Sustainability Report 2017 CONTENT

STATEMENT FROM THE CEO 4

WHERE WE OPERATE 5

SUMMARY OF THE YEAR 6

SUSTAINABILITY AT TELENOR 7 Responsible Business Conduct 7 Strategic Focus on Reducing Inequalities 7 About the Report 8

RESPONSIBLE BUSINESS AT TELENOR 9 Corporate Governance 9 Reporting and Stakeholder Engagement 9 Ethics and Anti-Corruption 10 Labour Rights and Standards 13 Supply Chain Sustainability 14 Human Rights 17 Privacy 18 Cyber Security 19 Environment and Climate Change 21 Child Online Safety 23 Digital Access and Outreach 25 Innovating and Researching for Shared Value 26 Mobile Phones & Health 28 Service Reliability 29

HOW TELENOR IMPACT SOCIETIES 30 UN Sustainable Development Goals 30 Tax policy 30 Economic Contribution to Society 32

SUSTAINABILITY ANALYTICS / NON-FINANCIAL DATA 34

ASSURANCE STATEMENT 35 4 TELENOR SUSTAINABILITY REPORT 2017 STATEMENT FROM THE CEO

STATEMENT FROM THE CEO

CONNECTING YOU TO WHAT MATTERS MOST. EMPOWERING SOCIETIES.

Connecting people, business and societies have been the core of our business for more than 160 years. We’re making sure that our customers are connected to what matters most in their everyday lives. To us, it’s more than good business. It’s empowering societies.

Sustainability at Telenor is about how we do business. We are committed to all UN Sustainable Development Goals but with specific focus on goal #10 Reduced Inequalities. We want to help unlock the benefits of the digital revolution and demonstrate how more can be achieved with connectivity. We work to raise standards and delivering wider access to our services.

Our people and our culture are instrumental in safeguarding the responsible and sustainable business that Telenor is committed to – both internally Connecting people, business and in our supply chain. We fully support and societies have been the the UN Global Compact Principles, and core of our business for more together with our customers and partners than 160 years. Today, we do we are well positioned to help deliver on so with more relevance and the UN Sustainable Development Goals. personalisation than ever.

– Sigve Brekke, CEO 5 TELENOR SUSTAINABILITY REPORT 2017 WHERE WE OPERATE

WHERE WE OPERATE

Scandinavia CEE* Asia Norway Hungary Pakistan Sweden Serbia Bangladesh Denmark Montenegro Thailand Bulgaria Malaysia Myanmar

Telenor ASA is listed on the Oslo Stock Exchange

* On 21 March 2018, Telenor announced it has entered into an agreement to sell its assets in Central and Eastern Europe (CEE) to PPF Group. The transaction includes Telenor’s wholly-owned mobile operations in Hungary, Bulgaria, Montenegro and Serbia and the technology service provider Telenor Common Operation. The transaction requires necessary regulatory approval and is expected to be completed within Q3 2018. 6 TELENOR SUSTAINABILITY REPORT 2017 SUMMARY OF THE YEAR

SUMMARY OF THE YEAR

HIGHLIGHTS 2017

Sustainability at Telenor is about how we do business. We are committed to all UN Sustainable Development Goals but with specific focus on goal #10 Environment and Climate Change Diverse Workforce Reduced Inequalities. This is where we can deliver the most Telenor’s total energy consumption was Telenor Group employed close to impact. approximately 3100 GWh – on the same level 31 000 people (excluding India) of which as for 2016 when comparing without India and 36 per cent are women. the associated emissions of greenhouse gases

was estimated to 1.1 million tonnes CO2.

Child Online Safety Mobile Birth Registration Supply Chain Sustainability

Since, 2014 Grameenphone has In Pakistan, Telenor and UNICEF Telenor carried out 5,000 supplier educated 140,000 children on child are collaborating with government inspections resulting in 560 major non- online safety, reaching 600 schools and authorities and more than 4,200 conformities. In addition, the business units directly engaged with 35,000 parents, designated government facilitators carried out more than 23,000 man-hours of teachers and guardians. have been trained and equipped to capacity-building among our suppliers. report births via Telenor’s mobile-based solution

Privacy Digital Access and Outreach Ethics and Compliance

Telenor has further strengthened Telenor Myanmar’s digital literacy centres, In 2017, Telenor logged 911 incoming its privacy function in terms of both the Lighthouses, are multi-purpose online compliance reports – where one third competence and capacity and all privacy hubs for local communities in Myanmar, and of these compliance incidents were resources have undergone extensive since November 2015, close to 100,000 substantiated. training. students have received online safety training. 7 TELENOR SUSTAINABILITY REPORT 2017 SUSTAINABILITY AT TELENOR

SUSTAINABILITY AT TELENOR

Responsible Business Conduct Telenor has developed high standards in implementing a global security Telenor exists to connect our customers the areas of anti-corruption, labour programme and establishing global to what matters most – we empower rights, human rights and the environment capabilities and common standards were societies. This is our purpose. Delivering as defined in international conventions prioritised. Experts have been recruited in internet access and connectivity is the and best practices. These standards will global roles as part of a critical capability foundation of what we do. It enables our be further developed and strengthened. programme, and local security officers customers to connect their digital lives. This also applies to the standards within are in place in all business units. Telenor We seek to personalise this experience supply chain sustainability, anti-trust and has a strong commitment to security, and based on their needs and preferences. Telenor’s role in contributing to society, this is at the foundation of everything the e.g. financial services for financial company does. At Telenor we are convinced that more inclusion or registration of child-births equality in the world is good for our through a mobile device. Gaining the customers’ trust is important business and for the people we serve. We to Telenor. Personal data is handled with remain committed to raising standards Telenor is contributing directly and care and customer data is used to create across our operations and to driving for indirectly to many of the UN Sustainable value for the customer. In 2017, in greater access and increased Development Goals and acknowledge the addition to preparing for implementation opportunities by empowering societies role of the private sector in delivering on of the new EU GDPR regulation, Telenor wherever we are. these goals. In 2017, Telenor chose to strengthened competencies and specifically focus its efforts on The recruited for new internal privacy Some of the markets in which Telenor United Nation’s global Sustainable capabilities. operates are emerging economies with Development Goal number 10: Reduced potentially complex and sensitive Inequalities. Telenor has set out targets Strategic Focus on Reducing political and social contexts, and the through to 2020 to contribute towards Inequalities associated risks related to corruption and this goal by continuing supply chain Responsible business and sustainability is human rights especially will continue to capacity-building, training children in an integral part of Telenor’s business fare high on the wider telecommunication online safety and utilising mobile strategy. It is about how we do business. industry agenda. technology for birth registration. Telenor We are committed to all UN Sustainable aims to reduce inequalities 1) by Development Goals but with specific Responsible Business Conduct is about improving access to services through focus on goal #10 Reduced Inequalities. mitigating Telenor’s most critical business leveraging digital services and Our purpose is to empower societies. The environment risks, seizing the connectivity in innovative ways to way we run our company is based on opportunity to generate positive long- address social and economic challenges, clear standards on everything from term value and meeting stakeholder and 2) by raising standards in privacy to anti-corruption, energy expectations. Strengthening awareness, employment and supply chain efficiency to human rights. We are accountability and transparency are key sustainability across the supply chain. working to continuously improve to securing our licence to operate and everything we do, and working with our ensure ethical and responsible business Cyber security is a global risk affecting suppliers to do the same. practices. the telecommunications industry, but is also a potential differentiator. In 2017, We want to help unlock the benefits of 8 TELENOR SUSTAINABILITY REPORT 2017 SUSTAINABILITY AT TELENOR

the digital revolution and demonstrate stimulate growth and create shared how more can be achieved with value, both for the business and society. connectivity. We have made access to At Telenor we work in partnership with financial services more available and local authorities and local organisations affordable. Our internet services have and through a global partnership with opened up possibilities to interact, learn, UNICEF. The skills, networks and participate and grow both socially and resources of our partners are essential to economically. More women are using achieve the outcomes we seek. these services than ever before. Farmers are better informed on how to increase About the Report their output. Telenor publishes this separate Sustainability Report in accordance with We work to raise standards and delivering reporting requirements mandated by the wider access to our services. This is why Norwegian Accounting Act §3-3c, which we have initiatives in all markets designed requires large enterprises to account for to grow children’s online resilience. Our what the company is doing to integrate efforts to register the births of thousands respect for human rights, labour rights of invisible children are ongoing in and social issues, the environment and Pakistan and will soon commence in anti-corruption into their business other Asian markets. And our supply strategies, daily operations and chain sustainability work as well as relationship with stakeholders. The report human rights due diligence efforts, shall at least contain information on continue to raise standards internally and policies, principles, procedures and downstream. standards the company uses to integrate the above considerations. As a responsible company however, we recognise that increased access does not In addition to these requirements of the always ensure more equal outcomes. Norwegian Accounting Act, Telenor’s not – in general – include performance Vigilance and proactive measures are Sustainability Report includes other data from our Indian operations, since sometimes needed to protect vulnerable material issues in line with stakeholder Telenor India has been treated as an groups or help them maximise the expectations as well as Oslo Stock asset held for sale and discontinued benefits of connectivity. Exchange’s guidance on the reporting of operations in Telenor’s financial reporting corporate responsibility. These material for 2017. Exceptions to this will be We have set targets for this work. To help issues in the report have been articulated significant incidents in India that will be vulnerable groups in our markets prepare through a materiality assessment based reported as part of our principles of for a digital future we will grow their on the Global Reporting Sustainability transparency. capacity, skills and resilience. By 2020, Standards’ principles, and embody issues we will facilitate access to identity for which are deemed to be most important On 21 March 2018, Telenor announced it seven million and educate and build the to both Telenor and its stakeholders. has entered into an agreement to sell its resilience of four million children on Details on Telenor’s materiality assets in Central and Eastern Europe online safety. assessment can be viewed at (CEE) to PPF Group. The transaction www.telenor.com/sustainability/ includes Telenor’s wholly-owned mobile Furthermore, we will raise standards for reporting/scope-and-principles. operations in Hungary, Bulgaria, our employees and our supply chain. We Montenegro and Serbia and the will build the capacity of our suppliers to DNV GL has been commissioned to carry technology service provider Telenor raise standards in their operations out an independent review of the Common Operation. The transaction through 100,000 hours of training. Sustainability Report, in particular to requires necessary regulatory approval assess the accuracy of claims. DNV GL’s and is expected to be completed within In all these efforts our partners will be independent review can be found at the Q3 2018. more important than ever. Partnerships end of this report. between governments, businesses and organisations are central in order to This sustainability report for 2017 does 9 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

