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CONTENTS
THIS IS KOMPLETT GROUP 3
Komplett Group at a glance 4
Letter from the chair 7
Our history 8
Our business segments 9
Consumer trends 13
Komplett Group’s strategic framework 14
Community engagements 16
Share information 17
OPERATIONS 20
GOVERNANCE 24
Group management 24
Board of directors 26
Corporate governance report 28
Internal control and risk management 33
CONSOLIDATED FINANCIAL STATEMENTS 88
Consolidated financial statements 89
Notes to the consolidated financial statements 93
Komplett ASA financial statements 120
Notes to the financial statements –
Komplett ASA 124
Independent auditor’s report 131
Independent sustainability auditor’s
limited assurance report 133
Contact 135
SUSTAINABILITY STATEMENT 37
General information 38
Environmental information 63
Social information 80
Governance information 85
Statement from the board of directors 87
BOARD OF DIRECTORS REPORT 19
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THE LARGEST
NORDIC ONLINE-
FIRST ELECTRONICS
RETAILER
Komplett Group was founded in Sandefjord,
Norway, in 1991 and introduced e-commerce to
the Norwegian market in 1996.
Today, Komplett Group is the leading online-first
company in the consumer electronics market in
the Nordics. The group operates five well-known
brands that serve customers in the B2C, B2B, and
Distribution segments.
These brands deliver integrated and seamless
shopping experiences, supported by high-quality
customer service, efficient logistics, and top-tier
last-mile solutions. They are all supported by
strategically located warehouses in Sandefjord,
Norway, and in Borås, Sweden.
Komplett Group’s scalable and efficient business
model enables cost leadership. In line with its
strategy, the group is committed to developing
and maintaining a portfolio of strong Nordic
retail brands that serve distinct segments while
realising commercial and cost efficiencies
through centralised operations. Komplett ASA is
listed on the Oslo Stock Exchange (KOMPL).
THIS IS
KOMPLETT
GROUP
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KOMPLETT GROUP AT A GLANCE
5
9
THE LARGEST
NORDIC ONLINE-
FIRST ELECTRONIC
RETAILER
Total revenues
NOK 15 775 million
REVENUES BY
COUNTRY
nNorway 47.9%
nSweden 50.3%
nDenmark 1.8%
REVENUES BY
SEGMENT
nB2C 72.5%
nDistribution 17.7%
nB2B 9.8%
NUMBER OF
EMPLOYEES
1 459
Male: 68.9%
Female: 31.0%
Other: 0.1%
High customer
satisfaction
Fast and convenient
delivery
Logistics centres
NetOnNet
34 locations in Norway
and Sweden
Norway
Main office Oslo
445 employees
Denmark
Sales only
Sweden
Main office Borås
1 014 employees
Webhallen
12 locations in Sweden
Loyal and engaged
customers
Knowledgable
customer service
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HIGHLIGHTS 2025
SALES GROWTH IN A
COMPETITIVE MARKET
3.1 per cent sales growth driven by improved
market momentum, strong performance in Norway,
and new product launches
DISCIPLINED
COST EXECUTION
Restructuring and efficiency measures
offset inflation and growth investments,
resulting in stable operating expenses
IMPROVED
GROSS MARGIN
Gross margin up 0.6pp, supported by
rebalanced pricing, stronger product mix and
more normalised competitive conditions
STABLE
FINANCIAL POSITION
Solid liquidity reserve and a leverage
ratio of 1.4x by the end of the year, in line
with agreed arrangements
CONTINUED FOCUS ON
REDUCING WASTE
Total packaging use reduced by more
than 60 tonnes from 2024 to 2025
ENERGY INTENSITY IN HIGH-IMPACT
SECTORS REDUCED
Energy intensity in high climate impact sectors
declined by 15 per cent year-on-year in 2025,
measured per unit of net revenue
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KEY FIGURES 2025
2022 2023 2024 2025
11.7%
13.1%
14.0% 14.0%
Operating cost percentage
Per cent
0.0%
2022 2023 2024 2025
1 794
2 211
2 091
2 257
12.3%
13.9%
13.7%
14.3%
Gross profit
NOK million
7.9%
2022 2023 2024 2025
87
139
−47
44
Adjusted EBIT
NOK million
+ NOK 91 million
2022 2023 2024 2025
14 618
15 861
15 301
15 775
Operating revenue
NOK million
3.1%
Note: Reported numbers are impacted by NetOnNet, which was consolidated into Komplett Group’s financial statements as of 1 April 2022.
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LETTER FROM THE CHAIR
This past year, Komplett Group has
implemented a series of structural and
strategic changes intended to support the
group’s long-term competitiveness. During
this period of change, our teams have
continued to drive operational improve-
ments while maintaining the strength of our
brands, and I would like to thank them for
their commitment and efforts.
Since joining Komplett Group as CEO in 2023, and later
becoming chair in 2025, I have come to know the group as
a customer-oriented organisation built on strong, well-
established brands. The position of our brands, together
with the strategic and commercial initiatives undertaken,
provides a foundation from which we can continue working
to strengthen the group’s competitiveness over time.
STRENGTHENING OUR OPERATIONAL EXECUTION
We have continued to develop our commercial capabilities,
including expanding our private label assortments and
strengthening our position in selected categories such
as domestic appliances. Our in-house manufactured
PCs, branded as Komplett PCs, have maintained a solid
position among dedicated gamers and technology-oriented
customers across the Komplett, NetOnNet and Webhallen
brands. This reflects how collaboration across the
organisation and customer insights can support commercial
development.
At the same time, we have addressed areas facing
challenges, particularly in Sweden, where progress has been
slower than initially expected. Measures to streamline our
logistics footprint and improve operational execution are
contributing to a more efficient platform, and we have also
reduced balance sheet exposure through an impairment
related to these operations.
Supported by initiatives aimed at improving margins and
maintaining cost control, the group delivered profitability
growth during the year and preserved a stable financial
position with solid liquidity. This provides a reasonable base
as we continue to develop the business.
ADVANCING OUR STRATEGIC AGENDA
As we continue to execute our strategic agenda, the
management team has been strengthened with additional
capabilities, including key resources responsible for our
brands and groupwide functions such as commercial
operations and HR, as well as new roles overseeing IT
and supply chain. These changes aim to enhance the
organisation’s ability to deliver on its strategic priorities.
In line with our strategic direction, our teams remain
committed to maintaining efficient and scalable operations
and delivering reliable, high-quality customer experiences
across categories and brands.
A STRONG PLATFORM OF BRANDS
Our brands are designed to complement each other, with
each concept addressing different customer preferences.
A recent consumer survey reconfirmed that our brands
are generally well understood in the market and highly
regarded by customers. This strong consumer relevance
helps support our position in the market and the consumer
perspective guides us in all decisions we make. During
the year, the group’s brands were also recognised for
great customer care and delivery service, contributing to
continued customer satisfaction and loyalty.
LOOKING AHEAD
We enter 2026 with a more stable financial position,
improved operational structures and clearer priorities.
Consumer sentiment is expected to support a generally
healthy market, although growth driven by recent product
launches is likely to moderate and competitive pressure
is likely to remain high. In addition, supply constraints in
memory components are expected to continue affecting
several of our key categories in the period ahead.
To navigate these conditions, we will remain focused on
disciplined execution and close engagement with our
customers. Our priorities include enhancing the customer
experience, strengthening our offering in targeted
categories, and continuing to improve commercial, supply
chain and operational efficiency across the group.
I would also like to thank Ros-Marie Grusén for her dedication
and commitment as CEO. During her tenure, she has
swiftly implemented important structural and operational
initiatives across the group and helped strengthen the
management team in line with our strategic direction. The
board regrets her decision to step down and thanks her for
her contribution.
Lastly, I would like to thank our employees for their ongoing
efforts to deliver great customer experiences across our
brands, as well as our partners, suppliers and shareholders
for their continued cooperation and support.
Yours sincerely
Jaan Ivar Semlitsch
Chair
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OUR HISTORY
Komplett.no
established
Webhallen.com
established
The group’s
distribution
activities are
operated under
the Itegra brand
Netonnet.se
established
Private label TV
established
Purchased an
office in Asia
Komplett +
Itegra
One of
AutoStore’s
first customers
First e-com
site with Black
Friday
Komplett Group
+ Webhallen
NetOnNet + SIBA,
SIBA brand
discontinued
Joint warehouse and
back office functions
in Sweden
IPO - listed at OSE
Komplett Group +
Ironstone
Komplett Group
+ NetOnNet
Gamified loyalty
programme
1996
1999
2022
2025
2016
20082005 20212013
201020072000
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OUR BUSINESS SEGMENTS
KOMPLETT
The preferred choice for technology-focused consumers
and gamers who seeks the latest technology, and an
approachable expert for customers less familiar with
technology.
NETONNET
34 self-service warehouse stores serving value-oriented
customers in the mass market who seek quality at
competitive prices.
WEBHALLEN
12 compact retail stores that target both dedicated gaming
enthusiasts and casual gamers through a playful, community-
focused retail experience.
KOMPLETT BEDRIFT
The B2B online electronics specialist supplying IT equipment,
technology products, and related services to corporate and
public-sector customers in the Norwegian market through
efficient digital platforms.
KOMPLETT FÖRETAG
Online electronics specialist targeting business customers
in the Swedish market, supplying IT equipment, technology
products, and related services.
IRONSTONE
The simple, secure IT partner specialising in cloud solutions
and managed services. The company helps enterprise clients
operate scalable, secure, and cost-efficient IT environments.
ITEGRA
Itegra specialises in large-scale distribution of a broad range
of IT hardware and telecom products to resellers, system
integrators, and business partners from its automated
distribution centre in Sandefjord.
The company focuses on efficient logistics and a wide
product portfolio to support professional B2B customers
across the Nordic market.
Business to consumer (B2C) DistributionBusiness to business (B2B)
NOK 11.4
billion
72%
NOK 1.5
billion
10%
NOK 2.8
billion
18%
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BUSINESS TO CONSUMER (B2C)
2021 2022 2023 2024 2025
6 382
9 785
11 195
10 877
11 435
Revenues
NOK million
2021 2022 2023 2024 2025
15.4%
13.6%
15.7%
15.4%
16.0%
Gross margin
Per cent
2021 2022 2023 2024 2025
11.8%
13.5%
14.4%
15.4% 15.4%
Operating cost
Per cent
2021 2022 2023 2024 2025
229
12
150
4
62
EBIT
NOK million
REVENUE GROWTH
(from 2024 to 2025)
5.1%
The group’s B2C operations focus on serving private consumers
across Norway, Sweden, and Denmark through its NetOnNet,
Komplett, and Webhallen brands.
The group operates in the electronics,
technology, and consumer goods markets
via six online stores, offering products from
third-party products alongside its own
private labels.
Komplett operates a pure online brand,
specialising in electronics, with a strong
focus on technology, computing, and gaming.
B2C customers are served through Komplett.
no, Komplett.se, and Komplett.dk, as well
as a pick-up point located at the Sandefjord
warehouse in Norway.
NetOnNet is positioned as a low-cost, value-
driven challenger, offering everyday low
prices to mass-market consumers across a
broad assortment of products, spanning both
leading brands and private label alternatives.
Its omnichannel model includes 34 self-
service logistics and warehouse stores in
Norway and Sweden. NetOnNet also has two
online stores, NetOnNet.se and NetOnNet.no.
Webhallen targets gaming enthusiasts in the
Swedish market. As an omnichannel provider,
it offers consumer electronics through its
online platform, Webhallen.com, as well
as 12 strategically located retail stores in
Stockholm and other major cities in Sweden.
Note: Reported numbers are impacted by NetOnNet, which was consolidated into Komplett Group’s financial statements as of 1 April 2022.
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BUSINESS TO BUSINESS (B2B)
2021 2022 2023 2024 2025
1 528
1 615
1 583
1 519
1 542
Revenues
NOK million
2021 2022 2023 2024 2025
18.0%
17.1%
17.7%
17.1%
17.7%
Gross margin
Per cent
2021 2022 2023 2024 2025
8.4%
9.9%
11.4%
12.2%
11.7%
Operating cost
Per cent
2021 2022 2023 2024 2025
146
116
100
74
93
EBIT
NOK million
REVENUE GROWTH
(from 2024 to 2025)
1.5%
Komplett Group launched its B2B operations in Norway in 2002.
Today, the B2B segment has become a leading online supplier of IT-
and electronics-related products, catering to corporate customers,
particularly small and medium sized enterprises (SMEs) and small
office/home office (SOHO) customers in the Nordic region.
It provides a fully digital customer experience
through its web shops, Komplettbedrift.
no and Komplettforetag.se, serving the
Norwegian and Swedish markets.
With a wide range of competitively priced,
in-stock products, Komplett B2B tailors its
solutions to meet individual customer needs,
to ensure a seamless online purchasing
experience. This is further supported by
experienced customer service teams and
fast, reliable delivery services.
In 2021, the group expanded its B2B
operations by acquiring Ironstone, a provider
of secure, cloud-based IT services and
solutions. With Ironstone, the group’s B2B
offering reflects a broad product selection,
digital accessibility, tailored customer SME
solutions, and advanced IT services.
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DISTRIBUTION
2021 2022 2023 2024 2025
3 124
3 207
3 078
2 907
2 798
Revenues
NOK million
2021 2022 2023 2024 2025
6.2%
5.4%
5.5%
5.3%
5.6%
Gross margin
Per cent
2021 2022 2023 2024 2025
3.7%
3.4%
3.9%
4.4% 4.4%
Operating cost
Per cent
2021 2022 2023 2024 2025
79
63
50
26
35
EBIT
NOK million
EBIT GROWTH
(from 2024 to 2025)
35.6%
The group’s distribution activities are operated under the Itegra
brand, which has been a central part of Komplett Group’s operations
since 1999.
Today, Itegra is a central player in Norway
and Sweden, specialising in large-scale
distribution contracts for resellers and major
entities.
The Distribution segment focuses on large-
scale contracts for mobile and IT products to
retailers and B2B customers. Specialising in
bulk distribution and serving resellers, Itegra
is uniquely positioned to meet the needs
of resellers and large entities, providing a
reliable source for high-volume orders. This
specialisation sets Itegra apart from the
group’s broader retail and B2B operations.
Itegra’s operations are supported by a world-
class setup in Sandefjord, Norway, which
ensures cost efficiency and fast delivery at
scale. The customer base includes leading
consumer electronics brands and retail
chains. Itegra serves its customers through
its websites, Itegra.no and Itegra.se
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SUSTAINED SHIFT
TOWARDS ONLINE
SHOPPING
Convenience remains a key factor
driving the growth of online shopping.
Following the stabilisation of post-
pandemic spending patterns,
e-commerce remains structurally
strong.
Consumers increasingly favour digital
channels that offer speed, availability
and flexibility. AI-driven tools such
as smarter search functions and
personalised recommendations are
becoming an integrated part of the
online shopping experience, particularly
among younger consumers.
GROWTH IN DIGITAL
ENTERTAINMENT AND
GAMING
The rapid growth of streaming services,
gaming, and new technologies is a key
trend driving demand for electronics.
Devices such as smart TVs, gaming
consoles, VR headsets, and high-
performance PCs with AI and voice
technologies are becoming more
popular as consumers seek higher-
quality entertainment experiences.
The rise of e-sports and cloud gaming
has further increased the demand for
advanced hardware and accessorises
that enable seamless and high-quality
content.
ADOPTION OF SMART
HOME AND CONNECTED
TECHNOLOGIES
The expansion of Internet of Things
(IoT) supports continued demand for
smart electronics, including wearables,
smart home devices, and connected
appliances.
Consumers value convenience,
efficiency, and automation, leading
to the popularity of products like
smart speakers, fitness trackers, and
home security systems. Advances in
AI and voice technologies are further
supporting this trend.
Komplett Group’s markets are influenced by digitalisation, product innovation and evolving
lifestyle trends, with technology and AI shaping the customer journey.
CONSUMER TRENDS
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Komplett Group’s strategic platform is
rooted in its vision of being the obvious
choice across its markets and stakeholders.
The group has a clear organic growth plan
targeting revenue increases above market
growth while improving profitability.
AMBITIONS AND OBJECTIVES
Komplett Group’s vision is to be the preferred partner for
customers, suppliers, and employees throughout the Nordic
region. The company’s strategy is centred on achieving
market leadership in e-commerce for consumer electronics,
by leveraging strong brands and operational efficiency, while
delivering a superior customer experience.
STRATEGIC GROWTH AREAS
Komplett Group is exposed to growth opportunities arising
from digitalisation trends, product innovations and evolving
lifestyle trends. The group benefits from growth in core
categories, such as computing and gaming, while expanding
into adjacent categories, such as domestic appliances. In
addition, NetOnNet has expanded its store network in line
with their omnichannel concept, with a new store opening
in Trondheim, Norway in 2025. Investments in digitalisation
and innovation remain a priority in order to meet evolving
consumer needs.
PROFITABILITY AND EFFICIENCY
Komplett Group seeks to improve profitability and efficiency
through commercial as well as operational measures.
Recent initiatives include groupwide cost measures, involv-
ing workforce reductions, as well as the consolidation of
logistics and back-office functions in Sweden. Moreover,
growth in private label and increased exposure in higher-
margin categories will have a positive impact on margins.
KOMPLETT GROUP’S STRATEGIC FRAMEWORK
SUSTAINABILITY AS A CORNERSTONE
Sustainability is integrated into Komplett Group’s strategy.
This is reflected in key initiatives to expand refurbished
and second-life product lines, to reduce emissions across
operations and the supply chain, and to promote diversity,
inclusion, and an attractive workplace.
FINANCIAL TARGETS
Revenue growth
Komplett Group has set a target of achieving NOK 20
billion in revenue, driven primarily by organic growth
initiatives.
Margin development
The group aims to be an industry leader in profitability
and targets an EBIT margin of 3-4 per cent.
Cash conversion
Cash conversion above 70 per cent.
SUSTAINABILITY GOALS
Clear business model
15 per cent of group revenues from circular products
and services by 2028.
Climate neutral
• Scope 1 and 2 GHG reduction of 42 per cent by 2030.
• Net zero by 2040.
Attractive and inclusive employer
• Industry leading employee engagement.
• Gender balance in leadership positions.
FIVE PILLARS LAY THE FOUNDATION FOR OUR CORPORATE STRATEGY
Komplett Group
The leading online-first champion with retail brands loved by customers
Unique retail
brands loved by
customers
Driving force
for sustainable
development
Leading efficiency
and OPEX cost
position
Integrated back-
end and shared
capabilities
Online-first
with speed,
convenience and
leading tech
OUR OPERATING MODEL
Commercial and cost advantages through shared functions and capabilities
Effective platform for expansion
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VALUE CHAIN
STRONG SUPPLIER
RELATIONS
Komplett Group has a wide
customer offering sourced
from a broad network of
high-quality suppliers of
leading brands. The supplier
code of conduct outlines the
legal obligations, and the
integrity standards Komplett
Group expects its suppliers
and business partners to
uphold. The group has a
central commercial team
that negotiates supplier
agreements and supports
compliance across the
group.
EFFICIENT
LOGISTICS
Efficient logistics and
inventory management are
key to Komplett Group’s
operations. The group’s
brands offer seamless
shopping experiences,
convenient delivery and
best-in-class last-mile
solutions. This is facilitated
by strategically positioned
warehouses in Sandefjord,
Norway, and in Borås,
Sweden. The Sandefjord
warehouse is known for
having one of Europe’s most
efficient systems.
ONLINE-FIRST
BUSINESS MODEL
The group’s portfolio of five
distinct brands is widely
recognised by customers
within the B2C, B2B and
Distribution segments. The
group serves its customers
through a combination of
online stores, self-service
warehouse shops (NetOnNet)
and small-box stores
(Webhallen). Across its key
markets, 90 per cent of the
orders are delivered on the
same or next day.
COMMITTED TO
CIRCULARITY
The group collaborates
with suppliers and recycling
partners to maximise waste
recycling. Products that
cannot be repaired are sent
to recycling partners, while
an efficient paper recycling
system is in place at the
Sandefjord warehouse. The
group also offers concepts
that enable customers
to purchase used and
remanufactured products,
along with buyback options.
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COMMUNITY ENGAGEMENTS
Komplett Group is dedicated to supporting
the communities in which they operate.
Through various initiatives, the company
collaborates with charitable organisations,
promotes sustainability, and fosters
inclusivity. Komplett Group aims to
contribute positively to society, and
below are a few examples of how the
group partners with organisations to drive
meaningful change.
GAMERS AGAINST CHILDHOOD CANCER
Initiated during Komplett’s Black Week in 2020, the “Gamers
against Childhood Cancer” charity event was held for the
sixth time in 2025. The initiative is dedicated to raising funds
for the Childhood Cancer Society in Norway, an organisation
that plays a central role in supporting affected families and
fighting childhood cancer.
Building on the success of previous years, “Gamers
against Childhood Cancer” brought together Norway’s top
streamers and gaming influencers for a livestream session at
Komplett’s studios in Sandefjord during Black Week to raise
awareness and mobilise support. It was with great pride that
we could announce that, through six years of collaboration
and effort, we have raised over NOK 12 million for the
Norwegian Childhood Cancer Society.
STREAMING FOR CHARITY
Streamhjälpen is a similar initiative in Sweden, where
streamers and gamers collaborate to raise money for
various charitable causes. By live streaming for 144 hours
straight, Webhallen has through Streamhjälpen successfully
mobilised the gaming community to support important
social issues and provide aid to those in need.
The event coincided with the huge Swedish charity
Musikhjälpen. 2025 saw Webhallen raise close to SEK
1.35 million and bring home an honourable title of the 4th
biggest contributor to Musikhjälpen. This brings the total
contribution to SEK 6.7 million over the past nine years.
SUPPORTING MENTAL HEALTH WITH MIND
Each year, NetOnNet makes a significant donation to Mind, a
non-profit organisation dedicated to promoting mental well-
being through knowledge, advocacy, and compassionate
support. Minds’s work makes a real difference through
initiatives like the Suicide Line, Elderly Line, Life Line, and
Parent Line, offering life-saving conversations and hope to
people in crisis.
For NetOnNet, supporting Mind reflects our core values of
care and humanity, especially during the holiday season - a
time that can be challenging for many. By contributing to
Mind, we help build a society where no one is left without
support when they need it most.
PROMOTING EQUALITY WITH CARE
Komplett Group collaborates with CARE Norway to
support initiatives aimed at promoting gender equality and
empowering women and girls. This partnership involves
various activities, including fundraising campaigns and
awareness programmes. Through these efforts, Komplett
Group helps CARE Norway provide resources and support
to women and girls, enabling
them to improve their economic
conditions, access education,
and protect their rights. The
cooperation highlights a shared
commitment to a more inclusive
society.
Amalie Olsen, Jonas Lihaug and
Kenneth Næss, tattooed for
money raised for the Norwegian
Children’s Cancer Association.
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Komplett ASA is a public limited liability
company organised pursuant to the
Norwegian Public Limited Companies Act.
The company was listed on the Oslo Stock
Exchange on 21 June 2021 under the ticker
code KOMPL.
Komplett has one class of shares, and in accordance with the
Norwegian Public Limited Companies Act, all shares have
equal rights and are freely transferable. The total number
of shares issued at 31 December 2025 were 175341161. The
nominal value per share is NOK 0.40.
TRADING IN THE KOMPLETT SHARE
The average daily volume of Komplett shares traded on the
Oslo Stock Exchange in 2025 was 0.06 million, equivalent to
0.03 per cent of the total number of Komplett shares issued
at year-end. The share closed at NOK 3.50 on 31 December
2025. The highest closing price was NOK 14.90, and the
lowest closing price was NOK 8.10. Komplett’s market
capitalisation was NOK 2.4 billion at 31 December 2025.
OUR DIVIDEND POLICY
The group has a policy of distributing 60-80 per cent of net
profit as annual dividend adjusted for one-offs and special
items, but expects no dividend to be paid for the financial
year 2025.
AUTHORISATION TO ACQUIRE TREASURY SHARES
At the annual general meeting in 2025, the board of directors
was granted an authorisation, on behalf of the company, to
acquire Komplett shares with a total nominal value equal to
10 per cent of the company’s share capital at the time the
authorisation was granted.
SHARE INFORMATION
The authorisation is valid until the company’s annual general
meeting in 2026, but no longer than 30 June 2026.
The authorisation was not used in 2025, and the company
owns no treasury shares at year-end 2025.
AUTHORISATION TO INCREASE SHARE CAPITAL
At the annual general meeting in 2025, the board of directors
was granted an authorisation to increase the company’s
share capital by up to NOK 7 000 000, in one or more rounds.
The authorisation may be utilised to issue consideration
shares to strengthen the company’s capital structure for
example in connection with acquisitions of other companies
or businesses.
The authorisation is valid until the company’s annual general
meeting in 2026, but no longer than 30 June 2026.
VOTING RIGHTS
Komplett has one class of share, and each share carries one
vote. Shareholders are entitled to vote for the number of
shares they own. It follows from the Norwegian public limited
liability companies act that only those who are shareholders
five working days before the general meeting (registration
date) have the right to participate and vote at the general
meeting.
SHAREHOLDERS
At 31 December 2025, Komplett had 3 111 shareholders. The
top 20 shareholders own 94.61 per cent of the shares.
SHARE PRICE DEVELOPMENT
NOK
FINANCIAL CALENDAR
First quarter
2026 reporting
Third quarter
2026 reporting
Second quarter
2026 reporting
Annual general
meeting
APRIL 2026
30
OCTOBER 2026
24
JULY 2026
17
MAY 2026
6
9
10
11
12
13
14
KOMPL OSEBX (indexed)
1 January – 31 December 2025
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ANALYST COVERAGE
Firm Contact Email
ABG Sundal Collier Petter Nystrøm petter[email protected]
DNB Carnegie Ole Martin Westgaard ole.martin.[email protected]
Nordea Sigurd Flaa [email protected]
Pareto Securities Phillihp Bjerke phillihp.bjerke@paretosec.com
SEB Håkon Fuglu hakon.fuglu@seb.no
SHAREHOLDER OVERVIEW
The 20 largest shareholders at 31 December 2025 Holding Stake
1 Canica Invest AS 74 376 317 42.42%
2 SIBA Invest AB 55 581 404 31.70%
3 Sole Active AS 6 165 112 3.52%
4 The Bank of New York Mellon SA/NV 6 116 715 3.49%
5 Verdipapirfondet Alfred Berg Gamba 5 478 731 3.12%
6 The Northern Trust Comp, London Br 4 232 010 2.41%
7 Verdipapirfondet Holberg Norge 4 226 644 2.41%
8 Verdipapirfondet Storebrand Norge 2 349 136 1.34%
9 Skandinaviska Enskilda Banken AB 2 306 840 1.32%
10 Wenaasgruppen AS 877 943 0.50%
11 Verdipapirfondet Storebrand Norge 581 918 0.33%
12 Emis AS 550 000 0.31%
13 Euroclear Bank S.A./N.V. 505 778 0.29%
14 Verdipapirfondet Storebrand Norge 491 321 0.28%
15 Cigalep AS 391 777 0.22%
16 LT invest AS 378 646 0.22%
17 Storebrand Livsforsikring as 353 972 0.20%
18 Nordnet Livsforsikring AS 319 435 0.18%
19 Nordea Bank Abp 308 500 0.18%
20 Verdipapirfondet Storebrand Aksje 295 845 0.17%
Total top 20 165 888 044 94.61%
Other 9 453 117 5.39%
Total number of shares 175 341 161 100.00%
175341161
SHARES
as at 31 December 2025
3 111
SHAREHOLDERS
as at 31 December 2025
NOK 2.4 BILLION IN MARKET CAP
as at 31 December 2025
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In 2025, Komplett Group delivered
consistent profitability improvements,
supported by better margins and proactive
cost control, while maintaining a stable
financial position with solid liquidity.
Significant steps have been taken to
strengthen the group’s operational platform
and organisational capabilities, and
despite intense competition, the group
has maintained high levels of customer
satisfaction and a solid market position
across its brands.
The year was characterised by gradually improving market
dynamics, supported by new product launches, particularly
within gaming-related categories. Operations in Norway
had good momentum, supported by steady demand for
Komplett’s inhouse manufactured PCs. Developments in
the Swedish operations remained challenging, and across
both the Norwegian and Swedish markets, sales have been
impacted by efforts to prioritise margin quality, especially in
the NetOnNet footprint.
In line with its strategic priorities, Komplett Group has
strengthened its commercial platform through improved
supplier terms and expansion within gaming, private label
and domestic appliances. Gross margin levels improved
versus 2024, reflecting a more rebalanced campaign and
price policy, especially in the telecom segment, as well as
positive product mix effects from strategic and commercial
measures.
Actions to optimise operations and accelerate profitability
have been reinforced during the year. Implemented
initiatives include the consolidation of logistics and back-
office functions in Sweden, as well as groupwide cost
IMPROVED PROFITABILITY AND STRATEGIC PROGRESS
Operations
measures, involving workforce reductions. The impact
from these actions mitigated the effects of general cost
inflation and growth investments and resulted in a stable and
controlled underlying cost base.
Improved credit and payment conditions have led to a
structurally improved liquidity reserve, and a stable financial
position. In the fourth quarter, non-cash impairment charges
were recognised to reduce balance sheet risk. These
impairments do not alter the view of the outlook or potential
of the businesses.
The group remains dedicated to the commercial initiatives
and measures to ensure cost degression and expects an
increasing positive impact into 2026, while making sure
Komplett Group remains the preferred partner to customers
and suppliers.
OPERATIONS
BUSINESS OVERVIEW
The board of directors’ statement covers Komplett ASA
(“the parent company” or “the company”) and its Norwegian
subsidiaries collectively referred to as Komplett Group (“the
group”).
The group is headquartered in Sandefjord, Norway, and has
offices at Lysaker, Norway, and in Borås, Stockholm and
Gothenburg, Sweden. NetOnNet also has a purchasing office
in Dongguan, China.
At the end of 2025, the group had a total of 1 459 employees
(headcount).
Business segments
Through the brands NetOnNet, Komplett, Webhallen,
Ironstone and Itegra, the group serves customers within the
B2C, B2B and Distribution segments.
Geographically, all the group’s brands are represented in
Sweden. In Norway, the group is present with the brands
Komplett, NetOnNet, Ironstone and Itegra, while in Denmark,
the group operates under the Komplett brand.
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The group’s reporting structure reflects its customer
segments: B2C (Komplett B2C, NetOnNet, and Webhallen),
B2B (Komplett B2B, Ironstone) and Distribution (Itegra).
The group offers a broad range of products and services
for consumers, the business market, and the public sector.
These offerings span across various categories such as
components, gaming, brown goods, peripherals, white
goods & home, handheld & accessories, and PCs.
STRATEGY AND MARKET POSITION
STRATEGY
Komplett Group has defined a clear strategic direction to
support its long-term growth ambition. The strategy is based
on leveraging the strengths of the group’s operating model,
which is built on independent, differentiated brands with
websites, shops and product offerings tailored to specific
customer segments and needs.
The group is combining brand autonomy with selected
shared functions and capabilities that provide scale
benefits, including a central commercial team, a shared
supply chain network and unified tech, analytics and data
platform.
An overview of Komplett Group’s strategic and financial
framework can be found on page 14 of this report.
MARKET POSITION
The group operates in a global competitive market and is the
leading online-first player in the e-commerce segment for
electronics and IT-products in the Nordic region.
The business is attractively positioned in the large and
structurally growing Nordic electronics and IT-products
market and benefits from the growth impact of continued
online migration.
The aggregated market share in the Nordic area is estimated
to be around 10 per cent.
