2023 Environmental, Social, and Governance Report

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Contents

OVERVIEW

DELIVERING A
TRUSTED BUSINESSCONTRIBUTING
TO SOCIETY

Letter from our CEO

3

Introduction

18

About Crayon

4

Our approach to ESG

9Promoting integrity, legal
compliance, and transparency

19

About this report

13

PROTECTING
THE PLANET

Introduction

24

Introduction

36

Enhancing employee well-being

25

Greening the IT landscape

37

Facilitating a circular economy

39

Maintaining data privacy and security 20

Advocating for diversity, equity,and inclusion30

Deploying AI responsibly

Respecting labor and human rights

32

Supporting local communities

34

21

ANNEXESManaging greenhouse gas emissions 40

A. Task Force on Climate-related
Financial Disclosures (TCFD) Index 44
B. Sustainability AccountingStandards (SASB) Index

46

C. 2023 EU Taxonomy Report

49

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Letter from our CEO
Dear Crayon shareholders, customers,
partners, and colleagues,

have comprehensive systems in place to ensure strong
corporate governance and risk management at alllevels of our business.

device management program to purchase moreenvironmentally friendly equipment for use by our
employees, practicing circular economy principles.

The year 2023 was notable for incredible change thatcame at a remarkable pace. There were challenging
economic conditions, geopolitical tensions, andunprecedented advancements in the capabilities andadoption of AI.

We achieved group-wide ISO 37001 certification in
2023, affirming that we have robust systems in place
to manage bribery-related risks and incidents. We
maintained our strong privacy and security culture,underpinned by investments in state-of-the art
technology and the relevant certifications. Crayon’s
responsible AI guidelines were embedded into all
external and internal AI projects and tools, protecting
users and society at large.

Closing remarks

Contributing to society

Sincerely,

As a global tech company, Crayon was not immune tothese external forces which created opportunities aswell as potential challenges and risks. To successfully
navigate these changes, we drew on our company
values of integrity, quality, pace, and agility.
Regardless of what was happening in the world, wenever lost sight of our vision of believing in the powerof technology to drive the greater good.
We continued to be a socially responsible company,
as evidenced by the comprehensive and impactfulenvironmental, social, and governance (ESG) activities
described in this report. We did this while achieving
commercial success – our financial performance is
described in our separate 2023 Annual Report.
Crayon consistently matures in its approach to ESG,
with steadfast support and leadership from myself,
the rest of the executive management team, and
our Board of Directors. My philosophy is that when I
commit to something, I need to deliver on it. Thanks to
the joint efforts of all our Crayonites, I am proud to say
we certainly delivered on ESG in 2023.

Delivering a trusted businessLeading with integrity is critical as it is the basis forbuilding trust, which Crayon must stand behind with
our employees, customers, and shareholders. We

Crayon played a role in local and national economic
development by creating jobs — our workforce grewby 16.65% in 2023 compared to 2022. We cultivateda culture of diversity, equity, and inclusion, with 65
nationalities represented in our workforce and women
occupying 32% of all roles at Crayon. We respectedlabor and human rights in our own operations andin our supply chain, conducting due diligence andpossessing the capacity to take corrective action
where necessary. We donated a total of US $106,012
to various charities worldwide and almost half
our employees volunteered to support our local
communities as part of our Crayon Cares initiative.

Protecting the planet
We tapped into our core strengths in areas such asdata analytics and AI to offer solutions that helped
our customers improve their environmental and social
performance in 2023. Catering to these customer
demands is an emerging revenue stream for Crayon.
Within our own operations, our combined Scope 1,
2 and 3 greenhouse gas emissions were 17,793 tonsof CO2 in 2023. We launched our global sustainable

Our ESG accomplishments to date provide a strong
foundation for the future. I look forward to making
even bigger strides in 2024, knowing we have the skills,
passion, and goodwill to become a more sustainable
company that creates long-term stakeholder value.

Melissa Mulholland, Chief Executive Officer

I look forward to making evenbigger strides in 2024, knowing
we have the skills, passion, andgoodwill to become a moresustainable company thatcreates long-term stakeholder
value.
– Melissa Mulholland, CEO

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DELIVERING A TRUSTED BUSINESSABOUT CRAYON
We believe in the power of technology
to drive the greater good.

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5ANNEXESOur businessCrayon is a customer-centric
information technology (IT)consultancy that enables customers
to maximize their software and cloudinvestments.
We help customers reduce costs, optimize theirsoftware and cloud, and leverage new opportunities
in AI. We have a global supply chain, partnering withthousands of software suppliers and three hyperscale
cloud providers to deliver our services.
Founded in Norway 22 years ago, our internationalpresence has grown. Today, our key markets are theNordics (our largest and most mature), Europe, Asia
Pacific, Middle East, Africa, and the United States.

4,021 FTEs

4 Main service offerings

46 countries

Full-time equivalent
employees worldwide

•
•
•
•

Software procurement
IT cost management
Cloud services
Data and AI solutions

Where Crayon is located80,000 customers

49.1 NOK billion

6.4 NOK billion

From SMEs to large enterprises,with a high share in public sector

Gross sales

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6ANNEXESOur values
Our core values are based on
our Nordic heritage.

INTEGRITYQUALITY

PACE

AGILITY

With our actions weshow integrity and weare accountable for ouractions and inactions

What we do, we do withexcellence and better
than anyone else

We are customer focused
and act and execute withurgency

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Our organizational structure
Crayon Group Holding ASA (Crayon)
is a Norwegian public limited liability
company incorporated and registeredin Norway. As a publicly traded
company, Crayon is listed on the Oslo
Børs (Oslo Stock Exchange) under the
ticker code CRAYN.
Crayon Group Holding ASA is the holding andparent company of the Crayon Group, with global
headquarters in Oslo, Norway. Through various
subsidiaries, Crayon has an operational presence in
46 countries worldwide in the form of sales, consulting,and technical support offices.
Additional details about Crayon’s legal form,ownership structure, and subsidiaries are provided inour separate 2023 Annual Report.

The Crayon Group comprises different customer-facing brands with local market resonance:

Part of7

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Our awards and recognitions
Crayon believes in executing withexcellence to achieve success. We are
grateful for the acknowledgement our
dedication received in 2023.
Crayon and our subsidiary company Anglepoint werenamed as Leaders in the Gartner Magic Quadrant for
Software Asset Management (SAM) Services1. Severalof our local offices were also acknowledged by media
companies like CRN and ARN for our innovative
solutions and our commitment to our customers andpartners.
Awards and recognition from our vendors included
those from Microsoft, Amazon Web Services (AWS),
Google, IBM, and Oracle. For example:• Microsoft Azure Expert MSP• AWS Premier Partner Status­

We were recognized foraccomplishments tied to ESG
Contributing to society• Great Place to Work Certified in India, US,
United Arab Emirates, and Africa.
• Crayon Australia won the Distributor forSocial Good award at the CRN Australia
Impact Awards for the second consecutive
year.
• Crayon participated in the 2023 SHE Index,
Europe’s largest gender diversity index1.
• Crayon was named 2023 Global Diversity
and Inclusion Employer of the Year by The
Digital Revolution Awards.
• Crayon was named a Social Impact Award
Winner by CRN, an IT media brand.
Protecting the planet• Crayon was rated a Category 3 performer
on PwC’s 2023 Climate Index which
evaluates the climate impact of Norway’s
100 largest companies.
1

1

Gartner®: Magic Quadrant for Software Asset Management
Managed Services. Published 05 September 2023. By: Yoann
Bianic, Stephen White, Jaswant Kalay, and Yolanda Harris2023 results had not yet been announced at the timeof publishing this report.

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OUR APPROACH TO ESG
Crayon’s ESG program is dynamic, demonstrating real
and meaningful progress with the passage of time.

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10ANNEXESOur ESG journey
Environment

We use the term environmental, social,and governance (ESG) as the planningand implementation framework for
all sustainability-related activities
that position Crayon as a socially
responsible company.

transition to an enhanced ESG strategy that will propel
us into the future. Please refer to Implications of CSRD
and ESRS and Annex C. 2023 EU Taxonomy Regulationin this report for more context.

Protecting the planetSocialContributing to society

Governance

17,793 tons of CO2

32% women

2 new initiatives

Total Scope 1, 2,
and 3 emissions(location-based)

Representation of
women in our overall
workforce

Crayon strives to maximize its positive impacts,
and to minimize its negative impacts, on the social,environmental, economic, and governance issues thatare within our purview.
Our wide-ranging ESG initiatives contribute toour business success by helping to strengthen
relationships with existing and potential customers
interested in these topics. Furthermore, these
initiatives are a component of our employer branding
and contribute to employees’ positive experiences
and perceptions of Crayon’s values. Some of our
ESG initiatives have the co-benefit of enabling us toanticipate and comply with regulatory requirements.
Investor and partner expectations shape our ESG
strategy and provide opportunities for collaboration.

Delivering atrusted business

Established to foster
industry-wide collaborations:• Crayon Integrity
Partnership Program• Crayon Security andPrivacy Partnership
Program10 grievances

0 data breaches

Global sustainabledevice management
program

Related to labor andhuman rights reported
against Crayon by third
parties

ISO 14001

US$106,012

ISO 37001

Global certificationfor our environmental
management system

Donated throughCrayon Cares

Global certification for
our anti-bribery andcorruption management
systemWe advanced our ESG agenda in 2023, achieving
successes in all three pillars as summarized in thegraphic and elaborated on throughout this report.
In 2024, we will take stock of our ESG progress with aview toward setting targets and ambitions at both theglobal and local levels. In doing so, we acknowledge
and celebrate the key milestones already reachedlinked to previously communicated targets. Strongly
influenced by the changing regulatory circumstances,the coming months are therefore an opportune time to

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Our stakeholder engagement on ESG
Our annual ESG report is publicly
available on our website andis proactively shared with our
employees, customers, and otherstakeholders, demonstrating Crayon’scommitment to transparency andaccountability.
Furthermore, our investors andanalysts can use our quarterly
earnings presentations,
one-on-one meetings, and roadshows
to discuss ESG-related matters.

Crayon has been a signatory to the United Nations
Global Compact (UNGC) since 2020. We embrace its
10 principles which span labor and human rights, theenvironment, and anti-corruption.
We perform well on the Ecovadis scorecard,an independent rating system of participatingorganizations’ ESG performance. Crayon had an
Ecovadis silver medal in 2023, putting us in the top 25%
of all companies evaluated by Ecovadis.
Crayon completes the climate change questionnaireof CDP (formerly known as the Carbon Disclosure
Project) each year, disclosing our greenhouse gas
emissions. CDP is an independent environmental
disclosure system used to drive transparency andaction around how organizations manage theirenvironmental impacts.
The UNGC, Ecovadis and CDP all have platforms
with interactive elements permitting stakeholder
engagement.

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Our governance of ESG
Environmental, social, and governanceissues receive visibility and support
from Crayon’s most senior leaders.

The role of our executive
management teamThe role of our board of directors• Chief Executive Officer• Chief Financial Officer• Chief Human Resources Officer• Chief Operating Officer• Chief Sales Officer• Chief Strategy Officer• Chief Technology Officer

Crayon’s 10-member Board of Directors performs
necessary control functions and partners with
Crayon’s executive management team on strategic
decision-making in all areas, including ESG. This helps
to ensure ESG is embedded into business strategy andvice versa. Within the board, the audit and risk board
committee is responsible for ESG reporting alongsideother non-ESG duties.
This governance structure is the result of changes
made in 2023 to empower the board and audit andrisk board committee to better preside over ESG
matters. In 2023 we merged the previous ESG board
committee with the audit and risk board committee.
We believe the complementary expertise from ESG
and other disciplines on the enlarged audit andrisk board committee advantages our overall ESG
performance.
Crayon’s full Board of Directors reviewed andapproved this ESG report prior to its publication.
Additional information about the Crayon Boardof Directors (including the audit and risk board
committee) is available in our separate 2023 Annual
Report.