RESPONSIBLE BUSINESS AT TELENOR

Corporate Governance addressing sustainability and the scope company drive continuous improvement Telenor Group’s corporate governance of compliance for the Committee. In its based on an active dialogue with principles and practices define a work, the Committee is guided by stakeholders. framework of rules and procedures for international conventions and the way business is governed and recommendations, the Telenor Code of Reporting controlled in all Telenor business units. Conduct, and policies and manuals Expectations with regard to sustainability Each business unit adopts the relevant relevant to the scope of the SCC. The reporting from major stakeholders governing documents. The governance Committee also supports the Board in continue to increase. Telenor firmly framework is used as a platform to fulfilling its responsibilities to specifically believes that reporting will contribute to integrate material sustainability issues address climate & environment, human open discussions and to building into its business strategies, daily rights, labour standards, and anti- knowledge on challenging issues. In order operations and relationship with corruption. to ensure structured, transparent and stakeholders. relevant reporting of sustainability More information on Telenor’s principles performance, Telenor Group reports to Telenor’s corporate values and ethical and practices for corporate governance various external organisations including standards represent an important can be read in Telenor’s Report on UN Global Compact, the international foundation for articulating and Corporate Governance in the Annual reporting standard GRI, and CDP implementing the governance framework. Report of 2017 and at www.telenor.com/ regarding climate change disclosure. Telenor works continuously to improve its about-us/corporate-governance. governance regime. In 2017, Telenor has Telenor uses the GRI Sustainability taken steps to simplify its governing Reporting and Stakeholder Reporting Standards-based materiality documents. All Group policies have been Engagement assessment process to involve a range of modified to ensure that they are risk Telenor believes good corporate external and internal stakeholders to help based and consist of clear and adequate governance involves openness, trustful identify social, economic and requirements that are measurable and disclosure and engagement between all environmental topics that matter most can be monitored. internal and external stakeholders. both to them and Telenor’s business. The scope of the current materiality Telenor’s commitment to integrity and Telenor’s commitment to integrity and assessment and engagement process transparency is clearly stated in Telenor’s transparency is clearly stated in Telenor’s can be found here: www.telenor.com/ Code of Conduct – which is owned and Code of Conduct. The Code of Conduct is sustainability/reporting/scope-and- approved by the Board, and must be owned and approved by the Board, and principles. signed by all employees. must be signed by all employees. In 2017, both Telenor Group and many of The Sustainability and Compliance The principles of transparency at Telenor Telenor’s business units reported locally Committee (the “Committee” or “SCC”) is are part of the corporate governance on their sustainability performance, a preparatory committee of the Board of framework and are implemented within which can be found at www.telenor.com/ Directors of Telenor ASA (the “Board”) company operations. Transparency and sustainability/reporting. that supports the Board in fulfilling the openness around sustainability-related Board’s responsibilities with respect to dilemmas and challenges will help the Telenor has continued its focus on human 10 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

rights transparency and reporting, In September 2017, Telenor Group’s including issuing an updated Authority General Counsel and Chief Corporate Request access report and reporting on Affairs Officer Wenche Agerup was alignment with the guiding principles from invited to the UN General Assembly in the Telecommunications Industry New York to discuss how the business Dialogue on Freedom of Expression and sector can commit to the Sustainable Privacy (ID). Development Goals (SDGs) and to present the reasons why Telenor has The new reports for 2017 are available chosen to focus on reducing inequalities here www.telenor.com/sustainability/ in society. In December 2017, Telenor gathered 24 responsible-business/privacy-and-data- exceptional young talents from an protection/handling-access-requests- The Rohingya situation in Myanmar was estimated 8000 applicants in 13 from-authorities. high on the international agenda in 2017. countries to the Telenor Youth Forum in Telenor viewed the developments in the Oslo. The participants worked in teams to For the fourth year in a row, the global Rakhine State in Myanmar with grave solve specific social challenges by climate reporting organisation CDP concern, and published a statement to designing digital solutions that can (formerly Carbon Disclosure Project) that effect in September 2017 which was reduce inequalities in society. rated Telenor Group in their ‘Leadership’ communicated to the Myanmar category as part of its climate ranking list authorities. See more information in the In 2018, Telenor will continue its for 2017. Telenor is still the best telecom chapter on Human Rights. stakeholder engagement within the company with headquarters in sustainability area: Scandinavia. The company follows developments closely and continues to focus on • Arrange meetings and broader Stakeholder engagement ensuring provision of services to all communication activities to engage As part of Telenor’s strategic focus on people in Myanmar. We will continue to with investors and relevant responsible business conduct, the seek to engage constructively and stakeholders in the company’s current company aims to develop its stakeholder encourage all parties to follow up on the sustainability challenges and relations as a long-term owner and recommendations in the Annan report. opportunities. business partner, true to its • Demonstrate how Telenor can commitments, values and the purpose of In October 2017, Telenor Group President empower societies through its empowering societies. The company will and CEO Sigve Brekke was invited to hold business and how we contribute to the purposefully apply business standards the Rafto Challenge lecture at NHH UN Sustainable Development Goal of that may be higher than what is decreed Norwegian School of Economics in Reduced Inequalities. by law in its respective markets. Bergen, presenting how Telenor Group works with human rights, how Telenor Ethics and Anti-Corruption Selected stakeholder engagement addresses challenges and how the Telenor has zero tolerance on corruption events within the sustainability area in company needs to stay vigilant and and Telenor’s ethical standards promote 2017: continuously improve. proper business practices and reflect relevant laws, regulations and In February 2017, Telenor in Myanmar In November 2017, top management in internationally recognised standards. held its 4th annual sustainability briefing Telenor Group and the business units in These standards are set out in our Code since 2014. At this session; the Telenor Thailand, Bangladesh and Malaysia were of Conduct (approved by the Board), Myanmar CEO Lars Erik Tellmann invited to local forums from the private Group Policy on Anti-Corruption expressed the company’s commitment to sector, government and NGOs to discuss (approved by the President and CEO), be open and transparent on its business, how to collaborate on the UN Sustainable Third Party Risk Policy (new) and other challenges, and how they face key Development Goals with a specific focus governing documents, that are sustainability issues such as responsible on challenges and opportunities for implemented in all Telenor’s subsidiaries business conduct in the supply chain, partnering to reducing inequalities in directly or indirectly controlled by Telenor energy innovation in a challenging society. These local top management ASA. market, ethics and compliance, cyber­ forums will continue in other Telenor crime and legal frameworks as well as markets in 2018. The Anti-Corruption Programme is part how to empower women in the workplace. of Telenor’s Governance model which 11 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

In accordance with a decision by the Telenor ASA Board of Directors in February 2017, Integrity Hotline management, fact finding and investigation of compliance cases have been moved from Group Compliance to Group Internal Audit & Investigation. Investigated cases are reported to the Risk and Audit Committee by the Head of Group Internal Audit and Investigation.

A description of Telenor’s Anti-Corruption Programme and the Ethics and Compliance function is publicly available on the web sites: www.telenor.com/ about-us/corporate-governance/ethics- compliance and www.telenor.com/ about-us/corporate-governance/anti- corruption.

Telenor Group’s Anti-Corruption Programme has been effective for years. Regular reviews, alignment with prevailing international guidelines and implementation of learning are essential The Code of Conduct must be signed by all employees upon joining the company. The Code for maintaining an effective Anti- of Conduct is signed annually along with mandatory e-learning. Corruption Programme. The programme is assessed and revised on a regular basis as part of the annual Group Governance clearly defines roles and responsibility for heads the group-wide Compliance Work Programme. implementation of the Anti-Corruption function and supports the President and Policy, both at Group and local business CEO and the Board in ensuring that the The Code of Conduct must be signed by unit level. A global anti-corruption Code of Conduct sets the appropriate all employees upon joining the company. community, consisting of business unit standards, and that these standards are The Code of Conduct is signed annually policy managers or experts appointed by implemented and enforced. Starting in along with mandatory e-learning. local policy owners, contributes to best 2018, the Chief Compliance Officer is also practice-sharing across the Group. responsible for the Anti-Corruption In Telenor, each employee has a personal Programme and the Third Party Risk responsibility to act with integrity and The Sustainability and Compliance Policy. speak up if they become aware of Committee of the Board supports the potential breaches. Leaders have a Board in fulfilling its responsibilities with The Group Chief Compliance Officer particular responsibility to act as good respect to ensuring that Telenor builds reports functionally and administratively role models and to build a safe, trustful and maintains an effective ethics and to the Group CEO & President and meets and transparent culture in their teams. compliance programme, maximises the regularly in (along with functional Managing breaches of the Code of inherent benefits of such a programme, reporting to) the Sustainability & Conduct and Governing Documents is an and consistently promotes a culture that Compliance Committee of the Board. important pillar of Telenor’s ethics and demands ethical business conduct and With effect from 1 January 2018, the compliance work. Employee confidence compliance with the Code of Conduct, our Local Head of Compliance in Telenor in reporting incidents is central to policies and procedures, and responsible business units will report to the Group ensuring an ethical corporate culture. business practices. Chief Compliance Officer and the local Board/Board Committee, as well as To encourage individuals such as The Group Chief Compliance Officer administratively to the local CEO. employees, suppliers and other 12 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

stakeholders to voice their concerns, Compliance Hotline & Incident HR. All incoming reports shall receive an Telenor has established a global external Management Benchmark Report answer from Group Investigations - either reporting hotline and website (Integrity (comparing annual analysis of all through the confidential and anonymous Hotline). Group Internal Audit & industries/customer data of NAVEX) has communication channel or via a preferred Investigation is conducting the a stable median level of global value over means of communication. The investigations and fact finding for the the past five years. In relation to compliance incidents were mainly in reported concerns. The new companies that also capture reports from Business Integrity, Theft & Embezzlement organisational model will increase all reporting channels (web, hotline, open and Working Environment. independence in the handling of cases. door, e-mails), the comparable median shows that Telenor is on a par with the About 60 per cent of the compliance The Integrity Hotline is a confidential industry. Increased use of incident incidents mentioned above were channel where anyone can ask questions management tools and a reduction in the substantiated. Of the substantiated and raise concerns about possible number of employees are reflected in this incidents, around 67 per cent resulted in breaches of Telenor’s Code of Conduct, year’s numbers. termination of employment or other including relevant laws, regulations and disciplinary sanction. In comparison, the governing documents. The report intake NAVEX Global 2017 Hotline Benchmark of the Integrity Hotline is operated by an report shows substantiation rates of external service provider, NAVEX Global, around 40 per cent over recent years. while investigations and case handling The reason for Telenor’s higher score may are dealt with by Group Investigations. reflect the fact that we get high quality The Integrity Hotline is also made reports, but it probably also indicates available to external parties. Reports that that the scope of cases for many are brought to Group Investigations via customers in the benchmarking study is e-mail or personal contact are logged in wider, including many HR cases which are the system. generally more difficult to substantiate. In 2017, Telenor logged The Integrity Hotline and case 911 incoming compliance As part of the transfer of responsibility for management system have enabled reports – where one third of fact finding and investigation from Group stronger global oversight for Telenor. these compliance incidents Compliance to the new unit Group Around 58 per cent of all incoming were substantiated. Internal Audit and Investigation (GIA&I), reports in 2017 came in through the Telenor is in the process of upgrading Integrity Hotline. systems and processes to ensure a robust handling of compliance cases. The reporting mechanism as well as a Out of all the incoming reports, 30 per Compliance will, when fact finding and strengthened focus on communication cent were submitted anonymously. As a investigation is concluded, handle the and training has contributed to an comparison, the NAVEX Global 2017 case as part of the updated resolution increase in the total number of concerns Hotline Benchmark report shows that the procedure which includes both over the last two years. median level has been stable at around disciplinary and corrective actions. 60 per cent anonymous reports since It is generally viewed as a sign of 2008. Integrity is a vital part of Telenor’s openness and trust that employees and business. Telenor’s management is other stakeholders speak up about their In 2017, Group Investigations logged 911 committed to sending clear, concerns. This allows the organisation to incoming reports, a small increase from unambiguous and regular messages to all address the issues, investigate and take 2016. Around 57 per cent of these staff and business partners that disciplinary action when needed, and incoming reports were considered to be corruption and bribery are unacceptable. especially to learn and aim to prevent compliance incidents and were being Telenor’s governing documents set one issues from recurring. The reporting handled by the Group Investigations single standard which shall govern all volume per 100 employees in 2017 organisation, along with 9 per cent of business activities, regardless of where amounted to 2.8 which is an increase questions. About 38 per cent of the such activities take place. Nevertheless, from 2.4 in 2016. incoming reports were concerns some markets in which Telenor operates pertaining to other parts of the are emerging economies with potentially The NAVEX Global 2017 Ethics & organisation, such as line management or complex and sensitive political and social 13 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

