ANNUAL REPORT
S
G
nvironmental
ocial
overnance
2022

Contents
Introduction 
4
 
 
CEO Letter 
6
 
Recharge a pioneer in ev charging 
7
 
Highlights 2022 ESG 
14
 
Materiality assessment and stakeholder dialogue 
17
 
Sustainability at Recharge 
18
 
ESG Governance Structure 
26
 
ESG reporting 
27
Environment 
28
 
Nature and climate crisis 
30
 
  Recharge´s impact 
31
 
  Recharges approach 
31
 
 Driving Change in 2022 
34
 
 Driving Change forward 
35
Social  
36
 
Diversity 
38
 
 Recharge´s impact 
39
 
 Recharges approach 
39
 
 Driving Change in 2022 
42
 
 Driving Change forward 
42
 
Human rights 
43
 
 Recharge´s impact 
43
 
 Recharges approach 
43
 
 Driving Change in 2022 
45
 
 Driving Change forward 
45
Governance 
46
 
Knowledge and competence 
49
 
 Recharge´s impact 
49
 
 Recharge´s approach 
49
 
 Driving change in 2022 
51
 
 Driving change forward 
51
 
Transparency 
52
 
 Recharge´s impact 
52
 
 Recharge´s approach 
52
 
 
Number and statistics 
56
Transparency Act Statement 
64
Equality statement 
70
TCFD disclosures 
76
GRI-index 
92
3

Recharge a
pioneer in
ev charging
Introduction
5
4

Recharge fully recognizes the signiﬁcance of the environmental, social and governance (ESG) aspects of business 
performance. In 2022, we have invested signiﬁcantly in our sustainability work: We have conducted a materiality 
assessment, developed a sustainability strategy, conducted a climate risk assessment, and complied with the 
expectations and regulation in the Transparency Act, and Equality and Anti-Discrimination Act.  
Through transparency and dialogue with all of our stakeholders, including our workforce, our customers, partners, 
and investors, we are building trust. With our ﬁrst ESG report, we push on that dialogue by providing more insight 
into the steps we have taken this past year to integrate sustainability and ESG into our culture and corporate 
strategy. Our goal is that assessments, targets, and measures related to ESG become integrated parts of goal 
managements, risk assessment, and the way we do business. 
We Care 
Electriﬁcation is the single most important measure to limit man-made climate change. Many sectors have to 
change their energy use, and we are working on what we believe is one of the most important. Electriﬁcation 
gives us the opportunity to reduce this ﬁgure to zero.  
Yes, we are a company that operates in a market economy and works to make money. But we also care about 
the consequences of what we do every day when we go to work. We care about making a diﬀerence and contri- 
buting to a better quality of life, not just for our customers and employees, but for everyone. If we succeed in our 
mission towards zero emissions transport, then we are making the world a better place. 
We Dare 
In order to create the rapid changes needed to reach the climate goals, we must all dare to move outside our 
comfort zones. We need to challenge our perceptions in the hiring process in order to create a brilliant, diverse 
work force that can solve any task an analyze a problem from all perspectives. At Recharge, we work to up-
hold diversity and non-discriminatory principles across our organization with regards to gender, nationality, age,  
ethnicity, religion, physical disabilities, sexual orientation, and gender identity. We have a goal of a 40 percent 
gender balance by 2025, a goal we are on our way to achieving.  
We must break new ground and innovate to create solutions that make it easier for people to make the choices 
that are best for the climate and the environment. Recharge therefore aims to stay at the forefront of the devel-
opment of our industry to help make electric vehicles (EVs) the obviously best choice for people who must have 
a car. That is why we were the ﬁrst in Norway with high power charging stations, we were the ﬁrst to open our 
charging network to other operators, we were the ﬁrst with rapid charging corridors between the Nordic capitals, 
and the ﬁrst with modular load balancing at our high power chargers. We have made improvements to how we 
ensure the universal design of our charging stations, ensuring wheelchair accessibility and other adjustments to 
make the chargers easy to use also for disabled people.  
Daring to go ﬁrst is demanding, but it is also enormously rewarding for us to see that we are creating the solutions 
that enable the development towards emissions-free transport to proceed even faster.   
We Share 
Norway is the world’s leading EV nation. Here, everyone can see that EVs in most cases work better than fossil- 
fueled cars, and it is no longer necessary to convince people that EVs are a good choice. Other countries are 
following this trend, and in order to make the changes even faster outside Norway’s borders, we share as much 
information as we can about what has made the Norwegian EV adventure possible. With over ten years’ expe-
rience as a charging operator, we have been part of the development of modern EVs from the start, and if by 
sharing our insights we can contribute to a faster transition to emission-free transport, then we believe it is our 
duty. This ESG report is an example of this, another example is its sister publication Recharge Insights, where we 
share more information about our business than any other charging operator in the world. 
We hope you will enjoy our ﬁrst ESG report! 
Recharge is a pioneer in providing EV charging services and 
one of the most experienced charge point operators in the 
industry. We have been building charging networks for EVs 
since 2011 (originally under the name Fortum Charge & Drive) 
and are a crucial facilitator for successful electriﬁcation of 
cars in the Nordics.  A success story that has contributed to 
the Nordics being the world’s most mature EV market. 
Ever since we opened our ﬁrst rapid charger in 2012, we have 
been driven by innovation, sustainability and the feedback 
from EV drivers. The green investments we make provide a 
solid infrastructure for an industry undergoing rapid devel-
opment. Today, we are the largest charge point operator in  
Norway – the world’s most well-developed EV nation. And 
every month, we welcome thousands of new EV drivers to 
Norwegian, Swedish, and Finnish roads. 
In 2020, our company was sold by Fortum to the British in-
frastructure fund Infracapital, which now has full ownership 
of Recharge. Recharge has located its headquarters in Moss 
(Norway), and with oﬃces in Stockholm (Sweden), Espoo  
(Finland) and Copenhagen (Denmark).  
RECHARGE
A PIONEER IN 
EV CHARGING
Kind regards,
Håkon Vist
CEO, Recharge
CEO LETTER
RECHARGE  A PIONEER IN EV CHARGING
7
6

THE HISTORY OF
DRIVING CHANGE
RECHARGE  A PIONEER IN EV CHARGING
AND ALL THE TIME CONTINUING TO GROW OUR CHARGING NETWORK AT A RAPID PACE
2012
CONNECTING 
NORDIC 
CAPITALS
Finalizing a corridor of 
fast chargers connecting 
the main cities of the 
Nordics, enabling longer 
travels for ﬁrst mover EV 
drivers
2020
CENTRALIZED 
POWER UNITS
Recharge is the ﬁrst to utilize 
modular HPC systems with 
centralized power units, further 
improving grid utilization, 
customer experience and 
capex and opex eﬃciency
2019
FIRST MODULAR LOAD 
BALANCING HPC
Recharge is the ﬁrst to utilize 
modular load balanced HPC 
systems, enabling improved 
grid utilization and customer 
experience
2020
OPEN NETWORK
The ﬁrst large Nordic 
CPO to adapt an open 
network strategy, i.e., 
enabling access for 
multiple service providers
2023
OSLO VULKAN 
GARAGE UPGRADE
The Oslo smart charging 
garage is further 
upgraded and improved 
with more high power 
chargers
2018
NORWAY'S FIRST HPC
Norway’s ﬁrst HPC charger 
opened at Nygårdskrysset  
2021
WIRELESS TAXI 
CHARGING
Conducting the 
world’s ﬁrst commer-
cial wireless charging 
for taxis in Oslo 
2022
INVESTING
IN ESG
Investing in ESG work, 
i.e., developing a 
sustainability strategy 
and an ESG report
2017
FIRST BLOCK-
CHAIN PAYMENT
First in the world to test 
blockchain payments 
on a charger 
2018
CONNECTING 
NORDIC CAPITALS 
HPC
The ﬁrst HPC corridor in 
the Nordics, connecting 
the capitals of Norway, 
Sweden and Finland 
2017
OSLO VULKAN 
SMART GARAGE
Opening of the world’s 
smartest charging garage 
in Oslo: 102 charge points 
with 2800 kW nominal DC 
out power and only 800 
kVA from the grid. Peak 
shaving battery and load 
balancing.
2016
WORLD´S LARGEST
CHARGING SITE
Opening the worlds 
largest fast charging site 
with Tesla at Nebbenes
9
8

ALL COUNTRIES
RECHARGE AT A GLANCE
RECHARGE  A PIONEER IN EV CHARGING
11
10

OUR
VALUE CHAIN 
RECHARGE  A PIONEER IN EV CHARGING
Norway - Total number of charge points pr. 31.12.2022
Sweden - Total number of charge points pr. 31.12.2022
Finland - Total number of charge points pr. 31.12.2022
2 607
542
836
RECHARGE
BUSINESS DEVELOPMENT IN 2022 
Furthermore, these are business highlights in 2022
• Recharge are in progress of establishing easier and more  
 convenient payment methods on our charging equipment,  
 ensuring easier and more accessible charging for all.
 Recharge will during 2023/2024 roll out new payment solu- 
 tions on charging equipment in our network. 
• Recharge has a strong focus on contribution to better use  
 of grid usage for load balancing on existing equipment. In  
 addition, Recharge is now working on how we can develop  
 our role in the energy system. In all our markets, the elec- 
 tricity grid is strained due to higher degrees of electriﬁcation,  
 which leads to longer lead times for getting grid connections  
 and higher degree of instability in the grid. Recharge will as a  
 ﬁrst step in this, pilot solutions that will enable a smart energy- 
 system in Sweden, with plans to go live during Q4 2023. 
 In this, Recharge will be able to sell back capacity to the  
 grid, when there is unbalance in the system, in which also 
 can be expanded with energy storage systems, micro  
 production or vehicle to grid solutions. 
• The transport sector is starting to electrify and as part of  
 this Recharge is piloting its ﬁrst public truck charging stations  
 in Sweden and Norway.  The ﬁrst site will go live in Norway  
 during 2023.
 
• In 2022, Recharge joined Drivkraft Norway together with  
 ﬁve other Charge Point Operators. Drivkraft Norway is an  
 association that represents the interest of fuel and energy  
 companies in Norway. Joining forces in Drivkraft Norway will  
 promote better charging services and make it even easier  
 to choose electric vehicles.   
• In 2022, Recharge also joined Danish eMobility and Drivkraft  
 Denmark, and Recharge also remained members of  
 SwedEnergy, PowerCircle and Renewables Norway.
RECHARGE  A PIONEER IN EV CHARGING
New charge points  
Recharge built a record breaking 751 new ultra-fast charge 
points during 2022. Fast chargers are being replaced with  
ultra-fast chargers and many brand-new sites are built with 
only ultra-fast. This is in line with our strategy to provide the 
chargers that people need most urgently. With lots of bigger 
cars with longer range on the roads, this means chargers that 
can ﬁll up your battery as fast as possible.
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VALUE
PROPOSITION
13
12

• A materiality assessment to further develop  
 the organisation’s understanding of its impacts  
 and potential impacts on the environment and  
 society, facilitated by a consulting ﬁrm.   
• The development of a sustainability strategy  
 with concrete targets.  
• A climate risk assessment to further identify and  
 prioritise risks and opportunities for Recharge.  
 Actions for 2023 were deﬁned.  
• Conducted due diligence and risk assessment  
 required by the Norwegian Transparency Act  
 and the Norwegian Equality and Anti- 
 Discrimination Act. Recharge will present our  
 work regarding the Transparency Act on our  
 homepages including a statement on our work  
 related to this Act within 30th June 2023 
• Systematic work to increase diversity.  
2022
HIGHLIGHTS ESG
HIGHLIGHTS 2022 ESG
MATERIALITY ASSESSMENT AND STAKEHOLDER DIALOGUE
RECHARGE
AMBITIONS AND TARGETS  
FOR THE FUTURE 
Below follows a summary of Recharge’s targets within all ESG areas, and further information about each area can be found 
under each material topic. 
Recharge has the following targets for 2023/2024 and onwards:
 
• Map the carbon accounts in scope 1, 2, and 3 in 2023 * 
 
• Establish a climate strategy by 2023
 
• We buy 100% electricity from wind and hydro power for all charge points where we  
 
 manage the electricity contracts. By 2024 we will ensure that this is also the case for the  
 
 minority of charge points where we do not manage the electricity contracts ourselves
 
• Establish a procurement policy on suppliers’ carbon footprint strategies and plans to  
 
 ensure alignment with net zero goals, by 2024
 
• Provide responsible grid utilisation with 100% Load Balancing on site level in 2025
 
• Ambition to oﬀset all our emissions in Scope 1 and Scope 2 with certiﬁcates (CERs) for the  
 
 year 2024
 
• Prepare for ISO 14001 certiﬁcation by 2024
 
 
* Scope 1 emissions are direct emissions from owned or controlled sources. Scope 2 emissions are indirect emissions from the generation of purchased  
 
 
energy. Scope 3 emissions are indirect emissions in the value chain outside the company`s own operations. This include areas like business travel, waste  
 
 
processing, and purchased goods and services.
ENVIRONMENTAL 
 Nature and climate crisis 
15
14

A materiality assessment involves mapping which sustaina-
bility opportunities and risks the company faces, as well as 
who the company’s most important stakeholders are and 
what they are most concerned about.  
During 2022, a materiality assessment was conducted with 
managers from Norway, Finland, and Sweden present. The 
purpose was to identify and prioritise the company’s most 
signiﬁcant ESG themes, i.e., where Recharge has the greatest 
impact – both positive and negative.   
The managers jointly assessed several factors in the company’s 
ESG approach. The group went through what they believe 
is Recharge’s core business, and who the company’s most  
important stakeholders are, and what is to be deﬁned as  
sustainability in Recharge. 
Recharge has a broad a complex group of stakeholders and 
believes that all of the stakeholders are increasingly interested 
in how we address the ESG issues and can achieve the goals 
together. The stakeholder assessment was carried out as a 
tabletop exercise.
An assessment was made of the most relevant megatrends 
within ESG and the industry’s concerns. The materiality  
assessment was based on the business strategy, including 
the company’s purpose and mission. 
Following a review of megatrends, industry, value chain ac-
tivities, and stakeholders’ interests and concerns, the group 
made a priority of the company’s most signiﬁcant areas within 
ESG as of ultimo 2022:
RECHARGE
MATERIALITY ASSESSMENT AND 
STAKEHOLDER DIALOGUE
MATERIALITY ASSESSMENT AND STAKEHOLDER DIALOGUE
MATERIALITY ASSESSMENT AND STAKEHOLDER DIALOGUE
We have deﬁned the following stakeholders:  
Costumers and end users
Environment 
Partners
Social  
Investors/shareholders 
Employees 
Community/authorities
Nature and climate crises 
Media
Diversity
Competitors
Human rights 
Primary
ESG
Secondary
Material Topic 
Governance 
Knowledge and competence 
Transparency
 
• Increase share of women in all organisational levels ≥40% by 2025 
 
• Follow-up on Equality and Anti-Discrimination Act measures
 
• Establish an HR strategy including a recruitment plan by Q2 2023
 
• Recharge will have an employee engagement index >80
 
• Recharge will design universal design-projects
 
• Recharge will perform due diligence according to OECD Guidelines for
 
 Responsible Business Conduct
 
• Follow up on the measures following the work with the Transparency Act 
 
 Establish a system for auditing and supplier follow-up during 2023
 
• Recharge will monitor the response rate for policy e-learning > 80%
 
• Start ESG reporting as of the reporting year 2022
 
• Take initiate to conduct due diligence assessment for suppliers during Q4 2023
SOCIAL 
Diversity and human rights 
GOVERNANCE 
Diversity and human rights 
17
16

At Recharge, sustainability is the very core of the company’s existence, and it’s strongly integrated 
with our purpose, ambition, and strategic pillars.
The Recharge company strategy
Sustainability is embedded in our values to care, to dare, and to share. We care about the environment 
and people and take responsibility for positive change. We dare to innovate for better solutions in 
mobility. And we believe in the power of sharing knowledge to secure the future in a sustainable way. 
For Recharge, sustainability is a prominent part of the company culture and a conscious consider-
ation in all business decisions as the company moves forward with the aspiration to drive change 
towards a green and sustainable future.  
Recharge works with a strategic approach to sustainability, where the aim is that assessments, 
targets, and measures related to ESG are to become an integrated part of goal management, risk 
assessments, and the way we do business.
At Recharge, we actively work to support the United Nations  
Sustainable Development Goals (UN SDGs). Businesses play a 
key role in delivering on and contributing to the goals and we 
support all deﬁned SDGs. Following up on the work for developing 
a sustainability strategy, we are still in the process of deﬁning and 
selecting which goals we mainly contribute to. So far, we have 
identiﬁed four goals as especially relevant to our business.
SUSTAINABILITY
AT RECHARGE
SUSTAINABILITY AT RECHARGE
SUSTAINABILITY AT RECHARGE
INDUSTRY
LEADER
VALUES
AMBITION
PURPOSE
Driving change by accelerating a clean electric future
Recharge is leading the green transition by providing open, 
convenient and accessible energy solutions making the  
conscious choice the abvious choice
CUSTOMER
FIRST
CARE
PASSION FOR
PEOPLE
DARE
OPERATIONAL
EXCELLENCE
SHARE
19
18

SUSTAINABILITY AT RECHARGE
SUSTAINABILITY AT RECHARGE
Ensure access to aﬀordable, reliable, sustainable and modern energy for all Electriﬁcation is 
the single most important tool in the ﬁght against climate change. A massive growth in new, 
renewable electricity production is needed, mainly from intermittent sources like wind and 
solar power.
 Recharge will enable solutions that contributes to smart energy systems which will transition 
the traditional charging stations we know today from being a strain on the power grid to 
becoming a resource for a stronger and more sustainable grid. This will alleviate the need for 
building more grids and will help create the ﬂexibility needed to support intermittent power 
production from wind and solar into the grid.
Build resilient infrastructure, promote inclusive and sustainable industrialization and foster 
innovation.
 
