tel-2025-12-31-1-en

Annual Report

2025

Introduction

Strategy,

Letter from the Chair and CEO

Our world is increasingly digital, and

connectivity is at its core. In 2025, we

continued to see increased customer

demand for Telenor’s services, and the

customers are looking for more

differentiation and sophistication. Today,

connectivity is a critical infrastructure

that fuels important changes across a

range of sectors in the society. It also

changes the ways in which we conduct

many of our interactions.

Our refreshed strategy, introduced in November

2025, underscores our dedication to deliver

exceptional connectivity and services for our

"Looking back on my first year as CEO in 2025,

a few top reflections stand out. First, the

geopolitical backdrop in increasingly shaping

our industry and elevating the importance of

Telenor's trusted role. Second, I am deeply

proud of the results we delivered together and

the discipline behind our execution. Third, the

fact that we set a clear course for the future

by launching our new strategy at our Capital

Markets Day. And finally, a strong lift in

employee engagement gives me real

confidence in what we can achieve together."

customers. To deliver on that ambition, we need

to be relevant, reliable, and user-friendly. Our

strategy is anchored in three pillars — customers,

technology and employees — which emphasise

collaborative value creation, world-class

customer experiences, and the deployment of

advanced technologies to facilitate simplification

and operational excellence.

Telenor enters this strategic phase from a

position of strength, having delivered results

aligned with our financial ambitions throughout

the 2022-2025 period. We now focus on

sustaining and building momentum over the next

three years, prioritising services-led growth,

technology-driven transformation, ongoing

simplification, and prudent capital allocation to

drive return on capital employed.

In 2025, we achieved robust growth in the

Nordics, particularly in Norway and Sweden. We

also saw EBITDA growth in Asia, with

Grameenphone in Bangladesh making a positive

contribution, even in the wake of political unrest

and macroeconomic setbacks. Our strategy is to

manage our leading Asian operations to generate

long-term value, while working towards a further

streamlining of our Group portfolio. The sale of

Telenor Pakistan was completed in December

2025, and our exit from Thailand was announced

in January 2026. These two transactions are

testaments to our commitment to simplify the

group portfolio and become a more Nordic-

centric group over time.

Benedicte Schilbred Fasmer

President and CEO

The proliferation of digital technologies presents

substantial opportunities for the communities we

serve but it also introduces new vulnerabilities. As

a trusted provider, Telenor is committed not only

to facilitating digital access but also to supporting

customers in navigating the digital landscape

safely.

In October, we published our Nordic Digital

Security 2025 report, highlighting rising security

concerns among both consumers and businesses.

The Nordic region faces increased risks from

cyberattacks and hybrid threats, reinforcing the

role of our communications infrastructure as a

strategic asset. Addressing these challenges will

require enhanced preparedness and strong

partnerships.

Advancements in AI have enabled Telenor to seize

new opportunities to improve our efficiency and

reliability. Throughout the year, we have

leveraged AI to foster innovation, drive

operational improvements, and enhance

customer journeys. Looking ahead, we will

continue investing in upskilling initiatives to

ensure that our people possess the skills needed

for future success. Our approach is to apply AI

judiciously, in areas where it adds meaningful

value, always maintaining a relentless focus on

how AI can deliver a better experience for

Telenor’s customers.

Sustainable business practices are integral to

Telenor’s identity and strategy. We remain

Jens Petter Olsen

Chair of the Board of

Directors

dedicated to network resilience, security, and

digital inclusion, and have set clear targets for

reducing operational emissions. As digital content

consumption grows, we are equally committed to

promoting digital wellbeing, particularly for

children and youth.

As Chair and CEO, we have had the privilege of

collaborating with many dedicated Telenor

employees who are invested in the company’s

long-term success. We are confident in their

ability to continue delivering outstanding services

to our customers and would like to express our

sincere appreciation for their contributions

throughout 2025. We would also like to thank both

our customers and our shareholders for putting

your trust in us – and reiterate our commitment to

keep you at the heart of everything we do.

Jens Petter og Benedicte 20241218_0-crop.jpg

Benedicte Schilbred

Fasmer

President and CEO

2025

With you, for a safer and smarter tomorrow.

Customers

OUR STANDOUT OFFER

Offering value through services that are relevant,

trusted and easy to use, enabled by resilient,

outstanding connectivity

Technology

OUR TECH ADVANTAGE

Technologists creating opportunities for our customers

and their future

Employees

OUR CULTURAL EDGE

Coming together, collaborating to create

2025

Our culture and values

One Telenor

In a world that is changing faster than ever, the

cultural foundation – our purpose and values – is

our compass. Telenor is guided by more than 170

years of experience as we keep moving beyond

connectivity, building a tomorrow that is better

than today, together.

Our purpose "With you, for a safer and smarter

tomorrow" is not just a statement – it is a

Trust

We build trust through reliability, respect,

transparency, and integrity. Trust is the

foundation that strengthens our execution

and reinforce our commitment.

Curiosity

We adopt a mindset of curiosity by exploring

new ideas and learning continuously, together.

Curiosity drives innovation and collaboration

across everything we do.

Passion

We show genuine care and boldness in every

action. Passion is our energy, pride, and a

customer-centric drive that turns ambition

into impact. We know that is not about

working harder but working wholeheartedly.

strategic tool, uniting us around a shared

direction. It speaks directly to our customers,

partners and society – and directly to employees

across Telenor. It is not about what we do, but

why we do it.

By uniting around a shared purpose and values,

we truly become One Telenor.

Our values

Our values are anchored in Telenor’s strengths

from the past. They are built on our strong

execution culture, while emphasising learning and

innovation, psychological safety and collaboration

as well as a stronger focus on the customer.

Together, these values shape how we work

across Telenor.

Sustainability, diversity and

inclusion

As the boundaries between digital and physical

life continue to blur, telecom operators are

becoming architects of societal infrastructure.

Telenor embraces this responsibility. Our

sustainability agenda is not an add-on - it is a

core driver of innovation, trust, and long-term

competitiveness. By operating responsibly,

empowering people, and enabling a greener,

more secure digital future, we aim to strengthen

the fabric of the societies we are part of—through

trust, curiosity and passion.

Our workforce is our greatest strength. A diverse

and inclusive workforce reflects the diversity in

our markets and suppliers, empowering us to

understand and better serve our customers and

stakeholders. Our ability to create a more diverse

Telenor is essential to our success.

A diverse workforce includes gender balance, age

balance and inclusion of people of different

ethnicities and cultural backgrounds. We are

committed to creating an equitable workplace

where everyone, including those with physical and

psychological disabilities, can thrive.

We believe that fostering an inclusive

environment where all employees feel valued and

supported is crucial. This includes providing

necessary means and resources to ensure that

individuals with disabilities can fully participate

and contribute to our success.

The Code of Conduct is the foundation of our

corporate culture and sets high standards of

integrity for how we do business in Telenor. It

guides us through day-to-day dilemmas and is the

basis for how we act as guardians of Telenor’s

integrity.

We are committed to fostering a working

environment where all employees are supported

and empowered in their work.

2025

Telenor's history

We have gone from

providing telegraphs

and phone booths to

delivering innovative

technologies and

critical infrastructure

that empower today’s

societies. It’s a long

way from where we

started in 1855.

1855-1900

In 1855, the first

Norwegian

telegraph line

opened by the

Norwegian Telegraph

Administration,

connecting Christiania

(Oslo) and the city of

Drammen. It soon

became clear to the

authorities that the

telephone would have

considerable

importance for society.

1900-1945

The first red phone booth

came to Norway in 1933.

Because of sparsely

populated regions, the

needs of the fishing

industry, and

topographical challenges

with mountains and

fjords, Telegrafverket

became a pioneer in

building both fixed and

wireless communications

networks.

1945-1969

The first television

broadcasts started

in Norway, and the

broadcast

transmissions

were provided by

Telegrafverket.

The name of the

company was

changed to

Televerket.

2025 -

Telenor continues on its

transformation journey.

A refreshed strategy

was launched. The sale

of Telenor Pakistan

was completed at year-

end, and the exit from

Thailand announced in

January 2026. With these

moves, Telenor becomes

a more Nordic-centric

group.

2000-2016

In December 2000,

Telenor was listed on

the Oslo Stock

Exchange , with gradual

reduction in state

ownership to 54% in 2006 .

The international expansion

continued at high pace,

including strengthening

positions in Sweden

and Denmark. In 2006,

Telenor reached 100 million

mobile subscriptions and in

2008, the company entered

India.

2017-2024

Reshaping and

focusing the portfolio

resulted in exit from

India, Myanmar and

Central and Eastern

Europe and disposal of

non-core assets, while

strengthening positions in

core geographies. The

target to become a net

zero company by 2045

was approved by Science

Based Targets initiative in

2024.

1970-1979

Televerket took a position

at the forefront of

telecommunications

research and development.

The first analogue

mobile networks and a

satellite connection with

North Sea oil platforms are

concrete results of these

initiatives. At the same

time, there were long

waiting lists to get a

telephone installed in

private homes.

1980-1999

The company was deeply

involved in development and

launch of the GSM system

for mobile

communication. In 1995,

Televerket changed its name

to Telenor. Based on it's

leading role in mobile

technology, Telenor's

international expansion

was kicked off with the entry

into Asian and Eastern

European markets from

1996.

2025

Business areas and markets

Telenor Nordics

The Nordics is a region characterised by

advanced economies with strong

purchasing power, high digital maturity,

and stable regulatory frameworks.

Telenor is uniquely placed in the Nordic

region, where it operates through the

fully owned entities Telenor Norway,

Telenor Sweden, Telenor Denmark, and

DNA in Finland.

In total, Telenor's Nordic operations include 10

million mobile customers, 4 million broadband

customers, and 2 million TV customers. The

business area accounts for approximately 78% of

Telenor's total revenues and adjusted EBITDA,

and employs a total of 7,547 people, of which 467

employees in Telenor Shared Services.

Telenor Norway

Telenor Norway is the incumbent telecom

operator and market leader in Norway, operating

under the Telenor main brand and the Talkmore

sub-brand. Telenor Norway serves 2.5 million

mobile customers, whereof around 63% is in the

consumer segment and 37% in the business

segment. The mobile subscriber market share is

around 43%.

In Norway, Telenor serves 1.4 million broadband

customers and 0.8 million TV customers, served

through its own fibre, cable and fixed wireless

networks. Telenor Norway's revenue market

share is around 51% within mobile, and around

30% within broadband. The strong brand position

leverages on security, resilience and network

coverage. Telenor Norway has 97% 5G population

coverage and 100% 4G population coverage. The

world-class mobile network has been consistently

proven through several awards.

Telenor Norway was one of the first operators in

the world to decommission its copper network.

The acquisition of GlobalConnect's consumer

fibre business in Norway, which was announced in

July 2025 and is expected to be completed in first

half of 2026, will further expand Telenor Norway's

fibre position.

Telenor Norway also includes the passive fibre

infrastructure company Telenor Fiber AS, which

was established in 2022 and is owned by Telenor

(70%) and the global investment firm KKR (30%).

Telenor Sweden

Telenor has been present in Sweden since 2001

and is Sweden’s third largest mobile operator,

with a subscriber market share of around 21%.

Telenor is operating in Sweden under the Telenor

main brand and the Vimla sub-brand, serving a

total of 3.1 million mobile customers , whereof

around 63% in the consumer segment. In addition,

Telenor Sweden serves 1.2 million broadband and

0.8 million TV customers, based on access to fibre

networks.

Finland

#2 in mobile market

#1 in broadband market

Norway

#1 in mobile market

#2 in broadband market

Sweden

#3 in mobile market

#3 in broadband market

Denmark

#2 in mobile market

#5 in broadband market

Mobile customers (in million)

Broadband customers (in million)

Market positions as of Q2'25. Sources: Analysys Mason; Telenor data; Telenor analysis. GDP per capita source: World Bank.

2025

The company's mobile revenue market share is

around 19%, and the broadband revenue market

share is around 13%.

Telenor Sweden shares 4G and 5G networks with

Tele2 through the joint venture Net4Mobility, with

50% ownership each. The joint networks include

both passive and active infrastructure. The 2G

and 3G networks were shut down in December

2025. Telenor Sweden has 100% 5G population

coverage.

Telenor Denmark

Telenor has been present in Denmark since 2000

and is the second largest mobile operator in the

country. Services are provided under the Telenor

main brand and CBB mobile sub-brand. Telenor

Denmark serves 1.7 million mobile customers,

whereof around 70% in the consumer segment

and 30% in the business segment. In addition,

Telenor Denmark serves 0.2 million broadband

customers, based on access to fibre and cable

networks. The mobile subscriber market share is

around 21%, while the mobile revenue market

share is around 24% and the broadband revenue

market share is around 5%.

Telenor Denmark shares a mobile network with

Norlys through the joint venture TN-Netværket,

where each of the parties has 50% ownership.

The 5G population coverage is 99%.

DNA (Finland)

Telenor entered Finland in 2019 through the

acquisition of DNA, which is the country's second

largest telecom operator. Services are offered

under the DNA main brand and the Moi sub-brand.

DNA serves 2.8 million mobile customers, whereof

around 82% in the consumer segment. In addition,

DNA serves 1.4 million broadband and 0.2 million

TV customers, based on own fibre and cable

(HFC) networks. DNA has a subscriber market

share of around 32% for mobile and 29% for

broadband. The revenue market share is around

30% within mobile, and around 34% within

broadband.

DNA's customer offerings are based on strong

mobile and broadband infrastructure. DNA has

100% 5G population coverage, and has a strong

network position with an award-winning network

carrying the highest amount of data per

subscriber in Europe. In northern and eastern

Finland, DNA shares a mobile network with Telia,

with 50% ownership each. Within fixed

broadband, DNA will upgrade its customers

currently on hybrid fibre coax (HFC) to fibre over

the coming years, further strengthening and

future-proofing the broadband infrastructure.

Telenor 5G population coverage

GDP per capita (2024)

Mobile data usage (Median GB/month/user)

Employees in Telenor Nordics

Spend on suppliers with SBTi targets

People trained in digital wellbeing

2025

Telenor Asia

Telenor has been present in Asia since

1996. Since 2022, focus has been on de-

risking the Asian portfolio and building

strong market-leading positions through

in-market consolidation in Thailand and

Malaysia. The sale of Telenor Pakistan

was completed in December 2025.

At year-end 2025,Telenor's Asian footprint

included the controlled entity Grameenphone in

Bangladesh, and the associates CelcomDigi in

Malaysia and True Corporation (True) in Thailand.

In total, Telenor Asia reaches 152 million mobile

subscribers, of which 67.8 million in the

associated companies in Malaysia and Thailand.

Telenor's focus is on being an active owner and

drive performance, with the aim to deliver cash

flow growth and value creation. The Asian

businesses are followed up from Telenor's

regional office in Singapore.

Telenor Asia accounts for approximately 18% of

the group's total revenues and 23% of the group's

adjusted EBITDA. Dividends from associates

contributes to Telenor's free cash flow.

Grameenphone (Bangladesh)

Telenor entered Bangladesh in 1996 as one of its

earliest international expansions. Grameenphone

is Bangladesh’s largest mobile operator with 83.9

million customers, and a subscriber market share

of around 45%. Only 58% of Grameenphone's

customers are using data services.

Grameenphone is listed on the Dhaka and

Chittagong Stock Exchanges, and Telenor holds a

55.8% stake. As of 31 December 2025, the market

value of Telenor's stake in Grameenphone was

around NOK 16 billion. Grameenphone has

delivered an annual average dividend yield of

around 7%, and close to 100% payout of net

profits. At the end of 2025, Grameenphone

employed 1,338 people.

CelcomDigi (Malaysia)

Telenor entered Malaysia in 1999 by acquiring an

ownership stake in the mobile operator Digi. In

2022, CelcomDigi was established through the

merger of Celcom and Digi. Telenor holds a 33.1%

stake in CelcomDigi, which is Malaysia's largest

mobile network operator with 20.3 million mobile

subscribers and a subscriber market share of

around 41%. The company is listed on the Stock

Exchange of Malaysia. As of 31 December 2025,

the market value of Telenor's stake in CelcomDigi

was around NOK 31 billion. CelcomDigi's dividend

policy is to pay out >80% of net earnings, paid

quarterly.

True Corporation (Thailand)

Telenor entered Thailand in 2000 by acquiring an

ownership stake in dtac. True Corporation is the

result of the merger of True and dtac in 2023. True

Corporation is listed on the Thailand Stock

Exchange and Telenor holds a 30.3% stake. The

company has 47.5 million mobile subscribers and

a subscriber market share of around 50%. As of 31

December 2025, the market value of Telenor's

stake in True was around NOK 37 billion. On 22

January 2026, Telenor announced the agreement

to sell its ownership stake in True Corporation to

Arise Digital Technology Company Limited.

Bangladesh

#1 in mobile market

Thailand

#2 in mobile market

Malaysia

#1 in mobile market

GDP per capita (USD '000, 2024)

Mobile customers (in million)

Market positions as of Q2'25. Sources: Analysys Mason; Telenor data; Telenor analysis. GDP per capita source: World Bank.

¹ Corresponds to 50% of the total sites in the joint operations.

2025

Telenor Infrastructure

Telenor Infrastructure manages and

develops key digital infrastructure in the

Nordic area. The business area

comprises telecommunication towers,

data centres, and an AI factory. Telenor

Infrastructure serves both internal and

external customers, and employs a total

of 135 people.

Telenor Towers

Telenor Towers is the largest tower company in

the Nordics with a total of 20,000 sites and an

estimated market share of 35%. The business

includes the fully owned companies Telenor

Towers Norway with 14,000 sites, Telenor Towers

Sweden with 1,000 sites, and DNA Towers in

Finland with 4,000 sites. In addition, Telenor has

around 8,000 1 sites through the 50% ownership

stakes in the tower joint operations in Sweden

(Net4Mobility), Finland (Finnish Shared Network)

and Denmark (TN-Netværket). These operations

are included in Telenor Nordics.

Skygard

The data centre company Skygard was founded in

2023 by Telenor, Hafslund, HitecVision, and

Analysys Mason. Telenor holds a 31.7% stake in

Skygard. Skygard's data centres will serve

customers with mission-critical use. The first data

centre with 8 MW capacity is currently under

construction in Oslo. The aim is to become

operational in the first half of 2026, with Telenor

Norway as a key tenant. The data centre will be

energy efficient and with the potential to provide

district heating for around 12,000 apartments.

In December 2025, Skygard acquired two data

centre facilities from Orange Business Services

Norway, marking a strategic expansion in the Oslo

region. The acquisition boosts Skygard's capacity

and strengthens the company's position as a

leading provider of secure data storage in

Norway.

Telenor AI Factory

Telenor AI Factory was launched in November

2024, and is Norway's first AI factory. The

company will build AI capabilities in Skygard for

both internal and external customers, based on

NVIDIA technology and targeting the sovereign,

secure and sustainable customer niche. At the

end of 2025, AI Factory had 11 customers, of

which 9 external. The external customers are

predominantly start-ups running AI use cases for

larger organisations.

Telenor Amp

Telenor Amp includes the fully-owned

companies Telenor Connexion, Telenor

Maritime, Telenor Linx, KNL, and Telenor

Cyberdefence, as well as several smaller

controlled and non-controlled assets. In

November 2025, Telenor Amp

completed the disposal of its 50%

ownership in Allente. Telenor Amp

employs a total of 628 people.

Telenor Connexion

Telenor Connexion is a global Internet of Things

(IoT) provider that helps enterprises connect and

operate their devices. The company is

headquartered in Sweden and manages

international IoT deployments for global

customers such as Volvo, Scania, Hitachi, and

Husqvarna. At the end of 2025, the customer base

included more than 26 million IoT connections

globally.

Telenor Maritime

Telenor Maritime is a leading provider of maritime

communication services, serving the cruise and

ferry segments, oil and gas offshore industry, and

fisheries. The product portfolio covers

connectivity, onboard mobile and Wi-Fi services,

and digital services enabling shipowners and ship

equipment suppliers to digitalise their operations.

Telenor Linx

Telenor Linx addresses the need for seamless

international communication, account security,

direct operator billing, and digital sales of data.

Headquartered in Norway, Telenor Linx is

connected to more than 600 mobile network

operators and more than 80 partners serving

customers around the world. With scalable

platforms and APIs, Telenor Linx helps telecom

operators and hyperscalers serve their

customers.

KNL

Based in Finland, KNL specialises in secure high-

frequency communication systems for defence

and critical operations. Its flagship CNHF

technology ensures encrypted, resilient

connectivity even under jamming or without

satellite/GPS infrastructure.

Telenor Cyberdefence

Telenor Cyberdefence was established in 2024,

and is headquartered in Norway. The company

provides managed security services, targeting the

business segment in the Nordic region.

2025

Products and services

Telenor strives to provide excellent

customer experiences. We offer a wide

range of products and services, based

on secure telecommunication networks

and digital infrastructure. Our customers

are consumers and businesses, telecom

operators, and service providers¹⁾.

Mobile subscriptions and services

Mobile subscriptions provide voice and data

connectivity. Combined with the connectivity

products, Telenor offers services like security and

ID theft insurance. Our customers can choose

from a range of price plans, targeting different

needs.

Broadband and TV

Broadband subscriptions provide access to

internet, and are delivered over fibre, cable and

fixed wireless technologies. Security is an integral

part of the broadband offerings. The TV solutions

provide news and entertainment services, with

Telenor taking the role as distributor of content.

Solutions for businesses

Solutions for business customers include

managed services, virtual private networks,

software defined networks, and network as a

service.

IoT solutions are offered through Telenor

Connexion and Telenor Nordics. Telenor Maritime

offers mobile maritime communication, serving

cruise and ferry segments, fisheries, and the oil &

gas industry. KNL offers secure communication

solutions for defence forces. Telenor AI Factory

offers AI infrastructure and services, while

Telenor Cyberdefence provides cybersecurity

services.

Sale of mobile phones and other devices

To complement the end-user services, Telenor

provides various hardware like mobile phones,

broadband modems, and TV boxes. As part of its

sustainability agenda, Telenor aims to reach 30%

take-back of mobile devices in the Nordics by end

of 2030. The take-back rate measures the number

of used mobile devices collected as share of new

mobile devices distributed during the year.

Wholesale and infrastructure services

Wholesale services include national and

international roaming and interconnect, solutions

for mobile and fixed virtual network operators and

service providers, as well as leased lines and

colocation at towers and data centres.

Changes to products and services during

the year

In November 2025, Telenor Norway launched the

new entertainment offering Streamix, which is a

stand-alone subscription service for streaming

apps.

Total revenues

NOK bn

Mobile service revenues²⁾

NOK bn

Broadband and TV revenues

NOK bn

1) ESRS reference for text on this page: ESRS 2 SBM-1-40 (a) i and ii

2) Mobile service revenues consist of mobile subscriptions and services and parts of solutions for businesses

2025

Highlights of the year

Throughout the year, the

network modernisation

continued in the Nordic

operations enabling secure

and resilient award-

winning networks.

At year-end, Telenor Nordics

reached 99% 5G population

coverage, with more than

28 000 base stations

upgraded to 5G.

In July, Telenor

announced the

acquisition of

GlobalConnect's

consumer fibre business

in Norway. The acquisition

includes around 140,000

fibre customers, and is

estimated to increase

Telenor's market share

from 22% to 29%.

In October, Telenor and

Vodafone Group

announced a new

strategic

procurement

partnership which

aims to leverage the

scale and global

capabilities of both

groups across major

areas of procurement.

During 2025, Telenor

continued to strengthen

its security offerings

to customers in the

Nordics.

The Finnish subsidiary

KNL, a provider of ultra-

secure defence

communication,

signed contracts with the

Swedish and Finnish

Defence Forces.

The entertainment

service Streamix was

launched in Norway in

November. Streamix is a

stand-alone streaming

aggregation service that

lets customers bundle

multiple streaming

subscriptions into one

monthly bill, with

flexibility to swap

services every 30 days.

In November, Telenor

completed the sale of

its 50% stake in

Allente to Viaplay Group

for total proceeds of NOK

0.6 billion.

In December, the sale of

Telenor Pakistan was

completed at a valuation

of NOK 5.7 billion on a

cash and debt free basis.

In 2025, Telenor delivered 23%

total shareholder return. The

dividend per share increased to

NOK 9.60 for financial year 2024, in

line with the dividend policy.

On 4 December, Telenor celebrated

its 25 years anniversary as a

listed company at the Oslo Stock

Exchange. Since stock-listing,

Telenor has delivered an average

annual total shareholder return of

close to 10%.

On 11 November, Telenor

presented its updated

strategy and financial

ambitions towards 2030

at the Capital Markets Day.

Updated sustainability

ambitions were also

provided, targeting significant

emission reductions, digital

inclusion, and responsible,

inclusive business practices.

2025

Key fig ures in 2025

Service revenues

+2.0%

organic growth in service revenues,

compared to 3.0% in 2024.

Adjusted EBITDA

+5.8%

organic growth in adjusted EBITDA,

compared to 3.3% in 2024.

Climate

67%

of Telenor's spend was from suppliers

that have set science-based emission

reduction targets, compared to 63% at

the end of 2024.

Cyber security

2.1 billion

attempts of digital fraud were blocked by

Telenor Norway's security filters,

compared to 2.2 billion in 2024.

Free cash flow

17.3 NOK billion

free cash flow (incl. M&A) generated in

2025, compared to NOK 13.3 billion in

2024.

Workforce

10,133

total number of employees at the end of

the year.

Diversity

38%

of senior leaders in Telenor were women

by end of 2025 , compared to 36% at the

end of 2024.

Return on capital employed

9.3%

in 2025, compared to 13.0% in 2024.

Excluding associates, the return on

capital employed was 13.7% in 2025,

compared to 13.9% in 2024.

2025

Strategy,

performance

and risk


Telenor’s strategy		Group performance		Performance in the business areas		Risk management
16	Telenor's strategy	21	Financial performance	27	Telenor Nordics	31	Responsibility for risk management
17	Strategic priorities in the business areas	23	Parent company performance and financial position	28	Telenor Asia	32	Risk management process
	Strategic priorities in the business areas		Parent company performance and financial position	29	Telenor Infrastructure	33	Risk overview
20	Ambitions and outlook	24	Sustainability performance	29	Telenor Amp
		25	Research and innovation
			Research and innovation

2025

Telenor's strategy

Providing critical connectivity and services to our customers

has been the core of Telenor's business for more than 170

years. Facing forward, leveraging new technologies and building

on the strength of the company's employees and culture will be

key to creating excellent customer experiences. By doing this,

Telenor also delivers attractive shareholder returns.

Connecting customers to what matters most has been the core of

our business for 168 years. Our ambition is to deliver critical

connectivity and services to customers and societies, continue to

strengthen our responsible business agenda and utilise the

2025

Telenor's strategy

Three years after launching the strategy

plan in 2022, Telenor has made firm

progress on direction and ambitions.

Looking ahead, we continue to simplify

and future-proof the company to deliver

superior connectivity and differentiated

services. Telenor's focus remains on

creating long-term value through

customer trust, operational excellence,

and technology leadership¹.

Facing forward

Telenor is building a future-fit company by

leveraging its strategic assets; an execution

culture, world-class networks, and growing

partner ecosystem. These strengths enable

Telenor to deliver on four priorities towards 2030:

driving growth through customer excellence,

accelerating technology-led transformation,

tapering operating and capital expenditure to

sales, and expanding return on capital employed

through disciplined portfolio management.

By combining streamlined customer experiences,

cloud-native and AI-powered platforms, and

operational efficiency, Telenor aims to create

sustainable value for customers and shareholders

while positioning for long-term success.

The ambitions towards 2030 are powered by a

robust value creation engine to drive return on

capital employed. Outstanding connectivity and

services drive top-line growth through customer

excellence, combined with simplification and

transformation to capture efficiencies. These

efforts generate cash flows that enable

reinvestments in world-class networks, talent and

a future-fit technology stack, which in turn drives

improved customer excellence and shareholder

returns.

Customers

Telenor is putting the customer needs at the heart

of everything we do. The ambition is to grow

through customer excellence. To achieve this, a

key priority is to deliver streamlined and enhanced

customer experience that makes it frictionless to

become a Telenor customer and a natural choice

to stay with us. At the same time, we are scaling

AI-infused customer care to create smarter and

more personalised experiences. Combined with

differentiated services and connectivity, we

deliver more value to our customers, ensuring

that Telenor stands out as a trusted provider of

world-class solutions.

Technology

Telenor aims to leverage technology by creating

smarter networks to drive operational excellence

and ensure superior performance for customers.

At the same time, we are simplifying our

operations through cloud adoption, enabling

flexibility and efficiency at scale. Becoming an AI-

powered telco is central to Telenor's ambition,

allowing us to enhance customer experience and

unlock new growth opportunities through

intelligent automation. Telenor also focuses on

driving service innovation of differentiated

solutions for both consumers and businesses.

Underpinning these priorities is a strong

foundation of security and resilience, ensuring

that networks and services remain robust and

trustworthy in an increasingly complex digital

landscape.

Employees

People and culture are the foundation for

delivering on Telenor's strategic ambitions. A

customer mindset is embedded across the

organisation. Telenor fosters an inclusive and

collaborative environment in which employees

feel valued and empowered to innovate and grow.

Telenor is building a future-fit organisation

through collaboration and skills development.

Employees are encouraged to work across

functions and continuously improve, while leaders

support mobility and career growth to ensure the

right skills for the future. By combining execution

culture, trusted networks and partner ecosystem

with opportunities for learning and

transformation, Telenor aims to attract and

develop outstanding talents.

Sustainability

Responsible business practices and sustainability

is an integral part of Telenor’s strategy. The

company is committed to operating green and

secure network infrastructure by reducing

environmental impact and ensuring resilient

networks that can withstand cyber threats and

extreme weather conditions.

At the same time, Telenor aims to drive digital

inclusion and wellbeing by enabling individuals

and businesses to participate safely and

confidently in the digital economy through

improved skills and awareness. Equally important

is the ambition to do business in a responsible and

inclusive way, fostering diversity in leadership and

maintaining high ethical standards across

Telenor's supply chain.

1) ESRS reference: ESRS 2 SBM-1-40 (a) iii

2025

Strategic priorities in the

business areas

Telenor's strategy and value creation is

founded on distinct value creation

agendas and strategic priorities for each

of the four business areas.

Telenor Nordics

The ambition for Telenor Nordics is to build on its

position as the largest communications service

provider in the region, with a relentless focus on

excellent customer experience, sustainable and

profitable growth, declining capital intensity, and

attractive returns on capital.

The Nordic markets are digitally advanced, stable

and characterised by high purchasing power.

Customers expect sophisticated services and

solutions, and Telenor leverages its scale and

strong market position to meet these demands.

Growth will be supported by a services-led

upselling approach, focusing on areas such as

security and entertainment while strengthening

connectivity. The transformation agenda centres

around simplifying operations, deploying shared

systems and automation, and enabling faster

service innovation and improved customer

experience.

Infrastructure priorities include expanding fibre,

strengthening our world-class mobile networks,

and ensuring societal responsibility as a provider

of critical services. Advanced security products,

and measures to prevent cyber threats are key to

building a secure and future-fit Nordic telco.

Digital security for business customers

Corporate network security can no longer be

viewed in isolation from the geopolitical

environment, as heightened tensions and hybrid

threats have blurred the lines between national

security and business continuity. Recognising

this, Telenor has embedded security into the

next generation networking solutions for Nordic

business customers, centralising product,

delivery, and operational functions to accelerate

expertise and speed to market. These efforts,

supported by shared best practices and cross-

border synergies, have delivered concrete

customer wins and strengthened resilience

strategies across sectors. This topic is

extensively highlighted in Telenor's annual

Nordic digital security report for 2025.

Leveraging scale within entertainment

Telenor Nordics' organisation for TV and

entertainment is fully implemented and has

accelerated the Nordic collaboration and

transformation into pan-Nordic scalable and

future-ready services and platforms. In 2025,

several new functions and services have been

introduced to our customers, such as a new set

top box in Norway, and enhanced home theatre

with wireless surround speakers in Finland.

Telenor Sweden has successfully initiated

migration of customers to the common Nordic

TV platform.

During 2025, Telenor Nordic updated its content

portfolio with new distribution rights with key

partners. In November, the streaming

aggregation service Streamix was launched in

Norway. With Streamix, customers can bundle

multiple streaming subscriptions into one

monthly bill, with flexibility to swap services

every 30 days.

Technology transformation

Telenor Nordics has accelerated technology

transformation, driven by legacy removal that

reduces risk, cost and complexity. These efforts

enhance security, resilience, and efficiency,

paving the way for modern solutions that deliver

better customer experiences. Investments in

Nordic platforms, such as private cloud and

advanced analytics, are enabling secure,

scalable infrastructure and data-driven

decisions. As examples, Telenor Norway has

launched its first distributed data products

utilising the Data and AI platform, while DNA has

launched several new AI and security products

and taken major steps in automating the service

provisioning. Telenor's modern networks will

contribute to unlocking advanced 5G services

and ensuring reliable connectivity, exemplified

with Telenor Norway expediting its 5G swap and

Telenor Sweden with extensive network

modernisation and strong effort reaching 90%

geographical coverage.

2025

Telenor Asia

In Asia, Telenor's strategic priority is to manage

leading telco assets for long-term value creation

and explore structural initiatives for portfolio

simplification over time. The business area

continues to be an important contributor to

Telenor's cash flow.

As an active owner, Telenor aims at contributing

to shaping the companies' strategy and driving

performance, deploying talent and capabilities in

key positions, and upholding high standards of

responsible business.

For Grameenphone in Bangladesh, the ambition is

to deliver sustainable growth through a carefully

managed transition from voice to data. This

transformation will require further development

of network quality, a simplified data-centric

product portfolio, and AI-powered transformation

initiatives.

On 31 December 2025, Telenor completed the

disposal of Telenor Pakistan. On 22 January 2026,

Telenor announced the sale of its ownership stake

in True Corporation in Thailand. Following these

events, Telenor remains an active owner and

committed partner for long-term value creation in

Grameenphone and CelcomDigi.

Transformation through AI in Bangladesh

Grameenphone launched its "AI & I"

transformation programme, aimed at

positioning the company as an AI-driven telco

and tech leader. By integrating artificial

intelligence across all areas of the business,

from network operations to customer service

and marketing, Grameenphone aims to deliver

faster and more personalised experiences for its

84 million customers.

Current use cases include personalised offers,

intelligent HR solutions that enhance workplace

efficiency, and AI-assisted network optimisation

for superior service quality and reliability.

As a first mover, Grameenphone has also

established the country's first enterprise-grade

AI factory, developed in partnership with Cisco

and NVIDIA GPU technology, to accelerate AI

model development and deployment. By

combining advanced infrastructure, strategic AI

use cases and employee enablement,

Grameenphone is set to strengthen its position

as a leading in AI-native telecommunications in

Bangladesh.

Completion of tower integration in Thailand

In 2025, True Corporation (True) successfully

completed the consolidation of its network

towers under the One Network initiative,

marking a major milestone post-amalgamation.

This represents the largest network

modernisation in ASEAN, affirming True's

dedication to delivering superior network

experience and driving long-term shareholder

value.

Source of image: True Corporation PCL

True's mobile subscriber base is now positioned

to benefit from 23% boosted 5G speeds,

supported by a 98% increase in 5G bandwidth.

Beyond the direct benefits of speed and

coverage, the tower integration also contributes

to environmental sustainability by reducing

redundant towers and improving power

efficiency through AI and machine learning.

Integration and transformation approaching

completion in Malaysia

Three years after the merger, CelcomDigi’s

integration and transformation programme is

now approaching completion, with major

milestones delivered across the business. At

year-end 2025, network modernisation and

integration surpassed 90% completion, resulting

in higher service quality and customer

experience in upgraded areas. The IT

consolidation reached 80% completion. The final

phases of the enterprise resource planning and

customer relationship management systems

are underway, and progressing towards full

completion early 2027.

On the retail front, over 60 CelcomDigi stores

have been modernised, and the planned refresh

of more than 300 exclusive partner stores has

reached two-thirds completion. The new

CelcomDigi app had 5.5 million registered users

at year-end 2025, only three months after

launch.

Source of image: CelcomDigi Berhad

2025

Telenor Infrastructure

The focus for Telenor Infrastructure is to create

value through driving operational excellence and

utilisation of its passive telecommunications

infrastructure assets in the Nordic region. The

strategy is based on further enhancing green

and efficient energy solutions, strengthening

resilience and optimising the asset portfolio. In

order to ensure strategic optionality, further

streamlining and structuring of the tower asset

portfolio across the Nordics is a priority.

Telenor Infrastructure's value creation strategy

includes taking an active ownership strategy

within towers and data centres. The business

area also includes Telenor AI Factory, which

aims to provide sovereign AI infrastructure

services in Norway. Service development is

being done with customers and scaled

according to demand.

Scaling AI Factory's sovereign AI cloud

In 2025, Telenor's AI Factory has moved from

launch to preparations to scale, onboarding both

internal and external customers onto Norway's

first sovereign and sustainable AI cloud platform

built to handle sensitive data. Telenor AI Factory

has supported a variety of use cases, from real-

time translation and predictive network

maintenance to Norwegian Large Language

Models (LLM)-as-a-service. To expand capacity

and continue cementing its role as a catalyst for

innovation and sustainable AI adoption in Norway,

an additional scalable unit of GPUs has been

purchased.

Distributed energy storage

DNA Towers in Finland introduced a new

business line using distributed energy storage

(DES) to establish a virtual power plant in the

radio access network. This enables optimisation

of electricity costs, while strengthening network

resilience and supporting electricity grids in

their transition to more variable renewable

energy sources.

Telenor Amp

Telenor Amp's strategy is to develop, refine

and create value close to the core telecom

services, with Internet of Things (IoT) and

security as the main focus areas. The ambition

is to build leading near-core businesses,

through a combination of developing existing

assets, working with external partners, and

targeted investments.

Telenor Amp pursues a develop-or-divest

strategy. The portfolio companies will either

be developed to their full potential within

Telenor, together with partners, or divested.

Amp's agenda also includes building positions

by combining existing assets within the

Telenor group, mainly within IoT and security.

Building a global IoT powerhouse

Telenor has taken a significant step in the IoT

strategy by consolidating the Nordic IoT

operations under Telenor Connexion. This

consolidation is about unlocking scale and

accelerating growth with a stronger platform to

serve customers across the Nordics and globally.

The global IoT market is large and sees rapid

growth with a rising demand for connected

devices across industries. Consolidating the IoT

operations will strengthen Telenor’s leading

position in the Nordic region while responding to

evolving market dynamics.

A strategic leap for KNL

KNL delivers advanced, secure, and resilient

communication solutions with advanced HF

technology ensuring encrypted connectivity even

in challenging environments. The signing of a

NORDEFCO frame agreement with the Finnish

Defence Forces and the Swedish Armed Forces

has accelerated the growth and the further

international potential for this Telenor backed

company.

2025

Ambitions and outlook

Telenor's commitment to deliver annual

growth in ordinary dividend per share

while ensuring a solid balance sheet,

remains strong. We have performed in

line with targets and ambitions set for

2025. In November 2025, financial and

sustainability ambitions towards

2028/2030 were introduced.

Delivered on ambitions for 2022-2025

Free cash flow before M&A reached NOK 12.9

billion in 2025, in line with the ambition of "around

13 billion". The leverage ratio was 2.2x at year-end

2025, within the targeted range of 1.8x-2.3x.

In the Nordics, the average annual organic growth

in adjusted EBITDA for 2022-2025 was 6.0%, in

line with the ambition of mid single-digit growth.

Capex in 2025 was NOK 1.5 billion lower than in

2022. On a currency-adjusted basis, the reduction

was NOK 2.0 billion, in line with the targeted NOK 2

billion reduction.

The share of supplier spend covered by science-

based targets was 67% at the end of 2025, slightly

exceeding the target of 66%.

New mid to long term financial ambitions

At the Capital Markets Day in November 2025,

Telenor communicated the following financial

ambitions towards 2028/2030:

Telenor Group

• Free cash flow before M&A, excluding dividends

from associates and potential new spectrum

commitments, of NOK 12-13 billion in 2028,

increasing further to NOK 14-15 billion in 2030;

• Return of capital employed above 11% in 2028,

and above 12% in 2030;

• Year-on-year growth in dividend per share;

• Net leverage ratio of 1.8x – 2.3x.

Telenor Nordics

• Low single-digit organic growth in service

revenues;

• Low-to-mid single-digit organic growth in

adjusted EBITDA;

• Capex-to-sales ratio tapering off to below 13%

in 2028, and further down to 11-12% in 2030.

Financial outlook for 2026

Telenor provided the following outlook for 2026

in connection with its fourth quarter 2025 release:

Telenor Group

• Low-to-mid single-digit organic growth in

adjusted EBITDA;

• Free cash flow before M&A, excluding dividends

from associated companies and spectrum

commitments incremental to 2025, of NOK 10-11

billion.

Telenor Nordics

• Low single-digit organic growth in service

revenues;

• Mid single-digit organic growth in adjusted

EBITDA;

• Around 14% capex to sales (excluding

leases).

As usual, the outlook does not factor in

potential items related to prior years’

activities, e.g. claims-related payments,

legacy taxes, tax refunds, and similar.

Mid to long term sustainability

ambitions

Operating green and secure networks

• 69% reduction in scope 1 & 2 emissions by

the end of 2030.

• Ensure consistently improved security

maturity across all Telenor companies.

Driving digital inclusion and wellbeing

• Train 800,000 people in the Nordics in

digital wellbeing by 2028.

• Provide 5 million people in Asia with useful

digital training by 2028.

Responsible and inclusive business

conduct

• 40% women in Telenor's top leadership by

2028.

• 85% timely resolution of sustainability non-

conformities in the supply chain by 2028.

In addition to the sustainability ambitions

towards 2028/2030, Telenor aims to become

a net-zero company by end of 2045.

2025

Group performance

Telenor's performance in 2025 reflects solid momentum on

strategy execution and value creation across all business areas.

The combined efforts contributed to revenue growth,

efficiency improvements, and lower capital intensity. In total,

this led to strong financial results for the group, in line with the

ambitions set out in 2022.

AAAAA

2025

Financial performance

Telenor concluded 2025 with strong

financial results, in line with the

company's communicated outlook and

ambitions. Telenor Nordics was the main

driver for the group's solid performance.

The sale of Telenor Pakistan was completed on 31

December 2025. In the financial reporting, Telenor

Pakistan is presented as discontinued operations,

and historical figures have been re-presented

accordingly. Consequently, all relevant financial

figures, except net income, earnings per share,

and free cash flow, are reported excluding

Telenor Pakistan.

See page 287 for more information about

Telenor's alternative performance measures.

Revenues

Total revenues for 2025 were NOK 76,548 million.

This was an increase of NOK 1,060 million, or 1.4%,

compared to 2024. Service revenues, which

constitute around 80% of Telenor's total

revenues, increased by NOK 487 million.

The 2.0% organic growth in service revenues was

largely driven by higher mobile service revenues in

the Nordics, fuelled by increasing demand for

value-added services, pricing initiatives, and

subscriber growth in Sweden, Denmark and

Finland. The revenue growth was also supported

by increased wholesale revenues, mainly due to a

national roaming agreement in Norway.

Operating expenses (opex)

Opex amounted to NOK 24,842 million, which was

a decrease of NOK 160 million compared to 2024.

Cost reductions in Telenor Nordics were driven by

cost management and good momentum on the

transformation agenda. This was offset by cost

increases in other business areas, in particular in

Telenor Asia and Telenor Amp.

EBITDA

Adjusted EBITDA amounted to NOK 34,462 million.

This was an increase of NOK 1,289 million

compared to 2024. On an organic basis, adjusted

EBITDA increased by 5.8%. The main contributor

to the improvement was Telenor Nordic, with

service revenue growth and opex reduction as

underlying drivers.


NOK in millions	2025	2024
Revenues	76,548	75,487
Service revenues	61,194	60,707
Organic service revenue growth	2.0%	3.0%
Operating expenses	(24,842)	(25,002)
EBITDA	34,292	33,863
Adjusted EBITDA	34,462	33,173
Adjusted EBITDA margin (%)	45.0%	43.9%
Organic adjusted EBITDA growth	5.8%	3.3%
Operating profit	17,978	17,912
Taxes	(4,364)	(3,719)
Net income from associated companies and joint ventures	1,823	6,812
Net income attributable to equity holders of Telenor ASA	7,034	18,336
Adjusted net income attributable to equity holders of Telenor ASA	11,310	9,159

Earnings per share (EPS)	5.14	13.32
Adjusted EPS	8.27	6.65

Capex excl. lease	10,535	12,528
Free cash flow before M&A	12,869	11,366
Total free cash flow	17,262	13,255
Leverage	2.2x	2.4x
Return on capital employed	9.3%	13.0%

Adjusted EBITDA

34.5billion

Free cash flow

17.3billion

Revenues

76.5billion

2025

EBITDA amounted to NOK 34,292 million, which

was an increase of NOK 429 million compared to

2024. The improvement was mainly due to the

mentioned growth in adjusted EBITDA, partly

offset by lower contribution from other income

and expenses.

Net income

Net income attributable to equity holders of

Telenor ASA amounted to NOK 7,034 million in

2025. This was a decrease of NOK 11,301 million

compared to 2024. The decrease was mainly

explained by the reversal of impairment of the

investment in True Corporation of NOK 7,015

million and a gain of NOK 1,359 million related to

the sale of the satellite business, both included in

2024, whereas 2025 included a loss of NOK 3,044

million from the disposal of Telenor Pakistan and a

provision of NOK 1,212 million related to Telenor

India. This was partly offset by improvement in

adjusted EBITDA and higher contribution from

associates.

Adjusted net income attributable to equity

holders of Telenor ASA amounted to NOK 11,310

million in 2025, compared to NOK 9,159 million in

2024. The increase was mainly driven by growth in

adjusted EBITDA and increased contribution from

associates. Adjusted earnings per share was NOK

8.27 compared to NOK 6.65 for 2024.

Capital expenses (capex)

Capex excluding leases amounted to NOK 10,535

million in 2025. The capex to sales ratio was 13.8%,

down from 16.6% in 2024. In the Nordics, capex

excluding leases amounted to NOK 8,478 million,

corresponding to a capex to sales ratio of 14.3%,

in line with the communicated outlook of "around

14%". The reduced capital intensity reflects that

the Nordic 5G rollout is nearing completion.

Financial position

Telenor's total assets decreased by NOK 7,157

million during 2025, to NOK 221,651 million . The

decrease was mainly due to disposal of Telenor

Pakistan and currency effects on total assets of

approximately NOK 3.3 billion, primarily as a result

of the strengthening of the NOK against the Asian

currencies.

Net debt decreased by NOK 5,057 million to NOK

81,731 million at year-end 2025. The decrease

reflects strong free cash flow of NOK 17,262

million, partially offset by dividend payments of

NOK 13,135 million to equity holders of Telenor

ASA. Interest-bearing liabilities excluding licence

obligations increased by NOK 902 million, while

cash and cash equivalents increased by NOK

5,955 million. The leverage ratio came down from

2.4x at year-end 2024 to 2.2x at year-end 2025,

returning to the targeted range of 1.8x-2.3x.

Total equity decreased by NOK 6,143 million to

NOK 75,629 million at year-end 2025. Net income

from total operations of NOK 8,363 million was

offset mainly by dividends to equity holders of

Telenor ASA and non-controlling interests of NOK

14,871 million and negative net translation

differences of NOK 2,746 million primarily due to

the strengthening of the NOK against the Asian

currencies.

Free cash flow

Total free cash flow in 2025 amounted to NOK

17,262 million. Free cash flow before M&A

activities was NOK 12,869 million, with the main

contributions coming from Telenor Nordics with

NOK 11,175 million and dividends from associates

of NOK 2,547 million. Telenor Pakistan, which was

classified as discontinued operations, contributed

with NOK 407 million to the group's free cash flow

before M&A.

Free cash flow from M&A activities amounted to

NOK 4,393 million, mainly due to the disposal of

Telenor Pakistan.

Free cash flow (NOK billion)

17.3

15.0

13.3

Cash and cash equivalents increased by NOK

6,155 million during 2025, as free cash flow and

proceeds from borrowings were only partially

offset by dividend payments to equity holders of

Telenor ASA.

Return on capital employed (ROCE)

Return on capital employed was 9.3% in 2025,

down from 13.0% in 2024. The decline was mainly

explained by the reversal of impairment of the

investment in True Corporation of NOK 7,015

million in 2024. Excluding associates and joint

ventures, return on capital employed was 13.7% in

2025, compared to 13.9% in 2024.

Parent company performance

and financial position

The activities of Telenor ASA

The parent company Telenor ASA encompasses

executive management and group functions.

Revenues mainly derive from offering a range of

services to the group companies. Expenses in the

parent company mainly relate to consultancy fees

in strategic group projects, property lease, IT-

operations and maintenance purchased from

other group companies. Telenor ASA's treasury

function manages the main part of Telenor's

external debt financing and provides loans and

guarantees to group companies. Treasury also

manages the group's cash pool.

Results

For 2025, Telenor ASA recorded revenues of NOK

355 million, compared to NOK 678 million in 2024,

while other operating expenses increased by NOK

504 million to NOK 582 million. Telenor ASA’s net

income for 2025 was NOK 11,638 million, after

receipt of a group contribution and dividends of

NOK 15,583 million.

Allocation of profit and financial position

During the year, external interest-bearing

liabilities increased from NOK 80,301 million to

NOK 85,997 million, of which NOK 779 million is

related to currency losses. The Board proposes to

allocate the net profit in 2025 of NOK 11,638

million to retained earnings. Telenor ASA has an

equity of NOK 107,794 million after this allocation.

In the view of the Board, Telenor ASA has a solid

financial position.

2025

Sustainability performance

Digital infrastructure has become a

foundation for societal wellbeing,

sustainable growth and secure

participation in an increasingly digital

world. In 2025, Telenor strengthened this

role by advancing secure and sovereign

solutions, and by enabling sustainability

through technology and digitisation.

Aligned with the sustainability statements,

Telenor Pakistan is included in the metrics,

excluding the end of period data for 2025.

Accelerating climate actions

Telenor remained broadly on track to achieve a

69% reduction in scope 1 and 2 emissions by

2030, despite an emission increase from 2024 to

2025. A key milestone was reached as 67% of our

suppliers by spend set science‑based climate

targets, fulfilling a major ambition of our 2022–

2025 strategy period. This reflects the growing

alignment across our value chain and the shared

recognition that the green transition requires

collective action.

The scope 1 & 2 emissions decreased by 32% in

2025, compared to the 2019 baseline. Long-term

power purchase agreements (PPAs) are the main

contributors to reduced emissions combined with

purchases of Guarantees of Origin for renewable

electricity. At year-end 2025, the Norwegian,

Finnish, and Danish PPA were operational. In

addition to the 2025 engagement target related to

scope 3, our associate True in Thailand set long-

term science-based targets in 2025, and

CelcomDigi submitted targets for validation

during the fourth quarter 2025.

The take-back rate for mobile devices in the

Nordics was 14% at the end of 2025. This is slightly

higher than a year ago, mainly driven by increased

take-back rates in Norway and Finland.

Expanding digital inclusion and wellbeing

Digital connectivity only creates value when

people can use it safely and meaningfully.

Through long-standing partnerships with UNICEF

and Plan International, Telenor reached 13.5

million individuals between 2021 and 2025 with

training that supports digital inclusion and

wellbeing—most of them in our Asian markets.

These efforts help ensure that the benefits of

digitalisation are accessible, equitable, and

empowering for individuals as well as societies.

During 2025, more than 1.2 million people, of

which 888,000 in Bangladesh, were trained in

digital skills and online safety together with

partners. In the Nordics almost 337 thousand

people, mainly children and youths were trained

during 2025. Focus areas in the digital skills

training include how to be safe and secure, how to

be a good friend when online, and digital well-

being.

Investing in people and culture

Our workforce is central to Telenor’s long-term

value creation. In 2025, we engaged employees

across the organisation to shape a renewed

purpose and customer-centric cultural

foundation. We strengthened our commitment to

diversity and inclusion, enhanced employee

engagement, and invested in AI tools and

awareness. A new people strategy was

introduced, focusing on seamless employee

experience, cross-functional collaboration, and

upskilling for an AI-enabled future.

The share of women in senior leadership positions

was 38% at year-end 2025, up from 36% a year

ago. The share of women in senior leadership

positions was higher than the share of women in

the total workforce, which was 31%.

Strengthening responsible business

practices

Health & Safety remains a non-negotiable priority.

In 2025, zero work-related fatalities were

recorded in Asia, though regretfully one fatal

accident involving a supplier employee occurred

in Sweden. We continued to reinforce supply

chain responsibility through a new strategic

partnership with Vodafone Procurement

Company and deeper collaboration within the

Joint Alliance on CSR (JAC), enhancing supplier

engagement, auditing and oversight. Through

mandatory trainings on Telenor’s code of conduct

and human rights practices, we reaffirmed our

commitment to ethical business practices.

The share of resolved non-conformities in the

supply chain was 96% at year-end, exceeding the

target of 90%. During the year, a total of 953

supplier audits and inspections were conducted in

Asia, and 67 in the Nordics.

Updated double materiality assessment

Our double materiality assessment for 2025

identified a broad set of impacts, risks, and

opportunities across nine material areas,

reflecting the increasingly complex interfaces

between telecom operations, society, and the

environment.

Active and transparent engagement with

stakeholders remains essential to maintaining

trust. Their insights continue to shape our

materiality assessments and guide our updates to

management and supervisory bodies.

Sustainability metrics


	2025	2024
Climate change mitigation
Scope 1 and 2: Reduction of absolute GHG emissions ¹⁾	32%	37%
Scope 3: Share of supplier spend covered by science- based targets	67%	63%
Circularity
Take-back rate of mobile devices (Nordics)	14%	13%
Digital skills, inclusion and online safety
Number of people trained in digital skills (in million) ²⁾	13.5	12.3
Mobile internet users (% active data users) ³⁾	62%	60%
Diversity, equity and inclusion
Women in senior leadership positions ³⁾	38%	36%
Responsible supply chain
Closure rate of non- conformities in the supply chain	96%	88%

1) Baseline year is 2019.

2) Accumulated from 2021.

3) End of period 2025 excluding Telenor Pakistan.

2025

Research and innovation

activities

Innovation in Telenor happens where

customer needs and technology meet.

Telenor has built a strong track record of

leadership in emerging technologies and

service development. As a result,

tangible value is created for customers

by combining research, innovation, and

customer insight.

Customer-driven innovation

Across the group and in every business area,

innovation initiatives are focused to create

intuitive, secure, and personalised experiences,

driven by Telenor's strong commitment to deliver

superior value to customers. In 2025, this includes

enhancing customer interactions through

AI‑powered chat and voice services, enabling

richer service personalisation, and improving

overall customer experience. In Norway, the

launch of the entertainment service Streamix has

given customers greater flexibility and choice.

Telenor continues to develop advanced security

solutions to protect users from digital fraud and

safeguard their data. Through the Telenor AI

Factory, Norway’s first sovereign AI factory,

customers can securely leverage cutting‑edge

technology to fuel their own innovation and

growth.

Research collaboration

Telenor is recognised for advancing

telecommunications research, working closely

with leading industry partners and academic

institutions to shape the future of digital

infrastructure. These collaborations provide early

insight into frontier technologies and emerging

trends and ensure that global research

perspectives strengthen Telenor's future

readiness in ways that can be applied to core

areas of business.

A major part of Telenor’s partnership portfolio

within research consists of long-term initiatives

within the EU research and innovation programme

Horizon Europe, and the Research Council of

Norway. Telenor is active in several Centres of

Excellence on 5G, 6G and artificial intelligence (AI)

research and innovation in Norway and Europe.

Together with leading scientific economists we

conduct research on digital transformation.

Exploring the future

Telenor's Open Lab is a test bed designed to

facilitate open innovation as a tool for growth,

collaboration and technological advancement

across industries to the better for society. As an

innovation playground, the Open Lab combines

customer-centric innovation processes with

advanced technological test beds.

Telenor’s research and innovation unit is

investigating emerging and forward-looking

technologies with a ten-year outlook for next-

generation networks. The unit is also

strengthening its research and innovation

infrastructure in artificial intelligence by

leveraging data and AI models to address

complex business challenges. Additionally,

Telenor is actively engaged in public discussions

regarding responsible AI.

AI survey among Telenor employees

During 2025, Telenor's research and innovation

unit executed a scientifically structured survey

about the use of AI tools within Telenor. Nearly

5,000 employees across Telenor contributed

with their perspectives on AI in the workplace.

The findings provide a factual basis for shaping

tools, training, and guidelines. A key insight is

that AI enhances not only automation and

efficiency, but also increases quality and skill

development using currently available tools.

The survey has also established a shared

language and benchmark, making collaboration

easier.

As an essential component of the global AI

programme, the survey results have been

actively used by the programme, individual

business units, and other strategic initiatives

across Telenor. As such, the survey has

contributed to deriving benefit from AI in

Telenor.

Connected forestry

The research and innovation team has worked

with the forestry industry to explore how mobile

connectivity could enable remote operation of

heavy equipment. Funded by Horizon Europe,

the COMMECT project targets improved

connectivity for forestry and agriculture in rural

areas.

Telenor’s research and innovation unit

addressed challenges like efficiency, safety,

sustainability, and limited 5G coverage in

Norway’s Forestry Living Lab. Industry

collaboration produced two prototypes: a

remote expert tool for machine operators and a

fire monitoring system. Field tests used mobile

private 5G, satellite backhaul, and 360° video

streaming. Data from drones and IoT sensors

were analysed with AI and machine learning.

Users anticipate reduced costs and emissions,

better safety, and fewer operational shutdowns.

These solutions suit Nordic countries, notably

Sweden and Finland’s large logging sectors. The

remote expert tool also supports autonomous

operation trends. Telenor's research and

innovation unit continues to engage

stakeholders to advance these results.

2025

Performance in the

business areas

Performance in 2025 was characterised by good progress on

strategic priorities across all business areas. In the Nordics, we

continued to see profitable growth and solid progress on the

ambitious transformation agenda. In Asia, we drove value

creation from the associated companies in Malaysia and

Thailand, while navigating through the challenging

macroeconomic situation in Bangladesh. Telenor Infrastructure

continued to streamline its tower business while building new

business within secure and sovereign infrastructure, and Amp

continued to develop its asset portfolio, focusing on IoT and

security.

2025

Telenor Nordics

Throughout 2025, Telenor Nordics

continued to develop its pan‑Nordic

operating model, which is based on

shared services and cross-Nordic

efficiency initiatives, while maintaining

strong local customer focus and

commercial momentum. This approach

resulted in 2.7% organic growth in

service revenues, 8.7% organic growth in

adjusted EBITDA, and a free cash flow of

NOK 11,165 million.

Mobile subscriptions grew by 48,000, mainly from

Sweden offsetting reductions in Norway.

Broadband subscriptions decreased by 48,000 as

good fibre growth in most markets was offset by

reductions in legacy technologies and fewer low-

margin fibre subscriptions in Sweden.

The service revenue growth was driven by

sustained momentum in mobile, while broadband

revenues declined slightly as the portfolio

continued to be optimised away from legacy and

low‑margin products.

Opex decreased by 1.3% organically, positively

impacted by efficiency initiatives more than

compensating for higher sales and marketing

costs.

Capex decreased as the 5G rollout is nearing

completion, reaching a total of NOK 8,478 million,

or 14.3% of revenues. At year-end, 5G population

coverage was approaching 100% in all markets.

Norway

In Norway, the value-driven commercial strategy

and firm cost control continued, resulting in

strong financial performance.

Competition in the mobile market remained

strong, particularly towards the end of the year,

leading to 57,000 fewer subscriptions. The

positive impact of the more-for-more strategy

continued and ARPU increased by 5%, resulting in

a 3.4% increase in mobile service revenues.

Within the broadband segment, higher fibre

revenues offset lower revenues from legacy

products, resulting in a 1.0% increase in

broadband service revenues. Fibre subscriptions

increased by 21,000, partly offsetting reductions

in cable and fixed wireless access subscriptions.


	Year		YoY Change
NOK in millions	2025	2024	Reported	Organic
Telenor Norway	20,996	20,483	2.5%	2.5%
Telenor Sweden	10,667	10,052	6.1%	0.8%
Telenor Denmark	4,730	4,432	6.7%	5.1%
DNA Finland	10,316	9,782	5.5%	3.7%
Service revenues	46,674	44,672	4.5%	2.7%
Telenor Norway	14,178	12,920	9.7%	9.7%
Telenor Sweden	5,303	4,644	14.2%	8.5%
Telenor Denmark	1,955	1,858	5.2%	3.7%
DNA Finland	5,254	4,804	9.4%	7.6%
Adjusted EBITDA	26,723	24,223	10.3%	8.7%
Operating profit	12,773	10,359	23.3%	n.m.
Capex excl. lease	8,478	9,678	(12.4)%	n.m.
Free cash flow before M&A	11,175	10,781	3.7%	n.m.
Total free cash flow	11,165	10,761	3.7%	n.m.

Together with stable opex and contribution from

mobile wholesale revenues, this resulted in 9.7%

growth in adjusted EBITDA.

Sweden

Strong sales performance and a targeted shift

from low-margin fixed products to 5G broadband

resulted in mobile subscription growth of 95,000

in 2025. While mobile service revenues increased

by 3%, fixed service revenues decreased by 3%,

mainly due to the mentioned shift from low-

margin legacy products to 5G broadband.

Combined with improved gross profit from

mobile, the fixed broadband transformation and a

4.4% organic reduction in opex, adjusted EBITDA

increased by 8.5% organically.

Denmark

Solid commercial performance saw mobile

subscriptions increasing by 4,000 mainly from

fixed wireless access, while fixed remained stable

as growth in fibre of 20,000 was offset by

reduction in legacy subscriptions. Pricing

initiatives and portfolio mix effects led to mobile

and fixed ARPU growth of 4% and 2%

respectively. Mobile service revenues grew by

7.2% organically, whereas fixed declined by 6.6%

from the decline in legacy services mainly from

decommissioning of the copper network.

An ongoing IT and sales channel transformation

led to opex increasing by 6.6%, but the strong

mobile performance resulted in an organic

adjusted EBITDA growth of 3.7%.

Finland (DNA)

Competition intensified throughout 2025, as

exemplified by the entry of MVNOs, but DNA still

saw a growth of 5,000 mobile and 15,000 fibre

subscriptions. The more-for-more strategy and

other value moves saw mobile ARPU increasing by

2% and fixed ARPU by 4%, resulting in organic

service revenue growth of 4.4% in mobile and

1.6% for fixed, despite lower revenues from legacy

products.

Firm cost control resulted in opex decreasing by

3.7% organically, mainly through lower personnel

costs. Combined with higher service revenues,

this resulted in 7.6% organic growth in adjusted

EBITDA.

2025

Telenor Asia

In 2025, Telenor Asia's service revenues

decreased by 0.2% while EBITDA

decreased by 3.0%, both measured on

an organic basis. Dividends from

associated companies amounted to NOK

2,010 million.

The slight decline in service revenues of 0.2% was

fully attributable to Grameenphone, as the figures

for business area Asia have been re-presented

following the completion of the sale of Telenor

Pakistan. As a result, business area Asia no longer

includes any contribution from Telenor Pakistan.

EBITDA for Asia also showed a decline in 2025,

driven partially by Grameenphone, but also from

from higher costs in the regional offices in Asia.

Net income from associated companies and joint

ventures amounted NOK 1,760 million, explained

by a contribution of NOK 522 million from

CelcomDigi and NOK 910 million from True. The

contribution from CelcomDigi was negatively

impacted by an adjustment of NOK 530 million

related to their associated company Digital

Nasional Berhad (DNB). CelcomDigi and True are

listed companies, and they normally publish their

quarterly results after Telenor. The share of

profits from these companies is therefore

included in Telenor's reporting with one quarter

lag.

For the full year of 2025, free cash flow before

M&A amounted to NOK 3,247 million. The increase

compared to last year was primarily driven by

True's inaugural dividend payout in the fourth

quarter of 2025.

Bangladesh (Grameenphone)

Grameenphone faced a difficult economic

environment in Bangladesh throughout 2025, as

inflationary pressure and weak consumer

spending affected demand and impacted growth.

Performance gradually improved during the year.

However, the underlying recovery remained weak.

For the full year, this resulted in a slight decline in

service revenue of 0.2%. Disciplined cost

management was a consistent focus throughout

the year. Consequently, adjusted EBITDA returned

to growth towards the second half of the year. For

the full year, adjusted EBITDA declined by 1.5% on

organic basis.

In January 2026, Grameenphone secured

spectrum in the 700 MHz band, with a licence

duration of 13 years. The spectrum is suitable for

improving indoor coverage and rural connectivity.

As of 31 December 2025, Grameenphone's market

capitalisation was NOK 29 billion on 100% basis, of

which Telenor’s stake accounted for NOK 16

billion. This was a decrease of 32% compared to

end of 2024, or 24% in local currency.

Malaysia (CelcomDigi)

CelcomDigi delivered results for 2025 in line with

financial guidance for the year. Service revenues

increased by 1.1%. EBIT rose 15.7%, reflecting

stronger topline contribution and ongoing cost

efficiencies. CelcomDigi’s integration and

transformation programme is now approaching

completion. CelcomDigi closed the year with 20.3

million mobile subscribers. The board of

CelcomDigi continued to declare quarterly

dividend payments throughout the year, of which

Telenor received NOK 1,382 million in 2025.

As of 31 December 2025, Celcom Digi's market

capitalisation was NOK 93 billion on 100% basis, of

which Telenor’s stake accounted for NOK 31

billion. This was a decrease of 14% compared to

end of 2024, or 12% in local currency.


	Year		YoY Change
NOK in millions	2025	2024	Reported	Organic
Service revenues	12,830	14,417	(11.0)%	(0.2)%
Adjusted EBITDA	7,835	9,049	(13.4)%	(3.0)%
Operating profit	4,708	5,674	(17.0)%	n.m.
Capex excl. lease	1,110	1,752	(36.6)%	n.m.
CelcomDigi	522	1,046	(524)	n.m.
True Corporation	910	6,041	(5,131)	n.m.
Others	328	134	194	n.m.
Net income from associates and joint ventures	1,760	7,221	(5,461)	n.m.
Dividends from associates and joint ventures	2,010	1,318	692	n.m.
Free cash flow before M&A	3,247	2,502	29.8%	n.m.
Total free cash flow	2,754	2,410	14.3%	n.m.

Thailand (True Corporation)

True Corporation reported a 0.7% decline in

service revenues in 2025, mainly driven by lower

contribution from the mobile and PayTV business

segments. Operating expenses were reduced by

16.0% and EBITDA increased by 7.0%, driven by

benefit from spectrum acquisition and realization

of synergies. During 2025, the net debt/EBITDA

ratio came down from 4.2x to 4.0x. The Board of

Directors have proposed a final dividend of THB

4.1 billion based on the net profit of the last three

months of 2025, representing a payout ratio of

104%. This brings the full-year dividend to THB

10.7 billion, representing a payout ratio of 116%.

As of 31 December 2025, True’s market

capitalisation was NOK 121 billion on 100% basis,

of which Telenor’s stake accounted for NOK 37

billion. This was a decrease of 5% compared to

the end of 2024, or 2% in local currency.

2025

Telenor Infrastructure

In 2025, Telenor Infrastructure delivered solid

performance despite the impacts of customers'

continued phase-out of legacy technologies like

2G/3G and copper. Performance was supported

by continued growth in the tower business and

build-up of new business within sovereign AI

compute services and data centre capacity.

The growth within the tower business in Norway

was driven by customers’ 5G deployment,

offsetting the negative effects from shut-down of

copper networks and 3G sunset in Sweden. The

mobile tenancy ratio increased from 1.6 to 1.7

during the year.

While the market for sovereign AI compute

services remained in an early stage, Telenor's AI

Factory continued to develop its business and

increase customer engagement. At year-end,

Telenor AI factory was serving 11 customers,

predominantly start-ups running pilot AI use cases

for larger organisations.

The associated company Skygard's first own-built

data centre is expected to be launched in second

quarter 2026, with Telenor Norway as a key

tenant. Early January 2026, Skygard strengthened

its data centre position in Norway through the

acquisition of two data centres in the Oslo area,

including an experienced operations team and an

established customer base.

Telenor Infrastructure's revenues in 2025 were

broadly stable. 28% of the total revenues came

from external customers. Stable total revenues

combined with lower operating expenses within

the tower business, resulted in 2.7% organic

growth in adjusted EBITDA after lease

depreciation. Cash flow before M&A was NOK 981

million, which was 3.8% higher than in 2024 .

Entering 2026, Telenor Infrastructure has a

strong operational foundation and a service

portfolio which is well positioned to meet the

growing demand for secure, scalable, and energy-

efficient digital infrastructure.


	Year		YoY Change
NOK in millions	2025	2024	Reported	Organic
Total revenues	3,318	3,282	1.1%	0.4%
Adjusted EBITDA after lease depreciation	1,671	1,596	4.7%	2.7%
Operating profit	974	940	3.6%	n.m.
Capex excl. lease	734	890	(17.6)%	n.m.
Free cash flow before M&A	981	946	3.8%	n.m.
Total free cash flow	709	866	(18.2)%	n.m.

Telenor Amp

Telenor Amp’s performance in 2025 was shaped

by industry shifts, strong subscription growth

within IoT, headwinds in application-to-person

(A2P) messaging, and significant progress within

defence communications. The development of

the asset portfolio continued, in line with the

business area's focus on IoT and security.

The IoT provider Telenor Connexion continued to

see strong volume growth, ending 2025 with a SIM

base of 26.3 million, which was 24% higher than at

year-end 2024. The volume growth stemmed

primarily from the markets outside the Nordic

home markets.

KNL delivered exceptionally strong performance

in the second half of 2025, as high-value orders of

secure communication solutions to Swedish and

Finnish defence forces under the NORDEFCO

frame agreement, started to materialise.

Telenor Maritime faced continued operational

challenges, including roaming restrictions and

falling rates, particularly within the cruise

segment.

Telenor Linx continued to experience structural

declines within international voice and A2P

messaging, while development of new digital

business is still in an early phase.

The divestment of Telenor’s 50% stake in Allente

to Viaplay Group was completed in November.

Prior to the divestment, dividends of NOK 533

million was received from Allente in 2025.

For Telenor Amp, this resulted in 0.7% growth in

total revenues, and 0.6% decrease in adjusted

EBITDA, with improving profitability towards year-

end. The free cash flow of NOK 512 million was

driven by dividends received from Allente, more

than compensating for settling of payments from

Linx to Telenor Pakistan.


	Year		YoY Change
NOK in millions	2025	2024	Reported	Organic
Total revenues	3,517	3,494	0.7%	(1.0)%
Adjusted EBITDA	445	448	(0.6)%	(4.6)%
Operating profit	205	1,644	(87.5)%	n.m.
Capex excl. lease	182	160	13.7%	n.m.
Net income from associates and joint ventures	95	(403)	498	n.m.
Dividends from associates and joint ventures	533	107	426	n.m.
Free cash flow before M&A	512	82	524.0%	n.m.
Total free cash flow	1,009	2,163	(53.3)%	n.m.

2025

Risk management

A well-functioning Enterprise Risk Management (ERM) is crucial

for Telenor to achieve our strategic ambitions. It is also a

commitment to our stakeholders. Telenor is exposed to a wide

range of risks across multiple markets. These risks are

prioritised based on a materiality assessment, with a primary

focus on mitigating and reducing exposure to acceptable levels.

Telenor also performs a double materiality risk assessment

related to sustainability topics. This chapter describes how risks

are managed across Telenor, the processes and the

organisation set up to manage risks, and highlights some of the

key risks facing Telenor and how these are handled.

2025

Responsibility for risk

management

Telenor’s risk management objective is

to earn competitive returns from its

business activities at acceptable risk

levels and without compromising its

purpose, values and Code of Conduct.

The Board of Directors of Telenor ASA

(Board) and its Risk and Audit Committee

(RAC) have key oversight roles in the

ERM process and carry out regular

reviews of the company’s most

important areas of exposure and its

internal control arrangements.

The involvement of the Board of

Directors

The Board has set out its responsibilities for

oversight of the company’s risk picture and

profiles in its instructions as follows:

“ The Board shall /…/ensure that the company’s

most important commercial and operational risks

are identified and that measures are implemented

to deal with these, and carry out an annual review

of the company’s most important areas of

exposure and its internal control arrangements.”

The involvement of the Risk and Audit

Committee (RAC)

RAC is a preparatory committee that supports the

Board on various topics. RAC's responsibilities

associated with risk management and control are

set out in its charter, and the annual wheel

together with the detailed planning and follow up

ensures that such responsibilities are covered

throughout each calendar year:

• Supervise the Group’s risk governance

structure and risk management practices.

• Supervise the procedures to identify and assess

financial and non-financial risk and implications.

• Review and discuss the risk policies and risk

management and present the holistic picture to

the Board for the Board’s consideration and

approval.

• Review the suitability of the risk reporting to the

Board as well as externally.

• Prepare the Board's review of the risk matrix.

In 2025, alongside its biannual review of group-

wide top risks, the RAC also conducted several in-

depth reviews of key risk areas. The RAC fulfilled

its supervisory role of overseeing the risk

governance structure, risk management

practices, procedures and policies, ensuring that

a yearly review on ERM methodology is conducted

thereof.

Three lines model

Telenor follows a three lines model to ensure

clarity of roles and responsibilities in the context

of risk management.

The first line resides with managers at all levels

throughout Telenor, who are responsible for risk

management within their areas of responsibility

and ensure that risk management is embedded in

day-to-day business processes. Ownership of top

risks and corresponding risk responses lies with

the Executive Vice Presidents of the company and

ultimately to the President & CEO. The most

important risk areas are regularly discussed in the

executive management meetings.

The second line includes Group enterprise risk

management (ERM), Group Compliance and other

specialist functions. The second line functions

develop policies and procedures for managing

risk, facilitate risk assessments and contribute to

the bi-annual ERM status updates. More broadly,

they support, challenge and monitor the first line.

Group ERM is the facilitator of the risk

management process and assists management

maintaining an appropriate risk management

framework, including policies, procedures, and

tools.

Group Internal Audit and Investigation provides

assurance as the third line function. The

department ensures a systematic and disciplined

approach to evaluate and improve the

effectiveness of Telenor’s risk management,

control, reporting and governance processes.

2025

Risk management process

Key steps in the risk management

process

ERM in Telenor is a coordinated process, which

pulls together information about risks and

mitigation activities using both a top down and a

bottom-up approach to form an integrated

assessment of the risk picture. This ensures a

consistent risk management effort across the

company. Telenor’s risk management process is

broadly based on ISO 31000:2018 and is an

iterative and dynamic process. This process

includes the following steps and is implemented

across all business areas and the Telenor

companies:

Step 1: Scope, context and criteria

Risks are linked to Telenor’s strategic ambitions,

goals and operations. Ambitions set for each

business area during the annual strategy process

are cascaded down to the Telenor companies

managed by each business area.

Step 2: Risk assessment

The strategic and operational risks that may

impact ambitions, goals or other objectives are

identified. The risk taxonomy is used as a guiding

tool in this process. The risks are analysed by

assessing the impact and likelihood for each risk.

Telenor uses both qualitative and quantitative

approaches to assess the impacts of the risks.

The risks are evaluated to prioritise according to

the ERM framework/methodology.

Step 3: Risk treatment

The objective is to reduce the exposure to an

acceptable level. The main risk responses are to

avoid, mitigate, share/transfer and accept. In case

of opportunity (upside of risk) the response is to

pursue/increase the opportunity.

Step 4: Risk reporting and aggregation

Risk and mitigation action information from all

levels and processes of the business come

together to form an integrated view of the risk

picture.

The risk management information flows from

Telenor companies to business areas and finally

to the Telenor Group/Head Quarters (HQ). The

top risks of the business areas and the underlying

Telenor companies are input to Telenor’s group-

wide risk picture which is linked to Telenor’s

ambitions. Additional risks from the ownership

perspective are also considered during the

aggregation process.

The aggregated risk picture is prepared bi-

annually by Group ERM. Calibrations and quality

assurance are done in the Group Risk Forum and

the Group Management (GM) before the

aggregated risk picture is presented to the RAC

and the Board.

Monitoring and communication

Monitoring and review are continuous activities

that run in parallel with all stages of the risk

"In the current landscape of macroeconomic and

geopolitical uncertainties, navigating

complexities is not a challenge to evade but a

terrain to skillfully navigate. The Board of

Directors believes that effective risk

management is the compass that guides Telenor

through this intricate journey, ensuring

sustainable value creations and resilience."

Ottar Ertzeid, Chair of Risk and Audit Committee

management process. Clear communication and

consultation are crucial for effective risk

management.

Risk taxonomy

An important part of the process is Telenor’s risk

taxonomy comprising a comprehensive, common

and stable set of risk categories and sub-

categories. It ensures a uniform approach to risk

identification and assessment process across the

Telenor companies and facilitates a risk

aggregation process at the Telenor Group level.

The risk taxonomy is reviewed periodically.

Risk appetite

Risk appetite is broadly defined as the level of risk

an entity deems acceptable in the pursuit of its

overall goals. Telenor’s Code of Conduct sets out

standards that Telenor commits to within various

areas, such as but not limited to, corruption,

climate and environment, health and safety,

privacy and human rights. For the full version of

Telenor’s Code of Conduct, refer to Telenor.com.

The objectives and appetite for financial risks are

described in note 31 to the consolidated financial

statements and include measures to limit liquidity

risk, interest rate risk, currency risk and credit

risk.

Double Materiality Assessment (DMA)

Telenor performed a DMA during 2025. The

Financial Materiality assessment was carried out

leveraging the materiality thresholds used in the

ERM process. See more information about the

DMA process on page 80.

2025

Risk overview

Development of risks in 2025

Telenor operates across multiple markets and

faces a diverse range of risks and geopolitical

events that may impact the business. Telenor is

exposed to a broad spectrum of risks, with

regulatory, political, and macroeconomic factors

among the most significant, particularly in the

Asian markets. However, the sale of Telenor

Pakistan and the announced sale of the ownership

stake in True Corporation in Thailand are

expected to reduce Telenor's overall risk

exposure in the region. While similar risks exist in

the Nordics, they tend to be less pronounced and

differ somewhat in nature.

This section highlights some of the main risks and

uncertainties that may impact Telenor’s

operations and how these risks are managed.

Many of the risk areas are related to sustainability

topics, and these are covered in more detail in the

Sustainability Statements.

Geopolitical risks

Risk factors

Global geopolitical developments are creating

significant uncertainty for Telenor, driven by

escalating U.S. - China technology competition,

expanding sanctions, tariff pressure and tighter

export controls. These pressures are disrupting

supply chains, increasing compliance burdens,

and impacting the availability and cost of key

network and IT components.

The tension between China and Western

countries continues to escalate. Western

governments are ramping up pressure and

restrictions against China's technology industry,

while China is trying to increase its influence and

operations worldwide. Cyber and hybrid threats

targeting critical infrastructure remain elevated.

The U.S. and Israeli military operation against Iran

that started on 28 February 2026 heightens the

risk of global financial market disruption and

prolonged macroeconomic deterioration. A direct

conflict involving Iran — a major oil producer and

a key actor around the Strait of Hormuz —

together with the risk of escalation involving other

oil‑producing countries, increases the likelihood

of sustained energy price volatility, tighter global

financial conditions, and renewed inflationary

pressures. These developments may impact

Telenor through higher operating and financing

costs. For Bangladesh, the situation may result in

shortage of energy supply, with direct and indirect

impact on Grameenphone.

Following the departure of the Bangladeshi Prime

Minister in August 2024, an interim government

led by Professor Muhammad Yunus oversaw the

transition to a parliamentary election held on 12

February 2026. While the election represents an

important stabilising milestone, uncertainty

remains around policy direction and momentum

of the reform process. As a consequence, slower

than anticipated economic recovery continues to

affect overall business activity and

Grameenphone's operations, keeping its

operational and strategic risks elevated.

Potential impacts

The ongoing geopolitical developments are giving

rise to a range of risks, including business security

(encompassing both cyber and physical security),

supplier and supply chain vulnerabilities, data

privacy concerns regarding personal information,

restrictions on the use of certain IT and network

suppliers, as well as financial risks. Each of these

risks, together with their possible impacts and

corresponding responses, are highlighted further

within this section.

Markets and Competition

Risk factors

The main market risk is a potentially more

intensified competition in the mobile markets in

the Nordics, driven by price promotions and

campaign offerings, the rise of new virtual

network operators, change in the market

structure, and change in customer preferences. In

Bangladesh, the transition from traditional voice

services to data represents an additional

competitive risk.

Potential impacts

Intensifying competition may increase churn and

erode revenue growth, market share, and

profitability.

Risk response

The market dynamics require ongoing adaptation

and innovation to sustain performance, and

several initiatives are in place to protect topline

growth. Ongoing transformation initiatives

designed to reduce fixed costs is also an

important contributor to build financial resilience

against changes in market conditions.

Business security

Risk factors

Telenor handles significant quantities of sensitive

and confidential information throughout its

business operations. In light of an increasingly

volatile geopolitical landscape, the threat

environment has intensified, with heightened

risks of sophisticated cyber-attacks including

ransomware and potential physical disruptions to

critical infrastructure. Furthermore, the rapid

acceleration of artificial intelligence and large

language models offer vast opportunities for

innovation but also introduce new risks.

Potential impacts

Unauthorised disclosure of confidential

information or disruptive attacks could adversely

affects customers or Telenor’s operations,

resulting in damage to business operations and

and loss of revenues, as well as erode customer

trust, damage Telenor's reputation and expose

the company to potential regulatory fines.

Risk response

Telenor’s security maturity programme measures

the enterprise-wide security posture and drives

targeted gap closing activities. Telenor’s common

security community fosters collaboration through

threat intelligence sharing to increase situational

awareness and provide actionable insights. The

Secure-by-design and risk-based approach uses

Telenor’s Defendable Architecture and industry

best practices. There is a strong focus on

continuous engagement, training and awareness

to embed a resilient security culture across the

organization. See more information about cyber

security on page 146.

2025

Suppliers and supply chain

Risk factors

Telenor handles a diverse array of supplies

required for its operations. The complexity of

supply chain management has increased due to

rapid technological advancement, heightened

geopolitical tensions, and evolving regulatory

demands.

Potential impacts

This elevated complexity and volatility may result

in increased costs, higher inventory levels, supply

interruptions, and non-compliance with sanctions,

export controls and environment standards.

Collectively, these impact may lead to additional

financial cost and reputational damage to the

company.

Risk response

Telenor's centralised procurement function

Telenor Procurement Company (TPC) adopts a

three-horizon strategy, focusing on short,

medium, and long-term measures to enhance

resilience and diversification through robust

supplier risk management. TPC continuously

monitors emerging risks and adapts its response

to safeguard operational continuity. Key

measures include securing long-term supply

agreements, forging innovative partnership, and

enhancing demand planning and forecasting. TPC

also optimises inventory and logistics to

anticipate lead times, leverages procurement

scale for competitive pricing, and ensures robust

category strategies. These initiatives reinforce

Telenor's ability to respond effectively to both

immediate and longer term supply chain

challenges.

Personal data

Risk factors

The privacy risk relates to the compliance risks of

personal data protection as regulated by relevant

privacy laws and regulations, as well as lack of

trust from stakeholders, customers and

employees. Privacy risk can occur in many ways,

such as, but not limited to, breach of

requirements relating to:

• Security

• Information governance

• Data retention

• Data subject rights

• Privacy notice

• Data Protection Impact Assessment

• Purpose and legal basis

• Data minimisation and anonymisation

• Cross border data transfer

Potential impacts

The impact on Telenor may be substantial fines,

class actions, loss of business opportunities, loss

of trust as well as loss of revenues. Risks may also

have an impact on society and on individual

consumers.

Risk response

To manage its privacy risk, Telenor has

established a group-wide Privacy Policy reflecting

important privacy principles, risk areas and

related control domains. The implementation of

the Privacy Policy is monitored across the

company. See more information about privacy on

page 129.

Network quality and robustness

Risk factors

The quality and reliability of Telenor’s

telecommunications services depend on the

resilience and stability of its networks, including

the networks of other service providers with

which it interconnects. These networks are

vulnerable to service interruptions, damage or

data breaches coming from targeted and

advanced cyber-attacks.

Potential impacts

Repeated, prolonged or major network or IT

system failure could affect customers and

damage Telenor’s reputation and financial

performance, including its ability to attract and

retain subscribers.

Risk response

Telenor invests in new technologies and

modernization of existing network which are

more robust and resilient in response to cyber-

attacks, climate change and extreme weather

events. Operational processes have been

designed to ensure conformity to legal and

security requirements, in addition to establishing

defendable architecture based on recognised

industry standards to protect the networks and

data from potential attacks and breaches.

Continuous proactive assessment, testing and

audits to identify gaps in operational and

technical capabilities are in place to ensure

business continuity and recovery from unwanted

incidents. Telenor deploys significant resources to

stop scam calls, spam, nuisance, unwanted robo-

calls and unsolicited calls.

Attract and retain employees

Risk factors

The transformation of Telenor’s organisation can

cause uncertainty amongst employees. This could

lead to difficulty in attracting, developing, and

retaining skilled employees.

Potential impacts

The lack of ability to attract and retain talent can

lead to lack of operational efficiency, lack of

innovation, loss of competitive advantage and

lack of ability to achieve Telenor's strategic

ambitions. The amount of change can lead to

disengagement and therefore decrease in

operational efficiency and/or increased turnover

of employees.

Risk response

Telenor's people strategy which was launched in

November 2025, mitigates talent related risks by

broadening talent management and succession

planning and developing future skills through

strategic workforce planning. Supported by

leadership, these initiatives ensure experts and

leaders are ready for critical roles, employees gain

skilled aligned with future needs, and Telenor

remains an attractive employer and a great work

place to work.

2025

People safety

Risk factors

Employees and suppliers involved in Telenor’s

operations are exposed to a range of health and

safety risks. Traffic, work at height, network

rollout in remote locations, terrorism, natural

disasters, social unrest, ergonomics and stress

remain risk areas that are relevant to Telenor.

Potential impacts

Risk can lead to fatalities or serious injury to

employees and suppliers. There is also a risk of

legal liabilities due to non-compliance with health

and safety regulations. Potential loss of critical

competencies and increased backlog of

important tasks resulting from higher sick leave is

another potential consequence.

Risk response

Telenor has implemented a set of policies guiding

its approach in this critical area with the aim of

reaching zero injuries to employees and business

partners. There are rigorous safety protocols and

training programmes in place to address the risk

exposure Telenor has over the past years

invested significant efforts into a Safety Advance

Program that aims to strengthen the Health and

Safety culture across, particularly the Asian

Telenor companies and the suppliers and

business partners. Telenor has a systematic

approach to incident investigations, aiming to

facilitate learning, provide training and monitor

risks. See more information about people safety

on page 110 and page 120.

Climate and environment

Risk factors

Climate-related physical risks include potential

damage to vital infrastructure and utilities through

the impact of more extreme weather events like

flooding, cyclones, rising sea levels and wildfires.

Climate-related regulatory risks include higher

indirect costs from regulation of greenhouse gas

emissions and higher capital costs from

renewable energy transition requirements.

Potential impacts

Increased frequency and severity of extreme

weather events and chronic climate change may

lead to damage to Telenor’s networks and

infrastructure and increased costs of repair,

maintenance. Increase in the cost of emitting

GHGs may lead to increased operating expenses.

Risk response

Telenor is proactively investing in infrastructure

where withstanding severe weather is a design

criterion. In flood prone areas in Asia tower

fundaments are raised and equipment is mounted

in the towers rather than on the ground. In Norway

investments in dual fibre connections to towers

are expected to reduce downtime in the mobile

network. Telenor is proactively sourcing

renewable electricity through long term Power

Purchase Agreements (PPA), to secure access to

renewable energy at predictable costs. See more

information about climate and environment on

page 85.

Corruption risk

Risk factors

Corruption is a threat to Telenor’s business and

the societies where the company operates,

particularly in Asia. It can undermine legitimate

business activities, distort competition, damage

reputations, and expose individuals to risk.

Corruption-related risks include bribery,

facilitation payments and trading in influence.

Potential impacts

Possible impacts include regulatory sanctions,

fines, penalties and reputational damage.

Corruption can also negatively impact economic

and social development in the affected societies.

Risk response

A risk-based Anti-Corruption Compliance

Programme to prevent, detect and remedy

corruption risk is implemented in all Telenor

subsidiaries. Telenor has a global network of

compliance officers who support implementation

of the programme in its subsidiaries. See more

information about corruption risk on page 142.

Human rights

Risk factors

Telenor’s most salient human rights risks remain

ensuring the right to privacy and data security,

freedom of expression, labour rights, working

conditions including health and safety in the

supply chain, forced and child labour in supply

chain, cyber security and children’s online safety.

Potential impacts

Potential consequences include breach of

personal data, compromised health and safety for

underprivileged and minorities as well as children

and underage working in hazardous conditions

which in turn could lead to children without leisure

time and education opportunities. A shortage in

labour supply could lead to systemic forced

labour, legal liabilities, reputational damage, and

other complaints against Telenor.

Risk mitigation/response

Respect for human rights is integral to Telenor’s

business and embedded in Telenor’s Code of

Conduct, Human Rights policy requirements, and

Telenor’s Supplier Conduct Principles. Telenor

performs due diligence to identify and mitigate

human right risks. Telenor conducts due diligence

to identify and mitigate human right risks. Telenor

has tool and processes and a risk based

approach, such as managing and monitoring

business partners, and driving programs and

initiatives that strengthen cyber security and

promote online safety . See more about human

rights on page 110, 120 and 129.

2025

Spectrum

Risk factors

There is risk related to the timing of spectrum

acquisitions, their price levels, and impact on

Telenor’s market positions and value creation in

the Asian markets. There is low risk associated

with spectrum in the Nordics.

Potential impacts

Spectrum related risks may have significant

financial impact and create uncertainty and

challenges for network investments and could

lead to Telenor not being able to provide services

due to lack of required spectrum.

Risk response

Telenor supports efficient use of spectrum

resources to handle the increasing demands for

mobile broadband capacity. Specific spectrum

risk responses are developed on a case-by-case

basis. Spectrum auctions are handled by a

centralised team with specific competence and

experience in the relevant aspects of spectrum

auctions and deployment.

Regulatory risk

Risk factors

Telenor’s operations are subject to requirements

through sector-specific laws, regulations and

national licences. Telenor depends on licences

and access to spectrum and numbering resources

in order to provide telecommunication services.

The risk is particularly high in Asian markets with

issues related to high spectrum prices, tax

regulation and disputes, renewal of licenses and

general unpredictability in the business

environment. In Bangladesh, Grameenphone has

several pending and unresolved regulatory and

legal cases. The divestment of Telenor Pakistan

has, however, reduced the overall exposure in this

area.

In addition to sector specific regulation Telenor’s

operations are exposed to general regulations

including but not limited to competition law. In

Bangladesh and Norway Telenor is exposed to the

risk of being accused of abusing a dominant

market position.

Potential impacts

Regulatory risk could affect Telenor’s results and

business prospects. Unforeseen events could

cause disruption in planned network rollouts and

generate risks associated with not meeting

license obligations. In Bangladesh, the risks can

impact the commercial freedom of

Grameenphone, and lead to an increased financial

burden through unexpected tax cost and negative

impact to reputation. Violation of competition

laws are subject to severe sanctions and can also

result in damage claims.

Risk response

Telenor is committed to working towards

securing modern regulatory frameworks and tax

regimes, ensuring that everyone can derive the

full benefit of a digital society.

Proactive engagement with key government

stakeholders is key to gaining insight and the best

possible understanding of applicable

requirements.

Telenor is also re-assessing legacy disputes and

de-risking the litigation portfolio by settling

selected cases through Alternative Dispute

Resolution (ADR) processes. Telenor has an

efficient and well-functioning competition

compliance programme aimed at reducing

competition law risks throughout the Group. For

more information, see note 23 Legal disputes and

contingencies in the Financial statements.

Restrictions on use of suppliers and

partners of IT and networks

Risk factors

Governments place restrictions on which

suppliers can be used. The restrictions are

typically referring to suppliers from specific

countries and are relevant for most key

technology domains including services. The

deployment of 5G equipment in several European

countries is a salient example.

Potential impact

So far, this risk seems to be more pronounced for

operations in Europe. As an example, such

restrictions can make it more difficult to conduct

a competitive tender process.

Risk response

Telenor follows a risk mitigation strategy that

factor in the regulatory requirements and

strengthen the trust of consumers, businesses

and partners.

Telenor is generally promoting open systems that

give suppliers a measure of flexibility. This

leverages industry initiatives like Open RAN,

cloud-native mobile core, and Open Digital

Architecture.

A global and strong relationship with partners

helps secure a holistic governance across Telenor

and contributes to proactive and constructive

dialogue with suppliers and governments.

2025

Currency risk

Risk factors

Currency risk arises when Telenor or any of its

subsidiaries has liabilities, investments, financial

instruments or enter into other transactions in

foreign currencies. A significant share of

Telenor’s revenues is generated from operations

with a functional currency other than the

Norwegian krone.