contexts, including markets associated promoting partnerships based on good EMPLOYEE INVOLVEMENT: In 2017 the with high corruption risks. This creates and trusting dialogue, e.g. in relation to Telenor Works Council – Europe (TWC-E) challenges that require robust, targeted acknowledged unions or through local held six meetings, including four where measures to mitigate such risks. All cooperation bodies such as the People European employee representatives met Telenor business units have a Council. with the Telenor Group Management. The responsibility to conduct regular risk objective was to enhance information assessments and risk-based reviews of All workforce restructuring in Telenor exchange and discussions in relation to their anti-corruption procedures, and shall be done with the aim of creating and transnational issues impacting implement remediating measures to sustaining long-term business value. employees, with a particular focus on the mitigate risks. Telenor is focused on Workforce restructuring shall be done in ongoing transformational changes in continuous improvement of risk a responsible manner, through verifiable Telenor Group. management processes. processes and in accordance with the Telenor Way and applicable legal Additionally, Telenor has continued its Labour Rights and Standards requirements and legislation. commitment to promoting employee Policy and Actions involvement in operations throughout the Maintaining a working environment and a At Telenor, attracting and retaining the Group. Almost all of Telenor’s operations culture that nurture occupational health, best talent through training and in Europe and Asia are providing for safety and personnel security (OHS&S) is development opportunities as well as employee involvement through dialogue important at Telenor. The OHS&S career prospects is fundamental to between management and recognised approach covers employees as well as continued competitiveness and growth. employee representatives, e.g. in relation in-house contractors, vendors and Telenor also strives for diversity, inclusion to acknowledged unions or through the suppliers. Telenor believes that the and equal employment opportunities in People Council as a local cooperation OHS&S of employees is vital to its accordance with the People Policy. body. business and makes a difference in employee engagement. Telenor is Status and Ambition In Bangladesh, Telenor and UNI Global committed to continuously learn from OCCUPATIONAL HEALTH, SAFETY AND Union have continued the dialogue on experience and improve its efforts within PERSONNEL SECURITY: In 2017, the fundamental labour rights, focusing in OHS&S and is currently reviewing Sickness Absence Rate (SAR) for the particular on the unionisation issue in its procedures, policies and actions within entire Telenor Group was 1.84 per cent. operations in the country. There is an this area. This number is reported with the ongoing court case filed by employees of acknowledgement of variations in Grameenphone related to union Telenor is committed to respecting labour reported data based on different local registration. In 2016, the Labour rights principles as laid down in the UN and national procedures and regulations Appellate tribunal announced a verbal Global Compact and ILO’s fundamental related to sickness reporting. The total verdict allowing for union formation in conventions. These principles relate to Lost Time Injury Frequency (LTIF) for Grameenphone. The parties involved respecting the rights to freedom of Telenor Group was 0.23 injuries per have been awaiting the written verdict for association and collective bargaining, the million worked hours. further guidance on the establishment of elimination of forced labour, child labour a union in the company. In January 2018, and discrimination in the workplace, and In 2017, close to 18,000 employees and the written verdict was announced by the are reflected in Telenor’s Code of in-house contractors attended Health, court, directing the case to the Director Conduct, Group People Policy and Safety, Security & Environment-related General of Labour. Telenor acknowledge Supplier Conduct Principles. awareness-training sessions. the verdict and are pleased to see movement in the case. We await Telenor believes in empowering There were no work-related employee or follow-up from the Director General of employees through management in-house contractor fatalities reported in Labour paving the way for union dialogue with employees or their Telenor Group for 2017. It is with great registration in the Bangladeshi service recognised employee representatives, regret that during 2017, we have sector. and by utilising the employees’ experienced seven fatalities in our supply experience and insight to influence chain in Pakistan, Bangladesh and India. Also in Bangladesh, the industry review of working conditions and contribute to We provide the context for those deaths the labour rules has shown progress sustainable business growth. Telenor in the chapter on Supply Chain during 2017. The Government appointed Group is, throughout its operations, Sustainability. a tripartite consultative committee to 14 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

propose a revised regulatory framework and in August, the government submitted a first draft on legal amendments to ILO for their review. A final proposal is expected in 2018 and Telenor is hoping that this will result in necessary legal clarifications of the labour rules applicable to the private service sector. Telenor views positively initiatives from its employees for establishing a union in Grameenphone according to applicable local laws and regulations.

DEVELOPING A DIVERSE WORKFORCE: Telenor aims to foster a diverse and dynamic workforce at all levels, in terms of gender, age, nationality and competence. Gender balance and diversity initiatives in 2017 included operationalising WIN (Women Inspirational Network) as a leadership development platform for more than 200 mid-level managers in all business units. Telenor has a six-month paid maternity leave policy for women employees as a minimum standard, 50/50 women and Telenor has a six-month paid maternity leave policy for women employees as a minimum men in the interview process (when standard, 50/50 women and men in the interview process (when possible), and structured possible), and structured review of review of leadership appointments through the People Committee. leadership appointments through the People Committee. Programme, which provides training continued identification and mitigation of opportunities to persons with disabilities the local risks, combined with increasing In 2017, Telenor continued to build its in the workplace. Integration of skilled group collaboration and secure local stance on gender balance and diversity personnel with migrant backgrounds also management attention and follow up. through its commitment to UN continued in Norway. Sustainable Development Goal #10. Telenor will continue to invest in While there are still gains to be made, At year-end 2017, Telenor Group programmes and initiatives to promote recent efforts have yielded positive employed close to 31,000 people greater diversity at all levels – gender, results. At year-end 2017, Telenor’s (excluding India) of which 36 per cent are age, nationality and competence - in the Group Executive Management included women. workplace, and in the societies where the 42 per cent women leaders, and the company operates. Moreover, Telenor will senior leadership level improved from 23 LOOKING AHEAD: Whilst undergoing continue its work to integrate people with per cent to 26 per cent women leaders. business transformation, Telenor Group disabilities through the company’s Open The nationality split amongst senior will continue promoting employee Mind Programme. leaders at year-end 2017 included involvement throughout Telenor Group, approximately 68 per cent and maintenance of good labour Supply Chain Sustainability Scandinavians, 13 per cent from the rest standards in the company’s operations. Policy and Actions of Europe, 16 per cent Asians, and 3 per Telenor strives for high standards in cent others. As Telenor Group operates in markets sustainability and continuous with differences in risk and regulation and improvement in its operations throughout During 2017, disability inclusion remained also differences related to the local the supply chain. Telenor’s Supplier high on Telenor’s agenda with five infrastructure, which to a high degree Conduct Principles (SCP) are based on business units running the Open Mind steers the OHS&S risks, we will focus on internationally recognised standards, 15 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

including requirements on human rights, fatalities in our supply chain: contractual relationship with Telenor health and safety, labour rights, the must comply with Telenor`s Supplier environment and anti-corruption. It is • In Pakistan, a supplier’s employee died Conduct Principles (SCP). An Agreement mandatory for all Telenor contracting in a motorbike accident. At the time of on Responsible Business Conduct (ABC) parties to agree to these principles. the incident he was not wearing his legally obliges the supplier to comply with safety helmet. the SCP and certain requirements set out Telenor’s approach to supply chain • In Pakistan, a supplier’s employee was in the ABCs. As at year-end 2017, we sustainability is to legally oblige the shot and killed in a robbery at a retail have signed approximately 9000 ABCs supplier to uphold responsible business outlet while undertaking a market visit. with almost all our active suppliers that practice, monitor compliance with • In Pakistan, a second line supplier’s we have defined as in-scope for ABC Telenor’s requirements and to undertake employee died in a road accident while (based on risk assessments). If a supplier capacity-building among suppliers. All three other employees were injured has objections to signing our ABC, the risk suppliers are obliged to extend the and sent to hospital. involving softer requirements shall be supplier requirements further down in • In Pakistan, a supplier’s employee died considered and procedures for their own supply chain. Partnership and when their car collided with a mini adjustments of text, clause on cooperation with suppliers is vital to truck. Three other employees were Responsible Business Conduct in the achieving a responsible supply chain. injured and sent to hospital. underlying contract, waivers and waived Telenor is an active member of the Joint • In Pakistan, a second line supplier’s category list shall be followed. A small Audit Cooperation (JAC) and Global employee fell down from a mobile number of waivers for signing the ABC are e-Sustainability Initiative (GeSI). tower and died. given based on a supplier’s refusal to • In Bangladesh, a supplier’s employee sign, and with the local CEO’s approval for Status and Ambition was killed in a road accident. local contracts or with Group KEY SUPPLY CHAIN RISKS: The supply • In India, a supplier’s employee was Sustainability for global contracts. chain responsibility focus in 2017 killed in a road accident while driving a remained on mitigation of supply chain motorbike Telenor is using EcoVadis as a risk-rating risk, capacity-building and monitoring system for global suppliers to increase compliance with Telenor’s requirements monitoring of the supplier’s sustainability on responsible business conduct. Our key performance. The EcoVadis platform is an risks are within working conditions in our external tool that measures a company’s Asian operations, such as health and performance based on a wide range of safety (especially road accidents) and sustainability criteria and is a well- labour standards including underage/ recognised tool used by a high number of child labour. We follow up to ensure that buyers across many industries, including preventive anti-corruption programmes the telecom industry. The purpose of are also in place with our suppliers. The business units organised using EcoVadis is to measure more than 23,000 man-hours sustainability performance based on There are also supply chain sustainability of capacity-building in our verified external information, reduce risk risks in the telecom downstream value supply chain and integrate sustainability into the chain and newer businesses such as sourcing processes. telecom distribution and sales, with digital suppliers as well as new digital In all incidents, our required reporting MONITORING COMPLIANCE: Telenor businesses. procedures were followed and each and carries out local inspections in all our every one of the incidents were handled markets in order to monitor compliance SAFETY: Our most fundamental immediately and individually with with the requirements on responsible responsibility as an employer is to keep mitigating actions. Risk re-assessment business conduct. In 2017, Telenor carried all people who work for us safe from harm and plans for preventing similar incidents out approximately 5000 supplier – and we do not differentiate between have been carried out. Employees’ inspections (ranging from simple site our own employees, in-house contractors families have been followed up and given visits to more comprehensive inspections or our suppliers’ employees. compensation. or audits) across the Group. 84 per cent of the inspections were carried out FATALITIES: It is with great regret that MITIGATING SUPPLY CHAIN RISKS: unannounced. More than 560 major non- during 2017, we have experienced seven All suppliers and parties having a direct conformities were identified during the 16 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

years) was identified. In 2017, the number of child labour/underage labour findings was significantly reduced from previous years: the number of incidents of underage labour in 2015 included 34 people, and the number of incidents of child labour in 2015 included 13 children. A similar number of incidents of underage labour in 2016 included 16 people and the number of incidents of child labour in 2016 included 4 children.

CAPACITY-BUILDING: The business units organised more than 23,000 man-hours of various capacity-building initiatives in 2017. The capacity-building involved various efforts to proactively build the local capacity of suppliers and sub- suppliers in order to drive continuous improvement in the supply chain. The activities vary from supplier to supplier depending on the overall risk picture of the business unit. Typical activities include on-site briefings, awareness sessions, workshops, forums, process 84 per cent of the approximately 5000 inspections were carried out unannounced and support, online portals and resource more than 560 major nonconformities were identified and followed up with mitigation guides, etc. The capacity-building is plans. adapted to the practical situation and according to the real need of the supplier, inspections across the business units and anti-corruption programmes, labour focusing on awareness of Telenor have been followed up with mitigation rights and working conditions as well as Supplier Conduct Principles issues as well plans and processes aiming to close health, safety and the environment. as specific activities related to skills these non-conformities. Telenor performed six of these audits of development (e.g. tower climbing). global suppliers on behalf of JAC in 2017. Typical topics are: Labour rights, health In 2017, Telenor transferred to a new After carrying out an audit, a Corrective and safety, anti-corruption, sustainability reporting tool platform. We have started Action Plan (CAP) listing all findings is requirements as well as green telecom, using DNV GL’s Synergi Life as a common agreed upon between the auditee and empowerment of women and diversity. reporting tool for all local supplier the auditor. Over time, JAC has carried Some business units have also worked in inspections with a focus on environment, out 366 audits in 27 countries, covering industry and cross-industry health and safety. The Synergi Life tool more than 817,000 workers. Going collaborations to synergise efforts in enables all our business units to manage forward, the number of yearly audits capacity-building. non-conformances, incidents, risk, risk carried out by JAC will increase and the analyses, audits, assessments and focus will mainly be on tier 2 and tier 3 In Asia, road-related accidents are improvement suggestions. suppliers. among the leading causes of on-the-job injuries and deaths, and as mentioned Through participation in the Joint Audit CHILD LABOUR/ UNDERAGE LABOUR: above, 70 per cent of all fatalities in Cooperation (JAC) together with other During 2017, Telenor recorded two Telenor’s supply chain in 2017 were road telecommunications operators (13 incidents in Pakistan and one incident in accidents; and all in Asia. Telenor Group’s members in 2017), Telenor gained access Bangladesh of underage labour (15-18 footprint in Asia covers more than sixteen to the results of 89 sustainability audits years) involving hazardous work. Further, thousand employees and approximately of global suppliers in 2017. A standard one incident in Bangladesh and one six hundred thousand supply chain JAC audit focuses mainly on preventive incident in Pakistan of child labour (12-14 employees. With such large numbers of 17 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