Sustainable industrialisation together with innovation and building infrastructure can trigger 
dynamic and competitive economic forces that create employment and value creation.
 
The core activity of Recharge is to build, operate and own charging infrastructure, enabling 
the automotive industry’s transition to producing electric vehicles. We have one of the largest 
charging networks in the Nordics, and we are investing heavily in innovating this network with 
higher charging speeds and smart solutions, both for storage and transmission of energy. 
Right from the start, Recharge has been at the forefront of innovation in our industry. We 
were the ﬁrst in to connect the capitals of Norway, Sweden and Finland with fast chargers, 
the ﬁrst to deploy high power charge points in the Nordics and also the ﬁrst to connect the 
Nordic capitals with high power chargers. We piloted the world’s ﬁrst block chain payment 
at a charging station and we had the ﬁrst modular and load balancing charging stations in 
the Nordics. We were the ﬁrst charge point operator in the Nordics to adopt an open network 
strategy, meaning easier access to our charging stations for our customers, letting them use 
their app of choice. We also pioneered the world’s ﬁrst wireless fast charging station for taxis, 
and we were the ﬁrst major charge point operator in Norway that enabled card payment 
terminals at our charging stations.
Make cities and human settlements inclusive, safe, resilient and sustainable
 
The world is becoming increasingly urbanized. Since 2007, more than half of the world’s pop-
ulation has lived in cities. This proportion is expected to increase to 60 percent in 2030. Cities 
are powerhouses of economic growth. They contribute about 60 percent of the world’s gross 
domestic product (GDP), but also about 70 percent of CO2 emissions.
 
At Recharge, we aim to build a world class charging network for emissions free electric cars. 
This includes both urban and rural areas, but there is no doubt that the main focus of our 
business is centered around urban areas. By building charging networks, we are an important 
input factor in creating cleaner and more sustainable living spaces. This is the main reason 
why we as a business actually exist. At Recharge, we see it as our mission to help cities and 
municipalities become more sustainable.
Ensure sustainable consumption and production patterns
 
Economic and social growth over the past century has come at the cost of major environ- 
mental degradation that has endangered the entire system of our future development.  
Sustainable consumption and production is about separating economic growth and environ- 
mental degradation and promoting a more environmentally friendly lifestyle.
 
Today, the car has become an important part of the lifestyle of the adult population, and 
the automotive industry is an industry with large and extensive value chains. At Recharge, we 
facilitate the adoption of electric cars that have a zero-emission consumption, so that we as 
consumers get a more responsible and sustainable consumption.
 
A transition from diesel and petrol cars to zero emission electric cars is an important step  
towards more sustainable consumption. By building a world class charging network,  
Recharge is enabling the transition towards electriﬁcation of transports, and a more sustainable 
consumption for people who need the car as a mode of transport.
Take urgent action to combat climate change and its impacts
 
The past eight years have been the warmest ever recorded by humans. Carbon dioxide (CO2) 
and other greenhouse gases in the atmosphere rose to record levels during this same period. 
Sea levels are rising and we are witnessing more and more extreme weather conditions. To 
save lives and livelihoods, urgent action is needed.
 
At Recharge, we help the Nordic countries keep their part of the Paris Agreement by facili-
tating simple and large-scale restructuring of our car ﬂeet. We will do everything we can to 
realise the urgently needed transition from diesel and petrol cars to zero emissions electric 
vehicles. We are conscious of our important role in this process, as a well developed charging 
infrastructure is vital to mass adoption of electric cars.
OUR CONTRIBUTIONS TO THE UN´S  
SUSTAINABILITY GOALS
21
20

ENVIRONMENTAL 
 Material topic: nature and climate crisis 
AMBITIONS 
Recharge is driving change by accelerating the green 
transition through introducing new technology and solu-
tions that ease the transition to EVs and smarter mobility 
solutions. 
Recharge will contribute to ﬁghting global warming by 
being carbon neutral in our company and value chain by 
2030 and net zero by 2040.  
TARGETS 
Recharge will  
• map the carbon accounts in scope 1, 2, and 3 in 2023 *
• establish a climate strategy by 2023
• buy 100 percent renewable energy for remaining minority  
 of charging stations where we don’t yet have this in place
• establish a procurement policy on suppliers’ carbon 
 footprint strategies and plans to ensure alignment with  
 net zero goals, by 2024
• provide responsible grid utilisation with 100% Load 
 Balancing on site level in 2025
• oﬀset all our emissions in Scope 1 and Scope 2 with  
 certiﬁcates (CERs) for the year 2023
• prepare for ISO 14001 certiﬁcation by 2024
* Scope 1 emissions are direct emissions from owned or controlled sources. 
Scope 2 emissions are indirect emissions from the generation of purchased  
energy. Scope 3 emissions are indirect emissions in the value chain outside 
the company`s own operations. This include areas like business travel, waste  
processing, and purchased goods and services.
In 2022, Recharge started work on a 
sustainability strategy and deﬁned 
ambitions for material topics. The 
ambitions are divided according to 
ESG and our strategy focus on both 
social and environmental dimensions 
of corporate responsibility. In this 
section of our report, we will provide 
a brief overview of our strategic am-
bitions and targets.
RECHARGE
SUSTAINABILITY 
STRATEGY 
SUSTAINABILITY AT RECHARGE
23
22

Policies, commitments, and guidelines 
Our work with sustainability is based on the UN Sustainable 
Development Goals, OECDs Guidelines for Multinational  
Enterprises, and the goals in the Paris agreement. To strengthen 
our eﬀort, we have developed   policies for our ESG work. 
These ensures that we behave ethically and in compliance 
with laws, regulations and our sustainability strategy and 
ambitions. This includes areas such as environment, human 
rights, diversity as well as preventing fraud, bribery and cor-
ruption and other ﬁnancial crimes, securing customer privacy 
and the health and safety of our employees.  
All employees of Recharge and its subsidiaries need to abide 
routines and procedures. This will also include contractors and 
subcontractors. The policies are made public on our website 
and employees are trained in the policy commitments reg-
ularly. For more information about our policies, please see 
chapter on transparency.
 SOCIAL 
Material topic: diversity and human rights
GOVERNANCE 
Material topic: diversity and human rights 
AMBITIONS ON DIVERSITY
Recharge aims to be an open and including organisation 
based on the values of tolerance, equality and transparency.  
We will make EV charging easy to use and accessible to all 
by providing a universally designed customer experience.
 
TARGETS 
•  Increase share of women in all organisational levels ≥40%  
 by 2025  
• Follow-up on Equality and Anti-Discrimination Act  
 measures 
• Establish an HR strategy including a recruitment plan by  
 Q2 2023
• Recharge will have an employee engagement index >80 
• Recharge will design universal design-projects 
 
AMBITION ON HUMAN RIGHTS
Recharge respects the fundamental rights and freedoms of 
all individuals aﬀected by our activities.
 
TARGETS 
• Recharge will perform due diligence according to OECD  
 Guidelines for Responsible Business Conduct
• Follow up on the measures following the work with the  
 Transparency Act. Establish a system for auditing and  
 supplier follow-up during 2023
AMBITION ON KNOWLEDGE AND COMPETENCE
Recharge will make sure all employees are well informed on the 
company in general, and on the company’s policies, values and 
guidelines.
 
TARGETS 
• Recharge will monitor the response rate for policy 
 e-learning > 80% 
 
AMBITION ON TRANSPARENCY 
Recharge will be a transparent and open organisation and will 
be challenged on our way to become a more sustainable  
company by our customers, stakeholders, and society in general.
TARGETS 
• Start ESG reporting as of the reporting year 2022 
• Take initiate to conduct due diligence assessment for 
 suppliers during Q4 2023 
SUSTAINABILITY AT RECHARGE
SUSTAINABILITY AT RECHARGE
25
24

Governance of ESG responsibilities at Recharge goes to the highest level of our company. The board of directors 
is collectively responsible for the eﬀective oversight of Recharge and our businesses. It determines Recharge’s 
strategic direction and objectives, business plan, viability and governance structure to help achieve long-term 
success and deliver sustainable shareholder value. 
The board has a responsibility to ensure that Recharge´s activities regarding sustainability topics are included 
in the company’s strategy, and that targets are deﬁned. The board receives updates three times annually from 
the management group in Recharge regarding ESG and also approves the ESG report. The board is responsible 
for ensuring that the Recharge risk management and internal control systems are adequate in relation to the 
regulations governing the business.  
In event of serious cases and deviations regarding the business, the Board of Directors will be notiﬁed either 
through Board meetings or in separate meetings. The whistleblowing procedure also opens for the employees, 
contractors and others to notify Recharge in potential breaches.
Recharge board of directors (per 27.6.2023) 
The CEO, supported by the board of directors, has the ultimate operational responsibility for the implementation 
of the strategic processes, including sustainability. Our ESG initiatives, governance and reporting are led by 
Director Legal, Compliance & ESG. The role is organised under the Finance, IT & Legal department, however the 
Director Legal, Compliance & ESG reports directly to the CEO on ESG issues.  
Recharge management team (per 27.06.2023)
*Starting 29 August 2023
ESG REPORTING
ESG REPORTING  
This report highlights Recharge’s approach and management 
of the environmental, social and governance (ESG) matters. It 
oﬀers an overview of our eﬀorts to reduce our environmental 
footprint, support our employees, and create long-term  
value for our stakeholders. The report covers all Recharge  
entities in Norway, Sweden and Finland.  
Prepared in accordance with the GRI Universal Standard 
2021, the ESG report of 2022 prioritises material topics identi- 
ﬁed through the materiality assessment conducted in the  
reporting year.  The GRI index located at the end of the  
report summarises the disclosures according to the GRI  
Universal Standards 2021 and directs readers to relevant  
sections of the report. Where information is not disclosed, 
the index provides a reason for omission. As this is our ﬁrst 
year reporting our ESG eﬀorts, we recognise that we need to  
reinforce our ESG data to provide a wider and more accurate 
picture of our work. This work is in progress, and we aim to 
have the ﬁrst carbon accounts disclosed in the ESG report 
of 2023.  
In addition, we have included our statements on 1) human 
rights and due diligence as required by the Norwegian 
Transparency Act 2) activity duty required by the Norwegian 
Equality and Anti-Discrimination Act, and 3) a statement on 
climate risk assessment in accordance with the guidelines in 
the TCFD framework. These statements can be found in the 
Appendix of the report.  
The report, which will be published annually, covers the ﬁscal 
year from 1 January 2022, to 31 December, 2022. As this is  
Recharge’s ﬁrst ESG report, no restatements from previous  
reports have been made. The report has not been externally 
assured, but has been created with assistance from Sustain-
ability AS.  
For questions about the report or  
Recharge’s work with ESG, please contact: 
Fredrick Holm-Hansen
Director Legal
Compliance & ESG  
fredrick.holm-hansen@rechargeinfra.com 
ESG
GOVERNANCE STRUCTURE
ESG GOVERNANCE STRUCTURE
Roy E. Williamson
Chair
Håkon Vist
CEO
Oskar
Svedenstedt
Strategy & Business 
Development
Aasmund
Westlind
Network  
Development
Morgan
Lind 
Network Developmen
Operations & QHSE
Maria
Brant
Product 
& Marketing
Morten 
Myrmel*  
Finance, IT
& Legal
Hege
Greaker
HR & People 
Communication
Lorenzo Cannizzo
Director
Andreas Bäckman
Director
Anette Holtedahl 
Director
Loredana Fazzini
Director
27
26

Recharge is  
driving change
by accelerating  
the green transition
Environment
29
28

ENVIRONMENT
Recharge’s vision for a cleaner world 
is reﬂected in our ambition to drive the  
transformation towards a low-emission 
energy system and optimal resource 
eﬃciency. We have made it our mission  
to engage our customers and society 
at large to help us drive the change for 
a greener and more sustainable world 
for future generations. Recharges ma-
terial topic relating to environmental 
factors are nature and climate crises. 
NATURE AND CLIMATE CRISIS
RECHARGE´S IMPACT 
NATURE AND CLIMATE CRISIS 
RECHARGE´S APPROACH 
Recharge aims to drive change by accelerating the green 
transition through introducing new technology that eases the 
transition to EVs and smarter mobility solutions. Our mission 
is to take the stress out of EV driving, focusing on expanding 
our open network and making the transformation from fossil 
to EV easy and convenient for our customers and partners. 
In this regard, we are contributing considerably to lowering 
emissions outside of our own operations and the society as 
a whole. Other positive impacts on air pollution and sound 
pollution.  
In our own operation, we aim to have as low emissions as 
possible. As we are in the process of mapping our emission 
through our carbon accounts, we don’t have the total over-
view of our impact as of 2022. We believe however, that our 
emissions are mostly related to energy use, and further the 
extraction and production of the materials used to build the 
charging stations. Further, waste and business travel might 
be contributing to our Scope 3 emissions. Recharge will ﬁnalise 
the company’s ﬁrst carbon accounts and disclose it in the 
ESG report of 2023.  
While reducing CO2 emissions is crucial to lower our environ-
mental footprint, we also see the importance of working on 
other areas such as waste, biodiversity, and circular economy. 
The company has a negative impact concerning increasing 
the demand for energy intensive battery production and 
scarce minerals for battery production. Further, Recharge 
has an impact when it comes to building sites, concerning  
materials and transport, defrosting building sites and logis-
tics. Within the supply chain, Recharge has an impact on 
choices of equipment, transport, and scarce commodities 
minerals, and sustainable use of resources ex grid.   
Even though most of the development and operations of our 
charging stations are outsourced to our partners, these are 
areas we will start mapping to a more extent in 2024 with the 
aim to set targets and measures.
Research from the Intergovernmental Panel on Climate 
Change (IPCC) shows that climate change is accelerating 
and leading to consequences that are becoming increas-
ingly intense. According to a report from The European En-
vironment Agency (EEA)1, transportation accounts for ca. 25 
per cent of CO2 emissions in the European Union (EU), with 
a total of 72 per cent of the emissions stemming from road 
transportation.  
In the report, the EEA points out that a larger part of the cars 
in the EU must switch to electricity (EVs) to reach the union’s 
climate targets of 55 per cent reduction in CO2 emissions by 
2030 and climate neutrality in 2040.  
According to the IPCC, sustainable management of nature 
and biological diversity is crucial for our ability to adapt to 
climate and environmental changes. According to the Inter-
governmental Science-Policy Platform on Biodiversity and 
Ecosystem Services (IPBES), the loss of nature is as big a 
threat as climate change. The ﬁrst global nature agreement 
which was agreed on at the end of 2022, marked a shift for 
the perseverance of nature and biodiversity.  
To tackle the nature- and climate crises, all sectors must 
adapt and contribute to succeed in limiting global warm-
ing to well under 2 degrees. Recharge will contribute to the 
transition by being carbon neutral in our own operations and 
value chain by 2030, and net zero by 2040. 
Our goal is to make it easier for EV drivers to make sustainable 
choices. We do this through solid partner networks, a focus 
on accessibility and with varied service oﬀerings along your 
way. 
Recharge aims to improve its environmental performance 
particularly with regards to the key areas for environmental 
impact: CO2 emissions, energy, water, waste, transport,  
hazardous materials, business operations, and biodiversity. 
We consider the following to be included:  
• reduce consumption of resources and improve the eﬃciency  
 of those resources  
• manage waste generated from business operations  
 according to the principles of reduction 
• re-use and recycling, identify all the sources of  
 environmental impact within the business 
• collect the relevant data for environmental management,  
 and as a minimum comply with all relevant environmental  
 legislation as well as other environmental requirements
31
30