Potential impacts

Foreign exchange gains and losses can arise when

contracts are made in currencies other than

functional currencies. Currency fluctuation affect

the investments' revenues and valuation in

foreign operations when translating financial

statements into Norwegian kroner.

Risk response

In order to partially mitigate the foreign exchange

risk associated with its net investments in foreign

operations, Telenor utilises foreign currency debt

in relevant currencies and derivatives to maintain

net investment hedges linked to the value of its

foreign investments.

Foreign currency debt is normally issued in Euros

and Swedish krona. Financial derivatives are used

to establish debt positions in other currencies.

Hedge ratios in Asian currencies are more limited

by local regulations and market capabilities, and

would involve greater liquidity risk.

For more information, note 31 Capital and

financial risk management in the Financial

statements.

Interest rate risk

Risk factors

Telenor is exposed to fluctuations in interest rates

through interest bearing liabilities and liquidity

management activities.

Potential impacts

Increased interest rates can result in to higher

interest rate expenses.

Risk response

The interest rate risk is managed using both fixed

and floating rate debt, and through interest rate

derivatives. The Group's finance policy states that

the portion of the fixed rate shall be between 50

and 100% of external debt.

For more information, see note 30 Interest-

bearing liabilities and note 31 Capital and financial

risk management in the Financial statements.

Credit and counterparty risk

Risk factors

Telenor’s exposure to credit risk mainly relates to

trade receivables, deposits with financial

institutions and financial derivatives. Credit risk

related to trade receivables is assessed to be

limited due to the high number of customers in

the Group’s customer base.

Potential impacts

Credit risk can result in to financial loss due to

counterparty default and not fulfilling its

contractual obligations.

Risk response

Credit risk arising from financial derivatives and

cash deposits is managed through diversification,

internal risk assessment, credit scoring, as well as

credit risk mitigation tools.

Exposures are spread across highly rated

institutions and monitored against maximum

limits for financial counterparties.

Liquidity risk

Risk factors

Liquidity risk refers to inability to meet payment

obligations. Telenor keeps liquidity risk low and

maintains financial flexibility through diverse

funding sources.

Potential impacts

Liquidity risk can result in to the company not

being able to meet its financial commitments.

Risk response

Telenor ensures access to a diversified set of

funding sources, including committed and

uncommitted sources of funding. Debt maturities

are spread out in time, and Telenor maintains

short-term and long-term liquidity forecasts.

According to the Group Finance Policy, Telenor

shall have sufficient sources of liquidity to cover

expected operational liquidity needs for the next

12 months. Telenor maintains a solid balance

sheet with a targeted net debt / EBITDA ratio of

1.8x – 2.3x, and has strong credit ratings. For more

information, see note 31 Capital and financial risk

management in the Financial statement.

2025

IF386y766

Corporate

governance

Governance principles

and framework

The Board and

governing bodies

Executive Management

Sustainability

matters

Executive

compensation

The overall structure

Telenor ASA Board of Directors

Group Management

Roles and responsibilities

Compensation to the

Corporate Assembly and the

Board

Key principles of Telenor's

governance model

The working committees of the

Board

The President & CEO

How sustainability matters

have been addressed

Executive Management

Compensation to the Group

Management

Governance framework

The General Meeting

Other governance functions

Basis for reporting

The Corporate Assembly

The Nomination Committee

The External Auditor

2025

way of Work etc

Governance

principles and

framework

Effective corporate governance relies on robust processes,

controls and procedures to monitor, manage and oversee a

company's operations. At Telenor, this is fundamental to value

creation, trust-building and securing access to capital. Over the

years, the Board and Executive Management have consistently

worked to strengthen our governance practices, making

corporate governance a value-adding differentiator in our

operations.

2025

The overall structure

Telenor is a public limited liability company,

governed in accordance with applicable laws,

regulations and best practices. Telenor's overall

structure is illustrated to the right, outlining

Telenor's principal governing bodies,

management functions and external auditor.

The Annual General Meeting serves as Telenor's

highest authority, empowered to make any formal

decision unless otherwise restricted by law or the

Articles of Association. The Corporate Assembly

acts as an oversight body, supervising the Board

of Directors ("Board") and the management of the

company. The Board itself is responsible for the

overall administration of the company, including

oversight of day-to-day management and the

safeguarding of its operations. The Board is also

tasked with ensuring that Telenor adheres to

generally accepted principles of effective control

of company activities ("corporate governance").

In addition, Telenor's governing framework

includes the Nomination Committee and two

preparatory working committees to the Board in

accordance with applicable law and corporate

governance principles, which support the Board in

fulfilling its responsibilities.

The President & CEO holds responsibility for the

daily management of Telenor's operations,

supported by advisory management teams

(referred to as "Group Management").

Key principles of Telenor's

governance model

Telenor upholds sound corporate governance by

establishing rules and procedures to guide its

business. This commitment is supported by a

strong governance framework in which roles and

duties related to risk management and internal

control are explicitly assigned and well

coordinated. The overall purpose is to ensure that

company values are consistently embedded

throughout the organisation, thereby fostering

long-term value creation for all stakeholders.

It is the role and responsibility of the Board to

ensure that Telenor complies with internationally

recognised standards for effective oversight of

the company’s activities. The Board is also tasked

with issuing the necessary guidelines for both

these activities and the broader corporate

management.

Telenor’s corporate governance principles and

practices are regularly reviewed and discussed by

the Board and Management. Furthermore, the

Board upholds this standards in its own work and

decision-making.

The Board and Group Management are

committed to the ongoing enhancement of

Telenor's governance framework, ensuring that

governing documents remain relevant and are

thoroughly implemented across the organisation.

Separately listed companies must also consider

the regulatory requirements applicable to listed

companies within their respective jurisdiction.

2025

Governance framework

Articles of Association

Telenor’s Articles of Association serve as a

constitutional document, setting out the

company's purpose, principal areas of business

activity and the framework for its governance.

Telenor's Articles of Association (AoA) were last

amended by the Annual General Meeting on 21

May 2025.

Telenor's AoA state: “The object of the company

is to engage in telecommunications and other

related activities. These activities may be

conducted by the company itself, by subsidiaries

or through participation in other companies or in

cooperation with others.” The complete Articles

of Association can be accessed at telenor.com.

Governing documents

Telenor's key governing documents comprise the

following:

• Code of Conduct

• Supplier Conduct Principles

• Group Governing Principles

• EVP Instructions and Group Delegation of

Authority

• Group Policies

• Finance Procedures

Telenor’s governing documents help ensure that

all employees conduct their activities in an ethical

manner and in compliance with applicable

legislation and Telenor standards.

Code of Conduct and Integrity Hotline

Implementing high ethical standards across

Telenor remains to be a strong focus of the Board.

Telenor’s Code of Conduct outlines legal

requirements, management ambitions, ethical

business practises and sustainability standards.

The Code of Conduct is fundamental to Telenor’s

corporate governance as it fosters a healthy and

robust corporate culture encouraging ethical

behaviour at every level.

The Code Principles form the foundation of

our ethical culture and define the core of

our business conduct. Key principles are:

We play by the rules. We follow laws,

regulations and our policies and, if in

conflict, we uphold the highest standard.

We are accountable for our actions. We

actively seek information, understand our

responsibilities, and recognise our wider

impact on the societies in which we operate.

We are transparent and honest. We are

open and truthful about our challenges.

We speak up. We ask questions when in

doubt and raise concerns without fear of

retaliation.

The Code of Conduct is owned and approved by

the Board and it is formally adopted by the boards

of each Telenor Company for implementation

across the organisation. Every year, all employees

are required to complete an updated e-learning

programme featuring dilemma-based training,

and to formally sign the Code of Conduct. In 2025,

the training programme achieved a completion

rate of 100%.

Employees who become aware of any kind of

infringement of the Code of Conduct are

encouraged to raise their concerns with their

leader or the Local or Group Chief Compliance

Officer. Neglecting to report such breaches may

itself be considered a breach of Telenor’s Code of

Conduct. To further support transparency,Telenor

has established an integrity hotline that is

accessible to all employees across the Group.

Supplier Conduct Principles

The Supplier Conduct Principles define the

minimum standards that apply to all suppliers and

any parties with whom Telenor has a direct

contractual relationship. The Supplier Conduct

Principles are approved by the Board.

Group Governing Principles

Telenor Group’s Governing Principles outline the

organisation's governance framework, detailing

the roles of key governing bodies within Telenor

ASA. They set out the interactions between

Telenor ASA and the business areas, as well as

both controlled and non-controlled entities.

Additionally, these principles define core global

processes, including strategy, financial reporting,

forecasting and reviews.These principles are

applicable to Telenor ASA, its business areas and

all Telenor Companies. The term "Telenor

Company" refers to any subsidiary, or group of

subsidiaries, that is directly or indirectly controlled

by Telenor ASA.

EVP Instructions and Group Delegation

of Authority

The EVP Instructions, issued by the President &

CEO to all EVPs, define authority limits, strategy

execution and governance, risk, sustainability and

compliance requirements as well as reporting

requirements. These Instructions are specifically

tailored to align with the distinct responsibilities

of each EVP. The Group Delegation of Authority

sets out the levels of authority regarding financial

commitments within controlled companies.

Group Policies

Telenor has established Group Policies that define

mandatory requirements for compliance risk

areas and other selected subject areas. These

policies include procedures designed to mitigate

risks associated with financial and sustainability

reporting. They also facilitate the assessment,

management and mitigation of tax, treasury and

enterprise risks. The policies set forth the

fundamental standards and principles to which all

Telenor Companies must adhere to.

Each Business Area EVP is responsible for

ensuring that Group Policies are adopted by each

local board of directors, and that they are

implemented and monitored effectively.

The outcome of the Group Policies

implementation monitoring is regularly reported

to Telenor Group.

2025

Finance policy and related procedures

Telenor maintains a Group Policy on finance and

related procedures, which sets out mandatory

requirements designed to mitigate risks

associated with incorrect accounting, financial

and sustainability reporting. The policy also aims

to assess, manage and mitigate tax risks, treasury

risks and enterprise risks.

Governance of associated companies

Telenor has established clear requirements for

the governance of its associated companies,

defined as entities in which Telenor holds

significant but non‑controlling shareholdings.

These companies are expected to implement and

comply with ethical standards that are aligned

with those of Telenor. Further, Telenor mandates

that associated companies operate in compliance

with applicable rules and regulations and within a

risk-based governance framework.This

framework must include a compliance and anti-

corruption programme, consistent with

recognised international standards. Furthermore,

Telenor requires these companies to ensure that

both the board and its shareholders receive

accurate, clear and up-to-date information on

relevant matters. Associated companies are

overseen through their respective boards, with

Telenor nominating directors to serve on boards

as appropriate.

Telenor systematically monitors the

implementation of, and adherence to, its

governance framework and ethical standards

within associated companies, as well as reviewing

their performance. The Business Area EVPs are

responsible for this oversight, operating in

accordance with the EVP Instructions issued by

the President & CEO. Directors of associated

companies, together with the functional teams

within each Business Area, support the Business

Area EVP in fulfilling those responsibilities.

In Asia, dedicated Investment Management

Teams for Malaysia and Thailand, along with

specialised expert functions (such as governance,

compliance, health and safety, sustainability and

legal), support the EVP & Head of Asia and

directors in overseeing the associated

companies. Their responsibilities include defining

ownership priorities, monitoring performance and

strategy, implementation governance frameworks

and addressing other areas to safeguard

Telenor's interests and maximise opportunities

within the associated companies.

Basis for reporting

Relevant laws and guidelines

Telenor ASA is a public limited liability company

incorporated under Norwegian law, with its shares

listed on the Oslo Stock Exchange (Oslo Børs). As

a listed company, Telenor complies with and

operates in accordance with rules and regulations

applicable to the Oslo Børs, including the

prevailing Issuer Rules and Rule Books. Further,

Telenor is subject to specific legal regulations in

all jurisdictions where the Telenor Group

conducts business.

Telenor reports in accordance with applicable

Norwegian legislation and EU regulations. The

consolidated financial statements for the Telenor

Group are prepared in compliance with IFRS®

Accounting Standards as adopted by the EU,

together with the supplementary requirements

set out in the Norwegian Accounting Act.

The Sustainability statements are prepared in

accordance with the applicable CSRD and ESRS

requirements, as detailed in the General

information section of the Sustainability

statements. Telenor complies with the corporate

governance principles and practices stipulated in

Section 2-9 of the Accounting Act and the

Norwegian Code of Practice for Corporate

Governance (Norwegian Code of Practice),

pursuant to the latest edition dated 28 August

2025, available at nues.no.

The Board of Directors' report in relation

to the Norwegian Code of Practice

The Board is committed to upholding a high

standard of corporate governance throughout

Telenor Group, in line with applicable Norwegian

and international legislation, as well as and

internationally recognised standards. In this

Annual Report, the Board outlines the company's

compliance with the Norwegian Code of Practice

by providing an index of the Code’s requirements

and references to the locations of the relevant

information, refer to page 43. Adherence to the

Norwegian Code of Practice operates on a comply

or explain principle, whereby any deviations must

be justified and explained, including a description

of any alternative solution adopted by the

company.

Deviations from the Norwegian Code of

Practice

Based on the Board's best assessment, Telenor

has identified three deviations from the

Norwegian Code of Practice: two relating to

Section 6 and one relating to Section 14. Each

deviation is detailed below.

General Meetings (section 6) - Board member

attendance

The Norwegian Code of Practice recommends

that all Board members attend the Annual General

Meeting (AGM). Telenor has not found it

necessary to require the presence of every Board

member. However, the Chair of the Board, the

Chair of the Nomination Committee and the

Corporate Assembly, the President & CEO and

other relevant members of management are

present at the AGM.

General Meetings (section 6) - Election of chair

The Norwegian Code of Practice recommends

that the general meeting should have the

opportunity to elect an independent chair.

According to Article 8 of the Articles of

Association of Telenor ASA, the Chair of the

Corporate Assembly presides over the general

meeting.

Takeovers (section 14)

Any reduction in the Norwegian state's ownership

stake requires a special resolution from the

Norwegian Parliament. Consequently, the Board

has not adopted specific guiding principles as

recommended by the Norwegian Code of

Practice, Section 14, as the parliamentary process

ensures that the intentions of the Code of

Practice are upheld. In the event of a takeover bid,

the Board will comply with the Norwegian Code of

Practice.

2025

Overview of Norwegian Code of Practice disclosures


Chapters in the Norwegian Code of Practice		Reference to chapter in this report
1	Implementation and reporting on Corporate Governance	Corporate governance/Governance principles and framework, page 39 Corporate governance/Governance principles and framework/ Basis for reporting, page 42
2	Business	Strategy, Performance and Risks/Telenor’s strategy, page 15 Strategy, Performance and Risks/Risk Management, page 30 Corporate governance/General information/Sustainability matters, page 59 Corporate governance/Governance principles and framework/ Governance framework/Articles of Association, page 41 Corporate governance/The Board and governing bodies/The Telenor ASA Board of Directors, page 45
3	Equity and dividends	Shareholder information/Telenor shares/Share capital and equity/Equity, page 70 Shareholder information/Telenor shares/Share capital and equity/Development of share capital in 2025, page 70 Shareholder information/Shareholders and dividends/ Shareholder remuneration/ Dividend policy, page 67 Shareholder information/Shareholder remuneration/Proposed dividend for 2025, page 67
4	Equal treatment of shareholders	Shareholder information/Shareholders and dividends/ Ownership, page 66 Shareholder information/Telenor shares/Share capital and equity/Increase in share capital, page 70 Shareholder information/Telenor shares/Shareholder principles/ Transparency and equal treatment, page 70
5	Shares and negotiability	Shareholder information/Telenor shares/Shareholder principles/ Transparency and equal treatment, page 70


Chapters in the Norwegian Code of Practice		Reference to chapter in this report
6	General meetings	Corporate governance/The Board and governing bodies/The General Meeting, page 50
7	Nomination committee	Corporate governance/The Board and governing bodies/The Nomination Committee, page 51
8	Board of directors: composition and independence	Corporate governance/The Board and governing bodies/The Telenor ASA Board of Directors, page 45 Corporate governance/The Board and governing bodies/The Corporate Assembly, page 51
9	The work of the board of directors	Corporate governance/The Board and governing bodies/The Telenor ASA Board of Directors, page 45
10	Risk management and internal control	Strategy, Performance and Risks/Risk Management, page 30 Corporate governance/The Board and governing bodies/The Telenor ASA Board of Directors, page 45 Corporate governance/The Board and governing bodies/The working committees of the Board, page 49 Corporate governance/The Executive Management, page 53 Corporate governance/Sustainability matters, page 59
11	Remuneration of the board of directors	Corporate governance/Executive compensation/Compensation to the Corporate Assembly and the Board, page 63
12	Salary and other remuneration for executive personnel	Corporate governance/Executive compensation/Compensation to the Group Management, page 63
13	Information and communications	Shareholder information/Telenor shares/Shareholder principles/ Information and communication, page 70
14	Takeovers	Shareholder information/Telenor shares/Shareholder principles/ Takeover, page 70
15	Auditor	Corporate governance/The Board and governing bodies/External auditor, page 52

2025

The Board and

governing bodies

The Board of Directors is ultimately responsible for overseeing

the management of Telenor and safeguarding effective

corporate governance. Telenor has established mandatory and

voluntary committees to maintain high standards of corporate

governance. The presence of highly skilled, experienced

members and a diverse composition within Telenor's governing

bodies is therefore essential. Competence in

telecommunications, technology, security and sustainability is

regarded by Telenor as critically important.

2025

The Telenor ASA Board of Directors



	Jens Petter Olsen Chair of the Board Committee: Chair of PCC Term of office: Elected 10 May 2023, re-elected 21 May 2025 for up to two years.		Gyrid Skalleberg Ingerø Deputy Chair of the Board Committee: Member of RAC Term of office: Elected 10 May 2023, re-elected 21 May 2025 for up to two years.		Ottar Ertzeid Board member Committee: Chair of RAC Term of office: Elected 10 May 2023, re-elected 21 May 2025 for up to two years.		Pieter Knook Board member Committee: Member of RAC Term of office: Elected 11 May 2020, re- elected 7 May 2024 for up to two years.

Born in 1961, Norwegian citizen and resident in Bern, Switzerland. Experience Olsen has extensive experience in the financial sector and capital markets. Since 2019 he has served on the Board of Directors of DNB Bank ASA, where he also chairs the Risk Management Committee. From 2008 to 2018, he held various management positions at Danske Bank, including Head of Markets Norway (2011 to 2014) and Head of Capital Markets (2014 to 2018). Olsen also brings over a decade of experience from Norges Bank and Norges Bank Investment Management (NBIM), where he led the New York office of NBIM from 2000 to 2008. Other directorships Olsen currently serves as Vice Chair of the Board of Directors at DNB Bank ASA. Education Olsen holds a degree in Economics and Business Administration ("Siviløkonom") from the Norwegian School of Economics (NHH) as well as a Master of Philosophy in Finance from London Business School, where he also participated in the PhD programme. Attendance rate in 2025 Attendance was 90 % for the Board and 100 % for PCC.		Born in 1967, Norwegian citizen and resident in Oslo, Norway. Experience Ingerø has extensive management experience working with listed and private equity- backed companies. From 2017-2023 she served as EVP & Group CFO at Kongsberg Gruppen ASA, where her responsibilities included sustainability reporting and taxonomy. Previous roles include positions in banking at Nordea, CFO / Investor Relation of Komplett Group ASA, SVP & CFO of Telenor Norge AS and SVP & CFO at Telenor Digital Businesses AS. She also spent 8 years at KPMG. Other directorships Ingerø is a board member at Gjensidige ASA, Kitron ASA, Höegh Autoliners ASA, KID ASA, Sentia ASA, Nammo AS, and BAMA AS. She has held various directorships in listed companies, including Chair and Board member positions within the Kongsberg Group and Telenor Group. Education Ingerø is a State Authorized Public Accountant from the Norwegian School of Economics (NHH) (“statsautorisert revisor”). In 2024, she completed sustainability reporting training provided by the Norwegian Institute of Directors Attendance rate in 2025 Attendance was 100 % for the Board and RAC.		Born in 1965, Norwegian citizen and resident in Oslo, Norway. Experience Ertzeid has held several senior management positions, including Group CFO of DNB Bank ASA from 2019 to 2021, where he was also responsible for sustainability reporting. Prior to that, he was CEO for DNB Markets from 2001 to 2019. He has also held other roles in DNB, including the position as CFO of DNB Boligkreditt AS and Head of Finance of Realkreditt. Other directorships Ertzeid is Chair of the Board of Directors of Entra ASA and Vice Chair of the Board of Directors of Argentum Fondsinvesteringer AS, Verdipapirforetakenes Sikringsfond (The Norwegian Investor Compensation Scheme) and Dextra Artes AS. He is also a Board member of Luminor Holding AS and Luminor Bank AS - the largest independent bank in the Baltics - as well as DNB Livsforsikring AS. Education Ertzeid holds a degree in Economics and Business Administration (“Siviløkonom”), specialising in Finance, from BI Norwegian Business School. Attendance rate in 2025 Attendance was 100 % for the Board and RAC.		Born in 1958, Dutch citizen and resident in London, United Kingdom. Experience Knook has broad international business experience in sales, marketing and product development from multinational technology companies. He held several management positions at Microsoft from 1990 to 2008, including President for Microsoft Asia (1997 to 2001) and SVP for Mobile Communications (2001 to 2008). He was Vodafone's Internet Services Director (2008 to 2010) and a Visiting Professor of Innovation at the University of Cambridge. Other directorships Knook is currently Chair of the Board of LINX – The London Internet Exchange (UK). Knook also serves as a board member at Alpha 10X (France) and is a member of Cambridge Angels. Previous directorships include serving as a member of the Board of Directors at TDC from 2013 – May 2018. Education Knook holds a degree in Engineering (Electrical Sciences) from the University of Cambridge. Attendance rate in 2025 Attendance was 100 % for the Board and the Board committees (TIC and RAC).

2025



	Grethe Bergly Board member Committee: Member of RAC Term of office: Elected 7 May 2024 for up to two years.		Marianne Dahl Board member Committee: Member of PCC Term of office: Elected 21 May 2025 for up to two years.		Mats Granryd Board member Committee: Member of PCC Term of office: Elected 21 May 2025 for up to two years.		Roger Rønning Employee representative Committee: Member of PCC Term of office: Elected 21 May 2025 for up to two years.

Born in 1962, Norwegian citizen and resident in Oslo, Norway. Experience Bergly is currently CEO of Multiconsult ASA since 2019, after being EVP since 2002. Prior to this she has been researcher and project manager at Norges Byggforskningsinstitutt, department head and project engineer at Aker Engineering AS and held various engineering consultant roles. Other directorships Bergly is a Board member of SOS Children's Villages and an advisory Board member at Sintef. Previously, she has chaired The Norwegian Association of Consultant Engineers and SFI – KLIMA 2050, served on Sintef Byggforsk's advisory board, and held board positions at Norplan AS, Norplan Tanzania and Multiconsult Asia Plt Ltd. Education Bergly holds a B.Sc. (Hons.) in Civil and Structural Engineering from the University of Manchester Institute of Science and Technology and an MBA from Heriot- Watt University, Edinburgh. Bergly has also attended the INSEAD Advanced Management Program. Attendance rate in 2025 Attendance was 100 % for the Board and RAC.		Born in 1974, Danish citizen and resident in Copenhagen, Denmark. Experience Dahl is a Global Senior Advisor at Boston Consulting Group, specialised in the Tech, Media, and Telco sector. She has held senior leadership roles at Microsoft, including Vice President for Western Europe and Country CEO for Denmark & Iceland, and previously served as Senior Vice President at TDC. With over 20 years of TMT experience, Dahl has a strong track record in driving growth through sales, marketing, and innovation. She also brings board experience from listed companies and has contributed to national digitalization initiatives in Denmark. Other directorships Dahl currently holds board positions at TietoEvry and the Technical University of Denmark (DTU). Education Dahl holds an M.Sc. from Aarhus University, Denmark. Attendance rate in 2025 Attendance was 100 % for the Board and PCC.		Born in 1962, Swedish citizen and resident in Stockholm, Sweden. Experience Granryd is the former Director General of the GSMA, where he led global industry initiatives and advocacy efforts until stepping down in March 2025. Prior to joining GSMA in 2016, he was President and CEO of Tele2, one of Europe’s fastest-growing telecom operators. Previously, he spent 15 years at Ericsson in senior roles across Europe, Asia, and Africa, including leading regional units and major global customer accounts. Other directorships Granryd has served as Chair of the Board of Directors at Vattenfall since 2022, where he is also a member of the Remuneration Committee. Since 2024, he has been Chair of the Board of Business Sweden and a member of the Board and the Risk and Audit Committee at Ratos. Education Granryd holds an M.Sc. from the Royal Institute of Technology in Stockholm. Attendance rate in 2025 Attendance was 100 % for the Board and 67 %¹ for PCC. ¹ The attendance rate is based on meetings held after assuming the position in May (2 out of 3 meetings)		Born in 1966, Norwegian citizen and resident in Eidskog, Norway. Experience Rønning has been with Telenor since 1985, initially working across customer-related functions including sales, marketing, and finance. Since 2007, he has served as a full-time union representative for Negotia and was elected head of the union in Telenor in 2016—a role he continues to hold. Rønning has board experience from Telenor Norge AS and Telenor Pensjonskasse and has served multiple terms in the Corporate Assembly. He was an employee- elected member of the Board of Directors at Telenor ASA from 2021 to 2023 and currently chairs the election committee in Negotia. Education Rønning holds a degree in IT and Marketing from NKS and a degree in Labour Law at University College of Southeast Norway. Rønning conducted leadership training for top union representatives at Kristiania University College. Attendance rate in 2025 Attendance was 100 % for the Board and PCC.

2025



	Sune Jakobsson Employee representative Committee: Member of PCC Term of office: Elected 10 May 2023, re- elected 21 May 2025 for up to two years		Irene Vold Employee representative Committee: Member of RAC Term of office: Elected 27the May 2021, re- elected 21 May 2025 for up to two years

Born in 1960, Norwegian citizen and resident in Frosta, Norway. Experience Jakobsson works at Telenor Norge AS and is Tekna's corporate and chief employee representative for both Telenor Norge and Telenor Shared Services. Since April 2023, he has held the corporate employee representative role while continuing his previous responsibilities. With extensive board experience and decades at various Telenor companies, Jakobsson has strong knowledge of Telenor's operations, a wide professional network, and solid technical expertise in telecommunications. Education Jakobsson holds an M.Sc. in Computer science from Norges tekniske høgskole (NTH), a bachelor degree in Telecommunications from Oslo Ingeniør Høyskole (OIH) and has 25 years of experience in Telenor-owned companies. He is currently a full stack developer at Telenor Norge AS, and previously worked at Comoyo AS, Telenor R&I, Stentofon AS and Norsk Data AS. Attendance rate in 2025 Attendance was 100 % for the Board and the Board committees (TIC and PCC).		Born in 1964, Norwegian citizen and resident in Jar, Norway. Experience Vold began her career at Televerket in 1985 and has since developed solid expertise and extensive experience within the telecommunications industry. She is responsible for key accounts for large Norwegian enterprises and has broad experience in customer management and relationship building. She has previously held leadership roles in sales and service. Vold currently serves as Deputy Chair of NITO Telenor Norway and has for many years been an employee representative for the Business division in Telenor Norway. Education Vold holds a degree in electronics engineering from Oslo University College of Engineering. She has also studied business administration and management at BI Norwegian Business School in Oslo. In 2024, she completed a course in sustainability reporting conducted by the Norwegian Institute of Directors. Attendance rate in 2025 Attendance was 100 % for the Board and the Board committees (PCC and RAC).

Role and responsibility of the Board

The Board is ultimately responsible for managing

the Telenor Group, ensuring sound governance

and effective organisation of the company's

operations, as well as overseeing Telenor’s

business activities. Its principal duties include

oversight and control. The Board establishes the

strategy, plans, frames and objectives for

Telenor's operations, including financial and

sustainability targets and ambitions.

Performance is reported to the Board on a regular

basis, providing updates on key performance

indicators for both financial and sustainability

objectives. Additionally, a key responsibility of

the Board is to make, or delegate authority for,

decisions on matters which, due to their nature,

are either unusual or of major importance to the

company.

Composition, diversity and

independence of the Board¹⁾

In accordance with Article 5 of Telenor’s Articles

of Association, the Telenor ASA Board of

Directors must comprise no fewer than five and

no more than 13 members.

Board members are elected for terms of up to two

years. As at 31 December 2025, the Board

comprised ten members, including three

employee-elected representatives, as required by

Norwegian company law. On 21 May 2025, the

Corporate Assembly appointed two new

shareholder-elected Board members.

The Board is structured to ensure a diverse range

of backgrounds and expertise to meet the

company’s needs. Of the 10 Board members,

there are four women and six men, and three of

the members are non-Norwegian citizens.

Except for employee-elected representatives,

none of the Board members are employees of

Telenor or carry out work for Telenor outside of

their board and committee duties. Management is

not represented on the Board, and all

shareholder-elected members are independent ²⁾.^.

The members of the Board are encouraged to

hold shares in the company. Further details

regarding their shareholdings can be found in the

Executive Compensation report.


Executive/non-executive	2025
Number of non-executive members	10
Number of executive members	0

Employee representatives	2025
Number of employee elected members	3

Gender split	2025
Female	4
Male	6
Board's gender diversity ratio	40%

Independence	2025
Percentage of independent board members	70%

1⁾ ESRS reference: ESRS 2 GOV-1-21

²⁾ For the classification of independent board members, Telenor bases its assessment on the Norwegian Code of Practice recommendations

2025

Expertise and skills of the Board¹⁾

The Board comprises members with diverse

experience and educational backgrounds, all of

which are highly relevant to Telenor's purpose and

operations in the telecommunications sector.

Experience relevant to Telenor's sector,

products and geographic locations

Telenor's principal activities are centred on

telecommunications and technology services. A

number of the Board members have held senior

management positions and board memberships

in companies within the telecommunications and

technology sector. The Board possesses a strong

familiarity with Telenor's products and services. In

addition, several Board members have direct

experience in product development within the

telecommunications and technology industries.

Various Board members bring expertise from

other B2B (business-to-business), B2C (business-

to-consumer) and capital-intensive industries.

Moreover, several Board members have

professional experience and a thorough

understanding of Telenor's key geographic

locations, including Asia and the Nordic region.

Sustainability-related expertise, including

expertise on business conduct matters

Telenor continues to ensure that the Board and

the Risk and Audit Committee (RAC) are equipped

with relevant sustainability expertise. Previous

training sessions have covered CSRD and double

materiality, including targeted content related to

sustainability reporting responsibilities. These

sessions have been facilitated by both external

and internal experts, contributing to the Board’s

overall competence in sustainability matters.

In addition, selected Board members have

participated in external courses on sustainability

reporting, and in-depth reviews of material

sustainability topics are regularly included on the

Board’s agenda. These discussions have further

strengthened the Board’s understanding of

Telenor’s key sustainability issues.

Several Board members also contribute

experience from executive roles and other

directorships involving oversight of sustainability

reporting. The Board benefits from access to

internal subject-matter experts on Telenor’s

material sustainability topics, and all members

complete annual Code of Conduct training, which

covers key aspects of responsible business

conduct.

As part of the Board's annual self-assessment, the

Board evaluates whether its competence remains

sufficient to fulfil its roles and responsibilities.

Through this assessment, the Board determines

for example whether the necessary skills and

expertise are present within the Board. The Board

also considers whether management adequately

prepares and manages relevant topical areas,

including those related to sustainability matters.

The work of the Board²⁾

The Board remains informed about Telenor’s

financial and sustainability position, ensuring that

its activities, accounts, and asset management

are subject to appropriate controls. In accordance

with the requirements of the Corporate

Sustainability Reporting Directive (CSRD) and the

European Sustainability Reporting Standards

(ESRS), the Board has significantly enhanced its

attention and duty of care in relation to

sustainability matters. These matters include

human rights, climate change, and other

environmental considerations, across the short,

medium, and long term. See page 59 for further

details about the Board's work on sustainability.

The Board ensures that Telenor has robust

internal controls regarding the rules and

regulations applicable to Telenor Group. It

develops an annual meeting plan, focusing

particularly on objectives, strategy, and

implementation.The Board’s annual cycle includes

reviewing, discussing and approving strategies,

business plans, and financial and sustainability

targets for the activities of Telenor Group.

Telenor’s strategy is outlined in the previous

chapters of this report. Further, the Board

undertakes any examinations deemed necessary

to fulfil its duties, either on its own initiative or at

the request of one or more of the members of the

Board.

The Board places strong emphasis on acquiring

valuable insights and remaining well-informed

across relevant areas, including operational,

technological, regulatory and market

developments.

Principles and instructions

The Board issues instructions governing its own

activities and those of the President & CEO, with

particular emphasis on clear internal allocation of

responsibilities and duties. These instructions set

out the manner in which the Board supervises

Telenor’s day-to-day management and overall

business operations. The Board reviews and

evaluates both its own instructions and those for

the President & CEO on an annual basis.

Principles for managing conflicts of interest are

detailed in Telenor’s Code of Conduct and apply

to both Board members and all employees. The

Board's instructions include provisions

disqualifying members from participating in the

consideration of decision-making of matters in

which they, or a related party, have a conflict of

interest.

The Board has established procedures to ensure

awareness of potential conflicts of interest,

promoting regular, open and transparent dialogue

regarding any interests Board members may

have, or that may be perceived to exist.

Internal control over financial reporting

(ICFR)

The main objective of ICFR is to ensure the

completeness, validity and accuracy of the

financial reporting process to reduce the risk of

significant error or material misstatement.

Telenor places strong emphasis on internal

controls,with particular attention to the oversight

of ICFR. The Board has established processes to

ensure that adequate internal controls are

maintained across all financially significant

Telenor companies worldwide. The Group

Governing Principles set out the key requirements

and expectations for the implementation of the

ICFR programme.

The Risk and Audit Committee (RAC) has

delegated the coordination and oversight of the

ICFR programme to Group Finance. Local

management in each financially significant

Telenor company is responsible for implementing

¹⁾ ESRS reference: ESRS 2 GOV-1-23 and GOV 1-21-c

²⁾ ESRS reference: GOV-1-22

2025

the ICFR programme and for providing quarterly

and annual ICFR status reports to Group Finance.

The RAC conducts evaluations of the ICFR

programme’s effectiveness. These evaluations

include identifying and assessment of all material

financial reporting risks. It ensures that

appropriate controls are implemented, executed,

and tested periodically throughout the year.

Where controls are found to be not operationally

effective, the potential impact and financial

exposure on the consolidated financial

statements are assessed.

Regular reviews are conducted to identify the

most relevant financial reporting risks and to

enhance Telenor’s ICFR best practices. These

reviews also ensure that identified risks are

consistently addressed by sufficient controls.

Twice a year, management reports the results of

the evaluations of the ICFR programme to the

RAC.

See page 60 for more information about risk

management and internal control over

sustainability reporting (ICSR).

Related party transactions

Telenor routinely engages in transactions with

related parties as part of its ordinary business

operations. Prior to approving any agreement

with a related party, the Board is required to

evaluate whether the terms are at arms' length

and to consider, as set out in the Board’s

instructions, whether obtaining an independent

third-party valuation is appropriate. This process

is conducted in accordance with the Public

Limited Liability Companies Act, Sections 3-8 and

3-9. The same assessment applies for the

President & CEO for agreements falling under day-

to-day management responsibilities.

Significant agreements with related parties,

including transactions involving associated

companies, are disclosed in note 36 Related

parties in the financial statements.

Board meetings in 2025

The Board typically convenes eight Board

meetings throughout the calendar year; however,

a minimum of four meetings is required. At any

time, individual Board members or the President &

CEO may request a Board meeting be held to

address specific matters.

The minutes from the Board meetings are shared

with selected members of management, the Head

of Group Internal Audit and Investigations, the

Chair of the Corporate Assembly and Telenor’s

external auditor.

In 2025, the Board convened ten times, including

two extraordinary meetings. The overall

attendance rate for the year at Board meetings

was 98% (incl. extraordinary meetings). For

employee-elected Board members, designated

deputies are invited to attend should one of those

members be unable to participate.

Board self-assessment

The Board conducts a systematic evaluation of its

performance, activities, and expertise through an

annual self-assessment, in line with the

Norwegian Code of Practice. The process

alternates between a comprehensive external

evaluation and a lighter internal review every

other year.

In 2025, the self-assessment was conducted

internally, where Board members completed a

questionnaire, covering the Board's way of work,

the Board's tasks, duties and responsibilities, the

Board's and Board member's competence and

expertise, and the collaboration with President &

CEO and management. The outcomes were

subsequently reviewed during the Board meeting

held on 16 December 2025.

The Directors’ and officers’ liability

insurance

Telenor has procured and maintains directors’

and officers’ liability insurance. The policy

provides coverage for pure financial loss arising

from claims made against an insured individual

due to a wrongful act committed or allegedly

committed in the capacity of a director or officer,

member of the supervisory board, member of the

management board or an employee acting in a

managerial or supervisory capacity.

Liability under this insurance is personal. The

Board conducts an annual review of the insurance

coverage to ensure continued adequacy.

Working committees of the

Board

The purpose of the committees

The Board has established two preparatory

working committees: The Risk and Audit

Committee and the People and Compensation

Committee. The committees do not possess

independent decision-making authority, except

where this is expressly delegated by the Board on

a case-by-case basis or as required by law. Their

primary function is to prepare matters for

consideration and/or decision by the Board.

The committees report directly to the Board, and

all Board members have access to all working

documents, including committee meeting

minutes.

The Board reviews the charters of its committees

on a regular basis to ensure they remain aligned

with evolving responsibilities. In the light of Risk

and Audit Committee’s expanded role under the

Corporate Sustainability Reporting Directive

(CSRD), its charter was recently updated to

include oversight of sustainability reporting. This

change formally recognises the Committee’s

responsibilities in this area. Further, there is a

continued emphasis on updating the annual wheel

and meeting schedules of the committees to

address all required and relevant topics. The

Board may also establish ad hoc committees as

deemed necessary.

The Risk and Audit Committee (RAC)

In 2025, the RAC convened nine meetings,

achieving an attendance rate of 100%. As of 31

December 2025, the committee comprised Ottar

Ertzeid (Chair), Grethe Bergly (Member), Gyrid

Ingerø (Member), Pieter Knook (Member) and

Irene Vold (Employee representative).

The Risk and Audit Committee is a working body

that supports the Board in fulfilling its

responsibilities, including statutory duties related

to financial and sustainability reporting, internal

control and audit. Further, the committee is

responsible for overseeing the internal audit and

investigation function, as well as the compliance

organisation, the compliance management

system, and risk management and control.

2025

The committee is established in accordance with

the requirements of Audit Committees as set out

in the Norwegian Public Limited Liability

Companies Act. The RAC charter was updated in

2024 to reflect the added responsibility for

supervision of sustainability reporting. In 2024, the

responsibilities for supervision of investigations

and compliance processes was also included in

the committee's mandate.

Throughout 2024, RAC members participated in

CSRD training sessions organised by Telenor,

involving both internal and external experts. These

sessions were specifically designed to address

the committee's responsibilities related to

sustainability reporting. The committee regularly

reviews whether any additional training is needed.

The People and Compensation

Committee (PCC)

In 2025, the PCC convened six meetings,

including one extraordinary meeting, achieving an

attendance rate of 96.3%. As of 31 December

2025, the committee comprised the following

members : Jens Petter Olsen (Chair), Marianne

Dahl (Member), Mats Granryd (Member), Sune

Jakobsson (Employee representative) and Roger

Rønning (Employee representative).

The People and Compensation Committee serves

as a preparatory committee, assisting the Board

in fulfilling its responsibilities concerning people

and compensation matters, including executive

remuneration, strategic human capital

management, as well as diversity and culture

development. The committee also provides

support to the Board on succession planning.

The General Meeting

The purpose of the General Meeting

The General Meeting serves as the company’s

highest governing authority. It is convened at

least once annually at the Annual General Meeting

(AGM). The General Meeting approves Telenor’s

Articles of Association and provides a key forum

for interaction among shareholders, elected

officers, and management. Telenor actively

encourages all shareholders to exercise their

rights by voting at the General Meeting. Notice of

the meeting along with all relevant documentation

is published on Telenor’s corporate website no

later than 21 days prior to the date of the AGM.

The notice also includes voting procedures and

instructions to shareholders wishing to propose

resolutions.

Preparatory documents for the General

Meeting

To enable shareholders to make informed

decisions on all matters to be discussed at the

General Meeting, draft resolutions and supporting

information are provided in detail and are

comprehensive. In accordance with the Articles of

Association, documents pertaining to the items

on the agenda - including those required by law to

be included in the notice - are not required to be

sent directly to shareholders if they are made

available on Telenor’s corporate website.

However, shareholders may request that such

documents be sent to them. Shareholders have

the opportunity to vote separately on each item

on the agenda and on each candidate nominated

for election to the company’s governing bodies.

In accordance with the Articles of Association, the

Annual General Meeting (AGM) shall be convened

once a year before the end of June. As specified

in Article 8 of the Articles of Association, the AGM

shall address the following matters:

• Approval of the financial statements and annual

report, including distribution of dividends.

• Any other matters to be addressed by the AGM

under law or pursuant to the Articles of

Association.

Attendance requirements for the

General Meeting

The General Meeting shall be convened by the

Board in accordance with the relevant statutory

requirements. The meeting may be conducted as

a physical meeting, a digital meeting or a

combination of both.

Shareholders wishing to attend the General

Meeting must provide advance notice no later

than two business days prior to the General

Meeting, or by such later deadline as determined

by the Board.

Shareholders who are unable to attend may vote

by proxy. The notice will include instructions on

proxy voting and provide specific guidance for

shareholders holding shares through nominee

accounts or custodians. The Board may also issue

guidelines for advance voting, which will be

included in the notice.

The minutes of General Meetings, including voting

results, attendance, shareholder representation

and pre-meeting documents, will be made

available on Telenor’s corporate website.

The AGM in 2025

The 2025 AGM of Telenor ASA was held on 21 May

2025. The meeting was held as a fully digital

meeting for the first time in 2024, and this format

was continued in 2025. Shareholders were invited

to follow the meeting via webcast and to cast

their votes electronically. The Board determined

that no prior registration was required; however,

to participate in voting, shareholders had to log in

before the AGM commenced. The meeting was

chaired by the Chair of the Corporate Assembly,

in accordance with Article 8 of the Articles of

Association. In addition to the Chair of the AGM -

who also serves as Chair of the Corporate

Assembly and the Nomination Committee - the

Chair of the Board, the President & CEO, the Chief

Financial Officer and the company’s external

auditor were in attendance.

Extraordinary General Meetings (EGM)

An Extraordinary General Meeting (EGM) may be

convened by the Board, the Corporate Assembly,

or the Chair of the Corporate Assembly. Should

the company’s external auditor or shareholders

holding at least five per cent of the share capital

submit a written request for an EGM to address a

specific matter, the Board is required to ensure

that an EGM is held within one month of receiving

of the request. No EGM was convened in 2025.

2025

The Corporate Assembly

The purpose and duties of the Corporate

Assembly

The Corporate Assembly serves primarily as a

supervisory body, overseeing the Board and the

President & CEO's management of the company,

as set out in Sections 6-35 to 6-40 of the Public

Limited Liability Companies Act, and Article 7 of

Telenor's Articles of Association. The Corporate

Assembly has established its own instructions

governing its operations. It is responsible for

electing the Board of Directors and the Chair of

the Board, as well as determining the Board’s

remuneration. Decisions made by the Corporate

Assembly regarding these elections are final, and

the General Meeting may not influence, alter, or

overturn them.

Composition of the Corporate Assembly

The composition of the Corporate Assembly is

determined to ensure broad representation of

Telenor's shareholders. The Corporate Assembly

comprises 15 members and two observers, each

elected for a term of two years. Ten members and

three deputies are elected by the General

Meeting. Five members and two observers, along

with their deputies, are elected by and from the

employees in accordance with the regulations

pertaining to the Norwegian Public Limited

Liability Companies Act concerning employees’

rights to representation on the board of directors,

corporate assembly, etc.

Activity in 2025

In 2025, the Corporate Assembly held three

ordinary physical meetings, consistent with the

requirements set out in the instructions. The Chair

of the Board and the President & CEO were

present at all meetings. The average attendance

among Corporate Assembly members in 2025

was 77,08%. Deputies were invited to attend when

members were unable to participate.

Further details regarding the members of the

Corporate Assembly can be found on on Telenor’s

corporate website.

The Nomination Committee

The Nomination Committee of Telenor ASA is

established in accordance with Article 9 of

Telenor ASA's Articles of Association. The

General Meeting has adopted specific instructions

governing the work of the Nomination Committee.

Members and election process

The Nomination Committee comprises four

members, who must be shareholders or

shareholder representatives, and who are

required to be independent of both the Board and

Executive Management. Members are elected by

the General Meeting, with the Chair of the

Corporate Assembly serving as Chair of the

Nomination Committee. When appointing

members, the interests of both the company and

its shareholders are duly considered. In

accordance with its instructions, the Nomination

Committee shall take into account the Company’s

requirements for expertise, capacity and diversity

when evaluating candidates.

The work of the Nomination Committee

The Nomination Committee at Telenor nominates

shareholder representatives to both the

Corporate Assembly and the Board, and proposes

their compensation. In addition, the Nomination

Committee provides recommendations to the

General Meeting regarding the election and

remuneration of members of the Nomination

Committee. During its work, the Nomination

Committee engages with shareholders, the Board

- individually with each member - and executive

personnel, as well as with members of the

Corporate Assembly where relevant. This process

supports the committee's responsibility for

overseeing the composition of the Board, the

Corporate Assembly, and the Nomination

Committee itself.

The Nomination Committee is committed to

ensuring that the Board's composition aligns with

the company's governance requirements. In its

considerations, the committee evaluates factors

such as gender, age, and other diversity aspects,

alongside industry knowledge, geographical

market experience, technical expertise, and

sustainability competence.

Activity in 2025

The Nomination Committee continues to engage

a consultancy firm to support the search for

board candidates with relevant background and

experience. Building on the current Board’s

competencies, the firm has contributed to a

structured assessment of future requirements to

guide the selection process. The Nomination

Committee held 11 meetings in 2025 with 100 per

cent attendance.

Further information regarding the composition

and background of the Nomination Committee

members, as well as details on how to submit

proposals, is available on Telenor’s corporate

website.

The Nomination Committee

Nils Bastiansen,

Chair

Elected by the

Corporate Assembly

on 10 May 2023, re-

elected 21 May 2025

Jan Tore Føsund,

member

Elected by the AGM

7 May 2019, last re-

elected 21 May 2025

Heidi Algarheim,

member

Elected by the AGM

11 May 2020, last re-

elected 7 May 2024

Anette Hjertø,

member

Elected by the AGM

10 May 2023, re-

elected 21 May 2025

2025

External auditor

In accordance with Norwegian regulations,

Telenor complies with all applicable requirements

governing the oversight of auditing and auditors,

including ensuring the external auditor’s

independence.

Independence

The external auditor provides the Risk and Audit

Committee with an annual written statement

confirming their independence. On a bi-annual

basis, a summary of all services provided by the

external auditor, beyond the statutory audit, is

presented to the Risk and Audit Committee. The

external auditor also reports any potential threats

to their independence and outlines the measures

undertaken to reduce these risks, in accordance

with the Audit and Auditors Act.

Audit fees and pre-approval

Telenor has established a pre-approval policy and

procedures for the approval of non-audit services

provided by the external auditor, as set by the

Board. At the General Meeting, the Board presents

a breakdown of the auditor’s remuneration,

distinguishing between audit fees and other

services, as disclosed in the Annual Report.

Attendance at meetings

The external auditor attends all meetings of the

Risk and Audit Committee, the Board meeting at

which the Annual Report is approved, and other

meetings upon request. The external auditor

presents the results of the audit to the Risk and

Audit Committee and the Board during the

meeting approving the Annual Report, including

any material changes to the company’s

accounting principles and significant accounting

estimates. Should any disagreement arise

between the external auditor and Telenor

Management on material topics, the external

auditor is authorised to report such

disagreements directly to the Board. At least once

annually, the Board of Directors meets with the

auditor in the absence of the President & CEO and

any other member of management.

Audit plan

The external auditor outlines aspects of the audit

plan to the Risk and Audit Committee and

communicates both interim and final results of

the audit work to the Committee.

Monitoring of internal control

weaknesses

Annually, the external auditor presents any

identified internal control weaknesses and

recommendations for improvement to the Risk

and Audit Committee and the Board. The external

auditor meets with the Risk and Audit Committee

and the Board at least once a year to discuss

these matters.

Limited audit assurance on sustainability

statements

The external auditor is engaged to provide limited

assurance over Telenor's sustainability

statements for 2025.

Election of a new auditor

In late 2023, Telenor initiated a process to appoint

a new external auditor, in accordance with the

auditor rotation regulations in the European

Union. The tender and selection process was

carried out during 2024, led by management in

close collaboration with the Risk and Audit

Committee. The final appointment was made by

the General Meeting in May 2025.

The new external auditor is Deloitte and will be

responsible for auditing the 2026 financial

statements and providing limited assurance over

the 2026 sustainability statements.

2025

Executive

Management

The President & CEO is responsible for the day-to-day

management of Telenor's operations, with the Group

Management acting as an advisory body for the President &

CEO. Telenor's operations are organised with four Business

Areas and a headquarter function, staffed by skilled

professionals in various expert roles to ensure good corporate

governance, including strict adherence to applicable laws and

regulations, policies and standards.

The Telenor management

2025


Group Management

	Benedicte Schilbred Fasmer President & CEO of Telenor Group		Torbjørn Wist EVP & Chief Financial Officer		Rita Skjærvik EVP & Chief People, Sustainability and External Relations Office		Cathal Kennedy Acting EVP & Group Chief Technology Officer
Born in 1965, Norwegian citizen and resident in Norway. Experience Fasmer is President and CEO of Telenor Group since December 2024, following her role as CEO of SpareBank1 Sør-Norge and Chair of the SpareBank1 Alliance. She has extensive experience in digital innovation and business transformation, along with a broad executive background in the financial industry. Previously, Fasmer held executive roles including Group EVP at Fremtind Forsikring and DNB, where she led Corporate Banking. Her career spans over 30 years across banking, capital markets, private equity, and FMCG. She has overseen companies subject to CSRD reporting and participated in related training. Her board experience includes Chair of the Oslo Stock Exchange, member of the Supervisory Board of the Central Bank of Norway, and board roles at Norwegian Air Shuttle, Vipps, Vocalink Ltd, and Finance Norway. Since 2025, Fasmer has served on the GSMA and NHO Boards. She was also a member of the UN High-Level Panel on Financial Accountability, Transparency and Integrity for the 2030 Agenda (FACTI Panel). Education Fasmer holds a degree in economics and business administration (siviløkonom) from the Norwegian School of Economics (NHH).		Born in 1968, Norwegian citizen and resident in Norway. Experience Prior to rejoining Telenor, Wist served as EVP & CFO in Wallenius Wilhelmsen ASA for over four years. Wist also assumed the role of Acting CEO of Wallenius Wilhelmsen from early March 2021 until the end of May 2022. During his tenure at Wallenius Wilhelmsen, Wist was actively engaged in sustainability reporting and related initiatives. Before his his time at Wallenius Wilhelmsen, Wist served as EVP & CFO at Scandinavian Airlines System (SAS). In addition to his executive role, Wist was SAS’ senior representative and spokesperson in Norway. Wist’s earlier career includes 13 years with Telenor Group, where he held senior positions in finance and served on multiple boards. His last role in Telenor was Group Treasurer, a position he held for five years. Earlier, Wist spent 11 years in investment banking in New York and London, having worked for Salomon Brothers, Merrill Lynch, and Greenhill & Co. Education Wist holds a business degree from the Richard Ivey School of Business at the University of Western Ontario in London, Canada. Based on this degree, he received the professional designation Siviløkonom from the Norwegian School of Economics (NHH).		Born in 1974, Norwegian citizen and resident in Norway. Experience Skjærvik has over 20 years’ experience in decision- making at senior management and board level across public and private sectors. She joined Telenor Norway’s Public Affairs team in 2014, later holding roles in Telenor Group such as SVP Head of CEO Office and SVP Head of Group Strategy and External Relations from June 2020. Skjærvik joined Telenor Group Executive Management in December 2021. In September 2022, her remit expanded to EVP People, Sustainability & External Relations, including oversight of sustainability reporting. In 2025, she attended a board training course at the Norwegian Institute of Directors and completed the Bursa Malaysia Mandatory Accreditation Programme on ESG. Prior to her role at Telenor, Skjærvik served as Deputy Chief of Staff for the Prime Minister of Norway. She brings solid experience from a range of political advisory positions in Norway. Education Skjærvik holds a Master’s Degree (Cand. polit.) in Political Science from the University of Oslo.		Born in 1972, Irish citizen and resident in Norway. Experience Kennedy served as Senior Vice President, Cloud and AI, within the Telenor Group CTO Office, prior to assuming the position of Acting EVP and Group CTO. Since joining Telenor in 2014, he has held several significant roles, including Chief IT Architect, as well as senior leadership positions overseeing IT across Nordic and European markets. Kennedy has led global transformation initiatives, developing and implementing technology strategies across Telenor. He has played a pivotal role in advancing cloud computing and artificial intelligence, as well as driving automation initiatives such as those aimed at enhancing energy efficiency. His contributions have reinforced Telenor’s commitment to innovation and digital transformation within the telecommunications sector. Education Kennedy holds a Bachelor of Science (BSc) degree in Computer Applications from Dublin City University.

2025



	Sigvart Voss Eriksen EVP & Head of Telenor Nordics		Dan Ouchterlony EVP & Head of Telenor Amp		Jannicke Hilland EVP & Head of Telenor Infrastructure		Jon Omund Revhaug EVP & Head of Telenor Asia
Born in 1974, Norwegian citizen and resident in Norway. Experience Voss Eriksen is an experienced executive with a strong track record in transformation, leadership, and industrial innovation. Prior to joining Telenor, he served as CEO of Omny, an industrial cybersecurity company established in 2023 and jointly owned by Aker and Telenor. His career includes leading customer-focused transformations across Telenor’s European and Asian operations. He served as CMO in dtac (Thailand), Telenor Hungary, and Pakistan, in addition to holding the position of Head of Strategy for Pannon GSM. He has also led HR, security, and business development functions in Pakistan, served as Circle CEO at Uninor (India), and previously worked within Telenor’s Nordic mobile operations. In 2017, Voss Eriksen became CEO of Tapad (U.S.), leading its turnaround and sale from Telenor to Experian. He later served as executive advisor to Experian. He is currently Chairman of the board for Easee and the Nordic Telenor subsidiaries. His previous board experience includes roles with Documaster, Disruptive Technologies, Dignio, Nofence, and Ardoq. Education Voss Eriksen holds a Master of Science, Industrial Economics and Technology Management from NTNU Norwegian University of Science and Technology.		Born in 1975, Swedish citizen and resident in Sweden. Experience Ouchterlony began his tenure at Telenor in 2022, taking on the role of Executive Vice President (EVP) and Head of Telenor Amp. He brings over two decades of leadership experience in business building, venture investments, and strategy across the tech and media sectors. Before joining Telenor, he held the position of EVP of Financial Services and Ventures at Schibsted ASA. Ouchterlony joined Schibsted in 2006 as VP of Strategy and Business Development, later transitioning to its corporate venture team in 2010. Earlier in his career, he worked at the consulting firm McKinsey & Company, providing advisory services to clients operating in the software, high technology, and media sectors. Throughout his career, Ouchterlony has also held board positions in several growth-stage and venture-backed companies, including regulated fintech firms, such as Lendo and Hypoteket. Education Dan Ouchterlony holds a master’s degree in Industrial Engineering and Management from KTH Royal Institute of Technology, Sweden.		Born in 1967, Norwegian citizen and resident in Norway. Experience Hilland joined Telenor as EVP & Head of Telenor Infrastructure in 2022. She brings over 25 years of experience from the energy sector, with a recent focus on the energy transition. Her expertise spans infrastructure development and operations in renewable energy, digital communication, and oil & gas. Prior to Telenor, she was CEO of Eviny, a Norwegian renewable energy company, where she led the company’s strategic direction and transformation agenda, including M&A. From 2008 – 2015, Hilland held senior roles at Equinor, including Head of Corporate Safety, Security and Emergency Preparedness, and was part of the Corporate Executive Committee. She also oversaw the Statoil Board of Directors Sustainability, Safety, Security and Ethics Committee. Earlier, she held various management positions at Norsk Hydro, including Offshore Installation Manager. Hilland holds several board member positions, including Deputy Chair of Yara International and member of the Yara Board Audit and Sustainability Committee. She is also on the board of Bonheur. Education Hilland holds a PhD in Physics from the University of Bergen (UiB) and a BSc Honours in Electrical and Electronic Engineering from the University of Manchester Institute of Science and Technology (UMIST). She also has completed a part-time study in Strategic Leadership at Norwegian Business School (NHH).		Born in 1966, Norwegian citizen and resident in Norway. Experience Revhaug is EVP & Head of Telenor Asia since 24 June 2025. Previously, he was acting EVP & Head of Telenor Nordics, following his role as COO in Telenor Nordics, with responsibility for technology, IT and Shared Services. He also served as Chief Transformation Officer at True/Dtac in Thailand, leading the merger between CP-owned True and Telenor-owned Dtac. Before that, he was the CEO of Telenor Myanmar, guiding the company through both Covid and the period of the military coup. Revhaug played a key role in establishing Telenor Group’s global sourcing function, and served as CEO of Telenor Procurement Company (TPC, Singapore). Currently, Revhaug serves as Chairman of Grameenphone and as Vice Chairman of both True Corporation and CelcomDigi, all listed companies in their respective markets. Previously, when leading the Nordics, he chaired the boards of Telenor's Nordic subsidiaries and was also a board member of TPC. Prior to this, he chaired Telenor Myanmar and was a board member of TT Network in Denmark. Education Revhaug holds a Master of Management degree from BI Norwegian Business School and a Cand. Mag. degree in Economics and Biology from the University of Tromsø, Norway.

2025

The President & Chief

Executive Officer (CEO)

The Board is responsible for appointing and

issuing governance instructions to the President &

CEO. Benedicte Schilbred Fasmer was appointed

as Telenor's President & CEO, effective from 2

December 2024.

The President & CEO is responsible for the day-to-

day management of Telenor ASA, ensuring that

the organisation's management and development

are conducted in accordance with applicable

laws, Telenor’s Articles of Association and the

resolutions adopted by the Board, the Corporate

Assembly and the General Meeting. The Board

determines the terms of employment for the

President & CEO’s terms, based on

recommendations from the People and

Compensation Committee.

The instructions to the President & CEO extend to

the management of the Telenor Group, including

its subsidiaries, ownership interests and

associated companies in the Group. They also

cover financial and sustainability reporting, the

granting powers of attorney, the submission of

matters for Board resolution and reporting duties

to the Board. Reporting procedures are designed

to ensure that the Board receives timely,

accurate and relevant information sufficient for

the effective execution of its responsibilities.

Management's work is organised through various

governing bodies and functions, established to

ensure good governance, compliance and risk

management.

Group Management

In 2025, the President & CEO was supported by an

advisory body called Group Management,

consisting of the Executive Vice Presidents (EVPs)

for Headquarters and the four business areas, in

addition to the President & CEO. While not

members of Group Management, the Chief

Communication Officer and General Counsel were

standing participants in Group Management

meetings.

The role of Group Management is to develop the

Group’s overall strategy and to monitor strategic

matters affecting Telenor as a whole. Each

member of the Group Management reported

directly to the President & CEO, in accordance

with their respective EVP Instructions. In addition

to regular weekly meetings throughout the year,

Group Management convened for seven extended

sessions lasting one to two days.

Composition and diversity of Group

Management¹⁾

During 2025, several changes were made within

Telenor’s Group Management. Following the

appointment of the new President & CEO on 2

December 2024, a new Executive Vice President

and Chief Financial Officer joined the company on

1 January 2025. In June 2025, the acting Head of

Telenor Nordics transitioned into the role of EVP

and Head of Telenor Asia. Concurrently, a new

EVP and Head of Telenor Nordics was appointed.

The EVP and Chief Technology Officer continues

to serve in an acting capacity.

Experience and competence are key criteria in the

selection of candidates to EVP positions. Telenor

recognises that assembling the right team -

comprising individuals with diverse expertise and

educational backgrounds - is essential to

achieving the company’s objectives and fostering

sustainable growth.

In 2025, Group Management consisted of

professionals with extensive experience in

telecommunications and a wide range of

educational backgrounds, including business

administration, finance, information technology,

political science, physics, electrical and industrial

engineering and biology.

By the end of 2025, Group Management

comprised the President & CEO and seven EVPs,

including three women and five men. The majority

of members originated from the Nordic region

and belonged to a similar age group. Telenor

remains committed to enhancing diversity in

future recruitment, aiming for broader

representation across various dimensions such as

ethnicity, cultural background, age and gender.

Expertise and skills of Group

Management²⁾

Experience relevant to Telenor's sector,

products and geographic locations

The Group Management team collectively

possesses extensive experience within the

telecommunications industry, directly aligned

with Telenor's objectives. The team is well

equipped to address the company’s operational

requirements.

Several members have worked closely with

Telenor’s products and services, and many hold

substantial experience across the various

geographic locations in which Telenor operates.

Sustainability-related expertise, including

expertise on business conduct matters

Telenor's Code of Conduct is central to the

company's corporate culture, establishing high

standards of integrity for conducting business. All

employees, including members of Group

Management, are required to complete Telenor's

annual Code of Conduct training, which

addresses key topics pertaining to sustainability

and business conduct.

Certain members of Group Management have

participated in professional development

activities focused on sustainability matters and

sustainability reporting.

Since 2022, the EVP People, Sustainability and

External Relations Officer has held responsibility

for sustainability within the Telenor Group.

Beyond the expertise of the EVPs, Group

Management benefits from the support of

sustainability specialists across various

departments within Telenor.

The Sustainability team, which reports to the EVP

People, Sustainability and External Relations

Officer, comprises subject matter experts with

experience across various sustainability areas.

The team is headed by the SVP Public Affairs &

Sustainability. These experts hold dedicated roles,

covering the overall sustainability agenda, as well

as specific areas including human rights,

inclusion, health, safety, supply chain

sustainability, climate and environment.

¹⁾ ESRS reference: ESRS 2 GOV-1-21.

²⁾ ESRS reference: ESRS 2 GOV-1-23.

2025

From 2024, Group Finance has assumed overall

responsibility for sustainability reporting,

leveraging existing skills, resources and systems

developed for financial reporting. This transition

has involved upskilling team members and

fostering close collaboration with both the

sustainability team and the reporting units within

scope.

Group Technology brings expertise across critical

technology domains such as cybersecurity, AI,

cloud computing, next generation networks,

innovation and procurement. This proficiency is

essential in supporting Telenor's initiatives in

multiple double materiality areas, such as

delivering resilient solutions for climate change

mitigation, driving energy savings, pursuing

science-based targets throughout the value

chain, facilitating digital transformation within

societies. and promoting security risk awareness.

In addition, the Group Compliance team

possesses extensive expertise in business

conduct matters, including corporate culture,

corruption and bribery and management of

relationships with suppliers. These areas are

addressed both in Telenor’s Code of Conduct and

through separate policies and related compliance

programmes related to Anti-Corruption and

Business Partner Management.

The Group Internal Audit & Investigation function

comprises experts to ensure e.g. that Telenor

maintains an effective whistle-blowing

mechanism. The Group Employer Role function

has labour law expertise, which is pertinent in the

context of business conduct matter. Furthermore,

Group Legal provides expertise in areas such as

business conduct.

Telenor is confident that these functions have the

requisite experience and expertise to effectively

oversee sustainability matters and address the

impacts, risks and opportunities identified by the

company. Group Management regularly assesses

whether particular sustainability issues require

attention and determines which experts should be

engaged, including consideration of external

specialists when appropriate.

Other governance functions

The Chief Compliance Officer and the

Compliance function

Group Compliance operates as a second line

function, led by the Chief Compliance Officer

(CCO). The CCO is responsible for overseeing

Group Compliance and ensuring the Compliance

function fulfils its designated roles and

responsibilities. The CCO reports to the EVP &

Chief People, Sustainability and External Relations

Officer, while also maintaining a direct reporting

line to the President & CEO.

The Group Compliance function advises and

supports the President & CEO with the following

objectives:

• Uphold and continually advance Telenor Group’s

high standards of governance and compliance

• Ensure that Telenor’s governance framework

addresses group-wide compliance risks and

requirements

• Monitor that compliance risks are effectively

managed throughout Telenor Group

Additionally, the President & CEO has appointed

the CCO to coordinate and support the

development, distribution, implementation and

monitoring of governing documents.

The Compliance function also advises

management during the resolution process

following the conclusion of compliance incident

investigations. Group Compliance is responsible

for ensuring that resolutions are fair, objective

and consistent across Telenor, and for ensuring

that relevant learnings from remedial actions are

shared throughout the organisation.

The CCO participates in Board meetings when

relevant, and at least twice a year. Furthermore,

Group Compliance reports to the Risk and Audit

Committee at a minimum twice a year, and as

required. Telenor also has a Compliance

Committee established to support and advise the

President & CEO in upholding high standards of

governance and compliance. The committee is

composed by President & CEO, Group CFO, EVP

PSER, Group General Counsel, CCO and Head of

GIAI, and convenes quarterly, or as needed.

Governance and compliance within Telenor’s

operations in Asia is delegated and managed by a

separate, local second line compliance function at

the Telenor Asia office in Singapore. To ensure

Telenor ASA receives adequate information,

including monitoring of policy implementation in

the Telenor Asia business area, Group

Compliance maintains regularly direct interaction

with Asia Compliance.

Group Internal Audit and Investigation

(GIAI)

Group Internal Audit and Investigation (GIAI)

operates as an independent internal audit and

investigation unit. The Head of GIAI reports to the

Board through the Risk and Audit Committee. GIAI

is a global function, authorised to conduct

engagements in Telenor ASA as well as any

subsidiary in which Telenor ASA, directly or

indirectly, holds more than 50 percent of the

voting shares or otherwise exercises control on

its own behalf or through its representatives.

Group Investment Committee (GIC)

The Group Investment Committee (GIC) is

responsible for providing recommendations to

the President & CEO, as well as other approval

bodies, regarding investments and other financial

commitments that exceed a specified threshold

or are considered to be of special interest or

significance. The GIC is chaired by the Group CFO

and comprises members with relevant expertise

in the field.

The GIC ensures alignment on decision-making

processes and strategic direction for proposals,

while safeguarding the quality and completeness

of business cases and risks assessments.

Furthermore, the committee performs post-

investment evaluations and promotes knowledge

sharing.

2025

Disclosure Committee for financial

reporting

The Disclosure Committee plays a vital role in

supporting the company’s efforts to comply with

external financial reporting requirements. The

Committee convenes to review the Telenor

Group's quarterly and annual reports, ensuring

that external reporting requirements are fulfilled.

Chaired by the Group CFO, its membership

includes relevant key individuals from the Group

Finance management team, as well as the Head of

Group Legal and the Head of Group

Communications.

See page 61 for details regarding the Disclosure

Committee for sustainability reporting.

Group Treasury

To ensure effective oversight, mitigation and

control of the Group's treasury activities, the

company has established Group Treasury as a

central corporate function. The roles and

responsibilities of Group Treasury are defined in

accordance with its mandate, as specified in the

treasury section of the Group Policy Finance.

Group Treasury operates within Group Finance

and reports directly to the Group CFO.

The objective of the treasury policy requirements

is to mitigate treasury risks within the Telenor

Group and to facilitate efficient management of

treasury activities. This policy also establishes a

comprehensive framework for managing treasury

risks including liquidity risk, financial counterparty

credit risk, currency risk and interest rate risk.

Page 58 _ TE_Telenor_2025_MG_5043_PRINT (002).jpg

Additionally, the treasury section of the Group

Policy Finance outlines the key principles relating

to capital structure, funding, cash management,

bank relationship management, treasury risk

management, issuance of guarantees and

treasury reporting requirements.

Business Area Meetings and Financial

Reviews

Business Area Meetings are typically conducted

with the business areas (Telenor Nordics, Telenor

Asia, Telenor Infrastructure and Telenor Amp)

between nine and 12 times a year, and are chaired

by the President & CEO. The primary purpose of

the Business Area Meetings is to regularly address

critical strategic, operational and financial or non-

financial matters, including topics such as people,

compliance, regulatory, and the actions necessary

to achieve defined milestones or ambitions.

Financial Review meetings are convened with the

business areas and key Telenor Companies on a

quarterly basis, chaired by the Group CFO. These

meetings focus on reviewing each Telenor

Company's financial performance, internal

control, the development of risks, regulatory

matters, and the forecasted financial

performance for the upcoming quarters.

2025

Sustainability

matters

Sustainability matters are regularly addressed in the

agendas of Telenor's governing bodies and Group

Management. This ensures integration of sustainability

into both strategic and operational decision-making, while

providing adequate oversight of how material impacts,

risks and opportunities are managed.

2025

Roles and responsibilities¹⁾

Board and Risk and Audit Committee

The responsibilities of the Board and the Risk and

Audit Committee (RAC) regarding sustainability

matters are defined by the the Board's instruction

and the RAC charter, respectively.

The Board has established clear objectives and

strategic ambitions for Telenor’s sustainability

initiatives. RAC acts as a preparatory committee,

supporting the Board in matters related to

financial and sustainability reporting, including

the oversight of relevant internal controls. The

Board receives regular updates on sustainability

matters and closely monitors the company's

performance. Additionally, the Board is

responsible for approving significant

sustainability targets and ambitions, such as the

transition plan to reduce greenhouse gas (GHG)

emissions.

Furthermore, the Board is responsible for

ensuring that the management prepares the

annual report in compliance with applicable

legislation. RAC is tasked with preparing the

Board's review of Telenor's sustainability

reporting and providing recommendations to

ensure its accuracy and integrity.

Executive Management

Telenor's Group Management plays a pivotal role

in ensuring that the company's commitment to

high standards of business conduct is embedded

within the company culture and consistently

upheld at every level of the organisation.

This is achieved by establishing a clear and

decisive tone from the top across all business.

The members of Group Management routinely

engage in discussions regarding Telenor’s

Responsible Business agenda, covering areas

such as compliance, anti-corruption, privacy and

data protection. They oversee the governance,

target setting and performance of matters related

to sustainability.

The EVP People, Sustainability and External

Relations (PSER) Officer is responsible for

gathering, consolidating and ensuring the quality

of content for both internal and external reporting

on sustainability. This encompasses areas of

health & safety, supply chain sustainability,

business partner management, authority requests

and climate & environment.

The EVP PSER provides support on

Environmental, Social and Governance (ESG)

parameters reporting to the EVP & Group Chief

Financial Officer (Group CFO) who holds overall

responsibility for ESG reporting. Furthermore, the

PSER Officer prepares reports for the Board of

Directors concerning the Corporate Governance

Statement, in accordance with the defined

instructions for this role.

The Group CFO holds ultimate responsibility for

the preparation and quality assurance of the

Annual Report, including the Sustainability

Statements, in accordance with the Group CFO's

EVP Instructions and the Sustainability Policy. The

EVP PSER and the Group CFO report directly to

the President & CEO and to the Board.

How sustainability matters

have been addressed²⁾

The Board, RAC and Group Management are

regularly updated on sustainability reporting and

material sustainability issues, including matters

related to business conduct as outlined in the

Sustainability Statements. Throughout 2025,

Telenor's sustainability matters were addressed

both as scheduled agenda items, in accordance

with the annual planning cycles and on ad hoc

basis when required. All topics presented to the

Board and its committees were initially prepared

and reviewed by Group Management in

collaboration with other relevant stakeholders.

Oversight over the strategy

The Board ensures that Telenor’s strategy

integrates sustainability ambitions and targets,

with regular reporting on progress for each

Business Area and for Telenor as a whole. These

topics are specifically addressed in Business Area

Meetings, as well as in Group Management and

Board meetings.

Target setting and mechanisms for

monitoring progress³⁾

Sustainability targets are typically approved by

the Board. Key Operational Performance

Indicators, Short-Term Incentives and

commitments related to Telenor's Capital Market

Day 2025 have received board approval. Other

targets of more operational nature are

established by Management and are reported to

the Board through in-depth topical reviews and

updates provided by the CEOs.

Further details regarding targets and their

approval processes are outlined in topic-specific

disclosures within the Sustainability Statements.

Quarterly performance reports, which include six

ESG Key Operational Performance Indicators, are

submitted to the Board on a quarterly basis,

enabling the Board to track progress against the

established targets. Group Management monitors

progress regularly and, at a minimum, conduct

reviews on a quarterly basis prior to reporting

performance to the Board.

Risk management and internal control

over sustainability reporting (ICSR)⁴⁾

Effective risk management is fundamental to all

deliberations concerning sustainability strategy

and major transactions, ensuring that Telenor

operates within its defined risk appetite. Telenor

conducts regular assessments of risks and

controls over its sustainability reporting. The RAC

plays a key role in overseeing that the risks and

controls over sustainability processes are robust

and implemented, and provides reports to the

Board on its findings.

Telenor is subject to risks arising from incomplete

or inconsistent reporting on the material

sustainability topics, including risks associated

with greenwashing. Additional risk pertain to the

accuracy of the data collected from various

sources and the potential for manual errors

occurring in the reporting process from

aggregating data into the consolidation system.

The risks are prioritised based on their potential

quantitative impact on the sustainability

statements, as well as qualitative considerations,

such as reputational risk and previous internal

control observations.

1) ESRS reference: ESRS 2 GOV-1-22

2) ESRS reference: ESRS 2 GOV-2-26

3) ESRS reference: ESRS 2 GOV-2-AR-6

4) ESRS reference: ESRS 2 GOV-5-36 (a) through (e)

2025

Telenor has adopted a risk based approach to

controls, including review procedures for both

quantitative and qualitative data in the

sustainability statements, executed at different

levels within the organisation. Telenor has also

implemented general information technology

controls over critical systems, including access

review and automated controls.

When internal control observations are identified,

they are communicated to the relevant

stakeholders within the organisation, and

appropriate remediation activities are

implemented. Management reports the results of

ICSR programme evaluations to the RAC. In 2025,

Management reported twice to the RAC.

The Disclosure Committee for

sustainability reporting

Management implemented the Disclosure

Committee for Sustainability Reporting in 2025 to

support the company's efforts in fulfilling the

CSRD requirements. The Committee convened for

the first time in February 2025 and will continue to

meet annually. Chaired by the Group CFO, the

Committee comprises key representatives from

the People, Sustainability and External Relations

and Group Finance management teams.

How impacts, risks and opportunities

have been addressed¹⁾

To ensure that both the Board and RAC are kept

fully informed on sustainability matters, relevant

topics are incorporated into annual plans, which

include both fixed and potential agenda items

based on e.g. regulatory requirements. The annual

plans are developed in cooperation with the Chair

of the Board, the Chair of RAC and relevant

stakeholders, and are subsequently presented to

the Board and RAC. Meeting agendas are

organised in accordance with the annual plans,

along with any ad hoc items that may arise during

the year.

In 2025, Telenor's material impacts, risks and

opportunities were addressed by the Group

Management, the RAC and/or the Board through

regular updates on Telenor's CSRD

implementation, the Double Materiality

Assessment (DMA) and the sustainability

statements. Sustainability considerations were

also integrated into enterprise risk reporting,

strategy execution reviews and discussions

related to short-term incentive plans. For an

overview of specific material topics addressed in

2025, please refer to the list on the right.

Information about interests and views of

affected stakeholders²⁾

The views of affected stakeholders were

incorporated into Telenor's Double Materiality

Assessment as well as other processes such as

the Human Rights Due Diligence process. Both the

RAC and the Board were kept informed of the

outcome of these processes, and the Board

subsequently approved the Double Materiality

Assessment.

Oversight over decisions on transactions

Major transactions decisions are made following

thorough considerations and due diligence

processes, during which relevant impacts, risks

and opportunities are assessed. Discussions

regarding transactions within Group Management

and the Board are often connected to strategy

execution deliberations.

Sustainability topics discussed by the Board


Material ESRS topics	Material ESRS sub-topics	Agenda items with material sustainability topics (information, discussion and decision items)
ESRS E1 - Climate change	Climate change adaptation	Performance on non-financial targets, Risk reporting, Presentation of Climate Transition Plan Decision on STIs including Climate Scope 3 Deep dive into geopolitical risks including supply chain sustainability
	Climate change mitigation
	Energy
ESRS E4 - Biodiversity & ecosystems	Direct impact drivers of biodiversity loss	Update on progress within Nature & Biodiversity
	Impacts on the site of species
ESRS E5 - Resource Use & circular economy	Resources inflows, including resource use	Performance on non-financial targets Presentation of Climate Transition Plan
	Resources outflows related to products and services, waste
ESRS S1 - Own workforce	Working conditions	Update on H&S incidents and Health & Safety Advancement Program, Performance on non- financial targets, Risk reporting, Presentation of Human Rights Due Diligence
	Equal treatment and opportunities for all
ESRS S2 - Workers in the value chain	Working conditions	Update on H&S incidents and Health & Safety Advancement Program, Performance on non- financial targets, Risk reporting, Presentation of Human Rights Due Diligence, Deep dive into geopolitical risks, including supply chain sustainability
	Other work-related rights
ESRS S4 - Consu- mers & end users	Information related impacts for consumers and/or end-users	Presentation of Human Rights Due Diligence
ESRS G1 - Business Conduct	Corporate Culture	Risk reporting: Compliance update, Group Internal Audit and Investigations, Update on reported concerns, investigations and resolutions, Code of Conduct e-learning, Cybersecurity Update
	Corruption & Bribery
	Management of relationship with suppliers
	Cybersecurity
Entity-specific	All areas	Presentation of Double Materiality Assessment

1) ESRS reference: ESRS 2 GOV-2-26 (a) through (c)

2) ESRS reference: ESRS 2 SBM-2-45 (d)

2025

Executive

compensation

The Corporate Assembly determines the compensation to

the Board of Directors, based on recommendation from

the Nomination Committee. Compensation to the Board of

Directors is not linked to the company’s performance.

Telenor’s compensation to the Group Management

comprises base salary, short-term incentive, long-term

incentive, pension plan, and benefits, as outlined in

Telenor’s Compensation Policy. It is the Board's view that

the compensation is in line with the Norwegian state

guidelines for executive compensation.

2025

Compensation to Corporate

Assembly and the Board

All aspects of compensation to the Corporate

Assembly and the Board of Directors are detailed

in Telenor Group’s Executive Compensation

Report for 2025 (Compensation Report), which is

published as a separate document, available on

Telenor.com.

Compensation to the Group

Management

The compensation policy

The Compensation Policy is defined to enable

Telenor to attract, engage and retain executives

to deliver on the business strategy and contribute

to the long-term interests and sustainability of the

Telenor Group. The Board of Directors’ policy for

compensation of the Group Management

(Compensation Policy) was approved by the

Annual General Meeting (AGM) on 21 May 2025.

For minutes of the 2025 AGM, please refer to

Telenor.com.

It is the Board’s assessment that the

implementation is in line with the Compensation

Policy and the Norwegian state guidelines for

executive compensation. The Compensation

Policy will be subject to approval by the Annual

General Meeting when there is a material change

and at least every fourth year, in accordance with

the Norwegian Public Limited Liability Companies

Act, section 6-16a and supplementing regulations.

Comprehensive details concerning compensation

to the President & CEO and the Group

Management are provided in the Compensation

Report.

Incentive schemes and compensation

linked to sustainability matters¹⁾

The principles governing Group Management's

compensation are outlined in the Telenor Group

Executive Compensation Policy, as approved by

the Annual General Meeting. The short-term

incentive plan (STI) forms part of their

compensation and is defined within the policy.

The primary objective of the STI is to provide

direction and motivation to achieve high

performance, aligned with strategic ambitions

and Telenor behaviours. This cash-based plan

allows for a maximum annual earning of 25% of

annual base salary for Group Management, in

accordance with state guidelines. Performance is

evaluated based on the achievement of set annual

performance measures, utilising a balanced

scorecard focusing on group-wide priorities,

including financial results and sustainable

business performance. For Group Management,

the scorecard - including weighting of KPIs and

targets - is approved by the Board on an annual

basis.

In 2025, the Telenor Group STI scorecard

comprised five financial and operational KPIs,

two of which were related to sustainability. These

two KPIs carried a combined weighting of 30% of

the scorecard.

The two KPIs were as follows:

• A climate-related KPI tied to progress towards

Telenor's scope 3 target of ensuring that 66% of

suppliers by spend have established science-

based targets for their own operations by 2025.

The target for 2025 was set at 69%, excluding

Telenor Pakistan.

• The Engagement and Enablement Index (EEI) is a

KPI designed to measure employee satisfaction,

encompassing factors that drive workforce

effectiveness and business performance across

all teams and markets. This index serves as a

foundation for systematic organisational

development and improvement efforts. The goal

is to improve the EEI index.

The proportion of variable compensation for

Group Management that is dependent on

sustainability-related targets or impacts, is

presented below.


Sustainability-related targets and/ or impacts	2025
Percentage of variable compensation dependent on sustainability-related targets and/or impacts	14%

Compensation to the Board of Directors is not

linked to company performance. Board members

receive a fixed annual compensation, along with

additional compensation for their participation in

Board committees. The full disclosures regarding

executive compensation are available in the

Telenor Group Executive Compensation Report

2025 on Telenor.com.

1) ESRS reference: ESRS 2 GOV-3-29

2025

Shareholder

information


Shareholders and dividends		The Telenor shares
66	Ownership	69	Trading and performance of the Telenor shares
67	Shareholder remuneration		Trading and performance of the Telenor shares
		70	Share capital and equity
		70	Shareholder principles

2025

Shareholders and

dividends

Telenor is listed on Oslo Stock Exchange and has around 55

thousand investors. The Norwegian state owns the majority

(54%) of the shares and the remaining 46% is available for

public trading. Telenor has a dividend policy of nominal

annual increase in dividend per share. For 2025, the Board

has proposed a dividend of NOK 9.70 per share, compared

to NOK 9.60 in 2024.

2025

Ownership

The Board is responsible for evaluating the

expectations that the shareholders and others

have towards the company, and for

Investor by type

Local versus foreign shareholders, by type

accomplishing the commercial targets which the

Board deems appropriate.

The Norwegian state is the largest shareholder in

Telenor, with a holding of 54 per cent of the

Telenor shares as of 31 December 2025. The

Ministry of Trade, Industry and Fisheries manage

the ownership interest. The Norwegian state

emphasises that partly state-owned companies

should comply with principles for good corporate

governance. The State's goal as owner is to

ensure the highest possible return over time in a

sustainable manner. Its active exercising of the

ownership policy is governed by the Norwegian

legislation for companies and by accepted

principles for exercising good ownership. The

rationale for the ownership in Telenor is to

maintain a leading telecommunications company

with head office functions in Norway, and to have

control of communications infrastructure that is

critical to society¹⁾.

The geographies where most shareholders are

based are Norway (68%), United states (10%),

United Kingdom (3%), Germany (4%) and Canada

(2%).

In 2025, approximately 39% of employees signed

up for shares through the Telenor Employee

Share Programme.

1) More information about administration of the

Norwegian state’s ownership interests and the

Government’s Ownership Policies can be found on

the Government’s webpages.

2025

Capital markets day (CMD)

On 11 November, 2025, Telenor hosted a Capital

Markets Day.

Key strategic priorities for the 2025-2030 period:

• Growth through customer excellence and

service innovation

• Accelerating technology-led transformation

• Tapering opex and capex to sales

• Driving shareholder value creation with a focus

on RoCE and prudent, consistent capital

allocation

Telenor also presented financial ambitions for

2028 and 2030. A detailed description of these

financial ambitions is provided on page 20. The

CMD presentation and supporting materials are

available on Telenor's website and investor portal.

Shareholder remuneration

The Board has an objective to provide its

shareholders with a return on their investments at

least equal to alternative investments with similar

risk profiles. Such a return should come in the

form of cash dividends and/or share buyback if

applicable, and increased share value.

Dividend policy

Telenor's dividend policy is to aim for year-on-

year growth in ordinary dividends per share. This

dividend policy forms the basis for the proposals

on dividend payments presented by the Board of

Directors to the Annual General Meeting. Ahead of

the 2025 Capital Markets Day, the Board

confirmed the commitment to Telenor's this

policy, in recognition of the benefits of a long-

term and predictable approach to shareholder

remuneration.

Telenor pays dividends on a semi-annual basis. In

addition, acquisition of treasury shares and/or

extraordinary dividends will be evaluated on a

case-by-case basis. The Public Limited

Companies Act provides for dividend payments to

be resolved by the Board pursuant to

authorisation from the General Meeting. Such

authorisation may only be provided until the next

ordinary AGM and dividends may only be resolved

based on the company’s latest approved annual

accounts.

Proposed dividend for 2025

The Annual General Meeting (AGM), following the

proposal from the Board, adopts a resolution on

the distribution of the dividend. The AGM on 21

May 2025 approved an ordinary dividend of in

total NOK 9.60 per share, representing an

increase of one per cent per share over the

previous year.

The Board will propose a total dividend of NOK 9.7

per share for the financial year 2025 to the AGM

on 19 May 2026. The proposed dividend would be

split into two tranches of NOK 5.00 and NOK 4.70

per share to be paid in June and October 2026,

respectively. The two tranches will have separate

ex. dividend and record dates. The proposed

dividend per share is one per cent higher than the

dividend per share paid out in 2025.

2025

Telenor shares

Telenor’s shares are listed on the Oslo Stock Exchange.

Transparency and equal treatment of shareholders along with

accurate and transparent investor communication are

important principles for us. While having one class of shares

and one stock-exchange listing, it is also possible to trade

American Depositary Receipts in the US on OTC QX.

2025

Trading and performance of

the Telenor shares

Stock Exchange listing and overseas

trading alternatives

On 4 December 2000, Telenor was listed on the

Oslo Stock Exchange (Oslo Børs) and the Nasdaq

in New York. In what was then the largest ever IPO

in Norway, Telenor offered more than 372 million

shares for sale, with an opening price of NOK 42.

Following the IPO, the ownership of the

Norwegian government in Telenor was 79%.

Telenor gained 55,000 new shareholders, of

which 53,000 were private, and the majority

Norwegian. Today, Telenor is still listed on the

Oslo Stock Exchange (delisted from the Nasdaq in

2007) and the shares are freely traded.

In addition to this, overseas investors have the

opportunity to trade the shares within in the form

of American Depositary Receipts (ADRs) on OTC

Markets, a regulated US market place. Telenor

ADRs are tradable in USD on OTC QX. This ensures

improved visibility for Telenor in the overseas

market and the best possible standards,

accessibility and liquidity for US-based investors

that prefer to trade Telenor stock as USD-quoted

securities during US trading hours.

Share-price performance in 2025

The graph on this page shows Telenor’s total

shareholder return relative to European telecom

stocks during 2025. The total shareholder return

for Telenor was 23% compared to the sector

index return of 17%.

Total shareholder return during 2025

Total shareholder return, Telenor compared to European Telecom Sector Index, per 31 December 2025


	1 Year	3 year	5 Year	10 Year	20 Year
Telenor	23%	97%	43%	88%	491%
Standard & Poor's Telecom Services Gross Return Index (SXKGR)	17%	55%	54%	16%	n/a

2025

Share capital and equity

Development of share capital in 2025

The share capital of Telenor is stated in the

Articles of Association, article 4. The company’s

share capital at year-end 2025 is NOK

8,210,099,934 divided into 1,368,349,989 shares,

each with a par value of NOK 6.00.

During the first quarter of 2025, 1,019,355 own

shares were acquired according to the

authorisation from the AGM, to meet obligations

in accordance with the company’s Long-Term

Incentive (LTI) plan for executive management

and in connection with Telenor’s general share

plan (ESP) for employees. In the first quarter of

2024, a total of 614,207 shares were distributed to

employees according to this authorisation.

At the AGM on 21 May 2025, the Board was given

authorisation according to section 9-4 of the

Public Limited Liability Companies Act to acquire

up to 10,000,000 of its own shares with a nominal

value of a total of NOK 60,000,000, which

corresponds to approximately 0.7% of the

company’s share capital. The authorisation was

given to cover the fulfilment of the company’s

obligations to employees who participate in

Telenor's share plans: the company's general

share purchase plan for employees (ESP), the

long-term share incentive plan for executive

management (LTI), and the executive

compensation element: salary substitute as

restricted shares for certain executives.

As per 31 December 2025, a total of 459,805

shares had been distributed to employees

according to this authorisation (since AGM in May

2025).

Increase in share capital

Telenor practices the principle that any decision

to waive the pre-emption rights of existing

shareholders to subscribe for shares in the event

of an increase in share capital should be justified.

Where the Board resolves to carry out an increase

in share capital and waive the pre-emption rights

of existing shareholders based on a mandate

granted to the Board, the justification should be

publicly disclosed in a stock exchange

announcement issued in connection with the

increase in share capital.

Equity

Telenor regards its consolidated equity to be at an

appropriate level considering the company’s

objectives, strategy, and risk profile.

Telenor’s objective is to create value for its

owners and stakeholders and involves a

continuous focus on ensuring that the company’s

equity is adapted to the company’s objectives,

strategy, and risk profile.

Purchase of treasury shares

At the AGM on 21 May 2025, the Board was given

authorisation according to the Public Limited

Liability Companies Act section 9-4, to

repurchase the company's own shares. The

authorisation encompasses up to 41,000,000

shares with a combined par value of NOK

246,000,000. The highest consideration that may

be paid for a share is NOK 250 and the lowest

consideration is NOK 50. The Board of Directors

may resolve how and when shares are

repurchased, subject to ordinary principles for

equal treatment of shareholders. Own shares that

are acquired shall be cancelled pursuant to the

Public Limited Liability Companies Act section

12-1. The authorisation is valid from the time of

registration of the authorisation in the Company

Registry until the next Annual General Meeting but

not beyond 30 June 2026.

Shareholder principles

Transparency and equal treatment

The Board endorses the principles of

transparency and equal treatment of all

shareholders. Telenor has one class of shares, and

each share equals one vote at the General

Meeting. The shares have no trading restrictions

in the form of Board consent or ownership

limitations. The Articles of Association of Telenor

ASA contain no restrictions on negotiability or

voting rights and all shares have equal rights.

Information and communication

Timely and accurate information from Telenor

shall help shareholders and other investors make

informed decisions relating to the purchase and

sale of the company’s shares, based on equal

access to information.

The Board provides guidelines on the company’s

reporting of financial and other information based

on openness and transparency, and in

accordance with requirements relating to equal

treatment of all participants in the securities

market. Each year, Telenor announces the dates

of important events, such as the AGM, the

publication of interim reports, public

presentations, and the payment date of any

dividends.

Information sent to the company’s shareholders is

made available on the Telenor website at the

same time as it is sent to the shareholders. The

Investor Relations function at Telenor ensures

that contact with the company’s shareholders is

maintained outside the General Meeting; see

Telenor’s corporate website.

Takeover

Any reduction of the Norwegian State’s stake in

Telenor requires a special resolution from the

Norwegian Parliament. For such reason, the Board

has not adopted any guiding principles as

recommended by the NCGB Code of Practice

since the process in Parliament will safeguard the

intentions set down in the NCGB principles. In the

event of a takeover bid, the Board will comply with

the NCGB principles.

2025

Sustainability

Sustainability as part of the strategy 41

Sustainability governance 42

Stakeholders and material topics 44

Basis for preparation 48

Environmental

Climate change 50

(e)Waste and circularity 56

Biodiversity 57

EU taxonomy for sustainable activities 58

Social

The report on Norwegian Transparency Act

(Human rights) 65

Integrity Hotline 69

Forced, child and underage labour 70

Employee development73

Diversity, equity and inclusion75

Occupational health and safety77

Digital skills, inclusion and online safety80

Governance

Responsible supply chain85

Privacy and data protection88

Cyber security90

Ethical business and anti-corruption92

Responsible tax practices94

SUSTAINABILITY STATEMENTS:

TRANSPARENCY ACT:

General information

Environment

Social

Governance

Human rights

Value creation, strategy and

governance

Climate change (ESRS E1)

110

Own workforce (ESRS S1)

142

Business conduct

(ESRS G1)

159

Policies and processes

Biodiversity and ecosystems

(ESRS E4)

120

Workers in the value chain

(ESRS S2)

162

Stakeholder engagement and

transparency

Value chain

146

Cyber security

(entity-specific)

General basis for preparation

100

Resource use and circular

economy (ESRS E5)

129

Consumers and end-users

(ESRS S4)

162

Way forward

Interests and views of stakeholders

Double materiality assessment

107

EU Taxonomy for sustainable

activities

135

Digital skills, inclusion and

online safety

(entity-specific)

151

Appendices to

Sustainability statements

Material impacts, risks and

opportunities

2025

General

information

Telenor’s sustainability ambitions build on the

company’s purpose of "With you for a safer

and smarter tomorrow", with digital inclusion

as a key driver of reduced inequalities and

contribute to social participation. As societies

become increasingly dependent on connectivity,

maintaining resilient networks against cyber and

physical threats is essential. By reducing

emissions, strengthening human rights across

the value chain, and fostering a diverse, inclusive

workforce, Telenor strives to make a meaningful

positive impact on both society and the

environment.