people working for and with Telenor, and To help us navigate and identify the areas on the number of authority requests with an extensive network spreading over of potentially greatest impact, we in our markets as well as a bi-annual huge areas of land, the company holds conduct human rights due diligence both ‘legal overview’ of key laws related major stakes in everyone’s safety. As at Group and business unit (BU) levels. to authority requests in our markets Telenor’s markets grow rapidly, traffic and Human rights are also included in our iii. Sustainability updates/ road-related safety is an increasing materiality matrix. Our activities are presentations – e.g. annual updates concern. Telenor launched a road safety drawing on the UN Guiding Principles on by Telenor Myanmar to stakeholders initiative in 2016 aimed at increasing Business and Human Rights and other on key human rights issues awareness of road safety and reducing international guidance. We also find it road accidents. This awareness work has helpful to look at human rights reflecting Status and Ambition continued in 2017. the four key roles we have as a company 2017 saw many challenges related to – employer, provider of telecom and human rights. The situation in the LOOKING AHEAD: Telenor’s focus on the digital solutions, purchaser of goods and Rakhine State in Myanmar was and long-term risks related to supply chain services, and investor. This makes, for continues to be high on the international will stay high on the responsible business example, labour rights, privacy and agenda. Telenor viewed the agenda, with continued work in 2018 on freedom of expression (see below and ch. developments in Rakhine with grave mitigation through local inspections, JAC Privacy), supply chain sustainability and concern, and published a statement to audits and capacity-building. Further, due diligence pre investment important that effect in September 2017 which was Telenor will secure thorough risk to us. communicated to the Myanmar assessment of the supply chain in the authorities. The company follows the business units and also improve efforts in Telenor has a three-pronged approach to developments closely and continues to capacity-building. human rights: focus on ensuring provision of services to all people in Myanmar. We will continue to Human Rights 1. Addressing actual and potential risks engage constructively and encourage all Policy and Actions and impacts of our business through parties to follow up on the Telenor’s business is about enabling i. Policies and processes – the recommendations in the Annan report. people to communicate, and the principle of ‘respect’ is anchored in company’s operations and services touch our Code of Conduct (CoC) and ADDRESSING RISKS: In order to stay on core human rights. We see that we can Supplier Conduct Principles (SCP), informed and follow developments in positively impact rights, e.g. through and due diligence is a policy human rights in our markets, we worked digital birth registration (see ch. requirement during 2017 to update our Group level Innovating and Researching for Shared ii. Guidance – dedicated tools drawing human rights due diligence. With Value), but also recognise that our on the UN Guiding Principles assistance from BSR we revisited our impact may be negative e.g. through iii. Training and awareness –specialist understanding of country risks, as well as potential misuse of our services (see ch. training, as well as management and exploring international trends and good Child Online Safety). Telenor is also board discussions practices for mitigation. This work also present in markets with significant human 2. Collaborating with others, for example fed into an update of BU level due rights challenges. Understanding the through diligence, starting with a pilot in four BUs complexity of the potential impacts of our i. Stakeholder dialogue - with peers, in Q4 2017. As part of this pilot our tools business, mitigating negative impacts civil society, investors, academia, to conduct due diligence are being and continuously improving are key focus government revised, recognising that our current areas. ii. Industry/multi-stakeholder tools are complex and taking in recent initiatives – member of e.g. Global international developments and guidance Human rights are governed internally as Network Initiative (GNI) and Joint since it was first developed in 2013-14. described in the chapter on “Corporate Audit Cooperation (JAC) (see SCS This is combined with refresher training Governance”, and reporting of grievances chapter) on human rights for BUs. Both the Group through the Integrity Hotline to 3. Being transparent on challenges and and BU-level processes are ongoing. Compliance is described in the chapter company practices to the extent “Ethics and Anti- Corruption“. Finally, possible in COLLABORATION: Privacy and freedom Telenor’s approach to enterprise risk i. Annual reporting – this report of expression continued to be high on the management is described in Sustaina­ ii. Issue-specific reporting - Including agenda both internationally and within bility and Compliance in the BoD report. our so-called ‘transparency report’ Telenor throughout 2017. For more 18 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

suppliers they have in common and share business. The company approaches the findings amongst them, thus these issues from a privacy point of view increasing efficiency and leverage in as well as a security angle, with policies terms of rectifying human rights risks at and manuals that set out mandatory suppliers. (see SCS chapter)] requirements applying across all operations. TRANSPARENCY: Telenor continued its annual reporting on authority requests in As the Internet of Things (IoT) is the access report for 2016 www.telenor. becoming more important, and privacy com/sustainability/responsible- and security challenges are growing, business/privacy-and-data-protection/ connected units are no longer isolated handling-access-requests-from- from public access and Telenor must authorities, as well as the annual report make it easy for end users to safely on the alignment with the Industry connect additional sensors or units to Dialogue Guiding Principles [link]. The their current solutions. Telenor will reports for 2017 will be published in continue to adapt to these challenges spring 2018. We also provided an update and provide secure solutions related to of our legal overview of the laws relevant IoT. to authority requests in our markets [link]. Since 2015, Telenor has had a clear privacy position: being open and Telenor also continued to develop its transparent about how personal data is transparency efforts related to its collected and used, committed to using operations in Myanmar with a local personal data to provide better and more seminar in February 2017. relevant services, and thorough in keeping personal data safe. Since 2015, In October 2017, Telenor Group President Telenor has been committed to the GSMA in-depth information on our internal and CEO Sigve Brekke was invited to hold Mobile Connect Privacy Principles. The efforts, please see the Privacy chapter. the Rafto Challenge lecture at NHH, principles establish a privacy baseline We also ran training sessions on human presenting how Telenor Group works with that applies to all parties that provide rights for personnel working on authority human rights, how we address challenges Mobile Connect-branded identity requests, e.g. in Telenor Norway. In March and how we need to stay vigilant and services. 2017, Telenor Group and six other continuously improve. members of the Telecommunications Telenor recognises that while Industry Dialogue (Millicom, Nokia, LOOKING AHEAD: The ongoing update of telecommunications generally Orange, Telefonica, Telia Company, the Group and BU human rights due contributes to freedom of expression, Vodafone) joined forces with the Global diligence will continue in 2018. This there may be challenges related to the Network Initiative (GNI). As members of includes training of key personnel. The business. In many situations, authorities the GNI we work together with internet outcomes of this process will steer our may have a legitimate need to require companies like Google, Facebook, Oath priorities for the rest of the year. Telenor telecommunications companies to and Microsoft, and civil society, academic will also prioritise the multi-stakeholder comply with requests that limit privacy or and investor members to address efforts of the GNI. free communication. For Telenor, it is challenges to privacy and freedom of important to seek to limit the risks of expression, in particular with respect to Privacy unlawful restrictions on privacy and authority requests. Telenor Group is a Policy and Actions freedom of expression to the extent that Board member of the GNI. Customers expect not only real-time, we can. We therefore have strict policies relevant and individualised services, they that govern Telenor’s approach in Telenor continued its collaboration with also expect that their privacy is responding to such requests. Telenor industry peers in the Joint Audit safeguarded. As a provider of mobile and continues to prioritise transparency and Cooperation (JAC), an industry initiative internet connectivity, respect for the introduces safeguards against potential on Supply Chain Sustainability where rights to privacy and freedom of abuse. As described in the Human Rights members conduct audits on major expression is central to Telenor’s core chapter, Telenor actively engages in the 19 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

Telecommunications Industry Dialogue Telenor has further strengthened its architecture, security culture, security on freedom of expression and privacy, as privacy function in terms of both intelligence and physical security. well as bilaterally with a range of competence and capacity. All privacy stakeholders. resources have undergone extensive Cyber Security training and the central privacy team in Policy and Actions Even though national requirements vary Telenor has been strengthened with an The growing digitalisation of society is throughout Telenor’s markets, Telenor increase in headcounts. Training has making us all more vulnerable to extreme strives to be transparent about how focused on general privacy upskilling and weather, human and technical errors as personal data is handled. Telenor believes on implementing improved processes to well as hostile acts that manipulate or this is the best approach to ensure and handle data breaches and requests from paralyse networks and services. build the trust of customers and authorities. In addition, Telenor has Increased use of telecommunications employees. produced new internal guidelines and services and an ever-increasing tools to assist privacy and commercial complexity of systems and infrastructure Status and Ambition professionals in their daily work relating leads to new cyber security risks. A VALUE-DRIVEN APPROACH TO to privacy matters. Criminals are becoming more advanced PRIVACY: An internal project to by the day. strengthen Telenor’s position on privacy STRENGTHENING PRIVACY was concluded in 2015, which addressed THROUGHOUT TELENOR: The Telenor As a network operator and provider of both how the company handles existing Group Privacy Policy was simplified in digital services, Telenor give cyber customer data and how products are 2017, and the Group Privacy Manual will security a high priority. The quality and designed going forward. Telenor has be revised in Q1 2018 with the objective reliability of our telecommunications decided to take a customer value-driven of strengthening the privacy services depend on the stability of our approach to privacy. Customers shall get organisation. Also, the Authority network and the networks of other as much value as possible when they Requests Manual was updated in 2017 to service providers with which we share their data with Telenor. Therefore, reflect and address new challenges. In interconnect. These networks are whenever the company processes data addition, the new Data Breach Manual vulnerable to damage or service on behalf of customers, Telenor strives to was implemented to strengthen interruptions, including interruptions add value to the current experience and preparedness and handling of possible caused by cyber security attacks. deliver more personalised and relevant data breaches. Repeated, prolonged or complex network services. or IT system failures could damage our LOOKING AHEAD: Governments and services and consequently the trust our Building a strong privacy culture in regulators across Telenor’s markets are customers place in us as a reliable Telenor is important. The commercial taking new steps to strengthen privacy communications provider. strategy of Telenor identifies the trust of and national security regulations and to our customers as one of the critical introduce new measures that directly or We depend on suppliers and third-party strategic enablers. At the same time, indirectly affect Telenor’s ability to providers for supply and maintenance of Telenor believes that, going forward, our manage customer data. This trend is equipment and services. Problems that dedication to privacy can develop into a expected to continue and Telenor will manifest themselves in relation to the differentiator in relevant markets. The also step up its focused work on privacy, supply chain may adversely affect our aforementioned commercial strategy freedom of expression and security to business and operations. We work closely addresses the growing concern among meet both regulatory requirements and with our suppliers to prevent loss, misuse customers regarding privacy by early the expectations of customers. or unauthorised disclosure of confidential consideration of privacy in Telenor’s information. This includes placing high business processes and strategic In order to meet privacy and security security requirements on suppliers, who activities. The current key objective of challenges, the following areas will be must ensure adequate levels of privacy this exercise is to ensure a strong level of prioritised in 2018: compliance with and security to stay in business. Telenor protection of Telenor customers’ data changes in the European General Data conducts a high degree of network and, in Europe, to ensure compliance with Protection Regulation (GDPR), monitoring and carries out regular and ad the European General Data Protection strengthened responsiveness to data hoc inspections of the work performed by Regulation (GDPR). breaches, implementation of Privacy by third parties. Design and Default, security operations, BUILDING INTERNAL CAPACITY: In 2017, vulnerability management, security Telenor is committed to providing secure, 20 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

well-functioning networks and services, Telenor’s global business. This strategy (CERT). Telenor will continue to raise the and has a strong interest in doing so. Our supports the rapid development in security level through securing our customers and society in general must technology and services by early systems and architecture, in order to have confidence in Telenor as a involvement of security and privacy in address less sophisticated attacks as well trustworthy supplier of safe, reliable and business processes and strategic as advanced attacks. secure telecommunications and digital initiatives. Furthermore, our ambition is to services. Below we set out our view on have security at the core of everything Telenor Group Security Policy and how to respond to the global cyber we do, in order to protect people in their Manuals were updated during 2017 with security challenge. digital life. the objective of strengthening Group involvement in strategic operational Status and Ambition During 2017, the global security decisions in the business units. The main Telenor is taking a number of steps to organisation in Telenor was strengthened purpose has been to simplify the protect customer data and critical with a substantial number of new security governing documents during the annual infrastructure. We are investing in experts. With these capabilities now in revision of the Governance Work security competence across our own place, Telenor is better equipped to cater Programme (GWP). organisation, and we are working with for current and future security challenges partners and vendors to raise awareness and needs, both at Group and business Furthermore, we are working and set clear expectations with regard to unit levels. Particular focus has been systematically with the transformation security. given to strengthening operational programmes in Telenor to ensure that security, through improved monitoring security is an integrated part, and that To meet the fast-evolving threats in the and establishment of critical operational security and business objectives are cyber domain, Telenor has developed a capabilities globally, such as a global aligned. Through this, Telenor is holistic, Group-wide and long-term Security Operations Centre (SOC) and strengthening security levels and security strategy aimed at securing Computer Emergency Response Team controls through several key transformation projects, such as in network virtualisation and common To meet the fast-evolving threats in the cyber domain, Telenor has developed a holistic, operating models. Group-wide and long-term security strategy aimed at securing Telenor’s global business.