Crayon’s seven-member executive management teamcomprises our:

Together, the executive management teammakes all major strategic and operational decisions,extending to those involving ESG. The Crayon
executive management team reviewed andapproved this ESG report prior to its publication.
On a day-to-day basis, the Chief Strategy Officer
has direct responsibility for ESG, overseeing andcollaborating with the Vice President of ESG. The Vice
President of ESG defines and realizes Crayon’s global
ESG priorities, including leading ESG reporting andthe preparation of this report. Critical concerns about
ESG are escalated to Crayon’s executive management
team, and where relevant and appropriate, toCrayon’s Board of Directors.
Additional information about Crayon’s executive
management team is available in our separate 2023
Annual Report.

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ABOUT THIS REPORTThe contents of this report reflect Crayon’scommitment to open communication, paired witha keen awareness of the ESG topics that matter mostto us and our stakeholders.

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Material topics
and its associated European Sustainability ReportingStandards (ESRS). For more information, pleaserefer to the discussion below under the heading
Implications of CSRD and ESRS.

Promoting integrity, legal
compliance, and transparency

D BUSINESS
STE
RU
AT

SO

Maintaining data
privacy and security

DEL
IVE
RI
N

Y
ET
CI

G

Respecting laborand human rights

The materiality of our 10 topics was establishedthrough a combination of the following:

A high-level review and update of the material ESG
topics was carried out in 2023 to ensure continued
salience and facilitate more streamlined reporting.
An in-depth analysis centered on the concept of
double materiality will be carried out in 2024 aspart of Crayon’s preparations to comply with the
Corporate Sustain­ability Reporting Directive (CSRD)

Enhancing employee
well-being
Advocating for diversity,
equity, and inclusion

In keeping with international best practice, we aim toalign our ESG activities with the United Nations (UN)
Sustainable Development Goals (SDGs) progressively
over time.

1. A materiality assessment
Crayon’s most recent formal materiality assessment
was conducted in 2021 with the assistance of KPMG
Norway. The assessment identified potential material
topics through peer benchmarking, document reviews,
internal and external interviews (including withinvestors and other stakeholders), and an analysisof strengths, weaknesses, opportunities, and threats(SWOT). Crayon’s executive management teamselected and ranked the most important issues whichwere then affirmed by a board committee.

Our material topics

2. A review of key standards and guidelines
We considered the 2023 Sustainability AccountingStandards Board (SASB) guidelines on material
sustainability topics for the software and IT services
industry; the Ten Principles of the UNGC (United
Nations Global Compact); and the UN SDGs.

CONTRIBUTINGTO

The 10 material topics in this report
represent Crayon’s most significant
environmental, social, and governanceimpacts. Information about Crayon’s
economic impact and financial
performance is available in our
separate 2023 Annual Report.

Deploying AI
responsibly

Supporting local
communities
PR

OT
EC

TIN G T H E PL A

Greening the
IT landscapeComments and questions on the ESG report
can be sent to: esg@crayon.com

T

Managing greenhousegas emissions

Facilitating acircular economy

Having identified the material topics, wedrew on the Global Reporting Initiative (GRI)
Standards to further inform the structure andcontents of this report.

NE

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Reporting period and geographic scope
Published in March 2024, this report
is Crayon’s third consecutive annual
ESG report. The reporting period is
1 January 2023 to 31 December 2023,
Crayon’s financial year.
We publish a single ESG report that is global inscope and applies to all our subsidiaries and entitiesin 46 countries.
The reporting period, as well as the entities andterritories covered in the ESG report, are alignedwith those delineated in our annual report. Pleaserefer to the separate 2023 Annual Report for
additional information.

Australia
Austria
Bulgaria
CanadaCzech Republic
Denmark
Estonia

FinlandFranceGermany
Hungary
Iceland
India
Indonesia

IrelandJapan
LatviaLithuania
Malaysia
Mauritius
Netherlands

New Zealand
NorwayOman
Philippines
PolandPortugal
Qatar

Republic of North
Macedonia
Romania
Saudi Arabia
SerbiaSingapore
Slovakia

Slovenia
South Africa
South Korea
Spain
Sri Lanka
SwedenSwitzerland

ThailandUkraineUnited Arab Emirates
United Kingdom
United States

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Implications of CSRD and ESRSThe European Union’s Corporate
Sustainability Reporting Directive(CSRD)1 and its delegated acts, theEuropean Sustainability ReportingStandards (ESRS)2, will compel futurechanges to Crayon’s approach to ESG
reporting.

As a publicly listed company subject to the soonto-be superseded European Union Non-Financial
Reporting Directive, Crayon will have to comply with
the new legislation from 2025, for the reporting period
1 January 2024 to 31 December 2024.
We welcome the increased rigor and prominence
accorded to ESG disclosures under the new regime.
Crayon has a track record of ESG reporting which
we are keen to build on. Reflecting our evolution, in
2025 we will no longer publish separate ESG andannual reports, and will instead produce a single, fully
integrated annual report with comprehensive ESG andfinancial data.
Furthermore, we will carry out a new CSRD-compliant
double materiality assessment in 2024 to underpin
both our revamped ESG strategy and our 2025 ESG
disclosures. Another improvement is that all ourreported material ESG data will undergo limited
assurance.
We are confident that these and other changes will not
only enable us to comply with the CSRD and ESRS, butalso augment the overall robustness and effectivenessof our ESG program.

1

2

2022/2464 Directive (EU) of the European Parliament and of
the Council of 14 December 2022 amending Regulation (EU)No 537/2014, Directive 2004/109/EC, Directive 2006/43/EC
and Directive 2013/34/EU as regards corporate sustainability
reporting.
2023/2772 Commission Delegated Regulation (EU) of 31 July 2023
supplementing Directive 2013/34 EU of the European Parliamentand of the Council as regards sustainability reporting standards.

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DELIVERING A TRUSTED BUSINESS
Crayon is well-positioned to comply with regulations,manage risk, and create safe business conditions
that our stakeholders can trust.

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Introduction
Crayon is committed to adhering to
all applicable laws and regulations
affecting our operations.

We take the appropriate measures to ensure our
employees understand the importance of honest andethical conduct, and consistently reflect this in internaland external interactions.
Our Legal Department and Trust Unit play vital roles indefining and driving aspects of Crayon’s governancearchitecture and culture.

MANDATEOVERVIEWMANAGEMENT|KEY POLICIESCONTENTS

Legal Department

Trust Unit

The mandate of the Legal Department is to
mitigate legal risks, ensure compliance with
relevant laws and regulations, and provide
comprehensive legal support to the organization.

The Crayon Trust Unit’s mandate is to safeguard
Crayon’s business operations and dataprocessing activities around the world. The unit’s
global control function encompasses commercial
compliance, (e.g. anti-bribery, internationalsanctions), integrity, safety, security, and privacy.

The Crayon Legal Department is led by the Chief
Legal Officer, who in turn reports to the Chief
Strategy Officer.

The Crayon Trust Unit is led by the Chief Security
Officer, who in turn reports to the Chief Executive
Officer.

Crayon’s delegation of authority (DoA) matrix
provides a clear framework for assigningauthority to approve actions and undertake
specific tasks. The DoA promotes employee
autonomy and accountability, thereby supporting
regulatory compliance and risk management.

Crayon’s Secured Productivity Policy provides
instructions to enable our employees toimplement the right business practices in theareas within the Trust Unit’s remit. All employees
are trained on the policy annually, and relevantbusiness functions receive additional role-based
directions.

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Promoting integrity, legal compliance, and transparency
Integrity is one of Crayon’s core values
and is central to our business strategy.
We have comprehensive systems inplace to ensure strong corporate
governance and risk management at
all levels of our business.
Our anti-bribery management system was certified
to the ISO 37001 standard following independent
external audits in 2023. These external audits aresupplemented with ongoing internal anti-bribery
audits. Our employees and other stakeholders cantherefore rest assured that we have a robust andworld-class system in place to identify, mitigate, andremediate bribery-related risks and incidents.
The Trust Unit’s third-party assessments incorporate
technology-enabled automation and risk-based
triggers to assess business relationships. Our business
partners and suppliers are assessed based on theircompliance with international sanctions, as well as
their consideration of ethics, security, privacy, andother obligations.
To provide our stakeholders with greater insights
into our governance controls, in 2023 we launched a
new Crayon Trust Center on our website. This online
portal provides tailored information on how Crayon
champions safety, integrity, compliance, security, andprivacy around the world.
In 2023, the Trust Unit partnered with Crayon’s humanresources team to implement a comprehensive setof measures and guidelines for the reporting andpost-investigation resolution of integrity concerns.

We received 10 concerns related to potential integrityrelated matters in 2023, all of which were successfully
closed (2022: 26).
To improve Crayon’s corporate compliance function, in
2023 the Legal Department revised our Delegation of
Authority (DoA) matrix.
We promote a ‘speak-up’ culture for employees tofeel comfortable raising concerns about any potential
integrity-related matters. We offer a variety ofconfidential ways to report concerns, including:• A trust desk where employees can directly reach out
to our dedicated specialists.
• A whistleblower channel where employees andexternal parties can submit an anonymous reportthrough a link on our website at Crayon.com/Trust.
It is important to us that employees feel confident inusing these channels. This is why we have a strict nonretaliation policy in place and diligently investigate
any concerns in the interests of the impacted parties,
in accordance with the EU Whistleblowing Directive.
Our dedicated investigation team for integrity-related
matters operates under the oversight of Crayon’s
Chairman of the Board to ensure its independence.
Please refer to our 2023 Annual Report for additional
information on corporate governance and risk
management.

We believe that integrity andbusiness go hand in hand and
we are committed to protecting
our unique company culturethat values integrity as we
continue our growth journey.
– Melissa Mulholland, Chief Executive Officer

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Maintaining data privacy and security
Crayon’s business operations andservices entail extensive dataprocessing. Our managed IT and
AI services, in particular, require us
to store and further process bothbusiness and personal data forcustomers around the world.

customer-facing security engineering teams —this assists in testing and leveraging new solutions
developed by the cyber security services team.

As information security and data protection areparamount to our operations, we have baked ‘privacy
by design’ and ‘security by default’ into how wedevelop and run our internal and customer-facing
services.

A prime example of our preventative approach todata protection risks in service delivery is our data
minimization review. This review is performed by
Crayon and our customers at the beginning of each
Data and AI project. Wherever possible, we use
the results of these reviews and methods such as
pseudonymization to process large amounts of data
while avoiding or limiting personal data. We performongoing reviews and audits to continuously improve
our security and privacy controls.

Because of our strong security and privacy culture,
Crayon’s Trust Unit receives proactive reports related
to security and privacy events from our employees
worldwide. This combination of timely reportingand ongoing security monitoring, followed by rapidand diligent event management prevented Crayon
from experiencing a data breach in 2023 (2022: 0).
Accordingly, we did not experience any substantiatedbreaches of customer privacy and losses of customer
data in 2023 (2022: 0).
We established two new initiatives in 2023 thatemphasize collaborations with our customers,
partners, and suppliers to foster integrity, security, andprivacy within our industry.
• Crayon Integrity Partnership Program.
• Crayon Security and Privacy Partnership Program.
One of Crayon’s existing strengths is the ongoingknowledge sharing between our internal andPrivacy by design
Crayon safeguards the privacy of those individuals
whose personal data we process. We invest in stateof-the-art technology and maintain resilient technicaland organizational measures to protect the data weprocess for our digital transformation services andsupport functions.