The group holds varying market shares across segments
and markets, with a particularly strong position in the B2C
segment.
ORGANISATION
Komplett Group is organised into three business segments:
B2B, B2C and Distribution, and operates an online-first
model combined with selected omnichannel concepts.
In B2C, the group focuses on private consumers across
Norway, Sweden and Denmark through its NetOnNet,
Komplett and Webhallen brands. As at 31 December 2025,
NetOnNet had 34 self-service warehouse stores in Norway
and Sweden, and online stores in both countries. NetOnNet
also has one local purchasing office in China. Komplett is a
pure online brand operating across all three markets, while
Webhallen operates in Sweden through its online store and
13 retail stores at year-end 2025, of which one temporary
outlet was closed in early 2026.
In B2B, the group focuses on corporate customers through
Komplett Bedrift in Norway, Komplett Företag in Sweden,
and Ironstone, which provides cloud-based IT services and
solutions.
The Distribution segment operates under the Itegra brand
and specialises in large-scale distribution contracts for
resellers and major entities in Norway and Sweden.
RESEARCH AND DEVELOPMENT
The group does not perform research and development
activities other than development activities connected to
technical solutions and functionality on the group’s web
stores.
FINANCIAL REVIEW
The following financial review is based on the consolidated
financial statements of Komplett ASA and its subsidiaries.
The statements have been prepared in accordance with
International Financial Reporting Standards (IFRS) as
adopted by the EU, as well as the Norwegian accounting
legislation.
Statement of profit and loss
Total operating revenue was NOK 15 775 million in 2025,
corresponding to an increase of 3.1 per cent compared with
NOK 15 301 million in 2024. The increase was mainly driven
by improving market conditions, also supported by positive
innovation cycles. Top line performance was negatively
impacted by efforts to balance margins and campaigns,
especially in Sweden.
KOMPLETT GROUP KEY FIGURES
NOK million 2025 2024
Operating revenues 15 775 15 301
Cost of goods sold (13 518) (13 211)
Gross margin 14.3% 13.7%
Employee benefit expenses (1 094) (1 013)
Other operating expenses (772) (760)
Depreciation and amortisation (408) (384)
Non-cash impairment charges (538) -
Operating profit (EBIT) (556) (67)
Net financial items (169) (169)
Tax expenses 65 44
Loss for the period (660) (192)
Cost of goods sold was NOK 13 518 million in the full year,
compared with NOK 13 211 million in 2024, reflecting
moderate sales growth. The group’s central commercial
team continues to work on improved commercial terms
as part of the centralisation and consolidation of group
sourcing and category management.
The gross margin improved from 13.7 per cent in 2024
to 14.3 per cent in 2025. The improvement was driven by
more rebalanced price and campaign policies, especially
in Sweden, and also reflects a more normalised pricing
environment.
Employee benefit expenses were NOK 1 094 million in
2025, compared to NOK 1 013 million in 2024. The increase
was mainly driven by severance and restructuring costs
associated with cost reduction measures as well as general
inflation that could not be mitigated through cost measures.
Other operating expenses totalled NOK 772 million in 2025,
compared with NOK 760 million in 2024. The increase was
driven by general cost inflation, partly mitigated by cost
measures.
Depreciation and amortisation totalled NOK 408 million in
2025, of which NOK 54 million was related to amortisation of
acquired customer value. This compares to NOK 384 million
in 2024. The year-over-year increase was mainly related to
right of use assets and software.
Non-cash impairment charges of NOK 538 million were
recognised in 2025, of which NOK 534 million were related
to goodwill attributed to the Swedish entities NetOnNet and
Webhallen. The impairments are made in light of the delayed
recovery in of the Swedish operations, and do not alter the
underlying potential of the business. As a consequence, the
inherent balance sheet risk has been significantly reduced.
The impairments were made in accordance with IFRS.
Please refer to note 11 for further details.
The operating result (EBIT) for 2025 amounted to a negative
NOK 556 million, including non-cash impairments, compared
with negative NOK 67 million in 2024.
Net financial items for the full year totalled NOK 169
million, on par with NOK 169 million in 2024. Interest on the
group’s credit facilities and factoring costs were the main
components of the financial expenses.
Tax income for the full year amounted to NOK 65 million,
compared with NOK 44 million in 2024. The increase reflects
the utilisation of a previously unrecognised tax loss carried
forward.
Loss for the period, including non-cash impairments, was
NOK 660 million, compared to a loss of NOK 192 million in
2024.
Statement of cash flows
Cash flow from operating activities amounted to NOK 757
million, compared to NOK 1 078 million in 2024. The cash
flow from operations was positively impacted by an increase
in trade payables of NOK 588 million, partly offset by an
increase in inventories of NOK 249 million and an increase in
accounts receivables of NOK 23 million.
Cash flow used in investing activities in 2025 was mainly
related to property, plant and equipment for new stores
and IT infrastructure, of which the majority was used for
upgrades to the IT systems. In 2025, cash flow used in
investing activities totalled NOK 129 million, compared to
NOK 163 million in 2024.
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Cash flow used in financing activities amounted to NOK
540 million in 2025, compared to NOK 419 million in 2024.
Financing activities mainly consisted of principal and
interest paid on lease liabilities and net interest paid on
loans, as well as NOK 154 million in repayment in accordance
with the Swedish tax deferred payment rules.
Statement of financial position and liquidity
Non-current assets amounted to NOK 3 430 million at the
end of the full year of 2025, compared with NOK 3 872 million
at the end of last year. The year-over-year decrease was
impacted by goodwill impairments of NOK 538 million, partly
offset by currency translation effects.
Current assets amounted to NOK 4 228 million at the end
of the year, compared with NOK 3 663 million in the same
period last year. Inventories represented NOK 2 297 million
at year-end, compared with 2 048 million one year earlier. A
total of NOK 1 411 million of receivables have been sold under
the factoring agreement, compared with NOK 1 573 million in
2024.
Cash and cash equivalents totalled NOK 814 million at the
end of the full year 2025, reflecting the temporary phasing
effects at year-end, compared to NOK 726 million at year-
end 2024.
Equity amounted to NOK 2 063 million at the end of the full
year 2025, compared with NOK 2 581 million in the same
period last year. The difference is mainly attributed to the
impact from changes in other equity stemming from the
impairment charges.
The equity ratio was 26.9 per cent at the end of the year
compared with 34.3 per cent at the end of 2024.
Total liabilities amounted to NOK 5 596 million at the end of
the full year 2025, compared with NOK 4 954 million in the
same period last year. Trade payables totalled NOK 2 661
million, representing an increase of NOK 588 million from the
prior-year period. Renegotiated supplier agreements and
improved payment terms contributed to a structural uplift
versus last year. As in the prior year, the increase in trade
payables was further driven by the phasing of black week,
which temporarily shifted supplier payments from the peak
months into 2026.
Since 2023, the Swedish subsidiaries have partly utilised the
extension of the Swedish tax deferred payment rules. The
total outstanding amount at 31 December 2025 was NOK 279
million, of which NOK 120 million is included in the group’s
long-term liabilities. The remaining NOK 160 million, which
matures in less than 12 months, is shown as part of other
current liabilities.
Total equity and liabilities amounted to NOK 7 659 million
at the end of the full year 2025, compared with NOK 7 535
million in the same period last year.
Financing and capital structure
The group’s total credit facilities include a revolving credit
facility in the amount of NOK 1 300 million and an overdraft
facility in the amount of NOK 400 million. In accordance
with its financing partners, the group has assessed that
the practice of increasing the overdraft facility to NOK 500
million in the fourth quarter will no longer be needed.
At 31 December 2025, NOK 800 million of the revolving credit
facility was utilised. Including available cash of NOK 814
million, the liquidity reserve was NOK 1 714 million at the end
of 2025, compared with NOK 1 726 million one year earlier.
Net interest-bearing debt at 31 December 2025 was NOK
106 million, excluding IFRS 16 liabilities, and NOK 604 million
including IFRS 16 liabilities, representing a reduction from
last year’s levels of NOK 231 million and NOK 251 million,
respectively. The reduction in long-term debt is attributed to
instalments paid on the Swedish tax deferral scheme, where
the outstanding long-term debt was NOK 120 million at the
end of December, compared with NOK 263 million one year
earlier. For further details, reference is made to the group’s
alternative performance measures in the appendix to this
report.
The leverage ratio, defined as NIBD / LTM EBITDA (adjusted
for certain exceptional items), was 1.4x at the close of the
fourth quarter of 2025. The net debt level was positively
affected by the temporarily high liquidity position at year-
end, which is expected to seasonally adjust during Q1.
These shifts have been catered for in the group’s underlying
covenant trajectory, which is 3.0x for ordinary quarters and
3.5x for Q1.
FINANCIAL REVIEW BY SEGMENT
B2C
The B2C segment represented 72.5 per cent of group
revenues in 2025.
B2C KEY FIGURES
NOK million 2025 2024
Operating revenues 11 435 10 877
Gross profit 1 826 1 678
Gross margin 16.0 % 15.4 %
Opex (ex dep) (1 657) (1 571)
Depreciation and amortisation (108) (103)
Total opex (1 765) (1 673)
Opex share (15.44%) (15.40%)
Operating profit (EBIT) 62 4
Operating margin (EBIT) 0.5% 0.0%
In 2025, B2C had operating revenues of NOK 11 435 million,
representing a 5.1 per cent increase from 2024. The increase
was mainly driven by improved market momentum, including
positive impacts from new product launches, partly offset by
margin protection measures and repositioning, primarily in
Sweden. In addition, currency effects had a positive impact.
In local currency, the operations in Norway had a revenue
increase of 12.3 per cent, while revenue declined by
1.6 per cent in Sweden. In Denmark, which represents
approximately 2.4 per cent of the B2C sales volume, revenue
declined by 9.3 per cent.
Gross profit was NOK 1 826 million, an increase from NOK
1 678 million in 2024. The gross margin increased to 16.0
per cent in 2025, compared with 15.4 per cent in 2024. The
progress reflects a more rebalanced campaign and price
policy, positive product mix effects and a more normalised
pricing environment.
Total operating expenses were NOK 1 765 million in 2025,
representing an increase of 5.4 per cent compared with
NOK 1 674 million in 2024. The increase was mainly due
to currency effects as well as growth investments and
temporarily higher costs associated with the consolidation
functions and other efficiency measures in Sweden, partly
offset by implemented cost and restructuring initiatives.
Operating profit (EBIT) was NOK 62 million in 2025,
compared with NOK 4 million in 2024. The EBIT margin was
0.5 per cent in 2025, compared to 0.0 per cent in 2024.
B2B
The B2B segment accounted for 9.8 per cent of group
revenues in 2025.
B2B KEY FIGURES
NOK million 2025 2024
Operating revenues 1 542 1 519
Gross profit 273 260
Gross margin 17.7% 17.1%
Opex (ex dep) (164) (172)
Depreciation and amortisation (16) (14)
Total opex (181) (186)
Opex share (11.7%) (12.2%)
Operating profit (EBIT) 93 74
Operating margin (EBIT) 6.0% 4.9%
The B2B segment had operating revenues of NOK 1 542
million in 2025, up 1.5 per cent from NOK 1 519 million in 2024.
Demand driven by an ageing installed base, combined with
good traction for the loyalty programme and a reinforced
sales team targeting the larger SME segment contributed to
the sales growth.
In local currency, the operation in Norway had a revenue
increase of 1.1 per cent, compared to 2024. In Sweden the
revenue growth was 0.8 per cent.
Gross profit amounted to NOK 273 million in 2025, and gross
margin was 17.7 per cent, up 0.6 percentage points from
2024, driven by an improved product mix and positive results
from price and campaign management.
Total operating expenses were NOK 181 million in 2025,
compared with NOK 186 million in 2024. The decrease
reflects the effects of implemented restructuring and
efficiency measures.
Operating profit (EBIT) was NOK 93 million in 2025, up from
NOK 74 million in 2024. This gave an EBIT margin of 6.0 per
cent in 2025 compared to 4.9 per cent in 2024.
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Distribution
The Distribution segment accounted for 17.7 per cent of
group revenues in 2025.
DISTRIBUTION KEY FIGURES
NOK million 2025 2024
Operating revenues 2 798 2 907
Gross profit 158 154
Gross margin 5.6 % 5.3 %
Opex (ex dep) (10) (118)
Depreciation and amortisation (14) (10)
Total opex (122) (128)
Opex share (4.4%) (4.4%)
Operating profit (EBIT) 35 26
Operating margin (EBIT) 1.3% 0.9%
Distribution had operating revenues of NOK 2 798 million in
2025, compared to NOK 2 907 million in 2024, representing
a decrease of 3.8 per cent. The year-over-year decline was
mainly attributable to weaker markets for resellers in the
SME segment and reduced large account sales, indirectly
related to their end-customers in the public sector.
In local currency, the operation in Norway had a decrease in
revenue of 5.2 per cent. In Sweden the revenue increased by
13.7 per cent.
Gross profit amounted to NOK 158 million in 2025, and gross
margin was 5.6 per cent, up 0.3 percentage points from
2024. Gross margin improved due to better product and
customer mix, along with ongoing operational efficiency.
Total operating expenses were NOK 122 million in 2025,
compared with NOK 128 million in 2024. The decrease was
mainly due to efficiency measures offsetting cost inflation.
Distribution recorded operating profit (EBIT) of NOK 35
million in 2025, up from NOK 26 million in 2024. This gave an
EBIT margin of 1.3 per cent in 2025 compared with 0.9 per
cent in 2024.
Other / IFRS
“Other / IFRS” represents group costs not allocated to
the operating segments: B2C, B2B, and Distribution. This
applies when costs are difficult to allocate fairly between the
segments.
Typical cost elements under this segment include
management costs and group strategic initiatives as well
as the different effects of IFRS (International Financial
Reporting Standards), especially IFRS 16, as the operating
segments are reported excluding IFRS effects. For
additional explanation, please refer to note 5 to the financial
statements.
INTANGIBLE RESOURCES
The group is dependent on intangible resources such as
consumer satisfaction, reputation and brand strength in
order to maintain its market position.
Furthermore, its operations depend on a well-functioning IT
infrastructure in order to fulfil customer expectations with
regards to service and delivery, and to ensure an efficient
business model in line with the group’s commitment to
maintaining its industry-leading cost position.
DIRECTORS’ AND OFFICERS’ INSURANCE
Komplett ASA has a board liability insurance for the group,
including the parent company and its subsidiaries. The
insurance covers the board members, CEO and members of
the management team. The insurance comprises personal
legal liabilities, including defence and legal costs.
GOING CONCERN
In accordance with section 2-2 (8) of the Norwegian
Accounting Act, it is confirmed that the going concern
assumptions continue to apply. The board of directors firmly
believes that Komplett Group has the ability to continue its
operations in the foreseeable future and hence confirms that
the accounts have been prepared on a going concern basis
and that this assumption is appropriate at the date of the
accounts, and that the group, after the proposed dividend,
has sufficient equity and liquidity to fulfil its obligations.
PARENT COMPANY RESULTS AND ALLOCATION OF NET
PROFIT
The parent company Komplett ASA had limited commercial
operations in 2025 but continued during the year to
build up certain central functions, including groupwide
responsibilities for supply chain and IT.
Komplett ASA recorded a loss before taxes of NOK 688
million in 2025, compared to a loss before taxes of NOK 115
million in 2024. The loss included group contributions from
subsidiaries of NOK 15 million in 2025, compared with NOK
84 million in 2024.
The company’s loss after taxes in 2025 was NOK 646 million
compared with a net loss of NOK 90 million in 2024. The
board proposes the following allocation of the net loss of
NOK 646 million for the parent company:
Transferred from other equity: NOK 646 million.
The board proposes that no dividend is to be paid for 2025.
GOVERNANCE
In accordance with section 2-2 (6) of the Norwegian
Accounting Act, a summary of the group’s key financial risks
is included in the Governance section on page 33 of this
directors’ report, and in note 4 to the financial statements.
Further, Komplett ASA is subject to corporate governance
reporting requirements under section 2-9 of the Norwegian
Accounting Act and the Norwegian Code of Practice for
Corporate Governance, cf. section 4-4 on the continuing
obligations of publicly listed companies. The annual
statement on corporate governance for 2025 has been
approved by the board of directors and can be found on
page28 of this directors’ report. The statement on corporate
governance also includes details on shares, equal treatment
of shareholders, and potential takeovers, pursuant to
section 2-2 (13) of the Norwegian Accounting Act.
SUSTAINABILITY
Information about working environment is included in
the Sustainability section (CSRD) of this directors’ report.
Further, the Sustainability statement contains climate and
environment reporting pursuant to section 2-3 and 2-4 of
the Norwegian Accounting Act.
Activities on gender equality and non-discrimination
Komplett is required to provide an annual equality
statement describing the company’s efforts to secure equal
opportunities under section 26-a in the Norwegian Equality
and Anti-Discrimination Act. The annual statement on
equality is available on www.komplettgroup.com.
EVENTS AFTER 31 DECEMBER 2025
Webhallen’s store in Fruängen, Stockholm closed in January
when its lease agreement ended. This closure did not result
in any material restructuring costs.
In February 2026, Kristian Torgersen joined Komplett Group
as chief technology officer, and Karl Eckerdal was appointed
managing director at NetOnNet. Nikoline Grøterud took up
the position as chief human resources officer in March 2026.
Vebjørn Torsetnes was appointed CEO of Komplett ASA
effective from 16 March 2026, succeeding Ros-Marie Grusén.
OUTLOOK
In 2025, Komplett Group has made good progress along
its strategic and operational priorities. Market conditions
improved throughout the year, and new product launches
contributed to demand growth in 2025, especially in the
gaming related categories.
Looking ahead to 2026, consumer sentiment and
replacement cycles are expected to support underlying
demand, although visibility varies across categories. The
impact from new product launches is expected to moderate
and constraints in the supply of memory chips may affect
demand patterns and pricing dynamics.
Going forward, the group will continue improving its
customer offering in selected categories, such as gaming,
private label and domestic appliances, while driving
commercial and supply chain excellence and operational
efficiency. Measures to maintain an industry-leading cost
position will be reinforced as required, with the aim of
ensuring a continued stable and controlled cost base.
The group remains dedicated to the commercial initiatives
and measures to ensure cost degression and expects an
increasing positive impact into 2026, while making sure
Komplett Group remains the preferred partner to customers
and suppliers.
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GROUP MANAGEMENT
VEBJØRN TORSETNES
CHIEF EXECUTIVE OFFICER (B 1974)
Joined Komplett Group in: 2026
Professional experience: Extensive retail
experience, most recently as managing
director of Jernia. Former CEO of Pascal and
Kremmerhuset, with additional leadership
background from Tilbords and Norli.
Education: Bachelor’s degree from BI
Norwegian Business School.
Number of Komplett ASA shares and options:
0 shares and 0 options.
THOMAS RØKKE
CHIEF FINANCIAL OFFICER (B 1968)
Joined Komplett Group in: 2023
Professional experience: Former CFO at
Saferoad Holding, Løgismose Meyers and
Kwintet Group. He further holds broad
international experience in operational
management positions and strategy consulting.
Education: Master’s degree in business
administration (lic. oec. HSG) and PhD (dr.
oec. HSG) in finance and accounting from the
University of St. Gallen, Switzerland.
Number of Komplett ASA shares and options:
0 shares and 1276608 options.
TRYGVE HILLESLAND
COMMERCIAL DIRECTOR (B 1980)
Joined Komplett Group in: 2023
Professional experience: Former managing
director Webhallen until 2025. More than 20
years’ experience from the electronics retail
industry. Former managing director of Elkjøp
Norway and Gigantti.
Education: System administrator from IT
Academy.
Number of Komplett ASA shares and options:
45 000 shares and 397 155 options.
KARL ECKERDAL
MANAGING DIRECTOR NETONNET (B. 1982)
Joined Komplett Group in: 2026
Professional experience: Former director
pharmacy operations & tender at Norsk
Medisinaldepot and general manager
Scandinavia at AniCura (Mars Inc.). Previous
executive roles at LloydsApotek and Apotek1.
Education: Master’s degree in business
administration from Lund University, with
specialisation in strategy and marketing.
Number of Komplett ASA shares and options:
12 425 shares and 0 options.
MORTEN JOHNSEN
MANAGING DIRECTOR KOMPLETT (B 1973)
Joined Komplett Group in: 2024
Professional experience: Former CFO of
Komplett Services and CFO at PetXL Group.
Prior experience from 14 years at Elkjøp Nordic,
most recently as commercial director.
Education: Master’s degree in corporate
governance and risk management from BI
Norwegian Business School.
Number of Komplett ASA shares and options:
0 shares and 189 677 options.
Governance
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KIM ANDERSSON
MANAGING DIRECTOR WEBHALLEN (B 1986)
Joined Komplett Group in: 2024
Professional experience: 17 years’ experience
from the electronics retail industry. Former
retail director in Webhallen, sales manager in
POWER and MediaMarkt Sweden.
Education: Degree in economics and statistics.
Number of Komplett ASA shares and options:
0 shares and 39 211 options.
MARKUS SOLVIK
CHIEF STRATEGY OFFICER (B 1986)
Joined Komplett Group in: 2022
Professional experience: Former CFO and
CSO at Løvenskiold Handel, and several years
as management consultant within retail and
consumer goods at Boston Consulting Group.
Education: Master’s degree in economics and
business administration from the Norwegian
School of Economics and Cornell University,
with a specialisation in financial economics.
Number of Komplett ASA shares and options:
0 shares and 631 688 options.
KRISTIAN KJERNSMO
CHIEF OPERATING OFFICER (B 1981)
Joined Komplett Group in: 2025
Professional experience: Former senior
director of supply planning & distribution in
Circle K Europe. Experience within supply chain
and operations from companies such as Orkla,
Circle K, Kearney, and Elkjøp Nordic.
Education: Master’s degree (Dipl.- Kfm.) from
Universität Mannheim in combination with
Università Bocconi.
Number of Komplett ASA shares and options:
0 shares and 150 465 options.
KRISTIAN TORGERSEN
CHIEF TECHNOLOGY OFFICER (B 1984)
Joined Komplett Group in: 2026
Professional experience: Former principal
consultant at Curamando and founding partner
at Eidra. Digital native with broad managerial
experience combining marketing, technology,
and change management to drive digital
transformation and growth.
Education: ARC leadership academy, Eniro
Business School
Number of Komplett ASA shares and options:
0 shares and 0 options.
NIKOLINE GRØTERUD JARMANN
CHIEF HUMAN RESOURCES OFFICER (B 1987)
Joined Komplett Group in: 2026
Professional experience: Former head of
people operations in Møller Mobility Group
with group-wide responsibilities of central
HR processes, employment law, compliance
and HRIS. Also served as HR manager at Texas
Instruments, responsible for England, Ireland
and the Nordics.
Education: Master’s degree in leadership and
organisational psychology from BI Norwegian
Business School.
Number of Komplett ASA shares and options:
0 shares and 0 options.
GROUP MANAGEMENT
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BOARD OF DIRECTORS
JAAN IVAR SEMLITSCH
CHAIR OF THE BOARD, NON-INDEPENDENT (B 1971)
Professional experience: CEO of Apotek1 Gruppen. Former
CEO of Komplett Group, Orkla and Elkjøp Nordic, and
previous associate partnerat McKinsey & Company.
Other assignments: Chair of the board at Norli.
Education:Master’s degree in business economics from the
Norwegian School of Economics.
Number of Komplett ASA shares: 180 000 shares.
FABIAN BENGTSSON
DIRECTOR, NON-INDEPENDENT (B 1972)
Professional experience: CEO of SIBA Fastigheter. Former
CEO of SIBA and several positions and directorships within
the SIBA Invest Group. Former chair and director of the
board at NetOnNet. Former chair of the Swedish Federation
of Business Owners. Former director of Axfood, Svensk
Fastighetsförmedling, Ordna Bolån, Tipser, Strawbees and
Irootfor.
Other assignments: Chair of SIBA Invest.
Education: Bachelor’s degree in business economics from
Lund University.
Number of Komplett ASA shares: 55 581 404 shares through
his ownership of approximately one third of the votes and
shares in SIBA Invest.
SUSANNE EHNBÅGE
DIRECTOR, INDEPENDENT (B 1979)
Professional experience: CEO of Lindex Group and Lindex.
Former CEO of SIBA and NetOnNet Group, and board member
at Resurs Bank, HiQ International and Mio.
Other assignments: Board member of Ahlsell Group and Clas
Ohlson.
Education: Master’s degree in industrial and financial
economics from the School of Economics and Commercial
Law, University of Gothenburg, and board education from
Ahrens.
Number of Komplett ASA shares: 0 shares.
INGVILD NÆSS
DIRECTOR, INDEPENDENT (B 1979)
Professional experience: Group COO at Kahoot! Group.
Former CEO of E-Tech and CIO at Schibsted, where she also
served as chief privacy & data trends officer. Previously a
business lawyer at Thommessen.
Other assignments: Chair of the board FeltGiS, board
member of CEMIT, Clever Inc. and Polyteknisk Forening.
Education: Cand. jur. from the University of Oslo. Executive
courses at Harvard Business School and Stanford Graduate
School of Business.
Number of Komplett ASA shares: 0 shares.
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JAN OLE STANGELAND
DIRECTOR, NON-INDEPENDENT (B 1967)
Professional experience: CEO at Canica, and holds several
board positions, including Canica group companies. Former
CFO at Canica.
Other assignments: Several board assignments.
Education: Business administration from BI Norwegian
Business School.
Number of Komplett ASA shares: 76 296 shares through
Stangeland Invest AS (owned 50/50 with related parties).
ANDERS ODDEN
WORKER DIRECTOR, EMPLOYEE (B 1978)
Professional experience: Former sales manager and key
account manager across several companies within the
electronics industry.
Other assignments: Sales director for Komplett Services.
Education: Bachelor’s degree from the BI Norwegian
Business School.
Number of Komplett ASA shares: 0 shares and 11 411 options
in Komplett ASA.
EMELIE VICTORIN
WORKER DIRECTOR, EMPLOYEE (B 1983)
Professional experience: Previous experience from project
management, management consulting, accounting and
digitalisation from Gislaved municipality, PWC and EY.
Other assignments: Product owner at NetOnNet.
Education: Master’s degree in business economics, with a
specialisation in accounting and risk management, from the
School of Economics, University of Gothenburg.
Number of Komplett ASA shares: 0 shares.
INGRID HAUGEN FOUGNER
OBSERVER (B 1992)
Professional experience: Director at Canica, and holds
several board positions, including Canica group companies.
Previous experience as relationship manager and senior
credit analyst within the banking sector.
Other assignments: Several board assignments, including
board member of Selvaag By, Classic Norway Hotels and F&H
Group.
Education: Master’s degree in international business from
Hult International Business School.
Number of Komplett ASA shares: 0 shares.
BOARD OF DIRECTORS
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Komplett Group considers good corporate
governance to be a prerequisite for trust
from shareholders, value creation and
adequate access to capital.
In order to secure a sound and sustainable corporate
governance, Komplett Group considers it important to
ensure good and healthy business practices, reliable
financial reporting, and an environment of compliance based
on applicable legislation and regulations, across the group
structure.
Komplett Group is required to report on corporate
governance under section 2-9 of the Norwegian Accounting
Act and the Norwegian Code of Practice for Corporate
Governance. The Accounting Act may be found (in
Norwegian) at www. lovdata.no. The Norwegian Code of
Practice for Corporate Governance, which was last revised
on 28 August 2025, may be found at www.nues.no.
This statement of policy will be an item of business at
Komplett ASA’s annual general meeting on 6 May 2026. The
company’s auditor has assessed whether the information
with regard to section 2-9 of the Accounting Act provided in
this statement is consistent with the information provided in
the annual financial statements. The auditor’s statement is
attached to this annual report.
A description of the company’s guidelines for equality
and diversity may be found under “Policies related to own
workforce” in the Sustainability statement of this annual
report.
CORPORATE GOVERNANCE REPORT
Corporate governance at Komplett Group shall be based on
the following main principles:
X Transparency. Communication with the company’s
shareholders, stakeholders and other interest groups
shall be based on transparency and openness on issues
relevant for the evaluation of the development and
position of the company.
X Independence. The relationship between the board of
directors, executive management and shareholders
shall be based on independence principles.
Independence shall ensure that all decisions are made
on an unbiased and neutral basis.
X Equal treatment. A fundamental objective for good
corporate governance is equal treatment and equal
rights for all of the company’s shareholders.
X Control and management. Sound control and
corporate governance mechanisms shall contribute
to predictability and reduce the level of risk for the
company’s shareholders, stakeholders and other
interest groups.
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1. IMPLEMENTATION AND REPORTING ON CORPORATE
GOVERNANCE
The board of directors at Komplett ASA actively adheres to
good corporate governance standards and will at all times
ensure that Komplett Group complies with the requirements
of section 2-9 of the Accounting Act and the Norwegian
Code of Practice for Corporate Governance (the “Code”). This
is done by ensuring that the topic of good governance is an
integral part of the decision-making process in matters dealt
with by the board. Komplett Group’s corporate governance
policy describes how Komplett Group complies with the
Code requirements and may be found at Komplett Group’s
website.
The board of directors has provided this report on the
company’s corporate governance as referenced to in the
directors’ report. The report covers every section of the
Code of Practice, and if the company does not fully comply
with the Code, the company has provided an explanation
of the reason for the deviation and what solution it has
selected.
Deviations from the Code: None.
2. BUSINESS
Komplett Group’s objectives, as clearly defined in its articles
of association, are as follows:
The objective of the company is trade in computer
equipment, electronics, and other goods, and to participate
in other companies and businesses.
The board of directors has defined clear objectives,
strategies and risk profiles for the company’s business
activities such that the company creates value for
shareholders in a sustainable manner. When carrying out
this work, the board of directors has taken into account
financial, social and environmental considerations.
The group’s goals, strategies and risk profiles have been
presented on page 33 of this report.
The board of directors evaluates the group’s goals, strategies
and risk profiles at least yearly.
Deviations from the Code: None.
3. EQUITY AND DIVIDENDS
The board of directors is mindful of maintaining an equity
capital at a level appropriate to the company’s objectives,
strategy, and risk profile, and continuously monitors the
group’s capital situation.
At 31 December 2025, the group’s equity totalled NOK
2063 million, representing an equity ratio of 26.9 per cent,
compared with 34.3 per cent at the end of 2024.
The board of directors has established and disclosed a clear
and predictable dividend policy for the group. Komplett
Group targets stable growing dividends year-on-year, and a
pay-out ratio of 60-80 per cent of net profit adjusted for one-
off costs and special items. In recent years, investments
and a challenging market environment has not permitted
dividend distributions.
Authorisations empowering the board of directors to
increase the company’s share capital or to purchase treasury
shares are limited to defined purposes and are granted
for a period no longer than until the next general meeting.
These authorisations are further described under Share
information on page 17 of this report.
Deviations from the Code: None.
4. EQUAL TREATMENT OF SHAREHOLDERS
Komplett ASA has one class of shares, and all shares carry
the same rights in the company.
If the board of directors proposes to deviate from share-
holders’ pre-emptive rights in connection with capital
increases, the board should specifically set out and justify
the proposal. This applies both when the capital increase
is resolved by the general meeting and when a board
authorisation is used. The justification should be included in
the stock exchange announcement that discloses the capital
increase. The justification should specifically state how the
principle of equal treatment of shareholders is safeguarded.
The company’s transactions in treasury shares shall be
carried out through Euronext Oslo Børs’ trading platform at
the prevailing trading price or by making a public offer to
all shareholders. If the company’s shares suffer from weak
liquidity, the board of directors shall take particular care
even when making purchases and sales through the
stock exchange, in order to ensure equal treatment of
shareholders.
