SUSTAINABILITY REPORT 2019

CONTENT
STATEMENT FROM THE CEO	
3
SUMMARY OF 2019	
4
SUSTAINABILITY AT TELENOR 	
5
About the report	
5
Responsible business conduct in Telenor	
5
RESPONSIBLE BUSINESS PERFORMANCE	
6
Corporate governance	
6
Code of Conduct	
6
Anti-corruption 	
7
Employee involvement	
7
Building a diverse and inclusive culture 	
8
Health, safety and people security	
8
Supply chain risk management	
9
Human rights impact	
10
Customer privacy	
10
Cybersecurity	
11
Climate impact and environmental management	
12
Digital inclusion 	
13
Social innovation	
14
Safe use of mobile communications	
15
HOW TELENOR IMPACTS SOCIETIES	
15
Tax position	
16
Economic contribution to society	
16
HOW TELENOR HELPS EMPOWER SOCIETIES: SDG IMPACT	
17
ESG METRICS 	
18
Analytical tool	
18
GRI index	
18
Verification statement	
18

At the time of writing, the world is 
grappling with a public health crisis. In 
every society, people are exploring new 
ways of educating their children, 
running their businesses and 
maintaining critical societal functions. 
The health and welfare of millions of 
people are at stake.  When a crisis like 
COVID-19 hits, it is a reminder of our 
shared commitment and responsibility 
to support the societies we are part of. 
At Telenor, we have a purpose, which is 
about connecting people to what 
matters most and empowering societies. 
In the light of the COVID-19 situation, 
this purpose is more relevant than ever.
Mobile technology is already at work to 
help the world address the current 
crisis. Telenor is involved in a range of 
initiatives to assist government 
agencies and to help people and 
businesses cope with the disruption 
they face. Our commitment to 
responsible business conduct and our 
ambition of empowering societies 
remain firm. In 2020 and beyond, we 
will continue to explore new ways of 
creating positive impact for customers 
and societies.
At Telenor, we fully support the UN’s 
2030 Agenda for Sustainable 
Development and the Global Compact 
Principles. Together with our partners, 
customers and stakeholders we are 
striving to raise standards in our 
operations and supply chains. Across 
our markets, we are providing access to 
services and opportunities that help the 
world deliver on the UN Sustainable 
Development Goals. The empowering 
capabilities of mobile phones have led 
us to focus particularly on SDG 10, 
“Reduced Inequalities”. 
Climate change is the greatest 
challenge of our generation. Over the 
last decade, Telenor has strived to 
deliver transparent reporting of our 
emissions. We have focused on energy 
efficiency initiatives in our network 
operations, understanding climate-
related risks and the business potential 
for delivering climate-friendly 
technologies. Going forward, we will 
step up these efforts and seek to further 
reduce our carbon footprint. Our people 
and our culture are at the heart of our 
commitment to sustainability. We all 
share the same ambition, as SDG 10 is 
part of our global business strategy. We 
are confident that by providing access 
to essential services and by contributing 
to improved working and operating 
standards, we will foster inclusion and 
empowerment in all the markets we 
serve.
Sigve Brekke, President & CEO 
Telenor Group
CONNECTED TO WHAT MATTERS MOST
	
TELENOR SUSTAINABILITY REPORT 2019
3

DIVERSE WORKFORCE
Telenor Group employed close to 20,000 as 
of year end 2019 (including DNA), of which 
37% are women. 30% of senior leadership 
positions are held by women, a 2% increase 
from 2018.
SUPPLY CHAIN SUSTAINABILITY
Telenor carried out 3,600 supplier 
inspections resulting in 650 major 
nonconformities, 81% of which were closed 
by year end 2019. In addition, the business 
units carried out close to 25,000 man-hours 
of capacity building among our suppliers.
ETHICS AND COMPLIANCE
In 2019, 704 incoming reports were logged 
through the Integrity Hotline. Reporting volume 
per 100 employees in 2019 was 3.2, an increase 
from 2018 and 2017.
SOLAR ENERGY 
By year end 2019, Telenor has installed solar 
energy solutions for close to 3,000 base 
stations in Asia up from 2,500 in 2018
DIGITAL BIRTH REGISTRATION
By year end 2019, more than 780,000 children 
have been registered in five districts of Pakistan 
through Telenor’s Digital Birth Registration 
solution.
CHILD ONLINE SAFETY
During 2019, training on how to be safer 
online has been delivered to 1.2 million 
children, resulting in the education of a total 
of 3.3 million children and young people.
CLIMATE FOOTPRINT
In 2019, Telenor’s total carbon emissions 
increased by approx. 9%, while carbon 
emissions per petabyte of mobile data traffic
decreased by approx. 29%, since the total
mobile data traffic increased by approx. 51%
- all data compared to 2018.
REDUCED INEQUALITIES 
We are committed to all UN Sustainable 
Development Goals and have a particular 
opportunity through our business to advance 
SDG 10 Reduced Inequalities.
RESPONSIBLE 
BUSINESS  
Responsible business 
and sustainability is 
an integral part of 
Telenor’s business 
strategy. It is about 
how we do business.
SUMMARY OF 2019
TELENOR SUSTAINABILITY REPORT 2019	
4

SUSTAINABILITY AT TELENOR 
About the report
Telenor publishes this Sustainability 
Report in accordance with reporting 
requirements mandated by the 
Norwegian Accounting Act §3-3c and the 
EU non-financial reporting directive. The 
report covers what Telenor does to 
promote, uphold and recognise human 
rights, labour rights, social issues, 
climate and environment issues, and 
anti-corruption measures into the 
business strategy, daily operations and 
relationship with stakeholders. The report 
covers information on policies, principles, 
procedures and standards the company 
uses to integrate the above 
considerations. In addition, other 
material issues, in-line with stakeholder 
expectations as well as Oslo Stock 
Exchange’s guidance on the reporting of 
corporate responsibility, are addressed. 
The Finnish company DNA was 
consolidated on 21 August 2019. DNA 
publishes its own sustainability report for 
2019, and this report does not include 
sustainability performance data from 
DNA’s operation in 2019.
DNV GL has been commissioned to carry 
out an independent review of the 
Sustainability Report, in particular to 
assess the accuracy of claims. 
More information at www.telenor.com/
sustainability/reporting/scope-and-
principles.
Responsible business conduct in 
Telenor
The foundation for Telenor’s strategy is 
its purpose: Connecting you to what 
matters most - empowering societies. 
Telenor is committed to responsible 
business conduct, and is driven by the 
ambition to reduce inequalities and 
empower societies.
Telenor fully supports the UN Global 
Compact Principles, and together with 
customers and partners, is well 
positioned to help deliver on the UN 
Sustainable Development Goals (SDGs). 
Telenor has chosen to focus particularly 
on SDG 10 Reduced Inequalities, which is 
embedded in the global business 
strategy. The company has set itself SDG 
10-related targets by the end of 2020, 
and has been reporting on progress since 
2016.
Telenor’s efforts to reduce inequalities 
include both providing access to services 
that foster inclusion and empowerment, 
and striving to raise working conditions 
and operating standards wherever 
Telenor is present. 
Access to services includes promoting 
digital inclusion by extending 
connectivity, building digital skills and 
resilience, and stimulating digital identity 
projects. This also includes making 
available financial inclusion services, 
health and education services, and big 
data/machine learning/AI solutions to 
further enhance and personalise 
services. 
Furthermore, Telenor is striving to raise 
standards in its operations and supply 
chain. This includes increasing employee 
involvement, promoting health, safety 
and people’s security, and reinforcing 
supply chain risk management. This also 
includes respecting and supporting 
human rights, protecting customer 
privacy, strengthening cybersecurity, 
maintaining standards of safe mobile 
Telenor has set long-
term targets towards 
2030 to reduce 50 
per cent CO2 emissions 
in Asian operations 
and 100 per cent CO2 
emissions in Nordic 
operations.
	