We launched a Crayon-built service and productdevelopment tool in 2023 to streamline reviews of
new digital transformation services and support
functions to ensure they are grounded in privacy
by design throughout the entire lifecycle. The tool
provides an enhanced method of capturing Crayon’s
Records of Processing and issuing role-based Secured
Productivity Instructions to employees around theworld.

Security by default
In 2023, Crayon’s information security team faced
a total of 9,890 security alerts and increasingly
leveraged the power of automation to successfully
close over 53% of all alerts by the end of the fourth

quarter. The remainder were closed through manual
review and intervention by the information security
team. This automation proved useful as both thevolume and sophistication of failed attacks grewthroughout the year.
Our information security team successfully completed
their annual penetration tests of multiple internal
applications and customer platforms in 2023. The
security team also converted the entire Microsoft

Sentinel security monitoring setup to Infrastructure
as Code to enable the rapid onboarding of any newservice and acquisition IT infrastructures.
One of Crayon’s existing strengths is the ongoingknowledge sharing between our internal andcustomer-facing security engineering teams —this assists in testing and leveraging new solutions
developed by the cybersecurity services team.

Your data is safe with Crayon
ISO 27001

ISO 27701

What does it mean?
Certification for information security
management system

What does it mean?
Certification for privacy information
management system

Crayon entity: All Crayon globally

Crayon entity: All Crayon globally

Trusted Information Security
Assessment Exchange (TISAX)

Cyber Essentials Plus

What does it mean?
Assessment required for processing confidential
business and personal data in the automotive
industry.

What does it mean?
Government-backed, industry-supported
certification scheme for organizations todemonstrate operational security against
common cyber-attacks

Crayon entity: Germany

Crayon entity: United Kingdom

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Deploying AI responsibly
Crayon’s Data & AI Center of
Excellence has been delivering
cutting-edge projects for customers
since March 2019 while simultaneously
ensuring we use AI responsibly.
Over time, the center has hardwired
responsible AI assessments into theentire life cycle of every customer
engagement, from the initial projectreview and decision-making phase all
the way through to project conclusion.

These assessments are based on the Crayon
Responsible AI Guidelines (CRAIG). The assessments
are performed together with our customers to ensure
there is a common understanding of potential risks
inherent to the development and deployment of AIpowered solutions. The assessments are also designed
to assist our customers comply with relevant industry
standards and the evolving legislative landscape, forinstance, the proposed EU Artificial Intelligence Act.
The Crayon Trust Unit leverages the longstanding
experience of our Data & AI Center of Excellence toimplement a responsible AI assessment framework
for internal AI-based projects, and to generate
instructions and guidelines for Crayon employees who
use AI-powered tools such as Microsoft 365 Copilot intheir daily work.

Our internal framework consists of risk and impact
assessments.
Crayon’s Artificial Intelligence Risk Assessment(AIRA) is a mandatory component within the dataprotection review when onboarding new solutions.
The AIRA estimates the risk of AI driven tools including
generative AI. The AIRA considers a range of factors
such as context, laws and regulations, stakeholders,
human oversight, data and privacy, and humanunderstandable AI. In the event of a predicted highrisk rating, an Artificial Intelligence Impact Assessment(AIIA) must be completed as a secondary level ofreview and decision-making.

safety and reliability, and privacy. The AIIA aims
to ensure that AI technology is used to enhance
productivity, efficiency, and decision-making while
complying with applicable law and respecting privacy,
confidentiality, and data security. Where applicable,both assessments must be completed and reviewed
before an AI tool is formally approved.

The AIIA contains additional considerations related
to ethical purposes, accountability, transparency
and explainability, fairness and non-discrimination,

Crayon’s seven guiding principles for responsible AI

Individual
responsibility

We equip our employees
to know responsibilities
and obligations

AppropriatenessWe strive for progressive
projects that create
value

Fairness and equity

We aim to instill fairness
and avoid discriminationand injusticeTransparency

We are open withstakeholders about theadvantages, limitations,and risks of AI

Inclusiveness andhuman centricity

We commit to beneficial
automation of workers’
roles, and incorporate
diverse voices indevelopment and testing

Technology

We emphasize quality,
safety, reliability,
robustness, andscalability

Stakeholderinteraction andcommunication

We engage all
relevant stakeholders,and consciously use
understandable
language

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Crayon’s responsible AI guidelines
in action: Our internal rollout of
Microsoft 365 Copilot
Microsoft 365 Copilot is generative AI software thatcan be used to automate and streamline tasks andactivities, thereby increasing employee efficiency andproductivity. Copilot represents a transformative leapin accessible and relatively affordable generative
AI tools suitable for mass adoption in variousorganizational settings.
When Copilot was launched in 2023, Crayon
immediately grasped the potential benefits of making
it available to our employees. Copilot’s capabilities
save time and improve the quality of outputs. We
therefore view Copilot as complementing the skills,
talent, and creativity of our workforce.
Crayon approached the deployment of Copilot within
our organization with the same rigor we apply to
all AI technologies — our steadfast commitment to
responsible AI did not waver. We had a two-pronged
deployment strategy:|

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a. Infrastructure readiness
Beyond ensuring the availability of requisite
licenses, infrastructure readiness for Copilot
extended to the scrutiny of information accesspolicies. While Copilot itself does not modify accessprivileges, it amplifies any imperfections in existing
permissions. It leverages the entirety of information
accessible to a user to generate responses, thereby
spotlighting any shortcomings in our information
governance. We carried out a comprehensive
internal audit using AvePoint Insights and identified
and rectified deficiencies in our data sharing oraccess rights. Utilizing Azure Purview, we instituted
robust access control frameworks.
b. People readiness
Integrating generative AI into our daily routinescomes with a responsibility to examine the output it
produces. In introducing Copilot we have mandated
adherence to a set of terms and conditions bespoke
to Microsoft Copilot. These guidelines underscorethe user’s obligation to verify the accuracy of
Copilot’s output and report any instances of data
oversharing. In essence, users are enjoined from
employing Copilot for queries that could yieldsensitive or confidential material.
Reflecting on our journey, the protocols we executedhave been pivotal in assimilating Copilot into our
workflows securely and ethically.

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CONTRIBUTING TO SOCIETY
Crayon is a reliable employer and an active andgenerous participant in the local communities where
we operate.

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Introduction
Crayon is a people-centricorganization. We consciously inject
an inclusive, partnership-oriented
philosophy in our relationships with
our employees and the communities inwhich we are embedded.
We give back and add value to society by:
Creating and supporting jobs directly and indirectly
We had a workforce of 4,021 employees in 2023,
representing an increase of 16.65% compared to 2022.
Our employees in turn contributed to their local andnational economies through their personal spend andtaxes.
Our global network of business partners provided a
range of services.
Assisting our employees to optimize their well-being
and productivity
We offered health and safety training, employee
assistance programs, and internal and external
professional development opportunities in 2023.
Our annual Crayon Value Awards honored our
employees’ contributions across all parts of ourorganization.
Encouraging diversity, equity, and inclusion in our
workforce
We take a holistic view of DEI and integrate DEI
principles into our recruitment and employment
practices.

We celebrated International Women’s Day and Pride
Month in 2023 and offered diversity and inclusion
training.
Addressing labor and human rights in our own
operations and in our supply chain
We carried out human rights due diligence activities
in our own operations and in our supply chain in 2023,
and published our 2023 Human Rights Transparency
Statement.
Donating and volunteering
Crayon Cares is our global charitable giving initiative.
In 2023, we made financial and in-kind donations andvolunteered in-person.
Being open to feedback and engagement
We offer various channels for our employees,
customers, business partners, and other stakeholders
to communicate with us.
Our executive management team can be contacted
directly; and our helpline consists of an email address,a phone number and an online portal.

I am impressed by the depth oftalent, dedication and thought­ful­ness exhibited by our employees
in their functional roles and in theircommunity outreach.
– Bente Liberg, Chief Human Resources Officer

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ANNEXES

Enhancing employee well-being
Crayon values its employees andstrives to create a safe and rewarding
work environment for them.
In an IT industry characterized by fierce competition
to attract and retain skilled employees who candeliver Crayon’s innovative services, we are proudof our high-caliber talent pool and collaborative
organizational culture.
Our network of local human resources (HR)representatives, led by the Chief Human Resources
Officer, develops and implements policies andstrategies to recruit, select, and engage employees.

Our group-wide people and culture strategy is
updated annually and has clear objectives andmetrics to position the HR function to support
employees and the organization in critical areas
such as employee well-being, diversity, equity andinclusion (DEI), and learning and development.

Our people and culture strategy
Talent attraction
and onboarding

Employee advocacy,
well-being and growth

Skills development
and training

Objective:
Attract, hire, andintegrate the best talent
to drive our company’s
growth.

Objective:
Empower our employees
to thrive, achieve their fullpotential, and advocate forour company.

Objective:
Foster an internal
culture of continuous
learning and growth,building critical skills
and competencies.

DEI
Objective:
Promote diversity,
equity, andinclusion within ourorganization.

Internal HR operations
Objective:
Create and optimize all our human resources processes and frameworks for
efficency, support, compliance, and employee satisfaction.

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Crayon 2023 workforce profile

Age ofemployees

In 2023, we had 4,021 full-time equivalent employees (2022: 3,447), indicating
a 16.65% increase in our workforce (in full-time equivalent numbers) compared
to 2022. The Nordics (primarily our headquarters in Norway) and Asia Pacific(primarily our offices in Australia and New Zealand) hosted most of ouremployees, together accounting for 48.52% (2022: 53%).

Longevity of
employment at Crayon

Employees by
category

The distribution of our employees around the world is as follows:
n
n
n
n
n
n
n

Asia Pacific (18.49%)
Western Europe (10.62%)
Southern Europe (3.61%)
Eastern Europe (5.61%)
Headquarters (8.41%)
India (12.09%)
Middle East and Africa (2.95%)
Nordics (Norway, Finland, Denmark,Sweden, Iceland) (30.03%)
n United States of America (8.2%)
n
n
n
n
n
n
n
n

< 20 years (0.37%)
21-30 years (23.90%)
31-40 years (37.01%)
41-50 years (25.16%)
51-60 years (11.55%)
61-70 years (1.98%)> 70 years (0.02%)

n
n
n
n

3 years and less (79.76%)
4 to 8 years (15.14%)
9 to 15 years (3.99%)
16 to 25 (1.1%)

n Technical (46.03%)
n Management (17.92%)
n All other employees (36.05%)

Average tenure: 2.9 years

1,239

78.7%

12.84%New hires

Global employee
retention rate

Employees covered bycollective bargaining
agreement

2022: 73% (restated)
We instituted a revised calculation
methodology in 2023 to improvedata accuracy. Accordingly, we
have restated the 2022 figure using
the new methodology to enable
comparability.

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PROTECTING THE PLANETEngaging our employees
Employee engagement reflects how connected wefeel with our work environment, colleagues, andleaders. It is important because it affects, and is in turnaffected by, employee morale and productivity.
Our annual internal employee awards to recognize
and celebrate our employees are a popular way
to engage our employees. In 2023, about 120 local
awards and six global awards were given to selected
employees. The two-day Value Award event took
place in Oslo, Norway in May 2023 at which the global
awards were center stage. The on-site activity wasattended by 18 finalists from all over the globe andwas capped by a festive ceremony – attended by theentire executive management team – where the final
global winners were announced.
To measure the success of our engagement efforts,
we conduct a global annual employee feedback
survey with the support of an independent third party.
Employees participate anonymously, giving Crayon ascore out of five across seven different categories.
The survey was conducted in October 2023. The survey
participation rate was at an all-time high of 69%(2022: 55%), and the overall survey score was 4.2 outof 5.0 (2022: 4.2 out of 5.0).
According to the survey, team spirit and manager
capabilities are Crayon’s greatest strengths. We havecreated action plans and regularly follow up on them.
In addition to the employee feedback survey, we
actively solicit and embrace feedback received
through other channels such as: monthly internal
townhall meetings; the company Intranet; internal
newsletters; one-on-one communication with directsupervisors and Crayon’s executive management
team; and individual performance and development
reviews.