Ensuring security at the core of everything we do is dependent on people, in addition to technology and processes. Our goal is to build a strong security culture within Telenor at all levels of the business. In 2017, we started a global Security Training Programme for all employees at Telenor. The aim of the programme is to raise awareness related to a broad range of security topics, such as phishing, secure passwords, and encryption, through a set of short and interactive lessons. In addition, cyber security exercises have been arranged in several business units to raise security awareness with top management. Going into 2018, we will explore different concepts to not only create general awareness regarding security, but to enable a security culture for every employee at Telenor.

Externally, Telenor actively contributes to strategic, international security arenas, 21 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

such as the GSMA Fraud and Security events. At the same time, the ICT Changing regulations, significant Group, the Information Security Forum industry’s technology and smart services reductions in renewable energy costs and (ISF), “Arendalsuka” in Norway and through the Internet of Things (IoT) have concerns about energy security will through active membership in the the potential to cut global carbon impact global energy markets. Telenor’s Europol Cyber Crime Centre Advisory emissions, reduce resource intensity, Asian markets are very different from its Group for Communication Providers. stimulate economic growth and deliver European markets, both in the company’s substantial social benefits. carbon footprint and the type of energy LOOKING AHEAD: The current challenges that Telenor uses for its network in the cyber security domain are Telenor continues to engage with the operations. In general, developing expected to increase and play an even industry organisations – such as GSMA countries will have the opportunity to more crucial role going forward. The and GeSI – and industry partners to leapfrog into the renewable age, and industry and society will become more embrace these opportunities. The Telenor has already, in several of its Asian digital and interconnected, for instance SMARTer 2030 report (co-financed and operations, started to replace traditional by entering into the cloud and IoT supported by Telenor) identified a diesel-based on-site generators with domain. For Telenor, this means we will number of sectors where the enabling cost-efficient solar/battery renewable continuously strengthen our critical potential of ICT can deliver significant energy technology. security capabilities and competencies carbon emissions reduction – up to 20 by establishing a well-functioning, global per cent by 2030 and close to ten times The growing demand for ICT products security operating model. the ICT industry’s own direct emissions. and mobile devices, and their increasingly This places ICT as one of the key short lifespans, has resulted in e-waste A number of key actions will be prioritised instruments for the achievement of the becoming a significant concern and risk in 2018 to meet the privacy and security climate commitments undertaken in Paris for the ICT industry. In this regard, all challenges, such as: and the implementation of related business units are mandated to secure national action plans. sustainable waste management. All • Compliance with changes in the electronic waste is to be reused, recycled European data protection regulation, The mobile industry will risk continued or safely disposed of, and all business related to GDPR growth in its total energy consumption units are to ensure that these processes • Strengthened monitoring of and and carbon footprint as mobile operators are conducted according to responsiveness to cyber attacks continue to increase their coverage, internationally recognised standards and • Further developing a global operating acquire more customers and develop regulations. model for security more mobile broadband services due to • Further capability upgrade within the market needs. The mobile industry Status and Ambition area of security operations, requires significant amounts of electricity For the fourth year in a row, the global vulnerability management, security in Telenor’s network operations, and most climate reporting organisation CDP architecture, security culture, security power is supplied on-grid by national (formerly Carbon Disclosure Project) intelligence and physical security. power generation companies. In Telenor’s rated Telenor Group in their ‘Leadership’ Asian operations, the company also relies category as part of its climate ranking list Environment and Climate Change heavily on diesel used in its on-site for 2017. Telenor is still the best telecom Policy and Actions generators to power infrastructure off- company with headquarters in Telenor is committed to minimising its grid in remote locations or areas of Scandinavia. environmental impact. Telenor’s business unreliable on-grid power. units operate with the policy of making all ENERGY CONSUMPTION AND CO2 reasonable efforts to minimise use of Telenor’s key focus has therefore been to EMISSIONS: In 2017, the total data traffic natural resources including energy, water stabilise energy consumption by volume in Telenor’s mobile network was and raw materials. improving the energy efficiency of its more than 2600 petabytes - an increase networks, as these represent around 80 of more than 300 per cent from 2015. In Climate change is one of the most per cent of the total energy consumption. 2017, Telenor’s total energy consumption complex challenges facing people, The business units are focusing on cost- was approximately 3100 GWh – businesses and governments. Climate- efficient energy initiatives: network approximately the same level as for 2016 related risks include potential damage to swaps, sourcing of energy-efficient when comparing without India. In 2017, vital infrastructure and utilities through technologies, infrastructure-sharing and our Asian operations consumed around the impact of more extreme weather energy efficient data centres and buildings. 69 million litres of diesel to power base 22 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

stations in off-grid areas or areas with unreliable on-grid power.

The associated emissions of greenhouse gases in 2017 for Telenor Group without India have been estimated to be a total of around 1.1 million tonnes of CO2 when using location-based electricity emission factors for the indirect scope 2 emissions, and close to 1.3 million tonnes of CO2 when using market-based electricity emission factors for indirect scope 2 emissions. The market-based method reflects the CO2 emissions from the electricity that a company is purchasing, which may be different from the electricity that is generated locally in the country.

In the period 2012-15, Telenor’s energy consumption per end customer (without India) dropped by approximately 18 per cent and the associated CO2 emissions per end customer dropped 24 per cent in the same period. In the period 2015-

2017, Telenor’s CO2 emissions per end Grameenphone in Bangladesh has more than 1200 solar powered base stations in place. customer increased by around 20 per cent due to the significant increase in data traffic volume – still representing only approximately 6 kg of CO2 per By year-end 2017, Telenor Pakistan had ENVIRONMENTAL MANAGEMENT: More customer per year in 2017. installed solar energy solutions for more than 61 per cent of Telenor’s than 700 of its base stations and is procurement processes with a contract planning for an additional 250 sites in value greater than USD 250,000 used a

Energy and CO2 per customer 2018. Grameenphone in Bangladesh has specified set of environmental criteria in more than 1200 solar powered base 2017. In addition, more than 177,000 kWh Kilo CO2 stations in place, and similarly Digi in meetings were carried out in Telenor’s

20 Malaysia has close to 60 base stations global organisation using video

15 powered by solar solutions. Also in conferencing and virtual meeting Myanmar, Telenor has started scaling up solutions that are reducing actual travel. 10 with solar/battery technology for more In 2017, Environmental Management 5 than 80 base stations in 2017 and roll- Systems (EMS) in line with ISO 14001 0 2013 2014 2015 2016 2017 out of solar/battery technology to were followed up in our business units n Energy use per customer another 1400 base stations in 2018. with the exception of Telenor Myanmar, n CO2 emissions per customer where planning has started up and EMS LOW CARBON SOLUTIONS: In 2017, implementation will be finalised in 2018. Telenor Group passed more than 12 Seven Telenor business units are now RENEWABLE ENERGY SOLUTIONS: In million SIM connected devices globally certified according to ISO 14001: Telenor Telenor’s Asian operations, the company on its IoT platforms. Telenor Connexion, Bulgaria, Telenor Serbia, Telenor Hungary, has, in 2017, continued to convert Telenor’s dedicated IoT company, designs Digi in Malaysia, Telenor Montenegro, traditional diesel-based on-site and operates global IoT solutions for the Grameenphone in Bangladesh and generators to renewable energy with global market. Telenor Pakistan. The revised ISO cost-efficient solar/battery technology. 14001:2015 standard has so far been 23 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

implemented in 8 business units. 2020, Telenor Group companies will influential and strong organisations such deliver training on how to be safer online as BRAC and Parentzone and by E-WASTE INITIATIVES: Mobile handset to four million children. By year-end 2017, developing its collaboration with Child recycling initiatives have been ongoing such training had been delivered to more Helpline International and UNICEF. All for several years in nine of our business than 1.3 million children and young business units have worked units: Telenor Hungary, Telenor Serbia, people. A further goal is to contribute to systematically to deliver on the targets Telenor Montenegro, Digi in Malaysia, growing a comprehensive ecosystem that that will enable the company to meet the dtac in Thailand, Telenor Sweden, Telenor takes a 360° view of risks, resilience and overall goal of offering meaningful Denmark, Telenor Norway and Telenor roads to recovery. training to four million children by 2020. Bulgaria, and in 2017 Grameenphone The group-wide ‘Be Smart Use Heart’ also started their mobile recycling Ensuring fool-proof child online safety is brand has now been firmly anchored initiative. Across Telenor, a total of more difficult. There are numerous devices across most companies in the Telenor than 168,000 mobile handsets and around today that offer connectivity, and footprint. mobile batteries were collected and child protection features aren’t always recycled in 2017. During 2016/2017, easy to set. Once children are online, CURRICULUM: Telenor believes the best updated guidelines/manuals for proper they will engage through a range of way to keep children safe is to make them handling of e-waste have been service platforms with different features aware of common risks and encourage implemented. and risks. Parents have a hard job them to make the right choices. Getting keeping up with their children. the key messages across in an effective LOOKING AHEAD: Telenor’s key climate manner is important and almost all measure has been to stabilise the energy Status and Ambition Telenor business units are involved with consumption in its networks while In 2017, Telenor continued to develop the physical outreach programmes in increasing market footprint, since company’s position on child online safety schools. Along with this, Telenor also network operations represent around 90 by forging new partnerships with makes a range of digital resources per cent of Telenor’s total CO2 emissions. Going forward, Telenor will plan for a All Telenor business units work systematically to deliver on the overall goal of offering scale-up of renewable energy combined meaningful online safety training to four million children by year-end 2020. with continued focus on energy efficiency initiatives in all of its network operations, resulting in both savings in operating expenses and reduced CO2 emissions.

Child Online Safety Policy and Actions When it comes to picking up new technologies and services, children and young people have fewer barriers than adults. As a result they are among those that benefit the most from connectivity. But in their exploring, they are also often over-trusting and therefore vulnerable. Children’s right to safety – online as well as offline – has firm backing in every society. But existing child rights mechanisms and organisations often struggle to deliver the support that’s needed. Telenor does not have a direct customer relationship with children. But Telenor’s services are used extensively by young people. Every Telenor business unit is therefore involved in efforts to grow the resilience of young people online, and by 24 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