Deviations from the Code: None.
5. SHARES AND NEGOTIABILITY
The shares of the company are freely transferable and there
are no restrictions on any party’s ability to own or vote for
shares in the company. No limitations on transactions have
been laid down in Komplett ASA’s articles of association.
Deviations from the Code: None.
6. GENERAL MEETINGS
Komplett Group seeks to ensure that as many shareholders
as possible can participate and vote in general meetings, and
that the general meeting is an effective meeting place for
shareholders and the board of directors. The annual general
meeting is held every year before the end of May.
Notices of general meetings and related documents are
made available on Komplett Group’s website no later than 21
days prior to the date of the meeting.
Shareholders who wish to participate in the general meeting
must give the company notice no later than two working days
prior to the general meeting.
The company facilitates the election of an independent chair
of the general meeting.
The nomination committee chair, the chair of the board
and other members of the board of directors are present at
general meetings, but normally not the entire board. To date,
no items of business at general meetings have made this
necessary. The CEO and CFO are normally present in order to
reply to any questions that may be raised.
Shareholders are given the opportunity to vote on each
of the proposals to be considered, including voting for
individual candidates to an office in the nomination
committee and on the board of directors.
Shareholders who are unable to attend the general meeting
may also vote in advance or by proxy. The proxy form is
designed in such a way that voting instructions can be given
for each item of business that is to be considered.
Both the notice of the general meeting and Komplett Group’s
website provide further information regarding the use of
proxies and shareholders’ right to submit items of business
for consideration at general meetings.
Under the first paragraph of article 8 in the articles of
association, the board of directors may decide that
documents concerning items of business to be considered
at the general meeting are not to be sent to shareholders
when the documents are made available on the company’s
website. This also applies to documents which by law must
be included in or attached to the notice of the general
meeting. A shareholder may nonetheless ask to be sent
documents pertaining to items of business to be considered
at the general meeting.
Deviations from the Code: The Code advocates that all
board members should participate at the general meeting.
However, if the agenda is such that it is not considered
necessary for every member to attend, not all Komplett ASA
board members will attend every time.
7. NOMINATION COMMITTEE
As laid out by the articles of association, Komplett ASA has a
nomination committee.
The general meeting elects the chair and members of the
committee and determines its remuneration. The general
meeting has also adopted instructions for the nomination
committee, which may be found at Komplett Group’s
website.
The nomination committee consists of three members, who
are elected for a term of up to two years. The majority of
the nomination committee shall be independent from the
company’s board of directors and executive management.
The committee is tasked with submitting the following
reasoned recommendations to the general meeting:
X Recommend candidates for the election to the board of
directors and the nomination committee, and
X Recommend a suitable remuneration for the members
of the board of directors and the nomination committee.
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The nomination committee’s recommendation of candidates
to the board of directors shall ensure that the board of
directors is composed to comply with legal requirements
and principles of corporate governance and that they
represent a broad group of the company’s shareholders.
The rules of procedure for the nomination committee
contain further guidelines for the preparation and
implementation of elections to the nomination committee
and the board of directors, as well as criteria for eligibility,
general requirements regarding recommendations, the
number of members in the committee and their term of
service, and detailed procedural rules for the work of the
nomination committee.
On 8 May 2024, the participants at the general meeting
elected the following members for the nomination
committee:
X Sverre R. Kjær, chair, elected until the annual general
meeting of 2026
X Nina Camilla Hagen, member, elected until the annual
general meeting of 2026
X Martin Bengtsson, member, elected until the annual
general meeting of 2026
Information and deadlines for submitting input and
proposals to the nomination committee are available at
Komplett Group’s website.
Information regarding the composition of the nomination
committee is posted on Komplett Group’s website under
“Investor Relations”.
The composition of the nomination committee is intended
to ensure that the interests of all the shareholders are
served and meets the requirement of the Norwegian Code of
Practice for Corporate Governance as regards independence
of the company’s management and board of directors. None
of the members of the nomination committee is a member
of the board of directors of Komplett Group ASA. Neither the
general manager nor other senior executives are members
of the committee.
Deviations from the Code: None.
8. BOARD OF DIRECTORS: COMPOSITION AND
INDEPENDENCE
The composition of the board is intended to serve the
interests of all the shareholders and to meet the company’s
need for expertise, capacity, and diversity, while ensuring
that the board can function effectively as a collegiate body.
The board’s composition meets the requirements of the
Norwegian Code of Practice for Corporate Governance as
regards board members’ independence of the company’s
executive management, main shareholders and material
business relationships. A majority of the shareholder elected
directors are defined as non-independent of the company’s
executive management and material business relationships.
At least two of the shareholder-elected directors are defined
as non-independent of the company’s main shareholders.
Representatives of the executive management are not
members of the board of directors. There are few instances
in which directors are disqualified from considering board
matters. Under article 5 of the articles of association, the
company’s board of directors shall consist of between 3 and
9 members, to be elected by the general meeting. There are
no other provisions in the articles of association governing
the appointment and replacement of directors.
Jo Olav Lunder was elected as the chair of the board by the
general meeting in May 2025 for a period until 1 August 2025.
Jaan Ivar Semlitsch was elected as the chair of the board by
the general meeting in May 2025 for the period from 1 August
2025 until the annual general meeting in 2027. The members
of the board of directors have been elected for no longer
than two years at a time.
In accordance with Komplett Group’s current system
of corporate democracy, two members of the board of
directors of Komplett ASA are elected from the group
employees.
A description of the expertise and background of the
individual board members, as well as information on
their record of attendance at board meetings and their
independence, can be found on page 26 and page 32 of this
annual report. The directors are encouraged to hold shares
in the company.
Deviations from the Code: None.
9. THE WORK OF THE BOARD OF DIRECTORS
The tasks of the board of directors are laid down in the rules
of procedure for the board of directors, which govern the
board’s responsibilities and duties and the administrative
procedures of the board, including which matters are
subject to board consideration and rules for convening and
holding meetings.
The board’s rules of procedures also contain rules regarding
the general manager’s duty to inform the board about
important matters and to ensure that board decisions
are implemented. There are also provisions intended to
ensure that company employees and other parties involved
are adequately informed of board decisions, and that the
guidelines for preparing matters for board consideration are
followed. Other instructions to the board and clarification
of its duties, authorisations, and responsibilities in respect
of the general management are provided through routine
communication.
The rules of procedure further establish that a director shall
not take part in the consideration of or a decision on an issue
that is of such importance to himself or herself or to any
related party that the member must be considered to have
an obvious personal or financial interest in the matter.
It is incumbent upon each director to consider on an ongoing
basis whether there are matters which, from an objective
point of view, are liable to undermine the general confidence
in that board member’s independence and impartiality, or
which could give rise to conflicts of interest in connection
with the board of directors’ consideration of the matter.
Such matters must be discussed with the board chair. In
cases where the chair of the board is, or has been, personally
involved in a matter of material significance, the board’s
consideration of that matter shall be chaired by another
member of the board to ensure an independent review.
According to the group’s code of conduct, employees
must on their own initiative inform their superior if they
should recuse themselves from dealing with or if they
have a conflict of interest in connection with a matter, and
consequently should not take part in considering the matter.
The board of directors adopts an annual meeting and activity
plan that covers strategic planning, business issues, and
oversight activities.
Transactions between the company and its shareholders,
a shareholder’s parent company, members of the board of
directors, executive management or closely associated
persons to any such party that are deemed material under
the Norwegian Public Limited Liability Companies Act,
are subject to certain procedures and approval by the
participants at the general meeting.
Furthermore, the board of directors is required to arrange
an independent auditor valuation of the transaction. In case
such a material transaction is entered into by a subsidiary
of the company, a separate notice shall be prepared and
published at the company’s website. The company has
adopted a policy for related party transactions.
The board of directors has established two permanent board
committees, which are described in further detail below.
These committees do not make decisions but supervise the
work of the company management on behalf of the board
and prepare matters for board consideration within their
specialised areas.
In this preparatory process, the committees have the
opportunity to draw on company resources, and to seek
advice and recommendations from sources outside the
company. The board has adopted instructions for the board
committees.
The remuneration committee
The remuneration committee members are Fabian
Bengtsson (chair), Jan Ole Stangeland and Susanne
Ehnbåge. The composition meets the requirements of the
Norwegian Code of Practice for Corporate Governance as
regards independence, and all the committee members are
considered to be independent of the executive management.
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The mandate of the committee, which is set out in the
Instructions for the remuneration committee, is as follows:
X Review the remuneration and compensation policy for
the members of the executive management.
X Review the performance of the CEO versus the adopted
objectives and recruitment policies, career planning,
and management development plans.
X Prepare matters relating to other material employment
issues in respect of the executive management.
The committee will also address special compensation
matters for group employees when these are deemed
particularly important to the group’s competitive position,
corporate identity, or ability to attract talent.
The audit committee
The audit committee members are Jan Ole Stangeland
(chair), Fabian Bengtsson and Ingvild Næss. The composition
of the committee meets the requirements of the
Norwegian Public Limited Liability Companies Act and the
Norwegian Code of Practice for Corporate Governance as
regards independence and competence. The nomination
committee’s recommendation of candidates for election to
the board contains information as to which board members
satisfy the requirements as regards independence and
competence to sit on the audit committee. The committee’s
mandate, which is set out in the Instructions for the audit
committee, is as follows:
X Inform the board of the outcome of the company’s
external audit and the assurance of the mandatory
sustainability reporting and explain how the external
audit and assurance contributed to the integrity of
financial and sustainability reporting and what the role
of the audit committee was in that process.
X Prepare the board’s follow-up on the financial and
sustainability reporting process, including the digital
reporting process and the process for identifying
the information reported according to sustainability
reporting standards, and make recommendations or
suggestions to ensure its integrity.
X Monitor the effectiveness of the company’s internal
quality control and risk management system regarding
the company’s financial reporting and sustainability
reporting, without breaching its independence.
X Maintain ongoing contact with the company’s external
auditors regarding the audit of the annual accounts
and the assurance of the sustainability reporting, in
particular monitoring the audit performance in light of
issues raised by the Financial Supervisory Authority in
accordance with article 26 (6) of the Audit Regulation.
X Review and monitor the independence of the company’s
external auditor pursuant to the Norwegian Auditors
Act, and in particular the appropriateness of the
provision of non-audit services to the company in
accordance with provisions set out therein, and article 5
of the Audit Regulation.
X Assess the auditor’s confirmation of independence and
conduct discussions as indicated in article 6 (2) of the
Audit Regulation.
X Be responsible for the procedure for the selection of
the company’s external auditor and recommend the
external auditor to be appointed.
Without limiting the audit committee’s responsibilities
described above, a more detailed description of the
tasks applicable to the audit committee is included in the
Instruction for the audit committee. Adjustments to the
committee’s mandate will be made on an ongoing basis in
line with new legal requirements.
The board of directors’ evaluation
Each year, the board of directors carries out an evaluation
of its own activities and competence, and discusses
improvements in the organisation and implementation of its
work, both at an individual level and as a group, in relation
to the goals that were set for its work. The results are made
available to the nomination committee.
Deviations from the Code: None.
10. RISK MANAGEMENT AND INTERNAL CONTROL
The board of directors is responsible for ensuring a sound
internal control and systems for risk management that
are appropriate in relation to the extent and nature of the
company’s activities.
The board and the executive management are continuously
monitoring the group’s risk exposure and the group con-
stant ly strives to improve its internal control processes.
An active approach is taken to risk management, where an
annual review of the company’s most important areas of
exposure to risk and its internal control arrangements is
presented and discussed with the board. The risk assess-
ment for 2025 is presented at page 33 of the annual report,
and a description of the use of financial instruments to
reduce financial risk is included in note 4 to the financial
statements.
Deviations from the Code: None.
11. REMUNERATION OF THE BOARD OF DIRECTORS
Remuneration of directors shall be reasonable and reflect
responsibilities, expertise, time invested, and the complexity
of the business.
Remuneration of directors is disclosed in note 7 to the group
consolidated financial statements and in the remuneration
report. The note shows that remuneration of the directors
is not linked to the group’s performance and that no options
have been granted to the shareholder-elected directors.
Save for the board members elected from the employees,
none of the board directors have taken on specific
assignments for the company other than their board
appointment. If they do, it will be disclosed to the full board,
and the board will approve remuneration for such additional
duties.
Deviations from the Code: None.
12. SALARY AND OTHER REMUNERATION FOR EXECUTIVE
PERSONNEL
The board of directors has adopted clear and understandable
guidelines for the remuneration of the executive manage-
ment team. The guidelines have been approved by the
participants at the general meeting.
The arrangements for salary and other remuneration of
executive personnel are designed to promote alignment of
interests between shareholders and executive personnel.
The remuneration arrangements should be simple and
transparent and address the criteria for goal attainment.
Absolute caps have been set for performance-related
remuneration. Performance-related remuneration is
essentially based on measurable criteria that the executive
personnel can influence.
The company’s remuneration principles shall be designed to
ensure responsible and sustainable remuneration decisions
that support the company’s business strategy, long-term
interests, and financial viability. Both the guidelines and the
yearly remuneration report may be found at Komplett Group’s
website.
The board’s remuneration committee presents a
recommendation concerning the terms and conditions
for the CEO to the board of directors and monitors the
general terms and conditions for other senior executives in
the group. The board assesses the CEO and his terms and
conditions once a year. A description of the remuneration of
the executive management and the group’s compensation
and benefits policy, including the scope and design of bonus
and share-price-related programmes, is given in the board
of directors’ statement of guidelines for the remuneration
of executive management approved by the general meeting
and the remuneration report; see note 7 to the group
consolidated financial statements.
Deviations from the Code: None.
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BOARD OF DIRECTORS MEETING ATTENDENCE
Meeting attendance
Name Assignment Director from year Last elected year
Independent of company
and management
Independent of major
shareholders
Remuneration
committee Audit committee Board of directors
Remuneration
committee attendance
Audit committee
attendance
Jaan Ivar Semlitsch Chair
1)
2025 2025 No Yes - - 4/4 - -
Ingvild Næss Director 2023 2025 Yes Yes - Member 12/12 - 8/8
Susanne Ehnbåge Director 2023 2025 Yes Yes Member - 11/12 4/4 -
Jan Ole Stangeland Director 2023 2025 Yes No Member Chair 12/12 4/4 8/8
Fabian Bengtsson Director 2022 2024 Yes No Chair Member 11/12 4/4 8/8
Emilie Victorin Worker director 2024 2025 - - - - 12/12 - -
Anders Odden Worker director 2019 2025 - - - - 12/12 - -
Ingrid Haugen Fougner Observer
2)
2025 2025 Yes No - - 7/7 - -
1)
From 1 August 2025.
2)
From 7 May 2025.
13. INFORMATION AND COMMUNICATIONS
It follows from Komplett Group’s IR policy that the company
discloses financial and other information based on openness
and taking into account the requirement for equal treatment
of all participants in the securities market.
The IR policy also includes guidelines for the company’s
contact with shareholders other than through general
meetings.
Komplett Group seeks to ensure that its accounting and
financial reporting inspires investor confidence. Komplett
Group’s accounting procedures are highly transparent. The
board of directors’ audit committee monitors company
reporting on behalf of the board. Komplett Group strives to
communicate actively and openly with the market.
The company’s annual and quarterly reports contain
extensive information on the various aspects of the
company’s activities. The company’s quarterly presentations
are webcasted live and may be found on Komplett Group’s
website, along with the quarterly and annual reports under
“Investor Relations”. Komplett Group aims to hold a capital
markets day at regular intervals, on which occasion the
market is given an in-depth review of the group’s strategic
direction and operational development.
All shareholders and other financial market players are
treated equally as regards access to financial information.
The group’s investor relations department maintains regular
contact with company shareholders, potential investors,
analysts, and other financial market stakeholders. The board
is regularly informed of this activity. The financial calendar
for 2026 may be found on Komplett Group’s website.
Deviations from the Code: None.
14. TAKEOVERS
The board of directors will not seek to hinder or obstruct
any takeover bid for the company’s operations or shares.
In the event of such a bid as discussed in section 14 of the
Norwegian Code of Practice for Corporate Governance,
the board of directors will, in addition to complying with
relevant legislation and regulations, seek to comply with
the recommendations in the Code of Practice. This includes
obtaining a valuation from an independent expert. On this
basis, the board will make a recommendation as to whether
or not the shareholders should accept the bid.
Deviations from the Code: The group has not found it
appropriate to draw up explicit guiding principles for the
group’s conduct in the event of a takeover bid. However,
the board will refer to the statement in the Code regarding
takeovers and will act accordingly if a take-over bid is made.
15. AUDITOR
The general meeting has elected Ernst & Young AS as the
company’s auditor. The board of directors, or the audit
committee, ensures that the auditor submits the main
features of the plan for the audit of the company to the audit
committee annually.
The external auditor also takes part in the board’s
discussions of the annual financial statements and
sustainability reporting. At the meetings, the CEO should
review any material changes in the company’s accounting
policies, the assessment of material accounting estimates,
and where applicable, material matters related to the
company’s sustainability reporting. The auditor should
comment on the CEO’s review, and account for key matters
of the audit. There have been no disagreements between the
auditor and management on any material matters in 2025.
Every year, the board or the audit committee reviews,
with the auditor, the internal control procedures and
risk management related to financial and sustainability
reporting, including deficiencies identified by the auditor,
and proposals for improvements.
The board of directors ensures that relevant matters may be
discussed with the external auditor without the presence of
the management. The external auditor is also invited to all
meetings of the board’s audit committee.
Komplett Group has established guidelines for the right of
the general management to use the external auditor for
services other than auditing. Responsibility for monitoring
such use in detail has been delegated to the audit
committee. Details of the company’s use and remuneration
of the external auditor are disclosed in note 7 to the group
consolidated financial statements. The participants of the
general meeting are informed about the group’s overall
remuneration to the auditor, broken down in accordance
with statutory requirements into remuneration for statutory
auditing and remuneration for other services. In connection
with the auditor’s participation in the audit committee and
the board of directors’ consideration of the annual financial
statements, the auditor also confirms his independence.
Deviations from the Code: None.
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Komplett Group is exposed to a range of
risks and maintains structured processes for
risk management and internal control.
In accordance with section 2-2 (6) of the Norwegian
Accounting Act, a summary of the group’s key financial risks
is included below and in note 4 to the consolidated financial
statements and note 10 to the Komplett ASA financial
statements.
OBJECTIVES
The group’s internal control and risk management work aims to:
X Develop an overview of key risk factors by identifying
the most important internal and external risks affecting
operations, financial performance, and compliance.
X Prioritise identified risks and assess the effectiveness
of existing controls
X Develop controls and mitigating actions for identified
key risk exposures
X Integrate risk management into an annual cycle and
core management processes
RISK MANAGEMENT PROCESS
The group’s annual risk management process involves the
board of directors, audit committee, group management
and business units. The process focuses on identifying and
mitigating material risk that may affect strategy, operations,
and financial performance.
Group management annually reviews the framework and
policies for risk management, which are then reviewed by
the board and the audit committee. The board, with support
from the audit committee, conducts regular reviews of key
risk areas and internal control routines. Each business unit
reports to group management on the follow-up of key risks
and adherence to internal control routines.
RISK ASSESSMENT PROCESS
For 2025, Komplett Group identified the most material
risk factors through a structured assessment of likelihood
and potential impact. The assessment process involved
representatives from all subsidiaries and group management
and resulted in ten material risk factors. Each of these risks
has the potential of influencing the group’s ability to achieve
its vision and long-term goals.
The ten most material risk factors have been grouped into
four main categories: strategic, operational, financial and
compliance risks.
INTERNAL CONTROL AND RISK MANAGEMENT
RISK ASSESSMENT PROCESS
Group management
Board of directors
Audit committee
Employees
THE FOUR RISK CATEGORIES
STRATEGIC RISKS
Strategic risks include both internal and external
events that pose challenges to Komplett Group’s
strategic goals, market position and competitive
advantages. These risks are primarily associated with
changes in the business environment, stakeholder
dynamics and global developments.
OPERATIONAL RISKS
Operational risks include internal and external events
that may disrupt day-to-day operations, potentially
impacting earnings and financial position. These risks
can generally be influenced and are often linked to
organisational processes, working methods and skills.
FINANCIAL RISK
Financial risks relate to changes in macroeconomic
conditions, supplier and customer credit exposure,
currency fluctuation, and liquidity. The group’s own
creditworthiness may also affect access to financing,
liquidity headroom and supplier credit terms.
COMPLIANCE RISK
Compliance risk involves potential negative impact
from ongoing changes in regulations, laws and other
framework conditions. This category captures the
legal, reputational, and financial penalties for failing to
comply with relevant internal and external regulations.
REPORTING GOVERNANCE
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1. MARKET CONDITIONS AND
COMPETITION
RESPONSIBLE: CCO
Description
Changes in consumer sentiment, competitive environment,
and macroeconomic developments may impact demand and
pricing dynamics. The group operates in the Nordic markets
but competes in a global e-commerce arena, and is exposed
to international trade conditions, currency movements and
geopolitical developments. Increased uncertainty related to
supply conditions, tariffs, and regulatory changes may elevate
market risk.
Mitigation
The group monitors market trends closely and continuously
adapt its product range and services to consumer demand.
The group has established a central commercial team that
continues to refine core assortments, extend the supplier base,
and improve commercial terms. Measures to increase supply
chain efficiency have also been launched. Commercial setup
and cost discipline remain key mitigation tools.
2. DIGITAL DEVELOPMENT
AND ADAPTION
RESPONSIBLE: CEO
Description
Changes in technology and digital innovation, evolving at an
increasing pace (e.g. AI, IoT), could lead to shifts in consumers
behaviour, market conditions, and competitive dynamics. Slow
digital development or delayed adaptation to new business
models may weaken the group’s market position.
Mitigation
The group continues to invest in scalable digital platforms and
in-house competence development. In line with the group’s
strategic priorities, a chief technology officer was recruited in
2025, with responsibility for the group’s technological platform
and digital strategy. Key initiatives include modernising core
systems, improving the online customer journey and marketing
efficiency, as well as driving automation and efficiency
measures in logistics operations. In 2025, master data were
centralised, and the group will continue to develop principles to
support coordinated, digital execution across brands.
3. BRAND STRENGTH AND
CUSTOMER LOYALTY
RESPONSIBLE: CEO
Description
The group’s brand recognition is central to its competitive
position. A lack of sustained focus on long-term brand building
and customer satisfaction may impact competitiveness and
profitability.
Mitigation
The group maintains a strong portfolio of differentiated brands
targeting distinct customer segments. Brand visibility is
strengthened through multi-channel marketing, personalised
services and increased loyalty-programme participation.
Feedback from a consumer survey conducted in October 2025
clearly validated the brand positioning for each of the group’s
brands, demonstrating that they are highly regarded by the
customers and well understood in the market.
In 2026, the group will continue to focus on brand development
through targeted marketing efforts to ensure that the product
range and service offering are aligned with customer needs.
4. COLLABORATION ACROSS
THE ORGANISATION
RESPONSIBLE: CEO
Description
Effective collaboration between business units is a central
element to ensure efficient use of resources, to foster a culture
of shared best practices, and to align with overall long-term
goals.
Mitigation
The group’s business model is built around selected shared
functions, including a central commercial team, a unified
supply chain network, and common tech, analytics, and data
structures. These structures promote cross-unit collaboration
and efficient use of resources.
Collaboration is further encouraged through value-driven
leadership with clear communication policies during change
processes, alignment on business plans, strategies, and
priorities across all business units, and clearly defined goals
for all units and employees. Goal setting and performance
management are supported by the implementation of the OKR
framework (objectives and key results). Employee satisfaction
is monitored through Winningtemp.
STRATEGIC RISKS
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OPERATIONAL RISKS
5. REPUTATIONAL RISK
RESPONSIBLE: CEO
Description
The group’s reputation may be adversely affected by pricing
practices, deficiencies in customer service, delivery issues,
incidents related to products or employees, or weaknesses
in areas such as GDPR or ESG. Reputational damage may
weaken customer trust, reduce loyalty and negatively impact
commercial performance.
Mitigation
The group mitigates reputational risk through defined
governance frameworks, policies, and control activities,
supported by internal and external reporting. Pricing practices
are governed by formal approval processes and documented
guidelines. Customer service quality and performance are
monitored through defined KPIs, with corrective actions
implemented where deviations are identified. Private
label products are subject to structured quality assurance
and supplier oversight. Compliance with GDPR and ESG
requirements is managed through systematic monitoring,
regular updates to procedures, and established internal control
mechanisms.
6. CYBER-ATTACKS
RESPONSIBLE: CFO
Description
Komplett Group’s operations rely on efficient IT and data
systems. The threat of external cyber-attacks, fraud, and IT
security challenges exposes the group to risks such as business
disruption, loss of sensitive data, and reputational damage.
Mitigation
Komplett Group regularly updates its IT platforms to ensure
robust IT security and data protection. Cyber security efforts
are increasingly aligned and coordinated across the business
units, supported by a structured mitigation programme.
In 2025, the group implemented a security governance and
control framework, which includes reviews of local security
measures and the establishment of improved group-wide
standards. In 2026, the group’s management team was
expanded with a chief technology officer. An information
security management system (ISMS) will be established to
manage security risks and further strengthen governance.
7. PEOPLE DEPENDENCY
RESPONSIBLE: CEO
Description
Komplett Group values its skilled workforce and acknowledges
the importance of documenting key processes and fostering
cross-functional competence in order to minimise people
dependency.
This approach ensures the ability to solve critical tasks or
address operational problems when key individuals are
unavailable.
Mitigation
The group mitigates the risk by systematically mapping and
documenting key processes, enhancing training through
relevant support systems and on-site sessions, as well as
conducting regular reviews of resource allocation to optimise
capability utilisation.
A new chief human resources officer was appointed in 2026,
with a mandate to reinforce systematic practices and unified
methodologies coupled with local adjustments. This will
further ensure clear structures for efficient execution and
organisational development.
8. GLOBAL SUPPLY DISRUPTIONS
RESPONSIBLE: CCO
Description
Global supply disruptions, such as those caused by sanctions,
pandemic, regional conflicts, and raw material shortages,
can affect the availability of components and commodities,
potentially impacting the group’s ability to deliver goods to
its customers. In addition, constraints in the supply of key
components, including memory chips, represent a source of
uncertainty that may affect availability, pricing and volumes
across several consumer electronics categories.
Mitigation
The group proactively monitors its supply chain and employs a
diversified sourcing strategy. The group’s central commercial
team ensures a coordinated and systematic dialogue with
multiple suppliers and inventory planning adjustments. This
approach increases the group’s ability to reduce exposure to
component shortages and adapt to unforeseen disruptions
across the value chain.
Supplier assessments and monitoring processes are
continuously strengthened through contractual measures and
close coordination across the group.
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9. FINANCIAL POSITION
RESPONSIBLE: CFO
Description
The group is exposed to financial risks through different
sources, including liquidity, credit and currency. These factors
may influence the group’s ability to meet financial obligations,
secure competitive financing terms, maintain predictable cash
flows and support long-term growth initiatives. Market volatility,
macroeconomic trends and fluctuations in consumer demand
may further affect the group’s financial position.
Mitigation
Financial risks are monitored and managed in accordance with
the group’s financial policies, supported by internal control and
reporting mechanisms.
The group aims to maintain a long-term leverage ratio aligned
with its risk bearing capacity. It targets a long-term leverage
ratio, defined as NIBD / LTM EBITDA (adjusted for certain
exceptional items), not exceeding 2-3x.
Liquidity is strengthened through ongoing working capital
improvements, optimised supplier terms and disciplined cost
management.
10. REGULATORY COMPLIANCE
RESPONSIBLE: CFO
Description
Regulatory changes across markets require ongoing adaptation
to ensure compliance and avoid potential impacts on
operations, customer relationships and market position.
Maintaining regulatory compliance is essential for Komplett
Group’s reputation and future growth.
Mitigation
The group actively ensures compliance with applicable
legislation and regulation through structured compliance
management. A cross-group compliance board meets regularly
and reports to group management.
Key mitigation initiatives include monitoring and implementing
regulatory updates, and strengthening compliance areas,
such as sustainability reporting, data protection and GDPR
processes. Moreover, new group policies are being rolled out
through training and e-learning, and additional resources have
been recruited to ensure group-wide compliance.
FINANCIAL RISK COMPLIANCE RISK
Currency exposure is mitigated through pricing adjustments,
purchasing routines aligned with currency developments and,
when relevant, the use of financial instruments.
Credit risk is reduced through supplier and customer credit
assessments, customer prepayment practices and a balanced
order size profile.
In accordance with section 2-2 (6) of the Norwegian Accounting
Act, a summary of the group’s management of financial risks is
also included in note 4 to the consolidated financial statements
and in note 10 to the Komplett ASA financial statements.
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CONTENTS
GENERAL INFORMATION 38
How we report 38
Sustainability governance 41
How we integrate sustainability 45
How we engage and prioritise 50
Embedding sustainability in our policies
and processes (MDR-P) 56
Appendix 1 58
Appendix 2 61
Appendix 3 62
ENVIRONMENTAL INFORMATION 63
Climate change 63
EU taxonomy 71
Appendix: KPI tables 73
Resource use and circular economy 76
SOCIAL INFORMATION 80
Own workforce 80
GOVERNANCE INFORMATION 85
Business conduct 85
SUSTAINABILITY
STATEMENT
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GENERAL INFORMATION
This sustainability statement provides an overview of Komplett Group’s efforts on matters
related to the environment, social issues and governance (ESG).
HOW WE REPORT
ABOUT THE REPORT (ESRS 2)
Basis for reporting (BP-1)
Komplett Group discloses sustainability information for
the fiscal year 2025 as required by the EU regulation on
sustainability reporting, the Corporate Sustainability
Reporting Directive (CSRD), and the applicable European
Sustainability Reporting Standards (ESRS), as well as the
Norwegian Accounting Act section 2-3.
This sustainability statement covers the entire Komplett
Group, including the subsidiaries Komplett Services AS,
Komplett Distribusjon AS, NetOnNet AB, Webhallen Sverige
AB, Komplett Services Sweden AB, Komplett Distribution
Sverige AB and Ironstone AS. The statement is prepared on
a consolidated basis, and the scope of consolidation is the
same as for the financial statements.
The sustainability statement is published annually and
covers the fiscal year from 1 January 2025 to 31 December
2025. Where data or initiatives relate to a specific
subsidiary, this is clearly specified. The disclosures include
information on material impacts, risks and opportunities
(IROs) connected to Komplett Group across the upstream
and downstream value chain, as well as within our own
operations.
Komplett Group has used the option provided by the ESRS to
omit information related to intellectual property, know-how,
innovation results, or impending developments, specifically
related to forward-looking financial allocations to business
activities as we consider these to have commercial value.
The ESRS index in this sustainability statement provides an
overview of the disclosures made according to the ESRS.
In addition, a chapter covers other mandatory national
reporting requirements. This is Komplett Group’s second
year of sustainability reporting under the CSRD, and we will
continue to align our disclosures with evolving European and
Norwegian requirements.
> For an overview of disclosures in the ESRS index, see ESRS
2 IRO-2
Data collection, consolidation and validation follow the
same principles as for financial reporting. Sustainability
data are gathered from all subsidiaries and consolidated at
group level by the relevant functions, ensuring consistency,
traceability, and internal control.