2023 Crayon employee
feedback survey

88.1%
According to our employee net promoter
results, most of our employees would
recommend Crayon as a place to work

69%
Survey participation rate

4.2
Overall score out of
5.0 across all categories|

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ANNEXESCreating learning and development
opportunities
We support our employees’ personal careerdevelopment and promote them within our company
whenever possible. We invest heavily in training for ourteams, guided by the belief that this not only improves
the quality and efficiency of our organization, but also
contributes to employee satisfaction and longevity oftenure at Crayon.

130
Total number of training
sessions hosted or paid for by
Crayon (internal and external)

136,667
Total duration of training
sessions held during the year
(in hours)

57.82%
Total percentage of emplyees
who participated in a training
sessionIn 2023, the content and target audiences of the
training sessions varied and included:• Training for all sales staff in the form of an internalsales development program focused on our own
sales methodology.
• Internal masterclasses on software asset
management for all services staff.
• Vendor/ software publisher training, with 3,096
new vendor certifications obtained in 2023.
• Seventy-eight other new internally developed
training programs were launched in 2023.
With workforce and succession planning in mind, we
identified critical people and positions and improved
our leadership and talent development programs
targeting these niches in 2023.

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Monitoring employee health andsafetyResponsibility for employee health and safety at
Crayon is shared between the Human Resources andTrust Unit teams. Sound safety and health practices
are integral to our operations, and we comply with all
local workplace safety regulations.
Crayon’s global business continuity and disasterrecovery planning ensures our sites are preparedin the event of a local emergency. When facedwith safety risks such as natural disasters or armed
conflicts, our Trust Unit and Human Resources teamcollaborate to provide tailored assistance, ranging
from remote guidance to on-site disaster recovery
management (e.g. evacuations).
Some of our sites provide health and safety training.
For example, in 2023 all our employees in Germany
completed an internally and locally developed training
course which covered topics such as how to respond in
the event of fire and other emergencies, and self-carefor better health.
Many of our sites worldwide offer an employee
assistance program to help employees navigate
difficult life situations, thus improving their healthand well-being. The assistance provided by Crayon is
confidential, giving employees peace of mind.

0
Number of workrelated fatalities(2022: 0)0
Number of workrelated injuries(2022: 0)

1.2%
Rate of absence fromwork due to sickness(2022: 2.3%)|

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Advocating for diversity, equity, and inclusion
From Crayon’s perspective, diversity,
equity and inclusion (DEI) broadly
covers gender, age, disability,
nationality, ethnicity, experience,education and other attributes.
Crayon values and encourages DEI in its workforce,
understanding that it adds business value by helping
to attract some of the best available talent on the
global marketplace. Applying DEI principles andpractices also enables Crayon to leverage our
employees’ skills and knowledge to anticipate andcater to our customers’ diverse and evolving needs.
The Crayon Integrity Handbook outlines behaviors
expected of our employees which include treatingothers with respect, being inclusive, and examining
unconscious biases. Crayon does not tolerate any
forms of harassment or discrimination. Reported
incidents of harassment and discrimination arereferred to our Trust Unit for investigation andresolution.
In 2023, one employee raised concerns regarding
alleged discrimination. Following thorough internal
reviews, it was determined that the allegations were
not made in good faith. Subsequently, appropriate
measures were taken after consulting with external
legal advisors. As part of our remedial efforts,
mandatory training sessions on workplace safety
and our code of conduct were conducted within theaffected region.

Our DEI performance in 2023
Heading into 2023 our ambition was to launch
employee resource groups (ERG) in furtherance of
our DEI objectives. Ultimately, we pivoted and instead
expanded our global DEI volunteer team. In 2023,
15 employees worldwide volunteered to help drive
the DEI agenda across the group by leveraging theirlocal initiatives and resources. Activities ranged fromanalyzing the metrics associated with our DEI training
series to hosting a workshop on the role and purposeof employee resource groups.
As part of our DEI information and awarenesscampaigns in 2023 we celebrated International
Women’s Day in March and Pride Month in June.
During our annual global inclusion week in October,
we used social media to showcase employee voices
on what inclusion means to them and posted otherrelevant content.
Legal restrictions and cultural sensitivities andcomplexities in Crayon’s different countries ofoperation constrained our ability to report on a wider
range of diversity metrics in 2023.

Some indicators of our performanceon DEI in 2023 were:

5,831

17-72

Number of training sessions delivered
as part of Crayon’s diversity andinclusion training series

Range in age from youngest
to oldest employee
2022: 17-71 years

2022: Not applicable as we first launched the diversity
and inclusion training series in 2023.

25%

65

Of employees promoted at
Crayon were women

Different nationalities in
Crayon’s workforce

2022: 25%

2022: 40+

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DELIVERING A TRUSTED BUSINESSGender and pay equity
Focusing on gender-based diversity and equity, in
2023 women made up 32% of our entire workforce andmen 68%. This pattern has held steady over the past
three years, with the proportion of women showing amodest increase of 1% between 2021 and 2023.
Breakdowns of the different ways in which womenparticipate in Crayon’s workforce are provided below.
In the past three years, the highest representationof women (50%) in our organization has been at thelevel of the Board of Directors. We have experienced
challenges at the executive management level withthe proportion of women declining from by 14% in
the same time frame. The proportion of women intechnical roles increased by 3% between 2021 and2023.
In 2023 Crayon implemented various measures toimprove gender equity and reduce the risk of genderbased discrimination in our organization:|

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1. Promotions were awarded with the mindset ofachieving intersectionality between merit and DEI.
The result was that 25% of all employees promoted
were women in 2023 (2022: 25%).
2. The third cohort of our internal Female Leadership
Program had 16 participants in the 2023–2024
cycle (2022-2023 cycle: 15 participants). The
program offers coaching and mentoring to female
employees who are identified as high potential
candidates. Since 2019, more than 50% of thewomen participating in the program have beenpromoted into leadership positions.
3. In recruiting to fill all open positions, we madeefforts to consider candidates from diverse
backgrounds.
4. To address pay equity concerns, in 2023 Crayon
initiated a multi-year project to evaluate andstandardize remuneration for similar roles, and in
the process, identify and eliminate discrimination
and bias. Gender, age, nationality, and otherattributes will be taken into account to ensure
fairness and equity. The global salarybenchmarking project will be rolled out toCrayon’s subsidiaries in early 2024.
Nevertheless, we continued to face challenges
and risks with respect to gender equity in
2023. In our experience, what appears to be theperennial shortage of women who enter careers
in technology continued to be a challenge in 2023.

Representation of women by seniority
Women in Crayon’s overall workforce (%)

2023

2022

2021

Representation of women by type of role

32%

32%

31%

Technical (%)

2023

2022

2021

24%

23%

21%

Women in Crayon’s executive management team (%)

29%

33%

43%

Management (%)

29%

29%

27%

Women on Crayon Board of Directors (%)

50%

50%

50%

All other employees (%)

43%

41%

40%

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Respecting labor and human rights
Crayon believes in the treatment of
employees with respect and dignity in
our own operations and in our supply
chain.

Crayon’s human rights
disclosures
Supplementary information
about Crayon’s humanrights due diligence activities
and progress is available
in our 2023 Human Rights
Transparency Statement.
The statement, which is
updated annually, is available
on Crayon’s global and United
Kingdom websites.
Crayon’s Human Rights
Transparency Statement
is prepared in compliancewith both the Norway
Transparency Act of 2022 andthe United Kingdom Modern
Slavery Act of 2015.

Forced labor, slavery, excessive working hours,
underpayment of wages and benefits, and inhumane
working conditions are some of the pernicious social
justice issues Crayon must vigilantly safeguard
against.
The steady growth of Crayon’s business year-on-year
places more onus on us to manage the potential riskof labor and human rights violations as we grow inscale and complexity.

We choose to prioritize labor and human rights because of:1.

Our signatory status in relation to theUnited Nations Global Compact (UNGC).

4.

The UNGC is underpinned by 10 Principles,six of which fall under the ‘human rights’and ‘labor’ pillars.

2.
3.

For example, the Norway Transparency Act
of 2022; the European Union’s proposed
Corporate Sustainability Due Diligence
Directive; and the United Kingdom Modern
Slavery Act of 2015.

Our alignment with the United Nations
Sustainable Development Goals.
Goal 8 (decent work and economic growth)and Goal 10 (reduced inequality).
Our support for the United Nations Guiding
Principles on Business and Human Rights(UNGPs).
We incorporate the UNGPs into the Crayon
Integrity Handbook and the Crayon Partner
Integrity Policy.

Planned and existing regulatory
instruments in Europe and other partsof the world that are or may become
applicable to Crayon.

5.

Increasing customer awareness and calls
for action.
Customer concerns and demands are
expressed as sustainability criteria inprocurement processes and contracts,
and in requests for information.

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Addressing labor and human rights
risks in our own operations
Crayon strictly abides by the applicable local laborlaws and our own internal policies (e.g. the Crayon
Integrity Handbook) throughout our operations.
Enforced by our global network of HR representatives,
our recruitment and employment systems and controls
aim to avoid child labor, human trafficking, unsafe
working conditions and other forms of exploitation in
our workforce.
The Crayon Integrity Handbook prohibits inappropriate
language, abuse of authority, disruptive behavior andoutlines other expected employee conduct. Crayon’s
operations must comply with all applicable environ­mental laws and follow health and safety requirements.
Appropriate measures are taken to censure
employees who act in breach of the law or ourpolicies, to remediate employees who are unjustly andnegatively impacted, and to improve the robustness of
Crayon’s policies and procedures.
We protect our employees’ right to collective
bargaining and freedom of association. In 2023 six
countries in the Nordics and the rest of Europe hadcollective bargaining agreements (CBAs) - CBAs
covered 12.84% of our employees. The CBAs give
Crayon staff a voice in strategic and operational
decisions, as well as issues such as remuneration,
health and safety, and working hours.
All Crayon employees can express their concerns
about working conditions and other matters to theirsupervisors and by directly contacting the executive
management team. We also have confidential
channels for reporting concerns, such as a dedicatedemail address (concerns@crayon.com) and atelephone hotline (+47 2396 8400).
In 2024, we will continue to offer a helpline but througha different service provider. Updated contact details
will be communicated to our stakeholders in due course.

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Please refer to our sections Enhancing employee
well-being and Advocating for diversity, equity andinclusion for additional information on health andsafety and DEI at Crayon.