TELENOR SUSTAINABILITY REPORT 2019
5

communication, and implementing 
diversity and inclusion policies. Climate 
change is a defining agenda of our times, 
and Telenor has set long-term targets 
towards 2030 to reduce 50 per cent CO2 
emissions in Asian operations and 100 
per cent CO2 emissions in Nordic 
operations.
Telenor’s business environment will 
become increasingly complex as 
digitalisation and the demand for 
connectivity proliferates. Some of the 
markets in which Telenor operates are 
emerging economies, with potentially 
complex and sensitive political and social 
contexts. Telenor continues to deploy 
sound corporate governance 
mechanisms, continuous focus on 
Telenor’s Code of Conduct and anti-
corruption measures, as well as 
processes to respect and support human 
rights.
Telenor faces a more severe threat 
landscape, higher expectations from 
customers and stakeholders, as well as 
increasing regulations and legislation. 
The company actively engages with 
stakeholders, and will continue 
strengthening its relations as a long-term 
owner and business partner, committed 
to its values and to the ambition of 
reducing inequalities and empowering 
societies. 
In 2020, responsible business conduct at 
Telenor will continue to focus on the most 
critical business environment risks, 
seizing the opportunity to generate 
positive long-term value and meeting 
stakeholder expectations. Strengthening 
awareness, accountability and 
transparency will remain key to securing 
our licence to operate and ensuring 
ethical and responsible business 
practices. Telenor will also continue to 
raise standards in its operations and 
supply chain, and will provide access to 
services and skills for a digital future to 
positively impact societies where it 
operates. 
More information at www.telenor.com/
sustainability/strategic-direction.
RESPONSIBLE BUSINESS 
PERFORMANCE
Corporate governance
Telenor Group’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. 
Each business unit adopts the relevant 
and agreed governing documents. The 
governance framework is used as a 
platform to integrate material 
sustainability issues into business 
strategies, daily operations and 
relationship with stakeholders.
More information on Telenor’s principles 
and practices for corporate governance 
can be read in Telenor’s Report on 
Corporate Governance in the Annual 
Report of 2019 on page 16–39, and at 
www.telenor.com/about-us/corporate-
governance.
Code of Conduct
Policy and actions
The Telenor Code of Conduct is owned 
and approved by the Group Board of 
Directors. The Code of Conduct embodies 
Telenor’s commitment to high ethical 
standards. Telenor strives to be a trusted 
partner of all customers, shareholders, 
vendors and employees, and to the 
communities where Telenor operates. 
Telenor’s business depends on this trust, 
and Telenor is committed to conducting 
its business in a responsible, ethical and 
lawful manner. 
Telenor’s commitment to integrity and 
transparency is stated in the Code of 
Conduct. The principles of transparency 
at Telenor are part of the corporate 
governance framework and are 
implemented within company operations.
The Code is applicable to all Telenor 
employees, board members and hired 
personnel. The Code is available on 
digital platforms and all devices, with 
links and drill-down functionalities, which 
provide immediate access to Telenor’s 
governing document framework. 
It is viewed as a sign of openness and 
trust that employees, suppliers and other 
stakeholders speak up about possible 
non-compliance with the Code of 
Conduct. This allows us to address their 
concerns, investigate and take 
disciplinary action when needed, and to 
learn from and prevent similar issues 
from reoccurring. Managing breaches of 
the Code of Conduct is an important part 
of Telenor’s compliance programme.
To encourage a speak-up culture, Telenor 
has established a global external 
reporting hotline, the Integrity Hotline, 
which is a confidential channel where 
anyone can ask questions or raise 
concerns about misconduct. The Integrity 
Hotline is available at secure.ethicspoint.
eu/domain/media/en/gui/102575/index.
html.
Status and ambitions
In 2019, 18,292 employees completed 
the eLearning programme for the Code of 
Conduct with dilemma training, and 
signed the Code of Conduct, which 
represents 100 per cent of the work force 
in scope. 
In 2019, 704 incoming reports were 
logged through the Integrity Hotline, of 
which 38 per cent were submitted 
anonymously. The reporting volume per 
100 employees in 2019 amounted to 3.2, 
which indicates an increase compared to 
both 2018 and 2017.
All incoming reports are assessed by the 
centralized Group Investigation  team. 
The reports that are assessed to meet 
defined criteria on materiality,  are further 
handled by Group Investigation. From 1 
January to 31 December 2019, the Group 
Investigation team initiated 19 
investigations and completed five 
Investigations that were started in 2018. 
TELENOR SUSTAINABILITY REPORT 2019	
6

At year end 2019, three investigations 
remained open. About 48 per cent of the 
incoming reports were concerns 
pertaining to other parts of the 
organisation, falling below the threshold 
for Group Investigation, and thus 
followed up by line management or HR.
Group Internal Audit and Investigation 
handles the investigation of alleged 
breaches of the Code whereas the 
Compliance Function handles the 
resolution of substantiated breaches. 
Investigated cases and its resolutions are 
reported regularly to both the Board 
Sustainability and Compliance 
Committee and the Board of Directors. 
The resolution of substantiated cases 
may involve disciplinary actions towards 
individuals and corrective actions, which 
strengthen Telenor’s policies or 
procedures. 
More information at www.telenor.com/
about-us/corporate-governance/
governance-in-telenor.
Anti-corruption 
Policy and actions
Telenor has zero tolerance for corruption, 
and the Code of Conduct prohibits 
corrupt conduct in all business activities. 
Telenor’s management sends clear, 
unambiguous and regular messages to 
all employees and business partners that 
any form of corruption is unacceptable. 
Telenor has implemented a risk-based 
Anti-Corruption Compliance Programme 
to prevent, detect and remedy corruption 
risks in all subsidiaries directly or 
indirectly controlled by Telenor Group. 
Where Telenor is not a controlling owner, 
these companies are required to comply 
with an ethical standard that is consistent 
with Telenor’s, and to operate within a 
risk-based compliance framework. Risks 
relating to corruption include bribery and 
trading in influence.
Status and ambitions
Telenor seeks to work with business 
partners who share its commitment to 
ethics and compliance and, in 2019, 
Telenor strengthened its processes 
around third-party background checks 
by establishing a digital platform to more 
effectively gather, manage and use 
information related to its vendors.
LOOKING AHEAD: Telenor also seeks to 
support its employees identify corruption 
risks and, in 2020, Telenor will 
strengthen its Anti-Corruption eLearning 
programme. The eLearning programme 
aims to build awareness and empower 
Telenor’s employees to manage the risks 
that they may face. Telenor will further 
develop the anti-corruption risk 
assessment and reporting processes to 
ensure that risks are identified and 
properly managed.
More information at www.telenor.com/
about-us/corporate-governance/anti-
corruption.
Employee involvement
Policy and actions
Telenor is committed to respecting labour 
rights principles as laid down in the UN 
Global Compact and International Labour 
Organisation (ILO)’s fundamental 
conventions. These principles relate to 
respecting the rights to freedom of 
association and collective bargaining, 
the elimination of forced labour, child 
labour, and discrimination in the 
workplace, and are reflected in Telenor’s 
Code of Conduct, Group People Policy 
and Supplier Conduct Principles. 
Telenor believes in empowering 
employees through management 
dialogue with employees and their 
recognised employee representatives, 
and by utilising the employees’ 
experiences and insights to influence 
working conditions and contribute to 
sustainable business growth. Telenor 
Group is, throughout its operations, 
promoting partnerships based on good 
and trusting dialogue, for example in 
relation to acknowledged unions, or 
through local cooperation bodies such as 
the People Council. 
All workforce restructuring in Telenor 
shall be done with the aim of creating and 
sustaining long-term business value. 
Workforce restructuring shall be done in 
a responsible manner, through verifiable 
processes and in accordance with 
Telenor’s purpose and behaviours, and 
applicable legal requirements and 
legislation. 
Status and ambition 
In 2019 the Telenor Works Council – 
Europe (TWC-E) held two meetings, one 
in the spring and one in the autumn, 
where European employee 
representatives met with the Telenor 
Group Management. After the acquisition 
of DNA in Finland, employee represen­
tatives from DNA participated as 
observers and will be members of TWC-E 
from 2020 onwards.
Additionally, Telenor has continued its 
commitment to promoting employee 
involvement in operations throughout the 
Group. GPEU (Grameenphone Employees 
Union) was registered by the Labour 
Directive of Bangladesh as a union in 
March 2019. As a consequence, 
Grameenphone signed a Recognition 
Agreement with GPEU in October 2019. 
The Frame Agreement between Telenor 
Group and UNI Global Union expired in 
May 2017 and has been up for 
renegotiation. In November 2019 Telenor 
Group and UNI Global Union agreed upon 
a renegotiated Agreement. The official 
signing took place in February 2020. 
LOOKING AHEAD: Whilst undergoing 
business transformation, Telenor will 
continue to promote employee 
involvement throughout Telenor Group 
and maintenance of good labour 
standards in the company’s operations. 
More information at www.telenor.com/
sustainability/responsible-business/
labour-rights-and-standards/dialogue-
initiatives.
	