NATURE AND CLIMATE CRISIS
NATURE AND CLIMATE CRISIS
Climate impact and climate risk 
As the Nordic region’s largest rapid charging network that is 
open to everyone, Recharge’s biggest contribution to the low 
emission transition is the positive impact of making EV charging 
more accessible throughout Norway, Sweden and Finland. 
We nevertheless acknowledge that we have a negative  
impact through CO2 emissions related to energy use and the 
production and development of our charging stations. We 
are in the process of mapping our emissions and will ﬁnalise 
carbon accounts by 2023.  
For Recharge it is of high importance to identify the most signi- 
ﬁcant climate-related risks and opportunities the company 
faces, as it can help us to make informed decisions about 
how to mitigate or take advantage of these factors.  
In 2022, Recharge conducted a climate risk assessment to  
assess how – and to what extent – we are exposed to climate 
risk.  The assessment was conducted in line with the recom-
mendations laid out in the framework developed by the Task 
Force on Climate-Related Financial Disclosures (TCFD). The 
complete management team participated in a workshop to 
identify signiﬁcant physical risk, transition risk and oppor- 
tunities caused by climate change. In the workshop, the identi- 
ﬁed risks and opportunities were assessed in a strategic 
and ﬁnancial context in three diﬀerent climate scenarios. As  
climate-related risks and opportunities inﬂuence Recharge’s 
strategic and ﬁnancial planning diﬀerently in the short, medium, 
and long term, we considered three-time horizons in the  
assessment.  
To identify the risk factors of most importance, the factors 
that could potentially impact the operations negatively and 
the probability of occurrence were assessed. For more infor-
mation about the climate risk assessment, please see the full 
statement prepared in accordance with the recommenda-
tions set by the TCFD in the Appendix of the report. 
Energy use 
Recharge`s operations are highly dependent on electrical 
energy. As the EV market grows rapidly, we naturally see a 
considerable increase in how much energy our growing number 
of charging points deliver. The growth is partly due to the fact 
that we are growing more than our competitors, but it is also 
evidence of an important milestone: we are entering a new 
phase of how EV drivers use their cars. The days of “practical 
when driving in the city” are gone. Now, due to rapid techno-
logical development in the car industry, people drive electric 
on longer trips, which means more use of rapid charging net-
works. 
Recharge`s energy consumption in 2022 was 64,4 GWh. The 
total aggregated GHG emission related to energy consumption 
was 506 tCO2 and the share of renewable energy was 100 
percent. All energy used in Recharge`s charging network has 
a guarantee of origin.  
Waste  
At Recharge, we acknowledge that our operations and de-
velopment of charging stations are commodity intensive. The 
use of raw material used in construction is considerable, and 
the need for more sustainable choices going forward is crucial 
to be able to operate in a sustainable way. Circular products 
and recycled materials are a great part of the solution, as 
well as sustainable waste handling where waste is reduced 
and wasted generated is sorted and recycled as materials. 
These are all areas we will look more into going forward.  
Recharge have a waste management system in place which 
ensures that we comply with local legislation regarding waste 
disposal and recovery. In 2022, Recharge does not have a full 
overview over tonnes generated waste and related Scope 3 
emissions. This will be included in our climate accounts which 
is to be ﬁnalised in 2023. Further, data on shares of waste 
fractions recycled and diverted to disposal is also in progress. 
We do know, however, that our largest waste fraction is  
electronic waste (EE-waste) such as batteries, electrical 
components and technical equipment. The handling of elec-
tronic waste is regulated in the countries we operate in, and 
Recharge complies with local legislation regarding the recy-
cling of electronic equipment.  
To enhance the circular use of electronical products, Recharge 
attempts to reuse components when possible. A QHSE Waste 
Management routine is in place, where a technical assess-
ment is made by Recharge personnel to assess whether the 
equipment has reached its end-of-life or if equipment can 
be reused and still supply the operations with certain spare 
parts. If not, it will be disposed at an oﬃcially certiﬁed recy-
cling facility.  
To handle the EE-waste, Recharge has partnered with RENAS  
(NO) which provides environmentally friendly collection,  
treatment and recycling of EE-waste in accordance with current 
regulations and certiﬁcation requirements. Recharge’s part-
ners undertake to follow Recharge Environmental Policy which 
includes a claim to dispose EE-waste to RENAS or equivalent 
actors.  
Nature and biodiversity  
To tackle climate change, we are strongly dependent on 
healthy and resilient nature, rich ecosystems and biodiversity. 
According to the World Economic Forum, more than half of 
In order for us to achieve our environmental goals we commit 
to doing the following;    
• Setting an example of leadership in environmental manage- 
 ment by promoting environmental awareness, preventing  
 and seeking to minimise the level of emissions in all areas  
 of Recharge’s operations, eﬀectively controlling the environ- 
 mental risks to employees, contractors and the general  
 public. 
• Compliance with environmental legislation, approved  
 Codes of Practice and industry-recognised guidelines.  
 Setting and reviewing at board level in conjunction with  
 Recharge’s professional environmental protection advisers,  
 environmental 
performance 
objectives 
and 
targets,  
 incident investigations and audit programs to facilitate  
 continual improvement. 
• Consulting with employees and providing appropriate in- 
 formation, instruction, and training to ensure all employees  
 and contractors are aware of their environmental obliga-  
 tions. All suppliers will have to sign and accept Recharge  
 Code of Conduct (CoC) which includes environmental  
 obligations. 
• Seeking to minimise waste in all operations by promoting  
 reuse, recycling and the use of recycled materials. Under- 
 taking an ongoing program of environmental protection  
 awareness and ensuring that enough resources are  
 allocated as required for the implementation of our  
 Environmental Policy.  
AMBITIONS
Recharge is driving change by accelerating the green 
transition through introducing new technology and solu-
tions that ease the transition to EVs and smarter mobility 
solutions. 
Recharge will contribute to ﬁghting global warming by 
being carbon neutral in our company and value chain by 
2030 and net zero by 2050.  
 
TARGETS 
• Recharge will map the carbon accounts in scope 1, 2 and  
 3 in 2023 *
• Recharge will establish a climate strategy by 2023
• Buy 100 percent renewable energy for remaining minority  
 of charging stations where we don’t yet have this in place  
• Recharge will establish a procurement policy on suppliers’  
 carbon footprint strategies and plans to ensure  
 alignment with net zero goals, by 2024
• Recharge will provide responsible grid utilisation with  
 100% load balancing in 2025 on site level 
• Recharge will oﬀset all our emissions in Scope 1 and  
 Scope 2 with certiﬁcates (CERs) for the year 2023
* Scope 1 emissions are direct emissions from owned or controlled sources. 
Scope 2 emissions are indirect emissions from the generation of purchased  
energy. Scope 3 emissions are indirect emissions in the value chain outside 
the company`s own operations. This include areas like business travel, waste  
processing, and purchased goods and services.
OUR AMBITIONS AND TARGETS 
33
32

NATURE AND CLIMATE CRISIS
NATURE AND CLIMATE CRISIS
DRIVING CHANGE IN 2022 
In 2022, Recharge established a new sustainability strategy.  
We have committed to being climate neutral in our own  
operation and supply chain by 2030, and net zero in 2050. 
Further, we have conducted a climate risk assessment. We 
also started to map our CO2 emissions, with the ﬁrst carbon 
accounts being ﬁnalised in 2023.  
In 2022, we have continued our work to lowering emissions 
outside of our own operations and the society as a whole.  
Recharge built a record breaking 751 new ultra-rapid charging 
points during 2022, while decommissioning 32 rapid chargers 
and 444 slow chargers. Rapid chargers are being replaced 
with ultra-rapid chargers and many brand-new sites are 
built with only ultra-rapid. This is in line with our strategy to 
provide the chargers that people need most urgently. With 
lots of bigger cars with longer range on the roads, this means 
chargers that can ﬁll up your battery as rapidly as possible. 
In 2022, Recharge provided 64.44 gigawatts hours (GWh).  
This is 61.9 per cent more than in 2021. Our growth in energy 
output came largely from ultra-rapid chargers, meaning 
chargers that provide 150 kilowatts or more. While energy 
provided at fast chargers (50-149 kilowatts) only increased 
11.6 per cent in 2022, ultra-fast chargers increased by 270.4 
per cent. The average charging session in our network delivers 
18.35 kilowatt hours, up by a little more than 3 kWh from the 
year before. The energy delivered diﬀers from a 15.64 kWh  
average for rapid charging sessions to 25.36 kWh for ultra- 
fast charging sessions. Cars with ultra-fast charging capability 
get more energy out of each session. 
We are delighted that the energy we provide is put to good 
use: Recharge enabled approximately 11 600 000 kilometres 
of CO2 free driving during 2022. That’s almost 8000 times 
around the equator. Driving this same distance with average 
petrol-driven passenger cars would have resulted in 52 325 
tonnes of CO2 emissions. 
the world’s economy is strongly or moderately dependent on 
nature. In their annual risk report of 2023, loss of biological 
diversity and ecosystem collapse is ranked as one of the big-
gest risks humanity will face by 2030.  
As to Recharges knowledge, no sites or operations are located 
in or near biodiversity sensitive areas. However, we acknow- 
ledge that our indirect impact throughout our supply chain 
might be considerable. This is especially related to the  
extraction of raw materials which is done partly through  
mining activities.  
To enhance protection of the environment in the supply chain 
and in operations done by our partners, it is stated in the  
Recharge Code of Conduct (CoC) that all suppliers must 
conﬁrm that they will oblige environmental statement pre-
sented by Recharge. 
The Code of Conduct and an Environmental Policy govern 
the requirements and expectations set towards contracts. 
Recharge is also planning an ISO 14001 accreditation for 
2024. In 2022, Recharges has not done risk assessments 
of negative impact on nature in the supply chain. Neither 
have we conducted screenings or assessments of suppliers  
regarding environmental criteria. Programs to protect, conserve 
or mitigate any biodiversity impacts are currently not in place. 
This is something we will look into going forward.  
As far as development done by our partners in Norway,  
Sweden and Finland goes, construction is highly regulat-
ed to protect nature and biodiversity. Most of the charging 
stations are built on commercial land, and regulation plans 
developed by the government are always followed. Further,  
Recharge has partnered with several petrol stations where 
the partners own the land. They are therefore obligated to 
monitor for spillage, leakage and remediate as well as to 
clean up if their business activities should cease. 
Recharge uses Caverion and others for installation work, and 
Rambøll as an advisor. 
DRIVING CHANGE FORWARD
Recharge`s vision for the future is to make the transition from 
fossil to electric vehicles easier for our customers and our 
partners. Together, we aim to make the world greener and 
more sustainable for future generations. 
Going forward, we are mapping our direct and indirect CO2 
emissions and will intensify our eﬀorts to reduce our own  
emissions, as well as continue to drive change in the transition 
to a low emission society. In 2023, we will ﬁnalise our ﬁrst car-
bon accounts which will include Scope 1, 2 and 3.  
Further, we will look into mapping out impacts related to 
waste, nature and biodiversity as well as the extraction and 
production of materials used across our supply chain. Going 
forward, waste management and circular product use will be 
a central aspect of how we conduct our business throughout 
our own operations and supply chain.
35
34

Social
Recharge aims 
to be an open 
an including  
organization
37
36

RECHARGE´S APPROACH 
Recharge has identiﬁed diversity as one of its material top-
ics and aims to be an open and inclusive organisation based 
on the values of tolerance, equality, and transparency.  We 
value diversity and strive to have employees from diﬀerent 
backgrounds.
Diversity is crucial for Recharge’s strategy, as we believe that 
diversity contributes to strengthening the organisational cul-
ture. We work systematically to develop an including working 
environment where equal opportunities are achieved for 
everyone. We are committed to equal treatment and have zero 
tolerance for discrimination and harassment. At Recharge, 
we work to uphold diversity and non-discriminatory principles 
across our organisation with regards to gender, nationality, 
age, ethnicity, religion, physical disabilities, sexual orientation 
and gender identity.  
To enhance diversity, the HR Director works to increase the 
level of awareness in the recruitment process. The most quali- 
ﬁed and suitable candidate will be chosen for employment 
and the HR Director makes sure that Recharge takes care of 
considerations such as equality and diversity in the recruit-
ment process.  
Recharge aims to improve the share of woman in our organi- 
sation by setting a concrete goal of at least 40% women in 
all organisational levels within 2025. By 31st December 2022 
Recharge had total 14 woman in the company. We acknow- 
ledge that this is too low and will implement the following 
measures to ensure that we increase this number:  
• Ensuring that diversity and equality is formally tied to  
 management responsibility and board of directors and a  
 part of Recharge’s way of working 
• Ensuring work-life balance for all employees 
• Increase diversity measures in HR processes, internal and  
 external job advisement
• Concrete marketing and approach advertisement to increase  
 diversity in Recharge 
• Ensuring that all employees receive oﬀer of training through  
 routines and processes 
• More systematic approach to map and ensure gender  
 balance, as well as assessing result from salary processes,  
 part time employees and employees in pat-/maternity leave 
Recharge board of directors recruited two women at the end 
of 2022*, which ensures that the board of directors consists of 
40% woman by 2023. 
For further information about diversity in Recharge, see 
“Number and statistics”.
* Formalised in January 2023
SOCIAL
Our purpose and success go beyond 
being a charge point operator.  We 
also have a responsibility to ensure 
the health, safety, and well-being of 
our employees, create an environ- 
ment that emphasises equality and 
inclusion and focuses on human 
rights.  Recharge’s two material topics 
relating to social factors are diversity 
and human rights.
DIVERSITY
Recharge wants its employees to thrive and experience 
a fair, safe and inclusive environment. Recharge is a fairly 
small organisation, with ambitions to grow. During 2022, we  
experienced a steep employee growth. We welcomed 26 
new employees and by the end of 2022, the head count 
was 59.  As our business grows, the need for a permanent HR 
function became increasingly clear, and in the spring of 2022,  
Recharge hired an HR Director.  
In 2022, Recharge has put eﬀorts in developing the HR  
function by outlining foundational structures and procedures 
to provide employees with clear guidance and structure for 
the work environment. Still in the initial phase, we have estab-
lished core HR processes.  
The HR Director has been a driving force for many initia-
tives; this includes structures and routines on recruitment, 
onboarding, learning, and competence and management 
development.  
Further, we have established and developed the employee 
and leadership handbook as well as the HR system “My work-
life”. This is an all-digital solution, where employees and leaders 
may access all relevant employment documents such as 
contract and development plan.   
Ultimately, having an HR function helps ensure compliance, 
consistency and uniformity across the organisation and free 
up managers’ time so they can focus on other aspects of 
their job. It also outlines choosing the right employees for the 
job, such as evaluating their skills, experience, and personality 
and considering and enhancing diversity.  
In July 2022, Recharge restructured the organisation with the 
aim to handle scalability as well as having an agile, but still 
robust, set up. Great eﬀort has been put into building the 
foundation for the future of Recharge and further ensuring 
that employees at Recharge have a good and safe work-
place.
DIVERSITY
RECHARGE´S IMPACT 
39
38

AMBITIONS
Recharge aims to be an open and including organisation 
based on the values of tolerance, equality, and transparency.  
We will make EV charging easy to use and accessible to all 
by providing a universally designed customer experience.  
 
TARGETS 
• Increase share of women in all organisational levels ≥40%  
 by 2025
• Follow up on Equality and Anti-Discrimination Act measures
• Establish an HR strategy including a recruitment plan by  
 Q2 2023 
• Recharge will have an employee engagement index >80
• Recharge will design universal design projects 
OUR AMBITIONS AND TARGETS 
For Recharge to achieve our diversity goals:  
• We are all committed to equal treatment and have zero  
 tolerance for discrimination and harassment  
• We value diversity, and we work systematically to develop  
 a good and including working environment where equal  
 opportunities are achieved for everyone  
• We believe that diversity contributes to value adding and  
 strengthens the organisational culture  
• We work to achieve a balanced composition of employees  
 in terms of religion, nationality, age, gender, gender identity,  
 cultural background, and more 
• We are setting an example of leadership in management  
 by promoting diversity awareness and seeking to increase  
 the share of women in Recharge by 40% within 2025  
• We comply with diversity and inclusion legislation across  
 our geographies  
Recharge complies with diversity and inclusion legislation in 
those countries we have oﬃces. Norwegian companies are 
obliged to work actively, targeted and systematically to pro-
mote equality and prevent discrimination through a four-step 
working method described in the Norwegian Equality and 
Anti-Discrimination Act. Through a risk assessment in 2022, 
Recharge laid the foundation for the work to ensure equal 
opportunities for all employees. For more information about 
Recharge’s work on equality and anti-discrimination, see  
appendix “Equality Statement 2022”. 
Recharge deploys employee engagement surveys annually 
to build a better workplace with employee and HR surveys. 
We work systematically to improve employee engagement, 
measure job satisfaction, get feedback on beneﬁts, or do 
performance evaluations. In addition, we run well-being 
pulse surveys to get feedback from colleagues regulary.
New employees, turnover, and parental leave 
In 2022, Recharge’s workforce turnover were only 1 person. We 
welcomed 26 new employees; 19 men and 7 women. Great  
eﬀorts are put into retaining employees through initiatives 
such as internal job applications, cross-boarding, compe-
tence development etc.   
All employees are covered by insurance schemes, employee 
rights and occupational health services, pensions provisions 
and the right to parental leave. No distinction is made  
between employers – permanent and temporary – in terms 
of insurance schemes, pensions and other rights. 
In 2022, 2 employees were on parental leave consisting of 0 
women and 2 men.  
Non-discrimination and whistleblowing 
Recharge wants an open culture of expression that will help 
ensure that reports of wrongdoing are handled quickly and 
responsibly at the lowest possible level. An open culture of 
expression is important for the business to improve and de-
velop and is also important for the sake of the working envi-
ronment and the individual’s well-being. We are committed 
to equal treatment and have zero tolerance for discrimination 
and harassment. 
Good business practice and a prudent working environment 
are central to Recharge’s operations. Recharge encourage 
reporting wrongdoing in accordance with this reporting  
routine, and Recharge is also responsible for making sure 
that whistleblowers do not experience any direct or indirect  
sanctions.  
Recharge has established a whistleblowing policy with  
accompanying routines and procedures. Whether it’s to  
prevent serious harm, reduce losses or build a loyal workforce, 
the beneﬁts of whistleblowing for Recharge are signiﬁcant 
and are integral to our success.  
To allow for anonymous reporting, we have one anonymous 
whistleblowing channel managed by an independent third 
party. Both internal and external whistleblowing channels are 
established, and in 2022, there was no reporting on miscon-
duct that is considered a whistleblowing in accordance with 
applicable law.  
Facilitation/accommodation 
Recharge strives to be a ﬂexible employer, and we are able 
to adjust tasks, working hours etc. for our employees when 
needed. Furthermore, we facilitate physical measures at the 
workplace that can contribute to equality and diversity, such 
as ergonomic adaption. Accommodation/facilitation is a 
topic in the employee survey in order to have an overview of 
needs for adjustments. 
Charging point accessibility 
Recharge is focussing on charging point accessibility to  
ensure disabled people not being left behind. We have 
teamed up with diﬀerent relevant organisations such as 
“Handikapforbundet” and “Tilsynet for universell utforming av 
ikt” to increase the accessibility of electric vehicle charging 
points. Recharge was the only charging point company present 
when “Standard Norge” invited for a discussion on how to  
design charging point stations to make them accessible for all. 
Recharge wants to further understand the challenges dis- 
abled people face and explore possible solutions to increase 
the accessibility of EV charging infrastructure.  
DIVERSITY
DIVERSITY
41
40