33

ANNEXES

Number of Crayon third parties
with labor and human rights
risk assessments initiated in 2023

Addressing labor and human rights
risks in our supply chain

Geographic breakdown of
all initiated human rights
risk assessments in 2023

117

Crayon’s Partner Integrity Policy describes the
behavior and practices we expect the partners in our
supply chain to exhibit, including upholding labor andhuman rights and protecting the environment.
We encourage external stakeholders such as ourcustomers, partners, and suppliers to reach out
to our Integrity team for support at concerns@
crayon.com or +47 2396 8400 or anonymously at
our online whistleblowing channel. In 2024, we willcontinue to offer a helpline but through a different
service provider. Updated contact details will be
communicated to our stakeholders in due course.

n Completed by
31 December 2023 (34%)
n Pending follow-up actions
or ongoing survey (66%)

We assess our business partners throughout the
lifecycle of our relationships with them. From alabor and human rights perspective, Crayon’s due
diligence assessments emphasize crucial aspects
such as human rights, child labor, environmental
governance, decent working conditions and DEI. The
assessments ensure our business partners’ compliancewith international regulations as well as our own
rigorous standards. Where necessary, we use the data
gathered through the assessments to filter out anddisengage from relationships that fail to meet ourstandards.
In 2023, Crayon’s Trust Unit led the continued
expansion and refinement of our supply chain due
diligence process. This was done with guidancefrom external experts, and a comparison of Crayon’s
approach with established best practices. One of theoutcomes was that we formulated policies to govern
our due diligence process in 2023, providing a clearer
framework for conducting thorough due diligenceassessments and evaluations.

|

1)

n
n
n
n
n

Western Europe and Nordics (79%)
India and APAC: (8%)
US (7%)
Central Eastern Europe (3%)
MEA and Africa (4%)

00Number of grievances related tolabor and human rights reported
against Crayon by third parties

Number of grievances related tolabor and human rights reported by
Crayon against third parties

100%

5%

Proportion of Crayon third parties
that have acknowledged andcommitted to complying with
Crayon’s Partner Integrity Policy1)

Proportion of Crayon third parties
rejected during onboarding due
to non-existent business integrity
program (including human rights)1)

Percentage of completed due diligence assessments

We are dedicated to continually enhancing our practices and contributing to the advancement of humanrights and global supply chain risk management. In 2024, third parties in high-risk categories will be
subject to follow-up reviews of their governance maturity and the integrity of their reporting under
Crayon’s due diligence process.

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Supporting local communities
Crayon considers itself part of the fabric of thelocal communities where we operate and conduct
sales. Due to our global scale, we have a strong
vantage point to observe the difficulties faced byunder-resourced and marginalized communities indifferent settings. We, therefore, give back through a
combination of cash donations, sponsorships, in-kind
donations of goods and materials, and our employees’
time and labor (employee volunteerism).

Crayon Cares: Some activities from around the world in 2023

These various activities are collectively branded as
Crayon Cares and are guided by the Crayon Global
Integrity Handbook to avoid conflicts of interest andother potential breaches of ethics and complianceregulations.
In 2023, we donated a total of US$106,012 to various
charities and non-governmental organizations (NGOs)
in 32 countries around the world as part of Crayon
Cares (2021:US$111,116). The funds comprised personal
contributions from our employees matched by funding
from Crayon. In addition, our employees volunteered
their time to initiatives such as tree planting andrunning to raise funds for worthy causes.
2023

2021

Total amount of funds raisedand donated (US$)

106,012111,116

Total number of hours
volunteered by Crayon
employees

16,4001,450

Employees taking part involunteer activities as apercentage of our workforce (%)

48.49%

12.82%

Note: 2022 data is not available

Click on the locations
for more details

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PROTECTING THE PLANET
We take our role as a co-steward of planet Earthseriously. Together, we can all make a difference.

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Introduction
Globally, environmental challenges
are mounting and range from natural
resource depletion to pollution andthreats to biodiversity. At Crayon, we
strive to do our part to monitor andmanage the environmental impacts
associated with our services.
We observe the precautionary principle by taking apragmatic approach that balances business needs
and the imperative to minimize and avoid harmful
impacts where possible.
This is reflected in Crayon’s Environmental Policy
which identifies the reduction of greenhousegas (GHG) emissions, energy consumption, andoperational waste as high impact areas given thenature of Crayon’s business. The policy encourages all
employees to conduct business in an environmentally
responsible manner within their domains (e.g. by
replacing business travel with virtual meetings andimproving recycling rates).
In 2023, Crayon held a group-wide ISO 14001:2015
certification covering 57 Crayon sites around theworld. ISO 14001 certification is an audit-based andsite-specific environmental management system. It
aims to minimize environmental impacts by identifying‘green’ impact areas (e.g. energy and water
consumption, recycling) and tracking performance inthese areas over time.

Crayon at COP28
In December 2023, employees from ouroffice in Dubai attended a segment of
the 28th meeting of the Conference of
the Parties (COP28) to the United Nations
Framework Convention on Climate Change(UNFCCC). During this event, we showcased
the deployment of Crayon’s AI capabilities
to prevent deforestation and increase
agricultural crop yields.

We think and act globally andlocally in our environmental
initiatives. From our role at
COP28 to our sustainable device
management program, we use
the means at our disposal forthe greater good.
– Jon Birger Syvertsen, Chief Strategy Officer

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PROTECTING THE PLANET|ANNEXESGreening the IT landscape
Crayon explores opportunities toincorporate environmental, social, andgovernance considerations into ourcustomer-oriented service offeringsand our in-house operations.
Green services and solutions
One of the ways in which Crayon supports the green
transition is by offering customers solutions to help
them improve their overall ESG performance. We draw
on our wealth of expertise and partner relationships indata analytics, AI, and cloud services to achieve realworld outcomes that positively impact people and theplanet.
Two examples illustrating Crayon’s belief in the powerof technology to drive the greater good are:1. Our collaboration with Felleskjøpet Agri in 2023
2. Our Tech4Good program
How Felleskjøpet Agri partnered with Crayon to
improve animal welfare and reduce feed waste
Felleskjøpet Agri is a Norwegian agricultural
cooperative serving numerous farms in Norway,
which specializes in high-quality animal feeds andfarming supplies. In 2023, Felleskjøpet embarked on
an ambitious pig nutrition project to:• Identify the optimal mix of various feed ingredients
to meet pigs’ nutritional needs and avoid over- andunder-feeding. This would in turn reduce animal
health complications and financial losses.
• Modernize the pig feeding process itself.

Felleskjøpet turned to Inmeta, a Crayon subsidiarycompany, for its expertise in data, AI, and machinelearning. The project challenges included integrating
advanced technology with traditional agricultural
practices, and balancing cost-effectiveness with
Norway’s stringent animal welfare standards.
The project was successfully executed from theanimal welfare, commercial, and technologicalstandpoints. The tool developed by Inmeta is designed
for Felleskjøpet’s feed advisors to recommend feedplans to pig farmers. The tool calculates the ideal
mix of feed ingredients based on various factors
such as pigs’ desired growth rate, pig breed, and thefarm’s specific feeding system. This customization
ensures that each pig’s dietary needs are precisely
met, optimizing animal health and growth, while
simultaneously reducing feed waste. Farmers benefit
from a streamlined feeding process and lower
operational costs.
The solution developed by Inmeta on behalf ofFelleskjøpet marks a significant shift from manual,
Excel-based methodologies to a modern cloud-based
system that is intuitive and easy to use. The underlying
technology is advanced – for example, building onan Azure architecture, Inmeta incorporates tools
such as SciPy Optimize in Python and Pydantic toconduct sophisticated and comprehensive analysesof components such as available feed ingredients,
nutritional content, necessary water input and farmcapacity.
Tech4Good program
Tech4Good is a Crayon program that combines
Crayon’s commercial relationships with non-profit
organizations (NPOs), with socially impactful initiatives
that draw on our technological expertise and areundertaken in partnership with the same NPOs.

Tech4Good’s geographic scope is the Asia Pacificregion.
Crayon provides varying levels of technical support
depending on NPO needs, ranging from licensing tomore extensive and complex technology solutions andservices. For example, Crayon sells software licenses
to NPOs at a discount, in recognition of the resource
constraints many NPOs operate under.
At the same time, Crayon co-designs and coimplements technological solutions that help tackle
societal issues such as forest conservation, climatechange, diversity in workplace recruitment, humantrafficking, and access to financial services for people
without bank accounts.
One of the environmental initiatives we launchedin 2023 is called Futures Offices. The South Pacificregion is severely impacted by climate change and todate, the region’s climate-related research has been
generated in Europe and North America. Tech4Good
aims to change that by building local capacity toresearch climate change mitigation and adaptation in
the different island nations.
Crayon is partnering with US-based Institute for the
Future, one local telecommunications company and
the TMX Group to establish three physical research
centers in Samoa, Tonga and Fiji by the end of
March 2025. The centers will research topics suchas rising sea levels and food security in relation toclimate change. Crayon’s role includes running ‘Trainthe Trainer’ programs to equip the participating
government departments.

37

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Crayon currently owns one data center in Iceland,
and leases capacity in two other data centers – one in
Norway, and another in Iceland. All three data centers
run entirely on electricity from renewable energy
sources. All three centers do not utilize any water forcooling, but instead utilize closed cooling systems andair ventilation (Iceland).
In our outsourced cloud hosting, we rely on ourcontracted service providers to proactively factor inenvironmental considerations.

38

ANNEXES

Our data centers

Green data hostingOver the years, Crayon has transitioned from having
its own physical data centers to utilizing third party
cloud hosting solutions. The benefits for us include
cost containment, and the ability to deploy large-scale
software updates and solutions quickly and efficiently.

|

Verne Data Center (Iceland)Síðumúli Data Center (Iceland)

Oslo Data Center (Norway)• Processing Sensa-managed service
infrastructure in Iceland• Leased by Sensa, a Crayon subsidiary• Processing Sensa-managed service
infrastructure in Iceland• Owned by Sensa, a Crayon subsidiary• On premises infrastructure forinternal Crayon solutions• Leased by Crayon (space andutilities); servers and hardware
owned by Crayon

30 m2

162 m2

15 m2

Surface area

Surface area

Surface area

234

334

33

Devices on premises (servers andnetwork equipment)

Devices on premises (servers, networkand surveillance equipment)

Devices on premises(load balancers, servers, switches,firewalls, NAS,
tape robot, console)

442,666 kWh863,633 kWh

66,592 kWh

Electricity consumption(electricity from renewable sources)

Electricity consumption(electricity from renewable sources)

Electricity consumption(electricity from renewable sources)

0 kiloliters

0 kiloliters

0 kiloliters

Water consumption

Water consumption

Water consumption

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Facilitating a circular economy
The circular economy is an alternative
economic and business model thataims to move away from linear value
chains (take-make-dispose) to value
chains that are as waste-free andregenerative as possible:• In the production phase of the lifecycle, circularvalue chains aim to minimize inputs of raw
materials, capital goods, and energy (including apreference for renewable energy).
• In the use phase of the lifecycle, circular value
chains aim to keep materials and products in use
continuously and reduce waste through methods
such as refurbishing, repairing, and maintaining.
• At the end of the lifecycle, circular value chains
aim to reduce waste through reusing, recycling,
biodegrading, and other strategies.
Crayon incorporates and observes circular economy
principles in different ways, most notably through oursustainable device management program and ourapproach to waste and water management at ourdifferent sites.

Our sustainable device management
program
Launched in the first half of 2023, Crayon’s sustainabledevice management program is led by our Global IT
team.

The program aims to standardize the procurementand disposal of internal IT equipment and hardware
according to the following sustainability criteria:
1. At the procurement stage, ensuring all devices
are energy efficient, easily repairable, and containsome recycled and non-toxic materials andcomponents.
2. While the devices are in use, defaulting to repair
and maintenance in order to prolong lifespans,potentially up to 10 years depending on the device.
3. At the end of life, recycling or reselling all usedhardware.
a. This includes reducing packaging waste by, forexample, returning old laptops to the
procurement vendors in the boxes the new
laptops were sent in.
The program currently focuses on hardware usedby our employees. We have compiled a digitalproduct catalog and ordering portal featuring
laptops, monitors, and accessories (e.g. docking
stations, keyboards, headsets) that meet the above
criteria. Enterprise hardware (e.g. videoconferencing
equipment) will be added to the sustainable device
management program in future.
A key feature of this global program is thecentralization of purchasing and disposal activities.
Crayon works with an external procurement partner
named Foxway that specializes in asset life-cycle
management and has a local presence in multiple
countries.
By 31 December 2023, the program was being
implemented at 80% of Crayon entities worldwide. We
intend to implement the program at the remaining
Crayon sites during the first half of 2024.

|

39

ANNEXESOur handling of waste and water

Nordics

At present, data on solid waste and water is only
available for our operations in the Nordics due todata constraints in other parts of the world.

