Telenor : GRI Report 2022

Telenor Content Index 2022

GRI Sustainability Reporting Standards

Preface

Telenor supports the Global Reporting Initiative (GRI) - as an Organisational Stakeholder - and its initiatives to drive sustainability reporting. Telenor reports in accordance with the GRI Sustainability Reporting Guidelines.

Statement of use

Telenor ASA has reported in accordance with the GRI Standards for the period 1 Jan 2022 - 31 Dec 2022.

Scope of the reporting is Telenor ASA and all Telenor's subsidiaries directly controlled by Telenor ASA ("business units").

Materiality assessment

In 2022, Telenor performed a double-materiality assessment conducted in line with the European Union's

Corporate Sustainability Reporting Directive (EU CSRD), the draft European Sustainability Reporting Standards (ESRS) and the guidance of the Global Reporting Initiative (GRI) 2021.

The scope of the assessment was a corporate-wide qualitative assessment and a high-level strategic prioritization. Risks, opportunities and impacts were identified depending on where the impact lies in the value chain - direct operations, suppliers, or end-users. Where risks, opportunities or impacts differed, the assessment highlighted the highest risk.

The materiality assessment process consisted of five main steps:

• 1. Identification of sustainability topics relevant to Telenor based on guidance and requirements as set in the relevant reporting standards including GRI, EU CSRD and ESRS (drafts), SASB, TCFD recommendations, GHG protocol, SDGs, UN Global Compact, etc.

• 2. Desktop research and draft scoring based on:

  • o Internal Telenor documentations including previous assessments conducted by Telenor such as the Corporate-wide Climate and Human Rights Impact Assessments

  • o Public resources and BSR expertise

  • o The risks identified by Telenor's enterprise risk management process

  • o Feedback from external analysis and rating of Telenor's ESG performance

• 3. Focus group interviews to identify and assess impacts and collect feedback on draft ratings:

  • o Methodology aligned with Telenor's Enterprise Risk matrix (severity and likelihood)

  • o 20 internal stakeholders interviewed from across different levels and regions in the Telenor organisation

  • o 7 external stakeholders interviewed - including suppliers, investors, industry associations, Non-Governmental Organisations

  • o Identification and analysis of the impacts in each material topic:

    • o Impact on Society and Environment - the criteria for assessing impact on society and the environment are set by global standards (GRI, EU CSRD, etc), considering scale, scope, and remediability.

    • o Impact on Business (risks and opportunities) - the criteria for assessing impact on business leverage Telenor's Enterprise Risk Management framework (severity and likelihood)

• 4. Revising assessment based on quantitative and qualitative input from stakeholders.

• 5. Validating results in a workshop with internal stakeholders.

The analysis identified a long list of 20 topics, split into Environmental, Social and Governance topics and prioritised the top 12 most material topics for Telenor, based on the significance of impact to society and

environment, impact on business, and the link to the company's strategic objectives. These top priority material

topics and corresponding GRI disclosures include:
TELENOR TOP PRIORITY MATERIAL AREA	CORRESPONDING GRI DISCLOSURE
Climate Adaptation	GRI 302: ENERGY 2016
GRI 305: EMISSIONS 2016
GRI 308: SUPPLIER ENVIRONMENTAL ASSESSMENT 2016
Climate Mitigation & Energy Use	GRI 302: ENERGY 2016
GRI 305: EMISSIONS 2016
GRI 308: SUPPLIER ENVIRONMENTAL ASSESSMENT 2016
Digital Skills & Inclusion	N/A
Online Safety	N/A
Diversity, Equity & Inclusion	GRI 401: EMPLOYMENT 2016
GRI 404: TRAINING AND EDUCATION 2016
GRI 405: DIVERSITY AND EQUAL OPPORTUNITY 2016
Occupational Health, Safety & Wellbeing	GRI 403: OCCUPATIONAL HEALTH AND SAFETY 2018
Forced labour	GRI 409: FORCED OR COMPULSORY LABOR
2016
Cybersecurity	N/A
Data protection	N/A
Freedom of expression & Privacy	GRI 418: CUSTOMER PRIVACY 2016
Anti-corruption	GRI 205: ANTI-CORRUPTION 2016
Responsible Supply Chain	GRI 204: PROCUREMENT PRACTICES 2016
GRI 308: SUPPLIER ENVIRONMENTAL ASSESSMENT 2016
GRI 414: SUPPLIER SOCIAL ASSESSMENT 2016

Section Material Areas & Key Highlights 2022 of Telenor's 2022 Annual Report outlines the level of impacts, risks and opportunities as identified by the materiality assessment process. The company will continue focusing on risks mitigation of material areas, and how these are integrated in the operational management and including business development.

The content in the report is to the best of our knowledge the most correct information available.