TELENOR SUSTAINABILITY REPORT 2019
7

Building a diverse and inclusive 
culture 
Policy and actions
Telenor is an equal opportunity employer, 
and diversity and inclusion is imperative 
to the way Telenor does business. It is 
about creating services and solutions 
that include different perspectives from 
employees, customers, stakeholders and 
partners. 
Discrimination is against Telenor’s Code 
of Conduct, and it is interpreted that no 
direct or indirect negative discrimination 
shall take place based on race, colour, 
gender, sexual orientation, age, disability, 
language, religion, employee 
representa­tion, political or other 
opinions, national or social origin, 
property, birth or other status. 
Status and ambition 
Telenor started the journey of 
systematically working with diversity in 
2014. In 2019, the diversity agenda was 
broadened from gender balance to focus 
on abilities, competence, nationalities 
and LGBTI inclusion.
By year end 2019, 30 per cent of senior 
leadership positions are held by women, 
a 2 per cent increase from 2018, while 
those in total workforce remained stable 
at 37 per cent. The mix of nationalities in 
Telenor’s senior leadership was also more 
diverse compared to 2018. All senior 
recruitments were approved by the 
President and CEO.
In 2019, Telenor continued to support 
various diversity networks like WIN 
(Women Inspirational Network in 
Grameenphone, FEN (Female 
Empowerment Network) in Norway, and 
Telenor Rainbow in Norway and Sweden, 
which brings together the LGBTI 
community in Telenor. Telenor Norway 
also participated in the Pride for the first 
time. Telenor continued to support 
Student Women Leadership Program in 
partnership with McKinsey, and the Girls 
in Tech collaboration with Plan 
International.
Telenor’s Open Mind programme 
continued to provide meaningful work 
opportunities to persons with disabilities. 
In Norway alone, where the programme 
also includes qualified non-EU 
immigrants, approximately 340 people 
have successfully graduated. In Pakistan, 
approximately 90 people have graduated 
from the programme.
LOOKING AHEAD: Built on a foundation of 
steady progress on gender balance, 
Telenor is expanding the current 
approach and deepening the 
commitment towards diversity and 
inclusion. This is supported by clear 
ambitions towards 2020, to build a 
culture that embraces and respects 
multiple viewpoints, mirroring Telenor’s 
current and future customer base 
worldwide.
More information at www.telenor.com/
career/diversity-inclusion.
Health, safety and people security
Policy and actions
Telenor shall promote high standards 
within health, safety and people security 
(HS&S) in order to ensure a healthy, safe 
and secure working environment. A 
healthy and sustainable work-life 
balance will be an integral part of 
Telenor’s HS&S focus. Telenor’s ambition 
is zero injuries to its employees and 
suppliers. To achieve this Telenor is 
committed to be safe and responsible. 
This applies to everyone working for 
Telenor.
Telenor is committed to work on HS&S in 
accordance with ISO45001, to learn from 
experience, and to continuously improve 
by identifying and managing HS&S risks 
in its operations, increasing HS&S 
awareness, preventing incidents and 
providing healthy, safe and secure 
working environments. 
Status and ambition 
In 2019, five fatal incidents were reported 
in Telenor’s supply chain in Pakistan and 
Bangladesh operations. The majority of 
these were related to road trans­
portation. Overall, a decrease of fatalities 
during the last five years has been 
observed. Telenor has experienced a 
steady decrease in lost time injury 
frequency (LTIF) among employees, from 
0.22 in 2018 to 0.17 in 2019, although 
man-hours also decreased during the 
same period.
The majority of lost time injuries involving 
employees are related to road trans­
portation. In Asia, road transportation 
remains a challenge, and is Telenor’s 
highest HS&S risk. In 2019, road safety 
awareness and initiatives have been 
implemented where risk exists. Telenor 
monitors the COVID-19 outbreak closely 
and will continue taking measures to 
minimise the impact on health and safety 
as well as ensuring business continuity.
In 2019, the Sickness Absence Rate (SAR) 
for Telenor Group increased slightly to 
1.85, compared to 1.82 in 2018. The SAR 
continues to be lower in Asian countries 
and higher in Scandinavian countries. 
There are variations in reported data 
based on different local and national 
procedures and regulations related to 
sickness reporting.
In 2019, Telenor began group-wide ISO 
45001 framework adoption, and business 
units Telenor Pakistan and Digi have been 
ISO 45001 certified. Telenor is 
continuously working on improving 
systematic learning process from 
incidents, and has started reporting on a 
KPI that measures its ability to report and 
follow up incidents. 
LOOKING AHEAD: In 2020 Telenor will 
continue to implement Group ISO 45001 
framework, risk assessment and 
investigation training. The global digital 
HS&S incident reporting system will be 
implemented, and continued focus will 
remain on road transportation by raising 
awareness and identifying activities to 
mitigate this risk further. Moreover, 
health and wellbeing programmes will 
continue to be implemented.
TELENOR SUSTAINABILITY REPORT 2019	
8

More information at www.telenor.com/
sustainability/responsible-business/
labour-rights-and-standards/health-
safety-and-security.
Supply chain risk management
Policy and actions 
Supply chain risk management continues 
to be high on Telenor’s materiality 
assessment, and is key for long-term 
business success. Through the 
Agreement for Responsible Business 
Conduct (ABC), Telenor’s Supplier 
Conduct Principles (SCP) are applicable 
for most supplier categories and 
contracts (based on risk assessments). 
The SCP are based on internationally 
recognised standards, including 
requirements on the respect for human 
rights, health and safety, labour rights, 
working conditions, conflict and other 
unsustainably mined minerals, 
environment, privacy and freedom of 
expression, and prohibited business 
practices. 
Telenor’s approach to supply chain 
sustainability starts with a contractual 
obligation for the supplier to uphold 
responsible business practices, monitor 
compliance with Telenor’s requirements, 
and build capacity on these topics within 
the supply chain. All suppliers are obliged 
to extend the supplier requirements to 
their own supplier base to help ensure 
that the requirements are implemented 
throughout the supply chain. Telenor 
believes that partnership and 
cooperation with suppliers and industry 
peers is vital to achieving a responsible 
global supply chain. 
Status and ambition 
KEY SUPPLY CHAIN RISKS: Telenor’s key 
risks in the supply chain continue to be 
health and safety issues such as road 
accidents, risks related to working at 
heights, other working condition deficits 
related to hours and wages, existence of 
underage labour, and risks to business 
ethics. The majority of these risks are in 
Telenor’s operations in Asia.
CHILD LABOUR/UNDERAGE LABOUR: 
During 2019, Telenor recorded and 
addressed seven cases of underage 
labour (15–18 years involving hazardous 
work). There have been no incidents of 
child labour (12–14 years) identified in 
our supply chain since 2017.
OTHER POTENTIAL RISKS: Use of conflict 
minerals is an indirect risk area for 
Telenor, and the company monitors that 
suppliers have a written policy and 
procedures in place to avoid knowingly 
acquiring conflict minerals. Based on 
recent years’ global audits conducted 
through the Joint Audit cooperation (JAC), 
an association of telecom operators, 
there have been no specific issues 
highlighted with any of the major 
suppliers of smartphones and tablets. 
Modern slavery is also a potential risk in 
Telenor’s supply chain, especially related 
to payment of wages and working hours. 
Telenor actively monitors suppliers to 
ensure they do not employ or use any 
form of forced, bonded or compulsory 
labour, and that they strictly prohibit any 
form of slavery or human trafficking.
CAPACITY BUILDING: Telenor’s business 
units conducted close to 25,000 hours of 
capacity building on topics related to the 
SCP throughout 2019. These efforts 
involved building awareness and capacity 
to drive continuous improvement. The 
activities vary between suppliers and 
regions, depending on the most relevant 
and salient risks in the scope of work 
towards Telenor. 
MONITORING COMPLIANCE: Telenor 
carries out site inspections at supplier 
premises and operational sites in all its 
markets to monitor compliance with the 
SCP requirements. In 2019, Telenor 
carried out 3,616 supplier inspections 
across the Group. 86 per cent of these 
inspections were unannounced. These 
inspections resulted in 650 major non-
conformities, which were followed up with 
mitigation plans and further monitoring. 
81 per cent of these non-conformities 
were resolved and closed by yearend.
Through participation in the JAC, Telenor 
also had access to 104 audit reports 
conducted in the global supply chain in 
2019. 
LOOKING AHEAD: Effective risk 
management in Telenor’s supply chain 
will remain a priority in 2020. Telenor will 
continue to strive for its supply chain 
sustainability efforts to have a positive 
impact on the business as a whole, and in 
In 2019, Telenor carried 
out more than 3,600 
supplier inspections 
across the Group. 86 per 
cent of these inspections 
were unannounced.
	