available, mainly to parents and children. school nurse “Helsesista” were empowering marginalised schoolchildren, In 2017, Telenor took further steps to introduced through a series of video especially girls, to make the right coordinate these efforts by contracting interviews. These videos have received decisions on how to interact and engage Parentzone in the UK to prepare an more than one million hits. At the same through the internet. The programme interactive and progressive curriculum time, Telenor Norway continued the “Bruk also aims to reduce gender inequality that can be applied at all local business Hue” school outreach programme and in around internet access and usage. units. This curriculum will have separate total more than 290,000 children and Grameenphone is also working to sections on Understanding the Digital 60,000 parents have been visited since sensitise parents, guardians and teachers World, Being a Digital Citizen and 2009. on internet safety. Recovering When Things Go Wrong. For parents there will be a section called DIGI: Digi in Malaysia continued to Since, 2014 Grameenphone has Raising Digital Citizens. Work on this develop their safe internet capacity- educated 140,000 children through 600 curriculum is now ongoing and it will be building programme in 2017, striving to schools across Bangladesh, and directly available for the business units in the convey their message on online risks and engaged with 35,000 parents, teachers spring of 2018. digital citizenship. An estimated 8000 and guardians. 250,000 copies of students were reached through regular communications material have been HELPLINE: Children will not always get school modules in 2017, another 21,000 distributed and 700 employees things right, and when they don’t it is were reached through a mobile learning participated in the programme as important that they have somewhere to unit, and 18,000 visitors went through an ambassadors. To ensure scalability, turn, and that mechanisms for recovery interactive exhibit in Kuala Lumpur. Grameenphone has partnered with the are in place. Child helplines play an Throughout the year Digi continued its largest NGO in the world, BRAC, which important role in this respect and Telenor close partnership with UNICEF, through operates the largest non-formal Group has, in 2017, supported the research workshops and a series of town education programme in the country. development of an e-learning hall forums on Healthy Teen programme that is designed to grow the TELENOR MONTENEGRO: In February skills of child helpline staff who receive 2017, UNICEF and Telenor Montenegro calls from children. Telenor does this in joined forces with the Montenegrin collaboration with Child Helpline Government to launch #EndViolence, International, which is an umbrella which aims to tackle the negative effects organisation for helplines around the of violence, neglect and dysfunctional world. The goal of this effort is that parenting. As part of the project, UNICEF helplines shall be better able to respond launched the mobile app #NetFriends, to questions relating to difficult focused on educating children on online experiences children have had online. At violence. The app contains an year-end 2017, the e-learning tools were By year end 2017, safer online educational role-play game, which takes completed and roll-out will commence in training had been delivered to children through real life scenarios and early 2018. more than 1.3 million children and makes them learn how to recognise, young people since 2014 prevent, stop and report violence. During TELENOR NORWAY: Surveys conducted May and June 2017, 80 teachers from among Norwegian parents reveal that nine schools in the capital Podgorica many remain concerned about their were educated on online safety and ability to effectively help their children be Relationships & Online Dating, targeting these teachers held workshops for 1300 safe online. In an effort to help those rural communities in Malaysia. pupils, taking them through scenarios parents, Telenor Norway has made new from the #NetFriends application. guidance available at the Foreldreskolen. GRAMEENPHONE: Bangladesh has a no portal. This includes such topics as large young population with 74.6 million Building on this first collaboration setting age limits for gaming and social young people under the age of 24 who between UNICEF and Telenor in media, and respecting children’s privacy. are starting their digital journey. As the Montenegro, the cooperation between Later in the year, a series of experts from, largest mobile ISP in the country, Telenor Montenegro and UNICEF was for example, Norway’s Criminal Grameenphone is committed to furthered by the signing of a three-year Investigation Service, the Ombudsman contributing to a safer internet agreement on “Digital literacy for every for Children, UNICEF and the Snapchat experience for this segment by child” in October 2017. 25 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

TELENOR DENMARK: During March and April 2017, together with partners, Telenor Denmark ran an online video competition targeting school children from 4th to 6th grade. The purpose was to engage children on the topic of digital bullying and encourage them to record a video of how digital bullying is experienced through their eyes. More than 100 classes participated in the competition.

LOOKING AHEAD: In 2018, Telenor will continue to run significant outreach programmes to achieve the ambitious target of reaching four million children by 2020. As part of this effort we will ensure the involvement of our specialist partners, both to ensure the quality of the materials and guidance we make available, and to ensure that the content is current and engaging. With the new Digital Citizenship curriculum, Telenor will also significantly add to the online resources available on our websites. To ensure that the work undertaken in this Since November 2015, close to 100,000 students have received online safety training at area is meaningful to the defined target Telenor Myanmar’s Lighthouses audience, it is important to strive to listen to the voices of children and young people as well as their parents. had also rolled out Wi-Fi offerings. In its farmers have limited or no access to mature markets, Telenor is adding agriculture information which results in Digital Access and Outreach network capacity to sustain and improve primitive farming techniques or poor farm Policy and Actions the mobile data user experience as management. Khushaal Zamindar is in As an increasing number of services are networks become congested. effect bridging the information gap becoming available online, connectivity is between smallholders and the large becoming even more important in the TELENOR PAKISTAN: In Pakistan, Telenor progressive farmers. effort to empower societies. Telenor sees continued to develop Khushaal Zamindar, this development as integral with the which is a free-of-charge Interactive As an extension of this successful company’s commitment to reduce Voice Response (IVR), robot-call and concept, Khushaal Aangan is aimed at inequalities in the societies where it SMS-based service providing localised, empowering Pakistan’s female farmers. In operates. Clearly the greatest challenges contextualised and customised weather December 2017, in partnership with the relating to access are in the emerging forecasts and actionable agriculture Punjab Livestock and Dairy Development markets in South Asia, but the challenge advisories to farmers. The service Board, Telenor Pakistan launched a free- of ensuring an inclusive internet is provides information on a range of cash of-charge IVR service designed for relevant for everyone. Telenor remains crops, fruits & vegetables, fodder and female farmers in Punjab. Appreciating committed to bringing the benefits of livestock in three different languages. the cultural sensitivities in the rural digital access and outreach to all. There are now more than four million setting of Pakistan which inhibit access to monthly active users, across Punjab, phones by females and interacting with Status and Ambition Sindh, Gilgit Baltistan and Chitral. Almost male voices on the other side, a By year-end 2017 Telenor had rolled out 90 per cent of farmers in Pakistan are dedicated information service for females 4G mobile technologies in all our markets, smallholders, out of which at least 60 per addressing their specific needs is an besides Bangladesh. All business units cent grow crops for subsistence. These ambitious effort towards digital inclusion 26 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

of smallholder farmer women. Khushaal National Electronics and Computer Sustainable Development Goals that Aangan was able to sign up more than Technology Centre and the Department were set in 2015. Leveraging the power of 30,000 users in less than one month. of Agricultural Extension, inventing an IoT mobile for sustainable development solution for agriculture. The device, a includes applying innovation, resources TELENOR DENMARK: Telenor Denmark’s sensor with the capability to monitor five and expertise to pursue the business “Kør Godt” is a free driving app that parameters (light, soil humidity, tempera­ opportunities inherent in building a enables users to track and improve their ture, water and wind) is linked to a router greener, more equitable and inclusive driving skills. It is the only telematics- with a dtac SIM relaying this information society. based insurance product on the Danish to the cloud. The solution will enable the market that does not require the user to sending of targeted advisory information RESEARCHING FOR SHARED VALUE: At install any kind of technical equipment in to farmers based on farm-level granular Telenor, research is key in helping the the car. “Kør Godt” enables all users to data, thereby helping smallholder company gain insights and competencies capitalise on their own data – either in a farmers to achieve productivity gains. to become a data-driven software very direct way by using it to gain a fair The solution will, for example, help to organisation. This ambition also has a discount on their car insurance, or by monitor and automatically adjust sustainability dimension. Research into using it to monitor their own skills behind temperature in a storage room depending using big data – the information flow from the wheel and becoming better drivers. on crop specificity. In early 2017, thirty digital communications analysis – has sets of devices were installed and trialled the potential to provide important TELENOR HUNGARY: Telenor Hungary’s by farmers across the country. insights that can help tackle socio- E-Tanoda programme enables digital economic challenges, such as the early tutoring based on a peer-to-peer TELENOR MYANMAR: Telenor Myanmar’s identification and prevention of diseases. concept where students from the top- digital literacy centres, the Lighthouses, performing Budapest secondary schools are multi-purpose online hubs for local Status and Ambition mentor children, mostly from Roma communities in Myanmar. They serve as INNOVATIVE SERVICES AND communities, living in disadvantaged digital literacy centres, they host child PROGRAMMES: Leveraging Mobiles & settlements. This pilot project started in online safety sessions as part of Telenor Partnerships to reduce inequalities: In January 2017 and was later extended to Myanmar’s outreach work, they are part 2017, Telenor and UNICEF continued the two new rural sites in five secondary of the company’s point of sale network global partnership to leverage the reach schools in Budapest. Telenor has been and they are often local printing hubs. and capability of connectivity for working with Microsoft and the Since November 2015, close to 100,000 children’s rights and development. In Foundation for 21st Century Pedagogy on students have received online safety 2017, Telenor and UNICEF continued the project. training at Telenor Myanmar’s building on their strong collaboration on Lighthouses. During 2017, some promoting child rights and Safe Internet DTAC: In 2017, dtac continued to develop Lighthouses were discontinued, as they in Bangladesh, Thailand, Malaysia, its SMART farmer project in Thailand, were not successful in fulfilling their role Denmark and Hungary and stepped up which aims to empower farmers through in the local community. Other centres their partnership in Serbia, Montenegro access to knowledge and information on were established in the same period and and Norway. their mobile phones. In partnership with 61 Lighthouses were in operation at year- the Thai Ministry of Agriculture and end 2017. In Pakistan, Telenor, UNICEF and Cooperatives, dtac has run extended government authorities are collaborating online marketing training courses Innovating and Researching for to improve the birth registration rates nationwide to help farmers successfully Shared Value using cellular technology. In line with the present and sell their products online. Telenor strives to introduce innovative global goals, the project will empower This has included sessions on the uses of digital communication to improve unregistered children with legal identity essentials of communications people’s lives, with solutions that can that can help curtail child labour, technology, online marketing for address social, economic and trafficking and marriages as well as agricultural products, required resources environmental problems, close the ensure the availability of authentic and for e-commerce, risks of financial scams, inequality gap and empower societies. timely data for better planning and trust protocols as well as workshops on access of public services such as justice, how to build online stores. INNOVATIVE SERVICES AND health, education and immunisation. PROGRAMMES: Telenor is committed to Dtac has also partnered with Thailand’s helping world leaders achieve the UN Given the learning during infrastructure 27 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

development and deployment, which In Thailand, dtac, UNICEF and the In Myanmar, Wave Money, with support among other things included the need for Ministry of Health are continuing their from the UN Capital Development Fund, further time investment in quality work providing users with free mobile is developing a gamified smartphone app capacity-building, the project has been information services to promote healthy to strengthen financial literacy among delayed and will not reach the target for mothers and children. In our systems, we women in remote areas. Through the 2017 to register the births of 700,000 registered more than 280,000 gaming application, people will learn children. Nevertheless, the project has subscribers in 2017. about savings, interest payments and been scaled up to five districts in the insurance while they play. The app will be provinces of Sind and Punjab in 2017. A In 2017, the efforts of Telenor Serbia, launched in 2018. significant ramp-up in design and scale UNICEF and local authorities continued from the pilot, the public birth registration to enable the social inclusion of the Roma Wave Money is working with Save the infrastructure is now digitised in the population in Serbia, including Children to provide income support as target districts and more than 4200 connecting this population to health well as financial literacy training. designated government facilitators are services. Beneficiaries receive transfers via Wave trained and equipped to report births via Money. Through targeted financial Telenor’s mobile-based solution. Financial inclusion: Easypaisa and Wave literacy training, beneficiaries learn how Designated facilitators have started Money, Telenor’s financial services to plan a budget and save for low-level reporting data, with more than 100,000 operations in Pakistan and Myanmar, investments to run a small business. birth reports submitted and 20,000 births service the mass markets. Valyou serves registered as of the end of 2017. The the niche segment of migrants in Easypaisa is supporting the Benazir target set by the partners for 2018 is to Malaysia. Telenor is focusing on initiatives Income Support Programme that register the births of 700,000 girls and aimed at promoting the financial provides income support to boys. inclusion of women. underprivileged families. The female recipients are provided with a monthly disbursement and the beneficiaries use Public birth registration infrastructure is now digitised in Telenor’s target districts and more mobile phones or specially designed ATM than 4200 designated government facilitators are trained and equipped to report births via Telenor’s mobile-based solution cards to cash-out their benefits via a mobile money agent. The programme focuses on empowerment of women to ensure provision and family subsistence. Easypaisa facilitates access to funds in remote areas of Pakistan and currently distributes monies to approximately 1.5 million beneficiaries under this programme.

Extending Life and Health Insurance Services: Telenor Group is offering life and health insurance to customers in several markets. Grameenphone’s Nirvoy Life Insurance increased its customer base to 5,670,000 in 2017. The aim of the service is to act as a mass loyalty product in addition to offering Grameenphone customers a social safety net. Easypaisa’s first mass market health insurance, Sehat Sahara, reached 125,000 subscriptions in 2017.