2025

Value creation, strategy and

governance

The year 2025 marked a period of significant

transformation for societies and industries

worldwide. Geopolitical shifts, technological

decoupling, and accelerating climate change

continued to reshape the global landscape. As

connectivity becomes ever more intertwined with

societal resilience, economic opportunity, and

environmental progress, telecom operators play

an increasingly pivotal role. For Telenor, this

interdependence reinforces its purpose: "With

you, for a safer and smarter tomorrow".

Strategy and business model

Connectivity, digitalisation and security are at the

core of the Company's strategy, and Telenor's

more than 10,000 employees are essential to

achieving its ambitions. Responsible business is

embedded in everything Telenor does.

Telenor welcomes the increased focus on

sustainability driven by the CSRD and ESRS

reporting which has resulted in a more structured

approach, including more focus on targets and

actions for the various material topics.

The sustainability focus has in the past, and now

increasingly so, resulted in changes to the

strategy and business model of Telenor. Several

of the material impacts covering environmental,

social and governance topics are part of the

current strategy.

Most of the material topics, such as climate &

environment, human rights, health and safety,

supply chain sustainability, digital skills,

governance, and development of employees have

been part of Telenor's responsible business

approach for several years.

Within circularity, the ambition of take-back rate

for mobile devices may potentially result in some

adjustments of products offered.

During 2025 Telenor launched its refreshed

strategy which will be valid for the period 2026

through 2030. The key sustainability ambitions fall

under three main categories, with the following

targets:

Operating green and secure network

infrastructure

• 69% reduction in Telenor's scope 1 & 2 GHG

emissions by end of 2030

• Ensure consistently improved security maturity

across all Telenor companies

Driving digital inclusion and wellbeing

• 800,000 people in the Nordics trained in digital

wellbeing by end 2028

• 5 million people in Asia to receive useful digital

training by end 2028

Doing business in a responsible and inclusive

way

• 40% women in Telenor's top leadership by end

of 2028

• 85% timely resolution of sustainability non-

conformities in the supply chain by end of 2028

For the 2025 report, Telenor reports on what has

been implemented in relation to the existing

strategy.

In 2024, each business area identified their

prioritized impacts, risks and value-creating

opportunities. The aim has been to further

integrate and define the actions and ambitions of

the material areas into the 2025 business

strategy. Overall, the strategy and business model

is considered resilient when it comes to capacity

to achieving sustainability targets and address the

material topics of Telenor. The impact on strategy

and business model is further described within

each material topic.

See page 16 for more information about the

strategy, page 20 for ambitions and page 116 for

more information about the characteristics of

Telenor's employees.

Governance

The processes designed to ensure that targets

are met within sustainability are also key for

Telenor to achieve its overall targets and

ambitions. As such, sustainability is an integral

part of Telenor's governance framework,

providing accountability and enabling the

company to plan, implement and monitor

progress on sustainability activities.

Telenor value chain

Telenor’s influence extends well beyond its direct

emissions and operations. Because of the scale of

Telenor's procurement, each link in the value

chain can influence change across the value

chain.

In the upstream value chain, the negative impacts

relate to raw material extraction from equipment

manufacturing, and risk of health and safety

incidents during network construction and

operation, in addition to scope 3 emissions in the

supply chain. There are also risk of human rights

and labour violations in parts of the global supply

chain. Telenor can shift supplier behaviour by

requiring science-based targets, ethical labour

practices, and environmental controls. Its

contractual frameworks enforce human rights

expectations deeper into the chain.

In own operations, increased data usage by

consumers drive energy usage in the network

infrastructure, while renewing the network

equipment creates e‑waste. Telenor can positively

impact network innovation through use of AI and

5G to increase energy efficiency among others.

Workforce diversity and skills investments build

equitable labour markets.

In the downstream value chain, Telenor can

impact device recycling and reuse to reduce

global raw material extraction. Digital inclusion

programs support societal resilience.

Telenor's value chain is presented on the next

page, showing where each of the material topics

in this report impacts the value chain.

2025

2025

General basis for preparation

Purpose and scope

The sustainability statements will present how

Telenor has identified its material sustainability

topics together with impacts, risks and

opportunities for each topic. The targets set by

management and how Telenor is working to

achieve these targets are presented within each

material topic. The Sustainability statements

provide a detailed account of Telenor's

environmental, social, and governance

performance for the reporting year 2025 and

comparative 2024 or prior periods where relevant.

The report covers Telenor's own operations along

with its upstream and downstream value chains,

highlighting the company's dedication to

comprehensive and transparent reporting.

Reporting frameworks and standards

These Sustainability Statements are prepared

based on the requirements of the Corporate

Sustainability Reporting Directive (CSRD) and the

European Sustainability Reporting Standards

(ESRS) according to the reporting requirements

mandated by the Norwegian Accounting Act

chapter 2-3.

The CSRD and ESRS became effective in Europe

from 1 January 2024. All reported data points in

the environmental, social, and governance

sections have been identified as material through

the company's double materiality assessment.

Descriptions of reporting methodologies are

generally included in the various material topics.

Consolidation principles and boundaries

The Sustainability statements have been prepared

following the same principles for consolidation as

the Telenor's financial statements. The

consolidated data includes the parent company

and all subsidiaries under Telenor ASA’s control.

Joint operations are included proportionately,

reflecting Telenor's share of assets and liabilities

in these operations. The major joint operations of

Telenor relate to joint ownership of towers and

other infrastructure.

Associates (such as True Corporation and

CelcomDigi) and joint ventures of Telenor are not

considered actors in the value chain, and Telenor

does not have operational control in these

entities. As such, they are generally not included

in the reporting of the various topics, except

when reporting greenhouse gas (GHG) emissions.

In ESRS E1 Climate change, the joint ventures and

associates are included according to ownership

share as scope 3 GHG emissions (category 15

Investments).

Acquired and disposed entities are included from

the date of acquisition and ending at the date of

divestment, meaning the date when control is

acquired or lost.

Telenor Pakistan - discontinued operation

Telenor Pakistan was part of the Telenor Group

until 31 December 2025 and was deconsolidated

as of that date.

For period-based sustainability metrics, Telenor

Pakistan is included in the consolidated figures for

the full reporting year 2025, reflecting

performance during the period in which the entity

was part of the group. Comparative figures for

2024 also include Telenor Pakistan, as it was part

of the group during that reporting period.

For point-in-time metrics measured as at 31

December 2025, Telenor Pakistan is excluded, as

control was lost at the reporting date.

Comparative figures for 2024 continue to include

Telenor Pakistan, as the entity was part of the

group at that date. Any resulting year-on-year

changes are explained in the relevant disclosures.

ESRS does not require a separate presentation

for discontinued operations as applied under IFRS

Accounting Standards. Accordingly, Telenor

Pakistan is included line by line in the relevant

sustainability metrics, without separate columns,

for the reporting period up to the date control

was lost.

Targets and achievements data up to and

including 2025 include Telenor Pakistan, reflecting

performance during the period in which the entity

was part of the group. Targets set for periods

from 2026 onwards exclude Telenor Pakistan,

following its deconsolidation as of 31 December

2025.

Refer to note 12 in the financial statements for

more information about disposed entities.

Any limitations in data availability or reporting

scope are disclosed in the relevant sections of the

report.

Omission due to intellectual property,

know-how or innovation

No information has been withheld due to

intellectual property, know-how or innovation

purposes.

Key sources of estimation uncertainty

The preparation of these sustainability

statements requires management to make

significant estimates that could be materially

different from actual results. Management uses

industry standards, trends, historical data,

consultation with experts or other relevant

sources where exact data is not available. The

estimates are periodically reviewed and updated.

The most significant estimates in the

sustainability statements of Telenor are described

below.

• GHG emissions in scope 3 (ESRS E1 Climate

change): Indirect sources are being used to

estimate value chain emissions, such as

calculation models based on averages and

assumptions. See more information on page 96.

• Energy consumption (ESRS E1 Climate change):

Diesel and electricity consumption figures are

partially estimated using historical data and

operational benchmarks where actual data was

incomplete. See more information on page 96.

2025

• Resource inflows (ESRS E5 Resource use and

circular economy): Material inflow per type

(towers, 5G radios and mobile phones) is

estimated by multiplying the number of units

added the reporting year with an estimate of the

amount (weight) of materials in a representative

unit See more information on page 103 and

onwards.

• Resource outflows (ESRS E5 Resource use and

circular economy): Telenor recognises the

resources that go into mobile phones, as

estimated under Resource inflow, also to be

relevant for Resource outflows. As Telenor sell

to client the phones purchased from producers,

it is assumed that inflows equals outflows. As

such, the inflows estimate also covers outflows.

See more information on page 104.

• Recyclable content: The share of recycled

content in phones is estimated as a weighted

average of the share of recycled content in the

nine phone models that Telenor sold the most of

in Norway in 2025, weighted by sales volumes.

For models for which there is no information on

the share of recycled content, we assume the

share is zero. See more information on page

103.

Further information on the key estimates,

judgements and assumptions applied are

described under the heading "reporting

methodologies" in each material topic.

Forward-looking statements

This report contains forward-looking statements

that involve inherent risks and uncertainties.

These statements are based on current

expectations and projections about future events,

and may differ materially from actual outcomes

due to various risk factors.

Changes and errors in reporting

methodologies

The sustainability disclosures in this report were

aligned with the requirements of the CSRD and

ESRS for the first time in 2024. Changes in

reporting methodologies are addressed in each

dedicated section for the relevant material topic.

Mandatory, phase-in and "may"

disclosure requirements

Telenor's disclosures in these Sustainability

statements follow the material topics and sub-

topics concluded in the Double Materiality

Assessment.

Telenor will adopt phase-in requirements when

they become mandatory. Telenor has not

disclosed the voluntary "may" requirements in this

report.

For 2025 Telenor is specifically making use of the

phase-in provisions in accordance with Appendix

C of ESRS 1 (ESRS 2 §17) for ESRS E4 Biodiversity

and Ecosystems after the "Quick fix" was passed

in the EU Parliament in July 2025 as part of the

Omnibus simplification process. Further, Telenor

makes use of the simplifications for the EU

Taxonomy. See Appendix 1 to the Sustainability

statements on page 151 for a complete overview

of all ESRS disclosure requirements with

references.

Limited audit assurance

These Sustainability statements have been

subject to limited assurance, refer to page 277.

Sustainability information stemming

from other legislation

As part of Telenor's Sustainability Statements,

metrics required according to the Norwegian

Account Act, § 2.3 are reported in ESRS S1 Own

Employees, page 118. Further, Appendix 2 to the

Sustainability statements, on page 154, provides a

list of which disclosure requirements that derive

from other EU legislation.

The report on the Norwegian Transparency Act is

a separate section after the Sustainability

statements, it is not part of the limited assurance

and is found on page 159 onwards.

2025

Incorporation by reference

Some of the strategy and governance disclosures

from the cross-cutting standard (ESRS-2) are

included in other sections to give a more

comprehensive description of Telenor's approach

to Sustainability. The relevant disclosure

requirements are listed in the first table to the

right.

Statement on due diligence

The second table below provides a mapping of

where in the Sustainability statements the

company provides information about its due

diligence process according to the core steps of

human rights due diligence (OECD Guidelines),

including how Telenor applies the main aspects

and steps of its due diligence process.

Overview of incorporation by reference


ESRS-2 reference	Disclosure requirement	Sub-chapter (chapter)	Page
SBM-1.40 (a) i and ii	Description of products, services and markets	• Products and services (Introduction)	11
SBM-1.40 (a) iii	Sustainability elements of strategy	• Our strategy (Strategy, performance and risks)	16
SBM-2-45 (d)	Information about affected stakeholders	• Information about interests and views of affected stakeholders (Corporate governance)	61
GOV-1-21	The composition, diversity and experience of the Board of Directors and management	• Composition, diversity and independence of the Board (Corporate governance) • Composition and diversity of the executive management (Corporate governance)	47
GOV-1-22	Roles and responsibilities of the administrative, management and supervisory bodies	• How impacts, risks and opportunities have been addressed (Corporate governance) • The work of the Board (Corporate governance)	60 48
GOV-1-23 and GOV-1-21-c	Skills and expertise of of administrative, management and supervisory bodies to oversee sustainability matters	• Expertise and skills of the Board (Corporate governance) • Expertise and skills of the Executive Management (Corporate governance)	48 56
GOV-2-26 GOV-2-AR-6	Information provided to and how sustainability matters addressed by the undertaking's administrative, management and supervisory bodies	• How sustainability matters have been addressed (Corporate governance)	60
GOV-3-29	Incentive schemes and remuneration policies linked to sustainability matters	• Incentive schemes and compensation linked to sustainability matters (Corporate governance)	63
GOV-5-36 (a)-(e)	Risk management and internal controls over sustainability reporting	• Risk management and internal controls over sustainability reporting (ICSR) (Corporate governance)	60

Overview of due diligence processes


Core elements of due diligence	Sections in the Sustainability statements	Page
Embedding due diligence in governance, strategy and business model	S1 Own workforce , and Corporate governance (in the Annual Report)	112 and 60
Identifying and assessing adverse impacts	S1 Own workforce and S2 Workers in the value chain	115 and 123
Taking action to cease, prevent or mitigate adverse impacts	S2 Workers in the value chain as well as throughout the report	124
Track implementation and results	S2 Workers in the value chain	124
Communicate how impacts are addressed	S2 Workers in the value chain, S4 Consumers and end-users, as well as throughout the report	124 and 126
Provide for or cooperate in remediation when appropriate	S1 Own workforce and S2 Workers in the value chain	115 and 126

2025

Interests and views of

stakeholders

Engagement with stakeholders

Active engagement with affected stakeholders is

essential to building trust and a key element in

strategic decision-making. Telenor seeks to

engage with key stakeholders in an open and

transparent manner. Feedback from stakeholders

play an integral part in the materiality assessment

process and is incorporated in updates to

company management and supervisory bodies.

Interests and views on strategy and

business model

Telenor collects views on sustainability aspects of

the company's strategy on an ongoing basis.

Expectations from investors and the majority

owner on Telenor include to show progress

towards the company's climate goals, focus on

circularity, inculcate an adaptive corporate

culture, maintain oversight on cybersecurity and

data privacy, conduct thorough due diligence,

adapt proactive approaches to labour rights

especially in supply chain, maintain high standards

in sustainability reporting and be a leader in ESG

while integrating long-term value drivers into its

strategy.

Civil society stakeholders expect Telenor to

conduct human rights due diligence, play a role in

the circular economy, prevent technology abuse

by state and non-state actors, focus on good

governance and whistleblower protection,

continue impactful projects on digital skills, and

maintain high standards in overall sustainability.

Employee representative groups expect Telenor

to address the societal and workforce impacts of

AI, ensure employee upskilling, maintain good

working conditions, be mindful of environmental

impact, and continue promoting inclusive

employment practices.

Engagement on social topics

Telenor also engages with stakeholders on

specific social topics:

Own workforce (ESRS S1)

Telenor actively engages its workforce to ensure

alignment with company strategy and promote

transparency. This engagement includes

gathering employee feedback through Employee

Engagement Survey (EES) and fostering open

communication through town-hall meetings and

engagement with labour unions. Development

opportunities are facilitated through the

performance appraisals and the People Dialogue

Process.

The outcomes of these efforts lead to

improvements in policies, employee growth plans

and initiatives, all contributing to a sustainable

and supportive workplace environment.

Workers in the value chain (ESRS S2)

Telenor uses various methods to understand

value chain workers’ perspectives, such as

comprehensive audits that align with SA 8000

standards and include interviews with

marginalised groups.

SA 8000 is an international standard for social

accountability, focusing on improving working

conditions and ensuring ethical practices in the

workplace, including fair wages, health and safety,

and freedom of association. The methods

emphasise building supplier capacity through

training and leveraging external research,

especially in the extractive value chain, to address

issues such as child labour.

Consumers and end-users (ESRS S4)

Telenor does not have a general group-defined

process for engaging with consumers and end-

users on impacts, risks and opportunities.

However, Telenor works to understand

expectations to and consequences from its

operations through participation in various

networks and forums. One example is the Global

Network Initiative (GNI), where proxies for users

are represented. An Al high-level forum of

external experts was set up in 2024 by Telenor to

identify the best way forward with ‘AI Skills, safety

and inclusion’ for both developers and users. A

final report was published, both for reading and

listening, in January 2025.

Telenor gathers input from respective markets

through consumer surveys and brand trackers.

The insights are used to inform and enhance

Telenor's global brand analysis. This approach

provides the company with valuable market-

specific data on brand perception and consumer

behaviour.

Digital skills (entity specific)

Telenor engages in dialogue with relevant

stakeholders to better understand customer and

societal expectations on efforts related to digital

inclusion and wellbeing. This is of specific value

when designing and evaluating various outreach

programmes in collaboration with the company's

global sustainability partners. Telenor also

interacts with governmental and regulatory

bodies, academia, industry organisations,

partners and NGOs, seeking to align its strategic

prioritisations accordingly.

2025

Overview of engagement with stakeholders

The table summarises how stakeholders’ interests and views inform Telenor's strategy and business model.


Stakeholder	Format of engagement	Purpose	Examples of outcomes
Employees	• Town hall meetings • Employee engagement surveys (EES) • In-person and digital trainings • Internal communication platforms (Workplace) • People dialogue • Engagement with labour unions	• Including employees' perceptions and experiences • Ensuring visibility of company strategy and performance • Fostering employee development • Retaining employees • Contributing to a sustainable workplace and working life	• Changes to policies and guidelines • Employee development plans • Workplace improvement plans and initiatives
Customers	• Customer satisfaction surveys • Call centres • Industry forums • Website	• Providing solutions, service and support • Collecting input on areas of improvement • Enabling business customers to achieve their targets	• Products and service improvements • Marketing activities • Information on network shutdowns where relevant
Suppliers	• Business partner due diligence • Supplier inspections • Workshops • Industry forums	• Compliance with Telenor's Code of Conduct and supplier conduct principles • Promoting and improving responsible business practices across the value chain • Protecting human and labour rights among workers • Decarbonising the supply chain	• Changes to policies and guidelines • Informed selection of suppliers • Supplier improvement plans and activities • Increasing number of suppliers with science-based climate targets
Investors	• Quarterly presentations • Annual General Meeting (AGM) • Regular investor meetings, including with majority owner • Investor calls and emails • ESG ratings • Capital market days	• Attracting investors • Promoting transparency • Understanding expectations	• ESG rating responses, plans and activities • Investor communication efforts and roadshows
Civil society & multi- stakeholder groups	• Open dialogue with local civil society organisations • Participation in both closed and public dialogue, in non-governmental organisations (NGOs), and multi-stakeholder forums • Partnerships and collaborations on national and international level • Contributions to research projects • Public meetings and consultations	• Designing and contributing to local and global sustainability initiatives • Providing emergency relief • Sharing best practice and driving thought leadership • Addressing concerns of local communities • Enabling build-out of renewable energy • Developing industry standards on sustainability	• Global sustainability partnerships with UNICEF, Plan International • Local community programmes on e.g., digital inclusion • Monetary contributions and donations • Alignment on sustainability practices • Rights holders perspectives received through engagement with for e.g. GNI, UN office of the High Commissioner on Human Rights, Global Child Forum, UN Global Compact
Governments, policymakers & regulators	• Direct dialogue with policymakers and regulators • Active participation in industry associations • Answering public consultations • Publication of reports, white papers and studies	• Addressing relevant policy topics • Ensuring regulatory compliance • Acquiring resources, such as spectrum	• Response to public consultations • Internal programmes and projects to ensure compliance • Aligning business model and strategy

2025

Double materiality assessment

Telenor’s 2025 double materiality assessment

(DMA) was conducted in accordance with CSRD

guidance and requirements, taking into account

the findings and recommendations from the

review of Telenor’s 2024 DMA.

The 2025 update is based on the 2024

methodology, as outlined below. Some changes

were made to the processes and methodology to

improve the quality of the output, without

compromising consistency requirements.

The DMA was performed corresponding to

Telenor’s context and organisational setup. The

reporting boundaries include the four business

areas and Group functions. The associates in Asia

were assessed as part of the value chain.

The outcome largely reflects the outcome of the

2024 DMA, while addressing some material

changes in the business environment during 2025.

The results were presented to the Board of

Directors on 17 September 2025. This included the

methodology applied, the outcome of the material

topics, list of impacts, risks and opportunities

(IROs), and an overview of IROs no longer material.

The 2025 update was based on the same four-

step methodology as applied in the previous year.

Understand the business, value chain

and related activities (step 1)

This phase involved understanding the context of

operations, including mapping the business area

(BA) value chains. The purpose was to gain a

better understanding of the extent of impact from

activities in the value chain in order to identify

potential ESRS focus areas. Key internal and

external stakeholders were also identified. This

phase resulted in creating a mapping of the value

chain against that of the ESRS and a stakeholder

engagement plan.

Identify relevant IROs (step 2)

This phase involved identifying IROs through

desktop research, strategic documents, prior

materiality results, human rights and

environmental impact assessments, supplier

agreements, surveys, risk picture, due diligence

reporting, employee engagement surveys, peer

and industry screening and additional stakeholder

engagement.

Assess materiality of the IROs (step 3)

This phase involved defining mechanisms and

criteria for assessing and scoring the IROs. The

scoring was done separately for risks and

opportunities (i.e. financial materiality) and for

impacts (i.e. impact materiality). The following

elements have been used as part of Telenor’s

scoring mechanism:

Financial Materiality

For financial materiality (i.e., risks and

opportunities) scoring was done based on

magnitude and likelihood, leveraging Telenor’s

Enterprise Risk Management (ERM) process. The

scoring was based on the potential magnitude of

the risk/opportunity, defined as the highest score

(scale 1-5) among:

• Financial impact of the opportunity/risk; or

• Resource dependency (impact on access, price

and/or quality of resources); or

• Regulatory (regulatory constraints to business);

• Reputation (to what extent the reputation is

affected)

multiplied by the likelihood (on a scale of 1-5) of

the risk/opportunity occurring.

Financial materiality assessment is a maturing

area which is expected to see data collection and

risk and opportunity modelling on financial results

improve over time. In the process of scoring

financial materiality, best efforts have been made

in applying estimates and discretionary

assessments based on professional judgements

and proxies. Estimates will continue to be

calibrated going forward.

Impact Materiality

For impact materiality, scoring was done based

on severity and likelihood. The scoring is based on

severity of the actual/potential impact, defined as

the average score (scale 1-5) of:

• Scale (how grave or beneficial)

• Scope (how widespread, the extent, or number

of cases)

• Irremediable character for negative impacts

(could it be remediated)

multiplied by the likelihood of occurrence (on a

scale of 1-5) of the impact happening.

For the cases where an impact is already

happening, the likelihood was scored 5. In the

case of a potential negative human rights impact,

the severity of the impact takes precedence over

its likelihood. Accordingly, for both financial and

impact materiality, each IRO was assigned a total

score from 1 to 25.

Each IRO clearly states whether it relates to own

operations or to the value chain, and which time

horizon it refers to: short, medium or long-term.

When identifying relevant impact and

dependencies, an evaluation was done to

determine whether a dependency or impact would

also lead to a risk or opportunity.

The IROs for each Business Area were

consolidated by assessing and grouping IROs by

similarities, rewriting the relevant IROs to ensure

relevance for group, and rescaling the scoring to

reflect for the multiplied effect for the entire

group. The scoring was performed by a core DMA

team, using input from topical experts, and

insights from the key internal and external

stakeholders as acquired during the stakeholder

engagement exercise.

An extended DMA team at group undertook

workshops to validate the scoring assessment

and to discuss strategic and reporting

implications. Once the IROs score was defined,

the next step was to group the IROs per the ESRS

topics and sub-topics and propose threshold

values to determine which topics would be

considered material or not.

2025

Determine thresholds for the material

areas (step 4)

Setting a threshold for materiality involves

professional judgement including:

• Quantitative considerations (leveraging

thresholds identified in the ERM process),

• Qualitative considerations and company-

specific factors (strategic importance,

stakeholder expectations, regulatory impact,

Telenor’s specific context, industry-specific

considerations)

• Input from the key stakeholders

• Transparency (i.e. ensuring the assessment

process is well documented and accountable to

withstand auditor scrutiny and external

stakeholder review)

IROs that scored close to the threshold value were

evaluated whether they should be included or

excluded as material IROs. In these evaluations,

the basis for the original scoring was considered,

along with an evaluation of what the outcome

would be if the topic was included or excluded in

future reporting. IROs that were proposed

material were then grouped according to their

ESRS topic and sub-topic.

The methodology and process

The 2025 approach is based on the 2024 output

and methodology and was performed in three

steps:

• Bottom-up input collected from BAs, where

each BA provided updated insights based on

their operational context, reflecting any shifts in

materiality from 2024 for their IROs.

• Calibrating and consolidating BA results into the

group-wide DMA update. Individual and

collective workshops were undertaken with

topical experts at group level to discuss,

calibrate and quality assure selected scores,

formulations, descriptions and evidence base.

• Validation of IROs through a joint workshop with

topical experts including the risk and strategy

functions concluding the process.

Actions taken in 2025 to improve quality

While consistency requirements limit the scope of

methodology changes in 2025, the aim has been

to improve the quality:

• Improved formulations: All 2024 IROs were

reviewed to ensure sufficient precision with

regards to source, affected stakeholders and

potential consequences. Based on updated and

clarified instructions from EFRAG, some IROs

were merged due to a combination of similar

impacts, some were re-labelled from impacts

into mitigating actions, and other IROs were

deemed immaterial after rescoring or IROs

having materialised.

• Strengthened financial impact assessment: The

material risks and opportunities from 2024 were

reviewed aiming to strengthen the financial

rationale and documentation of the scoring. The

financial magnitude scale (1-5) was the same as

in 2024, but it was clarified what the scale

corresponded to in financial terms.

• Further integration with company strategy: In

2025, the DMA output was further embedded

into the company strategy processes at group

and BA level.

• Further integration with ERM: The ESRS

recommends that financial impact criteria are

aligned with the company’s ERM. Such

alignment was undertaken in 2024. For the 2025

assessment, the most recent risk assessments/

revisions were leveraged. Some of the DMA

findings also informed the ERM process.

• Input from the geopolitical task force: The

geopolitical situation in 2025 remained volatile

with consequences to Telenor's business. The

ESRS requires that a DMA is updated if major

changes in the business context occur, e.g.,

geopolitical shifts, new social conventions or

new scientific evidence. In addition to

methodological alignment, the DMA core team

drew upon the output from the ERM Geopolitical

Task Force when updating the IROs.

Consultation with stakeholders

As part of the 2024 DMA process, Telenor

engaged over 50 internal and external

stakeholders to analyse perspectives and

emerging expectations on key sustainability

topics and actual or potential IROs. Internal

stakeholders engaged included leaders and

employees across the organisation, experts,

members of Group Management (GM), members

of the Risk and Audit Committee (RAC), the Board,

as well as employee union representatives.

External stakeholders included customers,

investors (including the majority owner

represented by the Norwegian Ministry of Trade,

Industry & Fisheries), partners, suppliers, industry

groups, civil society organisations, thought

leaders, non-governmental organisations and

trade unions. The input from the stakeholder

interviews was used towards categorising and

creating a list of IROs.

The 2025 process built on the 2024 stakeholder

consultations and input from regular stakeholder

dialogues.

Current financial effects from risks and

opportunities

There are several risks and opportunities within

sustainability that may have a material impact on

the financial performance, financial position or

cash flows both short, medium and long term.

These include cyber attacks, loss of personal

data, loss of revenue from extreme weather

impacting the network, inability to attract and

retain employees, safety incidents for own

employees or in value chain and corruption and

human rights incidents.

In 2025, Telenor has not observed any issues that

have materially impacted the financial

performance, financial position or cash flows in

2025 nor are such issues expected the next

reporting year. Telenor's Enterprise Risk

Management (ERM) is described on page 33.

2025

Impact, risk and opportunity (IRO)

process for environment and

governance topics

Climate change (E1)

Telenor has evaluated climate-related scenarios

to assess impacts of climate change on

operations and business models. Telenor's scope

1 & 2 target is aligned with the Paris agreement

limiting global warming to 1.5^o. Telenor's scope 3

target is aligned with a well below 2^oC emission

path. See page 87 for more information about the

scenarios used. Telenor has for several years

monitored and reported greenhouse gas (GHG)

emissions. Already available data and assessment

of scenarios was the starting point in discussions

with stakeholders to determine the material

impacts, risks and opportunities in the double

materiality assessment (DMA) in 2024.

Climate-related physical and transition risks

Telenor has worked with climate risks - both

physical and transition risks - in a systematic

manner for years, and published its first TCFD

climate risk report in 2022. Telenor is using the

TCFD recommendations for guidance on how to

distinguish between physical and transition risk.

The scenario analysis and assessments from this

report, with internal management of climate risk

as part of the company's ERM, is the foundation

for how climate risk and opportunities were

assessed in the DMA. The scenarios and their

related risks and opportunities, including a high-

emission scenario are presented in E1, as well as

the Resilience Analysis.

Extreme weather events, such as the flooding in

Pakistan in 2022 and the extreme rain and wind in

the Nordics from "Extreme Weather Hans" in 2023

has increased Telenor's understanding of the

importance of more robust infrastructure. The

events has led to increased knowledge on the

impact of such events to Telenor. This was also

used as input in the identification of the risks and

opportunities related to climate change.

Biodiversity and ecosystems (E4)

Telenor operates a large number of

telecommunication towers and radio equipment

sites on rooftops. The towers are often placed in

rural and natural areas. Telenor started its

investigations to assess whether its footprint has

a material impact on biodiversity and ecosystems

in 2023.

The assessment was started by launching a pilot

in Finland. It was decided to scope out radio

equipment on rooftops, as these sites are already

converted from nature to human infrastructure.

The focus was put on land-based

telecommunication towers. These assessments

now also cover Norway, Sweden and Denmark.

This work has resulted in a list of Telenor sites

that will be prioritised in future work.

Resource use and circular economy (E5)

Telenor has screened its operations in order to

identify the positive and negative impacts

together with risks and opportunities within the

area of resource use and circular economy. The

screening primarily used a collaborative survey-

based approach across telecom operators in the

global GSMA and JAC communities to identify and

align on the most material impacts, risks and

opportunities in the telecom sector.

Business conduct (G1)

The process to identify material impacts, risks and

opportunities in relation to business conduct

matters was performed through the same

process as described above. It included general

steps such as mapping the value chain,

stakeholder involvement and identifying a broad

set of potential IROs, followed by a thorough

process of scoring to determine the final IROs

relevant for business conduct. Business conduct

is relevant across Telenor's operations, so all

activities and locations are in scope.

2025

Material impacts, risks and

opportunities (IROs)

Following the above phases and methodology, the

outcome was aggregated per ESRS topic. Like in

2024, the DMA for 2025 resulted in the following

seven material ESRS topics in addition to two

entity-specific topics:

Environmental ESRS'

• E1 Climate change

• E4 Biodiversity and ecosystems

• E5 Resource use and circular economy

Social ESRS'

• S1 Own workforce

• S2 Workers in the value chain

• S4 Consumers and end-users

• Digital skills (entity-specific)

Governance ESRS'

• G1 Business conduct

• Cyber security (entity-specific)

More details about each IRO are presented in the

relevant material topics sections.

Embedding the material topics in the strategy and

risk management processes, Telenor aims to

ensure that IROs are understood, measured,

prioritised and mitigated. The outcome of the

DMA is being used to inform target-setting and

identify concrete initiatives to be reviewed from a

risk mitigation as well as value creation

perspective, as part of the strategy process.

Changes in materiality compared to

previous reporting period

The year 2024 was the first reporting year where

Telenor's DMA was in compliance with ESRS and

CSRD. In 2025, the nine material topics from 2024

remain. However, the sub-topic of protection of

whistleblowers was deemed as non-material as

the positive impact within this sub-topic is

considered regular practice.

After having improved the formulations according

to the process described above, the number of

IROs was reduced from 41 in 2024 to 31 in 2025,

leaving 10 IROs to be considered non-material.

The IROs under S1 related to Training and skills

development (S1-13) and addressing health and

safety within working conditions for own

employees (S1-14) from 2024 have been

discontinued as most hazardous work is

outsourced. The risk and negative impact remain

under S2 – Workers in the value chain.

The other 2024 sub-topics remain material in

2025. The output of the DMA also includes a list of

IROs linked to the volatile geopolitical changes

with scoring below the threshold of materiality.

These IROs have been monitored.

Overview of ESRS disclosure

requirements

A list of ESRS disclosure requirements complied

with in preparing these sustainability statements,

following the DMA and conclusion on material

topics for Telenor to report on under ESRS can be

found in Appendix 1 on page 151.

2025

Environment

Telenor is committed to reducing greenhouse gas

emissions across the value chain, and to enable customers

to reduce their emissions through use of innovative

services and technologies. In 2025, an important milestone

was reached in having more than 66% of supplier spend

covered by science-based targets. The company's

science-based targets were revised and a new scope 3

absolute emission reduction target was introduced. On

nature, the impact assessment continued, and on

circularity inflows and outflows were assessed for the first

time.

2025

ESRS E1

Climate change

Climate change is one of

the most serious challenges facing

humanity and requires that every

company does its share. Telenor is

committed to reducing greenhouse gas

emissions (GHG) across the value chain

and to safeguarding infrastructure

against extreme weather. Telenor is also

an important part of the emergency

preparedness in the markets it serves,

requiring a robust infrastructure that can

sustain flooding, heat waves, storms and

other extreme weather.

How Telenor makes an impact

Climate change affects Telenor’s entire value

chain, from upstream suppliers to its own network

operations and downstream customer use. There

are both transition risks linked to emissions and

energy consumption and physical risks from

extreme weather.

There are negative impacts related to Telenor's

GHG emissions and energy consumption. At the

same time, Telenor has identified positive impact

in enabling customers to cut emissions through

digital services and influencing suppliers to

decarbonise.

In 2025, GHG emissions within scope 1 and 2

decreased by 32% compared to 2019 (from base-

year), whereas the emissions increased by 8%

from last year. The increase happened mainly due

to the purchased amounts of renewable energy,

by way of power purchase agreements and

energy attribute certificates, which was not

sufficient to achieve a reduction in emissions.

Telenor met its target for supplier adoption of

science‑based targets of 66%, reaching 67% in

2025. The company advanced climate adaptation

measures through strengthening the

infrastructure and networks to better withstand

severe weather.

Going forward, Telenor will focus on expanding

renewable electricity use, continuing supply‑chain

decarbonisation and enhancing resilience across

all parts of the value chain.

2025

Impacts, risk and opportunities (IROs)

Telenor has identified the following impacts, risks

and opportunities related to ESRS E1 Climate

change.


IRO		Relevance for Telenor	Value chain	Short, medium- or long term
	Climate change adaptation - extreme weather
-	Negative impact	There is potential negative impact on consumers and end users if extreme weather damage critical network infrastructure resulting in service disruption.	= ↓	S, M, L
-	Risk	There is a risk that extreme weather, both short-term and particularly long-term, causes more damage to network infrastructure than planned for, resulting in service disruption for customers and end-users, revenue loss, repair costs, regulatory constraints and negative reputation.	↑ =	S, M, L
	Climate change mitigation - GHG emissions
-	Negative impact	There is actual negative impact on climate through GHG (greenhouse gas) emissions in Telenor’s value chain related to extraction, production/manufacturing/transport of raw materials, equipment for Telenor’s activities, energy consumption and usage of products and services.	↑ = ↓	S, M, L
	Climate change mitigation - digital services
+	Positive impact	There is an actual positive impact to the environment and society that Telenor’s services and connectivity contributes to the green transition, in the form of smart digital services, especially within the Internet of Things domain.	= ↓	S, M, L
	Energy
-	Negative impact	There is actual negative impact on climate from increased energy consumption due to increased data traffic and insufficient access to renewable energy, especially in Asian markets.	↑ =	S, M, L

Climate change adaptation - extreme weather

Increased resilience to climate events, such as by

removing single points of failure, ensures that

Telenor's critical systems and infrastructure

remain reliable and robust. This minimises

downtime and strengthens the organisation's

ability to withstand and recover from natural

disasters and extreme weather conditions,

benefiting end-users, organisations and societies.

Increased frequency and severity of extreme

weather events may increase infrastructure

damage and disruption of services. There is a risk

that Telenor will incur higher costs related to

maintenance and installation of infrastructure in

the future.

Climate change mitigation - GHG emissions

Telenor has emissions of greenhouse gases (GHG)

that contribute to climate change both in the

value chain and own operations. The emissions in

the upstream value chain are related to extraction

and production/manufacturing/transportation of

raw materials, input factors and equipment for

Telenor's activities. The emissions in the

downstream value chain are related to usage of

Telenor's products and services and emissions

from Telenor's investments in two large operators

in Thailand and Malaysia. Emissions to own

operations relate to energy usage to run business

operations.

2025

Climate change mitigation - digital services

Telenor has a positive impact on climate change

mitigation by influencing business partners and

suppliers to reduce GHG emissions through

requirements and standards. Telenor also helps

reduce customers' and end-users' GHG emissions

by offering digital products and solutions that

enhance efficiency and reduce the need to travel

and meet physically.

Energy

Increased energy consumption and lack of

renewable energy may result in increased energy

costs. GHG emissions from the use of alternative

or back-up generation of electricity to maintain

facility and network operations also have a

negative impact on the climate due to GHG

emissions.

Impact on strategy and business model

As climate change is expected to accelerate over

several decades, Telenor will continue to adapt its

operations to mitigate both acute and chronic

climate-related physical risks. As 40% of the GHG

emissions come from category 1 purchased

goods and services and category 2 capital goods;

scope 3, focus has been on impacting suppliers

and business partners to reduce their emissions.

The setting of science-based targets is an

important criterion when selecting new vendors.

Measures to reduce own emissions (scope 1 and

2) will primarily mean phasing in high percentages

of renewable energy whilst limiting the growth in

energy consumption. Building more robust

infrastructure to withstand increased extreme

weather is also embedded in business decisions.

Telenor will continue to develop new offerings for

customers and the overall society as they become

even more digitalised and dependent on resilient

connectivity services.

Telenor's resilience assessment addresses how

the transition to a lower-carbon and resilient

economy will affect macroeconomic trends,

energy consumption and mix, and technology

deployment assumptions. Telenor updates its

climate risk assessment as part of the company's

Enterprise Risk Management. Climate risk

assessment has been informed by the TCFD

recommendations.

The climate risk assessment is viewed through

three separate time horizons: Short, medium and

long-term, with long-term meaning by 2050. The

time horizons are aligned with Telenor's science

based and net-zero climate targets. There are

several layers of uncertainty with regards to

climate risk assessment, including scientific

uncertainties and inherent uncertainties with

regard to scenario work. Telenor has ample

opportunities to adjust its actions and policies

with regard to both transition and physical climate

risk.

The scope of the resilience analysis has been all of

Telenor's operations including its upstream value

chain, and downstream use of services. The

resilience analysis was done on a short, medium

and long time horizon, with the long time horizon

stretching to 2050. The different climate

scenarios and insight from technical experts with

knowledge of the Telenor infrastructure were

used in order to determine the material impacts,

risks and opportunities.

The climate scenarios

The assessment of the resilience of the strategy

and business model follows three distinct climate

scenarios that will have different impacts on the

strategy and business model of Telenor.


Telenor Scenario	IPCC¹⁾6th Assessment Report	IPCC - Warming by 2100 (best estimate)- degrees Celsius
Strong Mitigation Scenario (SMS)	SSP1-2.6 "Low"	1.3-2.4 (1.8)
Delayed and Disorderly Scenario (DDS)	SSP2-4.5 "Intermediate"	2.1-3.5 (2.7)
Business as usual Scenario (BUS)	SSP3-7.0 "High"	2.6-4.6 (3.6 )

¹⁾ IPCC stands for Intergovernmental Panel on Climate

Change

Strong Mitigation Scenario (SMS)

In this scenario, the world is able to regulate GHG

emissions so that best estimate global warming

does not exceed 2 degrees and net-zero CO2

emissions are achieved in the second half of the

century. The mitigation pattern is roughly

equivalent to the “Low” SSP1-2.6 scenario from

IPCC’s 6th Assessment Report. The primary risk

to Telenor in this scenario is transitional and

comes from policy change, as goods and services,

including energy, become more expensive due to

increased pricing of greenhouse gas emissions.

Though Telenor as a telecommunications

company will not be directly affected by increased

pricing of GHG emissions, in this scenario,

increased pricing of GHG emissions would drive

additional inflation in cost of goods and services

purchased by Telenor.

Delayed and Disorderly Scenario (DDS)

The physical damage from climate change is more

severe in this scenario and the mitigation/

transition is disorderly, as the global community

adapts to a changing world. The emission profile

in this scenario is roughly equivalent to the

“Intermediate” SSP2-4.5 scenario from IPCC’s 6th

Assessment Report. The transition risks to

Telenor in this scenario are less severe than in

SMS. However, the physical

risks and adaptation impacts are more severe,

especially toward the end of the long-term

horizon.

Business as Usual Scenario (BUS)

In this scenario, global emissions of GHG continue

to rise approximately at current levels. The pace

and severity of global warming

increase significantly. In this scenario, there are

significantly less stringent policies put into effect

worldwide. The emission profile in this

scenario is roughly equivalent to the “High”

SSP3-7.0 scenario from IPCC’s 6th Assessment

Report. The primary risk to Telenor in this

scenario comes from accelerating severity of

acute and chronic physical risks of climate

change, as extreme weather, sea level rise and

temperature rise all have increasingly severe

effects in the long term.

2025

Specifically, in this scenario, Telenor will suffer

greater costs of maintenance, repairs, as well as

reduced revenues due to service disruptions.

However, in this scenario, these effects will

become more severe over time, due to delays in

effects from higher emissions.

Transition risks are more severe to Telenor in

SMS, whilst physical risks are more severe in BUS.

In DDS, transition risks become more severe in

the longer term whilst physical risks also become

more severe.

At time of writing, SMS is looking less likely to

materialise, due to geopolitical drivers. At the

same time, DDS and BUS are looking more likely,

due to the same drivers. As with all future looking

reflections, scenario work like this is connected to

significant uncertainty, and needs to be updated

annually.

Telenor is using TCFD methodology in its scenario

work. The emissions scenarios are sourced from

the Sixth Assessment Reports of IPCC, the

socioeconomic aspects are informed by IEA

scenarios. Risk types assessed include Policy and

legal risk, Technology risk, Market risk, Reputation

risk, Acute physical risk and Chronic physical risk.

All risk types were included in the assessment.

The risk assessment includes both upstream and

downstream elements, though in the assessment

the upstream elements are evaluated as more

material.

Climate transition plan

Telenor’s climate transition plan outlines the

principles and plans for reaching the company’s

climate targets, including both climate mitigation

and adaptation measures to address transition

and physical risks, as well as opportunities within

climate enablement. Climate risk is an integral

part of Telenor’s Enterprise Risk Management

(ERM) process and is therefore systematically

assessed and managed under oversight from the

Board and the Risk and Audit Committee.

Telenor's Climate transition plan is updated when

relevant and is approved by the Board of

Directors. The Climate transition plan is not fully

aligned with the disclosure requirements in ESRS.

Targets

Telenor's near-term climate targets have been

validated as science-based by the Science Based

Targets initiative (SBTi) and are as follows:

• Reduce scope 1 and 2 emissions by 69% within

2030, from a 2019 baseline. The target reduction

for the Nordics operations is 95% and 50%

reduction for the Asia operations.

• Reduce scope 3 emissions by 28% within 2030,

from a 2019 baseline.

The targets are revised, considering that Telenor

Pakistan is no longer in Telenor's portfolio as of 31

December 2025. The targets listed above are

without Telenor Pakistan. Telenor's old scope 3

engagement target (to get 66% of spend coming

from suppliers with science-based targets)

expired end of 2025.

Telenor's initial SBTi validated science-based

targets were set in 2021. Since then, the targets

have been adjusted several times, due to portfolio

changes, however, for consistency, the baseline

year has been kept at 2019. After Telenor's initial

target setting, CSRD and ESRS requirements

state that the baseline year cannot be earlier than

3 years before the new target period. This means

that Telenor's science-based targets are not fully

aligned with ESRS requirements.

Telenor has further set a net-zero target

according to the net-zero standard developed by

SBTi. Telenor’s targets of reducing emissions by

at least 90% across all scopes and to neutralise

any residual emissions by 2045 (2040 for Nordics),

with 2019 as base year, have been validated by

SBTi.

The scope 1 & 2 target is consistent with the

criteria to limit global temperature rise to 1.5°C.

The scope 3 target was set with a well-below 2°C

aligned trajectory.

Telenor's scope 1&2 target is a joint target for

both scope 1 and scope 2 and does not include a

specific share for each scope. The scope 1&2

target includes CO2 only, as emissions of other

greenhouse gases are negligible. Calculation of

progress on the target is done via the market-

based method.

For certain categories (e.g. category 1 and 2)

within scope 3, all greenhouse gases are included,

as suppliers to Telenor will calculate the CO2

equivalents of their GHG emissions. For other

categories (e.g. category 3), only CO2 is included in

scope. The framework for science-based targets

developed by SBTi is built on the GHG Protocol

and follows principles for GHG accounting found

in that standard.

The consistency of Telenor's science-based

targets with its GHG inventory boundaries is

ensured by Telenor following the guidelines and

regulations of SBTi. Telenor has no major

omissions in its GHG inventory, and thus the

baseline value is representative for the activities

in the company.

2025

Decarbonisation levers

1 Achieved emission reductions until 2025

Emission reductions to date have primarily come

from lowering scope 1 and scope 2 emissions

through sourcing renewable energy. Specifically,

this has been achieved by replacing diesel

generators with solar/battery systems, by way

of signing Power Purchase Agreements

(PPAs), and finally by purchasing Energy

Attribute Certificates (EACs).

Energy efficiency initiatives, such as applying AI

and machine learning in base stations, have

delivered additional savings. Progress on scope 3

has been supported by suppliers reducing their

own emissions.

2. Energy efficiency

Efficiency initiatives include deploying new

technologies such as AI and machine learning in

base stations to optimise energy use. 5G

technology is more energy efficient per unit of

data traffic compared to previous generation

In parallel, legacy infrastructure, including

Norway’s copper network,is being

decommissioned, avoiding CO₂ emissions.

3. Additional PPAs

Telenor has signed a PPA in Denmark, which is

now in operation. An additional PPA may be

signed for Telenor’s operations in Sweden, and

work is continuing to enable a PPA for

Grameenphone.

4. Supplier engagement

Telenor will continue to drive scope 3 reductions

by actively engaging and influencing suppliers to

reduce their emissions.

Expected growth from energy consumption

Energy consumption is expected to rise, due to

increased data traffic from Telenor's customers,

which is in turn increasing emissions

Reduction of scope 1 and 2 emissions

The overall target is to reduce own emissions

(scope 1 and 2) by 69% within 2030, from a 2019

baseline. Scope 1 and 2 emissions, without any

mitigation actions, are expected to increase by

400,000 metric tonnes due to traffic growth by

2030.

The scope 1 and 2 emissions in 2019 (baseline

year) came mainly from electricity (96%) of which

86% came from the use of grid electricity (99% in

Nordic, 80% in Asia). As a result, reaching the

scope 1 and 2 target is primarily about sourcing

renewable grid electricity through Power

Purchase Agreements (PPAs) and Energy

Attribute Certificates (EACs). In addition, energy

efficiency initiatives and switching from diesel to

solar will contribute to reductions of emissions .

Power Purchase Agreements (PPAs) and Energy

Attribute Certificates (EACs)

Telenor uses two mechanisms to source

renewable electricity from the grid: PPAs and

EACs. Telenor has a clear preference to reduce

emissions through the use of PPAs, as these can

be structured to support the construction of new

capacity for renewable energy generation, known

as additionality.

However, as long as PPAs are currently not

available in Bangladesh, and because they will not

cover the entire purchased electricity volume in

any market, Telenor is also utilising EACs, which

are documentation of quantity and origin of

electricity from renewable energy sources.

Examples of such certificates include Guarantees

of Origin (GOs) in Europe and International

Renewable Energy Certificates (I-RECs) in Asia.

2025

In Bangladesh, where corporate PPAs are not

available, Telenor is actively advocating to

promote access to such PPAs. Additional PPAs

are expected to cut emissions by 370,000 metric

tonnes.

Energy efficiency

Improvements in energy efficiency contribute to

an additional reduction of 100,000 metric tonnes.

Energy efficiency initiatives include deployment of

new technology such as AI and machine learning

in base stations, which can be used to optimise

the energy consumption. In terms of energy

consumption per data traffic, 5G is more energy

efficient than earlier technology. In parallel, legacy

infrastructure including the copper network in

Norway is being decommissioned, reducing the

emissions.

Actual emissions against target

The development of scope 1 and 2 emissions, as

illustrated in the graph below, shows that an

increase in energy consumption combined with a

lack of renewable energy options led to an

increase of emissions from 2024.

Reduction of scope 3 emissions

Telenor's scope 3 emissions primarily come from

two sources: the implicit emissions in its spend

with suppliers delivering goods and services to

Telenor's operations, and the emissions

originating from True Corporation in Thailand and

CelcomDigi in Malaysia.

In accordance with Telenor's previous scope 3

science-based target (the engagement target),

the company has been engaging with suppliers to

adopt science-based targets aligned with the

Paris Agreement.

Going forward, Telenor will expect suppliers to

achieve actual emission reductions. The strategy

includes influencing suppliers through

procurement processes, supplier engagements at

all management levels and advocacy through

industry organisations.

The long-term plan involves monitoring suppliers'

emission reductions from 2026-2030, and fully

integrating supply chain emissions into the net-

zero target beyond 2030. Telenor's scope 3

approach also includes the investments in

Thailand (True Corporation) and Malaysia

(CelcomDigi).

Progress in achieving scope 3 targets

Telenor has met its scope 3 engagement target in

2025, as can be seen in the chart below. The

target was set in 2021. For the new absolute

emission reduction scope 3 target, 2025

performance reflected a 2% reduction (excluding

Telenor Pakistan) relative to the base year. In 2024

it was a 9% reduction from base year. The primary

driver of the increase observed from 2024 to 2025

is changes in supplier emission factors (further

explained in the footnotes to the GHG emissions

inventory).

2025

GHG removals and GHG mitigation projects

financed through carbon credits

Neither carbon removals nor carbon credits are

currently being used by Telenor (apart from a

smaller volume of carbon offsets used locally in

business units), but as part of its net-zero target,

Telenor must neutralise any residual emissions by

way of permanent storage (by way of carbon

removals). Telenor is monitoring the development

of the market for carbon removals in order to be

able to source such credits when they become

necessary, as per the SBTi net-zero standard,

which is currently being reviewed.

Actions and resources required to implement

the transition plan

Renewable electricity commitments

Telenor has entered ten-year PPAs for the

operations in Norway, Finland and Denmark to

secure the delivery of renewable electricity. The

agreements are a financial commitment and

included in the financial plans towards 2030. See

note 4 in the financial statements for more

information about how PPAs are accounted for.

Infrastructure investments

Each year, Telenor invests fixed and mobile

infrastructure to maintain modern, future-proof

networks. By phasing out legacy and deploying

advanced technologies, Telenor is enabling

energy efficiency and enhance the resilience of

the infrastructure. The total network

capital expenditures in 2025 was NOK 6 billion.

Climate mitigation and adaptation measures

Included in its overall financial plans towards

2030, Telenor plans to invest around NOK 1.3

billion in specific climate mitigation and

adaptation activities over the period 2026-2030.

These investments focus on initiatives to reduce

scope 1 and 2 emissions and strengthen the ability

to manage and mitigate climate-related risks.

Investment directly related to climate change

adaptation focuses on enhancing network

resilience to withstand both acute and chronic

climate impacts with dual transmission as an

example.

The following table show the opex and capex

related to specific actions of climate change

mitigation and adaptation taken during 2025, as

well as the previous period. The amount of

financial resources mitigation opex relates to the

cost of purchasing Energy Attribute Certificates

(EACs) including the renewable electricity part of

the PPAs, and the decrease compared to 2024 is

driven by lower effectuated prices of the EACs.

The annual financial resources mitigation relates

to energy efficiency initiatives, and other

investments during the year that support climate

mitigation. The increase in 2025 compared to

2024 is driven by actions supporting climate

mitigation in Telenor Denmark, Grameenphone

and Telenor Pakistan. Annual financial resources

adaptation relates to specific investments that

contribute to make the networks withstand

extreme weather and chronic climate change and

the increase compared to 2024 driven by

initiatives like dual transmission and mast

strengthening in Norway, distributed energy

storage in Finland, as well as initiatives in both

Grameenphone and Telenor Pakistan.


Annual financial resources climate change mitigation and adaptation (NOK in millions)	2025	2024
Annual financial resources mitigation (Opex)	17	28
Annual financial resources mitigation (Capex)	139	23
Annual financial resources adaptation (Capex)	163	4

Policies

Telenor has a Sustainability Policy that sets out

requirements for all Telenor companies with the

aim to protect the environment and contribute

towards climate c hange mitigation and

adaptation. The policy covers amongst other

topics scope 1 and 2 emission reduction,

sustainable procurement and environmental

management systems. The policy addresses the

main climate related impacts, risks and

opportunities. Group Compliance, supported by

Group Sustainability, runs an annual procedure to

monitor policy compliance. Each Business Area

EVP is accountable for ensuring that policies are

implemented in the respective business areas.

Integration of sustainability-related

performance in incentive schemes

Telenor has an incentive that directly reflects the

company's annual progress towards its scope 3

science-based target. The incentive represents a

common bonus-linked KPI across executive

management both at the corporate centre and

the heads of all four of the company's business

areas. The Climate KPI represents 15% weight of

the short-term incentive (STI) Telenor Group

scorecard and measured performance. Refer to

page 62 for more information.

Targets

The targets within climate change have been

described in the transition plan section above.

These GHG emissions targets include near-term

science-b ased targets as well as a long-term (net-

zero) target validated by SBTi.

Actions

Actions during the year

Reduction of scope 1 and 2 GHG emissions

Telenor has in previous years signed power

purchase agreements (PPAs) for its operations in

the Nordics. Currently, three PPAs are in

operation. The first PPA is for a wind power plant

located in Sweden which is powering Telenor's

operations in Norway. The second PPA, sourced

from a solar plant in Denmark, has started to

deliver power to Telenor's operations in Denmark,

whilst a the third PPA, sourced from a wind power

plant in Finland, went operational in the first

quarter of 2025.

Scope 3 GHG emissions

On scope 3, the work continued to ensure that

Telenor's suppliers set science-based targets.

Telenor reached the old scope 3 engagement

target in 2025. Also, True Corporation had its

science-based targets validated by SBTi in 2024.

CelcomDigi sent its science-based targets to SBTi

for validation.

2025

In 2025, Telenor set a scope 3 absolute emission

reduction target to replace the engagement

target. To track the emission reductions of

suppliers in a much more granular way, a new

system for monitoring company-specific

emissions has been implemented.

Safeguarding network against climate risk

To reduce the risk of network outages due to

severe climate events, Telenor has continued to

adapt the network infrastructure. Examples

include elevating equipment in flood-prone areas,

increasing cooling capacity in areas prone to

extreme heat and reducing the vulnerability of

severed fibre connections by duplicating these

through so-called "dual homing". These are multi-

year efforts that systematically adapt Telenor's

networks to withstand physical climate risk

effects.

Planned future actions

Reduction of scope 1 and 2 GHG emissions

Work will continue to follow the climate transition

plan. Telenor will evaluate signing additional PPAs

to meet the need for renewable electricity in the

Nordics. In Asia, work will continue to find sources

of renewable electricity. In Bangladesh, the supply

of renewable electricity is low. Work has focused

on advocating for increased access to renewable

energy, preferably by way of PPAs, as well as

sourcing renewable energy through EACs.

Safeguarding network against climate risk

Telenor’s adaptation plan reflects two levels of

ambition. Firstly, to continue delivering services

with at least the same availability despite

increased climate risks. Secondly, to improve

network availability as businesses and society

digitalise and adopt more mission-critical

services, dependent on high availability of 5G

slices or IoT, meeting strict SLAs and regulations.

Adaptation efforts are underway, such as

strengthening towers to withstand strong winds,

raising tower foundations and installing

equipment in flood-prone areas. Additionally,

more sites are being equipped with backup

battery power or increased battery capacity and

are being supported with dual fibre or microwave

back haul connections.

Energy consumption and mix

Most of Telenor's energy consumption is related

to grid electricity. The residual emissions of the

grids are markedly different between the Nordic

and Asian markets. The grid electricity in the

Nordics is dominated by hydroelectric power and

other renewable energy sources.

The grid electricity in Asia is more mixed, with

coal, gas and oil accounting for a significant

proportion of grid mix. Both regions' energy mix

includes a small proportion of nuclear energy.

Other fossil-based energy sources mainly come

from diesel, used in generators in the Asian

market where connection to grid electricity is

either unavailable or of poor quality, leading to

frequent brownouts. A significant amount of

these generators, particularly in Pakistan, have

been replaced by off-grid solar and storage

technologies.

Telenor has no significant activities in high climate

impact sectors.

Lock-in carbon and fossil fuels

Telenor's business does not contribute to carbon

lock-in because it primarily relies on digital

infrastructure, which can be rapidly upgraded to

use renewable energy sources, unlike industries

dependent on long-lived, carbon-intensive assets.

Furthermore, no significant capex (capital

expenditure) is related to assets that use fossil

fuels.

As some of the consumed electricity in the

Nordics was not covered by Guarantees of Origin,

the residual electricity consumption will carry the

residual energy mix emission factor for that

country, which to some extent will include a

smaller portion of nuclear energy. The total

amount of consumed nuclear energy by this

mechanism is negligible.


Energy consumption from non-renewable sources	2025	2024
Total fossil energy consumption (MWh)	951,751	906,329
Share of fossil sources in total energy consumption (%)	44%	43%

Energy consumption from renewable sources	2025	2024
Fuel consumption from renewable sources, including biomass (also comprising industrial and municipal waste of biologic origin, biogas, renewable hydrogen, etc.) (MWh)	0	0
Consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources (MWh)	1,180,898	1,159,996
The consumption of self-generated non-fuel renewable energy (MWh)	33,159	27,408
Total renewable energy consumption (MWh)	1,214,057	1,187,404
Share of renewable sources in total energy consumption (%)	56%	57%
Total energy consumption (MWh)	2,165,808	2,093,733

2025

GHG emissions - scopes 1, 2 and 3



Gross scope 1 and scope 2 GHG emissions	Retrospective				Milestones and target years
	2019 (Base year)	2024	2025	%N/N-1	2025	2030	2045 (Net zero)	Annual % target/Base year (2030)	Annual % target/Base year (2045)
Scope 1 GHG emissions
Gross scope 1 GHG emissions (tCO2eq)	95,640	101,755	102,974	1%
Nordic region	2,095	592	798	35%
Asia region	93,545	101,163	102,176	1%

Scope 2 GHG emissions
Gross location-based scope 2 GHG emissions (tCO2eq)	337,294	471,457	465,672	(1)%
Nordic region	32,413	17,204	12,971	(25)%
Asia region	304,882	454,253	452,688	(0.3)%
Gross market-based scope 2 GHG emissions (tCO2 eq)	462,197	249,114	275,143	10%
Nordic region	143,803	17,699	3,089	(83)%
Asia region	318,394	231,414	272,040	18%

Scope 1 and scope 2 GHG Emissions
Gross market-based scope 1 & 2 GHG emissions (tCO2eq)	557,837	350,869	378,117	8%	(35)%
Nordic region	145,898	18,291	3,887	(79)%
Asia region	411,939	332,577	374,216	13%

Scope 1 and scope 2 GHG emissions from continuing operations (excluding Telenor Pakistan)
Gross market-based scope 1 & 2 GHG emissions (tCO2eq)	362,087	201,650	235,817	17%
Nordic region ¹⁾	145,898	18,291	3,887	(79)%		(95)%		(9)%	(4)%
Asia region	216,189	183,358	231,916	26%		(50)%		(5)%	(4)%
Gross market-based scope 1 & 2 GHG emissions (% reduction from base-year)		(44)%	(35)%	(21)%	(37)%	(69)%	>(90%)	(6)%	(4)%

¹⁾ Annual % target/Base year (2045) of (4)% in Nordic region refers to 2040 (not 2045), aligned with the Nordic target.

2025


Gross indirect (scope 3) GHG emissions categories
	Retrospective				Milestones and target years
	2019 (Base year)	2024	2025	%N/N-1	2025	2030	2045 (Net zero)	Annual % target/Base year (2030)	Annual % target/Base year (2045)

Significant scope 3 GHG emissions
1 Purchased goods and services	448,776	343,509	477,870	39%
2 Capital goods	134,615	157,380	106,842	(32)%
3 Fuel and energy-related activities (not included in scope 1 or scope 2)	109,432	75,263	80,164	7%
4 Upstream transportation and distribution	2,527	2,672	2,415	(10)%
5 Waste generated in operations	N/A	N/A	N/A	—%
6 Business travelling	4,198	4,476	6,218	39%
7 Employee commuting	18,728	15,360	13,443	(12)%
8 Upstream leased assets	957	2,644	4,479	69%
9 Downstream transportation	N/A	N/A	N/A	—%
10 Processing of sold products	N/A	N/A	N/A	—%
11 Use of sold products	44,716	16,920	12,828	(24)%
12 End-of-life treatment of sold products	4,594	4,205	4,129	(2)%
13 Downstream leased asset	N/A	N/A	N/A	—%
14 Franchises	N/A	N/A	N/A	—%
15 Investments	368,596	389,185	389,185	—%
Total gross indirect (scope 3) GHG emissions (tCO2 eq)	1,137,140	1,011,614	1,097,573	8%

Share of spend to suppliers with science-based targets	8%	63%	67%	6%	66%	N/A	N/A
Share of investees with science-based targets ¹⁾		50%	100%	100%	100%	100%	100%
Total gross indirect (scope 3) GHG emissions (tCO2 eq) from continuing operations (excluding Telenor Pakistan)
Total gross indirect (scope 3) GHG emissions (tCO2eq)	1,045,786	948,159	1,025,889	8%
Total gross indirect (scope 3) GHG emissions (% reduction from base year)		(9)%	(2)%	(80)%		(28)%	>(90%)	(3)%	(4)%

¹⁾ Share of investees with science-based targets at 100% in 2025, consisting of True Corporation (which has validated science-based targets) and CelcomDigi (which has submitted targets to SBTi for validation)

2025

The increase in reported emissions from Purchased goods and services, and Capital goods, from 2024 to

2025, is primarily driven by changes in the emission factors used to convert supplier spend data to

supplier emissions data. For the majority of suppliers, emissions factors stem from estimations of their

emissions based on revenue, not from emissions numbers reported by them. This makes their emission

factors swing with changes in revenue. For suppliers with a year-on-year emissions volatility > 20 %

(defined by Telenor's emissions factor supplier, S&P, as an outlier), the compound, absolute emissions

change (largely driven by revenue increases) was 53 %.

GHG intensity per revenue


GHG intensity per net revenue	2025	2024	%N / N-1
Total GHG emissions (location-based) per net revenue (tCO 2 eq/000'NOK)	0.020	0.020	3%
Total GHG emissions (market-based) per net revenue (tCO2 eq/000'NOK)	0.018	0.017	6%


Quantitative Reconciliation	2025	2024
Net revenue used to calculate GHG intensity	81,387	79,928
Net revenue (other)	0	0
Total net revenue (note 3 and note 12 in financial statements)	81,387	79,928


Quantitative Reconciliation	2025	2024
Total GHG emissions location-based (tCO2 eq)	1,666,219	1,584,826
Total GHG emissions market-based (tCO2eq)	1,475,690	1,362,483
Total GHG emissions (tCO2 eq)	1,475,690	1,362,483

GHG emissions by country¹⁾


	2025			2024
GHG emissions by country (tCO2 eq)	Scope 1	Scope 2	Scope 3	Scope 1	Scope 2	Scope 3
Norway	127	670	189,299	154	630	161,580
Sweden	470	753	135,402	26	1,366	85,923
Denmark	74	59	76,258	233	15,498	58,679
Finland	127	1,607	138,847	180	204	153,442
Bangladesh	11,917	219,856	95,939	13,715	169,570	96,807
Pakistan	90,259	52,083	72,307	87,448	61,771	64,613
Other	0	101	390,053	0	73	390,571
Telenor	102,974	275,143	1,097,573	101,755	249,114	1,011,614

GHG emission reduction instruments and biogenic emissions²⁾


GHG Emission reduction instruments	2025	2024
Biogenic emissions of CO2 from combustion or bio-degradation of biomass not included in scope 1 GHG emissions	N/A	N/A
Percentage of contractual instruments used for sale and purchase of energy bundled with attributes about energy generation in relation to Scope 2 GHG emissions	37%	24%
Percentage of contractual instruments used for sale and purchase of unbundled energy attribute claims in relation to scope 2 GHG emissions	63%	76%
Percentage of contractual instruments, scope 2 GHG emissions ³⁾	68%	70%

Footnotes

¹⁾ In the GHG emissions by country table, there may be several business units for each country. For scope 3

emissions, listed emissions are attributed to the business units in the country, the actual emissions may happen

elsewhere (e.g. for upstream value chain emissions from suppliers)

²⁾ Entries marked "N/A" relate to disclosure requirements where data is not available, either for direct entries or to

perform estimates.

³⁾ While the Group's total percentage of contractual instruments is 68%, this represents 98% in the Nordic region and

43% in the Asia region.

2025

Disclosure of types of contractual

instruments (scope 2 GHG emissions)

Telenor uses energy attribute certificates (EACs)

to make claims on the source of renewable

electricity consumed by its operations. EACs

provide information about the quantity and origin

of electricity from renewable energy sources.

Telenor uses Guarantees of Origin (GOs) in Europe

and International Renewable Energy Certificates

(I-RECs) in Asia.

Significant changes in reporting boundaries

There were no significant changes in reporting

boundaries in 2025. Telenor Pakistan exited

Telenor's portfolio December 31, 2025, but the

company's emissions are included in the

reporting.

REPORTING METHODOLOGIES

Telenor follows the GHG Protocol Corporate

Standard for calculating its greenhouse gas

emissions as well as energy consumption, with

distinct methods for scope 1 and scope 2

emissions. There are no major omissions in the

GHG inventory or energy consumption data.

Telenor calculates energy consumption for both

fuels and electricity usage. For fuels, the

companies report used fuel volumes (litres or

cubic metres) that are then translated to energy

(MWh) based on publicly available conversion

factors (UK GHG Conversion Factors for

Company Reporting). For electricity

consumption companies report consumptions

directly as MWh.

Scope 1 emissions

For scope 1, emissions are estimated based on

specific emission factors tied to the types of

fuels and propellants consumed across

Telenor's operations, primarily sourced from

the United Kingdom's Department for Energy

Security and Net Zero (formerly DEFRA).

Scope 2 emissions

For scope 2 emissions, Telenor uses both

location-based and market-based approaches.

Location-based emission factors are provided

by the International Energy Agency (IEA), while

market-based factors are available only in

Nordic regions, where they are supplied by the

Association of Issuing Bodies (AIB). This

structured approach ensures consistency and

accuracy in Telenor’s GHG reporting.

Scope 3 emissions

Scope 3 emissions are estimated based on

various methods (average, spend-based,

distance-based, fuel-based, primary data),

according to the GHG Protocol. Categories 1, 2

and 15 represent the highest emissions and are

therefore included in Telenor's public scope 3

target validated by SBTi. Various emission

factors are used for different scope 3

categories. For category 3, data from Statista is

used, for category 11, IEA emission factors are

used. Categories 5, 9,10, 13 and 14 are deemed

immaterial, and no data is being reported.

Scope 3 - category 1 (purchased goods and

services and 2 (capital goods)

Emissions in categories 1 and 2 for "purchased

capital goods and services" are calculated using

a spend-based method, based on supplier

spend and supplier revenue emission intensities

for scope 1, 2 and 3 upstream where this data is

available. Telenor is committed to continuously

improving data quality, and in 2025 this included

corrections and refinements to the spend data.

An EEIO (Environmentally Extended Input–

Output) model is used for the remaining spend.

This is achieved by multiplying spend within

each specific sectorial spend category by the

matching sector-specific emission intensity

factor in the EEIO model.

Telenor does not currently request or use

bilaterally provided primary data from

suppliers, such as LCA data for purchased

products. However, for its most strategic

suppliers, Telenor regularly follows up progress

in suppliers' emission reduction plans and

initiatives. This latter work will intensify as

Telenor continues to reduce its category 1&2

scope 3 emissions.

Scope 3 - category 6, 11 and 12

Primary data was used to calculate emissions

for scope 3; categories 6, 11 and 12,

representing 2.1% of total scope 3 emissions for

reporting year.

Scope 3 - category 5, 9, 10, 13 and 14

N/A is used for these categories because they

are not applicable to Telenor.

Scope 3 - category 15 (investments)

Category 15 emissions include the investees

scope 1 and 2 emissions as publicly reported by

CelcomDigi and True Corporation, but not their

scope 3 emissions. This is according to

Telenor's interpretation of GHG Scope 3

standard, and also due materiality concerns

related to incomplete scope 3 data from certain

investees.

The reason scope 3, category 15 emissions

(investments) are the same for 2025 and 2024,

is that the emissions are based on the annual

reports of CelcomDigi and True Corporation for

2024 (as the 2025 reports are not published at

the of data collection for this report).

2025

ESRS E4

Biodiversity and

ecosystems

The World Economic Forum listed

bio-diversity loss and ecosystem

collapse as the second highest long

term risk in their 2025 risk review.

Loss of habitat is a key driver of this

ongoing crisis. Even though each

base station has a low impact on

nature and ecosystems, Telenor's

around 55,000 base stations across

its markets make this a material area.

How Telenor makes an impact

Telenor’s value chain affects biodiversity mainly

through the land use associated with building,

operating and maintaining telecom towers and

related infrastructure, which can fragment

ecosystems and disrupt species.

Studies to date indicate negative impacts to

habitat disturbance and barrier effects from

tower lighting. The topic is still immature with

limited data availability.

In 2025, Telenor completed its first Nordic‑wide

GIS‑based biodiversity assessments to

understand which sites are located in or near

sensitive areas. The company also advanced

restoration of land through the ongoing shutdown

of the Norwegian copper network. Although

Telenor currently has no standalone biodiversity

policy or dedicated targets, it has begun

assessing the mitigation hierarchy as a framework

for future action.

Entering 2026, Telenor plans to expand

biodiversity assessments to deepen its

understanding of high‑impact sites, and identify

concrete mitigation measures to better integrate

biodiversity considerations across its operations.

This assessment will be for internal use, and the

focus will not be on external reporting.

2025

Impacts, risks and opportunities (IROs)

Telenor has identified the following impacts, risks

and opportunities related to ESRS E4 Biodiversity

and ecosystems.


IROs		Relevance for Telenor	Value chain	Short, medium or long term
	Biodiversity loss
-	Negative impact	There is actual negative impact on nature from Telenor's construction, operation, maintenance, and decommissioning of telecommunication towers, cables and related infrastructure, contributing to fragmentation and disruption of ecosystems, as well as increased possibility for biodiversity loss.	↑ =	S, M
	State of species
-	Negative impact	There is potential negative impact on species, such as birds, due to barrier effects of telecommunication towers with artificial lighting which disrupts their navigation and increases the risk of collision, resulting in the species avoiding these areas and altering their migration routes. Other species may also be negatively affected by network infrastructure, e.g., animals getting trapped in copper infrastructure.	↑ =	S, M

The IRO process

Telenor’s work on its impact on biodiversity and

ecosystems is still in an early stage. Data at this

point in time is therefore scarce, and this section

emphasises Telenor's first steps in this area, as

well as what the company plans to step up in the

future. For 2025, Telenor is making use of the

phase-in provisions in accordance with Appendix

C of ESRS 1 (ESRS 2 §17), as well as the "Quick fix"

adoption by EU in July 2025.

Investigations into Telenor's impact on

biodiversity and ecosystems started with its DMA.

No dependencies, physical or transition risks or

systemic risks were identified in the DMA. This

does not necessarily mean that there are no such

risks, opportunities or dependencies, but

primarily reflects that the topic is immature in

Telenor. Consultations with potentially affected

communities have not been conducted.

Biodiversity loss

Telenor builds, develops and maintains

telecommunication towers, entailing the use of

land. In addition to the towers, there is often

supportive infrastructure, such as access roads,

electricity supply and auxiliary buildings. This land

area footprint contributes to fragmentation and

disruption of ecosystems, as well as increased

risk for biodiversity loss.

State of species

Telecommunication towers can result in barrier

effects and disrupt the navigation of birds, as well

as leading to increased risk of collisions. A barrier

effect is caused by towers with artificial lighting,

causing species to avoid these areas and alter

their migration routes.

Assessing the effects of sites on biodiversity

and ecosystems in the Nordics

Telenor have launched assessments of the

footprint of its operations in the Nordics, by using

Geographic Information Systems (GIS). All Nordic

business units have been covered in this

assessment. A key purpose of the assessment is

to get an overview of the extent the company's

sites in its Nordic markets affect biodiversity and

ecosystems, as well as the reported number of

sites in or near biodiversity-sensitive areas. The

outcome of the assessment is found in the table

of sites in or near biodiversity-sensitive areas.

Telenor has more granular data, but due to the

number of sites, as well as national regulation

restricting Telenor to publicly disclose exact site

locations, further details haven been exempted

from external reporting.

Impact on strategy and business model

Telenor is still in an early phase of investigation of

the impact from its operations on biodiversity and

ecosystems. This assessment has not matured

into an investigation on whether, or in which way,

biodiversity and ecosystems have an impact on

Telenor's strategy and business model. The area

involves risk to Telenor, and is not expected to

affect strategy and business model in major ways.

2025

The limited resilience analysis that has been made

is focused on Telenor's own operations, and the

short to medium time frame. The current

assessment provides guidance on which sites

(sites located in key biodiversity areas or areas

with red-listed species) should be prioritised for

mitigative measures in order to reduce negative

impact. Further work with the area will determine

the details of said measures.

Policies

Telenor does not have a standalone policy on

biodiversity and ecosystems. These topics are

briefly covered in the Sustainability Policy.

Targets

Telenor does not have targets for biodiversity and

ecosystems.

Actions

Actions during the year

The focus in 2025 has been to continue the

business unit assessment of impacts from the

company's operations. Telenor has been assisted

by a third-party team of biologists from the

international consultancy AFRY on relevant

targets for the area.

Decommissioning

Telenor is continuously decommissioning

infrastructure that is no longer in use, thereby

reducing the footprint and restoring previously

occupied land area back to nature. One important

project that continued in 2025 was the shutdown

and removal of the copper fixed network in

Norway. The scope of this action is Telenor's own

operations, and the primary time horizon is short-

term.

Co-sharing of sites

Part of the purpose of establishing Telenor

Infrastructure as a separate business area in 2022

was to sell access to towers to corporate

customers, who then will not need to build their

own new site for that area. Increased co-sharing

can lead to substantial savings in terms of the

number of base stations needed, and is thus a

positive contributor to lower impact on

biodiversity and ecosystems. The scope of this

action is primarily Telenor's own operations, and

the primary time horizon is short-term.

Planned future actions

Telenor is assessing the mitigation hierarchy,

which is a framework for managing negative

impacts on nature and ecosystems, as a relevant

framework for mitigative action. Telenor is not

currently using biodiversity offsets and has not

incorporated local and indigenous knowledge and

nature-based solutions into actions related to

biodiversity and ecosystems. .

Impact metrics related to biodiversity

and ecosystems change

The table below shows the number of sites in or

near protected areas and use of land.


	Number of sites in or near biodiversity- sensitive areas	Area of sites in or near biodiversity- sensitive areas (thousand m²)¹
Norway	155	346
Sweden	158	353
Denmark	343	766
Finland	54	121
Total	710	1,586

REPORTING METHODOLOGY

The methodology of this assessment is to cross

reference GIS map layers with all base stations

in a country with map layers containing

information about red-listed species, key

biodiversity areas (KBAs), protected areas and

nature types.

Although map availability differ between the

countries where assessments are undertaken;

Finland, Sweden, Denmark and Norway, the

main methodology remains similar. The

assessments provide an overview of where the

most impactful sites are located.

There are significant uncertainties in this initial

study of Telenor's footprint. One source of

uncertainty is that the map data available from

the four Nordic countries differ (e.g. for Finland,

there is a single metric integrating a lot of

different biodiversity information, and in

Sweden, red-listed species was not included in

the map material used). Also, in most cases,

only sites in (and not near) biodiversity-sensitive

areas is included. A third source of uncertainty

is the significant under-reporting of red-listed

species in a country.

¹The area is calculated by multiplying the sites with a factor of 2,233 m² per site. This is the average footprint per site, including a buffer zone with a radius of 25 m, based on a third party expert assessment.

2025

100

ESRS E5

Resource use and

circular economy

The telecom industry uses a significant

amount of electronic and electrical

equipment. The world is facing global

challenges due to the extraction of finite

materials and the growing volume of

electronic and electrical waste.

Strengthening circular business models

and co-sharing of infrastructure is

essential to reduce environmental harm,

conserve scarce resources, and support

a more sustainable digital society.

How Telenor makes an impact

Telenor impacts circularity and the environment

through its resource use in the value chain. The

most important negative impact is caused by the

procurement of electronic and network

equipment, whose production involve extensive

resource extraction and mining. In addition, the

limited level of circularity in Telenor's operation

and significant volumes of electronic waste from

network equipment, servers, PCs and mobile

phones have a negative impact.

Key risks include future shortages of critical ICT

equipment due to scarcity of raw materials, which

could increase costs or threaten network

operation. Telenor works to improve device

take‑back schemes, enhancing reuse and

refurbishment, increasing recycling rates, and

reducing the number of new network sites

through infrastructure sharing.

In 2025, Telenor completed its first resource

inflow and outflow estimates for selected product

categories. The take-back rate for mobile devices

was 14%, compared to 13% in the previous year,

when the figure only included mobile phones. The

change in methodology is explained further

below.

Going forward, Telenor will focus on scaling

circularity initiatives, expanding material‑flow

assessments, evaluating how to reuse network

and consumer devices, and collaborating further

with industry partners to standardise circular

practices.

2025

101

Impacts, risks and opportunities (IROs)

Telenor has identified the following impacts, risks

and opportunities related to ESRS E5 Resource

use and circular economy.


IROs		Relevance for Telenor	Value chain	Short, medium or long term
	Resource inflows and use
-	Negative impact	There is actual negative impact on environment and nature due to the use of raw materials (e.g. cobalt, lithium, gold, copper, palladium) in production of equipment and products that Telenor purchase (e.g. smartphones and network equipment).	↑	M
-	Risk	There is risk of shortage of certain ICT (information and communication technology) products and network equipment critical to Telenor's operations due to finite and/ or scarce resources, potentially resulting in higher costs and/ or delays in delivery of supplier products.	↑ =	M, L
	Resource outflows related to products and services
-	Negative impact	There is actual negative impact to the environment and society that circular economy in Telenor business models is still early phase. By increasing the take back rate and lifetime of handsets, Telenor can contribute to increased resource efficiencies in society.	↓	S, M
	Waste
-	Negative impact	There is actual negative impact on the environment from high consumption of EEE (electric and electronic equipment) especially when not recycled or reused.	=↓	M

Resource inflows and use

Telenor sources high volumes of EEE necessary

for mobile communications services, both in the

form of mobile devices and the equipment used in

mobile networks. Some of the raw materials used

to produce equipment are increasingly scarce and

finite resources. To expand connectivity, Telenor

also sources the construction of mobile towers,

data centres and other types of buildings. Telenor

aims to reduce these volumes, the number of

towers required, and/or build infrastructure that

can be shared by multiple customers, decreasing

environmental impact.

Resource outflows for products and services

To mitigate the negative impact on the

environment from consumption of resources and

creation of EEE-waste, Telenor is working to

increase the take-back rate of sold mobile phones

and devices, to ensure that these are refurbished

and resold, or recycled if necessary. This reduces

the need for new materials and energy for

manufacturing new devices, as well as reduces e-

waste and keeps important rare minerals in the

cycle.

Waste

The growing demand on electronic products and

their short lifespans has resulted in e-waste

becoming a significant concern and risk for the

industry. E-waste is considered hazardous waste,

as it contains toxic materials or can produce toxic

chemicals when treated inappropriately. In the

Nordics, Telenor sells a large number of mobile

phones to customers. As these are a considerable

source of e-waste, Telenor specifically prioritises

phone reuse and recycling within its own Nordic

operations.

Telenor sells very few mobile phones in its

markets in Asia, hence this is only material for the

Nordic operations.

Maturity

Circular economy as a sustainability area is less

mature in terms of methodologies, metrics, tools

and standards than the climate area. There is

limited support for sectorial and cross-industry

methods, metrics and criteria for setting science-

based targets, as well as available consistent and

comparable upstream and downstream data from

suppliers.

Telenor therefore cooperates with other telecom

operators to align on priorities and targets in this

area to promote consistent approaches and

expectations to common suppliers, thereby

supporting a scaled approach.

Due to this non-mature status, formal screening

of upstream and downstream suppliers' circular

economy target setting and performance is not

yet implemented. Consultation with affected

communities currently relies predominantly on

survey results from customers. In 2024, GSMA

conducted a consumer survey on the reuse of

mobile phones, covering 10,000 customers across

26 countries.

Telenor expects that new regulations and

standards for circular practices and target setting

will evolve over the coming years and the

company will adopt these when available.

2025

102

Impact on strategy and business model

Telenor will continue to develop its commercial

offerings in the Nordics, aiming to reach targets

set for device circularity. Telenor addresses

circularity of devices primarily through take-back

programmes, re-use/refurbishment and recycling.

The company runs several programmes to

encourage take-back of unused or obsolete

electronic devices as well as utilisation of re-used

or refurbished devices. The company ensures

data-wiping, inspection, repair and guarantees of

refurbished devices.

Telenor practices active network sharing in its

mobile networks at large scale in three of its

operations in the Nordics. In addition, the

separate Nordic Towers business pursues higher

future tenancy rates that will further reduce the

need for construction of additional towers. The

mobile operations in Asia will, to varying degrees,

offer space in their own towers and rent space

from others to increase tenancy ratios. There are

opportunities to increase these practices further.

Policies

Telenor's publicly available Sustainability Policy

guides the handling of the four IROs. To mitigate

negative impact on nature due to raw material use

in the upstream value chain, it applies the

Mitigation Hierarchy, to avoidance and reduce

raw material consumption. It also states that use

of raw materials in inflows shall be minimised,

implicitly encouraging use of recycled materials in

purchased goods.

To address the risk of shortages of ICT products,

it focuses on increased resource efficiency, life

extension and supplier diversification. To alleviate

the limited circularity of Telenor's operations, the

main measure is to strengthen device return

programmes and incentivising reuse. It mitigates

the negative impact of high consumption of EEE,

through strict e-waste standards, and extending

product lifecycles via refurbishment and reuse.

The policy requires Telenor's companies to use

certified suppliers for downstream handling of e-

waste and to apply the EU waste hierarchy in the

Waste Framework Directive as a tool to increase

circularity.

The policy covers all controlled operations,

geographies and relevant stakeholder groups,

including upstream and downstream. However, it

does not detail specific activities, as the best

method of compliance can vary based on

country-specific laws and regulations and is

therefore the responsibility of each operation.

Monitoring and reporting is currently limited to

handling of e-waste. Reporting on handling of

total e-waste is performed annually, while take-

back rates are reported quarterly. As part of both

the quarterly and annual reporting, the

development compared to earlier periods is

monitored, analysed and followed up if exceptions

are identified.

The accountable policy owner is EVP People,

Sustainability and External Relations.

Mitigation Hierarchy

¹) Outflows: Goods and materials that leave Telenor, such as sold products and waste

Targets

Telenor joined a sectorial initiative in GSMA

(Global System for Mobile Communications

Association) in 2023 that focuses on boosting

circularity for mobile devices. Telenor has ratified

the following voluntary outflow¹⁾ targets for

Telenor's Nordic mobile operations (see GSMA's

Mobile Net Zero 2024 report ):

• By 2030, the number of used mobile devices

collected through operator take-back

schemes should amount to 30% of the

number of new mobile devices distributed

directly to customers. The purpose of this

target is to prolong the active lifetime for a

higher number of mobile phones by

increasing the share of reused phones in the

market. The main assumption is that a higher

take-back rate for operators will help reduce

the number of still usable but unused phones

in peoples' homes.

• By 2030, no used mobile devices collected

through the operator should be landfilled.

This is a target that affects a subset of the

total e-waste that is quantified as landfilled in

this report.

These targets reflect the stated policy priority to

reduce e-waste reduction and handle e-waste

properly. The progress toward the targets is

reported annually per Nordic company. The

targets were agreed following a strategic analysis

across GSMA members that identified mobile

phones as the most urgent area to address within

resource use. The outcome was published in the

Strategy Paper for Circular Economy: Mobile

devices.

2025

103

The targets reflect EU recommendations

2023/2585 on improving the rate of return of used

mobile phones, tablets and laptops. They also

reflect the ambition to prolong the lifetime of

phones in the EU's agreement on revising EU rules

to make sustainable products the norm, and

thereby minimise virgin raw materials used in the

supply chain. The targets will increasingly

influence selection criteria in Telenor's sourcing

processes.

Telenor has measured the take-back rate since

2020. In 2025, the take-back rate at Nordic level

was 14%, a 1 percentage point increase from

2024, when the figure only included mobile

phones but still below the 18% target for the year.

The upward trend is largely driven by the new

"Splitt" program, which enables customers to

trade in their old mobile phones, as well as our

own marketplace for refurbished devices and

stand-alone trade-in options. The take-back rate

varied between 2% and 26% across the four

markets in the Nordics, with three markets

surpassing 14%. The 2030 target is still expected

to be within reach, but will be challenging to meet.

The second target of no landfill of collected

devices was not reached in 2025. Telenor will

continue its effort to improve data quality and

work with its partners to address this.

Actions

Actions during the year

Telenor prioritises participation in joint industry

initiatives, in GSMA and JAC (Joint Alliance for

Corporate Social Responsibility), to increase the

reuse of mobile phones and network equipment.

Both initiatives have annual action plans.

Activities with the highest impact across

participating members are pursued. Planned

activities are then funded, staffed and organised

accordingly. In general, GSMA activities primarily

address early analysis phases and operational

topics relevant for members, while JAC activities

focus on the execution phase, particularly in

upstream and downstream supply chains.

Cooperation in this area is the key to reaching the

required scale to create necessary to compete

with linear consumption models.

To be able to analyse and identify mitigation

measures for the three negative impacts in the

resource field going forward, Telenor in 2025

conducted a first estimate of a share of the

inflows and outflows from the company. The

results of this estimate is presented in the

following pages.

Planned future actions

Circularity of handsets and other devices

Telenor will work to increase the share of reused

phones in the sales mix to mitigate the negative

impact of raw material extraction and high

consumption of EEE. Telenor will participate in

several sector-specific collaboration projects with

other mobile telecom companies on circularity,

where the objective is to scale and standardise

practices to establish circular business models

within the industry.

Waste

All Telenor companies are mandated

to implement sustainable waste management

processes. All e-waste is to be reused or recycled

according to internationally recognised standards

and regulations. To ensure continuous

improvements of local performance, an

environmental management review shall be

conducted at least once a year. Telenor

companies are recommended to certify their

environmental management system according to

ISO 14001.

To avoid e-waste ending up in landfill, Telenor

ensures the proper disposal and recycling of EEE

materials at the end-of-life stage. Certified

suppliers of e-waste services, or those following

international standards for e-waste, are

prioritised.

Resource inflow

Telenor's resource inflows is mainly in EEE

products such as phones, home devices, as well

as network, IT and power/energy equipment.

Resource inflow was deemed material in the

double materiality assessment. For 2025, Telenor

has estimated the inflow of materials to a limited

scope, of three key elements of

telecommunications. Two are assets Telenor

procures to operate a telecom network; network

towers and 5G radios mounted on them. One is a

product for resale to customers to enable them to

use Telenor's network; mobile phones.

The resource scope is to cover material

resources. For towers, the main impact comes

from large amounts of steel, the production of

which includes large scale mining and a global

refining chain. For 5G radios, the scope of

resources is set to a selection of resources that

are key to 5G equipment and that have a

significant negative environmental impact in their

extraction/production process . For mobile

phones, the resources in scope were decided on

because the extraction of these metals is

especially degrading, both to local nature and to

climate.

This is the first stepping stone in an immature

area. To estimate resource inflows, Telenor must

be able to credibly quantify the inflow of products,

as well as retrieve credible sources for data on the

material contents in these products. In 2025,

Telenor has been able to do so for these three

inflows. In the future, Telenor intends to expand

the scope to cover more inflow types. This year's

first estimate covers only a share of the resources

flowing in to Telenor. Telenor expects that better

external data on material contents will become

available, improving the estimates.

This year, the geographical scope is limited to the

Nordics, because of more limited data availability

in Asia, where Telenor holds a minority share in

several countries. In the future, Telenor intends to

expand the scope to cover Asia.

Share of recycled content in phones

For 2025, Telenor has estimated the share of

recycled content in mobile phones. These

estimates are based on data covering about 10%

of the phones sold in Norway in 2025. The

recycled content in the population is estimated to

23.5%, with an average weight of recycled

content per mobile phone of 46.4 g and a total

weight of recycled content in all phones in the

population of 5.8 tonnes.

As phone sales is not part of the Asia business

models, this the estimate is geographically limited

to the Nordics. In the future, better external data

on material contents and recycled content in

products will become available, improving this

estimate.

2025

104

Inflow of resources


Inflow type	Content	Total material inflow (kg)
Inflow type	Content	2025
Towers	Steel	1,589,738
5G radios	Aluminium	651,826
	Barium	6
	Copper	342,209
	Gallium	2,249
	Germanium	2,347
	Gold	24
	Yttrium	1
Mobile phones	Cobalt	17,212
	Copper	17,212
	Gold	34
	Neodymium	344
	Palladium	5
	Silver	172
Total	Steel	1,589,738
	Aluminium	651,826
	Barium	6
	Copper	359,421
	Gallium	2,249
	Germanium	2,347
	Gold	58
	Yttrium	1
	Cobalt	17,212
	Neodymium	344
	Palladium	5
	Silver	172

Resource outflows

Telenor's resource outflows is mainly in EEE

products such as phones, home devices, as well

as network, IT and power/energy equipment. For

2025, Telenor reports on one metric: The take-

back rate of mobile devices.

Outflow of resources

Telenor recognises the resources that go into

mobile phones, as estimated under Resource

inflow, also to be relevant for Resource outflows.

As Telenor sell to client the phones purchased

from producers, it is assumed that inflows equals

outflows. As such, the inflows estimate also

covers outflows.

Take-back rate of mobile devices

The table below shows the take-back rate of

mobile devices, as share of mobile devices sold.


Returned mobile devices	2025	2024
Take-back rate mobile devices	14%	13%

Waste

In the Nordic region, the reported generated e-

waste is dominated by small consumer

electronics (mobile phones, home broadband

equipment and TV devices), network and IT

equipment. This e-waste includes over 50

different materials, including rare metals, plastics,

ceramics and silicon (source: GSMA). In Asia,

battery backup is commonly used, particularly in

Telenor Pakistan, due to electricity outages and

grid-reliability challenges. The limited lifespan of

these batteries is a significant contributor to the

reported e-waste.

A residual volume of e-waste is classified as

"non-recycled". This represents EEE that has been

collected to storage during 2025, but not yet

tested or evaluated to determine whether it can

be refurbished and reused, or whether it must be

recycled. The final reuse or recycling volume for

this residual volume will be included in the 2026

numbers.

Hazardous waste

Hazardous waste and how it has been handled is

shown in the tables below. The only hazardous

waste material to Telenor is e-waste. Telenor

currently does not distinguish between hazardous

and non-hazardous e-waste and considers all e-

waste as hazardous.

From 2024 to 2025, recycled e-waste in Telenor

Pakistan doubled, representing half of Telenor's

total reported e-waste. This increase was driven

by a battery-swap project that began in 2024, with

most of the activity taking place this year. In

contrast, e-waste volumes declined in the other

business units.

E-waste volumes are closely linked to equipment

replacement cycles, one-off projects, and

investments profiles including the durability of the

products involved.


Hazardous e-waste (in tonnes)	2025	2024
Total e-waste	4,016	4,409
Hazardous e-waste directed from disposal	3,988	4,391
Reused e-waste	141	223
Recycled e-waste	3,847	4,168
Hazardous e-waste directed to disposal	28	18
Incineration	0	0
Landfill	28	0
Other disposal operations	0	18
Percentage of non- recycled e-waste	0.70%	0.41%


Radioactive and other hazardous waste (in kg)	2025	2024
Radioactive waste	0	0
Other hazardous waste	0	0

E-waste

The most material waste stream for Telenor is e-

waste from end-of-life EEE across all operating

companies. Telenor does not report on other

types of waste, such as municipal waste, as this

has not yet been deemed material. Telenor will

work further on this topic and re-evaluate its

materiality within the resource outflows area.