TELENOR SUSTAINABILITY REPORT 2019
9

the societies in which it operates.
More information at www.telenor.com/
sustainability/responsible-business/
supply-chain-sustainability.
Human rights impact
Policy and actions
Telenor is committed to respecting and 
supporting human rights in accordance 
with the International Bill of Human 
Rights, the UN Guiding Principles on 
Business and Human Rights, and the ILO 
Declaration on the Fundamental 
Principles and Rights at Work.
Telenor applies an ongoing process of 
human rights due diligence, both at 
Group- and business unit levels, to 
identify, address and manage human 
rights-related risks and impacts resulting 
from Telenor’s own activities and those in 
its value chains.
Grievances are reported through 
Telenor’s Integrity Hotline. See chapter 
Code of Conduct for more information on 
the process of handling reports. 
Telenor is committed to being 
transparent on challenges and company 
practices to the extent possible through 
its annual reporting, issue-specific 
reporting (including the annual Authority 
Request Disclosure Report), and through 
other sustainability updates, 
presentations and forums.
Telenor engages with a number of 
organisations to advance its human 
rights objectives, including the UN Global 
Compact, the Global Network Initiative, 
GSMA, the Joint Audit Cooperation (JAC) 
and Global Union. 
Status and ambition
Telenor has communicated its human 
rights efforts and challenges on various 
public platforms in 2019, including on its 
own website, the UN’s Special Procedures 
website, the Business and Human Rights 
Resource Centre, and at the 8th UN 
Forum on Business and Human Rights.
DUE DILIGENCE: In mid 2019, Telenor 
conducted a Group-level human rights 
due diligence. The process identified 
Telenor’s most salient group-wide human 
rights risks: ensuring the right to privacy 
and freedom of expression, compliance 
with labour standards in the supply chain, 
ensuring online safety, preventing 
discrimination, and respecting land 
rights. Mitigating actions such as training 
and capacity building are in place for 
several of these risks, and Telenor is 
assessing how to strengthen these 
efforts and address gaps.
MYANMAR: 2019 continued to be a 
challenging year with respect to human 
rights in some of Telenor’s markets. The 
Rohingya situation in Northern Myanmar 
and the refugee camps in Bangladesh, 
including how Telenor can ensure 
connectivity in those areas, is of grave 
concern. In August 2019, the 
Independent Fact Finding Mission on 
Myanmar published a report urging the 
international community to sever ties 
with Myanmar’s military and any 
companies it controls and relies on. The 
report is a clear indication of the 
continued importance for Telenor to carry 
out due diligence on an ongoing basis – 
both in Telenor’s own processes as well 
as those in the supply chain. This is to 
ensure that the company is not complicit 
in human rights abuses or adverse 
impacts. Telenor also continues to 
engage in dialogue with authorities and 
other stakeholders at local and 
international levels. 
More information at www.telenor.com/
sustainability/responsible-business/
human-rights/mitigate/human-rights-
in-myanmar.
GLOBAL NETWORK INITIATIVE: In 2019, 
Telenor continued to engage with the 
multi-stakeholder Global Network 
Initiative (GNI) to address challenges 
related to authority requests that may 
limit privacy and/or freedom of 
expression. In 2019 it underwent its first 
GNI Independent Assessment by an 
external assessor. Following a detailed 
review of the assessment by the multi-
stakeholder GNI Board, it determined 
that Telenor is making good-faith efforts 
to implement the GNI Principles with 
improvement over time. Telenor will issue 
a public report following the release of 
the formal GNI report on the 2019 
assessments in 2020.
ACKNOWLEDGEMENT: In 2019, Telenor 
ranked among the top companies within 
the European telecommunications and 
technology industry in the Global Child 
Forum’s Benchmark Study on children’s 
rights and business. Additionally, The 
Economist & ECPAT Country Overview 
Briefing Paper on Sexual Exploitation of 
Children in Malaysia has acknowledged 
Digi for their efforts in limiting online 
child sexual abuse and safety in general. 
Telenor also ranked fourth out of 12 
telecommunications companies in the 
global 2019 Ranking Digital Rights (RDR) 
Corporate Accountability Index.
LOOKING AHEAD: Building on the work 
initiated in 2019, Telenor will continue its 
efforts to integrate human rights 
considerations throughout the company, 
through, inter alia, training and capacity 
building of staff across functions and 
business units. Telenor will also continue 
to prioritise multi-stakeholder efforts, 
including the GNI, take an active role in 
public policy discussions related to 
business and human rights, both 
nationally and internationally, and 
continue to strengthen transparency and 
stakeholder engagement efforts.
More information at www.telenor.com/
sustainability/responsible-business/
human-rights/mitigate.
Customer privacy
Policy and actions
Customers expect not only real-time, 
relevant and individualised services, they 
also expect that their privacy is safe­
guarded. As a provider of mobile and 
internet connectivity, respect for rights to 
privacy and freedom of expression is 
TELENOR SUSTAINABILITY REPORT 2019	
10