Waste (kg)In the Nordics, including our headquarters in
Norway, we track solid waste disposal with thegoal of increasing recycled or biodegradable/
composting waste (thereby contributing to a circular
economy). Conversely, we strive to minimize solid
waste that is either incinerated or goes to landfills as
this does not contribute to a circular economy.
We made some progress in 2023 – we experienced
an 18.62% decrease in the total waste generated
across all categories.
Of the total waste generated, 95% was either
recycled or composted (2022: 88%), and 5% wasdisposed of via landfill or incineration (2022: 12%).
We moved to new facilities in Iceland and Norway in2023, and in both cases, this resulted in better waste
management practices in terms of data monitoringand environmentally friendly waste disposal
methods.

2023

2022

Mixed waste, recycled

2,381

10,897

Paper waste, recycled

4,501

1,952

Residual waste, landfill

42

2,464

Residual waste, incinerated

2,229

2,713

Glass waste, recycled

13,242

1,941

Hazardous waste, landfill

2

Hazardous waste, recycled

1334

Organic waste, composting

24,353

9,801

Organic waste, treated

129

Organic waste, incinerated

81

Plastic waste, recycled

501

Plastic packaging waste,
recycled

135

Plastic waste, landfill

7

Plastic waste, incinerated

10

Metal waste, recycled

55

Municipal solid waste, landfill
EE waste, recycled
Cardboard waste, recycled

14
1,739.90

1,037

22,255149

3,689.6

Industrial waste, recycled

2,144

Wood waste, recycled
Total waste generated (kg)52

51
48,732

59,883

Our water consumption in the Nordics increased
from 3.32m3 per FTE in 2022 to 3.93m3 per FTE
in 2023, an 18% increase. This increase can be
attributed to more employees working at Crayonsites than from home and a larger kitchen at ourheadquarters in Norway.

Nordics

2023

2022

15,784

11,468Water (m3)
Water consumption

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PROTECTING THE PLANETManaging greenhouse gas emissions
Crayon supports international
scientific consensus which attributes
climate change to a recent andsignificant increase in anthropogenic(human-induced) greenhouse gas(GHG) emissions.
We perform an annual GHG inventory that measures
our Scope 1, 2, and 3 emissions. Our GHG inventory
covers our operations worldwide and is reported
to the CDP1. Crayon’s emissions are calculated inline with the applicable international GHG Protocol
standards.

In 2024, Crayon will prepare a decarboni­
zation plan with science-based emission
reduction targets. The plan will be submitted
to the Science Based Targets Initiative (SBTi)
for validation.

The greenhouse gas inventory was compiled inaccordance with: the WRI/WBCSD Greenhouse
Gas (GHG) Protocol – A Corporate Accounting andReporting Standard (1) (the Corporate Standard)(Revised Edition 2013) including the amendment to thisprotocol; the GHG Protocol Scope 2 Guidance (2015);
the GHG Protocol Corporate Value Chain (Scope 3
Standard and Scope 3 Calculation Guidance (2013);
and the Global Reporting Initiative Standards (GRI
305: Emissions, 2016).

Formerly known as the Carbon Disclosure Project, CDP is aninternational organization that aims to improve organizations’disclosure of their environmental performance by producing
annual questionnaires on climate change, supply chain, water,
and forests.

40

ANNEXES

Crayon’s total (location-based) emissions by scope

Our methodology to calculate
GHG emissions

Scope 1

2%

Direct emissions created by acompany’s activities

Scope 1 emissions were calculated using 2023
emissions factors from the UK Department ofEnvironment, Food, and Rural Affairs (DEFRA).
Scope 2 location-based emissions were calculatedusing 2023 emissions factors from DEFRA and theInternational Energy Agency (IEA). Scope 2 marketbased emissions were calculated using emission
factors from IEA and the Association of Issuing Bodies’
2023 publication on the Residual Mixes and European
Attribute Mix. For locations where a residual mix factor
was not available, the location-based emission factor
was used. Guarantees of origin for renewable energy
we consumed were taken into account.
Scope 3 emissions were calculated using 2023
emissions factors from DEFRA, Ecoinvent 3.9 and 3.10,
2020 emissions from the United States Environmental
Protection Agency, the World Input-Output Database
and the Open Input Output Database.

1|

Within Scope 3, emissions from purchased goods
and services were calculated based on the spendbased method. Emissions from business travel were
calculated based on a combination of either spend
or distance/fuel and mode of transport, depending

Scope 2

6%

Indirect emissions from acompany’s activities

Scope 3
Indirect emissions from all otheractivities up and down the value chain

92%

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DELIVERING A TRUSTED BUSINESS

on data availability. Waste-related emissions were
calculated based on actual waste disposed using
different disposal methods. Due to data constraints,
only three of the 15 Scope 3 sub-categories are
currently included in our GHG inventory.

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Total Scope 1, 2 and 3 locationbased emissions by region (2023)

Our absolute location-based emissions increased by
20.71% compared to 2022. Our total Scope 1, 2 and 3
location-based emissions were 17,793 tons of CO2 in
2023 (2022: 14,740).
The rise in absolute emissions was due to morecomprehensive and accurate data availability(Scope 1), more employees working from Crayon sites
instead of at home (Scope 2), and increased spend
on goods and services as our operations expanded(Scope 3).

GHG emissions

Unit

2023

2022

2021

Tons

332

266

167

Tons

995

885

774

Category 1: Purchased goods and services

Tons

12,224

10,235

5,341

Category 5: Waste generated in operations

Tons

8

19

Not available

Category 6: Business travel

Tons

4,234

3,335

548

Sub-total Scope 3

Tons

1

16,466

13,5895,889

Total location-based emissions (Scope 1 + 2 + 3)

Tons

17,793

4

14,7406,8302(metric tons of CO2 equivalent)

Scope 2 location-based
Scope 3

1n Nordics (including HQ) (41%)
n Europe (15%)
n Asia Pacific & Middle East
Africa (32%)
n United States (12%)

Emissions intensity/employee

Ton/FTE

4.43

4.28

2.36

Emissions intensity/revenue

Ton/million (NOK)

2.78

2.83

1.87

Scope 1

Tons

332

266

167

Scope 2 market-based

Tons

1,569

1,256

2,193

Category 1: Purchased goods and services

Tons

12,224

10,235

5,341

Category 5: Waste generated in operations

Tons

8

19

Not available

Category 6: Business travel

Tons

4,234

3,335

548

Sub-total Scope 3

1

1

Scope 3

Total Scope 1, 2 and 3 locationbased emissions by region (2022)

Scope 3 emissions accounted for the vast majorityof our emissions at 92% in 2023, followed by Scope 2
emissions at 6% and Scope 1 emissions at 2%. The same
pattern was exhibited in 2022. Due to data constraints,
only three of the 15 Scope 3 sub-categories are
currently included in our GHG inventory.
In terms of geographic spread, the Nordics (including
our headquarters in Oslo) accounted for the highest
proportion of our emissions, and the United States
had the lowest emissions. This pattern is somewhat
consistent with Crayon’s global operational footprint,
as the Nordics including our headquarters are where
we have the most employees, and the United States
the fewest. Please refer to our chapter Enhancing
employee well-being for more detailed information on
the geographic distribution of our employees.

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ANNEXES

Scope 1

Our emissions in 2023
In 2023 we experienced year-on-year revenue
growth of 23%, accompanied by a 1.88% decrease in
our carbon intensity. Carbon or emissions intensity inthis instance refers to tons of CO2 (location-based)
per million Norwegian Kroner (NOK) of revenue. Ouremissions intensity decreased from 2.83 tons of CO2
per million NOK in 2022 to 2.78 tons of CO2 per million
NOK in 2023.

|

Tons

16,466

13,5895,889

Total market-based emissions (Scope 1 + 2 + 3)3

Tons

18,367

15,11148,2492Emissions intensity/employee

Ton/FTE

4.57

4.38

2.84

Emissions intensity/revenue

Ton/million (NOK)

2.87

2.91

2.25

1

Due to data constraints, only three of the 15 Scope 3 sub-categories are currently included in our GHG inventory.
In 2021, we did not include one of our subsidiaries, rhipe; and only two of the 15 Scope 3 sub-categories were measured.
3)
In keeping with the GHG Potocol’s Scope 2 guidance, dual reporting on market-based and location-based emissions is shown.
4)
Restated to reflect increased data accuracy.
1)

2)

Values used to normalize our emissions data and calculate emissions intensity
n Nordics (including HQ) (42%)
n Europe (12%)
n Asia Pacific & Middle East
Africa (32%)
n United States (14%)

Unit

2023

2022

2021

Employees

Full-time equivalent employees (FTEs)

4,021

3,447

2,904

Revenue

Millions (Norwegian Kroner)

6,397

5,200

3,659

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Monitoring our energy consumption
Our total energy consumption in 2023 was 6,659MWh,
representing an 8.18% increase compared to 2022.
The increased energy consumption contributed to ourincreased Scope 1 and Scope 2 emissions in 2023.

Climate risks and opportunities
As discussed earlier in this chapter, indirect
greenhouse gas emissions upstream and downstream
in our value chain (Scope 3 emissions) accounted for
92% of our total carbon footprint in 2023, followedby Scope 2 emissions at 6% (indirect emissions frompurchased energy) and Scope 1 emissions at 2%(direct emissions from sources owned or controlled by
Crayon) respectively.
Within Scope 3 emissions, goods and services
procured from our value chain were the single biggest
component of our Scope 3 and overall emissions. We
are exploring measures such as cost containment andother interventions in our value chain as these would
have the biggest impact on our total carbon footprint.
We are also cognizant of the need to expand ourreporting to more Scope 3 sub-categories in order tohave a more accurate assessment of our emissions
and where and how to intervene.

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Notwithstanding, reducing Scope 3 emissions requires
collaborative efforts within our business ecosystem. In
future, Crayon will be working even more closely withour customers, partners and suppliers to drive down
emissions and their associated environmental impacts.
In 2024 we plan to set science-based emission
reduction targets in accordance with the Science
Based Targets Initiative (SBTi). The targets andaccompanying decarbonization plan will help us
to mitigate our carbon emissions. This exercise,
combined with the enhanced reporting requirements
under the CSRD and ESRS, will yield more insight into
our climate-related physical and transition risks andmitigation pathways. Where applicable, opportunities
for climate change adaptation may also be identified.
Additional information about our climate-related risks
and opportunities is available in other parts of thisreport:• Annex A: TCFD Index.
• Annex C: 2023 EU Taxonomy Report.

Energy consumption (MWh)

2023

2022

2021

Total Crayon energy consumption within the organization

6,659

6,156

6,316

Total energy consumption within the organization from non-renewable sources

3,686

2,921

2,536

971

512

249

Consumption from heavy oil
Consumption from diesel

316

558

418

Consumption of other non-renewable energy

2,399

1,850

1,869

Total energy consumption within the organization from renewable sources

2,973

3,235

3,780

17

29

22

2,956

3,206

3,758

Consumption of biomass energy
Consumption of other renewable energy|

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PROTECTING THE PLANETANNEXESA. Task Force on Climate-related Financial Disclosures (TCFD) Index
B. Sustainability Accounting Standards (SASB) Index
C. 2023 EU Taxonomy Report|

ANNEXES43

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PROTECTING THE PLANET|ANNEXESA. Task Force on Climate-related Financial Disclosures (TCFD) Index
According to the TCFD website, the TCFD fulfilled its mandate and officially disbanded in October 2023. However, pending our adoption of other frameworks in future, in 2023 Crayon chose to continue making climate disclosures inline with the TCFD framework in order to help us continue to improve the quality of our reporting. This approach is recommended good practice by the TCFD.

