Management approach

Explanation of the material topic and its Boundary

Please see below for a presentation on how Telenor measures and manages its material aspects. More information and process details can be found in the materiality assessment description here  (103-1a).

For Telenor, all material topics are relevant throughout our value chain, unless otherwise stated in the table below (103-1b and c).

Where relevant, any adjustments or limitations regarding boundary of a topic will also be found in the table (103-1c).

The management approach and its components – How we manage it

For Telenor, the purpose of the management approach is to control major risks and opportunities for all material topics, regardless of whether they are financial or non-financial. Therefore, material topics are in principle governed in the same way as described in our approach to Corporate Governance in general.

This main document is complimented by a set of key group policies with more detailed information about roles, responsibilities, and commitments for the material topics:

For further information, please see table below (column “How we manage it”) and also Telenor’s website on Corporate Governance

For commitments targets and actions on our material aspects, please see the relevant section in the Telenor Sustainability Report as part of the Telenor Annual Report 2020

Evaluation of the management approach

Each material topic has a corresponding chapter in the Sustainability part of the Annual Report where we also provide an evaluation of the management approach. Page references and any exemptions from the GRI standards may be found in the table starting next page.

Additional information on GRI 103-2 and GRI 103-3 can be found in the table below:

Material aspects as in GRI 102-47
How we manage it How it is monitored Targets and Results 2020
Digital Inclusion

– access to the service in all markets, including rural and remote areas. In emerging markets focus on bridging the digital divide.

The importance of ensuring access for all is essential to Telenor’s effort to empower societies.  Telenor sees this development as integral with the company’s commitment to reduce inequalities in the societies where it operates.  This is part of Telenor’s business strategy and is managed accordingly throughout the entire Group. We carefully track and report development of network capacity and coverage. This is reported all the way to top management at regular intervals.


Telenor Annual Report 2020 page 22 and 69 Digital Inclusion


Social Innovation

including solutions with social benefits, such as mFinance, mHealth, mAgri, mEducation, mGovernment, mWomen and smart working.

Given the nature of this material aspect, it is difficult to establish a separate governing document; however, it is a key focus in our strategy, firmly placing a responsibility throughout the business units with a coordinating responsibility at Group Sustainability.


Monitored and followed up by counting number of birth registrations and other indicators The different results are communicated to Group for continuous evaluation and improvement.



Telenor Annual Report 2020 page 67 and Social Innovation


Respect for Human rights

– ensuring that operations or business relationships do not infringe on human rights, -respecting the human right of freedom of expression

Telenor’s Code of Conduct, Policies, Supplier Conduct Principles and Our Culture, provide the Telenor Group with a common approach as to how we treat each other, how we serve our customers, how we run our business and what we believe our role to be in the societies where we operate. Detailed reporting on how we work with Human Rights can be found in our annual report. As part of our membership with the GNI, we have committed to implement the GNI Principles and undergo an independent assessment every two years to assess progress on this commitment. Telenor Annual Report 2020 -page 69 Respect for Human rights – Ambitions and targets
Customer and employee privacy framework

-keeping information safe and secure, being transparent about how we handle your data

Telenor’s customers expect not only real-time, relevant, and individualised services, they also expect that their privacy is safeguarded. As a provider of mobile and internet connectivity, respect for the rights to privacy and freedom of expression is central to Telenor’s core business. The company approaches these issues from a privacy point of view as well as a security angle, with policies and manuals that set out mandatory requirements applying across all operations. Telenor Annual Report 2020 page 71 – Ambitions and targets
Cyber security

– avoiding information being overused for commercial or other purposes or stolen

As a network operator and a global provider of digital services, Telenor is at constant high risk of cyber-attacks. Advanced threat actors are increasingly aiming to steal information, modify customer data or make our services unavailable. Telenor is continuously implementing security capabilities to prevent and reduce the effect of a range of threats, including the ability to swiftly detect and respond to unwanted activities. Alignment with our approach and governing principles is carefully monitored by our security functions.


Telenor Annual Report 2020 page 22 and 72 Cyber security – Ambitions and targets



Mobile communications and health 

– including electromagnetic fields from masts and mobile phones, user complaints concerning issues such as radiation, radio waves and Wi-Fi

Whenever Telenor installs new network equipment, we ensure public health and safety by adhering strictly to the electromagnetic exposure guidelines of the International Commission on Non-Ionizing Radiation Protection (ICNIRP). These guidelines are endorsed by the World Health Organisation (WHO). The responsibility lies with each business unit. Since all business units must work in accordance with national and international guidelines and these represent the basis for all our planning, installation work and safety measures at antenna sites; this is monitored by the line management Telenor Annual Report 2020 page 73 – Mobile masts and health – Ambitions and targets
Economic contribution to society

– includes investments in local communities, including job creation, skills development, charitable contributions, tax and licenses

The topic is an integrated part of our financial governance system.