central to Telenor’s core business. The 
company approaches these issues from a 
privacy point of view, as well as from a 
security angle, with policies and manuals 
that set out mandatory requirements 
applicable across all operations.
Telenor recognises that while 
telecommunications generally 
contributes to freedom of expression, 
there may be challenges related to the 
business. In many situations, authorities 
may have a legitimate need to require 
telecommunications companies to 
comply with requests that limit privacy or 
free communication. For Telenor, it is 
important to seek to limit the risks of 
unlawful and disproportionate 
restrictions on privacy and freedom of 
expression, to the extent that the 
company can.
Although national requirements vary 
throughout Telenor’s markets, Telenor 
strives to be transparent about how 
personal data is handled. Telenor 
believes this is the best approach to 
ensure and build the trust of customers 
and employees.
With the enforcement of GDPR in 2018, 
and gradual introduction and revision of 
privacy-related laws in Asian markets, 
privacy has become a more prominent 
issue in both broader society and in 
Telenor. In 2015, Telenor established a 
clear privacy position: being open and 
transparent about how personal data is 
collected and used, committed to using 
personal data to provide better and more 
relevant services, and thorough in 
keeping personal data safe.
Status and ambition 
In 2019, Telenor moved its centralised 
privacy unit under the compliance 
function in the Group. The privacy unit 
will focus on privacy oversight across the 
Group, in addition to supporting the Data 
Protection Officers (DPO) of the business 
units in monitoring and acting on privacy 
risks, ensuring effective internal controls 
for privacy are in place across Telenor.
Telenor Norway launched a new service 
in 2019 that helps subscribers delete 
their own personal data disclosed on the 
Internet.
AUTHORITY REQUESTS: In 2019, Telenor 
continued to prioritise transparency to 
mitigate potential human rights abuse by 
authorities, including by publishing the 
Authority Request Disclosure Report of 
2018. As described in the human rights 
chapter, Telenor has actively engaged in 
the Global Network Initiative (GNI) on 
freedom of expression and privacy, as 
well as bilaterally with a range of 
stakeholders, as part of Telenor’s 
collaborative effort to protect and 
advance freedom of expression and 
privacy.
LOOKING AHEAD: It is expected that 
governments and regulators across 
Telenor’s markets will continue to 
strengthen privacy and national security 
regulations, and introduce new measures 
that directly or indirectly affect Telenor’s 
ability to manage customer data. Telenor 
will continue to comply with regulatory 
requirements and meet the expectations 
of its customers.
In 2020, Telenor will prioritise the 
following areas: efficient oversight and 
risk management of privacy across 
Telenor, strengthened responsiveness to 
data breaches, and further embedding 
privacy into business operations.
More information at www.telenor.com/
sustainability/responsible-business/
privacy-and-data-protection.
Cybersecurity
Policy and actions 
The global nature of Telenor’s business 
and role as a provider of critical 
infrastructure means that it is at a 
constant risk of basic and advanced 
cyber threats, with cyber-attacks being 
one of the top enterprise risks. Telenor 
strives to always protect society and 
people in their digital lives. The key focus 
is to professionalise security across 
Telenor, and manage security risks 
according to industry best practices, 
local laws, and regulations. Telenor has 
established a global security 
organisation with a global way of work 
driving the security agenda, supported by 
global security capabilities and governed 
by joint meeting places and arenas
Telenor is bolstering its global 
capabilities for security monitoring and 
incident response, and the business units 
are conducting security uplifts in legacy 
environments and migrating to new 
infrastructure. The purpose is to 
implement best practice security 
controls in an infrastructure that enables 
efficient threat mitigation and incident 
response. Furthermore, it enables Telenor 
to apply a vendor-agnostic approach. 
Status and ambition 
FROM STRATEGY TO EXECUTION: During 
2019, Telenor brought security from 
strategy to execution in the business 
units at an operational level, 
demonstrating measurable impact in 
every business unit. Telenor has 
systematically strengthened its basic 
security posture in terms of people and 
competency, processes, technology, and 
vendor management. Telenor Group 
Policy Security is regularly updated in 
order to maintain strong governance.
THIRD PARTY RISKS: During 2019, Telenor 
has strengthened the focus on third-
party risk with a framework for strategic 
vendor management, established a 
cross-functional working group to 
address third-party risks, and security 
risk assessments have been performed in 
the business units.
EXTERNAL COLLABORATION: Telenor has 
actively contributed to several security 
arenas, such as the GSMA Fraud and 
Security Group, GSMA Fraud and Security 
Advisory Panel, ISF (Council Member), 
Europol EC3 (Advisory Board Member), 
ETNO (European Telecommunications 
Network Operators Association), ETSI 
(European Telecommunications 
	
TELENOR SUSTAINABILITY REPORT 2019
11

Standards Institute) and FIRST (Forum of 
Incident Response and Security Teams). 
Telenor is also a signatory to the Paris 
Call for Trust and Security in Cyberspace.
CYBER ATTACKS: In 2019, the two largest 
categories of threats detected by 
Telenor’s global security operations 
centre were ransomware, trojans, and 
other malware such as coinware. In 2019, 
more than 80 per cent decrease was 
observed in detected basic security 
incidents, which demonstrates increased 
security in the business units.
However, advanced cyber-attacks 
targeting business information, customer 
data and critical infrastructure continue 
to pose a significant risk, partly due to 
the difficulty in detecting such attacks. 
While Telenor has been successfully 
developing the capability to detect a 
wide number of threats globally, the 
process of establishing advanced levels 
of security is lengthy, requiring 
substantial changes in terms of 
competency, processes, technology and 
vendor management.
Telenor recognises the importance of 
collaboration and is working to establish 
a close dialogue with the authorities in all 
markets. Telenor shares experience and 
threat intelligence with the industry 
through established forums. Telenor 
Norway annually publishes a public 
security report, Digital Sikkerhet  
(www.telenor.no/om/digital-sikkerhet), 
and Telenor Security Operations Center 
(TSOC) regularly publishes information 
about detected incidents and cyber 
threat trends on the blog telenorsoc.
blogspot.com.
LOOKING AHEAD: Going into 2020, 
Telenor will continue to strengthen local 
and global capabilities protecting critical 
assets, customer data and confidential 
business information, with a focus on 
detecting and responding to security 
incidents. Furthermore, Telenor will 
strengthen internal security culture and 
competency among all employees, and 
continue to integrate security into 
strategic programmes and projects, 
striving to have security at the foundation 
of everything Telenor does.
More information at www.telenor.com/
about-us/corporate-governance/cyber-
security.
Climate impact and environmental 
management
Policy and actions 
Climate change is one of the greatest 
challenges facing people, businesses and 
governments.
Telenor’ s group-wide policy states that 
the business units shall make all 
reasonable efforts to minimise use of 
resources including energy, water and 
raw materials as well as seek to minimise 
carbon emissions from all parts of the 
operations. Further, the business units 
shall secure environmental management 
including sustainable waste management 
where all electronic waste shall be 
reused, recycled or safely disposed.
The mobile industry’s technology and 
smart services through Internet of Things 
(IoT) have the potential to cut global 
carbon emissions, reduce resource 
intensity, stimulate economic growth, 
and deliver substantial social benefits. 
Telenor has over the years followed up 
potential business initiatives and 
partnerships offering eco efficient 
solutions
The growing demand for ICT products 
and mobile devices, and their 
increasingly short lifespans, has resulted 
in e-waste becoming a significant 
concern and risk for the ICT industry. In 
this regard, all Telenor business units are 
mandated to secure sustainable waste 
management. All electronic waste is to be 
reused or recycled according to 
internationally recognised standards and 
regulations.
Status and ambition 
CLIMATE RISKS: For Telenor, climate-
related physical risks include potential 
damage to vital infrastructure and 
utilities through the impact of more 
extreme weather events and rising sea 
levels. Climate-related regulatory risks 
include potential higher operational 
costs due to increasing carbon taxes and 
energy/fuel taxes, as well as risks of 
higher capital costs due to a required 
transition towards the use of renewable 
energy solutions. 
By year end 2019, 
Telenor has installed 
solar energy solutions 
for close to 3,000 of its 
base stations in Asia.
TELENOR SUSTAINABILITY REPORT 2019	
12