Topic

Disclosure (qualitative or quantitative)

Crayon’s 2023 responsea) Describe the Board’s oversight of climate-related risks and opportunities.

See Crayon 2023 Annual Report, Statement of Corporate Governance, page 19.

b) Describe management’s role in assessing and managing climate-related risks andopportunities.

Our group-wide ISO 14001:2015 certification involves taking into account climate related risks and opportunities
to some extent. The leaders of the relevant functions participate in the environmental management review
meetings where climate and other environmental topics are covered.

GOVERNANCE

See our chapter Protecting the planet on page 35.
STRATEGYa) Describe the climate-related risks and opportunities the organization has identified
over the short, medium, and long term.

See our chapter, Climate risks and opportunities on page 42.
See our chapter, Greening the IT landscape on page 37.
See our Annex C. 2023 EU Taxonomy Report.

b) Describe the impact of climate-related risks and opportunities on the organization’s
businesses, strategy, and financial planning.

As companies implement their commitments to reduce their environmental impact and develop carbon targets,
we see potential opportunities to develop Crayon services that facilitate the green transition. See our chapter
Greening the IT landscape on page 37.
In 2024 we will set science-based emission reduction targets in accordance with the Science Based Targets
Initiative (SBTi). The targets and accompanying decarbonization plan will help us to mitigate our carbon
emissions. This exercise, combined with the enhanced reporting requirements under the CSRD and ESRS, will
yield more insight into our climate-related physical and transition risks. Where applicable, opportunities forclimate change adaptation may also be identified.

c) Describe the resilience of the organization’s strategy, taking into consideration different Our commitment to science-based emission reduction target setting, once operationalized, will contributetowards increasing the climate resilience of our day-to-day operations and overarching business strategy.
climate-related scenarios, including a 2°C or lower scenario.

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PROTECTING THE PLANET|ANNEXESTCFD continued
Topic

Disclosure (qualitative or quantitative)

Crayon’s 2023 response

RISK MANAGEMETa) Describe the organization’s processes for identifying and assessing climate-related risk. Crayon’s global ISO 14001: 2015 certification (our environmental management system) to some extent includes
processes for identifying and assessing climate-related risks.
b) Describe the organization’s processes for managing climate-related risks.

Crayon’s global ISO 14001: 2015 certification (our environmental management system) to some extent includes
processes for managing climate-related risks.

c) Describe how processes for identifying, assessing, and managing climate-related risks
are integrated into the organization’s overall risk management.

Crayon’s integrated risk management framework consolidates risks from all our management systems to offer
strategic insights for cross-domain decision-making.
See Crayon 2023 Annual Report, Statement of Corporate Governance, page 19.

METRICS AND TARGETSa) Disclose the metrics used by the organization to assess climate-related risks andopportunities in line with its strategy and risk management process.

See Crayon 2023 Annual Report, Statement of Corporate Governance, page 19.

b) Disclose Scope 1, Scope 2, and, if appropriate, Scope 3 greenhouse gas (GHG)
emissions, and the related risks.

See our chapter Managing greenhouse gas emissions on page 40.

c) Describe the targets used by the organization to manage climate-related risks,
opportunities and performance against targets.

In 2024 we will set science-based emission reduction targets in accordance with the Science Based Targets
Initiative (SBTi). The targets and accompanying decarbonization plan will help us to mitigate our carbon
emissions. This exercise, combined with the enhanced reporting re quirements under the CSRD and ESRS, will
yield more insight into our climate-related physical and transition risks. Where applicable, opportunities forclimate change adaptation may also be identified.

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PROTECTING THE PLANET|ANNEXESB. Sustainability Accounting Standards (SASB) Index
We report on the SASB sector-specific standard for the software and IT services industry, June 2023 version. Only sustainability topics and disclosures are included – activity metrics are excluded.

Topic

SASB code

Disclosure (qualitative or quantitative)

Crayon’s 2023 response

Environmental Footprint ofHardware Infrastructure

TC-SI-130a.1.

1. Total energy consumed,
2. percentage grid electricity,
3. percentage renewable

1, 2, 3:See our chapter Green data hosting on page 38.
See our chapter Monitoring our energy consumption on page 42.

TC-SI-130a.2.

Water usage

See our chapter Green data hosting on page 38.
See our chapter Our handling of waste and water on page 39.

TC-SI-130a.3.

Discussion of the integration of environmental considerations
into strategic planning for data center needs

See our chapter Green data hosting on page 38.

TC-SI-220a.1.

Description of policies and practices relating to behavioral
advertising and user privacy

Crayon’s commitment to protecting the privacy of those individuals whose personal data we process is cemented
in our horizontal approach to privacy by design. We maintain records of processing which define the lawful
purposes for which personal data may be processed and perform ongoing internal audits to ensure personal
data is only processed for the defined lawful purposes. Every Crayon team member around the world is provided
with data protection training during their onboarding, whereafter they are expected to champion privacy inthe knowledge that our success in data protection depends on their diligence when processing personal data
and when enabling individuals to exercise their privacy rights. Any data subject access request we receive goes
directly to Crayon’s Information Security and Data Protection team, where it is immediately reviewed by our
Data Protection Officer and actioned upon in the interests of the data subject.

Data Privacy and Freedom ofExpression

TC-SI-220a.2. Number of users whose information is used for secondary
purposesZero. Crayon does not process user information outside the parameters of the lawful purposes defined in ourrecords of processing and communicated in our privacy policies.

TC-SI-220a.3. Total amount of monetary losses as a result of legal proceedings
associated with user privacy

Zero. Crayon did not incur monetary losses in 2023 as a result of legal proceedings associated with user privacy.

TC-SI-220a.4. 1. Number of law enforcement requests for user information,
2. number of users whose information was requested,
3. percentage resulting in disclosure

Zero. Crayon did not receive law enforcement requests for user information in 2023.

TC-SI-220a.5. List of countries where core products or services are subject togovernment-required monitoring, blocking, content filtering, or
censoringZero. Crayon did not operate in any countries where core products or services are subject to governmentrequired monitoring, blocking, content filtering, or censoring in 2023.

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PROTECTING THE PLANET|ANNEXESSASB continued
Topic

SASB code

Disclosure (qualitative or quantitative)

Crayon’s 2023 response

Data Security

TC-SI-230a.1.

1. Number of data breaches,
2. percentage involving personally identifiable information (PII),
3. number of users affected

Zero. Crayon did not have any data breaches in 2023.

Recruiting and Managing a
Global, Diverse and Skilled
Workforce

TC-SI-230a.2. Description of approach to identifying and addressing data
security risks, including use of third-party cybersecurity
standards

Data security risks observed in the course of Crayon’s day-to-day operations and ongoing internal audits arecaptured in a dedicated risk register, which is addressed by Crayon’s Chief Information Security Officer, together
with the relevant stakeholders across the business as part of Crayon’s process of continuously improving its
Information Security Management System. Whereas Crayon’s service delivery teams are responsible for ensuringongoing compliance with third-party security standards against Crayon’s global technical and organizational
security measures, Crayon’s Trust Assurance team also reviews customer-specific security requirements as anintegral part of its ongoing internal audit.

TC-SI-330a.1.

1. Historically, we have not had a standardized global overview of employees’ immigration status. As part of ourefforts to further centralize and automate, going forward this information will be tracked in our HR system
and added individually per employee.
2. 78.7% of our employees are based outside Norway.

Percentage of employees that are:
1. foreign nationals and2. located offshore

TC-SI-330a.2. Employee engagement as a percentage

In 2023, the global employee feedback survey was conducted with the support of an external service provider
and had a 69% global employee participation rate.
The overall satisfaction score was 4.2 out of a maximum possible score of 5.0. The survey contained 47 rating
items (5-point Likert scale) in seven categories.
The employee net promoter score (eNPS) was 44, with 88.1% of our employees indicating they would recommend
Crayon as a place to work. (“How likely are you to recommend Crayon as a good place to work?”)

TC-SI-330a.3. Percentage of gender and racial/ethnic group representation for: 1. 29% female
1. management,
2. 24% female
2. technical staff, and3. 43% female
3. all other employees
Legal restrictions and other factors in Crayon’s different countries of operation constrained our ability to reporton metrics like race/ethnicity in 2023.
Intellectual Property Protection
and Competitive Behavior

TC-SI-520a.1.

Total amount of monetary losses as a result of legal proceedings
associated with anti-competitive behavior regulations

Zero. No legal proceedings associated with anti-competitive behavior regulations were initiated in 2023.

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PROTECTING THE PLANET|ANNEXESSASB continued
Topic

SASB code

Disclosure (qualitative or quantitative)

Managing Systemic Risks fromTechnology Disruptions

TC-SI-550a.1.. Number of
1. performance issues and2. service disruptions;
3 total customer downtime

Crayon’s 2023 response
1. 4
2. 27
3 2,910 minutes1
1

TC-SI-550a.2. Description of business continuity risks related to disruptions ofoperations

We had interruptions to the service 2,970 minutes in total, but as we do not license cloud-iQ no licenses were affected.

Crayon’s Corporate Security team manages global Business Continuity and Disaster Recovery (BCDR) planning.
Our BCDR plan outlines steps and procedures for risk assessment and business impact analysis, identification ofcritical processes and systems, points of contact, development of recovery strategies, and testing and validationof the plan. The plan ensures that critical functions can be restored and resumed from adverse events as quickly
and effectively as possible within defined recovery time and point objectives. This is to ensure stakeholder
confidence in Crayon’s agility to withstand disruptions and recover quickly. Crayon’s main risk spaces related
to disruptions of operations include Crayon’s customer-facing platforms, data centers, and the impact of theongoing war on Ukraine.

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ANNEXES

C. 2023 EU Taxonomy Report
About the EU Taxonomy Regulation
The EU Taxonomy Regulation1 aims to boost
investment in environmentally friendly activities bycreating a common language and framework forinvestors, issuers, and policymakers. It is a key elementof the European Green Deal’s aspirations for Europe tobecome a climate-neutral continent by 2050.
The taxonomy provided in the Regulation is aclassification tool that enables companies tocategorize their business activities as:• Taxonomy-eligible
Having the potential to be considered sustainable
and potentially contribute to one of the six
environmental objectives laid out in Article 9 of theRegulation.
• Taxonomy-aligned
Being taxonomy-eligible while also meeting
additional criteria specified in the Regulation, suchas complying with minimum safeguards and not
significantly harming any of the environmental
objectives.
Norway’s Sustainable Finance Act2, which entered into
force on 1 January 2023, is the Norwegian legislation
capturing the requirements of the EU Taxonomy
Regulation and its delegated acts, including theDisclosures Delegated Act. Consequently, in-scopecompanies incorporated in Norway such as our parent
Crayon Group Holding ASA, are required to report inline with Article 8 of the EU Taxonomy Regulation.

1

2

2020/852 Regulation (EU) of The European Parliament and of theCouncil of 18 June 2020 on the establishment of a framework tofacilitate sustainable investment, and amending Regulation (EU)2019/2088.
Act on the Disclosure of Sustainability Information in the Financial
Sector and a Framework for Sustainable Investments (LAW-202112-22-161)

Our scope of reporting
The reporting period of this, our first taxonomy report,
is Crayon’s 2023 financial year which ran from 1
January to 31 December 2023. The taxonomy reporting
period is aligned with that of our 2023 ESG Report andthat of our 2023 Annual Report.
The information is prepared on a group consolidated
level and presented in Norwegian Kroner (NOK), as in
the consolidated financial statements.

