-94
ESRS S1-4 Taking action 103
ESRS S2 MDR-A Taking action 113
ESRS S4 MDR-A Taking action and setting targets 115
ESRS G1-1 Business conduct policies and corporate culture 116-117
Tracking the effectiveness of these efforts and
communicating how impacts are addressed
ESRS E1, E5 Numbers and statistics – environment data 76-84, 95-99
ESRS S1, S2 Numbers and statistics – social data 104-110, 113
ESRS G1 Numbers and statistics – governance data 117
ESRS 2 SBM-1 Sustainability strategy and business model 46-51
Information provided in sustainability statement related to our due diligence process.
Embed responsible
business conduct
into policies and
management systems
Code of conduct
Supplier code of conduct
Anti-corruption and bribery policy
Whistleblower policy
Sustainability policy
Remediation
of negative impacts as
far as possible
01
Identify and
assess adverse
impacts
in operations, supply
chains and
business
relationships
02
Cease, prevent
or mitigate
adverse impacts
03
Track
implementation
and results
04
Communicate
how impacts are
addressed
05
06
KOMPLETT GROUP’S APPROACH
TO DUE DILIGENCE
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Managing compliance in the supply chain
One of Komplett Group’s goals is to develop relationships with suppliers and
business partners that share similar corporate values and conduct their
business in an ethical and compliant manner. The supplier code of conduct
outlines the legal obligations, and the integrity standards that Komplett Group
expects our suppliers and business partners to uphold.
Risk management and internal controls related to the sustainability
reporting
(GOV-5)
Komplett Group is developing an internal control system for sustainability
reporting designed to ensure accuracy and reliability of all sustainability
disclosures.
The risk assessment approach employed in the oversight of the sustainability
reporting identifies risks associated with flawed reporting. The identified risks
are prioritised based on the likelihood of reporting errors and the potential
consequences of misreporting.
In 2024, sustainability was integrated into the group’s ERM policy. The
structured ERM methodology for assessing risks is applied to sustainability
risks, including both risk assessments and in the materiality assessment.
Twice a year, the group CFO reports on material risks related to the reporting
process to the group management, audit committee, and board of directors,
providing insights into the effectiveness of the measures taken to mitigate these
risks. Findings related to our risk assessments are assigned to a designated
management member for subsequent follow up and mitigating actions. Going
forward, we aim to further integrate internal control over sustainability reporting
into existing internal control systems as well as establishing how to integrate
findings of our internal controls into relevant internal functions and processes.
A description of identified risks pertaining to the sustainability reporting
process follows below.
>> For additional information related to risk management, see risk and risk
management
Reporting process risks
Topic Primary risk Mitigating strategies
E1 Climate change Inconsistent or incomplete GHG emissions reporting due to data collection gaps or
inconsistent methodologies, as well as reliance on estimated data.
We have provided training on climate reporting to relevant representatives from all group companies. We have implemented
a GHG accounting system to ensure standardised GHG emissions reporting across all companies. We have used the four eyes
principle to review reported data from the group companies.
E2 Pollution Inadequate data collection on pollutant emissions to soil, leading to inaccurate or incomplete
disclosures.
We have included environmental aspects in supplier audits and performed 112 factory audits in 2024.
E5 Resource use and
circular economy
Ensuring accuracy and completeness of data is challenging due to the reliance on estimates
and varying definitions of circularity.
We have worked on improving data quality by gathering data from suppliers, such as data on recyclability and life cycle
assessments. We have initiated a process to improve our Product Information Management (PIM) system, which will allow us to
gather more data on the products we provide to our customers.
S1 Own workforce Incomplete or inconsistent workforce data reporting, particularly when it comes to
consolidating data.
We have established a working group for HR-representatives from all group companies and arranged sessions focusing on
aligning definitions and scope of HR-related data to ensure consistency and comparability.
S2 Workers in the
value chain
Lack of supply chain transparency leading to challenges in obtaining accurate worker data
from suppliers.
The audits conducted in China include assessements of human and labour rights.
S4 Consumers and
end-users
Incomplete or inaccurate reporting on data privacy. We have established clear guidelines for reporting breaches of data privacy.
G1 Business
conduct
The whistleblowing system may not capture all incidents, resulting in reporting not reflecting
the full reality.
We inform all our employees about our whistleblowing channel, and we have made the channel available to the public.
Identified risks related to the sustainability reporting process.
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HOW WE INTEGRATE SUSTAINABILITY
SUSTAINABILITY STRATEGY AND BUSINESS MODEL
(SBM-1)
Komplett Group is the leading online-first player in the Nordic market for
consumer electronics. The group has five distinct brands which are recognised
by customers within the B2C, B2B and Distribution segments. We categorise
our products into four main product groups. All these product groups relate to
material impacts of Komplett Group, such as emissions from production and
transportation, the resource inflows related to assembly of the products, recycled
material usage rate, the repairability of products and the recycling of e-waste.
Our main product categories, and relevant product examples, are:
Product category Product examples
Consumer Electronics TVs, headphones, climate control devices,
gardening tools
Computing Desktop and laptop computers, graphics cards,
gaming consoles
Home Cookers, washing machines, blenders
Telecom Mobile phones, tablets, smartwatches
Komplett Group also offers services targeting improved circularity. These
relate to our material impacts and include trade-in, buy-back and life-cycle
programmes, outlets, and sale of used products.
>> For more information about our circularity related services and actions, see
E5.SBM-1
Because the products Komplett Group provide are all connected with our
material impacts on climate change, the same applies to our customers. Our
significant customer groups are consumers in Norway, Sweden and Denmark,
small businesses in Norway and Sweden, and resellers in Norway and Sweden.
>> For additional information related to business model, see our business segments
>> For additional information related to strategy, see strategic and financial
roadmap
The most significant ESRS sectors for Komplett Group in terms of revenue
generation are wholesale & retail trade and software & IT services. Other ESRS
sectors connected to material impacts are transport, energy production,
manufacturing electronics, and mining. Komplett Group is not active in sectors like
fossil fuel, chemicals production, controversial weapons, or production of tobacco.
ESRS Sector Revenue (NOK million)
Wholesale & retail 15 176
Technology – Software & IT solutions 125
Total 15 301
Integrating sustainabiltiy across the value chain
Sustainability is one of the five pillars of our corporate strategy. Komplett
Group aims to be a driving force for sustainable development in consumer
electronics and retail industry. This entails offering products that have a long
life, can be repaired, and recycled, while also helping customers make more
informed choices. At the same time, we are going to make sure we are an
inclusive employer and follow responsible purchasing practices.
With a comprehensive value chain, Komplett Group is taking several steps to
integrate the findings of our impacts, risks and opportunities assessments into
the group’s strategy and business model. Upstream value chain refers to the
activities and actors involved before products reach Komplett Group. Downstream
value chain refers to the activities and actors involved after products leave
Komplett Group. We aim to act as a bridge between sustainable suppliers and eco-
conscious consumers, ensuring that products are not only high-quality but also
environmentally friendly. By incorporating insights from the entire value chain,
Komplett Group can identify opportunities for innovation, improve operational
resilience, and align its sustainability goals with long-term business success.
As a retailer and distributor of electronic products that contain essential raw
materials such as copper and lithium, Komplett Group prioritises responsible
procurement and processing practices for our suppliers to mitigate risks
associated with resource scarcity and environmental impact. This applies to all
suppliers of electronics and to our production of private label products in China
TOTAL NUMBER OF EMPLOYEES
IN KOMPLETT GROUP
1 482
Total employees
(headcount)
1 026
Sweden
456
Norway
Komplett Group
The leading online-
first champion
with retail brands
loved by
customers
Driving force
for sustainable
development
Online-first
with speed,
convenience
and leading
tech
Unique retail
brands loved
by customers
Leading
efficiency and
OPEX cost position
Integrated
back-end and
shared capabilities
across commercial,
digital and suppply
chain functions
FIVE PILLARS LAY THE FOUNDATION FOR OUR
CORPORATE STRATEGY
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in particular, where we can influence and set requirements for the upstream part
of our value chain. These inputs from the value chain are secured through long-
term supplier agreements, a focus on sustainable sourcing, and investments in
operational efficiency.
In our own operations, Komplett Group integrates sustainability by optimising
storage and packaging materials, such as LDPE and cardboard, to enhance
efficiency and ensure optimised waste reduction. We also aim to minimise
carbon emissions through improvements in transport logistics.
>> For more information about how we work with transport logistics, see E1 MDR-A
Downstream, Komplett Group manages customer relationships through return
policies and end-of-life services, including re-use and recycling initiatives.
In 2024, we revised our materiality assessment to reevaluate which
sustainability topics matter the most, both to us and to our stakeholders.
We upheld our three strategic focus areas – circular business model, climate
neutral and attractive and inclusive employer, with strategic goals for each.
These sustainability goals relate to all our significant groups of products and
services, customer categories and geographical areas as described herein.
We disclose these overall goals and strategic focus areas while recognising
that we will not disclose specific climate change-related targets this year,
as they are defined by the ESRS. We aim to have a transition plan in place
by the end of 2026, which will incorporate our overall ambition of achieving
climate neutrality by 2040. We aim to include the key milestones related to our
continued emission reduction efforts in the transition plan, which will be to
reduce our Scope 1 and 2 emissions by 42 per cent by 2030.
Similarly, we will not report on targets related to circularity this year, as they
are defined by ESRS. Recognising the importance of setting such targets , we
are working to improve data quality to establish a strong foundation for future
targets. Meanwhile, we set the direction by maintaining our strategic circularity
goal.
Selling electronic products in the Nordics, while focusing on sustainability
goals, such as emission reductions and circular business models, presents
several possible levers for improvement. By working with our goal of reducing
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overall emissions, we are exploring energy efficient product categories,
optimisation of logistics routes, the possibility of using more environmentally
friendly modes of transport, and whether we should consider engaging more
actively in carbon offset programs to compensate for unavoidable emissions.
With respect to our goal of expanding our circular business model, we are
continuously working on increasing product lifetimes and more effectively
communicating our recycling programs. We are also exploring the
viability of expanding our product-as-a-service initiatives. With regard to
aligning our sustainability goals with regional considerations, we consider
compliance with all regulatory obligations in all markets and customer
segments to be crucial and we plan to use significant resources towards
that end. Furthermore, as we continue to improve our calculation methods
and data infrastructure related to resource outflows and GHG emissions,
we will be able to dedicate resources more effectively to specific
geographic areas or consumer segments where we have the greatest
opportunity to improve results.
Based on these assessments, Komplett Group has set ambitions for the future
as described in this table.
Strategic focus areas for Komplett Group
Vision The obvious choice
Strategic
focus areas
Circular
business model
Climate
neutral
Attractive and
inclusive employer
Strategic goals
1)
15 per cent of Komplett Group’s revenues comes from
circular products or services by 2028
Scope 1 and 2 (1.5-degree pathway):
Reduction of at least 42 per cent GHG emissions by 2030, compared to 2022
baseline
Scope 1, 2 and 3:
Net zero by 2040
Industry leading employee temperature:
Temperature > index (index based on selected industries)
Gender balance in leadership positions
Ambitions Komplett Group is determined to contribute in the
transition to a circular economy. To do this Komplett Group
will focus on:
Prolonging the loop: Establish circular services, such as
return, repair and reuse, to allow for the products to stay
in the loop for as long as possible. Ensure access to spare
parts for products and refill (where applicable).
Enabling circular choices: Give information through our
platforms, make sustainable products available to our
customers and inform on services and end-of-life treatment
of products sold (nudging).
Komplett Group will reduce climate impact from the whole value chain and aim
to reduce emissions in line with the Paris Agreement (1.5-degree scenario). This
means:
Reducing direct emissions: Reduce emissions from transportation and buildings.
Optimise packaging to reduce material use, transport of air and protect the products
in transportation.
Reducing emissions from our products: Include climate criteria for the selection
of private label products. Working with sustainable category management across
product categories to increase recycled content, ensure products are repairable,
recyclable, and durable and reduce emissions.
Enabling sustainable choices: Offer sustainable products in each product category
and allow filtering based on emissions in production, circular-aspects and energy use.
Komplett Group aims to be an inclusive and attractive employer that attracts and
retains talent and has a positive impact on society. This means:
Creating a great work environment: Ensure that workers feel safe and have the
opportunity to develop, learn and progress – in short: that workers thrive.
Promoting equality and inclusion: Promote equal opportunities and diversity in the
work force.
Being a preferred employer: Have a high retention rate, attract, develop and retain
the best candidates.
Positive impact on society: Impact business partners, suppliers and communities
where we are present by taking care of our employees and promoting a positive
business culture.
Material topics
X E5 Resource outflow
X E5 Resource inflow
X E1 Climate change mitigation
X E5 Waste
X E1 Climate change mitigation
X E1 Energy
X E5 Waste
X S1 Working conditions
X S1 Equal treatment and opportunity for all
X G1 Corporate culture
SDGs
1) Our strategic goals set the direction for our sustainability work. As of now, they are not "targets" as defined by the ESRS for reporting purposes.
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BUSINESS MODEL AND VALUE CHAIN
With respect to our business model and value chain, Komplett Group’s
key business relationships are with our customers and suppliers. For our
customers, hereunder consumers and small businesses, we emphasise
building strong relationships through excellent customer service, a
sustainable product offering, as well as gathering customer feedback to
improve products and services. For our suppliers we emphasise sustainable
sourcing and partnering with suppliers who adhere to high environmental
and ethical standards. We prefer long-term contracts with the right
suppliers to support a stable supply chain.
By focusing on these areas, we can align our operations with our
sustainability goals and also meet the growing demand for eco-friendly
products in the Nordic market.
Customers
Downstream
Komplett
Own operations
Suppliers
Upstream
Recycling/
end-of-life
Raw
materials
Processing
of inputs
Production of
parts and
components
Assembly
of products
Packaging
& storage
Transport Storage &
packaging
Transport B2B and
consumers
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An overview of our value chain, covering suppliers, operations, financial structure, business segments, and key opportunities
Phase Aspects Details
Upstream
Suppliers Raw material suppliers, component manufacturers and key brands (Apple, Samsung, Asus, Sony, Andersson).
Key resources Sustainably sourced raw materials.
Sustainable sourcing Significant activities related to sourcing involve prioritising recycled materials, renewable energy and suppliers
adhering to ethical standards.
Key risks Supply chain disruptions, reliance on global suppliers and potential regulatory changes.
Own operations
Key activities X Product development with a focus on energy-efficient and durable designs.
X Sales and marketing outreach to key markets and customer groups.
X Customer support providing repair and refurbishment services.
Key resources
X Human resources, including IT, logistics and support.
X Advanced technology systems for logistics and manufacturing.
Impacts and risks
X Environmental impact: Reducing electronic waste and carbon emissions through sustainable practices.
X Social impact: Creating jobs and supporting local communities.
X Regulatory changes: Adapting to new environmental regulations and standards.
Cost structure in line
with IFRS 8 business
segments
Costs are primarily driven by procurement, logistics, warehousing and operational expenses. In the B2C segment
(Komplett B2C, NetOnNet, Webhallen), costs include inventory management, marketing, IT infrastructure and customer
service. These are also relevant for the B2B segment (Komplett B2B, Ironstone). The B2B segment also incur costs
related to tailored business solutions and account management. The Distribution segment (Itegra) has costs focused on
supply chain efficiency and bulk logistics.
Revenue in line with IFRS
8 business segments
Revenue is generated through direct consumer sales in B2C, enterprise sales and managed services in B2B, and
wholesale distribution in the Distribution segment. The B2C segment derives revenue from online and retail sales, while
B2B revenues stem from customised IT solutions and business contracts. The Distribution segment primarily earns
revenue from bulk sales to resellers and other partners.
Downstream
Significant markets The Nordic region represents a significant market, accounting for the large majority of revenue and is the primary focus
for sustainability efforts.
Distribution channels
X Online platforms (e-commerce).
X Retail stores (physical locations).
X Authorised resellers (local partners).
Customers
X Individuals seeking electronic goods or services (B2C).
X Companies requiring reliable products for operations (B2B).
Key opportunities Growth in demand for sustainable products and innovation in eco-friendly technology.
>> For more information about the cost structure and revenue of business segments in line with IFRS 8, see financial statements note 5
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Outputs and outcomes
The outputs from our operations and value chain are the products and services
we provide to our customers. This includes products, such as smartphones,
laptops, domestic appliances, gaming equipment and other electronic devices
and accessories, as well as services, such as repair, recycling programs and
customer support.
Our outcomes are the results and impacts of these outputs on our stakeholders,
including our customers and investors. They reflect the value delivered and can
be both qualitative and quantitative. By distinguishing between outputs and
outcomes, and focusing on both, we aim to effectively communicate the value
we deliver to customers, investors, and other stakeholders, while also reaching
our sustainability goals.
Current benefits Expected benefits
Customers Enhanced user experience: High-quality, reliable, and energy-
efficient products improve customers’ daily life and productivity.
Innovation: Continuous improvement and introduction of new
technologies that meet evolving customer needs.
Convenience: Access to a wide range of products and services,
including easy repair and recycling options.
Sustainability: Increased availability of eco-friendly products and
services that align with customers' values and environmental concerns.
Cost savings: Energy-efficient products reduce electricity bills
and durable products lower the need for frequent replacements.
Investors Stable returns: Consistent revenue from product sales and
services.
Growth opportunities: Expansion into new markets and product lines
driven by innovation and sustainability trends.
Market position: Strong brand reputation and market share in
the Nordic region.
Risk mitigation: Adoption of sustainable practices reduces regulatory
and reputational risks.
Other stakeholders Environmental impact: Reduced electronic waste and lower
carbon emissions through recycling programs and energy-
efficient products.
Circular economy: Enhanced circular business model that promote
reuse, refurbishment, and recycling, contributing to a more
sustainable economy.
Social impact: Job creation and support for local communities
through fair labour practices and community engagement.
Partnerships: Stronger collaborations with suppliers, governments,
and NGOs to drive sustainability initiatives and innovation.
Outputs and outcomes in terms of current and expected benefits for customers, investors and other stakeholders.
>> For additional information related to our value chain, see Komplett Group's
value chain
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HOW WE ENGAGE AND PRIORITISE
STAKEHOLDER ENGAGEMENT IN 2024
(SBM-2)
Optimising our sustainability efforts requires allocating resources to the most
material issues, with stakeholder engagement playing a key role in setting our
priorities.
We maintain an open and ongoing dialogue with stakeholders, seeking
external perspectives on our operations. By actively monitoring
the business environment and engaging with relevant groups
across the value chain, including suppliers, NGOs, and industry
organisations, we ensure that our approach remains informed
and responsive. An essential part of this is integrating
stakeholders’ views into our materiality assessments,
helping us understand key concerns across the value
chain.
After consulting with our stakeholders, we found that
their perspectives and interests align well with our
current business model. Therefore, we have not made
any changes to our strategy or business model based
on their input as of now. However, we shall continue
to listen to our stakeholders and remain open to future
adjustments to ensure our business model keeps pace
with new developments. This includes regular meetings
and surveys to gather feedback. We have not set a specific
timeline for any changes, but we are committed to acting
swiftly when adjustments are needed.
We expect our approach of continuous dialogue and adaptation
to strengthen our relationships with our stakeholders. By
demonstrating that we value their input and are willing to adapt, we
believe we can enhance their trust and support.
The group management and the board of directors are informed about the
views and interest of our affected stakeholders with regards to sustainability
related matters during the approval of the double materiality assessment and
the integrated annual report.
KOMPLETTGROUP’S
STAKEHOLDERS
Employees and
management
Suppliers
Nature
(silent stakeholder)
B2C customers
B2B customers
NGOs and
experts
Financial
institutions
Government/
regulators
Shareholders/
investors
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Stakeholder engagement
Why we engage How we engage Key topics of interest in 2024 How we responded
Customers B2C
Our B2C customers are core to our
business, and delivering best in class
customer experience is critical for our
success
X Multiple channels, including face-to-face meetings in shops,
customer care call centres and contact via our customer
loyalty programs
X Active interaction and prompt follow-up on queries/feedback
received via social media platforms such as Facebook, X and
Instagram
X Regular customer interactions via satisfaction surveys
X Gathering insight through sustainability surveys
X Sustainability and quality of products, services and operations
X Customer relationships and cooperation
X Recycling and waste management of consumer electronics
X Offer spare parts and repairs
X Offer a good working environment for our employees
X Environmentally friendly transportation
X Reducing GHG emissions
X Responding promptly to questions and concerns by e-mail,
phone (through our call centre) and social media
X Environmentally friendly deliveries indicated in online checkout
(NetOnNet)
X New packaging strategy for private label, ensuring efficient
packaging and use of more environmentally friendly packaging
Customers B2B
Our B2B customers are core to our
business, and delivering best in class
customer experience is critical for our
success
X Engaging through online communication, newsletters and
face-to-face meetings
X Gathering insight via surveys and interviews
X Sustainability and quality of products, services and operations
X Customer relationships and cooperation
X Packaging
X Transportation matters, including social aspects within the
transportation area
X GHG emissions including access to information about GHG
emissions
X Financing and payment terms
X Ongoing dialogue
X Continuous service development based on customer feedback
Suppliers
We expect our suppliers to deliver on
their commitments while living up
to internationally recognised best
practices
X Regular, direct dialogue
X Gathering insight via interviews
X Strategic collaborations and long-term relationships
X Working conditions for workers in the value chain
X Optimising energy consumption of products
X Producer responsibility such as eco-design of products
X Inspiring customers to buy more eco-friendly products
X Packaging
X Ongoing dialogue
X Strengthened group supplier code of conduct
X Conducted 112 factory audits for private label suppliers in 2024
X Continue to expand tier 2 due diligence – 160 in 2024
X Increased emphasis on working conditions in our audits
X Quality inspection on 100 per cent of private label shipments
prior to shipping
Shareholders/investors
We engage with shareholders and
investors to provide the public with
accurate, comprehensive, and timely
information, to form a solid basis
for making decisions related to the
valuation and trading of Komplett ASA
shares
X Quarterly and annual reports and presentations
X Regular engagement through regulatory financial
communications (financial reporting, stock exchange press
releases etc)
X Investor seminars
X Individual investor calls
X Majority owners are represented on the board of directors
X Gathering insight via interviews
X Equal treatment and opportunities for all
X Contribution to the green shift
X Transparent and regular reporting and disclosure
X Transparent communication
Key stakeholders, stakeholder engagement, and how their topics of interest are taken into account.
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Why we engage How we engage Key topics of interest in 2024 How we responded
Financial institutions
We engage with financial institutions
to ensure stable and efficient financing,
manage financial risks, and support
long-term growth through responsible
financial practices
X Continuous engagement through regulatory financial
communications
X Continuous dialogue
X Gathering insight via interviews
X GHG emissions
X Conditions for own workforce
X Human rights for workers in the value chain
X By reporting through our sustainability statement and
transparency act account
Employees and management
We depend on our employees, their
knowledge, engagement and diversity
to successfully deliver on our strategy
X Employee satisfaction and engagement measured through
surveys every two weeks
X Internal channels and quarterly group-wide townhalls
X Training and coaching
X Engagement with trade unions
X Regular job appraisals
X Flexible and hybrid working
X Career paths, learning and development
X Diversity, equality, and inclusion
X Safety, health, and well-being at work
X Proactive and systematic communication and training
X Individual performance reviews, development tools and
programs
X Flexible ways of working and smart tools
X Talent program
X Social committees for employee satisfaction
Government/regulators
We engage with government and other
regulators to share our knowledge and
shape regulatory actions in pursuit of
common goals and industry transition
X Meetings with relevant authorities
X Engagement and cooperation with organisations and experts
to inform government on sustainability matters
X Swedish chemical taxes on consumer electronics
X Taxes on spare parts and repairs
X Regulatory framework for second-hand trade and repair, to
improve and secure conditions for sales of second-hand
products
X Supported with insight and expertise
NGOs and experts
We commit ourselves to gain insights
and guidance on the issues that are
considered important in science and
among NGOs
X Gathering insight via interviews and dialogue X Repairability, circularity and recycling
X Sustainable packaging
X Inspiring customers to recycle
X Clear communication to customers on related topics
information
X End-of-life treatment
X Social responsibility in transport sector
X New packaging strategy for private label, ensuring efficient
and more environmentally friendly packaging
X We offer circular services such as Trade-In, sale of used
products and FLEX
Nature (silent stakeholder)
Just as we consider human
stakeholders, we need to be inclusive of
non-human stakeholders
X Silent stakeholder X The construction and operation of storage and store facilities
may require clearing land and/or altering the landscape,
potentially disrupting local ecosystems and habitats
X The generation and disposal of waste from storage operations,
such as packaging materials or hazardous waste, can impact
ecosystems if not managed properly
X Circular business through initiatives such as trade-in
programmes
X Trade-in and refurb planned to be implemented for Komplett
Services in 2025
X Emission reduction initiatives
X Ongoing energy surveys of our various properties
X Requirements for energy efficiency in construction and for
materials when building new properties
X We strive to have properties that are energy efficient and
environmentally friendly, that qualify for various certifications
Key stakeholders, stakeholder engagement, and how their topics of interest are taken into account.
Stakeholder engagement (continued)
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KOMPLETT GROUP’S MATERIAL IMPACTS, RISKS AND OPPORTUNITIES
(SBM-3)
In 2024, we updated our double materiality assessment, and the analysis
resulted in the identification of seven material topics and thirteen sub-topics
for the group. The updated assessment was facilitated by a third party to
ensure that all new methodological requirements are met and is now fully
aligned with the ESRS.
Description of material impacts, risks and opportunities resulting from the materiality assessment
Environment
Climate change:
X Impact: Most of Komplett Group's GHG emissions-
stem from upstream activities, hereunder mining
and extraction of raw materials and production and
transportation of components and products. Energy
consumption from our own buildings contributes to
energy use and indirectly to carbon emissions.
X Financial risk: Financial risk is assessed, particularly
with regard to increased costs. Based on an assess-
ment of the magnitude of the potential financial
effect and probability of occurrence, the risk was not
considered material.
X Financial opportunity: Reducing emissions from
transportation may have reputational benefits as
many customers, especially larger B2B customers,
emphasise this topic. In a long-term perspective,
we anticipate regulatory changes and increasing
demand for green investments to be the most signifi-
cant factors leading to financial effects.
X Time horizon: Short, medium and long term.
X Value chain: Upstream, own operations and down-
stream.
Pollution:
X Impact: Electronic prod-
ucts contain metals such
as cobalt, nickel and man-
ganese, which can, if not
treated appropriately, cause
pollution of soil.
X Financial risk: Financial risk
is assessed, particularly
with regard to increased
costs. Based on an assess-
ment of the magnitude of
the potential financial effect
and probability of occur-
rence, the risk was not con-
sidered material.
X Financial opportunity: No
financial opportunities are
identified.
X Time horizon: Short,
medium and long term.
X Value chain: Upstream.
Resource use and circular economy:
X Impact: While some electronics sold contain recycled materials,
virgin plastic is still mostly used due to its cost-effectiveness and
predictability in product quality. One of the goals Komplett Group
wants to achieve, is to offer more products made from recycled
materials. By being a part of an industry with rapid development
in new technologies and short product life spans, Komplett Group
may have a negative impact on overall e-waste levels. Komplett
Group must also pay attention to sustainable packaging to reduce
excessive resource use.
X Financial risk: Increased regulations on circularity, e-waste man-
agement, recycling, packaging, and use of chemicals may require
investments in R&D, design and increase costs.
X Financial opportunities: The most important opportunity overall
for Komplett Group lies in building strong and credible sustainabil-
ity initiatives and thereby creating more circular products and ser-
vices. This should involve all relevant aspects: sourcing recycled
and recaptured materials, designing for durability, recycling, repa-
rability, re-use, and adequate waste management.
X Time horizon: Short, medium and long term.
X Value chain: Upstream, own operations and downstream.
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Social
Own workforce:
X Impact: The positive impact on the company's own work-
force is crucial, as it influences talent attraction and retention.
Komplett Group recognises diversity as an essential but chal-
lenging factor in this context, as part of a male-oriented indus-
try, and have evaluated lack of gender balance as a potential
negative impact.
X Financial risk: There is a risk of not attracting the best and
right candidates if the company is not considered as an attrac-
tive employer with good working conditions, inclusion, and
diversity.
X Financial opportunity: There is an opportunity if the com-
pany manages to develop the right skills and retain talent. A
diverse organisation may lead to reputational benefits and in
turn attract more talent, possibly resulting in ability to design
enhanced products and better understand and communicate
with a diverse customer base.
X Time horizon: Short and medium term.
X Value chain: Own operations.
Workers in the value chain:
X Impact: The nature of the work in the electronics sup-
ply chain and mining production in particular presents
a risk of human rights violations, especially forced and
child labour. Komplett Group focuses on ensuring that
appropriate policies are in place, as well as contrac-
tual commitments with suppliers and supplier audits.
Workers in transportation and logistics are generally
assessed to have a higher risk of work rights viola-
tions because the sectors are under high pressure to
compete on flexibility and short-term responsiveness,
which may give pressure to reduce wages and work-
ing conditions.
X Financial risk: Financial risk is assessed, particu-
larly with regard to lost opportunities and compliance
breaches. Based on an assessment of the magnitude
of the potential financial effect and probability of
occurrence, the risk was not considered material.
X Financial opportunity: Financial opportunity is
assessed, particularly with regard to reduced costs.
Based on an assessment of the magnitude of the
potential financial effect and probability of occur-
rence, the opportunity was not considered material.
X Time horizon: Short, medium and long term.
X Value chain: Upstream and downstream.
Consumers and end-users:
X Impact: Ensuring safe and adequate manage-
ment of our customers’ data, particularly related
to GDPR compliance, is a critical factor for Kom-
plett Group.
X Financial risk: Financial risk is assessed, par-
ticularly with regard to lost opportunities and
reputation. Based on an assessment of the mag-
nitude of the potential financial effect and prob-
ability of occurrence, the risk was not considered
material.
X Financial opportunity: No financial opportunities
are identified.
X Time horizon: Short, medium and long term.
X Value chain: Downstream.
Governance
Business conduct:
X Impact: Protection of whistleblowers is considered a
potential negative impact for Komplett Group. Komplett
Group addresses the risks related to corporate culture
regarding business conduct, anti-corruption and whistle-
blower protection.
X Financial risk: There is a potential risk for Komplett Group
if whistleblowers do not know how and where to report or
that they are protected in the case of reporting on mat-
ters like corruption, breaches in business policies (by own
workers and suppliers) or other business conducts mat-
ters.
X Financial opportunity: Komplett Group can positively pro-
mote a strong culture with respect to good business con-
duct. A strong business ethics culture increases the ability
to impact employees, business partners and workers in
the value chain, and this is particularly important for pri-
vate label products. Strong governance structures include
the use of contractual agreements, policies, and targeted
actions in cases of whistleblowing, corruption or bribery.
X Time horizon: Short, medium and long term.
X Value chain: Upstream and own operations.
Description of material impacts, risks and opportunities resulting from the materiality assessment (continued)
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Material ESRS topics Material ESRS sub-topics Part of the value chain where impact is material (highlighted)
Upstream Own operations Downstream
E1: Climate change E1: Energy
E1: Climate change mitigation
E2: Pollution E2: Pollution to soil
E5: Resource use and circular
economy
E5: Resource inflow
E5: Resource outflow
E5: Waste
S1: Own workforce S1: Working conditions
S1: Equal treatment and opportunities for all
S2: Workers in the value
chain
S2: Working conditions
S2: Other work-related rights
S4: Consumers and end users S4: Information related impact
G1: Business conduct G1: Corporate culture
G1: Protection of whistleblowers
Overview of material topics, sub-topics, and where in the value chain of our business model the material impacts, risks and opportunities are concentrated, as highlighted.
Komplett Group’s strategy is designed to be resilient, with a focus on addressing
material sustainability impacts, risks, and opportunities across different parts
of our business model and value chain. Our risk management framework shall
ensure that these factors are embedded into decision-making and performance
measurement. The strategy includes specific targets for impacts, risks and
opportunities, with goals that are set with a long-term horizon in mind, ensuring
that our business model is adaptable to regulatory changes, market shifts, and
evolving customer expectations in the coming years.
In the short term (up to one year), we focus on operational efficiency and
immediate risk mitigation. In the medium term (one to five years), we aim to
capitalise on emerging opportunities related to circular economy and talent
retention. In the long term (five or more years), our strategy includes scalability
and adaptability to sustain growth and secure our position in a competitive and
sustainability-focused market.
We have aggregated the current and anticipated effects of material impacts,
risks and opportunities to provide a clear and comprehensive view of their
influence on our business model. Additionally, information relating to how these
impacts are connected to our strategy and business model is expressed in a
similar aggregated manner. This approach ensures the information remains
relevant and avoids unnecessary fragmentation, while maintaining focus on
material details. By presenting their effects collectively, we aim to reflect
their interconnected nature and overall significance to our operations and
strategy. The aggregation of impacts, risks and opportunities is expressed and
categorised as environmental, social and governmental.
Environmental impacts and opportunities and its effect on the business model
The most significant environmental impact for Komplett Group stems
from upstream activities, particularly raw material extraction, product
manufacturing, and transportation, which contribute to greenhouse gas
emissions. Although no immediate financial risks have been identified, we
anticipate long-term financial opportunities related to regulatory changes,
with a growing demand for sustainable products and green investments. These
opportunities are aligned with our strategic focus areas, including our goal
of achieving net-zero emissions (Scope 1, 2, and 3) by 2040, with a 42 per cent
reduction in Scope 1 and 2 GHG emissions by 2030.
To capitalise on these opportunities, we have integrated environmental
sustainability into our business targets. In the medium term, one of our
strategic goals is achieving 15 per cent of group revenue from circular products
and services by 2028, reflecting growing financial materiality from circular
economy practices for Komplett Group.
Social impacts and opportunities and its effect on the business model
From a social perspective, we recognise that attracting and retaining talent,
particularly through diversity and inclusion initiatives, is crucial for our long-
term success. The ability to develop and retain a skilled workforce is essential for
driving innovation and engaging a diverse customer base. This presents both risks
(eg if we fail to attract the right talent) and opportunities (eg through enhanced
employee satisfaction and performance). These initiatives are thus integral to
achieving our financial targets, including EBIT margin and cash conversion rate. In
response, we have set a strategic target to achieve and maintain industry-leading
employee satisfaction and achieve gender balance in leadership positions.
Governance framework and integrated risk management in the value chain
Komplett Group’s governance framework is built on strong business ethics,
with a focus on anti-corruption measures, whistleblower protection, and
compliance across our value chain. We address risks related to human rights
violations and unethical practices within the supply chain, particularly in
sectors such as mining and logistics. These efforts are supported by robust
policies, supplier audits, and contractual commitments, which help mitigate
potential risks and ensure long-term business continuity.
The governance-related financial risks and opportunities are integrated into our
overall risk management process, which is reviewed by the board of directors
and the audit committee. This top-down approach ensures that sustainability
risks, particularly those related to governance (such as business conduct and
ethics), are aligned with our broader strategy and long-term business objectives.
Strategic integration and financial effects
We have integrated material impacts, risks, and opportunities into our
overarching business strategy, aligning them with our operations and financial
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performance goals. Our long-term targets, including achieving NOK 20 billion
in sales, an EBIT margin of three to four per cent, and a cash conversion rate
above 70 per cent, are directly influenced by our ability to address material
sustainability-related financial risks and seizing the emerging financial
opportunities. More specifically:
X The focus on circular economy initiatives, including the strategic goal
of 15 per cent of revenue from circular products and services by 2028, is
expected to drive financial growth, while reducing the risk of resource
scarcity and ensuring compliance to current and future regulations.
X Our commitment to climate-related risk reduction, such as the net-zero goal,
aligns with regulatory trends and customer demand for greener solutions,
positioning us to capture long-term market opportunities.
X Talent retention and workforce development are essential for operational
success, influencing our ability to innovate, meet customer needs and
achieve financial goals.
Current and anticipated financial effects and our adjustments
The effects of the identified material risks and opportunities are influencing
our financial position, performance and cash flows. At an aggregated level,
this includes our ongoing sustainability initiatives related to adapting circular
economy practices and reducing emissions. This impacts both operational
efficiency and customer trust, which in turn are key drivers for market
differentiation and profitability. We also recognise that the continued integration
of sustainability into our business model will require ongoing resource allocation.
We acknowledge that certain financial risks related to regulatory changes,
circularity and resource use may lead to material adjustments within the next
annual reporting period. Specifically, investments in R&D, design for durability,
and compliance with future regulations on e-waste and packaging may lead
to changes in the carrying amounts of assets and liabilities, as we continue to
adapt to the evolving sustainability landscape.
>> For more information about our financial position, performance and cash
flows, see financial statements
As part of our discussions during the DMA process, we have analysed the
resilience of our strategy and business model as it is described in SBM-1
(sustainability strategy and business model). When assessing the capacity
of our strategy and business model to address material impacts, risks and
opportunities we have performed a qualitative evaluation of the necessary
steps to remediate impacts, mitigate risks and capitalise on opportunities.
For climate change related impacts, risks and opportunities, our resilience
analysis as well as a scenario analysis based on Intergovernmental Panel on
Climate Change (IPCC) and Network for Greening the Financial System (NGFS)
frameworks is, described in E1.SBM-3. Here we assess potential impacts
over the short (up to one year), medium (one year up to five years), and long-
term (more than five years) horizons. While no immediate risks related to our
capacity to address impacts was identified in relation to climate change, we
will continue to strengthen our ability to address climate-related disruptions as
well as opportunities, including circularity initiatives.
Assessing the opportunity that lies in attracting talent and keeping good employees,
we have looked at Komplett Group’s capacity to continue our training initiatives, social
benefits and work-life balance focus. We see this as an opportunity connected to the
risks associated with recruitment pool with an overrepresentation of male candidates.
Our capacity to address this issue is considered satisfactory.
When assessing our capacity to address human rights related risks in our
upstream supply chain, we have looked at recent training initiatives undertaken
by the procurement department as well as in our private label business. This
upskilling supports increased capacity to assess suppliers more accurately
and understanding the risks related to breaches of human rights. Furthermore,
with factory audits extending beyond tier 1, the supplier oversight related to
material impacts, risks and opportunities, is increasing. The capacity to address
the potential negative impact of privacy breaches related to customer data
is evaluated as adequate and robust as we are continuously running tests on
our cyber security measures in addition to informing our employees about the
policies governing privacy and data management.
The group builds on a strong business ethics culture and governance structures,
which enables us to positively impact employees, business partners and
workers throughout the value chain. As we consider corporate culture both
a risk and an opportunity for Komplett Group, we are actively evaluating
our resource allocations to ensure satisfactory follow-up of our initiatives.
Furthermore, we consider that the capacity to address the potential negative
impact of protection of whistleblowers to be strong, based on our governance
mechanisms, including our whistleblower channel and related policies.
>> For more information about impacts connected to strategy and business
model, see strategic focus areas, ambitions and targets in SBM-1
>> For more information about resilience and scenarios related to climate
change, see E1. SBM-3
Where impacts, risks and opportunities are likely to occur
How we manage and monitor material topics depends on where they are likely to
have an impact, and the expected risks and opportunities ahead. Acknowledging
that ESG issues will evolve and become increasingly important over the coming
years and decades, we adopt a long-term time perspective in our materiality
assessments and planning, extending beyond five years into the future.
How we define the value chain:
X Upstream: All activities related to our suppliers of third-party brands and
private label.
X Own operations: Storage, packaging, sale, transport, customer service and
administration.
X Downstream: Distribution and sale of goods and services to customers,
recycling and end-of-life treatment.
More details about each material sub-topic, including management of the
topics through policies adopted, actions and resources, and metrics and
targets for the material sustainability matters are described in the topical
chapters.
Changes in materiality results
While financial risks related to price pressure and reduced access to electronic
components remain, they fall below our materiality threshold. Compared to the
previous reporting period, climate change adaptation is therefore no longer
considered material in relation to CSRD reporting. Further, the production
of steel components and transportation from suppliers to our facilities are
assessed as having potential rather than actual impacts on water pollution,
making this topic non-material in relation to CSRD reporting.
Meanwhile, whistleblower protection is now classified as material. Komplett
Group maintains accessible whistleblower channels and given the potential
for severe human rights violations without them, we have reassessed its
significance accordingly.
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Non-material topics for Komplett Group
Unchanged non-
material topics
from previous
reporting period
Reasoning
Water and marine
resources
Water and marine resources are not classified as
material, as our operations have limited direct water use.
While data centres require potable water for cooling and
have an indirect impact through energy consumption,
this does not meet our CSRD-defined materiality
threshold.
Biodiversity and
ecosystems
Biodiversity and ecosystems are not classified as
material. Our locations, primarily in cities and industrial
zones, are unlikely to significantly impact biodiversity,
though site-specific nature risk assessments could
enhance our understanding.
Affected
communities
Affected communities are not classified as material. Our
business model, centered on e-commerce and retail,
has limited direct environmental or social effects on
specific geographic communities.
Topics deemed non-material in the previous period that remain non-material in 2024.
All impacts, risks and opportunities are covered by the ESRS disclosure
requirements, and no entity-specific impacts, risks and opportunities have
been assessed to be material for the group.
KOMPLETT GROUP’S MATERIALITY PROCESS
(IRO-1)
In 2024, we revised and strengthened our double materiality assessment in
accordance with the CSRD, using the same process to identify, assess and
manage impacts, risks and opportunities as in the prior reporting period.
The assessment builds on the analysis from 2023, which was also done with
reference to the directive.
By doing a double materiality assessment we have identified and assessed
sustainability matters relevant to the group’s operations and our stakeholders’
expectations. This process involves evaluating Komplett Group's impact on
factors related to environment, social and governance (impact materiality) and
understanding how risks and opportunities related to these factors influence
the group financially (financial materiality). We also mapped which impacts
have dependencies to financial risks and opportunities.
The assessment included a thorough analysis of relevant topics and sub-topics
as described in the ESRS, to define and prioritise which sustainability topics
to disclose in the sustainability statement. We also considered entity-specific
topics in addition to the defined ESRS topics, but did not identify any additional
material matters. The project team included members from Komplett ASA and
all the subsidiaries, as well as associated key resources and relevant experts
from different parts of the organisation.