In addition to following international accounting standards, Telenor has reported direct, country-by-country impact on investment, taxation, and employment, since 2014. Telenor Annual Report 2020 page 74 Economic contribution to society


Corporate governance framework

– including policies ensuring board independence, board diversity, remuneration and responsibility and accountability of the board


Telenor’s corporate governance principles and practices define a framework of rules and procedures for the way business is governed and controlled in all Telenor business units. The governance framework is used as a platform to integrate material sustainability issues into its business strategies, daily operations, and relationship with stakeholders. Business Unit performance reviews are conducted regularly with each of the main BUs in the Telenor Group, and are chaired by the Group CFO with participation from other relevant functional EVPs. The purpose of these meetings is to monitor and follow-up key strategic priorities, financial and operational performance relative to defined targets. Telenor Annual Report 2020  page 36, 37



– including anti-corruption and bribery, anti-competitive behaviour

Telenor has zero tolerance for corruption. Our ethical standards promote proper business practices and reflect relevant laws, regulations, and internationally recognized standards. These standards are set out in our Code of Conduct, the Group Policy on Anti-Corruption, Group Policy on Third Party Risk, and other guidance and governing documents. Ensuring the right corporate governance platform for ethics, anti-corruption, and transparency, undertaking social and environmental responsibility, and respecting human rights and labour rights, is monitored and managed through our Code of Conduct and other guiding documents Telenor Annual Report 2020  page 68 Anti-corruption – Ambitions and targets
Transparency and stakeholder engagement

– includes provision of timely, accessible, and accurate disclosure of performance, goals and policies related to sustainability activities.


These topics are managed through a combination of following public reporting requirements as well as being an active participant in several regional and international initiatives (Global Compact, GNI, GRI, etc.). Telenor believes good corporate governance involves accountability, responsibility, transparency, fairness, and effective engagement between all internal and external stakeholders. In addition to internal overview and control, our actions, results, and reporting is monitored both through independent third-party assurance as well as various interactions with local stakeholders. Telenor Annual Report 2020 – page 14 and 63


Employee diversity, equality, and inclusion

-including diversity, attraction and retention of the best people, training and development opportunities and career prospects


At Telenor, attracting and retaining the best talent through learning and development opportunities as well as career prospects is fundamental to continued competitiveness and growth. Telenor also strives for diversity, inclusion, and equal employment opportunities in accordance with the People Policy. Responsibility of tracking policy requirements, goals and targets lies with the line management. Group People and Sustainability oversees the process.



Telenor Annual Report 2020 – page 75 – Ambitions and targets


Employee health, safety, and security

– covers employees as well as in-house contractors, vendors, and suppliers


Telenor sets high standards in health, safety, and people security (HS&S). Maintaining a working environment and a culture that nurture HS&S is important at Telenor. Telenor is committed to learn from experience and continuously improve its efforts within HS&S. Responsibility of tracking policy requirements, goals and targets lies with the line management and Group People and Sustainability oversees the process.



Telenor Annual Report 2020 – page 78 – Ambitions and targets



Supply chain risk and resilience

– including human rights, occupational health, safety and personnel security, environment, conflict minerals, hazardous materials, etc.


Telenor strives for high sustainability standards and continuous improvement in its operations throughout the supply chain and works to ensure that its suppliers take a similar approach. Telenor’s approach to supply chain sustainability is to legally oblige the supplier to uphold responsible business practice, monitor compliance with Telenor’s requirements and to undertake capacity-building among its suppliers.


Telenor carries out inspections to monitor compliance with the requirements on responsible business conduct. Telenor Annual Report 2020  page 22 and page 80 – Ambitions and targets


Labour standards / Employee Rights

– relate to respecting the rights to freedom of association and collective bargaining, the elimination of forced labour, child labour and discrimination in the workplace, etc.

Telenor is committed to respecting labour rights principles as laid down in the UN Global Compact and International Labour Organization’s fundamental conventions. These principles are reflected in Telenor’s Code of Conduct, Group People Policy and Supplier Conduct Principles. Upholding labour rights will also be crucial when addressing the future of work, as professions evolve due to automation and the energy transition. Telenor is promoting

partnerships based on good and trusting dialogue, e.g.

in relation to acknowledged unions or through local

cooperation bodies such as the People Council.


Telenor Annual Report 2020  page 77 – Ambitions and targets


Climate change resilience

– including energy efficiency, energy use and reduction of greenhouse gas emissions– as well as services and technologies that enable society/ customers to reduce their climate impact

Climate change is today one of the greatest challenges facing people, businesses, and governments. Climate related risks include potential damage to vital infrastructure and utilities through the impact of more extreme weather events. Please see Climate impact


Energy use and emissions are closely monitored and followed up in all operations in line with the Group Sustainability Policy.


Telenor Annual Report 2020  page 82
Environmental management

– including EMS and waste management, circular economy, energy efficiency, energy use and reduction of greenhouse gas emissions

Telenor is committed to protecting the environment and contributing to the prevention of climate change.

Please see Environmental Management



Environmental Management Systems (EMS) in line with ISO 14001 shall be in place and followed-up in all business units. Telenor Annual Report 2020  page 82