HUMAN RIGHTS
RECHARGE`S IMPACT 
RECHARGE’S APPROACH 
Businesses signiﬁcantly impact the way we live and how  
human rights are protected. Therefore, enterprises must have 
a responsibility to respect those rights. The OECD guidelines 
for Multinational Enterprises set standards for responsible 
business conduct across a range of issues such as human 
rights, labour rights, and the environment. The Norwegian 
Transparency Act, which entered into force 1 July 2022, created 
a corporate duty to implement due diligence with respect to 
human and labour rights.  
The practical elements of that duty are linked explicitly to the 
OECD Guidelines and the risk-based approach common to 
Human Rights due diligence globally: due diligence should 
be an ongoing process, take into consideration the size and 
nature of the business and the operating context, as well as 
the salience and likelihood of negative impacts on human 
rights and decent labour rights. Additional requirements are 
created in the form of a duty to disclose its due diligence 
practice as well as a separate requirement that companies 
are to respond to public demands for information about their 
negative impacts and their due diligence process, if asked for 
information about these matters. 
In 2022, Recharge conducted an overall due diligence as-
sessment in accordance with the requirements of the Trans-
parency Act. In the risk assessment, we assessed both our 
own operations, business partners, and our supply chain.  
No negative consequences were identiﬁed during the recent 
due diligence assessment, given that the company operates 
in a low-risk environment for human rights abuses due to its 
location based in the Nordics. The majority of subcontractors 
and vendors are also based in Norway or in other low-risk 
countries.  
However, Recharge is aware of potential human and labour 
rights risks that may occur further down the supply chains. 
While none of our operations are located in areas at high risk 
for human rights issues, and we do not have operations in 
countries at risk for child labour, it is still imperative that both 
Recharge and our suppliers respect human and labour rights 
everywhere we do business.  
At Recharge, we respect and do our part to uphold and 
protect the fundamental human rights and labour rights of 
those we work with. We have zero tolerance for any violation 
of those rights, including the use of child labour, forced  
labour or human traﬃcking. We believe in providing a living 
and fair wage to all employees and respecting their right to 
freely associate and collectively bargain. These principles are 
embodied in our Code of Conduct and Modern Slavery Policy.  
A robust management approach is required to prevent, 
identify, and address potential human rights impacts. Our 
approach is grounded on the UN Universal Declaration on 
Human Rights, OECDs guidelines for Multinational Enterprises 
and ILOs conventions covering fundamental principles and 
rights at work. 
Based on the due diligence process conducted in 2022, several 
measures were implemented in order to strengthen our work 
to safeguard human rights and decent working conditions. 
For more information regarding our human rights and decent 
working condition assessment, see appendix “Statement due 
diligence assessment. 
Recharge´s Head of Supply Chain Management is responsi-
ble for all purchase of goods and services at Recharge. All  
potential suppliers are screened through a supplier question-
naire. Topics such as human rights, child labour, forced labour 
and decent working conditions are part of that screening. 
The Recharge Code of Conduct, which includes requirements 
on human and labour rights and decent working conditions, 
is part of contractual agreements and must be signed by the 
suppliers.  
Recharge has zero tolerance for forced labour, child labour, 
human traﬃcking etc. Our approach to slavery is elaborated 
in our Modern Slavery Policy. We require all our suppliers, sub-
contractors and partners to comply with the policy. Further, 
Recharge will ensure that contracts contain provisions allowing 
for termination if breach of the Modern Slavery Policy and 
non-compliance with equal provisions of UNGP rules are to 
be implemented.  
Recharge is committed to the protection of internationally 
recognised human rights and fair and ethical work practices. 
At Recharge, we comply with all applicable laws and regulations, 
including the Norwegian Transparency Act. 
At Recharge we have implemented our commitment to  
human rights and decent working conditions according to 
OECD guidelines for Multinational Enterprises. Speciﬁcally, 
our commitments include: 
HUMAN RIGHTS 
DIVERSITY
DRIVING CHANGE FORWARD 
Recharge is in a phase of rapid growth of employees. We are 
still in the early phases of structuring our eﬀorts on diversity,  
inclusion, and equality. Additional best practice research 
within recruitment, advancement, and retention has been 
identiﬁed and will lay the foundation for strengthening the 
work within this area. 
We will continue the work in 2023 and further formalise our 
structures and processes. We strongly believe that focus on 
diversity will strengthen our culture and business performance. 
We aim to strengthen the HR function with more resources in 
2023. This way, we put eﬀort into embedding diversity and 
inclusion among managers and in the organisation. Addition-
ally, it will free time for the HR Director to discuss strategic and 
forward-looking issues.  
In 2023, we will have a systematic approach to map and  
ensure gender balance, resulting from salary processes, part 
time employees and employees in parental leave.
DRIVING CHANGE IN 2022 
Recharge appointed an HR director in 2022 in order to in-
crease human capital development and nurture an inclusive 
environment. Establishing fundamental HR functions in this 
growth phase has been important to increase awareness on 
diversity, equality, and inclusion in the organisation.  
This speciﬁcally applies to the recruitment process. Through 
2022, HR has had a systematic and structured approach 
to the recruitment process: wording in job advertisements, 
onboarding, probationary period, career development etc.  
Consequently, diversity and equality are continuously on the 
agenda. Furthermore, we have developed a diversity and  
inclusion policy which will enter into force in 2023.  
In 2022, Recharge reviewed its work with equality and diversity 
and carried out a risk assessment relating to our work against 
discrimination and harassment according to the Equality and 
Anti-Discrimination Act. Among other measures, a diversity 
and inclusion policy with clear expectations on equal treat-
ment and zero discrimination was developed. Both internal 
and external whistleblowing channels are established, and in 
2022, there was no reporting on misconduct that is consid-
ered a whistleblowing in accordance with applicable law.
43
42

HUMAN RIGHTS 
 HUMAN RIGHTS 
For Recharge to achieve our ambitions and goals we commit 
to doing the following:  
• Ensuring that Recharge Code of Conduct is a part of any  
 contracts towards all Recharge’s suppliers and vendors  
 when purchasing services or goods  
• Implementing eﬀective systems and controls to ensure  
 modern slavery is not taking place anywhere in our business  
 or in any of our supply chains 
• Investigating thoroughly any actual or suspected breach of  
 the Modern Slavery Policy. This includes conducting audits  
 at suppliers/vendors whenever necessary 
• Consulting with employees and providing appropriate  
 information, instruction, and training to ensure all employees  
 are aware of their Modern Slavery Policy obligations 
Freedom of association 
Freedom of association refers to the right of all workers to 
join or form a legally recognised trade union or any other 
organisation. Freedom of association is a fundamental right 
enshrined in the Universal Declaration of Human Rights and 
the ILO Declaration on Fundamental Principles and Rights at 
Work.  
We respect the right of freedom of association, and Recharge 
fully complies with all laws regulating collective bargaining. 
We both respect and encourage employees to form and join 
unions of their own choice. Recharge maintains positive working 
relationships with union representatives and employees have 
their own representative in the board. As of 2022, Recharge 
has two employee representatives at the “Norway’s engi-
neering and technologist organization” (NITO) in Norway. 
These representatives are involved by HR in employee related 
question that aﬀect the business.   
• The board of director and management board have the  
 overall responsibility for the due diligence process 
• Commitments and policies are integrated in our governance  
 systems and routines 
• We apply due diligence on our operations and expect our  
 suppliers to do the same 
• We have a plan for regularly conducting due diligence and  
 publish statements on the assessments 
• We shall follow up on negative impact and major risk for our  
 employees and aﬀected parties related to our business and  
 supply chain 
• Our overall approach to human right and decent working  
 conditions is included in policies 
AMBITIONS
Recharge respects the fundamental rights and freedoms of 
all individuals aﬀected by our activities.  
 
TARGETS 
• Recharge will perform due diligence according to OECD  
 Guidelines on human rights and decent working conditions
• Recharge will follow up on the measures following the work  
 with the Transparency Act, and establish a system for  
 auditing and supplier follow-up during 2023
OUR AMBITIONS AND TARGETS 
DRIVING CHANGE IN 2022
Recharge is constantly working to strengthen our work on  
human rights and decent working conditions. Throughout the 
last year, we have updated and revised a number of rele-
vant documents helping guide our work, including the Code 
of Conduct, Modern Slavery Policy, governance documents 
and routines.  
The measures also include increased supplier dialogue. For 
those cases where the risk assessment uncovered that we 
did not have enough information about subcontractors in the 
value chain, we have asked for further documentation of how 
human rights and decent working conditions are accounted 
for. This work will continue going forward, and more information 
is provided in the Transparency Act statement in the appendix.
DRIVING CHANGE FORWARD
The eﬀorts put into due diligence in 2022, has helped us  
establish a clear overview of all risks related to human and 
labour rights, and contribute to develop solid monitoring sys-
tems that identify any potential risk and adverse impact it 
may have on our business and supply chain.  
Recharge has well-established and good relationships with 
all suppliers and will examine and map human rights and 
decent working conditions in the supply chain more closely 
going forward.  
Recharge has established a due diligence procedure and 
supplier   self-assessment survey related to social matters. The 
procedure for supplier follow-up will be implemented in 2023. 
In addition, plans for revisions and audits of suppliers with 
regards to topics such as human rights, working conditions, 
discrimination inclusion will be implemented going forward. 
We are committed to protecting our workers, ensuring that 
our workplace is more eﬃcient and productive. Regarding 
occupational health and safety, we will hire a Health and 
Safety manager in 2023.
45
44

Governance
Recharge commits to 
be a transparent and 
open organization
47
46

GOVERNANCE
Recharge is committed to the highest 
standards of corporate governance 
and making sure we apply best 
practices. Our corporate governance 
eﬀorts are highly focused on eﬀec-
tively managing risk and preserving 
long-term, sustainable value for 
the beneﬁt of our shareholders, our  
employees, and the broader society 
in which we operate. The two of our 
material topics related to corporate 
governance are knowledge and 
competence, and transparency.
KNOWLEDGE AND COMPETENCE
KNOWLEDGE AND COMPETENCE
RECHARGE´S IMPACT
Responsibility towards our employees also means training 
them and skilling them for the evolving needs of our business. 
At Recharge, we believe that skills enhancement is essential 
for a successful business.  We strongly believe in investing in 
our employees through development and training opportuni-
ties, ensuring they grow alongside our business. Training and 
development can not only motivate our employees, but also 
build the necessary skills within the company.
RECHARGE´S APPROACH
We understand the value that our talented employees bring 
to our team, and we strive to provide every individual with the 
necessary training, support, and opportunities for advance-
ment that will make them thrive and blossom. 
All employees are taught about, among other things, the 
company, operations, safety, and work tasks. Furthermore, 
specialised training is provided when needed in the various 
units of the operations. The department managers are  
responsible for providing employees with the necessary and 
relevant training.  
In the phase of expanding our business, Recharge has in 2022 
put eﬀorts in developing the HR function by outlining founda-
tional structures and procedures in order to establish basic 
HR processes. This includes structures and routines on recruit-
ment, pre-boarding, on-boarding and oﬀ-boarding.  This is a 
good starting point for further developing training opportuni- 
ties for our employees.  
Career development reviews are held with all employees  
annually and provide an opportunity to discuss potential 
next career and development steps for young talents as 
well as succession planning for key positions in the company. 
Throughout the year, our employees receive ongoing perfor-
mance feedback.  
Employee development and training is an investment that 
could signiﬁcantly raise opportunities for future results. In  
addition to prioritising resources timewise to training, we 
dedicate employee training on the budget every year. 
Providing opportunities for our employees to develop in their 
careers is a critical retention and succession beneﬁt. We oﬀer 
our employees access to   online/e-learning courses to support 
their individual development needs as well as test related to 
cyber security issues and other relevant topics. Furthermore,” 
Recharge Leadership School” promotes and builds leader-
ship skills within the organisation.
49
48

AMBITIONS
Recharge will make sure all employees are well informed 
on the company in general, and on the company’s policies, 
values and guidelines.  
 
TARGETS 
• Recharge will monitor the response rate for policy  
 e-learning > 80 % 
OUR AMBITIONS AND TARGETS 
DRIVING CHANGE IN 2022 
DRIVING CHANGE FORWARD 
In 2022, we established a performance management process 
for all employees. This process aims to foster the employee’s 
individual performance and ongoing development. Managers 
and employees agree on individual goals, and discuss be-
haviour, the necessary functional skills, and development 
measures that are relevant for both the current position and 
the potential next step in their career. 
Acquiring, and also retaining talented employees is a com-
petitive advantage. We continue to identify solutions that 
drive engagement and ensure a skilled and sustainable work-
force. In addition, we have established a solid cross-boarding 
process. Cross-boarding is the process of looking at existing 
employees, assessing who might be suitable for a vacant 
position, and training and adapting the chosen employee 
in connection to the promotion or change of position. In this 
way, we leverage existing resources in Recharge to perform 
tasks that arise in the company, rather than searching for new 
employees. 
In July 2022, Recharge restructured the organisation with the 
aim to handle scalability of the organisation. Furthermore, 
we considered the restructuring necessary in order to have 
an agile and eﬃcient, but still robust, set-up. Consequently, 
Recharge has many new leaders. We want our leaders to 
be agile leaders who can navigate our employees through 
change. Obligatory leadership development training, the 
“Recharge Leadership School”, was developed in 2022 and 
will be launched in 2023.  
Our values underpin everything that we do. We have  
developed policies, processes and governance that set and 
monitor our approach to ensuring we behave ethically and in 
compliance with laws and regulations. This includes preventing 
fraud, bribery and corruption and other ﬁnancial crimes, and 
how we address the human rights of our stakeholders in their 
interactions with our operations and activities. 
As part of our training programme, we introduced an e-learning 
course for all colleagues so they can adequately understand 
and know our policies and values.
As we’ve grown, it’s become mission-critical to not only pro-
vide robust training and development opportunities for our 
people, but to do so in a consistent and process-oriented 
way. Recharge plans to make signiﬁcant eﬀorts in reﬁning and 
advancing our training initiatives and implementing consist-
ency across all our entities and for all employee types.  
Companies don’t stay the same. As the pace of change in 
business increases, Recharge doesn’t stay the same. In 2023, 
we will implement a more formalised leadership development 
programme, the “Recharge Leadership School”. This way we 
aim to develop the talent we already have into the leaders 
we need for tomorrow. 
KNOWLEDGE AND COMPETENCE
KNOWLEDGE AND COMPETENCE
51
50

AMBITIONS
Recharge will be a transparent and open organisation and 
will be challenged on our way to become a more sustain-
able company by our customers, stakeholders, and society 
in general.  
 
TARGETS 
•  Start ESG reporting as of the reporting year 2022
• Take initiate to conduct due diligence assessment for  
 suppliers during Q4 2023
OUR AMBITIONS AND TARGETS 
TRANSPARENCY
TRANSPARENCY
Board of directors and management  
The Board of Directors (the board) is the highest governance 
body in Recharge. As Recharge is still a startup company, 
the involvement between the management and the board is 
tight. ESG is reported quarterly to the board of directors, and 
if needed separate work streams are conducted to ensure 
that the board are informed about any topics that needs 
their attention or involvement. Further, Recharge report to In-
fracapital (the owner) on ESG matters annually, including a 
quarterly reporting to the ESG responsible at Infracapital.   
Recharge has a weekly investment meeting ensuring that 
allocated funds received from Infracapital is spent correctly 
on expansion and new potential sites. The management also 
includes some of the board members in reviewing Recharges  
ongoing work related to ﬁnance, HR, operations during 
weekly and bi-weekly meetings. Regarding evaluation of the 
board on ESG matters, there has not been any evaluations 
as of 2022.   
 
In 2022 the board created a risk and audit committee as 
well as a remuneration committee. The committees are inde-
pendent and report to the board. The CEO and HR Director 
is participating in the remuneration committee in addition to 
Infracapital. The board seek to include relevant management 
employees in work relevant to each committee. As a mean to 
enhance diversity on the board level, two women was elected 
to the board at the end of 2022.   
Conﬂicts of interest  
The board ensures that conﬂict of interest is dealt with at 
every board meeting, ensuring that potential conﬂict of interest 
is dealt with and raised accordingly by, or to the chairman of 
the board.  
Until August 2022, Fortum had a board member in Recharge. 
If there was a case that involved Fortum, the board member 
from Fortum needed to revoke himself from that case. The 
speciﬁc case material and decisions related to such cases 
were held conﬁdential from the board member from Fortum, 
in order for the board to be compliant with conﬂict of interest. 
The board member from Fortum also needed to document 
how conﬂict of interest were handled at the board level.     
If a case concerns the board, communication channels are 
open to report either directly to CEO or the chairman of the 
board. The chairman is also hired in Recharge in a 50 percent 
role, ensuring that he also is aware of any critical topics or 
cases that might occur.   
TRANSPARENCY
RECHARGE´S IMPACT
Recharge strives to be open and professional in all we do, 
and we have a best practices approach in regard to good 
governance structures and transparency. We aim to have a 
close dialogue with our stakeholders and use their input to 
develop our business in a sustainable way going forward.
RECHARGE´S APPROACH
Recharge is committed to the highest standards of corpo-
rate governance and making sure we apply best practices. 
We have developed  policies, processes and governance 
that set and monitor our approach to ensuring we behave 
ethically and in compliance with laws and regulations. This 
includes areas such as preventing fraud, bribery and corrup-
tion and other ﬁnancial crimes, securing customer privacy 
and the health and safety of our employees. These routines 
and procedures apply to all employees of Recharge and its 
subsidiaries, as well as contractors and subcontractors. The 
policies are made public on our website. Further, we have  
established a grievance mechanism to make sure concerns and  
complaints are heard and investigated.
Nomination and selection of the 
board of directors
Communication of critical concerns 
to the board
53
52

TRANSPARENCY
TRANSPARENCY
In order for Recharge to achieve our health and safety goals, 
we commit to doing the following:  
• Setting an example of leadership in health and safety  
 management by promoting a positive safety culture, pro- 
 viding a safe place of work, healthy working conditions  
 including adequate welfare facilities, safe systems of work  
 and equipment, eﬀectively controlling the health and safety  
 risks to employees, contractors and the general public  
 ensuring the highest standards to avoid accidents 
• Compliance with Health and Safety Legislation, approved  
 Codes of Practice and industry-recognised guidelines.  
 Setting and reviewing at board level in conjunction with the  
 company’s professional health and safety advisers, health  
 and safety objectives and targets, accident investigations  
 and audit programs to facilitate continual improvement. 
• Consulting with employees and providing appropriate in- 
 formation, instruction and training to ensure all employees  
 and (sub-) contractors are aware of their health and safety  
 obligations.  
• Establish and keep procedures to deal with any emergencies,  
 crisis, or pandemic, such as COVID-19. 
• Establish risk assessments of all areas of work activities to be  
 carried out regularly, in order to identify hazards and work to  
 prevent instances of injury, disease and dangerous  
 occurrences arising. 
• Consulting with employees and providing appropriate in- 
 formation, instructions and training to ensure all employees  
 and contractors are aware of their health and safety  
 obligations. Undertaking an ongoing program of occupa- 
 tional health surveillance and ensuring that enough  
 resources are allocated as required for the implementation  
 of the Recharge Health & Safety Policy.  
In 2022 it was one case of total recordable injuries and 10 
near-miss injuries. There were zero fatal work accidents, and 
the lost time injury fervency rate was zero.  
Recharge has an independent and overall responsibility for 
ensuring that the safety, health and  working environment 
on our construction sites are safeguarded. In Recharge, this 
is carried out by preparing a plan for safety, health and the 
working environment (SHA plan) for all construction projects, 
in addition we ensure that the duties imposed on the coor-
dinator, the planners, the employers and sole proprietorships 
are carried out in accordance with the Construction client 
regulations (Applies for Norway)
 
It is our charging suppliers and their subcontractors who are 
exposed to QHSE risks during projects or performing oper-
ational and maintenance tasks on our charging locations. 
When carrying out the daily work, our partners are required 
to follow national regulations as well as internal company  
requirements in relation to HSE (Applies for all countries).
 