ENERGY CONSUMPTION: In 2019, 
Telenor’s total energy consumption was 
approximately 3,340 GWh –an increase 
of 9 per cent compared to recalculated 
data from 2018 – despite a 51 per cent 
increase in data traffic on Telenor’s 
mobile network to approximately 5,500 
petabytes in 2019.
CO2 EMISSIONS: The associated 
emissions of greenhouse gases in 2019 
for Telenor Group has 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, an increase of 
9 per cent compared to recalculated 
data from 2018. The operations in Asia 
account for 96 per cent of the CO2 
emissions, of which 80 per cent is related 
to grid electricity, while the remaining 16 
per cent stems from diesel generators. 
Nordic operations account for 4 per cent 
of the Group’s CO2 emissions (including 
fuel from car fleet, electricity purchases 
and business flights). In 2019, Telenor’s 
carbon emissions were 5.9 kg CO2 per 
customer per year, an increase of 1 per 
cent from 2018.
Further, Telenor Group’s total GHG 
emissions in 2019 was close to 1.2 million 
tonnes of CO2 when using market-based 
electricity emission factors for indirect 
scope 2 emissions, an increase of 1 per 
cent compared to the recalculated data 
from 2018. 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.
RENEWABLE ENERGY SOLUTIONS: By 
year end 2019, Telenor has installed solar 
energy solutions for close to 3,000 of its 
base stations in Asia, an increase from 
2,500 solar-based sites by year end 2018. 
LOW CARBON SOLUTIONS: In 2019, 
Telenor Group passed more than 15.7 
million SIM-connected devices globally 
on its IoT platforms, an increase from 13 
million IoT SIMs in 2018. Telenor 
Connexion, Telenor’s dedicated IoT 
company, designs and operates IoT 
solutions for the global market that can 
enable smart services with potential to 
cut global carbon emissions.
ENVIRONMENTAL MANAGEMENT: In 
2019, more than 72 per cent of Telenor’s 
procurement processes with a contract 
value greater than 250,000 USD used a 
specified set of environmental criteria 
such as hazardous substance handling 
and energy efficiency. In 2019, mobile 
handset recycling continued in Telenor’s 
business units, and more than 227,000 
mobile handsets and batteries were 
collected and recycled. During 2019, 
Telenor’s business units reported close to 
3,900 tonnes of obsolete electrical and 
electronic equipment waste (e-waste) 
removed from active operations, of which 
99 per cent was reused or recycled in an 
environmentally-sound manner.
LOOKING AHEAD: Telenor will continue to 
mitigate climate-related physical risks by 
ensuring robust infrastructure and 
safeguarding in its operations. Telenor 
will be driving a climate agenda that 
contributes to its position as a trusted 
brand, with a key focus on responsible 
business conduct and value creation. 
Telenor’s climate ambitions should help 
set a long-term direction towards group-
wide carbon neutral business operations 
in 2050, and should contribute to low-
carbon economies, in line with the Paris 
Agreement. In 2020, Telenor will disclose 
more climate-related risks information in 
line with the TCFD’s recommendations.
Telenor’s climate targets towards 2030 
are based on the new mobile sector-
specific decarbonisation pathway 
approved by the Scientific Based Targets 
initiative (SBTi). The new climate 
ambitions towards 2030 will allow 
Telenor to support the ambitious Paris 
Agreement goal of limiting global 
warming to 1.5°C, designed to 
substantially reduce the risks and effects 
of climate change: 
Telenor’s ambition for Nordic markets is 
to have carbon-neutral business 
operations by 2030, focusing on energy 
efficiency measures in network 
operations, purchasing renewable 
electricity, enabling carbon neutral 
transport (including its supply chain), and 
offsetting business flights. 
Telenor’s ambitions for Asian operations 
is 50 per cent reduction in carbon 
emissions by 2030, focusing on 
substituting diesel generators with solar 
solutions at base stations and exploring 
other renewable electricity options in the 
region.
In the coming period, we expect to see 
significant growth in data traffic that will 
increase energy consumption as well as 
emissions due to limited access to 
renewable energy, especially in the Asian 
region. Reaching our target will require 
very close follow up and implementation 
of energy efficiency measure in close 
cooperation with our vendors and 
partners.
More information at www.telenor.com/
sustainability/responsible-business/
environment-and-climate.
Digital inclusion 
Mobile connectivity and Internet access 
are catalysts for growth. Exclusion can 
have a negative effect, particularly on 
the ability of vulnerable groups to earn a 
living, increase income or improve their 
way of life. As children and young people 
increasingly explore and benefit from the 
digital world, the need to build their 
capacity and resilience to navigate safely 
remains ever important. Ensuring access 
and skills that help safely capture digital 
opportunities of the future, is therefore 
an important part of Telenor’s 
commitment to reduce inequalities and 
empower societies.
CHILD ONLINE SAFETY: In pursuit of the 
ambition to train four million children in 
online safety by 2020, Telenor business 
units reached out to approximately 1.2 
	
TELENOR SUSTAINABILITY REPORT 2019
13

million children in 2019, cumulatively 
training a total of approximately 3.3 
million children. This was achieved 
through collaboration with Telenor’s 
Global Sustainability Partners, UNICEF 
and Plan International, local 
organisations and government agencies. 
In October 2019, Telenor participated in 
the first ASEAN Stop Cyberbullying 
Workshop to lobby for online safety 
integration in national curricula. 
Moreover, nearly all Telenor Asian 
business units adopted Telenor’s 
Digiworld online safety resources.
In 2019, all business units undertook 
online safety training with a locally 
relevant approach. Efforts included 
outreach programmes, awareness 
campaigns, and capacity building of 
parents and teachers. Telenor Myanmar 
partnered with Plan International, the 
government and local partners to 
promote digital literacy and online safety, 
with an aim to reach 740,000 by the end 
of 2020. Another project to scale child 
online protection in Bangladesh was 
launched by Grameenphone and UNICEF. 
The goal is to build skills for 1.2 million 
children and youth by 2020. In 2019 
alone, Grameenphone trained almost 
600,000 children, created awareness for 
more than 200,000 parents, guardians 
and teachers, and reached 13 million 
through a national awareness campaign. 
In Malaysia, Digi continued to build its 
safe internet capacity building 
programme, and together with UNICEF 
and partners, ran a national awareness 
campaign against cyberbullying. Telenor 
Norway, together with partners, launched 
an interactive digitised version of Bruk 
Hue (Use your Head) programme to 
prevent cyberbullying, while the service 
Nettslett - offering psycho-judicial 
support related to online harm - was 
integrated in the subscriptions of 
600,000 customers. Telenor Denmark 
also utilised digital channels to create 
awareness and outreach for its 
#DigitalPænt programme.
SMART FARMING: Through the Smart 
Farmer project, dtac continues to 
empower smallholder farmers in Thailand 
with access to advanced technology and 
skills. In 2019, nearly 400 farmers were 
trained in online marketing, and the use 
of IoT and plot-specific weather forecast 
helped farmers increase crop yields and 
margin. An assessment in 2019 
suggested that farmers perceived 
advanced technology well and were 
willing to invest to elevate farming 
capacity. 
In Pakistan, Khushaal Zamindar, which is 
an Interactive Voice Response, outbound 
dialling and SMS-based information 
service, reached 7.5 million monthly 
active users to serve farmers, including 
women, through Khushaal Aangan health 
and agri info. The portfolio was expanded 
to include medical consultation, 
veterinary service, health insurance, crop 
insurance and personalised consultation 
for crops. 
DIVERSITY AND INCLUSION: In May 2019, 
Telenor Norway and PLAN International 
launched the Girls Create Tech Academy 
- a mentorship programme to reduce the 
digital gender gap in Norway, inspire 
more girls to choose education and 
challenge gender stereotypes in careers 
within technology. Thirty mentees under 
the guidance of female Telenor Norway 
employees are part of the one-year 
programme.
To mark the International Day of the Girl 
on 11 October, Telenor participated in 
Plan International’s ‘#GirlsTakeOver’ 
initiative, where aspiring young girls took 
over the positions of Telenor leaders in 
several markets as a symbolic gesture to 
encourage equal opportunities for girls.
In August 2019, Telenor, in partnership 
with Plan International, launched the 
study ‘PROGRAMMED OUT: The Gender 
Gap in Technology in Scandinavia’. This 
report reflects on reinforced gender roles 
and other barriers to women in 
Scandinavia with career ambitions in 
tech, and offers recommendations for the 
industry.
Leveraging the power of technology to 
advance inclusion for Persons with 
Disabilities (PWDs), Telenor Pakistan is 
piloting a Digital Job Portal aimed at 
providing livelihood and skills 
development opportunities to PWDs. 
Digi’s Yellow Heart is also providing 
differentiated offerings and rebates for 
seniors and PWDs to lower barriers of 
adopting a digital lifestyle.
Social innovation
Mobile connectivity and digital services 
have the potential to advance all UN 
SDGs through solutions that can address 
social, economic and environmental 
problems. In addition, research is 
instrumental in gaining insights and 
competencies to help connect customers 
to what matters most. Telenor continues 
to strengthen its efforts to leverage 
mobile for sustainable development, 
reduce inequalities and empower 
societies. 
DIGITAL BIRTH REGISTRATION: According 
to UNICEF, globally one in four children 
under five years old remain unregistered 
at birth, and are consequently at risk of 
being denied healthcare, education and 
social protection against child labour and 
early marriage. In Pakistan and Myanmar, 
Telenor is working with the governments 
and UNICEF to digitally register births 
efficiently, and with scale. 
In October 2019, Telenor Myanmar in 
collaboration with UNICEF implemented 
the Mobile Birth and Death Registration 
app in Mon State. The app will allow 
health workers to free up time lost in 
manual data entry and duplication, 
making the birth certificate issuance 
process more efficient. 
By 2019, the Digital Birth Registration 
project in Pakistan registered 780,000 
children in five districts. It is not expected 
that Telenor and partners will reach the 
ambition of 7 million digital birth 
TELENOR SUSTAINABILITY REPORT 2019	
14