Landfilled e-waste

28 tonnes of e-waste was landfilled in 2025. In line

with policy, all e-waste shall be handled separately

2025

105

from municipal waste and be handled for

recycling/recovery in line with laws and

regulations in each market by approved suppliers

of recycling services. Telenor relies on suppliers

to follow laws and regulations and to adhere to

contractual commitments for e-waste handling.

Radioactive waste

Telenor does not have radioactive waste from

direct operations. The telecom sector does not

use equipment or assets that contain radioactive

sources.

Durability of end-user products

There are two types of physical products that

Telenor has in its Nordic markets: mobile phones

and consumer home devices (routers, modems,

TV set-top boxes). For own-branded home

devices, Telenor or its outsourcing partners

collect, refurbish and repair and repackage such

devices before redistributing them to new

customers, providing the devices are not

outdated.

Telenor does not brand, produce or define

specifications for mobile phones that it purchases

to offer in the market, and Telenor is a minor

buyer of these on the global scene. Therefore,

durability, repairability and share of recyclable

content in mobile phones and their packaging is in

practice outside of Telenor's control and

influence.

Some mobile phone producers disclose data

about durability (such as upgrade ability), repair

options and use of recycled materials publicly, but

the majority currently do not. Telenor does not yet

systematically collect, monitor or make

purchasing decisions based on such upstream

information.

Traditionally, mobile phones were exchanged

approximately every other year in mature markets

like the Nordics, but this has increased in the last

years to about every third year. This development

is expected to continue, helped by new

regulations that set expectations for repairability

and more years of software and security updates.

The growing market for used mobile phones also

demonstrates that their active lifetime is

increasing.

There are currently no global standards for

repairability for EEE in general or end-user

equipment in particular. There have been limited

attempts to establish voluntary eco-design rating

systems, like the Eco Rating system for mobile

phones, however this has gained limited coverage

and adoption.

The recent and upcoming regulations in EU for

charger standardisation, repairability and years of

software and security upgrades are expected to

have a much more material impact on prolonged

lifetime, initially for end-user devices and later for

EEE equipment in general.

The lifetime of network and IT equipment used in

the B2B (business-to-business) market varies, but

as a rule of thumb IT servers and PCs have an

expected production lifetime in Telenor of +/- five

years. The majority of network equipment can be

expected to have an average active lifetime of +/-

10 years.

2025

106

REPORTING METHODOLOGIES

Take-back rate

The take-back rate of mobile devices is defined

as the number of used mobile devices collected

through operator take-back schemes, divided

by the number of new mobile devices

distributed to customers. For this year, the

take-back rate covers the Nordics. In 2025, the

industry association GSMA expanded its'

definition of take-back rate from "phones" to

include "devices", such as smart watches or

mobile routers with SIM support- Telenor

updated its' definition correspondingly.

Landfilled e-waste

The total reported e-waste includes all EEE that

is collected for potential disposal. This shall

either be reused or recycled. If any such e-

waste is not documented as recycled or reused,

it is reported as landfilled.

Circularity targets

The metrics used for Telenor's public targets

for circularity of mobile phones are sector-

specific definitions and have been jointly

developed with GSMA.

Metrics that measure reuse and recycling of

mobile phones and home broadband/TV

devices are calculated based on the number of

devices, not by the usual method of absolute

weight in tonnes.

Metrics for the total volume of e-waste for all

EEE are reported in tonnes.

Recycling data

Telenor collects data annually from all

operations about weight of all generated e-

waste and the share that is reused, recycled or

landfilled.

In addition, the operations in the Nordics that

distribute (rent/sell) phones, or home devices to

customers report more granular data about the

number of devices distributed, collected,

reused, recycled or landfilled. These granular

data are used to report against the take-back

rate target for mobile phones.

All other available data about durability

(designed lifetime), repairability, use of recycled

materials in inflow products and goods, as well

as their packaging, depend on this data being

made public by the respective upstream

suppliers of the purchased products.

Telenor currently does not collect data

necessary to report on the share of recyclable

materials in purchased products or in their

packaging.

Inflows

Material inflow per type (towers, 5G radios and

mobile phones) is estimated by multiplying the

number of units added the reporting year with

an estimate of the amount (weight) of materials

in a representative unit. While the estimate is

fairly complete for towers and mobile phones,

for 5G radios it covers a limited share of the

total for 2025.

The estimate of the amount of materials in a

representative unit is based on supplier data,

LCAs, industry reports, academic papers and

other sources. However, few suppliers publish

such data and there is a limited number of

relevant sources, constituting an uncertainty in

the estimation. For 2025, only open sources

have been considered.

Telenor uses the quantity of mobile phones sold

(the reporting year) as the quantification of the

inflow of mobile phones, assuming that the

inflow equals the outflow of mobile phones

(over time).

Share of recycled content in phones

The share of recycled content in phones is

estimated as a weighted average of the share

of recycled content in the nine phone models

that Telenor sold the most of in Norway in 2025,

weighted by sales volumes. For models for

which there is no information on the share of

recycled content, we assume the share is zero.

2025

107

EU taxonomy

for sustainable activities

The EU taxonomy regulation is a key

element of the European Green Deal. The

taxonomy is a classification system that

provides specific criteria for economic

activities to be defined as sustainable,

with the aim to direct investments

towards sustainable activities and

projects.

Economic activities are eligible when they fall

within the scope of the activities defined in the EU

Taxonomy, and aligned (sustainable) if it both

makes a substantial contribution to at least one of

the environmental objectives and meets all the

specific technical screening criteria, including the

'Do No Significant Harm' (DNSH) requirements.

For the telecom industry, the vast majority of

telecom activities, including mobile and fixed

networks, are currently not included in the

taxonomy. Telenor provide telecommunication

services and the sector classification is NACE

K61.1.

In accordance with the simplified delegated

regulation as amended in July 2025, Telenor has

applied the materiality thresholds for the 2025

reporting.

For 2025 the turnover considered non-material

amounted to NOK 1,776 million out of NOK 81,387

million or 2%. For 2025 the capex considered non-

material amounted to NOK 986 million out of NOK

17,024 million or 6%, and the opex considered

non-material amounted to NOK 193 million out of

NOK 5,345 million or 4%.

In the 2024 reporting Telenor reported four

activities as eligible to support the climate change

mitigation objective and two activities as eligible

within the circular economy. The turnover of

eligible activities was in total 2%, the eligible

capex was 5% and opex 2% in 2024.

The activities considered eligible for climate

change mitigation and circular economy were the

following:

• Data processing, hosting and related activities

(CCM 8.1 and NACE K63.10)

• Data-driven solutions for GHG emissions

reductions (CCM 8.2 and NACE K61.10,

K62.10/20/90 or K63.10)

• Installation, maintenance, and repair of

renewable energy technologies (CCM 7.6 as part

of construction and real estate activities which

could be associated with several NACE codes)

• Acquisition and ownership of buildings (CCM 7.7

and NACE M68 related to real estate activities)

• Sale of second-hand goods (CE 5.4 and NACE

G47 related to resale of used goods)

• Product-as-a-service and other circular use-

and result-oriented service models (CE 5.5 and

NACE G47 or O77 related to sale of retails goods

and rental and leasing activities)

Most of these activities relates to other sectors

than the telecommunication sector, but these

activities have been the basis of the assessment

of the non-material share for 2025.

Data processing, hosting and related

activities

Telenor has several data centres. However, these

are related to IT and network infrastructure.

Included in the non-material assessment the

investments in data centres has been considered,

as well as the revenues, capex and opex for the AI

Factory.

Data-driven solutions for GHG emissions

reductions

Telenor provides solutions that may enable

customers to reduce their emissions, and the

following products have been included in the

assessment of this activity: Internet of Things (IoT)

solutions for the automotive segment, utilities,

smart cities (e.g. optimisation of energy

consumption in buildings), solutions for remote

meetings as well as the company BLDNG.ai in

Telenor Amp.

Installation, maintenance, and repair of

renewable energy technologies

This activity covers installation, maintenance and

repair of renewable energy technologies. This has

previously mainly been related to invests in solar

sites in the mobile network to reduce the use of

diesel generators, replacement of equipment or

installation of solar panels on buildings.

Acquisition and ownership of buildings

This activity covers buying of real estate and

exercising the ownership of that real estate, and

corresponds to additions of buildings to property,

plant and equipment.

Sale of second-hand goods

This activity relates to sale of second-hand goods

that have been used for their intended purpose by

a customer. For Telenor this activity relates to the

sale of used mobile phones in the Nordics.

Product-as-a-service and other circular use

and result-oriented service models

Telenor has product-as-a-service model mainly

for different types of customer premise

equipment (CPE) such as routers, TV-boxes and

mobile phones.

Minimum safeguards

The assessment of minimum safeguards has been

done at group level covering human rights, anti-

corruption, taxation and fair competition. Telenor

follows and complies with the OECD guidelines for

multi-national enterprises. These topics are

covered in the Code of Conduct and Group

Governing Documents, as well as being integrated

in Telenor’s enterprise risk management

process.

Human rights

Telenor’s ambitions and requirements with

regards to human rights are embedded in the

company’s Code of Conduct, Supplier Conduct

Principles and Human Rights policy, which are

based on the following international instruments:

2025

108

the Universal Declaration of Human Rights (UDHR),

the International Covenant on Civil and Political

Rights (ICCPR), the International Covenant on

Economic, Social and Cultural Rights (ICESCR) and

the ILO Declaration on Fundamental Principles and

Rights at Work.

Telenor’s governance principles ensure that all

operating entities are committed to respecting

human rights in accordance with the UN Guiding

Principles on Business and Human Rights, the

OECD Guidelines for Multinational Enterprises, UN

Global Compact and the Global Network Initiative

(GNI) Principles on freedom of expression and

privacy. This includes assigning designated

resources to ensure regular human rights due

diligence across the organisation to identify and

address negative potential and actual human

rights impacts, as well as meaningful engagement

with stakeholders. These processes align with the

Norwegian Transparency Act requirements and

are reported upon accordingly.

Anti-corruption

Telenor is committed to conducting business

activities in a transparent manner, maintaining the

highest ethical standards, and complying with

applicable anti-corruption laws and

regulations. Telenor’s commitment and zero

tolerance for corruption is clearly stated in

Telenor’s Code of Conduct, which is the

foundation of the company’s corporate culture

and sets out high standards of integrity on how

Telenor does business.

The Code of Conduct and the Anti-Corruption

Policy prohibit corrupt conduct in all Telenor’s

business operations. The company actively

manages corruption risks through the Anti-

Corruption Compliance Programme, which

includes implementation of the internal controls

across the organisation to prevent, detect and

mitigate any improper conduct.

Taxation

Telenor maintains a responsible tax policy and

practices in line with legislation in every

jurisdiction of operation. Telenor follows the

terms of applicable double taxation treaties,

relevant OECD guidelines in dealing with transfer

pricing and establishing taxable presence. The

company endorses transparency and fairness

across the global tax system, exchange of

financial information and concerted action to

fight base erosion and profit shifting.

Fair competition

Adequate safeguards are in place to ensure that

Telenor is committed to competing fairly and to

complying with applicable competition laws and

regulations through Group governing documents,

including the Code of Conduct and Group

Competition Compliance Policy. This policy

ensures implementation of a risk-based

competition compliance programme, adhering to

relevant international standards to prevent,

detect and remedy improper conduct, including

but not limited to risk assessment,

communication and training, monitoring, incident

management and reporting. In addition, legal

experts are involved to advise on risk in day-to-

day operations.

The mandatory reporting table is found on page

157.


REPORTING METHODOLOGY The definitions of operational expenditure (opex) and capital expenditure (capex) according to the taxonomy regulation differ from the definition of opex and capex used in Telenor Group’s financial reporting. The relevant amount of revenues, capex and opex, is only allocated to one economic activity. The reporting boundaries correspond to the financial consolidated entities, including the discontinued operations. Turnover For Telenor, the turnover reported as part of the taxonomy corresponds to the total revenues reported as part of the consolidated financial statements and specified in note 3 Revenues NOK 76,548 million in addition to the external revenue of the discontinued operations of NOK 4,839 million as part of note 12. Of the total revenues reported as part of note 3, NOK 75,158 million are revenues from contract with customers (IFRS 15), and NOK 1,390 million are operating lease revenues (IFRS 16). For the specific activities, only external revenue is reported.

Capex (capital expenditures)

The capex to be reported as part of the

taxonomy is additions to property, plant and

equipment NOK 8,038 million (note 17 Property,

plant and equipment), intangible assets NOK

2,878 million, intangible assets internally

developed NOK 75 million ( note 15 Intangible

assets) and right-of-use assets NOK 4,760

million (note 16 Right-of-use assets) during the

financial year before depreciations,

amortisation and impairments, but excluding

fair value changes.

The total capex used as denominator in the KPI

calculations also includes additions to tangible

and intangible assets resulting from business

combinations.The intangible assets additions

are specified in note 15 Intangible assets. In

addition to the additions from the continued

operations NOK 1,273 million is included in the

capex denominator from discontinued

operations.

Opex (operating expenses)

The opex to be reported as part of the

taxonomy is non-capitalised costs that relate to

research and development, building renovation

measures, short-term lease, maintenance and

repair, and any other direct expenditures

related to the day-to-day servicing of the

assets. Related to day-to-day servicing, energy

cost is not included, but only cost related to the

maintenance of servicing. For Telenor the

following costs are included in the denominator

for the calculation of the taxonomy opex:

research and development NOK 197 million,

short-term leases NOK 69 million and operation

and maintenance cost NOK 4,612 million from

the continuing operations, in addition to in total

NOK 467 million from the discontinued

operations.

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Social

Telenor is a people company. Human rights, including

equal opportunity, diversity, inclusion, health, safety and

well-being, privacy and freedom of expression, are

imperative for how we engage with our employees, those

who work for or on behalf of Telenor, our customers, end

users and the societies we serve. Telenor has a long

history of engaging with our stakeholders. We are

committed to driving digital inclusion as a means to enable

people to thrive in an increasingly digital world.

2025

110

ESRS S1

Own workforce

Telenor is a people‑centric company

with more than 10,000 employees

across Nordics and Asia. Our

workforce is our most critical asset,

and their development, well‑being,

competence, and engagement

directly underpins our ability to deliver

secure, reliable connectivity and

execute on Telenor’s long‑term

strategy. A safe, fair, inclusive and

future‑fit workplace is therefore

central to how we create value.

How Telenor makes an impact

The skills, well‑being and engagement of our

employees directly affect the company’s ability to

deliver resilient connectivity and execute its

strategy.

The main impacts relate to working conditions,

equal opportunities and treatment, and the

positive effects of family‑related leave policies,

especially in Asian markets. Key risks include

potential gender pay gaps, challenges in

attracting and retaining critical talent, and

reputational or legal consequences if equal

opportunity requirements are not met.

Opportunities arise from strengthening diversity

and inclusion.

In 2025, achievements included expanding AI

upskilling programs, increasing the share of

employees with development plans. Telenor also

advanced its People Strategy to build a more

employee‑centric culture.

Going forward, the focus will be on further

strengthening AI fluency, embedding the new

purpose and values into everyday practices, and

improving gender equity, employee development

quality, and workplace well‑being to support

long‑term strategic execution.

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111

Impacts, risks and opportunities (IROs)

The material impacts, risks and opportunities

identified for Telenor's own workforce are

presented below, both in the table and addressed

in subsequent sections


IROs		Relevance for Telenor	Value chain	Short, medium- or long term
	Working conditions
+	Positive impact	There is actual positive impact on own employees in Telenor’s Asian companies due to family-related leave beyond national policies resulting in improved work-life balance.	=	S
	Equal treatment and opportunities - equal pay
-	Negative impact	There is potential negative impact on employees if they experience gender pay gap resulting in social disparities.	=	S
-	Risk	There is risk that sustained gender pay gap result in claims, inability to attract talent and negative reputation.	=	M, L
	Equal treatment and opportunities - diversity
+	Opportunity	There is an opportunity that further diversity within the workforce leads to better products and services and attract new talent.	=	M, L

Working conditions

Employees of Telenor are entitled to take family-

related leave. The policy for maternity leave for

Telenor group-wide is six months. This particularly

has positive impact for Telenor’s Asian markets,

where the local standard is less than six months.

Equal opportunities and treatment

Telenor is an equal opportunity employer.

Diversity and Inclusion are important to the

business, and are referenced in the Code of

Conduct, People Policy, People Strategy

2026-2028, and the company's sustainability

approach towards responsible business.

However there are a few areas to improve

continuously, which include gender pay gap.

Due to the gender pay gap, employees may not be

compensated in equal amounts for performing

equal work, therefore contributing to pay

inequalities and social disparities. This impact of

non-compliance with equal opportunity

requirements relates primarily to the female

population of the workforce, but could also act as

a deterrent for other gender identities when it

comes to recruitment.

Failure to attract the "best employees" can lead to

difficulties in executing on strategy due to a

workforce that does not have the skills required.

This risk relates to the entire workforce, although

there may be some subject matter areas where

this is more relevant.

Non-compliance with equal opportunity

requirements could result in fines or lawsuits,

damage to corporate reputation, loss of top talent

and a decrease in employee retention. Damage to

reputation could also affect Telenor's ability to

attract the necessary skills and competence. This

impact relates primarily to the female population

of the workforce, but a damaged reputation could

also act as a deterrent across the entire

workforce.

Improving workforce diversity and enabling

inclusion opportunities across the organisation

ensures that the company innovates, develops

and markets products and services to a diverse

customer base. Additionally, it enables Telenor to

create fair and equal opportunities to attract,

retain and develop talent and competence

required for future business needs.

Telenor is reliant on being able to attract and

retain the right people in order to develop the

business and execute on the strategy. All of the

risks and opportunities identified are closely

linked to this dependency on the workforce.

The transition to a more sustainable future is likely

to provide additional business opportunities for

Telenor and as a result, there are no material

negative impacts on Telenor's own workforce

driven by changes to achieve greener and

climate-neutral operations.

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Telenor's own workforce consists primarily of

permanent employees. In addition, the company

hires temporary employees and consultants to

cover periods of parental leave, sickness and

other longer term absence in the permanent

workforce, as well as for specific projects with a

set duration. Temporary employees and

consultants are usually engaged through agencies

and consultancies but in some cases they may be

directly engaged self-employed people.

Additionally, Telenor acknowledges that gender

pay gaps differ across markets. Several Telenor

entities undertake analyses that extend beyond

the requirement to report unadjusted pay gaps.

These enhanced evaluations, which emphasise

identifying and addressing unexplained

disparities, are considered essential to advancing

pay equity. Throughout 2026, Telenor will

continue to refine its methodology in preparation

for the forthcoming implementation of the Pay

Transparency Act.

Impact on strategy and business model

In order to continue developing the business and

deliver on the strategy, Telenor is dependant on

the workforce. The views, interests and rights of

people in the workforce are therefore a key

consideration in the strategy and business model.

During 2022-2025 the People Strategy was built

on three pillars; To build a future-ready

organisation, being the place to grow and

providing the employees a unique and meaningful

work experience. A strong people focus has been

continued during the next strategy period. The

2026-28 People Strategy will have an even

sharper focus towards an employee centric,

customer focused culture that is propelled by

skills development, as a driver for our business

strategy. This will be achieved through the

following three stated objectives:

- Enabled to achieve our best

- Passionate to Collaborate on Customer Needs

- Trusted to develop skills for the future

Policies

Telenor has four policies that relate to own

workforce and the material impacts, risks and

opportunities identified in this area. These are as

follows.

Code of Conduct

The Code of Conduct forms the foundation of

Telenor's corporate culture and sets out high

standards of integrity on how to do business. The

Code guides Telenor employees through day-to-

day dilemmas and is the basis for how they should

behave as guardians of Telenor's integrity. It helps

to make informed decisions and explains where to

go for more information and guidance. The Code

of Conduct is publicly available on Telenor.com.

The Board of Directors owns the Code of Conduct

and is ultimately responsible for its

implementation.

People Policy

The People Policy outlines the requirements for

identifying and addressing risk areas related to

Telenor’s employees, including culture, diversity

and inclusion, mobility, employer responsibility,

employee data administration, digital

collaboration tools and total rewards. It also sets

expectations to promote diversity and inclusion

and reduce potential sources of bias. This

includes requiring each Telenor company to

develop a local action plan for diversity and

inclusion, carry out equal pay analyses and ensure

diversity in recruitment and selection processes.

The policy is publicly available on Telenor.com.

Sustainability Policy

Telenor's Sustainability Policy is described within

E1 Climate change. In addition to the

environmental and climate perspective, this policy

sets out Telenor's commitment to respecting

human rights in accordance with the UN Guiding

Principles on Business and Human Rights, the

OECD Guidelines for Multinational Enterprises on

Responsible Conduct and the UN Global Compact

The scope of the policy includes ensuring regular

human rights due diligence across the

organisation. The policy is publicly available on

Telenor.com.

Through the Code of Conduct, the People Policy

and the Sustainability Policy, Telenor refers to the

UN Guiding Principles on Business and Human

Rights and the ILO Declaration on Fundamental

Principles and Rights at Work, and have guidelines

for employees that are in line with these

principles.

Human rights requirements are based on the

following international instruments: the Universal

Declaration of Human Rights, the International

Covenant on Civil and Political Rights, the

International Covenant on Economic, Social and

Cultural Rights and the principles concerning

fundamental rights in the eight ILO core

conventions set out in the Declaration on

Fundamental Principles and Rights at Work.

The People Policy explicitly addresses forced or

compulsory labour and child labour. It does not

explicitly use the term human trafficking, but the

description of the term forced or compulsory

labour within the policy ensures this aspect is also

covered.

The Code of Conduct and the People Policy also

specifically cover the areas of diversity and

inclusion. The Code of Conduct explicitly states

that 'All employees have a right to a workplace

environment, independent of work location, that

is free from harassment, intimidation,

discrimination or threats of violence for any

reason, including actions based on gender, sexual

orientation or identity, race, ethnicity, disability,

national origin, religious or cultural beliefs or

citizenship'.

How policies are implemented, to ensure

discrimination is prevented, is covered under

"Remediating negative impacts and channels to

raise concerns". Please see page 115 for more

information

Health, Safety and People Security Policy

The policy covers health, safety and people

security aspects, both within Telenor's own

organisation and within the value chain. The policy

is described in more detail in section S2 Workers

in the Value Chain on page 122 and is publicly

available on Telenor.com.

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113

Processes and mechanisms related to

human righ ts

Telenor’s approach to human rights is based on

the United Nations Guiding Principles on Business

and Human Rights (UNGPs) and key international

instruments and commitments. The Group

Sustainability Policy outlines requirements for

Telenor companies to respect human rights,

including taking steps to avoid and not be

complicit in human rights abuses, and seeks to

raise standards where possible in responsible

business conduct.

Human rights due diligence assessment

Telenor's Human Rights Due Diligence (HRDD)

takes a risk-based approach to assessing and

managing human rights and is also embedded in

other due diligence processes within the

company, e.g. supplier due diligence. It is also a

complement to other processes that identify

human rights-related risks, e.g. the Double-

Materiality Assessment (DMA) and Enterprise Risk

Management (ERM).

Telenor has been conducting company-wide

HRDD for 13 consecutive years and has

consistently reported on it externally. To ensure

that Telenor is meeting its obligations and has an

aligned approach towards conducting HRDD as a

continuous improvement journey throughout the

company, the Group Sustainability team has

made a suite of trainings and other resources

available, providing standardised templates and

guidance on conducting HRDD as an continuous

process within Telenor company operations and

value chains.

Human Rights Toolkit

Telenor is using a toolkit to perform an

assessment of its work related to human rights.

The toolkit is based on methodology and

terminology from the UN Guiding Principles on

Business and Human Rights.

The toolkit includes an assessment of stakeholder

engagement and impacts, risks and opportunities

within multiple areas where human rights are

relevant.

The toolkit is used both in the upstream and

downstream value chain and includes all Telenor

geographical markets and affected stakeholder

groups. The following areas are covered in the

toolkit:

• Data access and intercept legal authority

requests

• Freedom of expression, association and

assembly – network and content legal authority

requests

• Online speech and offline harm

• Child safety online

• Privacy and data security (customers and

partners)

• Science, technology and innovation

• Non-discrimination and DEI (Diversity, Equity

and Inclusion

• Worker well-being and safe working

environments

• Working conditions (wages, hours and benefits)

• Modern slavery, forced labour and child labour

• Corruption and bribery

• High-risk and conflict-affected contexts

• Digital inclusion, Digital Wellbeing, and Digital

Skills and Literacy

• Access to education

• Collective bargaining and freedom of

association

• Access to remedy (Grievance mechanism and

remediation)

• Land rights (including indigenous people)

• Environmental and infrastructure impacts

• Cyber security

The assessment is performed by each material

Telenor company and is signed off locally. The

assessments are made using the UN Guiding

Principles terminology for identification and

prioritisation of human rights risks. The tool

includes defining positive impacts on human

rights. The reporting includes mitigation actions.

In cases where significant human rights risks are

identified as part of the due diligence, the chair of

the relevant Telenor company Board shall be

notified as and when they are identified.

The yearly human rights due diligence assessment

by each material company is reported to

management and the Board of Directors at least

annually for review and shared learnings. The

process has remained the same as in the previous

year, but this year the assessments were light-

hand in order to align with the company overall

double materiality process.

Remedies and implementation

The procedure for handling health and safety

incidents that result in negative impacts is set out

in the HSS Incident Handling Guideline. The

guideline does not prescribe remedies, as these

must be handled on a case-by-case basis. For

other negative impacts, there are no set policies

or processes in place for handling or remedies. In

addition to the group policies, the Telenor

companies therefore put in place manuals, which

are more detailed than the policies. These are

aligned with the local laws and regulations as well

as with agreements with local unions, where

relevant.

Group Compliance is responsible for ensuring the

the implementation of all Group policies. The

process for this is described in more detail within

the Business conduct (G1) section of this report.

Targets

Target setting process

The target setting process in Telenor is primarily a

top-down process, where key performance

indicators are identified as part of the annual

strategy process. Based on an assessment by

executive management targets are set for select

indicators to measure progress on strategy

execution. In addition, there are targets

connected to the short-term incentive plan for

senior management. These are set based on

guidelines from the Board of Directors. For the

executive management team, these plans are

approved by the Board.

Women in senior leadership positions

Within own workforce, Telenor has set a target for

women in senior leadership positions with a

particular focus on senior leadership. This target

has been measured and followed up on for several

years.

2025

114

The share of women in senior leadership was at

38% at year-end excluding Telenor Pakistan

(37.5% including Telenor Pakistan) which was 36%

at year-end 2024 including Telenor Pakistan.

Although 40% target was not met, Telenor ended

the year at 38% and remain committed to

improving gender balance through upcoming

leadership appointments. Additionally, Telenor will

extend the gender balance ambitions into the next

strategy period. The target is to reach and

maintain 40% women amongst senior leaders

until 2028, and keep same targets for 2026 and

2027. This is to ensure that leadership gender

balance is maintained as a minimum threshold. It

will also enable balanced gender representation at

other levels of the organisation which can reduce

average pay gap.

Health, safety and security target

Telenor applies a common approach for

employees and suppliers, based on the ambition

of achieving zero injuries. Details are provided

under "Metrics" in this section, in line with the

Norwegian Accounting Act and in section S2

Workers in the value chain, on page 127. Targets

for fatalities and lost-time injuries (LTI) was

established in the baseline year 2021, with

baseline value of 49. Progress is measured

annually. Metrics reviewed under the

Advancement Plan, now use 2024 as the baseline

year for all other indicators.

Actions

Telenor uses several methods for determining

which areas to implement actions and to identify

what action is needed. Focus areas are defined

through feedback gathered via engagement with

stakeholders, as well as through strategic

planning processes where future needs and

expectations contribute to shaping the relevant

actions.

The policies and processes in place within Telenor

provide guidelines that should ensure that the

workforce is protected against any tensions that

may arise between the prevention or mitigation of

material negative impacts and other business

pressures. Furthermore, the culture in the

company and 'tone at the top' contribute to

reinforcing the expectations and requirements for

employees to be treated in accordance with

polices and to speak up if they are not.

There are a number of local initiatives and actions

across the company. These are not listed here,

but instead, the overview of key actions below

sets out the actions put in place across the group

that are linked to the material impacts, risks and

opportunities.

Actions during the year

Development plans

For all leaders to be people developers, and for

Telenor to ensure a learning culture is well

established, individual development plans are a

key enabler. Development plans should balance

organisational needs as well as individual

aspirations and competence.

The development plans support the 40 hours of

learning (per annum) approach in Telenor. This

contributes to the positive impact from training

and development as well as the opportunity to

attract and retain people. The ambition is for all

employees to have development plans. Going

forward the work will also focus on the quality of

such plans.

Upskilling on AI

Telenor launched the AI for All Starter Kit in 2024

as part of the global AI programme, establishing a

common foundation for AI understanding across

the workforce. In 2025, the initiative expanded

from a single course to a broader view of AI

learning, tracking completion of any AI-related

training taken by employees. This shift reflects

Telenor’s ambition to build practical, everyday AI

capability at scale. With continued efforts moving

forward, AI upskilling efforts will continue under

the global AI&I umbrella and the Nordic AI for

People agenda, guided by the AI Fluency Journey.

This framework brings together baseline, role-

based, and tool-based learning, supported by

communities and champion networks, and is

anchored in Telenor Academy’s recommended

content.

Gender pay gap

To close the gender pay gap, there is a need to

increase the share of women in the company and

enhance focus on reviewing historical pay

inequity based on experience, tenure and relevant

skill-set. As part of Telenor's commitment to

diversity, equity and inclusion there will be a

continued focus to reduce unexplainable pay gaps

for women.

The lack of progress within this area is to a large

extent driven by the industry trend in telecom and

tech companies, where there is typically a higher

share of male employees and applicants to open

positions. In addition to encouraging leaders,

Telenor ensures diversity in each stage of the

recruitment process (internal as well as external).

Planned future actions

Upskilling on AI

For 2026, two key targets guide this work: a 60%

AI fluency goal for the Nordics, and a 70% global

completion target for the upcoming mandatory

Responsible AI training to be introduced in 2026.

These efforts underline Telenor’s commitment to

equipping employees with the skills to use AI

confidently and responsibly as the organization

accelerates its transition towards an AI-powered

future.

Telenor culture

Telenor launched new purpose and values on

November 5th during the internal strategy launch

called Face Forward. During 2026, these will be

embedded into the different processes, policies,

communication and arenas. The purpose for

Telenor is: "With you, for a safer and smarter

tomorrow". The values are Trust, Curiosity &

Passion.

For 2025, the Telenor Behaviours (Always explore,

Create together, Keep promises and Be

respectful), together with the Code of Conduct,

are the foundation of Telenor's

culture and act as a guide and set expectations to

all behaviour and decision-making in Telenor.

According to the People Policy, Telenor

companies actively follow up the implementation

of the behaviours to create awareness,

commitment and compliance by offering

necessary training and support. During the

upcoming strategy process an even stronger

focus on a common culture will be emphasised.

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115

Incidents of actual negative impact during 2025

In 2025, there were no work-related fatalities

among own employees.

Engaging with own workers and workers'

representatives

Engagement with Telenor's own workforce

happens through a number of arenas, as

described below. The EVP People, Sustainability

and External Relations is responsible for ensuring

relevant policies and processes are in place, such

as EES, people dialogue process and engagement

with labour unions. Feedback and insights from

this dialogue are taken into account when

determining the company's strategy and actions.

People Dialogue Process

In this process, engagement with employees

takes place with leaders and employees having

periodic dialogues to review performance and

outline a plan for development. The People

Dialogue Process ensures that employees have an

appraisal (impact assessment), goals and a

development plan that is updated periodically.

Through the People Dialogue Process, all relevant

areas of impacts, risks and opportunities can be

covered, depending on the individual needs,

interests and priorities. The dialogues can be used

to identify areas where actions are required, but it

is also a useful arena to discuss potential

approaches to mitigation and to assess the

effectiveness of implemented actions.

Employee Engagement Survey

The annual Employee Engagement Survey (EES) is

another tool the organisation uses to engage with

employees, as well as to receive feedback on the

effectiveness of initiatives. When new initiatives

are put in place in parts of the organisation,

feedback on effectiveness is also measured

through a 'pulse survey' which is a shorter version

of the EES. This is usually conducted three to six

months after the EES, and can focus on specific

initiatives or focus areas.

The feedback and insights from the EES cover

areas related to all the material impacts, risks and

opportunities for own workforce, as well as

addressing areas within other topics, such as

business conduct.

The EES is used both to identify areas where

actions are needed, but also to measure the

effectiveness of implemented actions.

Union dialogue

There are a number of union collaboration and

meeting places across the Group:

• The "Corporate Collaboration

Forum" (Konsernets Samarbeidsutvalg) at

Group level meets approximately eight times per

year and includes President & CEO of Telenor

Group, EVP People, Sustainability and External

Relations and Group employee representatives.

• European Works Council (EWC) has a minimum

of two meeting per year, as well as additional

meetings as required. It includes EVP People,

Sustainability and External Relations and

representatives for employees from Telenor

Companies in Norway, Sweden, Finland and

Denmark.

• EVP & Group CTO, the EVPs of Telenor Nordics,

Telenor Amp and Telenor Infrastructure and

CEO of Telenor Shared Services AS all have

contact meetings with the corporate unions

between four and six times per year.

• There are regular local union meetings at

company level, within Telenor companies in the

Nordics and in Asia.

Telenor has an International Frame Agreement

with UNI Global Union (UNI). UNI is an organisation

of 20 million service sector workers around the

world, and the agreement gives a platform and

framework for dialogue between UNI and Telenor

on fundamental labour rights. Telenor has an

annual meeting with UNI.

In addition to the regular meeting places,

employee representatives and unions are

informed and consulted on issues of importance,

following local law, Collective Bargaining

Agreement requirements and local practice, in

particular prior to any significant restructuring in

the organisation.

In Norway, the equality and gender pay reporting

is also a topic for discussion with the local unions.

The union dialogue also covers other topics, such

as training and development, health and safety,

People Dialogue Process, EES and diversity and

inclusion. The discussions will cover areas where

actions are needed, the effectiveness of existing

actions, and ways to improve the effectiveness

further.

The requirement to engage with employees

across the different platforms described above is

set out in policy documents, agreements and local

laws and regulations. It is the responsibility of the

EVP People, Sustainability and External Relations

to ensure the engagement happens and that the

results inform the company's approach.

Remediating negative impacts and

channels to raise concerns

Reporting channels

Th e general approach to remedy in instances

where Telenor has caused or contributed to a

material negative impact on people in its

workforce is based on investigating and assessing

each case on an individual basis. Any employee

who becomes aware of such instances must

assess whether this should be resolved or

escalated to a manager, an HR representative or

other channels. The Code of Conduct training

includes information concerning how an

employee should handle various situations.

The main formal channels for the workforce to

raise concerns or needs include the people

dialogue process and the Employee Engagement

Survey, as well as the Integrity hotline. In addition,

there is a possibility to raise concerns to union

representatives, local compliance officers, local

health, safety and security (HSS) officers and

through a health and safety incident reporting

system. Not all of these are available in every

Telenor company, but all Telenor companies offer

various options to raise concerns to different

levels/areas of the organisation.

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116

Characteristics of our employees

Permanent and temporary employees by gender and country

Telenor's own workforce consists primarily of permanent employees. In addition, the company hires

temporary employees and consultants to cover periods of parental leave, sickness and other longer term

absence in the permanent workforce, as well as for specific projects with a set duration. In addition to

these we have a small number of employees that are working under non-guaranteed hours condition.

The telecom industry has traditionally been male-dominated, especially in technical and senior roles. In

addition there are fewer women pursuing degrees in STEM (Science, Technology, Engineering, and

Mathematics) fields, which are critical for many roles in telecommunication.

Telenor is trying to mitigate this by focusing on better diversity in the recruitment, development and

promotions processes, but there is still more to be done.

See note 5 in the financial statements for information about the salaries and personnel cost. The total

number of employees reported in note 5 is 10,000, rounded to the nearest thousand. This figure is based

on the total number of man-years and the average of the last five quarters. The methodology differs from

that used for reporting the number of employees in the Sustainability Statement.

Number of employees by gender (headcount)


Gender	2025	2024
Female	3,171	3,416
Male	6,955	7,915
Other	7	0
Total employees ¹⁾	10,133	11,331

¹⁾ The 2025 figures exclude 1,103 employees from Telenor Pakistan, compared with 1,060 employees included in 2024.

Total number of employees in countries (headcount)


Country	2025	2024
Norway	3,808	3,933
Sweden	1,790	1,817
Denmark	992	1,016
Finland	1,676	1,672
Bangladesh	1,338	1,327
Pakistan ¹⁾	255	1,301
Singapore	181	208
Other ²⁾	93	57
Total employees	10,133	11,331

¹⁾ The 2025 figures exclude 1,103 employees from Telenor Pakistan, compared with 1,060 employees included in 2024.

²⁾ Other include Portugal, Poland, Thailand and USA

Number of employees by employment type (headcount)


Permanent employees	2025	2024
Female	3,058	3,230
Male	6,754	7,637
Other	7	0
Total employees ¹⁾	9,819	10,867

¹⁾ The 2025 figures exclude 993 permanent employees from Telenor Pakistan, compared with 958 employees included in 2024.


Temporary employees	2025	2024
Female	113	186
Male	201	278
Other	0	0
Total employees ¹⁾	314	464

¹⁾ The 2025 figures exclude 110 temporary employees from Telenor Pakistan, compared with 102 employees included in 2024.

2025

117


Non guaranteed workforce	2025	2024
Female	13	7
Male	21	15
Other	0	0
Total employees	34	22

Employees turnover


Employees who have left Telenor	2025	2024
Number of employees	1,397	1,590
Rate of employee turnover	13%	14%

Diversity metrics

Age distribution in workforce

The number of employees split into the age groups of below 30, between 30 and 50 and above 50 is

shown below.


Age distribution in workforce	2025		2024
Age	Number of employees (Headcount)	Percentage of employees	Number of employees (Headcount)	Percentage of Employees
Employees under 30 years old	1,531	15%	1,791	16%
Employees between 30 and 50 years old	5,779	57%	6,707	59%
Employees over 50 years old	2,823	28%	2,833	25%

Gender diversity in senior leadership


	2025		2024
Gender	Number of employees (Headcount)	Percentage of employees	Number of employees (Headcount)	Percentage of employees
Female	35	38%	35	36%
Male	57	62%	62	64%
Other	0	—%	0	—%

As of year-end 2025, the total number of senior leaders was 92.

The share of women in senior leadership was at 38% at year-end excluding Telenor Pakistan (37.5%

including Telenor Pakistan) at year-end of 2025 which was 36% at year-end 2024 including Telenor

Pakistan. Although 40% target was not met, the company ended the year at 38% and remains committed

to improving gender balance through upcoming leadership appointments. Additionally, Telenor will

extend the gender balance ambitions into the next strategy period. The target is to reach and maintain

40% women amongst senior leaders until 2028, and keep same targets for 2026 and 2027. This is to

ensure that leadership gender balance is maintained as a minimum threshold. It will also enable balanced

gender representation at lower levels of the organisation which can reduce average pay gap.

2025

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Adequate wages

An adequate wage is defined by ILO as a wage that

meets the needs of a worker and their family,

considering the national economic and social

conditions of a country. Telenor is committed to

paying fair wages above the local living wage and

offering attractive benefits to employees, relevant

to each respective market. Telenor's pay setting

practices vary by market, in line with local

legislation and practices.

In the Nordics, employees are covered by

collective agreements and as such, adequate

wages are secured. In Asia, pay setting is based on

local benchmark data, and the companies are

currently placed above the 50th percentile of their

respective markets. Based on this, Telenor

believes that all employees are paid adequate

wages. During 2025, Telenor has initiated a pilot

project to strengthen the monitoring of wage

levels across the different markets.

Health and safety metrics

Telenor's updated DMA for 2025 resulted in Health

and safety as a material sub-topic which was

considered to be below the materiality threshold.

The main reason being that fieldwork, of

considerably higher risk, is being outsourced and

followed up under ESRS S2 - Workers in the value

chain.

However, Telenor monitors several metrics

related to health and safety, and below are

metrics required to report in line with the

Norwegian Accounting Act, § 2.2-10.


Health safety and security metrics for own workforce	2025	2024
Number of fatalities	0	0
Number of lost time injuries (LTI)	5	10
Lost-time injury frequency (LTIF)	0.25	0.51
Percentage of sickness absence frequency	2.80%	2.45%

Metrics related to non-employees are not

included, as this is a phase-in requirement; only

data for employees are disclosed. Work-related

injuries are captured by lost-time injuries (LTIs)

and fatalities. For the current reporting period,

there were no fatalities among employees, but

there were 5 LTIs.

In 2025 the Lost-time injury frequency LTIF was

0.25, while in 2024 it was 0.51. This reflects a

reduction in work-related lost-time injuries

involving Telenor employees.

Compensation metrics

Gender pay gap

Telenor acknowledges that gender pay gaps differ

across markets. Most Telenor entities undertake

analyses that extend beyond the requirement to

report unadjusted pay gaps. These enhanced

evaluations, which emphasise identifying and

addressing unexplained disparities, are

considered essential to advancing pay equity.

Throughout 2026, Telenor will continue to refine

its methodology in preparation for the

forthcoming implementation of the EU Pay

Transparency Act.

In 2025, Telenor updated its methodology from

reporting median to average total compensation

to align with CSRD requirements. Comparative

figures for 2024 have not been restated, as doing

so was assessed to be impracticable. To estimate

the impact of this methodological change, Telenor

also calculated the 2025 figures using the

previous median‑based approach. Under this

approach, the 2025 pay gap remains at 15%,

which is consistent with the average‑based result

and reflects a positive development compared

with 2024.


Gender pay gap	2025	2024
Weighted average gender pay gap	15%	17%

CEO compensation ratio

Telenor observes differences between company

size and geographies for the ratio of

compensation between the CEO or highest paid

employee and the median compensation of

employees. For the President & CEO, the local

market is perceived as the most relevant

comparison, as the global comparison will be a

more volatile measure, influenced by fluctuations

in foreign exchange rates and the global footprint

of the group.


CEO compensation ratio	2025	2024
P&CEO: Employees in Norway	15.0	14.7
P&CEO: Employees Global	22.3	21.9
Range of CEO/highest paid compensation ratio (by company)	1.7 to 60.9	1.5 to 37.3

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REPORTING METHODOLOGIES

Number of employees

Headcount: the number of employees in the

organisation as of year-end, (permanent and

fixed-term/temporary) including sick leaves,

parental leaves, etc. Does not include

contingent workers. This definition is broader

than financial FTE definition that focuses on

cost tied to active workforce.

Temporary employees

Fixed-term employees are directly employed by

Telenor, and have a specified end-date in their

contract. A non-guaranteed hours employee is

someone employed without a guarantee of a

minimum or fixed number of working hours,

without a contractual obligation.

Gender categories

In addition to female and male, the system

includes "other" to capture non-binary, other,

and undisclosed classifications. However,

reporting this category is voluntary, and it has

not been disclosed. Non-binary and other

classifications are considered part of the

reported categories.

Senior leaders

Telenor defines top management, or senior

leaders, as the President & CEO, their direct

reporting Executive Vice Presidents with their

direct reporting Senior Vice Presidents, the

CEOs of Telenor's main companies and their

direct reporting Chief Officers (CXOs).

Additionally, some CEOs of smaller Telenor

companies are regarded as senior leaders.

Lost-time injury (LTI)

An LTI is an injury where an employee was

unable to work the next scheduled working day

as a consequence of the injury. The injury

occurred while performing routine job

activities/responsibilities. This metric does not

include sick leave.

Lost-time injury frequency (LTIF)

LTIF measures all work-related fatal accidents

and lost-time injuries for Telenor employees per

million worked hours. An LTIF quantifies the

frequency of work-related injuries leading to

time away from work. It is calculated on the

basis of worked hours and is categorised as a

lagging indicator, as it provides insight into the

company's past safety performance. By

tracking the frequency of lost-time injuries,

Telenor can gauge the effectiveness of its

safety programmes and initiatives. Monitoring

this metric helps identify trends and patterns in

workplace injuries, which is valuable for

recognising hazards, high-risk activities or

areas in need of targeted safety interventions.

In 2025 the LTIF was 0.25, while in 2024 it was

0.51.

Sickness absence frequency

Sickness absence frequency is the frequency at

which employees are absent from work due to

illness or health-related reasons. It assesses the

prevalence and impact of sickness-related

absences. It is a proactive measure that

supports both employee well-being and

organisational effectiveness. In 2025, the

sickness absence frequency was 2.80%

compared to 2.45% in 2024.

Annual Turnover rate is calculated by dividing

the total number of leavers for the period by the

average headcount for the period. Number of

leavers includes both voluntary resignations

and involuntary terminations during the year.


Compensation metrics The gender pay gap is defined as the difference of average total compensation for the reporting year between female and male employees, expressed as a percentage of the average pay level of male employees. The group pay gap is the weighted average by company headcount. Telenor companies with 10 or more employees and where the number of observations in each gender category is at least 5 are included. Note that the methodology has changed from median to average total compensation effective 2025. The 2024 reported numbers are unchanged based on median total compensation. The CEO compensation ratio compares the total compensation of the CEO or highest-paid individual to the median total compensation for employees of each company, excluding the highest-paid individual. Companies with 10 or more employees are included. The compensation ratio for the President & CEO is reported against employees of the same market (Norway) and against employees in all markets (global). For the latter, compensation in local currencies have been converted to NOK without any adjustment for purchasing power. For the 22 Telenor companies in scope of reporting, the range of compensation ratios observed is reported, representing the CEO (or highest-paid employee) of each company against their employee population. Under both compensation metrics, it is the total compensation paid during the reporting year that has been applied. Amounts are annualised and in full-time equivalents and includes base pay, holiday pay, car allowance, STI, ESP bonus, LTI grant, overtime and shift allowances, benefits and pension.

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ESRS S2

Workers in the

value chain

Embracing responsibility for workers in

the value chain is essential to safeguard

human rights, mitigate risks, enhance

brand value and ensure long-term

success. At Telenor, this commitment is

reflected in the high standards of

business conduct, working conditions

and environmental management that are

expected and followed up in business

relationships.

How Telenor makes an impact

Throughout Telenor's value chain, there are more

than 13,000 local and global business partners and

suppliers. Workers in Telenor’s value‑chain are

primarily located in upstream activities such as

construction, installation and network operations

across all Telenor markets. The main impacts and

risks relate to health and safety incidents in these

high-risk environments.

Workers are also in various manufacturing hubs

producing phones, routers and other devices, and

Asian sales and distribution networks, where risks

such as hazardous working conditions and

exposure to child or forced labour may occur.

Telenor works to strengthen supplier practices

through robust due diligence, monitoring and

capacity‑building initiatives.

In 2025, Telenor recorded 40 lost‑time incidents

(LTIs) among supplier employees and one fatality

in the supply chain. The close‑out rate for

supply‑chain non‑conformities rose from 88% to

96%, while monitoring of high‑risk suppliers

dipped slightly from 99% to 94%, supported by

around 150 JAC audits and 1,020 additional

supplier inspections. Through these activities and

long‑term initiatives, Telenor continues to

promote transparency, safety and improved

labour conditions across its global value chain.

Going forward, Telenor will continue to strive for

meaningful impact by enhancing supplier

accountability and strengthening protections for

workers across the value chain.

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Impacts, risks and opportunities (IROs)

Telenor has identified the following impacts, risks

and opportunities for ESRS S2 - Workers in the

value chain.


IRO		Relevance for Telenor	Value chain	Timing
	Working conditions
-	Negative impact	There is actual negative impact on the health and safety of workers in the value chain due to high-risk work environments (e.g. work in heights or poor traffic conditions) which can result in serious injuries and fatalities.	↑ ↓	S
-	Risk	There is a risk that severe incidents to workers in the value chain can result in adverse health impacts or fatalities, which can result in legal liability, fines, operational delays, and negative reputation.	↑ ↓	L
	Other work-related rights
-	Negative impact	There is potential negative impact to children and workers in the value chain, as child and forced labour in Telenor’s value chains in Asia can result in a detrimental effect on children’s lives, health, and well-being.	↑	S
-	Risk	There is a risk of instances of child-, underage- or forced labour in the value chain, which can result in breaches of international conventions and national laws, compensation requirements/legal liability, and negative reputation.	↑	M

The IRO process

Telenor's value chain spans a wide range of

industries and geographical locations. Mapping

value chains beyond direct suppliers and business

partners, particularly in global value chains, can be

challenging due to their complex and changing

nature.

For Telenor, workers in the upstream value chain

mainly include those working in construction,

installation and upgrade of network and

infrastructure, which are used to expand,

maintain and run the networks that Telenor owns

and operates. In addition, marketing, information

systems, IT equipment and services, real estate

and office-related services, such as supplies,

cleaning, maintenance and catering/canteen

employ workers in connection with Telenor's

operations.

Telenor also has suppliers who employ workers

that manufacture devices such as handsets, Wi-Fi

routers, TV boxes, and SIM cards. These are sold

to customers and end-consumers through own

channels, retailers, franchises and partners.

Across the value chain, there are more than

13,000 active local and global business partners

and suppliers with recorded spend during the past

24 months across all Telenor-controlled entities,

whereas the previously reported figure of 19,000

suppliers also included inactive local and global

business partners and suppliers. From 2025

onwards, the reporting has been corrected to

include only active business partners and

suppliers. The number of workers employed

through the value chain is significant.

The risk of child labour, underage labour, and

forced labour in parts of the value chain remains a

serious concern, particularly in Asia. Addressing

these risks related to human rights and labour

rights requires continuous due diligence, supplier

engagement, and remediation measures to

prevent harm and uphold international labour

standards..

Working conditions

Negative impacts on workers in the value chain,

particularly regarding health and safety, arise

from high-risk work environments, which put

workers at risk for minor or serious injuries, and

fatalities.

The negative impact on workers is primarily in

upstream activities, such as construction,

installation and maintenance of Telenor's network

across all Telenor's geographical locations, where

work includes working at height, working with

electricity and operating heavy machinery in

remote locations.

Additionally, workers in the downstream part of

the value chain, particularly those in the sales and

distribution network within the Asian operations,

may be impacted by hazardous traffic conditions

and adverse weather.

There are a limited number of incidents, with

actual negative impact only on a small number of

workers in the value chain. However, the severity

may be high.

Serious or fatal accidents can have a severe

impact on Telenor’s business. There is a risk that

contractors do not train workers on Telenor's

sites according to routines and standards, which

could lead to severe Health, Safety and People

Security (HSS) incidents.

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Workers responsible for installation, operation

and use of equipment have a potential risk of

exposure to suboptimal labour practices. For

Telenor and its direct contracted suppliers, this

may lead to difficulty acquiring and retaining

talent, termination of contracts with key suppliers,

fines, criminal investigations, loss of operating

licences, partners opting out, delayed rollout

plans, and failure to deliver promised coverage to

customers. This risk affects a wide range of

workers within Telenor's value chain.

Other work-related rights

Within Telenor’s global value chain, child labour

may potentially occur, particularly in mining and

recycling activities. Within Telenor markets in

Asia, such as Bangladesh, potential negative

impacts may arise due to prevalence of child and

forced labour in supplier tiers. This could have a

detrimental effect on the lives, health and well-

being of children.

Forced labour is a concern, especially in high-risk

industries such as manufacturing and raw

materials extraction. This impact relates

particularly to the upstream part of the value

chain, involving elements deep within the supply

chains and further from Telenor's direct influence

than the direct contracted suppliers. Workers

affected by such impacts are often particularly

vulnerable due to inherent characteristics, such

as being young or migrant workers, or they may

be in a vulnerable situation driven by socio-

economic factors.

Within the parts of the value chain that Telenor

has the most significant possibility to influence

and impact, there are a limited number of child

and forced labour incidents, and the actual

negative impact is on a very small number of

workers in the value chain. However, the severity

is high. Within parts of the value chain that are

further away from Telenor's influence, there could

be a more widespread negative impact.

Related risks for Telenor in instances of child and

forced labour can be reputational damage and

legal actions, disrupting the supply chain and

impacting business continuity and revenues.

Impact on strategy and business model

Telenor's business model and strategy are reliant

on equipment and services that could pose a

negative impact or risk towards workers within

the value chain. This is driven both by the nature

of work, such as working at heights with

electricity, as well as involving industries where

there is a widespread risk, such as child and

forced labour in connection with extraction of

minerals for electronic equipment manufacturing.

To understand these risks and impacts, Telenor

has worked methodically over many years to

monitor and inspect these areas. This is, for

instance, done as part of the Joint Alliance for

CSR ('JAC') audits, where Telenor is a member.

Policies

Telenor has four policies that relate to workers in

the value chain and the material impacts, risks

and opportunities identified in this area. These

policies are described below.

Supplier Conduct Principles

The Supplier Conduct Principles (SCP) outline

Telenor’s expectations for responsible business

conduct among Telenor's suppliers, mirroring its

Code of Conduct. The SCP covers topics such as

human and labour rights, working conditions,

health and safety, and conflict minerals.

It is a code of conduct that must be complied with

by all suppliers and partners with a direct

contractual relationship with Telenor. The SCP

explicitly addresses human trafficking, forced

labour and child labour. Telenor ensures that

direct suppliers are liable for its sub-contractors

through contractual clauses mandating

transparency and adherence to Telenor’s

standards and remediation of any non-

conformities.

This has been done historically through the

Agreement on Responsible Business Conduct

(ABC) and from end 2024 via the Supplier

Conduct Principles Commitment (SCPC), which

suppliers are required to sign and which refers to

the Supplier Conduct Principles and is publicly

available on the Telenor website.

Third Party Risk Management Policy

The purpose and scope of the Third Party Risk

Management Policy is to ensure that business

partners, including all third parties such as

suppliers, vendors, distributors, franchisees,

agents and partners, follow Telenor’s standards

for responsible business conduct as set out in the

SCP. The policy also aims to ensure that

compliance risks associated with third parties are

identified, assessed and properly managed

throughout the lifetime of the relationship. The

policy is publicly available on the Telenor website.

Health, Safety and People Security Policy

The Health, Safety and People Security (HSS)

Policy aims to contribute to the ambition of zero

injuries among employees, suppliers and visitors,

and includes requirements relating to processes

to assess and manage HSS risks.

The policy also covers employee safety during

business travel, encourages incident reporting

and sets out requirements for suppliers related to

HSS. The policy is publicly available on

Telenor.com.

The HSS Policy sets out requirements regarding

ensuring the HSS management system remains

effective and in alignment with ISO45001

standards. It also refers to the Occupational

Safety and Health Administration (OSHA)

guidelines for incident definitions and

classifications in incident reporting.

The EVP People, Sustainability and External

Relations is the owner of the People Policy, the

Health, Safety and People Security Policy and the

Sustainability Policy and is ultimately responsible

for the implementations of these policies.

Group Compliance is responsible for ensuring the

policies are adopted and adhered to in the

different Telenor companies. In addition, all

Telenor employees must annually sign off on the

Code of Conduct.

Sustainability Policy

The policy covers areas such as Telenor's

commitment to respecting human rights in

accordance with the UN Guiding Principles on

Business and Human Rights, the OECD Guidelines

for Multinational Enterprises and the UN Global

Compact. The policy is described in more detail in

section E1 Climate change on page 91 and S1 Own

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123

workforce on page 112 and is publicly available on

the Telenor website.

The EVP for People, Sustainability and External

Relations is the owner of Third Party Risk

Management Policy, Health, Safety and People

Security Policy and the Sustainability Policy and is

ultimately responsible for the implementation of

these policies.

The policies and details of Telenor's commitment

to responsible business conduct, including human

rights, labour rights, working conditions and

health and safety are publicly available on

Telenor's website. The processes for engaging

with workers in the value chain are described

within the section Engaging with value chain

workers on impacts.

The policies do not set out the processes or

nature of remedies, as these may depend on the

type, scale and scope of impact. The processes

for remedies are described within the section

Remediating negative impacts and channels to

raise concerns.

Remedies and implementation

The procedure for handling health and safety

incidents that result in negative impacts is set out

in the HSS Incident Handling Guideline. The

guideline does not prescribe remedies, which

need to be handled on a case-by-case basis. This

applies also for other impacts, such as those

related to rights overall.

Processes and mechanisms related to

human rights

Annual assessment of human rights due

diligence

Telenor is using a Human Rights Toolkit to

perform an annual assessment of its continuous

human rights due diligence. The toolkit is based

on the methodology and terminology of the UN

Guiding Principles on Business and Human Rights.

The work related to human rights in the value

chain is part of the toolkit. The annual assessment

of human rights due diligence is further described

on page 112.

Targets

Within the area of workers in the value chain,

Telenor has both some long-term ambitions and

some specific annual targets that apply to direct

contracted supplier and their sub-suppliers.

Telenor reports quarterly and annually on the

ambitions and targets. Metric performance is

tracked in a system for web-based incident

reporting, and audit and inspections, as well as in

Telenor’s reporting system for tracking financial

and non-financial metrics. The aim of the targets

is to reduce the likelihood of negative impacts and

risks, focusing on the material areas that have

been identified. Telenor has been focusing on

these areas for many years, and the ambitions

and targets have been reported on during this

time.

All ambitions and targets have been set in a top-

down process. Workers in the value chain have

not been involved in setting these targets, but

they may be involved in tracking the effectiveness

of actions related to these targets, as described

within the Actions and Engagement with

stakeholders sections. They may also contribute

to assessing actual incidents and give inputs to

improvements needed to avoid such incidents in

the future.

Health and safety

Zero injuries ambition

Achieving zero injuries among workers and

ensuring mitigation of the company’s high risks

through the Making Zero Possible operational

standards launched in 2021 is described further

below in the section. This target emphasises the

utmost priority placed on safety, aiming for zero

injuries and fatalities within the scope of Telenor’s

work. It reflects a commitment to ensuring that all

employees and supplier employees return home

safely every day. Telenor has been working on this

for many years, but the target was formally

established in the baseline year 2021, where the

baseline value was 49. Telenor measures

progression against this target annually. For 2025,

the actual number of LTIs within Telenor's scope

of work was 40 and the number of fatalities in the

supply chain was 1.

Close-out rate of 90% for non-conformities

This is a critical target that reflects Telenor’s

commitment to addressing and resolving non-

conformities against the SCP. It measures the

closure percentage of non-conformities identified

through supply chain sustainability inspections

and audits performed on direct contracted

suppliers and/or their sub-suppliers. The metric is

calculated quarterly on a 12-month rolling basis.

For Nordic operations, the close-out rate is

calculated on both minor and major non-

conformities. In Asia, the metric is currently

calculated only on major non-conformities. This

allows the concentration of resources on driving

amicable closure of reoccurring systemic issues.

A high close-out rate indicates that mitigation

actions to rectify non-conformities are effectively

implemented.

The target has been approved by Executive

Management with a level of 80% for 2024 and

90% for 2025. The 2025 target was part of the

capital markets day (CMD) communication

presented in 2022 and was approved by the Board

as part of the strategy plan.

For 2025, the actual close-out rate was 96%,

compared to 88% in 2024, 61% in 2023 and 55% in

2022.

Monitoring 100% of high-risk suppliers

The purpose of this target is to evaluate the

extent to which Telenor is actively monitoring

direct high-risk business partners and their supply

chains. It calculates the proportion of high-risk

business partners that have undergone at least

one monitoring activity during the reporting

period, expressed as a percentage of the total

number of high-risk partners.

High-risk business partners are business partners

identified and categorised as high-risk by Telenor

companies based on the residual risk in the risk

assessment tool. The metric provides an

indication of Telenor's diligence in overseeing

high-risk business partners and their supply

chains. It assesses Telenor’s effectiveness in

identifying and mitigating potential risks related to

compliance, ethical practices and operational

integrity. It is measured in the Nordic and Asia

operations and is calculated on an annual basis.

The target, set in 2022 and to be achieved by 2024

and maintained at the same level in 2025, is part

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of the governance instructions document, which

is formally approved through the group-wide

governance work programme. For 2025, 94% of

high-risk suppliers have been monitored,

compared to 99% in 2024.

Child labour, underaged labour and forced

labour

Zero cases

This target reflects a commitment to ensuring the

protection of fundamental human rights,

promoting ethical practices and fostering a safe

and fair working environment. Telenor has worked

to prevent child labour, underaged labour in

hazardous conditions and forced labour for many

years, but for the purpose of this reporting the

baseline year is 2024, where the baseline value is

0 child labour cases, 6 cases of underaged labour

in hazardous conditions and 21 cases of forced

labour.

Actions

As described above, Telenor's value chain spans a

wide range of suppliers, business partners, and

other categories within the value chain. There are

both global and local agreements, with risks and

impacts that are more relevant for certain

industries or geographical regions.

The policies and processes in place within Telenor

provide guidelines that should ensure that

workers in the value chain are protected against

any tensions arising between the prevention or

mitigation of material negative impacts and other

business pressures.

By adhering to the governance in place within this

area, such situations should be avoided and the

workers' rights protected.

In the section below, the key actions applicable

across the group related to this area are

described. In addition, there are local actions and

initiatives that are not addressed here. Within the

workers in the value chain areas, and specifically

related to the material impacts and risks within

health and safety, and child and forced labour,

actions tend to be more long-term. These

continuous processes and initiatives aim to

prevent and mitigate the likelihood of negative

impacts and risks. The details of these processes

are also described below.

Ongoing actions and processes to mitigate

impacts and risks

Supplier due diligence

Telenor conducts due diligence activities to

identify, assess, and mitigate human rights and

SCP risks. The purpose of the process is ensure

that Telenor enters agreements with suppliers

and business partners that adhere to strict

requirements. The requirements are set to

safeguard human and labour rights, the well-being

of workers in the value chain and to ensure that

business partners uphold a high level of business

ethics.

Prior to engagement, the Integrity Due Diligence

process contributes to assess whether the third

parties have policies in place covering forced

labour/modern slavery, child labour, underage

labour, and health and safety.

Telenor requires suppliers to mirror the SCPC

with its sub-contractors and identify potential red

flags, such as possible breaches of labour rights

or lack of health and safety training and

management systems.

The process also includes a risk assessment,

where the level of inherent risk is determined

based on the nature of services provided, as well

as the profile and geography of the supplier.

Inherent risk level determines the requirement for

further risk assessment, which may include an

enhanced in-depth integrity due diligence.

Telenor companies manage supply chain

governance through procurement teams in each

market. At the global level, Telenor Procurement

Company (TPC) is responsible for establishing and

managing Global Framework Agreements (GFAs),

which may serve multiple markets.

The processes are continuous throughout the

year as new business partners are considered.

They are applicable across the entire group and

the effectiveness of these processes is measured

through the monitoring activities described

below.

Monitoring activities

Monitoring activities are primarily targeting direct

contracted suppliers and include risk-based

assessments, meetings with key vendors,

performance monitoring and audits and

inspections, both at the global and local level.

Post-contract, comprehensive questionnaires are

used to evaluate the ESG performance of high-

and medium-risk suppliers. Integrating

sustainability discussions in key vendor meetings

allows Telenor and its strategic business partners

to identify and mitigate potential risks.

Telenor adheres to a rigorous process of audits

and inspections based on industry standards, with

actions implemented based on the findings.

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Inspections are reviews based on the SCP and

SCPC, conducted with the aim to verify and

validate the supplier's implementation of controls

to manage risks.

Checklists and digital platforms are used to

ensure timely and proper closure of findings, with

inspections also triggered by significant or

moderate risk ratings and scheduled based on

risk assessments.

Audits are triggered by significant or moderate

risk ratings and occur annually or as needed. They

may include site visits, document reviews and

interviews with employees. They are deeper

checks to assess suppliers’ policies, processes

and systems in place to ensure compliance with

the SCP, with the aim to assess implementation

and identify areas for improvement.

Supplier audits and inspections often uncover

non-conformities or findings that need to be

addressed to ensure compliance and improve

processes. When such issues are identified, they

are documented and corrective action plans are

developed to address these findings. This may

involve revising policies, enhancing training

programmes or implementing new controls.

Global audits in the common industry supply chain

are conducted through Telenor’s membership in

JAC (Joint Alliance for Corporate Social

Responsibility), a non-profit association of

telecom operators, which supports collaborative

efforts to enhance supply chain sustainability

within the Information Communication

Technology. Through the JAC partnership Telenor

leverages audits conducted by other member

companies in the lower tiers of the global supply

chain.

JAC audits are conducted to identify the level of

conformance with JAC CSR principles and other

relevant standards. This includes joint efforts to

respect human rights and ethical standards,

particularly addressing forced labour, labour

exploitation and conflict minerals, as well as

ensuring health and safety within the supply chain.

In relation to child labour avoidance, the audits

include reviewing personnel records, proof of age

documentation, identity documents and worker

permits.

Health and safety is also an important part of the

audit and document review, along with

management systems. During audits, worker

interviews are carried out, providing a critical

addition to the meeting, facility evaluation and

documentation review. Interviewees are drawn

from a range of workers, including permanent,

temporary, subcontract labour, security, cleaners,

food preparation, etc. Interviewees are also drawn

from a pool of new workers in less skilled

positions, workers from various departments and

shifts, and workers of both genders.

Capacity-building

Telenor also focuses on awareness and capacity-

building activities, including internal training on

health and safety, and capacity-building in the

supply chain on topics related to relevant risks to

the SCP. Capacity-building focuses on continuous

improvement, selecting direct contracted

suppliers for training in critical risk areas to

enhance their capabilities.

Making Zero Possible

Telenor has implemented a set of operational

standards under the umbrella of Making Zero

Possible, designed to address the material

negative impacts and risks related to health and

safety. It includes areas such as road safety,

electrical safety, fire safety and working at height.

These apply to anyone who engages in high-risk

activities within the scope of their work for

Telenor.

In addition to the continuous processes described

above, that aim to reduce the likelihood of the

negative impacts and risks within the value chain,

there are also some specific initiatives where

Telenor has had additional focus during 2025.

Specific key actions in the reporting year

Health and safety Advancement Plan

In 2024, Management endorsed a plan to enhance

workplace safety standards and promote a

culture of safety and well-being throughout the

organisation. Throughout 2025, several steps

have been taken to advance Telenor’s Health &

Safety agenda, including review of Health & Safety

metric, targeted communication and

collaboration initiatives and work on behaviour. A

key milestone was the development of a Business

Impact Analysis Model to quantify the potential

impact of Health & Safety failures in Telenor's

business operations. A dedicated session for the

Group Management has been carried out to

promote awareness.

Road safety in Asia

Resources and efforts had been put into road

traffic accidents (RTA) reduction programs,

trainings, and uplift initiatives, in close

cooperation with Telenor's third parties, including

road safety trainings for high-risk functions,

safety checks for motorbikes used in operation

across the countries, and constant review of trips

and journey management to reduce the risks.

Telenor will continue these efforts and develop

initiatives to proactively reduce RTA as part of the

company's Safety Culture Maturity improvement

journey.

Human Rights and Labour Rights

Following the reported incidents in 2024, the

number of audits conducted in Asia has been

increased which have further strengthened

compliance and risk management. No new

incidents were reported in 2025.

Supporting children and youth working in

artisanal and small-scale cobalt mining

Child labour is commonly associated with mining

and recycling activities, while forced labour tends

to occur in manufacturing and raw material

sourcing. Vulnerable groups include migrant

workers and young individuals, who are

particularly at risk. Save the Children, The Centre

for Child Rights and Business and the Fair Cobalt

Alliance established the Child Rights Action Hub

DRC to jointly tackle child labour in cobalt

artisanal and small-scale mining (ASM) in the

Democratic Republic of the Congo (DRC). Telenor

has joined the initiative together with other JAC

members to support the expansion of the Hub's

activities through a three year pilot (2025–2027).

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126

Planned future actions

Advancing Health and safety in 2026

Telenor will continue to build on the efforts and

activities carried out under the Health and safety

Advancement Plan. Periodic assessments will

ensure alignment with relevant standards and

company policies, and efforts will continue to

encourage a culture of reporting and

collaboration across the organisation .

Addressing key material topics

Telenor will continue addressing key issues

related to supply chain sustainability such as safe

working conditions and conflict minerals, with

particular focus on workers and labour rights.

Human Rights Incidents in the value chain

In August 2025, a fatal accident occurred when

two employees of a field service subcontractor

were involved in a All-Vehicle-Terrain (ATV)

accident on route to a site, resulting in one fatality

and one injury. The incident has been investigated

as per Telenor's incident Guidelines, which include

understanding root causes and implementing

measures to mitigate negative impacts such as

strengthening site access practices and

continuing health and safety engagement and

audits.

Resources required to implement actions

Telenor has employees both in Telenor Group, at

the business area level and in the Telenor

companies who follow up on health and safety

and human rights. The Telenor companies have

established the roles and assigned the

responsibilities to ensure compliance with the

policies.

Cost related to initiatives as well as membership

fees paid to JAC, and costs of audits carried out

by JAC are considered to be part of the daily

operations. In the future, resources could include

participation fees for projects with NGOs or other

partners that address sustainability challenges

(such as child labour in mining and recycling) or

membership fees in industry initiatives to help

address challenges related to conflict minerals..

Engaging with value chain workers about

impacts

In an effort to gain insights into the perspectives

of value chain workers, Telenor uses several

methods, including comprehensive audits and

inspections, engagements related to the JAC, and

results from JAC worker voice surveys, which

provide valuable information. Additionally, Telenor

focuses on supplier and sub-supplier capacity-

building and training activities, capturing relevant

data to inform strategies (see section on

Monitoring Activities).

Audits and Inspections

Audits and Inspections remain the primary tool for

engaging with value chain workers, as they are

thorough and align with SA 8000 standards,

including interviews with marginalised groups.

Workers’ interviews are part of the audits and

inspections procedures described in detail under

the section Actions. Telenor performs a large

number of audits and inspections throughout the

year, across a number of sites, suppliers and

locations, primarily related to direct contracted

suppliers and their sub-suppliers. In addition,

Telenor performs 5 JAC audits and has access to

audits performed by other members, totalling

around 150 audits, covering various parts of the

upstream value chain.

The purpose of the audits is to ensure compliance

with all relevant agreements, standards and

processes. The interviews are conducted directly

with workers on the sites and cover topics such

as ensuring that workers have been trained

sufficiently and made aware of applicable

requirements, that they are paid in accordance

with laws and contracts, that they are aware of

relevant channels for reporting concerns and to

obtain feedback on the effectiveness of actions.

The requirement to follow up suppliers is set out

in the Third Party Risk Management Policy, as

described within the Policies section. It is the

responsibility of each Telenor company CEO to

ensure that the policy is implemented with a more

detailed manual in the company. Group and Asia

Compliance has a procedure in place for ensuring

policies have been adopted in the Telenor

companies.

External research

Furthermore, Telenor relies on consulting

research, particularly in the extractive value chain,

drawing insights from various organisations on

issues such as child labour.

Remediating negative impacts and

channels to raise concerns

Reporting channels

The Integrity Hotline is Telenor’s core grievance

mechanism. It is a confidential whistleblowing

channel intended for related questions and

reported concerns about potential breaches of

Telenor’s Code of Conduct, including relevant

laws, regulations and governing documents.

The service is accessible online to employees as

well as external stakeholders and is available 24

hours a day, seven days a week. It can

accommodate reports in local languages of all

Telenor’s markets. All queries and reports are

treated confidentially and with due respect to the

circumstances. Employees, suppliers and other

stakeholders are encouraged to use this channel

to speak up. One of Telenor’s Code of Conduct

principles is to “speak up” and Telenor does not

tolerate retaliation of any kind against those who

speak up in good faith.

The Integrity Hotline is made known to workers in

the value chain through audits and inspections

and is available on Telenor's website.

Remediation and follow-up

The process for following up on concerns

reported through the Integrity Hotline is described

in further detail within G1 Business conduct.

All serious incidents that may have caused or

contributed to a material negative impact shall be

reported and escalated by the concerned

informant to the relevant internal stakeholder. The

contract owner and responsible line, expert

function, and Group Policy owner must be notified

within 24 hours.

Any incidents involving Global Framework

Agreements Suppliers shall also be reported to

Telenor Procurement Company.

Local Supply Chain Sustainability (SCS) function is

responsible for overseeing that the incidents

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127

reported in digital incident/inspection/audit

management platform are handled satisfactorily.

Incident reporting and information gathering is

the first step of the process, where initial facts

and details relevant to the incident are collected.

Next, the loss potential and possible impact must

be defined, based on collected data.

Following this, a detailed investigation and

analysis is conducted. This includes performing a

root cause analysis to understand the underlying

issues and defining corrective and preventive

actions to address them. After the investigation,

systems are updated and experiences are shared.

Findings are recorded in a web-based incident

reporting system. The incident is closed once all

action items are completed, ensuring everything

is documented and resolved.

The depth of the investigation depends on the

incident's actual consequence and potential loss

rating. For all serious cases, an investigation team,

including relevant stakeholders, conducts the

investigation. The report is attached in the web

incident reporting tool and all steps are

documented.

Local SCS teams are required to establish a

process for ensuring that capacity-building/

training and awareness initiatives are in place

within the scope of the SCP.

When it comes to remediation, this is handled on

a case-by-case basis, aligned with the guidance

from UNGPs and OECD guidelines. In some

instances it may include financial compensation,

but for Telenor, the key focus is on learning from

such cases to prevent them from reoccurring.

Metrics


Child, underaged and forced labour	2025	2024
Findings of child labour (below 15 years)	0	0
Findings of underage labour doing hazardous work (age 15 - 18 years)	0	6
Findings of forced labour	0	21


Fatalities	2025	2024
Suppliers tier 1 and beyond involved in work for Telenor	1	0
Third parties involving members of public	0	2

Subsequent events

Two fatal incidents were reported by one of our

Asian operations after the end of the reporting

period. As these events occurred in early 2026,

they do not affect the safety metrics disclosed for

2025. However, given their seriousness, the

incidents are considered material subsequent

events. Telenor has initiated follow‑up actions in

line with our health and safety procedures.


Other value chain metrics	2025	2024
Capacity building of suppliers (man-hours)	39,383	18,823
Number of sustainability audits and inspections	1,020	929
Percentage of inspections and audits that were unannounced	66%	74%
Number of major non- conformities	316	327
Number of minor non- conformities	236	276
Close-out rate of non- conformities	96%	88%
Percentage of high risk suppliers that have been monitored	94%	99%
Reported number of lost- time injuries in the supply chain	40	N/A

Capacity building of suppliers in Grameenphone

had increased significantly in 2025, driven by

additional defensive motorbike riding and

emergency‑preparedness training.

Lost‑time injuries in the supply chain that are

captured through internal reporting process is

now formally incorporated into the non‑financial

reporting scope.

2025

128

REPORTING METHODOLOGIES

Telenor’s metrics related to health and safety

cover workers in the value chain, primarily

focusing on those employed by Telenor's direct

contract suppliers and their sub-suppliers,

particularly in high-risk activities and linked to

child and underaged labour in hazardous

working conditions. These metrics are not

validated by external bodies, but are based on

industry practices, including common industry

supply chain audits conducted through

Telenor’s JAC membership. These metrics are

captured through monitoring activities,

including audits and inspections, or incident

reporting. Because these methods are based on

sampled spot checks at a given time, they may

not provide a fully accurate picture or capture

all changes that occur outside the audit period.

However, they provide valuable insights and

highlight areas of improvements.

Child labour

Refers to a person below the age of 15 years

found working at any workplace for or on behalf

of Telenor.

Forced labour

Refers to documented instances where

individuals are compelled to work against their

will under threat of punishment or coercion.

Forced labour can also involve practices such

as confiscating workers' documents or

demanding payments from them, further

trapping them in exploitative conditions.

Underaged labour

Refers to a worker aged 15-18 involved in

hazardous work. Hazardous work is by its

nature or the circumstances in which it is

carried out, likely to harm the health

and/or be a safety risk to the worker. For

Telenor’s operations, this includes any work at

tower or construction sites, road transport,

manual labour and long working hours.

Fatalities Suppliers tier 1 and below: This metric

captures the number of work-related accidents

that cause loss of life. It includes accidents

occurring during work or production for Telenor

anywhere.

First tier supplier, or direct supplier, is defined

as any person and/or entity with a direct

contractual relationship with the Telenor

company and offering products and/or services

to the Telenor company. This includes any

manufacturer, vendor, contractor, consultant,

middleman, service or facilities provider, dealer,

distributor or other partner that is directly

cooperating with the Telenor company.

Lower tiers supplier is defined as sub-

suppliers to Telenor’s first tier suppliers.

Lost-Time Injuries involving supplier

employees or contractors. The metric

represents the number of reported lost-time

injuries (LTIs) among employees of Telenor's

supplier and contractors . Together with

fatalities in the value chain, and LTIs and

fatalities among Telenor's own employees, it

supports the Making Zero Possible ambition. A

limitation remains that not all LTIs in the value

chain may be reported, particularly less severe

cases, which could results in

underrepresentation of the actual incidents.

Major non-conformity

A major non-conformity is a significant issue

that poses a serious risk to the organisation or

its stakeholders. It often requires immediate

action to mitigate potential harm. It is a serious

breach of the SCP, potentially leading to life-

threatening conditions for workers or

individuals. Examples include breach of

minimum age requirements, forced labour,

severe accidents or prohibited business

practices. A major non-conformity will normally

be categorised as harmful to the workers

involved, the environment or detrimental to the

reputation of Telenor. A breach of national laws

will normally be classified as a major non-

conformity.

Minor non-conformity

A minor non-conformity is a less severe issue

that does not pose an immediate threat, but still

requires corrective actions. Addressing this

finding helps improve overall compliance. It

typically does not present a likely risk of harm to

the workers involved, the environment or the

reputation of Telenor. It can include lack of

awareness, lack of management attention,

incomplete records, missing safety signs, or a

one-time instance of forgetting safe working

practices.

Total number of audits and inspections

carried out

Audits and inspections are conducted to assess

compliance with safety standards and identify

potential hazards with the aim to identify areas

for improvement. Audits and inspections are to

be thorough, unbiased and shall reflect the

current state of safety practices and working

conditions. However, audits and inspections

may not capture all non-conformities, especially

those not immediately visible, or that occur

intermittently. They provide a snapshot in time

and must therefore be followed up by regular

meetings and dialogue.

Scope of the supply chain metrics

These metrics encompass data from the mobile

operators such as Telenor Norway, Telenor

Sweden, DNA, Telenor Denmark,

Grameenphone, Telenor Pakistan and Telenor

Towers.

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129

ESRS S4

Consumers and

end-users

Telenor's consumers and end-users are

typically subscribers of Telenor services

or users of subscriptions belonging to

others, such as employers or parents.

Freedom of expression and privacy are

key to the core business of Telenor.

Telenor is committed to protecting the

privacy of its customers and to creating

and maintaining secure and privacy-

friendly services that customers can use,

confident that their integrity and

personal sphere are being protected.

How Telenor makes an impact

Consumers and end‑users are central to Telenor’s

value chain because the company’s services may

impact people’s human rights. The topic is

increasingly important as digitalisation expands,

and also as authorities in some markets impose

e.g. network shutdowns or request access to user

data which can restrict freedom of expression,

privacy, and safety.

Key risks include undue authority requests and

demands, data breaches, cyberattacks and

misuse of personal information, all of which can

harm individuals and erode trust. Telenor works to

strengthen privacy, security and transparency,

allowing the company to position itself as a

trusted provider in complex digital ecosystems.

In 2025, Telenor continued its ongoing human

rights due diligence, including external

GNI‑aligned assessment, published transparency

reporting on authority requests, and rolled out

mandatory human rights training to all employees.

The company also refined internal processes to

manage privacy risks and engaged in dialogue

related to 2024 and 2025 network shutdowns in

Bangladesh and Pakistan.

Going forward, Telenor will continue

strengthening privacy frameworks, advocating for

rights‑based governance, and enhancing

safeguards that ensure secure and responsible

digital services for all users.

2025

130

Impacts, risks and opportunities (IROs)

Telenor has identified the following impacts, risks

and opportunities related to ESRS S4 Consumers

and end-users.


IRO		Relevance for Telenor	Value chain	Short, medium and long term
	Information-related impacts - Access to information, freedom of expression and privacy
-	Negative impact	There is actual negative impact to customers and end users when authorities request for network shutdowns/degradation and/or unduly request for Telenor to disclose customer data, resulting in limited access to information, freedom of expression, freedom of assembly and association, economic rights, privacy and/or safety.	= ↓	S, M
	Information-related impacts - Privacy
-	Negative impact	There is a potential negative impact on customers and end users if the supplementary governance measures currently in place to secure data transfers to, or access from, third countries prove insufficient. The impact increase with rapid negative geopolitical and regulatory changes, which could lead to loss of control over personal data, increased exposure to surveillance or misuse, and a reduced ability for individuals to exercise their rights, such as access, rectification, or objection.	= ↓	S, M
-	Negative impact	There is potential negative impact to customers and end users if their data is leaked or misused, due to fraud, cyberattacks and/or inadequate security and privacy measures which can lead to harm to the individual and their rights. Incorrect application of AI might amplify the impact.	= ↓	S, M
-	Risk	There is risk if customer’s and end user’s data is leaked or misused, due to fraud, cyberattacks and/or inadequate security and privacy measures which can lead to compliance breaches, administrative fines, and negative reputation. Incorrect application of AI might amplify the risk.	= ↓	S, M

Information-related impacts for consumers

and/or end-users

As the digital society evolves, more data is

collected from individuals, their devices and their

movements. The availability of unlimited storage

and the continued rapid development of data

analytics, automated decision-making, and AI

present both considerable opportunities and

considerable risks to societies, organisations and

individuals. At the same time, the ability to

connect and freely express opinions is under

pressure in many countries.

Telenor operates in markets where authorities

have been legally mandated to request for

network shutdowns or service degradation in

political situations, which can limit human rights

such as freedom of expression. Telenor's

compliance with such requests can restrict

people's ability to communicate, and in some

situations also impact their safety. Government

imposed network shutdowns also means loss of

revenue for Telenor.

There is a potential negative impact on customers

and end users if the supplementary governance

measures currently in place to secure data

transfers to, or access from, third countries prove

insufficient. The impact increases with rapid

negative geopolitical and regulatory changes,

which could lead to loss of control over personal

data, increased exposure to surveillance or

misuse, and a reduced ability for individuals to

exercise their rights, such as access, rectification,

or objection.

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131

As a telecom operator, Telenor collects

information and data related to individuals. This

data could be sensitive and could subject

individuals to harm in case of undue requests for

Telenor to disclose data, data misuse or a data

breach. R apid negative geopolitical and regulatory

changes could lead to increased exposure to such

harm. Data leakages and/or compromised data

can result in financial and security issues for

customers, partners and Telenor itself, including

costs to recover data, costs related to GDPR

compliance, and other costs of privacy breaches.

The nature of international communications

heightens the risk of data breaches and unlawful/

undue interception as data crosses borders.

Reference to other publications

As part of Telenor’s commitment to transparency,

the company has also reported on specific efforts

related to human rights challenges in Myanmar,

where Telenor had operations until the sale of

Telenor Myanmar was completed in March 2022.

See page on Human rights in Myanmar on the

Telenor corporate website.

Another publication which is available on the

website, is a summary of learnings and insights

from discussions with a high level human rights

expert forum which included focus on lessons

learned from Telenor's exit from Myanmar. The

forum, which concluded in 2024, discussed

human rights challenges and dilemmas to Telenor

in a global context.

Norwegian OECD National Contact Point final

statement on Telenor’s forced exit from

Myanmar

In November 2025, the Norwegian OECD National

Contact Point (NCP) published its final statement

in the case between the ‘Centre for Research on

Multinational Corporations' (SOMO) on behalf of

474 Myanmar-based civil society organisations vs.

Telenor ASA. Telenor published a response to the

NCP statement, disagreeing with several of their

conclusions. As to the nature of the adverse

human rights impacts covered by the case,

Telenor stated that “the NCP rightly places the

main responsibility for the grave human rights

violations in Myanmar with the military junta.

NCP further acknowledges the dilemmas faced by

Telenor following the military coup. Decisions

were taken under significant pressure from the

military regime and international sanctions, based

on the information available at the time. Telenor

disagrees that the efforts to protect the safety of

its local employees in Myanmar was not in line

with OECD Guidelines.

While acknowledging that Human Rights due

diligence should include all rights holders, when

faced with the brutal force of the military, Telenor

maintains that an employer cannot give

instructions which put employees’ lives at direct

risk, in line with internationally recognized

principles and the UN Guiding Principles on

Business and Human Rights (UNGPs). For

transparency, and until hindered by the junta,

Telenor published the number of authority

requests in Myanmar up until and including figures

for 2021.

Telenor had invested in, planned for, and would

have wanted to continue operating in Myanmar,

building infrastructure and providing millions of

customers with means of communications.

Telenor was forced to disengage, thus options for

remediation were limited.

Telenor has pursued all of the several remedial

actions defined in the public mediation MoU of

this case before the NCP, except one remaining

as addressed in Telenor’s response to the NCP

statement - to define a digital security relief

mechanism.

Telenor’s remedial actions include;

• Continued engagement with stakeholders and

rights holders, which included Telenor providing

Myanmar civil society representatives with

information about the specific actual and

potential risks associated with the digital eco-

system and the sale of Telenor Myanmar.

Telenor also initiated a Human Rights Expert

Forum to share learnings and insights.

• Conducting an independent ICT Eco-System

Study, funded by Telenor, to enhance Myanmar

civil society’s understanding of risks to users

from their digital footprints. A summary of this

study has been published by the NCP. The full

47-page version thorough expertise materials

was made available to the complainants

representing 474 civil society organizations for

further use with the rights holders.

• Revisiting Telenor’s assessment of risks to

former employees, to determine whether there

were any additional risks to be addressed.

• Telenor conducting an internal assessment of

lessons learned, including on how to have a

responsible market entry and exit, from their

work in Myanmar. This assessment was

informed by dialogue between Telenor and civil

society organisations in the context of the OECD

process.

• Creating lesson-sharing opportunities, based on

Telenor’s disengagement process in Myanmar

and especially with civil society and rights

holders in Myanmar as well as in other high-risk

regions.

• Following up on the implementation of the MoU

with regular (monthly) check-ins, with the aim to

reach a full agreement by the end of October

2022.

• Publishing of the MoU and joint statement: The

parties and the NCP published the text of the

MoU and a joint statement on the state of the

mediation process on the 28th of October 2022.

The parties also agreed to maintain

confidentiality on the mediation and any

additional information discussed.

Impact on strategy and business model

Exchange of ideas and access to information and

communication has been the foundation for

Telenor for 170 years. This is also visible in

Telenor's current purpose of "With you, for a

safer and smarter tomorrow". Responsible

business practice is at the core of Telenor’s

operations. The company's sustainability

ambitions are centred around making digital

connectivity greener, safer and more accessible.

In doing so, Telenor brings benefits to its

customers and creates long-term value for

society at large.

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132

Policies

Sustainability policy

Telenor’s Sustainability Policy addresses the

identification, assessment, management and

mitigation of material impacts, risks and also

opportunities of its business, and in relation to all

end-users. The policy implements the UN Guiding

Principles (UNGPs) on Business and Human Rights

and the OECD Guidelines for Multinational

Enterprises on Responsible Business Conduct, by

use of an internal kit of information and tools.

The sustainability policy seeks to ensure that

Telenor companies operate responsibly towards

society, including respect for human rights. It also

includes steps that must be taken to avoid the

occurrence of, or complicity in, human rights

abuses, in accordance with the previously

mentioned principles and guidelines, as well as

with the UN Global Compact and the Global

Network Initiative (GNI) Principles.

The policy applies to the operations of all Telenor

majority owned companies. Each Telenor

company board is accountable for adopting the

group policy and the highest individual

responsible for the implementation of the policy is

the local company CEO. The policy establishes a

starting point: where national law and

international human rights standards differ, the

company shall adhere to national law, while

seeking ways to respect international human

rights to the greatest extent possible. In

accordance with the policy, the company

communicates its human rights commitment

actively to external stakeholders.

The accountable policy owner for the

sustainability policy is EVP People, Sustainability

and External Relations. In alignment with the

UNGPs on Business and Human Rights, Telenor's

commitment to human rights is long standing and

embedded in its top governing document – the

Code of Conduct. This document also states that

in Telenor we foster a speak-up culture and

strictly prohibit retaliation against anyone who

raises concerns in good faith, ensuring ethical and

legal business practices.

Local authority requests - policies and

manuals

In every country where Telenor operates,

authorities have the legal power to access

personal data or network information. Authorities

typically need this information to solve crimes,

prevent security threats or find missing persons.

Telenor recognises the challenges of excessive

use of these powers.

The President and CEO of Telenor has instructed

the EVPs of Business Areas to ensure that

Authority Requests are handled in a professional

manner and in line with internationally recognised

principles, as set out in the UNGPs, the OECD

Guidelines for Multinational Enterprises on

Responsible Business Conduct and the GNI

principles. Local operators have implemented

authority requests policies and manuals to meet

the requirements in the EVP instructions and

additional requirements of local legislation.

Telenor Denmark will continue to follow the Group

authority request manual as guidance.

Telenor has a global Privacy Policy with high-level

requirements for all business areas and

subsidiaries. The policy outlines fundamental

principles for the processing of personal data and

general expectations for all Telenor companies,

regardless of their regulatory environments, in the

following areas:

• Formal allocation of responsibility and resources

for privacy management;

• Identification, management and reporting of

privacy-related risks;

• Implementation and operation of a system of

internal controls for privacy;

• Identification and management of external

regulatory requirements for the privacy area;

• Maintenance of up-to-date processing activity

inventories and documentation of legal basis for

the processing activities;

• Implementation and operation of key processes

related to management of personal data, such

as data protection impact assessments, privacy

by design, fulfilment of data subject rights and

data retention;

• Management of risks related to cross-border

transfers of personal data;

• Detection, prevention and mitigation of privacy

incidents;

• Management and monitoring of third-parties

processing personal data;

• Internal training and awareness related to

privacy;

• Management of threats to privacy caused by

algorithms and AI.

Telenor has a dedicated group function that

monitors the local compliance status and

implementation of its Privacy Policy through a

quarterly process that aggregates the policy

compliance status in each business area.

For the Asia business area, the privacy

compliance status is assessed and reported by

Telenor Asia. Each Telenor company has its own

privacy compliance function, which is locally

responsible for monitoring and reporting on the

status and performance of the Privacy Policy for

their company.

The policy owner of the Privacy Policy is the EVP

People, Sustainability and External Relations.

Telenor continuously develops good practice

guidelines for business areas and subsidiaries to

adopt and apply as they see appropriate. To

facilitate sharing of knowledge and good

practices across business areas and subsidiaries,

Telenor continues to facilitate privacy

communities, connecting privacy experts within

the group.

Cases of Authority requests

Telenor's internal process and governance in

relation to government requests are designed to

safeguard human rights. Telenor's membership in

the GNI provides shared learnings as well as the

means to build leverage in relation to regulatory

and legislative developments. Telenor also

addresses challenging cases by transparency as a

means of mitigation. The Telenor Integrity Hotline

includes human rights complaints.

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Processes and mechanisms related to

human rights

Respect and promotion of human rights are at the

foundation of how Telenor conducts business

across it markets, aligned with the company's

purpose of "With you for a safer and smarter

tomorrow". Telenor's human rights commitment

is stated in the Sustainability Policy.

Annual human rights due diligence

assessment

Telenor is using a Human Rights Toolkit to

perform an annual due diligence assessment of its

own work related to human rights. The toolkit is

based on methodology and terminology from the

UN Guiding Principles on Business and Human

Rights. The work related to human rights in

relation to consumers and end-users is part of the

toolkit. The annual assessment is further

described on page 112.

GNI independent assessment

Telenor is member of the Global Network Initiative

(GNI), a multi-stakeholder initiative to promote

and advance freedom of expression and privacy

rights across the technology ecosystem.

Approximately every three years, Telenor

undergoes an assessment performed by GNI,

covering respect of freedom of expression and

privacy in Telenor's governance, policies, due

diligence processes, stakeholder dialogue and

transparency activities.

The assessment process is done by accredited,

independent assessors who review materials and

interview employees to evaluate progress in

implementing the GNI principles. The process is

set to foster candid discussions and constructive

expert recommendations for continuous

improvement over time.

The GNI assessment process is confidential, in

order to allow for the review of internal, non-

public materials, including sensitive case studies

of government requests from countries around

the world. After assessments have been

completed, the GNI shares relevant information

about the process through its annual reports.

The GNI uses the findings for its multi-stakeholder

Accountability Committee and Board to

determine whether and how each member

company is ‘making good-faith efforts to

implement the GNI Principles with improvement

over time.’

Telenor has during 2025 worked with Deloitte as

an external assessor for an independent report to

be presented to the GNI Board during the first half

of 2026.

Yearly report of authority requests

Authorities have the legal power to access

personal data or network information, typically to

solve crimes, prevent security threats or find

missing people. Telenor recognises the challenges

of excessive use of these powers. Telenor

provides transparency as a mitigation, publishing

a yearly report on authority requests.

Trainings

Human rights training for employees, as well as

capacity-building and processes to pursue

continuous improvements, ensure sufficient

internal awareness of Telenor's commitments and

approach towards human rights, sustainability

projects, programmes and partnerships and

sustainability reporting.