TELENOR HEALTH: Telenor Health, a digital health subsidiary established by Telenor Group in 2015, leverages 28 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

technology to help make high-quality first-level data extraction in all three health and wellness information, advice countries. Opportunities to undertake a and services accessible to everyone, study of dengue in Malaysia are also particularly people in emerging markets. being explored. We are also looking at other potentially interesting insights to be In Bangladesh, Telenor Health partnered garnered from this kind of research, e.g. with Grameenphone to offer “TonicFree”, studying influenza in Norway. a free service to all active Grameenphone subscribers as part of an Mobile Phones & Health effort to drive both societal impact and Mobile communications are delivered via customer loyalty. The service includes radiofrequency signals that are discounted access to a qualified doctor electromagnetic fields (EMFs). Radio over the phone, discounts on services at base stations are the essential part of the over 200 hospitals, diagnostic centres infrastructure which transmit and receive and pharmacies, health and wellness those signals, and the base stations need content and free “hospital cash” to be located where people use their insurance coverage to help with costs mobile devices. A number of base such as lost wages and medication. By stations will be required, from macro sites end 2017, more than 4.7 million to small cells or in-building systems, to Grameenphone subscribers had joined provide sufficient coverage, signal TonicFree, with the member base growing strength and data capacity to maintain by as much as 20,000 per day. the quality of service that customers now expect. In April 2017, Telenor Health and Grameenphone launched the first two Policy and Actions customer-paid Tonic products, “Tonic At all its base stations and antenna Astha” and “Tonic Shurokkha”. Aimed at installations, Telenor is committed to the emerging middle classes, Astha and adhering strictly to national and concerned, it is important to note that Shurokkha include more comprehensive international guidelines for health and the WHO has concluded that health insurance coverage and free safety. Across Telenor, our business units ‘Considering the very low exposure levels access to doctors via phone and chat, work in accordance with the guidelines and research results collected to date, making high-quality healthcare more provided by national regulations and the there is no convincing scientific evidence accessible. Grameenphone and Telenor International Commission on Non- that the weak radiofrequency signals Health have sold paid Tonic offerings to Ionizing Radiation Protection (ICNIRP). from base stations and wireless networks both business customers and consumers, These guidelines are endorsed by the cause adverse health effects’. including through new channels such as World Health Organisation (WHO) and pharmacies. represent the basis for all our planning, The WHO further states that ‘research installation work and safety measures at has not been able to provide support for RESEARCHING FOR SHARED VALUE: antenna sites. a causal relationship between exposure Based on our 2015 study using big data to electromagnetic fields and self- for the analysis of social good, studying Telenor is also committed to recognising reported symptoms, or “electromagnetic the spread of dengue in Pakistan and the and respecting the public’s interest in hypersensitivity”. However, as mobile and impact of human mobility, Telenor Group acquiring environmental information wireless solutions become ever more has continued our collaboration with about electromagnetic fields, and ubiquitous, concerns about possible Harvard’s TH Chan School of Public striving to provide stakeholders with health risks from the long-term use of Health. Throughout the year, preparatory accurate and relevant information mobile communication solutions or from work for studies on the spreading of relating to installations, services and living near mobile communication towers multi-resistant malaria in a contiguous, products. are voiced in all the countries in which three-nation area (Thailand, Bangladesh Telenor companies operate. and Myanmar), has been conducted. The Status and Ambitions work is 90 per cent on the way towards As far as EMFs in the frequency ranges Even though no harmful effects have so the big milestone of full approval and used for mobile communications are far been proven in research, users may 29 TELENOR SUSTAINABILITY REPORT 2017 RESPONSIBLE BUSINESS AT TELENOR

take precautions to limit their exposure, heavy monsoon rains in Bangladesh installations, enhanced battery backup such as: itself, burst the banks of the rivers and at several base stations, and acquired flooded low-lying Bangladesh. high-tech mobile trailers ready to cater • Using hands-free equipment when Grameenphone came forward to support for communication in crisis areas. Telenor talking on mobile phones those most badly affected through its Norway also has mobile generators, • Avoiding long calls disaster response partner, the which can supply electricity to • Sending SMS/MMS rather than calling Bangladesh Red Crescent Society communication equipment during serious (BDRCS). Grameenphone network teams power failures. In addition, the company For further information:www.telenor.com/ also worked day and night to ensure that runs emergency drills and maintains a sustainability/responsible-business/ the GP network remained, as always, the dialogue with relevant authorities about safe-services/mobile-phones-and- most resilient in the face of such a robustness and emergency response. health. calamity. Many of Telenor’s business units, Service Reliability Tropical storms in August led to severe especially the ones operating in disaster- Reliability of service in all operating areas flooding in the northeast provinces of prone areas, have sound backup plans is key to delivering on the company’s Thailand, which affected dtac’s network and redundancy options to ensure promise to its customers. Telenor installations. Dtac emergency teams service reliability under challenging believes that the infrastructure it surveyed at incident areas and reported circumstances. provides is vital for helping customers back to relevant parties for urgent action. connect and keep safe, especially during Further, dtac coordinated with the times of disaster. Fire, flooding and other government to donate survival kits, and natural and man-made disasters are also provided free air-time to victims in hazards faced by all citizens, and when the incident area. they happen, communication networks are often disrupted. The ability to A storm caused power outages and communicate is essential in supporting transmission interruptions at 35 base disaster relief and saving lives. stations in Montenegro at the beginning of January. Storms and heavy rain in NETWORK AVAILABILITY DURING south, southwest and western Serbia NATURAL DISASTERS: 2017 was also a caused power outages at 106 base year when millions of people were stations in September. In both situations, affected by heavy flooding in our markets power company teams and Telenor teams in Asia. solved power problems at most of the sites quickly, and network operation was In Myanmar, Telenor provided life-saving restored within 24-48 hours. food, water and sanitation items to flood- affected households in Pakokku 2017 started out with relatively calm township, one of the three worst affected weather conditions in Norway and a townships in the Magway Region during stable situation for the Telenor network. the flooding in August. Provision of relief 2017 ended with two storms, Ylva and assistance was carried out by Telenor’s Aina, both with moderate impact on the implementing partner, Network Activities network. Electricity outages and fibre Group (NAG). A solar-powered mobile damage were the main reasons for phone charging station for affected Telenor’s customer impacts. A mobile people helped to keep them connected. mast collapsed due to strong winds during Ylva in November 2017. The mast In August, Bangladesh faced one of the was rebuilt and critical services were worst flood situations in decades. As a re-established before Christmas. Telenor conscious corporate citizen, Norway has, since the Dagmar (third Grameenphone came forward to support strongest storm to hit Norway in 50 those affected. Cascading rain waters years) swept over the country in 2011, from the mountains, coupled with the increased reserve power capacity at its 30 TELENOR SUSTAINABILITY REPORT 2017 HOW TELENOR IMPACT SOCIETIES

HOW TELENOR IMPACT SOCIETIES

Telenor’s global business contributes to society in a multitude of ways. Our digital services impact local economies via direct value creation, innovation and productivity gains in other industries, employment, investments in future value creation, and contribution to public finances via taxes and other levies.

We also believe that our business impacts social standards positively by exercising good corporate governance and compliance with good business conduct, and by enhancing sustainable business practices which drive the focus on social and working conditions in other At Telenor we are committed to UN Sustainable Development Goal #10 Reduced sectors. Inequalities as we believe this is where we can deliver the most impact. We believe the most effective way for us to contribute to this goal is to deliver wider access to our services and to raise the standards of our own work and help raise those of our partners in society. UN Sustainable Development Goals The participation of business in the implementation of the UN Sustainable through working with partners on with accountability and transparency. We Development Goals (SDGs) is critical as a initiatives such as mobile birth aspire to be a trusted company, key driver of innovation and employment. registration, growing children’s resilience recognised for strong business ethics. We Mobile technology has a key role to play, online, and focusing on decent working recognise the sovereign right of all States providing connectivity and services for conditions in our supply chains. We have to introduce new tax legislation and to billions of people around the world. set targets for this work and have amend old legislation. We understand the detailed our progress in this report. From importance of the taxes we pay in At Telenor we are committed to UN services such as mobile money and supporting the development and growth Sustainable Development Goal #10 mobile agriculture, to big data for social of the communities in which we operate, Reduced Inequalities as we believe this is good and mobile health services, we are and take a responsible approach where we can deliver the most impact. making a difference and contributing to respecting our tax obligations. We believe the most effective way for us the Sustainable Development Goals. to contribute to this goal is to deliver We support a stable and transparent wider access to our services and to raise Tax policy fiscal environment that is based on the standards of our own work and help Our commitment universal tax principles, levying tax based raise those of our partners in society. It is Telenor Group’s responsibility and our on predictable legislation applied by ambition to contribute to economic, objective authority, and tested by We are focused on amplifying and environmental and social development in independent court systems. Our aim is to accelerating our impact on the SDGs, countries where we are present, acting engage constructively in dialogue with 31 TELENOR SUSTAINABILITY REPORT 2017 HOW TELENOR IMPACT SOCIETIES

the relevant authorities on tax legislation, Telenor´s Code of Conduct is our tax authorities about our tax affairs, and such as reviews of tax rules and the need backbone, defining the ethical standards provide the information that is necessary for any changes. We support initiatives to for how we all conduct our business. for those authorities to perform their improve international transparency in work in a collaborative, courteous and taxation matters, including OECD Ambitions timely manner. measures on country-by-country Telenor Group shall be a prudent reporting and automatic exchange of taxpayer worldwide, and is committed to Telenor Group aims to apply diligent information. ensuring compliance with all relevant professional care and judgement, legal tax filing, tax reporting and tax including ensuring that all decisions are Governance payment obligations globally. We taken at an appropriate level and Telenor Group has an internal Policy on recognise a responsibility to pay the supported by documentation that Tax. This Policy is approved by our Group correct amount of tax in each of the evidences the judgements involved. We President & CEO. The Policy is owned by jurisdictions in which we operate. We may shall always be able to defend our our Group CFO, who is responsible for the respond to tax incentives and positions, and external advice may be tax strategy, the supporting governance exemptions, and aim to avoid double sought in relation to areas of complexity framework and for management of tax taxation on capital gains and dividend or uncertainty to support the Group in risk. repatriation. Contracts entered into complying with its tax strategy. between separate legal entities within Day-to-day responsibility for each of Telenor Group shall be documented and We aim to manage tax risk in the same these areas sits with the Group Head of be in accordance with the arm’s length way as any other operational risk across Tax, who reports to the CFO and will be principle. the Group. Business heads will generally communicating our tax strategy take the lead role in identifying, throughout the group. Furthermore, We shall be open and transparent with managing and monitoring tax risks within the business. Business heads are required to immediately notify the Tax Policy Telenor Group shall be a prudent taxpayer worldwide, and is committed to ensuring owner regarding matters that may compliance with all relevant legal tax filing, tax reporting and tax payment obligations globally. represent a tax exposure, and continuously update the Tax Policy owner on any subsequent developments.

In international matters, we shall follow the terms of the relevant Double Taxation Treaties and relevant OECD guidelines in dealing with such issues as transfer pricing and establishing taxable presence.

Transparency Concerns with regard to so-called tax havens have been mounting in recent years. Extensive efforts are ongoing internationally to prevent tax evasion and non-disclosure of financial information through the use of tax havens. Norwegian authorities have concluded tax information exchange agreements with a number of new countries. Norwegian requirements for country-by-country reporting have so far only been introduced for large companies and the issuers of listed securities in the extractive and forestry industries. 32 TELENOR SUSTAINABILITY REPORT 2017 HOW TELENOR IMPACT SOCIETIES