A broad range of input forms the basis for the assessment, such as reports,
documents, interviews and workshops, as well as information related to
Komplett Group and its sectors, business model and business relationships.
Examples of data sources are our HR-systems, sales and revenue monitoring
systems and enterprise resource planning systems. The scope of operations
covered are our own operations as well as upstream and downstream
operations as described in SBM-1 (sustainability strategy and business model),
and assumptions have been made on a general level related to qualitative
assessments pertaining to all impacts, risks and opportunities.
The methodology used in our double materiality assessment follows
a structured approach aligned with Komplett Group’s enterprise risk
management (ERM) framework. This alignment ensures consistency in how
we assess and manage all forms of risk and opportunities, including the
sustainability related ones.
The group companies’ ERM processes, centralised at group level, involve an
annual review and update of risk management procedures. This process is
structured as a core part of risk assessment and includes sustainability-related
risks, such as climate change impacts, resource scarcity, and regulatory
compliance, which are evaluated in terms of their likelihood and potential impact,
as well as opportunities in terms of potential and actual measures and actions.
By integrating the results of the double materiality assessment into our
enterprise-wide risk management, sustainability matters are subjected to the
same risk assessment criteria and governance procedures as other significant
business risks. This includes the reporting of risks to group management
and review by the board of directors and the audit committee. The double
| IN 2024, WE REVISED AND STRENGTHENED
OUR DOUBLE MATERIALITY ASSESSMENT IN
ACCORDANCE WITH THE CSRD
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materiality assessment is approved by the group management and endorsed
by the board of directors. We are currently reviewing our internal control
procedures to sufficiently include sustainability reporting.
Our materiality assessment is conducted in four steps
1. Understand
X Understand the context including business model, relationships, and
value chain
2. Identify
X Collect information from internal and external sources
X Identify impacts, risks and opportunities (IROs)
3. Evaluate
X Score topics
X Define the final list of material matters
4. Decide
X Determine threshold values
X Verification and approval by group management and endorsement
by board of directors
>> For additional information related to risk management, see risk and risk
management
Four step approach
1. Understand
The materiality assessment is based on Komplett Group’s previously
conducted materiality assessments and aims to understand our impacts, risks
and opportunities (IROs).
X Map Komplett Group’s activities, business model, business relationships
and value chain.
– Special attention is given to heightened risk areas, both by geography and
industry, such as operations in China and mining sites in African countries,
in addition to exposed industries like cleaning and transportation.
X Identify potential ESG-topics along the value chain.
X Build on Komplett Group’s existing stakeholder analysis and materiality
assessment from 2023.
2. Identify
Identify potential areas of influence through analysis and conversations
with internal and external stakeholders. The outcome of this step is a list of
potential material matters and their related IROs.
X Conduct documentation review and interviews with stakeholders in
addition to workshops with the project group to ensure a comprehensive
understanding of IROs.
X Identify impact, risks and opportunities, classify them (positive/negative,
actual/potential) and link them to different levels of the value chain and
ESRS topics.
X Document whether the identified impacts have connections to any risks
and/or opportunities.
Stakeholder engagement
Komplett Group’s existing sustainability reporting features a previously
conducted stakeholder mapping. The double materiality assessment builds
upon these existing efforts while also validating the relevance of each
stakeholder.
To fully comply with the CSRD, stakeholders were first identified, and the most
important ones were then agreed upon. Subsequently, a plan for stakeholder
engagement on ESG topics was created.
For example, the interview with Norsirk, an organisation responsible for
electrical and electronic (EE) waste, was conducted to discuss the circularity
and waste impacts of the electronic products value chain to a greater degree.
The dialogue validated many working hypotheses and showcased several
insightful ways for Komplett Group to impact the subject positively.
Sources used
X Workshops and interviews with internal stakeholders from across the group
companies and various fields of expertise.
X Interviews with external stakeholders, customer surveys and industry-insights.
X External reports and sources.
X Document review of internal reports.
Identification of relevant IROs for further assessment
Based on existing stakeholder analysis, materiality assessment, review
of Komplett Group's value chain and business models and review of IROs
identified by the Sustainability Accounting Standards Board (SASB), we started
off with a list of potential material sub-topics, that were further analysed
and reviewed. This «top-down» approach led to a list of potential material
sustainability matters at topic, sub-topic and sub-sub topic level.
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3. Evaluate
We determined the final list of material matters based on an assessment of the
materiality of the IROs, and also customised the scoring methodology.
Impact materiality
Score how Komplett Group affects the environment and society (inside-out)
based on severity and likelihood.
Severity:
X Scale of impact
X Scope of impact
X Irremediable character
X Likelihood
Scoring of impact
In assessing impacts, Komplett Group evaluates both qualitative and
quantitative factors.
For the qualitative assessment, Komplett Group considers 1) the direction of
the impact (negative or positive), 2) the type of impact (negative, positive), 3)
the time horizon (short, medium or long term), and 4) whether the impact has a
negative effect on human rights.
For the quantitative assessment, Komplett Group uses a scale from 1-5 to
assess the materiality of the impact. This scale is applied when scoring both
severity and likelihood.
The assessment is based on an inherent impact level. Hence, it does not
consider any implemented mitigating actions. For actual impacts, the
likelihood is set to 5, as the impact is occurring.
Financial materiality assessment
Score risks and opportunities by sustainability topic (outside-in).
Potential magnitude of the financial effects:
X Financial impact
X Reputational impact
X Compliance impact
H
ow grave is the impact?
How positive/beneficial
is the impact?
1 = signs of impact
5 = large impact
How widespread will the
impact be on the
population and economies
of affected ecosystems?
1 = few
5 = global
How hard is it to
counteract or rectify
the negative impact?
1 = easy and immediate
5 = irreparable
What is the likelihood
that the impact occurs?
When will it occur?*
1 = < 5% every 20 years
5 =>90% every year
or more/actual
Scale of impact Scope of impact
(only accounts for those
with negative impact)
Impact is occuring
Note that if there is a question of a potential violation of human rights,
the degree of severity will be emphasised more than the likelihood.
Likelihood
Score of
impact
Irremediable character
*
How grave is the
potential financial
impact?
1 = < NOK 5 million
5 = > NOK 25 million
How grave is the
potential reputational
impact?
1 = regional/local no loss in
clients/relationships
5 = national, severe loss
in clients/relationships
How grave is the
potential compliance
impact?
1 = limited non-compliance
5 = very significant
non-compliance,
large consequences
What is the likelihood
that the impact occurs?
When will it occur?
1 = < 5% every 20 years
5=>90% every year
ormore/actual
Financial impact Reputational impact
and
or
and
or
Likelihood
Score of
financial
impact
Compliance impact
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Scoring of financial effects
Our financial materiality assessment is based on an overall understanding
of how Komplett Group’s financial performance can be directly or indirectly
affected. Whether existing mitigating measures have already been
implemented is also taken into account. Even though risks and opportunities
can affect financial performance in different ways, their assessment can be
done under a common framework. This framework scores financial impacts
based on two levels across various impact dimensions and relates it to the
probability of occurrence. The thresholds for financial impact are selected to
match those generally used in Komplett Group’s overall ERM methodology.
Komplett Group risk and opportunity assessment matrix
Very low = 1 Low = 2 Medium = 3 High = 4 Very high = 5
Financial Negative/positive effect
P&L (profit after tax).
Negative/positive effect
P&L (profit after tax).
Negative/positive effect
P&L (profit after tax).
Negative/positive effect
P&L (profit after tax).
Negative/positive effect
P&L (profit after tax).
Reputation
(risks)
Individual cases of
negative publicity in
regional and/or local
media. Not resulting
in loss of clients or
relationships.
Some negative publicity
in regional and/or local
media. May result in
loss of some clients or
relationships.
Moderate negative
publicity in national
and/or local media. May
result in the loss of some
important clients or
opportunities.
Significant and repetitive
negative publicity in
national and/or regional
media. May result in loss
of important clients.
Very significant and
repetitive negative
publicity in national media.
May result in severe loss
of clients or preventing
new relations.
Reputation
(opportunity)
Individual cases of
positive publicity in
regional and/or local
media.
Some positive publicity
in regional and/or local
media.
Moderate positive
publicity in national and/or
local media.
Significant and repetitive
positive publicity in
national and/or regional
media.
Very significant and
repetitive positive
publicity in national media.
Compliance Limited non-compliance
and weaknesses related
to external or internal
laws/regulations.
No legal penalties but
internal warning to the
involved.
Smaller non-compliance
and weaknesses related
to external or internal
laws/regulations.
Low level of fraud,
corruption, etc., with
serious consequences for
the involved.
Moderate non-compliance
and weaknesses related
to external or internal
laws/regulations.
Moderate fraud,
corruption etc. with
serious consequences for
the involved.
Significant non-
compliance and
weaknesses related to
external or internal laws/
regulations.
Significant fraud,
corruption, etc., with
consequences for
management.
Very significant non-
compliance and
weaknesses related to
external or internal laws/
regulations.
Very significant fraud,
corruption, etc., with
consequences for
board of directors or
management.
Likelihood < 5% likelihood that event
will occur (less than once
every 20 years).
5%-40% likelihood that
the event will occur. Event
may occur within the next
10-20 years.
40%-60% likelihood that
the event will occur. Event
may occur within the next
5-10 years.
60%- 90% likelihood that
the event will occur. Event
may occur within the next
1-5 years.
> 90% likelihood that the
event will occur. Event
may occur every year or
more.
Scoring-matrix for financial effects based on effect dimensions and probability of occurrence.
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4. Decide
Facilitate discussions to agree on threshold values for deciding when impacts
are material, and thus will be covered in future ESG reporting, and to create
internal understanding of the topic.
X Determine threshold values to identify material ESRS topics.
X Anchor material sustainability themes.
X Understand how this is taken forward in strategy and reporting.
Komplett Group has decided on thresholds for materiality in collaboration with
internal stakeholders. To secure best practice based on EFRAG’s implementation
guidance, the thresholds for impact materiality, financial materiality and for
cases where the impact could have negative impacts on human rights, were set
separately this year. The thresholds are used to decide which impacts, risks and
opportunities are material for reporting. Based on the scoring of each impact, risk
or opportunity as described in section 3. Evaluate, the respective IRO is assessed
as either material for reporting or not material for reporting.
Thresholds for (potentially) negative impacts on human rights deviate from
impact materiality to emphasise that the severity of the negative impact on
human rights takes precedence over likelihood of occurrence.
As the group is developing its internal control procedures related to
sustainability reporting, decisions pertaining to the double materiality
assessment will be included.
We plan to update the materiality assessment at least every second year.
High – material for reporting
The topic is both strategically important and material for reporting
Medium – not material for reporting
The topic may be material for future reporting and should be monitored
Low – not material for reporting
The topic is considered non-material for Komplett’s sustainability reporting
Financial
materiality
Likelihood
Magnitude of
potential financial effect
Negative impact on
human rights (potential)
Likelihood
Severity
Impact
materiality
Likelihood
Severity
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DISCLOSURE REQUIREMENTS
(IRO-2)
Data points that derive from other EU legislation
Disclosure requirement Data point & description Legislation Page
ESRS 2, GOV-1 21 (d) Board’s gender diversity SFDR/BRR 42
21 (e) Percentage of board members who are independent BRR 42
ESRS 2, GOV-4 30 Statement on due diligence SFDR 44
ESRS 2, SBM-1 40 (d) (i) Involvement in activities related to fossil fuel activities SFDR/P3/BRR NR
40 (d) (ii) Involvement in activities related to chemical production SFDR/BRR NR
40 (d) (iii) Involvement in activities related to controversial weapons SFDR/BRR NR
40 (d) (iv) Involvement in activities related to cultivation and production of tobacco BRR NR
ESRS E1-1 14 Transition plan to reach climate neutrality by 2050 EUCL NS
16 (g) Undertakings excluded from Paris-aligned benchmarks P3/BRR NR
ESRS E1-4 34 GHG emission reduction targets SFDR/P3/BRR NS
ESRS E1-5 38 Energy consumption from fossil sources disaggregated by sources (only high climate impact sectors) SFDR 76
37 Energy consumption and mix SFDR 76
40-43 Energy intensity associated with activities in high climate impact sectors SFDR 77
ESRS E1-6 44 Gross Scope 1, 2, 3, and total GHG emissions SFDR/P3/BRR 79-80
53-55 Gross GHG emissions intensity SFDR/P3/BRR 81
Explanations for the table above:
Legislations:
X SFDR: Sustainable Finance Disclosure Regulation
X P3: EBA Pillar 3 disclosure requirements
X BRR: Climate Benchmark Standards Regulation
X EUCL: EU Climate Law
Abbreviations:
X NR: Not relevant
X NS: Not stated
X NM: Not material
List of disclosures of ESRS data points from other EU legislations.
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Data points that derive from other EU legislation (continued)
Disclosure requirement Data point & description Legislation Page
ESRS E1-7 56 GHG removals and carbon credits EUCL NR
ESRS E1-9 66 Exposure of the benchmark portfolio to climate-related physical risks BRR 73-75
ESRS E2-4 28 Amount of each pollutant listed in annex II of the E-PRTR regulation emitted to air, water, and soil SFDR NM
ESRS E5-5 37 (d) Non-recycled waste SFDR 99
39 Hazardous waste and radioactive waste SFDR 99
ESRS S1, SBM-3 14 (f) Risk of incidents of forced labour SFDR 100-101
ESRS S1-1 20 Human rights policy commitments SFDR 101-102
ESRS S1-17 103 (a) Incidents of discrimination SFDR 106, 110
104 (a) Non-respect of UNGPs on Business & Human Rights, ILO principles, or OECD guidelines SFDR/BRR 106
ESRS 2, SBM-3 11 (b) Significant risk of child labour or forced labour in the value chain SFDR 111
ESRS S2-1 17 Human rights policy commitments SFDR 111-112
18 Policies related to value chain workers SFDR 111-112
19 Non-respect of UNGPs on Business & Human Rights, ILO principles, or OECD guidelines SFDR/BRR 112
19 Due diligence policies on issues addressed by the fundamental International Labour Organisation Conventions 1 to 8 BRR 112-113
ESRS S2-4 36 Human rights issues and incidents connected to its upstream and downstream value chain SFDR 113
ESRS S4-1 16 Policies related to consumers and end-users SFDR 114
17 Non-respect of UNGPs on Business & Human Rights and OECD guidelines SFDR/BRR NM
ESRS S4-4 35 Human rights issues and incidents SFDR NR
ESRS G1-1 10 (b) United Nations Convention against Corruption SFDR 68-69, 117
10 (d) Protection of whistleblowers SFDR 117
ESRS G1-4 24 (a) Fines for violation of anti-corruption and anti-bribery laws SFDR/BRR NM
24 (b) Standards of anti-corruption and anti-bribery SFDR NM
List of disclosures of ESRS data points from other EU legislations.
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ESRS disclosure requirements index
Chapter Standard Disclosure requirement Page
GENERAL INFORMATION
About the report ESRS 2 BP-1, BP-2 39-41
Sustainability governance ESRS 2 GOV-1, GOV-2, GOV-3, GOV-4, GOV-5 42-45
Sustainable strategy and business model ESRS 2 SBM-1 46-51
Stakeholder engagement ESRS 2 SBM-2 52-54
Komplett Group’s material impacts, risks and opportunities ESRS 2 SBM-3 55-59
Komplett Group’s materiality process ESRS 2 IRO-1 59-63
Disclosure requirements ESRS 2 IRO-2 64-67
Embedding sustainability in our policies and processes ESRS 2 MDR-P 68-69
ENVIRONMENTAL INFORMATION
Climate change
Transition plan for climate change mitigation ESRS E1 E1-1 70
Resilience analysis ESRS E1 E1.SBM-3 70-71
Impacts, risks and opportunities ESRS E1 E1.IRO-1 72-75
Policies related to climate change mitigation ESRS E1 MDR-P §62 75
Taking action ESRS E1 MDR-A §62 75
Targets and metrics related to climate change ESRS E1 MDR-T §§72, 81 75-76
Energy consumption and mix ESRS E1 E1-5 76-77
Komplett Group’s GHG-accounts ESRS E1 E1.BP-2, E1-6 77-84
EU taxonomy
Pollution
Policies related to pollution ESRS E2 MDR-P, E2-1 92
Action and targets related to pollution of soil ESRS E2 MDR-A §62, MDR-T §§72,81 92
Resource use and circular economy
Policies related to resource use and circular economy ESRS E5 MDR-P §62 93
Resource inflows, resource outflows and waste ESRS E5 E5.IRO-1 93
Actions and efforts to increase circularity in Komplett Group ESRS E5 MDR-A §62 93-94
Tracking effectiveness of policies and actions through targets ESRS E5 MDR-T §§72, 81 95
Resource inflows ESRS E5 E5-4 95-97
Resource outflows ESRS E5 E5-5, E5.BP-2 97-99
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Chapter Standard Disclosure requirement Page
SOCIAL INFORMATION
Own workforce
Integrating material matters into our strategy and business model ESRS S1 S1.SBM-3 100-101
Policies related to own workforce ESRS S1 S1-1, MDR-P 101-102
Processes for engaging with own workforce and workers’ representatives ESRS S1 S1-2 102
Processes to remediate negative impacts and channels for employees to raise concern ESRS S1 S1-3 102-103
Taking action ESRS S1 S1-4, MDR-A 103
Tracking effectiveness of policies and actions through targets ESRS S1 S1-5, MDR-T 104-105
Characteristics of our employees ESRS S1 S1-6 105, 107-110
Diversity metrics ESRS S1 S1-9 106-108
Adequate salaries ESRS S1 S1-10 106
Health and safety ESRS S1 S1-14 106, 110
Incidents, complaints and severe human rights impacts ESRS S1 S1-17 106, 110
Numbers and statistics ESRS S1 S1-6, S1-7, S1-9, S1-14, S1-17 107-110
Workers in the value chain
Engaging with workers in the value chain ESRS S2 S2.SBM-3 111
Policies related to value chain workers ESRS S2 S2-1, MDR-P 111-112
Approach for engaging with value chain workers ESRS S2 S2-2 112
Processes for remediating negative impacts on workers in the value chain ESRS S2 S2-3 112-113
Taking action ESRS S2 MDR-A §62 113
Tracking effectiveness of policies and actions through targets ESRS S2 MDR-T §§72,81 113
Consumers and end-users
Customer engagement and information-related impact ESRS S4 S4.SBM-3 114
Policies related to consumers and end-users ESRS S4 S4-1 114
Processes for engaging with customers ESRS S4 S4-2 114
Processes to remediate negative impacts ESRS S4 S4-3 115
Taking action and setting targets ESRS S4 MDR-A §62, MDR-T §§72, 81 115
GOVERNANCE INFORMATION
Business conduct
The role of the administrative, management and supervisory bodies ESRS G1 G1.GOV-1 116-117
Business conduct policies and corporate culture ESRS G1 G1-1, MDR-P, MDR-A §62 117
ESRS disclosure requirements index (continued)
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EMBEDDING SUSTAINABILITY IN OUR POLICIES AND PROCESSES
(MDR-P)
Komplett Group integrates sustainability into our core business principles
and processes, which in turn govern how we make strategies and conduct our
everyday work. In 2024, we established several new business conduct policies
at group level. These are the sustainability policy, the privacy policy, the
information security policy, the product safety policy, the HR policy, and the
competition law policy.
All our corporate codes, policies, procedures, processes, and guidelines
are published on Komplett Group's internal website. Going forward, we will
consider publishing more policies on our external webpages to make them
available to our suppliers, business partners and other external stakeholders.
Where applicable, the standards and policies have been developed based on
internationally recognised initiatives and standards such as the UN Global
Compact’s principles, OECD Guidelines for Multinational Enterprises, ILO
conventions, General Data Protection Regulation (GDPR), and United Nations
Convention against Corruption. Komplett Services is also certified according
to ISO 9001 and ISO 14001.
All policies have been developed and adjusted to take the relevant stakeholder
considerations into account. This means in practice that for instance our
sustainability policy, and the policy for product safety, take into consideration
the input provided by customer surveys and regulatory obligations in Norway,
Sweden and Denmark. Additionally, relevant key resources with knowledge and
interests have been actively involved and consulted in the development of each
policy.
The scope of the group level policies is all group-companies, including
all subsidiaries where the group's ownership share is over 50 per cent. In
addition, the supplier code of conduct applies to all suppliers and business
partners. These policies in turn act as guidelines for the development of the
subsidiaries’ own respective policies. The relevant policy coverage per impact,
risk and opportunitiy is described in its respective chapter in the sustainability
statement. On the following page, we present an overview of the main policies
governing the operations of the Komplett Group.
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Main policies governing the operations of Komplett Group
Policy name Purpose Content Approval and responsibility
Code of conduct Ethical guide outlining standards for
employees and stakeholders.
X Compliance with local and international laws
X Principles: honesty, transparency, and respect
X Addresses environmental responsibility, fair competition, and information security
X Owned by the board of directors
X The group CEO is responsible for implementation and compliance
Corporate governance
policy
Ensures good governance practices, reliable
reporting, and compliance.
X Regulates roles between shareholders, board of directors, and management
X Sets objectives, means of attainment, and performance monitoring
X Ensures compliance with legislation and regulations
X Owned by the board of directors
X The group CEO is responsible for implementation and compliance
Supplier code of conduct Integrates UN Global Compact principles
for responsible business practices in
engagement with suppliers.
X Mandates compliance with local laws and international conventions
X Emphasises human rights, safe working conditions, and environmental responsibility
X Strict regulations on wages, working hours, child labour, and non-discrimination
X Owned by the group CEO
X Group CCO is responsible for implementation and compliance
Anti-corruption and
-bribery policy
Zero-tolerance approach to all forms of
corrupt activities.
X Prohibits bribery, kickbacks, facilitation payments
X Strict regulations on gifts, hospitality, and entertainment
X Mandatory anti-corruption training and whistleblower reporting
X Owned by group CEO
X Implemented by group CFO
Whistleblower policy Encourages reporting of concerns related to
violations of laws and ethics.
X Defines whistleblowing and applicable issues, including protection of whistleblowers
X Applies to all employees, business partners, and suppliers
X Reporting through electronic channels or other means
X Owned by group CEO
X Implemented by group CFO
Enterprise risk
management policy
Ensures systematic risk management and
contributes to value creation.
X Systematic and uniform approach to risk management
X Common understanding of group risks, including sustainability
X Early mapping, analysis, and control of significant risks
X Clarifies roles and responsibilities associated with risk management
X Owned by the board of directors
X The group CEO is responsible for implementation
X The group CFO is responsible for reporting risks to the audit
committee and the board of directors
Privacy policy Ensures that personal data processed within
Komplett Group is handled in a secure and
lawful manner.
X Komplett Group shall only process personal data in a lawful, correct, and transparent manner
in relation to the data subjects
X Komplett Group must be able to prove that the fundamental principles of data protection are
being followed
X Owned by group CEO
X Implemented by group CFO
Product safety policy Ensures safety of our customers and
compliance with all relevant laws and
regulations.
X Outlines our dedication to product safety and quality assurance and the measures we have
put in place to ensure this commitment
X Komplett Group shall uphold stringent safety standards to ensure that all products listed on
our platforms meet safety and quality requirements
X Owned by group CEO
X Implemented by group CCO
Human resources policy A unified framework that aims to maintain a
workplace culture that fosters collaboration,
diversity, and innovation.
X Principles and guidelines that ensure consistent, fair, and transparent human resources
practices in all subsidiaries and business units
X Ensuring compliance with relevant labour laws and regulations, including recruitment,
onboarding, performance management, employee wellbeing, and talent development
X Owned by group CEO
X Implemented by group CHRO
Sustainability policy Supports the management of legal
requirements and ensures common action
towards the group’s sustainability ambitions.
X Minimise the footprint from our operations and aim to create positive change by enabling a
responsible transition towards net-zero and sustainable production and consumption
X Outlines sustainability management principles and material sustainability topics
X Owned by the board of directors
X The group CEO is responsible for implementation and compliance
Local subsidiary policies Supplement group policies with local policies.
X Encompass HR, working environment, equality, discrimination, and harassment policies X Local ownership and approval
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ENVIRONMENTAL INFORMATION
Climate change is a key concern for Komplett Group. We are committed to reducing emissions, aligning our operations with global
standards, and minimising environmental impact across our value chain. In this section, we cover all our material topics: climate change,
pollution, and circular economy. Furthermore, to show the link between financial streams and our efforts related to environmental topics,
we include our disclosures related to the EU Taxonomy.
CLIMATE CHANGE
TRANSITION PLAN FOR CLIMATE CHANGE MITIGATION
(E1-1)
Komplett Group works continuously on improving data quality to secure a
sound information basis for our transition plan, including targets, actions,
quantification of investments and funding, as well as alignment with our overall
business strategy and financial planning. We aim to have a transition plan in
place by the end of 2026.
RESILIENCE ANALYSIS
(E1.SBM-3)
By doing our double materiality analysis in 2024 we have identified multiple
climate-related risks, including physical and transition risks, as described in
this sustainability statement. After thorough evaluation, none of these risks
have been found to be material as of now.
When analysing the resilience of our strategy and business model, we have
therefore covered the potential impacts of both physical and transition risks in
our own operations, upstream and downstream value chain.
Our resilience analysis is conducted by using climate scenario analysis based
on Intergovernmental Panel on Climate Change (IPCC) scenarios (2023) and
the Network for Greening the Financial System (NGFS) framework (2024).
This involves evaluating potential outcomes under different global warming
scenarios (eg 2.8°C and above 4°C, by 2100). The scenarios we have considered
include high and low physical and transition risks, assessing the impact of
delayed or ambitious policy actions. The uncertainty of when temperature rises
above critical thresholds or when transition events occur increases the risk. Our
approach is to assume that any changes in transition events will occur during a
medium to-long-term time horizon (five to ten years) and continually update our
strategies in line with expected changes for this time horizon.
>> For more information about our scenario analysis, see E1.IRO-1
Climate risks and business impact
We recognise the potential impact of climate change on our business model
and strategy, and consider Komplett Group well-prepared to address these
challenges.
X Physical Risks: While Northern Europe’s economic impact is expected to
be limited, global productivity declines could affect demand. Rising raw
material costs and transportation challenges may pressure margins. Our
owned and leased assets face some exposure to risks such as landslides
and floods, but given their locations, the likelihood remains low.
X Transition Risks: Regulatory requirements and market expectations for
sustainability will continue to grow. Keeping pace with technological
advancements and adapting our product portfolio is critical to maintaining
compliance and competitiveness.
Our strategy for strengthening our resilience towards climate events
Our strategy is founded on five pillars, as outlined in SBM-1 (sustainability
strategy and business model). Those pillars underpin our tactical choices and
are important for keeping our business model resilient to both changes in
economic shocks and sustainability events.
Komplett Group is continuously working to reduce our carbon footprint.
Furthermore, we are committed to strengthening our market position while
mitigating climate risks. While future climate impacts remain uncertain, we
continuously monitor public opinion, regulations, and technology to ensure the
continued resilience of our strategy.
As a digital first brand we need a business model that adapts to changing
environments. We have tackled the downturn during the Great Recession
and the supply chain turbulence in the aftermath of the Covid crisis. We are
confident in the resilience and adaptability of our business model.
We are mapping potential physical risks to our locations and have not identified any
material threats. However, we will refine our assessments further. In the medium
and long term, we will analyse the climate impact of our product portfolio to meet
regulatory requirements, align with shifting demand, and reduce our carbon
footprint.
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Building a climate-resilient organisation
Reducing our carbon footprint, mitigating risks, and upholding strong
governance will help secure long-term funding. Achieving our net-zero goal
requires company-wide engagement, including workforce upskilling. We have
introduced a circularity course for sales personnel at NetOnNet and plan to
expand sustainability training across subsidiaries.
To strengthen our efforts, we hired a dedicated sustainability manager in
2024. Furthermore, subsidiary controllers play an active role in our CSRD
process, enhancing our sustainability expertise. Our board, group CEO, and
group CFO have also undergone sustainability training and actively contribute
to our strategy development. We will evaluate our strategy considering new
information regarding climate risks.
Overview of the results of our resilience analysis
Risk and opportunity Possible resilience measures
Climate events causes
disruptions in our supply chain.
Reduce our dependency on sole
providers. Use third-party verification
to ensure sufficient measures are taken
to reduce risk from any ESG-events.
Shift in regulations related to
carbon footprint, such as higher
carbon tariffs.
Source products from low-emission
suppliers, monitor and track the ESG-
performance of our products.
Shift in regulations related to
circularity, such as requirements
regarding higher expected lifespan
of products or repairability.
Provide future-fit products and services
with a focus on circularity, like repair
services and sales of spare parts.
Change in public opinion and
market expectations.
Ensure a flexible business model, which
enables us to adapt to changes in
customer demand.
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Material ESRS topics Material ESRS sub-topics Part of the value chain where impact was material Impact materiality Financial materiality
E1: climate change
E1: Energy Upstream Own operations Downstream High High
E1: Climate change mitigation Upstream Own operations Downstream High Medium
IMPACTS, RISKS AND OPPORTUNITIES
(E1.IRO-1)
This topic relates to Komplett Group’s direct and indirect GHG emissions
from both our own operations and our value chain. It also covers our energy
consumption and how we may need to adapt to mitigate climate change impacts.
We are committed to reducing our own emissions and to helping our customers
make more sustainable choices. During the assessment of climate-related
risks and opportunities, transportation to customers was highlighted as
an area with potential financial effect, with potential opportunities lying in
alternative environmentally friendly modes of transportation. No climate-
related financial risks were assessed as material for Komplett Group, but
we fully acknowledge our impact on the environment through our emissions
throughout the value chain.
Energy
Energy consumption mainly comes from the use of fossil fuels and electricity
consumed by our operations. This contributes to carbon emissions, which is
part of the Scope 2 emissions. Energy consumption is increasing exponentially
within the tech sector globally, and Komplett Group can reduce energy
consumption by selling more energy efficient products.
We use energy in the form of electricity and district heating in our warehouses,
stores and offices. There is also significant energy use related to transportation
and logistics, moving products to and from storage facilities. In addition, cloud
computation offered by Ironstone requires large amounts of energy.
Climate change mitigation
Climate change mitigation is the act of reducing GHG emissions through
activities that can be tracked in our GHG accounts.
Most of our emissions stem from upstream activities, hereunder mining and
extraction of raw materials and production and transportation of components and
products. Purchased goods and services is also a significant emission category.
Upstream emissions are largely linked to fossil fuel use during extraction and
processing of materials, such as plastics, aluminium, lithium, in addition to the
upstream transportation of goods. Komplett Group works on mitigating these
emissions by reducing the use of natural resources and optimising packaging
and transportation methods.
Komplett Group can reduce emissions, especially related to transportation.
This includes transportation from suppliers to our operations for private label
products, as well as “last mile” transport from our operations to customer
for all products. We can work to mitigate emissions from transportation
by introducing efficient transportation alternatives and investigating
market opportunities for replacing fossil fuels with biofuel or electricity.
Additionally, we could push third-party brands to reduce emissions from their
transportation, which could also have reputational benefits.
Assessing climate impacts and climate-related hazards
We identify climate impacts by assessing emissions across our value
chain and operations, focusing on activities with high GHG emissions. Our
analysis informs mitigation strategies aligned with our emission reduction
targets, as described in our disclosures pertaining to the work on our
transition plan.
Further, we assess climate-related physical risks in our operations and value
chain through a structured process that identifies potential vulnerabilities
over the short-, medium-, and long-term. This includes screening
operational sites, supply chain activities, and critical assets for exposure
to climate-related hazards such as extreme weather events, flooding, and
heat stress. To identify risks, Komplett Group uses supply chain mapping
and location-based evaluations, supported by historical data and future
climate projections. The projections are informed by analyses from external
stakeholders, including the International Energy Agency (IEA), SINTEF,
WWF, and other research institutes and universities. Data from government
sources, such as the EU, US, and Norwegian authorities, as well as insights
from NGOs and environmental experts, provide additional depth to our
assessments. These evaluations were conducted as part of our double
materiality assessment.
Time horizons for all our assessments follow the guidelines of ESRS, and are
split into:
X Short term: The next annual reporting period
X Medium term: End of reporting period up to five years
X Long term: More than five years
As no impacts are expected in a longer time frame, we have not broken down
the long-term horizon. None of the identified climate-related hazards were
considered material for Komplett Group. However, during the assessment
process we looked at potential operational disruptions and financial impacts
across the value chain.
Climate-related risks
There is a lack of consensus regarding how climate change affects economic
and socio-economic aspects, and it is still too early to estimate the causal
effects of climate change on productivity and our society in general. In the
absence of empirical evidence, we can use a combination of economic models
and logical reasoning to gauge how the risks may affect Komplett Group.
We evaluate our climate risks using IPCC (2023)-scenarios (SSP1-2.6, SSP2-
4.5, and SSP3-7.0), combined with the NGFS (2024) approach of splitting into
high and low physical and transition risk. Nationally declared contributions
(NDCs) are estimated to lead to a global warming of 2.8 degrees Celsius -
close to the SSP2-4.5 scenario. However, the Paris Agreement has a goal
of limiting global warming to 1.5 degrees Celsius and no more than two
degrees Celsius (SSP1-2.6). A high-risk scenario with warming exceeding
four degrees Celsius should also be accounted for (SSP3-7.0). Our climate
scenarios build on analysis from well-known institutes such as The
Norwegian Centre for Climate Services.
We split our climate risks into transition risk and physical risk. This helps us
understand causes of uncertainty and what effect they might have on our
activities.
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Climate risks
TRANSITION RISKS
Policy and legal
Technology
Market
Reputation
PHYSICAL RISKS
Acute
Chronic
Physical risks and transition risks
Physical risks include risks that are caused by the gradual (or chronic) change
in our climate and from extreme weather events that are acute. To meet
changes in climate we will need to transform our society, in one way or another.
This introduces the transition risks. There will be changes in policies, our legal
frameworks, new technology will be introduced, our market will change, and
our reputation is at stake. Following the Network for Greening the Financial
System (NFGS), we divide our analysis into scenarios based on varying levels of
transition and physical risk:
X Disorderly scenario: High transition risk due to late policy interventions.
The greatest risk arises from sudden changes in identified climate-related
transition events.
X Hot house world scenario: High physical risk due to a lack of policy
interventions. This scenario involves an increase in both chronic and acute
physical risks.
X Orderly scenario: Gradual implementation of policy interventions. This
scenario presents lower transition and physical risks, making it easier to
prepare for compared to the other two.
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Climate-related transition events (based on TCFD classification)
Policy and legal Technology Market Reputation
New policies to reduce dependency
on fossil fuels
Technological changes - both a threat
and an opportunity
Gradual change in public opinions Dependent on high quality of our
sustainability reporting
New regulations or requirements to
reduce waste or energy consumption
Technology gap with competitors if
not adapted
Debate on lack of sustainable
products in our product categories
Risk of becoming irrelevant to
customers
Economic impacts of physical climate risk
We expect climate change to reduce global labour productivity, with the
greatest impact in countries near the equator due to rising temperatures
affecting work conditions and food production. While Northern Europe may
see limited effects, reduced global demand could lower Scandinavian exports,
potentially impacting Komplett Group’s sales.
Raw material costs are expected to rise as they become essential for the green
transition. Extreme weather and conflicts will disrupt transportation, while
higher temperatures and heat waves will slow productivity. These factors may
drive up input prices and reduce profit margins.
If emissions continue to rise, global temperatures could exceed 4°C under
the SSP3-7.0 scenario. The IPCC warns of worsening water access, declining
food production, and increased heat-humidity risks. As temperatures rise, the
effects on ecosystems and global welfare become harder to predict.
Transition risks
It is not obvious how transition risks affect Komplett Group. Government
efforts to fight climate change might result in more stringent policies that
affect Komplett Group, for example requirements to reduce the energy
consumption in facilities, or new regulations or requirements on the products
we sell. Technological changes are both a threat and an opportunity for Komplett
Group. If we do not embrace new technology, a gap to our competitors will
likely emerge. The market mechanisms have barely changed due to climate
change, and we have not seen significant changes in the behaviour of market
actors. The debate around sustainable products in the public opinion is only to a
certain extent visible. However, there is a gradual change taking place, and more
and more companies have sustainability policies that govern which products
they purchase. If we do not update our product portfolio according to changes
in market expectations, we might become irrelevant for our customers. Our
reputation can also be affected, which is dependent on our response to evolving
sustainability needs in addition to how we report and act on sustainability
matters.
The later our policy changes take effect and the more ambitious the politics for
reducing global warming becomes, the higher the transition risk becomes. If this
combination is deemed likely, then it is important to put in the right measures to
dampen any effect on changes in politics, regulation, market or technology.
Assessment approach
Our approach to climate risk is to closely monitor changes in the public opinion,
available technology, expected regulatory changes, and how climate change
affects economic and socio-economic factors. Komplett Group will evaluate
our strategy to incorporate new information regarding climate risks.
These assessments are conducted with a structured approach that considers
short-, medium-, and long-term timeframes to capture the evolving nature of
these risks. In the short term (the reporting year), the focus is on identifying
immediate risks and opportunities, such as environmentally friendly
transportation from our own operations to customers, which was considered
the most exposed business activity. Medium-term assessments, spanning from
the end of the reporting period to five years, address transitional events such
as increased emission regulations and a general shift toward energy-optimising
operations, which are expected to influence strategic planning and investments.
For long-term assessments, looking beyond five years, the analysis focuses on
broader structural changes and their potential implications. For example, the
feasibility and cost of transitioning our supply chain to align with environmentally
sustainable practices was considered in light of expected regulatory and market
shifts. In terms of the lifetime of our assets, no transition risks have been identified
in any of the different time horizons, due to the nature of our business model.
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Our physical assets like shops, distribution centres, warehouses, and
administrative facilities face potential climate-related hazards that could
disrupt supply chains and increase maintenance costs. While these risks are
not currently material, we aim to mitigate future impacts.
In our next reporting cycle, we will categorise assets into three groups and
assess physical risks accordingly. Although the overall risk remains low,
disruptions to distribution centres and warehouses pose the greatest concern.
Since shops and administrative facilities are leased and easily replaceable, we
will focus our climate risk assessment on distribution centres and warehouses.
Our business activities also face transition risks and opportunities. Compliance
with new regulations and shifting market demands may incur costs but also
foster innovation and competitiveness. We will closely monitor public opinion,
technology, regulatory changes, and economic factors, adjusting our strategy
as needed.
The financial assumptions, including operational costs and capital investments,
have been done at an aggregated and general level and has thus only been used
as guiding, and not decisive for our assessments, and are therefore not applied
to our financial statements.
>> For more information about our processes to identify and assess material
climate-related impacts, risks and opportunities, see ESRS 2 IRO-1
POLICIES RELATED TO CLIMATE CHANGE MITIGATION
(MDR-P §62)
Our policy framework was updated in 2024 to include a newly developed
sustainability policy that addresses environmental topics on a high level. A more
detailed policy which will address all sustainability matters related to climate
change mitigation, as well as a climate strategy, is planned for 2025. This is to
make sure that we cover all relevant impacts, risks and opportunities in our
policies.
TAKING ACTION
(MDR-A §62)
Komplett Group is continuously working to develop and further our actions on
climate change mitigation and energy use.
We strive to reduce emissions in all parts of our own operations, by reducing the
electricity consumption in our stores and warehouses, sourcing only renewable
energy and introducing zero-emission transport across our operations. In
addition, we are working to develop further actions related to climate change
mitigation and we plan to roll these out continuously as we develop them.
However, we have decided to not report on actions in full this year as we are
unable to meet all the required disclosure criteria. We will focus on improving
our data quality to secure the best possible foundation for our future actions,
transition plan and other measures for reducing emissions and energy use.
Nevertheless, we are proud to showcase some of our efforts related to climate
change despite not satisfying all the disclosure requirements.
Some of our efforts related to climate change are:
Reducing energy consumption
We monitor energy consumption throughout the year and will map our stores
on consumption per square meter. All new stores are fitted with LED lighting,
and we are working to change to LED in existing stores as well.
Enabling sustainable choices
Customers want to make sustainable choices, and we aim to support this by
offering products that are durable, repairable and recyclable. We also help
customers make more informed decisions by communicating sustainability
parameters. Furthermore, we work closely with our suppliers, encouraging
more sustainable practices.
Collaboration with our delivery suppliers
As an e-commerce actor, transport logistics is an extensive part of our
business, involving the daily transport of large quantities of goods. Upstream
transportation and distribution are large contributors to our GHG emissions.
Komplett Group collaborates with various courier suppliers in Sweden,
Denmark, and Norway, as well as several suppliers and producers delivering to
our warehouses. We strive to work with our delivery partners to find collective
solutions to this industry challenge.
All Komplett Group transports, both internal and with partners, must be
carried out in the most climate-friendly way possible. Key solutions include
using biodiesel, efficient packaging to reduce the number of transports, and
optimised transportation routes to reduce fuel consumption. All outgoing
shipments are handled through our warehouses and warehouse stores, where
the subsidiaries cooperate with various transportation partners.
Fossil-free deliveries to customers
Through participation in the branch-initiative “Fossil-free deliveries” led by
Svensk Handel, NetOnNet works to make it easier for customers to make
sustainable choices when shopping online. NetOnNet’s checkout clearly
indicates the fossil-free shipping options. If any fossil-free option is available,
it is always presented at the top of the list of shipping options.
Less customer returns
The high return rate within the e-commerce business is receiving public attention
because of its negative climate impact. Komplett Group strives to reduce the
return rate to a minimum, serving both our business and the environment. This
requires us to ensure that our customers receive the correct products with the
expected standard and quality. Detailed descriptions of our products, along with
reviews from other customers, are important for maintaining low return rates.
Customer product return rate
Per cent 2024 2023 2022
Komplett 2.6% 2.4% 2.1%
Webhallen 4.3% 4.2% 4.6%
NetOnNet 3.7% 3.9% 3.6%
Product return rate is measured as the number of items returned by customers divided by the total
number of items sold.