For Sweden the construction client responsibility are dele-
gated to our partner.
For further information, please see the “Recharge Health & 
Safety Policy” on our website.  
Customer Privacy 
Recharge ensures that personal data is processed in  
accordance with the EU General Data Protection Regulation 
2016/679 (GDPR). The “Recharge Privacy/GDPR Policy” is 
based on compliance with the regulation with an aim to 
serve as a manual regarding data protection, which means 
to ensure that data and communication is kept conﬁdential 
and process such information with care and diligence.  
Recharge has limited personal data from customers, besides 
what is gathered through our drop-in service (QR-code). The 
majority of customer data is located at external parties.  
In 2022, Recharge had no complaints concerning breaches 
of customer privacy. There has not been identiﬁed any leaks, 
thefts, or losses of customer data.  
For further information, please see the “Recharge Privacy/
GDPR Policy” on our website. 
Whistleblowing mechanism  
Recharge wants an open culture of expression that will help 
ensure that reports of wrongdoing are handled quickly and 
responsibly at the lowest possible level. An open culture of 
expression is important for the business to improve and  
develop and is also important for the sake of the working en-
vironment and the individual’s well-being.  
Recharge has a whistleblowing procedure to provide an  
accessible, fair way for people to have their concerns and 
complaints heard and investigated. Recharge is responsible 
for making sure that whistle-blowers do not experience any 
direct or indirect sanctions.  
Both internal and external whistleblowing channels are 
established, and in 2022, there was no reporting on miscon-
duct that is considered a whistleblowing in accordance with 
applicable law.   
For further information, please see the “Recharge Whistle-
blowing Routine and Procedure Policy” on our website. 
There is an ongoing dialog between the management, board 
and chairman in matters that concern the business outside 
ordinary board meeting. Any case or matter aﬀecting the 
business in Recharge will have priority from the board to  
address and mitigate as soon as possible. 
Remuneration policies and processes  
Employees in Recharge has a ﬁxed pay. All employees par-
ticipate in a bonus program based on a set of KPIs and 
goals for each employee and the division they are employed.  
Recharge does not operate with sing on bonus, but if an 
employee is recruited to a higher position, a salary review is 
performed. There are no termination payments in Recharge, 
unless agreed upon from case to case.  
The responsibility for determine remuneration in accordance 
with any given principles set out by the remuneration com-
mittee, is delegated to the HR Director together with the 
CEO. This is done in close co-operation with the remuneration 
committee. The views of stakeholders are addressed in meet-
ing with the committee. None other remuneration consultants 
are involved in the process. Stakeholders and shareholders 
have no impact on the remuneration policies and proposals 
through voting.
Compliance with laws, regulations and policies 
In 2022, there has been no instances of non-compliance 
with law and regulations. No ﬁnes for instances of non- 
compliance were paid during the reporting period.  
Further, no breaches to The Recharge policies or UN Global 
Compact Principles were identiﬁed in 2022.   
Anti-corruption 
Recharge actively supports the global ﬁght against ﬁnancial 
crime, including bribery, corruption, and anti-competitive 
behaviour. We will not tolerate any employee or associated 
person acting on its behalf engaging in any form of bribery 
and/or corruption and/or any behaviour that would breach 
applicable competition legislation. The Recharge Anti-Bribery, 
Corruption and Anti-Fraud Policy is based on applicable laws 
regarding this topic in each country we operate. In 2022 there 
were zero breaches to the policy. 
The policy shall ensure compliance of all of Recharge and 
employees (including contractors) with Recharge’s legal and 
regulatory bribery and corruption obligations, as well as ﬁght 
against fraud.  Further, it enhances a culture that promotes 
ethically sound behaviour and resource management, good 
internal control and preventing and uncovering bribery and 
corruption. All employees are made aware of the policy and 
the requirements. In 2022, Recharge conducted a training on 
the policy for employees and this will also be done in 2023.  
All supplier, vendors and other that Recharge purchases 
services and goods from have seen the Recharge Code of 
Conduct, which in short is based on the principles from our 
policies, including anti-corruption. Going forward it will be a 
focus area for Recharge to conduct risk assessments ant to 
enhance dialog with the suppliers and partners regarding the 
topic.  
For further information, please see the “Recharge Anti-Bribery, 
Corruption, and Anti-Fraud Policy” on our website.  
Health and safety 
Health and safety for our  employees are crucial to Recharge. 
We have a zero-accident vision and the aim with the  
“Recharge Health and Safety Policy” is to create a safe work-
ing environment, and to reduce the risk of accidents, injuries 
and fatalities at work. The policy protects the safety, welfare 
and health of all employees and any other person engaged 
in work, including contractors and subcontractors. 
We maintain and continually improve a documented and  
independently accredited Safety Management System com-
plying with the applicable law requirements and generally 
accepted health and safety standards for each country 
we operate in. Recharge has established health and safety 
representatives in Norway and Sweden in accordance with 
applicable law. The representatives regularly review working 
conditions to ensure the safety and well-being of our  
employees in cooperation with managers. In Finland, due to 
the number of employees there is currently no requirement to 
have a safety representative, but Recharge will monitor and 
assess the needs for such a representative during 2023.  
Our managers are responsible for ensuring that all internal 
policies and legal requirements for occupational health and 
safety are complied with. Occupational health and safety  
issues are discussed on a regular basis with work council rep-
resentatives, safety representatives and management rep- 
resentatives. All employees will be trained in the policy and 
the health and safety systems. 
Health and safety for employees working in relation with 
installation and operation of caring points are the subcon-
tractors’ responsibility. This is an area of high priority in all 
our installations plans and across the Recharge network. All  
subcontractors must comply with health and safety regula-
tions and Recharge`s policy.
55
54

Number and statistics
57
56

NUMBERS AND STATISTICS 
NUMBERS AND STATISTICS 
Category 
Category 
ENVIRONMENT
SOCIAL
Nature and climate crises
Diversity
Unit
Unit
2022
2022
Comment 
Comment 
Energy consumption 
MWh 
63 300 
Total aggregated GHG emission 
tCO2 
506
related to energy consumption 
Share of renewable energy used 
Per cent 
100 
Guarantee of origin in place 
Electricity provided for customers 
GWh 
64 
Enabled CO2 free driving during 
Km  
11 600 000
Oﬃce and mercantile positions  
Numbers 
Total 
 
40
Women 
 
10
Men 
 
30
New employee hires  
Numbers 
Total 
 
26
Women 
 
7
Men 
 
19
Age groups   
Numbers 
<30 
 
9
30-50 
 
15
>50 
 
2
Turnover  
Numbers 
Total 
 
1
Women 
 
1
Men 
 
0
Age groups   
Numbers 
<30 
 
0
30-50 
 
1
>50 
 
0
Sick leave   
Numbers 
Total 
 
0
Women 
 
0
Men 
 
0
Parental leave  
 
 
Employees that were entitled  
to parental leave  
Numbers 
Total 
 
2
Women 
 
0
Men 
 
2
Employees that took parental leave  
Numbers 
Total 
 
2
Women 
 
0
Men 
 
2
Employees that returned to work  
after parental leave ended   
Numbers 
Total 
 
2
Women 
 
0
Men 
 
2
Employees that returned to work 
after parental leave ended that 
were still employed 12 months 
after their return to work   
Numbers 
Total 
 
2
Women 
 
0
Men 
 
2
Return to work and retention rates  
of employees that took parental  
leave, by gender    
Numbers 
Total 
 
2
Women 
 
0
Men 
 
2
Employees 
 
 
All employees 
Numbers 
Total 
 
59
Women 
 
14
Men 
 
45
Broken down by region 
 
Recharge AS 
Numbers
Total 
 
40
Women 
 
10
Men 
 
30
Recharge Sweden AB 
Numbers
Total 
 
13
Women 
 
4
Men 
 
9
Recharge Finland Oy 
Numbers
Total 
 
6
Women 
 
0
Men 
 
6
Broken down by positions  
 
 
Executive management  
Numbers 
Total 
 
4
Women 
 
0
Men 
 
4
Management positions  
Numbers 
Total 
 
14
Women 
 
4
Men 
 
10
59
58

NUMBERS AND STATISTICS 
NUMBERS AND STATISTICS 
Category 
Category 
SOCIAL
GOVERNANCE
Diversity
Knowledge and competence
Transparency
Human rights
Unit
Unit
2022
2022
Comment 
Comment 
Diversity of governance bodies  
and employees  
 
 
Board of directors 
Per cent 
Women
<30 
 
0
30-50 
 
2*
>50 
 
0
Men
<30 
 
0
30-50 
 
2
>50 
 
2
Executive management  
Per cent 
Women
<30 
 
0
30-50 
 
0
>50 
 
0
Men
<30 
 
0
30-50 
 
3
>50 
 
2
Management positions  
Per cent 
Women
<30 
 
0
30-50 
 
3
>50 
 
1
Men
<30 
 
0
30-50 
 
9
>50 
 
1
Oﬃce and mercantile positions  
Per cent 
Women
<30 
 
2
30-50 
 
8
>50 
 
0
Men
<30 
 
6
30-50 
 
19
>50 
 
5
Ratio of basic salary and  
remuneration of women to men  
Thousand 
Average salary 
NOK
Total 
 
862 700 NOK
Women 
 
766 600 NOK
Men 
 
890 700 NOK
New suppliers that were 
 
 
Information disclosed based 
screened using social criteria 
Per cent 
100% 
on that all new suppliers sign  
  
 
 
the Recharge Code of Conduct
I ncidents of violations involving  
rights of indigenous peoples 
Number 
0 
No identiﬁed incident of  
 
 
 
violations involving the rights  
 
 
 
of indigenous people during  
 
 
 
the reporting period.
Percentage of total employees 
 
 
Recharge has a Goals and 
receiving regular performance and 
 
 
development dialogue with 
career development reviews 
Per cent 
100% 
all employees during the  
 
 
 
course of a calendar year. 
  
 
 
Distribution by gender and  
 
 
 
employee category in  
 
 
 
progress.
Total number of incidents of non- 
compliance with regulations and/ 
or voluntary codes concerning the 
health and safety impacts of 
products and services 
Number 
0
Conﬁrmed incidents of corruption  
and actions taken 
Number 
0
Incidents of non-compliance 
 
 
There is lacking MID 
concerning product and service 
 
 
meters on certain AC 
information and labeling 
Number 
0 
chargers in our Network,  
 
 
 
which Recharge as of Q1  
 
 
 
2023 is currently assessing.
Incidents of non-compliance  
concerning marketing  
communications 
Number 
0
ncidents of discrimination and 
 
 
See page xx for more 
corrective actions taken  
Numbers 
0 
information.  
 
 
*Two women was elected in to the BoD end of 2022
61
60

NUMBERS AND STATISTICS 
NUMBERS AND STATISTICS 
Category 
GOVERNANCE
Transparency
Unit
2022
Comment 
Legal actions for anti-competitive 
 
 
No legal actions pending or  
behavior, anti-trust, and monopoly 
 
 
completed. The Norwegian  
practices 
Number 
 
Competition Authority did  
 
 
 
conduct a survey of the  
 
 
 
Charge Point Operators  
 
 
 
(CPOs) in Norway in 2022 in  
 
 
 
regards to exclusivity agree- 
 
 
 
ments. There was no  
 
 
 
allegations towards Recharge,  
 
 
 
and found no wrongdoings in   
 
 
 
that survey. A notiﬁcation  
 
 
 
period was invoked upon all  
 
 
 
large CPO that will last to  
 
 
 
31st December 2023 regarding  
 
 
 
notifying if acquiring other  
 
 
 
companies.
Substantiated complaints 
 
 
No complaints concerning  
concerning breaches of customer 
 
 
breaches of customer privacy  
privacy and losses of customer 
 
 
and losses of customer data.  
data 
Number 
0 
Recharge has not identiﬁed  
 
 
 
any leaks, thefts, or losses of  
 
 
 
customer data.
Workers covered by an 
 
 
Data includes the percentage  
occupational health and safety 
 
 
of all employees and workers  
management system 
Per cent 
100 
who are not employees but  
 
 
 
whose work is controlled by  
 
 
 
the organization.
Work-related injuries 
Number 
1 
In 2022 it was one case of  
 
 
 
total recordable injuries and  
 
 
 
10 near-miss injuries. There  
 
 
 
were zero fatal work accidents,  
 
 
 
and the lost time injury fervency  
 
 
 
rate was zero.
The information disclosed includes Recharge AS, Recharge 
Sweden and Recharge Finland Oy. If information does not in-
clude all entities, a comment on this is mentioned in the com-
ment section.
63
62

Transparency Act Statement 
65
64

STATEMENT DUE DILIGENCE ASSESSMENT
Recharge is a charging point operator which builds, owns, and 
operates infrastructure for the charging of electric vehicles.  
Recharge is actively expanding our charging activities, and 
we currently operate in the Nordics, which include Norway, 
Sweden, and Finland. Recharge will also commence activities 
in Denmark during 2023/2024.  
Recharge oﬀers its network of charging stations to providers of 
electromobility services so they in turn can give their customers 
access to Recharge’s network of charging stations through 
subscription, app and other solutions (from third parties).  
Recharge currently oﬀers drop-in charging to the end cus-
tomers without a subscription but are looking into new ways 
to ensure easy payment of charging services in the future.
INTRODUCTION
Recharge is committed to the protection of internationally 
recognised human rights and fair and ethical work practices. 
At Recharge, we comply with all applicable laws and regula-
tions, including the Norwegian Transparency Act. 
The intention of the act is to promote companies’ respect for 
fundamental human rights and decent working conditions 
in connection with the production of goods and provision of 
services. The act includes a duty to carry out due diligence on 
fundamental human rights and decent working conditions in 
line with the OECD (Organisation for Economic Cooperation 
and Development) Guidelines for Multinational Enterprises. 
Recharge is committed to and base our policies and guide-
lines on UN Universal Declaration on Human Rights, OECDs 
Guidelines for Multinational Enterprises and ILOs conventions 
covering fundamental principles and rights at work. 
This document is prepared to comply with the duty to make a 
statement on the due diligence process.  
The statement will be published yearly and will be updated 
in case of any signiﬁcant changes in our risk assessment. This 
statement covers the period of 1 July 2022 – 31 December 
2022 as well as plans for initiatives going forward. All Recharge  
entities are included in the due diligence assessment. 
ORGANISATION 
In 2020, Recharge AS was sold to the British infrastructure 
fund manager InfraCapital which has 100% ownership of  
Recharge AS today. Recharge’s headquarter is located in 
Moss, Norway, with oﬃces in Stockholm (Sweden), Espoo  
(Finland) and Copenhagen (Denmark).  
At Recharge, we have implemented our commitment to  
human rights and decent working conditions according to 
OECD guidelines for Multinational Enterprises. Our commit-
ments include:  
• The board of directors and management team have the  
 overall responsibility for the due diligence process 
• Commitments and policies are integrated in our 
 governance systems and routines 
• We apply due diligence on our operations and expect our  
 suppliers to do the same 
• We have a plan for regularly conducting due diligence and  
 publish statements on the assessments 
• We will follow up on negative impact and major risk for our  
 employees and aﬀected parties related to our business and  
 supply chain 
• Our overall approach to human right and decent working  
 conditions is included in policies  
Recharge has a whistleblowing procedure to provide an  
accessible, fair way for people to have their concerns and 
complaints heard and investigated. Both internal and ex-
ternal whistleblowing channels are established, and in 2022, 
there was no reporting on misconduct that is considered a 
whistleblowing in accordance with applicable law.   
A due diligence assessment procedure is established. The 
CEO is responsible for the overall risk management on oper-
ational level. Director Legal, Compliance & ESG is responsible 
for the ESG-work and work carried out regarding the Trans-
parency Act. Director Legal, Compliance & ESG but is not a 
part of Recharge’s management team but reports directly 
to CEO on these matters. The board is ultimately responsible 
for ensuring that the risk management and internal control  
systems of Recharge accord with the regulations governing 
the business. The board reviews main risk areas and internal 
control systems annually, including strategy, The Code of 
Conduct, and other company guidelines and policies.
RISK ASSESSMENT
In 2022, Recharge conducted an overall due diligence  
assessment in accordance with the requirements of the 
Transparency Act based on a methodology including ISO 
Standard 31000 for managing risks. In the risk assessment, we 
investigated our own operations, business partners, and our 
supply chain.
Signiﬁcant risk areas in the value chain
Recharge performed an overall risk assessment of our value 
chain with focus on the following seven categories and related 
activities:  
• Charging equipment 
• Installation and services 
• Site equipment 
• Professional services 
• Logistics and warehousing 
• Indirect 
• IT 
Business partners which are indirectly part of our value chain 
were also part of the assessment. 
All our direct suppliers are based in Europe, except one. In the 
due diligence assessment, we primarily looked at risks associ-
ated with our direct suppliers and chose to assess risks at an  
overall strategic level. Further assessments will be conducted 
after measures are implemented, and once a year, as re-
quired in the Transparency Act.   
No negative consequences were identiﬁed during the recent 
due diligence assessment. This was expected, given that the 
company operates in a low-risk environment for human rights 
abuses due to its location based in the Nordics. The majority 
of subcontractors and vendors are also based in Norway or in 
other low-risk countries. 
However, Recharge is aware of potential human and labour 
rights risks that may occur further down the supply chains. 
Recharge aims to continuously improve the due diligence 
process going forward to identify any potential risk that may 
have adverse impact on our business and value chain. 
During the due diligence assessment, the most severe risks 
were identiﬁed in the category of charger and site equipment, 
IT, in addition to business partners. 
The risk assessment identiﬁed ﬁve risks related to fundamental 
human rights and decent working conditions for further  
follow-up: 
 