> For more information about the value chain, see Komplett
Group’s material impacts, risks, and opportunities in ESRS 2
SBM-3
Report details (BP-2)
When preparing this sustainability statement, Komplett
Group has adopted the time horizons defined in ESRS, which
are applied consistently throughout all assumptions and
estimates:
X Short-term time horizon; the next annual reporting
period in our financial statement;
X Medium-term time horizon; from the end of the short-
term reporting period up to five years; and
X Long-term time horizon; more than five years.
Komplett Group has measured greenhouse gas (GHG)
emissions since 2022. Emissions from Ironstone have been
reported since 2023. We continue to improve our methods
through automating processes and refining calculations.
To improve accuracy, we have continuously initiated efforts
to align ESG data with ESRS requirements and will continue
to strengthen data quality in 2026.
For our value chain, estimations are necessary given
the limited maturity and accuracy of available data for
some parts of the group’s business model. To meet ESRS
requirements, we therefore provide estimates for key
sustainability metrics based on indirect sources, recognising
inherent limitations in data collection and accuracy across
our upstream and downstream value chains.
In compliance with ESRS requirements, we disclose
metrics that rely on value chain data estimated using
sector averages or proxies. These include Scope 3 GHG
emissions and waste generation across product life cycles.
This approach reflects the complexity of obtaining precise,
primary data from our global network of suppliers, private-
label sourcing, diverse product categories, and distribution
channels.
Our sustainability statement relies on data from industry
benchmarks, sector averages, and third-party reports
when primary data are unavailable. While this methodology
aligns with recognised industry practice, it also follows the
same estimation and error-correction principles as applied
in financial reporting, meaning that material errors are
corrected retrospectively, changes in estimates are applied
prospectively, and all assumptions are based on reasonable
and supportable information available at the reporting date,
ensuring consistency and comparability over time.
The overall accuracy of these estimates is considered
moderate, as they are based on assumptions and sector-
wide averages rather than primary data from all value chain
participants. Certain quantitative metrics and financial
impacts are subject to a high degree of measurement
uncertainty due to factors beyond our immediate control,
such as regional variations in supplier data that can affect
the precision of our Scope 3 GHG emission reporting.
To improve accuracy, Komplett Group is enhancing data
collection, pursuing more granular supplier data, and
gradually reducing reliance on indirect sources, such as
sector averages. As part of this work, we have automated
file uploads in our carbon accounting system to reduce
manual data handling and minimise the risk of input errors.
Further opportunities for process improvements are
being assessed as part of the ongoing development of our
transition plan.
All information required for disclosure under the ESRS
is contained within this sustainability statement; no
information has been incorporated by reference, in
accordance with ESRS 1 section 9.1, and no disclosures
from other legislation or reporting frameworks have been
included.
We report assumptions influencing the accuracy of
metrics alongside each disclosure, and a summary of these
assumptions is provided in the table “Our reported metrics
that are subject to estimations and assumptions”. Detailed
descriptions are included in the environmental section.
If not otherwise specified, metrics disclosed in this
sustainability statement are not validated by an external
body beyond any statutory auditor.
Updated emission factors for Norwegian electricity in 2025
provide a more accurate reflection of electricity imports
and exports. As a result, we have recalculated the 2024
Scope 2 figures to align with the revised emission factor.
This explains the changes observed in purchased electricity
emissions compared with the previous reporting period.
Improved waste reporting in 2025 has provided clearer
insight into hazardous waste within electrical and electronic
waste streams. As a result, we reclassified 2024 figures to
reflect the updated definitions. This explains the reduction
in tonnes of hazardous waste from the previous reporting
period.
> For more information about concrete measures to
improve accuracy of datapoints, in addition to changes and
corrections from prior reporting periods in the methodology
descriptions, see E1-6, E5-4 and E5-5
> For more information about the assumptions influencing
the accuracy of metrics, see E1-6, E5-4 and E5-5
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OUR REPORTED METRICS THAT ARE SUBJECT TO ESTIMATIONS AND ASSUMPTIONS
Standard Datapoint (metric) KPI reference Description Accuracy
1)
ESRS E1
E1-6 Gross Scopes 1, 2, 3
and total GHG emissions
Gross Scopes 1, 2 and Total GHG emissions – Scope 3 GHG emissions (GHG Protocol) §44 Scope 3 emissions are estimated using a combination of activity-based and spend-based methodologies, with data
gaps filled by external averages and industry standards.
Moderate
Gross Scopes 1, 2, 3 and Total GHG emissions - total GHG emissions - value chain §52 Emissions data for the value chain involves aggregating Scope 1, 2, and 3 emissions. Variability in Scope 3 data,
especially emissions from activities out of control of Komplett Group, contributes to overall uncertainty.
Moderate
Gross Scope 3 greenhouse gas §51 Emission data from activities out of direct control of Komplett Group, such as production of products for sale, and end-
of-life treatment is particularly uncertain.
Moderate
Gross Scope 3 greenhouse gas emissions §51 Emission data from activities out of direct control of Komplett Group. Category 4 and 11, are uncertain due to lack of
either precise data or explicit how products are used by customers.
Low
Total GHG emissions location-based §§44, 52a Location-based Scope 2 emissions are calculated using grid-average emission factors, which can vary regionally and
annually. While relatively consistent, regional differences in grid data may introduce minor inaccuracies.
High
Total GHG emissions market-based §§44, 52b Market-based emissions are derived using supplier-specific and contractual data, where available. Missing data is
substituted with grid-average factors, leading to potential inaccuracies.
High
ESRS E5
E5-4 Resource inflow Overall total weight of products and technical and biological materials used during the reporting
period (mass)
§31a Uncertainty arises from the reliance on supplier data and assumptions about the material composition of products
where direct information is unavailable.
Moderate
Percentage of biological materials (and biofuels used for non-energy purposes) (per cent) §31b This percentage is estimated using assumptions about product composition due to incomplete or missing supplier data
regarding the biological and technical content of materials.
High
The absolute weight of secondary reused or recycled components, secondary intermediary
products, and secondary materials used to manufacture the undertaking’s products and
services, including packaging (mass)
§31c Uncertainty exists because recycled content data was not provided by most suppliers, and assumptions were made
about the absence of recycled materials in several product categories
Low
Percentage of secondary reused or recycled components, secondary intermediary products,
and secondary materials (per cent)
§31c Estimations are subject to significant uncertainty due to the same lack of supplier engagement, requiring reliance on
assumptions or external data where available.
Low
ESRS E5
E5-5 Resource outflow Expected durability of the products placed on the market, in relation to the industry average for
each product group (table/per cent)
§36a Durability is estimated using warranty periods for private label products and external deadlines as a proxy for industry
averages, which may not fully capture product lifespan.
Low
Rates of recyclable content in products (per cent) §36c Estimates rely on external data from waste management partners about recycling potential, and assumptions about
economic feasibility of recycling, rather than direct measurements.
Moderate
Rates of recyclable content in product packaging (per cent) §36c Uncertainty exists due to reliance on supplier input for packaging recyclability and the absence of comprehensive data
for certain product lines.
High
Non-recycled waste (mass) §37d Non-recycled waste data relies on estimates of treatment outcomes from waste management companies, with varying
levels of detail and accuracy across regions.
High
1)
Accuracy refers to the quality of our data and the precision of the methods used in calculating ESG metrics.
High accuracy: This indicates that the data is of high quality, and the methods applied yield results with minimal bias and deviation from the true metric.
Moderate accuracy: This level suggests that the data is of moderate quality, with methods that produce results showing medium bias and deviation from the true metric.
Low accuracy: This reflects data of low quality, where the methods result in larger biases and greater deviation from the true metric.
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Report details (BP-2) (Cont.)
Komplett Group has assessed workers in the value chain
as a material sustainability topic in the FY25 materiality
assessment. However, in line with the adopted delegated
regulation “quick-fix” pertaining to CSRD’s phase-in
provisions, the group will not disclose full sustainability
information on this topic at this stage. The topic remains
highly relevant for our business, given our global and
complex supply chain, and our responsibility to respect
internationally recognised labour and human rights
standards.
Although full disclosure is postponed, Komplett Group
continues to manage risks and impacts for workers in the
value chain in accordance with our established approach.
This includes the application of our supplier code of
conduct, supplier audits, and due diligence processes
designed to prevent and mitigate negative impacts on
workers in high-risk geographies and industries. Policies
and practices remain grounded in international standards,
including the UN Guiding Principles on Business and Human
Rights and the ILO core conventions. As time-bound
targets and metrics related to workers in the value chain
remain to be defined, we continue to refine our approach to
responsible sourcing, due diligence processes, and supplier
engagement to ensure effective target-setting in the future.
In 2024, Komplett Group’s due diligence identified systemic
risks related to mining and mineral sourcing, electronics
manufacturing, transport and logistics, and e-waste
handling, which were addressed through supplier audits,
contractual commitments, and targeted engagement with
affected workers and communities. This work continues
into 2025 and 2026, and the group maintains oversight
mechanisms to monitor effectiveness and provide
remediation where needed, for example through our
whistleblower channel and supplier follow-ups.
> For more information about our approach to value chain
labour practises, see separately published Transparency Act
statements for all subsidiary companies within the group.
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SUSTAINABILITY GOVERNANCE
THE ROLE OF THE ADMINISTRATIVE, MANAGEMENT AND
SUPERVISORY BODIES (GOV-1)
The board of directors has the overall responsibility for
overseeing the group’s governance, including sustainability
matters. The board approves the sustainability strategy, the
sustainability targets, and the annual sustainability report,
while also monitoring progress through updates presented
at least twice a year. Sustainability is an integrated part
of the group’s overall risk management framework and
strategic planning.
Day-to-day management of sustainability matters is dele-
gated to the group CEO. The group CFO is responsible for
the accuracy, completeness, and timeliness of sustainability
reporting, while the director legal & compliance ensures that
relevant sustainability information, policies and regulatory
updates are shared with both management and the board.
Together, the CFO and the director legal & compliance
coordinate the group’s internal control over sustainability
reporting (ICSR) and ensure alignment with the CSRD and
ESRS requirements.
Roles and responsibilities related to sustainability
impacts, risks, and opportunities are defined in the group’s
sustainability policy, which specifies the respective roles
of the board of directors, the audit committee, the group
CEO, the group CFO, the director legal & compliance, and the
managing directors of subsidiaries. These roles are reviewed
and updated as needed to reflect changes in governance and
regulatory expectations.
The audit committee supports the board by reviewing
sustainability-related controls, risk information and
compliance matters. The board discusses sustainability
performance, key risks, and progress towards strategic
targets as part of its regular meeting cycle and when
significant issues arise.
EXPERTISE AND DIVERSITY
Diversity in all aspects of our business, including in
leadership, is key to our success. The board of directors
consists of seven non-executive members, including
two worker directors, representing a mix of professional
backgrounds from retail, electronics and e-commerce. The
group management team comprises eight members, with a
wide variety of expertise, skills, and national backgrounds.
Members of both bodies are based in Norway and Sweden,
where Komplett Group operates, and possess insights into
the operations in China.
GOVERNANCE MODEL
NOMINATION COMMITTEE
Recommend candidates for the board of directors based on
competence and diversity considerations.
BOARD OF DIRECTORS
Strategic direction, oversight of material important topics.
Sign the annual, integrated report. Endorse the double materiality assessment.
GROUP MANAGEMENT
Day-to-day management of the company, including material sustainability matters.
Approve the materiality assessment and materiality threshold.
CFO
Financial and sustainability performance.
THE AUDIT COMMITTEE
Monitor the financial and sustainability reporting
processes and effectiveness of the group’s internal
quality control and risk management systems.
Roles and responsibilities related to sustainability impacts, risks and opportunities:
THE REMUNERATION COMMITTEE
Review the remuneration and benefits strategy for the
members and executive management.
LEGAL & COMPLIANCE SUSTAINABILITY HUMAN RESOURCES
PROCUREMENT QUALITY OTHER
THE COMPOSITION AND DIVERSITY OF THE BOARD OF DIRECTORS AND GROUP MANAGEMENT
INDEPENDENCE OF THE
BOARD OF DIRECTORS
GROUP MANAGEMENT’S
GENDER DIVERSITY RATIO
BOARD OF DIRECTORS’
GENDER DIVERSITY RATIO
4 independent
3 non-independent
57.0%
3 female
4 male
43.0%
1 female
7 male
12.5%
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The board collectively holds expertise in corporate gover-
nance, sustainability and risk management, as well as deep
sector knowledge of retail, technology and logistics. To
ensure informed decision-making, relevant and satisfactory
skills and expertise are available within both the group
management and the board. In 2024, the board undertook
a targeted ESG training focused on the group’s material
impacts, risks and opportunities. Following a year of CSRD-
aligned sustainability reporting, the board’s knowledge of the
group’s sustainability work continues to strengthen.
The board also leverages internal resources, including the
sustainability manager and director legal & compliance,
and engages external specialists when necessary to ensure
continuous progress and compliance. Gender balance and
a mix of nationalities are considered in board nominations
to ensure diverse perspectives. As of 2025, three of the
seven board members are women (43 per cent), and three
members holds a non-Norwegian nationality.
> For additional information related to the board of directors
and group management, see the board and management
presentation
SUSTAINABILITY MATTERS ADDRESSED (GOV-2)
The board of directors receives regular updates on
sustainability matters through established reporting
routines. The group CFO and the director legal & compliance
are responsible for ensuring that accurate and complete
information on sustainability performance, risks and
opportunities is provided to the board and the audit
committee. The group management is responsible for the
oversight and governance of Komplett Group’s overall risk
management, including sustainability risks.
The sustainability updates include targets, results from risk
assessments, and updates on regulatory developments such
as CSRD and ESRS implementation. Information specifically
covers identified impacts, risks and opportunities, including
changes since the previous reporting period, and the
findings of the group’s double materiality assessment when
updated. This information also includes the implementation
of due diligence processes, as well as the results and
effectiveness of policies, actions, metrics, and targets
adopted to address them. Additional briefings are provided
when significant sustainability-related incidents or changes
in regulations occur.
The audit committee supports the board by reviewing the
integrity of sustainability-related data, control systems and
compliance processes. In doing so, the audit committee
considers internal control findings, external assurance
outcomes and material sustainability risks relevant to the
group’s operations and value chain.
The board considers sustainability matters in a broader
business context, ensuring that material sustainability
issues and IROs are taken into account in the group’s
overall planning and oversight. When complex or emerging
topics require deeper technical insight, the board and the
group management are supported by the director legal &
compliance, the sustainability manager and external experts
engaged by the group.
Sustainability impacts, risks and opportunities are
integrated into the group’s risk management process and the
group’s Enterprise Risk Management (ERM) policy ensuring
that sustainability matters are systematically evaluated and
managed in the enterprise risk assessment process. This
approach promotes long-term resilience by identifying and
mitigating sustainability risks, with the objective of aligning
operations with Komplett Group’s ethical standards and
positively contributing to society.
When overseeing strategy, major transactions, and risk
management, Komplett Group must navigate various trade-
offs between financial performance, sustainability goals, and
regulatory compliance. Balancing short-term profitability
with long-term resilience requires weighing investments
in circular economy initiatives, supply chain sustainability,
and climate risk preparedness. While no formal process has
been established to assess these trade-offs in particular,
the group management and board of directors are aware and
actively working to integrate sustainability into our business
model and strategy while maintaining financial stability and
competitiveness.
> For more information about material impacts, risks and
opportunities resulting from our materiality assessment, see
SBM-3
INTEGRATION OF SUSTAINABILITY-RELATED
PERFORMANCE IN INCENTIVE SCHEMES (GOV-3)
Komplett Group’s remuneration structure aims to promote
long-term value creation and responsible business conduct.
Variable remuneration is linked to both financial and
operational performance indicators, while sustainability
considerations are reflected through the group’s strategic
objectives and governance expectations.
There are currently no separate or quantified sustainability-
related targets that directly determine variable pay for
members of group management or the board of directors.
However, sustainability performance forms part of the
overall assessment of management performance through
qualitative evaluations and annual goal-setting processes.
As we continue to embed sustainability across our
operations, we are assessing how sustainability
performance indicators can be integrated into the
remuneration framework. Future remuneration policies will
consider measurable sustainability-related objectives where
relevant and consistent with the group’s overall strategy and
risk appetite.
The board of directors reviews and approves the
remuneration policy and ensures alignment between
incentive mechanisms, the group’s long-term objectives and
sound governance principles.
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CORE ELEMENTS OF DUE DILIGENCE
Elements Paragraphs in the sustainability statement Page
Embedding due diligence in
governance, strategy and
business model
ESRS 2 GOV 2 – Sustainability matters addressed
42
ESRS 2 GOV 3 – Integration of sustainability related performance in incentive schemes
42
ESRS SBM-3 – Komplett Group’s material impacts, risks and opportunities
53-55
ESRS 2 GOV 2 – Sustainability matters addressed
42
ESRS 2 SBM 2 – Stakeholder engagement in 2025
50–52
ESRS 2 IRO 1 – Komplett Group’s materiality process
58-60
ESRS 2 MDR P – Embedding sustainability in our policies and processes
56-57
ESRS S1 2 – Processes for engaging with own workforce and workers’ representatives
82
Identifying and assessing
adverse impacts
ESRS 2 IRO 1 – Komplett Group’s materiality process
58-60
ESRS 2 SBM-3 – Komplett Group’s material impacts, risks and opportunities
53-55
ESRS G1 1 – Whistleblowing
86
ESRS 2 MDR P – Whistleblower policy
56-57
Taking actions to address
identified adverse impacts
ESRS E1 MDR A – Taking action
64
ESRS E5 – 2 Actions and efforts to increase circularity
77-78
ESRS S1 4 – Taking action
82
ESRS G1 2 – Business conduct policies and corporate culture
86
Tracking the effectiveness
of these efforts and
communicating how impacts
are addressed
ESRS E1, E5 – Numbers and statistics – environment data
67,80
ESRS S1– Numbers and statistics – social data
85
ESRS G1 – Numbers and statistics – governance data
86
ESRS 2 SBM 1 – Sustainability strategy and business model
45-49
Information provided in sustainability statement related to our due diligence process.
STATEMENT ON DUE DILIGENCE (GOV-4)
Due diligence is the process whereby we identify, prevent,
reduce, and take responsibility for how we manage actual
and potential adverse impacts on the environment and
people associated with our operations.
We are committed to conducting due diligence in
accordance with the concepts and principles set forth in
the UN Guiding Principles for Business and Human Rights
and OECD Guidelines for Responsible Business Conduct,
including the Norwegian Transparency Act.
MANAGING COMPLIANCE IN THE SUPPLY CHAIN
One of Komplett Group’s goals is to develop relationships
with suppliers and business partners that share similar
corporate values and conduct their business in an ethical
and compliant manner. The supplier code of conduct
outlines the legal obligations, and the integrity standards
that Komplett Group expects our suppliers and business
partners to uphold.
RISK MANAGEMENT AND INTERNAL CONTROLS RELATED
TO THE SUSTAINABILITY REPORTING (GOV-5)
Komplett Group maintains a structured framework for
identifying, assessing and managing sustainability-related
risks and opportunities. This framework is currently under
development and being progressively integrated into the
group’s overall enterprise risk management (ERM) and
internal control over financial reporting (ICFR) systems to
ensure a consistent approach across financial, operational
and sustainability domains. Further, the structured ERM
methodology for assessing risks is applied to sustainability
risks, including both risk assessments and the materiality
assessment.
The group CFO has overall responsibility for establishing
and maintaining the control environment for sustainability
reporting, while the director legal & compliance
coordinates risk-identification and monitoring processes
across the group, together with group treasury. Each
subsidiary’s managing director will assume responsibility
for implementing risk-management procedures locally
and for ensuring alignment with group policies. The risk
assessment approach employed in the oversight of the
sustainability reporting identifies risks associated with
inaccurate reporting. The identified risks are prioritised
based on the likelihood of reporting errors and the potential
consequences of misreporting.
The control system is being developed based on the
same principles applied in financial reporting, ensuring
accuracy, completeness and consistency of sustainability
data. It includes clearly defined roles and responsibilities,
segregation of duties, documentation requirements and
control activities governing data collection, consolidation
and reporting. As the framework evolves, key controls are
being defined and documented, and testing of selected
controls is planned for a limited number of sustainability
data points for the FY 2025 reporting cycle.
Sustainability-related risks and opportunities are reviewed
at least annually as part of materiality assessment and the
ERM process. The risks are also continuously monitored
to capture regulatory developments and stakeholder
expectations. Results are reviewed by group management
and reported to the board of directors through the regular
risk-management cycle.
Findings from control testing and risk reviews will be used
to improve the design and effectiveness of internal controls
over sustainability reporting (ICSR). Improvement actions
will be developed and followed up by the group CFO and
the director legal & compliance, with progress monitored
through the internal-audit follow-up process.
A description of identified risks pertaining to the
sustainability reporting process follows below.
> For additional information related to risk management, see
risk and risk management
EMBED RESPONSIBLE BUSINESS CONDUCT
into policies and management systems
• Code of conduct
• Supplier code of conduct
• Anti-corruption and bribery policy
• Whistleblower policy
• Sustainability policy
REMEDIATION of negative impacts as far as
possible
2
IDENTIFY AND ASSESS
ADVERSE IMPACTS
in operations, supply
chains and business
relationships
5
COMMUNICATE
how impacts are
addressed
3
CEASE, PREVENT OR
MITIGATE adverse
impacts
4
TRACK
implementation and
results
KOMPLETT GROUP’S APPROACH
TO DUE DILIGENCE
1
6
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REPORTING PROCESS RISK
Topic Primary risk Mitigating strategies
E1: Climate change Inconsistent or incomplete GHG emissions
reporting due to data collection gaps or
inconsistent methodologies, as well as
reliance on estimated data.
We have provided training on climate
reporting to relevant representatives from all
group companies.
We have implemented a GHG accounting
system to ensure standardised GHG
emissions reporting across all companies.
We have used the four eyes principle
to review reported data from the group
companies.
E5: Resource use and circular economy Ensuring accuracy and completeness of
data is challenging due to the reliance
on estimates and varying definitions of
circularity.
We have worked on improving data quality by
gathering data from suppliers, such as data
on recyclability and life cycle assessments.
We have initiated a process to improve our
Product Information Management (PIM)
system, which will allow us to gather more
data on the products we provide to our
customers.
S1: Own workforce Incomplete or inconsistent workforce data
reporting, particularly when it comes to
consolidating data.
We have established a working group for HR
representatives from all group companies
and arranged sessions focusing on aligning
definitions and scope of HR related data to
ensure consistency and comparability.
Additionally, we have performed tests on new
datapoint disclosure related to S1-16.
G1: Business conduct The whistleblowing system may not capture
all incidents, resulting in reporting not
reflecting the full reality.
We inform all our employees about our
whistleblowing channel, and we have made
the channel available to the public.
Identified risks related to the sustainability reporting process.
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HOW WE INTEGRATE SUSTAINABILITY
SUSTAINABILITY STRATEGY AND BUSINESS MODEL
(SBM-1)
Komplett Group’s business model is centred on the online
and omnichannel sale of consumer electronics, IT products
and related services across Norway and Sweden. The
group also offers private-label products, distribution of IT
and electronic equipment, and tailored B2B solutions. Our
purpose is to enable sustainable and digital living through
accessible technology and responsible business practices.
We categorise our products into four main product groups.
All these product-groups relate to material impacts of
Komplett Group, such as emissions from production and
transportation, the resource inflows related to assembly of
the products, recycled material usage rate, the repairability
of products and the recycling of e-waste.
Komplett Group also offers services targeting improved
circularity. These relate to our material impacts and include
trade-in, buy-back and life-cycle programmes, outlets, and
sale of used products.
> For more information about our circularity-related services
and actions, see E5.SBM-1
Because the products Komplett Group provide are all
connected with our material impacts on climate change, the
same applies to our customers. Our significant customer
groups are consumers in Norway, Sweden and Denmark,
small businesses in Norway and Sweden, and resellers in
Norway and Sweden.
> For additional information related to business model, see
our business segments
> For additional information related to strategy, see strategic
and financial roadmap
The most significant ESRS sectors for Komplett Group in
terms of revenue generation are wholesale & retail trade
and software & IT services. Other ESRS sectors connected
to material impacts are transport, energy production,
manufacturing electronics, and mining. Komplett Group is
not active in sectors like fossil fuel, chemicals production,
controversial weapons, or production of tobacco. Further-
more, none of our products or services are banned in any
markets.
REVENUE ESRS SECTOR
NOK million 2025 2024
Wholesale & retail 15 529 15 176
Technology – Software & IT solutions 130 125
Tota l 15 659 15 301
Integrating sustainability across the value chain
Sustainability is an integrated element of the group’s
strategy and is reflected in our long-term value-creation
model. The board of directors approves the overall strategic
direction, while group management is responsible for
implementation and follow-up. The sustainability strategy
is built around strategic focus areas: circularity, climate
impact, and being an attractive employer. These areas
combine financial, operational and sustainability objectives
and ensure that environmental and social considerations are
embedded in everyday decision-making.
Sustainability is one of the five pillars of our corporate
strategy. Komplett Group aims to contribute to sustainable
development in consumer electronics and retail industry.
This entails offering products that have a long life, can
be repaired, and recycled, while also helping customers
make more informed choices. At the same time, we are
going to make sure we are an inclusive employer and follow
responsible purchasing practices.
Material sustainability matters identified through the group’s
double materiality assessment are integrated into strategic
and operational planning. Each material matter is linked to
one or more of the strategic focus areas and translated into
policies, targets and actions. This ensures that the group
addresses both impact and financial materiality in line with
the ESRS framework.
The board receives updates on sustainability strategy at
least twice a year. Insights from sustainability reporting,
risk assessments and stakeholder engagement are used to
refine the business model and align strategic priorities with
regulatory developments and stakeholder expectations.
Sustainability aspects influence decisions across the
value chain, including product development, procurement,
logistics, marketing and customer service. For example,
the circularity focus guides investments in reuse, repair and
recycling schemes, while climate-related goals drive energy-
efficiency measures and low-emission transport solutions.
> For more information about how we work with transport
logistics, see E1 MDR-A
To expand our circular business model, we work to extend
product lifetimes and communicate recycling programmes
more clearly. We are also exploring the viability of expand-
ing our product-as-a-service initiatives. Aligning our
sustainability goals with regional considerations requires
full compliance with regulatory obligations in all markets
and customer segments. This will remain crucial, and we will
continue to allocate resources accordingly. As we continue
to improve our calculation methods and data infrastructure
related to resource outflows and GHG emissions, we will
be able to dedicate resources more effectively to specific
geographic areas or consumer segments where we have
the greatest opportunity to improve performance. Based on
these assesment, the group has set ambitions as described
in the table on the next page.
OUR MAIN PRODUCT CATEGORIES, AND RELEVANT PRODUCT EXAMPLES, ARE:
Consumer Electronics Computing Home Telecom
• TVs
• Headphones
• Climate control devices
• Gardening tools
• Desktop and laptop
computers
• Graphics cards
• Gaming consoles
• Cookers
• Washing machines
• Blenders
• Mobile phones
• Tablets
• Smartwatches
TOTAL NUMBER OF EMPLOYEES
IN KOMPLETT GROUP
Total
employees
1 459
Sweden
Norway
Unique retail brands
loved by customers
KOMPLETT GROUP
The leading online-first champion with retail brands loved by customers
Online-first with
speed, convenience
and leading tech
Integrated back-end and
shared capabilities across
commercial, digital and
suppply chain functions
Leading efficiency
and OPEX cost
position
Driving force
for sustainable
development
KOMPLETT GROUP’S STRATEGIC PLATFORM
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STRATEGIC FOCUS AREAS FOR KOMPLETT GROUP
VISION: THE OBVIOUS CHOICE
Strategic focus areas Circular business model Climate neutral Attractive inclusive employer
Strategic goals
1)
15 per cent of Komplett Group’s revenues comes from
circular products or services by 2028
Scope 1 and 2 (1.5-degree pathway): Reduction of at least
42 per cent GHG emissions by 2030, compared to 2022
baseline
Scope 1, 2 and 3: Net zero by 2040
Industry leading employee temperature: Temperature >
index (index based on selected industries)
Gender balance in leadership positions
Ambitions Komplett Group is determined to contribute in the
transition to a circular economy.
This means:
• Prolonging the loop: Establish circular services, such
as return, repair and reuse, to allow for the products to
stay in the loop for as long as possible. Ensure access to
spare parts for products and refill (where applicable).
• Enabling circular choices: Give information through
our platforms, make sustainable products available to
our customers and inform on services and end-of-life
treatment of products sold (nudging).
Komplett Group will reduce climate impact from the
whole value chain and aim to reduce emissions in line
with the Paris Agreement (1.5-degree scenario).
This means:
• Reducing direct emissions: Reduce emissions from
transportation and buildings. Optimise packaging to
reduce material use, transport of air and protect the
products in transportation.
• Reducing emissions from our products: Include climate
criteria for the selection of private label products.
Working with sustainable category management across
product categories to increase recycled content,
ensure products are repairable, recyclable, and durable
and reduce emissions.
• Enabling sustainable choices: Offer sustainable
products in each product category and allow filtering
based on emissions in production, circular-aspects and
energy use.
Komplett Group aims to be an inclusive and attractive
employer that attracts and retains talent and has a
positive impact on society.
This means:
• Promoting equality and inclusion: Promote equal
opportunities and diversity in the work force.
• Being a preferred employer: Have a high retention rate,
attract, develop and retain the best candidates.
• Positive impact on society: Impact business partners,
suppliers and communities where we are present by
taking care of our employees and promoting a positive
business culture.
Material topics • E5 Resource inflow
• E5 Resource outflow
• E5 Waste
• E1 Climate change mitigation
• E1 Climate change mitigation
• E1 Energy
• E5 Waste
• S1 Equal treatment and opportunity for all
• G1 Corporate culture
SDGs
1)
Our strategic goals set the direction for our sustainability work. As of now, they are not “targets” as defined by the ESRS for reporting purposes, except for the strategic goals pertaining to being an attractive and inclusive employer.
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Integrating sustainability across the value chain (cont.)
With respect to our business model and value chain,
Komplett Group’s key business relationships are with our
customers and suppliers. For our customers, hereunder
consumers and small businesses, we emphasise building
strong relationships through excellent customer service,
a sustainable product offering, as well as gathering
customer feedback to improve products and services. For
our suppliers, we emphasise sustainable sourcing and
partnering with suppliers who adhere to high environmental
and ethical standards. We prefer long-term contracts with
the right suppliers to support a stable supply chain.
By focusing on these areas, we can align our operations with
our sustainability goals and meet the growing demand for
eco-friendly products in the Nordic market.
The illustration shows Komplett Group’s position in the value
chain. Further details are provided on the following page.
BUSINESS MODEL AND VALUE CHAIN
UPSTREAM OWN OPERATIONS DOWNSTREAM
Packaging &
storage
B2B and
consumers
Raw materials
Storage &
packaging
Production of parts
and components
Transport
Recycling /
end-of-life
Processing of
inputs
Transport
Assembly of
products
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AN OVERVIEW OF OUR VALUE CHAIN, COVERING SUPPLIERS, OPERATIONS, FINANCIAL STRUCTURE, BUSINESS SEGMENTS,
AND KEY OPPORTUNITIES
Phase Aspects Details
Upstream Suppliers Raw material suppliers, component manufacturers and key brands (Apple,
Samsung, Asus, Sony, Andersson).
Key resources Sustainably sourced raw materials.
Sustainable sourcing Significant activities related to sourcing involve prioritising recycled materials,
renewable energy and suppliers adhering to ethical standards.
Key risks Supply chain disruptions, reliance on global suppliers and potential regulatory
changes.
Own operations Key activities • Product development with a focus on energy-efficient and durable designs.