registrations by 2020. This is due to 
challenges including training capacity of 
users, network availability in 
government-selected areas, approval 
process, and delays in improved solution 
rollout. It is expected that Telenor will 
reach 2 million birth registrations by year 
end 2020.
FINANCIAL INCLUSION: In Myanmar, 
Wave Money, with its large financial 
services distribution network, continues 
to drive financial inclusion. In 2019, Wave 
Money continued to facilitate 
humanitarian aid disbursements for 
World Food Program (WFP) and 
settlement of pensions via mobile money 
together with Myanma Economic Bank 
(MEB). In July 2019, Gpay—a mobile 
financial services solution by 
Grameenphone—was repositioned and 
simplified to facilitate financial inclusion 
for women and rural communities. This is 
being achieved through a partnership 
with Rural Electrification Board (REB) of 
Bangladesh. By year end, the effort has 
created a customer base of two million, 
of which 18 per cent are women. In 
Pakistan, Easypaisa, the country’s first 
mobile banking platform, introduced 
Enable Pay & Credit for the masses, 
digitising the payment value chain 
between distributors and retailers, and 
enabling easy access to credit. More than 
13,000 merchants benefitted from the 
service in 2019. 
USING BIG DATA AGAINST DRUG-
RESISTANT MALARIA: Drug resistance 
poses one of the greatest threats to 
malaria control, and results in increased 
morbidity and mortality. With an ambition 
to support local authorities to track and 
contain this emerging health threat, a 
research report was published in 
collaboration with Harvard T. H. Chan 
School of Public Health, Grameenphone, 
Telenor and other partners titled 
‘Mapping Imported Malaria in 
Bangladesh Using Parasite Genetic and 
Human Mobility Data’. The study, one of 
the largest efforts of its kind, shows that 
combining malaria genetic data with 
human mobility data from mobile 
networks can help map and predict the 
spread of drug-resistant malaria.
Safe use of mobile communications
Mobile communications are delivered via 
radio frequency signals that are 
electromagnetic fields (EMF). Radio base 
stations are the essential part of the 
infrastructure for transmitting and 
receiving those signals, and the base 
stations need to be located where people 
use their mobile devices.
Over many years, there has been certain 
public and stakeholder interest in human 
health issues related to EMF. With 5G, 
Internet of Things (IoT) and wearable 
devices,	 an increasing public interest in 
EMF is expected, with potential 
regulatory issues for the mobile industry, 
and business-limiting consequences for 
Telenor operations.
Throughout Telenor, all business units 
work strictly in accordance with the 
guidelines provided by national 
regulations and the International 
Commission on Non-Ionizing Radiation 
Protection (ICNIRP). These guidelines are 
endorsed by the World Health 
Organisation (WHO) and represent the 
basis for all of Telenor’s planning, 
installation work and safety measures at 
antenna sites.
More information at www.telenor.com/
sustainability/responsible-business/safe-
services/mobile-phones-and-health.
HOW TELENOR IMPACTS 
SOCIETIES
In Asia and Europe, Telenor contributes to 
society in a number of ways. Digitalisation 
allows countries to leapfrog stages of 
economic development. Digital 
processes allow most industries to 
produce more effectively with less 
physical strain. Digital services empower 
government services and information to 
reach citizens, and digital systems 
represent a frontline of democracy, 
security and defence. 
Telenor’s social agendas address and 
enforce these contributions: Telenor 
pursues a network rollout model that 
brings Internet to all. Telenor believes 
that digital services have the potential to 
reduce inequalities (UN Sustainable 
Development Goal #10) by providing the 
poorest with low-cost access to 
information and economic opportunities. 
Telenor’s deliberate policy of sustainable 
value chains and local procurement 
The foundation for 
Telenor’s strategy is its 
purpose: Connecting you 
to what matters most - 
empowering societies.
	
TELENOR SUSTAINABILITY REPORT 2019
15

enforces decent work and economic 
growth. Telenor communicates a value 
proposition of good governance between 
competent tax authorities and 
responsible taxpayers. 
Tax position
Telenor aspires to be a trusted company, 
recognised for strong business ethics. 
Telenor’s ambition is to contribute to 
economic, environmental and social 
development in countries where the 
company is present, acting with 
accountability and transparency. Telenor 
understands the importance of taxes to 
support this development, and takes a 
responsible approach respecting its 
obligations as a taxpayer. 
Telenor recognises the sovereign right of 
all states to amend existing or introduce 
new tax legislation, and Telenor supports 
a stable and transparent fiscal 
environment based on universal tax 
principles, founded on predictable 
legislation applied by objective authority, 
and tested by independent court 
systems. Telenor aims to constructively 
engage in dialogue with relevant 
authorities on tax legislation.
Telenor supports initiatives to improve 
international transparency in taxation 
matters, including OECD measures for 
country-by-country reporting and 
automatic exchange of information. Since 
2014, Telenor has communicated a 
sincere commitment to corporate 
responsibility by voluntarily reporting 
country-by-country income and tax 
contributions.
More information on Telenor’s tax policy 
at www.telenor.com/media/public-
policy/a-fiscal-environment-for-digital-
inclusion-and-economic-growth-
through-fiscal-stability.
Economic contribution to society
Telenor is a long-term owner, employer 
and taxpayer. Telenor supports efficient 
use of radio spectrum resources for the 
increasing demands for mobile 
broadband capacity. Telenor employs 
local vendors for network rollout and civil 
works, or alternatively buy network 
capacity from local tower companies. 
In 2019, Telenor was actively engaged in 
business start-up incubation and 
acceleration, not least through the 
Artificial Intelligence Lab in Norway, and 
5G development efforts with partners 
COUNTRY-BY-COUNTRY REPORTING1)
Financial Year 2019
NOK in millions
Revenues
EBITDA
Capex
(incl. licenses & 
spectrum)
Profit  
before taxes
Corporate 
income tax 
(CIT) paid
Headcount 
(FTEs) per 
31.12.2019 
Norway
28 658.0 
 11 199.9 
 6 495.6 
 4 110.4 
 3 701.8 
4 350
Sweden
12 857.0 
 5 289.3 
 1 815.7 
 3 070.9 
 563.6 
1 812
Denmark
4 871.3 
 1 390.7 
 516.6
535.9
 80.8 
1 215
Finland
 3 434.4 
 1 020.0 
 879.5 
 167.5 
 13.3 
1 512
Pakistan
 6 033.1 
 3 125.3 
 2 416.2 
 53.0 
 232.5 
1 812
Bangladesh
14 980.2 
 9 377.6 
 1 901.6 
 6 456.5 
 3 144.4 
2 303
Myanmar
5 759.2 
 3 363.9 
 884.4 
 547.4 
 (28.7) 
798
Thailand
 22 994.6 
 8 811.8 
 4 210.3 
 2 751.5 
 213.6 
3 945
Malaysia
 13 517.6 
 7 250.5 
 2 116.5 
 4 343.3 
 981.4 
1 844
Telenor Group
113 665.9
50 276.0
21 359.0
20 968.5
9 032.7
20 044
1)	 This table specifies the most important elements of Telenor’s direct economic contribution country-by-country. It includes Telenor’s revenues, EBITDA, capital expenditure 
including licenses and spectrum, the corporate income taxes paid in 2019 and the number of employees. The table does not specify all taxes and fiscal levies – only Corporate 
Income Tax (CIT) is included.
DIRECT VALUE CREATION
The table specifies the direct Gross Value Added of Telenor in five Asian countries. Frontier Economics: “The Mobile effect: How 
Connectivity Enables Growth”, Nov 2019.
Telenor - direct gross value added (GVA)
Million USD1)
Pakistan
Telenor
Bangladesh
Grameenphone
Myanmar
Telenor
Thailand
DTAC
Malaysia
Digi
2014
565
877
331
1276
1244
2016
721
1078
406
1033
913
2018
695
1272
314
846
933
1)	 Numbers are unadjusted for depreciation or inflation
TELENOR SUSTAINABILITY REPORT 2019	
16