Actions

Actions during the year

Annual human rights due diligence assessment

All major local companies in scope of the annual

human rights due diligence assessment

requirement have completed their assessments

and reported to Telenor Group, including

mitigations presented to management at the

relevant Telenor companies. Telenor Asia

supported the Asian companies in conducting the

process.

The 2025 human rights due diligence assessment

(HRDD assessment) requirement was set up as a

'light hand', for two main purposes. First, for the

business units to be able to benefit from the 2025

double materiality assessment (DMA), and the

impact assessments therein. Secondly, for the

business units to be able to finalise the 2025 HRDD

assessments, including formal local approvals,

already before end of year 2025. In this way the

full Telenor organization will be able to align

timewise the 2026 DMA and HRDD assessment

processes.

Risks reported as with high priority, and mitigation

measures, include but are not limited to the

following. Common prioritised areas, Nordics and

Asia: Privacy and data security, Supply chain

sustainability, Child safety online and Worker well-

being. In addition a Nordic prioritised area is

Diversity, equity and inclusion and Asia prioritised

areas are Authority requests for customer data

and network shutdowns, and Environmental and

infrastructure impacts.

The actions related to child safety online are

available on page 138. As to human rights and

Telenor’s forced exit from Myanmar, see

‘Stakeholder engagement and transparency’ on

page 162.

Telenor set up an external high-level forum of

experts to identify the best way forward for ‘AI

skills, safety and inclusion’ for both developers

and users. An external report with

recommendations was published in January 2025.

Quarterly privacy risk and policy compliance

assessment

Through a quarterly risk and policy compliance

assessment process, Telenor issues

recommendations to its companies on actions for

the implementation of the Privacy Policy and

related compliance risks. In line with Telenor's

governance model, decisions and execution of

actions is performed by each Telenor company

separately. Additionally, each Telenor company

has an appointed Privacy Officer, who is tasked

with local oversight of the Privacy Policy

implementation.

Shut-down of network in Pakistan and

Bangladesh

Local Telenor operators were linked to the

authority-imposed network shutdowns in

Pakistan and Bangladesh during 2025 and 2024,

with widespread and severe negative impacts for

end-users. Telenor has engaged in both local and

international dialogue in relation to relevant local

legislation to promote rights-based policy making

in relation to network shutdowns.

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Internal processes to identify actions and

necessary appropriate responses to respect the

rights of end-users at the time of network

shutdowns are in place, including local and group

dedicated resources and expertise from security,

legal, sustainability and human resources

departments. Local processes and resources for

crisis management can also be triggered.

Telenor’s membership in GNI provides shared

learnings and builds leverage in this regard,

facilitating both formal and informal advocacy

against network shutdowns as well as the

promotion of rule of law.

Key actions and expected outcomes regarding

authority requests for network shutdowns, in

summary;

• Active participation in the GNI (e.g. Representing

Telenor as Board alternate, Participation in

Policy working group)

• Shared learnings, joint leverage and Telenor

accountability, vis-à-vis the GNI, for continuous

improvement over time

• Advocacy (e.g GNI calling for improved

legislative framework and rule of law in

Bangladesh)

• Transparency, keeping stakeholders

continuously informed

Artificial intelligence actions

The rapid technological developments in artificial

intelligence, particularly generative AI, introduces

both new opportunities and increased risks

related to privacy. Telenor is committed to using

AI technologies in a way that is lawful, ethical,

trustworthy, and transparent way that creates

value for customers, employees, and society in

general. To support this, Telenor has defined a set

of Group-wide principles for responsible AI to

support the development and use of AI in a safe

and consistent way across the organisation.

In 2025, Telenor established a cross-disciplinary

global Responsible AI team, consisting of an

execution team with members from Business

Units/Business Areas, supported by experts from

relevant group functions. The Team is mandated

to strengthen Telenor's responsible AI capabilities

and governance as an integral part of the AI&I

strategy, with a clear set of deliverables.

Human rights training

The training on Telenor and Human Rights

released during 2024 was throughout 2025 rolled

out as mandatory for all employees. The course is

made available in English, Bengali, Danish, Finnish,

Norwegian and Swedish. The training is crafted

for all employees - irrespective of role, location, or

the services working with - to gain general

awareness about Telenor and Human Rights and

to see the respective tasks also from a Human

Rights point of view. And also for each and one to

see the business value of respecting and

promoting human rights .

Planned future actions

Telenor’s ambition is to continue to be a trusted

partner with strong brands by being transparent

and honest, playing by the rules, keeping

promises, being respectful and keeping personal

data secure. As to human rights Telenor launched

a human rights impact assessment (HRIA) on

Telenor Asia.

External expertise is leading the work which is to

be concluded before Summer 2026. The HRIA

covers Telenor’s business in Bangladesh,

Malaysia, and Thailand. The focus will be on salient

human rights impacts connected to technological

developments and changes in the business

environment and the aim is to identify and

prioritize Telenor’s human rights risks in these

markets, and to provide recommended actions to

address these risks. Telenor will also continue to

explore how an independent Myanmar digital

security relief mechanism could be established,

see more on page 131.

Targets

Telenor’s targets within this material topic do not

meet the full set of reporting requirements for

2025 in that they currently are not measurable and

outcome-oriented.

To ensure that Telenor meets its commitments in

relation to human rights, targets include to

continue to perform the annual assessments of

human rights due diligence and continue with the

quarterly privacy risk and compliance

assessments. This ensures risks and mitigating

actions are assessed locally every year, and

reported to group for coordination, joint learnings

and continuous improvement over time. Further,

as stated above, the GNI independent assessment

was performed in 2025, to be presented to the

GNI Board during the first half of 2026.

For the privacy area, the management of risks and

actions is a continuous effort in Telenor. The

company has not set any specific targets for

2025, but works systematically to assess and

manage compliance with Telenor's global privacy

policy.

Engaging with consumers and end-users

about targets and impacts

Telenor does not have a general group-defined

process for engaging with consumers and end-

users on all relevant issues at regular intervals.

However, Telenor works to understand

expectations to and consequences from its

operations through participation in various

networks and forums. Telenor engages with end-

user proxies to understand expectations and

assess impacts related to network shutdowns and

threats to freedom of expression and privacy,

mainly through participation in the GNI, a multi-

stakeholder forum where also proxies for users

are represented.

Remediating negative impacts and

channels to raise concerns

Telenor Group Internal Audit and Investigation has

the responsibility to manage the Integrity Hotline,

which is a confidential web-based channel for

whistleblowers. While customer concerns should

be handled at local customer service, concerns

about possible breaches of Telenor’s Code of

Conduct, including relevant laws, regulations and

Governing Documents can be logged in the

integrity Hotline. More information is detailed in

the Business Conduct section (G1).

Apart from that the responsibility for assessing

appropriate remedies to consumers on the basis

of negative impacts lies with the Telenor company

that provides the relevant service to the

consumer, Telenor does not have further

processes at the moment to assess the

effectiveness of measures taken.

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Entity-specific

Digital skills, inclusion and

online safety

Digitalisation and digital services have a

significant potential to improve people’s

lives, provide education, enable growth

opportunities and close inequality gaps.

However, technology can also create

inequalities and expose vulnerable

groups to harmful content. Telenor is

committed to empowering societies for

a safer and smarter tomorrow, by driving

connectivity and digital inclusion while

helping to build critical skills for an

inclusive digital future.

How Telenor makes an impact

Internet can expose children and other vulnerable

groups to harmful content and exploitation.

Telenor, as a provider of digital connectivity and

internet, enables access to a wide range of online

content and platforms, where also harmful

material may be accessible and exploitation

occurs . While Telenor does not create or host

such content, its infrastructure can inadvertently

expose children and vulnerable groups to online

risks, underscoring the need for robust

safeguards and responsible practices.

Telenor works to provide children, youth and

vulnerable groups with relevant digital skills, and

equip societies with connectivity. Telenor can also

protect individuals by implementing technical

safeguards restricting access to harmful content.

In 2025, Telenor delivered large‑scale digital skills

and online safety programmes across the Nordics

and Asia, partnering with organisations like

UNICEF and Plan International. About 1.2 million

people were upskilled. The company also

maintained a technical filter to block access to

child sexual abuse material and supported

helplines and awareness initiatives to strengthen

online safety.

Going forward, Telenor plans to upskill 800,000

people in the Nordics in digital wellbeing and to

digitally include 5 million in Asia by 2028. The

focus ahead is to provide training according to

skills needed, enhance resilience against online

risks, and contribute to technological progress

benefiting all users safely and responsibly.

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136

Impacts, risks and opportunities (IROs)

In 2025, the material impacts, risks and

opportunities related to digital skills, inclusion and

online safety were updated. They are presented in

the table and subsequent sections.


IROs		Relevance for Telenor	Value chain	Short-, medium- and long term)
	Harmful content and addiction
-	Negative impact	There is potential negative impact on children and other vulnerable groups to suffer from digital addiction and being exposed to harmful online content, also amplified by AI, which is offered by content providers through connectivity provided by Telenor.	↑ = ↓	S
	Connectivity, inclusion and upskilling
+	Positive impact	There is actual positive impact on individuals and society, particularly in Asia, by building networks and offering connectivity to remote places, providing digital inclusion & upskilling programs on several topics, and tools to restrict access to e.g., Child Sexual Abuse Material (CSAM) content.	↑ = ↓	S
	Trust through enablement
+	Opportunity	There is opportunity to build reputation and brand by promoting and enabling customers’ digital wellbeing.	↑ = ↓	M

The IRO process

Started in 2024, and continued in 2025, Telenor

screened its operations to identify the positive

and negative impacts, together with risks and

opportunities, within the area of digital skills and

online safety. The screening consisted of market

analysis from internal sustainability experts,

publicly available analysis from leading academic

scholars and official authorities and interviews

within non-governmental organisations (NGOs)

that are currently partners.

Harmful content and addiction

Internet is a space where children and other

vulnerable groups can be exploited. Telenor may

have negative impact on online safety for children

and other vulnerable groups by offering

connectivity to content providers and platforms

ere harmful content is accessed and exploitation

takes place.

Connectivity, inclusion and upskilling

Telenor is a significant contributor to digital

inclusion and upskilling individuals by providing

connectivity services and programmes.This is

especially evident in Bangladesh and Pakistan,

where connectivity can connect remote places,

transform lives and where the company provides

digital inclusion and upskilling through different

outreach programmes.

Trust through enablement

In the Nordic markets, digital addiction is a

growing concern, with potential negative impact

on e.g., mental health. Screen time management

is considered an increasingly desired skill. By

taking responsibility for digital wellbeing and offer

upskilling, Telenor can promote a balanced

relationship with technology, benefiting users and

the community. Such initiatives can enhance

Telenor's reputation as a responsible and socially

conscious player in the telecommunications

industry.

Impact on strategy and business model

As part of Telenor’s commitment to empowering

societies, the company strives to ensure digital

access for all, equip people with knowledge and

resources to operate effectively and safely, and

help foster a supportive ecosystem that can

address risks and grow digital resilience. These

areas have clear links to the current and future

commercial and technology agendas in Telenor

and are aligned with the aim of fostering a

learning culture.

The Telenor Global Sustainability Partnerships

with UNICEF and Plan International are key to

achieving the company’s ambitions. The target

beneficiaries for the partnerships are children and

youth and small and medium enterprises (SMEs)

led by youth and women. A special focus is being

placed on vulnerable and marginalised individuals.

Policies

The projects, programmes and partnerships

under the umbrella of digital skills and online

safety are governed by the Sustainability Policy.

The policy requires that sustainability efforts of all

Telenor companies should address defined

societal needs and be aligned with the overall

strategic direction of the company.

2025

137

The policy also outlines that efforts must be well-

defined, have clear goals, be aligned with

recognised partners and have proper reporting

and accounting mechanisms. The Sustainability

Policy is publicly available.

These requirements are further outlined in a

detailed governance framework communicated

to all local companies (Global Sustainability

Partnerships Guidelines). Included in the

governance framework are also principles and

definitions for designing, implementing and

reporting.

When drafting and updating the governance

framework, company-defined risks are

considered, in addition to impacts, opportunities,

and advice and needs from partners to ensure

that target groups' needs and societal needs are

met.

Telenor is also committed to the United Nations

Sustainable Development Goals, with particular

emphasis on education and inclusion. Telenor has

aligned its ambitions and commitments to

combat child sexual abuse material with the

industry organisation GSMA through the "GSMA

Mobile Alliance to combat Digital Child Sexual

Exploitation" since 2008.

The policies are anchored at Telenor Companies

CEO level and the Global Partnership Model

framework is anchored at the highest

management level

Targets

Access and connectivity

Telenor is committed to empowering societies by

driving connectivity and digital inclusion while

helping to build critical skills for a digital future.

For digital inclusion the first step has been

considered as providing access to data and

internet to users. In 2021, GSMA reported through

its State of the Mobile Internet Connectivity report

that 3.4 billion people did not use mobile internet,

despite living in areas with mobile broadband

coverage.

By the end of 2025, the share of active mobile

data users across Telenor Group reached 62%,

reflecting a modest increase compared to

previous years. However, this result fell short of

the target of 68% set for the 2022–2025

strategy period. The shortfall was primarily due to

lower data services uptake than expected in

Bangladesh.

The indicator is based on objective statistics from

the six business units with mobile operations,

based on actual usage. The movement in the

target is largely due to Grameenphone and

Telenor Pakistan. Tracking the progress and

effectiveness of this target is based on monthly

reports from the operations on mobile

subscribers and data users.

Training

In line with Telenor’s commitment towards the UN

Sustainable Development Goals (SDGs) Telenor

shall at a minimum of once per year assess

opportunities to undertake sustainability

programmes, projects and partnerships.

In 2017, Telenor set out to upskill 4 million people

by 2021. At the Capital Markets Day in 2022,

Telenor committed to continue to increase the

number of people trained and the target was set

to upskill another 6 million people by 2025

(baseline 2021). The target was developed based

on experience from resources required to run

similar programmes previously and the capacity

to expand in the markets Telenor operates.

Although the Group set target for the strategy

period was met in 2024, 2025 targets of people

trained were set per company:

• Telenor Norway: 50,000

• Telenor Sweden: 100,000

• Telenor Denmark: 26,000

• DNA: 70,000

• Grameenphone: 750,000

• Telenor Pakistan: 750,000

For more details, see table on page 139.

“Telenor’s Global Partnerships model” has been a

key instrument for target delivery. This model was

first adopted in 2018, with partners UNICEF and

Plan International, to develop and run

programmes and projects under the common

global theme ‘skills for a digital future’. The model

was renewed in 2022 and in 2024.

The aim of these partnerships has been to build a)

basic digital skills, b) advanced future skills and c)

online safety and security skills for children, young

people and vulnerable groups, focusing on

gender. In addition, SMEs are also a target group.

The projects under this umbrella are designed,

implemented and reported on in partnership by

the local Telenor companies and external

organisations. This includes target setting.

Telenor Group sets minimum requirements for

what constitutes as ‘training’ for the projects that

Telenor Companies design and implement.

Telenor Group also provides a governance

system, subject matter experts and partners

within the global partnerships model. The local

Telenor companies and external partners track

the overall progress and effectiveness of the

trainings, as required in the Sustainability Policy

and as agreed in the project descriptions. Telenor

Group receives reports quarterly, biannually and

annually.

In the coming strategy period, Telenor will

continue to operationalize its ambition to train

800,000 people in digital wellbeing in the Nordics,

and 5 million people trained in digital inclusion in

Asia, by end 2028.

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Actions

Actions during the year

Training in digital skills and online safety in the

Nordics

In 2025, Telenor ran projects providing training in

digital skills in all Nordic markets. The projects had

external partners participating in content

development, distribution and feedback loops,

such as NGOs, teacher’s organisations and leisure

organisations. Telenor companies offered

trainings to students, teachers and parents. In

addition, Telenor Norway offered trainings to the

leisure sector and DNA offered training to

immigrant youth and elderly. The skills acquired

were typically skills and knowledge within privacy,

safety, security, mental health, anti-bullying, social

skills and emotional skills.

In addition, Telenor companies continued to

explore digital wellbeing and skills to manage

digital addiction. An overall approach to

combatting digital addiction was co-developed

and then anchored across the Nordics. Telenor

Denmark, Telenor Sweden and DNA included

advise on conscious screen usage in their

trainings, while Telenor Norway is expected to

launch a dedicated training module in 2026. DNA

offered commercial products and services aimed

at enabling more conscious screen usage.

Telenor Norway and DNA made donations to

helplines as part of their efforts to enable further

dialogue and assistance. In all, the local Telenor

companies in the Nordics reached over 336,000

people with their programmes in 2025. The

projects had varying timelines, but all will continue

in 2026.

Training in digital skills and online safety in Asia

Grameenphone and Telenor Pakistan offered

trainings in digital skills in 2025. The target groups

included marginal communities, children in

schools, youth, parents, teachers, caregivers,

leisure organisations and the general population.

The projects had external partners participating in

content development, distribution and feedback

loops. Local NGOs, in addition to UNICEF and Plan

International, were important partners.

The skills acquired through the trainings have

been more focused on basic digital literacy and

safety skills, compared to the upskilling offered in

the Nordics. However, entrepreneurship trainings

have also been provided. In 2026, Grameenphone

will explore to offer training on screen time

management skills to the more mature user

groups.

Grameenphone’s training programmes reached

888,113 people in 2025.

In Telenor Pakistan, the projects faced

operational and logistical challenges which have

delayed the rollout of the training. This was

especially due to security issues in certain

regions. Following the divestment of Telenor

Pakistan, UNICEF will continue implementing the

projects to ensure sustained impact.

Combatting child sexual abuse online

In 2004, Telenor in Norway and the Norwegian

police authority co-developed a technical filter

that prevents users from accessing websites that

show defined child sexual abuse material (CSAM).

The filter has since been implemented by internet

service providers (ISPs) worldwide. According to

Interpol, the filter has become an important tool in

the fight against this crime. Blocking access

prevents re-victimisation of the children abused

and is expected to have a pedagogic stop effect

on users who may be about to commit a serious

offence by viewing or downloading illegal

material.

Interpol maintains and updates a list of domains,

or web addresses that disseminate known child

abuse material worldwide. This list is made

available to the Telenor companies through the

national police authorities. Telenor operating

companies then block access to these domains in

their networks. When users attempt to view the

page, they may be redirected to a ‘stop page’

containing information on the reason for the

redirection, links to legislation, where to complain,

etc. No criminal cases are generated due to users

being redirected from a domain containing child

sexual abuse material.

The filter is implemented in all Telenor operations

in the Nordic, with ongoing discussion for

implementation in Bangladesh in 2026. The filter

has become an important cornerstone in

Telenor’s response to one of the most negative

effects of our connectivity for children online.

Operating the filter that blocks the spread of child

sexual abuse material is an integral part of the

regular operations in the Nordics, as companies

continuously dedicate the necessary personnel

and technical resources. This includes regular

dialogue with local police authorities on technical

updates.

Telenor’s efforts to combat the creation and

dissemination of child sexual abuse material is

also found in the trainings offered on digital and

safety skills, where the dangers of grooming and

so-called self-generated CSAM are part of the

topics covered.

Planned future actions

Together with global partners Plan International,

UNICEF, and local partners, Telenor will continue

to explore trainings to match the changing needs

of the target groups and local societies. Telenor

will also seek to evolve its product portfolio to

better align with both the risks, impacts and

opportunities within this area.

Operating the filter restricting the spread of child

sexual abuse material and the cooperation with

local police authorities have become an integral

part of regular operations and is expected to

continue in the next strategy period. Telenor is

committed to continuing its efforts to combat this

crime by exploring new technology and

continuing the industry and regulatory

discussions, both in GSMA and in the EU.

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139

Training and upskilling projects in 2025

The table below summarises targets and results from the training and upskilling programs offered by Telenor and partners per market in 2025.


Telenor company	Programme objective(s) and main activities	Target Group	Targets for 2025	Results for 2025	Skills acquired

Telenor Norway	Provides training material on digital skills and child online safety for schools, leisure organisations and parents.	Children, parents, teachers, schools, municipalities, leaders in leisure activities	50,000¹	52,141	Skills within privacy, safety, security, mental health, anti-bullying, social and emotional skills

Telenor Sweden	Provides training material on digital skills and child online safety in schools. Distributes card deck games to schools and customers to generate dialogue. Engages children in creating content.	Children, parents, teachers, customers, employees	100,000¹	166,600	Skills within privacy, safety, security, mental health, anti-bullying, screen time management, social and emotional skills

Telenor Denmark	Provides training material on digital skills and child online safety in schools. Engages children in creating content. Provides material on cybersecurity (eBook and webinars) for SMEs.	Children in 4th-6th grade and their teachers. Small and medium-sized businesses.	26,000¹	27,816	Skills within privacy, safety, security, mental health, anti-bullying, screen time management, social and emotional skills. For SMEs: cyber security skills

DNA (Finland)	Provides training material on digital skills and online safety through gamification, card decks, webinars, school visits and events to multiple target groups.	Children, youth, teachers, immigrant youth, elderly, general population	70,000 ¹	90,048	Skills within privacy, safety, security, mental health, anti-bullying, screen time management, social and emotional skills

Grameenphone (Bangladesh)	Provides training on digital inclusion, literacy and online safety at multiple arenas such as courtyard sessions and community radio-based education, content in schools, online self-paced training, masterclasses and entrepreneurship boot camps.	Marginal communities, vulnerable groups, girls, women, children in schools, teachers, youth	750,000¹	888,113	Skills within privacy, safety, security, mental health, anti-bullying, social and emotional skills, STEM, entrepreneurship skills

Telenor Pakistan	Provides training material on digital skills and child online safety.	Adolescents, parents, teachers, caregivers, leisure organisations	750,000 ¹	15,651	Skills within privacy, safety, security, mental health, anti-bullying, social and emotional skills

¹In these projects some estimations are made. For more information, please see section on Reporting methodologies.

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Metrics

Access and connectivity

In 2025, Telenor had 62% active mobile data users in its customer base, as this is measured as closing

balance the end of year data 2025 is excluding Telenor Pakistan. Grameenphone had 58% active data

users at end of 2025. These metrics are reported regularly through a group-wide reporting system.

Training

The target set for the strategy period was reached in 2024 having upskilled over 12 million people since

the base year in 2021. In 2025, an additional 1,240,369 people received training in various digital skills.


Metrics	2025	2024	2023	2022	2021
Number of people trained in digital skills during the reporting year	1,240,369	8,175,456	1,087,608	1,314,040	1,688,290
Number of people trained in digital skills as of 31 December since base year (2021)	13,505,763	12,265,394	4,089,938	3,002,330	1,688,290
Active mobile data users (% of Telenor's customer base) ¹	62%	60%	58%	58%	58%

¹⁾The percentage of active mobile data users is end of year data, and discontinued operations are included in the figures until the year of disposal. Digi (former subsidiary in Malaysia) is included in 2021, dtac (former subsidiary in Thailand) is included in 2021 and 2022 and Telenor Pakistan is included until 2024.

REPORTING METHODOLOGIES

Telenor measures the number of people

receiving training within digital skills, and how

many customers who are active data users.

Combined, these two metrics constitute how

Telenor interprets and measures digital

inclusion.

Active data users

Data users counted are those defined as active

data users. To be defined as active, the user

must have a subscription and use at least 150 kb

of data during the previous three months.

Training

Training is defined as activities which provides

digital literacy, inclusion and safety & security

for defined target groups according to their

needs, societal needs and business needs in

Telenor’s markets.

The projects have different objectives,

timelines and different systems for feedback.

All projects but one (in Telenor Pakistan) have

integrated feedback loops, which provide

instant feedback from target groups. Other

projects have longer timelines, where results

come in later stages. Some projects are

designed as two-step models to provide

training for a defined primary target group (e.g.

teacher/parent/leader in volunteer sector) who

are to train the secondary target group (e.g.

pupils/children in the family or children in a

football club). Other projects can be hybrid or

digital.

Common for all reported projects are that the

designing, implementation and reporting shall

comply to these ten principles: 1) Shall build on

renowned external knowledge on digital skills

2) Shall reflect defined target group needs,

societal needs and business needs in Telenor’s

markets, 3) Shall be anchored with renowned

partners/experts, 4) Shall be tailored for one or

more defined target groups, 5) Shall teach

defined skills useful for the target group, 6) Shall

cover both hard and soft skills, 7) Shall be virtual,

in-person, hybrid and/or self-paced, 8) Shall be

based on clearly pre-defined learning outcomes,

9) Shall provide opportunity for feedback, and 10)

Shall sample annually if reporting is based on

estimates.

To reduce uncertainty in reporting based on

estimates, projects reporting such metrics are

required to apply transparent and documented

calculation methodologies and to perform annual

sampling with corresponding updates to

calculations. In 2025, this governance framework

contributed to overall good data quality.

However, improvement areas were identified in a

number of projects in Asia. In response,

corrective and mitigating measures have been

applied, and governance requirements have been

further strengthened. Work to improve project

governance will continue in 2026.

2025

141

Governance

Governance involves the application of Telenor’s

principles and processes to create value for the

company and our stakeholders. Responsible business

conduct - anchored in high ethical standards and a

robust anti-corruption policy - lies at the core of

everything we do. Privacy and data protection are, of

course, fundamental to our operations, alongside a

strong commitment to cyber security. We also dedicate

considerable effort to maintaining a responsible supply

chain, upholding a policy of zero tolerance towards

forced and child labour.

2025

142

ESRS G1

Business conduct

Corruption poses significant challenges

to global economic and social progress

as it undermines fair competition and

erodes confidence in the institutions and

public sector. This adversely affects

sustainable development and

disproportionately impacts vulnerable

communities. Telenor promotes

whistleblower protection, maintains zero

tolerance for corruption and bribery, and

upholds high standards for partners and

suppliers through comprehensive due

diligence, investigations, and audits to

manage and reduce risks.

How Telenor makes an impact

Business conduct is essential across Telenor’s

entire value chain, influencing how the company

manages ethical expectations from upstream

suppliers, internal operations and controls, and

downstream customer‑facing activities.

The main risk is that employees, suppliers and

other business partners fail to incorporate

appropriate anti-corruption programs, particularly

in high-risk markets. This can result in theft,

litigation, loss of trust and reputation, or loss of

contracts or business opportunities. Telenor

works to raise standards for business conduct,

and there is potential positive impact on societies,

business partners and their supply chains,

especially in Asia.

In 2025, Telenor strengthened its integrity

framework through 100% completion of

mandatory Code of Conduct training and zero

recorded cases of corruption or bribery. The

company also enhanced its governance approach

by integrating responsible AI requirements into

supplier agreements.

Going forward, Telenor will continue to improve

supplier oversight, strengthen anti‑corruption

capabilities and further embed responsible

business conduct processes across global

operations to support long‑term resilience and

trust.

2025

143

Impacts, risks and opportunities (IROs)

The material impacts, risks and opportunities

identified for business conduct in Telenor are

presented below.


IROs		Relevance for Telenor	Value chain	Short, medium or long term
	Corporate culture
+	Positive impact	There is potential positive impact on societies, business partners and their supply chains, especially in Asia, as Telenor aims to raise standards for business conduct where we operate.	↑ = ↓	S
	Corruption and bribery, and management of relationship with suppliers
-	Risk	There is a risk that employees, suppliers and other business partners in our value chain don’t adhere to Telenor’s high standards on governance and compliance and are failing to incorporate appropriate anti-corruption programs. This can result in theft, litigation, loss of trust, loss of contracts and business opportunities, and damaged reputation.	↑ = ↓	M

Corporate culture

The company strengthens corporate culture by

promoting robust governance practices and

addressing risks related to fraud and corruption

among its partners.

Telenor encourages portfolio companies to adopt

clear accountability frameworks, with defined

roles and responsibilities at every organisational

level. This approach improves operational

transparency and decision-making, strengthening

stakeholder trust—including investors,

customers, and regulators.

Corruption and bribery, and management of

relationship with suppliers

Failure by employees, suppliers, or business

partners to uphold Telenor’s governance and anti-

corruption standards can expose the company to

significant operational, financial, and reputational

risks.

Strict policies and guidelines require suppliers to

comply with anti-bribery and corruption (ABC)

standards. Through ongoing global evaluation and

monitoring of its business partners, Telenor

enforces stricter compliance measures,

effectively mitigating fraud and corruption

risks.This proactive stance supports a culture of

integrity and accountability.

Policies

Telenor’s governance framework is built on

robust ethical principles, enhanced transparency,

and a commitment to accountability. These core

values are systematically integrated into the

Group’s policies and operational procedures.

Code of Conduct, Anti-Corruption Policy and

Supplier Conduct Principles

The Code of Conduct reflects Telenor’s core

values and sets expectations for responsible

behaviour. It covers key areas including anti-

corruption, sanctions, human and labour rights,

climate, competition, confidentiality, conflict of

interest, financial integrity, fraud, privacy, and

workplace environment. The Code is owned and

approved by the Board of Directors and serves as

the foundation of our corporate culture.

The Anti-Corruption Policy complements the

Code, outlining Telenor’s Anti-Corruption

Compliance Programme. Updated in 2023, it

aligns with international standards, such as the

Foreign Corrupt Practices Act and UK Bribery Act,

and best practices and applies across all business

operations.

The Supplier Conduct Principles (SCP) outline

minimum standards for all direct suppliers and

partners of Telenor. Board-approved, the SCP

aligns with Telenor’s Code of Conduct and

prohibits corruption, bribery, and facilitation

payments. Suppliers must also ensure their

subcontractors comply via contractual terms.

In 2025, Telenor introduced contractual

provisions on responsible AI for inclusion in its

Global Framework Agreements (GFA),

establishing baseline requirements for ethical AI

use in sourcing, partnerships, and other AI-related

engagements.

2025

144

Communication of policies

Policies are communicated through both external

and internal channels and are made publicly

available online to promote transparency and

accessibility.

Telenor's primary awareness initiative is the

mandatory annual Code of Conduct training for all

employees. Each employee is required to

complete a comprehensive, annually updated

eLearning programme before signing the Code of

Conduct. This training encompasses capacity-

building, dilemma-based learning, and covers key

policy topics, alongside other awareness-raising

activities relevant to operational contexts. This

ensures that employees are well-prepared to

handle complex ethical situations.

Top management monitors training completion to

ensure consistently high participation rates. In

2025, the completion rate reached 100%.

Actions

Training and awareness

In addition to the annual Code of Conduct

training, targeted Anti-Corruption (AC) eLearning

modules are delivered throughout the company.

In-class training sessions are also organised for

specific target groups with varying risk profiles on

a rotational basis. In 2025, Group Compliance

provided tailored in-class AC training for top

management.

To further support the organisation and the

development of a culture of high integrity, an

Anti-Corruption Handbook is readily available to

all staff. This handbook offers practical guidance

across a wide range of risk areas, reinforcing the

principles outlined in the training and supporting

responsible decision-making throughout the

organisation.

A standardised methodology for identifying high-

risk functions was introduced in 2024 and has

been consistently applied throughout 2025.

Functions with elevated exposure to corruption

and bribery risks include procurement, sales,

government relations, and market expansion.

These areas are subject to targeted training.

To find the latest percentages of functions-at-risk

that are addressed by Telenor's training

programmes, please refer to the overview on the

right side of this page.

Corporate culture evaluation

Telenor promotes and evaluates its corporate

culture through leadership commitment, training,

and annual surveys. The Integrity Index, derived

from the Employee Engagement Survey,

measures perceptions of ethical behaviour and

speak-up culture. Results are monitored each year

at both global and local levels. The Integrity Index

represents the highest scores in the EES survey

and has remained consistently at high levels when

compared to external benchmarks.

Reporting mechanisms and investigations

Telenor maintains robust mechanisms for

identifying, reporting, and investigating concerns

related to business conduct, including corruption

and bribery.

Integrity Hotline

The Integrity Hotline is a confidential reporting

channel for concerns related to potential

breaches of Telenor’s Code of Conduct,

applicable laws, regulations, or other governing

documents. It is accessible online to employees

and external stakeholders, supports reporting in

local languages across all Telenor markets and

ensures confidentiality. Telenor actively

encourages employees, business partners, and

other stakeholders to speak up through this

channel.

Group Internal Audit and Investigation (GIAI)

Telenor addresses allegations or incidents of

corruption and bribery through a structured

process led by GIAI. This function oversees the

Integrity Hotline, assesses and investigates

reported breaches of the Code of Conduct,

prepares fact-based reports and recommends

remedial actions to strengthen internal controls

and processes. GIAI operates independently from

management and is responsible for prevention

and detection, ensuring objective investigations.

Its certified professionals, trained through the

Association of Certified Fraud Examiners (ACFE),

follow structured processes aligned with EU

Directive 2019/1937.

Speak Up Culture

At Telenor, promoting a speak up culture is

central to our ethical standards and business

integrity. We encourage employees and external

stakeholders to report potential breaches or

misconduct, as early action is key to preventing

wrongdoing. The Integrity Hotline provides a

confidential and anonymous way to raise

concerns via a secure inbox.

Protection for whistleblowers is a fundamental

principle of our Code of Conduct—retaliation is

strictly forbidden. Confidentiality is maintained

unless a report is made in bad faith, with intent to

harm or interfere. Concerns regarding business

conduct, including issues like corruption and

bribery, are managed through these established

mechanisms. Regular awareness training from

GIAI and Compliance reinforces the significance

of whistleblowing as part of Telenor’s culture.

Reporting to governance bodies:

The implementation status of the Anti-Corruption

Compliance Programme, along with statistics on

reported concerns, actions taken, and outcomes,

is communicated to management and the Board.

Metrics

Bribery and corruption metrics

The number of reported incidents of corruption or

briberies are presented in the table below.


Incidents of corruption or bribery	2025	2024
Number of convictions for violation of anti-corruption and anti-bribery laws	0	0
Amount of fines for violation of anti-corruption and anti- bribery laws	0	0

Functions at risks

The proportion of specific functions-at-risk

addressed by training programmes within Telenor

Group in 2025 is 82%.

2025

145

Management of relationship with

suppliers

Policy to prevent late payments to SMEs

The existing policy framework requires payments

to be made in a timely manner as a general

obligation. Measures to prevent late payments

with special attention to small and medium-sized

enterprises ( SMEs) are currently not addressed.

Risks and impacts related to supply chain

Telenor's commitment to responsible business

conduct extends to its suppliers and business

partners through the implementation of the

Supplier Conduct Principles and the Third Party

Risk Management Policy framework. Telenor

operates both local and global supply chains,

working with more than 13,000 suppliers. The

principal supplier categories include construction,

installation and upgrade of network and

infrastructure, marketing and services, devices

and equipment, information systems and IT.

These relationships involve manufacturers,

contractors, consultants, service providers and

others.

Within Telenor companies, supply chain

governance is overseen by dedicated

procurement teams in each market. At the global

level, Telenor Procurement Company (TPC) is

responsible for establishing and managing Global

Framework Agreements (GFAs) that may benefit

multiple markets.

Integrity Due Diligence (IDD) of potential suppliers

is an essential part of the procurement process,

as detailed in the Procurement Policy and Third

Party Risk Management Policy. The IDD process

evaluates such risks as sanctions, human and

labour rights violations, prohibited business

practices, health and safety, climate, privacy and

security. Local teams conduct risk assessments

for local suppliers, while TPC handles

assessments for global suppliers, with support

from subject matter experts as needed.

Telenor companies are responsible for

implementing mitigation measures and for

monitoring their respective suppliers. At the

global level, TPC holds regular meetings to review

key suppliers' sustainability performance. Group

Sustainability oversees suppliers through regular

audit and control activities. Further information

can be found in under the material topic Workers

in the value chain, see more details on page 122.

Environmental criteria in the selection of

suppliers

To reinforce its commitment to sustainability,

Telenor requires all major suppliers to establish

science-based targets (SBTs), preferably

validated through the Science Based Target

initiative (SBTi), prior to contract finalisation. If

these requirements cannot be fulfilled, a waiver

for the SBTs must be obtained and approved at

the Executive Vice President level before any

contract is signed. This policy is applicable to both

new contracts and contract renewals.

Social criteria in the selection of suppliers

Currently, there are no specific procurement

criteria for selecting suppliers based on social

indicators. However, if risk assessments identify

any red flags and risks relating to social matters,

that cannot be adequately mitigated, the supplier

will not be selected.

For certain strategic, large-scale contracts

involving comprehensive procurement processes,

sustainability criteria and scoring are applied.

These may include the extent of external

commitments, progress on health and safety

targets, diversity and inclusion, and transparency

practices.

REPORTING METHODOLOGIES

Number of convictions for violation of anti-

corruption and anti-bribery laws

If a court of law or other authoritative body has

issued a judicial ruling that a Telenor employee,

while acting on behalf Telenor, or a company

controlled by Telenor, has violated anti-bribery

or anti-corruption legislation, this must be

reported to headquarters. The total number of

such incidents occurring within the report

period shall be included in the report.

Total fines for violation of anti-corruption and

anti-bribery laws

This represents the aggregate level of fines

arising from convictions for violation of anti-

corruption or anti-bribery legislation, as

imposed by a court of law or any competent

authority during the reporting period. All fine

amounts must be reported, with no minimum

threshold applicable.

Percentage of training coverage for at-risk

functions

This percentage shows how many employees in

high-risk roles completed specific anti-bribery

and corruption training during the reporting

period, compared to the total number of

employees in those roles. Each Telenor

company documents which functions are

considered high-risk and provides the

appropriate training. The collected data must

be reported to headquarters.

2025

146

Entity-specific

Cyber security

Telenor prioritises security as the

foundation of its operations, aiming to

lead in cyber security and fraud

protection for connectivity services

while protecting society and individuals

in their digital lives. Cyber security

protects against threats such as

unauthorised access, data breaches and

service disruptions. Telenor has a

holistic, risk-based approach to enhance

security across all aspects, with global

collaboration among experts.

How Telenor makes an impact

Cyber security is essential across Telenor’s entire

value chain; Down-stream threats to customers

are becoming more sophisticated, Telenor assets

in a broad understanding must be protected, and

upstream supplier collaboration are essential due

to dependencies across systems and networks.

There is a risk that cyber-attacks could cause

service disruptions and information leaks,

potentially resulting in legal liabilities and

reputational damage for the company. At the

same time, by proactively addressing digital crime

and providing innovative security solutions,

Telenor can enhance its reputation and business

opportunities, while also mitigating the increasing

negative impacts that frequent and severe

cyberattacks have on customers, end users, and

critical societal functions

In 2025 - and apart from the specific incidents for

Telenor companies reported below -Telenor

faced no company-wide critical cyber security

incident. Security maturity continued to be

improved through targeted upgrades of security

controls in technical systems, way of work,

documentation and competency development.

The company also strengthened its cyber defence

capabilities by expanding services for enterprise

customers and deepening threat‑intelligence

collaboration with industry partners. These

initiatives supported a risk‑based governance

model covering both internal systems and

third‑party suppliers.

Going forward, Telenor’s key cyber security

priorities are to embed security into all systems

and processes from the outset, strengthen

resilience against increasingly advanced cyber

threats, and enhance the robustness of the

broader ecosystem and value chain to remain a

trusted partner for customers and society.

2025

147

Impacts, risks and opportunities (IROs)

Telenor has identified the following risks,

opportunities and negative impacts related to the

entity-specific material topic of Cyber security.


IROs		Relevance for Telenor	Value chain	Short, medium or long term
	Service disruption and information security breaches
-	Negative impact	There are actual negative impacts on the customers, end users and society due to cyberattacks being more frequent and severe, resulting in our services possibly being lost or degraded, affecting critical societal functions.	↑ = ↓	S, M, L
-	Risk	There is a risk that cyber-attacks result in service disruptions and information leakages, which further may lead to liabilities and negative reputation.	↑ = ↓	S, M, L
	Cyber security solutions and services enabling digital trust and commercial value
+	Opportunity	There is opportunity to increase reputation and business by preventing effects of digital crime by providing B2C, B2B and society at large with products, services, programs, strategic partnerships, new technology, expert know-how, innovative research, and raise awareness.	↑ = ↓	S, M, L

Service disruption and information security

breaches

Digital threats are escalating, manifesting in cases

such as cyberattacks, disinformation campaigns,

service disruptions, information leaks and can be

part of hybrid warfare.

Cyber attacks can disrupt services and lead to

personal data breaches. These types of incidents

can have serious consequences, including legal

liabilities, loss of customer trust and damage to

the company's reputation.

Cyber security solutions and services

enabling digital trust and commercial value

Telenor is a trusted partner in the operation of

critical infrastructure, focusing on fostering a

robust security culture, ensuring transparency

with stakeholders, enhancing physical security of

assets and bolstering capacity for emergency

preparedness and incident response.

Harm to customers and society resulting from

cyber incidents and attacks

Telenor continuously assesses the landscape of

different threats, including cyber security attacks.

This provides insights into potential cyber security

incidents. Inputs from partners and analyses of

incidents are used to evaluate the likelihoods for

attacks at Telenor's assets as well as relevant

incidents for our suppliers/partners and

customers. The ability to protect and respond to

such attacks is used in the evaluation of potential

impacts and to consider Telenor's security

maturity levels. The combination of likelihood and

impacts is used for estimating risks related to

cyber security incidents.

Policies

The scope of the Security Policy is business

security, covering information security, physical

security, external fraud management, personnel/

travel security and crisis management.

The policy defines principles and overall

requirements to safeguard Telenor's operations,

assets, services, customers and information from

security risks and threats.

Key principles include:

• Security in everything: Ensuring security

awareness at all levels, regular training, and

integrating security into daily operations.

• High security standards: Implementing security

measures according to recognised standards

and best practices.

• Customer protection: Ensuring customers are

protected in their digital lives and maintaining

Telenor's reputation as a trusted partner.

• Security by design: Integrating security in all

business aspects and applying principles of

security by design and defence in depth.

• Emergency preparedness: Ensuring effective

incident and crisis management processes.

The policy also outlines specific requirements in

various areas according to ISO/IEC 27001, 3GPP/

ETSI and other international security standards.

Supporting manuals and guidelines provide more

specific guiding and requirements. The policy is

owned by the EVP & Chief Technology Officer and

approved by the President & CEO.

2025

148

Security postures within Telenor companies are

evaluated on a regular, annual basis and the

findings are reported to the Board. This is part of

Telenor security governance defining roles and

responsibilities across the Telenor units. The

security assessments are also included in the

enterprise risk evaluations, encompassing

relevant risks from the perspectives of both

customers and suppliers.

Telenor Group Security Policy is available online

on Telenor.com.

The scope of the Security Policy includes

protecting Telenor assets as well as the

company's customers and engagements with

partners. As Telenor provides critical services,

governmental agencies are among key

stakeholders, in addition to customers and

partners.

Targets

In this annual report, ambitions and priorities

within cyber security do not fully comply with the

CSRD requirements when it comes to measurable

outcome-oriented targets. However, cyber

security remains a priority area for Telenor.

Telenor's Security Strategy Execution Programme

is a structured framework designed to elevate the

security maturity of Telenor companies. This is

executed according to the security governance and

includes tools, reporting templates, meeting

venues, personnel and methodologies. The

programme drives security initiatives forward by

setting company targets and facilitates structured

dialogues about risks, vulnerabilities, priorities and

necessary mitigations. Implemented security

controls are also validated by assurance initiatives

such as penetration testing. The programme

establishes a common language for discussing

security risks, plans, priorities and status. This is

one of the ways in which effectiveness against

priorities and ambitions is tracked.

Improvement of business security in Telenor is

followed up by defined processes, including the

Security Strategy Execution Programme. Status is

reported quarterly to Telenor executive arenas to

track efficiency of measures.

Objectives for internal metrics are set and

approved by relevant management levels,

including Board for the overall security

improvements. For 2025, the internal

performance assessment targets include security

maturity, insider risks, third-party security risk

management and ransomware recovery

advancements.

As Telenor companies operate in different

markets, manage different assets and provide

varying offerings, risks may differ. This is

considered when improvement actions are

planned and executed.

Telenor has set the following security ambitions:

• Truly embedding security into systems and

processes from the start. In particular, this key

for technologies like Generative/Agentic AI,

sovereign cloud-native and autonomous

networks. This will improve overall security

built on principles like defendable architecture

and measured through Telenor’s security

maturity process.

• Proven resilient operation leveraging effective

proactive and reactive security controls. In view

of cyber attacks becoming more advanced,

Telenor is evolving its controls and way of work

to protect, respond and recover. Cyberattacks

can disrupt services and lead to personal data

breaches, which can have serious consequences,

including legal liabilities, loss of customer trust

and damage to the company's reputation.

• Secure and robust ecosystem and value chain.

Telenor aims to be a trusted and preferred

partner for customers and partners across all

segments by leading the way with state-of-the-

art security and fraud protection in connectivity

services. By leveraging expert knowledge,

innovation, new technologies and strategic

partnerships, Telenor has the opportunity to

establish leading cyber security offerings and

protect assets, effectively thwarting digital

crime attempts.

The Security Strategy Execution Programme sets

security improvement targets for individual

companies with milestones according to local

business risk assessments and net effect of

improvement actions. This also considers inputs

from governments, such as when translating EU

NIS2 directive into national laws.

Action

Continuous and on-going actions

Telenor is continuously enhancing security

capabilities to prevent and mitigate a range of

threats. The company can swiftly detect and

respond to unwanted activities and is building

resilient networks based on a Telenor-developed

defendable architecture framework. This

framework includes robust design principles,

preventive controls, monitoring and detection,

vulnerability management and incident

management and response. Additionally, Telenor's

Security Strategy Execution Programme is a

structured framework designed to elevate the

security maturity of Telenor companies. This

framework includes tools, reporting templates,

meeting venues, personnel and methodologies. In

addition to assessing Telenor systems, suppliers

are also assessed and considered for the overall

risks. Several Telenor companies have obtained

ISO 27001 certification as an internationally

recognised confirmation of security controls

implemented.

Telenor is an active and contributing member in

national and international security forums such as

the Information Security Forum (ISF) and the GSM

Association Fraud and Security Group (FASG),

working to protect network and customer data

against attacks, fraud and crime. In these forums,

Telenor provides strategic input, shares

intelligence and builds responses.

Improving or maintaining security risk levels

requires continuous work across all the security

controls defined in the policy and the security

maturity model. Actions are part of the plans for

each of the relevant Telenor companies where

global scale and scope benefits are realised in

ways such as Global Frame Agreements, best

design guidelines and expert communities.

Actions during the year

Telenor continue to protect customers by

reducing the amount of security attacks and fraud

attempts hitting customers in different markets.

Telenor Cyberdefence has scaled up offerings to

the enterprise market for as a cyber security

service provider.

2025

149

Three of the main corporate initiatives include

insider risks, third-party security risks and

ransomware recovery. These were defined

according to the initial risk assessments. Regular

assessments and focused audits/testing have

also been conducted. Some of these involved

external security testing specialist companies.

Guidelines and implementations of cyber security

controls have been followed up through 2025 in

Telenor companies. Expert training is run to

strengthen competency of key persons across

the Telenor companies and mandatory security

case is part of the annual Code of Conduct for all

employees.

One Security - global action plans

Telenor security experts specialise in various

domains, including cyber security, telecom

network security, digital services, physical

security, security intelligence, service fraud,

communication and security awareness.

Telenor has global expert communities, covering

all companies, to share recent insights and best

approaches. There is collaboration with multiple

partners, including Telenor's system and service

suppliers, industry forums, international security

arenas, public agencies and customers. This

collaboration is driven by the global nature of the

threat landscape, which necessitates insights that

are applicable across industries and countries.

Telenor actively shares threat intelligence with

partners in both the private and public sectors to

mutually enhance the maturity and capabilities

within the markets where Telenor operates.

The goal is to foster greater transparency, assist

others in building expertise and strengthen

collective digital resilience.

Actions and resources in relation to material

sustainability matters

Resources, including financials, are embedded in

the overall business planning

Metrics

Granular metrics

Metrics are defined for internal setting of targets

and following up progress on execution. These

include overall maturity metrics as well as other

specialised metrics in areas such as attacks

prevented, supplier incidents, awareness and

customer-specific outcomes, and are adapted to

the specific business for each of the Telenor

companies.The granular metrics are reported to

relevant management levels and also used for

performance assessments of Telenor managers.

Incidents, certification and training

For 2025, the following key metrics are included in

the annual report to show overall status for the

cyber security area:


Metric	2025	2024
Number of critical cyber security incidents which occurred in Telenor and reported to local authority according to local legislation	11	11
Percentage of customers affected by privacy/data breach	0.29%	N/A
Percentage of main Telenor companies which possess ISO 27001 certification	35%	31%
Percentage of employees having completed expert security training	1.25%	1.39%
Percentage of employees completed information security training in Code of Conduct	100%	N/A

A closer look at the metrics

The number of critical cyber security cases is on

the same level for 2025 as for 2024. For 2025, all

reported customer‑impacting incidents captured

under this metric occurred within the Nordic

region. When assessed relative to the customer

base in the Nordic region, this corresponds to

approximately 2.3% of customers affected. When

assessed against Telenor’s total customer base,

the corresponding figure is 0.29%.

Customers may be impacted by privacy‑related

events as well as other security or operational

incidents, such as service availability or integrity

issues. All incidents were handled in accordance

with established incident response processes,

including corrective and preventive actions aimed

at reducing likelihood and potential impact. Where

applicable, incidents may be subject to regulatory

oversight, including potential fines or other

supervisory measures

Advanced cyber security training is delivered

through defined, expert-level courses organised

into specialised learning tracks, designed to build

deep competence in specific security domains.

The metric is based on Telenor’s internal learning/

training system logs and counts employees who

have successfully completed all mandatory

sessions and completion requirements for their

selected track. Most tracks are delivered by

external training partners and can include training

aligned to ISO/IEC standards and frameworks, as

well as preparation for professional certifications

(e.g., CISSP, CISM), reflecting the specialised

nature and higher intensity of this training

compared with general awareness programmes.

General security awareness is part of the Code of

Conduct metric.

2025

150

REPORTING METHODOLOGIES

Scope for the metrics

Metrics 1 and 3 below are measured across

the main majority-owned Telenor companies;

Telenor Norway, Telenor Svalbard, Telenor

Denmark, Telenor Sweden, DNA, Telenor

Pakistan, Grameenphone, Telenor Linx,

Telenor Connexion, Telenor Maritime, Telenor

Towers, Telenor Shared Services , Telenor

Cyberdefence and Telenor HQ. Metric 2 is

measured on the same Telenor companies as

for metrics 1 and 3, except Telenor Linx and

Telenor Shared Services as these 2

companies do not have end-customers. The

last 2 metrics involve all employees.

Critical cyber security incidents (1)

Authorities in each country set requirements

and expectations regarding reporting of

critical incidents within defined timelines. This

also implies that the level of criticality that

triggers reporting is decided by the relevant

governmental agencies.

The number of critical cyber security incidents

may be an indicator for the threat exposure

and the security maturity (proactive/reactive

controls) of an organisation. This is relevant for

an organisation's internal assets, its ability to

deliver services to customers and its relations

with suppliers and partners.

A cyber security incident will have different

levels of impacts on the business and service

delivery, and assessments regarding this are

used for categorisation and further inputs to

managing and reporting incidents.

The metric is reported in alignment with

national authorities. Authorities may also follow

up with specific investigations, if relevant.

Cyber security incidents as a metric are

relevant for several industries, as highlighted by

the EU directive on Network and Information

Security.

The metric is an aggregation of numbers for the

countries relevant for Telenor.

Percentage of customers affected by

privacy/data breach (2)

Information leakage can affect customer data

that may be part of privacy regulations. Cases

are to be reported to local authorities according

to national/regional regulations.

A privacy/data breach refers to any handling of

information not complying with applicable laws

and regulations, as well as Telenor internal

procedures and documents such as Code of

Conduct, policies/ guidelines, and employment

contracts

The percentage of customers may be an

indicator of the threat exposure and the

security maturity of an organization. This metric

is relevant for several industries as highlighted

in the EU directive on Network and Information

Security.

The metric is reported in alignment with

national authorities. Authorities may also follow

up with specific investigations, if relevant.

The metric is an aggregation of numbers for the

countries relevant for Telenor.

ISO 27001 certification (3)

ISO 27001 certification is done by authorised

entity for a defined scope. Scopes in this

context typically refer to Telenor companies

and must be renewed on regular basis.

ISO 27001 certification follows a process and

criteria executed by an external entity as

defined by ISO.

The metric is the percentage of all Telenor

companies with valid certificates in the

reporting year.

Training (4)

Expert training classes are conducted with

defined courses. The metric uses Telenor

internal system logs that track persons who

have successfully completed mandatory

sessions of the training. Most of the training

courses are from Telenor-external partners.

Competency is a key factor for detecting,

responding and recovering from cyber security

incidents.

Competency is also needed to track the threat

landscape and translate that into necessary

proactive and reactive security controls, both

internally and for suppliers/partners as well as

customers. Percentage of employees having

completed expert security training in 2025 is

measured as aggregate for all Telenor units

(base is all employees in Telenor)

Percentage of employees completed

information security training in Code of

Conduct (5)

Code of Conduct is mandatory for all Telenor

employees in full engagement during the

period of this training. One of the training

cases is information security to raise

awareness and deepen understanding of

threats and proper actions to be taken.

2025

151

Appendix 1 to the Sustainability statements

Disclosure requirements in ESRS covered by Sustainability statements

These sustainability statement are prepared to comply with mandatory disclosures requirements under ESRS-2, as well as

material topics and sub-topics concluded in the double materiality assessment. Telenor will adopt all phase-in requirements

when they become mandatory. Telenor has generally not disclosed the voluntary "may" requirements in this report.


Reference	Disclosure requirement	Section	Page

ESRS 2	General disclosures
BP-1	General basis for presentation of the sustainability statements	Sustainability Statement	75
BP-2	Disclosure in relation to specific circumstances	Sustainability Statement	75
GOV-1	The role of the administrative, management and supervisory bodies	Incorporated by reference:	60
GOV-2	Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies	Incorporated by reference:	60
GOV-3	Integration of sustainability in incentive schemes	Incorporated by reference:	63
GOV-4	Statement on sustainability due diligence	Sustainability statement	77
GOV-5	Risk management and internal controls over sustainability matters	Incorporated by reference:	60
SBM-1	Value chain	Sustainability statements/ general information/value chain	74
SBM-1	Sustainability elements of strategy and impact on products, services and markets [40 (a), (e), (f) and (g)]	Strategy, performance and risks/products, services and markets	11
SBM-1	Headcount by geographical area [40 (a)(iii)]	Sustainability statements	116
SBM-2	Interests and views by stakeholders	Sustainability statements	78
SBM-3	Material impacts, risks and opportunities and their interaction with strategy and business model	Sustainability statements	83
IRO-1	Description of the process to identify and assess material impacts, risks and opportunities	Sustainability statements	83


Reference	Disclosure requirement	Section	Page

IRO-2	Disclosure requirements in ESRS covered by the undertaking's sustainability statement	Appendix 1 to the Sustainability statements	This appendix
IRO-2	Disclosure requirements that derive from other EU legislation	Appendix 2 to the Sustainability statements	154
ESRS E1	Climate change
ESRS 2, GOV-3	Integration of sustainability-related performance in incentive schemes	Sustainability statements - incorporated by reference	63
E1-1	Transition plan for climate change mitigation	Sustainability statements	88
ESRS 2- SBM-3	Material impacts, risks and opportunities and their interaction with strategy and business model	Sustainability statements	86
ESRS 2, IRO-1	Description of processes to identify and assess material climate-related impacts, risks and opportunities	Sustainability statements	82
E1-2	Policies related to climate change mitigation and adaptation	Sustainability statements	91
E1-3	Actions and resources in relation to climate change policies	Sustainability statements	91
E1-4	Targets related to climate change mitigation and adaptation	Sustainability statements	91
E1-5	Energy consumption and mix	Sustainability statements	92
E1-6	Gross Scopes 1, 2, 3 and total GHG emissions	Sustainability statements	93

2025

152


Reference	Disclosure requirement	Section	Page

ESRS E4	Biodiversity and ecosystems
Telenor is making use of the phase-in relief from EU's "Quick fix" as of July 2025 for ESRS E4. However, Telenor is continuing to disclose certain relevant disclosure requirement under this material topic for FY 2025.
ESRS 2, SBM-3	Material impacts, risks and opportunities and their interaction with strategy and business model	Sustainability statements	98 (phase-in)
E4 - IRO-1	Description of processes to identify and assess material biodiversity and ecosystem-related impacts, risks and opportunities	Sustainability statements	98 (phase-in)
E4-1	Transition plan on biodiversity and ecosystems in strategy and business model	Sustainability statements	Phase-in
E4-2	Policies related to biodiversity and ecosystems	Sustainability statements	99 (phase-in)
E4-3	Actions and resources related to biodiversity and ecosystems	Sustainability statements	99 (phase-in)
E4-4	Targets related to biodiversity and ecosystems	Sustainability statements	99 (phase-in)
E4-5	Impact metrics related to biodiversity and ecosystems change	Sustainability statements	99 (phase-in)
ESRS E5	Resource use and circular economy
ESRS 2, IRO-1	Description of processes to identify and assess material resource use and circular economy-related impacts, risks and opportunities	Sustainability statements	101
E5-1	Policies related to resource use and circular economy	Sustainability statements	102
E5-2	Actions and resources related to resource use and circular economy	Sustainability statements	103
E5-3	Targets related to resource use and circular economy	Sustainability statements	102
E5-4	Resource inflows	Sustainability statements	103
E5-5	Resource outflows	Sustainability statements	104
ESRS S1	Own workforce
S1 SBM-3	Material impacts, risks and opportunities and their interaction with strategy and business model	Sustainability statements	111
S1-1	Policies related to own workforce	Sustainability statements	112
S1-2	Processes for engaging with own workers and worker's representatives about impacts	Sustainability statements	113
S1-3	Processes to remediate negative impacts and channels for own workers to raise concerns	Sustainability statements	115


Reference	Disclosure requirement	Section	Page

S1-4	Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions	Sustainability statements	114
S1-5	Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities	Sustainability statements	113
S1-6	Characteristics of undertaking’s employees	Sustainability statements	116
S1-8	Collective bargaining coverage and social dialogue	Sustainability statements	Phase-in
S1-9	Diversity metrics	Sustainability statements	117
S1-10	Adequate wages	Sustainability statements	118
S1-11	Social protection	Sustainability statements	Phase-in
S1-12	Persons with disabilities	Sustainability statements	Phase-in
S1-13	Training and skills development metrics	Sustainability statements	Not material
S1-14	Health and safety metrics	Sustainability statements	Not material
S1-15	Work-life balance metrics	Sustainability statements	Phase-in
S1-16	Compensation metrics - pay gap and total compensation	Sustainability statements	118
S1-17	Incidents, complaints and severe human rights impacts	Sustainability statements	Phase-in

ESRS S2	Workers in the value chain
ESRS-2, SBM-3	Material impacts, risks and opportunities and their interaction with strategy and business model	Sustainability statements	121
S2-1	Policies related to workers in the value chain	Sustainability statements	122

2025

153


Reference	Disclosure requirement	Section	Page

S2-2	Processes for engaging with value chain workers about impacts	Sustainability statements	126
S2-3	Processes to remediate negative impacts and channels to raise concerns	Sustainability statements	126
S2-4	Taking action on material impacts on value chain workers and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions	Sustainability statements	124
S2-5	Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities	Sustainability statements	123
ESRS S4	Consumers and end-users
S4 SBM-3	Material impacts, risks and opportunities and their interaction with strategy and business model	Sustainability statements	129
S4-1	Policies related to consumers and end-users	Sustainability statements	132
S4-2	Processes for engaging with consumers and end-users about impacts	Sustainability statements	133
S4-3	Processes to remediate negative impacts and channels for consumers and end-users to raise concerns	Sustainability statements	134
S4-4	Taking action on material impacts on consumers and end-users and approaches to to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions	Sustainability statements	133
S4-5	Targets related to managing material negative impacts, advancing positive impacts and managing material risks and opportunities	Sustainability statements	134

Entity- specific	Digital skills, inclusion and online safety
IRO	Material impacts, risks and opportunities related to digital skills and online safety	Sustainability statements	136
MDR-P	Policies related to digital skills and online safety	Sustainability statements	136
MDR-A	Taking action on digital skills and online safety	Sustainability statements	138


Reference	Disclosure requirement	Section	Page

MDR-T	Targets in relation to digital skills and online safety	Sustainability statements	137
MDR-M	Metrics in relation to digital skills and online safety	Sustainability statements	140

ERS-2 G1	Business conduct
GOV-1	Role of administrative, supervisory and management bodies	Sustainability statements	60
IRO-1	Description of processes to identify and assess material impacts, risks and opportunities	Sustainability statements	142
G1-1	Business conduct policies and corporate culture	Sustainability statements	143
G1-2	Management of relationships with suppliers	Sustainability statements	144
G1-3	Prevention and detection of corruption or bribery	Sustainability statements	144
G1-4	Incidents of corruption or bribery	Sustainability statements	144

Entity- specific	Cyber security
IRO	Material impacts, risks and opportunities related to cyber security	Sustainability statements	147
MDR-P	Policies related to cyber security	Sustainability statements	147
MDR-A	Taking action on cyber security	Sustainability statements	148
MDR-T	Targets in relation to cyber security	Sustainability statements	148
MDR-M	Metrics in relation to cyber security	Sustainability statements	149

2025

154

Appendix 2 to the Sustainability statements

Disclosure requirements that derive from other EU legislation

The table below provides an overview of ESRS data points that derive from other EU legislation, cf. ESRS 2 Appendix B and where this information can be found if deemed material. The relevant EU legislations are

Sustainable Finance Disclosure Regulations (SFDR), EU Climate law (EUCL), Pillar 3 (P3) and Benchmark Regulation(BRR).


ESRS reference		Disclosure requirement	Legislation reference	Materiality	Annual report reference

ESRS-2	Data point	General disclosures
GOV-1	21 d	Board’s gender diversity ratio	SFDR	Material	47
GOV-1	21 e	Percentage of independent Board members	SFDR	Material	47
GOV-4	30	Statement on due diligence	SFDR	Material	77
SBM-1	40 d (i) through 40 d (iv)	Activity in and revenue from fossil fuels, chemical, controversial weapons and/ or tobacco industry	SFDR	Not material	N/A
ESRS E1		Climate change
E1-1	14	Transition plan for climate change mitigation	EUCL	Material	88
E1-1	16 f	Exclusion from EU Paris-aligned Benchmarks	SFDR, P3, BRR	Not material	N/A
E1-4	34 a and 34 b	Emission reduction targets	SFDR, P3, BRR	Material	91
E1-5	37 a and 37 c	Energy consumption from fossil and renewable sources	SFDR	Material	92
E1-5	37 b	Energy consumption from nuclear sources	SFDR	Not material	N/A
E1-5	38 a and 38 b	Fuel consumption from coal and coal products and from crude oil and petroleum products	SFDR	Not material	N/A
E1-5	38 c and 38 d	Fuel consumption from natural gas and other fuel sources	SFDR	Not material	N/A
E1-5	38 e	Consumption of purchased or acquired electricity, heat, steam or cooling from fossil sources	SFDR	Not material	N/A
E1-5	40-43	Energy consumption and intensity from activities in high-climate-impact sectors	SFDR	Not material	N/A
E1-6	48-52	Scope 1, scope 2 and scope 3 emissions	SFDR, P3, BRR	Material	93
E1-6	53 and 55	GHG emission intensity	SFDR, P3, BRR	Material	95

2025

155


ESRS reference	Data point	Disclosure requirement	Legislation reference	Materiality	Annual report reference

E1-7	56	GHG removals and storage	EUCL	Material	91
E1-9	66	Assets at material financial risk	P3	N/A	Phase-in
E1-9	67 c	Carrying amount of real estate assets by energy efficiency classes	P3	N/A	Phase-in
E1-9	69	Financial opportunities (cost savings, market size and changes to net revenue) from climate change actions	BRR	N/A	Phase-in
ESRS E4		Biodiversity and ecosystems
E4 SBM-3	16 a through 16 c	Activities in biodiversity-sensitive areas, impacts related to land degradation, desertification and soil sealing, and to operations affecting threatened species	SFDR	Material	99
E4-2	24 a through 24 c	Policies on sustainable land or agriculture practices, sustainable oceans and sea practices, and deforestation practices	SFDR	Material	99
ESRS E5		Resource-use and circular economy
E5-5	11, 13 and 14	Non-recycled waste	SFDR	Material	104
E5-5	28 c and 28 e	Hazardous waste	SFDR	Material	104
ESRS S1		Own workforce
S1 SBM-3	11 b	Geographies or commodities with risk of forced labour	SFDR	Material	112
S1 SBM-3	11 b	Geographies or commodities with risk of child labour	SFDR	Material	112
S1-1	20 a	General approach to Human Rights	SFDR	Material	112
S1-1	20 b	General approach to engagement with own workforce	SFDR	Material	115
S1-1	20 c and 32 c	Approach and availability of grievance and remedy in regards to own workforce	SFDR	Material	115
S1-1	21	Policies are aligned with internationally recognized instruments	SFDR	Material	112
S1-1	22	Policies addressing human trafficking, forced labour and child labour	SFDR	Material	122
S1-1	23	Policies on accident prevention	SFDR	Material	122
S1-16	97 a and 97 b	Gender pay gap, CEO compensation ratio	SFDR, BRR	Material	118
S1-17	103 a	Incidents of discrimination	SFDR	Not material	N/A
S1-17	104 a	Severe human rights issues and incidents	SFDR, BRR	Not material	N/A

2025

156


ESRS reference	Data point	Disclosure requirement	Legislation reference	Materiality	Annual report reference
ESRS S2		Workers in the value chain
S2 SBM-3	11 b	Geographies or commodities with risk of forced labour	SFDR	Material	122
S2 SBM-3	11 b	Geographies or commodities with risk of child labour	SFDR	Material	125
S2-1	17 a and 19	Human rights policy commitments and approach related to value chain workers, aligned with internationally recognised standards	SFDR	Material	122
S2-1	17 b	General approach to engagement with value chain workers	SFDR	Material	126
S2-1	17 c	Approach to remedy for human rights impacts	SFDR	Material	126
S2-1	18 and 19	Policies explicitly addressing forced labour and child labour, aligned with internationally recognised standards	SFDR	Material	122
S2-1	18	Undertaking has a supplier code of conduct	SFDR	Material	122
S2-4	19 and 36	Severe human rights issues and incidents connected to value chain workers	SFDR, BRR	Material	127
ESRS S4		Consumers and end-users
S4-1	16 a, b and c	Policies related to consumers and end-users	SFDR	Material	132
S4-4	17	Non-respect of UNGPs on business and human rights and OECD guidelines	BRR	Not material	N/A
S4-4	35	Human rights issues and incidents	SFDR	Material	133
ESRS G1		Business conduct
G1-1	10 b and c	Statement if no policies exist in regard to anti-corruption and bribery and to protect whistle-blowers	SFDR	N/A as Telenor has policies in place	N/A
G1-4	24 a	Number of convictions and amount of fines for violations of anti-corruption and bribery laws	SFDR	Material	144

2025

157

Appendix 3 to the Sustainability statements

EU Taxonomy KPIs for sustainable activities

Proportion of turnover, CapEx and Opex from products or services associated with Taxonomy-eligible or Taxonomy-aligned economic activities - disclosure covering year 2025


					Breakdown by environmental objectives of Taxonomy aligned activities
KPI (1)	Total (2)	Proportion of Taxonomy eligible activities (3)	Taxonomy aligned activities (4)	Proportion of Taxonomy aligned activities (5)	Climate change Mitigation (6)	Climate change Adaptation (7)	Water (8)	Circular Economy (9)	Pollution (10)	Biodiversity (11)	Proportion of enabling activities (12)	Proportion of transitional activities (13)	Not assessed activities considered non-material (14)	Taxonomy aligned activities in previous financial year 2024 (15)	Proportion of Taxonomy aligned activities in previous financial year 2024 (16)
Text	NOK million	%	NOK million	%	%	%	%	%	%	%	%	%	%	NOK million	%
Turnover	81,387	—%	—	—%	—%	—%	—%	—%	—%	—%	—%	—%	2%	—	—%
CapEx	17,024	—%	—	—%	—%	—%	—%	—%	—%	—%	—%	—%	6%	1.8	0.01%
OpEx	5,345	—%	—	—%	—%	—%	—%	—%	—%	—%	—%	—%	4%	—	—%

2025

158

Transparency Act

Telenor is committed to respecting and promoting

human rights. This commitment is the foundation

for Telenor's business conduct across its markets

and is aligned with the company’s purpose "With

you, for a safer and smarter tomorrow" creating

impact beyond connectivity by enabling societies to

thrive in a digital future. This section represents

Telenor ASA's report on due diligence according to

the Norwegian Transparency Act for work on

fundamental human rights and decent working

conditions.

2025

159

The Report on the Norwegian

Transparency Act

Telenor conducts and reports on

human rights due diligence as part of


Area	Reference to pages
About Telenor, including description of structure and areas of operation	7
Value chain	74
Main supplier categories	121
Own workforce	110
Workers in the value chain	120
Diversity and inclusion	110
Mitigation actions undertaken to address, cease and mitigate actual adverse impacts and identified significant risks of adverse risks	114, 124 and 133
Conflict minerals	120
Grievance mechanism	134

its commitment to the UN Guiding

Principles on Business and Human

Rights. This commitment is the

foundation for Telenor's business

conduct across its markets and is

aligned with the company’s purpose

"With you, for a safer and smarter

tomorrow" creating impact beyond

connectivity by enabling societies to

thrive in a digital future.

Basis for reporting

Telenor’s human rights commitment is embedded

in the company’s Code of Conduct, Supplier

Conduct Principles and human rights policy

requirements, which in turn are anchored in the

Universal Declaration of Human Rights (UDHR), the

International Covenant on Civil and Political Rights

(ICCPR), the International Covenant on Economic,

Social and Cultural Rights (ICESCR) and the ILO

Declaration on Fundamental Principles and Rights

at Work.

Reference to other sections

Telenor considers the process and disclosure in

this section of Telenor’s Annual Report 2025,

including links to other sections, to meet the

Norwegian Transparency Act due diligence

requirements as per section 5. More information

about Telenor and various human rights policies

and processes can be found in the sections listed

below.

Reporting by legal entities in Norway

All legal entities owned by Telenor that exceed the

threshold of two of the three criteria set out by

the Transparency Act will make their reports

available on their websites by 30 June 2026.

The content in this section can be subject to

regular updates and revisions, with a view to

continuous improvement in line with international

human rights standards. In the event of significant

changes to Telenor’s risk assessments during the

year, updates will be made on Telenor.com

according to the company’s usual procedure.

Policies and processes

Labour rights

Telenor respects labour rights principles as laid

down in the UN Global Compact and the ILO

Declaration on Fundamental Principles and Rights

at Work. These principles relate to respecting the

rights to freedom of association and the effective

recognition of the right to collective bargaining.

They also relate to the elimination of all forms of

forced or compulsory labour, the effective

abolition of child labour, the elimination of

discrimination in respect of employment and

occupation and a safe and healthy working

environment. These principles are reflected in

Telenor’s Code of Conduct, Group People Policy,

Group Sustainability Policy and Supplier Conduct

Principles. Telenor works continuously to promote

employee involvement and maintains good labour

standards in the company’s operations.

Requests for Information under section 6

of the Act

Telenor has a transparent and open mechanism

on its website to allow for information requests

under the Transparency Act. More information

about this can be found here. During 2025,

Telenor received 31 requests for information

through this channel. Most enquiries were related

to the business operation of Telenor Norway.

Telenor responds to information requests

received via other channels as well. In addition, 49

grievances relating to human rights were reported

through the Integrity hotline.

Human rights due diligence

All Telenor companies are required to conduct

and document continuous human rights due

diligence to identify, address and manage human

rights related risks and impacts resulting from the

company’s own activities and those in the value

chain. This is in line with Telenor’s responsibility to

respect and promote human rights, and in

accordance with internal policies.

The human rights risk-based due diligence is to be

integrated with ongoing due diligence and risk

assessment processes where possible. In the

assessments and mitigation response, business

units are required to follow, to the extent possible,

the higher standard when national law and

international human rights law differ. If in conflict,

Telenor shall adhere to national law, while also

seeking ways to respect international human

rights to the greatest extent possible, in

accordance with the UN Guiding Principles on

Business and Human Rights.

During 2025, each Telenor company continued to

implement mitigation actions as identified in the

2024 human rights due diligence assessment

outcome. Local due diligence and impact

assessments during 2025 were summarised using

Telenor’s Human Rights due diligence assessment

toolkit, including risk prioritisation and

mitigations, presented to management of the

relevant Telenor companies, and to Telenor Group

management and Board of Directors.

2025

160

Training and awareness

Training and capacity-building relating to

identified human rights risks are key to Telenor’s

approach to mitigation. On-site and off-site

training sessions for suppliers are organised by

several Telenor companies, while the yearly Code

of Conduct training, including human rights


Area	Prioritised risks	Value chain	Telenor connection	Impacts	Mitigations include	Expected results
Common	Privacy and data security	Downstream: Customers and end-users	Telenor handling customer and employee data	Privacy and security	Auditing, awareness-building, access controls, internal governance, reporting, risk controls and impact assessments, controls against phishing attacks, AI governance	Increased awareness among end- users, and increased use of safe services.
	Supply chain sustainability	Upstream: Suppliers	Telenor procuring	Health & safety, workers' rights and well-being. Forced, underage and child labour.	Supplier due diligence, risk assessments, monitoring activities such as audits and inspections, capability building activities to ensure compliance with Telenor's standards. Clear roles and responsibilities across the organization.	Fewer H&S incidents through continuous improvement in suppliers’ way-of-work.
	Child safety online	Downstream: End- users	Telenor services used by children	Children's well-being and safety online, risks and opportunities	Partnering with child rights organisations, building digital literacy for children, blocking of child sexual abuse materials	Increased risk awareness among end-users, and improved digital well- being.
	Worker well-being	Own operations: Own workforce	Telenor employees	Safety of frontline workers, mental and physical well- being, risks and opportunities	Trainings, actions and tools to support management as well as employees, surveys for follow-up, inspections, incident investigation procedures.	Maintained high standards for employee safety, based on continuous pre-emptive actions. Low levels of sick-leave among Telenor employees.
Nordics¹	Diversity, equity and inclusion	Own operations: Own workforce	As an employer to promote diversity, equity and inclusion	Equal opportunities and inclusive treatment in career advancement and the workplace, and pay gap	Professionalization of leaders; equal pay assessments	A continued inclusive work environment
Asia	Authority requests for customer data, network shutdowns	Downstream: Customers and end-users	Telenor handling authority requests for network shutdowns, historic customer data, blocking of websites and distribution of SMS with specific content	Freedom of expression and privacy, access to information	Advocacy efforts towards improved legislation. Authority requests are handled through a dedicated team for assessment and routing, guided through a manual to ensure compliance.	Improved legislation and transparency over time. Continued robust processes for handling of authority requests, including transparent communication.
	Environmental and infrastructure impacts	Downstream: Customers and end-users	Bangladesh highly vulnerable to impacts by climate change	Service interruptions during extreme weather events and overall contribution to emissions	Telenor climate goals	Achievement on net-zero emissions over time
¹⁾ Including other Norway-based Telenor subsidiaries that exceed the threshold for two of three conditions as provided in the Transparency Act.

considerations, has been completed by 100% of

Telenor’s employees. The training on Telenor and

Human Rights released during 2024 was,

throughout 2025, rolled out as mandatory for all

employees. End of year the completion rate was

70 percent.

The course is available in English, Bengali, Danish,

Finnish, Norwegian and Swedish. The training is

crafted for all employees - irrespective of role,

location, or the services working with - to gain

general awareness about Telenor and Human

Rights and to see the respective tasks also from a

Human Rights point of view. And also for each and

one to see the business value of respecting and

promoting human rights .

Salient risks

In Telenor’s Nordic and Asian companies, salient

risk areas identified included the following. Based

on severity, likelihood, and Telenor’s current

management of risks, the below are the residual

risks prioritized vis-à-vis other identified risks.

2025

161

Telenor’s work to respect and promote

the rights of children and young people

Telenor consistently ranks highly in the Global

Child Forum's assessments. For more information

about actions undertaken to promote digital skills,

inclusion and online safety, see page 135.

Risk-based due diligence in the supply

chain

Telenor has a risk-based approach to conducting

due diligence in the supply chain. The level of

inherent risk is determined based on the nature of

the services provided, as well as the profile and

geography of the supplier. Inherent risk level

determines the need for additional risk

assessment, ranging from basic screening to

enhanced in-depth integrity due diligence.

Tools, including relevant platforms and systems,

are made available to dedicated resources in

Telenor for undertaking risk-based due diligence

at pre-contract and post-contract stages. These

tools encompass assessment of ESG risk

dimensions covered in Telenor’s Supplier

Conduct principles, including human and labour

rights, prohibited business practices, health and

safety, environment, privacy and data security.

At the pre-contract stage, risk reviews are

processed either by the Telenor company

procurement team for local suppliers, or Telenor

Procurement Company (TPC) for global suppliers,

supported by subject matter experts where

required. At the post-contract stage, local

suppliers are continuously monitored and

followed up by Telenor Supply Chain Sustainability

teams in collaboration with Procurement,

contract owners and subject matter experts.

In 2025, Telenor introduced contractual

provisions on responsible AI for inclusion in its

General Framework Agreements (GFA),

establishing baseline requirements for ethical AI

use in sourcing, partnerships, and other AI-related

engagements.

Inspections and audits are considered effective

monitoring tools across all tiers, including those

beyond the contracted entity. Self-assessment

questionnaires are sent to sub-suppliers based on

risk picture.

Operations have been informed, including

guidance, that working with third parties,

business partners and customers in conflict-

affected and high-risk areas requires heightened

human rights due diligence.

At the global level, where supplier tiers are

located in geographies outside of Telenor’s

footprint, Telenor works with the Joint Alliance for

Corporate Social Responsibility (JAC) to

undertake audits in the industry’s common supply

chain. Through the JAC partnership, Telenor

benefits from audits conducted by member

companies in the lower tiers of the global supply

chain. For further reporting on Telenor's supply

chain sustainability work, see page 120.

Freedom of expression and privacy

Freedom of expression and privacy are key to the

core business of Telenor. Authorities can legally

access personal data or restrict communication,

which may impact privacy and freedom of

expression. This includes disclosing customer

information, traffic data, or allowing interception

of communications to solve crimes or prevent

threats. Telenor recognises the societal

importance of these actions but also the potential

for misuse. Telenor shall respond to authority

requests (e.g. for data access, intercept, network

and content law enforcement requests) in ways

that respect laws and regulations, as well as

international human rights standards such as the

UN Guiding Principles on Business and Human

Rights (UNGPs) and the Global Network Initiative

(GNI) Principles.

See page 113 for more information about

processes and mechanisms related to human

rights. Telenor’s annual Authority Requests

Report is available on Telenor.com.

2025

162

Stakeholder engagement and

transparency

Introduction

Telenor maintains a proactive approach to

transparency and stakeholder engagement in

order to effectively address and manage the

identified human right impacts. This is in line with

stakeholder expectations to disclose processes

and dilemmas to the greatest extent possible. It

includes information through the Sustainability

statements within the Annual Report, the annual

Authority Request Report on Telenor.com and

through other sustainability updates,

presentations and public arenas.

Telenor engages with a number of organisations

to advance its human rights objectives, including

the UN Global Compact, the Global Network

Initiative (GNI), the Global System for Mobile

Communications Association (GSMA), and the

Joint Alliance for Corporate Social Responsibility

(JAC).

An overview of stakeholder engagement related

to human rights is shown in the below table. The

stakeholder engagement process is described in

more detail on page 78 and issue-specific

stakeholder engagement is further described on

page 133.

Outcomes of Telenor’s internal learning

process from the Myanmar engagement

The extraordinary situation since the military

takeover in Myanmar on 1 February 2021 made it

impossible for Telenor to continue operations in

the country, and a sale of the company was

completed in March 2022. As part of the efforts to

learn from the process of Telenor's forced exit

from Myanmar, and to share that transparently

with the larger stakeholder community, Telenor

published the learnings on Telenor.com, providing

valuable lessons on its exit crisis management.

These learnings broadly relate to improved crisis

management processes, improved stakeholder

engagement and internal information flows.

OECD Norwegian National Contact (NCP)

As part of its human rights commitment, Telenor

has also actively engaged with the OECD

Norwegian National Contact Point (NCP) on a

complaint raised in July 2021 in relation to the sale

of Telenor Myanmar.

In November 2025, the Norwegian OECD National

Contact Point (NCP) published its final statement

in the case and Telenor published a response to

the NCP statement, including reaffirming its

commitment to OECD Guidelines.

As part of the actions agreed by the parties, an

independent ICT Ecosystem Study was finalised in

2024 with the objective of enhancing the

understanding of civil society about risks related

to the digital footprints of users. A summary of

the study was made public for the benefit of all.

Way forward

Telenor is committed to continuous improvement

over time and will continue to strengthen internal

awareness and capacity to identify and address

actual and potential human rights risks in

operations and within the value chains. The

company will continue to engage with multi-

stakeholder platforms, partners, investors and

other stakeholders.


Overview of stakeholder engagement
Area	Issues	Stakeholder proxies include
Artificial intelligence	AI ethics, AI skills, AI act compliance	GSMA, AI Pact, GNI
Children's rights	Digital skills and digital well-being	Plan International, UNICEF, Save the Children
Health and well-being	Workers rights and well-being	Unions and Employer organisations
Human rights challenges in a changing business environment	Lessons learned from forced exit Myanmar, impact of transition to new business model, and operating in external environments where respecting human rights can be challenging	BSR
Supply chain sustainability	Health & safety, forced, underage and child labour, conflict minerals, living wage	JAC
Freedom of expression and surveillance privacy	Network shutdowns and authority requests	GNI

2025

163

Financial

Statements


Consolidated financial statements		Parent company financial statements		Statements and opinions		Alternative performance measures (APMs)
165	Income Statement	254	Financial statements of the parent company	276	Responsibility statement by the Board and the President & CEO	288	Performance and organic growth measures
166	Statement of comprehensive income		Financial statements of the parent company			292	Investments, borrowings and free cash flow
167	Statement of financial position	258	Notes to the parent company financial statements	276	Statement from the Corporate Assembly		Investments, borrowings and free cash flow
168	Statement of cash flows		Notes to the parent company financial statements		Statement from the Corporate Assembly	298	Definitions
169	Statement of changes in equity			277	Independent auditor's limited assurance on sustainability statements
170	Notes to the consolidated financial statements
	Notes to the consolidated financial statements			281	Independent auditor's report on the financial statements

2025

164

Consolidated

financial statements

Telenor is Norway's leading telecom provider with operations in

Nordics and Asia. Telenor is listed on the Oslo Stock Exchange

with the Norwegian State as main shareholder with a holding of

54 %. The consolidated financial statements are prepared in

accordance with the IFRS® Accounting Standards.

Connecting customers to what matters most has been the core of

our business for 168 years. Our ambition is to deliver critical

connectivity and services to customers and societies, continue to

strengthen our responsible business agenda and utilise the

2025

165

Consolidated income statement

Telenor Group 1 January – 31 December


NOK in millions, except earnings per share	Note	2025	2024
Revenues	3	76,548	75,487

Cost of materials and traffic charges	4	(17,244)	(17,313)
Salaries and personnel costs	5	(9,814)	(9,741)
Other operating expenses	6	(15,028)	(15,261)
Other income	8	744	1,479
Other expenses	8	(913)	(788)
EBITDA		34,292	33,863
Depreciation and amortisation	15, 16, 17	(16,312)	(15,878)
Impairment losses	15, 16, 17, 18	(2)	(73)
Operating profit		17,978	17,912

Share of net income (loss) from associates and joint ventures	35	1,618	206
Impairments and gain (loss) on disposal of associates and joint ventures	35	205	6,606
Net income (loss) from associates and joint ventures		1,823	6,812

Financial income	9	676	1,040
Financial expenses	9	(3,692)	(4,255)
Net currency gains (losses)	9	347	(533)
Change in fair value of financial instruments	9	(477)	2,518
Net financial income (expenses)		(3,147)	(1,230)
Profit before taxes		16,654	23,494
Income taxes	10	(4,364)	(3,719)
Profit (loss) from continuing operations		12,290	19,776
Profit (loss) from discontinued operations	12	(3,927)	333
Net income		8,363	20,109


NOK in millions, except earnings per share	Note	2025	2024

Net income attributable to:
Non-controlling interests		1,329	1,773
Equity holders of Telenor ASA		7,034	18,336
Net income		8,363	20,109

Earnings per share in NOK:
Basic/diluted from continuing operations	11	8.01	13.08
Basic/diluted from discontinued operations	11	(2.87)	0.24
Basic/diluted from total operations	11	5.14	13.32

2025

166

Consolidated statement of comprehensive income

Telenor Group 1 January – 31 December


NOK in millions	Note	2025	2024
Net Income		8,363	20,109

Other comprehensive income (loss)
Translation differences on net investment in foreign operations	28	(2,196)	9,881
Amount reclassified from other comprehensive income to income statement on disposals	28	3,022	(33)

Net gain (loss) on hedge of net investment	28, 31	(705)	(2,483)
Income tax on net investment hedge		155	546
Amount reclassified from other comprehensive income to income statement on disposal	28	(82)	—
Income tax on net investment hedge reclassified to income statement on disposal		19	—

Share of other comprehensive income (loss) of associated companies and joint ventures	35	(183)	(85)
Amount reclassified from other comprehensive income to income statement on disposal	28	25	—
Items that subsequently may be reclassified to income statement		55	7,826

Net gain (loss) on equity investments	28	(37)	52
Remeasurement of defined benefit pension plans	21, 28	528	265
Income taxes on pension remeasurement		(101)	(62)
Items that will not be reclassified to income statement		390	255

Other comprehensive income (loss), net of taxes		446	8,081
Total comprehensive income (loss)		8,809	28,190

Total comprehensive income (loss) attributable to:
Non-controlling interests		958	1,892
Equity holders of Telenor ASA		7,851	26,299

2025

167

Consolidated statement of financial position

Telenor Group as of 31 December


NOK in millions	Note	2025	2024

ASSETS
Deferred tax assets	10	3,067	4,614
Goodwill	14, 18	26,822	26,319
Intangible assets	15	9,379	9,542
Right-of-use assets	16	20,326	26,120
Property, plant and equipment	17	51,552	54,678
Associates and joint ventures	35	66,514	66,793
Contract costs and prepaid costs	26	5,858	5,420
Other non-current financial assets	27	6,198	7,869
Total non-current assets		189,717	201,355

Prepaid taxes		211	770
Inventories		862	877
Trade and other receivables	19	13,701	13,812
Other current financial assets	27	825	1,614
Cash and cash equivalents	20	16,335	10,380
Total current assets		31,934	27,453

Total assets		221,651	228,808


NOK in millions	Note	2025	2024

EQUITY AND LIABILITIES
Equity attributable to equity holders of Telenor ASA	28	70,479	75,855
Non-controlling interest	28	5,150	5,917
Total equity		75,629	81,772

LIABILITIES
Non-current lease liabilities	29	11,399	13,697
Non-current interest-bearing liabilities	30	74,187	72,730
Non-current non-interest-bearing liabilities	27	1,363	1,362
Deferred tax liabilities	10	4,453	3,874
Pension obligations	21	1,966	2,068
Provisions and obligations	22	6,369	6,923
Total non-current liabilities		99,737	100,652

Current lease liabilities	29	3,660	3,844
Current interest-bearing liabilities	30	12,607	11,350
Trade and other payables	24	21,243	22,774
Current tax payables		1,846	1,711
Current non-interest bearing liabilities	27	1,004	1,577
Provisions and obligations	22	892	908
Liabilities classified as held for sale	12	5,033	4,220
Total current liabilities		46,285	46,384

Total equity and liabilities		221,651	228,808

2025

168

Consolidated statement of cash flows

Telenor Group 1 January – 31 December


NOK in millions	Note	2025	2024

Profit (loss) before taxes from continuing operations		16,654	23,494
Profit (loss) before taxes from discontinued operations	12	(3,182)	340
Profit (loss) before taxes from total operations		13,472	23,834

Net interest expense		3,026	3,288
Interest paid		(2,997)	(3,761)
Interest received		361	786
Income taxes paid		(3,727)	(3,783)
Net (gains) losses from disposals, impairments and change in fair value of financial assets and liabilities		4,257	(3,361)
Depreciation, amortisation and impairment losses		17,304	16,944
Net income (loss) from associates and joint ventures		(1,823)	(6,812)
Dividends received from associates and joint ventures	35	2,547	1,425
Net currency (gains) losses not related to operating activities		(322)	716
Changes in operating working capital	13	140	2,748
Other adjustments		(1,016)	(542)
Net cash flow from operating activities		31,222	31,481

Purchases of property, plant and equipment and intangible assets	13	(11,338)	(12,929)
Prepayment of right-of-use assets including initial direct cost	13	(590)	(454)
Proceeds from sale of property, plant and equipment and intangible assets		85	45
Purchases of businesses, net of cash acquired	13	(794)	(249)
Proceeds from disposal of businesses, net of cash disposed	13	2,949	2,138
Income tax withheld from proceeds relating to disposal of businesses	13	(179)	—


NOK in millions	Note	2025	2024
Proceeds from sale of other investments		97	53
Purchases of other investments		(68)	(90)
Net cash flow from investing activities		(9,838)	(11,486)

Proceeds from borrowings	13	18,079	6,278
Repayments of borrowings	13	(13,494)	(13,877)
Payments of lease liabilities related to spectrum licences	13	(687)	(1,216)
Payments of lease liabilities related to other lease contracts	13	(4,037)	(3,652)
Purchase of treasury shares	28	(195)	(1,971)
Dividends paid to non-controlling interests in subsidiaries	11	(1,732)	(1,871)
Dividends paid to equity holders of Telenor ASA	11	(13,135)	(13,082)
Net cash flow from financing activities		(15,202)	(29,391)

Effects of exchange rate changes on cash and cash equivalents		(27)	(78)
Net change in cash and cash equivalents		6,155	(9,474)

Cash and cash equivalents as of 1 January		10,104	19,580
Cash and cash equivalents as of 31 December	20	16,258	10,104

2025

169

Consolidated statement of changes in equity

Telenor Group as of 31 December


	Attributable to equity holders of Telenor ASA
NOK in millions	Paid-in capital	Other reserves	Retained earnings	Cumulative translation differences	Total	Non-controlling interests	Total equity
Equity as of 1 January 2024	8,379	(21,985)	84,172	(6,089)	64,483	5,951	70,434
Net income for the period	—	—	18,336	—	18,336	1,773	20,109
Other comprehensive income (loss) for the period	—	151	—	7,812	7,963	119	8,081
Total comprehensive income (loss) for the period	—	151	18,336	7,812	26,299	1,892	28,190
Disposal of subsidiaries with non-controlling interests	—	—	—	—	—	(50)	(50)
Dividends	—	—	(13,082)	—	(13,082)	(1,876)	(14,958)
Purchase of treasury shares	(101)	(1,794)	—	—	(1,895)	—	(1,895)
Share-based payment, exercise of share options and distribution of shares	—	50	—	—	50	—	50
Equity as of 31 December 2024	8,278	(23,578)	89,426	1,723	75,855	5,917	81,772
Net income for the period	—	—	7,034	—	7,034	1,329	8,363
Other comprehensive income (loss) for the period	—	258	—	558	817	(371)	446
Total comprehensive income (loss) for the period	—	258	7,034	558	7,851	958	8,809
Acquisition of subsidiaries with non-controlling interests	—	—	—	—	—	11	11
Dividends	—	—	(13,135)	—	(13,135)	(1,736)	(14,871)
Purchase of treasury shares	(1)	(4)	—	—	(5)	—	(5)
Share-based payment, exercise of share options and distribution of shares	—	(86)	—	—	(86)	—	(86)
Equity as of 31 December 2025	8,277	(23,410)	83,325	2,281	70,479	5,150	75,629

See note 28 for additional equity information.

2025

170

Notes to the consolidated financial statements

Telenor Group


General information		Operating assets and liabilities		Financial assets, liabilities and risk management
1	Company information and basis of preparation	14	Goodwill	27	Financial assets and non-interest-bearing liabilities
		15	Intangible assets	28	Equity
Performance		16	Right-of-use assets	29	Lease liabilities
2	Segments	17	Property, plant and equipment	30	Interest-bearing liabilities
3	Revenues	18	Impairment of assets	31	Capital and financial risk management
4	Costs of materials and traffic charges	19	Trade and other receivables	32	Fair values of financial instruments
5	Salaries and personnel costs	20	Cash and cash equivalents	33	Guarantees
6	Other operating expenses	21	Pension obligations
7	Research and development costs	22	Provisions and obligations	Group composition and consolidation
8	Other income and other expenses	23	Legal disputes and contingencies	34	Consolidation and group companies
9	Financial income and expenses	24	Trade and other payables	35	Associates and joint arrangements
10	Income taxes	25	Contractual commitments
11	Earnings per share and dividends	26	Contract costs and other prepaid costs	Other
12	Held for sale and discontinued operations			36	Related parties
13	Cash flow information			37	Key management compensation
				38	Fees to external auditor
				39	Shareholders
				40	Events after the reporting period

2025

171

NOTE 1

Company information and basis of preparation

Telenor is a Norwegian listed company offering telecommunications services in the

Nordics and Asia. The consolidated financial statements of Telenor are prepared

according to the IFRS® Accounting Standards. The accounting policies are described

in this note and in the individual notes to the financial statements.