• Sales and marketing outreach to key markets and customer groups.
• Customer support providing repair and refurbishment services.
Key resources • Human resources, including IT, logistics and support.
• Advanced technology systems for logistics and manufacturing.
Impacts and risks • Environmental impact: Reducing electronic waste and carbon emissions
through sustainable practices.
• Social impact: Creating jobs and supporting local communities.
• Regulatory changes: Adapting to new environmental regulations and
standards.
Cost structure in line with IFRS 8
business segments
Costs are primarily driven by procurement, logistics, warehousing and
operational expenses. In the B2C segment (Komplett B2C, NetOnNet, Webhallen),
costs include inventory management, marketing, IT infrastructure and customer
service. These are also relevant for the B2B segment (Komplett B2B, Ironstone).
The B2B segment also incur costs related to tailored business solutions and
account management. The Distribution segment (Itegra) has costs focused on
supply chain efficiency and bulk logistics.
Revenue in line with IFRS 8
business segments
Revenue is generated through direct consumer sales in B2C, enterprise sales
and managed services in B2B, and wholesale distribution in the Distribution
segment. The B2C segment derives revenue from online and retail sales, while
B2B revenues stem from customised IT solutions and business contracts. The
Distribution segment primarily earns revenue from bulk sales to resellers and
other partners.
Downstream Significant markets The Nordic region represents a significant market, accounting for the large
majority of revenue and is the primary focus for sustainability efforts.
Distribution channels • Online platforms (e-commerce).
• Retail stores (physical locations).
• Authorised resellers (local partners).
Customers • Individuals seeking electronic goods or services (B2C).
• Companies requiring reliable products for operations (B2B).
Key opportunities Growth in demand for sustainable products and innovation in eco-friendly
technology.
> For more information about the cost structure and revenue of business segments in line with IFRS 8, see financial
statements note 5
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Stakeholder Current benefits Expected benefits
Customers Enhanced user experience: High-quality, reliable, and energy-
efficient products improve customers’ daily life and productivity.
Innovation: Continuous improvement and
introduction of new technologies that meet
evolving customer needs.
Convenience: Access to a wide range of products and services,
including easy repair and recycling options.
Sustainability: Increased availability of eco-
friendly products and services that align
with customers’ values and environmental
concerns.
Cost savings: Energy-efficient products reduce electricity bills
and durable products lower the need for frequent replacements.
Investors Stable returns: Consistent revenue from product sales and
services.
Growth opportunities: Expansion into
new markets and product lines driven by
innovation and sustainability trends.
Market position: Strong brand reputation and market share in the
Nordic region.
Risk mitigation: Adoption of sustainable
practices reduces regulatory and
reputational risks.
Other stakeholders Environmental impact: Reduced electronic waste and lower
carbon emissions through recycling programmes and energy-
efficient products.
Circular economy: Enhanced circular
business model that promote reuse,
refurbishment, and recycling, contributing to
a more sustainable economy.
Social impact: Job creation and support for local communities
through fair labour practices and community engagement.
Partnerships: Stronger collaborations with
suppliers, governments, and NGOs to drive
sustainability initiatives and innovation.
Outputs and outcomes in terms of current and expected benefits for customers, investors and other stakeholders.
OUTPUTS AND OUTCOMES
The outputs from our operations and value chain are the
products and services we provide to our customers. This
includes products, such as smartphones, laptops, domestic
appliances, gaming equipment and other electronic
devices and accessories, as well as services, such as repair,
recycling programmes and customer support.
Our outcomes are the results and impacts of these
outputs on our stakeholders, including our customers and
investors. They reflect the value delivered and can be both
qualitative and quantitative. By distinguishing between
outputs and outcomes, and focusing on both, we aim to
effectively communicate the value we deliver to customers,
investors, and other stakeholders, while also reaching our
sustainability goals.
> For additional information related to our value chain, see
Komplett Group’s value chain
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HOW WE ENGAGE AND PRIORITISE
STAKEHOLDER ENGAGEMENT IN 2025 (SBM-2)
Komplett Group engages systematically with the group’s
key stakeholders to understand expectations, identify
sustainability priorities and inform strategic decision-
making. Stakeholder engagement is an integral component
of the group’s double materiality assessment and supports
both impact and financial materiality evaluations.
The group’s principal stakeholder categories are employees,
customers, suppliers and business partners, investors and
shareholders, and authorities and regulators. Engagement
takes place through established channels and at regular
intervals suited to each group’s relationship with the
group. Employees are consulted through surveys, union
representation and management dialogue; customers
through feedback channels, service data and brand surveys;
suppliers through onboarding assessments, audits and
continuous follow-up; and investors through regular
reporting and meetings.
The purpose of these engagements is to gather insights on
potential and actual impacts, risks and opportunities, and
to ensure that stakeholder perspectives are reflected in
the group’s sustainability strategy and business model. In
the 2025 reporting cycle, stakeholder input confirmed the
relevance of topics such as circularity, responsible sourcing,
data protection and employee well-being.
The interests and views of our stakeholders align well with
our business model, so no changes to our strategy have
been, or will be, made based on their input. Responsibility
for stakeholder engagement on sustainability matters
rests with the director legal & compliance, supported by
the sustainability manager and relevant functions at group
and subsidiary level. Results from stakeholder dialogue are
consolidated annually and presented to group management
and the board of directors as part of the materiality-
assessment and strategic-planning process.
> For more information on how stakeholder input is
reflected in the identification of material impacts, risks and
opportunities, see ESRS 2 SBM-3
KOMPLETT GROUP’S STAKEHOLDERS
Shareholders/
investors
Nature
(silent stakeholder)
B2C customers B2B customers Employees and
management
NGOs and B2B
customers
Suppliers Government/
regulators
Financial
institutions
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STAKEHOLDER ENGAGEMENT
Why we engage How we engage Key topics of interest in 2025 How we responded
Customers B2C
Our B2C customers are core to our business, and delivering best in
class customer experience is critical for our success
• Multiple channels, including face-to-face meetings in shops,
customer care call centres and contact via our customer loyalty
programmes
• Active interaction and prompt follow-up on queries/feedback
received via social media platforms such as Facebook, X and
Instagram
• Regular customer interactions via satisfaction surveys
• Gathering insight through sustainability surveys
• Sustainability and quality of products, services and operations
• Customer relationships and cooperation
• Recycling and waste management of consumer electronics
• Offer spare parts and repairs
• Offer a good working environment for our employees
• Environmentally friendly transportation
• Reducing GHG emissions
• Responding promptly to questions and concerns by e-mail,
phone (through our call centre) and social media
• Environmentally friendly deliveries indicated in online checkout
(NetOnNet)
• Packaging strategy for private label, ensuring efficient
packaging and use of more environmentally friendly packaging
Customers B2B
Our B2B customers are core to our business, and delivering best in
class customer experience is critical for our success
• Engaging through online communication, newsletters and face-
to-face meetings
• Gathering insight via surveys and interviews
• Sustainability and quality of products, services and operations
• Customer relationships and cooperation
• Packaging
• Transportation matters, including social aspects within the
transportation area
• GHG emissions including access to information about GHG
emissions
• Financing and payment terms
• Ongoing dialogue
• Continuous service development based on customer feedback
Suppliers
We expect our suppliers to deliver on their commitments while
living up to internationally recognised best practices
• Regular, direct dialogue
• Gathering insight via interviews
• Strategic collaborations and long-term relationships
• Working conditions for workers in the value chain
• Optimising energy consumption of products
• Producer responsibility such as eco-design of products
• Inspiring customers to buy more eco-friendly products
• Packaging
• Ongoing dialogue
• Strengthened group supplier code of conduct
• Conducted 97 factory audits for private label suppliers in 2025
• Continued to expand tier 2 due diligence checks – 124 in 2025
• Increased emphasis on working conditions in our audits
• Quality inspection on 100 per cent of private label shipments
prior to shipping
Shareholders/investors
We engage with shareholders and investors to provide the public
with accurate, comprehensive, and timely information, to form
a solid basis for making decisions related to the valuation and
trading of Komplett ASA shares
• Quarterly and annual reports and presentations
• Regular engagement through regulatory financial
communications (financial reporting, stock exchange press
releases etc)
• Investor seminars
• Individual investor calls
• Majority owners are represented on the board of directors
• Gathering insight via interviews
• Equal treatment and opportunities for all
• Contribution to the green shift
• Transparent and regular reporting and disclosure
• Transparent communication
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Why we engage How we engage Key topics of interest in 2025 How we responded
Financial institutions
We engage with financial institutions to ensure stable and efficient
financing, manage financial risks, and support long-term growth
through responsible financial practices
• Continuous engagement through regulatory financial
communications
• Continuous dialogue
• Gathering insight via interviews
• GHG emissions
• Conditions for own workforce
• Human rights for workers in the value chain
• By reporting through our sustainability statement and
transparency act account
Employees and management
We depend on our employees, their knowledge, engagement and
diversity to successfully deliver on our strategy
• Employee satisfaction and engagement measured through
surveys every two weeks
• Internal channels and quarterly group-wide townhalls
• Training and coaching
• Engagement with trade unions
• Regular job appraisals
• Flexible and hybrid working
• Career paths, learning and development
• Diversity, equality, and inclusion
• Safety, health, and well-being at work
• Proactive and systematic communication and training
• Individual performance reviews, development tools and
programmes
• Flexible ways of working and smart tools
• Social committees for employee satisfaction
Government/regulators
We engage with government and other regulators to share our
knowledge and shape regulatory actions in pursuit of common
goals and industry transition
• Meetings with relevant authorities
• Engagement and cooperation with organisations and experts to
inform government on sustainability matters
• Swedish chemical taxes on consumer electronics
• Taxes on spare parts and repairs
• Regulatory framework for second-hand trade and repair,
to improve and secure conditions for sales of second-hand
products
• Supported with insight and expertise
NGOs and experts
We commit ourselves to gain insights and guidance on the issues
that are considered important in science and among NGOs
• Gathering insight via interviews and dialogue • Repairability, circularity and recycling
• Sustainable packaging
• Inspiring customers to recycle
• Clear communication to customers on related topics information
• End-of-life treatment
• Social responsibility in transport sector
• New packaging strategy for private label, ensuring efficient and
more environmentally friendly packaging
• We offer circular services such as Trade-In, sale of used
products and FLEX
Nature (silent stakeholder)
Just as we consider human stakeholders, we need to be inclusive
of non-human stakeholders
• Silent stakeholder • The construction and operation of storage and store facilities
may require clearing land and/or altering the landscape,
potentially disrupting local ecosystems and habitats
• The generation and disposal of waste from storage operations,
such as packaging materials or hazardous waste, can impact
ecosystems if not managed properly
• Circular business through initiatives such as trade-in
programmes
• Trade-in and refurb planned to be implemented for Komplett
Services in 2025
• Emission reduction initiatives
• Ongoing energy surveys of our various properties
• Requirements for energy efficiency in construction and for
materials when building new properties
• We strive to have properties that are energy efficient and
environmentally friendly, that qualify for various certifications
Key stakeholders, stakeholder engagement, and how their topics of interest are taken into account.
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KOMPLETT GROUP’S MATERIAL IMPACTS, RISKS AND OPPORTUNITIES (SBM-3)
In 2025, we updated our double materiality assessment, and the analysis resulted in the identification of five material topics and ten sub-topics for the group.
DESCRIPTION OF MATERIAL IMPACTS, RISKS AND OPPORTUNITIES RESULTING FROM THE MATERIALITY ASSESSMENT
Topic Sub-topic IRO Impact Value Chain Time Horizon Description
E1: Climate change Climate change mitigation Impact Production and transportation of components and products in the upstream value chain.
E1: Climate change Climate change mitigation Impact Emissions related to production of packaging.
E1: Climate change Climate change mitigation Impact Emissions from upstream transportation.
E1: Climate change Energy Impact Emissions related to energy consumption at warehouses, stores and offices.
E1: Climate change Climate change mitigation Impact Emissions related to transportation from own operations to customers.
E5: Resource use & circular economy Resource inflows Impact Assembly of products with low degree of recycled materials and high degree of potentially harmful virgin materials like plastic.
E5: Resource use & circular economy Waste Impact Waste generation in own operations and administration.
E5: Resource use & circular economy Waste Impact Waste generation from packaging products for customers not treated by Komplett Group.
E5: Resource use & circular economy Resource outflows Impact Difficulty of re-use of previously sold products due to inadequate recyclable design and repairability options for products.
E5: Resource use & circular economy Waste Impact Customers potentially inadequately disposing or recyling e-waste resulting in hazardous waste not being treated properly.
E5: Resource use & circular economy Resource outflows Impact Selling products with low lifespand potentially increasing resource use and the need for management of hazardous materials.
E5: Resource use & circular economy Waste Risk Changing regulatory landscape for the electronics sector related to regulation of outflow of materials and waste management
(e.g. e-waste, chemical tax/non-toxic environment).
E5: Resource use & circular economy Resource outflows Opportunity Increase circularity of products, packaging and circular services (reparability, re-use, recyclability, packaging).
E5: Resource use & circular economy Resource outflows Opportunity Circular services related to repair and extension of end-of-life.
S1: Own workforce Equal treatment and opportunities for all Impact Ensuring diversity and inclusion of employees.
S1: Own workforce Equal treatment and opportunities for all Impact Low gender diversity.
S1: Own workforce Equal treatment and opportunities for all Impact Training and skills development of employees not optimised across the group.
S1: Own workforce Equal treatment and opportunities for all Opportunity Opportunity related to ensuring diversity through training.
S1: Own workforce Equal treatment and opportunities for all Risk Risk of not attrackting the best and right candidates and maintaing skillfull employees (training and skills development).
G1: Governance Corruption and bribery Risk A breach in code of conduct and anti-corruption policy and regulations from suppliers has associated costs.
G1: Governance Protection of whistleblowers Risk Not getting information related to business conduct matters.
G1: Governance Corporate culture Opportunity Streamline ways of working across subsidiaries from group level to capitalise on best practices and stregthen corporate culture.
Positive Negative Actual impact Potential impact Upstream Own operations Downstream
Time horizons
Short-term time horizon: the next annual reporting period in our financial statements;
Medium-term time horizon: from the end of the short-term reporting period up to five years; and
Long-term time horizon: more than five years.
Overview of material topics, sub-topics, and where in the value chain of our business model the material impacts, risks and opportunities are concentrated, as highlighted
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Komplett Group applies a structured and group-wide process
to identify, assess and manage material sustainability IROs
in line with the CSRD and ESRS requirements. Our strategy
is designed to be resilient, with a focus on addressing
material sustainability impacts, risks, and opportunities
across different parts of our business model and value
chain. The group’s risk management framework shall ensure
that these factors are embedded into decision-making and
performance measurement. The strategy includes specific
targets for impacts, risks and opportunities, with goals that
are set with a long-term horizon in mind, ensuring that our
business model is adaptable to regulatory changes, market
shifts, and evolving customer expectations in the coming
years.
The double materiality assessment encompasses two
dimensions: (1) impact materiality, which considers how the
group’s activities affect people and the environment, and
(2) financial materiality, which assesses how sustainability-
related matters create or influence financial risks and
opportunities for the group. The assessment covers the
group’s own operations as well as upstream and downstream
value chains and is updated at least every second year or
when significant changes occur.
In the short term (up to one year), we focus on operational
efficiency and immediate risk mitigation. In the medium
term (one to five years), we aim to capitalise on emerging
opportunities related to circular economy and talent
retention. In the long-term (five or more years), our strategy
includes scalability and adaptability to sustain growth and
secure our position in a competitive and sustainability-
focused market.
We have aggregated the current and anticipated effects
of material impacts, risks and opportunities to provide a
clear and comprehensive view of their influence on our
business model. Additionally, information relating to how
these impacts are connected to our strategy and business
model is expressed in a similar aggregated manner. This
approach ensures that the information remains relevant and
avoids unnecessary fragmentation, while maintaining focus
on material details. By presenting their effects collectively,
we aim to reflect their interconnected nature and overall
significance to our operations and strategy. The aggregated
impacts, risks and opportunities are categorised into
environmental, social and governance dimensions.
Environmental impacts and opportunities and its effect
on the business model
The most significant environmental impact for Komplett
Group stems from upstream activities, particularly
raw material extraction, product manufacturing, and
transportation, which contribute to greenhouse gas
emissions. Although no immediate financial risks have been
identified, we anticipate long-term financial opportunities
related to regulatory changes, with a growing demand
for sustainable products and green investments. These
opportunities are aligned with our strategic focus areas,
including our goal of achieving net-zero emissions (Scope 1,
2, and 3) by 2040, with a 42 per cent reduction in Scope 1 and
2 GHG emissions by 2030.
To capitalise on these opportunities, we have integrated
environmental sustainability into our business targets. In the
medium term, one of our strategic goals is achieving 15 per
cent of group revenue from circular products and services
by 2028, reflecting growing financial materiality from
circular economy practices for Komplett Group.
Social impacts and opportunities and its effect on the
business model
From a social perspective, we recognise that attracting and
retaining talent, particularly through diversity and inclusion
initiatives, is crucial for our long- term success. The ability
to develop and retain a skilled workforce is essential for
driving innovation and engaging a diverse customer base.
This presents both risks (e.g. if we fail to attract the right
talent) and opportunities (e.g. through enhanced employee
satisfaction and performance). These initiatives are thus
integral to achieving our financial targets, including EBIT
margin and cash conversion rate. In response, we have set
a strategic target to achieve and maintain industry-leading
employee satisfaction and achieve gender balance in
leadership positions.
Governance framework and integrated risk management
in the value chain
Komplett Group’s governance framework is built on strong
business ethics, with a focus on anti-corruption measures,
whistleblower protection, and compliance across our value
chain. We address risks related to human rights violations
and unethical practices within the supply chain, particularly
in sectors such as mining and logistics. These efforts
are supported by robust policies, supplier audits, and
contractual commitments, which help mitigate potential
risks and ensure long-term business continuity.
The governance-related financial risks and opportunities
are integrated into our overall risk management process,
which is reviewed by the board of directors and the
audit committee. This top-down approach ensures that
sustainability risks, particularly those related to governance
(such as business conduct and ethics), are aligned with our
broader strategy and long-term business objectives.
Strategic integration and financial effects
We have integrated material impacts, risks, and oppor-
tunities into our overarching business strategy, aligning
them with our operations and financial performance goals.
Our long-term targets, including achieving NOK 20 billion in
sales, an EBIT margin of three to four per cent, and a cash
conversion rate above 70 per cent, are directly influenced by
our ability to address material sustainability-related financial
risks and seizing the emerging financial opportunities. More
specifically:
X The focus on circular economy initiatives, including the
strategic goal of 15 per cent of revenue from circular
products and services by 2028, is expected to drive
financial growth, while reducing the risk of resource
scarcity and ensuring compliance with current and
future regulations.
X Our commitment to climate-related risk reduction, such
as the net-zero goal, aligns with regulatory trends and
customer demand for greener solutions, positioning us
to capture long-term market opportunities.
X Talent retention and workforce development are
essential for operational success, and our ability to
innovate, meet customer needs and achieve financial
goals.
Current and anticipated financial effects and our
adjustments
The effects of the identified material risks and opportunities
are influencing our financial position, performance and cash
flows. At an aggregated level, this includes our ongoing
sustainability initiatives related to adapting circular
economy practices and reducing emissions. This impacts
both operational efficiency and customer trust, which in turn
are key drivers for market differentiation and profitability.
We also recognise that the continued integration of
sustainability into our business model will require ongoing
resource allocation.
> For more information about our financial position,
performance and cash flows, see financial statements
In 2025, we conducted both scenario analyses and resilience
analyses of our strategy and business model as it is
described in SBM-1 (sustainability strategy and business
model). When assessing the capacity of our strategy and
business model to address material impacts, risks and
opportunities we have performed a qualitative evaluation
based on the quantitative analysis from our scenario analysis
to identify the necessary steps to remediate impacts,
mitigate risks and capitalise on opportunities.
For climate change related impacts, risks and opportunities,
our resilience analysis as well as a scenario analysis based
on Intergovernmental Panel on Climate Change (IPCC)
and Network for Greening the Financial System (NGFS)
frameworks is described in E1.SBM-3. Here we assess
potential impacts over the short (up to one year), medium
(one year up to five years), and long- term (more than
five years) horizons. While no immediate risks related to
our capacity to address impacts have been identified in
relation to climate change, we will continue to strengthen
our ability to address climate-related disruptions as well as
opportunities, including circularity initiatives.
Attracting and retaining talent is as a key opportunity that
supports the group’s long-term resilience. Komplett Group
maintains solid capacity to advance training initiatives,
employee benefits and work-life-balance measures across
our companies. These actions help mitigate risks associated
with a recruitment pool traditionally dominated by male
candidates and strengthen diversity and inclusion.
In the upstream supply chain, we have strengthened our
approach to human rights-related risks through targeted
upskilling within the procurement department and the
private-label organisation. Expanded training programmes
and deeper factory audits, extending beyond tier 1 suppliers,
have strengthened oversight and improved the ability to
identify and respond to potential human rights breaches.
The group’s capacity to manage data-protection and
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privacy risks is considered robust. Continuous testing of
cybersecurity measures and mandatory employee training
ensure compliance with internal policies and external data-
protection requirements.
Komplett Group’s culture of strong business ethics and
well-established governance structures further reinforce
our ability to manage material impacts and risks. A clear
ethical framework, supported by a third-party whistleblower
channel and related policies, safeguards employees and
partners and fosters accountability. Corporate culture is
therefore viewed both as a potential risk and as a strategic
opportunity to strengthen trust and resilience throughout
the value chain.
> For more information about impacts connected to strategy
and business model, see strategic focus areas, ambitions
and targets in SBM-1
> For more information about resilience and scenarios
related to climate change, see E1. SBM-3
Where impacts, risks and opportunities are likely to occur
How we manage and monitor material topics depends on
where they are likely to have an impact, and on the expected
risks and opportunities ahead. Acknowledging that ESG
issues will evolve and become increasingly important over
the coming years and decades, we adopt a long-term time
perspective in our materiality assessments and strategic
planning, typically extending beyond five years. This
approach ensures that sustainability considerations are
integrated into the strategic and financial planning horizons.
Changes in materiality results
Pollution to soil has been evaluated as falling below the
CSRD-defined threshold, as the identified potential
impacts occur beyond the group’s control in the value
chain. Likewise, the topic of consumers and end-users
has been reassessed, as Komplett Group does not process
sensitive personal data. Any potential negative impacts
from information-related risks, such as data breaches, are
therefore less severe than previously considered and fall
below the materiality threshold.
Finally, workers in the value chain remain material. However,
in line with the CSRD’s phase-in provisions, Komplett Group
has opted not to disclose sustainability information related
to this topic at this stage.
All impacts, risks and opportunities are covered by the ESRS
disclosure requirements, and no entity-specific impacts,
risks or opportunities have been assessed to be material.
KOMPLETT GROUP’S MATERIALITY PROCESS (IRO-1)
In 2025 we revised and strengthened our double materiality
assessment in line with the CSRD and ESRS requirements.
The assessment builds on analyses from 2023 and 2024 and
uses a structured process to identify, assess and manage
sustainability-related impacts, risks and opportunities
across our operations and value chain. Enhancements
include stronger integration with our enterprise risk
manage ment framework and expanded coverage of up-
stream and downstream activities.
The assessment follows four steps: Understand, Identify,
Evaluate and Decide, and considers both impact materiality
and financial materiality, including interlinkages between
impacts, risks and opportunities. Material matters are
assessed using the same risk criteria, time horizons and
governance procedures as other significant business
risks and are reported to group management, the audit
committee and the board of directors. Findings directly
inform our strategy, policies, targets and disclosures, and
the assessment is reviewed at least every second year or
when significant changes occur.
A detailed description of our materiality process can be
found in Appendix 1, and forms part of this sustainability
chapter.
> For more information about our materiality process, see
Appendix 1
DISCLOSURE REQUIREMENTS (IRO-2)
Information in accordance with IRO-2, including tables
presenting data points derived from other EU legislation and
the ESRS disclosure requirements index, is presented in a
separate appendix to the report.
> For more information about our disclosure tables, see
Appendix 2 and 3
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EMBEDDING SUSTAINABILITY IN OUR POLICIES AND PROCESSES (MDR-P)
Komplett Group integrates sustainability into our core
business principles and processes, which in turn govern
how we develop strategies and conduct our everyday work.
In 2024, we established several new group-level business
conduct policies, including the sustainability policy, privacy
policy, information security policy, product safety policy, HR
policy, and competition law policy. In 2025, we continued to
strengthen our governance framework with the introduction
of a business continuity policy, an AI policy and a policy for
internal control over sustainability reporting. Furthermore,
group-wide training initiatives have been implemented for
our code of conduct, HR policy, sustainability policy and
supplier code of conduct.
All our corporate codes, policies, procedures, processes,
and guidelines are published on the group’s internal
website. Going forward, we will consider publishing more
policies on our external webpages to make them available
to our suppliers, business partners, and other external
stakeholders.
Where applicable, the standards and policies have been
developed based on internationally recognised initiatives
and standards such as the UN Global Compact’s principles,
OECD Guidelines for Multinational Enterprises, ILO
conventions, General Data Protection Regulation (GDPR),
and United Nations Convention against Corruption. Komplett
Services is also certified according to ISO 9001 and ISO
14001.
All policies have been developed and adjusted to take the
relevant stakeholder considerations into account. This
means in practice that for instance our sustainability policy,
and the policy for product safety, take into consideration
the input provided by customer surveys and regulatory
obligations in Norway, Sweden and Denmark. Additionally,
relevant key resources with knowledge and interests have
been actively involved and consulted in the development of
each policy.
The scope of the group level policies is all group-companies,
including all subsidiaries where the group’s ownership
share is over 50 per cent. In addition, the supplier code of
conduct applies to all suppliers and business partners. These
policies in turn act as guidelines for the development of the
subsidiaries’ own respective policies. The relevant policy
coverage per impact, risk and opportunity is described in
its respective chapter in the sustainability statement. The
following page presents an overview of the main policies
governing the operations of the Komplett Group.
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MAIN POLICIES GOVERNING THE OPERATIONS OF KOMPLETT GROUP
Policy name Purpose Content Approval and responsibility
Code of conduct Ethical guide outlining standards for employees and stakeholders. • Compliance with local and international laws
• Principles: honesty, transparency, and respect
• Addresses environmental responsibility, fair competition, and information security
• Owned by the board of directors
• The group CEO is responsible for implementation and compliance
Corporate
governance policy
Ensures good governance practices, reliable reporting, and compliance. • Regulates roles between shareholders, board of directors, and management
• Sets objectives, means of attainment, and performance monitoring
• Ensures compliance with legislation and regulations
• Owned by the board of directors
• The group CEO is responsible for implementation and compliance
Supplier code of
conduct
Integrates UN Global Compact principles for responsible business
practices in engagement with suppliers.
• Mandates compliance with local laws and international conventions (ILO)
• Emphasises human rights, safe working conditions, and environmental responsibility
• Strict regulations on wages, working hours, forced labour, child labour, and non-discrimination
• Owned by the group CEO
• Group CCO is responsible for implementation and compliance
Anti-corruption and
-bribery policy
Zero-tolerance approach to all forms of corrupt activities. • Prohibits bribery, kickbacks, facilitation payments
• Strict regulations on gifts, hospitality, and entertainment
• Mandatory anti-corruption training and whistleblower reporting
• Owned by group CEO
• Implemented by group CFO
Whistleblower policy Encourages reporting of concerns related to violations of laws and ethics. • Defines whistleblowing and applicable issues, including protection of whistleblowers
• Applies to all employees, business partners, and suppliers
• Reporting through electronic channels or other means
• Owned by group CEO
• Implemented by group CFO
Enterprise risk
management policy
Ensures systematic risk management and contributes to value creation. • Systematic and uniform approach to risk management
• Common understanding of group risks, including sustainability
• Early mapping, analysis, and control of significant risks
• Clarifies roles and responsibilities associated with risk management
• Owned by the board of directors
• The group CEO is responsible for implementation
• The group CFO is responsible for reporting risks to the audit
committee and the board of directors
Continuity and
emergency policy
Ensures a group-wide framework for emergency preparedness, crisis
management, and business continuity within Komplett Group.
• Guidelines for safeguarding people, assets, and operations
• Securing reputation in the event of emergencies, operational disruptions, or external threats.
• Owned by group CEO
• Implemented by group CFO
Privacy policy Ensures that personal data processed within Komplett Group is handled in
a secure and lawful manner.
• Komplett Group shall only process personal data in a lawful, correct, and transparent manner in
relation to the data subjects
• Komplett Group must be able to prove that the fundamental principles of data protection are being
followed
• Owned by group CEO
• Implemented by group CFO
Product safety policy Ensures safety of our customers and compliance with all relevant laws
and regulations.
• Outlines our dedication to product safety and quality assurance and the measures we have put in
place to ensure this commitment
• Komplett Group shall uphold stringent safety standards to ensure that all products listed on our
platforms meet safety and quality requirements
• Owned by group CEO
• Implemented by group CCO
Human resources
policy
A unified framework that aims to maintain a workplace culture that
fosters collaboration, diversity, and innovation.
• Principles and guidelines that ensure consistent, fair, and transparent human resources practices in
all subsidiaries and business units
• Ensuring compliance with relevant labour laws and regulations, including recruitment, onboarding,
performance management, employee wellbeing, and talent development
• Owned by group CEO
• Implemented by group CHRO
Sustainability policy Supports the management of legal requirements and ensures common
action towards the group’s sustainability ambitions.
• Minimise the footprint from our operations and aim to create positive change by enabling a
responsible transition towards net-zero and sustainable production and consumption
• Outlines sustainability management principles and material sustainability topics
• Owned by the board of directors
• The group CEO is responsible for implementation and compliance
Climate and
circularity policy
Covers all environmental IRO’s to guide emission reduction, promoting
circular practices and supporting sustainable operations.
• Reduce GHG emissions and improve resource efficiency
• Align subsidiaries with legal and ESRS sustainability requirements
• Support sustainable business opportunities and risk management
• Guide operational integration of climate and circularity initiatives
• Owned by group CEO
• Implementation is overseen by director of legal & compliance
• Subsidiary managing directors implement locally in business units
Local subsidiary
policies
Supplement group policies with local policies. • Encompass HR, working environment, equality, discrimination, and harassment policies • Local ownership and approval
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APPENDIX 1
KOMPLETT GROUP’S MATERIALITY PROCESS (IRO-1)
In 2025, we revised and strengthened our double materiality
assessment in accordance with the CSRD, using the
same structured process to identify, assess and manage
sustainability-related impacts, risks and opportunities as in
previous reporting periods. The 2025 assessment builds on
analyses from 2023 and 2024 and has been refined to ensure
stronger integration with the group’s ERM framework and
enhanced coverage of upstream and downstream activities.
The results of the double materiality assessment are
integrated into Komplett Group’s enterprise-wide risk
management. Sustainability matters are evaluated using
the same risk criteria and governance procedures as other
significant business risks. Identified impacts, risks and
opportunities are reported to group management and
reviewed by the board of directors and the audit committee,
ensuring that findings from the assessment directly inform
the group’s strategy, policies and target setting.
Sustainability-related opportunities are evaluated using
the same time horizons and criteria as impacts and
risks. Opportunities with strategic relevance, such as
circular business models, low-carbon sourcing, product
innovation or operational efficiencies, are integrated into
Komplett Group’s management processes. This includes
incorporation into strategic planning, business-unit target
setting, investment considerations and annual priority-
setting. Progress on key opportunities is monitored
through established management reporting and forms
part of the regular dialogue between business units, group
management and the board.