and authorities in Thailand and Malaysia. 
A private-public 5G Lab was launched in 
Malaysia in 2019. In Bangladesh, Telenor 
and the industry advocate the intro­
duction of 5G development in dialogue 
with authorities.
Existing public policy positions on mobile 
spectrum management, 5G, taxation, net 
neutrality, and free flow of data, were 
supplemented in 2019 by a new policy 
position on e-SIM.
In 2019, Telenor’s investments, excluding 
licences and spectrum, amounted to NOK 
17.4 billion (16.7 billion in 2018), from a 
total revenue of NOK 113.7 billion (105.9 
billion), with a resulting investment ratio 
of 15.3 per cent (15.8 per cent). 
Telenor is among the top foreign inves-
tors in all its Asian markets. In 2019, 
Frontier Economics published a study 
that quantified Telenor’s direct and in­di-
rect value creation in five Asian markets. 
Direct value added was estimated along 
global national accounting conventions. 
Frontier Economics estimated that 
Telenor’s local companies generated 
direct value added in Asia at 4.1 billion 
USD. Since 2014, value creation in Asia 
has fluctuated not least by the effect of 
volatile currency depreciation. Taking 
account of currency depreciation, 
Telenor’s value creation is still increasing 
in Pakistan and Bangladesh, but stagnant 
in saturated markets such as Thailand 
and Malaysia. In mature Asian markets 
and the Nordics, Telenor takes great 
effort to improve further economic value 
creation by opening up the opportunities 
in 5G, the Internet of Things, Artificial 
Intelligence, and other advanced digital 
services.
Frontier Economics has estimated that 
the value creation in 2018 per Telenor 
employee in the five Asian countries was 
on average 367,719 USD, or forty times 
higher than the national average of 
9,270 USD per employee. With above 
average labour productivity, Telenor and 
the telecommunications industry drive 
high-skilled job creation, domestic 
spending power, and national economic 
growth. In Telenor’s five Asian markets, 
the mobile industry created skills and 
wage opportunities for 132,750 
employees in 2018.
Other than Telenor’s direct economic 
contribution as measured in the table 
above, the company also stimulates 
increased value creation in other 
companies and sectors by investing in 
infrastructure, buying local goods and 
services, and raising their productivity via 
digitalisation. In Telenor’s five Asian 
markets, highly digital sectors have 
increased their value creation between 6 
and 12 per cent per year since 2005, and 
expanded to now represent 65–75 per 
cent of all economic activity. By growing 
considerably faster than other sectors, 
highly digital companies give specific and 
substantial extra growth stimulus.
More information on the study from 
Frontier Economics at www.telenor.com/
sustainability/frontier-economics-report.
After almost a decade of Corporate 
Income Tax (CIT) rate reductions in 
Europe and Asia, there were no notable 
changes in 2019. Apart from direct taxes 
on profits and revenues, Telenor also 
pays substantial regulatory fees and 
indirect taxes on products and services, 
such as Value Added Tax (VAT), General 
Sales Tax (GST), customs duties, service 
taxes, Revenue Sharing, etc.
HOW TELENOR HELPS 
EMPOWER SOCIETIES:  
SDG IMPACT
An assessment of how Telenor impacts 
the United Nations Sustainable 
Development Goals (SDGs) can be found 
at www.telenor.com/wp-content/
uploads/2020/03/Telenor-SDG-
Impact-Assessment-2019.pdf. Building 
on the first impact assessment in 2018, 
this year Telenor has also taken into 
consideration the risks from business 
activities, which has helped paint a 
broader picture of areas of SDG impact.
In 2019 SDG impact 
assessment report, 
Telenor has also taken 
into consideration the 
risks from business 
activities, which has 
helped paint a broader 
picture of areas of SDG 
impact.
	
TELENOR SUSTAINABILITY REPORT 2019
17

ESG METRICS 
Analytical tool
An overview of Telenor’s historic 
sustainability performance is available by 
downloading the Telenor Group 
Sustainability Performance Analytical 
tool, where figures are separated per 
business unit, and covers the period from 
2012 to 2019, at www.telenor.com/
sustainability/reporting/key-
figures/#analytical-tool. The table below 
shows a synopsis of key metrics from 
2017 to 2019.
GRI index
Telenor reports its sustainability 
performance in accordance with the 
Consolidated Set of GRI Sustainability 
Reporting Standards. These standards 
incorporate the key concepts and 
disclosures from GRI G4 guidelines with a 
new and improved structure and format. 
The standards are issued by the Global 
Sustainability Standards Board (GSSB), 
and Telenor uses them to report publicly 
on its impacts on the economy, the 
environment and society. GRI represents 
a universally-applicable, comparable 
framework which facilitates transparency 
and accountability. 
Telenor’s GRI index can be found at  
www.telenor.com/sustainability/
reporting/gri-index.
Verification statement
DNV GL has been commissioned by 
Telenor to carry out an independent 
review of the Sustainability Report 2019, 
in particular to assess the accurancy of 
non-financial claims. The engagement 
has been undertaken in accordance with 
the requirements in the ISAE 3000 
standard, as well as DNV GL’s general 
method for assessments of sustainability 
reporting.
More information at www.telenor.com/
sustainability/reporting/our-performance.
TELENOR GROUP - NON-FINANCIAL KEY FIGURES
2017
2018
2019
People & Organisation
 
 
 
Women in total workforce (%)
36
37
37 
Women in management positions (%)
26
28
30 
Health, Safety & Security
 
 
 
Fatalities – employees
0
0
0 
Lost Time Injury Frequency (LTIF)
0.23
0.22
0.17 
Sickness Absence Rate (full year average)
1.84
1.82
1.85 
Supply Chain Sustainability
 
 
 
Capacity building of suppliers (man-hours)
23 660
20 028
24 986 
Sustainability inspections and audits
5 000
3 515
3 616 
Fatalities in the supply chain – including tiers below tier 1 
7
4
5 
Climate Change
 
 
 
Total carbon emissions (thousand tonnes CO2)
1 065
1 013
1 080 
Direct carbon emissions/Scope 1 (thousand tonnes CO2)
225
219
209 
Indirect carbon emissions /Scope 2 (thousand tonnes CO2)
819
777
852 
Other indirect carbon emissions/Scope 3 (thousand tonnes CO2)
21
17
18 
Total energy use (GWh)
3 183
3 061
3 340
Carbon emissions per mobile data traffic (tonnes CO2 / petabyte)
408
277
196
Environment
 
 
 
Customer mobile phones and batteries collected for recycling or reuse
168 000
315 000
227 000 
Municipal waste recycled (%)
40
49
55 
Electronic waste recycled/reused (%)
97
86
99 
TELENOR SUSTAINABILITY REPORT 2019	
18

2201108 • BOLT.as
www.telenor.com
Read more about sustainability in Telenor at www.telenor.com/sustainability