The calculation of the share of returned goods includes both B2B and B2C
transactions and encompasses ordinary returns, services, and repurchases.
Ordinary returns occur when customers for different reasons change their
minds. Services involve repairs of goods that are sent back to the customer.
Repurchases involve items that cannot be repaired and are credited, scrapped,
or exchanged.
TARGETS AND METRICS RELATED TO CLIMATE CHANGE
(MDR-T §§ 72, 81)
Komplett Group has not yet set measurable outcome-oriented targets related
to climate change, as they are defined in the ESRS. This is due to the transition
plan currently being developed and the challenges in obtaining accurate and
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reliable data necessary for meaningful target-setting.
The effectiveness of our policies and actions is monitored through continuous
analysis of all material impacts, risks, and opportunities. We currently use
qualitative assessments to track progress and have not yet established a
defined level of ambition or any associated quantitative metrics.
Despite not disclosing specific targets related to climate change, as they
are defined by the ESRS, we are disclosing overall goals and strategic focus
areas. Our goal is to have a transition plan in place by the end of 2026, which
will incorporate our overall ambition of achieving climate neutrality by 2040.
We aim to include key milestones related to our continued emission reduction
efforts in the transition plan, which will be to reduce our Scope 1 and 2
emissions by 42 per cent by 2030.
As of now, for Scope 1 and 2 we use 2022 as our baseline year. While we initially
also set 2022 as the baseline year for Scope 3 emissions, improvements in our
emissions accounting in 2024 have led us to reassess. We are now working
toward using this year’s GHG-accounts as the new baseline year for Scope 3
emissions. When developing the transition plan, improved emission figures
might prompt us to reevaluate milestones and goals going forward.
ENERGY CONSUMPTION AND MIX
(E1-5)
Komplett Group's operations involve the consumption of energy through
electricity, district heating and transportation, contributing to carbon
emissions within Scope 2.
Our ambition is to reduce energy consumption and increase the use of
renewable energy sources at our locations. By continuously implementing
new processes and technologies aimed at reducing energy consumption
and the overall energy footprint, Komplett Group is taking steps each year
to achieve this ambition. These steps include, but are not limited to, more
efficient lighting in our facilities, reducing reliance on fossil fuel transport and
increasing the amount of fossil-free electricity purchased.
Green electricity
NetOnNet and Webhallen aim to use green electricity in all properties where
the companies are free to choose their electricity suppliers. LED-lightning is
installed in all NetOnNet stores in Sweden. This is in progress for the stores
in Norway as well. Komplett Services purchases electricity from solar panels,
which covers part of the energy needed to run one of the company's two central
warehouses. Going forward, we will look at the possibility of more solar panels.
Energy-efficient products
The tech sector's increasing energy consumption globally presents an
opportunity for Komplett Group to influence customers by promoting more
energy-efficient products. Demand for energy-saving products is expected to
increase significantly in the future, and this will be reflected in the subsidiaries'
assortment of energy-efficient products. Customers will also in the future
have the possibility to filter products on websites based on energy efficiency.
As high-climate impact sectors are associated with activities described in
NACE codes A through H, Komplett Group generates revenue from:
X NACE code G.46.5 Wholesale of information and communication equipment
X NACE code G.47.4 Retail sale of information and communication equipment
in specialised stores
X NACE code G.47.5 Retail sale of other household equipment in specialised
stores
To calculate net revenue from activities in high-climate impact sectors we
assume, for this purpose, that all revenues except revenue from Ironstone are
associated with the activities described in the mentioned NACE codes. The
relevant line for consolidation with our financial statements can be found under
the note 5 segment information.
Energy consumption and mix
2024
(1) Fuel consumption from coal and coal products (MWh) 0
(2) Fuel consumption from crude oil and petroleum products (MWh) 191
(3) Fuel consumption from natural gas (MWh) 0
(4) Fuel consumption from other fossil sources (MWh) 0
(5) Consumption of purchased or acquired electricity, heat, steam, and cooling from fossil sources (MWh) 5 067
(6) Total fossil energy consumption (MWh) 5 259
Share of fossil sources in total energy consumption (%) 29.96%
(7) Fuel consumption from nuclear sources (MWh) 763
Share of consumption from nuclear sources in total energy consumption (%) 4.34%
(8) Fuel consumption for renewable sources, including biomass
(also comprising industrial and municipal waste of biologic origin, biogas, renewable hydrogen, etc.) (MWh)
12
(9) Consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources (MWh) 11 521
(10) The consumption of self-generated non-fuel renewable energy (MWh) 0
1)
(11) Total renewable energy consumption (MWh) 11 533
Share of renewable sources in total energy consumption (%) 65.70%
Total energy consumption (MWh) 17 554
1) We are not able to identify share of energy production consumed by Komplett Group. Solar panels are installed on the rooftop of a storage building rented by Komplett Services.
The energy produced by the solar panel is consumed by Komplett Services and other tenants renting offices in the same building. In 2024, 63MWh were produced, most of it probably consumed by Komplett Group.
The produced energy not consumed by Komplett Group or the other tentants, is automatically transferred to the grid and sold.
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Overview net revenue Komplett Group
Amounts in NOK million 2024
Net revenue from activities in high climate impact sectors
used to calculate energy intensity and GHG intensity 15 177
Net revenue (other) 125
Total net revenue (financial statements) 15 301
Basis for calculation of Energy intensity (total energy consumption per net revenue).
Energy intensity per net revenue
MWh/NOK million revenue 2024 2023
% 2024
/ 2023
Total energy consumption from activities in
high climate impact sectors per net revenue
from activities in high climate impact sectors 1.15 1.12 3%
KOMPLETT GROUP’S GHG ACCOUNTS
(ESRS E1-6)
Disclosure of metrics estimated using indirect sources
(BP-2)
Komplett Group’s GHG emissions metrics include value chain data estimated using
indirect sources where direct data is unavailable. Scope 1 and Scope 2 emissions
are calculated using activity-based data, with Scope 3 emissions estimated using
financial and sales data, external averages and industry standards. Emission
factors are derived from suppliers, external parties, and LCAs, with all greenhouse
gases converted into CO
2
eq using the IPCC AR6 GWP method.
The metrics' accuracy varies depending on data sources, with Scope 1 and
Scope 2 emissions being highly accurate due to direct measurements, while
Scope 3 estimates, particularly for commuting and waste, are moderate due to
reliance on proxies and indirect data. Emission from fugitive cases is included
in our Scope 1 from 2024. The change in method of how emissions from Scope 1
are calculated from 2023 to 2024 is explained by the inclusion of fugitive gases
alone. Scope 3 was only partly covered in the figures for 2023 and represents
the most significant change. An error related to the attribution of GHG emission
per subsidiary was detected in figures reported in 2023. When finalising design
on tables showcasing emissions from the different subsidiaries, a formatting
error occurred, resulting in incorrect emissions associated with the different
subsidiaries. However, all figures reported represented accurate figures, and as
such the error did not influence the overall disclosures of total emissions.
There have been no significant changes to the definition of Komplett Group’s
reporting legal entities or our value chain that affect the year-to-year
comparability of reported GHG emissions. Our climate report is based on both
the financial control and operational control approaches in accordance with
the ESRS. According to the ESRS, we apply the financial control approach,
which means we include both the parent company and any subsidiaries
consolidated in the accounting group. Financial assets not consolidated into
the group are included when the group has operational control. For Komplett
Group, this means that all buildings, vehicles, and equipment used in daily
operations are included in Scope 1 and 2, even if they are not necessarily owned
by the group. The group does not own any assets that it does not fully control.
We calculate our GHG emissions in accordance with the GHG Protocol
Corporate Standard and ESRS E1. The methodologies used include activity-
based and spend-based approaches, depending on the precision and
availability of data. Our emissions factors are sourced from suppliers, external
parties, and Life Cycle Analyses (LCAs), with all greenhouse gases translated
into CO
2
equivalents (CO
2
e) using the IPCC’s AR6 global warming potential (GWP)
method. High-quality, activity-based data is prioritised for Scope 1 emissions,
such as fuel consumption and refrigerant leaks.
The emission factors used for calculating Scope 1 emissions are retrieved from
DEFRA (2024). Scope 2 emissions are calculated using both the location-based
and market-based methods.
We use emission factors from the Association of Issuing Bodies (AIB), as this
is the standard emission factor in our GHG reporting platform Position Green.
This in contrast from our 2023 report where we used emission factors for what
our former carbon accounting partner called Nordic mix. AIB does not account
for any import or export of electricity between countries when calculating
emission factors. Norway has only renewable energy production, hence the
location-based emission factor is zero. This explains most of the reduction in
location-based emissions from 2023 to 2024.
Scope 3 emissions are estimated using financial and sales data, combined with
external averages and industry standards. For categories like commuting and
waste, we rely on geospatial analysis and external statistics to ensure reasonable
estimates where direct data is unavailable. Emission factors used to calculate
Scope 3 emissions are further described i the table "Scope 3 categories".
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The list of climate impact of Komplett Group within Scope 3 comes from the
following inventory categories, as defined by the GHG protocol:
X Category 1 - Purchased goods and services
X Category 2 - Capital goods
X Category 3 - Fuel and energy distribution
X Category 4 - Upstream transport
X Category 5 – Waste
X Category 6 - Business travel
X Category 7 - Employee travel
X Category 11 - Use of sold products
X Category 12 - End-of-life treatment
We exclude certain Scope 3 categories due to their minimal impact or
irrelevance to our business model. Upstream leased assets, downstream leased
assets, processing of sold products, franchises, and investments are deemed
non-relevant. Short-term leased warehouses and emissions from shared retail
spaces are excluded due to their insignificance. These exclusions may be
reassessed as data availability and GHG emissions accounting improve.
Between the reporting dates of entities in our value chain and the finalisation of
this sustainability statement, no significant events or changes in circumstances
that materially impact the disclosed GHG emissions have been identified.
Changes in reporting practices, such as adjustments in waste data estimation
methods or refinements of transportation emissions calculations, do not
significantly alter the comparability or reliability of reported emissions. Where
necessary, we disclose template-based estimates or assumptions, such as
for mall-based stores’ waste data or commuting distances, and adjust these
estimates based on sales data or operational activity to ensure consistent and
accurate reporting.
We are continuously dedicating resources to improve the quality of our GHG
accounts. In 2024, we have improved the quality of our Scope 3 reporting, and
we are proud to disclose more comprehensive and accurate GHG emissions
accounting for the reporting year. This means however, that emission data
reported in prior statements, in particular for Scope 3, have been less accurate
and does not make for good comparison of our emissions year on year.
Furthermore, this improved accuracy prompts us to recalculate our historic
data and baseline year of 2022.
Changes and corrections of prior reporting periods
Standard Datapoint (metric) ESRS ref Description Accuracy
E1-6 Total GHG emissons §44 Changes in our boundaries from 2023 to 2024:
Scope 1 and 2:
X No changes in boundaries.
Scope 3:
X In 2024 we include category 2, 7, 11 and 12. None of them was included in our carbon accounting for 2023.
X Category 1 now includes emission from production of goods for sales.
X Category 3 is reported as earlier, but now covers emissions from a broader set of categories.
X Category 4 for 2024 this also includes transport of inbound goods for all products (not Private Label only), and transport within Komplett Group.
X Category 5 is as reported for 2023.
X Category 6 is as reported for 2023.
Moderate
E1-6 Total GHG emissons §44 We have identified an error in the prior reporting period. The average emission factor for waste is significantly lower for 2024. Last reporting period
accounted emissions from the incineration process in emissions from household waste and plastics in waste-to-energy incineration. For the cur-
rent reporting period we have followed best practices and reporting standards – which excludes emission from the incineration process (as this is
included in emissions from distant heating.
Moderate
>> For more information about uncertainty related to KPI’s due to assumptions, in addition to other changes, correction and errors from prior reporting periods, see ESRS 2 BP-2.
| IN 2024, WE HAVE
IMPROVED THE QUALITY
OF OUR SCOPE 3
REPORTING
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Data origin per Scope
tCO
2
e Per cent
Primary Secondary Primary Secondary
Scope 1 38 43 46.6% 53.4%
Scope 2 673 2 407 21.9% 78.1%
Scope 3 285 412 803 0.1% 99.9%
Total 996 415 253 0.2% 99.8%
The amount and share of of primary and secondary data used to calculate emissions per scope.
GHG EMISSIONS
(tCO
2
eq)
81
3 080
413 000
Scope 1 Scope 2 Scope 3
Direct emissions
from our owned
or controlled
sources
Indirect emissions
from the generation
of purchased
energy (market-based)
All other indirect
emissions that
occur in our
value chain
Direct emissions (Scope 1)
Komplett Group’s Scope 1 emissions stem from the fuel combustion
from leased vehicles and refrigerants. Komplett Group has no stationary
combustion.
Indirect emissions from electricity (Scope 2)
Komplett Group’s Scope 2 includes emissions from purchased electricity,
heating and cooling in offices, warehouses, and stores. Energy from electricity
and heating at our owned and leased locations accounts for the majority of
our total energy consumption and Scope 2 emissions. Some of our purchased
energy comes with contractual obligations related to attribute certificates, but
this does not comprise all purchased energy for all business units.
Indirect emissions (Scope 3)
Komplett Group’s Scope 3 emissions come from purchased goods and services,
capital goods, and fuel and energy distribution. Emissions also arise from
upstream and downstream transport, waste generation, business travel,
and employee travel. Additionally, the use and end-of-life treatment of sold
products contribute to our overall environmental impact.
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Komplett Group GHG accounts 2024
Retrospective Milestones and target years
1)
Base year
(2022)
Base year
(2024)
Comparative
(2023) 2024 % 2024/2023 2025 2030 2040 Target
Scope 1 GHG emissions
Gross Scope 1 GHG emissions (tCO
2
eq) 102 81 84 81 (4%) - - - -
Percentage of Scope 1 GHG emissions from regulated emission trading schemes (%) 0% 0% 0% 0% - - - - -
Scope 2 GHG emissions
Gross location-based Scope 2 GHG emissions (tCO
2
eq) 623 305 648 305 (53%) - - - -
Gross market-based Scope 2 GHG emissions (tCO
2
eq) 2 206 3 080 2 627 3 080 17% - - - -
Significant Scope 3 GHG emissions
Total Gross indirect (Scope 3) GHG emissions (tCO
2
eq) - 413 088 5 711 413 088 7133% - - - -
1) Purchased goods and services - 313 363 1 519 313 363 20530% - - - -
2) Capital goods - 5 543 - 5 543
3) Fuel and energy-related Activities (not included in Scope 1 or Scope 2) - 177 243 177 (27%) - - - -
4) Upstream transportation and distribution - 67 953 3 569 67 953 1 804% - - - -
5) Waste generated in operations - 9 228 9 (96%) - - - -
6) Business traveling - 387 153 387 154% - - - -
7) Employee commuting - 1 894 - 1 894 - - - - -
11) Use of sold products - 23 590 - 23 590 - - - - -
12) End-of-life treatment of sold products - 171 - 171 - - - - -
Total GHG emissions
Total GHG emissions (location-based) (tCO
2
eq) - 413 473 6 443 413 473 6 317% - - - -
Total GHG emissions (market-based) (tCO
2
eq) - 416 248 8421 416 248 4 843% - - - -
Total GHG emissions disaggregated by Scopes 1 and 2 and significant Scope 3.
1) Komplett Group does not disclose climate figures related to milestones and target years as we have not yet adopted a transition plan and are in the early stages of our full GHG accounts.
For the past two years, we have operated with 2022 as the baseline year for our
emissions reporting, but due to significant improvements in our GHG accounts,
we are in the process of recalculating. Due to this, we will maintain our baseline
figures for Scope 1 and 2 from 2022, but use the 2024 figures as new baseline
year for Scope 3 emissions. Furthermore, this means that we will also need to
disaggregate our milestone emission figures related to our reduction. For this
year’s reporting we have opted not to disclose milestone figures as they will be
subject to change.
As for the reporting period, Komplett Group does not apply any internal
carbon pricing schemes.
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Contractual instruments for Scope 2
2024
Covered by contractual
instruments (MWh)
Share
bundled (%)
Share
unbundled (%)
Share of electricity covered
by contractual instruments
Komplett Group 5 753 100% 0 47.7%
To reduce our market-based emissions Komplett Group buys Guarantees of
Origin (GOs) which represents 100 per cent of our contractual instruments
related to Scope 2 GHG emission. The GOs are bundled together with the
purchase of energy for our shops and offices in NetOnNet, where we
control the choice of electricity provider. We have no other contractual
instruments for carbon removal or energy attribute certificates.
GHG intensity per net revenue
(tCO
2
eq/Monetary unit) Comparative (2023) 2024 % 2024 / 2023
Total GHG emissions (location-based) per net revenue 0.00000042 0.00002724 6 317%
Total GHG emissions (market-based) per net revenue 0.00000055 0.00002745 4 847%
>> For more information about net revenue figures used to calculate GHG
intensity, see E1-5
Biogenic emissions of CO
2
from the combustion or bio-degradation of
biomass not included in Scope 1 GHG emissions is six tonnes CO
2
eq. We
have not identified biogenic emissions for Scope 2 or Scope 3.
>> For additional information related to our GHG emissions, see Komplett Group's
climate report
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Scope 3 categories
Coverage Methodology Assumptions Emission Factors Tools/ references Boundaries
Scope 3
Cat 1.
Purchased
goods and
services
Included in GHG inventory Spend-based Our purchased goods for sale are divided into ten
categories of similar products, and we assume that
using average emission factors related to these ten
categories provide a reasonable representation of
the emissions associated with these goods. The
same applies to purchased goods and services for
internal use.
Emission factors are based on
cradle-to-grate emission from
the relevant industry (Exiobase
3.9 2019).
Position Green, own
calculations to
subtract the freight
cost from product
revenue.
All upstream (cradle-to-gate) emissions of
purchased goods and services.
Cat 2.
Capital goods
Included in GHG Inventory Spend-based We assume that using average emission factors
for our five categories of purchased capital goods
provides a reasonable calculation of the emissions
associated with these goods.
Emission factors are based on
cradle-to-grate emission from
the relevant industry (Exiobase
3.9 2019).
Position Green All upstream (cradle-to-gate) emissions of
purchased capital goods.
Cat 3.
Fuel and energy
distribution
Included in GHG inventory Activity-based We assume that using average emission factors
for fuel and energy production and distribution in
Scope 1 and Scope 2 gives reasonable estimations
connected to fuel and energy distribution.
Emission factors are based
on industry averages and
calculated automatically by our
sustainability reporting tool (IEA
2024).
Position Green For upstream emissions of purchased fuels:
All upstream (cradle-to-gate) emissions
of purchased fuels (from raw material
extraction up to the point of, but excluding
combustion). For upstream emissions
of purchased electricity: All upstream
(cradle-to-gate) emissions of purchased
fuels (from raw material extraction up to
the point of, but excluding, combustion by
a power generator). For transmission and
distribution losses: All upstream (cradle-
to-gate) emissions of energy consumed
in a transmission and distribution system,
including emissions from combustion.
Cat 4.
Upstream
transport and
distribution
Included in GHG inventory Transport and distribution
of goods and services within
Scandinavia is precalculated by
transport suppliers, transport
and distribution of goods from
our product suppliers is spend-
based.
We assume that transport cost can be represented
by a percentage of product revenue, and that
this is comparable to our private label products
(approximately four per cent of revenue).
Furthermore, we have assumed that average
emission factors for transport is reasonable in this
context.
Emission factors are based on
cradle-to-grate emission from
the transport industry (Exiobase
3.9 2019).
Position Green,
own calculations
to estimate freight
costs.
The Scope 1 and Scope 2 emissions of
transportation and distribution providers
that occur during use of vehicles and
facilities.
Overview of Scope 3 categories along with methodologies, significant assumptions, emission factors used to calculate or measure GHG emissions.
Boundaries considered for estimated emissions are also included, as well as disclosure of why some categories have been excluded.
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Coverage Methodology Assumptions Emission Factors Tools/ references Boundaries
Scope 3
Cat 5.
Waste
Included in GHG inventory Activity-based We assume that using average emission factors
for each type of waste treatment method provide a
fair representation of emissions from this category.
Furthermore, for a small share of our shops
and offices, we have made assumptions about
allocation of waste treatment method based on
square meters or sales revenue.
Emission factors is an industry
average that include S cope 1
and Scope 2 emissions from
each waste treatment method
(DEFRA 2024).
Position Green,
own calculations
to estimate waste
figures where
data is missing or
where waste data is
reported aggregated
(shopping malls
or shared office
spaces).
The Scope 1 and Scope 2 emissions of waste
management suppliers that occur during
disposal or treatment.
Cat 6.
Business travel
Included in GHG inventory Primarly activity-based and
pre-calculated by travel agency,
spend-based for local travels,
bus and taxi.
The majority of travels are covered by the travel
agency. For other transport costs, we assume that
using average emission factors for different travel
modes, combined with spend data, provides a
reasonable estimate of emissions.
Emission factors are based
on supplier-specific data and
industry averages for modes
of transport (DEFRA 2024 /
Exiobase 3.9 2019).
Position Green The Scope 1 and Scope 2 emissions of
transportation carriers that occur during
use of vehicles.
Cat 7.
Employee travel
Included in GHG inventory Activity-based We have made assumptions on average travel
distances using geospatial analysis, modes of
transport, and frequency of commuting (each
working day). Allocation to each travel mode is
based on nation travel statistics.
Emission factors are based on
industry averages for modes
of transport (NTM 2018, DEFRA
2024, NTMCalc.Advanced 4.0).
Position Green The Scope 1 and Scope 2 emissions of
employees and transportation providers
that occur during use of vehicles.
Cat 8.
Upstream leased
assets
Excluded from GHG
Inventory, as the impacts
are deemed immaterial,
occurrence of emission is
irregular, data on fugitive
gases is insufficient.
N/A N/A N/A N/A N/A
Cat 9.
Downstream
transport and
distribution
Excluded from GHG
Inventory, as transport and
distribution before final
sale is covered in category
1, high uncertainty on post-
delivery emissions.
N/A N/A N/A N/A N/A
Scope 3 categories (continued)
Overview of Scope 3 categories along with methodologies, significant assumptions, emission factors used to calculate or measure GHG emissions.
Boundaries considered for estimated emissions are also included, as well as disclosure of why some categories have been excluded.
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Coverage Methodology Assumptions Emission Factors Tools/ references Boundaries
Scope 3
Cat 10.
Processing of
sold products
Excluded from GHG
Inventory, as it is deemed
non-relevant (parts and
components covered under
category 1).
N/A N/A N/A N/A N/A
Cat 11.
Use of sold
products
Included in GHG Inventory Activity-based We have made assumptions on average
usage patterns, product lifetimes, and energy
consumption for our ten different product
categories, based on industry documentation and
research papers. Within the ten product categories,
we have made assumptions on which products are
most representative for the entire product category.
Emission factors includes
emissions from electricity usage,
using location based emission
factor (AIB 2024).
Position Green, own
calculations to
estimate product
lifetime and energy
consumption.
The direct use-phase emissions of sold
products over their expected lifetime.
Cat 12.
End-of-life
treatment of
sold products
Included in GHG Inventory Activity-based Our assumptions regarding the distribution of
packaging waste across different waste treatment
categories are based on data from our waste
management supplier. Additionally, we have
estimated the proportions of electronic versus non-
electronic waste for our sold products and we have
assumed that all our sold products are treated as
EE-waste.
Emission factors are average
factors for waste treatment
methods (DEFRA 2024).
Position Green, own
calculations (based
on data from Norsirk)
to estimate the split
of waste categories
into paper and
cardboard, plastics
and residual waste.
The Scope 1 and Scope 2 emissions of waste
management companies that occur during
disposal or treatment of sold products.
Cat 13.
Downstream
leased assets
Excluded from GHG
Inventory, as it's expected
to be a minor part of our
emissions.
N/A N/A N/A N/A N/A
Cat 14.
Franchises
Excluded from GHG
Inventory, as franchises are
not relevant for Komplett
Group’s business model.
N/A N/A N/A N/A N/A
Cat 15.
Investments
Excluded from GHG
Inventory, as investments
are not relevant for
Komplett Group’s business
model.
N/A N/A N/A N/A N/A
Overview of Scope 3 categories along with methodologies, significant assumptions, emission factors used to calculate or measure GHG emissions.
Boundaries considered for estimated emissions are also included, as well as disclosure of why some categories have been excluded.
Scope 3 categories (continued)
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EU TAXONOMY
In 2024, Komplett Group has conducted a comprehensive assessment to
report in line with the EU Taxonomy disclosure requirements, including
mapping of relevant financial data, mapping of relevant eligible activities
according to the Climate and Environmental Delegated Acts, and assessing
the group’s economic activities in alignment with the EU Taxonomy. The
process has been managed at group level, with data collection and activity
screening processes carried out in collaboration with all subsidiaries.
BACKGROUND
The EU Taxonomy is a classification system for environmentally sustainable
activities. It is a key component of the European Commission’s action plan to
reorient capital flows towards economic activities that are deemed sustainable.
By reallocating capital and direct investments towards sustainable projects and
activities, EU aims to take a step closer to reach the objectives of the European
Green Deal. To achieve this, it was necessary to clearly define what constitutes a
sustainable activity, leading to the creation of the EU Taxonomy.
ECONOMIC SUSTAINABLE ACTIVITIES
In the EU Taxonomy, a sustainable economic activity is an economic activity
providing a substantial contribution to one of six environmental objectives,
defined by the EU Commission:
1. Climate change mitigation
2. Climate change adaptation
3. Sustainable use and protection of water and marine resources
4. Transition to a circular economy
5. Pollution prevention and control
6. Protection and restoration of biodiversity and ecosystems
To qualify as a sustainable economic activity, the activity need to substantially
contribute to one of the objectives above, and at the same time, the activity
must not significantly harm any of the other environmental objectives. It must
also meet minimum social and governance safeguards.
DISCLOSURE REQUIREMENTS
Organisations, here both companies under the scope of the Corporate
Sustainability Reporting Directive (CSRD) and financial market participants
that offers financial products, are required to report on their alignment with
the EU Taxonomy Regulation, by reporting on the following:
Taxonomy-eligibility: Share of economic activities described in the Delegated
Acts supplementing the EU Taxonomy Regulation. Conversely, a non-eligible
activity refers to any economic activity not yet described in the Delegated Acts
supplementing the Taxonomy Regulation.
Taxonomy-alignment: Share of eligible activities meeting the technical
screening criteria set out in the Delegated Acts for that activity, in addition to
minimum safeguards. This invites organisations to do a screening process, in
which an eligible activity is assessed in terms of its:
X “substantial contribution” to one of the six environmental objectives
X “do no significant harm” to the other five environmental objectives
X compliance with “minimum safeguards”
Minimum safeguards
Komplett Group ensures compliance with minimum safeguards through
structured due diligence processes aligned with the OECD Guidelines. These
processes cover labour rights for both employees and workers throughout
the value chain. Measures addressing bribery, corruption, and decent working
conditions are embedded in the company’s compliance framework and
reinforced through our code of conduct, which applies to all employees.
In 2024, we identified no instances of non-compliance with minimum
safeguards, or legal accountability for violations in these areas. For more
information on our approach to responsible business practices, see the
sections; own workforce, workers in the value chain and business conduct, in
the sustainability statement.
>> For more information on our policies and how we govern social safeguards,
see ESRS2 MDR-P, S1-1, S2-1, and G1-1
Methods for defining and calculating EU Taxonomy KPIs
Taxonomy-eligibility and -alignment performance are reported on three key
performance indicators: turnover, capital expenditure (CapEx) and operational
expenditure (OpEx), for each economic activity classified as eligible and
aligned. The group’s interpretations of the Taxonomy’s three KPI definitions
are based on guidance from the delegated acts. These interpretations may be
revised as EU Taxonomy guidelines evolve and reporting practices develop.
The group defines the three KPIs as follows (see table):
Turnover CapEx OpEx
Total turnover is defined as external revenue in accordance with the Interna-
tional Financial Reporting Standards (IFRS), which correspons to total operating
income in the consolidated income statement in the group's financial state-
ment. Please see note 6 in the consolidated income statement. The revenue KPI
is defined as Taxonomy-eligible turnover (numerator) divided by total turnover
(denominator).
The total operating income for Komplett Group was NOK 15.3 billion in financial
year 2024 (denominator).
Total CapEx is defined as capital expenditures is defined in IFRS. This KPI includes addi-
tions to tangible and intangible assets before amortisation and depreciation, including
impairments, and excluding goodwill and fair value changes. Please see note 11, 12 and 19
for reference. The CapEx KPI is defined as Taxonomy-eligible CapEx (numerator) divided by
total CapEx (denominator).
For Komplett Group, the total CapEx in accordance with the EU Taxonomy definition was
NOK 277 million in financial year 2024 (denominator).
Total OpEx refers to operating expenses not recognised as assets, but include cost of employees
executing repairs of products, short-term lease expenses, and day-to-day maintenance, cleaning,
and repair costs (including building renovation measures). The OpEx KPI is defined as Taxnomy-el-
igible OpEx (numerator) divided by total OpEx (denominator). As EU Taxonomy OpEx has a different
definition than IFRS, the OpEx used cannot be directly derived from the Financial Statments.
For Komplett Group, the total OpEx in accordance with the EU Taxonomy definition was NOK 42 mil-
lion in financial year 2024 (denominator).
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SCOPE
Komplett Group falls under the scope of the EU Taxonomy regulation, as the
regulation applies to large public entities under the scope of the CSRD with
more than 500 employees.
This report covers the period from 1 January 2024 to 31 December 2024
and evaluates all six environmental objectives outlined in the EU Taxonomy.
Komplett Group has assessed all its economic activities that has the potential
to substantial contribute to one of the five environmental targets, and, if so,
the relevant environmental screening criteria set forth in the Environmental
Delegated Act.
ASSESSMENT OF ACTIVITIES FOR 2024
Komplett Group operates in the retail and e-commerce sector, where few of
its primary economic activities are included in the EU Taxonomy at reporting
date. Therefore, most of the group’s economic activities are defined non-
eligible, meaning that these are not described in the delegated acts at the time
of reporting.
The Taxonomy eligible economic activities have been identified by screening
the activities in the Climate Delegated Act (Commission Delegated Regulation
(EU) 2021/2139), the Complimentary Climate Delegated Act (Commission
Delegated Regulation (EU) 2022/1214), the Environmental Delegated Act
((Commission Delegated Regulation (EU) 2023/2486), and the amendments to
the Climate Delegated Act (Commission Delegated Regulation (EU) 2023/2485).
To determine whether the eligible economic activities qualify as
environmentally sustainable (Taxonomy-aligned), the activities have been
assessed by screening against the criteria outlined in Regulation (EU)
2020/852, article 3. Additionally, the Taxonomy-alignment of these eligible
activities has been evaluated according to Annex II of the Environmental
Delegated Act, with the examination of technical screening criteria for
environmental objectives undertaken for each activity, and the assessment of
minimum safeguards conducted at the group level.
Taxonomy-eligible and -aligned activities
The table below outlines the share of Komplett Group’s turnover, CapEx and
OpEx attributed to economic activities identified as Taxonomy-eligible, and
Taxonomy-aligned.
Turnover: The primary source of turnover contributing to the numerator of
the turnover KPI in 2024 is sales of second-hand products within the product
categories Computing and Telecom, more specifically NetOnNet's resale of second-
hand products sold through its marketplace called "used" (Swedish: Begagnade").
The taxonomy-aligned turnover for 2024 remains at same level as 2023.
CapEx:There were no sources of CapEx contributing to the numerator of
the CapEx KPI in 2024, as the two identified activities did not involved any
investments or other types of additions to tangible or intangible assets.The
taxonomy-aligned CapEx for 2024 remains at same level as 2023.
FY 2024
Total
(NOK million)
Share of Taxonomy-eligible
economic activities
Share of Taxonomy-aligned
activities
Share of non-eligible
economic activities
Turnover 15 301 0.1% 0 .1% 99.8%
Capital expenditure (CapEx) 277 0% 0% 100%
Operating expenditure (OpEx) 42 16% 16% 84%
OpEx:The sources of OpEx contributing to the numerator of the OpEx KPI in
2024 stem from the cost of FTE's for the operating personnel executing repairs
of certain products from Komplett Services and NetOnNet, with no allocation
of fixed cost or other operating expenses related to repairs. The taxonomy-
aligned OpEx for 2024 remains at same level as 2023.
Double counting: For the calculation of the denominator of the turnover, CapEx
and OpEx KPIs, we have extracted the figures directly from our internal system,
ensuring that the figures are only counted once in each KPI. To avoid double
counting, the group has set up a control function to assure all financial data
associated with each activity.
IDENTIFYING ELIGIBLE AND ALIGNED ACTIVITIES
Potential to contribute to the environmental objective: Circular Economy
Komplett Group has identified two Taxonomy-eligible activities, all with the
potential to contribute to the environmental objective “Transition to a circular
economy.”
The technical screening criteria for Taxonomy-alignment for these activities
was adopted into Norwegian law in the early stages of 2024, and Komplett
Group has screened all relevant activities against the outlined criteria in the
Commission Delegated Regulation (EU) 2023/2486.
5.1 Repair, refurbishment, and remanufacturing
Assessment of eligibility: Repairment of products in-house is an eligible activity
according to our assesment of the definition presented in the EU Taxonomy. The
economic activities relate to Komplett Group’s repair of products that can be
classified under the NACE code C26 Manufacture of computer, electronic and
optical products, and C27 Manufacture of electrical equipment.
Komplett Services and NetOnNet carries out repairs in certain cases,
typically when a customer makes a warranty claim or files a complaint about
a product, while Webhallen has limited in-house repair capabilities. The
repair activities performed by Komplett Services, NetOnNet and Webhallen
are conducted independently. The subsidiaries do not perform repair
activities for each other, eliminating the risk of double counting the relevant
financial KPI. Komplett Services repairment activities are connected to
a broad range of product categories, while both Komplett Services and
Webhallen repair PCs. However, the magnitude of PC repairs in Webhallen
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is significantly lower than in Komplett Services. Repairs on PCs not sold by
Komplett Group represents a small revenue stream, as repairs are invoiced
to end-consumers. NetOnNet primarily conducts its repairs on private
label products, especially within the TV and electric vehicles categories.
However, repairs of electric vehicles are not included in the definition of the
eligible activity. Hence, this is excluded from Komplett Group’s reporting on
eligibility on this activity.
Substantial contribution: To make a substantial contribution to the
environmental objective transition to a circular economy, Komplett Group’s
repaired products must be conducted with the intention to extend the lifetime
of the products. The replaced or broken parts in the repaired products must
also either be reused, recycled, or disposed in accordance with applicable
EU and national legislations. In addition, replacing, reusing, or disposing of
spare parts must follow a waste management plan that ensures materials and
components not used in the same product are either repurposed elsewhere,
recycled when reuse is not possible, or disposed of in compliance with EU
regulations if neither reuse nor recycling is feasible.
The group has assessed and documented compliance with these requirements.
Thus, the group's eligible repair activities meet the technical criteria for
substantial contribution.
Do no significant harm (DNSH):
Komplett Group has assessed and documented compliance with the DNSH
criteria outlined in Annex 2 of the Environmental Delegated Act for the eligible
repair activity.
The activity meet the DNSH criteria for climate change mitigation, as it comply
with the limits for GHG emissions and heat and cooling generation. For climate
change adaptation, the screening was based on the climate risk assessment
conducted at the group level across all business units. Regarding water and
marine resources, the eligible repair activity do not involve or impact water and
are therefore assessed as within the required limits. For pollution prevention,
the activity fully comply with the DNSH criteria, as it do not generate any
hazardous or pollutive waste listed in the relevant appendix. Further, no
hazardous substances are used in the repair process.
5.4 Sale of second-hand goods
Assessment of eligiblity: Komplett Group’s resale of second-hand products is
an eligible activity. This encompasses Komplett Group’s sales of second-hand
products previously used for their intended purpose before by customers, and
that can be classified under the NACE codes C26 and C27.
This includes NetOnNet’s resale of second-hand products, sourced from
an external partner and sold as used products, marked as “used” (Swedish:
“begagnade”), through its sales channels. In addition, the eligible activity covers
NetOnNet’s sale of products received from the trade-in program, known as “Byt
in”, which is sold to an external partner for resale to end-customers. Webhallen
has a similar trade-in program, but as the customers sells this directly to the
external partner these transactions are not considered eligible.
Both NetOnNet and Webhallen sell products in the “Bargain” category (Swedish:
“Fyndvaror”), sold at reduced prices due to repairs, minor defects, being opened,
or damaged packaging. Similarly, Komplett Services, sells products in the
“Demonstration” category (Norwegian: “Demovarer”), including demo products,
returned products and repaired products resold to end-consumers. However,
due to uncertainty regarding whether these products meet the definition in the
Taxonomy for second-hand, these activities are considered non-eligible.
Substantial contribution to circular economy: The eligible activities within
NetonNet, the sale of products in the “used” category (“begagnade”), and the
trade-in program “Byt in”, have been screened against the technical criteria to
make a substantial contribution to the environmental objective: Transition to a
circular economy. The activity “begagnade” is complying with strict packaging
material requirements, confirmed by the FSC certificate, and thus aligns with
the technical criteria set for substantial contribution for this activity. However,
for “Byt-in”, the activity do not meet the packaging criteria, set in the screening
criteria for substantial contribution to circular economy. The packaging activity
is executed at several locations in NetOnNet, where the packaging material does
not meet the requirement of being made from at least 65 per cent recyclable
material.
Do no significant harm (DNSH):
The sale of second-hand goods meets the DNSH criteria for climate change
mitigation, as the activity complies with limits on heat and cooling generation,
as well as the requirements of the 2009/125/EC Directive. Komplett Group has
a strategy in place to account for GHG emissions and to provide fossil fuel-free
delivery where possible. For climate change adaptation, the activity is included
in Komplett Group's climate resilience analysis and risk assessment, and hence
meet the relevant DNSH criteria.
The activity also meets the DNSH criteria for water and pollution, as it complies
with emission permits and does not generate any harmful substances listed in
the Appendix.
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APPENDIX: KPI TABLES
The key performance indicators (KPIs) include turnover, CapEx, and OpEx.
The KPIs are presented using the templates in Annex II to the Disclosure
Delegated Act.
Turnover – KPI table:
Substantial contribution criteria DNSH criteria (‘does not significantly harm’)
Economic
activities
Code
Turnover
Proportion of
turnover
Climate change
mitigation
Climate change
adaptation
Water
Pollution
Circular economy
Biodiversity
Climate Change
mitigation
Climate change
adaptation
Water
Pollution
Circular economy
Biodiversity
Minimum
safeguards
Taxononmy aligned
(A.1) or eligible (A.2)
proportion turnover,
year 2023
Category enabling
activity
Category
transitional
activity
MNOK % Y; N;N/EL Y/N % E T
A. TAXONOMY-ELIGIBLE ACTIVITIES
A.1. Environmentally sustainable activities (taxonomy-aligned)
Sale of second-hand goods CE 5.4 19 0.1% N/EL N/EL N/EL N/EL Y N/EL Y Y Y Y - N/A Y 0.1%
Turnover of environmentally sustainable activities
(taxonomy-aligned) (A.1)
19 0.1% 0% 0% 0% 0% 0.1% 0% 0.1%
Of which enabling 0 0.0% 0% 0% 0% 0% 0% 0% 0%
Of which transitional 0 0.0% 0% 0%
A.2 Taxonomy-eligible but not environmentally sustainable activities (not taxonomy-aligned activities)
EL; N/EL
Sale of second-hand goods
CE 5.4 17 0.1%
N/EL N/EL N/EL N/EL EL N/EL 0.1%
Turnover of taxonomy-eligible but not
environmentally sustainable activities (not
taxonomy-aligned activities) (A.2)
17 0.1%
0% 0% 0% 0% 0.1% 0% 0.1%
A. Turnover of taxonomy eligible activities (A.1+A.2)
36 0.2%
0% 0% 0% 0% 0.2% 0% 0.2%
B. TAXONOMY-NON-ELIGIBLE ACTIVITIES
Turnover of taxonomy non-eligible activities 15 266 99.8%
TOTAL 15 301 100.0%
Y
Yes (taxonomy-eligible and taxono-
my-aligned activity with the relevant
environmental objective)
N
No (taxonomy-eligible but not taxon-
omy-aligned activity with the relevant
environmental objective)
N/EL
Not eligible (taxonomy-non-eligible
activity for the relevant environmen-
tal objective)
EL
Eligible (taxonomy-eligible activity for
the relevant environmental objective)
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CapEx – KPI table:
Substantial contribution criteria DNSH criteria (‘does not significantly harm’)
Economic
activities
Code
CapEx
Proportion of
CapEx
Climate change
mitigation
Climate change
adaptation
Water
Pollution
Circular economy
Biodiversity
Climate change
mitigation
Climate change
Adaptation
Water
Pollution
Circular economy
Biodiversity
Minimum
safeguards
Taxonomy aligned (A.1)
or eligible (A.2)
proportion
CapEx, year 2023
Category enabling
activity
Category transitional
activity
MNOK % Y; N;N/EL Y/N
%
E T
A. TAXONOMY-ELIGIBLE ACTIVITIES
A.1. Environmentally sustainable activities (taxonomy-aligned)
-
CapEx of environmentally sustainable
activities (taxonomy-aligned) (A.1)
0 0% 0% 0% 0% 0% 0% 0%
0%
Of which enabling 0 0%
0%
Of which transitional 0 0%
0%
A.2 Taxonomy-Eligible but not environmentally sustainable activities (not taxonomy-aligned activities)
EL; N/EL
None 0 0.0% N/EL N/EL N/EL N/EL 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%
A. 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 277 100%
TOTAL 277 100%
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OpEx – KPI table:
Substantial contribution criteria DNSH criteria (‘does not significantly harm’)
Economic
activities
Code
OpEx
Proportion of
OpEx
Climate change
mitigation
Climate change
adaptation
Water
Pollution
Circular economy
Biodiversity
Climate change
mitigation
Climate change
adaptation
Water
Pollution
Circular economy
Biodiversity
Minimum
safeguards
Taxonomy aligned (A.1)
or eligible (A.2)
proportion
Opex, year 2023
Category enabling
activity
Category transitional
activity
MNOK % Y; N;N/EL Y/N
%
E T
A. TAXONOMY-ELIGIBLE ACTIVITIES
A.1. Environmentally sustainable activities (taxonomy-aligned)
Repair, refurbishment, and
remanufacturing
CE 5.1 7 16% N/EL N/EL N/EL N/EL Y N/EL Y Y Y Y - N/A Y
20%
OpEx of environmentally sustainable
activities (Taxonomy-aligned) (A.1)
7 16% 0% 0% 0% 0% 21% 0%
20%
Of which enabling -
N/A
Of which transitional -
N/A
A.2 Taxonomy-Eligible but not environmentally sustainable activities (not taxonomy-aligned activities)
EL; N/EL
None N/EL N/EL N/EL N/EL EL N/EL
OpEx of taxonomy-eligible but not
environmentally sustainable activities
(not taxonomy-aligned activities) (A.2)
0 0% 0% 0% 0% 0% 0% 0%
0%
A. OpEx of taxonomy eligible activities
(A.1+A.2)
7 16% 0% 0% 0% 0% 20% 0%
20%
B. TAXONOMY-NON-ELIGIBLE ACTIVITIES
OpEx of taxonomy non-eligible activities 35 84%
TOTAL 42 100%
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Nuclear and fossil gas related activities:
Row Nuclear energy related activities Yes/No
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
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
The table above shows whether Komplett Group is involved in nuclear or fossil gas-related activities,
which must be disclosed under the EU Taxonomy.