We are currently reviewing our internal control procedures
to further include sustainability reporting within the scope
of internal control over non-financial data.
The assessment follows a four-step approach — Understand,
Identify, Evaluate and Decide, – which is aligned with
Komplett Group’s risk-management cycle and endorsed by
group management and the board of directors.
OUR MATERIALITY ASSESSMENT IS
CONDUCTED IN FOUR STEPS
1. Understand
• Understand the context including business
model, relationships, and value chain
2. Identify
• Collect information from internal and
external sources
• Identify impacts, risks and opportunities
(IROs)
3. Evaluate
• Score topics
• Define the final list of material matters
4. Decide
• Determine threshold values
• Verification and approval by group manage-
ment and endorsement by board of directors
1. Understand
By conducting a double-materiality assessment, Komplett
Group identifies and evaluates sustainability matters
relevant to the group’s operations and to stakeholder
expectations. This process examines both impact
materiality, that is how the group affects the environment
and society, and financial materiality which relates to how
environmental, social and governance factors may influence
the group’s financial position, performance or cash flows.
Interlinkages between impacts and financial dependencies
are mapped to understand how sustainability matters create
or mitigate financial risks and opportunities.
The process starts with a mapping of Komplett Group’s
business model, activities and value chain, including
upstream and downstream relationships as described in
SBM-1. Special attention is given to heightened risk areas,
both by geography and industry, such as operations in
China and mining sites in African countries, in addition to
exposed industries like cleaning and transportation. The
scope covers the parent company and all subsidiaries and
considers entity-specific factors when relevant. The project
team includes representatives from group management,
subsidiaries and key functions such as legal & compliance,
finance, HR and procurement. Its aim is to develop a shared
understanding of potential environmental, social and
governance topics that may be connected to the group’s
activities.
2. Identify
Potential impacts, risks and opportunities are identified
through analyses of internal reports, policies and data,
combined with workshops and interviews with both
internal and external stakeholders. Information sources
include HR systems, sales and revenue monitoring tools,
procurement and supplier-assessment data, as well as
external studies and sector benchmarks. Quantitative data
are complemented by qualitative insights from stakeholder
dialogues and expert judgement.
Based on the existing stakeholder analysis, the previous
materiality assessments, a review of Komplett Group’s value
chain and business models, and a mapping of IROs identified
by recognised frameworks such as the Sustainability
Accounting Standards Board (SASB). We started with
a top-down list of potential material sub-topics, which
were then analysed and refined through workshops and
documentation review. This structured approach resulted
in a comprehensive list of potential sustainability matters at
topic, sub-topic and sub-sub-topic level, forming the basis
for the subsequent evaluation phase.
Each identified topic is linked to one or more ESRS topical
standards (E, S and G). The identification phase also includes
an initial screening of potential IROs across the full value
chain to determine their relevance and the level at which
they may occur – whether in our own operations, upstream
supply chain or downstream use phase.
The process applies both qualitative and quantitative criteria
to prioritise which matters proceed to evaluation, taking
into account the scale, scope and irremediable character
of actual or potential impacts, the likelihood of occurrence,
and the potential financial magnitude, covering profitability,
reputation and compliance dimensions.
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3. Evaluate
The purpose of the evaluation phase is to determine which
impacts, risks and opportunities are material for Komplett
Group. The assessment applies both quantitative and
qualitative criteria to ensure that identified matters are
consistently prioritised and comparable across business
units.
When evaluating material impacts, risks and opportunities,
Komplett Group applies the same time horizons as defined
for the group’s sustainability and financial reporting in BP-2.
The short-term horizon covers the next annual reporting
period, the medium-term extends up to five years, and the
long-term extends beyond five years. These horizons are
applied consistently across our materiality assessment, risk
management and strategy processes to ensure alignment
between financial and sustainability-related planning.
Each impact is assessed according to its severity—which
considers the scale, scope and irremediable character of the
impact—and its likelihood. For the qualitative assessment,
Komplett Group considers 1) the direction of the impact
(negative or positive), 2) the type of impact (negative,
positive), 3) the time horizon (short, medium or long term),
and 4) whether the impact has a negative effect on human
rights. The combination of these factors determines the
overall materiality of the impact. Potential and actual
impacts are scored on a scale from 1 to 5, aligned with the
risk methodology applied in the group’s enterprise risk
management (ERM) framework. The assessment is based
on an inherent impact level. Hence, it does not consider
any implemented mitigating actions. For actual impacts,
the likelihood score is set to 5 as the impact has already
occurred.
Financial materiality is assessed by evaluating how
sustainability-related matters may influence the group’s
financial position, performance or cash flows, either directly
or indirectly. The evaluation considers potential magnitude
of financial effects, covering profitability, reputation
and compliance dimensions, together with probability
of occurrence. Thresholds and risk-scoring criteria are
consistent with those used in Komplett Group’s ERM
framework, ensuring integration between sustainability and
broader risk management.
How grave is the impact?
How positive/beneficial
is the impact?
1 = signs of impact
5 = large impact
How grave is the
potential financial
impact?
1 = < NOK 5 million
5 = > NOK 25 million
How widespread will
the impact be on the
population and economies
of affected ecosystems?
1 = few
5 = global
How grave is the
potential reputational
impact?
1 = regional/local no loss in
clients/relationships
5 = national, severe loss
in clients/relationships
How hard is it to counteract
or rectify the negative
impact?
1 = easy and
immediate
5 = irreparable
How grave is the
potential compliance
impact?
1 = limited non-compliance
5 = very significant
non-compliance,
large consequences
What is the likelihood that the
impact occurs?
When will it occur?
*
1 = < 5% every 20 years
5 = > 90% every year
or more/actual
What is the likelihood
that the impact occurs?
When will it occur?
1 = < 5% every 20 years
5 = > 90% every year
or more/actual
SCALE OF
IMPACT
FINANCIAL
IMPACT
SCOPE OF
IMPACT
REPUTATIONAL
IMPACT
IMPACT IS OCCURING
(only accounts for those
with negative impact)
COMPLIANCE
IMPACT
LIKELIHOOD
LIKELIHOOD
SCORE OF
IMPACT
SCORE OF
FINANCIAL IMPACT
and/or
IMPACT IS OCCURING
and/or
*
Note that if there is a question of a potential violation of human rights, the
degree of severity will be emphasised more than the likelihood.
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KOMPLETT GROUP RISK AND OPPORTUNITY ASSESSMENT MATRIX
Very low = 1 Low = 2 Medium = 3 High = 4 Very high = 5
Financial Negative/positive effect P&L
(profit after tax).
Negative/positive effect P&L
(profit after tax).
Negative/positive effect P&L
(profit after tax).
Negative/positive effect P&L
(profit after tax).
Negative/positive effect P&L
(profit after tax).
Reputation (risks) Individual cases of negative
publicity in regional and/or local
media. Not resulting in loss of
clients or relationships.
Some negative publicity in
regional and/or local media. May
result in loss of some clients or
relationships.
Moderate negative publicity
in national and/or local
media. May result in the loss
of some important clients or
opportunities.
Significant and repetitive
negative publicity in national and/
or regional media. May result in
loss of important clients.
Very significant and repetitive
negative publicity in national
media. May result in severe loss
of clients or preventing new
relations.
Reputation (opportunity) Individual cases of positive
publicity in regional and/or local
media.
Some positive publicity in
regional and/or local media.
Moderate positive publicity in
national and/or regional media.
Significant and repetitive positive
publicity in national and/or
regional media.
Very significant and repetitive
positive publicity in national
media.
Compliance Limited non-compliance and
weaknesses related to external or
internal laws/regulations.
No legal penalties but an internal
warning to the involved.
Smaller non-compliance and
weaknesses related to external or
internal laws/regulations.
Low level of fraud, corruption,
etc., with serious consequences
for the involved.
Moderate non-compliance and
weaknesses related to external or
internal laws/regulations.
Moderate fraud, corruption etc.
with serious consequences for
the involved.
Significant non- compliance and
weaknesses related to external or
internal laws/ regulations.
Significant fraud, corruption,
etc., with consequences for
management.
Very significant non- compliance
and weaknesses related to
external or internal laws/
regulations.
Very significant fraud, corruption,
etc., with consequences for board
of directors or management.
Likelihood < 5% likelihood that event will
occur (less than once every 20
years).
5%-40% likelihood that the event
will occur. Event may occur within
the next 10-20 years.
40%-60% likelihood that the
event will occur. Event may occur
within the next 5-10 years.
60%- 90% likelihood that the
event will occur. Event may occur
within the next 1-5 years.
> 90% likelihood that the event
will occur. Event may occur every
year or more.
Scoring-matrix for financial effects based on the effect dimensions and probability of occurrence.
FINANCIAL
MATERIALITY
IMPACT
MATERIALITY
NEGATIVE IMPACT ON
HUMAN RIGHTS (POTENTIAL)
High – material for reporting
The topic is both strategically
important and material for reporting
Medium – not material for reporting
The topic may be material for future
reporting and should be monitored
Low – not material for reporting
The topic is considered non-
material for Komplett’s sustainability
reporting material for reporting
The evaluation process combines internal and external
data sources, management judgement and stakeholder
perspectives. The results are reviewed and validated by
group management and the sustainability manager before
being submitted to the board for approval as part of the
double materiality assessment.
4. Decide
The final step of the assessment process is to determine
which impacts, risks and opportunities are material for
reporting. This step is based on the scoring results and
qualitative evaluations from the previous phases.
Thresholds for impact materiality, financial materiality
and potential negative impacts on human rights are
established in line with EFRAG’s implementation guidance
and Komplett Group’s ERM methodology. These thresholds
guide the decision of which matters are deemed material for
disclosure and for internal management focus. Thresholds
for (potentially) negative impacts on human rights deviate
from impact materiality to emphasise that the severity of
the negative impact on human rights takes precedence over
likelihood of occurrence.
Discussions to agree on thresholds and final classifications
are facilitated with representatives from group
management, sustainability, legal and finance functions to
ensure that material sustainability matters are assessed
consistently with financial and operational risks. The results
of this process are presented to the group management for
review and subsequently to the board of directors and the
audit committee for final consideration.
To strengthen governance, the double materiality
assessment will be reviewed at least every second year, or
more frequently if significant changes occur in the group’s
operations, value chain or regulatory environment.
LIKELIHOODLIKELIHOOD LIKELIHOOD
FINANCIAL EFFECT
SEVERITY
SEVERITY
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APPENDIX 2
DISCLOSURE REQUIREMENTS (IRO-2)
Data points derive from other EU legislation
DATA POINTS DERIVE FROM OTHER EU LEGISLATION
Disclosure
requirement DP Description Legislation Page
ESRS 2, GOV 1 21(d) Board’s gender diversity SFDR/BRR
42
21(e) Percentage of board members who are independent BRR
42
ESRS 2, GOV 4 30 Statement on due diligence SFDR
43
ESRS 2, SBM 1 40(d)(i) Involvement in activities related to fossil fuel activities SFDR/P3/BRR NR
40(d)(ii) Involvement in activities related to chemical production SFDR/BRR NR
40(d)(iii) Involvement in activities related to controversial weapons SFDR/BRR NR
40(d)(iv) Involvement in activities related to cultivation and production of tobacco BRR NR
ESRS E1 1 14 Transition plan to reach climate neutrality by 2050 EUCL NS
16(g) Undertakings excluded from Paris aligned benchmarks P3/BRR NR
ESRS E1 4 34 GHG emission reduction targets SFDR/P3/BRR NS
ESRS E1 5 38 Energy consumption from fossil sources disaggregated by sources (only high
climate impact sectors)
SFDR
65
37 Energy consumption and mix SFDR
65
40-43 Energy intensity associated with activities in high climate impact sectors SFDR
66
ESRS E1 6 44 Gross Scope 1, 2, 3, and total GHG emissions SFDR/P3/BRR
67
53-55 Gross GHG emissions intensity SFDR/P3/BRR
67
ESRS E1 7 56 GHG removals and carbon credits EUCL NR
ESRS E1 9 86 Exposure of the benchmark portfolio to climate related physical risks BRR NR
ESRS E2 4 28 Amount of each pollutant listed in Annex 1 of the E PRTR regulation emitted to
air, water and soil
SFDR NM
ESRS E5 5 37(d) Non recycled waste SFDR
80
ESRS E5 1 39 Hazardous waste and radioactive waste SFDR
80
ESRS S1, SBM 3 14(f) Risk of incidents of forced labour SFDR
81
ESRS S1 21 17 Human rights policy commitments SFDR
56
ESRS S1 17 103(a) Incidents of discrimination SFDR
85
ESRS S2 2 104(a) Non respect of UNGPs on Business & Human Rights, ILO principles,
or OECD guidelines
SFDR/BRR NM
Disclosure
requirement DP Description Legislation Page
ESRS S2, SBM 3 11(b) Significant risk of child labour or forced labour in the value chain SFDR
54
ESRS S2 1 7 Human rights policy commitments SFDR NM
ESRS S2 1 11 Policies related to value chain workers SFDR NM
ESRS S2 4 14 Non respect of UNGPs on Business & Human Rights, ILO principles, or OECD
guidelines
SFDR/BRR NM
ESRS S4 1 35 Due diligence policies on issues addressed by the International Labour
Organisation Conventions 1 to 8
SFDR NM
ESRS S4 4 17 Human rights issues and incidents connected to its upstream and downstream
value chain
SFDR NM
ESRS G1 5 11 Non respect of UNGPs on Business & Human Rights and OECD guidelines SFDR/BRR NM
ESRS G1 6 20 Human rights issues and incidents SFDR NR
ESRS G1 1 10(b) United Nations Convention against Corruption SFDR
86
ESRS G1 7 40 Protection of whistleblowers SFDR NM
ESRS G1 4 24(a) Fines for violation of anti corruption and anti bribery laws SFDR/BRR NM
ESRS G1 4 24(b) Standards of anti corruption and anti bribery SFDR NM
List of disclosures of ESRS data points from other EU legislations.
EXPLANATIONS FOR THE TABLE ABOVE
Legislations:
SFDR: Sustainable Finance Disclosure Regulation
P3: EBA Pillar 3 disclosure requirements
BRR: Climate Benchmark Standards Regulation
EUCL: EU Climate Law
Abbreviations:
NR: Not relevant
NS: Not stated
NM: Not material
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APPENDIX 3
ESRS DISCLOSURE REQUIREMENTS INDEX
Topic Page
General information
About the report ESRS 2 BP-1, BP-2
38-40
Sustainability governance ESRS 2 GOV-1, GOV-2, GOV-3, GOV-4, GOV-5
41-44
Sustainable strategy and business model ESRS 2 SBM-1
45-49
Stakeholder engagement ESRS 2 SBM-2
50-52
Komplett Group’s material impacts, risks and opportunities ESRS 2 SBM-3
53-55
Komplett Group’s materiality process ESRS 2 IRO-1
58-60
Disclosure requirements ESRS 2 IRO-2
61
Embedding sustainability in our policies and processes ESRS 2 MDR-P
56-57
Environmental information
Climate change
63
Transition plan for climate change mitigation ESRS E1 E1-1
63
Resilience analysis ESRS E1 E1.SBM-3
63-64
Impacts, risks and opportunities ESRS E1 E1.IRO-1
63-64
Policies related to climate change mitigation ESRS E1 MDR-P §62
64
Taking action ESRS E1 MDR-A §62
64-65
Targets and metrics related to climate change ESRS E1 MDR-T §§72, 81
65
Energy consumption and mix ESRS E1 E1-5
65-66
Komplett Group’s GHG-accounts ESRS E1 E1.BP-2, E1-6
66-70
EU taxonomy
71
Resource use and circular economy
76
Policies related to resource use and circular economy ESRS E5 MDR-P §62
76
Resource inflows, resource outflows and waste ESRS E5 E5.IRO-1
76
Actions and efforts to increase circularity in Komplett Group ESRS E5 MDR-A §62
76-77
Tracking effectiveness of policies and actions through targets ESRS E5 MDR-T §§72, 81
77
Resource inflows ESRS E5 E5-4
77-78
Resource outflows ESRS E5 E5-5, E5.BP-2
78-79
Topic Page
Social information
Own workforce
80
Integrating material matters into our strategy and business model ESRS S1 S1.SBM-3
80
Policies related to own workforce ESRS S1 S1-1, MDR-P
80
Processes for engaging with own workforce and workers’ representatives ESRS S1 S1-2
81
Processes to remediate negative impacts and channels for employees to raise concern ESRS S1 S1-3
81
Taking action ESRS S1 S1-4, MDR-A
81-82
Tracking effectiveness of policies and actions through targets ESRS S1 S1-5, MDR-T
82-83
Characteristics of our employees ESRS S1 S1-6
83
Diversity metrics ESRS S1 S1-9
83
Incidents, complaints and severe human rights impacts ESRS S1 S1-17
84
Governance information
Business conduct
85
The role of the administrative, management and supervisory bodies ESRS G1 G1.GOV-1
85
Business conduct policies and corporate culture ESRS G1 G1-1, MDR-P, MDR-A §62
85
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ENVIRONMENTAL INFORMATION
Komplett Group is committed to reducing our environmental footprint and supporting
the transition to a more resource-efficient and low-carbon economy. Climate change and
circular economy are our material environmental topics, and we work across our value chain
to reduce emissions and strengthen circular practices.
Material ESRS topics
Material ESRS
sub-topics Part of the vale chain where impact was material
Impact
materiality
Financial
materiality
E1: Climate change Energy Upstream Own operations Downstream High Medium
Climate change
mitigation
Upstream Own operations Downstream High Medium
CLIMATE CHANGE
TRANSITION FOR CLIMATE CHANGE MITIGATION (E1-1)
Komplett Group does not yet have a formally adopted
transition plan for climate change mitigation. A transition
plan is under development, with the objective of being
completed and operational by the end of 2026.
The transition plan process is structured in several phases
during 2025 and 2026 to ensure a robust and data-driven
outcome. During 2025, the group has completed the quality
assurance of our greenhouse-gas inventory. This provides
a reliable baseline for the forthcoming plan. Growth and
projec tion analyses have been carried out to assess expect-
ed future emissions under a business-as-usual scenario.
In early 2026, the work will focus on identifying and evalua-
ting potential emission-reduction measures in terms of
impact and feasibility. The definition of specific climate
targets is planned for subsequent stages and will be
anchored in the group’s overall strategy and ambition level.
Based on the measure analysis and the resulting climate-
reduction targets, the final stage of the process will include
the development of a detailed action plan that consolidates
and prioritises measures, defines responsibilities, and
establishes a clear timeline for implementation. This
structured approach ensures that our transition plan will be
finalised and ready for board approval by the end of 2026.
When completed, the plan will outline how Komplett Group
aligns our decarbonisation pathway with the objectives
of the Paris Agreement and the EU Climate Law, aiming to
contribute to limiting global warming to 1.5 °C.
CLIMATE RESILIENCE, IMPACTS, RISKS AND
OPPORTUNITIES (E1.SBM-3)(E.1-IRO-1)
Analytical framework and process
In our updated double materiality analysis for 2025, Komplett
Group strengthened the group’s analytical framework
regarding climate-related risks through an extensive climate
scenario analysis. Additionally, we conducted a resilience
analysis based on the findings from our updated materiality
assessment. This work, conducted in 2025, builds on the
Intergovernmental Panel on Climate Change (IPCC) and
Network for Greening the Financial System (NGFS) pathways
and forms part of our enterprise risk management.
We identify and assess climate-related impacts, risks and
opportunities, together with the resilience of our business
model through a structured process combining double
materiality analysis with scenario-based modelling across
three ESRS-aligned time horizons: short-term (2020–2039),
medium-term (2040–2059), and long-term (2080–2099).
Longer horizons to 2100 capture structural climate
transitions and provide the foundation for our resilience
analysis.
Oversight of the process rests with the board, group CEO,
and group CFO, ensuring that identified climate-related
issues are embedded into strategic planning and financial
decision-making.
Scope and boundaries of the resilience analysis
The climate resilience analysis covers our Nordic operations
(Sandefjord and Borås), key upstream supplier regions in
Guangdong and Jiangsu (China), and downstream distri-
bution in the Nordics. Both acute and chronic physical risks,
and transition risks, are included across the value chain.
Excluded are non-material supplier relationships outside
these regions and immaterial downstream sales channels,
based on proportionality from a preliminary risk assessment
showing negligible risk compared to identified hotspots. No
material physical or transition risks have been excluded from
the analysis.
Critical assumptions and scenario design
Key assumptions include a gradual tightening of global
and EU climate policies (carbon pricing, stricter product
standards, extended producer responsibility), increasing
renewable energy demand, and accelerating circular-
economy and energy-efficient technologies. Macroeconomic
assumptions reflect stable long-term GDP growth in the
Nordics, continued manufacturing reliance on China, and
energy price volatility as a major driver.
The analysis applies IPCC SSP1-2.6 (low-emission transition)
and SSP5-8.5 (high-emission physical risk) scenarios,
complemented by the NGFS Net Zero 2050 pathway,
ensuring a full range of plausible futures. Region-specific
datasets for Northern Europe and supplier regions in China
capture local hazards and market transitions. We evaluate
the risks identified through the scenario analysis against the
resilience of our business model, considering the relevant
resources and all activities as outlined in MDR-A §62. We
further assess the potential mitigating actions required to
ensure strategic alignment and long-term resilience.
Climate impacts
We regularly screen our operations and value chain to
identify actual and potential sources of greenhouse gas
emissions. Our most significant emissions occur upstream
in the production of goods for resale, notably plastics,
aluminium, lithium, and other metals. Transportation and
logistics represent the second-largest source, while energy
use in warehouses, offices, stores, and Ironstone cloud
services constitutes the third.
These findings inform our mitigation strategies, supplier
engagement, circular-economy measures, and low-emission
logistics, and directly link to E1-6 (GHG inventory) for
transition planning.
OVERVIEW OF CLIMATE-RELATED RISKS AND
OPPORTUNITIES
Physical risks
Physical risks are identified using high-emission scenarios
(SSP5-8.5). Key hazards include flooding, heat stress,
storms, water stress, and sea-level rise. In the Nordic
region, warehouses and distribution centres face moderate
exposure to heat and water stress, with rainfall extremes
projected to rise in a 2 °C scenario in the long-term scenario.
Shops and offices, being leased, are considered low
exposure assets. Suppliers in Guangdong and Jiangsu face
higher short-term exposure to flooding, storms, and heat
stress, creating the most significant physical risks in our
value chain.
Critical raw materials such as copper and lithium remain
vulnerable in a long-term scenario, as global production is
concentrated in regions with high water stress, potentially
increasing supply shortages and costs.
Transition risks and opportunities
Transition risks and opportunities are assessed using
1.5°C-aligned scenarios (SSP1-2.6, NGFS Net Zero 2050).
Key risks include carbon pricing, stricter product standards,
extended producer responsibility requirements, energy
price volatility, and increasing supply-chain transparency
obligations.
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While no risks reached materiality thresholds in 2025 on
a short-term basis, adverse scenarios indicate potential
financial effects above NOK 25 million in a long-term
perspective. The transition offers growth in circular
services, demand for sustainable logistics, renewable
energy sourcing for Ironstone, and efficiency gains in cloud
solutions.
Komplett Group holds no material assets locked into
high-emission pathways. No assets were identified as
incompatible with, or requiring significant effort to align
with, a climate-neutral economy.
Results of the resilience and scenario analysis
The resilience analysis confirms that transition risks such
as evolving regulation, product standards and customer
expectations are increasing in significance, but also
generate opportunities for circular solutions and sustainable
products. Physical risks remain moderate in Northern
Europe but represent higher short-term challenges for
Chinese suppliers due to flooding and heat stress.
All identified material assets and activities at risk are
captured within our strategic and investment planning
frameworks. Based on current climate scenarios and
assumptions, our strategy and business model are assessed
to remain resilient under both low- and high-emission
pathways across all scenario horizons.
Financial assessment and uncertainties
Each risk has been evaluated against financial materiality
thresholds (NOK 5–25 million impact on profit after tax)
and likelihood categories. Transition risks, such as carbon
pricing and supply-chain transparency, may exceed NOK 25
million in high-probability scenarios, while physical risks in
Guangdong and Jiangsu could create significant disruption
costs.
Quantitative precision is limited by uncertainties in
global climate policy and technology trends, but these
uncertainties are integrated into risk management and
investment planning.
> For more information about our financial position,
performance and cash flows, see financial statements
Adaptation capacity and strategic response
Komplett Group has multiple levers to adapt to climate risks
across the short, medium and long term:
X Maintaining access to affordable financing through
credible climate action.
X Redeploying and upgrading logistics assets in the
Nordics and adjusting sourcing in Asia if risk levels
increase.
X Expanding circular services and aligning the product
portfolio with regulatory and market shifts.
X Re-skilling the workforce through group-wide
sustainability training
Our adaptation capacity is underpinned by a flexible
e-commerce business model, low capital intensity, and
scalable logistics infrastructure. This enables rapid asset
redeployment, portfolio shifts towards energy-efficient
products, and continued access to financing at competitive
rates.
To support implementation, we appointed a dedicated
sustainability manager in 2024, and integrated climate
resilience into enterprise risk management in 2025.
Our board, group CEO, and group CFO have completed
sustainability training and actively shaped our strategy
review process.
Uncertainties and continuous monitoring
The resilience assessment involves inherent uncertainty
due to evolving climate policies, technological advances
and supply-chain dependencies. We continue to monitor
regulatory, market and physical developments to ensure our
strategy remains aligned with long-term value creation and
climate-neutral objectives.
CLIMATE RISKS
TRANSITION RISKS PHYSICAL RISKS
• Policy and legal • Acute
• Technology • Chronic
• Market
• Reputation
> For more information about our processes to identify
and assess material climate-related impacts, risks and
opportunities, see ESRS 2 IRO-1
POLICIES RELATED TO CLIMATE CHANGE MITIGATION (E1-2)
At Komplett Group, we manage our material climate-related
impacts, risks and opportunities through our climate and
circularity policy, adopted in 2025. The policy applies to
all subsidiaries where Komplett Group holds more than 50
per cent ownership and sets out principles for responsible
resource use, greenhouse-gas reduction, and the transition
to circular business models.
The climate and circularity policy forms part of the group’s
overarching sustainability framework and ensures that all
relevant impacts, risks and opportunities related to climate
change mitigation are addressed. Climate change adaptation
has been assessed but is currently not considered material
for Komplett Group.
> For more details about key contents and scope of the
policies, see ESRS 2 MDR-P
The policy defines expectations for managing greenhouse-
gas emissions and transition risks across the value chain. It
promotes emission reduction, sustainable logistics, product
reuse and repair, responsible sourcing, and improved
packaging efficiency. These objectives are reinforced by
supporting group-wide documents such as the business-
continuity policy, supplier code of conduct, HR policy
and product-safety policy, which together strengthen
responsible practices across operations and procurement.
Energy efficiency and renewable energy are integral parts
of the policy. Warehouse automation, logistics optimisation
and reduced packaging volumes contribute to lower energy
use and emissions.
Implementation and monitoring are overseen by the group
CFO and the director legal & compliance, ensuring alignment
with the group’s sustainability strategy and enterprise-risk-
management framework.
TAKING ACTION (MDR-A §62)
Komplett Group is continuously working to develop and
further our actions on climate change mitigation and energy
use. We have not yet adopted formalised actions as defined
under the ESRS, as the group is currently in the process of
developing a transition plan to be finalised by the end of
2026. The decision to defer full disclosure reflects our focus
on improving data quality and establishing a robust baseline
for future emission-reduction measures.
Nevertheless, we are implementing a range of activities
that support emission reduction and prepare the ground for
future ESRS-defined actions. These include initiatives to
reduce energy consumption, support sustainable customer
choices, and improve logistics efficiency.
Energy consumption
We monitor energy use across stores and warehouses and
map consumption per square metre. All new stores are fitted
with LED lighting, and existing stores are being gradually
upgraded. Energy-efficiency initiatives are coordinated
under the climate and circularity policy and managed by the
operations and facility teams in the business units.
Sustainable customer choices
We aim to enable sustainable consumption by offering
durable, repairable and recyclable products, and by
RESULTS SUMMARY TABLE
Risk/Opportunity Possible resilience measures
Regulatory changes (emissions, energy standards, carbon pricing,
reporting, supply-chain transparency)
Monitor evolving regulations, strengthen compliance and supplier
engagement, source from low-emission suppliers.
Circularity and e-waste regulations Expand repair/reuse services, improve lifecycle management,
adapt product portfolio.
Technological change and energy efficiency requirements Strengthening innovation and technology partnerships.
Market expectations for sustainable products Enhance sustainability branding, expand circular offerings,
maintain model flexibility.
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communicating sustainability parameters to help customers
make informed decisions. We also work closely with
suppliers to encourage sustainable product development
and packaging solutions.
Collaboration with delivery suppliers
Transport logistics account for a significant share of
Komplett Group’s emissions. We collaborate with several
transport providers in Norway, Sweden and Denmark
to develop joint solutions for reducing emissions. Key
measures include biodiesel use, route optimisation, and
improved packaging efficiency to reduce the number of
shipments.
Sustainable transportation
To improve operational efficiency and reduce the need for
plastic packaging, Komplett Services invested in a new
packaging line in Sandefjord in 2022. The new packaging
line enables better-adapted cardboard packaging, resulting
in more efficient use of transport capacity and a reduced
need to transport empty space, thereby supporting lower
transport demand and associated emissions.
Through participation in the industry initiative Fossil-Free
Deliveries led by Svensk Handel, NetOnNet makes it easier
for customers to select fossil-free shipping options, which
are displayed at the top of checkout alternatives.
Reducing customer returns
The return rate within e-commerce has climate implications.
Komplett Group strives to minimise returns by ensuring
correct product information and quality.
CUSTOMER PRODUCT RETURN
2025 2024 2023 2022
Komplett 2.4% 2.6% 2.4% 2.1%
Webhallen 4.8% 4.3% 4.2% 4.6%
NetOnNet 3.4% 3.7% 3.9% 3.6%
Product return rate is measured as the number of items returned by customers
divided by the total number of items sold.
The rate is measured as the number of items returned
divided by total items sold, covering both B2B and B2C
transactions.
Resources and timeframe
Resources for climate-related activities are embedded in
operational budgets and primarily allocated to sustainability,
logistics and procurement functions. Capital expenditure
relates mainly to energy-efficiency investments, while
operating resources include personnel time and analytical
work. Dedicated resource allocations will be formalised once
the transition plan is completed in 2026.
TARGETS AND METRICS RELATED TO CLIMATE CHANGE
(MDR-T §§72, 81)
Komplett Group has not yet established ESRS-defined
measurable, outcome-oriented targets related to climate
change. This is primarily due to the ongoing development
of the group’s transition plan and to remaining challenges
in obtaining sufficiently accurate and reliable data for
meaningful target-setting. We aim to finalise and disclose
such targets as part of the transition plan by the end of
2026.
The effectiveness of our policies and actions is nevertheless
monitored through analysis of all material climate-related
impacts, risks, and opportunities. At present, progress
is evaluated mainly through qualitative assessments and
process indicators rather than quantitative targets. We have
not yet defined a specific level of ambition or numerical
key performance indicators, but performance trends are
discussed annually with the group CFO and director legal &
compliance as part of sustainability follow-up.
Despite not disclosing specific ESRS-defined target, we
maintain strategic climate goals and long-term focus areas.
Our overarching ambition is to achieve climate neutrality by
2040, and we are working towards a verified transition plan
by 2026 that will include measurable milestones, including
an interim goal of reducing Scope 1 and 2 emissions by 42
per cent by 2030.