Company information

The consolidated financial statements of Telenor (referred to as “the company”) comprise the parent

company and its subsidiaries. The parent company Telenor ASA is a Norwegian public limited company

listed on the Oslo Stock Exchange under the ticker TEL. The principal activities of Telenor are described

in note 2 Segments. The headquarter is at Snarøyveien 30, N-1360 Fornebu, Norway and the telephone

number is +47 810 77 000.

Basis of preparation

The consolidated financial statements are prepared in accordance with IFRS® Accounting Standards as

adopted by the EU and the additional requirements of the Norwegian Accounting Act. The consolidated

financial statements were approved by the Board of Directors on 25 March 2026 and is subject to

approval by the Annual General Meeting on 19 May 2026.

The consolidated financial statements have been prepared on a historical cost basis, except for equity

investments (primarily shareholdings of less than 20%) and derivative financial instruments, which are

carried at fair value. The financial year corresponds to the calendar year. The consolidated financial

statements are presented in Norwegian Kroner (NOK), which is the functional currency of Telenor ASA.

Amounts are rounded to the nearest million, unless otherwise stated. As a result of rounding, amounts

and percentages may not add up to the total.

Telenor Pakistan sale completed

The sale of Telenor Pakistan was completed on 31 December 2025, and Telenor Pakistan has been

presented as discontinued operations as it represents a major line of business. Discontinued operations

are excluded from continuing business in the income statement and is presented on a single line as

"profit (loss) from discontinued operations". Comparative information for the income statement and

related notes has been re-presented accordingly. The statement of cash flow include Telenor Pakistan

both in the current and prior year. Refer to note 12 Held for sale and discontinued operations for further

information.

ACCOUNTING POLICIES

Descriptions of accounting principles are generally included in the various notes to the financial

statements. The general principles relating to foreign currency translation, distinction between

current and non-current assets and liabilities and government grants are described below.

Foreign currency translation

The consolidated financial statements are presented in NOK, which is functional currency of Telenor

ASA. The assets and liabilities of foreign entities with functional currencies other than NOK are

translated into NOK at the exchange rate on the reporting date. The income statements are translated

at the average exchange rates for the year except significant transactions that are translated using

the daily exchange rate. The translation differences arising from the translation are recognised in

other comprehensive income until the disposal of the net investment, at which time they are

recognised in the income statement.

Current/non-current classification

Asset and liabilities are classified as current when they are expected to be realised, sold, used or

settled in Telenor’s normal operating cycle, which is normally within twelve months after the reporting

date. Other assets and liabilities are classified as non-current. Financial instruments, other than those

held for trading, are classified based on maturity. Hedging instruments are classified consistently with

the underlying hedged item.

Government grants

Government grants are recognised when there is reasonable assurance that the grant will be received.

Grants that relate to expenses are normally recognised as a reduction of the expense over the related

period. Grants that relate to assets are deducted from the carrying amount of the asset and result in

lower depreciation over the useful life of the asset.

2025

172

Adoption of new and revised standards, amendments and interpretations effective

from 1 January 2025

The accounting policies applied are consistent with those applied in the previous financial year, except

for the implementation of new and revised accounting standards as described below. The amendments

adopted with effect from 1 January 2025 relevant for Telenor include:

Lack of Exchangeability (Amendments to IAS 21 The Effects of Changes in Foreign Exchange Rates)

The amendments to IAS 21 clarify how an entity assesses whether a currency is exchangeable into

another currency and establish a consistent framework to be applied when exchangeability is lacking. In

such circumstances, the amendments provide guidance on determining the appropriate exchange rate

and introduce additional disclosure requirements. Restrictions or shortages of foreign currency may

result in a lack of exchangeability and could affect the exchange rates applied when translating financial

statements into NOK. The amendments to IAS 21 effective from 1 January 2025 has not had significant

impact on Telenor’s consolidated financial statements as all relevant currencies for Telenor were

assessed as exchangeable in 2025, including the Bangladeshi Taka (BDT).

Telenor has not early adopted any other standard, interpretation or amendment that has been issued but

are not yet effective.

New and revised standards, amendments and interpretations issued, but not yet

effective

At the date of authorisation of these financial statements, the following amendments and standard that

could affect Telenor’s consolidated financial statements were issued but not effective:

Nature-dependent Electricity Contracts (Amendments to IFRS 9 Financial Instruments and IFRS 7

Financial Instruments: Disclosures)

The amendments to IFRS 9 and IFRS 7, effective from 1 January 2026 (endorsed by the EU 30 June 2025),

address the accounting for nature-dependent electricity contracts, including power purchase

agreements (PPAs). The amendments clarify the application of the ‘own-use’ requirements in IFRS 9,

permit certain nature-dependent electricity contracts to be designated as hedging instruments, and

introduce additional disclosure requirements to enhance transparency regarding the effects of such

contracts on an entity’s financial performance and cash flows. Telenor has three active PPAs structured

as base-load agreements with fixed volumes and is therefore not exposed to volume variability.

Accordingly, the amendments do not currently apply to Telenor. The accounting treatment of energy

purchases under these PPAs, including the assessment of the ‘own-use’ criteria under IFRS 9, is

described in note 4 Cost of materials and traffic charges.

KEY ACCOUNTING JUDGEMENTS

The preparation of the consolidated financial statements requires management to make significant

judgment in selecting and applying accounting policies in certain areas. Such judgments typically involve

complex or unusual transactions that are not directly addressed in the IFRS Accounting Standards, or

when judgment is required to assess terms like “highly probable”, “significant” or “prolonged”.

The areas where management has applied accounting judgment that could potentially have a significant

impact on the consolidated financial statements are described in the following notes:

◦ Note 35 Associates and joint arrangements (about “significant” and “prolonged” decline in market

value)

KEY SOURCES OF ESTIMATION UNCERTAINTY

The preparation of the consolidated financial statements requires management to make significant

estimates that could result in material adjustments to the carrying amount of the asset or liability the next

financial year. The estimates include difficult, subjective and complex assessments of the outcome of

matters that are inherently uncertain. Management uses historical results and experience, consultations

with experts, trends, forecasts, scenarios of future development and other methods found reasonable

under the circumstances when assessing the estimates.

The most significant estimates in the consolidated financial statements of Telenor are described in the

following notes:

◦ Note 10 Income taxes (uncertain tax positions)

◦ Note 16 Right-of-use assets (determine lease term for perpetual leases of towers and other

infrastructure)

◦ Note 17 Property, plant and equipment (determine useful lives and residual value)

◦ Note 18 Impairment of assets (assumptions used in the impairment model)

◦ Note 22 Provision and obligations (asset removal obligation, or ARO)

◦ Note 23 Legal disputes and contingencies (assessment of legal claims)

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173

Amendments to the Classification and Measurement of Financial Instruments (IFRS 9 and IFRS 7)

The amendments to IFRS 9 and IFRS 7 clarify the accounting for the settlement of financial liabilities

using electronic payment systems and the assessment of contractual cash flow characteristics of

financial assets, including those with environmental, social and governance (ESG)-linked features. In

addition, the amendments revise disclosure requirements for investments in equity instruments

designated at fair value through other comprehensive income and introduce new disclosure

requirements for financial instruments with contingent features that are not directly related to basic

lending risks and costs. The implementation of these amendments are effective from 1 January 2026

(endorsed by the EU 27 May 2025) and are not expected to have a significant impact on the consolidated

financial statements.

IFRS 18 Presentation and Disclosure in Financial Statements

The new IFRS 18 Presentation and Disclosure in Financial Statements effective 1 January 2027 (endorsed

by the EU 13 February 2026) replaces IAS 1 Presentation of Financial Statements. IFRS 18 will apply

retrospectively. IFRS 18 introduces new requirements for presentation within the income statement,

including specified totals and subtotals. Furthermore, entities are required to classify all income and

expenses within the income statement into one of five categories: operating, investing, financing,

income taxes and discontinued operations, whereof the first three are new.

The standard requires disclosure of management-defined performance measures and additional

subtotals of income and expenses. It also introduces new requirements for the aggregation and

disaggregation of financial information, clarifying what information should be presented in the primary

financial statements and what should be disclosed in the notes based on their respective roles. In

addition, narrow-scope amendments have been made to IAS 7 Statement of Cash Flows, which include

changing the starting point for determining cash flows from operations under the indirect method, from

‘profit or loss’ to ‘operating profit or loss’ and removing the optionality around classification of cash

flows from dividends and interest. In addition, there are consequential amendments to several other

standards. Telenor is currently working to identify all impacts the amendments will have on the primary

financial statements and notes to the financial statements.

The most material impacts expected on the consolidated financial statements are as follows:

• Foreign exchange (FX) differences will be classified in the same category as the related income or

expense that gave rise to the FX difference. The change impacts primarily the presentation and does

not result in changes to the amounts reported in the consolidated income statement.

• Management‑defined Performance Measures (MPMs) will be disclosed in a separate note, including a

description of the MPMs, calculation methods and reconciliation to the closest subtotal in the income

statement as well as tax and non-controlling interest effects.

• New disclosure of specified expenses by nature when expenses are presented by function within the

operating category of the statement of profit or loss. Telenor currently applies a mixed expense

presentation, predominantly by nature.

• The financing component of mobile phones instalment plans and finance cost related to sale of trade

receivables will be reclassified from the financing category to the operating category in the income

statement. Similarly, interest income from bank accounts will be reclassified from the financing

category to the investing category.

• In the statement of cash flow, interest and dividends from associates and joint ventures received will

be reclassified from operating activities to investing activities, while interest paid will be reclassified

from operating activities to financing activities.

A reconciliation for each line item in the statement of profit or loss between amounts restated under

IFRS 18 and amounts previously presented under IAS 1 will be provided in notes disclosures.

Management anticipates that these amendments and the new IFRS 18 standard will be adopted at

effective dates stated above. There are no other standards, interpretations, or amendments effective

from 1 January 2026 or later that are expected to have a significant impact on the consolidated financial

statements.

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NOTE 2

Segments

Telenor has four operating segments. The mobile and fixed line businesses are

reported in the Nordic and Asia segments. The Infrastructure segment consists of

certain passive infrastructure in the Nordic countries, and the portfolio of adjacent

businesses and companies are reported in the Amp segment.

Segments

Nordics

The Nordics segment consist of mobile and fixed operations in Norway, Sweden, Denmark, and

Finland. Offerings include mobile subscriptions and mobile phones, telephony, broadband, data

security, communications services, and TV services to both residential and business customers. The

segment also offers wholesale services.

Asia

The Asia segment consists of mobile operations in Grameenphone (Bangladesh) . The sale of Telenor

Pakistan was completed on 31 December 2025. Telenor is presented as discontinued operations,

meaning results are not included in the Asia segment results but included in free cash flows for 2025

and 2024. Refer to note 12 Held for sale and discontinued operations for further information.

Grameenphone offerings include mobile subscriptions, as well as wholesale services. The segment

also has ownership in the associates CelcomDigi and True Corporation as well as the joint venture

Easypaisa Digital Bank (previously Telenor Microfinance Bank), which are included in the segment as

investments in associates and joint arrangements. See further information in note 35 Associates and

joint arrangements.

Infrastructure

The Infrastructure segment provides passive telecom infrastructure in the Nordics such as towers,

masts and buildings. The Infrastructure segment builds, develops and maintains passive telecom

infrastructure and leases it to both internal and external customers. In addition, the Infrastructure

segment includes the AI Factory, as well as the associate data centre company Skygard.

Amp

Telenor Amp consists of a portfolio of businesses and companies that are near the core of Telenor’s

business. Offerings include a wide variety of services, including Internet of Things (IoT), digital

authentication and various communication services. The segment also have ownership in associates,

including Carousell.The associate Allente was divested in November 2025.

Other

Other include corporate functions like Group leadership, strategy, finance, procurement and

insurance. External revenue include procurement services provided to associates, insurance and

operating office leases.

ACCOUNTING POLICIES

The segment information is reported to the President and CEO and management team in Telenor.

Telenor’s chief operating decision maker is the President and CEO. The financial segment information

is used for assessing performance and allocating resources in the group. The operating and reportable

segments are based on business activities and geographical location.

The accounting principles for the segment reporting are consistent with those for the consolidated

financial statements. However, gains and losses arising from internal bad debt provisions are excluded

from the segment results. All transactions between the segments are based on market conditions.

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175

Segment Information 2025


NOK in millions	Revenues	External revenues	Total Operating Expenses	EBITDA before other income and other expenses ^1,2)	EBITDA ^1,2)	Depreciation, amortisation and impairment losses ³⁾	Operating profit (loss)	Capex excl. lease ²⁾	Free cash flow before M&A
Nordics	59,341	58,740	(17,119)	26,723	26,579	13,806	12,773	8,478	11,175
Asia	13,724	13,349	(5,105)	7,835	7,842	3,134	4,708	1,110	3,247
Infrastructure	3,318	933	(757)	2,017	2,002	1,029	974	734	981
Amp	3,517	3,055	(1,322)	445	414	209	205	182	512
Other	1,476	472	(2,054)	(578)	(424)	95	(519)	31	(3,264)
Discontinued operations (Telenor Pakistan)	—	—	—	—	—	—	—	—	407
Eliminations	(4,829)	—	1,516	(1,982)	(2,122)	(1,959)	(163)	—	(190)
Group	76,548	76,548	(24,842)	34,462	34,292	16,314	17,978	10,535	12,869

Segment Information 2024


NOK in millions	Revenues	External revenues	Total Operating Expenses	EBITDA before other income and other expenses ^1,2)	EBITDA ^1,2)	Depreciation, amortisation and impairment losses ³⁾	Operating profit (loss)	Capex excl. lease ²⁾	Free cash flow before M&A
Nordics	56,560	55,989	(17,052)	24,223	23,644	13,285	10,359	9,678	10,781
Asia	15,477	14,998	(5,489)	9,049	9,019	3,345	5,674	1,752	2,502
Infrastructure	3,282	886	(745)	1,952	1,931	991	940	890	946
Amp	3,494	3,113	(1,130)	448	1,810	167	1,644	160	82
Other	1,705	502	(2,326)	(621)	(658)	91	(750)	47	(3,474)
Discontinued operations (Telenor Pakistan)	—	—	—	—	—	—	—	—	463
Eliminations	(5,031)	—	1,739	(1,879)	(1,883)	(1,928)	44	—	66
Group	75,487	75,487	(25,002)	33,173	33,863	15,951	17,912	12,528	11,366

1) See table below for reconciliation of EBITDA.

2) For definitions of EBITDA and capex excl. lease, see Alternative Performance Measures.

3) For impairments see note 15, 16, 17 and 18.

2025

176

Reconciliation


NOK in millions	2025	2024
EBITDA before other income and other expenses	34,462	33,173
Other income	744	1,479
Other expenses	(913)	(788)
EBITDA	34,292	33,863

Geographical distribution of external revenues based on customer location


NOK in millions	2025	2024
Norway	26,564	25,054
Sweden	14,233	13,659
Denmark	6,279	5,941
Finland	13,209	12,564
Bangladesh	13,347	14,995
Other countries	2,915	3,275
Total revenues	76,548	75,487

Assets by geographical location of the company


	Non-current assets excluding deferred tax assets, contract cost and other non-current financial assets		Total assets
NOK in millions	2025	2024	2025	2024
Norway	37,489	36,863	58,992	56,475
Sweden	17,492	17,724	26,218	23,802
Denmark	5,150	5,144	7,934	8,092
Finland	37,428	38,524	44,954	45,088
Thailand	25,979	24,309	26,038	24,372
Malaysia	36,904	38,710	36,904	38,710
Bangladesh	11,506	14,406	15,740	18,767
Pakistan	901	5,899	914	8,315
Singapore	1,734	2,925	2,314	5,033
Other countries	12	5	1,642	154
Total assets	174,596	184,508	221,651	228,808

2025

177

Note 3

Revenues

Revenues from rendering of services mainly come from subscription fees and

usage‑based traffic revenues from Telenor’s mobile voice and data services. Mobile

phones and other devices are sold individually or together with subscriptions. Telenor

also provides broadband and TV services to households, as well as data networks and

other communication services to private and business customers.

ACCOUNTING POLICIES

Revenue from rendering of services

Revenues from rendering of services are recognised over time or based on usage. Outbound roaming

charges, in addition to voice and non-voice traffic fees, are recognised based on the minutes or data

used.

Sale of mobile phones and other devices

Revenues from the sale of mobile phones and other devices are recognised at point in time when the

equipment is delivered to the customer.

Bundled multi-element contracts

Bundled multi-element contracts are contracts that consist of several separate identifiable performance

obligations. These typically include subscription, mobile phone, screen insurance and other services as

part of Telenor’s mobile operations. The transaction price is net of discounts and sales related taxes. The

transaction price for bundled contracts is allocated to each identified performance obligation based on

relative prices Telenor would achieve by selling the same goods or services to a similar customer on a

stand-alone basis. Discounts are allocated proportionately to all performance obligations in the contract

unless there is observable evidence to allocate it differently.

Mobile swap contracts

Telenor offers customers in some markets the possibility to buy mobile phones through instalment plans

with the option to upgrade to a new phone before completing all payments. If the option is exercised, the

customer pays any remaining months of minimum instalment under the original contract and enters a new

contract. The transaction price at inception of the contract includes an estimate of the payments to be

received based on the expected value approach using historical data.

In some markets with mobile swap contracts, Telenor is obligated to accept the return of the original

mobile phone and a refund liability is recognised. A return good asset (see note 19), with a corresponding

adjustment to cost of sales, is recognised representing the right to recover the returned handsets. In

other markets, an external third party takes ownership of the device, resells it and guarantees a

compensation to Telenor. In these contracts, Telenor includes estimated amounts from the third party as

part of the total consideration to be received at inception of the contract.

Financing components

The sale of mobile phones and other devices may include a financing component, as the mobile phone or

other devices are provided to a customer at the start of the contract, and payments are received over an

instalment period. Financing components are not considered when the timing of the payment is at the

discretion of the customer (for example prepaid mobile services) or the timing difference between

rendering the service or good and payment is less than twelve months. If a significant financing

component is provided to the customer, the transaction price is adjusted, and interest revenue is

recognised over the customer’s payment period using an interest rate reflecting the relevant risk-free

rate and customer specific credit risk.

Sales through dealers

Mobile phones and other devices sold through dealers where the dealer is acting as an agent to sell

subscription services for Telenor, Telenor is normally not part of the dealer's sales contract for the sale of

the mobile phones and other devices. The commission paid to the dealers for sale of the subscription is

presented as contract acquisition cost and is recognised as an operating expense over the expected

customer life, see more information in note 26 Contract cost and other prepaid costs.

Sales where Telenor is acting as an agent

Telenor may act as an agent in certain sales transactions, for example insurance products offered as part

of a bundled mobile subscription. In such cases, the net commission is recognised as revenue.

Contract assets and liabilities

See note 19 for more information about trade receivables and contract assets and note 24 for more

information about contract liabilities related to customer contracts.

Lease revenues (IFRS 16)

Telenor has operating lease arrangements in which it is a lessor, mainly related to passive infrastructure

sharing with other telecommunication operators. Telenor has classified these leases as operating leases

because they do not transfer substantially all the risks and rewards incidental to ownership of the

underlying assets. Lease revenues are recognised on a straight-line basis over the lease term.

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178

Revenues from rendering of services

Revenues from rendering of services in mobile operations include subscription fees and usage‑based

traffic revenues from mobile voice and data services. Subscriptions are provided on prepaid or postpaid

terms. Revenue in mobile operations also include inbound and national roaming, revenues from service

providers and Mobile Virtual Network Operators, and interconnection fees from other operators using

Telenor’s network. Revenue from rendering of services in fixed operations include broadband, TV, data

networks, cybersecurity services, broadcasting and telephony.

Subscription fees are typically flat‑rated and some contracts include minimum commitment periods.

Billing cycles for both mobile postpaid and fixed services are predominantly monthly, though some

contracts follow longer recurring cycles, such as quarterly, depending on customer and contractual

terms.

Other revenues from rendering of services include revenues that are not classified as mobile or fixed

operations, such as services related to maritime communication, data centres and Internet-of-Things

(IoT) in Telenor Connexion.

Sale of mobile phones and other devices

Telenor sells mobile phones and other devices through its own sales channels. Mobile phones and other

devices may be sold separately or as part of bundled offerings that include subscriptions or other

services such as screen insurance. Certain mobile phone sales include instalment plans, and in some

markets, customers may upgrade to a new mobile phone after paying a minimum number of instalments.

Operating lease revenues

Revenue from operating lease predominantly stems from Infrastructure segment which leases out

passive infrastructure for mobile and fixed networks in Norway, Sweden and Finland. Operating lease

revenue of NOK 1,390 million (NOK 1,292 million in 2024) recognised in the income statement includes

variable lease revenue of NOK 193 million (NOK 196 million in 2024) primarily relating to energy charges

received from lessees based on the consumption and revenue from sublease of NOK 41 million (NOK 39

million in 2024) related to surplus office space. The following table sets forth the maturity analysis of

committed lease payments to be received in nominal terms after the reporting date.


NOK in millions	2025	2024 ¹⁾
Less than 1 year	635	639
1 to 2 years	54	67
2 to 3 years	27	32
3 to 4 years	5	14
4 to 5 years	1	3
Total	723	756
¹⁾ Comparative figures for 2024 have been re‑presented to exclude the discontinued operation.

2025

179

Disaggregation of revenues

Revenues are disaggregated by major revenue streams divided into the reportable segments as shown in note 2 Segments in the table below.


2025
NOK in millions	Mobile operations	Fixed operations	Other revenues from rendering of services ¹⁾	Total revenues from rendering of services ²⁾	Sale of mobile phones and other devices	Total revenues from contracts with customers (IFRS 15)	Operating lease revenues (IFRS 16)	Total revenues
Telenor Norway	14,988	9,339	8	24,336	2,210	26,546	6	26,552
Telenor Sweden	8,148	3,437	1	11,586	1,538	13,123	156	13,280
Telenor Denmark	4,693	629	—	5,322	844	6,166	48	6,214
DNA Finland	8,389	2,584	—	10,973	2,211	13,185	34	13,219
Other/eliminations	(4)	(102)	183	78	(1)	77	—	77
Nordics	36,215	15,888	192	52,295	6,802	59,097	244	59,341
Grameenphone - Bangladesh	13,265	—	—	13,265	12	13,277	197	13,474
Other/eliminations	—	—	250	250	—	250	—	250
Asia	13,265	—	250	13,515	12	13,527	197	13,724
Infrastructure	—	—	22	22	—	22	3,296	3,318
Amp	—	1,264	2,253	3,517	—	3,517	—	3,517
Other	—	—	1,189	1,189	—	1,189	287	1,476
Eliminations	(474)	(368)	(1,349)	(2,191)	(3)	(2,194)	(2,635)	(4,829)
Group	49,006	16,785	2,556	68,347	6,810	75,158	1,390	76,548

1) Other revenues from rendering of services includes Internet of Things (IoT) in non-mobile operations and other non-core business revenues.

2) Service revenues as explained in chapter Alternative Performance Measures are not comparable with “total revenues from rendering of services” disclosed in this note. The reason is that revenue from rendering services to other operators

and other wholesale activities are not part of service revenue definition in Alternative Performance Measures.

2025

180


2024
NOK in millions	Mobile operations	Fixed operations	Other revenues from rendering of services ¹⁾	Total revenues from rendering of services ²⁾	Sale of mobile phones and other devices	Total revenues from contracts with customers (IFRS 15)	Operating lease revenues (IFRS 16)	Total revenues
Telenor Norway	13,993	9,291	3	23,287	1,926	25,213	8	25,221
Telenor Sweden	7,494	3,378	—	10,872	1,737	12,609	171	12,780
Telenor Denmark	4,333	663	—	4,996	818	5,814	43	5,856
DNA Finland	7,890	2,517	—	10,407	2,239	12,646	35	12,681
Other/eliminations	(47)	(101)	171	23	(1)	23	—	22
Nordics	33,663	15,748	174	49,585	6,719	56,304	256	56,560
Grameenphone - Bangladesh	14,915	—	—	14,915	9	14,924	214	15,138
Other/eliminations	—	—	339	339	—	339	—	339
Asia	14,915	—	339	15,254	9	15,263	214	15,477
Infrastructure	—	—	238	238	—	238	3,044	3,282
Amp	—	1,576	1,919	3,495	—	3,495	—	3,495
Other	—	—	1,428	1,428	—	1,428	276	1,704
Eliminations	(452)	(368)	(1,709)	(2,528)	(4)	(2,532)	(2,499)	(5,031)
Group	48,126	16,956	2,389	67,471	6,724	74,195	1,292	75,487

1) Other revenues from rendering of services includes Internet of Things (IoT) in non-mobile operations and other non-core business revenues.

and other wholesale activities are not part of service revenue definition in Alternative Performance Measures.

2025

181

Note 4

Costs of materials and traffic charges

The cost of material and traffic charges include the cost of sold mobile phones and

other materials, network capacity costs and national and international traffic charges

from other operators.


Cost of materials and traffic charges
NOK in millions	2025	2024
Traffic charges	(5,271)	(5,710)
Cost of materials and other¹⁾	(11,972)	(11,603)
Total costs of materials and traffic charges	(17,244)	(17,313)

1) Cost of materials and other include variable lease expenses, see note 16 Right-of-use assets for more information.

Power Purchase Agreements (PPAs)

Telenor has signed ten-year PPAs for Norway, Denmark, and Finland for delivery of renewable energy

from wind and solar farms to its operations. The wind power plant located in Sweden that will power

Telenor's operations in Norway became operational in early 2024. The wind power plant in Finland went

operational in January 2025, and the solar plant in Denmark became operational in July 2025. Further

detail on the Group’s contractual commitments related to the PPAs is provided in note 25 Contractual

commitments.

ACCOUNTING POLICIES

Cost of sold mobile phones and other materials is recognised at the point of sale. Traffic charges are

recognised when incurred. Power Purchase Agreements (PPAs) to buy energy from wind and solar parks

include both Guarantees of Origin (GOs) and fixed prices for energy. The PPAs fulfil the "own use"

exemption under IFRS 9, hence the purchase of energy under the PPAs at fixed price are recognised as

cost of materials and traffic charges when incurred.

Note 5

Salaries and personnel costs

Telenor had around 10,000 full-time equivalent employees for its continuing

operations both as of 2025 and as of 2024 . The employees have various benefits in

addition to salary, including a share- based payment program.


Overview of salary and personnel costs
NOK in millions	2025	2024
Salaries and holiday pay	(8,881)	(8,574)
Social security tax	(1,047)	(1,011)
Pension costs including social security tax (note 21 )	(1,083)	(1,081)
Share-based payments ¹⁾	(148)	(189)
Other personnel costs	(333)	(338)
Own work capitalised	1,678	1,451
Total salaries and personnel costs	(9,814)	(9,741)

1) Include expenses related to the Group's employee share programme, and the Group's long term incentive

programme for managers and key personnel. Please refer to note 37 Key management compensation.

Share-based payment program

Employees and managers worldwide are offered to purchase Telenor shares at a discounted price and

potentially earn bonus shares if the share price exceeds certain benchmarks in the future. Bonus shares

are awarded net after tax and Telenor withhold and pay withholding taxes on behalf of the employee. The

share-based payment programs including the withholding tax are considered as equity-settled share-

based payments, where the fair value of the bonus shares is estimated at the grant date and expensed

over the vesting period. Social security taxes are recognised as cash-settled share-based payments

measured at fair value and remeasured at each reporting date.

2025

182

Note 6

Other operation expenses


NOK in millions	2025	2024
Other cost of premises, vehicles, office equipment etc.	(765)	(804)
Operation and maintenance	(4,612)	(4,687)
Marketing and sales commission	(4,201)	(4,070)
Advertising	(1,265)	(1,253)
External personnel and consultancy fees	(1,621)	(1,669)
Variable lease expenses ¹⁾	(1,435)	(1,574)
Other ²⁾	(1,129)	(1,204)
Total other operating expenses	(15,028)	(15,261)
1) See note 16 Right-of-use assets for more information.
2) Includes expenses related to short term and low value leases, refer to note 16 Right-of-use assets for more information.

Note 7

Research and development costs

Research and development activities in 2025 focused on strengthening future

network capabilities and advancing digital technologies. Most activities related to

early‑phase development, which generally do not meet the capitalisation criteria

under IAS 38 and are therefore expensed as incurred.

ACCOUNTING POLICIES

Research and development costs are assessed for whether or not they meet the capitalisation criteria in

IAS 38 Intangible Assets. Generally, they are expensed as incurred as they do not meet the requirements.

Research and development costs

Research and development costs that have been recognised in the income statement amount to NOK

197 million in 2025 (NOK 149 million in 2024). Expensed activities mainly relate to next‑generation

networks and internet technologies, artificial intelligence and advanced analytics, cloud‑based solutions,

and development of business and operating models. Typical costs include salaries, tools, and

technology‑related upgrades.

2025

183

Note 8

Other income and other expenses

Income and expenses not regarded as part of regular operational performance are

presented on a separate line as other income and other expenses in Telenor. It

includes gains and losses on disposal of PPE and other non-current assets,

restructuring costs, losses from onerous contracts and fines concluded in legal

disputes.

Other income and other expenses


NOK in millions	2025	2024
Gains on disposals of property, plant and equipment (PPE), right-of-use assets and operations	741	1,479
Other	3	—
Total other income	744	1,479
Losses on disposals of property, plant and equipment (PPE), right-of-use assets and operations	(429)	(277)
Expenses for workforce reductions, onerous contracts and other	(484)	(511)
Total other expenses	(913)	(788)

For the year 2025, total other income of NOK 744 million mainly related to NOK 535 million gain from the

sale of shares in subsidiary owned by Telenor Norway, followed by the merger between Telenor Software

Lab and Jottacloud in Norway. Total other expenses of NOK 913 million consisting mainly of losses on

disposals of property, plant and equipment, right-of-use assets and operations of NOK 429 million, of

which NOK 298 million in Telenor Norway and workforce reductions of NOK 430 million, of which NOK 257

million in Telenor Norway.

In 2024, total other income of NOK 1,479 million is mainly related to gain from the sale of Telenor Satellite

of NOK 1,359 million. Total other expenses of NOK 788 million consisted mainly of workforce reductions

of NOK 509 million, of which NOK 309 million in Telenor Norway.

ACCOUNTING POLICIES

Other income and other expenses are items that are not regarded as part of regular operational

performance. The purpose of presenting these items on separate lines is to enable comparison of

underlying profitability between periods. It includes gains and losses on disposal of non-current assets

such as property, plant and equipment (PPE) and intangible assets. It also includes gains and losses

from sale of subsidiaries, unless the sale is presented as discontinued operations.

Restructuring costs are included to the extent they qualify as a restructuring in IAS 37 Provisions,

Contingent Liabilities and Contingent Assets. Costs related to reduction of personnel is only included

when they relate to the time the employee no longer renders services to Telenor. Costs for loss

contracts are included when they qualify as onerous contracts under IAS 37. Material fines concluded in

legal disputes are included, whereas settlements on legal disputes are only included in other income

and other expense when they relate to the business as a whole and are non-recurring in nature.

2025

184

Note 9

Financial income and expenses

Financial income in Telenor includes interest income on cash equivalents as well as customer credit. The

interest expenses mainly relate to bonds, derivatives, and other borrowings in addition to lease liabilities.

Other financial items include foreign currency gains and losses and change in fair value of hedging

instruments and hedged items.

Financial income and expenses


NOK in millions	2025	2024
Interest income on cash and cash equivalents	465	830
Other financial income	211	210
Total financial income	676	1,040

Interest expenses on financial liabilities ¹⁾	(3,335)	(3,835)
Other financial expenses	(357)	(420)
Total financial expenses	(3,692)	(4,255)

Foreign currency gains	1,648	3,152
Foreign currency losses	(1,301)	(3,685)
Net foreign currency gains (losses)	347	(533)

Net change in fair value of financial instruments at fair value through profit or loss	(616)	2,398
Net change in fair value of hedging instruments and hedged items	139	93
Net gains (losses and impairment) on financial assets and liabilities	—	27
Change in fair value of financial instruments	(477)	2,518
Net financial income (expenses)	(3,147)	(1,230)
1) Includes interest expenses on lease liabilities, see note 16 Right-of-use assets for more information.

ACCOUNTING POLICIES

Interest expenses related to bonds, commercial papers, bank loans and bank overdrafts are recognised at

amortised cost using the effective interest-rate method. Foreign currency gains and losses arise from

monetary assets and liabilities denominated in foreign currencies that are translated to the functional

currency. All such exchange differences are recognised in the income statement except exchange

differences on foreign currency borrowings and monetary items that provide an effective hedge against a

net investment in a foreign entity. These gains and losses are recognised in other comprehensive income

until the disposal of the net investment, at which time they are recognised in the income statement.

Dividend income from investments is recognised when the rights to receive payment have been

established (declared by the Annual General Meeting or otherwise) and classified as financial income.

In 2025, the total financial income decreased by NOK 365 million compared to 2024 , primarily due to

lower average interest rates on cash and cash equivalents.

Interest expenses on the financial liabilities decreased by NOK 500 million compared to 2024, mainly

driven by lower average interest rate and favourable foreign exchange effects following a strengthening

of NOK.

Net foreign currency gain amounted to NOK 347 million in 2025, compared to net losses of NOK 533

million in 2024 . The improvement primarily reflects favourable NOK exchange rate movements during

2025.

The significant positive net change in fair value of financial instruments in 2024 mainly related to fair

value adjustment of the shareholder loan for the indirectly owned shares in the True Corporation. In

2025, the net change in fair value is negative.

2025

185

Note 10

Income taxes

Telenor is in a tax payable position in most jurisdictions. Telenor is involved in several

legal proceedings and discussions related to its tax position where the outcome is

uncertain. Uncertain tax positions may require significant judgment including

assessment of future taxable profits and estimating the outcome of significant tax

disputes.

Income tax expense


NOK in millions	2025	2024
Profit before taxes	16,654	23,494
Current taxes	(3,384)	(2,921)
Deferred taxes	(980)	(798)
Income taxes	(4,364)	(3,719)

Current taxes

In 2025, current taxes are impacted by the retroactive implementation of a lower tax deprecation rate in

Bangladesh on equipment acquired from 2022. In 2024, Grameenphone reversed NOK 487 million in

current tax provisions, after receiving clarifications on certain tax provisions in the new Income Tax Act

of 2023.

Deferred taxes

In 2025, deferred taxes are impacted mainly by a provision for withholding tax on retained earnings in

True Corporation, partly offset by the effect of the above mentioned retroactive change in tax

depreciation in Bangladesh. In 2024, deferred taxes were mainly impacted by the realisation of tax losses

in Norway.

ACCOUNTING POLICIES

Telenor bases its assessment of taxable income on interpretation of relevant laws and regulations, and

when it is considered as probable that the tax treatment will be sustained in a tax review. Current tax

assets and liabilities are measured at the amount expected to be recovered or paid to the tax authorities.

Deferred tax assets and liabilities are calculated using the liability method where deferred taxes are

recognised on the difference between the tax base and the carrying amount of the assets and liabilities,

including tax losses carried forward. Deferred tax assets and liabilities are not recognised on goodwill.

They are also not recognised on investments in subsidiaries, associates, or joint ventures where the

timing of the reversal can be controlled, and it is probable that the temporary difference will not be

reversed in the foreseeable future. Deferred tax assets are only recognised to the extent it is more likely

than not that the tax assets will be utilised. Deferred tax assets and liabilities are offset when there is a

legally enforceable right, and Telenor is capable to and intends to settle on a net basis. The enacted tax

rates at the end of the reporting period and undiscounted amounts are used. A change in deferred tax

assets and liabilities because of change in tax rates is recognised in profit or loss, except when it relates to

items that previously was recognised in other comprehensive income or directly in equity. Deferred tax is

provided for undistributed earnings in subsidiaries when distribution is expected in foreseeable future.

Deferred tax for undistributed earnings in associated companies is provided for as the timing of the

reversal of the temporary differences cannot be controlled by Telenor. Telenor applies the exemption not

to recognise and disclose information about deferred tax assets and liabilities related to Pillar II Rules, as

provided in IAS 12 Income Taxes.

KEY SOURCES OF ESTIMATED UNCERTAINTIES

Significant judgements are required when assessing uncertain tax assets, like tax losses carried forward,

including assessment of taxable profits in futures years as well as tax planning strategies and the

existence of taxable temporary differences. Entities with a history of recent losses need convincing

evidence that sufficient future taxable profit will be generated before a tax asset is recognised.

Uncertainty related to new transactions and events and the interpretation of new tax rules may also affect

these judgements. Telenor is involved in various legal proceedings, disputes and claims related to its

income tax positions where the outcomes is subject to significant uncertainty. The management

assessment may include interpretation of relevant laws, regulations, and the outcome of similar tax

disputes in the same jurisdiction, expert opinions from external tax advisors and communication with the

tax authorities. A tax provision is recognised when an unfavourable outcome is considered probable, and

a reliable estimate can be made. In Norway, a formal decision made by the tax authorities or lower courts

is presumed to represent the best estimate for accounting purposes unless expert opinions can point to

errors clearly indicating that the tax assessment is incorrect. The tax provision is updated whenever the

assumptions change. Tax disputes are disclosed in this note if they are considered significant for Telenor.

See also note 23 Legal Disputes and contingencies.

2025

186

Effective tax rate

The table below reconciles the reported income tax expense to the expected income tax expense

according to the Norwegian corporate income tax rate of 22%. It also discloses the main elements of the

tax expense. Comments are provided on selected line items below the table.


Effective tax rate
NOK in millions	2025	2024
Income tax expense at corporate income tax rate in Norway 22%	(3,664)	(5,169)
Effect of tax rates outside Norway different from 22%	(695)	(764)
Current and deferred taxes on retained earnings and dividends	(446)	(290)
Impairment (reversal) of True Corporation	(59)	1,543
Impairment of Carousell	—	(87)
Gain on disposal of Telenor Satellite	—	299
Gain from merger of Telenor Software Lab and Jottacloud	118	—
Fair value adjustment of shareholder loan funding the investment in True Corporation	(36)	352
Grameenphone tax settlements and new tax act	—	487
Other items	101	(37)
Prior year assessments or adjustments on current tax	317	(52)
Income taxes	(4,364)	(3,719)
Effective tax rate in %	26.2	15.8

Tax rates outside Norway different from 22%

Effects are mainly related to Grameenphone Ltd. (Bangladesh: 40%) having higher nominal tax rates than

the nominal tax rate for Norway. Telenor Sweden (20.6%) and DNA (Finland: 20%) have lower nominal tax

rates.

Current and deferred taxes on retained earnings and dividend

Includes current taxes on dividends received, as well as change in deferred tax liability (primarily

withholding tax) recognised on undistributed earnings in subsidiaries and associates outside of Norway.

Gain from the merger between Telenor Software Lab and Jottacloud in Norway

In 2025, Telenor merged its cloud business (Telenor Software Lab) with Norwegian cloud storage

provider Jottacloud.

Fair value adjustment of shareholder loan funding the investment in True Corporation

In 2025, negative fair value adjustment of NOK 212 million has been recognised on the shareholder loan

related to the funding of investment in True Corporation, compared to positive fair value adjustment of

NOK 2,068 million in 2024.

Grameenphone tax settlements and new tax act

After receiving in 2024 clarifications on certain tax provisions in the new Income Tax Act of 2023,

Grameenphone reversed NOK 487 million in provisions.

2025

187

Tax losses carried forward

Tax losses carried forward expire as follows as of 31 December 2025


NOK in millions	Norway	Denmark	Other	Total
2026	—	—	24	24
2027	—	—	24	24
2028	—	—	21	21
2029	—	—	124	124
2030	—	—	—	—
2031 and later	—	—	102	102
Not time-limited	1,870	188	16	2,074
Total tax losses carried forward	1,870	188	311	2,369
Of which deferred tax assets have not been recognised	—	172	280	452
Of which deferred tax assets have been recognised	1,870	15	32	1,917

In 2025, tax losses carried forward, before and after valuation allowance, reduced by NOK 53 million and

NOK 50 million compared to 2024. The change in 2025 is mainly related to generation of tax loss carry

forward in Norway and utilisation of tax loss carry forward in Denmark.

Tax assets recognised on tax losses carried forward

Norway and Denmark recognised tax assets on unused tax losses as Telenor expects there will be

sufficient future taxable profits available to utilise these losses.

Tax losses carried forward expire as follows as of 31 December 2024


NOK in millions	Norway	Denmark	Other	Total
2025	—	—	18	18
2026	—	—	34	34
2027	—	—	46	46
2028	—	—	49	49
2029	—	—	136	136
2030 and later	—	—	117	117
Not time-limited	1,616	299	—	1,916
Total tax losses carried forward	1,616	299	400	2,316
Of which deferred tax assets have not been recognised	—	172	277	448
Of which deferred tax assets have been recognised	1,616	127	123	1,867

In 2024, tax losses carried forward, before and after valuation allowance, decreased by NOK 547 million

and NOK 563 million, mainly related to utilisation of tax loss carry forward in Norway and Denmark.

2025

188


Tax effect of temporary differences and tax losses carried forward as of 31 December
NOK in millions	2025					2024
NOK in millions	Deferred tax assets	Deferred tax liabilities	Of which deferred assets not recognised	Recognised in the income statement		Deferred tax assets	Deferred tax liabilities	Of which deferred assets not recognised	Recognised in the income statement
Tangible and intangible assets	1,839	(8,412)	—	519		1,966	(9,415)	(297)	(583)
Undistributed earnings in foreign subsidiaries and associated companies	—	(501)	—	(193)		—	(352)	—	(93)
Non-current borrowings	3,553	(3)	—	(1,871)		6,031	(39)	—	559
Other non-current items	1,270	(2,010)	—	(36)		1,144	(1,685)	—	(157)
Total non-current assets and liabilities	6,662	(10,926)	—	(1,581)		9,140	(11,492)	(297)	(274)
Total current assets and liabilities	2,549	(87)	—	597	3,071		(86)	—	(384)
Tax losses carried forward	518	—	(102)	12		508		(103)	(141)
Valuation allowance recognised in the income statement				(8)					1
Deferred tax recognised in the income statement				(980)					(798)
Total deferred tax assets/liabilities	9,729	(11,013)	(102)			12,719	(11,579)	(400)
Net deferred tax assets/liabilities		(1,386)					740
Of which deferred tax assets		3,067					4,614
Of which deferred tax liabilities		(4,453)					(3,874)

For 2025, total non-current assets and liabilities decreased by NOK 2,478 million, and NOK 566 million

respectively. Total current assets decreased by NOK 522 million. Tax losses carried forward decreased by

NOK 10 million. Net deferred assets/liabilities decreased by NOK 2,126 million. The change is mainly due to

the utilisation of tax losses carry forward and the Telenor Pakistan disposal.

For 2024, total non-current assets and liabilities increased by NOK 585 million, and NOK 1,160 million

respectively. Total current assets and liabilities increased by NOK 384 million and NOK 40 million

respectively. Tax losses carried forward decreased by NOK 126 million. Net deferred assets/liabilities

decreased by NOK 187 million.

2025

189

Changes in net deferred tax assets and liabilities


NOK in millions	2025	2024
As of 1 January	740	927
Recognised in the income statement	(980)	(798)
Recognised in other comprehensive income	56	497
Recognised directly to equity	8	8
Acquisitions and disposals of subsidiaries	(880)	(16)
Discontinued operations	(135)	119
Translation differences on deferred taxes	(195)	3
As of 31 December	(1,386)	740

Recognised in the income statement

The change of the amount recognised in the income statement between 2025 and 2024 is mainly

related to Bangladesh and Norway.

Recognised in other comprehensive income

The change of the amount recognised in other comprehensive income between 2025 and 2024 is mainly

related to losses on net investment hedges.

Disposal of subsidiaries

2025 is related to the Telenor Pakistan disposal.

Discontinued operations

2025 and 2024 is related to the reclassification of Telenor Pakistan to discontinued operations.

Pillar II

Telenor group is within scope of OECD Pillar II legislation. On the reporting date, local Pillar II legislation

has been enacted and entered into force in Norway and in most of the relevant jurisdictions where

Telenor operate and have constituent entities. Telenor has developed procedures for gathering

information required for assessing the applicability of the safe harbour rules and estimation of effective

tax rate for countries that do not qualify for safe harbour.

The assessment for 2025 is that the Telenor has no related current tax exposure for this year, because

safe harbour is applicable and/or estimated effective tax rate is above 15%. Telenor applies the

exemption not to recognise and disclose information about deferred tax assets and liabilities related to

Pillar II income taxes, as provided in the amendments to IAS 12 Income Taxes issued in May 2023. Based

on the tax rate in the countries where Telenor has taxable presence, any exposure to top-up tax is not

expected to be material. Due to the complexities in applying the legislation combined with the fact that

not all information about future events is available, top-up tax can however not be ruled out for Telenor

in 2026 or later years.

2025

190

Note 11

Earnings per share and dividends

The earnings per share (EPS) for 2025 was NOK 5.14 compared to NOK 13.32 for 2024.

The dividend policy in Telenor is to aim for a year-on-year growth in nominal dividend

per share. The annual dividends are normally paid in two instalments. The Board of

Directors has proposed a dividend of NOK 9.70 per share for 2025.

ACCOUNTING POLICIES

Earnings per share (EPS) is the amount of profit generated for the financial year attributable to equity

shareholders divided by the weighted average ordinary outstanding shares.

Earnings per share

The calculations of earnings per share attributable to the ordinary equity holders of Telenor ASA are

shown below.

Net income to equity holders of Telenor ASA


NOK in millions	2025	2024
Net income from continuing operations after non-controlling interest	10,962	18,002
Net income (loss) from discontinued operations after non-controlling interest	(3,927)	333
Net income from total operations attributable to equity holders of Telenor ASA	7,034	18,336

Number of shares


In thousands	2025	2024
Weighted average number of shares for the purpose of both basic and diluted earnings per share	1,368,211	1,376,441

Basic/Diluted earnings per share


NOK	2025	2024
Basic/Diluted earnings per share from continuing operations	8.01	13.08
Basic/Diluted earnings per share from discontinued operations	(2.87)	0.24
Basic/Diluted earnings per share from total operations	5.14	13.32

Dividends to equity holders of Telenor ASA


NOK	2025	2024
Ordinary dividend per share in NOK – paid	9.60	9.50
Ordinary dividend per share in NOK - proposed by the Board of Directors	9.70	9.60

Total dividend of NOK 13,135 million has been paid and charged to equity in 2025 (NOK 13,082 million in

2024).

In respect of 2025, the Board of Directors proposed an ordinary dividend of NOK 9.70, to be approved by

the Annual General Meeting on 19 May 2026. The total amount of dividend is estimated to be NOK 13,272

million based on the outstanding number of shares as of 31 December 2025. The dividend will be split into

two tranches of NOK 5.00 and NOK 4.70 per share to be paid out in June and October 2026, respectively.

Dividends paid to non-controlling interests

During 2025, dividends paid to non-controlling interests in subsidiaries amounted to NOK 1,732 million

(NOK 1,425 million in Grameenphone and NOK 304 million in Telenor Fiber AS). During 2024, dividends

paid to non-controlling interests in subsidiaries amounted to NOK 1,871 million (NOK 1,627 million in

Grameenphone and NOK 245 million in Telenor Fiber AS).

2025

191

Note 12

Held for sale and discontinued operations

Operations presented as discontinued operations and held for sale includes Telenor

India which was disposed in 2018, Canal Digital which was disposed in 2020 and

Telenor Pakistan which was disposed in 2025.

Discontinued operations and liabilities held for sale

Pursuant to earlier announced sale of Telenor Pakistan, on 31 December 2025, the sale transaction was

completed. The group received NOK 1,582 million (net of tax) for sale of shares, in addition to NOK 2,335

million received by Telenor Pakistan from the buyer in shareholder loan for settling Telenor Pakistan's

internal debt towards Telenor ASA. Loss on disposal of NOK 3,044 million (net of tax) was recognised.

Historical income statement figures of Telenor Pakistan until disposal date, including loss on disposal,

have been presented as discontinued operations as it represents a major line of business.

Summary all disposal groups

The profit (loss) of all disposal groups including Telenor Pakistan, India and Canal Digital presented as

discontinued operations until disposal, and subsequent adjustments is shown in the following table:


NOK in millions	2025	2024
Revenue	4,839	4,441
EBITDA	2,082	1,704
EBIT	1,092	711
Profit (loss) before tax	917	600
Income tax	(547)	(6)
Profit (loss) after tax	370	594
Gain (loss) on disposal before tax	(4,099)	(260)
Income tax	(198)	—
Gain (loss) on disposal after tax	(4,297)	(260)
Profit (loss) from discontinued operations	(3,927)	333

ACCOUNTING POLICIES

Non-current assets and disposal groups are classified as held for sale if their carrying amounts will be

recovered principally through sale rather than continuing use. This also applies for situations where the

Group continues its operations but loses control over the operation. Non-current assets and disposal

groups classified as held for sale are measured at the lower of their carrying amount and fair value less

cost to sell and presented separately as assets held for sale and liabilities held for sale in the statement of

financial position.

The criteria for held for sale classification is regarded as met only when the sale is highly probable, and the

asset or disposal group is available for immediate sale in its present condition. Actions required to

complete the sale should indicate that it is unlikely that significant changes to the plan will be made or that

the plan to sell will be withdrawn. In addition, management must be committed to the plan, and must be

expected that the sale will be completed within a year.

Property, plant and equipment and intangible assets are not depreciated or amortised once classified as

held for sale. The equity method is discontinued for associated companies classified as held for sale.

A disposal group qualifies as discontinued operation if it is a cash generating unit that has either been

disposed of, or is classified as held for sale, and represent a separate major line of business or

geographical area of operations. Discontinued operations are excluded from the results of continuing

operations and are presented as a single amount as profit or loss after tax from discontinued operations

in the income statement. Discontinued operations are also excluded from segment reporting. All

consolidation procedures are still applicable, and only external revenues and expenses are shown as

discontinued operation.

2025

192

Profit (loss) after tax represents Telenor Pakistan only. Loss on disposal after tax for 2025 of NOK 4,297

million includes NOK 3,044 million loss (net of tax) related to Telenor Pakistan, of which NOK 2,909 million

relates to reclassification of translation differences including net investment hedge (net of tax) from

other comprehensive income. In addition, loss on disposal after tax for 2025 includes NOK 182 million

based on a ruling from tax authorities in a VAT case related to the then Canal Digital business in Norway

for the period 2016-2019. Telenor India contributed with a loss of NOK 1,072 million including NOK 1,212

million additional provision with interest based on adverse Supreme Court ruling in another operator's

case related to one time spectrum charge. The one time spectrum charge relates to the period when

original spectrum licenses were quashed on 2 February 2012 until circle businesses were either

continued after the subsequent spectrum auction in 2012 or closed down in 2013, see note 23 Legal

disputes and contingencies for further information. Loss on disposal after tax for 2024 was primarily

related to Telenor India accrual of incremental interest for the demand from Department of

Telecommunication (DoT) in India and related currency effect.

Cash flow related to discontinued operations presented below are from external transactions and hence,

the cash flows for discontinued operations do not reflect these operations as if they were standalone

entities. Cash flow from investing activities include cash received related to disposal of shares net off the

de-consolidation of cash and cash equivalents in disposed entity. The below cash flow relates solely to

Telenor Pakistan except for NOK 197 million payment related to Canal Digital case in 2025 as part of net

cash flow from investing activities.



NOK in millions	2025	2024
Net cash flow from operating activities	1,193	1,503
Net cash flow from investing activities	1,294	(487)
Net cash flow from financing activities	1,865	(908)
Total cash flows from discontinued operations	4,353	107
Effects of exchange rate changes on cash and cash equivalents	17	(15)
Net cash flows from discontinued operations	4,370	92

Net cash flow from operating activities for 2025 were impacted by NOK 289 million in additional income

tax payments in Pakistan due to forgiveness of intercompany receivables towards Telenor Pakistan. Net

cash flow from investing activities for 2025 include proceeds of NOK 1,582 million (net of tax) as

consideration for sale of shares in Telenor Pakistan and NOK 671 million positive effect due to

deconsolidation of negative cash balance in Telenor Pakistan. Net cash flow from financing activities for

2025 include NOK 2,335 million received by Telenor Pakistan from the buyer in shareholder loan for

settling Telenor Pakistan's internal debt towards Telenor ASA.

The entire amount of the liability classified as held for sale as of 31 December 2025 and as of 31

December 2024 represents Telenor India.


NOK in millions	2025	2024
Liabilities
Current liabilities	5,033	4,220
Total liabilities held for sale	5,033	4,220

Telenor India

On 23 February 2017, the Group entered into an agreement with Bharti Airtel Limited (Airtel), whereby

Airtel would take full ownership of Telenor India. The transaction was completed on 14 May 2018. The

exposure to claims related to the period Telenor owned the business remains with Telenor. A guarantee

to Airtel was recognised at fair value as of closing date of the transaction, and subsequent changes to

the estimate, including interest accrued and currency effects, are recognised on the discontinued

operations line in the income statement.

The liability of NOK 5,033 million as of 31 December 2025 includes NOK 1,435 million related to

aforementioned one time spectrum charge. The remaining liability of NOK 3,598 million predominantly

stem from dispute on how to calculate adjusted gross revenue (AGR) which is the basis for determining

licence fees in India culminated in 2019 in a ruling by the Supreme Court (the "AGR Judgement"). A

government established payment moratorium provides that liabilities related to AGR Judgement shall, at

the latest, be paid down in six annual instalments. Final instalment amounts payable are subject to

change, but the first instalment payable in the first quarter of 2026 is currently expected to be

approximately NOK 0.7 billion. The outstanding payments accrue interest.

It follows from Telenor’s indemnity undertaking to Bharti Airtel that Telenor’s payment obligation can be

accelerated by Bharti Airtel, as well as by Telenor itself. See note 23 Legal disputes and contingencies for

further information regarding the dispute.

Accumulated amounts recognised in Other comprehensive income.

The accumulated amounts for discontinued operations recognised in Other comprehensive income

within Equity are as follows:


NOK in millions	2025	2024
Telenor India	(921)	(1,180)

2025

193

NOTE 13

Cash flow information

This note summarises the most significant cash inflows and outflows during the year,

including significant investments and disposals in addition to payments of interest-

bearing liabilities and leasing liabilities.

Changes in operating working capital

Changes in operating working capital include changes in inventory, trade and other receivables and trade

and other payables (excluding capital expenditure related trade and other payables).


NOK in millions	2025	2024
Change in inventory	14	114
Change in trade and other receivables	(119)	2,245
Change in trade and other payables	244	389
Change in operating working capital	140	2,748

The negative decline in change in trade and other receivables in 2025 compared to 2024 was primarily

related to increase in receivables for mobile phones sold on instalments in Telenor Norway, Telenor

Sweden and Telenor Denmark. Telenor has several working capital improvement initiatives in place in the

Nordics that impacts working capital positively. See note 19 Trade and other receivables for information

related to third party financing of mobile phones receivables and note 24 Trade and other payables for

more information related to Supplier Finance Arrangements.

ACCOUNTING POLICIES

Telenor presents the statement of cash flows using the indirect method. Cash inflows and outflows are

shown separately for investing and financing activities, while operating activities include both cash and non-

cash line items. Interest received and paid, and dividends received, are reported as a part of operating

activities. Dividends distributed by Telenor ASA and subsidiaries with non-controlling interests are included

as a part of financing activities. Value-added tax (VAT) and other similar taxes are regarded as collection of

tax on behalf of authorities and are reported net. Discontinued operations are included in the cash flow

statement and information about operating, financing, investing cash flows from discontinued operations is

shown in note 12 Held for sale and discontinued operations.

Purchases of property, plant and equipment and intangible assets


NOK in millions	2025	2024
Additions to property, plant and equipment and (see note 17 )	(8,038)	(10,616)
Additions to intangible assets (see note 15)	(2,953)	(2,980)
Change in estimates for ARO obligations	(279)	355
Changes in accounts payable and prepayments	(132)	302
Other adjustments	63	10
Purchases of property, plant and equipment and intangible assets	(11,338)	(12,929)

During 2025 and 2024, change in accounts payable and prepayment is mainly related to Norway. Change

in estimate for ARO obligations primarily reflects movements in the discount rates with no immediate

cash effect.

Prepayment of right-of-use assets including initial direct cost


NOK in millions	2025	2024
Additions to right-of-use assets (see note 16)	(4,760)	(5,257)
Lease liabilities	4,372	4,843
Other adjustments	188	36
Prepayments at or before lease commencement including initial direct cost	(200)	(378)
Prepayments prior to commencement of leases	(390)	(76)
Prepayment of right-of-use assets including initial direct cost	(590)	(454)

Cash payments at or before lease commencement date and payments of initial direct costs are classified

as cash outflows from investing activities. Subsequent payments during the lease term are classified as

cash outflows from financing activities.

During 2025, the recognised lease liabilities of NOK 4,372 million represent the deferred payments of total

additions in right-of-use assets of NOK 4,760 million, where NOK 200 million was paid at or before lease

commencement date mainly relating to prepayments of other lease contracts in Sweden, which is

classified as cash outflow from investing activities. See note 16 Right-of-use assets for more information.

2025

194

During 2024, the recognised lease liabilities of NOK 4,843 million represent the deferred payments of

total additions in right-of-use assets of NOK 5,257 million, where NOK 378 million was paid at or before

lease commencement date mainly relating to prepayments of other lease contracts in Sweden and

Norway, which is classified as cash outflow from investing activities. See note 16 Right-of-use assets for

more information.

Prepayments prior to commencement of leases of NOK 390 million in 2025 is solely related to last

instalment of spectrum licenses acquired in the renewal auction in 2023 in Sweden. Acquired spectrum

licenses has a commencement date 1 January 2026 when existing spectrum licenses expires.

Acquisitions and disposals of businesses

Acquisition of subsidiaries, associates and joint ventures

The table below shows the effects on the consolidated statement of financial position from acquisition

of subsidiaries, associates, and joint ventures.


NOK in millions	2025	2024
Investments in associates and joint ventures	3,126	2,323
Total other non-current assets	37	27
Current assets	50	9
Liabilities	(28)	(8)
Non-controlling interests	(11)	—
Total purchase price and capital injections	3,175	2,352
Of which non-cash	(2,356)	(2,101)

Cash payments related to acquisitions	(819)	(251)
Cash in subsidiaries acquired	25	2
Purchases of businesses, net of cash acquired	(794)	(249)

During 2025, cash effect of investments of NOK 794 million include investments in associates of NOK 803

million of which NOK 493 million was related to cash effect converting the remaining 1.7% indirect

ownership interest in True Corporation into direct ownership and NOK 234 million related to investment

in Skygard Holding.

The non-cash effect of the purchase price of NOK 2,356 million relates primarily to investment in

associates and joint ventures and includes NOK 1,750 million related to conversion of earlier provided

loan in 2023 into direct ownership via shares and NOK 572 million related to Jottacloud transaction, see

further details related to in note 35 Associates and joint arrangements.

During 2024, cash effect of investments of NOK 249 million include NOK 224 million related to

investments in associate. The non-cash effect of the purchase price of NOK 2,101 million primarily related

to conversion of earlier provided loan in 2023 into shares in True Corporation in 2024. See further details

related to True transaction in note 35 Associates and joint arrangements.

Disposals of businesses

The table below shows the effects on the consolidated statement of financial position from disposals of

subsidiaries, associates, and joint ventures.


NOK in millions	2025	2024
Associates and joint ventures (refer to note 35 )	659	4
Other non-current assets	5,824	1,243
Current Assets	2,029	434
Liabilities	(6,154)	(656)
Gains (losses) adjusted for translation differences on disposals ^{1) 2)}	(568)	1,121
Sales price	1,790	2,145
Of which non-cash	499	245

Proceeds received as sale consideration	2,290	2,390
Cash in subsidiaries disposed of	659	(252)
Proceeds from disposal of businesses, net of cash disposed	2,949	2,138

1) Total gain (loss) adjusted for translation differences in 2025 excludes NOK 2,965 million relating to reclassification

of translation differences from other comprehensive income to the income statement before tax, total loss

including translation differences in the income statement equals NOK 3,533 million, of which NOK 4,099 million loss

in discontinued operations.

2) Total gain (loss) adjusted for translation differences in 2024 excludes NOK 33 million relating to reclassification of

translation differences from other comprehensive income to the income statement, total gain including translation

differences in the income statement equals NOK 1,154 million, of which NOK 260 million loss in discontinued

operations.

2025

195

The proceeds from disposals of NOK 2,949 million during 2025 primarily relates to the sale of Telenor

Pakistan of NOK 2,432 million and sale of Allente of NOK 640 million. The non-cash effect of the sale price

of NOK 499 million primarily relates to non-cash loss on disposal in discontinued operations related to

India of NOK 1,072 million, see note 12 Held for sale and discontinued operations partly offset by non-cash

gain of NOK 535 million on merger between Telenor Software Lab and Jottacloud in Norway.

The proceeds from disposals of NOK 2,138 million during 2024 primarily related to the sale of Satellite of

NOK 2,122 million. The non-cash effect of the sale price of NOK 245 million primarily relates to loss on

disposal in discontinued operations related to India, see note 12 Held for sale and discontinued

operations.

Income tax withheld from proceeds relating to disposal of businesses

Upon completion of sale transaction of Telenor Pakistan, NOK 179 million was withheld by the buyer from

the sale proceeds related to the sale of shares and paid to the Pakistani tax authorities as capital gains

tax. Telenor believes that no capital gain arose from transaction and will therefore pursue a refund of the

tax withheld from the tax authorities in Pakistan.

Total cash effect of Telenor Pakistan sale transaction in 2025

The group received NOK 1,582 million (net of tax) as consideration for sale of shares in Telenor Pakistan.

Telenor Pakistan had an overdrawn bank balance, which led to a positive effect of NOK 671 million due to

deconsolidation. Total cash effect in investing activity was NOK 2,253 million. As part of sale transaction,

Telenor Pakistan received NOK 2,335 million from the buyer in shareholder loan, classified in financing

activity, for settling Telenor Pakistan's internal debt towards Telenor ASA. Telenor Pakistan was

disposed together with the debt towards its new shareholder. The total cash effect from disposal of

Telenor Pakistan was NOK 4,588 million. See further details related to Telenor Pakistan sale transaction in

note 12 Held for sale and discontinued operations.

Cash payments related to lease contracts


NOK in millions	Classification in cash flow statement	2025	2024
Payments of lease liabilities – principal portion	Financing activities	4,724	4,868
Payments of lease liabilities – interest portion	Operating activities	672	710
Payments of variable, short term and low value leases	Operating activities	2,319	2,534
Prepayments made at or before lease commencement including initial direct cost	Investing activities	590	454
Total cash outflow		8,306	8,566

Repayments of the principal portion related to lease liabilities in 2025 of NOK 4,724 million (NOK 4,868

million in 2024) include instalment payment of spectrum licences of NOK 687 million (NOK 1,216 million in

2024) and repayments of other leases of NOK 4,037 million (NOK 3,652 million in 2024). The instalment

payments of spectrum licences in 2025 were mainly in Grameenphone and Norway, whereas in 2024 it

related to Grameenphone, Norway and Pakistan. The increase in repayments of other leases mainly

related to Nordics, Grameenphone and Pakistan.

Repayments of the interest portion of lease liabilities in 2025 of NOK 672 million include repayments of

interest related to spectrum licences of NOK 164 million (NOK 236 million in 2024) and repayments of

interest related to other lease contracts of NOK 508 million (NOK 473 million in 2024).

Payments of variable, short term and low value leases of NOK 2,319 million (NOK 2,534 million in 2024)

include variable lease payments of NOK 2,237 million (NOK 2,449 million in 2024) and payments of short

term and low value leases of NOK 83 million (NOK 85 million in 2024).

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196

Reconciliation of interest bearing liabilities


	2025			2024
NOK in millions	Interest-bearing liabilities	Lease liabilities	Total	Interest-bearing liabilities	Lease liabilities	Total
Balance as of 1 January	84,080	17,541	101,621	87,475	17,308	104,783
Cash flow from financing activities
Proceeds from borrowings	18,079	—	18,079	6,278	—	6,278
Repayments of borrowings	(13,494)	—	(13,494)	(13,877)	—	(13,877)
Payments of lease liabilities related to spectrum licences	—	(687)	(687)	—	(1,216)	(1,216)
Payments of lease liabilities related to other lease contracts	—	(4,037)	(4,037)	—	(3,652)	(3,652)
Net cash flow from financing activities	4,585	(4,724)	(139)	(7,599)	(4,868)	(12,467)
Change due to hedge accounting	(150)	—	(150)	(43)	—	(43)
Effects from exchange rate fluctuations	641	(771)	(130)	3,974	586	4,560
Net interest paid/accrued	35	233	268	60	165	225
Disposals	(2,946)	(1,149)	(4,095)	—	(44)	(44)
New lease contracts	—	4,372	4,372	—	4,843	4,843
Termination and reassessment of lease contracts	—	(426)	(426)	—	(455)	(455)
Other	548	(16)	532	213	6	219
Other changes	(1,872)	2,243	371	4,205	5,101	9,305
Balance as of 31 December	86,793	15,060	101,853	84,080	17,541	101,621
Non-current liabilities	74,187	11,399	85,586	72,730	13,697	86,426
Current liabilities	12,607	3,660	16,267	11,350	3,844	15,195

Cash flow from financing activities consists of proceeds from and repayments of borrowings, including repayments of principal portion of lease liabilities. Net cash inflow from financing activities excluding

repayments of lease liabilities amounted to NOK 4,585 million in 2025 compared to outflow of NOK 7,599 million in 2024, see note 30 Interest-bearing liabilities for more information.

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Note 14

Goodwill

Goodwill relates to excess values that have not been allocated to other assets in

business combinations and typically include the value of synergies, employees and

other assets that do not qualify for recognition as separate identifiable assets.

Goodwill is not amortised but tested for impairment together with other assets in

cash-generating units, refer to note 18 Impairment of assets for further information.

Origination of goodwill

The table below illustrates where the goodwill has originated and the development in carrying amounts.


NOK in millions	Telenor Sweden	DNA Finland	Other ¹⁾	Total
Accumulated cost
As of 1 January 2024	5,919	17,090	2,540	25,549
Translations differences	116	870	84	1,070
Additions	—	—	22	22
Derecognised on disposal of subsidiaries	—	—	(24)	(24)
As of 31 December 2024	6,035	17,960	2,622	26,617
Translations differences	387	94	16	496
Additions	—	—	—	—
Arising on acquisition of subsidiaries	—	—	24	24
As of 31 December 2025	6,421	18,054	2,661	27,137
Accumulated impairment
As of 1 January 2024	(268)	—	(48)	(316)
Translations differences	(5)	—	—	(5)
Derecognised on disposal of subsidiaries	—	—	24	24
As of 31 December 2024	(273)	—	(24)	(297)
Translations differences	(18)	—	—	(17)
As of 31 December 2025	(291)	—	(24)	(314)

Carrying amount
As of 31 December 2024	5,762	17,960	2,598	26,319
As of 31 December 2025	6,131	18,054	2,638	26,822

1) Other includes goodwill allocated mainly to Infrastructure and Telenor Norway.

ACCOUNTING POLICIES

Goodwill arises in business combinations as the difference between the consideration and the acquired

business’ identifiable assets and assumed liabilities at the acquisition date. Assets and liabilities are

generally recognised at fair value, except for non-current assets classified as held for sale and deferred

taxes which are recognised at nominal value.

The fair value of any previously held equity interests and the amount of any non-controlling interest is also

included when determining the amount of goodwill. The fair value assessment of assets and liabilities in a

business combination involves various valuation techniques that include assumptions on future revenues,

net income, outcome of legal claims and other variables.

Telenor always use external valuation experts to assess the fair value of assets and liabilities in significant

business combinations. For more information about the impairment testing of goodwill, see note 18

Impairment of assets.

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NOTE 15

Intangible assets

A significant part of intangible assets relates to software either acquired individually,

generated internally or acquired in business combinations. Intangible assets also

include customer bases and trademarks in addition to other intangible assets.

ACCOUNTING POLICIES

Intangible assets acquired individually are measured initially at cost and recognised as an intangible assets

when control has been obtained over the asset, future economic benefits are expected to flow to the

entity and the cost can be measured reliably. The cost to be capitalised as part of the assets includes

direct and incremental costs and, for qualifying assets, borrowing costs. The cost of intangible assets

acquired in a business combination is the fair value at the date of acquisition. Following that initial

recognition, intangible assets are carried at cost less accumulated amortisation and any impairment

losses. The straight-line amortisation method is used for most intangible assets as this best reflects the

consumption of the assets. The amortisation period for a customer base is the expected lifetime of the

customer relationship, and the amortisation method is based on historical experience of churn

(customers ending their relationship) for the different businesses. The useful lives and amortisation

methods are reviewed at least annually. Refer to note 18 Impairment of assets for further information

about impairment.

Intangible assets


NOK in millions	Customer base	Trademarks ¹⁾	Software acquired	Internally generated software	Others	Work in progress ²⁾	Total
Accumulated cost
As of 1 January 2024	2,652	4,706	18,923	5,915	429	846	33,469
Reclassifications ³⁾	—	—	615	523	107	(1,259)	(14)
Additions	6	—	1,229	—	32	1,542	2,809
Additions internally developed	—	—	—	160	10	—	170
Translation differences	105	238	366	85	16	26	835
Derecognition	(30)	—	(2,090)	(213)	35	(92)	(2,390)
Disposal of businesses	(280)	—	(1)	—	—	—	(281)
As of 31 December 2024	2,452	4,944	19,042	6,471	627	1,063	34,599
Reclassifications ³⁾	—	—	697	413	142	(1,260)	(9)
Additions	—	—	1,357	—	13	1,508	2,878
Additions internally developed	—	—	—	71	3	—	75
Additions through acquisition of subsidiaries	—	—	13	—	—	—	13
Translation differences	29	26	18	205	4	21	302
Derecognition	(1)	(13)	(713)	(128)	(29)	—	(885)
Disposal of businesses	—	—	(495)	—	(87)	(8)	(590)
As of 31 December 2025	2,480	4,956	19,919	7,031	673	1,324	36,384

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NOK in millions	Customer base	Trademarks ¹⁾	Software acquired	Internally generated software	Others	Work in progress ²⁾	Total
Accumulated amortisation and impairment losses
As of 1 January 2024	(1,799)	(1,205)	(16,050)	(4,823)	(314)	—	(24,190)
Reclassifications ³⁾	—	—	—	—	4	—	4
Amortisation - continuing operations	(269)	—	(1,820)	(700)	(73)	—	(2,861)
Amortisation - discontinued operations	—	—	(30)	—	—	—	(30)
Translations differences	(71)	(61)	(302)	(61)	(13)	—	(508)
Derecognition	18	—	2,059	205	(35)	—	2,247
Disposal of businesses	279	—	—	—	—	—	279
As of 31 December 2024	(1,841)	(1,265)	(16,142)	(5,379)	(431)	—	(25,057)
Reclassifications ³⁾	—	—	—	1	2	—	2
Amortisation - continuing operations	(268)	(46)	(1,898)	(674)	(99)	—	(2,985)
Amortisation - discontinued operations	—	—	(27)	—	—	—	(27)
Translations differences	(26)	(5)	(61)	(159)	(2)	—	(253)
Derecognition	1	13	664	113	29	—	820
Disposal of businesses	—	—	432	—	65	—	497
As of 31 December 2025	(2,135)	(1,303)	(17,032)	(6,097)	(438)	—	(27,006)

Carrying amount
As of 31 December 2024	611	3,679	2,900	1,092	196	1,063	9,542
As of 31 December 2025	345	3,653	2,887	934	235	1,324	9,379
Amortisation periods in years	3-20	-	3-7	3	3-5	-	-

1)The carrying amount of trademarks with indefinite useful lives is NOK 3,465 million as of 31 December 2025 (NOK 3,446 million as of 31 December 2024). The trademarks with finite useful lives as of 31 December 2025 are represented by the

trademark of Welho in DNA Finland with the carrying amount NOK 187 million (Welho trademark with NOK 233 million as of 31 December 2024). The amortization period for the trademark of Welho in DNA Finland is 5 years.

2)The additions line items represent net additions of work in progress during the financial year. Work in progress capitalised and activated within the same financial year is shown as additions in the relevant asset categories in this table.

3)Including reclassifications to/from other lines in the statement of financial position which are not a part of this table.

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Note 16

Right-of-use assets

Telenor has chosen to account for the right to use the spectrum as a lease, where the

identified asset is the frequency band that is exclusive for Telenor in the lease period.

Telenor also leases passive infrastructure such as towers and cables in addition to

land and property. Refer to note 29 Lease liabilities for more information.

ACCOUNTING POLICIES

A lease liability and a right-of-use asset is recognised at commencement date in lease contracts where

Telenor has the right to direct the use and obtains substantially all the economic benefits from the use of

an identified asset. For spectrum contracts, Telenor has chosen to account for the right to use the

spectrum as a lease, where the identified asset is the frequency band that is exclusive for Telenor during

the lease term. Lease payments on short-term leases (less than 12 months) and low-value asset leases

(mainly small non-core leases) are generally expensed on a straight-line basis over the lease term. The

short-term exemption does not apply to spectrum leases or leases with purchase options.

The lease liability represents the net present value of lease payments over the lease term and include fixed

payments, in-substance fixed payments, non-lease components, residual value guarantees and lease

incentives. The lease payments also include the exercise price of a purchase option reasonably certain to

be exercised and termination penalties when termination is expected. Variable lease payments such as

licence payments based on revenue sharing arrangements are expensed as incurred.

The incremental borrowing rate generally used to determine the net present value is based on the

respective country’s risk-free rate for the term corresponding to the lease term, adjusted for own credit

risk. Subsidiaries with external financing use the external borrowing rate corresponding to the lease term.

KEY SOURCES OF ESTIMATION UNCERTAINTY

For lease of land for own towers or leasing of towers from tower companies or other operators, factors

considered in particular for assessing the lease term are technology development and potential changes

in business models. Based on an assessment of these factors, the lease term for Telenor’s leases relating

to sites will normally be within a range of 4 to 7 years. This means that the lease term for sites with renewal

options shall normally be the higher of a non-cancellable period or within a range of 4 to 7 years. Some

sites may be in strategically important locations and it might be more than reasonably certain that the

sites will be maintained beyond 7 years. In these cases, the lease term may be up to 10 years.

The non-cancellable lease period is basis for the lease liability, and periods covered by options to extend

or terminate the lease are included only when it is reasonably certain the lease period will be extended.

Determining the lease term can involve significant estimation uncertainty for lease contracts with

extension or termination options, as an assessment of whether or not it is reasonably certain that the

lease period will be extended is required. The broader economics of the contract and not only contractual

termination payments are basis for such assessment.

The lease liability is remeasured if the lease term or lease payments change, or there are other significant

event or significant change in circumstances. Significant amounts paid up-front on spectrum and other

lease contracts are recognised as prepayment until commencement date. Non-refundable value-added

tax is included as initial direct cost. The right-of-use asset is depreciated on a straight-line basis over the

shorter of its estimated useful life and the lease term.

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Right-of-use assets

Right-of-use assets are classified based on the nature of underlying assets as follow:


NOK in millions	Spectrum licences ¹⁾	Network passive infrastructure	Cables	Land	Buildings	Subscriber Equipment	Others	Total
Accumulated cost
As of 1 January 2024	26,974	10,367	5,445	2,030	4,285	97	192	49,391
Additions	81	2,346	992	289	704	544	302	5,257
Derecognition	(135)	(528)	(566)	(24)	(352)	(2)	(40)	(1,646)
Disposal of companies	—	—	(33)	—	(56)	—	—	(89)
Reclassifications	—	—	—	—	—	—	9	9
Translation differences	1,403	516	183	145	108	3	14	2,372
As of 31 December 2024	28,324	12,701	6,021	2,440	4,689	642	477	55,294

Additions	441	1,330	686	305	989	521	488	4,760
Derecognition	(1)	(587)	(744)	(38)	(1,121)	(5)	(75)	(2,572)
Disposal of companies	(5,577)	(1,681)	(208)	(1,023)	(70)	—	(169)	(8,728)
Reclassifications	(5)	(236)	—	—	—	98	—	(143)
Translation differences	(1,980)	(801)	(60)	(135)	27	4	19	(2,926)
As of 31 December 2025	21,202	10,727	5,695	1,548	4,513	1,259	741	45,685

Accumulated depreciation
As of 1 January 2024	(11,780)	(5,197)	(3,113)	(1,207)	(2,180)	(6)	(77)	(23,560)
Depreciation - continuing operations	(1,618)	(1,452)	(680)	(247)	(691)	(94)	(94)	(4,876)
Depreciation - discontinued operations	(384)	(165)	(9)	(73)	(5)	—	(5)	(641)
Impairment - continuing operations	—	—	—	—	(64)	—	—	(64)
Derecognition	88	397	307	16	345	—	36	1,189
Disposals of companies	—	—	24	—	25	—	—	49
Reclassification	(2)	—	—	—	—	—	—	(2)
Translation differences	(642)	(326)	(109)	(108)	(79)	—	(4)	(1,270)
As of 31 December 2024	(14,339)	(6,743)	(3,581)	(1,619)	(2,649)	(100)	(144)	(29,174)

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NOK in millions	Spectrum licences ¹⁾	Network passive infrastructure	Cables	Land	Buildings	Subscriber Equipment	Others	Total
Accumulated depreciation
Depreciation - continuing operations	(1,601)	(1,377)	(664)	(254)	(686)	(293)	(187)	(5,063)
Depreciation - discontinued operations	(368)	(158)	(8)	(81)	(7)	—	(15)	(637)
Derecognition	1	496	498	21	1,099	—	39	2,155
Disposals of companies	3,010	1,565	146	775	57	—	23	5,576
Reclassification	—	43	—	—	—	(17)	—	26
Translation differences	1,212	401	64	101	(11)	(1)	(8)	1,758
As of 31 December 2025	(12,084)	(5,773)	(3,546)	(1,056)	(2,197)	(412)	(292)	(25,360)

Carrying amount
As of 31 December 2024	13,985	5,958	2,440	821	2,040	542	333	26,120
As of 31 December 2025	9,118	4,954	2,149	492	2,316	848	449	20,326

Weighted average remaining lease term in years
As of 31 December 2024		6	8	5	10	2	3
As of 31 December 2025		5	8	7	9	2	2

Related lease liability disaggregated per class of right-of-use assets
As of 31 December 2024	4,120	6,646	2,061	1,017	3,144	346	207	17,541
As of 31 December 2025	3,453	5,391	1,678	455	3,305	440	337	15,059

1)See table below for overview spectrum licences, including lease term.

For lease of network passive infrastructure (lease of tower space in networks and lease of part of

buildings for own towers), land for own sites or towers and lease of buildings for office spaces,

equipment and retail stores, lease agreements generally contain termination options or renewal options.

These options are used to limit the period to which Telenor is committed to individual lease contracts

and to maximise operational flexibility in terms of dynamic network requirements. The remaining non-

cancellable period for lease contracts under network passive infrastructure is 4 years on average. The

non-cancellable period for lease contracts related to land is 2 years on average.

In 2025, the additions in network passive infrastructure were mainly related to Norway. The additions in

cables were mainly in Sweden. The additions in building were mainly related to Infrastructure, Finland and

Denmark. The additions in land were mainly related to discontinued operations in Pakistan. The additions

in subscriber equipment were mainly related to Norway and Denmark.

In 2024, the additions in network passive infrastructure were mainly related to Infrastructure site sharing

leases in Grameenphone and Norway. The additions in cables were mainly in Sweden and

Grameenphone. The additions in building were mainly related to Telenor Norway, Telenor Finland,

Telenor Real Estate and Sweden. The additions in land were mainly related to Grameenphone due to

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203

contract extension, Pakistan and Sweden. The additions in subscriber equipment were mainly related to

Norway and Sweden.

For lease of spectrum, the agreements are generally non-cancellable. Telenor has not considered

periods covered by renewal options even if in some agreements the option to renew exists, given the

uncertainty around terms and conditions of renewal of licences.

Spectrum licenses

The following table sets forth the spectrum licences that Telenor holds as of 31 December 2025:


Spectrum (MHz)	Bandwidth (MHz)	Spectrum expiration

Telenor Norway
700	2x10	2039
800	2×10	2033
900	2×15	2033
1800	2×10 + 2×20	2028/2033
2100	2×20	2032
2600	2×40	2042
3500	120	2042
Telenor Sweden
700	2x10 ¹⁾	2040
800	2x10 ¹⁾	2035
900	2x6 ¹⁾ + 2×5	2025
1800	2×20 ¹⁾ + 2x10 ¹⁾	2027/2037
2100	2x9.8 + 2x10 ¹⁾ + 1×5	2025
1800	2x25	2054
2600	2x40 ¹⁾	2025
3500	100 ¹⁾	2045


Spectrum (MHz)	Bandwidth (MHz)	Spectrum expiration

Telenor Denmark
700	2x5 ²⁾	2040
800	2x10 ²⁾	2034
900	2x10 ²⁾	2034
1500	45 ²⁾	2042
1800	2x25 ²⁾	2032
2100	2x20 ²⁾	2042
2600	2x20 + 1x10	2030
3500	140 ²⁾	2042
26000	600 ²⁾	2042
DNA, Finland
700	2x10	2033
800	2x10	2033
900	2x11.6	2033
1800	2x24.8	2033
2100	2x19.8	2033
2600	2x20	2029
3500	130	2033
26000	800	2033
Grameenphone, Bangladesh
900	2×7.4	2026
1800	2×7.2 + 2×7.4 + 2×0.4	2026
1800	2x5	2033
2100	2×10	2026
2100	2×10	2028
2500	80	2033

1)The licenses are held by Net4Mobility (a joint operation with Tele 2, owned 50% by Telenor).

2)The licenses are held by TT Netværket (a joint operation with Telia, owned 50% by Telenor).

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Lease expenses

Expenses recognised in the income statement related to lease contracts are presented below:


NOK in millions	Classification in income statement	2025	2024
Depreciation of right-of-use assets	Depreciation and amortisation	5,062	4,877
Interest expenses on lease liabilities	Financial expenses (note 9)	806	752
Variable lease expenses not dependent on index or rate	Other operating expenses (note 6)	1,435	1,574
Variable lease expenses not dependent on index or rate	Cost of materials and traffic charges (note 4)	468	501
Expenses relating to short term leases	Other operating expenses (note 6)	69	73
Expenses relating to low value leases	Other operating expenses (note 6)	14	12
Total		7,853	7,788

Total variable lease expenses of NOK 1 902 million (NOK 2 075 million in 2024) recognised in other

operating expenses and cost of material and traffic charges include NOK 1 147 million (NOK 1 334 million in

2024) related to spectrum and NOK 789 million (NOK 707 million in 2024) related to other lease contracts.

Variable lease expenses related to spectrum agreements vary mainly with revenue, as a significant part

of the expenses are based on share of revenues under the agreements. Variable lease expenses related

to other lease contracts of NOK 789 million (NOK 707 million in 2024) represent mainly energy charges

paid to lessors as part of the lease agreements for some mobile sites, and the expenses vary with the

consumption of energy on those mobile sites in addition to changes in prices.

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205

Note 17

Property, plant and equipment

The majority of the property, plant and equipment (PPE) in Telenor relate to

investments in network equipment and infrastructure, including base stations, cables,

fibre and radio equipment. Other assets include equipment for cable TV in addition to

buildings, land and administrative assets.

ACCOUNTING POLICIES

Property, plant and equipment are recognised at cost less accumulated depreciation and any impairment

losses. The cost includes borrowing costs for qualifying assets. If Telenor has a legal or constructive

obligation to dismantle, remove and restore a site, an asset retirement obligation (ARO) is recognized with

a corresponding increase in the related asset within property, plant and equipment. ARO relate mainly to

base stations and installed network and infrastructure equipment, in addition to certain buildings. See

note 22 Provision and obligations for further information for further information.

Estimated useful lives for similar types of assets may vary between different geographical areas due to

factors such as growth rate, maturity of the market, history and expectations for replacements or transfer

of assets, climate and quality of components used. Estimated useful life, depreciation method and

residual value are evaluated at least annually.

The straight-line depreciation method is used as this best reflects the consumption of the assets, which

often is the passage of time. Residual value is estimated to be zero for most assets, except for some

commercial buildings and vehicles that are not expected to be used for the whole economic life. Refer to

note 18 Impairment of assets for further information.

KEY SOURCES OF ESTIMATION UNCERTAINTY

Depreciation expenses are based on management’s estimates of depreciation method, useful life and

residual value. Estimates may change due to technological developments, competition, changes in market

conditions, geopolitical developments, climate change and other factors. In particular, technological

developments are difficult to predict as trends and pace of development may change over time.

The ARO is a significant estimate with significant uncertainty related to the timing of the removal and

restoration of the sites, whether the restoration actually will take place and to future price development as

the work will take place well into the future. See note 22 Provision and obligations for further information

about the asset removal obligation.

Climate changes can potentially lead to destruction of assets from flooding, fires or other natural disasters.

Climate changes and increased focus on sustainable businesses may impact technological development,

markets and economic or legal environment which are critical estimates in the evaluations of useful lives.

A change in estimated useful life is a change in accounting estimate, and depreciation plans are adjusted

prospectively. Refer to note 18 Impairment of assets for further information.

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Property, plant and equipment


NOK in millions	Local regional and trunk networks	Mobile Telephone network	Subscriber equipment	Switches and equipment	Radio installations	Cable-TV equipment	Buildings	Land	Corporate administrative assets	Work in progress ¹⁾	Total
Accumulated cost
As of 1 January 2024	61,406	28,578	2,746	7,436	17,929	6,391	4,666	251	9,144	6,559	145,104
Reclassifications ²⁾	(464)	1,840	61	125	1,094	27	(105)	—	585	(3,159)	3
Additions	1,754	1,151	169	192	1,752	87	201	1	975	4,336	10,616
Additions through acquisition of subsidiaries	—	—	—	—	—	—	—	—	3	—	3
Translation differences	815	952	28	206	702	20	112	14	306	91	3,246
Derecognition	(353)	(2,489)	(565)	(1,686)	644	(184)	(918)	—	(915)	(18)	(6,484)
Disposal of businesses	—	—	—	—	—	—	(132)	—	(358)	—	(490)
As of 31 December 2024	63,157	30,032	2,438	6,272	22,121	6,340	3,823	266	9,740	7,810	151,999
Reclassifications ²⁾	558	1,314	57	122	219	24	62	—	380	(2,590)	146
Additions	2,010	854	89	564	2,631	13	172	7	1,023	676	8,038
Translation differences	(111)	(481)	78	(222)	(1,590)	66	(94)	(24)	(278)	43	(2,613)
Derecognition	(18,569)	(1,827)	(502)	(120)	(1,731)	(16)	(85)	—	(762)	(20)	(23,632)
Disposal of businesses	(1,124)	(3,081)	—	(750)	(2,592)	—	(346)	(61)	(676)	(224)	(8,854)
As of 31 December 2025	45,921	26,810	2,161	5,866	19,058	6,428	3,533	187	9,426	5,694	125,085

Accumulated depreciation and impairment losses
As of 1 January 2024	(40,261)	(19,449)	(1,641)	(6,501)	(10,757)	(5,101)	(3,363)	(29)	(6,373)	—	(93,474)
Reclassifications ²⁾	(5)	198	5	—	(234)	—	45	—	—	—	9
Depreciation - continuing operations	(1,839)	(1,778)	(657)	(354)	(1,970)	(248)	(213)	—	(1,080)	—	(8,141)
Depreciation - discontinued operations	(48)	(92)	—	(34)	(101)	—	(11)	—	(38)	—	(323)
Impairment - continuing operations	—	—	—	—	(3)	—	—	—	—	(6)	(9)
Translations differences	(388)	(687)	(21)	(170)	(543)	(18)	(69)	(4)	(224)	—	(2,125)
Derecognition	345	2,439	583	1,684	(699)	178	914	—	869	—	6,313
Disposal of businesses	—	—	—	—	—	—	97	—	333	—	430

2025

207


NOK in millions	Local regional and trunk networks	Mobile Telephone network	Subscriber equipment	Switches and equipment	Radio installations	Cable-TV equipment	Buildings	Land	Corporate administrative assets	Work in progress ¹⁾	Total
As of 31 December 2024	(42,196)	(19,370)	(1,730)	(5,375)	(14,305)	(5,188)	(2,601)	(33)	(6,516)	(6)	(97,321)
Reclassifications ²⁾	(22)	(27)	20	—	—	—	25	—	(23)	6	(20)
Depreciation - continuing operations	(1,854)	(1,933)	(501)	(382)	(2,034)	(241)	(212)	—	(1,107)	—	(8,264)
Depreciation - discontinued operations	(44)	(106)	—	(40)	(89)	—	(10)	—	(35)	—	(324)
Impairment - continuing operations	—	(3)	—	—	—	—	1	—	—	—	(2)
Translation differences	89	381	(65)	186	1,160	(60)	69	4	205	—	1,969
Derecognition	18,541	1,775	502	120	1,494	16	80	—	745	—	23,272
Disposal of businesses	965	2,462	—	608	2,236	—	279	29	578	—	7,157
As of 31 December 2025	(24,521)	(16,821)	(1,774)	(4,883)	(11,538)	(5,474)	(2,369)	—	(6,154)	—	(73,533)

Carrying amount
As of 31 December 2025	21,401	9,989	387	983	7,520	954	1,164	187	3,273	5,694	51,552
As of 31 December 2024	20,961	10,663	708	897	7,816	1,152	1,222	233	3,223	7,804	54,678
Depreciation periods years ³⁾	3-30	5-20	3	3-7	5-15	3-15	5-30	-	2-10	-	-

1) The Additions line items represent net additions of work in progress during the financial year. Work in progress capitalised and activated within the same financial year is shown as Additions in the relevant asset categories in this table.

2) Including reclassifications to/from other lines in the statement of financial position which is not a part of this table.

3) Asset categories presented in this movement schedule is an aggregated total from different asset components belonging to a particular category, and the disclosed depreciation rates represent a range of useful lives allocated to

components.

2025

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Note 18

Impairment of assets

Telenor has significant investments in the network and infrastructure required to

operate in the telecom industry, such as base stations, networks and radio

equipment. Other significant classes of assets include goodwill, customer bases and

software. Goodwill is tested for impairment annually and when impairment indicators

are present. Telenor did not recognise any significant impairments related to

consolidated entities in 2025 and 2024.

Cash Generating Units (CGUs) with significant goodwill

The CGUs in Telenor are based on the countries with mobile and fixed operations in addition to tower

operations. The goodwill in Telenor mainly relate to the two CGUs Telenor Sweden and DNA in Finland,

see note 14 Goodwill for more information. Management has projected cash flows based on financial

forecasts and strategy plans covering the period 2026-2028 in the value-in-use impairment calculations.

The discount rates and terminal value nominal growth rates are shown in the table below.


	Discount rate after tax (%)		Discount rate pre-tax (%)		Nominal growth in cash flow in terminal value (%)
	2025	2024	2025	2024	2025	2024
Telenor Sweden	6.0	6.3	7.1	7.7	1.0	1.0
DNA	5.5	6.5	6.4	7.7	1.0	1.0

The estimated cash flows and corresponding discount rates are after tax in the value-in-use calculation.

The recoverable amounts would not change significantly if pre-tax cash flows and pre-tax discount rates

had been applied instead.

Impairment in 2025 and 2024

Telenor did not recognise any significant impairments for CGUs in 2025 and 2024. On 31 December 2025,

the disposal of Telenor Pakistan to Pakistan Telecommunications Company Ltd (PCTL), announced 14

December 2023, was completed after having received the required regulatory approvals.

Refer to note 35 Associates and joint arrangements for information about impairments of associated

companies and joint arrangements.

ACCOUNTING POLICIES

Impairment indicators are assessed at each reporting date for individual assets and Cash Generating

Units (CGUs). Impairment testing is performed if any indicators are identified and at least annually for

goodwill, intangible assets with indefinite useful life and intangible assets not yet brought into use.

Identification of Telenor’s main CGUs is based on the countries where Telenor operates its mobile and

fixed operations and its tower operations. The CGU may include both fixed and mobile operations as they

are monitored and reported as one operating unit. The value-in-use method is generally used in the

impairment testing where estimated future cash flows are discounted to their present value using a

discount rate. Fair values are used when these are available, for example when the CGU is a listed

company. Impairments are recognised by reducing carrying amount of goodwill first before other assets

are reduced on a pro-rata basis. Impairments of goodwill are not reversed.

KEY SOURCES OF ESTIMATION UNCERTAINTY

Impairment triggers

Significant management judgment is used when assessing impairment triggers. The following factors are

assessed: significant fall in market values; significant underperformance relative to historical or projected

future operating results; significant changes in the use of the assets or the strategy for the overall

business, including assets that are decided to be phased out or replaced and assets that are damaged or

taken out of use; significant negative industry or economic trends; significant loss of market share;

significant adverse political and/or regulatory development including unfavourable court decisions and

significant cost overruns in the development of assets.