Materials and components from subcontractors: lack of  
subcontractor overview 
Materials and components in transformers: need to further 
assess potential risk related to materials 
Oﬃce cleaning: need to check the agreement with regard to 
working conditions  
Materials and components in hardware (IT): need to assess 
the leasing agreement 
Software-solution (IT) provided from company outside EU; 
follow up agreement on working conditions.  
Risks were assessed according to the probability of occur-
rence and the degree of severity. All the treats were catego-
rised with the descriptions “may occur”, and “severe” (but not 
“very severe”).
MEASURES 
In general, we assess the risk for violation to be low in our  
value chain. We have good overview over suppliers in our value
chain, and over several years, we have established good 
partnerships with our suppliers.   
Concrete measures and initiatives have been identiﬁed to 
manage the identiﬁed severe risks. For those cases where the 
risk assessment uncovered that we did not have enough in-
formation about subcontractors in the value chain, we have 
asked for further documentation of how human rights and 
decent working conditions are accounted for.
TRANSPARENCY ACT STATEMENT
TRANSPARENCY ACT STATEMENT
67
66

Initiatives to mitigate risk
Recharge has reached to our main suppliers and installation 
partners in which are committed to perform due diligence 
according to OEDC Guidelines for Multinational Enterprises. 
The companies in question, aim to minimise the risk of any 
possible connection between their activities and activities in 
the supply chain and harm on people, society, or the envi-
ronment. They have a code of conduct and procedures for 
due diligence in order. The supplier(s) feedback is that they 
conduct responsibility survey for each operator, which speci- 
ﬁcally ensures the responsibility of the workforce, compliance 
with the law, and human rights issues, which are important 
points in Norway’s transparency regulations. 
In regard to the installation company all personnel suppliers 
have to sign their supplier code of conduct and also the 
company conduct audits of selected suppliers each year.  
Health and safety for employees working in relation with  
installation and operation of caring points are the subcon-
tractors’ responsibility. The installation company conﬁrms that 
this is an area of high priority in all their installations plans and 
across the Recharge network. All subcontractors must comply 
with health and safety regulations and Recharge`s policy.   
Recharge expect the same from our suppliers and business 
partners as from ourselves: all employees and aﬀected par-
ties must be treated with respect and dignity. Through our 
code of conduct for suppliers, we explicitly communicate 
an expectation to our suppliers to comply with UNGP and 
OECDs guidelines for multinational enterprises. Suppliers are 
responsible for ensuring that their sub-suppliers and sub- 
contractors comply with our code of conduct. Recharge  
suppliers must document compliance with the code of  
conduct and also allow audits upon request.  
RESULTS
Recharge is constantly working to strengthen our work on  
human rights and decent working conditions. Throughout 
the last year, we have updated and revised a number of 
relevant documents helping guide our work, including the 
code of conduct, governance documents, and routines. The  
measures also include an increased supplier dialogue. This 
work will continue going forward. These measures will help us 
establish a clear overview of all risks related to human rights 
and labour rights and contribute to solid monitoring systems 
that identify any potential risk that may have adverse impact 
on our business and value chain.  
Recharge has established a due diligence procedure and 
supplier self-assessment survey related to social matters. The 
procedure for supplier follow-up will be implemented in 2023. 
In addition, plans for revisions and audits of suppliers with  
regards to topics such as human rights, working conditions, 
discrimination, and inclusion will be implemented going forward. 
Risks identiﬁed 
Risk mitigation 
Materials and components from subcontractors  
Ask the suppliers for a list of subcontractors in the value  
 
chain – outside of Europe
Materials and components in transformers 
Ask Caverion for a list of subcontractors in their value chain, 
 
including risk countries in Europe. Contact the subcontractors and  
 
get their list of subcontractors in their value chain
Oﬃce cleaning 
Follow up the landlord regarding decent working conditions in the  
 
contract
Materials and components in hardware (IT) 
Ask the suppliers for a list of subcontractors in the value chain  
 
regarding hardware in IT
Software-solution (IT) provided from company  
Follow up the subcontractor regarding documentation on decent  
outside the EU 
working conditions and human rights 
TRANSPARENCY ACT STATEMENT
TRANSPARENCY ACT STATEMENT
69
68

Equality statement
71
70

EQUALITY STATEMENT 2022
Introduction
According to The Equality and Anti-Discrimination Act § 26, 
all Norwegian employers are obliged to work actively, targeted 
and systematically to promote equality and prevent discrim-
ination in the workplace. All private sector employers of a  
certain size (50+ employees) must comply with the regulation. 
By the end of 2022, we counted 42 employees at Recharge 
AS, and 59 total in the Recharge group. As a company with 
ambitions to grow, we have decided to comply with the four-
step method in accordance with the act and report on the 
company’s status. The statement is divided in two parts.  
 1. The status of gender equality in the company  
 2. The work we have done on the activity duty in anti-
  
discrimination  
Recharge is a charging point operator with charging stations 
in Norway, Finland and Sweden. Recharge develops services 
through innovation, an open network, and green investments, 
and by this making the transformation from fossil to electric 
vehicles easy and convenient. Recharge has identiﬁed  
“diversity” as one of its material topics and aims to be an open 
and including organisation based on the values of tolerance, 
equality, and transparency. We strive to have employees from 
diﬀerent backgrounds, and want Recharge to be a fair, safe, 
and inclusive place to work.
Part 1: State of Gender Equality
Gender Balance on Group level
Recharge aims to improve the share of woman in our organi- 
sation by setting a concrete goal of at least 40% women in 
all organisational levels within 2025. In 2022, Recharge devel-
oped a diversity policy.  
Full-time and part-time employment 
In 2022, 1 employee was employed part time at Recharge.  
Permanent and temporary employment 
There were no temporary employees at Recharge in 2022.  
Parental leave 
Two men and no women were on parental leave in 2022.  
The average weeks of leave were 15 weeks. 
For further statistics about diversity in Recharge, see number 
and statistics in the appendix of the report.
Recharge is a fairly young and small organisation, with am-
bitions to grow. Recharge wants its employees to thrive and 
experience a fair, safe and inclusive environment. In 2022,  
Recharge has put eﬀorts in dedicating resources to devel-
oping HR practices on ambitions towards diversity and inclu-
sion and to set up for long-term success in attracting and 
retaining talent. Recharge appointed an HR director in 2022 
in order to increase human capital development and nurture 
an inclusive environment.  
During 2022, Recharge has worked on outlining foundational 
structures and procedures to provide employees with clear 
guidance and structure for work environment. Even though 
we are in the initial phase, we have established core HR pro-
cesses. This includes structures and routines on recruitment, 
learning and competence, management development and 
further development of the employee handbook. Both internal 
and external whistleblowing channels are established, and in 
2022, there was no reporting on misconduct that is consid-
ered whistleblowing in accordance with applicable law.
Part 2: Reharge’s work for equality and 
anti-discrimination
Gender
2022
Women 
14
Men 
45
Total 
59
EQULITY STATEMENT
73
72

EQULITY STATEMENT
EQULITY STATEMENT
Topic
Work-life balance 
Training and development
The duty to accommodate 
Eﬀorts towards preventing 
harassment 
Measure
Responsible
Timeframe
• Recharge strives to be a 
 ﬂexible employer, and we are  
 able to adjust tasks, working  
 hours etc. for a period of time  
 for our employees when 
 needed.  
• Going forward, the employee  
 surveys will include questions  
 regarding work-life question.  
 Measures will be based on  
 ﬁndings.   
• Systematic training and 
 development of employees,  
 including basic training for all  
 employees, leadership
 development and employee  
 development conversation.  
• Further development of  
 leadership manual, employee  
 handbook and internal  
 routines.  
Recharge has plans to:  
• Communicate duty to 
 accommodate in internal 
 routines and job adverts.  
• Establish a diversity and  
 inclusion policy with clear  
 expectations to accommo- 
 date employee needs in  
 recruitment processes as well  
 as at the workplace.  
• Accommodation/facilitation is  
 a topic in the employee survey.  
• Recharge monitors through  
 pulse surveys (frequency yet to  
 be decided).  
• Corporate compliance 
 committee has been  
 established.  
• Topic is included in the  
 employee survey.  
• Harassment will be included  
 as a topic in the leader handbook.  
• Internal and external whistle- 
 blower channels and routines  
 are in place.  
HR
HR
HR
HR
Q2 2023
Q1-Q2 2023
Q1 2023
Q1-Q2 2023
Risk assessment 
To address the requirements for due diligence in accordance 
with the legal framework, Recharge conducted a risk assess-
ment in 2022. The process was facilitated by Sustainability 
AS, based on ISO 31000 for managing risks. In the preliminary 
phase, a mapping was conducted by the HR Director and 
Director Legal, Compliance & ESG to assess the status of the 
group’s work with equality and diversity. Following the map-
ping, a workshop was conducted where the organisation 
was represented by the HR Director, communication director, 
compliance oﬃcer, and employee representatives.  
The ﬁndings indicated that Recharge generally lacks for-
mal procedures and guidelines related to their equality and  
anti-discrimination eﬀorts. Most of the work up until now is 
a result of a good company culture and solid HR processes. 
Few concrete goals and measures were in place, although 
we do evaluate and implement necessary measures on a 
case-by-case basis. Recharge has dedicated resources and 
eﬀorts to strengthen the work even further.    
Identiﬁed risk factors and potential reasons for risk 
According to the legal framework, the goals are predeﬁned, 
namely 1) we will contribute to promote equality and diversity 
and 2) prevent discrimination and harassment. In the risk  
assessment, we assessed potential threats that may aﬀect our 
ability to reach these goals. Recharge examined the general 
risk for discrimination and inequality within the following areas: 
recruitment, advancement, facilitation, work-life balance, 
training & development, and wages and working conditions. 
Within each area, Recharge covered the following grounds 
for discrimination in the assessment: gender, pregnancy,  
parental leave, caregiver responsibilities, ethnicity, religion, 
philosophies of life, functional ability, sexual orientation, gen-
der identity, gender expression, and a combination of these.  
In the risk assessment, threats were evaluated based on like-
lihood of occurrence and the degree of severity. The most 
prominent risks that pose as a threat for Recharge’s ability 
to ensure equal opportunities are highlighted below with  
concrete actions in the following section. These are related to 
work-life balance, training, the duty to accommodate, and 
eﬀorts towards preventing harassment.
Work-life balance: 
• As an organisation in the process of upscaling the 
 business, there are many tasks and few people. The 
 expectations about what needs to be done and when may  
 be challenging for some employees. 
Training and development: 
• As an upscaling business it might be hard to dedicate time  
 to training and development.  
The duty to accommodate: 
• In the physical environment we have some challenges as  
 the lift is not installed for the top ﬂoor.  
Eﬀorts towards preventing harassment:  
• Minimal focus at leadership level due to major workload 
• Diﬃcult being the one to raise concerns in a culture where  
 “everyone” is happy 
Results  
Post risk assessment, concreate measures were identiﬁed 
to reduce the likelihood of threats occurring and strengthen 
our ability to promote equal opportunities. The measures 
were prioritised based on probability, followed by severity, 
and assigned to diﬀerent members of the group. The measures 
are related to work-life balance, training, facilitation and  
preventing harassment:
75
74

TCFD disclosures
77
76

TCFD DISCLOSURES
TCFD DISCLOSURES
Financial markets need clear, comprehensive, high-quality 
information on the impacts of climate change. This includes 
the risks and opportunities presented by rising temperatures, 
climate-related policy, and emerging technologies in our 
changing world. The Financial Stability Board created the 
Task Force on Climate-Related Financial Disclosures (TCFD) 
to improve and increase reporting of climate-related ﬁnan-
cial information. 
The TCFD framework is made up of 11 recommended disclo-
sures divided into four pillars that represent core elements of 
how organisations operate. The four pillars are: governance, 
strategy, risk management, and metrics and targets. More 
over, the framework separates into three main categories: 
risks related to the physical impacts of climate change, risk  
related to the transition to a lower-carbon economy, and  
climate-related opportunities. The framework has also incor-
porated ﬁnancial impact as an integral part of its disclosure 
recommendations. 
As a part of Recharge`s ﬁrst ESG report, a climate risk disclo-
sure has been prepared in line with the recommendations set 
by the TCFD. The report has been reviewed and approved by 
the management team and the board of directors.
1.  GOVERNANCE
Disclose the organisation’s governance around climate- 
related risks and opportunities. 
a) Describe the board’s oversight of climate-related risks and 
opportunities 
The board of directors (the board) recognises the importance 
of steering the impact of potential climate-related risks 
and opportunities on Recharge`s business and strategy. The 
board therefore supports the recommendations of the Task 
Force on Climate-Related Financial Disclosures (TCFD).  
The board has the ultimate responsibility for management 
of climate-related issues in the company. The board has a 
responsibility to ensure that Recharge´s activities regarding 
climate issues are included in the company’s strategy, and  
that climate-related targets are deﬁned. The board receives 
regular updates from the management team in Recharge  
regarding ESG and climate risk. The board is responsible 
for ensuring that the risk management and internal control 
systems of Recharge accord with the regulations governing 
the business. The board reviews main risk areas and internal  
control systems annually, including strategy, The Code of 
Conduct and other company guidelines and policies.
b) Describe the management’s role in assessing and managing 
climate-related risks and opportunities.
The CEO at Recharge has the highest operational level  
responsibility for climate-related issues, risks and opportunities 
and is responsible for both assessing and managing climate- 
related risks and opportunities. The CEO and the rest of 
TASK FORCE ON CLIMATE-RELATED 
FINANCIAL DISCLOSURES
Core Elements of Recommended Climate-Related Financial Discolosures
Governance
Strategy
Risk management
Metrics and
Targets
Governance
The organisation´s governance around climate-related risks 
and opportunities.
Strategy
The actual and potential impacts of climate-related risks and 
opportunities on the organisation´s business, strategy and  
ﬁnancial planning.
Risk Management
The processes used by the organisation to identify, assess 
and manage climate-related risks.
Metrics and Targets
The metrics and targets used to assess and manage relevant 
climate-related risks and opportunities.
Governance
Recommended 
Disclosures
Strategy
Recommended 
Disclosures 
Risk management
Recommended  
Disclosures
Metrics & Targets
Recommended 
Disclosures 
Disclose the organisa-
tion’s governance around 
climate-related risks and 
opportunities.
a) Describe the board’s 
oversight of climate-re-
lated risks and opportu-
nities.
b) Describe the man-
agement’s role in as-
sessing and managing 
climate-related risks and 
opportunities.
isclose the actual and 
potential impacts of 
climate-related risks 
and opportunities on the 
organisation’s business, 
strategy, and ﬁnancial 
planning where such 
information is material.
a) Describe the cli-
mate-related risks and 
opportunities the organi-
sation has identiﬁed over 
the short, medium, and 
long term. 
b) Describe the impact 
of climate-related risks 
and opportunities on the 
organisation’s businesses, 
strategy, and ﬁnancial 
planning. 
c) Describe the resilience 
of the organisation’s 
strategy, taking into 
consideration diﬀerent 
climate-related scenar-
ios, including a 2°C or 
lower scenario. 
Disclose how the or-
ganisation identiﬁes, 
assesses, and manages 
climate-related risks
a) Describe the organ-
isation’s processes for 
identifying and assessing 
climate-related risks. 
b) Describe the organ-
isation’s processes for 
managing climate-relat-
ed risks. 
c) Describe how pro-
cesses for identifying, 
assessing, and manag-
ing climate-related risks 
are integrated into the 
organisation’s overall risk 
management. 
Disclose the metrics and 
targets used to assess 
and manage relevant 
climate-related risks and 
opportunities where such 
information is material 
a) Disclose the metrics 
used by the organisation 
to assess climate-related 
risks and opportunities 
in line with its strategy 
and risk management 
process. 
b) Disclose Scope 1, 
Scope 2, and, if appropri-
ate, Scope 3 greenhouse 
gas (GHG) emissions, and 
the related risks. 
c) Describe the targets 
used by the organisation 
to manage climate-relat-
ed risks and opportunities 
and performance against 
targets. 
79
78