2024 is applied as the common baseline year for all scopes.
This reflects the enhanced emission reporting established
in 2024, which provided a more complete and consistent
emissions inventory across all scopes. 2024 is applied
as the common baseline year for all scopes. This reflects
the enhanced emission reporting established in 2024,
which provided a more complete and consistent emissions
inventory across all scopes. As data accuracy improves,
the transition plan will re-evaluate all milestones and goals
to ensure alignment with verified GHG inventories and
methodological consistency.
ENERGY CONSUMPTION AND MIX (E1-5)
Komplett Group’s operations involve the consumption
of energy through electricity, district heating and
transportation, contributing primarily to Scope 2 emissions.
Our ambition is to reduce energy consumption and increase
the share of renewable energy sources across all sites. By
continuously implementing new processes and technologies
aimed at improving energy efficiency and reducing our
overall energy footprint, Komplett Group takes measurable
steps each year toward this ambition. These include, among
others, replacing lighting systems with LED, optimising
warehouse operations, reducing reliance on fossil fuel
transport, and increasing purchases of fossil-free electricity.
Renewable electricity
NetOnNet and Webhallen aim to use green electricity in
all properties where they can choose their supplier. LED-
lighting is installed in all NetOnNet stores in Sweden, and the
transition is ongoing for stores in Norway. Komplett Services
purchases electricity from rooftop solar panels, which
covers part of the energy needed to run one of the group’s
two central warehouses. Most of this energy was consumed
locally in the warehouse; surplus production is exported to
the grid.
Energy-efficient products
The growing energy use associated with technology globally
creates an opportunity for Komplett Group to influence
customers by promoting energy-efficient products. Demand
for energy-saving solutions is expected to rise, and this will
be reflected in our product assortment and in new online
filters that allow customers to sort by energy efficiency.
As high-climate impact sectors are associated with
activities described in NACE codes A through H, Komplett
Group generates revenue from:
X NACE code G.46.5 Wholesale of information and
communication equipment
ENERGY CONSUMPTION AND MIX
2025 2024
(1) Fuel consumption form coal and coal products (MWh) - -
(2) Fuel consumption from crude oil and petroleum products (MWh) 137 191
(3) Fuel consumption from natural gas (MWh) - -
(4) Fuel consumption from other fossil sources (MWh) - -
(5) Consumption of purchased or acquired electricity, heat, steam, and cooling from fossil sources (MWh) 4 878 5 067
(6) Total fossil energy consumption (MWh) 5 015 5 259
Share of fossil sources in total energy consumption (%) 28.7% 30.0%
(7) Fuel consumption from nuclear sources (MWh) 3 154 763
Share of consumption from nuclear sources in total energy consumption (%) 18.0% 4.3%
(8) Fuel consumption for renewable sources, including biomass (MWh) - 12
(9) Consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources (MWh) 9 312 11 521
(10) The consumption of self-generated non-fuel renewable energy (MWh)
1)
0 0
(11) Total renewable energy consumption (MWh) 9 312 11 533
Share of renewable sources in total energy consumption (%) 53.3% 65.7%
Total energy consumption (MWh) 17 481 17 554
1)
We are not able to identify share of energy production consumed by Komplett Group. Solar panels are installed on the rooftop of a storage building rented by
Komplett Services. The energy produced by the solar panel is consumed by Komplett Services and other tenants renting offices in the same building. In 2025,
364MWh were produced, most of it probably consumed by Komplett Group. The produced energy not consumed by Komplett Group or the other tenants, is
automatically transferred to the grid and sold.
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(CO
2
e) using the IPCC’s AR6 global warming potential (GWP)
method. High-quality, activity-based data is prioritised for
Scope 1 emissions, such as fuel consumption and refrigerant
leaks.
The emission factors used for calculating Scope 1 emissions
are retrieved from DEFRA (2025). Scope 2 emissions are
calculated using both the location-based and market-based
methods.
Scope 3 emissions are calculated data from our partners,
within transport of goods to our customers and business
travels, but they are also estimated using financial and
sales data, combined with external averages and industry
standards. For categories like commuting and waste, we
rely on geospatial analysis and external statistics to ensure
reasonable estimates where direct data is unavailable.
Emission factors used to calculate Scope 3 emissions are
further described in the table “Scope 3 categories”.
The list of climate impact of Komplett Group within Scope 3
comes from the following inventory categories, as defined by
the GHG protocol:
X Category 1
Purchased goods and services
X Category 2
Capital goods
X Category 3
Fuel and energy distribution
X Category 4
Upstream transport
X Category 5
Waste
X Category 6
Business travel
X Category 7
Employee travel
X Category 11
Use of sold products
X Category 12
End-of-life treatment
We exclude certain Scope 3 categories due to their minimal
impact or irrelevance to our business model. Upstream
leased assets, downstream leased assets, processing of sold
products, franchises, and investments are deemed non-
relevant.
> For more information about external validation of metrics,
see ESRS2 BP-2
KOMPLETT GROUP’S GHG ACCOUNTS (E1-6)
Disclosure of metrics estimated using indirect sources
(BP-2)
Komplett Group’s GHG emissions metrics include value chain
data estimated using indirect sources where direct data is
unavailable. Scope 1 and Scope 2 emissions are calculated
using activity-based data, with Scope 3 emissions estimated
using financial and sales data, partner data, external
averages, and industry standards. Emission factors are
derived from suppliers, external parties, and LCAs, with all
greenhouse gases converted into CO
2
eq using the IPCC AR6
GWP method.
The metrics’ accuracy varies depending on data sources,
with Scope 1 and Scope 2 emissions being highly accurate
due to direct measurements, while Scope 3 estimates,
particularly for commuting and waste, are moderate due to
reliance on proxies and indirect data. Fugitive emissions are
included in our Scope 1 from 2024 and onwards.
There have been no significant changes to the definition
of Komplett Group’s reporting legal entities or our value
chain that affect the year-to-year comparability of reported
GHG emissions. Our climate report is based on both the
financial control and operational control approaches in
accordance with the ESRS. According to the ESRS, we apply
the financial control approach, which means we include both
the parent company and any subsidiaries consolidated in the
accounting group. Financial assets not consolidated into the
group are included when the group has operational control.
For Komplett Group, this means that all buildings, vehicles,
and equipment used in daily operations are included in
Scope 1 and 2, even if they are not necessarily owned by the
group. The group does not own any assets that it does not
fully control.
We calculate our GHG emissions in accordance with
the GHG Protocol Corporate Standard and ESRS E1. The
methodologies used include activity- based and spend-
based approaches, depending on the precision and
availability of data. Our emissions factors are sourced from
suppliers, external parties, and Life Cycle Analyses (LCAs),
with all greenhouse gases translated into CO
2
equivalents
X NACE code G.47.4 Retail sale of information and
communication equipment in specialised stores
X NACE code G.47.5 Retail sale of other household
equipment in specialised stores
To calculate net revenue from activities in high-climate
impact sectors we assume, for this purpose, that all
revenues except revenue from Ironstone are associated with
the activities described in the mentioned NACE codes. The
relevant line for consolidation with our financial statements
can be found under the note 5.
OVERVIEW NET REVENUE KOMPLETT GROUP
Amounts in NOK million 2025 2024
Net revenue from activities in high climate
impact sectors used to calculate energy
intensity and GHG intensity
15 529 15 177
Net revenue (other) 130 125
Basis for calculation of Energy intensity (total energy consumption per net
revenue.
Energy data and methodology
Energy consumption covers the group’s own operations,
meaning warehouses, offices, retail stores, and cloud-
service facilities (Ironstone), and applies the same
organisational boundary as for Scope 1 and 2 GHG
emissions. Reported figures include purchased electricity,
district heating, and fuel used for transport and logistics.
Feedstocks not used for energy purposes are excluded.
All energy data are expressed in MWh and converted from
supplier invoices and fuel reports using standard IPCC
conversion factors. Renewable electricity is recognised
only where origin is contractually certified by Guarantees of
Origin (GoOs) or equivalent market instruments.
Energy consumption is the main driver of the group’s
direct (Scope 1 and 2) greenhouse gas emissions, as
disclosed in E1-6 (GHG emissions), where changes in energy
use and energy mix are directly reflected in emission
trends. Updated AIB location-based factors now include
cross-border electricity flows, meaning Norway is no longer
reported as 100 per cent renewable and the energy mix for
2025 reflects the broader Nordic power market.
ENERGY INTENSITY PER NET REVENUE
MWh/MNOK Revenue 2025 Comparative 2024 % 2025 / 2024
Total energy consumption from activities in high climate impact sectors per net revenue
from activities in high climate impact sectors
0.98 1.16 (15%)
CHANGES AND CORRECTIONS OF PRIOR REPORTING PERIODS
Standard Datapoint (metric) ESRS ref. Description Accuracy
E1-6 Total GHG emissions §44 Scope 1
• No changes or corrections
Scope 2
• Updated emission factor for Norwegian electricity to account for import
and export of electricity. We have recalculated 2024 figures for 2025.
Scope 3
• Category 11 was overestimated by 32 432 tonnes CO
2
e due to a punching
error. We have recalculated 2024 figures for 2025.
Moderate
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Short-term leased warehouses and emissions from shared
retail spaces are excluded due to their insignificance. These
exclusions may be reassessed as data availability and GHG
emissions accounting improve.
Between the reporting dates of entities in our value chain
and the finalisation of this sustainability statement, no
significant events or changes in circumstances that
materially impact the disclosed GHG emissions have been
identified.
Changes in reporting practices, such as adjustments
in waste data estimation methods or refinements of
transportation emissions calculations, do not significantly
alter the comparability or reliability of reported emissions.
Where necessary, we disclose template-based estimates or
assumptions, such as for mall-based stores’ waste data or
commuting distances and adjust these estimates based on
sales data or operational activity to ensure consistent and
accurate reporting.
Changes and corrections of prior reporting periods
We have identified one error in our 2024 emissions
reporting. An overestimation with 32 432 tonnes CO
2
e was
reported due to a punching error for scope 3 category 11 –
use of sold products.
> For more information about uncertainty related to KPIs due
to assumptions, in addition to other changes, correction and
errors from prior reporting periods, see ESRS 2 BP-2
KOMPLETT GROUP GHG ACCOUNTS 2025
Retrospective Milestones and target years
1)
Base year
2024
Comparative
2024 2025
%
2025 / 2024 2030 2050
Annual % target
/ Base year
Scope 1 GHG emissions
Gross Scope 1 GHG emissions (tCO
2
eq) 81 81 57 (29) - - -
Percentage of Scope 1 GHG emissions from regulated emission trading schemes (%) - - - 0% - - -
Scope 2 GHG emissions
Gross location-based Scope 2 GHG emissions (tCO
2
eq) 336 336 341 2% - - -
Gross market-based Scope 2 GHG emissions (tCO
2
eq) 3 080 3 080 2 810 (9%) - - -
Significant Scope 3 GHG emissions
Total gross indirect (Scope 3) GHG emissions (tCO
2
eq) 426 652 426 652 480 032 13% - - -
1 Purchased goods and services 313 363 313 363 336 710 7% - - -
2 Capital goods 5 543 5 543 5 155 (7%) - - -
3 Fuel and energy-related activities (not included in Scope 1 or Scope 2) 178 178 171 (4%) - - -
4 Upstream transportation and distribution 67 953 67 953 86 499 27% - - -
5 Waste generated in operations 10 10 12 30% - - -
6 Business traveling 387 387 298 (23%) - - -
7 Employee commuting 1 894 1 894 1 018 (46%) - - -
8 Upstream leased assets N/A N/A N/A N/A - - -
9 Downstream transportation N/A N/A N/A N/A - - -
10 Processing of sold products N/A N/A N/A N/A - - -
11 Use of sold products 37 155 37 155 50 018 35% - - -
12 End-of-life treatment of sold products 171 171 152 (11%) - - -
13 Downstream leased assets N/A N/A N/A N/A - - -
14 Franchises N/A N/A N/A N/A - - -
15 Investments N/A N/A N/A N/A - - -
Total GHG emissions
Total GHG emissions (location-based) (tCO
2
eq) 427 068 427 068 480 430 12%
- - -
Total GHG emissions (market-based) (tCO
2
eq) 429 813 429 813 482 899 12%
- - -
1)
Komplett Group does not disclose climate figures related to milestones and target years as we have not yet adopted a transition plan and are in the early stages of our full GHG accounts.
Total GHG emissions disaggregated by Scopes 1 and 2 and significant Scope 3 categories.
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TOTAL GHG EMISSIONS
SCOPE 1
57
tCO
2
eq
Direct emissions from our
owned or controlled sources
SCOPE 2
2 810
tCO
2
eq
Indirect emissions from the
generation of purchased
energy (market-based)
SCOPE 3
480 032
tCO
2
eq
All other indirect emissions that
occur in our value chain
DATA ORIGIN PER SCOPE
tCO2e Per cent
Primary Secondary Primary Secondary
Scope 1 57 - 100% 0%
Scope 2 30 3780 0.9% 99.1%
Scope 3 7 798 47 2234 1.6% 98.4%
Tota l 7 885 47 6014 1.6% 98.4%
The amount and share of primary and secondary data used to calculate
emissions per scope.
There is a slight change the way data origin for scope 1 and
2 have been classified for 2025. In Scope 1 the key change
from 2024 to 2025 is the reclassification of company
vehicles from secondary to primary, resulting in 100 per cent
primary data in 2025, compared to 46.6 per cent in 2024. In
Scope 2 most data remain secondary in 2025 with 0.9 per
cent primary and 99.1 per cent secondary; this is because
parts of the portfolio still lack complete information and
therefore rely on standard emission factors. In comparison,
Scope 2 in 2024 consisted of 21.9 per cent primary data. The
underlying activity data are unchanged, the shift primarily
concerns classification and improved consistency. For
Scope 3, primary data in 2025 represents an increase to 1.6
per cent from 0.2 per cent in 2024.
Direct emissions (Scope 1)
Komplett Group’s Scope 1 emissions stem from the fuel
combustion from leased vehicles and refrigerants. Komplett
Group has no stationary combustion.
Indirect emissions from electricity (Scope 2)
Komplett Group’s Scope 2 includes emissions from pur-
chased electricity, heating and cooling in offices, ware-
houses, and stores. Energy from electricity and heating at
our owned and leased locations accounts for the majority
of our total energy consumption and Scope 2 emissions.
Some of our purchased energy comes with contractual
obligations related to attribute certificates, but this does not
comprise all purchased energy for all business units. Total
GHG emissions are reported with a clear distinction between
emissions derived from location-based and market-based
Scope 2 calculations, in accordance with ESRS E1 AR 47 (b).
Indirect emissions (Scope 3)
Komplett Group’s Scope 3 emissions come from purchased
goods and services, capital goods, and fuel and energy
distribution. Emissions also arise from upstream and
downstream transport, waste generation, business travel,
and employee travel. Additionally, the use and end-of-
life treatment of sold products contribute to our overall
environmental impact. Emissions from purchased cloud
computing and data centre services amounted to 0.28
tonnes CO
2
e and is part of our reported emissions in
category 1, upstream purchased goods and services.
In 2025, Komplett Group applies 2024 as the baseline
year for Scope 1, Scope 2 and Scope 3 emissions. Based
on the enhanced greenhouse gas accounting completed
in 2024, this year has been established as the common
and consolidated baseline across all scopes. The 2024
baseline also serves as the reference point for the ongoing
development of the group’s transition plan.
As part of the continued development and formalisation of
the transition plan, milestone reduction targets have not yet
been established. For 2025, milestone figures are therefore
not disclosed, as they will be evaluated and defined as an
integrated element of the transition plan framework.
As for the reporting period, Komplett Group does not apply
any internal carbon-pricing schemes.
To reduce our market-based emissions Komplett Group
buys Guarantees of Origin (GOs) which represents 100 per
cent of our contractual instruments related to Scope 2 GHG
emission. The GOs are bundled together with the purchase
of energy for our shops and offices in NetOnNet, where
we control the choice of electricity provider. We have no
other contractual instruments for carbon removal or energy
attribute certificates.
> For more information about net revenue figures used to
calculate GHG intensity, see E1-5
Biogenic emissions of CO
2
from the combustion or
biodegradation of biomass not included in Scope 1 GHG
emissions are two tonnes CO
2
eq. This a reduction from six
tonnes in 2024, and is related to a decrease in our use of
biodiesel. We have not identified biogenic emissions for
Scope 2 or Scope 3.
CONTRACTUAL INSTRUMENTS FOR SCOPE 2
2025 2024
Covered by contractual instruments (kWh) 5 843 5 753
Share bundled (%) 100 100
Share unbundled (%) - -
Share of electricity covered by contractual instruments (%) 50.3 47.7
GHG INTENSITY PER NET REVENUE
tCO2eq/Monetary unit 2025 Comparative2024 % 2025 / 2024
Total GHG emissions (location-based) per net revenue 0.000030681 0.000027908 9.93%
Total GHG emissions (market-based) per net revenue 0.000030838 0.000028090 9.79%
> For additional information related to our GHG emissions,
see Komplett Group’s climate report
> For more information about external validation of metrics,
see ESRS2 BP-2
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SIGNIFICANT SCOPE 3 CATEGORIES
Category Coverage Methodology Assumptions Emission factors Tools/references Boundaries
Category 1
Purchased goods
and services
Included
in GHG
inventory
Spend-based Our purchased goods for sale are divided into ten categories of similar products,
and we assume that using average emission factors related to these ten
categories provide a reasonable representation of the emissions associated with
these goods. The same applies to purchased goods and services for internal use
Emission factors are based on cradle-
to-gate emission from the relevant
industry (Exiobase 3.9.2019).
Position Green, own calculations to
subtract the freight cost product
revenue and consolidate spending
across business units.
All upstream (cradle-to-gate)
emissions of purchased goods and
services.
Category 2
Capital goods
Included
in GHG
inventory
Spend-based We assume that using average emission factors for our ten categories of
purchased capital goods provides a reasonable calculation of the emissions
associated with these goods.
Emission factors are based on cradle-
to-gate emission from the relevant
industry (Exiobase 3.9 2019).
Position Green All upstream (cradle-to-gate)
emissions of purchased capital goods
Category 3
Fuel and energy
distribution
Included
in GHG
inventory
Activity-based We assume that using average emission factors for fuel and energy production
and distribution in Scope 1 and Scope 2 gives reasonable estimations connected
to fuel and energy distribution.
Emission factors are based on
industry averages and calculated
automatically by our sustainability
reporting tool (IEA 2024).
Position Green For upstream emissions
Category 4
Upstream
transport and
distribution
Included
in GHG
inventory
Transport and distribution of goods
and services within Scandinavia is
precalculated by transport suppliers,
transport and distribution of goods from
our product suppliers is spend-based.
We assume that transport cost can be represented by a percentage of product
revenue, and that this is comparable to our private label products (approximately
four per cent of revenue). Furthermore, we have assumed that average emission
factors for transport is reasonable in this context.
Emission factors are based on cradle-
to-grate emission from the transport
industry (Exiobase 3.9 2019, DEFRA
(2025), AIB (2025)).
Position Green, own calculations to
estimate freight costs.
The Scope 1 and Scope 2 emissions
of transportation and distribution
providers that occur during use of
vehicles and facilities.
Category 5
Waste
Included
in GHG
inventory
Activity-based We assume that using average emission factors for each type of waste
treatment method provide a fair representation of emissions from this
category. Furthermore, for a small share of our shops and offices, we have made
assumptions about allocation of waste treatment method based on square
meters or sales revenue.
Emission factors is an industry
average that include Scope 1 and
Scope 2 emissions from each waste
treatment method (DEFRA 2025).
Position Green, own calculations to
estimate waste figures where data
is missing or where waste data is
reported aggregated (shopping malls
or shared office spaces).
The Scope 1 and Scope 2 emissions
of waste management suppliers that
occur during disposal or treatment.
Category 6
Business travel
Included
in GHG
inventory
Primarily activity-based and pre-
calculated by travel agency, spend-
based for local travels, bus and taxi
The majority of travels are covered by the travel agency. For other transport
costs, we assume that using average emission factors for different travel modes,
combined with spend data, provides a reasonable estimate of emissions
Emission factors are based on
supplier-specific data and industry
averages for modes of transport
(DEFRA 2025 / Exiobase 3.9 2019).
Position Green The Scope 1 and Scope 2 emissions
of transportation carriers that occur
during use of vehicles.
Category 7
Employee travel
Included
in GHG
inventory
Activity-based We have made assumptions on average travel distances using geospatial
analysis, modes of transport, and frequency of commuting (each working day).
Allocation to each travel mode is based on nation travel statistics.
Emission factors are based on
industry averages for modes of
transport (NTM 2018, DEFRA 2025,
NTMCalc.Advanced 4.0)
Position Green The Scope 1 and Scope 2 emissions
of employees and transportation
providers that occur during use of
vehicles.
Category 11
Use of sold
products
Included
in GHG
inventory
Activity-based We have made assumptions on average usage patterns, product lifetimes, and
energy consumption for our ten different product categories, based on industry
documentation and research papers. Within the ten product categories, we have
made assumptions on which products are most representative for the entire
product category
Emission factors includes emissions
from electricity usage, using location
based emission factor (AIB 2025).
Position Green, own calculations to
estimate product lifetime and energy
consumption.
The direct use-phase emissions of
sold products over their expected
lifetime. We have not calculated direct
use-phase of gas from sold BBQ-
equipment, or refrigerated gases from
our refrigerators and freezers. We will
include this in our reporting for 2026
Category 12
End-of-life
treatment of sold
products
Included
in GHG
inventory
Activity-based Our assumptions regarding the distribution of packaging waste across different
waste treatment categories are based on data from our waste management
supplier. Additionally, we have estimated the proportions of electronic versus
nonelectronic waste for our sold products and we have assumed that all our sold
products are treated as EE-waste.
Emission factors are average factors
for waste treatment methods (DEFRA
2025).
Position Green, own calculations
(based on data from Norsirk)
to estimate the split of waste
categories into paper and cardboard,
plastics and residual waste.
The Scope 1 and Scope 2 emissions of
waste management companies that
occur during disposal or treatment of
sold products.
Overview of Scope 3 categories along with methodologies, significant assumptions, emission factors used to calculate or measure GHG
emissions. Boundaries considered for estimated emissions are also included, as well as disclosure of why some categories have been excluded.
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EXCLUDED SCOPE 3 CATEGORIES
Scope 3 Coverage
Category 8
Upstream
leased assets
Excluded from GHG inventory, as the impacts are deemed immaterial, occurrence of emissions is irregular, data on
fugitive gases is insufficient.
Category 9
Downstream
transport and
distribution
Excluded from GHG inventory, as transport and distribution before final sale is covered in category 1, high
uncertainty on post-delivery emissions.
Cat.10
Processing of
sold products
Excluded from GHG inventory, as it is deemed non-relevant (parts and components covered under category 1).
Category 13
Downstream
leased assets
Excluded from GHG inventory, as it is expected to be a minor part of our emissions.
Category 14.
Franchises
Excluded from GHG inventory, as franchises are not relevant for Komplett Group’s business model.
Category 15
Investments
Excluded from GHG inventory, as investments are not relevant for Komplett Group’s business model.
Overview of Scope 3 categories that are excluded from the climate account.
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EU TAXONOMY
In 2025, Komplett Group updated the assess-
ment to report in line with the EU Taxonomy
disclosure requirements, including mapping
of relevant financial data, mapping of relevant
eligible activities according to the Climate
and Environmental Delegated Acts, and
assessing the group’s economic activities in
alignment with the EU Taxonomy.
The process has been managed at group level, with data
collection and activity screening processes carried out in
collaboration with all subsidiaries.
Background
The EU Taxonomy is a classification system for environ-
mentally sustainable activities. It is a key component of the
European Commission’s action plan to reorient capital flows
towards economic activities that are deemed sustainable. By
reallocating capital and direct investments towards sustain-
able projects and activities, EU aims to take a step closer to
reach the objectives of the European Green Deal. To achieve
this, it was necessary to clearly define what constitutes a sus-
tainable activity, leading to the creation of the EU Taxonomy.
Economic sustainable activities
In the EU Taxonomy, a sustainable economic activity is
an economic activity providing a substantial contribution
to one of six environmental objectives, defined by the EU
Commission:
1. Climate change mitigation
2. Climate change adaptation
3. Sustainable use and protection of water and marine
resources
4. Transition to a circular economy
5. Pollution prevention and control
6. Protection and restoration of biodiversity and
ecosystems
To qualify as a sustainable economic activity, the activity
needs to substantially contribute to one of the objectives
above. At the same time, the activity must not significantly
harm any of the other environmental objectives. It must also
meet minimum social and governance safeguards.
Disclosure requirements
Companies under the scope of the Corporate Sustainability
Reporting Directive (CSRD) and financial market participants
that offers financial products, are required to report on their
alignment with the EU Taxonomy Regulation, by reporting on
the following:
Taxonomy-eligibility: Share of economic activities
described in the Delegated Acts supplementing the EU
Taxonomy Regulation. Conversely, a non-eligible activity
refers to any economic activity not yet described in the
Delegated Acts supplementing the Taxonomy Regulation.
Taxonomy-alignment: Share of eligible activities meeting
the technical screening criteria set out in the Delegated Acts
for that activity, in addition to minimum safeguards. This
invites organisations to do a screening process, in which an
eligible activity is assessed in terms of its:
X “substantial contribution” to one of the six
environmental objectives
X “do no significant harm” to the other five environmental
objectives
X compliance with “minimum safeguards”
Minimum safeguards
Komplett Group ensures compliance with minimum
safeguards through structured due diligence processes
aligned with the OECD Guidelines. These processes cover
labour rights for both employees and workers throughout
the value chain. Measures addressing bribery, corruption,
and decent working conditions are embedded in the group’s
compliance framework and reinforced through our code of
conduct, which applies to all employees.
In 2025, we identified no instances of non-compliance with
minimum safeguards, or legal accountability for violations
in these areas. For more information on our approach to re-
sponsible business practices, see the sections on own work-
force and business conduct in the sustainability statement.
> For more information on our policies and how we govern
social safeguards, see ESRS2 MDR-P, S1-1, and G1-1
Methods for defining and calculating EU Taxonomy KPIs
Taxonomy eligibility and alignment performance is reported
on three key performance indicators: turnover, capital
expenditure (CapEx) and operational expenditure (OpEx), for
each economic activity classified as eligible and aligned.
The group’s interpretations of the Taxonomy’s three KPI
definitions are based on guidance from the delegated acts.
These interpretations may be revised as EU Taxonomy
guidelines evolve and reporting practices develop.
Scope
Komplett Group falls under the scope of the EU Taxonomy
regulation.
This report covers the period from 1 January 2025 to
31 December 2025 and evaluates all six environmental
objectives outlined in the EU Taxonomy. Komplett Group has
assessed all its economic activities that have the potential
to substantially contribute to one of the five environmental
targets, and, if so, the relevant environmental screening
criteria set forth in the Environmental Delegated Act.
Assessment of activities for 2025
Komplett Group operates in the retail and e-commerce
sector, where few of its primary economic activities are
included in the EU Taxonomy at reporting date. Therefore,
most of the group’s economic activities are defined
non- eligible, meaning that these are not described in the
delegated acts at the time of reporting.
The Taxonomy eligible economic activities have been iden-
tified by screening the activities in the Climate Delegated
Act (Commission Delegated Regulation (EU) 2021/2139),
the Complimentary Climate Delegated Act (Commission
Dele gated Regulation (EU) 2022/1214), the Environmental
Delegated Act ((Commission Delegated Regulation (EU)
2023/2486), and the amendments to the Climate Delegated
Act (Commission Delegated Regulation (EU) 2023/2485).
To determine whether the eligible economic activities
qualify as environmentally sustainable (Taxonomy-aligned),
the activities have been assessed by screening against
the criteria outlined in Regulation (EU) 2020/852, article3.
Additionally, the Taxonomy-alignment of these eligible
activities has been evaluated according to Annex II of the
Environmental Delegated Act, with the examination of
technical screening criteria for environmental objectives
undertaken for each activity, and the assessment of
minimum safeguards conducted at the group level.
Taxonomy-eligible and -aligned activities
The table below outlines the share of Komplett Group’s
turnover, CapEx and OpEx attributed to economic activities
identified as Taxonomy-eligible, and Taxonomy-aligned.
THE GROUP DEFINES THE FOLLOWING THREE KPIs
Turnover CapEx OpEx
Total turnover is defined as external
revenue in accordance with the Inter-
national Financial Reporting Stand-
ards (IFRS), which corresponds to total
operating income in the consolidated
income statement in the group’s finan-
cial statement. Please see note 6 in the
consolidated income statement. The
revenue KPI is defined as Taxonomy
eligible turnover (numerator) divided
by total turnover (denominator).
The total operating income for
Komplett Group was NOK 15.8 billion in
financial year 2025 (denominator).
Total CapEx is defined as capital
expenditures is defined in IFRS. This KPI
includes additions to tangible and intan-
gible assets before amortisation and
depreciation, including impairments,
and excluding goodwill and fair value
changes. Please see note 11, 12 and 19
for reference. The CapEx KPI is defined
as Taxonomy eligible CapEx (numerator)
divided by total CapEx (denominator).
For Komplett Group, the total CapEx
in accordance with the EU Taxonomy
definition was NOK 299 million in
financial year 2025 (denominator).
Total OpEx refers to operating expenses not
recog nised as assets, but include cost of employ-
ees executing repairs of products, short-term
lease expenses, and day-to-day maintenance,
cleaning, and repair costs (including building
reno vation measures). The OpEx KPI is defined
as Taxonomy eligible OpEx (numerator) divided
by total OpEx (denominator). As EU Taxonomy
OpEx has a different definition than IFRS, the
OpEx used cannot be directly derived from the
Financial Statements.
For Komplett Group, the total OpEx in accordance
with the EU Taxonomy definition was NOK 40
million in financial year 2025 (denominator).
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Turnover: The primary source of turnover contributing to the
numerator of the turnover KPI in 2025 is sales of second-
hand products within the product categories Computing and
Telecom, more specifically NetOnNet’s resale of second-
hand products sold through its marketplace called “used”
(Swedish: “Begagnade”). The taxonomy-aligned turnover for
2025 remains at same level as 2024.
CapEx: There were no sources of CapEx contributing to the
numerator of the CapEx KPI in 2025, as the two identified
activities did not involve any investments or other types of
additions to tangible or intangible assets. The taxonomy-
aligned CapEx for 2025 remains at same level as 2024.
OpEx: The sources of OpEx contributing to the numerator of
the OpEx KPI in 2025 stem from the cost of FTEs for the op-
erating personnel executing repairs of certain products from
Komplett Services and NetOnNet, with no allocation of fixed
cost or other operating expenses related to repairs. The tax-
onomy-aligned OpEx for 2025 is slightly higher than in 2024.
Double counting: For the calculation of the denominator of
the turnover, CapEx and OpEx KPIs, we have extracted the
figures directly from our internal system, ensuring that the
figures are only counted once in each KPI. To avoid double
counting, the group has set up a control function to assure
all financial data associated with each activity.
IDENTIFYING ELIGIBLE AND ALIGNED ACTIVITIES
Potential to contribute to the environmental
objective: Circular economy
Komplett Group has identified two Taxonomy-eligible
activities, both with the potential to contribute to the
environmental objective “Transition to a circular economy.”
The technical screening criteria for Taxonomy-alignment
for these activities was adopted into Norwegian law in the
early stages of 2024, and Komplett Group has screened
all relevant activities against the outlined criteria in the
Commission Delegated Regulation (EU) 2023/2486.