Assumptions used in the goodwill impairment testing

The assessment of value-in-use includes significant management judgments and estimates, including

determining the discount rate (WACC), estimating future performance, revenue generating capacity of

the assets, margins, prices on future renewals of spectrum licences, political, regulatory and climate risk,

required maintenance capex, network and technological developments, and assumptions of the future

market conditions. There are significant variations between different markets with respect to growth,

mobile penetration, Average Revenue Per User (ARPU), market share, inflation, regulatory costs, and

technological development, resulting in differences in EBITDA margins, future investments, and long

terms growth assumptions. In some markets, certain expenses and capex are denominated in foreign

currency and impacted by currency fluctuations. Recessionary effects and increased macroeconomic

risks may impact the estimates of growth, future performance and discount rates used in estimating

recoverable amounts of assets. Discount rates are impacted by several macroeconomic factors including

borrowing rates, country risk, inflation assumptions and currency development. For assumptions used,

external evidence has been taken into consideration.

2025

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Assumptions used in the impairment testing of CGUs with goodwill

Cash flows

Discounted cash flow models have been applied to determine the value-in-use for CGUs. The cash flows

are based on the most recent financial forecasts approved by management. The cash flows beyond the

explicit forecast period have been extrapolated into perpetuity using a constant nominal growth rate to

arrive at the terminal value. The estimates of value in use have been compared to market valuation and

multiples for peers in the telecommunication business for reasonableness.

Growth rates

The expected growth in revenue, EBITDA, and EBITDA margin for a cash-generating unit is based on

historical performance, expected development in the market in which the entity operates and

assumptions in terms of development in market share. The growth rates applied in the explicit forecast

period converge from its current level experienced over the last few years to the long-term growth level

in the market where the entity operates. The growth rates used to extrapolate cash flow projections

beyond the explicit forecast period are not higher than the average expected long-term growth in the

markets in which the entities operate. In periods with relatively low discount rates, the estimated growth

rates used in the projections might be determined significantly below the average expected long term

growth observed in the market.

Average Revenue Per User (ARPU)

ARPU is a measure for average revenue per subscription per month, which is a key component when

estimating revenue growth. ARPU is calculated based on mobile revenues from the company’s own

subscriptions, divided by the average number of subscriptions for the relevant period. ARPU is estimated

based on the current ARPU level and expected future market development.

EBITDA¹⁾ margin

The EBITDA margin is estimated based on the current margin level and expected future market

development. Committed or implemented operational efficiency programmes are included. Changes in

the outcome of these initiatives may affect future estimated EBITDA margins.

1) Refer to page 287 for description of alternative performance measures.

Capital expenses (capex)¹⁾and spectrum licences

A normalised level of capex as a percentage of revenues (capex/revenues) is assumed in the long run.

Changes in traffic volumes and number of subscriptions during a growth phase will affect the future

capex/revenues ratio. Estimated capex reflect the level of capex needed for maintaining current

operation. Costs related to future spectrum acquisitions are estimated based on historical levels of

spectrum costs compared to revenue included in the assessment of future spectrum prices. Telenor also

takes into consideration the development in neighbouring countries and more advanced markets for

potential spectrum auctions in emerging markets.

Discount rates

Discount rates are based on Weighted Average Cost of Capital (WACC) derived from the Capital Asset

Pricing Model (CAPM). The WACC reflects current market assessments of the time value of money and

the risks specific to the asset or the CGU to which the asset belongs. Until May 2025, Telenor followed a

“one size fits all” model based on US interest rates and Equity Risk Premiums (ERPs) across Asia and the

Nordics. As of June 2025, cost of capital for the Nordic businesses are based on country specific interest

rates and ERPs in the Nordics. Under the old methodology, discount rate after tax for Telenor Sweden

and DNA in 2025 would have been 7.0% and 6.7% respectively (9.7% and 7.7% before tax). In Asian

economies where the risk-free yields are considered unreliable, the WACC rates used in discounting the

future cash flows are based on a US 30-year risk-free interest rate, adjusted with a country risk premium

and the inflation differential between the US and the relevant country. The discount rates consider the

debt premium, market risk premium, gearing, corporate tax rate, inflation, and asset beta. For CGUs in

economies with significant inflation difference from the USD in the coming years, rolling discount rates

are applied.

Climate-related risks

Telenor is exposed to climate-related physical risks such as potential damage to infrastructure and

utilities through the impact of more extreme weather events and rising sea levels. Climate-related

regulatory risks include potentially higher operational costs due to increasing carbon taxes and energy/

fuel taxes, as well as risks of higher capital expenditures due to a required transition towards the use of

renewable energy solutions and energy efficient networks. Climate-related risks are considered in the

cash flow projections and in impairment indicators.

2025

210

Note 19

Trade and other receivables


NOK in millions	Category	2025	2024
Receivables from contracts with customers		11,056	11,390
Provision for expected credit losses on trade receivables		(501)	(765)
Total receivables from contracts with customers as of 31 December	FAAC¹⁾	10,555	10,625

Interest-bearing receivables		—	83
Accrued finance income		15	8
Other non-interest-bearing receivables		641	885
Provision for expected credit losses on other current receivables		(16)	(17)
Total other current receivables as of 31 December	FAAC ¹⁾	641	959

Contract asset		225	143
Return good asset ³⁾		109	110
Governmental taxes and duties		130	212
Prepayments		2,041	1,763
Total other current non-financial assets as of 31 December	NF²⁾	2,505	2,229

Total trade and other receivables as of 31 December		13,701	13,812

1) FAAC: Financial assets at amortised cost

2) NF: Non-financial assets and liabilities

3) Asset for the right to recover returned goods on settling refund liabilities

As of 31 December 2025, NOK2,110 millions (NOK 1,582 millions as of 31 December 2024) of trade and

other receivables relates to instalments for mobiles and other devices not due within one year.

ACCOUNTING POLICIES

Trade and other receivables are recognised at fair value including directly attributable transaction costs

and subsequently measured at amortised cost using the effective interest rate method. A customer

contract asset is recognised when the revenue from contracts with customers exceeds amounts received

or receivable, for example when payment for mobile phones or other devices is done through future

instalments or subscription fee payments. Contract assets are transferred to trade receivables when the

rights to payment become unconditional, which is normally when the invoice has been issued. Refer to

further information in note 3 Revenues.

Trade receivables and contract assets are adjusted for provision for impairment in accordance with the

expected credit loss model. The simplified approach is applied measuring the loss allowance at an amount

equal to lifetime expected credit losses. Impairment for expected credit losses is assessed every

reporting period and calculated by considering the historic evidence of the level of bad debt experienced

for customer types and the ageing of the receivable balance.

Telenor has arrangements in place to sell trade receivables to third parties which are used on selected

portfolios of receivables. The receivables are derecognised when the rights to the cash flows and

substantially all risks and rewards are transferred to the third party. The cash received for sold receivables

from the third party is presented as cash flows from operating activities.

Sale of trade receivables from instalment plans for mobile phones

Telenor may from time to time sell certain portfolios of trade receivables related to instalment plans for

mobile phones and other devices to a third-party. The reason for selling such receivables is to improve

the working capital and better align the cash inflows from the sale of mobile phones with the cash

outflow from the purchase of mobile phones. Telenor is acting as a collecting agent and has provided a

credit guarantee to cover losses above a certain threshold in the event default rates are significantly

higher than historical rates. It has been assessed that there is only a remote probability for losses under

the credit guarantee, and that substantially all risks and rewards are transferred. As of 31 December

2025, the nominal value of derecognised trade receivables was NOK 1,316 million, compared to NOK 1,197

million in the prior year. The financial cost from the derecognition of the trade receivables was NOK 47

million in 2025 and NOK 43 million in 2024.

2025

211

Specification of provision for expected credit losses on trade receivables


NOK in millions	2025	2024
Provisions as of 1 January	(765)	(651)
Change during the year - continuing operations	33	(69)
Change during the year - discontinued operations	(4)	(13)
Disposal of subsidiaries	144	8
Currency and other effects	90	(40)
Provision as of 31 December	(501)	(765)

Realised losses for the year - continuing operations	(248)	(274)
Realised losses for the year - discontinued operations	—	—
Recovered amounts previously provided for - continuing operations	27	24
Recovered amounts previously provided for - discontinued operations	—	—

Specification of contract assets


NOK in millions	2025	2024
Balance as of 1 January	143	106
New contract assets during the period less transfer to receivables	47	43
Currency and other effects	35	(5)
Balance as of 31 December	225	143

Specification of the age distribution of trade receivables


			Past due on the reporting date in the following periods:
NOK in millions	Carrying amount	Not past due on the reporting date	Less than 30 days	Between 30 and 60 days	Between 61 and 90 days	Between 91 and 180 days	Between 181 and 365 days	More than 365 days
As of 31 December 2025
Trade receivables	11,056	9,386	726	121	89	147	184	403
Provision for expected credit losses on trade receivables	(501)	50	(49)	(12)	(18)	(35)	(71)	(366)
Total trade receivables	10,555	9,436	678	109	71	112	112	36
As of 31 December 2024
Trade receivables	11,390	9,187	766	300	180	185	178	594
Provision for expected credit losses on trade receivables	(765)	(122)	(33)	(93)	(18)	(43)	(91)	(363)
Total trade receivables	10,625	9,065	733	206	162	142	87	229

For the trade and other current receivables that are not impaired or past due, there are no indicators at the date of the reporting that the debtors will not be able to meet their payment obligations.

2025

212

Note 20

Cash and cash equivalents


NOK in millions	2025	2024
Cash in the group’s cash pool systems	6,391	6,380
Cash outside the group’s cash pool systems ¹⁾	9,944	4,000
Total cash and cash equivalents in statement of financial position	16,335	10,380
Bank overdraft (part of cash and cash equivalents in statement of cash flows)	(77)	(277)
Total cash and cash equivalents in statement of cash flows	16,258	10,104

1) Includes restricted cash in Grameenphone of NOK 9 million as of 31 December 2025 (NOK 11 million as of

31 December 2024).

Cash pool arrangements

Telenor has established cash pool arrangements where Telenor ASA is the account holder and the other

companies in the group are sub-account holders or participants. The cash pool arrangements allow

netting of cash positions within the group. Subsidiaries in which Telenor owns less than 90% of the

shares are normally not participants in the cash pool arrangements held by Telenor ASA.

ACCOUNTING POLICIES

Cash equivalents are held for the purpose of meeting short-term cash commitments. Cash and cash

equivalents include bank deposits, fixed rate bonds and commercial papers with original maturity of three

months or less which are readily convertible to known amounts of cash and subject to insignificant risk.

2025

213

Note 21

Pension obligations

Telenor offer several different pension plans to its employees. The most common

pension plan is the defined contribution plan where a contribution is made to the

employee’s individual pension account. This arrangement is in addition to the plans

organised by governments providing a basic pension entitlement to all taxpayers.

Telenor also has defined benefit plans with future pension obligations that are mostly

closed for new members.

Significant pension arrangements in Telenor

Telenor provides pension plans for employees in Norway which follow the requirements in the Act on

Mandatory company pensions. In addition, the Norwegian government provides social security payments

to all retired Norwegian citizens. Such payments are calculated by reference to a base amount annually

approved by the Norwegian parliament (G-regulation). Benefits are determined based on the employee’s

length of service and compensation. The cost of pension benefit plans is expensed linearly over the

period that the employees render services and becomes eligible to receive benefits. Telenor Pension

Fund, covering the defined benefit plans offered to all employees in Norway, was closed to new members

during 2006 and replaced by defined contribution plans with insurance companies.

In Norway, 3,187 of the employees were members of the contribution plan as of 31 December 2025 (3,494

as of 31 December 2024). In 2025, 724 of the employees were covered by the defined benefit plans

through Telenor Pension Fund (805 in 2024). Telenor Pension Fund paid out pensions to 2,555 retirees in

2025 (2,530 in 2024). In Sweden, 1,312 of the employees were members of the contribution plan as of 31

December 2025 (1,306 as of 31 December 2024). Telenor Sweden has a defined benefit plan with 492

active members in 2025 (522 in 2024). Telenor Sweden paid out pensions to 285 retirees in 2025 (252 in

2024). Other companies outside Norway and Sweden primarily offer contribution plans.

The funded defined benefit plans in Norway have net funds of NOK 2,799 million million as of 31

December 2025 (NOK 2,154 million million in net funds as of 31 December 2024). The current service cost

was NOK 122 million in 2025 (NOK 131 million in 2024). Net interest income was NOK 79 million in 2025

(NOK 57 million in 2024). Unfunded defined benefit plans have previously been offered to executive

employees. These plans are now closed. As of 31 December 2025, the net defined benefit liability

recognised in the statement of financial position was NOK 646 million (NOK 673 million as of 31 December

2024). The average duration of the Norwegian defined benefit plans at the end of the reporting period is

13 years.

ACCOUNTING POLICIES

Defined contribution plans

A defined contribution plan is a type of retirement plan where the employer makes contributions on a

regular basis to the employee’s individual pension account. The benefits received by the employee are

based on the employer contributions and gains or losses from investing the capital. Contributions to

defined contribution pension plans are recognised as an expense in the income statement as incurred.

Defined benefit plans

A defined benefit plan is a pension plan where the employer promises an annual pension on retirement

based on a percentage of the salary upon retirement and the employee's earnings history, years of service

and age. The pension obligations are determined by discounting the estimated future pension cash

outflows less the fair value of plan assets. The defined benefit obligation is calculated annually by

independent actuaries using the projected unit credit method and depends on a number of actuarial

assumptions. The discount rate is based on interest rates of high-quality corporate bonds denominated in

the same currency and with similar maturity as the related pension obligation. Other actuarial

assumptions include expected salary growth, inflation and return on assets as well as demographical

factors concerning mortality, employee turnover, disability and early retirement. Assumptions about all

these factors are based on the situation at the time the assessment is made, whereas it is expected that

such factors will change over the long periods for which pension calculations are made. Any changes in

these assumptions will affect the calculated pension obligations with immediate recognition in other

comprehensive income.

Current and past service cost, in addition to non-routine pension settlements, is presented as salaries and

personnel costs, and the net interest expense is recognised as financial expense in the income statement.

Remeasurements including actuarial gains and losses and the return on plan assets exceeding the

discount rate, are recognised in the statement of comprehensive income and are not subsequently

reclassified to the income statement. A plan curtailment is when Telenor is committed to reduce the

number of employees in a plan or change the terms, so the employees are entitled to reduced benefits or

is no longer eligible for benefits. Past service cost is recognised in the income statement on the earlier of

the date of the plan amendment or curtailment or when the related restructuring cost is recognised. Gains

and losses on curtailments form part of service cost and are presented as part of other income or other

expenses in the income statement.

Defined benefit multi-employer plans (such as the AFP arrangement in Norway) are accounted for as

defined contribution plans when insufficient information is available to calculate Telenor’s proportionate

share.

2025

214

The service cost was NOK 2 million in 2025 (NOK 5 million in 2024). Net interest cost was NOK 23 million

(NOK 21 million in 2024). Telenor does not have a right to use the net funds in the funded plans to settle

the obligations under the unfunded plans.

Telenor is member of an agreement-based early retirement plan (new AFP) in Norway. Essentially all the

Norwegian employees are entitled to life- long benefits from the age of 62 from this plan, in addition to

other plans. The plan is financed through a pooled arrangement, where private sector employers cover

2/3 of the funding requirements and the Norwegian government covers 1/3. For 2025, the contribution

was 2.7% of total salaries between 1 and 7.1 times the base amount (G) (2.7% for 2024). For 2026, the

contribution is set to 2.7%. The plan is considered to be a defined benefit multi-employer plan with

limited funding and where plan assets are not segregated. The information required to calculate a

proportionate share of the plan, and account for the plan as a defined benefit plan, is not available from

the plan administrator. Consequently, the plan is accounted for as a defined contribution plan.

The defined benefit plan in Sweden has a net benefit liability of NOK 1,247 million as of 31 December 2025

(NOK 1,289 million as of 31 December 2024). The service cost was NOK 49 million and net interest cost

was NOK 51 million in 2025 (NOK 47 million and NOK 45 million in 2024, respectively). The discount rate

used for the pension calculations as of 31 December 2025 was 3.8% (3.3% as of 31 December 2024) and

expected salary increase was set to 2.7% (2.8% in 2024).

For the Norwegian defined benefit plans, the Group applies the K2013 risk table for mortality and a risk

table for disability based on historical figures in Telenor Pension Fund (both implemented in 2013). The

average expected lifetime in the risk tables is 88 years for men and 92 years for women.

The table below shows the probability of an employee in a certain age group becoming disabled or dying,

within one year, as well as expected lifetime.


	Mortality%		Disability%		Expected lifetime
Age	Men	Women	Men	Women	Men	Women
40	0.1	—	0.1	0.1	88	92
50	0.1	0.1	0.2	0.3	88	92
60	0.3	0.2	0.8	1.2	87	91
70	1.1	0.8			88	91
80	3.6	2.5			90	92

The plan assets were measured at fair value as of 31 December 2025 (31 December 2024). The calculation

of the projected benefit obligations (PBO) as of 31 December 2025 was based on the member base as of

30 September 2025 (7 October 2024).

The actuarial calculations for the Telenor Pension Fund obligations were carried out by independent

actuaries. The present value of the projected defined benefit obligation, and the related current service

cost and past service cost, were measured using the projected unit credit method.

Employees in Norway that leave Telenor before the age of retirement receive a paid-up policy. Telenor

Pension Fund administers some of these policies. This is at the discretion of the Telenor Pension Fund

and does not affect Telenor. At the time of issuance of a paid-up policy, Telenor is relieved of any further

obligations towards the receiver. The funds and obligations are valued at the time of issuance of paid-up

policies and are derecognised from pension obligations and plan assets.

2025

215

Changes in the defined benefit obligation and fair value of plan assets


	2025			2024
NOK in millions	Defined benefit obligation	Fair value plan assets	Net defined benefit asset (liability)	Defined benefit obligation	Fair value plan assets	Net defined benefit asset (liability)
As of January	(9,406)	9,481	75	(9,196)	8,973	(223)
Current service cost	(206)	—	(206)	(223)	—	(223)
Net interest	(347)	347	—	(334)	316	(18)
Discontinued operations	(11)	—	(11)	(9)	—	(9)
Sub-total included in Income Statement	(565)	347	(217)	(567)	316	(251)

Return on plan assets (excluding amounts included in net interest expense)	—	212	212	—	292	292
Actuarial changes arising from changes in demographic assumptions	163	—	163	(10)	—	(10)
Actuarial changes arising from changes in financial assumptions	286	—	286	158	—	158
Experience adjustments ¹⁾	(149)	—	(149)	(168)	—	(168)
Sub-total in Other Comprehensive Income	301	212	512	(20)	292	272

Business combinations, disposals and held for sale	109	(76)	34	134	(134)	—
Contributions by employer	—	423	423	—	219	219
Benefits paid	318	(249)	69	310	(224)	86
Translation differences	(10)	(53)	(63)	(66)	37	(29)

As of 31 December	(9,253)	10,086	833	(9,406)	9,481	75
As of which classified as:
Pension obligations			(1,966)			(2,068)
Other non-current assets ²⁾			2,798			2,143

1 )Telenor does not have a right to use the net funds in the funded plans to settle the obligations under the unfunded plans.

2) Experience adjustments on benefit obligations are the effects of differences between previous actuarial assumptions and what has actually occurred.

2025

216

Assumptions used to determine defined benefit obligations for Norwegian companies as of 31 December


	2025	2024
Discount rate in %	4.35	3.50
Future salary increase in %	3.75	3.25
Future increase in the social security base amount in %	3.75	3.25
Future turnover in %	2.68	2.86
Future pension increases in %	2.75	2.25
Expected average remaining service period in years	7	7

Telenor has used the Norwegian covered bonds (OMF – Obligasjoner med fortrinnsrett) as basis for the

discount rate as of 31 December for both 2025 and 2024 for the Norwegian plans. OMFs are covered

bonds issued by mortgage companies owned by Norwegian banks under a well- established legal

framework. Generally, bonds with ratings better than AA are considered to be of high quality. Most OMFs

have AAA rating.

Components of net periodic benefit cost


NOK in millions	2025	2024
Current service cost	(206)	(223)
Net interest cost	—	(18)
Net periodic benefit costs	(206)	(242)
Contribution plan costs	(886)	(865)
Discontinued operations	(22)	(18)
Total pension costs charged to the income statement for the year	(1,114)	(1,124)
Of which reported as other expense (note 8)	(9)	(8)
Of which reported as pension cost (note 5)	(1,083)	(1,081)
Of which reported as net interest cost (note 9)	—	(18)
Of which reported as discontinued operations (note 12)	(22)	(18)

Sensitivity analysis

The table below shows an estimate of the potential effects of changes in the key assumptions for the

defined benefit plans in Norway. The following estimates are based on facts and circumstances as of

31 December 2025. Actual results may deviate materially from these estimates.


NOK in millions	Discount rate		Future salary increase		Social security base amounts		Annual adjustments to pensions		Turnover
Change in % is percentage points	-1%	+1%	-1%	+1%	-1%	+1%	-1%	+1%	-1%	+1%
Increase (decrease) in benefit obligations	1,031	(844)	(226)	227	50	(68)	(719)	844	7	(17)

Asset categories

Telenor Pension Fund’s weighted average asset allocations as of 31 December, by asset category, were:


	2025	2024
Bonds %	60	58
Equity securities %	34	37
Other %	6	5
Total	100	100

The bond investments are in securities issued by the Norwegian government, Norwegian municipals,

financial institutions, and corporations. Bonds held in foreign currencies are to a large extent currency

hedged. Equity investments are both in Norwegian and foreign securities. There is no currency hedging

for investments in foreign equity securities. The category Other consist mainly of investments in Private

Equity and Hedge funds.

Contributions in future years

Expected contributions to the Telenor Pension Fund in 2026 is approximately NOK 267 million. The table

below shows expected benefit payments from the Norwegian defined benefit plans in future years:


NOK in millions
Within the next 12 months (next annual reporting period)	263
Between 2 and 5 years	1,238
Next 5 years	2,150
Total expected payments next 10 years	3,651

2025

217

Note 22

Provisions and obligations

Telenor makes provisions for legal disputes when they become probable and the

amount can be reliably estimated. Provisions are also made for asset retirement

obligations representing the removal and restoration cost for infrastructure operated

by Telenor. Other provisions relate to restructuring costs and onerous contracts.

Provisions and obligations


	2025			2024
NOK in millions	Current	Non-current	Total	Current	Non-current	Total
Provisions for workforce reduction and onerous (loss)	405	215	620	477	259	736
Asset retirement obligations	29	6,001	6,030	31	6,427	6,458
Other provisions	458	153	611	400	237	637
Total provisions and obligations	892	6,369	7,261	908	6,923	7,831

ACCOUNTING POLICIES

Provisions are made when there is a present legal or constructive obligation, an outflow of resources is

probable and a reliable estimate can be made. Provisions are measured using management’s best estimate

of the expenditure required to settle the obligation at the reporting date and are discounted to present

value. Asset retirement obligations (ARO) primarily relate to base stations and installed network and

infrastructure equipment in addition to some buildings, see note 17 Property, plant and equipment.

The net present value of the future Asset Retirement Obligation (ARO) is discounted using a pre-tax risk-

free rate, as risks are reflected in the estimated cash flows. After initial recognition, an accretion expense

is recognised as a finance cost. Subsequent adjustments to the ARO arising from changes in estimated

removal costs or discount rates are recorded as a corresponding adjustment to the carrying amount of the

related property, plant, and equipment. Changes in ARO relating to assets that are no longer in use are

recognised in the income statement, with the impact of changes in the discount rate presented as financial

items and all other changes recorded as operating expenses.

KEY SOURCES OF ESTIMATION UNCERTAINTY

Provisions are estimated based on a number of assumptions and are highly uncertain in nature. In

particular, the amounts related to legal disputes can be significant and the assessment of probability and

the possible outcome include highly judgmental and complex assessments made by management.

There is also significant uncertainty related to the timing of the asset retirement obligation, as the removal

and restoration of the sites will occur well into the future and strategy, technological developments,

markets and other factors may impact the timing. There is also significant uncertainty related to the asset

removal cost due to uncertain future price development and possibility of negotiations of prices for a large

number of removals. Further, there is potentially agreements that relieve Telenor from its obligations and

uncertainty as to whether the restoration actually will take place.

Due to these uncertainties, the actual costs for legal claims and asset retirement obligations may be

significantly different from the current estimates.

2025

218

Development in provisions

The table below shows the development of provisions during 2025.


NOK in millions	Workforce reduction and onerous (loss) contracts	Asset retirement obligations	Other provision	Total	Legal disputes (included in trade and other payables)
As of 1 January	736	6,458	637	7,831	1,373
Obligations arising and effects of changes in estimates during the year	434	(253)	884	1,066	186
Accretion expense	—	130	10	141	—
Amounts utilised	(628)	(248)	(798)	(1,674)	(165)
Other changes and translation difference	78	(18)	(113)	(53)	(174)
Derecognised on disposal of subsidiaries	—	(40)	(11)	(51)	(147)
As of 31 December	620	6,030	611	7,261	1,074

Workforce reduction

Provisions for workforce reduction included 555 employees as of 31 December 2025 compared to 637

employees the year before.

Asset retirement obligation

The decrease in provisions for 2025 primarily reflects an increase in the discount rate and dismantling

activities, partially offset by accretion expense, with the majority of the Asset Retirement Obligation

(ARO) expected to be settled over 20–50 years.

Other provision

The provision decreased slightly during the year, primarily due to additions for employee bonuses, partly

offset by bonus payments, with the remaining decrease arising from other changes and translation

differences.

Legal disputes

Provisions for legal disputes are mainly recognised as Trade and other payables in note 24. Provisions

made for discontinued operations are disclosed in note 12 Held for sale and discontinued operations. For

information about legal disputes, see note 23 Legal disputes and contingencies.

2025

219

Note 23

Legal disputes and contingencies

Telenor is subject to various legal proceedings, disputes and claims including

regulatory discussions related to its business, licences and investments. Management

makes a provision for legal disputes when an unfavourable outcome is probable and a

reliable estimate can be made. The most significant legal disputes are summarised in

this note.

Significant legal proceedings, claims and regulatory discussions

Significant legal proceedings, claims and regulatory discussions are summarised below. Some of the

legal cases include a statement that a provision has been made. Cases that do not state that a provision

has been made either (a) do not have a provision and the matter is treated as a contingent liability; or (b)

a provision has been established but the fact has not been disclosed as it can seriously prejudice our

position. Disclosing that a provision has been made to the counterparty would reveal the fact that

Telenor believes it is probably that a cash outflow will occur and that that an amount can be reliably

estimated.

While acknowledging the uncertainties related to these matters, management is of the opinion that

based on the information currently available, these matters will be resolved without any material financial

adverse effect individually or in aggregate. See note 22 Provisions and obligations for further information

about development in legal dispute provisions.

Grameenphone, Bangladesh

BTRC audit

The Bangladesh Telecommunications Regulatory Commission (BTRC) conducted over several years an

information system audit of Grameenphone for the period 1997 to 2014. On 2 April 2019, Grameenphone

received a demand notice from BTRC for payment of NOK 10,394 million, which included NOK 1,899

million in principal, NOK 5,120 million in interest (up to December 2017), and NOK 3,374 million to National

Board of Revenue (NBR) including some matters pending in ongoing formal resolution processes (sub-

judice). These claims are unjustified from Telenor’s and Grameenphone’s position.

Overall, the Demand is based on allegations that Grameenphone has, amongst other things, underpaid

various taxes, such as corporate taxes, SIM tax, VAT, and revenue share from its mobile operation. No

provision has been recorded based on the Demand dated 2 April 2019, as such.

ACCOUNTING POLICIES

Legal disputes are usually contingent in nature, meaning the possible obligation depends on future events

outside the company’s control, for example a court decision. Provisions are made for legal claims where

an unfavourable outcome is probable and the amount required to settle the dispute can be reliably

estimated. Provisions are based on management’s best estimate of the amount required to settle the

obligation and are discounted to present value.

KEY SOURCES OF ESTIMATION UNCERTAINTY

There is significant uncertainty related to predicting the outcome of legal proceedings, disputes and

claims. The potential obligations can represent significant amounts, the disputes may involve complex

assessments of contracts and legislation, and political and country risk is high in certain disputes. Due to

these uncertainties, the future actual costs for legal disputes may be significantly different than current

estimates. Management evaluates the degree of probability of an unfavourable outcome and the ability to

make a reasonable estimate of the amount of loss. Unanticipated events or changes in these factors may

require management to make a provision for matters that become probable or reliable, or change a

provision made in a previous reporting period.

In 2019, the Appellate Division of the Supreme Court (AD) restrained BTRC from taking any steps to

realise or enforce the Demand, subject to payment of a deposit of NOK 1,597 million by Grameenphone.

The amount was paid and recognised as non-current financial assets (see note 27). The original title suit,

where the court is supposed to assess the merits of the Demand, is pending at the District Court and the

court has requested the parties to respond to the commencement of a possible mediation process. A

meeting to explore this has been postponed several times, and is currently scheduled to 26 April 2026.

One of the claims under the Demand in the BTRC-case is related to how VAT on the payment of 2G

license fee shall be handled. The AD concluded that Grameenphone should pay NOK 960 million in VAT, a

principle amount Grameenphone paid under protest on 14 June 2023. Grameenphone is involved in a

"without prejudice" reconciliation exercise with BTRC, where substantial late payment fees are among

the topics.

SIM tax on replacement SIM cards (part of BTRC audit)

The Large Taxpayer Unit-VAT has issued three notices to Grameenphone claiming SIM tax on the

replacement of SIM cards issued during three time periods from July 2007 to June 2015. In 2019 and

2020, the VAT Appellate Tribunal (the Tribunal) gave decisions in Grameenphone’s disfavour in two of the

three periods (2007-2011 and July 2012-June 2015), representing a total demand of NOK 1,158 million.

Grameenphone has appealed the decisions to the High Court Division of the Supreme Court who passed

stay orders on these two decisions by the Tribunal until final adjudication. Out of this claim, NOK 826

million are also part of BTRC audit Demand dated 2 April 2019 as discussed above.

2025

220

Workers Profit Participation Fund

Mobile operators in Bangladesh have since 2013 been required by an amendment in the Bangladeshi

Labor Act to establish a Worker’s Profit Participation Fund (“WPPF”) for distribution of 5 % of the

company’s annual net profit to their employees. Grameenphone has applied to such requirement since

then, as well as the period between 2010-2012 due to a court order that stated that the mobile operators

also for such period were subject to WPPF. There are individual disputes at Labour Court with former

employees of Grameenphone claiming additional amounts. Before any substantive hearing,

Grameenphone has contested these cases on maintainability ground seeking summary dismissals.The

Labor Court has rejected the maintainability applications and Grameenphone has appealed the

rejections to the Supreme Court. The Appellate Division in the Supreme Court has directed its High Court

Division to conclude the hearing of these appeals.

India

Telenor’s previous operations in India are subject to a number of disputes with the Indian Department of

Telecommunications (DoT). Telenor has provided guarantees for certain claims to the current owner

Bharti Airtel. Refer to note 12 Held for sale and discontinued operations for further information about the

guarantee, payment plans and provisions related to the period Telenor owned the business in India.

The AGR case

A long lasting dispute between the telecommunications industry and DoT regarding how to calculate

adjusted gross revenue (AGR) which is the basis for determining licence fees in India culminated in 2019

in a ruling by the Supreme Court (the "AGR Judgement"). The ruling resulted in substantial additional

amounts being due from Indian telcos, including substantial interests and penalties accrued over many

years. The AGR judgement also applies to Telenor’s former Indian operation, and therefore additional

AGR dues has become payable by Bharti Airtel (as Telenor’s successor in India), and indemnifiable by

Telenor.

The AGR judgement have bearing on demands amounting to NOK 3,242 million on a gross basis. Interest

accruals on demand notices received are currently estimated to NOK 1,418 for demand notices covered

by the Supreme Court orders. For demand notices received, not covered by the Supreme Court orders,

there are ongoing reviews performed by DoT and continued dialogue between Telenor and DoT. As on 31

December 2025, estimated amount not covered by Supreme court order including interest was NOK 654

million. Telenor has settled NOK 2,095 million of the mentioned demands. A government established

payment moratorium provides that the remaining amount shall be paid down in six annual instalments.

Final instalment amounts payable are subject to change, but the first instalment payable in the first

quarter of 2026 is currently expected to be approximately NOK 0.7 billion. The outstanding payments

accrue interest.

Telenor is assessing the situation based on the Indian Supreme Court decision of October 2025 allowing

the Indian government to review the AGR dues of Vodafone Idea only (and not other operators), as a

result of the financial strain of Vodafone Idea. On 31 December 2025, the Government deferred certain

payments of the AGR dues for Vodafone Idea, according to a new repayment plan.

The one time spectrum fee case

On 2 February 2012, the Indian Supreme Court cancelled all 2G licences, including those held by Telenor's

subsidiary at the time (Unitech Wireless). In February 2013, the Supreme Court ordered payment of

retroactive spectrum fees for such continued use of spectrum after the licences had been cancelled. On

14 February 2017, DoT issued a demand notice of NOK 864 million (including interest incurred as per

February 2017). Telenor challenged such demand before the Telecom Disputes Settlement and Appellate

Tribunal in India. The next hearing in the matter is scheduled on 8 July 2026. In its judgement dated 20

February 2026 in a similar case involving another operator, Mobile TeleSystems India (MTS), the Supreme

Court allowed DoT's appeal on several accounts with respect to calculation of spectrum charges and

applicable interest. The MTS case is expected to have bearing on Telenor's matter, although uncertainty

remains with respect to calculation of charges for Telenor.

The amalgamation case

DoT has further issued a notice to eight entities of Unitech Wireless relating to a financial penalty of NOK

1,178 million imposed, due to an alleged violation of a merger approval for the Unitech Wireless entities.

Telenor has contested the basis for the claim. This issues was closed on 27 June 2025 without any

financial penalty.

Norway

In a summons to Asker and Bærum district court on 24 November 2022, Telia Norge AS has claimed

Telenor ASA and Telenor Norge AS (Telenor) for compensation related to alleged losses in Tele2,

Network Norway, Ventelo, Phonero and TDC for the years 2008-2014, after which Telia has claimed to be

the legal successor. Telia’s preliminary calculation of losses exceeds NOK 600 million. The claims are

based on the decisions by ESA of 29 June 2020 and the Norwegian Competition Authority of 21 June

2018 concluding that Telenor had violated the EEA Agreement Article 54, inter alia. Telenor has disputed

the claims.

Asker and Bærum district court decided, in agreement with the parties, to first assess the time-bar

issues and thereafter the merits of the claims. On 13 January 2025, the district court ruled that the claims

from Telia were not time-barred. Telenor appealed parts of the decision to the Borgarting court of appeal

whereby the court on 9 March 2026 upheld the decision by the Asker and Bærum district court. Telenor is

currently assessing the next steps.

2025

221

Note 24

Trade and other payables


NOK in millions	Category	2025	2024
Trade payables		6,512	6,636
Accruals		6,797	8,149
Total trade payables and accruals as of 31 December	FLAC¹⁾	13,309	14,785
Contract liabilities		4,729	4,749
Government taxes, tax deductions etc		3,205	3,240
Total other payables as of 31 December	NF²⁾	7,934	7,988
Total trade and other payables as of 31 December		21,243	22,774

1) FLAC: Financial liabilities at amortised cost.

2) NF: Non-financial assets and liabilities.

Specification of customer contract liabilities


NOK in millions	2025	2024
Balance as of 1 January	4,749	4,726
Revenue recognised that was included in opening balance	(4,212)	55
New contract liabilities less transfer to revenue	4,410	(126)
Disposal of companies	(170)	(8)
Currency and other effects	(48)	101
Balance as of 31 December	4,729	4,749

Customer contract liabilities comprise Group’s obligation to transfer services to its customers for which

it has received consideration in advance. This includes unearned revenue relating to prepaid services,

connection fee not considered to be a separate performance obligation, and other contract liabilities.

ACCOUNTING POLICIES

Trade and other payables

Trade and other payables relate to amounts owed to suppliers and customer contract liabilities include

amounts received from a customer that exceed the revenue recognised, for example prepaid

subscriptions. Customer contract liabilities are expected to be realised within in the Group’s normal

operating cycle and are classified as current.

Supplier Finance Arrangement

The supplier finance arrangements (SFA) are classified as trade payables, with contracts and payment

terms managed directly with vendors. All finance costs are covered by vendors. The SFA is non-interest

bearing liability, and cash outflows are shown as operating activities in the statement of cash flows.

2025

222

Supplier Finance Arrangement (SFA)

Telenor has a supplier finance arrangement in the Nordics where selected vendors can receive early

payment for invoices through a financial institution. Vendors enrolled in the program can choose which

invoices to finance. Telenor will make the payment of the invoice to the finance provider instead of the

vendor. The vendors bear the financing cost associated with arrangement. The payment terms agreed

with the vendors involved in the arrangement mainly vary with range between 60 and 120 days.

Trade payables part of the SFA


NOK in millions	Balance as of 31 December 2025	Balance as of 31 December 2024
Presented in trade payables	1,096	1,052
Of which suppliers have been paid by finance providers	491	600

Credit terms

The ranges of agreed credit (payment) terms with the vendors participating in the supplier finance

arrangement, compared to vendors outside the arrangement are shown in the table below.


	2025		2024
Range of payment due dates	Trade payables part of the SFA	Comparable trade payables not part of the SFA	Trade payables part of the SFA	Comparable trade payables not part of the SFA
Norway	60-90	30-60	60-90	30-60
Sweden	60-90	30-60	60-90	30-60
Denmark	90-120	60-90	90-120	30-60
Finland	60-90	30-60	60-90	30-60

Note 25

Contractual commitments

Telenor has entered into agreements that include fixed future payments obligations and minimum

purchase commitments, which are summarised in this note.

2025


		Payment due by period
NOK in millions	Total	2026	2027	2028	2029	2030	After 2030
Contractual purchase obligations
IT-related agreements	334	261	38	17	17	—	—
Power purchase agreements (PPAs)	944	101	101	99	99	99	444
Other contractual obligations¹⁾	4,394	4,167	110	59	50	9	—
Committed investments
Property, plant and equipment and intangible assets	733	732	1	—	—	—	—
Total contractual obligations	6,406	5,261	250	176	166	108	444

2024


		Payment due by period
NOK in millions	Total	2025	2026	2027	2028	2029	After 2029
Contractual purchase obligations
IT-related agreements	544	447	40	23	17	17	—
Power purchase agreements (PPAs)	9	7	2	—	—	—	—
Other contractual obligations ¹⁾	4,389	4,028	210	54	52	36	9
Committed investments
Property, plant and equipment and intangible assets	1,287	1,283	4	—	—	—	—
Total contractual obligations	6,229	5,765	256	76	69	53	9

1) The majority of the amounts included in Other contractual obligations are commitments to purchase mobile phones

and other devices from suppliers.

2025

223

Note 26

Contract cost and other prepaid costs

Contract costs include costs for obtaining customer contracts, like commissions to

dealers. It also includes costs for fulfilling customer contracts, like direct labour and

material costs for connection and installation of equipment on customer premises.

Contract costs and other prepaid costs


NOK in millions	2025	2024
Contract costs	5,820	5,342
Governmental taxes and duties	38	78
Total non-current non-financial assets as of 31 December	5,858	5,420

Contract costs

ACCOUNTING POLICIES

When contract costs related to customer contracts are incremental and expected to be recovered, they

are recognised as contract cost assets and amortised over the expected customer lifetime. Renewal

periods are included in the period based on historical churn data, unless new costs are incurred on

contract renewals. These costs are included in operating costs. The practical expedient of not capitalising

contract costs that would have been amortised within 12 months has been applied. See note 3 Revenues

for more information about the customer contracts.

The below tables set forth the costs capitalised and amortised during the year 2025 and 2024:


NOK in millions	As of 31 December 2024	Cost capitalised during the year	Reclassified to assets held for sale	Amortisation - continued operations	Amortisation - discontinued operations	Translation differences	As of 31 December 2025
Contract acquisition costs	5,307	3,572	(57)	(3,010)	(21)	(78)	5,712
Contract fulfilment costs	35	102	(3)	(26)	(2)	2	108
Total contract costs	5,342	3,673	(61)	(3,036)	(22)	(76)	5,820


NOK in millions	As of 31 December 2023	Cost capitalised during the year	Reclassified to assets held for sale	Amortisation - continued operations	Amortisation - discontinued operations	Translation differences	As of 31 December 2024
Contract acquisition costs	4,543	3,362	—	(2,694)	(28)	123	5,307
Contract fulfilment costs	37	16	—	(16)	(4)	1	35
Total contract costs	4,581	3,378	—	(2,710)	(32)	124	5,342

2025

224

Note 27

Financial assets and non-interest-bearing liabilities

Derivatives such as forward currency contracts and interest rate swaps are used to

mitigate financial risks. Other financial assets include commercial papers, deposits

and equity investments.

Non-current financial assets


NOK in millions	Fair value level⁴⁾	Category	2025	2024
Equity investments	3	FVTOCI¹⁾	905	961
Financial derivatives	2	FVTPL ²⁾	15	63
Financial derivatives designated for net investment hedge	2		218	1,142
Other financial non-interest-bearing assets		FAAC³⁾	4,745	4,306
Fair value hedge instruments	2		—	36
Other financial interest-bearing assets		FAAC³⁾	312	306
Interest-bearing loans to associates and joint ventures	2	FVTPL ²⁾	3	1,055
Total non-current financial assets as of 31 December			6,198	7,869

1) FVTOCI: Fair value through other comprehensive income.

2) FVTPL: Fair value through profit and loss.

3) FAAC: Financial assets at amortised cost.

4) For information about the fair value level of financial instruments, see note 32.

Equity investments

Equity investments (FVTOCI) include capital contribution to Telenor Pension Fund of NOK 298 million and

other equity investments of NOK 607 million (NOK 298 million and NOK 663 million in 2024, respectively).

ACCOUNTING POLICIES

Financial assets and liabilities

Financial instrument are contract that gives rise to a financial asset of one entity and a financial liability or

equity instrument of another entity. Financial instruments are recognised when Telenor becomes a party

to the contractual provisions of the instrument, using trade date accounting. Financial assets and

liabilities are offset when there is intention and legally enforceable right to settle the contracts net.

Categories of financial assets and liabilities

The categorisation of the financial instrument for measurement purposes is based on the objective and

the contractual cash flow characteristics determined at initial recognition. Telenor does not apply the fair

value option.

Telenor has financial assets classified in the following measurement categories:

◦ FAAC - financial assets at amortised cost. Consist of financial assets held to collect contractual cash

flows that are solely payments of principal and interest.

◦ FVTOCI - financial assets at fair value through other comprehensive income. Consist of equity

investments not held for trading.

◦ FVTPL - financial assets at fair value through profit or loss. Include derivatives not designated for

hedging purposes, assets held for trading and financial assets that are not classified in one of the other

categories.

Telenor has financial liabilities classified in the following categories:

◦ FLAC - financial liabilities at amortised cost. Consist of liabilities that are not a part of the category at fair

value through profit or loss.

◦ FVTPL - financial liabilities at fair value through profit or loss. Include derivatives not designated for

hedging purposes and other liabilities held for trading.

2025

225

Other financial non-current non-interest-bearing assets

Other financial non-current non-interest-bearing assets as of 31 December 2025 includes a deposit of

NOK 1,652 million paid to the Bangladesh Telecommunication Regulatory Commission (BTRC, see note

23), pension funds of NOK 2,798 million and long term deposits of NOK 294 million (NOK 1,910 million, NOK

2,143 million and of NOK 252 million in 2024, respectively).

Interest-bearing loans to associates and joint ventures

The interest-bearing loans to associates in 2024 relate to a receivable against the joint ventures holding

the indirect ownership in True Corporation of NOK 1,055 million. This receivable was classified as FVTPL.

The loan was settled one year earlier than originally expected, upon transfer of remaining shares from

the joint ventures to Telenor in second quarter 2025.

Current financial assets


NOK in millions	Fair value level³⁾	Category	2025	2024
Assets held for trading	2	FVTPL¹⁾	92	82
Bonds and commercial papers > 3 months		FAAC²⁾	358	319
Receivables on associates and joint ventures	2	FVTPL ¹⁾	—	1,055
Financial derivatives	2	FVTPL ¹⁾	1	—
Financial derivatives designated for net investment hedge	2		374	157
Total other current financial assets as of 31 December			825	1,614

1) FVTPL: Fair value through profit and loss.

2) FAAC: Financial assets at amortised cost.

3) For information about the fair value level of financial instruments, see note 32.

Receivables on associates and joint ventures

In 2024, receivables on associates include an interest-bearing receivable, classified as FVTPL, against the

joint ventures holding the indirect ownership in True Corporation of NOK 1,055 million. The receivable

was extinguished upon transfer of remaining shares from the joint ventures to Telenor in second quarter

2025.

Equity investments

Equity investments include equity instruments and capital contribution to Telenor Pension Fund. Equity

investments not held for trading are financial assets with changes in fair value through other

comprehensive income (FVTOCI). Unrealised gains and losses are reclassified within equity from other

reserves to retained earnings when the investment is disposed. Equity investments held for trading are

financial assets with changes in fair value through profit and loss (FVTPL), and transaction costs are

immediately expensed. Telenor does not have equity instruments held for trading.

Derivatives

Telenor uses derivative financial instruments, such as forward currency contracts, interest rate swaps

and cross currency interest rate swaps, to hedge its risks associated with interest rate and foreign

currency fluctuations. The derivative financial instruments are measured at fair value. Any gains or losses

arising from changes in fair value on derivatives that are not cash flow hedges or hedges of net

investments are recognised in the income statement as financial income or expense.

Embedded derivatives

Embedded derivatives are separated from the host contract and recognised at fair value, except when the

risks and economic characteristics are closely related to the host contract and the host contract is not

carried at fair value. The currency derivative embedded in committed purchase or sales contracts are not

separated when the payment is in one of the party’s functional currency or in a commonly used currency

in the relevant economic environment. Unrealised gains or losses are recognised in the income statement.

Other current and non-current financial assets

Financial assets such as various receivables and deposits initially recognised at fair value including directly

attributable transactions costs and subsequently normally measured at amortised cost using the effective

interest rate method. These financial assets are adjusted for provision for impairment in accordance with

the expected credit loss model. As part of the transaction between dtac and True, a shareholder loan was

provided to joint ventures for funding the transaction. This shareholder loan does not satisfy the solely

payment of principal and interest test, hence cannot be recognised at amortised cost using the effective

interest rate method.

2025

226

Non-current non-interest-bearing liabilities


NOK in millions	Fair value level³⁾	Category	2025	2024
Financial derivatives	2	FVTPL¹⁾	240	389
Financial derivatives designated for net investment hedge	2		467	415
Other non-interest-bearing liabilities		FLAC ²⁾	656	557
Total non-current non-interest-bearing liabilities as of 31 December			1,363	1,362

Current non-interest-bearing liabilities


NOK in millions	Fair value level³⁾	Category	2025	2024
Financial derivatives	2	FVTPL¹⁾	3	82
Financial derivatives designated for net investment hedge	2		347	757
Other non-interest-bearing liabilities		FLAC ²⁾	654	738
Total current non-interest-bearing liabilities as of 31 December			1,004	1,577

1) FVTPL: Fair value through profit and loss.

2) FLAC: Financial liabilities at amortised cost.

3) For information about the fair value level of financial instruments, see note 32.

2025

227

Note 28

Equity

This note summarises and explains the movements in equity for the Telenor group. It

also presents the financial information for subsidiaries that have significant non-

controlling interests.

Paid-in capital


NOK in millions, except number of shares	Number of shares	Share capital	Other paid in capital	Treasury shares	Total paid-in capital
Paid in capital as of 1 January 2024	1,399,458,033	8,397	69	(86)	8,380
Purchase of shares and shares issued under share- based payment programme	—	—	—	(101)	(101)
Cancellation of shares	(31,108,044)	(187)	—	187	—
Paid in capital as of 31 December 2024	1,368,349,989	8,210	69	—	8,278
Purchase of shares and shares issued under share- based payment programme	—	—	—	(1)	(1)
Paid in capital as of 31 December 2025	1,368,349,989	8,210	69	(1)	8,277

Telenor ASA had a share capital of NOK 8,210,099,934 divided into 1,368,349,989 ordinary shares with a

nominal value of NOK 6 each, both as of 31 December 2025 and as of 31 December 2024. The company held

94,769 treasury shares as of 31 December 2025 and 82,575 treasury shares as of 31 December 2024 from

the share-based payment programme (see note 5 Salaries and personnel costs).

On 8 February 2023, Telenor announced a share buyback program for the year 2023-2024. The total

programme comprised 31,108,044 shares, of which 14,320,524 shares were repurchased from the market

during 2023 for NOK 1,625 million. With this, the market part of the buyback programme was finalised. The

remaining 16,787,520 shares were purchased from the Norwegian state through the Ministry of Trade,

Industry and Fisheries. The 31,108,044 shares were cancelled following approval by the Annual General

Meeting in May 2024, hence the Ministry’s ownership interest in Telenor of 53.97% remained unchanged.

The shares that were repurchased in the open market had an immediate cash effect whereas the pro rata

shares from the Norwegian state were paid simultaneously with the capital reduction in June 2024.

Other reserves


NOK in millions	Net unrealised gains/ (losses) reserve	Employee equity benefits reserve	Pension remeasure ment reserve	Share of equity adjustments and other comprehensive income in associates and joint ventures	Other equity transactions	Total other reserves
Other reserves as of 1 January 2024	406	614	1,424	1,499	(25,927)	(21,984)
Other comprehensive income (loss), net of taxes	52	—	184	(85)	—	151
Share-based payment	—	50	—	—		50
Purchase of treasury shares	—	—	—	—	(1,794)	(1,794)
Other reserves as of 31 December 2024	458	664	1,608	1,414	(27,721)	(23,578)
Other comprehensive income (loss), net of taxes	(37)	—	453	(183)		233
Amount reclassified from other comprehensive income to income statement on disposal	—	—	—	25	—	25
Share-based payment	—	(86)	—	—	—	(86)
Purchase of treasury shares	—	—	—	—	(4)	(4)
Other reserves as of 31 December 2025	421	578	2,061	1,256	(27,725)	(23,410)

Net unrealised gains/losses reserve

This reserve includes unrealised gains and losses arising from changes in fair value of equity investments

are recognised directly in other comprehensive income until the investment is disposed of, at which time

the cumulative gain or loss is reclassified within equity from other reserves to retained earnings.

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228

Employee equity benefits reserve

Share-based payments represents 1) increase in other reserves due to cost charged to income statement

over the vesting period based on the fair value measured at grant date for equity-settled share-based

payments provided to employees, including key management personnel, as part of their remuneration and

2) decrease in other reserve when the programme is settled. In 2025, the group paid NOK 195 million

related to the equity-settled share-based programme (NOK 77 million in 2024), refer to note 37 Key

management compensation for further details on this programme.

Pension re-measurement

This reserve includes the effect of re-measurement of pension obligations arising due to change in

assumptions, such as discount rate and long- term demographic trends.


NOK in millions	Pension remeasurement	Income taxes	Net pension remeasurement
As of 1 January 2024	1,841	(417)	1,424
Other comprehensive income (loss)	233	(49)	184
As of 31 December 2024	2,074	(466)	1,608
Other comprehensive income (loss)	572	(119)	453
As of 31 December 2025	2,646	(585)	2,061

See note 21 Pension obligations for more information.

Share of equity adjustments and other comprehensive income in associates and joint ventures

This reserve includes underlying adjustments to equity in associates and joint ventures, such as other

comprehensive income, share buybacks and transactions with non-controlling interests. During 2025, a

loss of NOK 25 million was reclassified from other comprehensive income to income statement upon

disposal of Allente.

Other equity transactions

This includes the decrease in other reserves as a result of purchase of treasury shares and cancellation of

treasury shares and the increase due to re-issuance of shares under share-based payment programmes

as well as transfers from other paid-in capital, including transfers from other paid-in capital related to

cancellation of treasury shares. The price paid in excess of the nominal value of the shares reduces this

reserve. During 2023, Telenor repurchased 14.3 million shares from the market and in 2024, Telenor

repurchased 16.8 million shares from the Norwegian state. The total of 31.1 million repurchased shares

were cancelled in June 2024 following approval by the Annual General Meeting in May 2024.

Cumulative translation differences


NOK in millions	Foreign currency translation	Net investment hedge	Income taxes	Net translation differences
As of 1 January 2024	(1,515)	(5,843)	1,272	(6,089)
Changes during 2024, excluding effects of disposal	9,782	(2,483)	546	7,845
Amount reclassified from other comprehensive income to income statement on disposal	(33)	—	—	(33)
Net changes during 2024	9,749	(2,483)	546	7,812
As of 31 December 2024	8,234	(8,326)	1,818	1,723
Changes during 2025, excluding effects of disposal	(1,851)	(705)	155	(2,401)
Amount reclassified from other comprehensive income to income statement on disposal	3,022	(82)	19	2,959
Net changes during 2025	1,171	(787)	174	558
As of 31 December 2025	9,405	(9,113)	1,992	2,281

During 2025, a loss of NOK 2,959 million reclassified from other comprehensive income to income

statement include NOK 2,909 million related to Telenor Pakistan disposal and included in the total loss

recognised on disposal. See note 12 Held for sale and discontinued operations.

During 2024, a gain of NOK 33 million was reclassified from other comprehensive income to the income

statement which was related to disposals of Norkring, Telenor Satellite and Telenor Maritime in Sweden

and included in the total gains recognised on disposal of these subsidiaries.

In 2025, the translation difference loss on net investment in foreign operations of NOK 1,851 million was

caused by appreciation of the Norwegian Krone against all relevant Asian currencies. The depreciation of

the Malaysian Ringgit by 2% and Thai Bath by 3% against Norwegian Krone had the most significant

impact on the translation difference loss.

In 2024, the translation difference gain on net investment in foreign operations of NOK 9,782 million was

caused by depreciation of the Norwegian Krone against all relevant currencies. The appreciation of Danish

Krone and Euro by 5%, Malaysian Ringgit by 15% and Thai Bath by 12% against Norwegian Krone had the

most significant impact on the translation difference gain.

2025

229

Non-controlling interests (NCI)


NOK in millions	Country of incorporation and operation	NCI share of net income (loss) 2025	NCI share of net income (loss) 2024	NCI in the statement of financial position 31 December 2025	NCI in the statement of financial position 31 December 2024	NCI share of dividend in 2025	NCI share of dividend in 2024

Grameenphone Ltd.	Bangladesh	1,113	1,537	2,044	2,744	1,428	1,631
Telenor Fiber AS	Norway	213	236	3,170	3,261	304	245
Others		3	1	(64)	(88)	4	—
Total		1,329	1,773	5,150	5,917	1,736	1,876

Summarised financial information for subsidiaries with significant NCI

Summarised statement of financial position as of 31 December:


	2025		2024
NOK in millions	Grameenphone Ltd	Telenor Fiber AS	Grameenphone Ltd	Telenor Fiber AS
Current assets	1,135	428	1,492	463
Non-Current assets	14,665	14,446	17,364	13,977
Current liabilities	(7,125)	(543)	(8,048)	(624)
Non-Current liabilities	(4,295)	(3,784)	(4,972)	(2,927)
Total equity	4,380	10,546	5,836	10,888
Attributable to:
Equity holders of Telenor ASA	2,336	7,377	3,092	7,627
NCI	2,044	3,170	2,744	3,261

Summarised Comprehensive income information 1 January – 31 December:


2025			2024
NOK in millions	Grameenphone Ltd	Telenor Fiber AS		Grameenphone Ltd	Telenor Fiber AS
Revenues	13,474	2,424		15,138	2,406
Net income	2,578	672		3,384	753
Total comprehensive income	1,774	672		3,551	753
Attributable to NCI	729	213		1,661	237

The comparative information for amount attributable to NCI related to Grameenphone Ltd has been

restated to include NCI share of other comprehensive income in addition to NCI share of net income.

Summarised cash flow information 1 January – 31 December:


2025			2024
NOK in millions	Grameenphone Ltd	Telenor Fiber AS		Grameenphone Ltd	Telenor Fiber AS
Operating activities	5,075	1,587		5,749	1,726
Investing activities	(1,171)	(1,382)		(1,936)	(1,502)
Financing activities	(3,952)	(209)		(4,710)	(235)
Effect of exchange rate changes on cash and cash equivalents	(93)	—		57	—
Net increase/(decrease) in cash and cash equivalents	(142)	(3)		(840)	(11)

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230

Note 29

Lease liabilities

This note gives further information about the lease liabilities of Telenor, such as lease

liabilities per currency and in addition maturity profile. Refer to note 16 Right-of-use

assets for description of accounting policies and key sources of estimation

uncertainty relating to lease liabilities and right-of-use assets. Note 13 Cash Flow

information includes more information about the cash flow movements in lease

liabilities.

Lease liabilities measured at amortised cost


	2025			2024
NOK in millions	Current	Non-current	Total	Current	Non-Current	Total
Lease liability related to spectrum licences	752	2,676	3,428	760	3,339	4,098
Lease liability related to other lease contracts	2,908	8,723	11,631	3,084	10,358	13,442
Total lease liabilities	3,660	11,399	15,059	3,844	13,697	17,541

Distribution of lease liabilities per currency


		2025			2024
NOK in millions	Currency	Spectrum licences	Other lease contracts	Total	Spectrum licences	Other lease contracts	Total
Bangladesh	BDT	1,372	3,555	4,927	1,541	4,187	5,728
Norway	NOK	1,281	3,422	4,703	1,604	3,353	4,957
Denmark	DKK	580	902	1,481	654	784	1,438
Sweden	SEK	45	2,227	2,272	47	2,155	2,203
Finland	EUR	150	1,366	1,516	166	1,725	1,891
Pakistan	PKR	—	—	—	—	1,141	1,141
Pakistan	USD	—	—	—	87	—	87
Other	NOK	—	160	160	—	97	97
Total		3,428	11,631	15,059	4,098	13,442	17,541

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231

Lease liabilities maturity profile


NOK in millions	Total as of 31 December 2025	< 1 year	2 years	3 years	4 years	5 years	6 years	7 years	8 years	9 years	10 years	>10 years
Lease liabilities related to spectrum licences	3,428	752	433	402	404	419	432	262	119	50	37	120
Lease liabilities related to other lease contracts	11,631	2,908	2,376	1,582	1,033	919	539	393	297	214	162	1,209
Sum of lease liabilities	15,059	3,660	2,809	1,984	1,437	1,338	971	655	416	264	198	1,329
Future interest payments	2,948	735	557	419	323	252	187	140	108	87	75	65
Total including future interest payments	18,007	4,395	3,365	2,404	1,759	1,590	1,158	795	524	351	273	1,394


NOK in millions	Total as of 31 December 2024	< 1 year	2 years	3 years	4 years	5 years	6 years	7 years	8 years	9 years	10 years	>10 years
Lease liabilities related to spectrum licences	4,098	760	747	435	394	394	407	418	198	112	44	189
Lease liabilities related to other lease contracts	13,442	3,084	2,523	1,859	1,351	1,001	916	538	392	289	201	1,289
Sum of lease liabilities	17,541	3,844	3,270	2,295	1,745	1,394	1,323	956	590	400	244	1,478
Future interest payments	3,189	768	599	456	356	280	218	161	119	93	75	65
Total including future interest payments	20,730	4,612	3,869	2,751	2,101	1,674	1,542	1,116	709	493	320	1,543

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Note 30

Interest-bearing liabilities

The current and non-current debt in Telenor mainly consists of bonds issued under

the EMTN programme (Euro Medium Term Note), bonds issued in other markets and

bank loans. Forward contracts and cross currency swaps are used to hedge foreign

exchange rate risk for certain assets

Interest-bearing liabilities


	2025			2024
NOK in millions	Current interest- bearing liabilities	Non-current interest- bearing liabilities	Total	Current interest- bearing liabilities	Non-current interest- bearing liabilities	Total
Interest-bearing liabilities measured at amortised cost
Bank loans	695	—	695	754	—	754
Bonds	11,830	73,068	84,899	10,590	71,004	81,594
Other liabilities	7	96	102	6	79	85
Interest-bearing liabilities measured at fair value
Fair value hedge instruments	75	1,023	1,097	—	1,647	1,647
Total interest-bearing liabilities	12,606	74,187	86,793	11,350	72,730	84,080
Fair value of debt ¹⁾			83,468			80,245
Of which fair value hierarchy level 1 ²⁾			82,416			79,198
Of which fair value hierarchy level 2 ²⁾			1,052			1,047

1) Excluding lease liabilities and licence obligations.

2) For information about the fair value hierarchy for valuation of financial instruments, see note 32 .

ACCOUNTING POLICIES

Interest-bearing liabilities are initially measured at fair value net of transaction costs and are subsequently

measured at amortised cost using the effective interest-rate method (FLAC). In addition, where fair value

hedge accounting is applied the hedged liabilities are adjusted for gains and losses attributable to the risk

being hedged. On extinguishment of debt, in whole or in part, the difference between the carrying amount

of the liability and the consideration paid is recognised in the income statement.

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233

Non-current interest-bearing liabilities


		2025		2024
NOK in millions	Currency	Debt before the effect of currency swaps	Debt adjusted for the effect of currency swaps ¹⁾	Debt before the effect of currency swaps	Debt adjusted for the effect of currency swaps ¹⁾
Company
Telenor ASA	EUR	62,140	50,900	64,955	44,358
	NOK	7,747	9,864	3,746	6,946
	SEK	4,204	10,209	3,949	17,149
	USD		3,656		3,010²⁾
	THB				1,126²⁾
Total Telenor ASA		74,091	74,628	72,650	72,589
DNA - Finland	EUR			—	—
Other non-current interest-bearing liabilities		96	96	80	80
Total subsidiaries		96	96	80	80
Total non-current interest-bearing liabilities		74,187	74,724	72,730	72,669

1) Debt adjusted for currency swaps includes financial instruments that are not classified as interest-bearing liabilities

in the statement of financial position.

2) The comparative figures for 2024 have been corrected. The previously reported USD amount of 4 123 million has

been revised to 3 010 million, and THB 1 126 million (previously reported as 0) has now been included, as the foreign

exchange amount was omitted in 2024. This correction relates solely to note disclosure.

Debt issued under Telenor ASA’s EMTN programme is based on documentation that is commonly used

for investment grade issuers in the Eurobond market. This documentation contains provisions restricting

the pledge of assets to secure future borrowings without granting a similar secured status to the existing

lenders (negative pledges).

Bonds issued under the EMTN programme are subject to a Change of Control Clause. Such Change of

Control shall be deemed to have occurred if a person or entity, other than the Kingdom of Norway,

directly or indirectly owns or acquires more than 50% of the issued ordinary share capital of Telenor

ASA. If such Change of Control leads to a downgrade below investment grade rating, the holder of such

bonds can require Telenor ASA to redeem the principal amount together with accrued interest. The full

definition of this Change of Control Clause is described in the Final Terms for each specific bond issue.

Current interest-bearing liabilities


		2025		2024
NOK in millions	Currency	Debt before the effect of currency swaps	Debt adjusted for the effect of currency swaps ²⁾	Debt before the effect of currency swaps	Debt adjusted for the effect of currency swaps ²⁾
Company
Telenor ASA	NOK ¹⁾		243	—	(1,081)
	EUR ¹⁾	11,905	(4,841)	7,650	(2,230)
	SEK		8,587	—	1,105
	MYR		2,471	—	2,530
	THB		5,710	—	4,782
	USD¹⁾		(313)	—	3,199
Total Telenor ASA		11,905	11,856	7,650	8,305
DNA - Finland	EUR			2,939	2,939
Grameenphone - Bangladesh	BDT	578	578	478	478
Pakistan	PKR			210	210
Other current interest-bearing liabilities		123	123	73	73
Total subsidiaries		702	701	3,700	3,700
Total current interest-bearing liabilities		12,606	12,558	11,350	12,005

1) Telenor ASA’s debt positions in Norwegian kroner and euro as of 31 December 2025 and US Dollars as of 31

December 2024, are net asset positions when including currency swaps.

2) Debt adjusted for currency swaps includes financial instruments that are not classified as interest-bearing liabilities

in the statement of financial position.

Telenor ASA Bonds and EMTN Programme – Movements in 2025:

• In March, a EUR 250 million bond issued by DNA Plc matured and was repaid.

• In April, a EUR 750 million EMTN bond was issued at 3.375%, maturing 2032

• In May, a EUR 650 million bond under the EMTN programme matured and was repaid.

• In November, a NOK 4 000 million EMTN bond was issued at 4.945% maturing 2035.

All outstanding debt issued by Telenor ASA is unsecured. The interest-bearing liabilities in subsidiaries

are generally not guaranteed by Telenor ASA.Refer to note 31 Capital and financial risk management for

further information about capital management, maturity profile of the interest-bearing liabilities, liquidity

risk, exchange rate risk, interest rate risk and derivatives.

2025

234

Note 31

Capital and financial risk management

This note outlines the objectives and policies for capital and financial risk

management, along with the exposure and sensitivity for financial risks including

liquidity risk, interest rate risk, foreign exchange risk, and credit risk. Telenor employs

various types of derivatives to hedge against such risks.

Managing capital

Following the structural changes in the portfolio, and triggered by closing of the merger in Malaysia from

2022, Telenor has measured the leverage as the ratio of Net debt to EBITDA before other items plus

dividends from associated companies and joint ventures. Telenor aims to maintain a solid balance sheet

through keeping the leverage ratio in the range of 1.8x to 2.3x to ensure financial flexibility and cost

efficient funding (see page 293 for more information about net debt and leverage ratio).

As of 31 December 2025, the reported leverage ratio was 2.2x (compared to 2.4x as of 31 December

2024). The targeted capital structure provides a good balance between shareholder return and a solid

balance sheet with stable access to global debt markets, while also supporting Telenor’s strategic

priorities. As of 31 December 2025, Telenor ASA’s long-term credit rating was “Baa1/stable outlook” by

Moody’s Investors Service and “A-/stable outlook” by Standard & Poor’s (S&P).

Key elements of the Group’s capital structure include interest-bearing debt as disclosed in note 30, cash

and cash equivalents as disclosed in note 20 and equity attributable to the shareholders of Telenor ASA

as presented in the consolidated statement of changes in equity and in note 28.

In order to adjust the capital structure, the Group may acquire or sell own shares, distribute dividends to

shareholders, return capital to shareholders or issue new shares. In 2025, Telenor paid shareholders

dividend of NOK 13,135 million comprised of ordinary dividends paid out in June 2025 (NOK 5.00 per

share) and October 2025 (NOK 4.60 per share).

For the financial year 2025, the Telenor Board of Directors will propose an ordinary dividend of NOK 9.70

per share to be resolved by the Annual General Meeting in May 2026 and paid out in two tranches of NOK

5.00 and NOK 4.70 per share in June 2026 and October 2026 respectively. The total ordinary dividend

amount proposed for the financial year 2025 based on outstanding number of shares as of 31 December

2025 is NOK 13,272 million.

ACCOUNTING POLICIES

Hedge accounting is applied for fair value hedges and hedges of net investments in foreign operations

when the hedging criteria are met. For fair value hedges, the carrying amount of the hedged item is

adjusted for gains and losses attributable to the risk being hedged. The derivative is also measured at fair

value, and gains and losses from both the hedging instrument and the hedged item are recognised in the

income statement.

Hedge effectiveness is assessed on an ongoing basis, and hedge accounting is discontinued if the hedge

no longer meets the hedge accounting criteria. If the hedged item still exists and is not sold, the fair value

adjustment to the hedged item attributable to the risk being hedged at de-designation will be amortised in

the income statement over the remaining time to maturity.

A hedge of a net investment in a foreign operation is accounted for in a similar way as a cash flow hedge.

Foreign exchange gains or losses on the hedging instrument relating to the effective portion of the hedge

are recognised directly in other comprehensive income while any foreign exchange gains or losses

relating to the ineffective portion are recognised in the income statement. On disposal of the foreign

entity, the cumulative foreign exchange gains or losses recognised in other comprehensive income is

reclassified to the income statement. Refer to note 27 Financial assets and non-interest-bearing liabilities

for further information on accounting policies for derivatives.

2025

235

Telenor’s shareholder remuneration policy is to aim for a year-on-year growth in dividend per share,

where the annual dividends are paid in two instalments. Buyback of own shares or extraordinary dividend

pay-outs might also be used as a measure to reach a targeted leverage.

Financial risk

Telenor Group Treasury is responsible for funding and financial risk management for the parent company

and subsidiaries owned, directly or indirectly, more than 90% by Telenor ASA. Subsidiaries owned less

than 90% normally have stand-alone financing and management of financial risks. Beyond hedging

activities, the Group has limited trading activities.

Liquidity risk

To reduce liquidity risk and maintain financial flexibility, the Group ensures access to a diversified set of

funding sources. Debt issued in the international capital market is predominately issued under the

existing EMTN programme (Euro Medium Term Note) to secure longer dated funding and under existing

ECP programme (Euro Commercial Paper) to secure shorter dated funding up to 12 months. In addition to

these uncommitted loan programmes, the Norwegian domestic capital market is used from time to time.

Telenor ASA also has a sustainability-linked committed syndicated revolving credit facility (RCF) of EUR

1.8 billion with maturity in 2030. The RCF was undrawn as of 31 December 2025.

When permissible by local rules and regulations, subsidiaries owned 90% or more are part of Telenor

ASA’s cash management framework agreements and participate in Telenor ASA’s cash pool setup.

Subsidiaries owned less than 90% have established separate framework agreements for banking

services.

Telenor ASA shall have sufficient sources of liquidity to cover expected operational liquidity needs for

the next 12 months. Liquidity requirements to fund acquisitions is considered separately.

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236

Maturity profile of the Group’s liabilities (in nominal values)


NOK in millions	Total	< 1 year	2 years	3 years	4 years	5 years	6 years	7 years	8 years	9 years	10 years	>10 years	Not specified
Liabilities as of 31 December 2025
Interest-bearing liabilities
Financial Debt	86,462	12,455	7,378	7,662	14,530	7,908	5,885	8,870	—	5,916	15,767	93	—
Other interest-bearing liabilities	77	77	—	—	—	—	—	—	—	—	—	—	—
Sum of interest-bearing liabilities ¹⁾	86,539	12,531	7,378	7,662	14,530	7,908	5,885	8,870	—	5,916	15,767	93	—
Non-interest-bearing liabilities
Trade and other payables	21,243	21,243	—	—	—	—	—	—	—	—	—	—	—
Other current non-interest-bearing liabilities	654	654	—	—	—	—	—	—	—	—	—	—	—
Derivative financial instruments	1,057	386	4	204	—	462	—	—	—	—	—	—	—
Other non-current non-interest bearing borrowings	656	—	—	—	—	—	—	—	—	—	—	—	656
Sum of non-interest-bearing liabilities	23,610	22,283	4	204	—	462	—	—	—	—	—	—	656
Total	110,149	34,814	7,382	7,866	14,530	8,371	5,885	8,870	—	5,916	15,767	93	656

Future interest payments	12,284	2,004	1,884	1,738	1,583	1,348	981	949	650	627	520

Total including future interest payments	122,433	36,818	9,266	9,604	16,113	9,719	6,866	9,819	650	6,543	16,287	93	656
Liabilities as of 31 December 2024
Interest-bearing liabilities
Financial Debt	83,400	11,076	11,756	7,273	7,637	14,338	7,885	5,885	—	5,835	11,627	90	—
Other interest-bearing liabilities	277	277	—	—	—	—	—	—	—	—	—	—	—
Sum of interest-bearing liabilities ¹⁾	83,676	11,352	11,756	7,273	7,637	14,338	7,885	5,885	—	5,835	11,627	90	—
Non-interest-bearing liabilities
Trade and other payables	22,773	22,773	—	—	—	—	—	—	—	—	—	—	—
Other current non-interest-bearing liabilities	738	738	—	—	—	—	—	—	—	—	—	—	—
Derivative financial instruments	1,643	878	36	247	350	—	132	—	—	—	—	—	—
Other non-current non-interest bearing borrowings	557	—	—	—	—	—	—	—	—	—	—	—	557
Sum of non-interest-bearing liabilities	25,711	24,388	36	247	350	—	132	—	—	—	—	—	557
Total	109,387	35,741	11,792	7,520	7,987	14,338	8,017	5,885	—	5,835	11,627	90	557

Future interest payments	10,198	1,981	1,676	1,378	1,262	1,072	822	459	424	423	402	299

Total including future interest payments	119,585	37,722	13,468	8,898	9,249	15,410	8,839	6,344	424	6,258	12,029	389	557
1) The maturity tables do not include lease liabilities related to licences or other lease liabilities. See note 29 for more information on licence commitments and lease liabilities.

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237

Interest rate risk

The Group is exposed to interest rate risk through funding and cash management activities and aims to

manage this risk to reduce financial costs over time. Changes in interest rates affect the fair value of

assets and liabilities. Interest income and interest expense in the income statement are influenced by

changes in interest rates in the market. In 2025, average interest rate for the Group was 3.0% on interest-

bearing liabilities, excluding lease and licence liabilities (3.5% in 2024).

The majority of debt issued by the Group is fixed rate debt. The Group uses interest rate derivatives to

manage interest rate risk of the debt portfolio. This typically involves interest rate swaps, swapping fixed

interest rates to floating interest rates and vice versa.

According to Group Policy, external debt instruments shall maintain a balanced profile between fixed and

floating rate debt. The portion of the fixed rate shall be over 50% of external debt. Leasing is not under

active interest rate risk management and thus not included in the ratio. As of 31 December 2025, the

portion of fixed rate of Group’s debt was 63% (64% as of 31 December 2024). For Telenor ASA, the

portion of fixed rate debt as of 31 December 2025 was 63% (63% as of 31 December 2024).

Derivative instruments designated as fair value hedging instruments

In order to manage interest rate risk, a portion of the debt may be swapped to floating interest rate by

using interest rate swaps. Fair value hedge accounting is applied when hedge accounting criteria are

met. There is an economic relationship between the hedged items and the hedging instruments, as the

terms of the interest rate swaps match the terms of the fixed rate bonds (i.e., notional amount, maturity,

payment and rate set dates).

Effectiveness testing is performed using the hypothetical derivative method and compares changes in

fair value of the hedging instrument against the changes in fair value of the hedged item attributable to

the hedged risk. Hedge ineffectiveness in fair value hedges can arise from:

• Different interest rate curve applied to discount the hedged items and hedging instruments.

• Differences in timing of cash flows of the hedged items and hedging instruments. The table below

shows the effects of the Group’s fair value hedges.

The change in fair value of the hedging instrument and the hedged item is recognised on the line item

Net change in fair value of hedging instruments and hedged items under Net financial income (expenses)

in the income statement, see also note 9.

Fair value hedging relationships


NOK in millions	2025	2024
Net gain / (loss) recognised in the income statement on hedged items	(399)	(800)
Net gain / (loss) recognised in the income statement on hedging instruments	539	893
Amount of hedge ineffectiveness	139	93

Financial instruments designated as hedging instruments in fair value hedges are classified on the line

items Other non-current financial assets and Other current financial assets in the statement of financial

position, see note 27, and current and non-current interest-bearing liabilities, see note 30:


	2025		2024
NOK in millions	Assets	Liabilities	Assets	Liabilities
As of 31 December
Nominal amounts fair value hedge instruments	31,170	—	33,544	—
Fair values of fair value hedge instruments	—	1,097	36	(1,647)

The following table shows the maturity profile of interest proceeds and payments of the Group’s fair

value hedge instruments (in nominal values):


NOK in millions	Total	< 1 year	2 years	3 years	4 years	5 years	6 years	7 years	8 years	9 years	10 years	>10 years
As of 31 December 2025	(1,144)	(431)	(336)	(203)	(61)	(23)	(25)	(28)	(30)	(6)	(1)	—
As of 31 December 2024	(2,198)	(766)	(597)	(438)	(236)	(63)	(24)	(24)	(24)	(24)	(2)	—

The terms of the fixed rate receive leg of the interest rate swaps designated as fair value hedge

instruments match the terms of the fixed rate pay leg of the hedged items. The average interest rate

terms of the floating pay legs of the interest rate swaps are EURIBOR 3/6 months + 67 basis points (+ 67

basis points in 2024) for EUR denominated swaps.

The table below shows the carrying amounts of the Group’s fair value hedge items, which are recognised

on the line items Non-current interest- bearing liabilities and Current interest-bearing liabilities in the

statement of financial position:

2025

238


NOK in millions	2025	2024
As of 31 December
Carrying amount of hedged items recognised in the statement of financial position	29,110	32,251
Fair value hedge adjustments included in the carrying amount of the hedged items	(844)	(1,243)

Interest rate risk sensitivity analysis

The Group calculates the sensitivity on the change in fair value of assets and liabilities of a defined

parallel shift in the yield curve of the relevant currencies. For each simulation, the same shifts in interest

rates are used for all currencies. The sensitivity analysis is run only for assets and liabilities that represent

significant interest-bearing positions. Due to debt instruments the net position is a liability. Interest-

bearing debt is measured at amortised cost, hence the effect of change in fair value is not recognised in

the income statement. For debt designated in fair value hedge relationships, changes in fair value

attributable to the hedged interest rate risk are recognized in the income statement together with the

related derivates. This is shown in the table below


	2025		2024
NOK in millions	Yield curve increase 50 Basis points	Yield curve decrease 50 Basis points	Yield curve increase 50 Basis points	Yield curve decrease 50 Basis points
Reduction (increase) in fair value of net liabilities	1,363	(1,417)	1,311	(1,367)
Gain (loss) in the income statement	(7)	8	(2)	4

Sensitivity analysis of change in floating interest rates on net financial items in the income statement:


	2025		2024
NOK in millions	Yield curve increase 50 Basis points	Yield curve decrease 50 Basis points	Yield curve increase 50 Basis points	Yield curve decrease 50 Basis points
Gain (loss) in the income statement	(134)	134	(149)	149

Exchange rate risk

The Group is exposed to changes in the exchange rate of NOK relative to other currencies. The value of

the Group’s net investments in foreign entities and proceeds from these investments varies with

changes in the foreign exchange rate. The net income of the Group is also affected by currency

fluctuations, as the profit and losses from foreign operations are translated into NOK using average

exchange rates for the period. Exchange rate risk related to some net investments in foreign operations

is partly hedged by issuing debt instruments in the respective currencies. Combinations of money

market instruments (Commercial Paper and bonds) and derivatives (foreign exchange forward contracts

and cross currency swaps) are used for this purpose. Net investment hedge accounting is applied when

possible.

Exchange rate risk also arises when Telenor ASA or any of its subsidiaries enter into transactions or

holds monetary items denominated in other currencies than their own functional currency. In

accordance with Group Policy, committed cash flows in foreign currency equivalent to NOK 300 million

or above are evaluated for hedging.

Financial instruments designated as hedging instruments of net investment in foreign

operations

As of 31 December 2025 and 31 December 2024, material hedging positions are designated as net

investment hedges.

There is an economic relationship between the hedged items and the hedging instruments as the net

investment creates a translation risk that is offset by the foreign exchange risk on the debt and

derivatives designated as hedging instruments.

Net investment hedging is mainly applied in currencies that have well-functioning financial markets. Local

regulations and market capabilities limit Telenor’s ability to establish effective net investment hedges in

Asian currencies, and the use of available instruments would involve greater liquidity risk. For additional

information on the currency composition of debt, see note 30.

The Group has established hedge ratios to match the underlying risk of the hedging instruments with the

hedged risk component. Hedge ineffectiveness may arise when the amount of the investment in the

foreign subsidiary becomes lower than the amount of the debt and derivatives designated as hedging

instruments. There was no ineffectiveness in the years ending 31 December 2025 and 31 December 2024.

For additional information and a reconciliation of the net investment hedge balance in equity,

see note 28.

2025

239

Net investment hedging relationships


NOK in millions	2025	2024
Amount recognised directly to other comprehensive income (OCI)	(705)	(2,483)
Amount reclassified from OCI to the income statement on disposal	(82)	—

Interest-bearing debt and derivatives designated as hedging instruments in net investment hedges (only

effective part of instruments is included):


	2025		2024
NOK in millions	Debt	Derivatives	Debt	Derivatives
As of 31 December
Nominal amounts net investment hedge instruments	(57,096)	6,180	(57,934)	11,476
Fair value net investment hedge instruments	(54,397)	(221)	(54,910)	128

Debt designated as hedging instruments in net investment hedges are recognised on the line items Non-

current interest-bearing liabilities and Current interest-bearing liabilities in the statement of financial

position.

Classification of derivatives designated for net investment hedge in the consolidated statement

of financial position:


NOK in millions	2025	2024
As of 31 December
Other non-current assets	218	1,142
Other financial current assets	374	157
Non-current non-interest-bearing financial liabilities	(467)	(415)
Current non-interest-bearing liabilities	(347)	(757)
Fair value net investment hedge instruments	(221)	128

2025

240

The following table shows the maturity profile (in nominal values) of the Group’s net investment hedge

instruments (only effective part of instruments is included):


NOK in millions	Total	< 1 year	2 years	3 years	4 years	5 years	6 years	7 years	8 years	9 years	10 years	>10 years
As of 31 December 2025	(55,903)	(9,414)	(3,499)	(5,182)	(9,856)	(3,718)	(5,041)	(7,296)	(213)	(4,781)	(6,903)	—
As of 31 December 2024	(50,044)	(4,780)	(7,125)	(3,365)	(4,801)	(9,882)	(2,539)	(4,963)	(224)	(224)	(4,934)	(7,207)

Average currency rates in cross currency swaps designated as net investment hedge instruments were

NOK/USD 8.51 (8.51 in 2024), USD/EUR 0.85 (1.17 in 2024), SEK/EUR 10.83 (10.83 in 2024) and NOK/EUR 11.52

(11.43 in 2024) in 2025. In 2025, average currency rates in foreign exchange contracts designated as net

investment hedge instruments were NOK/USD 10.23 (11.06 in 2024), NOK/EUR 11.79 (11.75 in 2024), USD/

EUR 0.85 (1.06 in 2024), USD/MYR 0.24 (0.22 in 2024) and USD/THB 0.03 (0.03 in 2024).

Exchange rate risk sensitivity analysis

This analysis does not consider correlation between currencies. Empirical studies confirm substantial

diversification effect across the currencies that the Group is exposed to. The three sensitivity analyses

shown below represent impact on the income statement due to fluctuations in the functional currencies,

the impact on other comprehensive income translating functional currencies into the presentation

currency NOK and lastly the effect on net income if the presentation currency NOK weakens or

strengthens.

Currency gains and losses on monetary items in foreign currency are recognised in the income

statements of Telenor ASA and its subsidiaries. Net currency gains (losses) in foreign subsidiaries are

translated to NOK in the consolidated income statement. The table below shows the effect on

consolidated net currency losses in the income statement of 10% depreciation in functional currencies in

the Group, keeping other currencies constant (only significant exposures above NOK 100 million are

included in the table):


Monetary Item Currency
	2025				2024
NOK in millions	EUR	SEK	USD	Other	EUR	SEK	USD	Other
Depreciating Functional Currency
NOK	(789)	773	(365)	(119)	(232)	(625)	(418)	(107)

Translation of subsidiaries from their functional currencies into the presentation currency of the Group

(NOK) will impact the Group’s other comprehensive income (OCI) and equity. If NOK had weakened by

10% against all other functional currencies of the Group, the change in the carrying amount of

consolidated equity as of 31 December 2025, including effects of net investment hedge, would have been

an increase of approximately NOK 7.1 billion (increase of NOK 7.9 billion as of 31 December 2024).

2025

241

The table below shows the impact on OCI of net investment hedge (NIH) instruments if the functional

currency weakened by 10%.


	2025			2024
NOK in millions	EUR	SEK	Other	EUR	SEK	Other
Currency effect on OCI (before tax) of NIH instruments
NOK	(2,982)	(1,291)	(818)	(2,746)	(1,056)	(844)
Effect on other comprehensive income (OCI)			(5,091)			(4,646)

Translation of net income from subsidiaries with functional currency other than NOK, also represents a

currency exposure for the Group’s reported figures. If the presentation currency (NOK) had weakened /

strengthened by 10% against all other currencies included in the analysis, net income from continuing

operations for the Group would have been NOK 1,024 million higher / lower in 2025 (NOK 1,650 million in

2024).

Credit risk

Credit risk is the loss that the Group would suffer if a counterparty fails to perform its financial

obligations. The Group considers its maximum exposure to credit risk to be as follows:

Maximum credit exposure


NOK in millions	2025	2024
Cash and cash equivalents	16,335	10,380
Bonds and commercial papers > 3 months (note 27)	358	319
Financial derivatives (note 27 )	609	1,398
Trade and other current financial receivables (note 19)	11,196	11,584

The Group’s credit risks largely arise from trade receivables, financial derivatives and cash and cash

equivalents.

Credit risk from cash and cash equivalents is managed by the Group’s Treasury department in

accordance with the principles defined in the Group Policy Treasury. Cash deposits are only made with

approved counterparties and in accordance with approved credit limits per counterparty.

Counterparty credit limits for core banks are approved by Telenor ASA's Board of Directors. The limits

are set to minimise the concentration of risks and therefore mitigate financial loss through a

counterparty’s potential payment default. Credit risk arising from financial derivatives and cash deposits

is managed through diversification, internal risk assessment and credit scoring, as well as credit risk

mitigation tools. The main risk mitigation tools include legal netting and collateral agreements.

Credit risk related to trade receivables is assessed to be limited due to the high number of customers in

the Group’s customer base. As such, no further credit risk provision is required in excess of the normal

provision for bad and doubtful receivables. See note 19 for information on receivables in terms of age

distribution and provision for bad debt. Credit risk related to sale of mobile phones on instalment plans,

where the effect of discounting is considered material, is also assessed to be limited. Credit risk related

to such arrangements are embedded in the discount rate and reflected as reduced revenue.

As of 31 December 2025, no cash collateral (receivable) was posted. As of 31 December 2024, NOK 4

million was posted as cash collateral (receivable).

2025

242

Note 32

Fair values of financial instruments

Based on the characteristics of the financial instruments that are recognised in the

financial statements, the financial instruments are grouped into classes and

categories. The estimated fair values of Telenor’s financial instruments are based on

available market prices and various valuation methodologies as summarised in this

note.

Fair value hierarchy

Telenor measures fair values using the following fair value hierarchy that reflects the significance of the

inputs used in measuring fair value:

Level 1: Quoted prices (unadjusted) in active markets for identical financial instruments

Level 2: Inputs other than quoted prices included within Level 1 that are observable for assets or liabilities,

either directly (i.e. as prices) or indirectly (i.e. derived from prices).

Level 3: Inputs for assets or liabilities that are not based on observable market data (unobservable

inputs).

Interest-bearing liabilities

Fair values of interest-bearing liabilities as shown in note 30 are based on quoted prices where available.

Interest-bearing liabilities that are not traded in an active market have been estimated using yield curves

which incorporate estimates of the Telenor ASA credit spread. The credit curves have been extrapolated

using indicative prices on debt issuance by Telenor ASA for different maturities. The yield curves have

been interpolated from cash and swap curves observed in the market for different currencies and

maturities.

Trade receivables and other current and non-current financial assets

For trade receivables and other current receivables, see note 19 for more information, the carrying

amount is assessed to be a reasonable approximation of fair value. The effect of not discounting is

considered to be immaterial for this class of financial instruments. Telenor has issued a shareholder loan

to the joint ventures holding the indirect ownership in True Corporation. These shareholder loans are

recognised at fair value through profit or loss, see note 27.

Trade payables and other non-interest-bearing financial liabilities

For trade payables and other non-interest-bearing financial liabilities, see note 24 for more information,

the carrying amount is assessed to be a reasonable approximation of fair value. The effect of not

discounting is considered to be insignificant for this class of financial instruments.

Equity investments

Equity investments are recognised at fair value, see note 27. Listed shares are based on quoted prices at

the end of the reporting period. Fair value of unlisted shares is estimated by using commonly used

valuation techniques or measured at cost if the investment does not have a quoted market price in an

active market and the fair value cannot be reliably measured.

Cash and cash equivalents

The fair value for this class of financial instruments is assessed to be equal to the nominal amount.

Derivatives

Fair value of currency swaps, foreign currency forward contracts and interest rate swaps as shown in

note 27 is estimated based on calculating the net present value of future cash flows, using interest rate

curves, exchange rates and currency spreads as of 31 December 2025 and 31 December 2024,

respectively.

Note 33

Guarantees


NOK in millions	2025	2024
Guarantee obligations as of 31 December	2,033	1,579

Telenor has provided various types of guarantees to external parties, including guarantees relating to

partnership agreements and guarantees for the pension funds. Purchased bank guarantees are not

included in the table.

2025

243

Note 34

Consolidation and group companies

Telenor had 86 subsidiaries in 15 countries at year-end 2025 . All subsidiaries have the

same reporting period and use consistent accounting policies.

ACCOUNTING POLICIES

The consolidated financial statements include entities where Telenor ASA has control, which is normally

when Telenor has more than 50% of the voting power through ownership or agreements, except where

non-controlling interests prevent the exercise of control. Intercompany transactions, balances, revenues,

expenses and unrealised internal profit or losses are eliminated on consolidation. Non-controlling

interests in subsidiaries are presented separately from the equity attributable to the owners of the parent.

Non-controlling interests have been measured at the proportionate fair value of net identifiable assets at

the date of the business combination and share of changes in equity since the date of the business

combination. Dormant subsidiaries are consolidated, but are not included in the list of subsidiaries and

number of countries in this note as they do not represent Telenor's activities.


		Ownership interest
Company name	Office	31 December 2025	31 December 2024
Bjørvika IKT AS	Norway	67%	67%
Bldng. AI AS	Norway	100%	100%
Gintel AS ¹⁾	Norway	67%
SnT East Holding AS	Norway	100%	100%
Talkmore AS	Norway	100%	100%
Telenor Agder Vestfold og Telemark 2 AS	Norway	100%	100%
Telenor AI Factory Norway AS	Norway	100%	100%
Telenor Asia Holding AS	Norway	100%	100%
Telenor Communication II AS	Norway	100%	100%
Telenor Consult AS	Norway	100%	100%
Telenor Cyberdefence AS ⁴⁾	Norway	100%	100%
Telenor Digital Infrastructure Holding AS	Norway	100%	100%
Telenor Eiendom Hareløkken AS	Norway	100%	100%
Telenor Festekontrakter AS	Norway	100%	100%


		Ownership interest
Company name	Office	31 December 2025	31 December 2024

Telenor Fiber AS	Norway	70%	70%
Telenor Forsikring AS	Norway	100%	100%
Telenor GTI AS	Norway	100%	100%
Telenor IoT AS¹⁾	Norway	100%
Telenor Jeløy Radio AS	Norway	100%	100%
Telenor KB AS	Norway	100%	100%
Telenor Låveveien 55 AS	Norway	100%	100%
Telenor Linx AS	Norway	100%	100%
Telenor Maritime AS	Norway	100%	100%
Telenor Marketplace Invest AS	Norway	100%	100%
Telenor Mobile Communications AS	Norway	100%	100%
Telenor Mobile Holding AS	Norway	100%	100%
Telenor Møre og Romsdal og Trøndelag 2 AS	Norway	100%	100%
Telenor Networks Holding AS	Norway	100%	100%
Telenor Nord 2 AS	Norway	100%	100%
Telenor Nordics AS	Norway	100%	100%
Telenor Norge AS	Norway	100%	100%
Telenor Procurement Company AS	Norway	100%	100%
Telenor Procurement Holding AS	Norway	100%	100%
Telenor Real Estate AS	Norway	100%	100%
Telenor Shared Services AS	Norway	100%	100%
Telenor Software Lab AS²⁾	Norway		100%
Telenor Sovereign Cloud Norway AS ¹⁾	Norway	100%
Telenor Svalbard AS	Norway	100%	100%
Telenor Towers AS	Norway	100%	100%
Telenor Towers Norway AS	Norway	100%	100%
Telenor Tracking Solutions AS	Norway	100%	100%
Telenor Tryvann Radio AS	Norway	100%	100%
Telenor Vestlandet og Rogaland 2 AS	Norway	100%	100%
Telenor Viken og Innlandet 2 AS	Norway	100%	100%
Telenor Øvre Strandgate 5 2 AS	Norway	100%	100%

2025

244


		Ownership interest
Company name	Office	31 December 2025	31 December 2024

Tilsig AS ³⁾	Norway		51%
Grameenphone Ltd	Bangladesh	56%	56%
MVNO Systems A/S	Denmark	100%	100%
Telenor A/S	Denmark	100%	100%
Telenor Danmark Holding A/S	Denmark	100%	100%
Tn Finance A/S	Denmark	100%	100%
Canal Digital Finland OY	Finland	100%	100%
DNA Kauppa OY	Finland	100%	100%
DNA Oyj	Finland	100%	100%
DNA Tower Finland Oy ⁵⁾	Finland	100%	100%
European Mobile Operator Oy	Finland	100%	100%
KNL Networks OY ⁶⁾	Finland	100%	100%
Moi Mobiili Oy	Finland	100%	100%
Telenor Finland Holding OY	Finland	100%	100%
Telenor Global Services Hong Kong Ltd	Hong Kong	100%	100%
Telenor India Private Ltd	India	100%	100%
Unitech Wireless (Tamilnadu) Private Limited	India	67%	67%
Vodafone Telenor Procurement Company SCSp ¹⁾	Luxembourg	51%
Telenor Pakistan BV Ltd	Netherlands	100%	100%
Telenor Shared Services Pakistan (PVT) Ltd	Pakistan	100%	100%
Margalla Ventures Ltd ²⁾	Pakistan		100%
Orion Towers (Private) Limited ²⁾	Pakistan		100%
Telenor LDI Comminication (PVT) Ltd ²⁾	Pakistan		100%
Telenor Pakistan (Private) Ltd ²⁾	Pakistan		100%
Telenor Linx Polska	Poland	100%	100%
TSS Portugal, Unipessoal LDA	Portugal	100%	100%
Telenor Asia PTE Ltd	Singapore	100%	100%
Telenor Asia Towers Pte. Ltd ²⁾	Singapore		100%
Telenor Global Services Singapore PTE Ltd	Singapore	100%	100%
Telenor GO Pte Ltd	Singapore	100%	100%


		Ownership interest
Company name	Office	31 December 2025	31 December 2024

Telenor Malaysia Investments Pte Ltd	Singapore	100%	100%
Telenor Pakistan Investments Pte Ltd	Singapore	100%	100%
Telenor Procurement Company Pte.Ltd.	Singapore	100%	100%
Telenor South Asia Investment Pte Ltd	Singapore	100%	100%
Telenor South-East Asia Investment Pte Ltd	Singapore	100%	100%
Telenor Thailand Investments Pte Ltd	Singapore	100%	100%
Telenor Connexion AB	Sweden	100%	100%
Telenor Gauntlet Holding AB	Sweden	100%	100%
Telenor Sverige AB	Sweden	100%	100%
Telenor Tower Sweden AB	Sweden	100%	100%
BCTN Holding Co., Ltd.	Thailand	100%	100%
BCTN Innovation Co., Ltd.	Thailand	100%	100%
Telenor Asia (IHQ) Ltd	Thailand	100%	100%
Thai Telco Holdings Ltd. ²⁾	Thailand		100%
FJ Labs Telenor Co-Invest II LP	USA	99%	99%
FJ Labs Telenor Co-Invest III LP	USA	99%	99%
Telenor Digital Holding Inc.	USA	100%	100%
Telenor Inc	USA	100%	100%

1) Acquired or established in 2025. 2) Sold or dissolved in 2025. 3) Changed name from Where20 AS in 2025 and ownership is 12% per 31 December 2025. 4) Merged with Watchcom Security Group AS in 2025. 5) Merged with Telenor Towers Finland Oy and Telenor Towers Holding Oy in 2025. 6) Changed name from Telenor Maritime Oy in 2025.