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POLLUTION
Pollution to soil from raw material producers is a key issue within our
upstream supply chain. This environmental challenge has the potential to
significantly impact ecosystems, and it is therefore identified as a material
topic for Komplett Group to address as part of our broader sustainability
efforts.
Material ESRS topics Material ESRS sub-topics Part of the value chain where impact was material Impact materiality Financial materiality
E2: Pollution E2: Pollution to soil Upstream Own operations Downstream High Low
Pollution of soil: Being a technology provider, Komplett Group acknowledges
the presence of metals such as cobalt, copper, nickel, and manganese in
electronics and lithium batteries in several of our products. These metals have
substantial impacts on topsoil around mining and smelting sites and release
significant amounts of heavy material into the environment. The identification
of potential pollution-related impacts in the upstream part of our value
chain is based on assumptions and information collected from international
newsletters and publications on lithium batteries in particular, and chemistry
and related fields in general. We have not conducted consultations with
affected communities.
POLICIES RELATED TO POLLUTION
(MDR-P, E2-1)
Our policy framework was updated in 2024 to include a newly developed
sustainability policy that addresses environmental topics on a high level,
including pollution. The policy addresses pollution to soil and in particular the
risk related to electronic products and batteries containing toxic metals such
as cobalt, nickel, lithium and manganese. Furthermore, the policy addresses
preventive measures and control.
>> For more information about our sustainability policy, see MDR-P in ESRS2
ACTIONS AND TARGETS RELATED TO POLLUTION
OF SOIL
(MDR-A §62) (MDR-T §§ 72, 81)
Recognising the need for a solid foundation before setting detailed actions
and targets, we have chosen not to report fully on them this year. Instead,
we are prioritising improvements in data quality to ensure a robust basis
for future measures. Moreover, in 2024 a new sustainability policy has been
established. However, due to the nature of this risk, we are not yet able to track
the effectiveness of policies and actions. We will continue working towards
defining our level of ambition in this area.
Furthermore, we have not established measurable outcome-oriented targets
for pollution to soil, as this issue has been assessed as material primarily
in upstream activities rather than within our own operations. Additionally,
microplastics have been evaluated as not material to our business activities.
Since pollution to soil is mainly an upstream issue, we do not currently have
specific processes to monitor the effectiveness of relevant policies and
actions beyond regular supplier follow-ups conducted by our procurement
teams. These follow-ups rely on qualitative evaluations, as no specific targets,
metrics, or baseline year have been set.
While we do not have immediate plans to establish measurable targets in
this area, we will continue to assess impacts, risks, and opportunities within
our operations and value chain. Future improvements in data quality and risk
assessment may lead to further refinements in our approach.
| SOIL POLLUTION FROM RAW MATERIAL
PRODUCERS IS A KEY ISSUE WITHIN OUR
UPSTREAM SUPPLY CHAIN
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RESOURCE USE AND CIRCULAR ECONOMY
Resource use and circularity are key priorities for Komplett Group, and
we are committed to reducing our environmental impact by extending
product lifecycles and improving material efficiency. With electronic waste
being the fastest-growing waste stream globally, we actively work to
address this challenge by facilitating e-waste collection, promoting reuse
and refurbishment, and collaborating with recycling partners to recover
valuable materials. In this section, we cover all our material topics related to
resource use and circularity, including resource inflows, outflows, and waste
management.
Material ESRS topics Material ESRS sub-topics Part of the value chain where impact was material Impact materiality Financial materiality
E5: Resource use and
circular economy
E5: Resource inflow Upstream Own operations Downstream High High
E5: Resource outflow Upstream Own operations Downstream High High
E5: Waste Upstream Own operations Downstream High High
POLICIES RELATED TO RESOURCE USE AND
CIRCULAR ECONOMY
(MDR-P §62)
Our policy framework was updated in 2024 to include a newly developed
sustainability policy that addresses environmental topics on a high level. A
more detailed policy covering environmental topics, including resource use
and circular economy is planned for 2025. This is to make sure we cover all the
relevant impacts, risks and opportunities in our policies.
>> For more details regarding our sustainability policy, see ESRS 2 MDR-P
RESOURCE INFLOWS, RESOURCE OUTFLOWS AND WASTE
(E5.IRO-1)
Circularity is one of Komplett Group’s core strategic focus areas, including the
path for developing new and circular business concepts, focusing on recycling,
durability, and reusability. A particular emphasis is put on minerals and
materials used in electronics that have significant environmental footprints.
Komplett Group uses supplier assessments, product lifecycle analysis,
factory audits and third-party certifications and dialogue to evaluate risks
and opportunities in operations and the value chain. Consultations involve
engagement with suppliers and industry partners to identify opportunities for
material reuse, product durability, and waste reduction.
For all subsidiaries, resource use and circular economy initiatives are led
by a dedicated member of the management group, who oversees programs
like trade-in schemes and sustainable packaging strategies. Materials used
includes plastics, metals, and electronics components, with increasing efforts
to incorporate recycled materials in private label products and packaging.
Continuing business as usual leads to significant risks related to increased
regulatory pressure under the European Green Deal and the Circular Economy
Action Plan. Non-compliance with recycling targets and packaging standards
for private labels could lead to financial penalties and increased operational
costs. We therefore see opportunities in adopting circular economy practices,
such as using more recyclable materials and offering low-emission products.
Transitioning to a circular economy involves upfront investments in R&D,
redesigning private label products to meet recyclability targets, and expanding
collection systems. However, a successful transition would offer financial
resilience through improved customer trust, better compliance with regulations,
and reduced lifecycle costs of products. Resource use and associated risks
are most prominent upstream in raw material extraction and packaging, where
regulations demand higher recyclability. Downstream risks relate to the
management of e-waste and product returns. All business units have been
assessed jointly, as the resource inflows, outflows and waste are similar.
>> For more details about the process of identifying IRO’s related to E5 in the
value chain, see ESRS 2 IRO-1
ACTIONS AND EFFORTS TO INCREASE CIRCULARITY IN KOMPLETT
GROUP
(MDR-A §62)
Komplett Group is continuously working to further our actions regarding
resource use and circularity.
Recognising the importance of continuing to implement measures and actions,
we have decided not to report in full, as they are defined in the ESRS, regarding
actions this year. We will focus on improving our data quality to secure the
best possible foundation for our future actions and other measures regarding
resource use and circularity.
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Despite not being able to disclose specific actions as required by the ESRS, we
are nevertheless describing some of our impacts related to circularity, such
as re-use of previously sold products, in addition to capitalising on material
financial opportunities, like increased revenue from repair services. Some of
these efforts can be found in the table below.
Efforts related to climate change mitigation and adaptation
Service Recycling and re-use of previously sold products
Trade-in
programme
NetOnNet’s trade-in programme is offered both online and in warehouses in Norway and Sweden. The service enables customers to return
used products. Upon returning a product, customers are either rewarded with a gift card or a discount on a new product. More than 13 000
products were returned in 2024. NetOnNet’s partner, Foxway, purchases NetOnNet’s used products, repairs them, and produces spare parts,
creating a second lifecycle for the devices. This approach saves energy and resources by reducing the production of new products. Most
devices are given a new life by being sold to new customers. The collected products are sorted according to their condition. Some items do
not need much attention and can simply be sent to the second lifecycle after repair, while others need to undergo a more thorough repair.
When replacing broken or worn parts, NetOnNet reuses components from unrepairable products as far as possible before using new parts.
Some items are, however, severely damaged and therefore not suitable for a second lifecycle. These items can still be recycled, and the raw
materials can be reused.
Sale of used
products
Both at Webhallen and NetOnNet, customers can buy pre-owned products such as laptops and mobile phones.
Webhallen
Revive
Webhallen continues with the trade-in programme, Revive. The service enables customers to bring their old mobile phone, iPad or MacBook
to Webhallen in exchange for a new one. When customers turn in their old product, they are either rewarded with a gift card or a discount on
a new product. The trade-in value of the product is based on criteria set by Corporate Mobile Recycling (CMR). In 2024 there were a total of 91
trades with an average value of SEK 1 772. The total product value was SEK 161 315. These products are bought by a partner company who
resells the products as second-hand products.
Outlets and
demo products
Our companies also offer bargain and outbound products for sale, in addition to items returned by customers. All products for sale in the online
outlets are of high quality but cannot be sold as A-grade goods. Our companies also offer bargain and outbound products in physical stores
and through partners.
Komplett FLEX FLEX is a service offered by Komplett Services that enables consumers to subscribe to a product, with an option after two years to either
return the used product or keep it. Customers can choose this service for more than 1 000 of Komplett Service’s products. This gives
Komplett Services better control over the product life cycle and makes it easier for the consumer to dispose their products in a sustainable
way. Komplett Services ensures that returned products are either refurbished and given a new owner or recycled in an eco-friendly manner, in
alignment with Komplett Group's goal of promoting sustainable product life cycles. Today, FLEX represents approximately 8.8 per cent of B2C
sales in Norway and Sweden.
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TRACKING EFFECTIVENESS OF POLICIES AND ACTIONS THROUGH
TARGETS
(MDR-T §§ 72, 81)
Recognising the importance of setting targets, as defined by ESRS, we have
decided not to report our actions and targets related to resource inflows,
outflows, and waste in full this year. Instead, we are improving data quality
to establish a strong foundation for future targets, as well as maintaining our
strategic circularity goal. Additionally, our new sustainability policy includes
circularity aspects.
The main reasons as to why we have not yet set specific ESRS targets for
resource inflows, outflows and waste can be summarised by these key
challenges:
X We currently lack sufficient data on material composition, sourcing, waste
generation and recovery, making it difficult to define measurable targets.
X Our complex supply chain depends on supplier practices, product design
and end-of-life treatment, limiting our direct influence on circularity in
resource inflows.
We are continuously working on enhancing our policies as we are still refining
our approach to responsible sourcing, recycled content, product durability,
and waste reduction before setting long-term commitments.
One of our strategic goals is to have 15 per cent of Komplett Group’s revenue
deriving from circular products and services by 2028. This means prolonging the
loop through circular services and enabling circular choices for our customers.
As data quality improves and industry standards evolve, we will set measurable
ESRS targets that align with our strategic goal related to circularity.
We are currently developing our goals related to increased revenue streams
from circular products and services. In 2024, we have calculated the percentage
of revenue from circular business models that support extended life or circular
use (re-use) of products to be 2.87. This revenue figure is derived from repairs
beyond warranty, sale of spare parts, sale of used products, trade-in services,
B2B leasing and our FLEX model.
To secure clear definitions and ensure a faithful representation of our circular
revenue, we ha have made some limitations that impact our calculations. Due
to this, revenue from our distribution services in Itegra is excluded from the
calculation. Furthermore, waste management (when not resold or sold as parts)
and warranty repairs are not included. Also, for the time being, we have chosen not
to report demo products and goods sold in our outlets as circular business models.
RESOURCE INFLOWS
(E5-4)
Resource inflows relate to the use of raw materials in our products, the use
of recycled materials, and the reuse of materials in production. Product
packaging and material use is also relevant in this regard.
Upstream resource inflow refers to the acquisition of resources at the
early stages of production or supply chain. This includes sourcing of raw
material, components, and the extent of use of recycled material. For our own
operations, the concept of resource inflows refers to which products Komplett
Group chooses to offer, materials used in private labels and circularity
requirements for our products.
While some electronics sold and produced may contain recycled materials,
virgin plastic is mostly preferred due to its cost-effectiveness and
predictability when it comes to product-quality. One of the goals Komplett
Group wants to achieve, is to ensure more products are made from recycled
materials. As of today, it is unfortunately difficult to say if and exactly how
much is being recycled.
Most consumer electronics provided by Komplett Group, including phones,
computers, and tablets, can be recycled when handled properly. Komplett
Group may influence resource inflow by carefully curating its product catalogue.
By prioritising products that are designed with longevity, repairability, and
recyclability in mind, we can encourage a shift toward more sustainable
consumption. In particular, we can have a positive impact on the design and
packaging of private label products, as Komplett Group may develop and
promote products that adhere to strict environmental and ethical standards.
Risks and opportunities
One of the main building blocks of the European Green Deal, is the new circular
economy action plan and we see increased regulations regarding circularity
for electronics and packaging and recycling targets. For our private labels,
increasing recycling targets in the EU would require a higher recyclability
rate of Komplett Group’s products, necessitating further investments in R&D,
design and collection. This may increase costs for Komplett Group.
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On the other hand, an increase in the use of recyclable materials and stocking
of low-emission products may result in customers opting to purchase
electronics from Komplett Group, as customer preferences are shifting.
Especially improvement in customer perception and reputation may contribute
to positive customer spending behaviour. In addition, new and improved
circularity-related services represent profit opportunities.
Packaging material use
Tonnes 2024 2023
Cardboard and paper 815 845
Single-use wood pallets 341 338
Plastics 66 54
Total 1 222 1 237
Sustainable packaging
For Komplett Group, it is essential to reduce the use of natural resources by
improving the sustainability of our packaging. A material risk we face is the
increasing regulations on circularity, recycling, and packaging materials, which
may require investments in new solutions to ensure compliance. However, this
also presents a material opportunity to enhance our packaging practices by
prioritising recycled and recaptured materials, reducing excess packaging,
and improving recyclability. We aim to minimise material consumption,
particularly non-renewable resources, by optimising packaging design and
reusing internal cartons and pallets multiple times in our warehouse-to-store
shipments until they are no longer functional.
Consumer electronics are mainly shipped in cardboard boxes, often filled with
a lot of air or with fillers like paper or plastics. Due to the standardised sizes,
the boxes are often larger than the products ordered. The use of material and
transport volume is therefore higher than necessary.
To handle this challenge, Komplett Services has invested in a packaging
machine at the warehouse in Sandefjord. With this packing line, as much
as 99 per cent of Komplett Service’s orders leaving AutoStore have been
shipped without plastic since 2022. We have estimated that this reduces
the use of plastic by 16 to 19 tonnes a year. The reduced size of the cardboard
boxes has also reduced transportation volumes by the equivalent of 390
containers per year.
All subsidiaries in Komplett Group continue their efforts to reduce the climate
footprint of shipments to customers and within their own operations. In
addition to the positive impact that the packing line has had on current plastic
consumption, we are actively working to reduce the volume of parcels sent to
customers, resulting in reduced usage of packaging materials such as bubble
wrap and cardboard. In many cases, we also stick the address label directly on
the product packaging rather than putting the product in a shipping box, which
saves both cardboard and air. We also aim to use thinner stretch film (plastic)
in situations where it provides sufficient protection for the product without
compromising the integrity of the shipment. This is assessed based on factors
such as product fragility, transport conditions, and warehouse handling
requirements.
The overall total weight of products and technical and biological materials
used during the reporting period is 26 725 tonnes, 4 226 tonnes biological
materials and 22 499 tonnes technical materials. As sourcing is not governed
by a dedicated policy, the percentage of biological materials (and biofuels
used for non-energy purposes) that is sustainably sourced is zero. The
absolute weight of secondary reused or recycled components, secondary
intermediary products and secondary materials used to manufacture Komplett
Group’s products, (including packaging) is estimated to be 624 tonnes while
the percentage of secondary reused or recycled components, secondary
intermediary products and secondary materials is calculated to be 2.34.
Methodology and key assumptions
To evaluate resource inflows in Komplett Group, we have made calculations
based on the total weight of products and materials used during the reporting
period. Our assessments have relied on a combination of supplier reports,
group-level data, and GHG emissions records. We have obtained net and
gross weights of products sold from our purchasing reports at group level
and collected packaging data separately from each company using reports
provided directly by our suppliers.
When we collected data from suppliers across key categories, responses were
limited, making it necessary to rely on assumptions about resource inflows.
Specifically, we have assumed that all products sold by Komplett Group are
composed entirely of technical materials. Technical material are materials
| WE AIM TO MINIMISE MATERIAL
CONSUMPTION BY OPTIMISING PACKAGING
DESIGN AND REUSING INTERNAL CARTONS
AND PALLETS MULTIPLE TIMES IN OUR
WAREHOUSE-TO-STORE SHIPMENTS
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which do not naturally decompose after they are used. For packaging, we have
categorised paper-based materials and wood pallets as biological materials,
while plastic packaging is classified as technical material. In cases where
specific data is unavailable, the biological material composition of certain
categories is estimated at zero per cent.
Our approach to calculating resource inflows highlights key areas for
improvement in supplier engagement and data transparency. While gross
and net product weights are readily available at a group level, packaging
data has required a more granular collection process from suppliers. The
lack of comprehensive supplier data has also limited our ability to accurately
assess the composition of materials, leading to conservative assumptions for
products and packaging. For instance, when recycled content information was
missing, a recycled rate of zero per cent is assumed.
RESOURCE OUTFLOWS
(E5-5)
Resource outflows refer to durability, reparability, recycling of products and
product materials after use, and reducing waste. While most of our products
are designed and produced outside of our own operations, we assemble
Komplett PCs based on the customers preferred components. Other than
these PCs no other products come out of our own production process. This
means that for our own operations resource outflows mainly relates to how we
communicate and create business opportunities that facilitate more circular
products and packaging that ensure repairability, reuse and recyclability.
Downstream, outflow relates to what happens to products after they have been
sold, that is whether they are reused or recycled, as well as waste management.
As a supplier of electronic products and producer of private label products,
e-waste levels are a topic of high importance. We see significant opportunities
in building services that increase circularity in product design and re-use of
products and materials. Products lacking repair, durability and replacement
options foster a throwaway culture, promoting frequent replacements and
resource waste. Komplett and NetOnNet's trade-in and return solutions,
while well-intentioned, could inadvertently drive-up e-waste by encouraging
consumers to return functional items and buy new ones.
However, Komplett Group can also work together with suppliers to improve
the product durability by improving repeatability. This may incentivise re-use
of products. It is also possible to reduce waste generated by using more
sustainable packaging. Since most products are pre-packaged however, these
efforts need to be done in cooperation with our suppliers.
By offering effective return logistics, including repair and recycling, Komplett
Group may positively impact the circularity of products. We also participate
in a comprehensive system for the collection, sorting, reuse, recycling,
and proper disposal of electronic waste, which we also support financially.
Moreover, we offer returns through return services, "NetOnNet Byt Inn ",
"Webhallen Revive" and "Komplett Flex".
Waste management
For Komplett Group, effective and responsible waste management is a priority
in our sustainability strategy. We continually work to find solutions to reduce
waste in our operations and to help our customers do the same. This includes
establishing a sustainable waste system and recovering valuable resources
more efficiently by incorporating them into the life cycle of new products and
services. Waste generated from harvesting and extraction of raw materials is
considered significant, as well as waste from production of components such
as plastic components.
In Komplett Group’s operations, waste materials include recyclable metal
and glass, packaging plastics, and paper and cardboard. Electronic waste,
including mixed EE waste, contains valuable components and requires careful
disposal. Mixed, residual, and organic waste, such as packaging remnants,
are mainly managed through recycling and energy recovery to minimise
environmental impact. These are similar to waste streams within our sector
and for companies with similar activities.
In 2024, the total amount of waste in the Komplett Group was approximately
1960 tonnes. The largest waste fractions were paper and cardboard, wood,
general waste and electronic waste. All fractions are in general recycled, either
as materials or as energy recovery. The share of recycled waste in Komplett
Group was 59.94 per cent in 2024.
By partnering with waste management actors in Norway and Sweden, along
with our suppliers, we have established efficient ways to collect electronic
waste from our customers. We also offer customers the opportunity to buy
used and remanufactured products, in addition to trade-in options.
| THE SHARE OF RECYCLED
WASTE IN KOMPLETT GROUP
WAS 60 PER CENT IN 2024
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Management of electronic waste
Products containing electronic materials can be both dangerous and toxic.
Therefore, it is very important that these products are recycled when they
no longer function or no longer are in use. Materials such as lead, chromium,
mercury, beryllium, arsenic, and cadmium can be dangerous if not handled
properly. There is also a risk of these chemicals getting into soil or water.
Komplett Group encourages all customers to return their broken or damaged
electronics to us so that we can make sure all e-waste is recycled in an
approved manner.
Methodology, key assumptions, and results
To assess resource outflows, we have analysed the durability, reparability,
and recyclability of products, as well as waste management practices, using
a combination of direct measurements and estimations based on reliable
external and internal data sources.
To assess durability, we use the warranty periods of our private label products
as a proxy for product lifespan. In the absence of comprehensive data from
suppliers, this approach provides a consistent basis for estimation across all
product categories.
Industry average durability is determined using complaint deadlines sourced
from the Norwegian Consumer Authority (Forbrukertilsynet) and the Swedish
Tax Agency (Skatteverket). Regulatory complaint deadlines are assumed to
indicate how long a consumer can expect a product to last. Based on this
approach, we estimate the expected durability of all product categories to be
100 per cent of the industry average.
Given the variability of warranties across producers, we acknowledge that
this estimate may not fully reflect the actual lifespan of all products we
sell. However, in the absence of supplier-specific figures, we have taken a
conservative approach to ensure a reasonable and consistent estimate of
product durability.
For reparability disclosures, we have employed the recognised French
Repairability Index, which evaluates key factors such as documentation
availability, ease of disassembly, accessibility and cost of spare parts, and
specific product features. Each criterion is scored from 0 to 20, and these
scores are summed to a total out of 100. This total is then divided by 10 and
rounded to one decimal place to give the final grade on a scale from 1 to 10. A
higher score indicates better repairability.
Product group Reparability (French Reparability Index)
Consumer electronics 7.8
Computing 6.0
Home 6.5
Telecom 6.0
Repairability scores are collected for the top ten best-selling products
across Komplett Group’s ten main product categories, which are further
aggregated for reporting purposes. Scores are sourced from manufacturer
websites, Amazon.fr, Conrad.fr, and other publicly available data. For some
of our product categories scores are unavailable for all the top ten best-
selling products, and for those categories we have used a minimum of five
repairability scores to calculate category averages. The lowest repairability
score within each category is chosen as a conservative indicator of overall
reparability, except for Home which is a weighted average due to large
differences between the repairability of small and major domestic appliances.
Furthermore, the repairability score for the Computing category currently only
considers laptops. However, this category also includes desktops and system
integrations, which are generally more repairable than laptops.
For recyclability, we have considered the rates of recyclable content in both
products and packaging. The recyclable content in products is approximately
80 per cent and 74 per cent for packaging. Product categories consistent
with those used in other reporting areas have been analysed, with data
on recycling potential sourced from waste management partners such as
Norsirk and Franzefoss. Supplier reports have provided additional insights
into the recyclability of packaging materials. For our estimates, we have
treated all products sold by Komplett Group as electronics and presuming
that recyclability rates reported by partners reflect economic feasibility. This
analysis has provided both potential and actual recycling rates, using waste
management performance as a benchmark.
We have calculated waste metrics using actual data collected across Komplett
Group facilities, including offices, warehouses, and retail outlets in Norway
and Sweden. Each company has gathered waste data directly from suppliers,
documenting types of waste, both hazardous and non-hazardous, and their
management processes. In Norway, partners such as Norsirk and Franzefoss
handled waste for Komplett Services and Distribusjon, while other partners
like El-kretsen and Stena Recycling managed waste for Webhallen and
NetOnNet in Sweden. This data was collected using a process aligned with GHG
Accounting practices, ensuring accuracy and completeness.
Disclosure of metrics estimated using indirect sources and correction
of prior reporting errors
(BP-2)
Komplett Group’s resource inflow and outflow metrics incorporate value chain
data estimated using indirect data sources due to limited availability of direct data
from suppliers. For inflows, we rely on assumptions about material composition
and recyclability rates based on supplier reports, public data, and waste
management partners. For outflows, repairability and recyclability rates are
estimated using indices, external data, and assumptions about industry practices.
The preparation of these metrics is based on proxy data, industry guidelines,
and assumptions derived from internal and external sources, resulting in a
moderate level of accuracy. Gaps in supplier data and a lack of standardised
reporting contribute to inherent limitations.
To enhance accuracy, we plan to improve supplier engagement, expand data
collection processes, and align with industry standards, aiming to establish a
sound foundation for future reporting periods.
In 2023, when reporting on the organic waste fraction from Komplett Services
an extra zero was added, resulting in 182 tonnes reported instead of 18.2
tonnes. This skewed the total waste figure disclosed at Komplett Group level
with 164 tonnes. Thus, the reported figure of total waste of 2 259 tonnes was
incorrect and should have been 2 095. For comparison, in 2024 Komplett
Group's total waste is 1 960 tonnes.
>> For list of KPI metrics that are subject to uncertainty, see table in ESRS 2 BP-2
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Resource outflow
2024 tonnes
Total waste generated 1 960
Hazardous waste diverted from disposal 293
Hazardous waste diverted from disposal
due to preparation for reuse -
Hazardous waste diverted from disposal
due to recycling 187
Hazardous waste diverted from disposal
due to other recovery operations 106
Non-hazardous waste diverted from disposal 1 654
Non-hazardous waste diverted from disposal
due to preparation for reuse -
Non-hazardous waste diverted from disposal
due to recycling 988
Non-hazardous waste diverted from disposal
due to other recovery operations 666
Hazardous waste directed to disposal 2
Hazardous waste directed to disposal by incineration -
Hazardous waste directed to disposal by landfilling 2
Hazardous waste directed to disposal
by other disposal operations -
Non-hazardous waste directed to disposal 11
Non-hazardous waste directed to disposal by incineration -
Non-hazardous waste directed to disposal by landfilling 11
Non-hazardous waste directed to disposal
by other disposal operations -
Non-recycled waste 13
Total amount of hazardous waste 295
Total amount of radioactive waste -
In Komplett Group’s operations, waste materials include recyclable metal
and glass, packaging plastics, and paper and cardboard. Electronic waste,
including mixed EE waste, contains valuable components and requires careful
disposal. Mixed, residual, and organic waste, such as packaging remnants,
are mainly managed through recycling and energy recovery to minimise
environmental impact. This is very similar to waste streams in our sector and
for companies with similar activities.
In 2024, the total waste generated for Komplett Group was 1 960 tonnes. Forty
per cent of our total waste is non-recycled.
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SOCIAL INFORMATION
At Komplett Group, we are committed to promoting fair labour practices, responsible business and a safe and inclusive experience for everyone who
interacts with our products and operations. Our work on social responsibility spans three key areas: our workforce, employees in our value chain and
consumers and end users.
OWN WORKFORCE
Komplett Group aims to be an inclusive and attractive employer that attracts
and retains talent and has a positive impact on society. Our organisation relies
on our employees, and their diverse skills and traits are essential. We respect
and cherish the variation in experience and backgrounds that our employees
bring, which contributes to creating a diverse and inclusive workforce. Our
dedication to building a workplace that values and utilises the diverse features
of our employees is a key part of our social sustainability strategy.
In our 2024 materiality assessment, the topics of working conditions and
equal treatment and opportunities for all were defined as material and will be
emphasised in this sustainability statement.
Material ESRS topics Material ESRS sub-topics Part of the value chain where impact was material Impact materiality Financial materiality
S1: Own workforce
S1: Working
conditions
Upstream Own operations Downstream High High
S1: Equal treatment and
opportunities for all
Upstream Own operations Downstream High High
Working conditions: Working conditions relates to the physical and
psychological conditions that workers are exposed to while working, and we
recognise that conditions such as wage, working time, work-life balance, and
freedom of association can impact workers’ health and safety.
Komplett Group has the opportunity to improve conditions for our employees,
resulting in a healthier and likely more productive workforce. This impact is
particularly relevant for warehouse workers.
Equal treatment and opportunities for all: This topic relates to gender
equality, diversity and inclusion, as well as training and development.
Although Komplett Group is part of a male-oriented industry, we
are committed to being a preferred employer and to providing equal
opportunities, irrespective of gender, at all levels of our organisation. If
done right, this helps Komplett Group attract and keep the best candidates
regardless of gender.
INTEGRATING MATERIAL MATTERS INTO OUR STRATEGY AND
BUSINESS MODEL
(S1.SBM-3)
In our materiality assessment, the topics of working conditions and equal
treatment and opportunities for all are defined as material. These priorities have
shaped our overall strategy, with the topics integral to our core strategic focus
areas.
>> For more information on our strategic focus areas, ambitions, and targets,
see ESRS 2 SBM-1
The scope of the disclosures pertaining to material impacts includes all
our permanent employees, temporary employees, non-guaranteed hours
employees, and trainees. Non-employees, as defined by the ESRS, are
not included in the scope of these disclosures. For Komplett Group, non-
employees encompass independent contractors and employees engaged
through staffing agencies, with our team in China as an example. Regardless
of contract type, individuals subject to material impacts have various roles
and responsibilities, including warehouse management, customer service,
administrative tasks, and IT development.
Positive impacts on employees in all countries of operation include promoting
secure employment, adequate wages, work-life balance, and health and
safety, supported by commitments to sick leave reduction and respecting
freedom of association. Opportunities to improve employee conditions exist,
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particularly for warehouse workers in enhancing health and productivity.
This opportunity is dependent on the material impact identified for Komplett
Group to ensure employees’ safety and health by securing good working
conditions.
The consumer electronics and IT hardware retail sectors have traditionally
attracted more male employees, particularly in technical sales, product
development and warehouse services. We have therefore identified not
attracting the right talents as a risk. However, as we are committed to being
a preferred employer and to providing equal opportunities for all genders
at all levels of our organisation, we also recognise this as an opportunity
for Komplett Group. Furthermore, we see training as an opportunity to
support diversity in general. Training and education opportunities for all help
build necessary skills and knowledge within the company. In other words,
we recognise that there is an interdependency between attracting the
right candidates, providing adequate training and ensuring diversity in the
organisation.
No material impacts on workers from transition plans for greener, climate-
neutral operations were identified, as no such plans are currently in place.
Given that Komplett Group’s own employees are employed and work in Norway
and Sweden, the risk of forced or compulsory labour and child labour is
considered low in our own operations.
POLICIES RELATED TO OWN WORKFORCE
(S1-1) (MDR-P)
Our commitment to the well-being, safety, and development of our employees is
integrated in our corporate governance. Guided by our code of conduct, which
applies to all employees, we prioritise an ethical, safe, inclusive, and empowering
work environment at all levels. Through an annual review of the code of conduct,
we ensure adaptability and continuous improvement. Furthermore, when
assessing our ways of working with the code of conduct, we identify necessary
remediation actions required in the event of negative impacts.
The impacts, risks and opportunities identified that relate to our own
workforce, such as diversity, freedom of association, training, and health and
safety are addressed in our group HR policy, which applies to all employees.
Our firm commitment to human rights is outlined in our sustainability policy,
which explicitly addresses human trafficking, forced or compulsory labour,
and child labour. Developed in alignment with UN Global Compact’s principles,
OECD Guidelines for Multinational Enterprises, ILO conventions, General Data
Protection Regulation, and United Nations Convention against Corruption
(UNCAC), this policy applies to all employees.
To monitor compliance, we have established several processes such as
regular audits, employee engagement through surveys and employee
reviews, and grievance mechanisms. Further, to enable remedy for human
rights impacts, we have established a whistleblower channel, available
to our employees, suppliers, customers and the public. In the event that
human rights impacts are identified, we develop and implement remediation
plans to address and mitigate these impacts effectively. This might involve
legal assistance and collaboration with relevant unions, authorities and
organisations.
The HR policies in the subsidiaries are primarily to support managers and
describe how to work with a wide range of HR-related issues at the subsidiary
level. This includes key material areas and topics such as recruitment,
employee health, diversity and inclusion of targets, skills development and
working conditions. Detailed health and safety measures to track and prevent
workplace accidents are implemented at the subsidiary level.
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Both our code of conduct, HR policy and sustainability policy are aimed at the
elimination of discrimination and harassment, and the promotion of equal
opportunities, inclusion and diversity.
In Komplett Group, we do not tolerate discrimination or harassment, for
instance based on gender, nationality, ethnicity, language, sexual orientation,
age, or religious and political beliefs, in any part of our organisation. This
expectation is embedded in our code of conduct and HR-policy. We take
these matters very seriously and closely follow up incidents reported through
our various channels, among which is a third-party managed whistleblower
channel.
All policies are available internally to all employees.
>> For more details about how the group’s policies outline procedures and ways
of working related to human rights and material impacts in own workforce, see
ESRS 2 MDR-P
>> For more details about the group’s policies related to human rights and
material impacts in own workforce, see “Embedding sustainability in our policies
and processes” in ESRS 2 MDR-P
PROCESSES FOR ENGAGING WITH OWN WORKFORCE AND WORKERS’
REPRESENTATIVES
(S1-2)
Communication and collaboration with our employees and their representatives
are integral to our commitment to transparency and inclusivity. Our
engagement processes facilitate an open dialogue, encouraging active
participation in decision-making. By engaging with our workforce, we
gain valuable insights into the perspectives of marginalised or particularly
vulnerable employees. Through these collaborative efforts, we strive to create
an environment where everyone feels heard and valued. The chief HR officer is
responsible for ensuring that these engagement processes are implemented
and that their outcomes inform Komplett Group's approach.
Workforce representation and its engagement process Description and approach
Employee representatives Komplett Group values social dialogue and collective bargaining. Employees are given platforms
to contribute to decision-making regarding compensation, well-being, and working conditions.
The company upholds human rights principles, including freedom of association and collective
bargaining, as defined by the Universal Declaration of Human Rights (1948), the two international
covenants on civil and political rights (1966) and economic, social and cultural rights (1966), and the
core conventions of the International Labour Organization (ILO).
Collective bargaining agreements Komplett Group is part of employer associations NHO Service and Virke (Norway) and Svensk
Handel (Sweden). Agreements between Svensk Handel and relevant unions apply in Sweden, while
the EL & IT Forbundet and Abelia agreements apply in Norway.
Working environment committee (AMU) AMU is a decision-making body for workplace safety and environmental matters at Komplett
Services, consisting of six representatives (three from the employer, three from employees), plus
an occupational health service representative. The committee meets quarterly to oversee health,
safety, and welfare initiatives.
Employee board At Komplett Services, a seven-member employee-led board, facilitated by HR, meets regularly
to implement measures improving the psychosocial work environment. Employees can provide
input on workplace issues. At NetOnNet, a similar initiative called Eventpatrullen organises social
activities for both office staff and warehouse employees.
Employee surveys Bi-weekly pulse surveys via Winningtemp assess employee satisfaction and engagement, enabling
real-time tracking of workplace conditions and identifying areas for improvement. Ironstone is not
using this platform.
Information meetings Townhall and subsidiary-level meetings with top management provide employees with direct
communication channels to express concerns and contribute with ideas. The frequency may vary,
from monthly in certain periods, to weekly in peak periods.
Leadership engagement Leadership teams across the group meet annually to discuss strategy, culture, and employee
engagement. Regular appraisals and performance reviews ensure open dialogue between
employees and leaders.
Stage at which engagement with relevant stakeholders occurs, type of engagement and frequency.
PROCESSES TO REMEDIATE NEGATIVE IMPACTS AND CHANNELS FOR
EMPLOYEES TO RAISE CONCERNS
(S1-3)
All employees at Komplett Group, along with our business partners and
suppliers, are encouraged to report suspected violations of our code of
conduct, other policies and procedures, or laws and regulations related to
our operations or supply chain. There is a strict protection of whistleblowers
according to our whistleblower policy. Reports can be made through our
whistleblower channel, with the option to remain anonymous, or by any other
means preferred by the whistleblower. Through regular interactions with
employees and close monitoring of the whistleblower channel, we consider our
process for raising concerns and ensuring employee’s trust to be robust.
Addressing negative impacts and providing channels for our employees to
voice their concerns are integral components of our social responsibility. We
have established effective mechanisms for reporting and addressing concerns
in addition to the whistleblower programme, including bi-weekly pulse surveys,
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and regular forums where employees can express their thoughts and bring
attention to any issues they may encounter. These are all vital measures and
components in remediation if we were to cause or contribute to negative
impacts on our employees.
Processes for providing remedy in a situation where Komplett Group has caused
or contributed to a material negative impact on people in our own workforce will
vary depending on the type of negative impact. Although we do not have a pre-
defined process, key steps of a general approach include creating a tailored
remediation plan and allocate the necessary support to affected individuals.
Throughout the process, we remain committed to tracking the effectiveness of
all actions taken to ensure continuous improvement and accountability.
>> For more information on whistleblower policy and principles describing the
follow-up process of concerns raised and protection against retaliation, see G1-1
TAKING ACTION
(S1-4) (MDR-A)
Employee satisfaction is a top priority for Komplett Group, and we work
continuously to secure this. Our main actions are aimed at mitigating negative
material impacts and dependencies on our own workforce, as well as pursuing
material opportunities. We prioritise actions that promote diversity and
inclusion, health and safety, freedom of association, and skills development.
By engaging in dialogue, conducting surveys, and forming employee boards,
employee perspectives influence decisions and activities within the different
subsidiaries.
>> For more information about the processes for engaging with our own
workforce and workers’ representatives, including the working environment
committee and Winningtemp, see S1-2
Actions to manage the material impacts, risks and opportunities related to our
own workforce are taken both on group level and by each company. At group
level, the chief HR officer has the overall responsibility for material impacts on
our own workforce. This includes, but is not limited to, operational responsibility
for monitoring Winningtemp and organising the Talent Taskforce.
Example of action at group level
The Talent Taskforce is the group's talent development program, led by
chief HR officer, which aims to identify and nurture future leaders within the
organisation. The program involves a meticulous selection process where
leaders identify potential talents, and 14 individuals were chosen to participate.
The taskforce has met for two gatherings during 2024, covering topics such
as project management, change management, practical leadership training,
negotiation and presentation techniques. The program includes ongoing
support with designated mentors from group management, monthly progress
meetings, and plans for future sessions. The goal is to build a strong leadership
pipeline and foster a sense of belonging and career growth within the company.
Example of action at company level
Most actions related to own workforce are taking place at the company level,
where the company management teams have the operational responsibility for
making sure engagement takes place and that results inform the company’s
approach. Actions taken to mitigate negative impacts and promote positive
impacts on own workforce at company level include regular employee dialogue,
work environment checkups at stores, non-discrimination practices in
recruitment, and preventive health care measures through health insurance
and occupational health services. Further, we ensure that non-alcoholic
alternatives are always available if alcohol is served at social events. When
serving food, allergies and cultural/religious considerations, or other
preferences that the employee may have, are considered.
The mental health awareness week ("Psykt bra på jobb") at Komplett Services
was organised in recognition of the World Mental Health Day on October 10th.
This was an initiative from HR and the employee board to focus on mental
health at work. Throughout the week, various activities and lectures on the
topic of mental health were organised. In addition, inspiration was shared on
how to take care of your own mental health and be a good colleague at work.
>> For more information and description of the employee board, see processes
for engaging with own workforce and workers’ representatives in S1-3
The effect of actions taken is tracked through Winningtemp. For instance,
after the mental health awareness week, the score in Winningtemp showed
significant improvement. No actual material negative impact has been
identified during the year. Hence, no remediation actions have been necessary.
Moreover, no negative impact on employees from the transition to greener
climate-neutral economy has been identified.
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TRACKING EFFECTIVENESS OF POLICIES AND ACTIONS THROUGH
TARGETS
(S1-5) (MDR-T)
To maintain and strengthen our position as an attractive and inclusive
employer, Komplett Group has set two strategic targets related to employee
satisfaction and diversity: Industry leading employee temperature and gender
balance in leadership positions. The stakeholders involved in the target setting
related to own workforce include various HR-representatives. The target is
overseen by the chief HR officer. Our targets related to own workforce aim
to address the following material impacts, risks and opportunities related to
equal treatment and opportunities for all.
1. Ensuring diversity and inclusion of employees: Komplett Group
is committed to being a preferred employer and to providing equal
opportunities to employees at all levels of our organisation to attract and
keep the best candidates.
2. Low gender diversity: Komplett Group is part of a predominantly male-
oriented industry. This may lead to Komplett losing or not attracting the
right candidates if we are not recognised as a place for diversity and
inclusion.
ATTRACTIVE AND INCLUSIVE EMPLOYER
Industry-leading employee
temperature
Gender balance in
leadership positions
Industry-leading employee temperature
Komplett Group aspires to have an industry-leading employee temperature.
This target aligns with our policy objectives set forth in our code of conduct
and in our HR policy, described under Policies related to own workforce. Our
target is to achieve a temperature score above the industry index, which
covers retail companies. The target is relative and measured through our
employee satisfaction survey, which looks at our employees’ loyalty and
engagement and gives an indication of how our employees feel about our
company. Winningtemp, an AI-powered platform, is used to ensure neutrality
and eliminate internal bias in the measurement process. Using a third-party
provider helps securing objectivity of the results.