Since 2014, Telenor Group has increasingly evident. The vital role of that employs millions in Telenor’s communicated a sincere commitment to digital services was acknowledged in markets. We are a long-term investor, corporate responsibility by voluntarily 2016 when both the European Union and employer and taxpayer. In 2017, Telenor reporting country-by-country incomes several national governments devised invested NOK 23.5 billion from a total and tax contributions. We support digital modernisation strategies, including revenue of NOK 124.8 billion, adding up initiatives to improve international tax in the Nordic countries, Hungary, to an investment ratio of 18.9 per cent transparency, including OECD initiatives Pakistan and Thailand. In 2017, Telenor capital expenditure to revenue (22.8 per for country-by-country reporting and made enhanced contributions to the cent investment ratio in 2016). During the automatic exchange of information. Digital Norway initiative by investing in coming years, Telenor is committed to the Norwegian Industry 4.0 centre investing further in our markets in support Economic Contribution to Society (Toppindustrisenteret). Telenor also of the ambition to capture new growth In this chapter, we report on our engaged in national dialogue with opportunities, enhance internet access economic contribution to society, our governments on improved telecom and connectivity, and improve efficiency. country-by-country contributions to frameworks in Myanmar and Bangladesh. public finances, and our specific In 2016, a study conducted by KPMG contribution to reduced inequalities. Telenor has reported our country-by- quantified Telenor’s economic country earnings, investments, taxation contribution to our 13 countries of There is an increasing focus on the and employment since 2014. We report operation at a total of USD 20.3 billion discrepancy between the positive growth and pay taxes at the legally-obliged level (NOK 163.8 billion) in 2015, divided effects of globalisation and digitalisation, in each country in a responsible and between USD 7 billion (NOK 56 billion) in against the unequal distribution of the transparent way (see notes to the direct gross value added by our own gains of this development. In many Financial Report for details). Telenor business, and a further USD 13.4 billion countries, stable economic growth advises governments to forge tax (NOK 107.8 billion) value added induced combines with stagnant, or even falling systems based on universal tax principles in other companies through our local real incomes for parts of the population. as advocated by the IMF and World Bank, value chains and employee spending. The with universal tax levels across a broad methodology to estimate direct value We believe that we can contribute in two tax base. Tax collection practices should added was further elaborated at basic ways to closing the emerging rest on predictable legislation applied by company level in December 2016 inequality gap. We already contribute to an objective authority, tested by (Telenor Research 05/2016: Telenor in reduced inequalities by providing internet independent courts. Predictable and the National Economy: A Methodology). access, digital and financial inclusion, universal taxation is a crucial safeguard In accordance with global national which again empowers entrepreneurship for efficient investment and affordable accounting conventions, the formula can among those in need of new income. services for everyone. be applied to Telenor where Gross Value Further, our contributions to public Added corresponds to EBITDA plus total finances enable public services in Status and Ambitions personnel cost. On publicly reported education, health, and other services A company contributes directly to the accounting data covering the last four that benefit all. We support the obligation national economy through its years, this yields the following direct of corporate organisations to pay their investments, wages, taxes and fees, and Gross Value Added contribution for lawful and legitimate, due share of taxes indirectly through the similar production Telenor Group: and levies in the countries of local that the company induces in vendors and operation. Still, it is largely in the hands of partners in the value chain. Mobile For Telenor Group as a whole, corporate local governments to ensure that communication creates a vibrant income tax is paid in those countries legitimate tax revenues have a socially ecosystem of large and small businesses where we have our operations. The just effect on society via public services.

Policy and Actions NOK million EBITDA + Total personnel cost = Gross Value Added Telenor is dedicated to enhancing mobile 2014 40,490 11,375 51,865 communication and digital services to facilitate economic development and 2015 43,326 12,406 55,732 better public services. The role of mobile 2016 45,103 13,152 58,255 services and digital access in economic 2017 48,891 12,802 61,693 growth and innovation is becoming 33 TELENOR SUSTAINABILITY REPORT 2017 HOW TELENOR IMPACT SOCIETIES

corporate income tax rate has been Telenor Group follows the terms of reduced in some countries over the last applicable Double Taxation Treaties, few years, which will have an impact on relevant OECD guidelines in dealing with our payable taxes. Entering 2017, Norway transfer pricing and establishing taxable reduced the corporate income tax rate presence, and the recently introduced from 25 per cent to 24 per cent, and in BEPS initiatives. We endorse the aims of 2018 the tax rate will be 23 per cent. In transparency and fairness across the Hungary, the corporate income tax was global tax system, exchange of financial reduced from 19 per cent to 9 per cent in information, and concerted action to the same period. However, corporate fight base erosion and profit shifting. Our income tax (CIT) is only one part of our policy and practice is in line with total tax contributions - we also pay legislation in all our markets. several industry-specific taxes, fees, indirect taxes (VAT, GST, sales tax, etc.) and customs duties.

COUNTRY-BY-COUNTRY REPORTING Financial Year 2017

Corporate Profit income tax Employees *NOK in millions Revenues* EBITDA* Capex* before taxes* (CIT) paid* total per 31.12 Norway 31 490 10 823 7 817 9 318 1 486 5 364 Sweden 15 121 5 560 1 846 4 147 684 1 985 Denmark 5 620 1 116 654 1 580 -344 1 789 Hungary 4 591 1 525 310 1 037 147 1 183 Bulgaria 3 159 1 227 222 664 59 2 169 Serbia 3 374 1 047 267 456 122 1 283 Montenegro 448 150 78 76 11 276 Thailand 18 989 7 571 4 028 981 131 4 532 Malaysia 12 238 5 701 2 580 3 690 978 2 323 Bangladesh 13 155 7 704 1 502 5 031 2 040 3 118 Pakistan 9 185 4 344 1 545 2 518 934 5 570 Myanmar 6 427 2 768 2 551 1 743 460 818

Telenor Group 124 756 48 891 23 543 21 960 6 854 30 800

This table specifies the most important elements of Telenor’s direct economic contribution country-by-country. It includes Telenor’s revenues, EBITDA, capital expenditure, the corporate income taxes paid in 2017 and the number of employees, ex. India. The table does not specify all taxes and fiscal levies – only Corporate Income Tax (CIT) is included. 34 TELENOR SUSTAINABILITY REPORT 2017 SUSTAINABILITY ANALYTICS / NON-FINANCIAL DATA

SUSTAINABILITY ANALYTICS / NON-FINANCIAL DATA

Analytical tool with a new and improved structure and review of the Sustainability Report 2017, A deep dive into Telenor’s sustainability format. The standards are issued by the in particular to assess the accuracy of performance figures is available by Global Sustainability Standards Board claims. The engagement has been downloading the Telenor Group (GSSB), and we use them to report undertaken in accordance with the Sustainability Performance Analytical publicly on our impacts on the economy, requirements in the ISAE 3000 standard tool 2017 where figures are separated the environment and society. GRI as well as DNV GL’s general method for per Business Unit and covers 2012 – represents a universally applicable, assessments of sustainability reporting. 2017 www.telenor.com/sustainability- comparable framework which facilitates performance-analytical-tool. transparency and accountability. Telenor’s GRI index can be found here: GRI index www.telenor.com/sustainability/ Telenor reports its sustainability reporting/gri-index. performance in accordance with the GRI Sustainable Reporting Standards. These Verification statement standards incorporate the key concepts DNV GL has been commissioned by and disclosures from GRI G4 guidelines Telenor to carry out an independent

Fornebu, 20 March 2018

Gunn Wærsted Jørgen Kildahl Chair Vice Chair of the Board

Jon Erik Reinhardsen Jacob Aqraou Grethe Viksaas Sally Davis Roger Rønning Board member Board member Board member Board member Board member

René Richard Obermann Sabah Qayyum Harald Stavn Sigve Brekke Board member Board member Board member President & CEO 35 TELENOR SUSTAINABILITY REPORT 2017 ASSURANCE STATEMENT

ASSURANCE STATEMENT

Independent Limited Assurance Report to the Directors of Telenor ASA

Scope of engagement

Telenor ASA (“Telenor”) commissioned DNV GL Business We have not performed any work, and do not express any Assurance Norway AS (“DNV GL”, “us” or “we”) to conduct a conclusion, on any claims related to Lost Time Incident limited assurance engagement over Selected Information Frequency (LTIF), any financial claims in the section “Economic presented in the 2017 Sustainability Report (the “Report”) for contribution to society”, nor any on other information that the reporting year ended 31st December 2017. may be published in the Report or on Telenor’s website for the current reporting period or for previous periods. Selected information The scope and boundary of our work is restricted to a review Our conclusion of claims within the Report sections (the “Selected Based on the procedures we have performed and the evidence Information”) listed below: we have obtained, nothing has come to our attention that causes us to believe that the Selected Information presented . Sustainability at Telenor in the Report is not fairly stated and has not been prepared, in o Responsible Business Conduct all material respects, in accordance with the Criteria. Strategic Focus on Reducing Inequalities o This conclusion relates only to the Selected Information, and is About the Report o to be read in the context of this Assurance Report, in particular

the inherent limitations explained below. . Responsible Business at Telenor o Corporate Governance Standard and level of assurance o Reporting and Stakeholder Engagement We performed a limited assurance engagement in accordance Ethics and Anti‐Corruption o with the International Standard on Assurance Engagements o Labour Rights and Standards (ISAE) 3000 revised – ‘Assurance Engagements other than Supply Chain Sustainability o Audits and Reviews of Historical Financial Information’ o Human Rights (revised), issued by the International Auditing and Assurance Privacy o Standards Board. This standard requires that we comply with o Cyber Security ethical requirements and plan and perform the assurance o Environment and Climate Change engagement to obtain limited assurance. o Child Online Safety o Digital Access and Outreach DNV GL applies its own management standards and o Innovating and Researching for Shared Value compliance policies for quality control, in accordance with o Mobile Phones & Health ISO/IEC 17021:2011 ‐ Conformity Assessment Requirements o Service Reliability for bodies providing audit and certification of management systems, and accordingly maintains a comprehensive system . How Telenor Impact Societies of quality control including documented policies and o UN Sustainable Development Goals procedures regarding compliance with ethical requirements, o Tax policy professional standards and applicable legal and regulatory o Economic Contribution to Society requirements.

The procedures performed in a limited assurance engagement Please see www.telenor.com/wp‐ vary in nature and timing from, and are less in extent than for, content/uploads/2018/03/Claims‐assured‐by‐DNV‐GL‐ a reasonable assurance engagement; and the level of 16032018.pdf for a detailed presentation of all claims that assurance obtained is substantially lower than the assurance have been reviewed. that would have been obtained had a reasonable assurance

Relevant data and activities between 1st January 2017 and 31st engagement been performed. We planned and performed our December 2017 were sampled to check for consistency work to obtain the evidence we considered sufficient to between claims and actual performance. To assess the claims, provide a basis for our opinion, so that the risk of this which includes an assessment of the risk of material conclusion being in error is reduced but not reduced to very misstatement in the Report, we have used Telenor Group’s low. non‐financial reporting criteria (the “Criteria”), which can be found here www.telenor.com/wp‐ content/uploads/2018/03/Telenor‐non‐financial‐reporting‐ criteria.pdf 1

36 TELENOR SUSTAINABILITY REPORT 2017 ASSURANCE STATEMENT

Basis of our conclusion Our competence, independence and quality

We are required to plan and perform our work in order to control consider the risk of material misstatement of the Selected DNV GL established policies and procedures are designed to Information; our work included, but was not restricted to: ensure that DNV GL, its personnel and, where applicable, ˃ Assessing the appropriateness of the Criteria for the others are subject to independence requirements (including Selected Information; personnel of other entities of DNV GL) and maintain ˃ Conducting interviews with Telenor’s management independence where required by relevant ethical to obtain an understanding of the key processes, requirements. This engagement work was carried out by an systems and controls in place to generate, aggregate independent team of sustainability assurance professionals. and report the Selected Information; Our multi‐disciplinary team consisted of professionals with a ˃ Seven visits to Telenor’s head office in Oslo to combination of environmental and sustainability assurance review processes and systems for preparing market‐ experience. level data consolidated at group level; and ˃ Performing limited sample testing of the Selected Responsibilities of the Directors of Telenor and Information to check that data had been DNV GL appropriately measured, recorded, collated and The Directors of Telenor have sole responsibility for: reported. - Preparing and presenting the claims in accordance

with the Criteria; Inherent limitations - Designing, implementing and maintaining effective All assurance engagements are subject to inherent limitations internal controls over the information and data, as selective testing (sampling) may not detect errors, fraud or resulting in the preparation of the claims that is free other irregularities. Non‐financial data may be subject to from material misstatements; greater inherent uncertainty than financial data, given the - Measuring and reporting the claims based on their nature and methods used for calculating, estimating and established Criteria; and determining such data. The selection of different, but - Contents and statements contained within the acceptable, measurement techniques may result in different Report and the Criteria. quantifications between different entities. Our responsibility is to plan and perform our work to obtain Our assurance relies on the premise that the data and limited assurance about whether the Selected Information has information provided to us by Telenor have been provided in been prepared in accordance with the Criteria and to report to good faith. DNV GL expressly disclaims any liability or co‐ Telenor in the form of an independent limited assurance responsibility for any decision a person or an entity may make conclusion, based on the work performed and the evidence based on this Assurance Report. obtained. We have not been responsible for the preparation of the Report.

For and on behalf of DNV GL Business Assurance Norway AS

03.04.2018

Jørgen Hanson Gareth Manning Principal Consultant and Lead Assuror Principal Consultant and Reviewer DNV GL – Business Assurance DNV GL – Business Assurance

2

www.telenor.com

2181022 • Bolt Communication AS • boltcommunication.no