2025

245

Note 35

Associates and joint arrangements

Telenor has two major associates in Malaysia (CelcomDigi) and in Thailand (True

Corporation) with a combined carrying amount of NOK 62,878 million. The market

value as of 31 December 2025 for these two listed entities was NOK 67,293 million. The

share of net income from the aforementioned companies are reported with one

quarter lag, with adjustment for significant events.

Associates and joint ventures


NOK in millions	2025	2024
Balance as of 1 January	66,793	50,942
Additions	3,126	2,323
Disposals	(659)	(4)
Impairment reversal	265	6,604
Share of net income	1,618	206
Share of other comprehensive income	(183)	(85)
Dividends received	(2,547)	(1,425)
Translation differences	(1,898)	8,232
Balance as of 31 December	66,514	66,793
of which investment in CelcomDigi	36,904	38,710
of which investment in True Corporation	25,974	24,303
of which investment in Carousell	1,673	1,830
of which investment in Allente	—	987
of which investment in Jotta Group	560	—
of which investment in easypaisa digital bank	879	631
of which investment in Skygard	335	89
of which others	189	243

ACCOUNTING POLICIES

Associates are those entities where Telenor has significant influence, but not control or joint control,

usually between 20 to 50 percent voting power. Joint ventures are those entities where unanimous

consent is required by the owners on important decisions and where the parties have rights to net assets.

Interests in joint ventures and associates are accounted for using the equity method. The investments are

initially recognised at cost (including transaction costs) and subsequently adjusted for the share of profits

and losses, dividends received and impairment. The share of net income is presented on a separate line in

the income statement.

An investment is a joint operation when unanimous consent is required by the owners on important

decisions and Telenor and the parties have rights to specific assets and obligations. These arrangements

are consolidated on a line-by-line basis with a share of revenues and costs, and the specific assets and

liabilities or the proportionate share of jointly owned assets and liabilities. The accounting for joint

operations structured through separate vehicles (joint ventures), reflects the Group’s involvement in the

assets and liabilities and not the joint operations involvement with other joint operators.

For investments where financial statements are not available at the time Telenor publishes its report, the

share of net income is recognised with a one quarter lag. Adjustments are made for significant

transactions or events known in the market. To ensure consistency, the Annual Report is not updated in

situations where the financial statements for the investee are made available after fourth quarter and

before the issuance of the Annual Report, unless the transactions or events are deemed significant.

KEY ACCOUNTING JUDGMENT

The net investment in associated companies is impaired if there is objective evidence of impairment. A

decline in market value of listed entities compared to cost is considered as objective impairment evidence

if the decline is significant or prolonged. The determination of what constitutes a significant or prolonged

decline is a matter of fact that requires the application of significant judgement.

2025

246

Additions

On 19 March 2025, Telenor announced the merger between Telenor Software Lab and Jottacloud in the

cloud storage market. The transaction was completed 30 April after the necessary regulatory approvals.

Jotta Group has an enterprise value of NOK 1.5 billion, and Telenor's equity share upon recognition was

NOK 572 million.

The ownership interests in True Corporation have been structured into direct ownership and indirect

ownership through joint ventures owned together with Charoen Pokphand Group (CP Group). In June

2025, as part of the agreement with Charoen Pokphand Group, Telenor acquired the remaining 1.7%

indirect ownership of True Corporation, held through the joint ownership structure. The shares were

transferred at fair value of THB 12.5 per share, equal to NOK 2,243 million, against settlement of the

outstanding receivables related to the joint ownership structure, and a net cash outflow of NOK 493

million.

In 2025, Telenor injected NOK 234 million into Skygard. The majority of the funds was contributed in the

fourth quarter 2025, and they will be used mainly to fund the acquisition of two data centres from Orange

Business Services Norway, announced 8 January 2026.

On 11 July 2024, Telenor acquired shares for NOK 2,962 million, bringing the total ownership interest in

True Corporation to 30.3%. 789 million shares were transferred from the joint ventures to Telenor, with a

corresponding reduction in the shareholder loans granted by Telenor and CP Group. Telenor's ownership

was divided into 28.6% direct ownership and 1.7% indirect ownership as of 31 December 2024.

Disposals

Allente was reclassified to held for sale and equity accounting discontinued in the third quarter of 2025,

when Telenor entered into an agreement to sell its 50% stake to Viaplay for SEK 1.1 billion, adjusted for

dividend to be received before closing. Telenor recognised a loss on disposal of NOK 58 million in the

fourth quarter of 2025 upon receiving the necessary regulatory approvals.

On 22 January 2026, Telenor announced an agreement to sell 24.95% of the shares in True Corporation,

together with a mutual put/call option for the sale of the remaining 5.35%. On 13 March 2026, the sale of

24.95% was completed. Please see note 40 Events after the reporting period for further information.

Impairments

In the third quarter of 2025, Telenor reversed the remaining impairment of NOK 269 million in True

Corporation left from the fourth quarter 2023, as fair value of the investment had exceeded carrying

value for a prolonged period.

In the first quarter of 2024, Telenor reassessed the carrying amount of True Corporation based on the

share price as of 31 March 2024. The increase in market value since the impairment recognised as of 31

December 2023 was deemed significant, and an impairment reversal of NOK 7,015 million for the

investment was recognised. The estimated recoverable amount after the reversal of the impairment was

NOK 20,577 million as of 31 March 2024. Due to the increase in market value of True Corporation during

2024, a positive fair value adjustment of NOK 2,068 million was recognised in net financial items related

to the fixed price share purchase agreement with the joint ventures established as part of the funding

arrangement with shareholder loan for the True investment.

In the fourth quarter 2024, an impairment assessment of Carousell was performed that resulted in an

impairment of NOK 411 million. The recoverable amount of Carousell was based on sales multiples for

similar entities. Sales multiples were used as Carousell is not profitable. Similar entities to Carousell

within the classified business, were deemed to be entities with low or negative growth, as Carousell

currently have low growth rate. The sales multiple used for Carousell as of 31 December 2024 was 3.6x,

which was equal to the median in the peer group. The carrying amount of Carousell as of 31 December

2024 after impairment was NOK 1,830 million, of which goodwill of NOK 2,192 million.

Material associates and joint ventures

CelcomDigi

CelcomDigi is an associate where Telenor controls 33.1% of the shares and voting rights. The associate is

accounted for using the equity method. CelcomDigi is a telecommunication company, listed on Bursa

Malaysia Berhad. Telenor share of CelcomDigi’s market value amounted to NOK 30,764 million as of

31 December 2025 (NOK 35,743 million as of 31 December 2024). The market value of CelcomDigi

increased above the carrying amount in second quarter of 2025 after having been below from the

second half of 2024. According to Telenor's accounting principles, the measurement of "prolonged

decline" was then reset. As of 31 December 2025, the market value is below the carrying amount of NOK

36,904 million by 17%. The subsequent decline in market value in 2025 has not been deemed to be

significant nor prolonged. CelcomDigi's share price as of 31 December 2025 was MYR 3.19, and carrying

value reflect an implicit share price of MYR 3.83.

In accordance with Telenor’s accounting principles, the reported results from CelcomDigi’s second

quarter was adjusted in Telenor’s third quarter reporting, taking into account the publication of the

annual report 2024 for Digital Nasional Berhad (DNB), an associate of CelcomDigi. The report revealed a

distressed situation for the company, which strongly indicated its fair value being impaired. The negative

impact on Telenor’s pro-rata share of net income from CelcomDigi was NOK 530 million. CelcomDigi has

not recognised this value decline in their own financials for 2025.

2025

247

As the financial quarterly results of the listed company CelcomDigi are not published at the time Telenor

reports its quarterly results, Telenor include the share of profits from CelcomDigi with a one quarter lag.

Significant events reported by CelcomDigi in their fourth quarter, is in accordance with the equity

method, adjusted for in the annual report of the respective year, thereby altering the original numbers

reported in Telenor's fourth quarter report. In the fourth quarter 2024, CelcomDigi reported one

significant event, impacting Telenor's share of net income in the Annual Report 2024 negatively with NOK

139 million.

Telenor is not aware of significant restrictions limiting the ability of CelcomDigi to transfer funds to its

shareholders. For example, under the form of dividends, repayment of advances or loans made.

The following table sets forth the summarised financial information of CelcomDigi. The financial

information includes the allocated excess values recognised as part of the merger, and reconciliation

with the carrying amount of the investment for Telenor.


NOK in millions	2025	2024
Statement of comprehensive income
Revenue	31,004	29,626
EBITDA	13,454	13,120
Depreciation and amortisation	(7,658)	(7,479)
Net financial items	(3,033)	(1,376)
Income tax expense	(1,187)	(1,106)
Net income (loss)	1,576	3,159
Other comprehensive income(loss)	—	—
Total comprehensive income (loss)	1,576	3,159
Telenor's ownership in %	33.1%	33.1%
Share of net income (loss)	522	1,046
Share of other comprehensive income (loss)	—	—
Share of total comprehensive income (loss)	522	1,046


NOK in millions	2025	2024
Statement of financial position
Non-current assets	80,466	85,540
Current assets excluding cash and cash equivalents	11,143	9,875
Cash and cash equivalents	1,647	1,205
Non-current non-interest bearing liabilities	(5,214)	(5,449)
Non-current interest bearing liabilities	(25,905)	(27,456)
Current non-interest bearing liabilities	(20,365)	(18,178)
Non-controlling interest	(304)	(285)
Total equity	41,467	45,252
Telenor's share of equity	13,726	14,979
Goodwill related to the Telenor's investment	23,179	23,731
Carrying amount of investment	36,904	38,710
Dividends received	1,382	1,318

True Corporation

Telenor increased its direct ownership in the associate True Corporation to 30.3% in second quarter

2025 after acquiring the remaining 1.7% of shares owned indirectly through a joint venture. True is a

telecommunication company, listed on the Stock Exchange of Thailand. Telenor’s share of True’s market

value amounted to NOK 36,529 million as of 31 December 2025 (NOK 38,448 million as of 31 December

2024, including the indirect ownership). True Corporation's share price as of 31 December 2025 is THB

10.90, and carrying value reflect an implicit share price of THB 7.80.

As the financial quarterly results of the listed company True Corporation are normally not published at

the time Telenor reports its quarterly results, Telenor include the share of net income from True with a

one quarter lag. Significant events reported by True in their fourth quarter, is in accordance with the

equity method, adjusted for in the annual report of the respective year, thereby altering the original

numbers reported in Telenor's fourth quarter report. In the fourth quarter 2025, True reported four

significant events, impacting Telenor's share of net income in the Annual Report 2025 negatively with

NOK 153 million (negative NOK 633 million in the fourth quarter 2024).

The Group is not aware of significant restrictions limiting the ability of True Corporation to transfer funds

to its shareholders. For example, under the form of dividends, repayment of advances or loans made.

2025

248

The following tables sets forth the summarised financial information of True Corporation, including the

allocated excess values recognised as part of the merger, adjustments for difference in accounting

policies, and reconciliation with the carrying amount of the investment for Telenor.


NOK in millions	2025	2024
Statement of comprehensive income
Revenue	64,371	60,164
EBITDA	30,134	22,694
Depreciation, amortisation and impairment	(23,166)	(19,788)
Net financial items	(5,438)	(6,433)
Income tax expense	713	39
Net income (loss)	2,244	(3,488)
Other comprehensive income (loss)	(530)	(318)
Total comprehensive income (loss)	1,714	(3,806)
Telenor's ownership in %	30.3%	28.6%
Share of net income (loss) ¹⁾	644	(973)
Reversal of impairment of goodwill	269	7,015
Share of other comprehensive income (loss) ¹⁾	(152)	(89)
Share of total comprehensive income (loss)	760	5,953


NOK in millions	2025	2024
Statement of financial position
Non-current assets	198,880	203,094
Current assets excluding cash and cash equivalents	18,531	22,434
Cash and cash equivalents	4,322	5,609
Non-current non-interest bearing liabilities	(10,666)	(10,336)
Non-current interest bearing liabilities	(130,858)	(119,924)
Current non-interest bearing liabilities	(51,730)	(70,636)
Non-controlling interest	75	(98)
Total equity	28,554	30,143
Telenor's share of equity	8,652	8,621
Goodwill related to the Telenor's investment	17,322	15,682
Carrying amount of investment	25,974	24,303
Dividends received (before withholding tax)	629	—

Joint operations

Telenor is part of four joint arrangements structured through separate vehicles for networks sharing in

Sweden, Denmark, and Finland. The activities are designed for the provision of output to the investors

and hence these arrangements are classified as joint operations.

1) Share of net income and share of comprehensive income is based on weighted ownership of 28.7% for 2025 and 27.9%

for 2024.


Joint Operation	Description	Ownership interest in %
3G Infrastructure Services AB	Joint operation with the mobile operator 3 in Sweden ¹⁾	50
Net4Mobility HB	Joint operation under partnership agreement with the mobile operator Tele2 Sverige AB in Sweden ¹⁾	50
TT Netværket P/S	Joint operation with the mobile operator TeliaSonera Mobile Holding AB in Denmark	50
Suomen Yhteisverkko Oy	Joint operations with mobile Operator Telia Finland Oy in Finland ²⁾	49

1) Under Swedish law, all partners in a partnership are jointly and severally liable for all obligations in a partnership.

2) According to the shareholder’s agreement, both partners in are jointly and severally liable for all obligations in the

joint undertaking.

2025

249

Note 36

Related parties

Telenor ASA is as of 31 December 2025 owned 53.97% by the Kingdom of Norway

represented through the Ministry of Trade, Industry and Fisheries (MTIF). Transactions

between Telenor and Norwegian authorities and between Telenor and its associated

companies and joint ventures are regarded as related party transactions. All

transactions with these related parties are based on the arm’s length principle.

Transaction with Norwegian authorities

The Norwegian telecommunications market is governed by the Electronic Communications Act which

came into force 1 January 2025 and other regulations issued pursuant to this Act. Telenor provides

designated Universal Service Obligations (USO) through an agreement with the Norwegian Ministry of

Local Government and Regional Development (MLGRD), which from January 2024 was transferred to the

new Ministry of Digitalisation and Public Governance, and in June 2025 transferred to the Norwegian

Communications Authority. The USO obligation entails among other things the provision of public voice

telephony and basic access to internet to all households and companies if no alternative service

(including satellite) is available. Telenor is imposed USO obligations to provide text telephony services for

the deaf and hearing impaired, but does not receive any compensation for providing the USO services.

In addition, Telenor was in 2025 and 2024 subject to Special Service Obligations (SSO), mainly related to

security and emergency following an agreement between the Norwegian Ministry of Justice and Public

Security and Telenor Coastal Radio. In 2025 and 2024, NOK 109 million and NOK 106 million, respectively,

was received as compensation under this agreement. Effective 1 January 2026, the Norwegian State will

be taking over the responsibility for the Coastal Radio service from Telenor.

Telenor may also receive compensation for the obligations to fulfil additional requirements on the

network to serve national security issues and other statutory services. In 2025 and 2024, compensation

for such activities of NOK 79 million and NOK 116 million, respectively, was received.

In 2025 and 2024, Telenor received NOK 207 million and NOK 187 million in government grants,

respectively, in connection with construction of broadband networks in designated areas in Norway.

Telenor pays an annual fee and an annual levies to Norwegian Communications Authority for delivering

electronic communication services, including payments for frequencies and numbers. The sum of fee

and levies was NOK 211 million and NOK 203 million in 2025 and 2024 , respectively. In addition, Telenor

sold capacity in the DAB radio broadcast network and related services to Norsk rikskringkasting of NOK

243 million in 2025 and NOK 238 million in 2024.

Telenor provides mobile and fixed telephony services, leased lines, customer equipment, internet

connections, TV distributions and other services to the state and companies controlled by the state in

the normal course of business and at arms-length prices. It also purchases services, such as postal

services, in the normal course of business and at arm’s-length prices. Details of such transactions are not

included in this note.

Transactions with associated companies and joint ventures

Sales, purchases, receivables and payables with associated companies and joint ventures are shown in

the tables below.


	2025		2024
NOK in millions	Sales to	Purchases from	Sales to	Purchases from
	547	(778)	623	(824)


	2025		2024
NOK in millions	Receivables	Payables	Receivables	Payables
	172	(9)	173	(66)

Sales to associated companies in 2025 include NOK 336 million to True Corporation and NOK 165 million

to CelcomDigi (NOK 305 million and NOK 238 million in 2024), mainly through Telenor Procurement

Company. Telenor has a receivable against True Corporation of NOK 93 million and against CelcomDigi of

NOK 78 million (NOK 42 million and NOK 67 million in 2024).

Purchases from Strex and 4T regarding mobile content services were NOK 532 million and NOK 184

million in 2025 (NOK 566 million and NOK 131 million in 2024).

Transactions with subsidiaries and joint operations have been eliminated on consolidation and do not

represent related party transactions. See note 35 for further information about joint operations and note

34 for further information about group companies. For compensation to key management personnel,

please refer to note 37 Key management compensation.

2025

250

Note 37

Key management compensation

Management compensation by categories

The table below outlines key management compensation for 2025 and 2024 by categories. The figures

presented in each category are the total amounts for both the President & CEO, and Group Management.


NOK in millions	2025	2024
Base Salary¹⁾	46.7	43.7
Salary substitute ²⁾	3.8	0.2
Benefits³⁾	4.7	1.6
Short-term incentive (STI) ⁴⁾	9.3	4.5
Long-term incentive (LTI)⁵⁾	7.2	4.8
Extraordinary items ⁶⁾	6.2	2.4
Pension⁷⁾	3.3	7.8
Total compensation	81.1	65.1

1) Base salary also includes earned holiday pay.

2) Salary substitute reflects the earned substitute, the net amount is invested in Telenor shares up to four times each

year. The shares are locked for the length of the executive's employment.

3) Benefits include any type of cash or benefit in kind, such as car allowance or car benefit, ESP discount, insurances,

mobile phone and broadband subscriptions, taxable commuting expenses, and expatriate benefits such as

accommodation and children schooling.

4) The STI reflect the annual bonus earned in the respective year. Any applicable holiday pay is reported under ‘Base

salary’.

5) The LTI is a multi-year incentive plan that is a restricted share-based plan. The shares are locked for a period of 3

years. The amounts reported for the LTI plan reflect the annual cost of all active programs in that year.

6) Extraordinary items may include one-time compensation such as sign-on or retention bonus, relocation costs,

termination, and severance related payments.

7) The calculations of pension benefits earned are based on the same actuarial and other assumptions as used in the

pension benefit calculations in note 21 Pension obligations.

In addition to the above, fees to the Board of Directors amount to NOK 7.3 million in 2025 and NOK 6.5

million in 2024. The fees consist of an annual fee reflecting the role in the Board and additional fees for

any Board committee the respective director takes part in. For more information about executive

compensation see page 62 and the Telenor Executive Compensation Report.

Loans to employees

Total loans to employees were NOK 1.2 million as of 31 December 2025 and NOK 5.0 million as of

31 December 2024.

Note 38

Fees to external auditor

The table below summarise the incurred audit fees to the external auditor for 2025 and 2024. The

amounts include fees for both Norwegian and foreign subsidiaries.


	Audit fees		Fees for other assurance		Fees for tax services		Other fees
NOK in millions, excluding VAT	2025	2024	2025	2024	2025	2024	2025	2024
Telenor ASA	7.8	7.5	6.2	3.8	2.5	0.4	—	—
Other subsidiaries	30.8	30.8	3.9	3.7	13.5	15.0	6.0	6.0
Total Group auditor	38.6	38.3	10.1	7.5	16.0	15.4	6.0	6.0
Other auditors in subsidiaries	0.5	0.5	0.1	—	—	—	—	—
Total	39.1	38.8	10.2	7.5	16.0	15.4	6.0	6.0

Fees for audit services relate to statutory audits. Other assurance services mainly include attestation

services required by laws and regulations, including reviews of information systems, audits, attestations

and agreed‑upon procedures reported to regulators and other external stakeholders.

Fees for tax services include tax compliance support and advisory services regarding applicable tax rules

and consequences, as well as tax due‑diligence work related to acquisitions, disposals and other

transactions.

Other fees primarily relate to process-, systems-, project- and supplier reviews, financial due diligence

services and advisory support related to with acquisitions, disposals and other transactions.

2025

251

Note 39

Shareholders

Telenor ASA had about 56,600 registered shareholders as of 31 December 2025 ,

compared to about 55,900 the year before. All ordinary Telenor shares have equal

voting rights and the right to receive dividends.

Shareholders according to shareholder register ¹⁾


Name of shareholders		Number of shares	%
1	Ministry of Trade, Industry and Fisheries, Kingdom of Norway	738,432,900	53.97
2	Folketrygdfondet	67,296,911	4.92
3	State Street Bank and Trust Comp	28,827,136	2.11
4	State Street Bank and Trust Comp	22,302,785	1.63
5	State Street Bank and Trust Comp	14,270,525	1.04
6	CLEARSTREAM BANKING S.A.	11,101,714	0.81
7	Citibank, N.A.	9,697,603	0.71
8	JPMorgan Chase Bank, N.A., London	9,328,886	0.68
9	JPMorgan Chase Bank, N.A., London	9,262,131	0.68
10	VERDIPAPIRFONDET KLP AKSJENORGE IN	8,030,738	0.59
11	State Street Bank and Trust Comp	7,631,050	0.56
12	JPMorgan Chase Bank, N.A., London	7,344,213	0.54
13	VERDIPAPIRFONDET STOREBRAND NORGE	6,987,827	0.51
14	VPF DNB AM NORSKE AKSJER	6,843,059	0.50
15	Euroclear Bank S.A./N.V.	6,839,235	0.50
16	DZ Privatbank S.A.	6,831,789	0.50
17	VERDIPAPIRFONDET DNB NORGE INDEKS	6,766,493	0.49
18	State Street Bank and Trust Comp	6,744,208	0.49
19	SIX SIS AG	6,251,158	0.46
20	VERDIPAPIRFONDET STOREBRAND INDEKS	5,975,394	0.44
	Total held by 20 largest shareholders	986,765,755	72.11
	Total all Telenor shares	1,368,349,989	100.00

Shareholders based on beneficial ownership ²⁾


Name of shareholders		Number of shares	%
1	Government of Norway	738,432,900	53.97
2	Folketrygdfondet	67,296,911	4.92
3	BlackRock	39,217,122	2.87
4	Vanguard	28,025,423	2.05
5	DWS Investments	24,898,946	1.82
6	Storebrand Asset Management	20,598,274	1.51
7	DNB Asset Management AS	19,354,251	1.41
8	KLP Kapitalforvaltning AS	15,031,122	1.10
9	Union Investment	14,158,102	1.03
10	State Street Investment Management	12,375,937	0.90
11	Nordea Funds	8,874,912	0.65
12	Arrowstreet Capital	8,844,474	0.65
13	Alfred Berg Kapitalforvaltning	8,814,549	0.64
14	Deka Investments	8,444,638	0.62
15	UBS Asset Management	8,083,223	0.59
16	Quebec Deposit and Investment Fund (CDPQ)	8,047,045	0.59
17	Danske Invest	7,311,755	0.53
18	Geode Capital Management, LLC	6,636,421	0.48
19	Aberdeen Investment Management	6,302,719	0.46
20	Pyrford International	5,998,692	0.44
	Total held by 20 largest shareholders	1,056,747,416	77.23
	Total all Telenor shares	1,368,349,989	100.00

1) Source: VPS share register

2) The data is provided by Nasdaq Advisory Services and is obtained through an analysis of beneficial ownership and

fund manager information provided in replies to disclosure of ownership notices issued to all custodians on the

Telenor VPS share register. Every reasonable effort has been made to verify the data; however, neither Telenor nor

Nasdaq Advisory Services can guarantee the accuracy of the analysis.

2025

252

Note 40

Events after the reporting period

Divestment of True Corporation

On 22 January 2026, Telenor entered into an agreement to sell its 30.3% ownership interest in True

Corporation in Thailand to Arise Digital Technology Company Ltd in two tranches. The first tranche to sell

24.95% of the shares was completed on 13 March 2026 at the agreed price of THB 11.70 per share,

equivalent to a cash proceeds of approximately THB 98.9 billion (NOK 30 billion) received at closing and a

deferred payment of THB 2.0 billion (NOK 0.6 billion), due 6 months after closing.

The agreement also includes a mutual put/call option for the sale of Telenor’s remaining 5.35% interest,

exercisable two years after completion of the initial transaction, at the higher of THB 11.70 per share and

the volume-weighted average price over the last 90 trading days prior to the trading day.

Hedging arrangements have been entered into to convert the Thai baht proceeds into other currencies in

line with the intended use of funds.

Grameenphone final dividend for 2025

On 2 February 2026, the Board of Directors of Grameenphone Ltd. proposed final dividend for 2025 of

BDT 10.50 per share, which corresponds to approximately NOK 1.2 billion total dividend and

approximately NOK 0.5 billion for the non-controlling interests ownership share.

Telenor ASA dividend for 2025

Based on the performance during the year, the Board of Directors of Telenor ASA proposes an ordinary

dividend of NOK 9.70 per share for 2025, to be declared by the Annual General Meeting (AGM) on 19 May

2026. The proposed dividend shall be split into two tranches of NOK 5.00 and NOK 4.70 per share, to be

paid in June and October 2026 respectively, and represents a 1% increase per share compared to 2024.

Share buyback programme

The Board of Directors has resolved a three‑year share buyback programme of NOK 15 billion. The

programme follows Telenor’s established shareholder remuneration framework, which includes

dividends and share repurchases, and will be executed subject to AGM‑granted authorisations and

proportionate share redemptions with the Norwegian state to maintain its ownership share. The Board

will assess the annual execution of the programme in line with Telenor’s financial ambitions and balance

sheet targets.

700MHz spectrum award in Grameenphone

On 21 January 2026, the Bangladesh Telecommunication Regulatory Commission approved the allocation

of 2×10 MHz spectrum in the 700 MHz band to Grameenphone Ltd., a 55.8%-owned subsidiary of Telenor

ASA. The spectrum will be awarded at a base price of approximately BDT 22 billion (around NOK 2 billion)

for a 13-year licence commencing from 1 June 2026, payable in ten annual instalments, with additional

annual fees estimated at BDT 240 million (around NOK 23 million) from 2027.

Fourth-quarter events in True Corporation (adjusted)

On 19 February 2026, True Corporation issued their fourth-quarter 2025 results where they reported

significant one-time effects, of which impacted Telenor's share negatively with NOK 153 million. Telenor

has recognised the significant one-time effects in the income statement line “share of net income (loss)

from associates and joint ventures” for 2025. Refer to note 35 Associates and joint arrangements for

further information

India Supreme Court ruling impacting Spectrum charge dispute (adjusted)

On 20 February 2026, the Indian Supreme Court issued a judgment in a related operator’s case, clarifying

the one‑time spectrum charge and related interest. The ruling is expected to set a precedent that may be

relevant to the review of Telenor’s corresponding case (see note 12 Held for sale and discontinued

operations and note 23 Legal disputes and contingencies). As a result, the Group reassessed the

provision, increasing the loss from discontinued operations by NOK 1,212 million and liabilities held for

sale by NOK 1,196 million, with a NOK 16 million positive effect in OCI.

Easypaisa deferred tax recognition (adjusted)

In March 2026, the associate Easypaisa Digital Bank’s audited 2025 financial results were finalised and

released, confirming the recognition of a deferred tax asset of PKR 10.8 billion on previously

unrecognised tax losses carried forward. As a result, Consequently, Telenor has adjusted share of net

income from associated companies and joint ventures with NOK 214 million for 2025.

2025

253

Parent company

financial statements

(Telenor ASA)

Telenor ASA is a holding company with the executive

management and the internal bank of Telenor Group. It also

holds other typical corporate functions such as strategy, risk,

communications, research and development, security, people,

finance, legal and internal audit & investigation. The parent

company financial statements have been prepared in

accordance with simplified IFRS Accounting Standards.

Connecting customers to what matters most has been the core of

our business for 168 years. Our ambition is to deliver critical

connectivity and services to customers and societies, continue to

strengthen our responsible business agenda and utilise the

2025

254

Parent company income statement

Telenor ASA 1 January – 31 December


NOK in millions	Note	2025	2024

Revenues	1	355	678

Salaries and personnel costs	2, 14	(663)	(702)
Other operating expenses	3	(582)	(1,086)
EBITDA		(890)	(1,110)

Depreciation, amortisation and impairment losses	7	(52)	(29)
Operating Profit		(942)	(1,139)

Financial income	5	17,158	29,958
Financial expenses	5	(3,100)	(4,338)
Net currency gains (losses)	5	(619)	(2,159)
Net change in fair value of financial instruments	5	(128)	434
Net gains (losses and impairment) on financial assets	5	(514)	(3,522)
Net financial income (expenses)		12,797	20,373

Profit before taxes		11,855	19,234
Income taxes	6	(217)	1,049

Net income		11,638	20,283

Parent company statement of comprehensive income

Telenor ASA 1 January – 31 December


NOK in millions	2025	2024
Net Income	11,638	20,283
Other comprehensive income (loss)
Remeasurement of defined benefit pension plans	217	26
Income taxes on pension remeasurement	(48)	(5)
Items that will not be reclassified to income statement	169	21

Other comprehensive income (loss), net of taxes	169	21

Total comprehensive income (loss)	11,807	20,304

2025

255

Parent company statement of financial position

Telenor ASA as of 31 December


NOK in millions	Note	2025	2024

ASSETS
Deferred tax assets	6	3,832	3,580
Pension funds	14	546	319
Goodwill		20	20
Right-of-use assets	7	706	754
Property, plant and equipment		32	37
Shares in subsidiaries	8	166,179	160,433
Non-current interest-bearing receivables from Group companies	15	30,971	33,471
Other non-current financial assets	9, 11	857	1,853
Total non-current assets		203,143	200,467

Trade and other receivables from Group companies	15	364	233
Trade receivables external		1	2
Current receivables Group companies	10, 15	521	1,790
Other current financial assets	9, 11, 15	600	425
Cash and cash equivalents	10, 11	13,334	8,595
Total current assets		14,821	11,045
Total assets		217,964	211,512


NOK in millions	Note	2025	2024

EQUITY AND LIABILITIES
Equity	12	107,794	109,129
Liabilities
Non-current lease liabilities	7, 15	683	725
Non-current interest-bearing external liabilities	11	74,092	72,651
Non-current non-interest-bearing external liabilities	11	672	767
Pension obligations	14	500	519
Other provisions		26	45
Total non-current liabilities		75,973	74,707

Current lease liabilities	7, 15	53	53
Current interest-bearing liabilities to Group companies	11, 15	20,772	17,917
Current interest-bearing external liabilities	11	11,905	7,651
Current non-interest-bearing liabilities to Group companies	11, 13, 15	109	238
Current non-interest-bearing external liabilities	11, 13	1,359	1,817
Total current liabilities		34,197	27,676
Total equity and liabilities		217,964	211,512

2025

256

Parent company statement of cash flows

Telenor ASA 1 January – 31 December


NOK in millions	Note	2025	2024

Profit before taxes		11,855	19,234

Income taxes paid	6	(54)	(5)
Net (gains) losses, impairment and change in fair value of financial assets and liabilities	5	514	3,522
Depreciation, amortisation and impairment losses	7	52	29
Net interest (income) expenses (external)	5	2,061	2,275
Received dividend	5	4,821	22,105
Recognised dividend	5	(4,821)	(22,105)
Net changes in interest accruals against Group companies		(849)	(1,261)
Net currency (gains) losses not relating to operating activities		231	2,663
Interest received (external)		303	691
Interest paid (external)		(2,228)	(2,990)
Net changes in other accruals		(3,349)	(356)
Net cash flow from operating activities		8,536	23,802

Purchases of property, plant and equipment and intangible assets		(4)	(36)
Purchases of and capital increase in subsidiaries	8	(3,326)	—
Net cash flow from investing activities		(3,330)	(36)


NOK in millions	Note	2025	2024

Proceeds from borrowings		12,704	4,798
Repayments of borrowings		(7,607)	(12,548)
Payments of lease liabilities	7	(36)	(47)
Net change in receivables and payables to group companies		7,673	(9,297)
Purchase of treasury shares		(216)	(2,027)
Received from sale of treasury shares		214	134
Dividends paid to equity holders of Telenor ASA	12	(13,135)	(13,082)
Net cash flow from financing activities		(403)	(32,069)

Effect on cash and cash equivalents of changes in foreign exchange rates		(64)	8
Net change in cash and cash equivalents		4,739	(8,295)

Cash and cash equivalents as of 1 January	10	8,595	16,890
Cash and cash equivalents as of 31 December	10	13,334	8,595

2025

257

Parent company statement of changes in equity

Telenor ASA – for the years ended 31 December 2024 and 2025


NOK in millions (except for number of shares)	Number of Shares	Share Capital	Treasury Shares	Share Premium	Pension remeasurement	Other Reserves	Retained Earnings	Total Equity
Equity as of 1 January 2024	1,399,458,033	8,397	(87)	69	85	(20,906)	116,238	103,796
Net income for the period	—	—	—	—	—	—	20,283	20,283
Other comprehensive income for the period	—	—	—	—	21	—	—	21
Total comprehensive income	—	—	—	—	21	—	20,283	20,304
Dividends	—	—	—	—	—	—	(13,082)	(13,082)
Purchase of treasury shares ¹⁾	—	—	(101)	—	—	(1,794)	—	(1,895)
Cancellation of shares	(31,108,044)	(187)	187	—	—	—	—	—
Share-based payment, exercise of share options and distribution of shares	—	—	1	—	—	5	—	6
Equity as of 31 December 2024	1,368,349,989	8,210	—	69	106	(22,695)	123,439	109,129
Net income for the period	—	—	—	—	—	—	11,638	11,638
Other comprehensive income for the period	—	—	—	—	169	—	—	169
Total comprehensive income	—	—	—	—	169	—	11,638	11,807
Dividends	—	—	—	—	—	—	(13,135)	(13,135)
Purchase of treasury shares ¹⁾	—	—	—	—	—	(4)	—	(4)
Share-based payment, exercise of share options and distribution of shares	—	—	(1)	—	—	(2)	—	(3)
Equity as of 31 December 2025	1,368,349,989	8,210	(1)	69	275	(22,701)	121,942	107,794

1) The share buyback includes net movement in shares purchased/allocated for ESP and LTI program.

2025

258

Notes to the financial statements of parent company

Telenor ASA



1	General information and summary of significant	10	Cash and cash equivalents
	accounting principles	11	Financial instruments and risk management
2	Salaries and personnel costs	12	Equity and dividends
3	Other operating expenses	13	Current and non-interest-bearing liabilities
4	Research and development costs	14	Pension obligations
5	Financial income and expenses	15	Related Parties
6	Income taxes	16	Guarantees
7	Leases
8	Shares in subsidiaries
9	Other financial assets

2025

259

Note 1

General information and summary of significant accounting

principles

Telenor ASA is the holding company with the executive management and internal bank (Group Treasury)

of the Telenor Group. It also holds other typical corporate functions such as strategy, risk,

communications, research and development, security, people, finance, legal and internal audit &

investigation.

Basis of preparation

The financial statements have been prepared in accordance with simplified IFRS Accounting Standards

pursuant to the Norwegian Accounting Act § 3-9 and regulations regarding simplified application of IFRS

Accounting Standards issued by the Ministry of Finance on 7 February 2022.

Telenor ASA’s accounting principles are consistent with the accounting principles for the group. Where

the notes for the parent company are substantially different from the notes for the group, these are

shown below. Otherwise, reference is made to the notes for the consolidated financial statements.

Revenues and operating expenses

Revenues are mainly sale of group services to other group companies, sale of research and development

services and sale of other consultancy services. Purchases from other group companies consist mainly

of consultancy fees in strategic group projects, property lease, IT-operations, and maintenance.

Investment in subsidiaries

Shares in subsidiaries and loans provided to subsidiaries are evaluated at the lower of cost or fair value.

Any impairment losses and reversal of impairment losses are classified as net gains (loss and

impairment) on financial assets in the income statement.

Cash pool arrangement

Telenor has established cash pool arrangements where Telenor ASA is the account holder and the other

companies in the group are sub-account holders or participants. Subsidiaries in which Telenor owns less

than 90% of the shares are normally not participants in the cash pool arrangements held by Telenor ASA.

The cash pool arrangements allow netting of cash positions within the group, hence the group's net

deposits in the arrangement is an outstanding balance between Telenor ASA and the financial institution.

Non-current interest-bearing liabilities

Net change in group internal drawing rights are loans to, and placements from group companies. These

loans and placements have high turnover and are presented net. Telenor ASA conducts the main part of

the external debt financing in the group, and provides loan and guarantees to, and receives deposits

from group companies.

2025

260

Note 2

Salaries and personnel costs

Please refer to the corporate governance section of the Board of Directors’ report as well as note 37 and

note 38 of the consolidated financial statements, for further information about compensation to the

Board of Directors, management and auditor.


NOK in millions	2025	2024
Salaries and holiday pay	(496)	(498)
Social security tax	(68)	(85)
Pension cost including social security tax (note 14)	(55)	(60)
Share-based payments ¹⁾	(24)	(31)
Other personnel costs	(20)	(28)
Total salaries and personnel costs	(663)	(702)
Number of labour-years employed, average	273	287

1) Share-based payments are costs related to Telenor's employees share program and Long Term Incentive plan (LTI) for senior

executives and key personnel.

Note 3

Other operating expenses


NOK in millions	2025	2024
Operating expenses related to country offices and services from shared service centres	(46)	(156)
Cost of premises, vehicles, office equipment, operation and maintenance etc.	(109)	(108)
Marketing, representation and sales commission	(34)	(29)
Workforce reductions and onerous contracts	(3)	(34)
Other operating expenses ¹⁾	(390)	(759)
Total other operating expenses	(582)	(1,086)

1) Other operating expenses are primarily related to safeguarding of interests and assessment of new market

opportunities. In addition, audit fees and other fees to the auditor are included, see note 38 in the consolidated

financial statements. Provision of bad debt of NOK 12 million is recognised against intercompany trade receivables,

a reduction of NOK 174 million compared to 2024 related to sale of Telenor Pakistan (Private) Ltd.

Note 4

Research and development costs

Research and development expenses in Telenor ASA were NOK 65 million in 2025 and NOK 61 million in

2024 . Research and development activities related to new technologies and secure full utilisation of

existing technologies and network.

2025

261

Note 5

Financial income and expenses


NOK in millions	2025	2024
Interest income from Group companies	1,253	1,698
Interest income (external)	313	691
Group contribution and dividends from subsidiaries	15,583	27,565
Other financial income	9	4
Total financial income	17,158	29,958

Interest expenses to Group companies	(686)	(1,307)
Interest expenses (external)	(2,374)	(2,966)
Other financial expenses	(40)	(65)
Total financial expenses	(3,100)	(4,338)

Foreign currency gain	9	679
Foreign currency loss	(628)	(2,838)
Net foreign currency gains (losses)	(619)	(2,159)

Net change in fair value financial instruments at fair value through profit or loss	(151)	341
Net change in fair value of hedging instruments and hedged items	23	93
Net change in fair value of financial instruments	(128)	434

Impairment and losses on loans to group companies ¹⁾	(5)	—
Impairment losses on shares in subsidiaries ²⁾	(509)	(3,522)
Net gains (losses and impairment) on financial assets	(514)	(3,522)

Net financial income (expenses)	12,797	20,373

1) Impairment and losses on loans to group companies in 2025 related to an impairment of a financial receivable in

Telenor Tracking Solutions AS.

2) Impairment losses on shares in subsidiaries in 2025 are related to impairment of NOK 509 million in Telenor GTI

AS. Impairment losses on shares in subsidiaries in 2024 are related to impairment of NOK 3,316 million in Telenor

Communication II AS and NOK 206 million in Telenor Shared Services AS.

Group contribution and dividends received from group companies are recognised as financial income in

the year it is approved by the General Meeting in the relevant company and Telenor ASA obtains the right

to the group contribution and dividends.

In 2025, Telenor ASA received and recognised taxable group contribution, which relates to the financial

year 2024, from Telenor KB AS of NOK 4,427 million. Telenor ASA also received and recognised tax-free

group contributions, which relates to the financial year 2024, from Telenor Mobile Communications AS of

NOK 3,500 million and Telenor Asia Holding AS of NOK 2,835 million. Telenor ASA also received dividends

of NOK 3,445 million from Telenor Mobile Holding AS, dividends of NOK 700 million from Telenor

Networks Holding AS and dividends of NOK 676 million from Telenor GTI AS. In 2025, Telenor ASA

provided a group contribution of NOK 2,346 million to Telenor Asia Holding AS, with tax effect for the

2023 income year, recorded as a capital contribution in the intermediate holding company Telenor

Holding AS.

In 2024, Telenor ASA received and recognised tax-free group contribution, which relates to the financial

year 2023, from Telenor Mobile Communications AS of NOK 2,360 million and Telenor Asia Holding AS of

NOK 3,100 million. Telenor ASA also received dividends of NOK 17,300 million from Telenor Mobile

Holding AS, dividends of NOK 3,200 million from Telenor Networks Holding AS, dividends of NOK 1,325

million from Telenor Communication II AS and dividends of NOK 280 million from Telenor Shared

Services AS.

2025

262

Note 6

Income taxes

Income tax and effective tax rate


NOK in millions	2025	2024
Profit before taxes	11,855	19,234

Change in group contribution prior year	(516)	—
Resolution of disputed items and adjustment in prior years' current income tax	(1)	(49)
Change in deferred taxes	300	1,098
Income Tax	(217)	1,049

Tax Basis
Profit before taxes	11,855	19,234
Effect of other comprehensive income	217	26
Non-deductible expenses and tax-free income	293	3,574
Group Contribution prior year	(3,081)	—
Dividend – tax-free	(4,821)	(22,105)
Group contribution prior year - tax-free	(6,335)	(5,460)
Changes in temporary differences recognised in income statement	(3,436)	56
Prior years adjustments to estimated tax	(9)	80
Group contribution current year	6,147	3,081
Tax loss carryforwards	(830)	1,514
Tax basis for the year	—	—
Current taxes at nominal income tax rate in Norway (22% in 2025 and 2024)	—	—


NOK in millions	2025	2024

Effective Tax rate
Income tax expense at corporate income tax rate in Norway (22% in 2025 and 2024)	(2,608)	(4,231)
Non-deductible expenses and tax-free income	(112)	(792)
Accounting effect of received tax-free dividend	1,060	4,863
Accounting effect of received tax-free group contribution	1,394	1,201
Resolution and adjustments of disputed item	1	3
Other	48	5
Income tax	(217)	1,049
Effective tax rate in %	1.8%	-5.5%

2025

263

Temporary differences


NOK in millions	2025	2024	Changes
Temporary differences as of 31 December
Non-current assets	7	5	2
Interest element in connection with fair value hedges of liabilities	844	1,257	(413)
Financial derivatives	(1,642)	(1,954)	312
Losses on guarantees	(280)	(280)	—
Unrealised foreign exchange losses and gains on non-current borrowings	(7,673)	(11,588)	3,915
Other accruals for liabilities	(42)	(58)	16
Pension liabilities	47	(200)	247
Group contribution	(6,147)	(735)	(5,412)
Disallowed interest deduction carried forward	(1,847)	(1,204)	(643)
Tax loss carryforwards	(684)	(1,514)	830
Total temporary differences as of 31 December	(17,417)	(16,271)	(1,146)

Tax Rate	22%	22%	—
Net deferred tax assets	3,832	3,580	252
Changes in net deferred tax assets:
Recognised in other comprehensive income¹⁾			(48)
Recognised in the income statement			300

1) Deferred taxes recognised in other comprehensive income is related to tax re-measurement of defined benefit

pension plans. Other comprehensive income elements are presented gross in the comprehensive income with the

related tax effect on a separate line. Tax effect of 22% is included in change in deferred taxes.

The general tax rate in Norway is 22% in 2025.

Non-deductible expenses and tax-free income for 2025 includes impairment on shares in Telenor GTI AS

with NOK 509 million. For 2024 impairment on shares in Telenor Communication II AS with NOK 3,316

million and in Telenor Shared Services AS with NOK 206 million were included.

For 2025, Telenor ASA has elected, same as for 2024, to apply the option under Norwegian tax rules to

treat accumulated unrealised foreign losses on non-current borrowings as a temporary difference, but

not for the entire loss in 2025.

2025

264

Note 7

Leases

Right-of-use assets


NOK in millions	Buildings	Computers
Accumulated cost
As of 1 January 2024	978	—
Additions and remeasurement¹⁾	(100)	1
As of 31 December 2024	878	1

Additions	19	2
Derecognition	(27)	—
As of 31 December 2025	870	3
Accumulated depreciation
As of 1 January 2024	(101)	—
Amortisation	(24)	—
As of 31 December 2024	(125)	—

Amortisation	(41)	(1)
As of 31 December 2025	(166)	(1)
Carrying amount
As of 31 December 2024	753	1
As of 31 December 2025	704	2
Related lease liability disaggregated per class of right- of-use assets
As of 31 December 2024	777	1
As of 31 December 2025	735	1

1) Reassessment of lease liability based on current lease payment.

L ease liability


	2025			2024
NOK in millions	Current	Non- current	Total	Current	Non- current	Total
Lease liability related to buildings and computers	53	683	736	53	725	778
Total lease liabilities	53	683	736	53	725	778

Group as lessee

Telenor disposed its ownership of the headquarter office building at Fornebu, Norway in 2020. Upon

closing of the transaction, the group entered into several lease agreements with Snarøyveien 30 AS for

leasing back office space in parts of the building. In 2021 Telenor has entered corresponding new lease

agreements with group companies that have offices at Fornebu with the same conditions.

The non-cancellable period under the lease agreements is between 7-15 years, with a lease term of 7-25

years.

Telenor ASA has accounted for the new lease agreements in accordance with IFRS 16 Leases from

commencement date of the agreement on 1 October 2021. Lease liability and a corresponding right-of-

use asset is recognised at the commencement date of the lease.

2025

265

The lease liabilities maturity profile


NOK in millions	31. December 2025	< 1 year	2 years	3 years	4 years	5 years	6 years	7 years	8 years	9 years	10 years	>10 years
Lease liabilities - buildings and computers	736	53	41	37	37	37	37	37	37	37	37	346
Future interest payments	178	17	16	15	14	14	13	12	11	10	10	46
Total including future interest	914	70	57	52	51	51	50	49	48	47	47	392

Changes in lease liabilities


NOK in millions	2025	2024
Lease liabilities as of 1 January	778	924
Increase in lease liabilities related to other lease contracts due to new contracts or modification of existing contracts	(6)	(99)
Increase due to interest expense accrued	18	7
Decrease due to repayments of principal portion of lease liabilities	(36)	(47)
Decrease due to repayments of interest portion of lease liabilities	(18)	(7)
Lease liabilities as of 31 December	736	778

Cash payments made relating to lease contracts


NOK in millions	Classification in cash flow statement	2025	2024
Repayments of lease liabilities – principal portion	Financing activities	36	47
Repayments of lease liabilities – interest portion	Operating activities	18	7
Total cash outflow		54	54

Expenses recognised in the income statement related to lease contracts


NOK in millions	Classification in income statement	2025	2024
Depreciation of right-of-use assets ¹⁾	Depreciation and amortisation	42	24
Interest expenses on lease liabilities ¹⁾	Financial expenses (note 5)	18	7
Variable lease expenses not dependent on index or rate	Other operating expenses (note 3)	29	30
Total		89	61

1) Depreciation was reduced by NOK 19 million and interest expenses was reduced by NOK 12 million in 2024 regarding

the reassessment of lease liability.

2025

266

Note 8

Shares in subsidiaries

The table below sets forth Telenor ASA’s direct ownership interest in its subsidiaries. These subsidiaries

are mainly holding companies. Ownership interests correspond to voting interest if not otherwise stated.

Telenor subsidiaries at year-end 2025 are listed in note 34 in the consolidated financial statements.

Shares in subsidiaries


NOK in millions	Office	Ownership interest in % 2025	Ownership interest in % 2024	Carrying amount as of 31 December 2025	Carrying amount as of 31 December 2024
Telenor Networks Holding AS ¹⁾	Norway	100.0	100.0	84,261	80,817
Telenor Shared Services AS	Norway	100.0	100.0	420	420
Telenor Communication II AS ²⁾	Norway	100.0	100.0	4,505	3,920
Telenor Mobile Holding AS ³⁾	Norway	100.0	100.0	72,806	70,977
Telenor KB AS	Norway	100.0	100.0	—	—
Telenor Forsikring AS	Norway	100.0	100.0	300	300
Telenor Maritime AS ⁴⁾	Norway	98.9	98.9	172	172
Telenor GTI AS ⁵⁾	Norway	100.0	100.0	3,205	3,714
Telenor Real Estate AS	Norway	100.0	100.0	105	105
Telenor Digital Infrastructure Holding AS ⁶⁾	Norway	100.0	100.0	406	10
Telenor Nordics AS	Norway	100.0	100.0	—	—
Total				166,179	160,433

1) The increase in carrying amount relate to paid-in capital as part of a restructuring of the tower companies under

one holding company in 2025

2) There has been a capital injection from Telenor ASA to Telenor Communication II AS in 2025.

3) There has been a capital contribution from Telenor ASA to Telenor Mobile Holding AS in 2025.

4) The remaining 1.1% of shares in Telenor Maritime AS are owned by Telenor Communication II AS.

5) The shares in Telenor GTI AS were impaired in 2025.

6) There has been a capital injection from Telenor ASA to Telenor Digital Infrastructure Holding AS in 2025.

Note 9

Other financial assets


NOK in millions	2025	2024
Capital contribution in Telenor Pension Fund ¹⁾	298	298
Derivatives financial instruments	233	1,197
Other financial assets external	326	358
Total other non-current financial assets	857	1,853

Receivables from Group companies	149	196
Other current financial assets external	451	229
Total other current financial assets	600	425

1) The amount capitalised in the statement of financial position is the cost price, which is considered an

approximation of fair value. Telenor ASA holds the entire core capital in the Telenor Pension Fund. The capital

contribution to Telenor Pension Fund is classified as equity investment.

2025

267

Note 10

Cash and cash equivalents


NOK in millions	2025	2024
Net deposit in cash pool	6,266	6,380
Other deposits	7,068	2,215
Total cash and cash equivalents	13,334	8,595

Deposits in cash pool by subsidiaries	14,817	12,139
Drawings on cash pool by subsidiaries	(521)	(1,790)
Drawings on cash pool by Telenor ASA	(8,030)	(3,969)
Net deposits in cash pool	6,266	6,380

Note 11

Financial risk management

Telenor ASA’s treasury function is responsible for financial risk management including liquidity

management, interest rate risk, managing foreign exchange risk, credit risk and capital management.

The activities in the treasury function are performed according to policies and procedures approved by

the Board of Directors of Telenor ASA.

Telenor ASA issues debts in Norwegian and foreign capital market mainly through certificates and

bonds. In addition, Telenor ASA has a sustainability-linked committed syndicated revolving credit facility

(RCF) of EUR 1.8 billion with maturity to 2030. The RCF was undrawn as of 31 December 2025.

Financing of the Group’s activities implies that Telenor ASA’s income statement is exposed to changes in

interest rates in the market. Fluctuation in interest rates also influences the fair value of assets and

liabilities.

Telenor ASA holds debt in other currencies than Norwegian Kroner (NOK) and is exposed to currency risk

related to changes in value of NOK compared to other currencies. Net investment hedge relationships

are established to partly match currency fluctuation on debt instruments to currency fluctuations on

foreign investments.

The Company is exposed to credit risk related to receivables and financial instruments with positive

value against external parties and other companies in the Group.

Telenor ASA uses derivatives as forward currency contracts and interest rate swaps to manage the risk

exposure related to changes in currency and interest rates. All derivative contracts are measured at fair

value with changes through profit and loss. If the derivatives are designated for cash flow hedge

accounting or as part of a hedge of net investment, the changes in fair value are recognised as other

comprehensive income.

See also note 27 and note 31 in the consolidated financial statements where financial risks and

accounting for financial instruments are explained in detail.

2025

268

Fair value of financial instruments

Principles for estimating fair values

Based on the characteristics of the financial instruments that are recognised in the financial statements,

the financial instruments are grouped into the classes and categories described below. The estimated

fair values of the financial instruments are based on market prices and the valuation methodologies per

class are described below.

Fair value hierarchy

Telenor ASA measures fair values using the following fair value hierarchy that reflects the significance of

the inputs used in measuring fair value:

Level 1: Quoted prices (unadjusted) in active markets for identical financial instruments.

Level 2: Inputs other than quoted prices included within Level 1 that are observable for the asset or

liability, either directly (i.e. as prices) or indirectly (i.e. derived from prices).

Level 3: Inputs for assets or liabilities that are not based on observable market data (unobservable

inputs).

Interest-bearing liabilities

Fair values of interest-bearing liabilities are based on quoted prices where available. Interest-bearing

liabilities that are not traded in an active market have been calculated using yield curves, which

incorporates estimates of the Telenor ASA credit spread. The credit curve has been extrapolated using

indicative prices on debt issuance by Telenor ASA for different maturities. The yield curves have been

interpolated from cash and swap curves observed in the market for different currencies and maturities.

Trade receivables and other current and non-current financial assets

For trade receivables and other current receivables, the nominal amount is assessed to be a reasonable

approximation of fair value. The effect of not discounting is considered to be immaterial for this class of

financial instruments.

Equity investments

Fair values for listed shares are based on quoted prices at the end of the reporting period. Fair value of

unlisted shares is calculated using commonly used valuation techniques or measured at cost if the

investment does not have a quoted market price in an active market and the fair value cannot be reliably

measured.

Trade payables and other non-interest-bearing financial liabilities

For trade payables and other non-interest-bearing financial liabilities the nominal amount is assessed to

be a reasonable approximation of fair value. The effect of not discounting is considered to be immaterial

for this class of financial instruments.

Cash and cash equivalents

The fair value for this class of financial instruments is assessed to be equal to the nominal amount.

Derivatives

Fair values of currency swaps, foreign currency forward contracts and interest rate swaps are estimated

based on calculating the net present value of future cash flows, using interest rate curves, exchange

rates and currency spreads as of 31 December 2025 and 2024, respectively.

The tables below show the maturity profile of Telenor ASA’s debt in nominal values:

2025

269

Maturity profile 2025


NOK in millions	Carrying amount	Total as of 31 December 2025	2026	2027-2029	2030-2034	2035>
Interest-bearing liabilities
Bonds and Commercial Papers	84,899	85,216	11,843	29,649	27,881	15,843
Other interest-bearing liabilities	1,098	—	—	—	—	—
Total interest-bearing liabilities external	85,997	85,216	11,843	29,649	27,881	15,843

Other interest-bearing liabilities Group companies	5,955	5,955	5,955	—	—	—
Drawing on Group cash pools	14,817	14,817	—	—	—	14,817
Interest-bearing liabilities Telenor Group	20,772	20,772	5,955	—	—	14,817

Non-interest-bearing liabilities
Trade and other payables external	832	832	832	—	—	—
Trade and other payables Group companies	77	77	77	—	—	—
Other current non-interest-bearing liabilities	177	177	177	—	—	—
Derivative financial instruments liabilities	1,053	1,053	382	209	463	—
Other non-current non-interest-bearing liabilities	26	26	—	—	—	—
Total non-interest-bearing liabilities	2,165	2,165	1,468	209	463	—
Total	108,934	108,153	19,266	29,858	28,344	30,660

Future interest payments		12,048	1,941	5,035	4,523	548
Total including future interest payments	108,934	120,201	21,207	34,893	32,867	31,208

2025

270

Maturity profile 2024


NOK in millions	Carrying amount	Total as of 31 December 2024	2025	2026-2028	2029-2033	2034>
Interest-bearing liabilities
Bonds and Commercial Papers	78,654	80,090	7,650	26,677	28,108	17,655
Other interest-bearing liabilities	1,647	—	—	—	—	—
Total interest-bearing liabilities external	80,301	80,090	7,650	26,677	28,108	17,655

Other interest-bearing liabilities Group companies	5,778	5,778	5,778	—	—	—
Drawing on Group cash pools	12,139	12,139	—	—	—	12,139
Interest-bearing liabilities Telenor Group	17,917	17,917	5,778	—	—	12,139

Non-interest-bearing liabilities
Trade and other payables external	724	724	724	—	—	—
Trade and other payables Group companies	238	238	238	—	—	—
Other current non-interest-bearing liabilities	255	255	255	—	—	—
Derivative financial instruments liabilities	1,606	1,606	840	634	132	—
Other non-current non-interest-bearing liabilities	45	45	—	30	15	—
Total non-interest-bearing liabilities	2,867	2,867	2,057	664	147	—
Total	101,085	100,874	15,485	27,341	28,255	29,794

Future interest payments	—	10,158	1,940	4,317	3,199	701
Total including future interest payments	101,085	111,032	17,425	31,658	31,454	30,495

For specification regarding external interest-bearing liabilities in Telenor ASA, see note 30 in the consolidated financial statements.

2025

271

Changes in external interest-bearing liabilities


NOK in millions	2025	2024
As of 1 January	80,301	84,110
Change in cash flow from financing activities	4,097	(7,750)
Change in fair value adjustment of hedge items	399	800
Change in fair value of hedge instruments	(550)	(843)
Effects from changes in foreign exchange rates	779	3,793
Interest ¹⁾	36	41
Other changes	935	150
As of 31 December	85,997	80,301

1) Classified as cash flow from operating activities

Note 12

Equity and dividends

Allocation of equity and dispositions over the last two years is shown in a separate table, see statement

of changes in shareholders’ equity. Nominal value per share is NOK 6.

Dividends paid and proposed


	2025	2024
Dividends per share in NOK – paid	9.60	9.50
Dividends per share in NOK - proposed by the Board of Directors	9.70	9.60

Dividend of NOK 13,135 million has been recognised to equity in 2025 (NOK 13,082 million in 2024).

Board of Directors proposes an ordinary dividend of NOK 9.70 for 2025 (NOK 13,273 million), to be

declared by the Annual General Meeting (AGM) on 19 May 2026. The proposed dividend shall be split into

two tranches of NOK 5.00 and NOK 4.70 per share, to be paid in June and October 2026, respectively.

On 8 February 2023, Telenor announced a share buyback programme for the year 2023-2024. The total

programme comprised 31.1 million shares, of which 14.3 million shares were repurchased in the market

during 2023. With this, the market part of the buyback programme was finalised.

The remaining 16.8 million shares were purchased from the Kingdom of Norway through the Ministry of

Trade, Industry and Fisheries and hence the Ministry's ownership interest in Telenor of 53.97% remains

unchanged. The 31.1 million shares were cancelled following approval by the Annual General Meeting in

May 2024. The shares that were repurchased in the open market had an immediate cash effect whereas

the pro rata shares from the Norwegian state were paid simultaneously with the capital reduction in June

2024.

Note 13

Current and non-interest-bearing liabilities


NOK in millions	Category	2025	2024
Trade payables to Group companies	FLAC ¹⁾	77	238
Financial derivatives to Group companies	FVTPL²⁾	32	—
Current non-interest-bearing liabilities within the Group		109	238

Trade payables external	FLAC¹⁾	832	724
Government taxes, tax deductions, holiday pay etc.	NF ³⁾	119	124
Income taxes payable	NF ³⁾	1	55
Financial derivatives	FVTPL²⁾	350	839
Other current liabilities	FLAC ¹⁾	57	75
Current non-interest-bearing external liabilities		1,359	1,817

1) FLAC: Financial liabilities at amortised cost.

2) FVTPL: Fair value through profit and loss

3) NF: Non-financial assets and liabilities.

2025

272

Note 14


NOK in millions	2025	2024
Service cost	(17)	(21)
Net interest cost	(5)	(7)
Contribution plan cost	(38)	(39)
Total pension costs recognised in the income statement	(60)	(67)
Of which reported as pension cost (note 2)	(55)	(60)
Of which reported as net interest cost (note 5 )	(5)	(7)

Pension obligations

Telenor ASA is obliged to follow and complies with the Act on Mandatory Company Pensions. The

company has a pension scheme according to the requirements set in the Act. Telenor ASA follows the

same assumptions as the group, see note 21 to the consolidated financial statements.

Telenor ASA expects to contribute approximately NOK 72 million to the Telenor Pension Fund in 2026. A

total of 46 employees were covered by defined plan of the Telenor Pension Fund. Telenor Pension Fund

paid out pensions to 372 persons.

Changes in the defined benefit obligation and fair value of plan assets

Pension costs


	2025			2024
NOK in millions	Defined benefit obligation	Fair value plan assets	Net liability defined benefit	Defined benefit obligation	Fair value plan assets	Net liability defined benefit
As of 1 January	(1,413)	1,213	(199)	(1,398)	1,146	(251)
Service cost	(17)	—	(17)	(21)	—	(21)
Net interest	(46)	41	(5)	(45)	38	(7)
Sub-total included in Income Statement	(63)	41	(22)	(66)	38	(28)

Return on plan assets (excluding amounts included in net interest)	—	186	186	—	34	34
Actuarial changes arising from changes in financial assumptions	51	—	51	34	—	34
Experience adjustments	(21)	—	(21)	(42)	—	(42)
Sub-total included in Other Comprehensive Income	30	186	216	(8)	34	26

Effects of business combinations and disposals	36	(39)	(3)	(10)	7	(3)
Contributions by employer	—	27	27	—	34	34
Benefits paid	74	(46)	28	69	(46)	23
As of 31 December	(1,336)	1,382	46	(1,413)	1,213	(199)
Of which classified as:
Pension obligations			(500)			(519)
Pension assets¹⁾			546			319

1) Telenor does not have a right to use the net funds in the funded plans to settle the obligations under the unfunded plans

2025

273

Note 15

Related parties

Telenor ASA’s transactions with its major shareholder, the Norwegian State represented by the Ministry

of Trade, Industry and Fisheries, are discussed in note 36 to the consolidated financial statements.

Telenor ASA’s other related parties consist mainly of subsidiaries of the group. Telenor ASA sells and

buys services from these companies, see note 1 for further description, and provides loans and receives

deposits from the companies. When permissible by local rules and regulations, subsidiaries owned 90%

or more are part of Telenor ASA’s cash pool systems and the internal bank in Group Treasury. Through

the internal bank, the subsidiaries can get loans, place excess liquidity, and make currency exchanges.

In addition, Telenor ASA receives dividends that are recognised as financial income, see note 5 . Group

contributions and dividends recognised in 2025 and 2024 of NOK 15,583 million and NOK 27,565 million,

respectively, are received from companies within Other units.

Lease liabilities to Telenor Real Estate AS of NOK 735 million in 2025 and NOK 777 million in 2024 are

included under financial transactions, Liabilities, see note 7.

Sales to and purchases from Group companies


	2025		2024
NOK in millions	Sales	Purchases	Sales	Purchases
Operational subsidiaries in the following countries:
Norway	155	10	263	19
Sweden	70	34	134	47
Denmark	27	6	66	17
Finland	33	1	89	21
Grameenphone – Bangladesh	16	—	9	1
Pakistan	6	—	21	—
Holding companies and other entities	45	390	64	591
Total	352	441	646	696

Trade receivables and payables Group companies


	2025		2024
NOK in millions	Receivables	Liabilities	Receivables	Liabilities
Operational subsidiaries in the following countries:
Norway	43	11	29	13
Sweden	17	2	16	2
Denmark	3	2	4	3
Finland	1	1	2	2
Grameenphone – Bangladesh	107	10	123	10
Pakistan	—	—	134	—
Holding companies and other entities	315	51	41	208
Total	486	77	349	238

2025

274

Financial income and expenses Group companies


	2025		2024
NOK in millions	Financial income	Financial expense	Financial income	Financial expense
Operational subsidiaries in the following countries:
Norway	312	30	331	95
Sweden	99	7	117	36
Denmark	—	25	4	44
Finland	175	63	106	73
Holding companies and other entities	667	561	1,140	1,059
Total	1,253	686	1,698	1,307

Financial receivables and payables Group companies


	2025		2024
NOK in millions	Receivables	Liabilities	Receivables	Liabilities
Operational subsidiaries in the following countries:
Norway	4,541	—	3,508	—
Sweden	3,594	—	2,460	—
Denmark	—	16	—	16
Finland	3,871	—	1,400	—
Holding companies and other entities	18,990	6,671	26,103	6,540
Drawings and deposits cash pool by subsidiaries	521	14,817	1,790	12,139
Total	31,517	21,504	35,261	18,695

Note 16

Guarantees


NOK in millions	2025	2024
Guarantee liabilities	1,068	615

Guarantee liabilities contain the unrecognised guarantee liabilities issued by Telenor ASA. The guarantee

liabilities mainly consist of guarantees issued by Telenor ASA on behalf of subsidiaries.

Purchased bank guarantees are not included in the table.

2025

275

Statements and audit

reports

Connecting customers to what matters most has been the core of

our business for 168 years. Our ambition is to deliver critical

connectivity and services to customers and societies, continue to

strengthen our responsible business agenda and utilise the

2025

276

Responsibility statement by the Board and CEO

Board of Directors report (page 3 to 162 )

We confirm that, to the best of our knowledge,

the Board of Directors report have been prepared

in accordance with the Norwegian Accounting

Act and that it gives a true and fair view of the

development, performance and financial position

of the Company and the Group including a

description of the principal risks and uncertainties

that they face.

Sustainability statements (page 71 to 157)

We confirm that, to the best of our knowledge,

the sustainability statements are prepared in

compliance with the Norwegian Accounting Act

chapter 2-3 including compliance with European

Sustainability Reporting Standards (ESRS) and

Article 8 of EU Regulation 2020/852 (the EU

Taxonomy Regulation). In our opinion, the

Sustainability Statements give a true and fair view

of the group's sustainability performance in

accordance with the stated reporting

requirements.

Financial statements (page 163 to 274)

We confirm that, to the best of our knowledge,

the consolidated financial statements for the year

ended 31 December 2025 have been prepared in

accordance with IFRS® Accounting Standards as

adopted by the EU and the additional

requirements of the Norwegian Accounting Act,

and that the financial statements for the parent

company for the year ended 31 December 2025

have been prepared in accordance with simplified

IFRS® Accounting Standards pursuant to the

Norwegian Accounting Act §3-9 and the

regulations regarding simplified application of

IFRS Accounting Standards issued by the Ministry

of Finance on 7 February 2022.

Further, we confirm that, to the best of our

knowledge, the financial statements give a true

and fair view of the Company’s and Group’s

assets, liabilities, financial position and results of

operations. We confirm that the prerequisites for

the going concern assumption exist and that the

financial statements have been prepared based

on a going concern basis.

ESEF regulation

We confirm that, to the best of our knowledge,

the annual report of Telenor ASA for the financial

year 1 January – 31 December 2025 with the file

name: tel-2025-12-31-0-en.zip have been prepared

in compliance with the ESEF Regulation.

[This translation from Norwegian has been prepared for information purposes only.]

The Board of Directors and the President and CEO

have today approved the annual report of Telenor

ASA for 2025.

Fornebu, 25 March 2026

Jens Petter Olsen

Chair of the Board

Gyrid Skalleberg Ingerø

Deputy Chair of the Board

Ottar Ertzeid

Board member

Pieter Knook

Board member

Grethe Bergly

Board member

Marianne Dahl

Board member

Mats Granryd

Board member

Roger Rønning

Employee representative

Sune Jakobsson

Employee representative

Irene Vold

Employee representative

Benedicte Schilbred Fasmer

President and CEO

Statement from the

Corporate Assembly

On 25 March 2026, the Corporate

Assembly of Telenor ASA passed the

following resolution:

The Corporate Assembly recommends

that the Annual General Meeting approves

the Board’s proposal for Financial

Statements for Telenor Group and Telenor

ASA for 2025 as presented to the

Corporate Assembly, by transfer of NOK

11,638 million to retained earnings and a

dividend payment of NOK 9.70 per share

to be paid out in two instalments of NOK

5.00 per share and NOK 4.70 per share in

June and October 2026, respectively.

2025

277

Limited

assurance

report on

sustainability

statements

2025

278

2025

279

2025

280

2025

281

Audit

report on

financial

statements

2025

282

2025

283

2025

284

2025

285

2025

286

2025

287

Alternative

performance

measures (APMs)

The financial reporting of Telenor includes alternative

performance measures (APMs) in addition to the consolidated

financial statements prepare according to IFRS® Accounting

Standards. The APMs are used to enhance the understanding of

Telenor’s performance. Some measures are necessary to

understand the underlying results and enable useful

comparison of results over time. Other measures provide

insight into return of investments, capital intensity or ability to

service debt.

Connecting customers to what matters most has been the core of

our business for 168 years. Our ambition is to deliver critical

connectivity and services to customers and societies, continue to

strengthen our responsible business agenda and utilise the

2025

288

Performance and organic growth measures

Organic revenue growth

Organic revenue growth is defined as revenue growth adjusted for significant effects of acquisitions and

disposals of operations, and currency effects. The measure provides useful and necessary information to

investors and other stakeholders for the following reasons:

• it provides additional information on underlying growth of the business without the effect of certain

factors unrelated to its operating performance;

• it is used for internal performance analysis; and

• it facilitates comparability of underlying growth with other companies (although the term “organic” is

not a defined term under IFRS and it may not be comparable with similar measures reported by other

companies.

Organic revenue growth 2025


NOK in million	2025	2024	Change whole year	Change YoY
Total revenues	76,548	75,487	1,060	1.4%
Impact using exchange rates for 2025		(600)	600
M&A			—
Organic revenue	76,548	74,887	1,661	2.2%

Organic revenue growth 2024


NOK in million	2024	2023	Change whole year	Change YoY
Total revenues	75,487	76,400	(913)	(1.2)%
Impact using exchange rates for 2024		(31)	31
M&A		(964)	964
Organic Revenue	75,487	75,406	81	0.1%

2025

289

Service revenues and organic service revenue growth

Service revenues consist of mobile and fixed subscription and traffic in addition to other value-added

services (not included in subscription and traffic revenues) such as Internet of Things (IoT), maritime

communication, AI Factory and other end-user related services in mobile and fixed operations.

Subscription and traffic revenues consist of revenues from mobile subscription and traffic, fixed

telephony, fixed internet/TV and fixed data services.

Organic service revenue growth is defined as service revenue growth adjusted for significant effects of

acquisitions and disposals of operations, and currency effects. The measure provides useful and

necessary information to investors and other stakeholders for the following reasons:

• it refers to the core revenue streams of the business making up more than 75% of total revenues and

almost the entire gross profit for the Group;

• it provides additional information on underlying growth of the business within these core revenue

streams, without the effect of certain factors unrelated to its operating performance;

• it is used for internal performance analysis; and

• it facilitates comparability of underlying growth with other companies (although the term “organic” is

not defined under Accounting Standards and may not, therefore, be comparable with similarly titled

measures reported by other companies).

Organic service revenue growth 2025


NOK in million	2025	2024	Change whole year	Change YoY
Service revenues	61,194	60,707	487	0.8%
Impact using exchange rates for 2025		(742)	742
M&A			—
Organic service revenues	61,194	59,965	1,229	2.0%

Organic service revenue growth 2024


NOK in million	2024	2023	Change whole year	Change YoY
Service revenues	60,707	59,062	1,645	2.8%
Impact using exchange rates for 2024		(109)	109
M&A		—	—
Organic service revenues	60,707	58,953	1,754	3.0%

Reconciliation of service revenues and total revenues


NOK in million	2025	2024
Total revenues	76,548	75,487
Less: Mobile phones and other devices	(6,810)	(6,724)
Less: Lease revenues	(1,390)	(1,292)
Revenues from rendering of services	68,347	67,471
Less: Revenue from other operators	(5,497)	(5,214)
Less: Other revenues	(1,656)	(1,550)
Service Revenues	61,194	60,707

2025

290

Gross profit and organic growth in gross profit

Gross profit is a key financial parameter for Telenor and is the difference between total revenue and

costs of materials and traffic charges. Gross profit reflects the profitability contribution of Telenor’s

revenue growth in its markets and therefore describes Telenor’s potential for sustainable value creation.

This makes the gross profit a key financial parameter to monitor, and it is also used for internal

performance analysis. Organic growth in gross profit is defined as growth in gross profit when adjusted

for significant effects of acquisitions and disposals of operations, and currency effects.

Growth in organic gross profit 2025


NOK in million	2025	2024	Change whole year	Change YoY
Total revenues	76,548	75,487	1,060	1.4%
Cost of materials and traffic charges	(17,244)	(17,313)	69	(0.4)%
Gross profit	59,304	58,175	1,130	1.9%
Impact using exchange rates for 2025		(845)	845
M&A		—	—
Organic gross profit	59,304	57,330	1,974	3.4%

Growth in organic gross profit 2024


NOK in million	2024	2023	Change whole year	Change YoY
Total revenues	75,487	76,400	(913)	(1.2)%
Cost of materials and traffic charges	(17,313)	(18,637)	1,325	(7.1)%
Gross profit	58,175	57,763	411	0.7%
Impact using exchange rates for 2024		(120)	120
M&A		(909)	909
Organic gross profit	58,175	56,734	1,441	2.5%

Operating expenses (opex) and organic growth in operating expenses

Operating expenses (opex) is a key financial parameter for Telenor and consists of salaries and personnel

cost and other operating expenses. Telenor’s continuous effort to improve efficiency makes opex a key

financial parameter to follow. It is also used for internal performance analysis. Organic growth in

operating expenses is defined as growth in operating expenses when adjusted for significant effects of

acquisitions and disposals of operations, and currency effects.

Growth in organic operational expenses 2025


NOK in million	2025	2024	Change whole year	Change YoY
Salaries and personnel costs	9,814	9,741	73	0.7%
Other operating expenses	15,028	15,261	(233)	(1.5)%
Operational expenses	24,842	25,002	(160)	(0.6)%
Impact using exchange rates for 2025	—	(242)	242
M&A	—	—	—
Organic operational expenses	24,842	24,760	82	0.3%

Growth in organic operational expenses 2024


NOK in million	2024	2023	Change whole year	Change YoY
Salaries and personnel costs	9,741	9,771	(29)	(0.3)%
Other operating expenses	15,261	15,099	162	1.1%
Operational expenses	25,002	24,869	133	0.5%
Impact using exchange rates for 2024	—	(6)	6
M&A		(245)	245
Organic operational expenses	25,002	24,618	383	1.6%

2025

291

Adjusted EBITDA and EBITDA margin

Earnings before interest, tax, depreciation, and amortisation (EBITDA) is a key financial parameter for

Telenor. Adjusted EBITDA is measured as EBITDA before other income and other expenses. Other

income and other expenses include items such as gains and losses on disposals of fixed assets and

operations, workforce reductions, onerous contracts, and one-time pension costs. Refer to note 8 for

more information about other income and other expenses.

Adjusted EBITDA margin is defined as adjusted EBITDA divided by total revenues. These measures are

useful to investors and other stakeholders in evaluating operating profitability on a more variable cost

basis as they exclude depreciation and amortisation expenses related primarily to capital expenses and

acquisitions that occurred in the past and non-recurring items. Adjusted EBITDA margin is used to

evaluate operating performance in relation to Telenor’s competitors. Adjusted EBITDA margin enables

comparison between segments and other operators.

Reconciliation between EBITDA and adjusted EBITDA


NOK in million	2025	2024
EBITDA	34,292	33,863
Other income	(744)	(1,479)
Other expenses	913	788
Adjusted EBITDA	34,462	33,173

Adjusted EBITDA margin


NOK in million	2025	2024
Total revenues	76,548	75,487
Adjusted EBITDA	34,462	33,173
Adjusted EBITDA margin	45.0%	43.9%

Organic growth in adjusted EBITDA

Organic growth in adjusted EBITDA is defined as growth in adjusted EBITDA, excluding significant effects

of acquisitions and disposals of operations, and currency effects. The measure provides useful and

necessary information to investors, and other stakeholders for the following reasons:

• it provides additional information on underlying growth of the business without the effect of certain

factors unrelated to its operating performance; and

• it is used for internal performance analysis.

Organic adjusted EBITDA growth in 2025


NOK in million	2025	2024	Change whole year	Change YoY
Adjusted EBITDA	34,462	33,173	1,289	3.9%
Impact using exchange rates for 2025		(603)	603
M&A		—	—
Organic adjusted EBITDA	34,462	32,570	1,892	5.8%

Organic adjusted EBITDA growth in 2024


NOK in million	2024	2023	Change whole year	Change YoY
Adjusted EBITDA	33,173	32,894	279	0.8%
Impact using exchange rates for 2024		(114)	114
M&A		(664)	664
Organic adjusted EBITDA	33,173	32,115	1,057	3.3%

2025

292

Investments (capex), borrowings and free cash flow

Capital expenditures

Capital expenditures (capex) consist of investments in property, plant, and equipment (PPE), intangible

assets and right-of-use-assets, including licences and spectrum. Capex excludes business combinations

and asset retirement obligations, as well as discontinued operations. Capex is a measure of investments

made in the operations in the relevant period and is useful to investors and other stakeholders in

evaluating the capital intensity of the operations. Capex excl. lease and capex/revenues is deemed to

better gauge the actual capital expenditures incurred in the period than the payment for purchases of

PPE, intangible assets and right-of-use assets in the cash flow statement.

Capex excl. lease is relevant to users to measure the level of underlying investments. Historically, leases

have varied significantly between reporting periods.

Calculation of capex to revenues


NOK in million	2025	2024
Purchases of property, plant and equipment and intangible assets	11,338	12,929
Prepayment of right-of-use assets including initial direct cost	590	454
Capex related working capital and other changes	(267)	(9)
Deferred lease obligations including licences	4,369	4,821
Less:
Discontinued operations	(1,256)	(483)
Total Capex incl. leases	14,773	17,714
License and spectrum acquisition	(441)	(75)
Other leases	(3,797)	(5,111)
Capex excl. lease	10,535	12,528
Total revenues	76,548	75,487
Capex excl. lease/Revenues (%)	13.8%	16.6%
Total Capex/Revenues (%)	19.3%	23.5%

Investments

Investments consist of capex and investments in businesses. Investments in businesses comprise

purchase of shares in both controlled and non-controlled entities from a third party, including

acquisitions of businesses not organised as separate companies as well as capital injections into non-

controlled entities. Investments (or total investments) is deemed to better gauge the actual investments

for the period than in the purchases of property, plant and equipment (PPE) and intangible assets line

items in the cash flow statement.

Reconciliation


NOK in million	2025	2024
Capital expenditures	14,773	17,714
Investments in businesses	2,569	2,344
Investments	17,342	20,057

2025

293

Net interest-bearing debt excluding licence obligations (net debt)

Net debt consists of both current and non-current interest-bearing liabilities, current and non-current

lease liabilities less related current and non-current hedging instruments, financial instruments, such as

debt instruments and derivatives, and cash and cash equivalents. Net debt is adjusted for license

obligations.

Net debt is a measure of the Group’s net indebtedness that provides an indicator of the overall balance

sheet strength. It is also a single measure that can be used to assess both the Group’s cash position and

its indebtedness. The use of the term ‘net debt’ does not necessarily mean that the cash included in the

net debt calculation is available to settle the liabilities included in this measure.

Net debt is considered to be an alternative performance measure as it is not defined in Accounting

Standards. The most directly comparable Accounting Standards measure is the aggregate interest-

bearing liabilities (both current and non-current) and cash and cash equivalents. A reconciliation from

these to net debt is provided below.

Net debt excluding licence obligations


NOK in million	2025	2024
Non-current interest-bearing liabilities	74,187	72,730
Non-current lease liabilities	11,399	13,697
Current interest-bearing liabilities	12,607	11,350
Current lease liabilities	3,660	3,844
Less:
Cash and cash equivalents	(16,335)	(10,380)
Hedging instruments	—	(36)
Financial instruments	(358)	(319)
Adjustments:
Non-current licence obligations	(2,676)	(3,339)
Current licence obligations	(752)	(760)
Net interest-bearing debt excluding licence obligations	81,731	86,788

Leverage

Telenor measures leverage as the ratio of net debt to adjusted EBITDA and dividends from associates

and joint ventures. The leverage definition is aligned with our alternative performance measure organic

adjusted EBITDA growth for controlled entities, and cash flow contribution from associates and joint

ventures. Further, the usage of adjusted EBITDA for controlled entities prevents temporary spikes in

leverage due to other income and expenses and thus ensures transparency and a better understanding

of Telenor’s ability to cover debt with profits from its regular operations. While the numerator (net debt)

is measured at the end of the period, the denominator (adjusted EBITDA and dividend from associates

and joint ventures) is measured over the last 12 months period.

Telenor aims to maintain a solid balance sheet through keeping leverage ratio in the target range of 1.8x

to 2.3x, in order to maintain financial flexibility and ensure cost efficient funding. If reported leverage is

outside this range, we will take measures to return to the range. The measure provides useful

information about the strength of our financial position and is regularly reported internally.

Leverage ratio


NOK in million	2025	2024
A - Net debt	81,731	86,788
B - Adjusted EBITDA	34,462	34,980
C - Dividends from associates and joint ventures	2,547	1,425
D - Leverage ratio D=A/(B+C)	2.21	2.38

12 months adjusted EBITDA for the period 31 December 2024 includes adjusted EBITDA contribution of

NOK 1,807 million from Telenor Pakistan.

2025

294

Free cash flow

Telenor makes use of free cash flow and free cash flow before M&A activities as important performance

measures when presenting and discussing the reported results. Telenor believes it is both useful and

necessary to communicate free cash flow and free cash flow before M&A activities for the following

reasons:

• Free cash flow and Free cash flow before M&A activities allow management and investors to evaluate

Telenor’s liquidity and cash generated by the operations.

• Free cash flow excludes items that are deemed discretionary, such as financing activities. In addition,

Free cash flow before M&A activities excludes cash flows relating to acquisitions and disposals of

businesses.

• Free cash flow facilitates comparability with other companies, although Telenor’s measure of Free cash

flow may not be directly comparable to similar titled measures used by other companies.

• These measures are used for planning, reporting and incentive purposes.

Free cash flow before M&A - segment reporting

Free cash flow before M&A in the segments (see note 2) deviates from the group definition on the

following:

• Internal interest paid and received are excluded, including interest on lease liabilities.

• Payments of internal transfers of non-current assets are excluded.

• Placements of excess liquidity into financial instruments with duration of 3-12 months are excluded.

Reconciliation

A reconciliation of net cash flow from operating activities, net cash flow from investing activities and

certain line items of financing activities to free cash flow and free cash flow before M&A activities is

provided in the table below.

Payments for acquisitions and proceeds from disposal of businesses (M&A) include:

• Acquisitions and disposals where Telenor acquire or lose control and the cash effects are classified in

investing activities.

• Acquisitions including capital injections and disposal of investments in associates and joint ventures

that are classified in investing activities.

• Transactions with non-controlling interests that does not result in change of control for Telenor that

are classified in financing activities.

• Proceeds from borrowings in the disposed business that are classified in financing activities but are

connected to sale transaction and the related debt is deconsolidated together with business disposed.


NOK in million	2025	2024
Net cash flows from operating activities	31,222	31,481
Net cash flows from investing activities	(9,838)	(11,486)
Payments of lease liabilities related to spectrum licences	(687)	(1,216)
Payments of lease liabilities related to other lease contracts	(4,037)	(3,652)
Dividends paid to and purchase of shares from non-controlling interest	(1,732)	(1,871)
Proceeds from borrowings by Telenor Pakistan as part of sale transaction	2,335	—
Free cash flow	17,262	13,255
M&A activities	4,393	1,889
Free cash flow before M&A activities	12,869	11,366

2025

295

M&A activities reconciliation to cash flow statement


NOK in million		2025	2024
Classification in cash flow statement	M&A transaction
Purchases of businesses, net of cash acquired	True Corporation	(493)	(34)
	Investments in other associates	(310)	(190)
	Other acquisitions	9	(25)
Proceeds from disposal of businesses, net of cash disposed	Pakistan	2,432	—
	Satellite	—	2,122
	Allente	640	—
	Canal Digital	(197)	—
	Otrum	84	—
	Other disposals	(10)	16
Income tax withheld from proceeds relating to disposal of businesses	Pakistan	(179)	—
Proceeds from sale and purchase of other investments	Other disposals	82	—
Proceeds from and repayments of borrowings	Pakistan ¹⁾	2,335	—
Total		4,393	1,889

¹⁾ The group received NOK 2,335 million in Telenor Pakistan just before the disposal from the buyer in

shareholder loan for settling Telenor Pakistan's internal debt towards Telenor ASA. Telenor Pakistan was

disposed together with debt towards its new shareholders.

2025

296

Return On Capital Employed (ROCE)

Return on capital employed is a metric which is used to evaluate profitability and development of

profitability in Telenor's existing business. The measure is calculated by dividing the earnings of last

twelve months by the average balance of capital employed for the same twelve-month period. Earnings

are defined as operating profit including share of profits from associates and joint ventures, less income

taxes. Acquisitions and disposal effects that do not exhibit 12 months returns in actual figures are

excluded from the calculation for the respective period.

Capital employed is defined as the sum of total equity and net interest-bearing debt including licence

obligations and net pension obligations. The average of capital employed during the period is calculated

as average of opening and closing balance for the given twelve-month period. The calculated return on

capital employed is based on the actual generated return, and hence it may be impacted by unusual

returns or losses at a particular point of time.

Return on capital employed is provided both including and excluding associates and joint ventures. ROCE

excluding non-controlled entities provides additional information on Telenor’s operational efficiency and

profitability, as it isolates returns generated from capital employed in areas where Telenor exercises

control. As such, this metric is also more aligned with internal capital allocation and performance follow-

up.

Reconciliation


NOK in million	2025	2024
Operating profit	17,978	17,912
Share of net income (loss) including gains/losses from associates and joint ventures	1,823	6,812
Income taxes	(4,364)	(3,719)
A - Earnings	15,437	21,006


Total equity as of beginning of the period	81,772	70,434
Net interest bearing debt including licence obligations as of beginning of the period	90,886	84,956
Net pension obligations as of beginning of the period	2,068	1,821
B - Total capital employed as of beginning of the period	174,727	157,212

Total equity as of end of the period	75,629	81,772
Net interest-bearing debt including licence obligations as of end of the period	85,160	90,886
Net pension obligations as of end of the period	1,966	2,068
C - Total capital employed as of end of the period	162,754	174,727

D - Average capital employed before adjustments (D=(B+C)/2)	168,740	165,969

E - Adjustment for Telenor Pakistan	2,554	4,980
F - Average capital employed	166,186	160,990
G - Return on capital employed (G=A/F)	9.3%	13.0%

Share of net income (loss) including gains/losses from associates and joint ventures	1,823	6,812
H - Earnings (A) excluding associates and joint ventures	13,614	14,194

Carrying amount of associates and joint ventures as of beginning of period	66,793	50,942
Carrying amount of associates and joint ventures as of end of period	66,514	66,793
Average capital employed of associates and joint ventures	66,653	58,867
I - Average capital employed (F) excluding associates and joint ventures	99,532	102,122
J - Return on capital employed (G) excluding associates and joint ventures (J=H/I)	13.7%	13.9%

2025

297

Adjusted net income and adjusted EPS

Adjusted net income is defined as net income (attributable to equity holders of Telenor ASA) adjusted for

items affecting comparability between periods. These line items in the income statement are listed in the

reconciliation table to the right and is the complete list of line items adjusted for including relevant effect

on income tax and non-controlling interests.

Adjusted earnings per share (adjusted EPS) is calculated as adjusted net income attributable to equity

holders of Telenor ASA, divided by average number of shares outstanding. The definition does not adjust

for write-downs, gains/losses or other above-mentioned items affecting comparability within associated

companies.

We believe adjusted net income and adjusted EPS provide useful and necessary information to investors,

and other stakeholders for the following reasons:

• they provide additional information on the underlying earnings performance of the business without

the effect of factors of non-recurring nature; and

• they increase the transparency and increases the usefulness of tracking the development the group’s

operational and financial performance over time in a single measure.

Reconciliation


NOK in million	2025	2024
Net income attributable to equity holders of Telenor ASA	7,034	18,336
Adjustments:
Other income	(744)	(1,479)
Other expenses	913	788
Impairment losses	2	73
Impairments and gain (loss) on disposal of associates and joint ventures	(205)	(6,606)
Net currency gains (losses)	(347)	533
Net change in fair value of financial instruments	477	(2,491)
Net gains (losses and impairment) of financial assets and liabilities	—	(27)
Gain/loss on disposal in discontinued operations	4,297	260
Income tax effect of above items	(91)	(195)
Non-controlling interest share of above items	(27)	(33)
Total adjustments	4,276	(9,177)
Adjusted net income attributable to equity holders of Telenor ASA	11,310	9,159
Average numbers of shares outstanding ¹⁾	1,368	1,376
Earnings per share ²⁾	5.14	13.32
Adjusted earnings per share ²⁾	8.27	6.65

¹⁾ in million

²⁾ in NOK

2025

298

Definitions

Subscriptions

Mobile subscriptions include contract (postpaid) and prepaid subscriptions to Telenor customers.

Wholesale subscriptions and SIM cards used for IoT applications and twin/multi-SIM cards are not

included.

Fixed broadband, TV and telephony subscriptions include access over fibre, hybrid fibre cable, copper

(xDSL), and fixed wireless access.

Average revenue per user (ARPU)

Mobile ARPU is calculated based on revenues from subscription fees, outgoing traffic and value-added

services from own subscriptions, and interconnect revenues, divided by the average number of

subscriptions for the relevant period.

For fixed operations, ARPU is calculated based on revenues from own subscriptions, divided by the

average number of subscriptions for the relevant period.

Organic change

Organic change in a financial metric, typically when compared to the same period last year, is calculated

by adjusting for significant effects of acquisitions and disposals of operations (M&A) and currency

effects. The term is mainly used for describing the year-on-year development in service revenues and

adjusted EBITDA.

Scope 1, 2 and 3 greenhouse gas (GHG) emissions

Scope 1 emissions are the emissions Telenor makes directly, mainly from diesel generators. Scope 2

emissions are indirect emissions from purchased energy. Scope 3 cover all other indirect emissions both

up and down the value chain and covers areas such as purchased goods and services, capital goods,

employee commuting, use of sold products and investments. Telenor follows the corporate standard

from GHG Protocol for calculating the GHG emissions.

Take-back rate for mobile devices

The take-back rate for mobile devices is defined as the number of used mobile devices collected through

operator take-back schemes, divided by the number of new mobile devices distributed to customers.

Number of people trained in digital skills

Measures the number of people receiving meaningful training within digital skills, inclusion and safety &

security. Every person counted must complete a training session (virtual, in-person, hybrid and/or self-

paced).

Mobile internet users

Measures the share of active mobile data users out of Telenor’s mobile subscription base. Users with at

least 150kb of data during the last three months are defined as active data users.


3	Introduction	38	Corporate governance	71	Sustainability
14	Strategy, performance and risks	64	Shareholder information	163	Financial statements