The scale is from 1-10. The target applies to all employees in Komplett Group’s
own operations, except Ironstone which does not use the tool Winningtemp.
Employees in upstream and downstream value chains do not participate in the
survey.
The methodology for measuring employee temperature includes employee
surveys to all employees twice a month, and industry benchmarking.
The survey covers a broad range of questions related to key engagement
drivers, such as personal development, leadership, and team dynamics. The
temperature score is designed not only to track overall satisfaction but also to
identify potential risks and areas for improvement.
The significant assumptions are that such surveys sufficiently capture a
representative picture of all employees' satisfaction, and that the industry
benchmarking represents a reasonable comparison. Neutrality and objectivity
of the industry average is secured by sourcing the index from a third party
provider, ensuring unbiased comparisons. The index includes several
comparable peers within the same geography that respond to the same
questions, ensuring consistent and reliable benchmarking.
The first year of reporting on the employee satisfaction target was 2023. In
2023, the temperature score was identical to the industry index (7.7). Although
the target is relative, progress is measured from this score. The target does
not apply to a specific period but is reported annually. It might change with
improved methods of capturing employee satisfaction.
No changes in the target or underlying measurement methodologies,
significant assumptions, limitations, sources or process to collect data were
made in 2024. Hence, the results are comparable.
The performance in 2024 was 7.7/10 for Komplett Group against an industry
index of 7.6. The industry index was the same in Norway and Sweden. Absolute
employee temperature is the same as it was in 2023, while the relative
temperature is slightly improved due to a lower industry index. The highest
scores for all companies are related to leadership, team and engagement. The
weakest area for all companies is personal development.
Komplett temperature:
7.7
Average value in
Komplett Group 2024
Index:
7.6
Compared with other
organisations within the
same industry
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Komplett Group (total) Komplett ASA Komplett Services Webhallen NetOnNet
Temperature 7.7 7.9 7.9 7.5 7.7
Response rate 70% 81% 85% 70% 64%
The target is monitored twice a month in Winningtemp by all managers and is
overseen by the chief HR officer. All employees have the opportunity to add
comments anonymously, which will always be answered. The response rate of
70 per cent is a decrease from 77 per cent last year. However, we still consider
this response rate to be sufficient to provide a representative assessment of
employee satisfaction.
Gender balance in leadership positions
Komplett Group aims to achieve gender balance in leadership positions. The
target is aligned with our policy objectives set forth in our code of conduct
and in our HR policy, described under Policies related to own workforce.
The target is to achieve a balance between male and female leaders overall.
The target is relative and applies to all leadership positions in Komplett
Group’s own operations. A significant assumption is that gender balance is
beneficial, contributing to a diverse workforce that enhances our collective
capabilities.
Our ambition for 2030 is to achieve gender balance at group level, meaning a
representation of both men and women in leadership positions between 40 and
60 per cent. This is in line with best practice. It also reflects that we operate
in a male-oriented industry, where the majority of our employees are male. At
least 40 per cent of both men and women in leadership positions is therefore
considered flexible and allows for the leadership groups to represent the
workforce.
We have made some changes in the target and underlying measurement
methodologies, in 2024.
X First, our understanding and definition of gender balance is updated to
encompass a broader range, namely 40 to 60 per cent representation of
both men and women. Hence, the results are comparable, but the long-term
target is no longer defined as 50/50.
X In 2023, the reported number for gender balance in leadership positions was
32 per cent, reflecting the female proportion of the workforce. However,
we have seen the need to change how this number is calculated. In 2023,
the number was measured as an average of the management teams of the
subsidiaries and the top management.
X The updated methodology for measuring gender balance involves
calculating the share of female leaders over the total number of leaders.
This number is weighted against the total number of employees in each
company to ensure a balanced figure. We also report specifically on
the gender balance at group management and at board level to provide
transparency. Going forward, we will measure progress from the 2024 figure
which is based on the updated methodology.
In 2024 the share of female leaders in the group in total was 28 per cent. The
share at top management level was 25 per cent, while the share at subsidiary
management level was 36 per cent.
Share of female leaders 31.12.2024
Group top management level 25%
Subsidiary management level 36%
Komplett Group 28%
CHARACTERISTICS OF OUR EMPLOYEES
(S1-6)
With subsidiaries operating in different countries, we conducted joint
workshops with all HR management employees responsible for supplying
HR-related data to ensure alignment of calculation methods and similar
definitions. Like the previous reporting year, Komplett Group have opted to
disclose our employee numbers in head count at the end of the reporting
year. This means that the number of employees might be higher than the year
average, due to the temporary employment of staff during holiday seasons.
EMPLOYEE CHARACTERISTICS
(ESRS S1-6)
1 482
Employees
total
172
New
hires
155
Employees
temporary
GENDER BALANCE AT GROUP LEVEL
68.2%
Men
0.1%
Other
31.7%
Women
When reporting on own employees, Komplett Group considers all employees
that are under contractual obligations to work for either the group or one of
the group’s subsidiaries. Employees employed by third-party providers are
counted as non-employees, which includes hired labour resources at our
offices in China.
>> For more information about metrics related to the characteristics of our
employees, see the table number and statistics
>> For more numbers on employees, see note 7 in the financial statements
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DIVERSITY METRICS
(S1-9)
Top management is defined as members of the group management. Of eight
members of the group management, two are female (25 per cent).
At Komplett Group, we cherish diversity as a fundamental element within our
organisation. Our proactive initiatives aim to attract individuals with diverse
backgrounds, experiences and perspectives, appreciating the value that a
diverse workforce brings to our collective capabilities.
>> For more information on metrics related to diversity of our employees, see the
table at the end of the Own workforce chapter
ADEQUATE SALARIES
(S1-10)
At Komplett Group, we seek to provide competitive salaries and to ensure
fairness. We are committed to providing equitable salaries for all employees
that reflect the individual’s skills, contributions, and responsibilities, and that
are in line with the expectations in the market. No employees earn below the
applicable adequate wage benchmark, regardless of geographic location
or function. All group companies are committed to collective bargaining
agreements and comply with salary levels as stipulated by joint negotiations.
We actively support professional development through training, mentorship
and clear career paths, empowering our employees to advance within the
group. This dual emphasis on competitive salaries and career growth creates
a workplace where employees feel valued, motivated and rewarded as they
hopefully reach their full potential within Komplett Group.
HEALTH AND SAFETY
(S1-14)
We care for our employees, and safety is a top priority. All employees
are covered by health and safety management systems based on legal
requirements and recognised standards and guidelines. Our belief is that all
accidents are preventable. Occupational health and safety are regular topics
in various committees, and training is integrated into the onboarding process.
The group companies work independently and approach employee safety with
slight variations through routines established within the companies prior to the
mergers.
Work-related injuries during the year refer to any physical harm or illness
suffered by an employee as a result of work activities or environment.
Work-related injuries:
2024 2023 2022
Number of accidents 16 8 20
During the reporting year, there have been no fatalities in our own workforce
as a result of work-related injuries or work-related ill health, nor any fatalities
as a result of work-related injuries or work-related ill health of other workers
working on our sites.
INCIDENTS, COMPLAINTS, AND SEVERE HUMAN RIGHTS IMPACTS
(S1-17)
We are committed to addressing events, complaints, and human rights impacts
with utmost seriousness. Our processes for handling such issues are robust,
involving thorough investigations and corrective actions. We encourage the
use of open communication channels for employees to report concerns, and
our commitment to human rights remains unwavering.
We have established whistleblower channels both at the group level and for our
subsidiaries. Employees can voice their concerns through the whistleblower
channel, the Winningtemp platform or other preferred channels. In 2024, 147
complaints related to potential discrimination were filed through the different
available channels, mainly Winningtemp. Out of these, one case was identified
as actual discrimination.
No cases related to severe human rights issues and incidents connected to
own workforce have occurred in 2024, including cases of non-respect of UN
Guiding Principles and OECD Guidelines for Multinational Enterprises. Neither
have any such cases been reported to Komplett Group or to the National
Contact Points for OECD Multinational Enterprises during the year. We have
not received any fines or penalties, nor been subjected to any compensation
claims for damages due to violations regarding social or human rights factors
or incidents.
>> For more information on metrics related to discrimination and human rights
violations, see the table number and statistics
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NUMBERS AND STATISTICS
Komplett
Group
Komplett
Group
Komplett
Services AS
Komplett
Services AB
Komplett
ASA
NetOnNet
AB
Web hallen
AB
Ironstone
AS
ESRS DR Paragraph Measure Unit 2024 2023 2024 2024 2024 2024 2024 2024
EMPLOYEE SATISFACTION
ESRS S1 Winningtemp average rating (0-10) Rate 7.7 7.7 7.9 7.9 7.9 7.7 7.5 N/A
EMPLOYEES OVERALL
ESRS S1 S1-6 50 a Total employees 1/1/2024 Headcount 1 394 - 343 18 17 675 323 18
ESRS S1 S1-6 50 a Total employees 31/12/2024 Headcount 1 482 1 561 330 17 26 871 218 20
Employees as share of total (end of year) Per cent 100% - 22% 1% 2% 59% 15% 1%
ESRS S1 S1-6 50 a Average number of employees over the year Headcount 1 438 - 337 18 22 773 271 19
EMPLOYEES BY GENDER (per 31/12)
ESRS S1 S1-6 50 a Male Headcount 1 011 1 061 241 13 18 560 160 19
ESRS S1 S1-6 50 a Female Headcount 470 499 88 4 8 311 58 -
ESRS S1 S1-6 50 a Other Headcount 1 1 1 - - - - -
EMPLOYEES BY COUNTRY (per 31/12)
ESRS S1 S1-6 50 a Norway Headcount 456 444 330 - 26 81 - 19
ESRS S1 S1-6 50 a Sweden Headcount 1 026 1 094 - 17 - 790 218 1
EMPLOYEES BY CONTRACT TYPE (per 31/12)
ESRS S1 S1-6 50 b Number of permanent employees Headcount 1 306 1 338 325 17 26 737 201 -
ESRS S1 S1-6 50 b Of which are full time Headcount 860 905 312 17 26 365 120 20
ESRS S1 S1-6 50 b Of which are part time Headcount 466 433 13 - - 372 81 -
ESRS S1 S1-6 50 b Number of temporary employees Headcount 155 221 4 - - 134 17 -
ESRS S1 S1-6 50 b Of which are full time Headcount 10 48 2 - - 8 - -
ESRS S1 S1-6 50 b Of which are part time Headcount 145 175 2 - - 126 17 -
ESRS S2 S1-7 51 b Number of non-guaranteed hours employees Headcount - - - - - - - -
ESRS S1 S1-6 50 b Number of trainees Headcount 1 2 1 - - - - -
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Komplett
Group
Komplett
Group
Komplett
Services AS
Komplett
Services AB
Komplett
ASA
NetOnNet
AB
Web hallen
AB
Ironstone
AS
ESRS DR Paragraph Measure Unit 2024 2023 2024 2024 2024 2024 2024 2024
GENDER BALANCE (per 31/12)
ESRS S1 S1-6 50a Total female employees Per cent 32% 32% 27% 24% 31% 36% 27% 5%
ESRS S1 S1-6 50a Total female employees Headcount 470 - 88 4 8 311 58 1
ESRS S1 S1-6 50 b Female in permanent position - full time Per cent of total (headcount) 18% - 24% 24% 31% 16% 18% 5%
ESRS S1 S1-6 50 b Female in permanent position - full time Headcount 272 - 80 4 8 140 39 1
ESRS S1 S1-6 50 b Female in permanent position - part time Per cent of total (headcount) 9% - 1% - - 14% 6% -
ESRS S1 S1-6 50 b Female in permanent position - part time Headcount 140 - 4 - - 123 13 -
ESRS S1 S1-6 50 b Female in temporary position - full time Per cent of total (headcount) 0% - 1% - - - - -
ESRS S1 S1-6 50 b Female in temporary position - full time Headcount 2 - 2 - - - - -
ESRS S1 S1-6 50 b Female in temporary position - part time Per cent of total (headcount) 4% - 1% - - 6% 3% -
ESRS S1 S1-6 50 b Female in temporary position - part time Headcount 56 - 2 - - 48 6 -
ESRS S1 S1-6 50 b Female in non-guaranteed hour position Per cent of total (headcount) - - - - - - - -
ESRS S1 S1-6 50 b Female in non-guaranteed hour position Headcount - - - - - - - -
ESRS S1 S1-9 66 a Management positions Per cent of total (head count) 10% - 18% 29% 42% 3% 14% 25%
ESRS S1 S1-9 66 a Management positions Headcount 180 - 61 5 11 67 31 5
ESRS S1 S1-9 66 a Female in management positions
Per cent of total management
positions (head count) 29% - 25% 0% 27% 31% 29% 0%
ESRS S1 S1-9 66 a Female in management positions Headcount 48 - 15 - 3 21 9 -
EMPLOYEES BY AGE GROUP (per 31/12)
ESRS S1 S1-9 66 b Age <30 Per cent 37% 38% 15% 6% 0% 45% 46% 20%
ESRS S1 S1-9 66 b Age <30 Headcount 546 - 50 1 - 391 100 4
ESRS S1 S1-9 66 b Age 30-50 Per cent 56% 54% 72% 88% 77% 48% 53% 80%
ESRS S1 S1-9 66 b Age 30-50 Headcount 823 - 237 15 20 420 115 16
ESRS S1 S1-9 66 b Age >50 Per cent 8% 7% 13% 6% 23% 7% 1% 0%
ESRS S1 S1-9 66 b Age >50 Headcount 113 - 43 1 6 60 3 -
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Komplett
Group
Komplett
Group
Komplett
Services AS
Komplett
Services AB
Komplett
ASA
NetOnNet
AB
Web hallen
AB
Ironstone
AS
ESRS DR Paragraph Measure Unit 2024 2023 2024 2024 2024 2024 2024 2024
NEW, PERMANENT EMPLOYEE HIRES
ESRS S1 Total Headcount 171 181 27 2 2 111 24 5
ESRS S1 Women Headcount 69 72 11 1 1 48 7 1
ESRS S1 Men Headcount 102 109 16 1 1 63 17 4
ESRS S1 Other Headcount - - - - - - - -
ESRS S1 By age group Headcount - - - - - - - -
ESRS S1 Age <30 Headcount 93 94 11 - - 70 10 2
ESRS S1 Age 30-50 Headcount 71 81 12 2 2 38 14 3
ESRS S1 Age >50 Headcount 7 6 4 - - 3 - -
TURNOVER RATE
ESRS S1 S1-6 50 c Total turnover Headcount 123 283 26 3 1 16 75 2
ESRS S1 S1-6 50 c Turnover rate Per cent 9% 18% 8% 18% 5% 2% 28% 11%
TURNOVER BY GENDER
ESRS S1 S1-6 50 c Female Per cent 10% 19% 9% 25% 17% 2% 38% 0%
ESRS S1 S1-6 50 c Female Headcount 45 - 8 1 1 5 30 -
ESRS S1 S1-6 50 c Male Per cent 8% 18% 7% 15% 0% 2% 23% 16%
ESRS S1 S1-6 50 c Male Headcount 79 - 18 2 - 11 45 3
TURNOVER BY AGE GROUP
ESRS S1 S1-6 50 c Age <30 Per cent 10% - 17% 0% 0% 2% 27% 0%
ESRS S1 S1-6 50 c Age <30 Headcount 48 141 8 - - 6 34 -
ESRS S1 S1-6 50 c Age 30-50 Per cent 8% - 7% 13% 6% 2% 27% 19%
ESRS S1 S1-6 50 c Age 30-50 Headcount 68 130 16 2 1 9 37 3
ESRS S1 S1-6 50 c Age >50 Per cent 7% - 5% 67% 0% 2% 80% 0%
ESRS S1 S1-6 50 c Age >50 Headcount 8 12 2 1 - 1 4 -
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Komplett
Group
Komplett
Group
Komplett
Services AS
Komplett
Services AB
Komplett
ASA
NetOnNet
AB
Web hallen
AB
Ironstone
AS
ESRS DR Paragraph Measure Unit 2024 2023 2024 2024 2024 2024 2024 2024
TURNOVER BY REGION
ESRS S1 S1-6 50 c Norway Per cent 8% - 8% 0% 5% 9% - 17%
ESRS S1 S1-6 50 c Norway Headcount 36 - 26 - 1 6 - 3
ESRS S1 S1-6 50 c Sweden Per cent 9% - 0% 17% 0% 1% 28% 0%
ESRS S1 S1-6 50 c Sweden Headcount 88 - - 3 - 10 75 -
HEALTH AND SAFETY
ESRS S1 Total estimated working hours Number 2 407 198 2 189 626 642 844 34 256 50 380 1 256 924 384 829 37 965
ESRS S1 Sick leave Per cent 4.9% 5.3% 4.4% 2.4% 1.0% 5.2% 5.9% 0.3%
ESRS S1 Near miss incident Number 38 44 1 - - 34 3 -
ESRS S1 S1-14 88a
Employees covered by health and safety
management system Per cent 100% 100% 100% 100% 100% 100% 100% 100%
ESRS S1 S1-14 88b Fatalities in own workforce Number - - - - - - - -
ESRS S1 S1-14 88b Fatalities of other workers at our sites Number - - - - - - - -
ESRS S1 S1-14 88c Work related accidents for own workforce Number 16 9 - - - 8 8 -
ESRS S1 S1-14 88c Work related accidents for own workforce Rate 9 - - - - 6 21 -
DISCRIMNIATION AND HUMAN RIGHTS
ESRS S1 S1-17 103 a Incidents of discrimination Number 1 1 - - - 1 - -
ESRS S1 S1-17 103 b Complaints filed through internal channels Number 147 - 17 - 5 111 14 -
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WORKERS IN THE VALUE CHAIN
Komplett Group requires that all our suppliers commit to our ethical
expectations that are in harmony with international standards by signing
our supplier code of conduct. This chapter describes our expectations and
our engagement with workers in the value chain. In 2024, we improved our
risk mapping and actions related to fundamental human rights and decent
working conditions by initiating assessment of sub-suppliers.
With regards to workers in the value chain, the 2024 materiality assessment
emphasises the topics of working conditions and other work-related rights
of workers in our supply chain. This relates to how Komplett Group manages
relationships with our suppliers.
Material ESRS topics Material ESRS sub-topics Part of the value chain where impact was material Impact materiality Financial materiality
S2: Workers in the
value chain
S2: Working conditions Upstream Own operations Downstream High Medium
S2: Other work-related rights Upstream Own operations Downstream High Medium
ENGAGING WITH WORKERS IN THE VALUE CHAIN
(S2.SBM-3)
Our operations rely heavily on our suppliers, and Komplett Group has a complex
and global supply chain. This is of high strategic relevance for the entire group.
All value chain workers who can be materially impacted by Komplett Group are
included in the scope of disclosure. This includes vulnerable groups of workers,
such as workers at our own sites who are not part of our own workforce and
workers in the downstream supply chain, such as transportation. It also
encompasses migrant workers, trade unionists, female workers, and workers
in low-income countries, who are particularly vulnerable to negative impacts.
Working conditions refer to the conditions that workers are exposed to while
performing duties connected to Komplett Group’s business activities and
includes areas such as health and safety, working time, freedom of association
and adequate wages.
The identified material negative impacts are primarily systemic, connected to
mining and mineral sourcing in certain geographies, such as South America,
Africa and Asia. Furthermore, we have exposure to sectors that have systemic
risks of labour rights violations.
X Mining and mineral sourcing, particularly in industries like lithium mining
and other raw materials for microchips, involve risks for workers, such as
harsh conditions, noise, long hours, and vibrations. Komplett Group may sell
products with lithium extracted in such conditions. Key concerns include
workers' ability to organise and recruitment fees leading to potential debt
bondage.
X Workers in the transportation and logistics value chain face a higher risk
of labour rights violations due to the sector’s intense competition based
on flexibility and responsiveness, which can lead to reduced wages and
compromised working conditions. Moreover, workers involved in e-waste
recycling or disposal are at risk of exposure to harmful substances if not
properly trained and equipped. Ensuring safe e-waste disposal practices is
essential to protecting these workers' health.
X Other work-related rights are assessed as material as the nature of work in
the upstream electronics supply chain presents a significant risk of human
rights violations, especially when it comes to occurrences of forced labour
and child labour in China. Consequently, we must acknowledge that there is
a risk that consumer electronics sold by the group may contain components
produced by child labour.
X The risk of other human rights violations is particularly high in the mining
industry, as such violations are particularly existent in mineral sourcing
for lithium and raw materials used for microchips and in production of
electronics parts, metals, and plastics.
We influence our supply chain positively by ensuring that we have appropriate
policies and contractual commitments with suppliers in place. Furthermore, in
2024, efforts to eliminate child and forced labour included identifying suppliers
beyond tier 1 and conducting due diligence and audits. This also involved direct
engagement with affected communities. Specific groups of workers impacted
by these efforts include young workers in high-risk regions, factory workers
in countries with known labour issues, and migrant workers who may be
vulnerable to exploitation.
Audits and engagement with affected communities help us understand
how certain workers might be more at risk of harm, depending on their
characteristics, work environment, or activities.
POLICIES RELATED TO VALUE CHAIN WORKERS
(S2-1) (MDR-P)
One of Komplett Group’s goals is to develop relationships with business
partners that share similar corporate values and conduct their business in an
ethical and compliant manner. The supplier code of conduct is the Komplett
Group policy that outlines the legal obligations and the integrity standards
that we expect our suppliers and business partners to uphold. The external
suppliers we purchase from must sign and adhere to our supplier code of
conduct, which is based on the UN Universal Declaration of Human Rights, the
UN Guiding Principles on Business and Human Rights, the ILO’s (International
Labour Organisation) eight fundamental human rights conventions on working
life, the Convention on the Rights of the Child, UN Global Compact, and the
OECD Guidelines for Multinational Enterprises.
Furthermore, our sustainability policy explicitly addresses the group’s
expectations and principles regarding trafficking of human beings, forced
labour and child labour. If the suppliers have their own code of conduct, they
must nevertheless comply ours as a minimum. They also need to provide us
with information about their subcontractors upon request. The standards,
expectations and principles outlined in the policies apply to all value chain
workers.
Compliance with relevant policies is monitored through regular supplier
audits which includes engagement with the value chain workers. A more
detailed description about our engagement with workers in the value chain
is outlined in the next section. In case of a breach that merits remediation
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actions, Komplett Group’s general approach will be to dedicate a working
group that will enable all necessary initiatives. Furthermore, our specialised
team in China, is already following a structured set of procedures and
approaches for applying remediation actions.
No cases of non-respect of the UN Guiding Principles on Business and Human
Rights, ILO Declaration on Fundamental Principles and Rights at Work or OECD
Guidelines for Multinational Enterprises that involve value chain workers have
been reported during 2024.
>> For more details about how the group’s policies outline procedures and ways
of working related to material impacts in workers in the value chain, including
our supplier code of conduct and sustainability policy, see ESRS 2 MDR-P
APPROACH FOR ENGAGING WITH VALUE CHAIN WORKERS
(S2-2)
Komplett Group has an ongoing dialogue with our suppliers, creating a
collaborative atmosphere that goes beyond business transactions. This
continuous engagement covers material and product providers, as well as
delivery services.
We aim to understand and address any possible negative impacts that might
occur in our value chain. We have processes to identify, assess, and mitigate
risks, ensuring a comprehensive approach to maximise positive impacts and to
minimise negative impacts. Additionally, in Norway we are under obligations to
inspect (Påseplikten) salaries and working conditions for sub-suppliers in at-risk
industries, such as cleaning services and road freight transport. This includes
yearly spot-checks of at least two sub-suppliers in the at-risk categories where
we demand documentation on employment contracts, time-sheets and pay-
slips. Furthermore, our process may involve interviews as an alternative means
of gathering information. These inspections of our value chain workers that
may be particularly vulnerable to impacts provides insights into whether our
suppliers and business partners adhere to Komplett Group’s standards of decent
working conditions and adequate salaries.
Moreover, in 2024, we conducted 112 factory audits, even extending to due
diligence assessments of tier 2 suppliers, in addition to audit-related structured
dialogue and feedback sessions for employees at the factories in China
producing our private label products. The effectiveness of our engagement with
value chain workers is assessed through our factory audits.
The operational responsibility for ensuring that engagement with value chain
workers takes place, and that the results inform the company's approach, lies
with the chief commercial director at group level, who oversees and integrates
feedback into the decision-making processes.
PROCESSES FOR REMEDIATING NEGATIVE IMPACTS ON WORKERS IN
THE VALUE CHAIN
(S2-3)
Komplett Group has implemented processes to rectify negative impacts
and established channels to amplify the voices of workers within our
value chain. Our primary instrument is an external whistleblower channel,
complemented by routine evaluations and audits of our suppliers. Policies
protecting individuals from retaliation for raising concerns are embedded in
the whistleblower policy and in the supplier code of conduct, ensuring safety
and confidentiality for all users. Komplett Group has also implemented a
process to follow up employees in certain vulnerable areas like transport and
cleaning, as required by Norwegian law. This three-fold approach ensures that
concerns are heard and effectively addressed in the event of incidents where
Komplett Group can make a positive contribution. We assess awareness and
trust in our structures by analysing feedback and compliance during audits and
through open communication about available channels like the whistleblower
mechanism.
Our supply chain is extensive and multi-tiered, presenting several risks.
While we prioritise audits of factories producing private label products,
it is important to recognise that the broader supplier network also poses
inherent risks. Despite our robust control measures for private label suppliers,
particularly at tier 1, the overall complexity of the supply chain necessitates
ongoing risk management efforts. One of the primary concerns is the lack
of visibility beyond our tier 1 suppliers, which limits our ability to maintain
comprehensive oversight. Additionally, operating a substantial portion of
our supplier network in China exposes us to geopolitical uncertainties and
potential regulatory changes.
We conduct regular factory audits and have increased our emphasis on
ensuring good working conditions for the workers in the value chain. In
cases where factories are found to have minor deviations from our expected
standards, we give them the opportunity to improve and have a re-audit later.
Prior to such re-audit, no orders are placed with this supplier. Moreover, if they
fail to improve, or the breach is severe, collaboration is terminated.
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Breaches related to forced labour and child labour result in immediate
termination of contract.
We track and monitor issues and material negative impacts raised through the
whistleblower channel and supplier evaluations, ensuring effectiveness of our
remediation efforts, through follow-up actions, re-audits, and documented
outcomes. To assess the effectiveness, we involve stakeholders, including
workers and suppliers, in the evaluation process. The aim is to gather diverse
perspectives and ensure that our actions meet the needs and concerns of
those affected.
>> For more details about our whistleblower channel, and our general approach
and processes for remedy related to negative material impacts for workers in
the value chain, see G1-1
TAKING ACTION
(MDR-A § 62)
To effectively manage our impacts, risks and opportunities related to workers
in the value chain, we have implemented several initiatives throughout 2024,
and we plan to take further actions in the coming years. However, we have
decided to not report specifically on actions for the reporting year 2024, as
we will first develop a process to evaluate and secure the effectiveness of our
initiated actions.
In 2024, Komplett Group standardised the supplier code of conduct at group
level and began centralising the purchasing processes to ensure its consistent
application. While our ability to influence suppliers is strongest with private
label products, our commitment to ethical practices extends throughout our
entire supplier network. All suppliers producing private label products have
incorporated the updated supplier code of conducted into the agreements
with Komplett Group. For all other suppliers of goods for sale we are currently
working on a risk-based approach, where we prioritise the inclusion of the
updated supplier code of conduct in the agreement with our largest suppliers.
Our specialised team in China conducted 112 tier 1 factory audits in 2024.
Additionally, the due diligence checks against tier 2 suppliers were carried
out, involving a total of 160 tier 2 suppliers. Compliance at tier 1 suppliers was
verified through physical factory audits based on ISO standards, covering
Corporate Social Responsibility (CSR), Quality Management Systems (QMS),
and Environmental Management Systems (EMS). The CSR protocol includes
specific criteria in areas such as child labour, forced labour, discrimination, fair
compensation, safe working environments, health provisions, union rights, and
environmental impact. This approach goes beyond basic compliance, aiming to
uphold fundamental rights and support the well-being of all workers.
Through the audits, we found that some suppliers did not meet our required
standards. We mandated corrective actions to bring these suppliers up to
our standards. Unfortunately, for 11 suppliers, we had to terminate contracts
as they failed to comply. We uphold strict guidelines against unapproved
subcontracting, with monitoring conducted by the local team in China to
ensure adherence. No incidents of child or forced labour were reported or
detected at our factories in 2024.
TRACKING EFFECTIVENESS OF POLICIES AND ACTIONS THROUGH
TARGETS
(MDR-T §§ 72, 81)
Komplett Group is committed to enhancing the well-being of workers in our
value chain. We continue to implement our updated supplier code of conduct,
collaborate with global suppliers, strengthen risk assessments, and take
mitigating actions under the Norwegian Transparency Act. However, we
have not yet set measurable outcome-oriented targets due to several key
challenges:
X Our complex and multilayered supply chain means that our products are
sourced from diverse regions, making it difficult to establish standardised
and measurable targets across all suppliers.
X Comprehensive and reliable data on working conditions, labour rights, and
supplier performance is still being collected, resulting in limited baseline
data which is an impediment for setting meaningful targets.
We are continuously refining our approach to responsible sourcing, due
diligence processes, and supplier engagement to ensure effective target-
setting in the future.
The effectiveness of our policies and actions is currently monitored through
audits, supplier evaluations, and compliance checks based on internationally
recognised human rights frameworks. As data quality improves, we will
work toward establishing measurable goals to drive sustainable and ethical
practices for workers in our value chain.
>> For additional information related to workers in the value chain, see Komplett
Group's Transparency Act Account
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CONSUMERS AND END-USERS
Komplett Group serves customers in the B2C, B2B, and distribution
segments. Building on decades of expertise and deep customer commitment,
the group enjoys a loyal and growing customer base. Best-in-class customer
satisfaction is our top priority. This includes ensuring the right to privacy and
protection of personal data for all our customers.
Material ESRS topics Material ESRS sub-topics Part of the value chain where impact was material Impact materiality Financial materiality
S4: Consumers and end-users
S4: Information-related
impact
Upstream Own operations Downstream High Medium
Information-related impact: There are privacy concerns associated with
collecting customer data, and Komplett Group has access to a wide range of
customer data. Inadequate data handling would impose a negative impact risk
on our customers.
CUSTOMER ENGAGEMENT AND INFORMATION-RELATED IMPACT
(S4.SBM-3)
Komplett Group collects personal information from customers and shall
therefore comply with GDPR regulations.
It is a priority to ensure the rights to privacy and protection of personal data for
all types of customers who register their information at Komplett Group.
For the cloud-based IT solutions by Ironstone, the data may contain
critical business and operational information for customers and private
information about users. Inadequate data handling would thus impose a
negative impact risk for our customers. Occurrence of material negative
impact is primarily related to individual incidents, for example in the case of
cyber-attacks.
All consumers and end-users who can be materially impacted by the
collection of personal data are included in the scope of our disclosures.
The impact related to privacy is relevant to all customers who register their
information at Komplett Group. Particularly vulnerable groups with respect to
personal information are defined as customers under the age of 18 as well as
our most senior customers. Through supplying PCs to public school students,
we gather personal information from customers under the age of 18. We
consider our policies and processes for managing personal information to
be sufficient also for these groups. Komplett Group does not handle or store
sensitive information about any of our customers.
Vulnerable groups are identified by considering a formal list of potentially
vulnerable groups with regard to data privacy and assessing this list against
our available information.
POLICIES RELATED TO CONSUMERS AND END-USERS
(S4-1)
It is clearly stated in our code of conduct that we strive to provide exceptional
service, prioritise customer satisfaction, and maintain the trust and loyalty of
our customers. Further, we commit to safeguard confidential and proprietary
information in the digital realm, ensuring the privacy and security of online
transactions and customer data. These commitments are further outlined in
our privacy policy. We also have local policies for processing of personal data
as well as local data protection officers and GDPR officers.
Our firm commitments to human rights are described in our sustainability
policy, which also apply to our handling of information-related data. The policy
is aligned with UN Guiding Principles on Business and Human Rights, ILO
Declaration on Fundamental Principles and Rights at Work or OECD Guidelines
for Multinational Enterprises that involve consumers and/or end-users. No cases
of violations of human rights have been reported in our downstream value chain.
These policies apply to our handling of personal data for all customers.
Compliance is monitored through internal audits and/or ISO audits. Customers
can submit questions and request information regarding our policy
commitments to human rights related to personal privacy and the handling
of data through our contact forms available on our website. In the event of
incidents that call for remedy, a dedicated working group will be established to
determine the most effective and appropriate actions to undertake.
>> For more information about how privacy and human rights are regulated in
our privacy policy and sustainability policy, see embedding sustainability in our
policies and processes
PROCESSES FOR ENGAGING WITH CUSTOMERS
(S4-2)
At Komplett Group, we are transparent about our data collection practices and
our handling of consumer information, not only to ensure GDPR compliance
but also as part of our commitment to deliver great customer experience. In
the digital era, where data privacy is paramount, we believe that upholding the
principles of GDPR is not just a legal obligation but a fundamental element in
protecting the trust our customers place in us. All relevant information about
privacy is available in the privacy policies at our websites.
Privacy is included in our yearly sustainability-related customer survey, and
customers also have the opportunity to provide feedback through a contact
form available for customers at our websites. To accommodate different
needs, including those of particularly vulnerable groups, such as customers
under the age of 18 as well more senior customers, we make sure that
customers can reach us through different communication channels, including
phone. Any customer feedback related to privacy will be considered in our
privacy policies and frameworks. The overall responsibility for ensuring that
customer engagement takes place, and that the results and feedback inform
our practices, lies with the companies’ local management teams.
We have systems in place for tracking and monitoring customer review
feedback, and we are currently in the process of improving and standardising
our group templates for internal reporting and follow-up of customer
concerns related to privacy issues, to be able to analyse the effectiveness of
our actions.
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PROCESSES TO REMEDIATE NEGATIVE IMPACTS
(S4-3)
Addressing negative impacts, especially those associated with privacy
concerns, is a priority for Komplett Group. No actual negative material impact
has been identified in 2024.
Our processes for handling customer data are robust, and we have
established channels for consumers and end-users to voice concerns. In
addition to the complaints form, as described in this chapter, we have a
whistleblower channel available to all customers where customers can raise
concerns anonymously without fear of retaliation. Our view, based on a high
frequency of usage, is that our customers are aware of and trust our channels
to voice concerns.
All potential breaches are assessed, and relevant cases are reported further
to the appropriate authority, such as the Norwegian Data Protection Authority
(Datatilsynet) and the Swedish Authority for Privacy Protections (IMY).
This contributes to detecting deviations faster and to initiating preventive
measures that increase the safety of our customers’ personal data.
In the case of material negative impact related to handling of personal data
because of a cyber-attack, this is handled by a third-party partner as well as by
internal experts on IT security.
>> For more information about our whistleblower policy, including how it
protects customers against retaliation, see G1-1
TAKING ACTION AND SETTING TARGETS
(MDR-A § 62) (MDR-T §§ 72, 81)
We highly value our customers and their privacy, continuously adopting and
refining our actions and targets. However, we have not yet set measurable
outcome-oriented targets and actions for the following reasons:
X We have prioritised conducting a privacy maturity analysis to establish a
solid foundation for future actions, targets, and roadmaps.
X Our focus has been on developing a new privacy policy, standardised
group templates for privacy follow-up, and a data-sharing agreement to
ensure compliance with all privacy regulations.
X With 2024 as our baseline year, we are gathering data to enable
meaningful tracking of progress toward our ambition of zero severe
privacy breaches.
As our data quality and privacy framework mature, we will reassess
and establish measurable targets to enhance consumer and end-user
protection through our future actions.
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GOVERNANCE INFORMATION
Komplett Group operates across various cultural environments, labour conditions, and risk landscapes. We are committed to responsible business
behaviour in our own operations and throughout the value chain. This means fostering responsibility by having appropriate policies and practices, not
tolerating fraud and corruption, ensuring a culture of respect, honesty, and fairness, and supporting transparency.
In this section, we cover the identified material governance topics: corporate culture and whistleblower protection.
Additional information on corporate governance is presented in our corporate governance report.
BUSINESS CONDUCT
Material ESRS topics Material ESRS sub-topics Part of the value chain where impact was material Impact materiality Financial materiality
G1: Business conduct
G1: Corporate culture Upstream Own operations Downstream Low High
G1: Protection of
whistleblowers
Upstream Own operations Downstream High High
Corporate culture relates to how Komplett Group establishes, develops and
promotes a strong culture with respect to business conduct. This sub-topic is
intrinsically related to protection of whistleblowers, and these sub-topics are thus
considered and described together. Komplett Group strives to act responsibly and
with integrity to ensure compliance with relevant laws and regulations.
Komplett Group has a risk-based approach to compliance, with risk
assessments conducted for its own operations. Identified risks are evaluated
and mitigated where appropriate. We have policies in place that strive to
ensure the right to speak up and hinder corruption and bribery. In addition,
our focus on business conduct impacts business partners and suppliers, for
example through our code of conduct.
Komplett Group can positively promote a strong culture when it comes
to business conduct. Strong business ethics increases the group’s ability
to impact employees, business partners and workers in the value chain,
which is particularly important for our private label products. We have
strong governance structures in place including the use of contractual
agreements and policies, as well as targeted actions related to topics such as
whistleblowing, corruption and bribery.
THE ROLE OF THE ADMINISTRATIVE, MANAGEMENT AND SUPERVISORY
BODIES
(ESRS2 GOV-1)
At Komplett Group, the board of directors is responsible for the oversight
of material matters, including business conduct, while the group CEO is
responsible for implementation and day-to-day management. Our code of
conduct, sustainability policy and corporate governance policy are approved
and owned by the board of directors, whereas the group CEO is responsible for
the implementation and compliance of the policies.
Komplett Group’s board of directors and group management possess expertise
in key areas such as business conduct, compliance, and governance, with
members who are specialised in areas like privacy and ethics. Moreover,
several board members have undergone training in ethical business conduct,
enhancing their oversight of compliance matters and contributing to a culture
of integrity within the organisation. In 2024 the board of directors and parts of
the group management participated in an ESG-training session covering new
regulations, board responsibilities, material topics, transition plan, taxonomy
and implementation plans.
>> For more details about the relevant expertise and sustainability-related
experience of our board of directors and group management, see ESRS 2 GOV-1
>> For additional information related to the board of directors and group
management, see the board and management presentation
Komplett Group’s corporate governance policy, updated in 2024, outlines the
group’s corporate governance principles based on the Norwegian Code of
Practice for Corporate Governance. The principles are designed to establish a
basis for good corporate governance. The way we are governed is vital to our
value creation over time and to the achievement of a sustainable profitability.
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BUSINESS CONDUCT POLICIES AND CORPORATE
CULTURE
(G1-1) (ESRS 2 MDR-P) (MDR-A §62)
Komplett Group has identified corporate culture as a material financial
opportunity and is committed to fostering a positive environment. Additionally,
we emphasise the importance of an effective whistleblowing mechanism, given
both our current positive impact and the financial risks that could arise if we
fail to adequately protect whistleblowers. We have decided not to report in full
on specific actions related to our governance aspects as we are in a process
of assessing the most effective resource allocation to optimise our efforts.
However, our policies, covering both our corporate culture and the protection
of whistleblowers, include our code of conduct, sustainability policy, supplier
code of conduct, anti-corruption and bribery policy, and whistleblower policy.
Komplett Group does not report on actions related to anti-corruption and
bribery this year as it is not material for reporting purposes. However, we have
launched a series of efforts to promote our corporate culture, whistleblower
protection and to capitalise on the financial opportunities that come from good
governance.
>> For more details about how we embed sustainability in our policies and
processes to manage material IRO’s, see “embedding sustainability in our
policies and processes”
Compliance culture
Promoting and upholding an ethical culture across the Komplett Group where
everyone feels comfortable speaking up and raising concerns, is important
for our employees and for our business. We focus our efforts on guiding the
business in making the right decisions and speaking up when situations fail to
meet our standards.
Compliance risk management
All operations at Komplett Group are assessed for compliance risks through
the Enterprise Risk Management process. Key risks with respect to business
conduct and corporate culture identified in 2024 were related to regulatory
compliance.
Compliance training
Mandatory onboarding sessions where our code of conduct, anti-corruption
and bribery and whistleblower policies are covered shall be provided to all
employees across our organisation and all employees must read and sign the
policies. In addition, employees can find information and guidance about our
standards and procedures for ethical business conduct on our subsidiaries’
intranet pages.
Whistleblowing
Our whistleblower channel is open to our customers and the public.
Furthermore, we expect employees and business partners to report suspected
violations of our code of conduct, other policies and procedures, or laws and
regulations, both related to our own operations and in our supply chain.
Komplett Group has an obligation to investigate all reports made, and all
notifications shall be treated confidentially, as regulated and further described
in our whistleblower policy.
Reports of misconduct are first received by a third party and then handled
by our internal whistleblower team. A whistleblower report can be submitted
via a dedicated web page, from any device and in any language. The reporter
can choose to remain anonymous. By telephone, the reporter can speak
with a specialist or leave a secure recorded voice message. Information
on how to report in the whistleblower system can be found on each of the
subsidiaries’ intranet page, and on bulletin boards in common areas. Komplett
Group prohibits any retaliation against whistleblowers and is committed to
implementing effective measures to safeguard them within the organisation.
In 2024, six cases were reported in our whistleblower channel.