TCFD DISCLOSURES
TCFD DISCLOSURES
Recharge’s management team will include relevant employees 
when assessing climate-related issues that occur in the com-
pany.  Director Legal, Compliance & ESG reports directly to 
the CEO but is not a part of Recharge’s management team.  
The process for managing climate-related opportunities  
often occurs in tandem with climate-related risk manage-
ment. The CEO, in collaboration with the Director Legal, 
Compliance & ESG, is responsible for proposing, implementing, 
and following up climate-related opportunity initiatives to-
gether with relevant employees in Recharge.
2. STRATEGY
Disclose the actual and potential impacts of climate-related 
risks and opportunities on the organisation’s businesses, 
strategy, and ﬁnancial planning where such information is 
material. 
a) Describe the climate-related risks and opportunities the 
organisation has identiﬁed over the short, medium, and long 
term.  
b) Describe the impact of climate-related risks and opportuni- 
ties on the organisation’s businesses, strategy, and ﬁnancial 
planning. 
Identiﬁed climate-related risks and opportunities  
In line with the recommendations laid out in the TCFD frame-
work, Recharge has in December 2022 conducted a pro-
cess to assess how – and to what extent – the company is 
exposed to climate risk and opportunities. Representatives 
from the management team and other key positions par-
ticipated in the workshop to identify signiﬁcant physical risk, 
transition risk and opportunities caused by climate change. 
In the workshop, the identiﬁed risks and opportunities were 
assessed in a strategic and ﬁnancial context in three diﬀer-
ent climate scenarios. More information about the scenario  
analyses is disclosed in chapter 2c.  
As 
climate-related 
risks 
and 
opportunities 
inﬂuence  
Recharge’s strategic and ﬁnancial planning diﬀerently in 
the short, medium, and long term, the company considered 
these three time horizons in the assessment. The following 
deﬁnitions of time horizons are applied:
 
For Recharge it is important to identify the most signiﬁcant 
climate-related risks and opportunities the company faces, 
as it can help us to make informed decisions about how to 
mitigate or take advantage of these factors. At the core of 
our ESG work is an ambition to contribute to limiting the long-
term global temperature increase to 1,5°C, in line with the 
Paris agreement. Our business is built on a renewable energy 
and the need for solutions to transform the transport sector 
in a transition to a low emission society. 
To identify and prioritise the risk factors of most importance, the factors potentially that could negatively impact the opera-
tions and the probability of occurrence were assessed: 
The prioritization of 2022, not been done regarding opportunities. This will be followed up on in 2023. In the following, the  
identiﬁed risks and opportunities are explained in more detail.
Time horizon
Year
Short term 
2022-2025 
Medium term  
2025-2035
Long term 
2035-2050
Happens
Eﬀect of threats
Not happen
Happens often
Can happen
Small
Big
Powe outages due 
to wind and stroms
Lack in political 
action to provide 
enough grid access
Material scarcity
Flood and landslides
Extreme heat waves
Power deﬁcit due 
to extreme weather 
conditions
Faster mar-
ket growth then 
developments in 
infrastructure
Rising sea levels
Decline in use of 
personal vehicles
Extreme weather 
events aﬀecting 
the supply chain
New and better 
technology
81
80

Identiﬁed
risk
Floods and 
landslides
Extreme 
weath-
er events 
aﬀecting the 
supply chain
Description
of risk
Climate change 
and temperature 
increases may 
lead to more 
rainfall, and in-
creased frequency 
of ﬂoods and 
landslides due to 
extreme amounts 
of rain.
Climate change 
and temperature 
increases may 
lead to increased 
cases of extreme 
weather all over 
the world.  This will 
impact Recharge`s 
supply chain and 
might lead to 
stops or delays 
in the supplies 
of materials and 
equipment need-
ed in operations 
and development.
- Downtime in op-
erations due to 
damage to 
equipment and 
charging stations. 
- Charging 
stations made 
unavailable to 
customers due to 
closed roads and 
areas. 
- Delays in pro-
duction of materi-
als and equipment 
needed to build 
and develop 
charging stations. 
- Increased prices 
due to high volume 
demand and scar-
city of materials.
- Lost sales due to 
downtime.
- Increased cost 
due to repairing of 
charging stations 
and equipment. 
 
Increased costs 
due to higher pric-
es on commodities 
and materials.   
Delays and stops 
in development of 
operations.
All scenarios. The 
risk will increase 
in slow adaption 
and climate chaos 
scenario. 
All scenarios. 
Short term, medi-
um term and long 
term. 
Frequency ex-
pected to increase 
at medium and 
long term.
Frequency ex-
pected to increase 
both on a medium 
term and long 
term.
Through our 
subcontractor 
assessments are 
carried out prior 
to establishment 
of charging 
stations, based on 
information from, 
among others, the 
Norwegian Water 
Resources and 
Energy Directorate 
(NVE). In cases 
of ﬂoods and 
landslides, NVE will 
issue a warning.
On-going 
dialogue with 
manufactures and 
suppliers.
Potential
impacts
Potential
ﬁnnancial 
impacts
Most 
relevant 
scenario
Time 
horizon
Mitigation 
strategy
Acute physical risk 
Through our acute physical risk identiﬁcation process, we identiﬁed ﬂoods and landslides and extreme weather 
conditions that might lead to events of power outages, power deﬁcit and delays in the supply chain as signiﬁcant to 
Recharge. Such events may impact Recharge’s direct operations, cause disruptions in the supply chain and increase 
costs
RISK
RISK
Power out-
ages due 
to wind and 
storms
Power 
deﬁcit due 
to extreme 
weather 
conditions
Extreme 
heat waves
Climate change 
and temperature 
increases may 
lead to increased 
frequency of wind 
and storms. Cases 
of trees falling on 
lines, water ingress, 
and lightning 
strikes may aﬀect 
the likelihood 
and frequency of 
power outages.
Increased cases of 
extreme weather 
and less rainfall 
may lead to lack 
of power supply 
in Europe which is 
highly dependent 
on hydro power.
Climate change 
and temperature 
increases may 
lead to cases of 
extreme heat 
waves, even in the 
Nordics.
- Downtime in 
operations due to 
lack of electricity. 
- Downtime in 
operations due to 
lack of power and 
electricity. 
- Some com-
ponents used in 
charging stations 
are vulnerable 
to increase heat. 
Damage could 
lead to downtime 
in operations. 
- Lost sales due to 
downtime
- Lost sales due to 
downtime.
- Lost sales due to 
downtime
- Increased cost 
due to repairing of 
charging stations 
and equipment. 
All scenarios.
A possibility in all 
scenarios.
Slow adaption 
and climate chaos 
scenario.
Short-term, medi-
um term and long 
term. 
Frequency ex-
pected to increase 
at medium and 
long term.
Frequency ex-
pected to increase 
both on a medium 
term and long 
term.
Frequency ex-
pected to increase 
both in a medium 
term and long 
term.
Recharge will as-
sess and monitor 
energy usage, 
in order to have 
equipment that 
still can provide up 
time even with lack 
of less rainfall.
Dialogue with 
manufactures to 
ensure that equip-
ment withstands 
extreme heat.   
Replacement of 
electrical com-
ponents that can 
withstand higher 
heat and instal-
lation of cooling 
fans.
Identiﬁed
risk
Rising sea 
levels
Description
of risk
Sea levels may rise 
due to expanding 
ocean volumes 
from temperature 
increases and from 
melting glaciers 
and ice sheets.  
A need to relocate 
some charging 
stations where ris-
ing sea level might 
aﬀect operations.
- Lost sales.  
- Increased cost 
related to  
relocation.  
Climate chaos 
scenario.
Long term.
Conducting net-
work development 
assessments relat-
ed to the potential 
of rising sea levels 
in the future.
Potential
impacts
Potential
ﬁnnancial 
impacts
Most 
relevant 
scenario
Time 
horizon
Mitigation 
strategy
Chronic physical risk 
Chronic physical risks refer to longer term shifts in climate patterns, such as sustained higher temperatures that may 
cause sea level rise or chronic heat waves.  For Recharge, rising sea level is addressed as the one of signiﬁcance:
PHYSICAL RISK
TCFD DISCLOSURES
TCFD DISCLOSURES
83
82

TCFD DISCLOSURES
TCFD DISCLOSURES
Identiﬁed
risk
Lack in po-
litical action 
to provide 
enough grid 
access 
Reluctance 
to new ener-
gy sources
Description
of risk
Political reluctance 
to expansion 
of the pow-
er grid, lack in 
development of 
infrastructure and 
eﬃcient utilisation 
of existing power 
grids may lead 
to reduced grid 
assess needed 
for Recharge’s 
operations and 
development.   
Development 
of new energy 
sources is crucial 
for providing 
enough energy in 
the transition to a 
low emission soci-
ety. Due to some 
reluctance in the 
population for en-
ergy sources such 
as development of 
wind and nuclear 
power, there is a 
risk that political 
will might be 
aﬀected. The result 
might be less ener-
gy available than 
what is needed for 
a full and eﬀective 
transition to EVs in 
the transportation 
sector.
-Downtime in 
operations due 
to lack of energy 
capacity 
-A slowdown in 
development of 
charging stations.
-Downtime in 
operations due 
to lack of energy 
capacity 
-A slowdown in 
development of 
charging stations.
In case of lack 
in grid access, 
Recharge will need 
to slow down de-
velopment, which 
will have a direct 
impact on revenue. 
Further, existing 
charging stations 
might be aﬀected 
due to lack of 
energy.
Less energy avail-
able may cause 
Recharge to slow 
down develop-
ment, which will 
have a direct 
impact on revenue. 
Further, existing 
charging stations 
might be aﬀected 
due to lack of 
energy.
All scenarios, but 
the risk is increas-
ing in climate 
chaos and slow 
adaption society 
where there might 
be less policy and 
regulation intro-
duced to secure 
the transition to 
renewable energy 
solutions.
The risk is increas-
ing in climate 
chaos and slow 
adaption society 
where there might 
be less policy 
and regulation 
introduced for de-
velopment of low 
emission energy 
solutions.
Short term and 
medium term.
Medium and long 
term.
As this is one of the 
biggest challenges 
the charging 
industry is facing 
today, the industry 
has established 
“Drivkraft Norge”, 
which among oth-
er things, aims to 
put political pres-
sure on authorities 
with the aim to 
develop the power 
grid faster.
The industry 
has established 
“Drivkraft Norge”, 
with the aim to put 
political pressure 
on authorities 
regarding the de-
velopment of new 
energy solutions to 
meet the demand 
of energy needed 
for a successful 
transition to EV 
transportation.
Potential
impacts
Potential
ﬁnnancial 
impacts
Most 
relevant 
scenario
Time 
horizon
Mitigation 
strategy
Transition risk: policy and legal 
Transitioning to a lower-carbon economy may involve extensive policy-related and legal changes to address mitiga-
tion of impacts and adaptation requirements related to climate change. Recharge has identiﬁed political resistance 
and lack of action as most signiﬁcant.
TRANSITION RISK
85
84

TCFD DISCLOSURES
TCFD DISCLOSURES
Identiﬁed
risk
Decline 
in use of 
personal   
vehicles 
Faster mar-
ket growth 
than devel-
opments in 
infrastruc-
ture
Description
of risk
There is a risk that 
a transitions to 
a low emission 
society and the 
attention around 
climate change 
will impact the 
consumer behav-
iour related to the 
use of vehicles. 
As more focus is 
placed on the 
need for action on 
all levels in society, 
more people might 
replace personal 
vehicles with  pub-
lic transport, and 
car sharing and 
car hire services 
when a vehicle is 
needed.  
There is a high and 
growing demand 
for EV charging 
in the Nordics, 
and the market 
is developing 
rapidly.  Infrastruc-
ture needed on 
the other hand is 
not developing as 
fast as needed to 
cover the demand 
from consumers 
and charging 
companies.
As personal 
vehicles are 
Recharge`s market 
segment today, a 
decline in demand 
might rapidly 
aﬀect the business 
and operations.
Slower develop-
ment in infrastruc-
ture than what is 
required from the 
consumer demand 
might lead to long 
queues, which 
might give the 
charging industry 
a bad reputa-
tion. Further, the 
industry might 
be blamed for 
excessive load on 
the power grid.  
Decrease in 
market share and 
revenue.
Reputational risk 
might have an ef-
fect on Recharge’s 
revenue. 
Low emission 
society.
Slow adaption 
society
Short term and 
medium term.
Medium term
Recharge might 
have to relocate 
to other markets 
and products. One 
way to do this is 
to participate in 
development and 
technology pro-
jects together with 
the industry.
The industry 
has established 
“Drivkraft Norge”, 
with the aim to put 
political pressure 
on authorities 
regarding the 
development 
of infrastructure 
needed for a suc-
cessful transition to 
EV transportation.
Potential
impacts
Potential
ﬁnnancial 
impacts
Most 
relevant 
scenario
Time 
horizon
Mitigation 
strategy
Transition risk: market 
While the ways in which markets could be aﬀected by climate change are varied and complex, one of the major ways 
is through shifts in supply and demand for certain products and services. Recharge has identiﬁed a decline in the use 
of personal vehicles as risk of signiﬁcance.
Transition risk: reputation 
Climate change has been identiﬁed as a potential source of reputational risk tied to changing customer or community 
perceptions of an organisation’s contribution. Recharge has identiﬁed a lack of speed in development in infrastructure 
compared to a rapid market demand as a risk of signiﬁcance.
TRANSITION RISK
Identiﬁed
risk
New and 
better tech-
nology
Material 
scarcity
Description
of risk
As the technology 
is rapidly improving 
to transit to a low 
emission society, 
there is a risk that 
competitors are 
introducing newer 
and better tech-
nology making 
EV charging more 
eﬃcient for the 
customer. There 
is  also risk related 
to developments 
in technologies 
such as hydrogen, 
which might 
aﬀect the market 
demand for EVs. 
New technology 
such as charging 
while driving on 
rechargeable 
roads might also 
aﬀect the industry 
in the future.   
Rapid develop-
ment in the EV 
market might 
lead to scarcity of 
materials needed 
for production and 
development of 
changing stations. 
Materials used are 
also components 
in other technolo-
gy products, which 
will also aﬀect the 
level of scarcity 
globally.
- Changes in con-
sumer behaviour 
to newer and 
better solutions 
provided by com-
petitors.  
- New technology 
that might outper-
form EV charging.
- Delays in pro-
duction of equip-
ment needed to 
build charging 
stations.  
- Increased prices 
due to higher de-
mand the supply 
of materials.   
- Decrease in 
market share and 
revenue.
-Increased materi-
al costs.  
-Slowdowns 
or stops in the 
development of 
operations.  
Low emission 
society
Low emission 
society and slow 
adaption society.
Medium and long 
term.
Medium term and 
long term.
Recharge works 
with various tech-
nology projects. 
An example is 
the development 
of wireless taxi 
charging in Oslo, 
which is a step 
towards dynamic 
charging rather 
than using classic 
charging stations.
On-going 
dialogue with 
manufactures and 
suppliers.
Potential
impacts
Potential
ﬁnnancial 
impacts
Most 
relevant 
scenario
Time 
horizon
Mitigation 
strategy
Transition risk: technology 
Technological improvements or innovations that support the transition to a lower-carbon and energy-eﬃcient 
economic system can have a signiﬁcant impact on organisations.  Recharge has identiﬁed development of new and 
better technology and material scarcity as most signiﬁcant.
TRANSITION RISK
87
86

TCFD DISCLOSURES
TCFD DISCLOSURES
Identiﬁed 
opportu-
nities 
A business 
well suited 
for climate 
change 
adaption
Description 
of oppor-
tunity 
As the market 
leader in the 
Nordics, Recharge 
is well suited for 
contributing and 
taking further mar-
ket share in the EV 
charging market.
To keep the global 
temperature rise 
in line with the 
Paris agreement, 
a transition to low 
emission transpor-
tation solutions 
is necessary. 
EV technology 
is a well suited 
and developed 
technology in this 
regard.
Increased market 
share and revenue.  
Low emission 
society and slow 
adaption society.
Long term and 
medium term.
Make arrange-
ments to meet the 
market’s needs 
and continue 
to take market 
shares.
Potential 
ﬁnancial 
impacts 
Most 
relevant 
scenario
Time 
horizon
Positioning 
strategy
Resilience 
The concept of climate resilience involves organisations developing adaptive capacity to respond to climate change 
to better manage the associated risks and seize opportunities, including the ability to respond to transition risks and 
physical risks.  Recharge has identiﬁed resilience due to being a company well suited for the transition to a low emis-
sion society as an opportunity.
OPPORTUNITIES
c. Describe the resilience of the organisation’s strategy, taking into consideration diﬀerent climate-related scenarios, including 
a 2°C or lower scenario.  
Scenario analysis 
Scenario analysis is a well-established method for developing strategic plans that are more ﬂexible or robust to a range of 
plausible future states. In line with the recommendations laid out in the TCFD framework, Recharge included scenarios in the 
climate risk assessment to identify and highlight how the diﬀerent scenarios might play out related to the identiﬁed risks and 
opportunities. The following scenarios were applied
Potential 
impacts of 
exploring the 
opportunity 
Identiﬁed 
opportu-
nities 
Increased  
utilisation of 
the power 
grid
New markets 
for electric 
charging
Description 
of oppor-
tunity 
Load-balancing 
charging stations 
can utilise the 
power output in 
a more sustain-
able way going 
forward. This is 
not only related 
to the chargers 
in Recharge’s 
operations, but 
also load balances 
towards the power 
grid in the markets 
Recharge oper-
ates in.
A transition to 
a low emission 
society will require 
low emission 
technology in the 
markets for goods 
transport and 
construction. To 
be able to lower 
emissions, a tran-
sition to EVs and 
electric machines 
is needed.
With ﬂexible 
agreements, there 
is an opportunity 
for increased 
utilisation of the 
power grid in the 
markets Recharge 
operates in. 
Further, there is 
a possibility of 
creating an energy 
market.
A transition to 
EVs and electric 
machines in goods 
transportation and 
construction will 
increase the de-
mand for electric 
charging. As new 
markets are devel-
oping, it will have 
a direct impact 
on Recharge’s 
business.
-New markets and 
revenue.  
-Lowered cost due 
to higher eﬃciency. 
-New markets and 
increased revenue.  
-Increased cost for 
developments into 
new markets.
Low emission 
society
Low emission 
society and slow 
adaption.
Medium term
Medium term.
A solution for 
this is already in 
place in Finland. 
Sweden is under 
development. 
As for Norway, 
Recharge expect 
the developments 
to be slower with 
solutions intro-
duced in 2030 at 
the earliest.
Assess the 
potential for new 
markets on an 
ongoing basis.
Potential 
impacts of 
exploring the 
opportunity 
Potential 
ﬁnancial 
impacts 
Most 
relevant 
scenario
Time 
horizon
Positioning 
strategy
Resource eﬃciency 
It is proven to be possible for organisations to reduce operating costs by improving eﬃciency across production and 
distribution processes. Recharge has addressed increased utilisation of the power grid as an opportunity of signiﬁ-
cance.
Markets 
Organisations that proactively seek opportunities in new markets or types of assets may be able to diversify their 
activities and better position themselves for the transition to a lower-carbon economy. Recharge has identiﬁed the 
potensial of new markets for electric charging as an opportunity.
OPPORTUNITIES
89
88