External Assurance

EY has carried out an independent limited assurance of Telenor's Sustainability Report 2022 to assess the accuracy of claims. The engagement has been undertaken in accordance with the International Standards on Assurance Engagements (ISAE) 3000 (Revised) Assurance engagements Other Than Audits or Reviews of

Historical financial information ("ISAE 3000 (Revised)"). Reported indicators from the following sections of the present index have also been within the scope of the assurance: GRI 3: MATERIAL TOPICS DISCLOSURES, GRI 302: ENERGY 2016; GRI 305: EMISSIONS 2016; and GRI 308: SUPPLIER ENVIRONMENTAL ASSESSMENT 2016. EY's attestation letter can be found onhttps://www.telenor.com/sustainability/reporting-our-performance/reporting-and-verification/

TELENOR GRI INDEX REPORT 2022

Statement of use GRI 1 used Applicable GRI Sector Standards(s)	Telenor ASA has reported in accordance with the GRI Standards for the period 1 Jan 2022 - 31 Dec 2022.
GRI 1: Foundation 2021
No sector guidelines apply

GRI

Disclosure

GRI 2: GENERAL DISCLOSURES 2021

Location

Omission

2-1	Organizational details
2-2	Entities included in the organization's
sustainability reporting
2-3	Reporting period, frequency and contact
point
2-4	Restatements of information
2-5	External assurance
2-6	Activities, value chain and other business
relationships
2-7	Employees
2-8	Workers who are not employees
2-9	Governance structure and composition
2-10	Nomination and selection of the highest
governance body
2-11	Chair of the highest governance body
2-12	Role of the highest governance body in
overseeing the management of impacts
Sensitivity: Open

Name: Telenor ASA

Ownership & legal form:Articles of Association HQ location: Fornebu, Norway

Countries of operation:https://www.telenor.com/about/our-companies/nordics/

2022 Annual report, Sustainability Report chapter, section Reporting Frameworks and Verification

1 Jan 2022 - 31 Dec 2022

Frequency: Annual- aligned with financial reporting

Date of publication of 2022 Annual Report: 28 March 2023 Contact point: Teodora Mitrovska-Forbord, Director Sustainability, E-mail:[e-mail]

2022 Annual Report - Sustainability Report chapter, section Reporting Frameworks and Verification

An independent limited assurance of the content of the 2022 Sustainability Report has been done by EY. Attestation letter available onhttps://www.telenor.com/sustainability/reporting-our-performance/reporting-and-verification/

2022 Annual Report, Sustainability Report chapter, section Responsible Supply Chain

2022 Annual Report, Sustainability Report chapter, Section Diversity & Inclusion and section Key ESG Figures

2022 Annual Report, Sustainability Report chapter, section Responsible Supply Chain and section Health, Safety, People Security and Wellbeing

Corporate Governance Report as part of 2022 Annual Report

Corporate Governance Report as part of 2022 Annual Report, section 9 The Work of the Board of DirectorsTelenor Corporate Governance

Group Leadership Team

Corporate Governance Report as part of 2022 Annual Report, section 7 Nomination Committee

The chairperson of Telenor's board of directors is not an executive officer. Corporate Governance Report as part of 2022 Annual Report

Corporate Governance Report as part of 2022 Annual Report

GRI	Disclosure	Location 2022 Annual report, Sustainability Report chapter, section Sustainability Governance	Omission
2-13	Delegation of responsibility of managing impacts	2022 Annual report, Sustainability Report chapter, section Sustainability Governance
2-14	Role of the highest governance body in sustainability reporting	2022 Annual report, Sustainability Report chapter, section Sustainability Governance
2-15	Conflict of interests	Corporate Governance Report as part of 2022 Annual Report, section 9 The work of the Board of Directors 2022 Annual report, Sustainability Report chapter, section Integrity Hotline Telenor Code of Conduct
2-16	Communication of critical concerns	2022 Annual report, Sustainability Report chapter, section Integrity Hotline Corporate Governance Report as part of 2022 Annual Report
2-17	Collective knowledge of the highest governance body	Corporate Governance Report as part of 2022 Annual Report
2-18	Evaluation of the performance of the highest governance body	Corporate Governance Report as part of 2022 Annual Report
2-19	Remuneration policies	2022 Executive Compensation Report
2-20	Process to determine remuneration	2022 Executive Compensation Report
2-21	Annual total compensation ratio	2022 Executive Compensation Report 2022 Annual report, Sustainability Report chapter, section Diversity & Inclusion
2-22	Statement on sustainable development strategy	2022 Annual report, Board of Directors Report chapter, section Strategy and Key Milestones 2022 Annual Report, Sustainability Report chapter, section Strategy and Direction
2-23	Policy commitments	Our commitments are based on a wide range of standards and frameworks. These are described in the respective material areas sections of the E - Environmental, S - Social and G - Governance chapters in the 2022 Annual Report Sustainability Report chapter