WHISTLEBLOWER PRINCIPLES
Komplett Group has established a common policy and system for
whistleblowing, where the basic principles for handling reports are as follows:
X All reports are taken seriously
X All reports will be sufficiently investigated within reasonable time in a fair,
open minded and objective manner
X Confidentiality and information security
X Protection of whistleblowers
X Whistleblowers reporting in good faith will not be subject to reprisals
X Whistleblowers will get timely feedback and information about the process,
at the latest within three months of reporting
X Right to be informed of the nature and cause of the accusation against
oneself and to be heard
X Process documented in writing
Corporate culture and at-risk functions
Komplett Group actively promotes a culture of openness and transparency,
establishing accessible communication channels that encourage engagement
and direct interaction across the organisation. To support this, Komplett Group
facilitates organisation-wide townhall meetings, regular leadership check-ins,
employee surveys, and dedicated intranet channels, enabling employees to
voice concerns and participate in strategic discussions without fear of reprisal.
As part of a risk-based approach to business conduct, we recognise that
certain functions are more exposed to risks related to corruption and bribery.
Specifically, roles within procurement and supplier management, particularly
those engaging with suppliers in regions such as China, are considered at
higher risk. Komplett Group has implemented targeted safeguards through our
code of conduct and supplier code of conduct and provides regular training to
address and mitigate these risks effectively. Our employees in high-risk roles
have participated in training sessions on negotiations in 2024, which included
attention to compliance, ethics, and risk areas such as corruption and bribery.
| OUR WHISTLEBLOWER CHANNEL IS OPEN
TO OUR CUSTOMERS AND THE PUBLIC
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KOMPLETT ASA:
CORPORATE GOVERNANCE REPORT
Komplett Group considers good corporate governance to be a
prerequisite for value creation, trust from shareholders, and adequate
access to capital. To secure a sound and sustainable corporate
governance, Komplett Group considers it important to ensure good
and healthy business practices, reliable financial reporting, and
an environment of compliance based on applicable legislation and
regulations, across the group structure.
Komplett Group is required to report on corporate governance under section
2-9 of the Norwegian Accounting Act and the Norwegian Code of Practice for
Corporate Governance. The Accounting Act may be found (in Norwegian) at
www. lovdata.no. The Norwegian Code of Practice for Corporate Governance,
which was last revised on 14 October 2021, may be found at www.nues.no.
This statement of policy will be an item of business at Komplett ASA’s annual
general meeting on 7 May 2025. The company’s auditor has assessed whether
the information with regard to section 2-9 of the Accounting Act provided
in this statement is consistent with the information provided in the annual
financial statements. The auditor’s statement is attached to this annual report.
Corporate governance at Komplett Group shall be based on the following main
principles:
X Transparency. Communication with the company's shareholders,
stakeholders and other interest groups shall be based on transparency
and openness on issues relevant for the evaluation of the development and
position of the company.
X Independence. The relationship between the board of directors, executive
management and shareholders shall be based on independence principles.
Independence shall ensure that all decisions are made on an unbiased and
neutral basis.
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X Equal treatment. A fundamental objective for good corporate governance is
equal treatment and equal rights for all of the company's shareholders.
X Control and management. Sound control and corporate governance
mechanisms shall contribute to predictability and reduce the level of risk for
the company's shareholders, stakeholders and other interest groups.
A description of the company's guidelines for equality and diversity may be found
under "Our policies and principles" and "Own workforce" in the ESG section of this
annual report.
1. IMPLEMENTATION AND REPORTING ON CORPORATE GOVERNANCE
The board of directors at Komplett ASA actively adheres to good corporate
governance standards and will at all times ensure that Komplett Group
complies with the requirements of section 2-9 of the Accounting Act and
the Norwegian Code of Practice for Corporate Governance. This is done by
ensuring that the topic of good governance is an integral part of the decision-
making process in matters dealt with by the board. Komplett Group’s corporate
governance policy describes how Komplett Group complies with the Code
requirements and may be found at Komplett Group’s website.
The board of directors has provided this report on the company’s corporate
governance as referenced to in the directors’ report. The report covers every
section of the Code of Practice, and if the company does not fully comply with
the Code of Practice, the company has provided an explanation of the reason
for the deviation and what solution it has selected.
Deviations from the Code: None.
2. BUSINESS
Komplett Group’s objectives, as clearly defined in its articles of association,
are as follows:
The objective of the company is trade in computer equipment, electronics, and
other goods, and to participate in other companies and businesses.
The board of directors has defined clear objectives, strategies and risk profiles
for the company’s business activities such that the company creates value
for shareholders in a sustainable manner. When carrying out this work, the
board of directors has taken into account financial, social and environmental
considerations.
The group’s goals, strategies and risk profiles have been presented on page 33
of this report.
The board of directors evaluates the group’s goals, strategies and risk profiles
at least yearly.
Deviations from the Code: None.
3. EQUITY AND DIVIDENDS
The board of directors is mindful of maintaining an equity capital at a level
appropriate to the company’s objectives, strategy, and risk profile, and
continuously monitors the group’s capital situation.
At 31 December 2024, the group’s equity totalled NOK 2 581 million,
representing an equity ratio of 34.3 per cent compared with 37.2 per cent at the
end of 2023.
The board of directors has established and disclosed a clear and predictable
dividend policy for the group. Komplett Group targets stable growing dividends
year-on-year, and a pay-out ratio of 60-80 per cent of net profit adjusted for
one-off costs and special items. In recent years, investments and a challenging
market environment has not permitted dividend distributions.
Authorisations empowering the board of directors to increase the company’s
share capital or to purchase treasury shares are limited to defined purposes
and are granted for a period no longer than until the next general meeting.
These authorisations are further described under Share information on page 17
of this report.
Deviations from the Code: None.
4. EQUAL TREATMENT OF SHAREHOLDERS
Komplett ASA has one class of shares, and all shares carry the same rights in
the company.
If the board of directors resolves to issue new shares and deviate from existing
shareholders’ pre-emptive rights pursuant to an authorisation granted to the
board of directors, the stock exchange announcement issued in connection
with the share issue shall also include a justification for the deviation.
The company’s transactions in treasury shares shall be carried out through Oslo
Stock Exchange's trading platform at the prevailing trading price or by making
a public offer to all shareholders. If the company’s shares suffer from weak
liquidity, the board of directors shall take particular care even when making
purchases and sales through the stock exchange, in order to ensure equal
treatment of shareholders.
Deviations from the Code: None.
5. SHARES AND NEGOTIABILITY
The shares of the company are freely transferable and there are no restrictions
on any party’s ability to own or vote for shares in the company. No limitations on
transactions have been laid down in Komplett ASA’s articles of association.
Deviations from the Code: None.
6. GENERAL MEETINGS
Komplett Group seeks to ensure that as many shareholders as possible can
exercise their rights by participating in general meetings, and that the general
meeting is an effective meeting place for shareholders and the board of
directors. The annual general meeting is held every year before the end of May.
Notices of general meetings and related documents are made available on
Komplett Group’s website no later than 21 days prior to the date of the meeting.
Shareholders who wish to participate in the general meeting must give the
company notice no later than two working days prior to the general meeting.
The company facilitates the election of an independent chair of the general
meeting.
The nomination committee chair, the chair of the board and other members of
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the board of directors are present at general meetings, but normally not the
entire board. To date, no items of business at general meetings have made
this necessary. The CEO and CFO are normally present in order to reply to any
questions that may be raised.
Shareholders are given the opportunity to vote on each individual matter,
including the election of every single candidate to an office in the nomination
committee and on the board of directors.
Shareholders who are unable to attend the general meeting may also vote
in advance or by proxy. The proxy form is designed in such a way that voting
instructions can be given for each item of business that is to be considered.
Both the notice of the general meeting and Komplett Group’s website provide
further information regarding the use of proxies and shareholders’ right to
submit items of business for consideration at general meetings.
Under the first paragraph of article 8 in the articles of association, the board
of directors may decide that documents concerning items of business to be
considered at the general meeting are not to be sent to shareholders when the
documents are made available on the company’s website. This also applies to
documents which by law must be included in or attached to the notice of the
general meeting. A shareholder may nonetheless ask to be sent documents
pertaining to items of business to be considered at the general meeting.
Deviations from the Code: The Code advocates that all board members should
participate at the general meeting. However, if the agenda is such that it is not
considered necessary for every member to attend, not all Komplett ASA board
members will attend every time.
7. NOMINATION COMMITTEE
As laid out by the articles of association, Komplett ASA has a nomination
committee.
The general meeting elects the chair and members of the committee
and determines its remuneration. The general meeting has also adopted
instructions for the nomination committee, which may be found at Komplett
Group’s website.
The nomination committee consists of three members, who are elected
for a term of up to two years. The majority of the nomination committee
shall be independent from the company’s board of directors and executive
management.
The committee is tasked with submitting the following reasoned
recommendations to the general meeting:
X Recommend candidates for the election to the board of directors and the
nomination committee, and
X Recommend a suitable remuneration for the members of the board of
directors and the nomination committee.
The nomination committee’s recommendation of candidates to the board
of directors shall ensure that the board of directors is composed to comply
with legal requirements and principles of corporate governance and that they
represent a broad group of the company’s shareholders.
The rules of procedure for the nomination committee contain further
guidelines for the preparation and implementation of elections to the
nomination committee and the board of directors, as well as criteria for
eligibility, general requirements regarding recommendations, the number of
members in the committee and their term of service, and detailed procedural
rules for the work of the nomination committee.
The participants at the general meeting elected the following members for the
nomination committee:
X Sverre R. Kjær, chair, elected until the annual general meeting of 2026
X Nina Camilla Hagen, member, elected until the annual general meeting
of 2026
X Martin Bengtsson, member, elected until the annual general meeting
of 2026
Information and deadlines for submitting input and proposals to the
nomination committee are available at Komplett Group’s website.
Information regarding the composition of the nomination committee is posted
on Komplett Group’s website under “Investor Relations”.
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The composition of the nomination committee is intended to ensure that
the interests of all the shareholders are served and meets the requirement
of the Norwegian Code of Practice for Corporate Governance as regards
independence of the company’s management and board of directors. None
of the members of the nomination committee is a member of the board of
directors of Komplett Group ASA. Neither the general manager nor other senior
executives are members of the committee.
Deviations from the Code: None.
8. BOARD OF DIRECTORS: COMPOSITION AND INDEPENDENCE
The composition of the board of directors is intended to serve the interests of
all the shareholders and to meet the company’s need for expertise, capacity,
and diversity, while ensuring that the board can function effectively as a
collegiate body.
The board’s composition meets the requirements of the Norwegian Code of
Practice for Corporate Governance as regards board members’ independence
of the company’s executive management, main shareholders, and material
business relationships. At least two of the directors are defined as non-
independent of the company’s main shareholders.
All the directors are defined as independent of the company’s executive manage-
ment or material business relationships. There are few instances in which
directors are disqualified from considering board matters. Representatives of
the executive management are not members of the company’s board of directors.
Under article 5 of Komplett ASA’s articles of association, the company’s board of
directors shall consist of between 3 and 9 members, to be elected by the general
meeting. There are no other provisions in the articles of association governing
the appointment and replacement of directors.
Jo Olav Lunder was elected as the chair of the board by the general meeting in
May 2024 for a period until the annual general meeting in 2026. The members of
the board of directors have been elected for no longer than two years at a time.
In accordance with Komplett Group’s current system of corporate democracy,
two members of the board of directors of Komplett ASA are elected from the
group employees.
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A description of the expertise and background of the individual board members,
as well as information on their record of attendance at board meetings and
their independence, can be found on page 20 and page 124 of this annual report.
The directors are encouraged to hold shares in the company.
Deviations from the Code: None.
9. THE WORK OF THE BOARD OF DIRECTORS
The tasks of the board of directors are laid down in the rules of procedure for
the board of directors, which govern the board’s responsibilities and duties
and the administrative procedures of the board, including which matters
are subject to board consideration and rules for convening and holding
meetings.
The board’s rules of procedures also contain rules regarding the general
manager’s duty to inform the board about important matters and to ensure that
board decisions are implemented. There are also provisions intended to ensure
that company employees and other parties involved are adequately informed
of board decisions, and that the guidelines for preparing matters for board
consideration are followed. Other instructions to the board and clarification
of its duties, authorisations, and responsibilities in respect of the general
management are provided through routine communication.
The rules of procedure further establish that a director must not take part
in the consideration of or a decision on an issue that is of such importance
to himself or herself or to any related party that the member must be
considered to have an obvious personal or financial interest in the matter. It
is incumbent upon each director to consider on an ongoing basis whether
there are matters which, from an objective point of view, are liable to
undermine the general confidence in that board member’s independence
and impartiality, or which could give rise to conflicts of interest in
connection with the board of directors’ consideration of the matter. Such
matters must be discussed with the board chair. According to the group’s
code of conduct, employees must on their own initiative inform their superior
if they should recuse themselves from dealing with or if they have a conflict
of interest in connection with a matter, and consequently should not take
part in considering the matter.
The board of directors adopts an annual meeting and activity plan that covers
strategic planning, business issues, and oversight activities.
Transactions between the company and its shareholders, a shareholder’s
parent company, members of the board of directors, executive management
or closely associated persons to any such party that are deemed material
under the Norwegian Public Limited Liability Companies Act, are subject to
certain procedures and approval by the participants at the general meeting.
Furthermore, the board of directors is required to arrange an independent
auditor valuation of the transaction. In case such a material transaction
is entered into by a subsidiary of the company, a separate notice shall be
prepared and published at the company’s website. The company has adopted a
policy for related party transactions.
The board of directors has established two permanent board committees,
which are described in further detail below. These committees do not make
decisions but supervise the work of the company management on behalf of
the board and prepare matters for board consideration within their specialised
areas. In this preparatory process, the committees have the opportunity to
draw on company resources, and to seek advice and recommendations from
sources outside the company.
The remuneration committee
The remuneration committee members are Fabian Bengtsson (chair), Jan Ole
Stangeland and Susanne Ehnbåge. The composition of the committee meets
the requirements of the Norwegian Code of Practice for Corporate Governance
as regards independence, and all the committee members are considered to
be independent of the executive management. The mandate of the committee,
which is set out in the Instructions for the remuneration committee, is as
follows:
X Review the remuneration and benefits strategy for the members of the
executive management
X Review the performance of the chief executive officer (CEO) versus
the adopted objectives and recruitment policies, career planning, and
management development plans; and
X Prepare matters relating to other material employment issues in respect of
the executive management.
The committee will otherwise deal with special questions relating to
compensation for group employees insofar as the committee finds that
these questions concern matters of particular importance for the group’s
competitive position, corporate identity, recruitment ability, etc.
The audit committee
The audit committee members are Jan Ole Stangeland (chair), Fabian
Bengtsson and Ingvild Næss. The composition of the committee meets the
requirements of the Norwegian Code of Practice for Corporate Governance
as regards independence and competence. The nomination committee’s
recommendation of candidates for election to the board contains information
as to which board members satisfy the requirements as regards independence
and competence to sit on the audit committee. The committee’s mandate,
which is set out in the Instructions for the audit committee, is as follows:
X inform the board of the outcome of the company's external audit and the
assurance of the mandatory sustainability reporting and explain how the
external audit and assurance contributed to the integrity of financial and
sustainability reporting and what the role of the audit committee was in that
process;
X prepare the board's follow-up on the financial reporting process and the
sustainability reporting process, including the digital reporting process
and the process for identifying the information reported according
to sustainability reporting standards, and make recommendations or
suggestions to ensure its integrity;
X monitor the effectiveness of the company’s internal quality control and
risk management system regarding the company's financial reporting and
sustainability reporting, without breaching its independence;
X maintain ongoing contact with the company’s external auditors regarding
the audit of the annual accounts and the assurance of the sustainability
reporting, in particular monitoring the audit performance in light of issues
raised by the Financial Supervisory Authority in accordance with article 26
(6) of the Audit Regulation;
X review and monitor the independence of the company's external
auditor pursuant to the Norwegian Auditors Act, and in particular the
appropriateness of the provision of non-audit services to the company
in accordance with provisions set out therein, and article 5 of the Audit
Regulation;
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X assess the auditor's confirmation of independence and conduct discussions
as indicated in article 6 (2) of the Audit Regulation; and
X be responsible for the procedure for the selection of the company's external
auditor and recommend the external auditor to be appointed.
Without limiting the audit committee's responsibilities described above, a
more detailed description of the tasks applicable to the audit committee
is included in the Instruction for the audit committee. Adjustments to the
committee’s mandate will be made on an ongoing basis in line with new legal
requirements.
The board of directors’ evaluation
Each year, the board of directors carries out an evaluation of its own activities
and competence, and discusses improvements in the organisation and
implementation of its work, both at an individual level and as a group, in relation
to the goals that were set for its work. The results are made available to the
nomination committee.
Deviations from the Code: None.
10. RISK MANAGEMENT AND INTERNAL CONTROL
The board of directors is responsible for ensuring a sound internal control and
systems for risk management that are appropriate in relation to the extent and
nature of the company’s activities.
The board and the executive management are continuously monitoring the
group’s risk exposure and the group constantly strives to improve its internal
control processes. An active approach is taken to risk management, where an
annual review of the company’s most important areas of exposure to risk and
its internal control arrangements is presented and discussed with the board.
The risk assessment for 2024 is presented at page 33 of the annual report, and
a description of the use of financial instruments to reduce financial risk is
included in note 4 to the financial statements.
Deviations from the Code: None.
11. REMUNERATION OF THE BOARD OF DIRECTORS
Remuneration of directors shall be reasonable and reflect the board’s
responsibilities, expertise, time invested, and the complexity of the business.
Remuneration of the board of directors is disclosed in note 7 to the group
consolidated financial statements and in the remuneration report. The note
shows that remuneration of the directors is not linked to the group’s
performance and that no options have been granted to the shareholder-
elected directors.
Save for the board members elected from the employees, none of the board
directors have taken on specific assignments for the company other than their
board appointment. If they do, it will be disclosed to the full board, and the
board will approve remuneration for such additional duties.
Deviations from the Code: None.
12. SALARY AND OTHER REMUNERATION FOR EXECUTIVE PERSONNEL
The board of directors has adopted clear and understandable guidelines for
the remuneration of the executive management team. The guidelines have
been approved by the participants at the general meeting. The company’s
remuneration principles shall be designed to ensure responsible and
sustainable remuneration decisions that support the company’s business
strategy, long-term interests, and financial viability. Both the guidelines and
the yearly remuneration report may be found at Komplett Group’s website.
The board’s remuneration committee presents a recommendation concerning
the terms and conditions for the CEO to the board of directors and monitors
the general terms and conditions for other senior executives in the group.
The board assesses the CEO and his terms and conditions once a year. A
description of the remuneration of the executive management and the group’s
compensation and benefits policy, including the scope and design of bonus and
share-price-related programmes, is given in the board of directors’ statement
of guidelines for the remuneration of executive management approved by
the general meeting and the remuneration report; see note 7 to the group
consolidated financial statements.
The company’s arrangements in respect of salary and other remuneration
should help ensure the executive personnel and shareholders have convergent
interests and should be simple. Absolute caps have been set for performance-
related remuneration.
Deviations from the Code: None.
13. INFORMATION AND COMMUNICATIONS
It follows from Komplett Group’s IR policy that the company has guidelines
for the reporting of financial and other information based on openness and
taking into account the requirement for equal treatment of all participants in
the securities market. The IR policy also includes guidelines for the company’s
contact with shareholders other than through general meetings.
Komplett Group seeks to ensure that its accounting and financial reporting
inspires investor confidence. Komplett Group’s accounting procedures
are highly transparent. The board of directors’ audit committee monitors
company reporting on behalf of the board. Komplett Group strives to
communicate actively and openly with the market. The company’s annual
and quarterly reports contain extensive information on the various aspects
of the company’s activities. The company’s quarterly presentations are
webcasted live and may be found on Komplett Group’s website, along with
the quarterly and annual reports under “Investor Relations”. Komplett Group
aims to hold a capital markets day at regular intervals, on which occasion
the market is given an in-depth review of the group’s strategic direction and
operational development. A capital markets day was held in February 2024,
the presentation material and webcast from the event is available on Komplett
Group’s website.
All shareholders and other financial market players are treated equally as
regards access to financial information. The group’s investor relations
department maintains regular contact with company shareholders, potential
investors, analysts, and other financial market stakeholders. The board is
regularly informed of this activity. The financial calendar for 2025 may be
found on Komplett Group’s website.
Deviations from the Code: None.
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CORPORATEGOVERNANCE
14. TAKEOVERS
The board of directors will not seek to hinder or obstruct any takeover bid for
the company’s operations or shares. In the event of such a bid as discussed
in section 14 of the Norwegian Code of Practice for Corporate Governance,
the board of directors will, in addition to complying with relevant legislation
and regulations, seek to comply with the recommendations in the Code of
Practice.
This includes obtaining a valuation from an independent expert. On this basis,
the board will make a recommendation as to whether or not the shareholders
should accept the bid.
Deviations from the Code: The group has not found it appropriate to draw up
explicit guiding principles for Komplett Group’s conduct in the event of a takeover
bid. However, the board of directors will refer to and endorses the statement in
the Code of Practice regarding take overs and will act accordingly in the event
that a take-over bid is made.
15. AUDITOR
The general meeting elected Ernst & Young AS as the company’s auditor in
2023, after BDO had conducted the audit of the company since 2013.
The board of directors ensures that the external auditor submits the main
features of the plan for the audit of the company to the audit committee
annually.
The external auditor also takes part in the board’s discussions of the annual
financial statements. At these meetings the auditor should report on any
material changes in the company’s accounting principles and key aspects of
the audit, and comment on any material estimated accounting figures. There
have been no disagreements between the auditor and management on any
material issues in 2024.
Every year, the external auditor presents to the board an assessment of
risk, internal control procedures, including weaknesses, and proposals for
improvement. The board of directors ensures that relevant matters may be
discussed with the external auditor without the presence of the management.
The external auditor is also invited to all meetings of the board’s audit committee.
Komplett Group has established guidelines for the right of the general
management to use the external auditor for services other than auditing.
Responsibility for monitoring such use in detail has been delegated to the audit
committee. Details of the company’s use and remuneration of the external
auditor are disclosed in note 7 to the group consolidated financial statements.
The participants of the general meeting are informed about the group’s overall
remuneration to the auditor, broken down in accordance with statutory
requirements into remuneration for statutory auditing and remuneration
for other services. In connection with the auditor’s participation in the audit
committee and the board of directors’ consideration of the annual financial
statements, the auditor also confirms his independence.
Deviations from the Code: None.
APPENDIX: BOARD OF DIRECTORS’ DETAILS
Meeting attendance
Name Assignment
Year
elected
Independent of
company and
management
Independent
of major
shareholders
Remuneration
committee
Audit
committee
Board of
directors
Remuneration
committee
Audit
committee
Jo Olav Lunder Chair 2022 Yes No - - 11/11 - -
Susanne Ehnbåge Director 2023 Yes Yes Member - 11/11 3/3 -
Ingvild Næss Director 2023 Yes Yes - Member 11/11 - 8/8
Jan Ole Stangeland Director 2023 Yes No Member Chair 11/11 3/3 8/8
Fabian Bengtsson Director 2022 Yes No Chair Member 11/11 2/3 8/8
Emelie Victorin Worker
director
2024 - - - - 6/6 - -
Anders Odden Worker
director
2019 - - - - 11/11 - -
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CORPORATEGOVERNANCE
OTHER REPORTING
Komplett Group, which is listed on the Oslo Stock Exchange, must comply with Norwegian legislation, namely the Transparency Act and
the Equality and Anti-Discrimination Act. These statements are available on our website, together with our Climate Report for 2024.
TRANSPARENCY ACT ACCOUNT 2024
The Transparency Act supports the protection of basic human rights and
fair working conditions related to the production of goods and the provision
of services. Komplett ASA and four of its subsidiaries, Komplett Services
AS, Komplett Distribusjon AS, Ironstone AS and NetOnNet AB, are obliged by
the act to carry out and report on due diligence in accordance with the OECD
Guidelines for Multinational Enterprises on Responsible Business Conduct.
Webhallen AB, Komplett Services AB and Komplett Distribution AB are not
directly subject to the act. However, all activities within Komplett Group are
assessed as part of the group’s due diligence. The Transparency Act Account
for 2024 gives an overview of the companies' ongoing work to meet their
responsibilities within their own operations, with their business partners and
throughout their supply chain.
>>Read more about Transparency Act Account 2024
EQUALITY AND ANTI-DISCRIMINATION STATEMENT 2024
The act requires Norwegian companies to disclose information on gender
equality and anti-discrimination. The act applies to Komplett Services AS,
and therefore the Komplett Services related numbers and statements are
disclosed in this report. Further, information and numbers regarding Komplett
Group in total are disclosed in our Sustainability statement.
>>Read more about Equality and Anti-Discrimination Statement 2024
CLIMATE REPORT 2024
The Sustainability statement provides a summary of Komplett Group's
greenhouse gas (GHG) emissions. In addition, we publish a climate report,
which explains and accounts for our emissions, estimations, calculations and
data capture in more detail. Tracking our GHG emissions is a vital part of our
climate change strategy, helping to understand our impacts and identify areas
for reducing GHG emissions. It also allows us to compare our performance and
monitor progress over time.
>> Read more about GHG emissions in our Climate Report 2024
OPENINACR OBATREADER
FORBET TERNAVIGATION
KOMPLETT SERVICES AS
EQUALITY AND ANTI-DISCRIMINATION STATEMENT 2024
OPENINACR OBATREADER
FORBET TERNAVIGATION
CLIMATE REPORT 2024
OPENINACR OBATREADER
FORBET TERNAVIGATION
TRANSPARENCY ACT ACCOUNT 2024
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CORPORATEGOVERNANCE
STATEMENT FROM THE BOARD OF DIRECTORS
We confirm that the financial statements for the period 1 January up to and including 31 December 2024 have,
to the best of our knowledge, been prepared in accordance with applicable accounting standards and give a
true and fair view of the assets, liabilities, financial position and profit or loss of the company and the group as a
whole, and that the board of directors’ report includes a fair review of the development and performance of the
business and the position of the company and the group as a whole, together with a description of the principal
risks and uncertainties that they face.
Sandefjord, 20 March 2025
Board of directors, Komplett ASA
Jo Olav Lunder
Chair
Ingvild Næss
Director
Jan Ole Stangeland
Director
Fabian Bengtsson
Director
Susanne Ehnbåge
Director
Anders Odden
Worker director
Emelie Victorin
Worker director
Jaan Ivar Semlitsch
CEO
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CORPORATEGOVERNANCE
FINANCIAL STATEMENTS
THIS IS KOMPLETT GROUP
Komplett Group at a glance.............................................................4
Key figures ......................................................................................5
Letter from the CEO ........................................................................7
Our business segments ...................................................................9
Consumer trends .......................................................................... 13
Strategic and financial roadmap .................................................. 14
Value chain .................................................................................... 15
Community engagements ............................................................. 16
Share information ..........................................................................17
DIRECTORS’ REPORT
Board and management presentation ......................................... 20
Board of directors’ statement ......................................................24
Risk and risk management ............................................................33
Sustainability statement ..............................................................38
General information ..............................................................................39
Environmental information ...................................................................70
Social information .............................................................................. 100
Governance information ...................................................................... 116
Corporate governance report ...................................................... 118
Other reporting ........................................................................... 125
FINANCIAL STATEMENTS
Overview of the financial statements ......................................... 128
Consolidated financial statements ............................................. 129
Consolidated notes ..................................................................... 133
Komplett ASA financial statements ........................................... 162
Komplett ASA notes .................................................................... 166
Independent auditor’s report ...................................................... 173
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FINANCIALSTATEMENTS
Consolidated statement of comprehensive income ............................ 129
Consolidated statement of financial position ...................................... 130
Consolidated statement of cash flows .................................................. 131
Consolidated statement of changes in equity ....................................... 131
Notes to the consolidated financial statements ...................................133
Note 01 General information ................................................................... 133
Note 02 Critical accounting estimates and judgements .......................... 133
Note 03 Accounting policies .................................................................... 134
Note 04 Financial instruments – risk management ................................ 138
Note 05 Segment Information .................................................................. 141
Note 06 Revenues from contracts with customers ................................. 143
Note 07 Employee benefit expenses and audit fees ................................ 145
Note 08 Finance income and expenses ................................................... 148
Note 09 Income tax.................................................................................. 148
Note 10 Earnings per share ..................................................................... 149
Note 11 Intangible assets ........................................................................ 150
Note 12 Property, plant, and equipment .................................................. 152
Note 13 Investments in associates .......................................................... 152
Note 14 Trade and other receivables ....................................................... 153
Note 15 Inventories ................................................................................. 154
Note 16 Cash and cash equivalents ......................................................... 154
Note 17 Share capital, shareholder information, and dividend ............... 154
Note 18 Share option plan ....................................................................... 155
Note 19 Leases .........................................................................................157
Note 20 Other current liabilities and long-term debt ............................... 158
Note 21 Provision for service and guarantee obligations ........................ 158
Note 22 Notes supporting the cash flows ................................................ 158
Note 23 Pledges and guarantees ............................................................. 159
Note 24 Related party transactions......................................................... 160
Note 25 Consolidated companies ............................................................ 160
Note 26 Events after the reporting date ................................................... 161
Statement of profit and loss – Komplett ASA ...................................... 162
Statement of financial position – Komplett ASA ................................. 163
Statement of cash flows – Komplett ASA ............................................. 164
Statement of changes in equity – Komplett ASA ................................. 164
Notes to the financial statements – Komplett ASA ...............................166
Note 01 Accounting principles ................................................................ 166
Note 02 Corporate changes ......................................................................167
Note 03 Investments in subsidiaries and associated companies .............167
Note 04 Cash and cash equivalents ......................................................... 168
Note 05 Group balances (receivables and payables) .............................. 168
Note 06 Income tax ................................................................................ 169
Note 07 Pledges and guarantees ........................................................... 170
Note 08 Employee benefit expenses ...................................................... 170
Note 09 Items that are aggregated in the financial statement ................ 171
Note 10 Financial market risk .................................................................. 171
Alternative performance measures (APM) ............................................... 172
Independent auditor’s report .................................................................173
FINANCIALSTATEMENTS OVERVIEW
KOMPLETTGROUP KOMPLETTASA
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FINANCIALSTATEMENTS
CONSOLIDATED STATEMENT OF COMPREHENSIVE INCOME
FOR THE YEAR ENDED 31 DECEMBER
Amounts in NOK million | Note | 2024 | 2023 |
| Operating revenues | |||
Revenues from sale of goods | |||
Other operating revenues | |||
Total revenues | 6 | ||
| Operating expenses | |||
Cost of goods sold | 15 | ( | ( |
Employee benefit expenses | 7 | ( | ( |
Depreciation and amortisation expense | 11, 12, 19 | ( | ( |
Impairment | 11, 12, 19 | ( | |
Other operating expenses | 19, 21 | ( | ( |
Total operating expenses | ( | ( | |
Operating profit | ( | ( | |
| Finance income and expenses | |||
Share of results of equity-accounted investments | 13 | ||
Finance income | 8 | ||
Finance expenses | 8, 19 | ( | ( |
Net finance income and expenses | ( | ( | |
Profit before tax | 5 | ( | ( |
Tax expense | 9 | ||
Profit for the year | ( | ( |
Amounts in NOK million | Note | 2024 | 2023 |
| Other comprehensive income | |||
| Items that may be reclassified to profit or loss: | |||
Exchange gains arising on translation of foreign operations | |||
Total comprehensive income | ( | ( | |
| Profit for the year attributable to: | |||
Owners of the parent | ( | ( | |
Total | ( | ( | |
| Total comprehensive income attributable to: | |||
Owners of the parent | ( | ( | |
Total | ( | ( | |
| Earnings per share | |||
Continued operation (basic and diluted) - in NOK | 10 | ( | ( |
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FINANCIALSTATEMENTS – KOMPLETT GROUP
CONSOLIDATED STATEMENT OF FINANCIAL POSITION
AT 31 DECEMBER
Amounts in NOK million | Note | 31.12.2024 | 31.12.2023 |
| NON-CURRENT ASSETS | |||
| Intangible assets | |||
Goodwill | 11 | ||
Software | 11 | ||
Customer relationships | 11 | ||
Brand names | 11 | ||
Total intangible assets | |||
| Property, plant, and equipment | |||
Right-of-use assets | 3, 19 | ||
Leasehold improvements | 12 | ||
Machinery and fixtures | 12 | ||
Total property, plant, and equipment | |||
| Other non-current assets | |||
Deferred tax asset | 9 | ||
Investments in equity-accounted associates | 13 | ||
Other receivables | 4, 14 | ||
Total other non-current assets | |||
Total non-current assets | |||
| CURRENT ASSETS | |||
Inventories | 15 | ||
Total inventories | |||
| Other current assets | |||
Trade receivables - regular | 4, 14 | ||
Trade receivable from deferred payment arrangements | 4, 14 | ||
Other current receivables | 4, 14, 19 | ||
Total other current assets | |||
| Cash and cash equivalents | |||
Cash and cash equivalents | 4, 16 | ||
Total cash and cash equivalents | |||
Total current assets | |||
Total assets |
Amounts in NOK million | Note | 31.12.2024 | 31.12.2023 |
| EQUITY | |||
Share capital | 17 | ||
Share premium | 17 | ||
Other equity | ( | ( | |
Total equity | |||
| LIABILITIES | |||
| Non-current liabilities | |||
Deferred tax liabilities | 9 | ||
Provisions and other liabilities | |||
Interest-bearing loans and borrowings | 4, 20 | ||
Non-current lease liabilities | 19, 20, 23 | ||
Other non-current liabilitiesties | 20 | ||
Total non-current liabilities | |||
| Current liabilities | |||
Short-term loans | 4, 16, 22, 23 | ||
Trade payables | 4 | ||
Public duties payable | 4 | ||
Current income tax | 9 | ||
Current lease liabilities | 3, 19 | ||
Other current liabilities | 4, 6, 20, 21 | ||
Total current liabilities | |||
Total liabilities | |||
Total equity and liabilities |
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FINANCIALSTATEMENTS – KOMPLETT GROUP
CONSOLIDATED STATEMENT OF CASH FLOWS
FOR THE YEAR ENDED 31 DECEMBER
Amounts in NOK million | Note | 2024 | 2023 |
| Cash flows from operating activities | |||
Profit before income tax | ( | ( | |
Profit/(loss) on discontinued operations (before tax) | |||
Profit for the year | ( | ( | |
Income taxes paid | ( | ( | |
Depreciation and amortisation expense | 11, 12, 19 | ||
Impairment | |||
Share of post-tax profits from equity accounted investments | 13 | ( | ( |
Finance items | 8 | ||
Changes in inventories, trade payables, and trade receivables | ( | ||
Currency effects | |||
Other changes in accruals | |||
Net cash flows from operating activities | |||
| Investing activities | |||
Investments in property, plant, and equipment | 11, 12 | ( | ( |
Dividend from associated company | |||
Net cash used in investing activities | ( | ( | |
| Financing activities | |||
Proceeds from loans and borrowings | 20, 22 | ||
Repayment of loans and borrowings | 20, 22 | ( | ( |
Changes in bank overdrafts | 22 | ( | |
Principal paid on lease liabilities | 19 | ( | ( |
Interest paid on lease liabilities | 8, 19 | ( | ( |
Interest paid on loans and overdrafts | 8 | ( | ( |
Issue of share capital | |||
Net cash used in financing activities | ( | ( | |
Net increase in cash and cash equivalents | |||
Cash and cash equivalents at beginning of year | 16 | ||
Cash and cash equivalents at end of year | 16 |
CONSOLIDATED STATEMENT OF CHANGES IN EQUITY
FOR THE YEAR ENDED 31 DECEMBER
| Foreign | ||||||
| Share | Share | Other | currency | Total | ||
Amounts in NOK million | Note | capital | premium | equity | changes | equity |
At 1 January 2023 | ( | |||||
Profit for the year | ( | ( | ||||
Other comprehensive Income | ||||||
Total comprehensive Income for the year | ( | ( | ||||
Long-term incentive programme | ||||||
Issue of share capital | 17 | |||||
Contributions by and distributions to owners | ||||||
At 31 December 2023 | ( | |||||
At 1 January 2024 | ( | |||||
Profit for the year | ( | ( | ||||
Other comprehensive Income | ||||||
Total comprehensive income for the year | ( | ( | ||||
Long-term incentive programme | 18 | |||||
Issue of share capital | 17 | |||||
Contributions by and distributions to owners | ||||||
At 31 December 2024 | ( |
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FINANCIALSTATEMENTS – KOMPLETT GROUP
Sandefjord, 20 March 2025
Board of directors, Komplett ASA
Jo Olav Lunder
Chair
Ingvild Næss
Director
Jan Ole Stangeland
Director
Fabian Bengtsson
Director
Susanne Ehnbåge
Director
Anders Odden
Worker director
Emelie Victorin
Worker director
Jaan Ivar Semlitsch
CEO
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FINANCIALSTATEMENTS – KOMPLETT GROUP
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
133 KOMPLETT ASA
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|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
NOte 03 ACCOUNTING POLICIES
NOTE 3.1 ACCOUNTING POLICIES
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|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
Factoring
Komplett has entered factoring arrangements to improve
its working capital. Under these arrangements, the com-
panies sell certain accounts receivable and receive
immediate payment.
The group utilises mostly non-recourse factoring where
the factor assumes the rights to the cash flow, the risk,
and rewards and where the receivable is derecognised in
accordance with IFRS 9.
Recourse factoring agreement does not meet the crite-
ria of derecognition according to IFRS 9, and the receiva-
ble is booked as a regular accounts receivable. In case of
recourse factoring, any pre-payments from the factor are
booked as debt.
As of 31 December 2024, there are no recourse factoring
agreements with pre-payments from the factor.
The charges from the factor are split between finance
and operational. Client limit fees and finance/interest
cost are booked as financial cost. The fixed administra-
tion fee per invoice is booked as an operational cost.
Classification of balance sheet items
Current assets and current liabilities include items due
for payment within a year after the balance sheet date,
as well as items that relates to the operating cycle. Other
items are classified as fixed asset/long-term liabilities.
Receivables from deferred payment are considered as
being part of the operating cycle, and consequently clas-
sified as a current asset.