Economic activity as described in the Climate
Delegated Act

As required by law, this report covers Crayon’s
business activities that are either eligible or noneligible under the taxonomy, as well as our taxonomyaligned activities. In 2024, we will enhance ourscreening and reporting methodologies to improve
the accuracy of our reporting, with a focus on climatechange mitigation and adaptation.
Progress made in evaluating our economic activities
in 2023
Our preliminary analysis in 2023 showed that parts of
Crayon’s core business may potentially correspondPotentially in-scope Crayon services
and solutions

Activity 8.1 Data processing, hosting, and related activities
Data processing and hosting
Storage, manipulation, management, movement, control,
We have three data centers in Norway anddisplay, switching, interchange, transmission or processing of
Iceland. One data center is owned by us,
data through data centres(376), including edge computing. The
and we lease capacity in the other two. Our
economic activities in this category could be associated withthree data centers assist clients in lowering
NACE code J63.11 in accordance with the statistical classification of their carbon footprint by migrating, storing,
economic activities established by Regulation (EC) No 1893/2006. and processing their data from less energyAn economic activity in this category is a transitional activity as
efficient on-premise facilities to our efficientreferred to in Article 10(2) of Regulation (EU) 2020/852 wheredata centers. Additionally, these data centers
it complies with the technical screening criteria set out in thisare powered by renewable energy sources.
Section.

to some of the relevant, in-scope economic activities
identified in the Climate Delegated Act.
We screened the Taxonomy rules to create a list of
economic activities that could potentially be eligibleor aligned. The description of each economic activity
was mapped against our operations and the broader
context to establish the best possible fit.
Crayon service offerings and solutions that we believe
may potentially be in-scope are as follows:

Potentially applicable environmental objective
as described in Climate Delegated Act• Mitigation

Activity 8.2 Data-driven solutions for greenhouse gas emissions
Cloud migration• Mitigation
reductions
We offer cloud migration services to our• Adaptation
Development or use of ICT solutions that are aimed at collecting, customers including banks, governmenttransmitting, storing data and at its modelling and use whereentities and utility companies. In addition to
those activities are predominantly aimed at the provision of
the convenience of remote access to services
data and analytics enabling GHG emission reductions. Suchand operations, digitalization and cloud
ICT solutions may include, inter alia, the use of decentralized
migration services may assist Crayon’s clients
technologies (i.e. distributed ledger technologies), Internet ofin reducing their emissions and consumption
Things (IoT), 5G and Artificial Intelligence. The economic activities of cloud resources by transitioning fromin this category could be associated with several NACE codes,
less efficient on-premise setups to cloudin particular J61, J62 and J63.11 in accordance with the statisticalenvironments. Furthermore, these technologies
classification of economic activities established by Regulation (EC) could potentially ensure safer and more
No 1893/2006.
resilient data management and infrastructurein the face of severe weather events.

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DELIVERING A TRUSTED BUSINESSEU Taxonomy continued
For each relevant business activity, the EU Taxonomy
requires companies to disclose the percentage of their
turnover, operating expenditures (OpEx) and capital
expenditures (CapEx) that is eligible, non-eligible andaligned. Although we made progress in 2023, Crayonis still in the process of completing our assessment andwill have more comprehensive findings to disclose in
next year’s Taxonomy report.
Consequently, for 2023 we are reporting zeroeligibility and zero alignment across turnover,
CapEx and OpEx.
More disclosures are in the following pages using theprescribed statutory templates:• Our eligibility and alignment KPIs for turnover,
CapEx and OpEx.
• Our activities related to nuclear energy andfossil gas.
Our accounting policies: The information on thefollowing pages is prepared on a group consolidated
level and presented in Norwegian Kroner (NOK),
the same approach as in Crayon’s separate 2023
Annual Report. Our definitions and calculation
methodologies for turnover, CapEx, and OpEx in thefollowing pages are derived directly from Crayon’s
separate 2023 Annual Report and are the same. The
2023 Annual Report contains Crayon’s consolidated
annual financial statements, which are compiled incompliance with the International Financial ReportingStandards (IFRS) and the relevant legislation.

|

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51

ANNEXESEU Taxonomy continued

TurnoverFinancial year 2023

Year

Biodiversity (16)Minimum Safeguards (17)

Y/N

Y/N

Y/N

Y/N

Y/N

Y/N

%

Category (transitional activity) (20)

Circular Economy (15)Y/N

A. TAXONOMY-ELIGIBLE ACTIVITIESCategory (enabling activity) (19)

Pollution (14)Proportion of Taxonomy-aligned (A.1.)
or -eligible (A.2.) turnover, Year 2022 (18)

Water (13)%Climate Change Adaptation (12)%Climate Change Mitigation (11)%Biodiversity (10)%DNSH criteria (‘Does Not Significantly Harm’)Circular Economy (9)%Pollution (8)%Water (7)%Climate Change Adaptation (6)Climate Change Mitigation (5)NOKmillions

Substantial Contribution Criteria
Proportion of Turnover, Year 2023 (4)Turnover (3)Code (2)Economic Activities (1)

E

T

N/A

A.1. Environmentally sustainable activities (Taxonomy-aligned)

N/A
0%

-

-

-

-

-

-

N/A

0%

-

-

-

-

-

-

N/A

0%

-

-

-

-

-

-

N/A

Turnover of environmentally sustainable activities (Taxonomy-aligned) (A.1)

0.00

0%

-

-

-

-

-

-

-

-

-

-

-

-

-

N/A

-

-

Of which enabling

0.00

0%

-

-

-

-

-

-

-

-

-

-

-

-

-

N/A

-

-

Of which transitional

0.00

0%

-

-

-

-

-

-

-

-

-

-

-

-

-

N/A

-

-

A.2 Taxonomy-Eligible but not environmentally sustainable activities (notTaxonomy-aligned activities)
Data processing, hosting and related activities

8.1

0.00

0%

Data-driven solutions for GHG emissions reductions

8.2

0.00

0%

Turnover of Taxonomy-eligible but not environmentally sustainable activities(not Taxonomy-aligned activities) (A.2)

0.00

0%

A. Turnover of Taxonomy-eligible activities (A.1+A.2)

0.00

0%

Turnover of Taxonomy-non-eligible activities

6,397

100%

TOTAL (A+B)

6,397

100%

B. TAXONOMY-NON-ELIGIBLE ACTIVITIESCONTENTS|

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ANNEXESEU Taxonomy continued

Capital expenditure
Financial year 2023

Year

Biodiversity (16)Minimum Safeguards (17)

Y/N

Y/N

Y/N

Y/N

Y/N

Y/N

%

Category (transitional activity) (20)

Circular Economy (15)Y/N

A. TAXONOMY-ELIGIBLE ACTIVITIESCategory (enabling activity) (19)

Pollution (14)Proportion of Taxonomy-aligned (A.1.)
or -eligible (A.2.) CapEx, Year 2022 (18)

Water (13)%Climate Change Adaptation (12)%Climate Change Mitigation (11)%Biodiversity (10)%DNSH criteria (‘Does Not Significantly Harm’)Circular Economy (9)%Pollution (8)%Water (7)%Climate Change Adaptation (6)Climate Change Mitigation (5)NOKmillions

Substantial Contribution Criteria
Proportion of CapEx, Year 2023 (4)CapEx (3)Code (2)Economic Activities (1)

E

T

N/A

A.1. Environmentally sustainable activities (Taxonomy-aligned)

N/A
0%

-

-

-

-

-

-

N/A

0%

-

-

-

-

-

-

N/A

0%

-

-

-

-

-

-

N/A

CapEx of environmentally sustainable activities (Taxonomy-aligned) (A.1)

0.00

0%

-

-

-

-

-

-

-

-

-

-

-

-

-

N/A

-

-

Of which enabling

0.00

0%

-

-

-

-

-

-

-

-

-

-

-

-

-

N/A

-

-

Of which transitional

0.00

0%

-

-

-

-

-

-

-

-

-

-

-

-

-

N/A

-

-

A.2 Taxonomy-Eligible but not environmentally sustainable activities (notTaxonomy-aligned activities)
Data processing, hosting and related activities

8.1

0.00

0%

Data-driven solutions for GHG emissions reductions

8.2

0.00

0%

CapEx of Taxonomy-eligible but not environmentally sustainable activities(not Taxonomy-aligned activities) (A.2)

0.00

0%

A. CapEx of Taxonomy-eligible activities (A.1+A.2)

0.00

0%

Capex of Taxonomy-non-eligible activities

154

100%

TOTAL (A+B)

154

100%

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ANNEXESEU Taxonomy continued

Operating expenditure
Financial year 2023

Year

Biodiversity (16)Minimum Safeguards (17)

Y/N

Y/N

Y/N

Y/N

Y/N

Y/N

%

Category (transitional activity) (20)

Circular Economy (15)Y/N

A. TAXONOMY-ELIGIBLE ACTIVITIESCategory (enabling activity) (19)

Pollution (14)Proportion of Taxonomy-aligned (A.1.)
or -eligible (A.2.) OpEx, Year 2022 (18)

Water (13)%Climate Change Adaptation (12)%Climate Change Mitigation (11)%Biodiversity (10)%DNSH criteria (‘Does Not Significantly Harm’)Circular Economy (9)%Pollution (8)%Water (7)%Climate Change Adaptation (6)Climate Change Mitigation (5)NOKmillions

Substantial Contribution Criteria
Proportion of OpEx, year 2023 (4)OpEx (3)Code (2)Economic Activities (1)

E

T

N/A

A.1. Environmentally sustainable activities (Taxonomy-aligned)

N/A
0%

-

-

-

-

-

-

N/A

0%

-

-

-

-

-

-

N/A

0%

-

-

-

-

-

-

N/A

OpEx of environmentally sustainable activities (Taxonomy-aligned) (A.1)

0.00

0%

-

-

-

-

-

-

-

-

-

-

-

-

-

N/A

-

-

Of which enabling

0.00

0%

-

-

-

-

-

-

-

-

-

-

-

-

-

N/A

-

-

Of which transitional

0.00

0%

-

-

-

-

-

-

-

-

-

-

-

-

-

N/A

-

-

A.2 Taxonomy-Eligible but not environmentally sustainable activities (notTaxonomy-aligned activities)
Data processing, hosting and related activities

8.1

0.00

0%

Data-driven solutions for GHG emissions reductions

8.2

0.00

0%

OpEx of Taxonomy-eligible but not environmentally sustainable ac-tivities(not Taxonomy-aligned activities) (A.2)

0.00

0%

A. OpEx of Taxonomy-eligible activities (A.1+A.2)

0.00

0%

OpEx of Taxonomy-non-eligible activities

756

100%

TOTAL (A+B)

756

100%

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PROTECTING THE PLANET|ANNEXESEU Taxonomy continued

Nuclear and fossil gas related activities
After an assessment of our activities, we concluded that in 2023 Crayon did not have any exposure to or
involvement in activities related to either nuclear energy or fossil gas.

Nuclear energy related activities
1

The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovativeelectricity generation facilities that produce energy from nuclear processes with minimal waste from the fuel cycle.

NO

2

The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce
electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production, as
well as their safety upgrades, using best available technologies.

NO

3

The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity
or process heat, including for the purposes of district heating or industrial processes such as hydrogen production from nuclear
energy, as well as their safety upgrades.

NO

Fossil gas related activities
4

The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce
electricity using fossil gaseous fuels.

NO

5

The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool andpower generation facilities using fossil gaseous fuels.

NO

6

The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities
that produce heat/cool using fossil gaseous fuels.

NO

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ANNEXES

Crayon Group Holding ASA
Gullhaug Torg 50484 Oslo
Crayon.com