TCFD DISCLOSURES
TCFD DISCLOSURES
3. RISK MANAGEMENT
Disclose how the organisation identiﬁes, assesses, and 
manages climate-related risks:  
a) Describe the organisation’s processes for identifying
and assessing climate-related risks  
b) Describe the organisation’s processes for managing
climate-related risks  
c) Describe how processes for identifying, assessing,
and managing climate-related risks are integrated into the 
organisation’s overall risk management. 
The identiﬁcation, assessment, and management of cli-
mate-related risks and opportunities is an integral part of Re-
charge`s multidisciplinary risk and opportunity management.  
The board of directors and management team conduct 
regular reviews of the company’s activities for identifying,  
assessing, and responding to climate-related risks and  
opportunities.  
2022 was the ﬁrst year of implementation of the climate-risk 
management process recommended in the TCFD framework. 
The identiﬁcation and assessment process were conducted 
through a workshop with representatives from the manage-
ment team and other key personnel, providing a balanced 
picture of the risks and opportunities Recharge faces due to 
climate change and the transition to a low emission society.
4. METRICS AND TARGETS 
Disclose the metrics and targets used to assess and manage 
relevant climate-related risks and opportunities where such 
information is material.  
a) Disclose the metrics used by the organisation to assess  
climate-related risks and opportunities in line with its strategy 
and risk management process. 
b) Disclose Scope 1, Scope 2 and, if appropriate, Scope 3 
greenhouse gas (GHG) emissions and the related risks. 
c) Describe the targets used by the organisation to manage 
climate-related risks and opportunities and performance 
against targets. 
Recharge aims to drive change by accelerating the green 
transition through introducing new technology and solutions 
that ease the transition to EVs and smarter mobility solu-
tions. We will contribute to ﬁghting global warming by being  
carbon neutral in our company and value chain by 2030 and 
net zero by 2050. 
The following metrics will contribute to the goal:  
• Mapping the carbon footprint in scope 1, 2 and 3 in 2023.   
• Establishing a climate strategy by 2023.   
• 100 per cent renewable energy in chargers by 2023.  
• Establishing a procurement policy on suppliers’ carbon  
 footprint strategies and plans to ensure alignment with net  
 zero goals, by 2024.    
• Provide responsible grid utilisation with 100% load balancing  
 on site in 2025.   
• Oﬀ set all emissions in Scope 1 and Scope 2 with certiﬁcates  
 (CERs) for the year 2023.  
From 2022, Recharge discloses sustainability data in accord-
ance with the GRI Universal Standards. GHG emissions are 
not available for 2022. Please see page the environmental 
chapter in the report for more information about how  
Recharge manages the area of climate change and GHG 
emissions.   
Low-emission society
Slow adaption society
Climate chaos society
In this scenario, we assume that all the goals of the Paris Agreement are met, and the global 
temperature increase is limited to 1.5 °C compared to preindustrial levels. The scenario 
presumes a rise in climate policy ambitions and the pace of climate regulation is high. The 
scenario also assumes that global CO2 emissions decline fast and that technological solutions 
are developed to cut emissions rapidly.  
A high carbon price is introduced in most economies, and global power is mainly generated 
using renewables. Customers, suppliers, investors, and societies are increasingly becoming 
climate-conscious and demand more sustainable products and operations. Transitional risks 
and opportunities dominate the low-emission society scenario, and the physical risks are of 
less magnitude than expected in the early 2020s.
In the slow adaption society scenario, the global temperature increase is limited to 2 degrees. 
However, it takes time before the world’s countries deliver emission reductions in line with the 
Paris Agreement. But, because of stricter climate policy around year 2030, the global temper-
ature increase stabilised at 2 °C compared to preindustrial levels in 2050.  
The costs of phasing out fossil fuels is higher than in the low-emission society scenario, due to 
lack of ﬁnancial incentives to transform. Gradually, ground-breaking technology is introduced 
that accelerates the low-carbon development. The scenario is dominated by increasing  
physical risks due to a lack of coordinated policy actions to limit climate change, but an  
increasing focus on transitional risks and opportunities around year 2030 is also relevant. 
In a climate chaos society scenario, the global average temperature is projected to increase 
by 4°C or more by the end of this century, compared to preindustrial levels. This scenario is 
based on the assumption that there will be no signiﬁcant eﬀorts to reduce greenhouse gas 
emissions and that the global economy will continue to operate as it does today. 
In the climate chaos society scenario, the impacts of climate change are expected to be  
severe and widespread. There could be signiﬁcant disruption to global food production,  
leading to shortages and price increases. There could also be more frequent and intense 
heatwaves, droughts, and extreme weather events, such as ﬂoods and hurricanes, which 
could cause physical damage to infrastructure and disrupt economic activity. In addition, 
sea levels are likely to rise, leading to increased coastal ﬂooding and erosion, and threatening 
low-lying areas and small islands. The impacts of the BAU 4°C scenario is expected to  
disproportionately aﬀect vulnerable communities and ecosystems.
SCENARIO
91
90

GRI Content Index
93
92

GRI 2: General disclosures
The organization and its reporting practices
2-1
2-2
2-3
2-4
2-5
Activities and workers
2-6
2-7
2-8
Governance
2-9
2-10
2-11
2-12
2-13
2-14
2-15
2-16
2-17
2-18
2-19
2-20
2-21
Strategy, policies and practices
2-22
2-23
2-24
2-25
2-26
2-27
2-28
Stakeholder engagement
2-29
2-30
GRI 3: MATERIAL TOPICS
3-1
3-2
3-3
Complete
Complete
Complete
Complete
Complete
Complete
Requirement 2-7b is not disclosed
N/A 
Complete
Complete
Complete
Complete
Complete
Complete
Complete
Requirement 2-16 b is not disclosed
Complete
Complete
Complete
Complete
Not complete
Complete
Complete
Complete
N/A 
Complete
Complete
Complete
Incomplete
Incomplete
Complete
Complete
Organizational details
Entities included in the organization’s sustainability reporting
Reporting period, frequency and contact point
Restatements of information
External assurance
Activities, value chain and other business relationships
Employees
Workers who are not employees
Governance structure and composition
Nomination and selection of the highest governance body
Chair of the highest governance body
Role of the highest governance body in overseeing the management of impacts
Delegation of responsibility for managing impacts
Role of the highest governance body in sustainability reporting
Conﬂicts of interest
Communication of critical concerns
Collective knowledge of the highest governance body 
Evaluation of the performance of the highest governance body
Remuneration policies
Process to determine remuneration
Annual total compensation ratio
Statement on sustainable development strategy
Policy commitments
Embedding policy commitments
Processes to remediate negative impacts
Mechanisms for seeking advice and raising concerns
Compliance with laws and regulations
Membership associations
Approach to stakeholder engagement
Collective bargaining agreements
Process to determine material topics
List of material topics
Management of material topics
Not applicable. Recharge does not have temporary, part time e.g employees  
Not applicable. Recharge does not have temporary, part time e.g employees  
Information unavailable
Information unavailable
Information unavailable
Limited to stakeholder engagement in the prosess of materiality assessment
Information unavailable
GRI CONTENT INDEX
GRI CONTENT INDEX
GRI disclosure
COMPLETNESS
GRI description
REASON FOR OMISSION
GENERAL DISCLOSURES
MATERIAL TOPICS
Location
GRI CONTENT INDEX
Recharge has reported the information cited in this GRI content index for the period January 1 2022, to December 31 2022, 
in accordance with the GRI Universal Standards 2021. 
 
Page 7-13
Page 27
Page 27
Page 27
Page 27
  
Page  7 and 12
Page 58-59
N/A
  
Page 26, 53-54 and 60 
Page 53
Page 26 og 53
Page 26
Page 26
Page 26
Page 53
Page 26 and 53-54
Page 26 and 53
Page 53
Page 54
Page 54
N/A
  
Page 6 and page 18-25
Page 25,43 and 52
Page 25 and 52
N/A
Page 26, 41 and 55
Page 54
Page 44
Page 17
N/A
 
Page 17
Page 17
Location stated under 
each material topic 
95
94

GRI CONTENT INDEX
GRI CONTENT INDEX
GRI disclosure
COMPLETNESS
GRI description
REASON FOR OMISSION
Location
3-3
GRI 305: EMISSIONS 2016
305-1 
305-2
305-3
305-4
305-5
GRI 302: ENERGY 2016
302-1
302-2
302-3
302-4
302-5 
GRI 304: BIODIVERSITY 2015
304-1
304-2
304-3
304-4
GRI 308: SUPPLIER ENVIRONMENTAL  
ASSESSMENT 2016
308-1
308-2
GRI 306: WASTE 2020
306-1
306-2
306-3
306-4
306-5
3-3
GRI 401:  EMPLOYMENT 2016
401-1
401-2
401-3
GRI 405: DIVERSITY AND EQUAL OPPORTUNITY 
2016
405-1
405-2
GRI 406: NON-DISCRIMINATION 2016
406-1
N/A
Incomplete
N/A
N/A
N/A
Complete
N/A
N/A
N/A
N/A
Complete
Complete
N/A
Complete
N/A
N/A
Complete
Complete
N/A
N/A
N/A
Complete
Complete
Complete
Complete
Complete
Incomplete
Complete
Management of material topics
Direct (Scope 1) GHG emissions
Energy indirect (Scope 2) GHG emissions
Other indirect (Scope 3) GHG emissions
GHG emissions intensity
Reduction of GHG emissions
Energy consumption within the organisation
Energy consumption outside of the organization
Energy intensity
Reduction of energy consumption
“Reductions in energy requirements of products and services products and services”
Operational sites owned, leased, managed in, or adjacent to, protected areas and areas of 
high biodiversity value outside protected areas
Signiﬁcant impacts of activities, products and services on biodiversity
Habitats protected or restored
IUCN Red List species and national conservation list species with habitats in areas aﬀected 
by operations
New suppliers that were screened using environmental criteria
Negative environmental impacts in the supply chain and actions taken
Waste generation and signiﬁcant waste-related impacts
Management of signiﬁcant wasterelated impacts
Waste generated
Waste diverted from disposal
Waste directed to disposal
Management of material topics
New employee hires and employee turnover
Beneﬁts provided to full-time employees that are not provided to temporary or parttime employees
Parental leave
Diversity of governance bodies and employees
Ratio of basic salary and remuneration of women to men
Incidents of discrimination and corrective actions taken
Information unavailable. Area of focus in 2023.
Limited to total aggregated GHG emission related to energy consumption. 
Information unavailable. Area of focus in 2023.
Information unavailable. Area of focus in 2023
Information unavailable. Area of focus in 2023
Information unavailable. Area of focus in 2023.
Information unavailable. Area of focus in 2023.
Information unavailable. Area of focus in 2023.
Information unavailable. Area of focus in 2023.
Information unavailable. Area of focus in 2023.
Information unavailable.
Information unavailable. Assessments not conducted by Recharge in 2022. 
Information unavailable. Assessments not conducted by Recharge in 2022. 
Information unavailable.
Information unavailable.
Information unavailable.
Ratio not disclosed
ENVIRONMENT
SOCIAL
Nature and climate crises
Diversity
Page 30-35 and TCFD 
disclosure page 77
N/A
Page 58
N/A
N/A
N/A
Page 33 and page 58
N/A
N/A
N/A
N/A
Page 34
Page 34
N/A
Page 34
N/A
N/A
Page 33
Page 33
N/A
N/A
N/A
Page 39-42
Page 40 and 59
Page 40
Page 59
Page 60
Page 60
Page 41 og 61
97
96

GRI CONTENT INDEX
GRI CONTENT INDEX
GRI disclosure
COMPLETNESS
GRI description
REASON FOR OMISSION
Location
3-3
GRI 414: SUPPLIER SOCIAL ASSESSMENT 2016
414-1
414-2 
GRI 408: CHILD LABOR 2016
408-1
GRI 409: FORCED OR COMPULSORY LABOR 
2016
409-1
GRI 407: FREEDOM OF ASSOCIATION AND 
COLLECTIVE BARGAINING 2016
407-1
3-3
GRI 404: TRAINING AND EDUCATION 2016
404-1
404-2
404-3
3-3
GRI 403: OCCUPATIONAL HEALTH AND  
SAFETY 2018
403-1
403-2
403-3
403-4
403-5
403-6
403-7
403-8
403-9
403-10
GRI 205: ANTI-CORRUPTION 2016
205-1
205-2
205-3
Complete
Incomplete
N/A
N/A
N/A
N/A
Complete
N/A
Complete
Incomplete
Complete
Complete
Complete
N/A
Incomplete
Incomplete
N/A
Incomplete
Complete
Complete
Incomplete
N/A
Complete
Complete
Management of material topics
New suppliers that were screened using social criteria
Negative social impacts in the supply chain and actions taken
Operations and suppliers at signiﬁcant risk for incidents of child labor
Operations and suppliers at signiﬁcant risk for incidents of forced or compulsory labor
Operations and suppliers in which the right to freedom of association and collective bargaining 
may be at risk
Management of material topics
Average hours of training per year per employee
Programs for upgrading employee skills and transition assistance programs
Percentage of employees receiving regular performance and career development reviews
Management of material topics
Occupational health and safety management system
Hazard identiﬁcation, risk assessment, and incident investigation
Occupational health services
Worker participation, consultation, and communication on occupational health and safety
Worker training on occupational health and safety
Promotion of worker health
Prevention and mitigation of occupational health and safety impacts directly linked by 
business relationships
Workers covered by an occupational health and safety management system
Work-related injuries
Work-related ill health
Operations assessed for risks related to corruption
Communication and training about anti-corruption policies and procedures
Conﬁrmed incidents of corruption and actions taken
Information disclosed based on that all new suppliers sign the Recharge 
Code of Conduct
Information unavailable. In progress. 
Information unavailable. In progress. 
Information unavailable. In progress. 
Information unavailable. In progress. 
Information unavailable.
Distribution by gender and employee category not disclosed. In progress. 
Information unavailable.
Limited information disclosed. Information unavailable.
Limited information disclosed. Information unavailable.
Information unavailable.
Limited information disclosed. Information unavailable.
Information limited to sickleave. 
Information unavailable.
SOCIAL
GOVERNANCE
Human rights
Knowledge and competence
Transparency
Page 43-45
Page 61
N/A
N/A
N/A
N/A
Page 49-51
N/A
Page 49
Page 61
Page 52-55
Page 54-55
Page 55
N/A
Page 55
Page 54-55
N/A
Page 55
Page 54 and page 62
Page 55 and page 62
Page 59
N/A
Page 54
Page 54 and 61
99
98

GRI CONTENT INDEX
GRI CONTENT INDEX
GRI disclosure
COMPLETNESS
GRI description
REASON FOR OMISSION
Location
GRI 205: ANTI-CORRUPTION 2016
205-1
205-2
205-3
GRI 206: ANTI-COMPETITIVE BEHAVIOR 2016
206-1
GRI 416: CUSTOMER HEALTH AND SAFETY 
2016
416-1
416-2
GRI 417: MARKETING AND LABELING 2016
417-1
417-2
417-3
GRI 418: CUSTOMER PRIVACY 2016
418-1
N/A
Complete
Complete
Complete
N/A
N/A
N/A
Complete
Complete
Complete
Operations assessed for risks related to corruption
Communication and training about anti-corruption policies and procedures
Conﬁrmed incidents of corruption and actions taken
Legal actions for anti-competitive behavior, anti-trust, and monopoly practices
Assessment of the health and safety impacts of product and service categories
Incidents of non-compliance concerning the health and safety impacts of products and services
Requirements for product and service information and labeling
Incidents of non-compliance concerning product and service information and labeling
Incidents of non-compliance concerning marketing communications
Substantiated complaints concerning breaches of customer privacy and losses of customer 
data
Information unavailable.
Information unavailable.
Information unavailable.
Information unavailable.
GOVERNANCE
Transparency
N/A
Page 54
Page 54 and 61
Page 62
N/A
N/A
N/A
Page 61
Page 61
Page 55
101
100

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