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|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
136 KOMPLETT ASA
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ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
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|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
(All figures in NOK million) | 2024 |
| Currency | |
EUR | +/- 240 |
USD | +/- 110 |
TOTAL | +/- 350 |
| Functional | ||
| 31.12.2024 | currency | |
(All figures in local currencies in million) | NOK | SEK |
| Exposed currency | ||
NOK | N/A | 107.1 |
SEK | (41.1) | N/A |
EUR | 6.9 | 8.3 |
USD | (6.8) | 16.3 |
DKK | 2.4 | - |
GBP | (1.9) | 12.2 |
PLN | (2.0) | - |
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|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
| 0-6 | 6-12 | 1-3 | 3-5 | After 5 | ||
Amounts in NOK million | Total | months | months | years | years | years |
| 31 December 2024 | ||||||
Long-term loans 1) | 995 | 33 | 33 | 930 | - | - |
Other non-current liabilities 1) | 278 | 4 | 3 | 271 | - | - |
Short-term loans | - | - | - | - | - | - |
Trade payables | 2 073 | 2 073 | - | - | - | - |
Public duties payable | 490 | 490 | - | - | - | - |
Other short-term liabilities 1) | 491 | 415 | 77 | - | - | - |
Total | 4 328 | 3 015 | 113 | 1 200 | - | - |
| After 5 | ||||||||
Amounts in NOK million | Total | 0-6 months | 6-12 months | 1-3 years | 3-5 years | years | ||
| 31 December 2023 | ||||||||
Long-term loans 1) | 922 | 31 | 31 | 860 | - | - | ||
Other non-current liabilities 1) | - | - | - | - | - | - | ||
Short-term loans | - | - | - | - | - | - | ||
Trade payables | 1 563 | 1 563 | - | - | - | - | ||
Public duties payable | 409 | 409 | - | - | - | - | ||
Other short-term liabilities 1) | 862 | 556 | 306 | - | - | - | ||
Total | 3 757 | 2 559 | 337 | 860 | - | - |
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|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
| Financial | Financial | |||
| Financial | assets at | Financial | liabilities at | |
| assets | amortised | liabilities | amortised | |
| Amounts in NOK million | at fair value | cost | at fair value | cost |
| Assets | ||||
Non-current receivables | - | 9 | - | - |
Trade receivables | - | 153 | - | - |
Trade receivables - deferred payment arrangements | - | 27 | - | - |
Other current receivables | - | 709 | - | - |
Cash and cash equivalents | - | 726 | - | - |
| Liabilities | ||||
Long-term loan | - | - | - | 800 |
Other non-current liabilities | - | - | - | 263 |
Provisions and other liabilities | - | - | 34 | 11 |
| Trade payable, public duties payable, and other current | ||||
liabilities | - | - | - | 3 053 |
Forward currency contracts 1) | 2 | - | - | - |
| Financial | Financial | |||
| Financial | assets | Financial | liabilities | |
| assets | at amortised | liabilities | at amortised | |
| Amounts in NOK million | at fair value | cost | at fair value | cost |
| Assets | ||||
Non-current receivables | - | 9 | - | - |
Trade receivables - regular | - | 245 | - | - |
Trade receivables - deferred payment arrangements | - | 79 | - | - |
Other current financial asset | - | 660 | - | - |
Cash and cash equivalents | - | 230 | - | - |
| Liabilities | ||||
Long-term loans | - | - | - | 800 |
Other non-current liabilities | - | - | - | - |
Provisions and other liabilities | - | - | 37 | 11 |
| Trade payable, public duties payable, and other current | ||||
liabilities | - | - | - | 2 819 |
Forward currency contracts 1) | 16 | - | - | - |
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|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
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|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
| Profit and loss - 2023 | ||||||
Amounts in NOK million | B2C | B2B | Distribution | Other | IFRS 16 | Total |
| Operating income | ||||||
Revenues from contract with customers | 11 008 | 1 472 | 3 061 | (0) | - | 15 541 |
Other operating revenues | 188 | 110 | 17 | 5 | 0 | 320 |
Total operating income | 11 195 | 1 583 | 3 078 | 5 | 0 | 15 861 |
| Operating expenses | ||||||
Cost of goods sold | (9 438) | (1 302) | (2 909) | 0 | - | (13 650) |
Employee benefit expenses | (770) | (83) | (61) | (101) | - | (1 014) |
Depreciation and amortisation | (78) | (9) | (7) | (43) | (198) | (335) |
Impairment | - | - | - | (983) | - | (983) |
Other operating expenses | (759) | (89) | (50) | (80) | 214 | (765) |
Total operating expenses | (11 045) | (1 482) | (3 029) | (1 206) | 16 | (16 746) |
Operating result | 150 | 100 | 50 | (1 201) | 16 | (885) |
| Financial income and financial expenses | ||||||
Share of profit or loss from associates | - | - | - | 3 | - | 3 |
Financial income | - | - | - | 124 | - | 124 |
Financial expenses | - | - | - | (271) | (19) | (291) |
Net financial items | - | - | - | (145) | (19) | (164) |
Profit or loss before taxes | 150 | 100 | 50 | (1 347) | (3) | (1 050) |
Amounts in NOK million | 2024 | 2023 |
Norway | 906 | 968 |
Sweden | 2 885 | 2 881 |
Total | 3 791 | 3 849 |
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|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
| Disaggregation based on type of customers - 2024 | |||||
Amounts in NOK million | B2C | B2B | Distribution | Other | Total |
Sale to consumers (B2C) | 10 877 | - | - | - | 10 877 |
Sale to corporates (B2B) | - | 1 519 | - | - | 1 519 |
Sale to resellers (Distribution) | - | - | 2 907 | - | 2 907 |
Other | - | - | - | (2) | (2) |
Total operating income | 10 877 | 1 519 | 2 907 | (2) | 15 301 |
| Revenues based on geographic location of customers - 2024 | |||||
Amounts in NOK million | B2C | B2B | Distribution | Other | Total |
Norway | 3 214 | 1 353 | 2 734 | (2) | 7 299 |
Sweden | 7 358 | 166 | 173 | - | 7 698 |
Denmark | 305 | - | - | - | 305 |
Total operating income | 10 877 | 1 519 | 2 907 | (2) | 15 301 |
| Revenues by product or service - 2024 | |||||
Amounts in NOK million | B2C | B2B | Distribution | Other | Total |
Sale of goods | 10 636 | 1 392 | 2 904 | - | 14 932 |
Consumer finance | 127 | 0 | - | - | 127 |
Commision from insurance | 74 | 1 | - | - | 76 |
Services | 40 | 126 | 3 | - | 168 |
Other | 0 | - | - | -2 | (2) |
Total operating income | 10 877 | 1 519 | 2 907 | (2) | 15 301 |
| Disaggregation based on type of customers - 2023 | |||||
Amounts in NOK million | B2C | B2B | Distribution | Other | Total |
Sale to consumers (B2C) | 11 195 | - | - | - | 11 195 |
Sale to corporates (B2B) | - | 1 583 | - | - | 1 583 |
Sale to resellers (Distribution) | - | - | 3 078 | - | 3 078 |
Other | - | - | - | 5 | 5 |
Total operating income | 11 195 | 1 583 | 3 078 | 5 | 15 861 |
| Revenues based on geographic location of customers - 2023 | |||||
Amounts in NOK million | B2C | B2B | Distribution | Other | Total |
Norway | 3 150 | 1 411 | 2 883 | 5 | 7 449 |
Sweden | 7 750 | 172 | 195 | - | 8 117 |
Denmark | 295 | - | - | - | 295 |
Total operating income | 11 195 | 1 583 | 3 078 | 5 | 15 861 |
| Revenues by product or service - 2023 | |||||
Amounts in NOK million | B2C | B2B | Distribution | Other | Total |
Sale of goods | 11 008 | 1 472 | 3 061 | - | 15 541 |
Consumer finance | 112 | 1 | - | - | 113 |
Commision from insurance | 67 | 1 | 15 | - | 83 |
Services | 8 | 109 | 2 | - | 119 |
Other | - | - | - | 5 | 5 |
Total operating income | 11 195 | 1 583 | 3 078 | 5 | 15 861 |
143 KOMPLETT ASA
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ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
| Contract balances for contracts with customers | ||
Amounts in NOK million | 2024 | 2023 |
Net refund liabilities | 9 | 8 |
Customer loyalty programme | 6 | 9 |
Gift certificates & vouchers | 27 | 28 |
Total | 42 | 45 |
144 KOMPLETT ASA
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ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
| Audit fees to the auditors in the group entities is as follows (excluding VAT): | ||
Amounts in NOK million | 2024 | 2023 |
Statutory audit | 5.0 | 5.3 |
Other assurance services 1) | 1.1 | 0.2 |
Other non-assurance services | 0.2 | 0.3 |
Total | 6.3 | 5.8 |
| Employee benefit expenses: | ||
Amounts in NOK million | 2024 | 2023 |
Salaries | 666 | 649 |
Social security expenses | 179 | 183 |
Contribution to pension schemes | 48 | 47 |
Fees for external staff | 90 | 84 |
Share option plan (see note 18) | 8 | 5 |
Bonuses | 11 | 28 |
Other expenses | 11 | 17 |
Total | 1 013 | 1 014 |
The number of full-time equivalents that has been employed during the financial year: | 1 157 | 1 203 |
145 KOMPLETT ASA
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|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
Key management compensation | 2024 | 2023 | ||||||||||||
| Extra- | Value of | Extra- | Value of | |||||||||||
| Bonuses | ordinary | Other | options | Bonus | ordinary | Other | options | |||||||
Amounts in NOK million | Salary | earned | items | Pension | benefits | granted | Total | Salary | earned | items | Pension | benefits | granted | Total |
Jaan Ivar Semlitsch, group CEO | 6.76 | - | - | 1.34 | 0.19 | 4.13 | 12.41 | 5.78 | 2.00 | - | 1.10 | 0.18 | 2.52 | 11.59 |
Thomas William Scobie Røkke, group CFO | 3.87 | 0.58 | - | 0.65 | 0.47 | 2.36 | 7.93 | 3.04 | 0.97 | - | 0.50 | 0.40 | 1.64 | 6.56 |
Andreas Westgaard, group CCO | 3.95 | 0.59 | - | 0.66 | 0.19 | 2.41 | 7.81 | 1.90 | 0.61 | - | 0.26 | 0.09 | 1.52 | 4.39 |
Markus Solvik, group CSO | 2.43 | 0.36 | - | 0.31 | 0.19 | 1.00 | 4.29 | 1.71 | 0.86 | - | 0.19 | 0.00 | 0.88 | 3.64 |
Kristin H Torgersen, group CHRO | 2.33 | 0.35 | - | 0.29 | 0.16 | 0.96 | 4.08 | 2.24 | 0.85 | - | 0.27 | 0.16 | 2.74 | 6.26 |
Erlend Stefansson, managing director Komplett Services | 3.12 | 0.46 | - | 0.47 | 0 .19 | 1.29 | 5.53 | 2.73 | 1.01 | - | 0.39 | 0.23 | 1.16 | 5.52 |
Josefin Dalum, managing director NetOnNet | 2.52 | 0.37 | - | 0.88 | 0.08 | 0.99 | 4.83 | 0.20 | 0.00 | - | 0.13 | 0.01 | - | 0.33 |
Trygve Hillesland, managing director Webhallen | 2 .12 | 0.33 | - | 0.24 | 0.20 | 0.91 | 3.80 | - | - | - | - | - | - | 0.00 |
Anders Torell, managing director Webhallen | 0.25 | - | - | 0.05 | 0.01 | 0.00 | 0.30 | 3.04 | 0.66 | - | 0.53 | 0.08 | 1.88 | 6.20 |
Roger Sandberg, group procurement officer | - | - | - | - | - | - | - | 1.17 | 0.00 | 2.07 | 0.37 | 0.07 | 2.66 | 6.34 |
Susanne Holmstrøm, managing director NetOnNet | - | - | - | - | - | - | - | 3.49 | 0.00 | 3.34 | 0.96 | 0.11 | 0.00 | 7.9 0 |
Martin Klafstad, managing director Komplett | - | - | - | - | - | - | - | 0.33 | 0.00 | - | 0.00 | 0.00 | 0.00 | 0.33 |
Trine L Jensen, COO/CIO | - | - | - | - | - | - | - | 0.58 | 0.00 | - | 0.02 | 0.06 | 1.88 | 2.53 |
Lars Olav Olaussen, group CEO | - | - | - | - | - | - | - | 3.00 | 0.00 | 2.40 | 0.53 | 0.19 | 0.00 | 5.75 |
Krister Pedersen, group CFO | - | - | - | - | - | - | - | 0.40 | 0.00 | 1.20 | 0.01 | 0.01 | 0.00 | 1.62 |
Total | 27.34 | 3.04 | - | 4.88 | 1.67 | 14.05 | 50.97 | 29.60 | 6.96 | 9.01 | 5.26 | 1.61 | 16.89 | 68.96 |
Key management - share options | Opening | Average exercise | Ending | Average exercise | Average | |||
balance | Granted | Forfeited | Exercised | price (A) | balance | price (B) | maturity | |
Jaan Ivar Semlitsch, group CEO | 500 000 | 1 172 279 | - | - | - | 1 672 279 | 11.73 | 3.99 |
Thomas William Scobie Røkke, group CFO | 361 049 | 670 939 | - | - | - | 1 031 988 | 11.49 | 4.03 |
Andreas Westgaard, group CCO | 415 781 | 685 332 | - | - | - | 1 101 113 | 10.98 | 4.07 |
Markus Solvik, group CSO | 193 864 | 284 484 | - | - | - | 478 348 | 11.79 | 3.98 |
Kristin H Torgersen, group CHRO | 502 810 | 272 773 | - | - | - | 775 583 | 14.56 | 3.70 |
Erlend Stefansson, managing director Komplett Services | 254 192 | 365 975 | - | - | - | 620 167 | 11.81 | 3.98 |
Josefin Dalum, managing director NetOnNet | - | 281 209 | - | - | - | 281 209 | 9.59 | 4.36 |
Trygve Hillesland, managing director Webhallen | - | 258 059 | - | - | - | 258 059 | 9.59 | 4.36 |
Anders Torell, managing director Webhallen | 313 352 | - | (313 352) | - | N/A | - | N/A | N/A |
Total | 2 541 048 | 3 991 050 | (313 352) | - | 6 218 746 | - | - |
146 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
| Compensation to the board of directors: | ||||
Amounts in NOK million | Role | Committee | 2024 | 2023 |
Jo Lunder (2022-2024) | Chair | Remuneration | 0.63 | 0.63 |
Lars B Thoresen (2019-2023) | Director | Audit | - | 0.20 |
Sarah Willand (2021-2023) | Director | Remuneration | - | 0.19 |
Jennifer Geun Koss (2020-2023) | Director | Audit | - | 0.17 |
Susanne Ehnbåge (2023-2025) | Director | Remuneration | 0.48 | 0.24 |
Jan Ole Stangeland (2023-2025) | Director | Audit and remuneration | 0.57 | 0.33 |
Ingvild Næss (2023-2025) | Director | Audit | 0.45 | 0.26 |
Fabian Bengtsson (Jun 2022-2024) | Director | Audit and remuneration | 0.63 | 0.72 |
Anders Odden (2019-2025) | Worker director | - | 0.16 | 0.14 |
Emelie Victorin (2024-2025) | Worker director | - | 0.10 | - |
Nora Eldås (2021-2023) | Worker director | - | - | 0.05 |
Anna Fernmo (2021-2024) | Worker director | - | 0.07 | 0.10 |
Sverre R. Kjær (2021-2026) | - | Nomination | 0.08 | 0.08 |
Karin B Orgland (2021-2023) | - | Nomination | - | 0.04 |
Nina C. Hagen (2021-2026) | - | Nomination | 0.04 | 0.04 |
Martin Bengtsson (2023-2026) | - | Nomination | 0.04 | - |
Total | 3.23 | 3.18 |
| Shares held by group management and board members at 31 December 2024: | |
| Number of shares | |
Jaan Ivar Semlitsch, group CEO | 180 000 |
Andreas Westgaard, group CCO | 158 147 |
Kristin H Torgersen, group CHRO | 11 835 |
Erlend Stefansson, managing director Komplett Services | 50 847 |
Trygve Hillesland, managing director Webhallen | 45 000 |
Jo Olav Lunder, chair (Cigalep AS) | 391 777 |
Jan Ole Stangeland, director | 76 296 |
Fabian Bengtsson, director (SIBA Invest AB) | 55 581 404 |
Total | 56 495 306 |
147 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
Amounts in NOK million | 2024 | 2023 |
Interest income | 11.7 | 8.6 |
Foreign exchange gains | 2.2 | - |
Other finance income | 0.1 | 0.1 |
Total financial income | 14.0 | 8.7 |
Amounts in NOK million | 2024 | 2023 |
Interest on debts and borrowings | 120.3 | 116.0 |
Interest on leases | 22.6 | 19.3 |
Foreign exchange losses | 0.4 | 2.0 |
Other finance expenses | 41.4 | 38.5 |
Total finance expenses | 184.7 | 175.9 |
Amounts in NOK million | 2024 | 2023 |
Profit before tax | (236) | (1 050) |
Non taxable items 1) | 31 | 974 |
Use of tax loss carried forward | (4) | (54) |
Changes in temporary differences | 66 | 131 |
Taxable income | (144) | 1 |
| Income tax expense: | ||
Current income tax | - | 3 |
| Correction of previous years current income taxes | (3) | 0 |
Changes in deferred tax | (41) | (15) |
Total income tax expense | (44) | (11) |
Income tax expense Norwegian operations | (29) | (10) |
Income tax expense foreign operations | (15) | (2) |
Total income tax expense | (44) | (11) |
Amounts in NOK million | 2024 | 2023 |
Profit before tax | (236) | (1 050) |
Income tax based on applicable tax rate (22%) | (52) | (231) |
Effect from foreign currency and different tax rates | 1 | 1 |
Changes in not recognised tax loss carried forward | 1 | 3 |
Effect of income from associated company after tax | - | 0 |
Correction of previous years current income taxes | (4) | 1 |
Effect of double tax on branch (periodisation difference) | 3 | - |
Not deductible expenses | 7 | 214 |
Effect of used not capitalised deferred tax asset | - | - |
Income tax expense | (44) | (11) |
Effective tax rate | 18.6% | 1.1% |
148 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
| Temporary differences and tax positions | ||
Amounts in NOK million | 2024 | 2023 |
Intangible assets | 1 449 | 1 480 |
Property, plant, and equipment | (58) | (44) |
Inventories | (26) | (27) |
Receivables | (5) | (8) |
Provisions | (32) | (45) |
Tax losses carried forward 2) | (535) | (370) |
Total temporary differences and tax positions | 794 | 986 |
Temporary differences and tax positions not included in the basis for deferred tax 2) | 227 | 226 |
Basis for deferred tax | 1 021 | 1 212 |
Net deferred tax | 206 | 248 |
| Specification in the statement of financial position: | ||
Deferred tax asset | 63 | 30 |
Deferred tax | 270 | 277 |
Net deferred tax | 206 | 248 |
| Tax payable in the statement of financial position: | ||
| Current income tax payable | 0 | 3 |
Prepaid tax/prior income tax payable | 8 | 9 |
Net tax payable | 8 | 12 |
Amounts in NOK million | 2024 | 2023 |
| Result allocated to the holders of ordinary shares | ||
Profit for the year | (192) | (1 038) |
Result allocated to the holders of ordinary shares | (192) | (1 038) |
| Average number of shares | ||
Shares at the beginning of the period | 175 341 161 | 175 297 579 |
Effect of new shares | - | 39 642 |
Average number of shares | 175 341 161 | 175 337 221 |
Earnings per share (basic and diluted) - in NOK | (1.10) | (5.92) |
149 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
| Customer | |||||
| relation- | Brand | ||||
Amounts in NOK million | Goodwill | Software | ships | names | Total |
Cost at 31 December 2022 | 2 251 | 694 | 503 | 1 127 | 4 576 |
Additions | - | 176 | - | - | 176 |
Disposals | - | 1 | - | - | 1 |
Foreign currency effects | 139 | 6 | 24 | 80 | 249 |
Cost at 31 December 2023 | 2 389 | 878 | 527 | 1 207 | 5 002 |
Cost at 31 December 2023 | 2 389 | 878 | 527 | 1 207 | 5 002 |
Additions | - | 102 | - | - | 102 |
Disposals | - | (143) | - | - | (143) |
Foreign currency effects | 15 | 3 | 6 | 19 | 43 |
Cost at 31 December 2024 | 2 404 | 839 | 533 | 1 227 | 5 003 |
Acc. amortisation and impairments at 31 December 2022 | (119) | (476) | (206) | - | (802) |
Amortisation charge | - | (53) | (51) | - | (104) |
Disposals | - | (0) | - | - | (0) |
Impairments | (932) | (37) | - | - | (969) |
Foreign currency effects | - | (2) | (4) | - | (6) |
Acc. amortisation and impairments at 31 December 2023 | (1 051) | (569) | (262) | - | (1 882) |
Acc. amortisation and impairments at 31 December 2023 | (1 051) | (569) | (262) | - | (1 882) |
Amortisation charge | - | (80) | (52) | - | (132) |
Disposals | - | 143 | - | - | 143 |
Impairments | - | - | - | - | - |
Foreign currency effects | 0 | (1) | (2) | - | (3) |
Acc. amortisation and impairments at 31 December 2024 | (1 051) | (506) | (316) | - | (1 874) |
Carrying amount at 31 December 2022 | 2 131 | 218 | 297 | 1 127 | 3 773 |
Carrying amount at 31 December 2023 | 1 338 | 309 | 265 | 1 207 | 3 120 |
Carrying amount at 31 December 2024 | 1 353 | 333 | 217 | 1 227 | 3 130 |
Carrying amount of assets with indefinite life | 1 353 | - | - | 1 227 | 2 580 |
Amortisation rate | 15 - 25% | 14 - 20% |
| Useful economic life | ||
2024 | 2023 | |
Customer relationships | 5 - 7 years | 5 - 7 years |
Software | 3 - 7 years | 3 - 7 years |
| Customer | |||||
Amounts in NOK million | Goodwill | Software | relationships | Brand names | Total |
| Cash generating units | |||||
Komplett B2C | 164 | 79 | - | - | 243 |
Komplett B2B | 218 | 33 | - | - | 251 |
Itegra | 68 | 69 | - | 5 | 141 |
Webhallen | 86 | 63 | - | 53 | 203 |
Ironstone | 78 | 15 | 5 | 5 | 103 |
NetOnNet | 739 | 74 | 212 | 1 164 | 2 188 |
Total at 31 December 2024 | 1 353 | 333 | 217 | 1 227 | 3 130 |
| Intangible assets by cash generating units at 31 December 2023 | |||||
| Customer | |||||
Amounts in NOK million | Goodwill | Software | relationships | Brand names | Total |
| Cash generating units | |||||
Komplett B2C | 166 | 89 | - | - | 255 |
Komplett B2B | 214 | 36 | - | - | 250 |
Itegra | 68 | 75 | - | 5 | 148 |
Webhallen | 85 | 28 | - | 52 | 165 |
Ironstone | 78 | 17 | 7 | 5 | 109 |
NetOnNet | 727 | 62 | 258 | 1 145 | 2 193 |
Total at 31 December 2023 | 1 338 | 309 | 265 | 1 207 | 3 120 |
150 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
| Key assumptions applied: | |||
| Long term growth | EBIT-margin | Discount rate | |
| Cash generating unit | rate in sales | terminal value | (after tax) |
NetOnNet | 2.0% | 3.6% | 10.0% |
Webhallen | 2.0% | 2.3% | 10.0% |
Ironstone | 2.0% | 10.0% | 12.5% |
Komplett B2C | 2.0% | 4.0% | 11.5% |
Komplett B2B | 2.0% | 7.0% | 11.5% |
Itegra | 2.0% | 1.7% | 11.5% |
| Cash generating unit | ||||||
Amounts in NOK million | Growth in terminal value | EBIT-margin in TV | Discount rate | |||
Changes in assumptions | -0.5 pp | -1.0 pp | - 0.5 pp | - 1.0 pp | + 0.5 p | + 1.0 p |
NetOnNet | -107 | -201 | -280 | -560 | -160 | -302 |
Webhallen | -13 | -25 | -70 | -139 | -24 | -46 |
151 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
| Leasehold | Machinery and | ||
| Amounts in NOK million | improvements | equipment | Total |
Cost at 31 December 2022 | 44 | 402 | 446 |
Additions | 7 | 28 | 36 |
Disposals | - | (2) | (2) |
Impairment | - | (6) | (6) |
Foreign currency effects | 1 | 8 | 9 |
Cost at 31 December 2023 | 52 | 431 | 483 |
Cost at 31 December 2023 | 52 | 431 | 483 |
Additions | 7 | 60 | 67 |
Disposals | (1) | (110) | (111) |
Impairment | - | - | - |
Foreign currency effects | 0 | (3) | (3) |
Cost at 31 December 2024 | 58 | 378 | 436 |
Acc. depreciation and impairments at 31 December 2022 | (31) | (282) | (313) |
Depreciation | (4) | (36) | (41) |
Disposals | - | 2 | 2 |
Foreign currency effects | 0 | (2) | (2) |
Acc. depreciation and impairments at 31 December 2023 | (35) | (319) | (354) |
Acc. depreciation and impairments at 31 December 2023 | (35) | (319) | (354) |
Depreciation | (6) | (42) | (48) |
Disposals | 1 | 109 | 110 |
Foreign currency effects | (0) | 4 | 4 |
Acc. depreciation and impairments at 31 December 2024 | (41) | (248) | (289) |
Carrying amount at 31 December 2022 | 13 | 121 | 134 |
Carrying amount at 31 December 2023 | 16 | 112 | 128 |
Carrying amount at 31 December 2024 | 17 | 130 | 147 |
Economic life | 3 - 5 years | 3 - 7 years | |
Depreciation rate | 20% | 15 - 25% | |
Depreciation method | Linear | Linear |
Name | Country | Industry | Proportion of ownership |
Fabres Sp. Z.o.o. | Poland | Consulting | 40.0% |
Amounts in NOK million | 2024 | 2023 |
At 1 January | 12.2 | 13.6 |
Share of profit after tax | 1.5 | 2.8 |
Dividend | (5.3) | (4.1) |
At 31 December | 8.4 | 12.2 |
Amounts in PLN million | 2024 | 2023 |
Assets | 10.6 | 14.8 |
Liabilities | 1.4 | 2.0 |
Equity | 9.2 | 12.8 |
Revenues | 18.6 | 21.3 |
Total operating expenses | (16.5) | (17.8) |
Net financial items | (0.4) | (1.1) |
Profit of the year | 1.8 | 2.4 |
152 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
Amounts in NOK million | 2024 | 2023 |
Trade receivables at face value at 31 December | 160 | 254 |
Less: Provision for expected credit loss | (7) | (9) |
Net trade receivables | 153 | 245 |
Receivables written off during the years | 11 | 10 |
Collected on receivables written of in prior periods | (5) | (6) |
Changes in provision during the year | (3) | 3 |
Impairment loss during the year | 2 | 6 |
At 31 December 2024 | Total | Current | 0-30d | 30-60d | 60-90d | >90d |
Trade receivables at face value | 159.9 | 95.3 | 32.7 | 4.2 | 5.5 | 2 2.1 |
Provision for expected credit loss | 6.6 | 0.2 | - | - | - | 6.4 |
Net trade receivables | 153.2 | 95.1 | 32.7 | 4.2 | 5.5 | 15.7 |
At 31 December 2023 | Total | Current | 0-30d | 30-60d | 60-90d | >90d |
Trade receivables at face value | 254.0 | 116.2 | 81.7 | 9.8 | 12.3 | 33.9 |
Provision for expected credit loss | 8.9 | 0.4 | - | 0.4 | 0.5 | 7.6 |
Net trade receivables | 24 5.1 | 115.8 | 81.7 | 9.5 | 11.8 | 26.3 |
Amounts in NOK million | 2024 | 2023 |
Gross amount receivable at 1 January | 107 | 100 |
Less provision at 1 January | (28) | (9) |
Carrying amount 1 January | 79 | 91 |
Additions during the year | 0 | 267 |
Down payments | (52) | (283) |
Interest income | 3 | 17 |
Net losses during the year | (2) | 6 |
Change in loss provision | (1) | (19) |
Carrying amount 1) at 31 December | 27 | 79 |
Receivables due during next twelve months | 49 | 67 |
Receivables due after twelve months | 7 | 40 |
Less provision for losses | (29) | (28) |
Total | 27 | 79 |
Amounts in NOK million | 2024 | 2023 |
Public duties receivable (VAT)/Tax | 39 | 52 |
Receivables from suppliers | 567 | 506 |
Prepaid payroll element on option | 1 | 6 |
Other receivables and prepaid expenses | 102 | 96 |
Sum | 709 | 660 |
Amounts in NOK million | 2024 | 2023 |
Rent deposits | 1 | 1 |
Warranty - The Swedish Customs | 4 | 4 |
Pension premium fund | 4 | 3 |
Sum | 9 | 9 |
153 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
Amounts in NOK million | 2024 | 2023 |
Inventories carried at cost | 2 088 | 2 233 |
Provision not allocated to specific goods | (40) | (39) |
Booked value | 2 048 | 2 194 |
Amounts in NOK million | 2024 | 2023 |
Changes in provision for obsolescence included in cost of goods sold | 1 | (11) |
Amounts in NOK million | 2024 | 2023 |
Cash at hand and on demand bank deposits | 726 | 230 |
Amounts in NOK million | 2024 | 2023 |
Bank deposits bound for payment of tax due | 5.1 | 3.5 |
Number of shares | 2024 | 2023 |
Ordinary shares | 175 341 161 | 175 341 161 |
| Number | Nominal | Type of | Share capital | Share premium | |
| Date/year | of shares | value NOK | change | NOK million | reserve NOK million |
31 December 2019 | 14 451 031 | 2.00 | 29 | 1 075 | |
31 December 2020 | 14 451 031 | 2.00 | 29 | 1 075 | |
May 2021 | 72 255 155 | 0.40 | Split 1) | 29 | 1 075 |
31 December 2021 | 72 255 155 | 0.40 | 29 | 1 075 | |
04 April 2022 | 107 497 579 | 0.40 | 43 | 2 780 | |
16 November 2022 | 134 997 579 | 0.40 | 54 | 3 175 | |
08 December 2022 | 175 297 579 | 0.40 | 70 | 3 741 | |
03 February 2023 | 175 341 161 | 0.40 | 70 | 3 741 |
154 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
The 20 largest shareholders at 31 December 2024 Holding | Stake | Type of account | ||
1 | Canica Invest AS | 74 376 317 | 42.42% | Ordinary |
2 | SIBA Invest AB | 55 581 404 | 31.70% | Ordinary |
3 | Sole Active AS | 6 165 112 | 3.52% | Ordinary |
4 | Verdipapirfondet Alfred Berg Gambak | 5 832 206 | 3.33% | Ordinary |
5 | The Bank of New York Mellon SA/NV | 5 425 413 | 3.09% | Nominee |
6 | The Northern Trust Comp, London Branch | 3 899 116 | 2.22% | Nominee |
7 | Verdipapirfondet Holberg Norge | 2 400 000 | 1.37% | Ordinary |
8 | Verdipapirfondet Holberg Norden | 2 200 000 | 1.25% | Ordinary |
8 | Verdipapirfondet Storebrand Norge | 1 607 937 | 0.92% | Ordinary |
10 | Skandinaviska Enskilda Banken AB | 1 365 500 | 0.78% | Nominee |
11 | Verdipapirfondet Alfred Berg Norge | 1 142 323 | 0.65% | Ordinary |
12 | Wenaasgruppen AS | 823 499 | 0.47% | Ordinary |
13 | Verdipapirfondet Alfred Berg Norge | 501 511 | 0.29% | Ordinary |
14 | UBS AG | 500 423 | 0.29% | Nominee |
15 | Gulbrand Gråstein AS | 469 805 | 0.27% | Ordinary |
16 | Verdipapirfondet Storebrand Norge | 404 120 | 0.23% | Ordinary |
17 | Nian AS | 393 335 | 0.22% | Ordinary |
18 | Cigalep AS | 391 777 | 0.22% | Ordinary |
19 | LT Invest AS | 378 646 | 0.22% | Ordinary |
20 | Nordnet Livsforsikring AS | 374 957 | 0.21% | Ordinary |
Total top 20 | 164 233 401 | 93.67% | ||
Other | 11 107 760 | 6.33% | ||
Total number of shares | 175 341 161 | 100.00% |
Shares held by board directors and CEO Title | Number of shares | |
Jo Lunder (Cigalep AS) | Chair | 391 777 |
Fabian Bengtsson (SIBA Invest AB) | Director | 55 581 404 |
Jan Ole Stangeland (Stangeland Invest AS) | Director | 76 296 |
Jaan Ivar G. Semlitsch | CEO | 180 000 |
| Total costs and social security provisions | ||
Amounts in NOK million | 2024 | 2023 |
Total IFRS cost | 8.34 | 5.51 |
Total social security provisions | - | - |
| Granted instruments 2024 | |
Instrument | Option |
Quantity 31 December 2024 (instruments) | 4 561 699 |
Quantity 31 December 2024 (shares) | 4 561 699 |
Contractual life 1) | 5.00 |
Strike price 1) | 9.63 |
Share price 1) | 9.21 |
Expected lifetime 1) | 3.48 |
Volatility 1) | 0.51 |
Interest rate 1) | 0.04 |
Dividend 1) | - |
FV per instrument 1) | 3.55 |
155 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
| Quantity and weighted average prices 2024 | ||
Activity | Number of instruments | Weighted average strike price |
Outstanding options 1.1 | 3 619 588 | 20.12 |
Granted | 4 561 699 | 9.63 |
Terminated | (696 082) | 23.19 |
Outstanding options 31.12 | 7 485 205 | 13.44 |
Vested CB | 753 904 | 28.97 |
| Outstanding instruments overview at 31 December 2024 | ||||||
Outstanding instruments | Vested instruments | |||||
| Weighted | ||||||
| average | Weighted | Vested | Weighted | |||
| Expiry/ | Strike | Number of | remaining | average | instruments | average |
| vesting date | price | instruments | contractual life | strike price | 31.12.2024 | strike price |
2025 | 9.20 | 798 205 | 4.36 | 9.20 | - | - |
2026 | 9.48 | 798 211 | 4.36 | 9.48 | - | - |
2027 | 9.76 | 2 898 351 | 4.36 | 9.76 | - | - |
2027 | 10.98 | 66 932 | 4.67 | 10.98 | - | - |
2024 | 12.73 | 83 156 | 4.59 | 12.73 | 83 156 | 12.73 |
2025 | 13.11 | 83 156 | 4.59 | 13.11 | - | - |
2026 | 13.51 | 249 469 | 4.59 | 13.51 | - | - |
2024 | 14.40 | 233 899 | 4.42 | 14.40 | 233 899 | 14.40 |
2025 | 14.83 | 233 903 | 4.42 | 14.83 | - | - |
2026 | 15.28 | 701 710 | 4.42 | 15.28 | - | - |
2024 | 16.07 | 100 000 | 4.11 | 16.07 | 100 000 | 16.07 |
2025 | 16.55 | 100 000 | 4.11 | 16.55 | - | - |
2026 | 17.0 5 | 300 000 | 4.11 | 17.05 | - | - |
2024 | 17.86 | 125 340 | 4.30 | 17.86 | 125 340 | 17.86 |
2025 | 18.40 | 125 340 | 4.30 | 18.40 | - | - |
2026 | 18.95 | 376 024 | 4.30 | 18.95 | - | - |
2022 | 61.80 | 55 147 | 2.48 | 61.80 | 55 147 | 61.80 |
2023 | 63.65 | 47 805 | 2.48 | 63.65 | 47 805 | 63.65 |
2024 | 65.56 | 108 557 | 2.48 | 65.56 | 108 557 | 65.56 |
Total | 7 485 205 | 753 904 |
| Quantity and weighted average prices 2023 | ||
Activity | Number of instruments | Weighted average strike price |
Outstanding options 1.1 | 401 025 | 64.32 |
Granted | 3 338 701 | 16.41 |
Terminated | (120 138) | 64.60 |
Outstanding options 31.12 | 3 619 588 | 20.12 |
Vested CB | 130 700 | 62.67 |
Outstanding Instruments | Vested Instruments | |||||||
| Weighted | ||||||||
| average | Weighted | Vested | Weighted | |||||
| Expiry/ | Strike | Number of | remaining | average | instruments | average | ||
| vesting date | price | instruments | contractual life | strike price | 31.12.2023 | strike price | ||
- | - | - | - | - | - | - | ||
- | - | - | - | - | - | - | ||
- | - | - | - | - | - | - | ||
- | - | - | - | - | - | - | ||
2024 | 12.73 | 83 156 | 4.59 | 12.73 | - | - | ||
2025 | 13.11 | 83 156 | 4.59 | 13.11 | - | - | ||
2026 | 13.51 | 249 469 | 4.59 | 13.51 | - | - | ||
2024 | 14.40 | 233 899 | 4.42 | 14.40 | - | - | ||
2025 | 14.83 | 233 903 | 4.42 | 14.83 | - | - | ||
2026 | 15.28 | 701 710 | 4.42 | 15.28 | - | - | ||
2024 | 16.07 | 100 000 | 4.11 | 16.07 | - | - | ||
2025 | 16.55 | 100 000 | 4.11 | 16.55 | - | - | ||
2026 | 17.0 5 | 300 000 | 4.11 | 17.05 | - | - | ||
2024 | 17.86 | 250 680 | 4.30 | 17.86 | - | - | ||
2025 | 18.40 | 250 680 | 4.30 | 18.40 | - | - | ||
2026 | 18.95 | 752 048 | 4.30 | 18.95 | - | - | ||
2023 | 61.80 | 69 021 | 2.48 | 61.80 | 69 021 | 61.80 | ||
2024 | 63.65 | 61 679 | 2.48 | 63.65 | 61 679 | 63.65 | ||
2024 | 65.56 | 150 187 | 2.48 | 65.56 | - | - | ||
Total | 3 619 588 | 130 700 |
156 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
Amounts in NOK million | Land and buildings | Vehicles | Total |
At 1 January 2023 | 557 | 2 | 559 |
Additions incl.adjustments to existing contracts | 206 | 2 | 207 |
Amortisation | (189) | (1) | (190) |
Impairment | (8) | - | (8) |
Foreign currency effects | 32 | - | 32 |
At 31 December 2023 | 597 | 3 | 600 |
At 1 January 2024 | 597 | 3 | 600 |
Additions incl. adjustments to existing contracts | 108 | 1 | 109 |
Amortisation | (204) | (1) | (204) |
Foreign currency effects | 9 | - | 9 |
At 31 December 2024 | 511 | 3 | 514 |
Economic life/lease term | 1-9 years |
Amortisation method | Straight line |
| Lease liabilitiies | ||
Amounts in NOK million | 31.12.2024 | 31.12.2023 |
| Undiscounted lease payments and year of payment | ||
Less than 1 year | 212 | 222 |
1-2 years | 161 | 196 |
2-3 years | 97 | 138 |
3-4 years | 63 | 90 |
4-5 years | 41 | 36 |
More than 5 years | 12 | 21 |
Total undiscounted lease payments | 586 | 703 |
Amounts in NOK million | 2024 | 2023 |
At 1 January 2024 | 608 | 558 |
Additions | 111 | 228 |
Interest expenses | 23 | 19 |
Lease payments | (230) | (205) |
Foreign currency effects | 6 | 8 |
Total lease liabilities at 31 December | 518 | 608 |
| Whereof: | ||
Current lease liabilities | 186 | 180 |
Non-current lease liabilities | 331 | 428 |
Total cash outflows for leases | 230 | 205 |
| Summary of other lease expenses recognised in profit or loss | ||
Amounts in NOK million | 2024 | 2023 |
Expensed lease payment for short-term leases and low value leases | 11.7 | 18.3 |
Variable lease payments | 26.4 | 22.6 |
157 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
Amounts in NOK million | 2024 | 2023 |
Provision for service and guarantee obligations | 32 | 30 |
Accrued employee benefit expenses | 118 | 127 |
Provision from contract with customer | 89 | 62 |
Tax deferred payment - Sweden | 150 | 443 |
Other short term liabilities | 99 | 200 |
Total other current liabilities | 487 | 862 |
Amounts in NOK million | 2024 | 2023 |
Long-term loans | 800 | 800 |
Tax deferred payment - Sweden | 263 | - |
Lease liabilities | 331 | 391 |
Total long term debt | 1 394 | 1 228 |
Amounts in NOK million | 2024 | 2023 |
At 1 January | 30 | 30 |
Utilised during the year | (28) | (28) |
Additions services and guarantee obligations for the year | 30 | 27 |
At 31 December | 32 | 30 |
| 2024 | |||||
| Non-current | Other non- | Current | Financial | ||
| loans and | current | loans and | liabilities at | ||
| Amounts in NOK million | borrowings | liabilities | borrowings | fair value | Total |
At 1 January 2024 | (800) | - | - | (37) | (837) |
Net cash flow | - | 41 | - | - | 41 |
| Non-cash flows | |||||
- Reclassification from other current liabilities | - | (304) | - | - | ( 3 0 4 ) |
- Miscellaneous provisions | - | - | - | - | - |
- Fair value adjustments | - | - | - | 3 | 3 |
At 31 December 2024 | (800) | (263) | - | (34) | (1 097) |
| 2023 | |||||
| Non-current | Other non- | Current | Financial | ||
| loans and | current | loans and | liabilities at | ||
| Amounts in NOK million | borrowings | liabilities | borrowings | fair value | Total |
At 1 January 2023 | (400) | - | (625) | (46) | (1 071) |
Net cash flow | (400) | - | 625 | - | 225 |
| Non-cash flows | |||||
- Miscellaneous provisions | - | - | - | 8 | 8 |
- Fair value adjustments | - | - | - | - | - |
At 31 December 2023 | (800) | - | - | (37) | (837) |
158 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
| Utilised | Utilised | ||||
Amounts in NOK million | Classification | Total facility | Covenants (C) /Pledge (P) | 31.12.2024 | 31.12.2023 |
| Type | |||||
| Revolving | Long-term | NOK 1 300 mil- | C - leverage ratio < 4.00 and | 800 | 8 0 0 |
| credit facility | lion | equity ratio > 30% | |||
| P - receivables, inventory | |||||
| and tangible fixed assets | |||||
Overdraft facility | Short term | NOK 500 million | C - leverage ratio < 4.00 and | - | - |
| equity ratio > 30% | |||||
| P - receivables, inventory | |||||
| and tangible fixed assets | |||||
Total | 800 | 800 |
| Financial guarantees | ||
Amounts in NOK million | 2024 | 2023 |
Guarantees related to leases | 27 | 26 |
Guarantees to the tax collector | 12 | 12 |
Guarantees to suppliers | 25 | - |
Total | 64 | 38 |
Total mortgage-backed liabilities and financial guarantees | 864 | 838 |
159 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
Amounts in NOK million | 2024 | 2023 | |
Kullerød Eiendom AS¹ | Lease of office and warehouse | 29 | 28 |
F&H Asia Limited¹ | Purchase of products | 23 | 24 |
Resurs Bank & Solid² | Sales of products | 9 | 9 |
Resurs Bank & Solid² | Sale of services and profit sharing | 168 | 146 |
Resurs bank | Purchase of factoring services | 39 | 39 |
SIBA Fastigheter AB² | Lease of office and warehouse | 25 | 19 |
Total | 294 | 265 |
| Parent company |
| Komplett ASA |
Subsidiaries | Country of incorporation | Proportion of ownership |
Komplett Services AS | Norway | 100.0% |
Komplett Services Sweden AB | Sweden | 100.0% |
Komplett Distribusjon AS | Norway | 100.0% |
Komplett Distribution Sverige AB | Sweden | 100.0% |
NetOnNet AB | Sweden | 100.0% |
Webhallen Sverige AB | Sweden | 100.0% |
Ironstone Holding AS | Norway | 7 3.1% |
Ironstone AS 1) | Norway | - |
Ironstone AB 1) | Sweden | - |
| Subsidiaries without activity | ||
Marked Gruppen AS | Norway | 100.0% |
160 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
161 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
STATEMENT OF PROFIT AND LOSS – KOMPLETT ASA
FOR THE YEAR ENDED 31 DECEMBER
Amounts in NOK million Note 20 24 2023
Operating revenues
Revenues from sale of goods - -
Total operating income - -
Operating expenses
Employee benefit expenses 8 (78) (55)
Other operating expenses 8 (37) (43)
Total operating expenses (115) (98)
OPERATING PROFIT (115) (98)
Finance income and expenses
Income from investments in associated companies 5 4
Finance income 9 88 133
Finance expenses 9 (94) (797)
Net finance (1) (659)
PROFIT BEFORE TAX (115) (757)
Tax expense 6 25 9
PROFIT FOR THE YEAR (90) (748)
Attributable to:
Ordinary dividends - -
Other equity (90) (748)
TOTAL (90) (748)
162 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
FINANCIAL STATEMENTS – KOMPLETT ASA
STATEMENT OF FINANCIAL POSITION – KOMPLETT ASA
AT 31 DECEMBER
Amounts in NOK million Note 31 December 2024 31 December 2023
NON-CURRENT ASSETS
Intangible assets
Deferred tax asset 6 41 11
Total intangible assets 41 11
Non-current financial assets
Investments in subsidiaries 2, 3 3 749 3 734
Investments in associates 3 5 5
Total other non-current assets 3 754 3 739
Total non-current assets 3 795 3 750
CURRENT ASSETS
Current receivables
Current receivables from group companies 5 164 245
Other current receivables 8 2
Total current receivables 171 247
Cash and cash equivalents
Cash and cash equivalents 4 601 118
Total cash and cash equivalents 601 118
Total current assets 772 365
Total assets 4 567 4 115
Amounts in NOK million Note 31 December 2024 31 December 2023
EQUITY
Paid in equity
Share capital 70 70
Share premium 3 741 3 741
Other paid in equity 46 37
Total paid in equity 3 857 3 849
Retained earnings
Other equity (1 139) (1 049)
Total retained earnings (1 139) (1 049)
Total equity 2 718 2 800
LIABILITIES
Non-current provisions
Pension liabilities 7 3
Provision for other long-term obligations 2 34 37
Total non-current provision 41 40
Non-current liabilities
Long-term loans 7 800 800
Total non-current liabilities 800 800
Current liabilities
Short-term loans 7 - -
Current payables to group companies 5 973 444
Trade payables 8 1
Other current liabilities 16 30
Total current liabilities 1 008 475
Total liabilities 1 849 1 315
Total equity and liabilities 4 567 4 115
163 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
FINANCIAL STATEMENTS – KOMPLETT ASA
STATEMENT OF CASH FLOWS – KOMPLETT ASA
FOR THE YEAR ENDED 31 DECEMBER
Amounts in NOK million Note 2024 2023
Cash flows from operating activities
Profit before tax (90) (757)
Change in fair value of finanial liabilities (3) (0)
Group contribution received (84) (131)
Impairment - 721
Long-term incentive program 8 3
Changes in trade payables 6 (4)
Other changes in accruals (47) 13
Net cash flows used in operating activities (210) (155)
Investing activities
Investments in subsidiaries 2, 3 (0) (49)
Loans to group companies - (6)
Proceeds received from loans to group companies 1 -
Net cash (used in)/from investing activities 1 (55)
Financing activities
Proceeds from loans and borrowings 7 - (100)
Changes in bank overdrafts 561 344
Group contributions received 131 84
Issue of share capital - 1
Net cash from financing activities 692 329
Net increase in cash and cash equivalents 482 118
Cash and cash equivalents at beginning of year 118 -
Cash and cash equivalents at end of year 601 118
STATEMENT OF CHANGES IN EQUITY – KOMPLETT ASA
FOR THE YEAR ENDED 31 DECEMBER
Amounts in NOK million Note
Share
capital
Share
premium
Other
equity
Other
equity
Total
equity
At 1 January 2023 70 3 741 32 (301) 3 542
Profit for the year - - - (748) (748)
Long-term incentive programme - - 5 - 5
Issue of share capital - 1 - - 1
Transaction costs - - - - -
At 31 December 2023 70 3 741 37 (1 049) 2 800
At 1 January 2024 70 3 741 37 (1 049) 2 800
Profit for the year - - - (90) (90)
Long-term incentive programme - - 8 - 8
At 31 December 2024 70 3 741 46 (1 139) 2 718
164 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
FINANCIAL STATEMENTS – KOMPLETT ASA
Sandefjord, 20 March 2025
Board of directors, Komplett ASA
Jo Olav Lunder
Chair
Ingvild Næss
Director
Jan Ole Stangeland
Director
Fabian Bengtsson
Director
Susanne Ehnbåge
Director
Anders Odden
Worker director
Emelie Victorin
Worker director
Jaan Ivar Semlitsch
CEO
165 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
FINANCIAL STATEMENTS – KOMPLETT ASA
NOTES TO THE FINANCIAL STATEMENTS – KOMPLETT ASA
NOte 01 ACCOUNTING PRINCIPLES
The financial statements have been prepared in accord-
ance with the Norwegian Accounting Act and generally
accepted accounting principles in Norway.
The following describes the main accounting policies
used in the preparation of the financial statements of the
parent company. These policies are applied in the same
way in all periods presented, unless otherwise stated in
the description.
Subsidiaries and investment in associates
Subsidiaries and investments in associates are valued at
cost in the company accounts. The investment is valued
as cost of the shares in the subsidiary, less any impair-
ment losses. An impairment loss is recognised if the
impairment is not considered temporary, in accordance
with generally accepted accounting principles. Impair-
ment losses are reversed if the reason for the impairment
loss disappears in a later period.
Dividends, group contributions and other distributions
from subsidiaries are recognised in the same year as they
are recognised in the financial statement of the provider.
If dividends/group contributions exceed withheld profits
after the acquisition date, the excess amount represents
repayment of invested capital, and the distribution will be
deducted from the recorded value of the acquisition in the
balance sheet for the parent company.
Distributions
The proposed dividend/group contribution for the finan-
cial year are recognised as current liabilities.
Balance sheet classification
Current assets and short-term liabilities consist of
receivables and payables due within one year, and items
related to the inventory cycle. Other balance sheet items
are classified as fixed assets/long-term liabilities.
Current assets are valued at the lower of cost and fair
value. Short-term liabilities are recognised at nominal
value.
Fixed assets are valued at cost, less depreciation and
impairment losses. Long-term liabilities are recognised
at nominal value.
Accounts receivable and other receivables
Accounts receivable and other current receivables are
recorded in the balance sheet at nominal value less pro-
visions for doubtful accounts. Provisions for doubtful
accounts are based on an individual assessment of the
different receivables. For the remaining receivables, a
general provision is estimated based on expected loss.
Liabilities
Short-term and long-term liabilities are recognised in the
balance sheet at the nominal amount at the time of estab-
lishment.
The purchase liability for the remaining shares in Iron-
stone Holding AS, classified as a non-current provision, is
recognised at fair value where change in value is recog-
nised as a financial income or financial expense.
Foreign currency translation
Transactions in foreign currency are translated at the
rate applicable on the transaction date. Monetary items
in a foreign currency are translated into NOK using the
exchange rate applicable on the balance sheet date.
Non-monetary items that are measured at their histori-
cal price expressed in a foreign currency are translated
into NOK using the exchange rate applicable on the trans-
action date. Non-monetary items that are measured at
their fair value expressed in a foreign currency are trans-
lated at the exchange rate applicable on the balance
sheet date. Changes to exchange rates are recognised in
the income statement as they occur during the account-
ing period.
Income tax
The tax expense consists of the tax payable and changes
to deferred tax.
Period tax constitutes the expected tax payable on this
year's taxable result at the current tax rates on the bal-
ance sheet date and any corrections of tax payable for
previous years.
Deferred tax/tax assets are calculated on all differences
between the book value and tax value of assets and liabil-
ities.
Deferred tax is calculated as 22 per cent of temporary dif-
ferences and the tax effect of tax losses carried forward.
Deferred tax assets are recorded in the balance sheet
when it is more likely than not that the tax assets will be
utilised.
Taxes payable and deferred taxes are recognised directly
in equity to the extent that they relate to equity transac-
tions.
Cash flow statement
The cash flow statement is presented using the indirect
method. Cash and cash equivalents include cash, bank
deposits and other short-term, highly liquid investments
with maturities of three months or less. At year-end, cash
and cash equivalents consist of cash and bank deposits.
166 KOMPLETT ASA
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ANNUAL REPORT 2024
|
NOTES TO THE FINANCIAL STATEMENTS – KOMPLETT ASA
NOte 02 CORPORATE CHANGES
There has not been any changes in top managment in Kom-
plett ASA during 2024, but do see note 26 in the consolidated
financial statement for events after the reporting date.
There has not been any material change in the group's
legal structure and only a minor increase in ownership in
the subsidiary Ironstone Holding AS.
NOte 03 INVESTMENTS IN SUBSIDIARIES AND ASSOCIATED COMPANIES
Amounts in NOK
Share
capital Currency
Number
of shares
Face
value
Ownership
= voting rights
Carrying
amount
Subsidiary (in NOK million)
Komplett Services AS 900 000 NOK 900 1 000 100.0% 506
Komplett Services Sweden AB 100 000 SEK 1 000 100 100.0% 137
Komplett Distribusjon AS 10 000 000 NOK 100 100 000 100.0% 110
Komplett Distribution Sverige AB 300 000 SEK 3 000 100 100.0% 23
NetOnNet AB 604 068 SEK 6 040 680 0.10 100.0% 2 581
Webhallen Sverige AB 210 000 SEK 210 1 000 100.0% 241
Ironstone Holding AS 410 400 NOK 4 104 100 7 3.10 % 152
Marked Gruppen AS 1 000 000 NOK 1 000 000 1 100.0% -
Total 3 749
Amounts in NOK
Share
capital Currency
Number
of shares
Face
value
Ownership
= voting rights
Carrying
amount
Associated company (in NOK million)
Fabres Sp. z o.o. 950 000 PLN 19 000 50 40.0% 5
Total 5
167 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE FINANCIAL STATEMENTS – KOMPLETT ASA
Information about the subsidiaries' equity and profit and loss in accordance with the latest financial statements:
Amounts in NOK million
Business
office Equity
Profit or loss
before tax
Company
Komplett Services AS Sandefjord 325 59
Komplett Distribusjon AS Sandefjord 186 (10)
Komplett Services Sweden AB Stockholm in Sweden 47 3
Komplett Distribution Sverige AB Gothenburg in Sweden 14 1
NetOnNet AB Borås in Sweden 494 51
Webhallen Sverige AB Stockholm in Sweden 67 (78)
Ironstone Holding AS Oslo 60 (1)
Marked Gruppen AS Sandefjord (225) -
NOte 04 CASH AND CASH EQUIVALENTS
Komplett ASA is the principal in the group's multi-
currency cash pool, where the top account is classified
as bank and this was NOK 598 million at 31 December
2024. Balances with subsidiaries are classified as current
receivables, or current payables, from group companies.
The company has a restricted bank deposits of NOK 2.9
million bound for payment of tax due at 31 December
2024. At 31 December 2023, there was a restricted bank
deposit of NOK 2.4 million.
NOte 05 GROUP BALANCES (RECEIVABLES AND PAYABLES)
Receivables
Amounts in NOK million 2024 2023
Group contribution 69 131
Cash pool balance with subsidiaries 88 107
Other current receivables 1 -
Current loans 5 6
Total 164 244
Liabilities
Amounts in NOK million 2024 2023
Cash pool balance with subsidiaries 971 429
Other current liabilities 2 15
Total 973 444
168 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE FINANCIAL STATEMENTS – KOMPLETT ASA
NOte 06 INCOME TAX
Basis for current income tax
Amounts in NOK million 2024 2023
Profit before tax (115) (757)
Non-deductible income and expenses 2 715
Changes in temporary differences 88 -
Interest deduction limitations 7 -
Use of tax loss carried forward 19 -
Basis for current income tax (0) (42)
Income tax expense
Current income tax (22%) - -
Changes in deferred tax (25) (9)
Income tax expense (25) (9)
Temporary differences and tax positions
Amounts in NOK million 2024 2023
Pension liabilities (7) -
Tax loss carried forward (19) (42)
Interest deductions carried forward (161) (8)
Total (187) (50)
Deferred tax asset (41) (11)
Reconciliation of effective tax rate
Amounts in NOK million 2024 2023
Profit before tax (115) (757)
Income tax based on applicable tax rate (22%) (25) (167)
Income tax expense (25) (9)
Deviation (0) (157)
Reconciliation
Non-deductible expenses (0) (157)
Tax loss not included in deferred tax asset - -
No use of tax loss carried forward - -
Total (0) (157)
169 KOMPLETT ASA
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NOTES TO THE FINANCIAL STATEMENTS – KOMPLETT ASA
NOte 07 PLEDGES AND GUARANTEES
Amounts in NOK million Classification
Total
facility Covenants (C) /pledge (P)
Utilised
31.12.2024
Utilised
31.12.2023
Type
Revolving credit facility Long-term
loans
1 300 C - leverage ratio < 4.00 and equity ratio
> 30% P - receivables, inventory and
tangible fixed assets
800 800
Overdraft facility Short-term
loans
500 C - leverage ratio < 4.00 and equity ratio
> 30% P - receivables, inventory and
tangible fixed assets
- -
Total 800 800
Komplett ASA has a NOK 1.3 billion syndicated revolving credit
facility with its two core banks. The agreement was signed in
December 2022 and will mature in December 2027, following
the utilisation of both extension options. In addition, the group
has a NOK 400 million overdraft limit linked to the group cash
pool, which can be increased to NOK 500 million in Q4. Per 31
December 2024, the overdraft has not been utilised.
The aforementioned agreements with the banks include
covenants for a minimum equity ratio of 30 per cent and a
ratio of net debt to EBITDA. The leverage ratio covenant
is 4.0x for 31.12 2024, while amended ratios for Q1 2025
and Q2 2025 are respectively 4.5x and 4.0x, respectively.
Thereafter the ratio will be 3.0x for ordinary quarters, but
3.5x for Q1 due to seasonality in the business. Covenants
are measured at consolidated financial figures.
The credit facilities have pledges in property, plant and
equipment, receivables, and inventory. The pledge in
Komplett ASA is NOK 2 160 million.
The group was in compliance with financial covenants in 2024.
Financial guarantees
Amounts in NOK million 2024 2023
The tax collector 12 12
Guarantees related to leases 3 2
Warranty for account payables (parent company guarantees) 524 525
Guarantees to suppliers 25 -
Total 565 539
Komplett ASA guarantees for an additional amount of NOK 1 342 million related to potential loans in subsidiaries.
NOte 08 EMPLOYEE BENEFIT EXPENSES
Employee benefit expenses
Amounts in NOK million 2024 2023
Salaries 45.1 28.7
Social security expenses 9.4 7.0
Contribution to pension schemes 5.1 4.1
Share option plan 8.3 2 .1
Bonuses 4.4 8.2
Compensations to board members 3.3 2.4
Other expenses 2.6 2.4
Total 78.1 55.0
The average number of full-time equivalents employed during
the financial year 16 10
Management remuneration
For information concerning remuneration to management, see "Remuneration report for financial year 2024" and
note 7 Employee benefits in the consolidated financial statement.
Audit fees
Audit fees to the auditors in the group entities is as follows (excluding VAT)
Amounts in NOK million 2024 2023
Statutory audit 0.91 1.70
Other assurance services 0.98 -
Other non-assurance services 0.08 0.23
Total 1.98 1.93
170 KOMPLETT ASA
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ANNUAL REPORT 2024
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NOTES TO THE FINANCIAL STATEMENTS – KOMPLETT ASA
NOte 09 ITEMS THAT ARE AGGREGATED IN THE FINANCIAL STATEMENT
Finance income
Amounts in NOK million 2024 2023
Other interest income 0.1 1.3
Interest received from group companies 0.6 0.3
Group contribution received 84.3 130.9
Changes in financial liabilities 2.6 -
Other financial income 0.5 0.9
Total 88.1 133.3
Finance expenses
Amounts in NOK million 2024 2023
Other interest expenses 88.3 74.7
Impairment of shares in subsidiaries - 721.0
Changes in financial liabilities - 0.5
Loss on financial instrument in group companies 5.5 -
Other financial expenses 0.4 0.4
Total 94.2 796.7
NOte 10 FINANCIAL MARKET RISK
Overview
Komplett ASA is a holding company that has investments
in subsidiaries. The company expects that future reve-
nues will be dividends from investments in subsidiaries
and associated companies.
Currency risk
The company is exposed to currency risk from invest-
ments and loans to subsidiaries. For additional informa-
tion, see note 4 to the consolidated financial statement.
Interest rate risk
Interest rate risk occurs in the short and medium term
because of the company's debt having floating interest
rates. The loan portfolio is linked to SEB base rate and
fluctuates in relation to fluctuations in this.
Credit risk
The company has no external sales and no external
receivables, hence low exposure to credit risk. As of 31
December 2024, the company has a short term loan to
Ironstone Holding AS of NOK 5 million classified as Cur-
rent receivables from group companies, see note 5.
171 KOMPLETT ASA
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ANNUAL REPORT 2024
|
NOTES TO THE FINANCIAL STATEMENTS – KOMPLETT ASA
ALTERNATIVE PERFORMANCE MEASURES (APM)
The APMs used by Komplett Group are set out below:
Gross profit: Total operating revenue less cost of goods sold. The group
has presented this item because it considers it to be a useful measure to
show the management’s view on the overall picture of profit generation
before operating costs in the group’s operations.
Gross margin: Gross profit as a percentage of total operating revenue.
The group has presented this item because it considers it to be a useful
measure to show the management’s view on the efficiency of gross profit
generation of the group’s operations as a percentage of total operating
revenue.
Reconciliation
Amounts in NOK million FY 2024 FY 2023
Total operating revenue 15301 15 861
- Cost of goods sold (13211) (13 650)
= Gross profit 2090 2 211
Gross margin 13.7% 13.9%
Total operating expenses (adj.): Total operating expenses less cost of
goods sold and one-off cost. The group has presented this item because
the management considers it to be a useful measure of the group’s effi-
ciency in operating activities.
Operating cost percentage (adjusted): Total operating expenses less cost
of goods sold and one-off cost as a percentage of total operating revenue.
The group has presented this item because the management considers it
to be a useful measure of the group’s efficiency in operating activities.
Reconciliation
Amounts in NOK million FY 2024 FY 2023
Total operating revenue 15301 15 861
Total operating expenses 15368 16 746
- Cost of goods sold (13211) (13 650)
- One-off cost (20) (41)
- Impairment - (983)
= Total operating expenses (adj.) 2137 2 073
Operating costs percentage (adj.) 14.0% 13.1%
EBITDA excl. impact of IFRS 16: Derived from financial statements as
the sum of operating result (EBIT) plus the sum of depreciation and amor-
tisation for the segments B2C, B2B, Distribution and Other. The group
has presented this item because it considers it to be a useful measure to
show the management’s view on the overall picture of operational profit
and cash flow generation before depreciation and amortisation in the
group’s operations, excluding any impact of IFRS 16.
Reconciliation
Amounts in NOK million FY 2024 FY 2023
EBIT (67) (885)
- EBIT - IFRS 16 (16) (16)
+ Dep B2C, B2B, Distribution, Other 180 1 120
= EBITDA excl IFRS 16 97 218
EBIT adjusted: Derived from financial statements as operating result
(EBIT) excluding one-off costs. The group has presented this item
because it considers it to be a useful measure to show the management’s
view on the efficiency in the profit generation of the group’s operations
before one-off items.
Reconciliation
Amounts in NOK million FY 2024 FY 2023
Total operating revenue 15301 15 861
EBIT (67) (885)
+ One-off cost 20 41
+ Impariment - 983
= EBIT adjusted (47) 139
EBIT margin adjusted (0.3%) 0.9%
EBIT margin adjusted: EBIT adjusted as a percentage of total operating
revenue. The group has presented this item because it considers it to be
a useful measure to show the management’s view on the efficiency in the
profit generation of the group’s operations before one-off items as a per-
centage of total operating revenue.
EBIT margin: Operating result (EBIT) as a percentage of total operating
revenue. The group has presented this item because it considers it to be
a useful measure to show the management’s view on the efficiency in the
profit generation of the group’s operations as a percentage of total oper-
ating revenue.
Reconciliation
Amounts in NOK million FY 2024 FY 2023
Total operating revenue 15301 15 861
EBIT (67) (885)
EBIT margin (0.4%) (5.6%)
Net working capital: Comprising inventories, trade receivables, trade
payables and other current assets and liabilities. The management con-
siders it to be a useful indicator of the group’s capital efficiency in its
day-to-day operational activities. Part of the deferred Swedish tax lia-
bility is classified as other current liabilities in accordance with local
accounting principles, while the part which has maturity of more than 12
months is classified as other non-current liabilities. At 31.12.2024 NOK
150 million is shown as part of other current liabilities, while NOK 263 mil-
lion is included in non-current liabilities.
Reconciliation
Amounts in NOK million FY 2024 FY 2023
Inventory 2048 2 194
+ Trade receivables - regular 153 245
+ Trade payables (2073) (1 563)
+/-Other assets and liabilities (277) (623)
= Net working capital (149) 253
Net interest-bearing debt: Interest-bearing liabilities less cash and cash
equivalents. The group has presented this item because the manage-
ment considers it to be a useful indicator of the group’s indebtedness,
financial flexibility and capital structure. As mentioned above, inter-
est-bearing debt only includes the deferred Swedish tax liability of NOK
263 million with maturity above 12 months. The net interest-bearing debt
incl. IFRS 16 is a useful measure as indebtedness, including the lease lia-
bilities from IFRS 16, is relevant for the covenants of the group’s credit
facilities.
Reconciliation
Amounts in NOK million FY 2024 FY 2023
Long-term loans 800 800
+ Other non-current liabilities 263 -
+ Short-term loans - -
- Cash/cash equivalents (726) (230)
= Net interest bearing debt 337 570
+ IFRS 16 liabilities 518 608
= Net interest bearing debt including IFRS 16 854 1 178
Operating free cash flow: EBITDA excl. impact of IFRS 16 less investment
in property, plant and equipment, less change in net working capital less
change in trade receivable from deferred payment arrangements. The
group has presented this item because the management considers it to
be a useful measure of the group’s operating activities’ cash generation.
Reconciliation
Amounts in NOK million FY 2024 FY 2023
EBITDA excl IFRS 16 97 218
- Investments (168) (212)
+/- Change in net working capital 401 392
+/- Reclassified to other non-current liabilities 304 -
+/- Change in deferred payment 52 12
= Operating free cash flow 686 410
172 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
NOTES TO THE FINANCIAL STATEMENTS – KOMPLETT ASA
Statsautoriserte revisorer
Ernst & Young AS
Stortorvet 7, 0155 Oslo
Postboks 1156 Sentrum, 0107 Oslo
Foretaksregisteret: NO 976 389 387 MVA
Tlf: +47 24 00 24
00
www.ey.no
Medlemmer av Den norske Revisorforening
A member firm of Ernst & Young Global Limited
To the General Meeting in Komplett ASA
INDEPENDENT AUDITOR'S REPORT
Report on the audit of the financial statements
Opinion
We have audited the financial statements of Komplett ASA (the Company) which comprise:
• The financial statements of the company, which comprise the balance sheet as at 31 December
2024 and the income statement and statement of cash flows for the year then ended and notes to
the financial statements, including a summary of significant accounting policies, and
• The financial statements of the group, which comprise the balance sheet as at 31 December
2024, the income statement, statement of comprehensive income, statement of changes in equity
and statement of cash flows for the year then ended and notes to the financial statements,
including material accounting policy information.
In our opinion:
• the financial statements comply with applicable statutory requirements,
• the financial statements give a true and fair view of the financial position of the company as at 31
December 2024 and its financial performance and cash flows for the year then ended in
accordance with the Norwegian Accounting Act and accounting standards and practices
generally accepted in Norway, and
• the consolidated financial statements give a true and fair view of the financial position of the
group as at 31 December 2024 and its financial performance and cash flows for the year then
ended in accordance with IFRS Accounting Standards as adopted by the EU.
Our opinion is consistent with our additional report to the audit committee.
Basis for opinion
We conducted our audit in accordance with International Standards on Auditing (ISAs). Our
responsibilities under those standards are further described in the Auditor’s responsibilities for the audit of
the financial statements section of our report. We are independent of the Company and the Group in
accordance with the requirements of the relevant laws and regulations in Norway and the International
Ethics Standards Board for Accountants’ International Code of Ethics for Professional Accountants
(including International Independence Standards) (IESBA Code), and we have fulfilled our other ethical
responsibilities in accordance with these requirements. We believe that the audit evidence we have
obtained is sufficient and appropriate to provide a basis for our opinion.
To the best of our knowledge and belief, no prohibited non-audit services referred to in the Audit
Regulation (537/2014) Article 5.1 have been provided.
We have been the auditor of the Company for 2 years from the election by the general meeting of the
shareholders on 9 May 2023 for the accounting year 2023.
Penneo Dokumentnøkkel: INEBP-D69NA-YLGKJ-V17NQ-QJZEK-ANR96
2
Independent auditor's report - Komplett ASA 2024
A member firm of Ernst & Young Global Limited
Key audit matters
Key audit matters are those matters that, in our professional judgment, were of most significance in our
audit of the financial statements for 2024. These matters were addressed in the context of our audit of the
financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate
opinion on these matters.
Impairment assessment of goodwill and other intangible assets
Basis for the key audit matter
The carrying amount of goodwill and other
intangible assets as of 31 December 2024 was
NOK 1 353 million and NOK 1 777 million
respectively and make up of 41,5 % of total
assets. The carrying amounts, which are
allocated to six cash generating units (CGU’s),
relates to acquisitions primarily in 2022 and prior
years. Management has estimated the
recoverable amounts of each cash generating
unit based on value-in-use (VIU) calculations,
which require significant judgement related to
estimated future cash flows and discount rates.
Due to the continued challenging market situation
with low discretionary spending the impairment
test performed by management have concluded
with a recoverable amount close to the carrying
amounts related to the CGU for NetOnNet and
related to the CGU for Webhallen. The
impairment assessment of goodwill and other
intangible assets is a key audit matter because of
the significant carrying amounts, the impairment
indicators identified, and the considerable
estimation uncertainty, complexity and
subjectivity related to determination of
recoverable amount.
Our audit response
We obtained an understanding of and evaluated
the design over the Group’s impairment
assessment process, including the cash
generating units. We assessed key assumptions
applied in estimated future cash flows such as
revenue growth rates, EBIT margins, discount
rates and the growth rate for the terminal period.
We evaluated the historical accuracy of
management’s estimates by comparing actual
cash flows to previously estimated cash flows to
assess the reasonableness of management
forecasts for future cash flows. We agreed the
input data used by management to supporting
evidence such as actual results, future budgets
and long-term plans approved by the Board of
Directors. Further we assessed managements
sensitivity analyses and benchmarked relevant
key assumptions to comparable companies in the
same industry, as well as market statistics. We
involved our internal valuation specialists to
assess the VIU calculation and the
reasonableness of the discount rates applied by
management. We refer to note 11 Intangible
assets and note 2 Critical accounting estimates
and judgements in the consolidated financial
statements.
Other information
The Board of Directors and Chief Executive Officer (management) are responsible for the information in
the Board of Directors’ report and the other information presented with the financial statements. The other
information consists of the information included in the annual report other than the financial statements
and our auditor’s report thereon. Our opinion on the financial statements does not cover the information in
the Board of Directors’ report and the other information presented with the financial statements.
In connection with our audit of the financial statements, our responsibility is to read the information in the
Board of Directors’ report and for the other information presented with the financial statements. The
purpose is to consider if there is material inconsistency between the information in the Board of Directors’
report and the other information presented with the financial statements and the financial statements or
Penneo Dokumentnøkkel: INEBP-D69NA-YLGKJ-V17NQ-QJZEK-ANR96
3
Independent auditor's report - Komplett ASA 2024
A member firm of Ernst & Young Global Limited
our knowledge obtained in the audit, or otherwise the information in the Board of Directors’ report and for
the other information presented with the financial statements otherwise appears to be materially
misstated. We are required to report that fact if there is a material misstatement in the Board of Directors’
report and the other information presented with the financial statements. We have nothing to report in this
regard.
Based on our knowledge obtained in the audit, it is our opinion that the Board of Directors’ report
• is consistent with the financial statements and
• contains the information required by applicable statutory requirements.
Our statement on the Board of Directors’ report applies correspondingly for the statement on Corporate
Governance.
Our statement that the Board of Directors’ report contains the information required by applicable law does
not cover the sustainability report, for which a separate assurance report is issued.
Responsibilities of management for the financial statements
Management is responsible for the preparation of the financial statements of the Company that give a
true and fair view in accordance with the Norwegian Accounting Act and accounting standards and
practices generally accepted in Norway, and for the preparation of the consolidated financial statements
of the Group that give a true and fair view in accordance with IFRS Accounting Standards as adopted by
the EU. Management is responsible for such internal control as management determines is necessary to
enable the preparation of financial statements that are free from material misstatement, whether due to
fraud or error.
In preparing the financial statements, management is responsible for assessing the Company’s and the
Group’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern
and using the going concern basis of accounting unless management either intends to liquidate the
Company or the Group, or to cease operations, or has no realistic alternative but to do so.
Auditor’s responsibilities for the audit of the financial statements
Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are
free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that
includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an
audit conducted in accordance with ISAs will always detect a material misstatement when it exists.
Misstatements can arise from fraud or error and are considered material if, individually or in the
aggregate, they could reasonably be expected to influence the economic decisions of users taken on the
basis of these financial statements.
As part of an audit in accordance with ISAs, we exercise professional judgment and maintain professional
scepticism throughout the audit. We also:
• Identify and assess the risks of material misstatement of the financial statements, whether due to
fraud or error, design and perform audit procedures responsive to those risks, and obtain audit
evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not
detecting a material misstatement resulting from fraud is higher than for one resulting from error,
as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override
of internal control.
Penneo Dokumentnøkkel: INEBP-D69NA-YLGKJ-V17NQ-QJZEK-ANR96
173 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
AUDITOR’S REPORT
4
Independent auditor's report - Komplett ASA 2024
A member firm of Ernst & Young Global Limited
• Obtain an understanding of internal control relevant to the audit in order to design audit
procedures that are appropriate in the circumstances, but not for the purpose of expressing an
opinion on the effectiveness of the Company’s and the Group’s internal control.
• Evaluate the appropriateness of accounting policies used and the reasonableness of accounting
estimates and related disclosures made by management.
• Conclude on the appropriateness of management’s use of the going concern basis of accounting
and, based on the audit evidence obtained, whether a material uncertainty exists related to
events or conditions that may cast significant doubt on the Company’s and the Group’s ability to
continue as a going concern. If we conclude that a material uncertainty exists, we are required to
draw attention in our auditor’s report to the related disclosures in the financial statements or, if
such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit
evidence obtained up to the date of our auditor’s report. However, future events or conditions
may cause the Company and the Group to cease to continue as a going concern.
• Evaluate the overall presentation, structure and content of the financial statements, including the
disclosures, and whether the financial statements represent the underlying transactions and
events in a manner that achieves fair presentation.
• Obtain sufficient appropriate audit evidence regarding the financial information of the entities or
business activities within the Group to express an opinion on the consolidated financial
statements. We are responsible for the direction, supervision and performance of the group audit.
We remain solely responsible for our audit opinion.
We communicate with the board of directors regarding, among other matters, the planned scope and
timing of the audit and significant audit findings, including any significant deficiencies in internal control
that we identify during our audit.
We also provide the audit committee with a statement that we have complied with relevant ethical
requirements regarding independence, and to communicate with them all relationships and other matters
that may reasonably be thought to bear on our independence, and where applicable, related safeguards.
From the matters communicated with the board of directors, we determine those matters that were of
most significance in the audit of the financial statements of the current period and are therefore the key
audit matters. We describe these matters in our auditor’s report unless law or regulation precludes public
disclosure about the matter or when, in extremely rare circumstances, we determine that a matter should
not be communicated in our report because the adverse consequences of doing so would reasonably be
expected to outweigh the public interest benefits of such communication.
Report on other legal and regulatory requirement
Report on compliance with regulation on European Single Electronic Format (ESEF)
Opinion
As part of the audit of the financial statements of Komplett ASA we have performed an assurance
engagement to obtain reasonable assurance about whether the financial statements included in the
annual report, with the file name komplettasa-2024-12-31-0-en.zip have been prepared, in all material
respects, in compliance with the requirements of the Commission Delegated Regulation (EU) 2019/815
on the European Single Electronic Format (ESEF Regulation) and regulation pursuant to Section 5-5 of
the Norwegian Securities Trading Act, which includes requirements related to the preparation of the
annual report in XHTML format and iXBRL tagging of the consolidated financial statements.
In our opinion, the financial statements, included in the annual report, have been prepared, in all material
respects, in compliance with the ESEF Regulation.
Penneo Dokumentnøkkel: INEBP-D69NA-YLGKJ-V17NQ-QJZEK-ANR96
5
Independent auditor's report - Komplett ASA 2024
A member firm of Ernst & Young Global Limited
Management’s responsibilities
Management is responsible for the preparation of the annual report in compliance with the ESEF
Regulation. This responsibility comprises an adequate process and such internal control as management
determines is necessary.
Auditor’s responsibilities
Our responsibility, based on audit evidence obtained, is to express an opinion on whether, in all material
respects, the financial statements included in the annual report have been prepared in accordance with
the ESEF Regulation. We conduct our work in accordance with the International Standard for Assurance
Engagements (ISAE) 3000 – “Assurance engagements other than audits or reviews of historical financial
information”. The standard requires us to plan and perform procedures to obtain reasonable assurance
about whether the financial statements included in the annual report have been prepared in accordance
with the ESEF Regulation.
As part of our work, we perform procedures to obtain an understanding of the company’s processes for
preparing the financial statements in accordance with the ESEF Regulation. We test whether the financial
statements are presented in XHTML-format. We evaluate the completeness and accuracy of the iXBRL
tagging of the consolidated financial statements and assess management’s use of judgement. Our
procedures include reconciliation of the iXBRL tagged data with the audited financial statements in
human-readable format. We believe that the evidence we have obtained is sufficient and appropriate to
provide a basis for our opinion.
Oslo, 20 March 2025
ERNST & YOUNG AS
The auditor's report is signed electronically
Petter Frode Larsen
State Authorised Public Accountant (Norway)
Penneo Dokumentnøkkel: INEBP-D69NA-YLGKJ-V17NQ-QJZEK-ANR96
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På vegne av: Ernst & Young AS
Serienummer: no_bankid:9578-5994-4-4118388
IP: 147.161.xxx.xxx
2025-03-20 18:03:46 UTC
Penneo Dokumentnøkkel: INEBP-D69NA-YLGKJ-V17NQ-QJZEK-ANR96
174 KOMPLETT ASA
|
ANNUAL REPORT 2024
|
AUDITOR’S REPORT
Statsautoriserte revisorer
Ernst & Young AS
Stortorvet 7, 0155 Oslo
Postboks 1156 Sentrum, 0107 Oslo
Foretaksregisteret: NO 976 389 387 MVA
Tlf: +47 24 00 24 00
www.ey.no
Medlemmer av Den norske Revisorforening
A member firm of Ernst & Young Global Limited
To the General Meeting of Komplett ASA
INDEPENDENT SUSTAINABILITY AUDITOR'S LIMITED ASSURANCE REPORT
Limited assurance conclusion
We have conducted a limited assurance engagement on the consolidated sustainability statement of
Komplett ASA, included in Sustainability Statement of the Board of Directors’ report (the “Sustainability
Statement”), as at 31 December 2024 and for the year then ended.
Based on the procedures we have performed and the evidence we have obtained, nothing has come to
our attention that causes us to believe that the Sustainability Statement is not prepared, in all material
respects, in accordance with the Norwegian Accounting Act section 2-3, including:
• compliance with the European Sustainability Reporting Standards (ESRS), including that the
process carried out by the Group to identify the information reported in the Sustainability
Statement (the “Process”) is in accordance with the description set out in General information,
and
• compliance of the disclosures in EU taxonomy (E1) of the Sustainability Statement with Article 8
of EU Regulation 2020/852 (the “Taxonomy Regulation”).
Basis for conclusion
We conducted our limited assurance engagement in accordance with International Standard on
Assurance Engagements (ISAE) 3000 (Revised), Assurance engagements other than audits or reviews of
historical financial information (“ISAE 3000 (Revised)”), issued by the International Auditing and
Assurance Standards Board.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our
conclusion. Our responsibilities under this standard are further described in the Sustainability auditor’s
responsibilities section of our report.
Our independence and quality management
We have complied with the independence and other ethical requirements as required by relevant laws
and regulations in Norway and the International Code of Ethics for Professional Accountants (including
International Independence Standards) issued by the International Ethics Standards Board for
Accountants (IESBA Code), which is founded on fundamental principles of integrity, objectivity,
professional competence and due care, confidentiality and professional behaviour
The firm applies International Standard on Quality Management 1, which requires the firm to design,
implement and operate a system of quality management including policies or procedures regarding
compliance with ethical requirements, professional standards and applicable legal and regulatory
requirements.
Other matter
The comparative information included in the Sustainability Statement was not subject to an assurance
engagement. Our conclusion is not modified in respect of this matter.
Responsibilities for the Sustainability Statement
The Board of Directors and the Managing Director (management) are responsible for designing and
implementing a process to identify the information reported in the Sustainability Statement in accordance
Penneo Dokumentnøkkel: ONNOH-896QY-BV6Y5-JVCN9-41IYN-1298X
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Independent sustainability auditor's limited assurance report - Komplett ASA
A member firm of Ernst & Young Global Limited
with the ESRS and for disclosing this Process in General information of the Sustainability Statement. This
responsibility includes:
• understanding the context in which the Group's activities and business relationships take place
and developing an understanding of its affected stakeholders;
• the identification of the actual and potential impacts (both negative and positive) related to
sustainability matters, as well as risks and opportunities that affect, or could reasonably be
expected to affect, the Group's financial position, financial performance, cash flows, access to
finance or cost of capital over the short-, medium-, or long-term;
• the assessment of the materiality of the identified impacts, risks and opportunities related to
sustainability matters by selecting and applying appropriate thresholds; and
• making assumptions that are reasonable in the circumstances.
Management is further responsible for the preparation of the Sustainability Statement, in accordance with
the Norwegian Accounting Act section 2-3, including:
• compliance with the ESRS, and
• preparing the disclosures in EU taxonomy of the Sustainability Statement, in compliance with the
Taxonomy Regulation;
• designing, implementing and maintaining such internal control that management determines is
necessary to enable the preparation of the Sustainability Statement that is free from material
misstatement, whether due to fraud or error; and
• the selection and application of appropriate sustainability reporting methods and making
assumptions and estimates that are reasonable in the circumstances.
Inherent limitations in preparing the Sustainability Statement
In reporting forward-looking information in accordance with ESRS, management is required to prepare
the forward-looking information on the basis of disclosed assumptions about events that may occur in the
future and possible future actions by the Company. Actual outcomes are likely to be different since
anticipated events frequently do not occur as expected.
Sustainability auditor’s responsibilities
Our responsibility is to plan and perform the assurance engagement to obtain limited assurance about
whether the Sustainability Statement is free from material misstatement, whether due to fraud or error,
and to issue a limited assurance report that includes our conclusion. Misstatements can arise from fraud
or error and are considered material if, individually or in the aggregate, they could reasonably be
expected to influence decisions of users taken on the basis of the Sustainability Statement as a whole.
As part of a limited assurance engagement in accordance with ISAE 3000 (Revised) we exercise
professional judgement and maintain professional skepticism throughout the engagement.
Our responsibilities in respect of the Sustainability Statement, in relation to the Process, include:
• obtaining an understanding of the Process, but not for the purpose of providing a conclusion on
the effectiveness of the Process, including the outcome of the Process;
• considering whether the information identified addresses the applicable disclosure requirements
of the ESRS; and
• designing and performing procedures to evaluate whether the Process is consistent with the
Group's description of its Process set out in General information.
Our other responsibilities in respect of the Sustainability Statement include:
• identifying where material misstatements are likely to arise, whether due to fraud or error; and
Penneo Dokumentnøkkel: ONNOH-896QY-BV6Y5-JVCN9-41IYN-1298X
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Independent sustainability auditor's limited assurance report - Komplett ASA
A member firm of Ernst & Young Global Limited
• designing and performing procedures responsive to where material misstatements are likely to
arise in the Sustainability Statement. The risk of not detecting a material misstatement resulting
from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery,
intentional omissions, misrepresentations, or the override of internal control.
Summary of the work performed
A limited assurance engagement involves performing procedures to obtain evidence about the
Sustainability Statement. The procedures in a limited assurance engagement vary in nature and timing
from, and are less in extent than for, a reasonable assurance engagement. Consequently, the level of
assurance obtained in a limited assurance engagement is substantially lower than the assurance that
would have been obtained had a reasonable assurance engagement been performed.
The nature, timing and extent of procedures selected depend on professional judgement, including the
identification of disclosures where material misstatements are likely to arise in the Sustainability
Statement, whether due to fraud or error.
In conducting our limited assurance engagement, with respect to the Process, we:
• obtained an understanding of the Process by:
o performing inquiries to understand the sources of the information used by management
(e.g., stakeholder engagement, business plans and strategy documents); and
o reviewing the Company’s internal documentation of its Process; and
• evaluated whether the evidence obtained from our procedures with respect to the Process
implemented by the Company was consistent with the description of the Process set out in
General information.
In conducting our limited assurance engagement, with respect to the Sustainability Statement, we:
• obtained an understanding of the Group's reporting processes relevant to the preparation of its
Sustainability Statement by
o obtaining an understanding of the Group's control environment, processes, control
activities and information system relevant to the preparation of the Sustainability
Statement, but not for the purpose of providing a conclusion on the effectiveness of the
Group's internal control
o and obtaining an understanding of the Group's risk assessment process.
• evaluated whether the information identified by the Process is included in the Sustainability
Statement;
• evaluated whether the structure and the presentation of the Sustainability Statement is in
accordance with the ESRS;
• performed inquires of relevant personnel and analytical procedures on selected information in the
Sustainability Statement;
• performed substantive assurance procedures on selected information in the Sustainability
Statement;
• where applicable, compared disclosures in the Sustainability Statement with the corresponding
disclosures in the financial statements and other sections of the Board of Directors’ report;
• evaluated the methods, assumptions and data for developing estimates and forward-looking
information;
• obtained an understanding of the Group's process to identify taxonomy-eligible and taxonomy-
aligned economic activities and the corresponding disclosures in the Sustainability Statement;
• evaluated whether information about the identified taxonomy-eligible and taxonomy-aligned
economic activities is included in the Sustainability Statement, and
Penneo Dokumentnøkkel: ONNOH-896QY-BV6Y5-JVCN9-41IYN-1298X
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Independent sustainability auditor's limited assurance report - Komplett ASA
A member firm of Ernst & Young Global Limited
• performed inquiries of relevant personnel, analytical procedures and substantive procedures on
selected taxonomy disclosures included in the Sustainability Statement.
Oslo, 20 March 2025
ERNST & YOUNG AS
This document is signed electronically
Petter Frode Larsen
State Authorised Public Accountant (Norway)
Penneo Dokumentnøkkel: ONNOH-896QY-BV6Y5-JVCN9-41IYN-1298X
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På vegne av: Ernst & Young AS
Serienummer: no_bankid:9578-5994-4-4118388
IP: 147.161.xxx.xxx
2025-03-20 18:03:46 UTC
Penneo Dokumentnøkkel: ONNOH-896QY-BV6Y5-JVCN9-41IYN-1298X
176 KOMPLETT ASA
|
ANNUAL REPORT 2024
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AUDITOR’S REPORT
Komplett ASA
Visitor address:
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www.komplettgroup.com