5.1 Repair, refurbishment, and remanufacturing
Assessment of eligibility: Repairment of products in-house
is an eligible activity according to our assessment of the
definition presented in the EU Taxonomy. The economic
activities relate to Komplett Group’s repair of products that
can be classified under the NACE code C26 Manufacture
of computer, electronic and optical products, and C27
Manufacture of electrical equipment.
Komplett Services and NetOnNet carry out repairs in certain
cases, typically when a customer makes a warranty claim
or files a complaint about a product, while Webhallen has
limited in-house repair capabilities. The repair activities
performed by Komplett Services, NetOnNet and Webhallen
are conducted independently. The subsidiaries do not
perform repair activities for each other, eliminating the risk
of double counting the relevant financial KPI.
Komplett Services repairment activities are connected to
a broad range of product categories, while both Komplett
Services and Webhallen repair PCs. However, the magnitude
of PC repairs in Webhallen is significantly lower than in
Komplett Services. Repairs on PCs not sold by Komplett
Group represent a small revenue stream, as repairs are
invoiced to end-consumers. NetOnNet primarily conducts
its repairs on private label products, especially within the TV
and electric vehicles categories.
Repairs of electric vehicles are not included in the definition
of the eligible activity. This is excluded from Komplett
Group’s reporting on eligibility for this activity.
Substantial contribution: To make a substantial contribution
to the environmental objective transition to a circular
economy, Komplett Group’s repaired products must
be conducted with the intention to extend the lifetime
of the products. The replaced or broken parts in the
repaired products must also either be reused, recycled, or
disposed of in accordance with applicable EU and national
legislations. In addition, replacing, reusing, or disposing
of spare parts must follow a waste management plan that
ensures materials and components not used in the same
product are either repurposed elsewhere, recycled when
reuse is not possible, or disposed of in compliance with EU
regulations if neither reuse nor recycling is feasible.
The group has assessed and documented compliance with
these requirements. Thus, the group’s eligible repair activi-
ties meet the technical criteria for substantial contribution.
Do no significant harm (DNSH)
Komplett Group has assessed and documented compliance
with the DNSH criteria outlined in Annex 2 of the
Environmental Delegated Act for the eligible repair activity.
The activity meets the DNSH criteria for climate change
mitigation, as it complies with the limits for GHG emissions
and heat and cooling generation. For climate change
adaptation, the screening was based on the climate
risk assessment conducted at the group level across all
business units. Regarding water and marine resources,
the eligible repair activity does not involve or impact water
and is therefore assessed as within the required limits. For
pollution prevention, the activity fully complies with the
DNSH criteria, as it does not generate any hazardous or
pollutive waste listed in the relevant appendix. Further, no
hazardous substances are used in the repair process.
5.4 Sale of second-hand goods
Assessment of eligibility
Komplett Group’s resale of second-hand products is an
eligible activity. This encompasses Komplett Group’s sales
of second-hand products previously used for their intended
purpose before by customers, and that can be classified
under the NACE codes C26 and C27.
This includes NetOnNet’s resale of second-hand products,
sourced from an external partner and sold as used products,
marked as “used” (Swedish: “begagnade”), through its sales
channels. In addition, the eligible activity covers NetOnNet’s
sale of products received from the trade-in programme, known
as “Byt in”, which is sold to an external partner for resale to
end-customers. Webhallen has a similar trade-in programme,
but as the customers sell this directly to the external partner
these transactions are not considered eligible.
Both NetOnNet and Webhallen sell products in the “Bargain”
category (Swedish: “Fyndvaror”), sold at reduced prices
due to repairs, minor defects, being opened, or damaged
packaging. Similarly, Komplett Services, sells products in
the “Demonstration” category (Norwegian: “Demovarer”),
including demo products, returned products and repaired
products resold to end-consumers. However, due to
uncertainty regarding whether these products meet the
definition in the Taxonomy for second-hand, these activities
are considered non-eligible.
Substantial contribution to circular economy
The eligible activities within NetOnNet, the sale of products
in the “used” category (“begagnade”), and the trade-in
programme, “Byt in”, have been screened against the technical
criteria to make a substantial contribution to the environmen-
tal objective: Transition to a circular economy. The activity
“begagnade” is complying with strict packaging material
requirements, confirmed by the FSC certificate, and thus
aligns with the technical criteria set for substantial contribu-
tion for this activity. However, for “Byt-in”, the activity does not
meet the packaging criteria, set in the screening criteria for
substantial contribution to circular economy. The packaging
activity is executed at several locations in NetOnNet, where
the packaging material does not meet the requirement of
being made from at least 65 per cent recyclable material.
Do no significant harm (DNSH)
The sale of second-hand goods meets the DNSH criteria
for climate change mitigation, as the activity complies
with limits on heat and cooling generation, as well as the
requirements of the 2009/125/EC Directive. Komplett Group
has a strategy in place to account for GHG emissions and to
provide fossil fuel-free delivery where possible. For climate
change adaptation, the activity is included in Komplett
Group’s climate resilience analysis and risk assessment and
hence meet the relevant DNSH criteria.
The activity also meets the DNSH criteria for water and
pollution, as it complies with emission permits and does not
generate any harmful substances listed in the Appendix.
FY 2025
NOK million Tota l
Share of Taxonomy-eligible
economic activities
Share of Taxonomy-aligned
activities
Share of non-eligible
economy activities
Turnover 15 775 0.2% 0.1% 99.7%
Capital expenditure (CapEx) 299 0% 0% 100%
Operating expenditure (OpEx) 40 17.3% 17.3% 82.7%
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APPENDIX: KPI TABLES
The key performance indicators (KPIs) include turnover, CapEx, and OpEx. The KPIs are presented using the updated templates following the Commission delegated regulation (EU) 2026/73 of 4 July 2025 amending Delegated Regulation (EU) 2021/2178.
OVERALL – KPI TABLE
Financial year (N) 2025
Breakdown by environmental objectives of Taxonomy-aligned activities
KPI
MNOK % MNOK % % % % % % % % % % MNOK %
Turnover 15 775 0.2% 20 0.1% % % % 0.1% % % % % % 19 0.1%
CapEx 299 0% - % % % % % % % % % % - -
OpEx 40 17.3% 7 17.3% % % % 17.3% % % % % % 7 16%
Total
Proportion of Taxonomy-
eligible activities
Taxonomy-aligned activities
Proportion of Taxonomy-
aligned activities
Climate Change Mitigation
Climate Change Adaptation
Water
Circular Economy
Pollution
Biodiversity
Proportion of enabling activities
Proportion of transitional activities
Not assessed activities
considered non-material
Taxonomy-aligned activities in previous
financial year 2024
Proportion of Taxonomy-aligned
activities in previous financial year 2024
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TURNOVER – KPI TABLE
Reported KPI (Turnover) 15 775
Financial year (N) 2025
Environmental objective of Taxonomy-aligned activities
Economic activies
15 775 % MNOK % % % % % % %
(E where
applicable)
(T where
applicable)
%
Sales of second-hand goods CE 5.4 0.2% 20 0.1% % % % 0.1% % % 60%
Sum of alignment per objective % % % 0.1% % %
Total KPI (Turnover) 0.2% 20 0.1% % % % 0.1% % %
Code
Taxonomy-eligible KPI
(Proportion of Taxonomy-eligible Turnover)
Taxonomy-aligned KPI
(Monetary value of Turnover)
Taxonomy-aligned KPI
(Proportion of Taxonomy-aligned Turnover)
Climate Change Mitigation
Climate Change Adaptation
Water
Circular Economy
Pollution
Biodiversity
Enabling activity
Transitional activity
Proportion of Taxonomy-aligned in
Taxonomy-eligible
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OPEX – KPI TABLE
Reported KPI (OpEx) 40
Financial year (N) 2025
Environmental objective of Taxonomy-aligned activities
Economic activities
40 % NOK % % % % % % %
(E where
applicable)
(T where
applicable)
%
Repair, refurbishment, and remanufacturing CE 5.1 17.3% 7 17.3% % % % 17.3% % % 100%
Sum of alignment per objective % % % 17.3% % %
Total KPI (OpEx) 17.3% 7 17.3% % % % 17.3% % %
Code
Taxonomy-eligible KPI
(Proportion of Taxonomy-eligible OpEx)
Taxonomy-aligned KPI
(Monetary value of OpEx)
Taxonomy-aligned KPI
(Proportion of Taxonomy-aligned OpEx)
Climate Change Mitigation
Climate Change Adaptation
Water
Circular Economy
Pollution
Biodiversity
Enabling activity
Transitional activity
Proportion of Taxonomy-aligned in
Taxonomy-eligible
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RESOURCE USE AND CIRCULAR ECONOMY
Material ESRS topics
Material ESRS
sub-topics Part of the vale chain where impact was material
Impact
materiality
Financial
materiality
E5: Resource use and
circular economy
E5: Resource inflow Upstream Own operations Downstream High Medium
E5: Resource outflow Upstream Own operations Downstream High High
E5: Waste Upstream Own operations Downstream High High
Resource use and circularity are key priorities for Komplett
Group in reducing environmental impact. The group
addresses the global challenge of electronic waste through
collection, reuse, refurbishment, and collaboration with
recycling partners to recover materials. Increasing resource
dependency poses a risk to supply security, while circular
solutions offer opportunities to improve material efficiency,
reduce waste, and strengthen long-term resource resilience.
IMPACTS, RISKS AND OPPORTUNITIES RELATED TO
RESOURCE USE AND CIRCULAR ECONOMY (E5.IRO-1)
Circularity is one of Komplett Group’s core strategic focus
areas, including the path for developing new and circular
business concepts, focusing on recycling, durability,
and reusability. A particular emphasis is put on minerals
and materials used in electronics that have significant
environmental footprints.
Komplett Group applies the same structured double-
materiality process described in ESRS 2 IRO-1 to identify,
assess and manage sustainability impacts, risks, and
opportunities related to resource use and circular
economy. As part of this process, we use supplier
assessments, product life cycle analysis, factory audits,
and third-party certifications and dialogue to evaluate
risks and opportunities in operations and the value chain.
Consultations involve engagement with suppliers and
industry partners through surveys and day-to-day operations
to identify opportunities for material reuse, product
durability, and waste reduction.
For all subsidiaries, resource use and circular economy
initiatives are led by a dedicated member of the
management group, who oversees programmes like trade-in
schemes and sustainable packaging strategies. Materials
used include plastics, metals, and electronics components,
with increasing efforts to incorporate recycled materials in
private label products and packaging.
Continuing business as usual leads to significant risks
related to increased regulatory pressure under the European
Green Deal and the Circular Economy Action Plan. Non-
compliance with recycling targets and packaging standards
for private labels could lead to financial penalties and
increased operational costs. We therefore see opportunities
in adopting circular economy practices, such as using more
recyclable materials and offering low-emission products.
Transitioning to a circular economy involves upfront
investments in R&D, redesigning private label products
to meet recyclability targets, and expanding collection
systems. However, a successful transition would offer
financial resilience through improved customer trust,
better compliance with regulations, and reduced life cycle
costs of products. Resource use and associated risks are
most prominent upstream in raw material extraction and
packaging, where regulations demand higher recyclability.
Downstream risks relate to the management of e-waste
and product returns. All business units have been assessed
jointly, as the resource inflows, outflows, and waste are
similar.
Findings from the materiality assessment feed directly into
policy implementation and target-setting, including the
group goal of achieving 15 per cent of revenues from circular
products and services by 2028.
> For more details about the process of identifying IRO’s
related to E5 in the value chain, see ESRS 2 IRO-1
POLICIES RELATED TO RESOURCE USE AND CIRCULAR
ECONOMY (MDR-P §65)
Komplett Group’s climate and circularity policy commits the
group to extending product lifetimes, enabling reuse and
repair, offering take-back and recycling solutions, reducing
waste and packaging, and promoting material efficiency
and recyclability, with a target of achieving 15 per cent of
revenues from circular products or services by 2028.
The policy applies across all group companies with majority
ownership. Overall accountability rests with the group CFO,
supported by the director of legal & compliance and the
managing directors of each subsidiary.
The policy is aligned with the EU Taxonomy, the CSRD/
ESRS framework, the EU Circular Economy Action Plan, and
other recognised standards, and promotes sustainable use
of resources throughout our value chain. Furthermore, the
policy reflects stakeholder expectations, including customer
demand for sustainable choices, supplier collaboration on
material efficiency, and evolving regulatory requirements.
The policy addresses strategies to minimise waste, as well
as waste treatment strategies, without prioritising the
two. The policy is communicated internally via the group’s
intranet, and externally through sustainability reporting.
Implementation is monitored through annual reporting on
revenue share from circular products and services, product-
return and recycling rates, and waste-reduction KPIs.
Progress is reviewed by group management and reported in
the annual sustainability statement.
> For more details regarding our sustainability policy, see
ESRS 2 MDR-P
ACTIONS AND EFFORTS TO INCREASE CIRCULARITY(E5-2)
Komplett Group is continuously strengthening its actions
and allocation of resources to promote resource efficiency
and circularity. 2025 marks the first year of reporting in
accordance with the ESRS requirements for actions under
E5. While data quality improvements remain a key focus, we
are now mapping all initiatives and investments related to
resource use and circular business models.
Key actions implemented
The following actions illustrate the measures implemented
across the group to reduce resource consumption, extend
product lifetimes, and increase circular revenue. The actions
are designed as ongoing operational practices rather than
time-limited projects and do not have fixed end dates but
evolve continuously as part of our long-term circularity
strategy.
Trade-in and re-use programmes
NetOnNet Trade-In enables customers to return used
products for discounts or gift cards. In 2025, close to 10
000 products were returned under this programme. This
represents a decline from 2024, where more than 13 000
products were returned. Partner Foxway repairs and resells
products, or reuses components creating a second life cycle
and reducing demand for new materials.
When replacing broken or worn parts, we reuse components
from unrepairable products as far as possible before using
new parts. Some items are, however, severely damaged and
therefore not suitable for a second life cycle. These items
can still be recycled, and the raw materials can be reused.
Webhallen Revive provides a similar model for mobile
devices, tablets and computers. When customers turn in
their old product, they are either rewarded with a gift card
or a discount on a new product. In 2025, 234 trade-ins were
completed, with an average trade-in value of SEK 1 410. In
2024, 91 trade-ins with an average value of SEK 1 772 were
registered. The trade-in value of the product is based on
criteria set by Corporate Mobile Recycling and the products
are bought by a partner company who resells the products as
second-hand products.
Sale of pre-owned products
Both Webhallen and NetOnNet offer certified pre-owned
products, such as laptops and mobile phones. These sales
extend product lifetimes and reduce waste.
Outlets and demo-products
Our companies also offer bargain and outbound products for
sale, in addition to items returned by customers. All products
for sale in the online outlets are of high quality but cannot be
sold as A-grade goods. Our companies also offer bargain and
outbound products in physical stores and through partners.
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Leasing and subscription model – Komplett FLEX
Customers can subscribe to products and either return
or purchase them after two years. FLEX covers over 1 000
products and accounts for approximately 8.6 per cent of
B2C sales in Norway and Sweden. Comparatively, FLEX
accounted for approximately 8.8 per cent in 2024. The FLEX
programme gives Komplett Services better control over
the product life cycle and makes it easier for the consumer
to dispose of their products in a sustainable way. Returned
items are refurbished or recycled responsibly.
Monitoring and expected effects
Monitoring of actions related to resource use and circularity
is currently focused on qualitative assessment and internal
follow-up through management reviews. Komplett Group
is in the process of developing common indicators and
reporting routines to ensure consistent measurement of
progress across subsidiaries from 2025 onwards.
Key expected benefits include:
X Reduced resource consumption through reuse and
repair
X Lower waste volumes and improved recycling rates
X Increased share of revenue from circular business
models (target 15 per cent by 2028)
Resources allocated and forward plan
Komplett Group assesses whether operational or capital
expenditures related to circularity initiatives are significant
by applying the same materiality and governance
principles used in our financial planning and enterprise
risk management. Expenditures are considered significant
when they represent a substantial investment relative to
our annual budgeting framework, require approval through
established governance processes, or have a notable impact
on our business model, cost structure, or infrastructure.
During the reporting period, no circular economy actions
required significant operational or capital expenditure
beyond normal business activities. Consequently, no
separate disclosure of financial resources under ESRS E5
MDR-A is required for the reporting year. This is compatible
with figures expressed in our financial reporting. For 2026,
Komplett Group plans to expand take-back and refurbish
systems to additional product categories, and to dedicate
additional financial resources to component reuse and
circular-revenue tracking. The group opts not to disclose the
exact figures pertaining to the future investments in these
activities. These actions form the foundation for scaling the
circular business model across all subsidiaries.
> For more information about our financial position,
performance and cash flows, see financial statements
TRACKING EFFECTIVENESS OF POLICIES AND ACTIONS
THROUGH TARGETS (MDR-T §§72,81)
Komplett Group recognises the importance of establishing
measurable targets for resource use and circular economy
in line with ESRS requirements. However, in 2025 we have
decided not to report fully on targets and actions related to
resource inflows, outflows, and waste, as our focus remains
on improving the quality and consistency of underlying data.
This will ensure a robust foundation for future quantitative
targets and disclosures.
Our current measurable ambition is the strategic focus
area of achieving 15 per cent of revenues from circular
products and services by 2028, as set out in the Climate
and Circularity Policy. This goal reflects our commitment to
prolonging product lifetimes and enabling circular customer
choices through reuse, repair, and refurbishment.
Reasons for not having specific ESRS targets
We have not yet set detailed quantitative targets for material
efficiency, waste generation, or resource recovery due to the
following challenges:
X Limited availability and comparability of data on
material composition, sourcing, waste generation and
recovery across subsidiaries; and
X Dependence on supplier practices, product design
and end-of-life management, which limits our direct
influence over upstream circularity outcomes.
Current progress and data development
Komplett Group is continuously refining its approach to
responsible sourcing, recycled content, product durability
and waste reduction before defining long-term ESRS-aligned
commitments. In 2025, we calculated that 2.85 per cent of
the group’s revenue derived from circular business models
that support extended product life or reuse, compared to
2.87 per cent in 2024This figure includes revenues from
repairs beyond warranty, sales of spare parts, trade-in
services, B2B leasing, and the FLEX model, but excludes
waste management, warranty repairs, demo products, outlet
goods, and distribution services.
Forward plan
During 2026, we will work toimprove the accuracy of data on
material inflows, waste streams and circular revenue, which
includes improving product reuse, repair and recyclability,
while continuing to reduce packaging. We will also evaluate
the feasibility of establishing quantitative group-wide ESRS
targets from the 2026 reporting year.
As data quality improves and industry standards mature,
Komplett Group will set measurable ESRS E5 targets
that align with our strategic ambition for circularity and
strengthen the monitoring of progress across subsidiaries.
RESOURCE INFLOWS (E5-4)
Resource inflows relate to the use of raw materials in
products, packaging materials, and components, as
well as the extent to which recycled or reused inputs are
incorporated in Komplett Group’s operations and value chain.
Product packaging and material efficiency are also relevant
aspects.
Upstream resource inflows cover the acquisition of
materials and components in the early stages of the supply
chain, while for own operations the concept refers mainly to
the materials used in private-label products and packaging,
and to the product types Komplett Group chooses to market.
Material composition and sourcing
During the reporting period, the total weight of products
and technical and biological materials used was 32 376
tonnes, of which 5 247 tonnes were biological materials and
27 128 tonnes technical materials. The share of secondary
(reused or recycled) materials was estimated at 609 tonnes,
representing 1.88 per cent of total materials used, including
packaging.
While some electronics sold or produced contain recycled
materials, virgin plastics remain predominant because of
quality stability and cost considerations. One of Komplett
Group’s long-term objectives is to increase the use of
recycled materials in private-label products and packaging.
OVERVIEW OF MATERIAL COMPOSITION
Tonnes 2025 2024
Total weight of products and technical and
biological materials used
32 376 26 725
Biological materials 5 247 4 226
Technical materials 27 128 22 499
Share of secondary (reused or recycled)
materials
609 624
Percentage of total secondary materials used
(including packaging)
1.88% 2.34%
Impacts, risks and opportunities
Komplett Group’s most significant environmental impact
from resource inflows is associated with the use of virgin,
non-renewable materials—particularly plastics and metals—
in private-label packaging and products. The limited
availa bility of verified data on recycled content restricts the
ability to quantify environmental benefits from secondary
materials.
Increasing regulatory requirements represent a key risk,
as stricter rules on recyclability, packaging reduction, and
material reporting may require additional investments in
research, development and system upgrades. The group is
also exposed to supply-chain risks, including dependence
on upstream suppliers’ ability to deliver verified recycled
content and potential price volatility in raw materials.
Moreover, there is a reputational risk associated with failing
to meet stakeholder expectations regarding circular design
and packaging practices.
At the same time, Komplett Group identifies several
opportunities related to resource inflows. Expanding the use
of post-consumer recycled materials in private-label products
and packaging can reduce the environmental footprint while
meeting increasing customer demand for sustainable and
repairable products. These preferences may strengthen the
group’s brand position and drive sales growth.
Critical raw materials and upstream sourcing
Komplett Group does not extract or process critical raw
materials. However, many electronic products rely on metals
such as cobalt, lithium and rare-earth elements listed in the
EU Critical Raw Materials Act. Through supplier require-
ments and audits, the group promotes transparency and
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encourages the use of recognised standards such as the
OECD Due Diligence Guidance for Responsible Supply Chains
of Minerals.
Packaging materials
Packaging constitutes a material component of resource in-
flows for Komplett Group. The main materials used are card-
board, paper, wood and plastics, amounting to 1 175 tonnes
The group is working to reduce virgin-material use through
increased recycled content and packaging optimisation. For
further information on actions taken to minimise packaging-
related impacts, see E5-2 (Actions and resources).
PACKAGING MATERIAL USE
Tonnes 2025 2024 2023
Cardboard and paper 779 815 845
Single-use wood pallets 334 341 338
Plastics 62 66 54
Tota l 1 175 1 222 1 237
Methodology and assumptions
Calculations are based on the total net and gross weights of
products and materials sold during the reporting period. The
assessment combines supplier reports, group-level purchas-
ing data, and GHG-emission records, while packaging data
were collected separately from each subsidiary using reports
provided directly by suppliers. Where supplier data were
incomplete, conservative assumptions were applied to ensure
consistency and transparency in the results. Products are
generally assumed to consist entirely of technical materials
unless otherwise specified. Paper-based packaging and
wooden pallets are treated as biological materials, whereas
plastic packaging is categorised as technical material.
In cases where specific information on recycled content was
unavailable, a recycled rate of zero per cent was assumed.
This ensures that the reported figures represent a minimum
verified share of recycled material rather than an estimate
based on assumptions. Recycled content is defined in
accordance with supplier declarations and follows the
established industry standards for post-consumer recycled
materials in the electrical and electronic equipment sector.
The applied methodology highlights the importance of
strengthening supplier engagement and improving data
transparency across the group’s value chain. While gross
and net product weights are readily available at group
level, packaging data require more granular collection
from suppliers. The limited availability of detailed supplier
data has therefore constrained the ability to determine
precise material composition, but the approach provides
a conservative and credible basis for reporting until more
comprehensive data are obtained.
Data cover all subsidiaries within Komplett Group’s
consolidation scope. The main data limitations relate to
material composition from upstream suppliers. In 2026,
we will work to strengthen our supplier engagement and
data transparency to enable more accurate calculations
of recycled content and secondary material use in future
reporting cycles.
As in the previous reporting year, we follow the defined
process to prevent double counting, with clearly specified
scopes, metrics, and system boundaries. We apply built-in
control mechanisms in our analyses and conduct internal
data checks and figure validation. In 2025, data has also
been gathered from multiple sources, allowing for cross-
checks and improved reliability. Our methodologies and
data sources are documented to ensure transparency and
traceability in the reporting.
> For more information about external validation of metrics,
see ESRS2 BP-2
RESOURCE OUTFLOWS (E5-5)
Resource outflows mainly include products and packaging
sold through Komplett Group’s business units. While most
products are externally manufactured, our own PC assembly
and return schemes represent our direct influence on
circular outcomes. Consequently, resource outflows from
our own operations primarily relate to how we enable and
communicate circular product and packaging choices,
facilitate repair and reuse services, and support responsible
end-of-life management.
Impacts, risks and opportunities
Komplett Group’s main environmental impacts related to
resource outflows stem from the limited durability and
reparability of electronic products, which may lead to
premature disposal and e-waste generation. Short product
life cycles contribute to higher demand for raw materials and
larger waste volumes. We also recognise that trade-in and
return schemes could unintentionally increase e-waste if not
accompanied by effective repair and reuse mechanisms.
Regulatory risk arises from tightening EU requirements on
extended producer responsibility and mandatory e-waste-
collection targets, which may increase compliance costs.
Reputational risk is linked to stakeholder expectations
for circular product design. At the same time, significant
opportunities exist to extend product lifetimes and recover
value through refurbishment, resale, and material recycling.
Cooperation with suppliers to improve design for repair and
durability, combined with continued expansion of take-
back and repair programmes, strengthens compliance,
reduces environmental footprint and enhances customer
loyalty. These factors are integrated into the group’s
double-materiality assessment and overall circular economy
strategy (see ESRS 2 IRO-1 and E5 IRO-1).
Product and material outflows
Downstream outflows mainly comprise electronic products
sold to customers that later enter reuse, refurbishment or
recycling systems. Through NetOnNet Byt Inn, Webhallen
Revive and Komplett FLEX, customers can return or trade in
used electronics, which are subsequently refurbished, resold
or recycled through certified partners. The group participates
in national collection systems in Norway and Sweden for the
sorting, reuse and recycling of electronic waste.
Durability, reparability and recyclability of products
To assess resource outflows, we have analysed the durability,
reparability, and recyclability of products, using a combination
of direct measurements and estimations based on reliable
external and internal data sources. Durability is estimated
using the warranty periods of our private label products as a
proxy for product lifespan. In the absence of comprehensive
data from suppliers, this approach provides a consistent basis
for estimation across all product categories.
Industry average durability is determined using complaint
deadlines sourced from the Norwegian Consumer
Authority (Forbrukertilsynet) and the Swedish Tax Agency
(Skatteverket). Regulatory complaint deadlines are assumed
to indicate how long a consumer can expect a product to
last. Based on this approach, we estimate the expected
durability of all product categories to be 100 per cent of the
industry average.
Given the variability of warranties across producers,
we acknowledge that this estimate may not fully reflect
the actual lifespan of all products we sell. However, in
the absence of supplier-specific figures, we have taken
a conservative approach to ensure a reasonable and
consistent estimate of product durability.
For reparability disclosures, we have employed the
recognised French Repairability Index, which evaluates
key factors such as documentation availability, ease of
disassembly, accessibility and cost of spare parts, and
specific product features. Each criterion is scored from 0 to
20, and these scores are summed to a total out of 100. This
total is then divided by 10 and rounded to one decimal place
to give the final grade on a scale from 0 to 10. A higher score
indicates better repairability.
Product group
Repairability
(French repairability Index)
Consumer electronics 7.7
Computing 7.1
Home 7.4
Telecom 6.5
Repairability scores are collected for the top ten best-
selling products across Komplett Group’s ten main product
categories, which are further aggregated for reporting
purposes. Scores are sourced from manufacturer websites,
Amazon.fr, Conrad.fr, and other publicly available data. For
some of our product categories scores are unavailable for all
the top ten best-selling products, and for those categories
we have used a minimum of five repairability scores to
calculate category averages.
The lowest repairability score within each category is
chosen as a conservative indicator of overall reparability,
except for Home which is a weighted average due to large
differences between the repairability of small and major
domestic appliances. Furthermore, the repairability score
for the Computing category currently only considers laptops.
However, this category also includes desktops and system
integrations, which are generally more repairable than
laptops.
For recyclability, we have considered the rates of recyclable
content in both products and packaging. The recyclable
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content in products is approximately 77 per cent and 71 per
cent for packaging. Product categories consistent with
those used in other reporting areas have been analysed, with
data on recycling potential sourced from waste manage-
ment partners such as Norsirk, Norsk Ombruk, Recipo,
and Franzefoss. Supplier reports have provided additional
insights into the recyclability of packaging materials. For our
estimates, we have treated all products sold by Komplett
Group as electronics and presuming that recyclability rates
reported by partners reflect economic feasibility. This anal-
ysis has provided both potential and actual re cycling rates,
using waste management performance as a benchmark.
Waste management
Effective waste management is integral to Komplett Group’s
circularity strategy. Waste from operations mainly consists
of paper and cardboard, plastics, wood, metals, glass, and
electronic waste. Mixed residual and organic fractions are
primarily treated through recycling or energy recovery. In
2025, total waste generated amounted to 2 462 tonnes, of
which 62.3 per cent was recycled or recovered as energy.
These waste profiles are comparable to those of peers
within the same sector.
Certified operators in Norway and Sweden, such as Norsirk,
Norsk Ombruk, Recipo, Franzefoss, El-kretsen, and Stena
Recycling, handle hazardous fractions and recover valuable
components. Products containing electronic materials may
include substances such as lead, chromium, mercury, and
cadmium that require careful handling. Komplett Group
therefore cooperates with certified partners to ensure
safe treatment of e-waste and encourages customers to
return used or damaged electronics for proper recycling.
This practice helps prevent pollution of soil and water
while recovering valuable metals for reuse. Customers
are encouraged to return obsolete electronics for proper
treatment through these systems.
We continually work to find solutions to reduce waste in
our operations and to help our customers do the same.
This includes establishing a sustainable waste system
and recovering valuable resources more efficiently by
incorporating them into the life cycle of new products and
services. Waste generated from harvesting and extraction
of raw materials is considered significant, as well as
waste from production of components such as plastic
components.
By partnering with waste management actors in Norway
and Sweden, along with our suppliers, we have established
efficient ways to collect electronic waste from our customers.
We also offer customers the opportunity to buy used and
remanufactured products, in addition to trade-in options.
We have calculated waste metrics using actual data collec-
ted across Komplett Group facilities, including offices,
warehouses, and retail outlets in Norway and Sweden.
Each company has gathered waste data directly from
supp liers, documenting types of waste, both hazardous
and non-hazardous, and their management processes. In
Norway, partners such as Norsirk, Norsk Ombruk, Recipo,
and Franzefoss handled waste for Komplett Services and
Distribusjon, while other partners like El-kretsen and Stena
Recycling managed waste for Webhallen and NetOnNet in
Sweden. This data was collected using a process aligned
with GHG accounting practices, ensuring accuracy and
completeness.
Disclosure of metrics estimated using indirect sources and
correction of prior reporting errors (BP-2)
Komplett Group’s resource inflow and outflow metrics
incorporate value chain data estimated using indirect
data sources due to limited availability of direct data from
suppliers. For inflows, we rely on assumptions about material
composition and recyclability rates based on supplier reports,
public data, and waste management partners. For outflows,
repairability and recyclability rates are estimated using indices,
external data, and assumptions about industry practices.
The preparation of these metrics is based on proxy data,
industry guidelines, and assumptions derived from internal
and external sources, resulting in a moderate level of
accuracy. Gaps in supplier data and a lack of standardised
reporting contribute to inherent limitations.
To enhance accuracy, we plan to improve supplier
engagement, expand data collection processes, and
align with industry standards, aiming to establish a sound
foundation for future reporting periods.
Komplett Group’s insight into the classification of hazardous
waste within electrical and electronic waste streams has
improved significantly with our waste reporting in 2025.
This is supported by more detailed sorting processes and
enhanced identification of components such as batteries
RESOURCE OUTFLOW
Tonnes 2025 2024
Total waste generated 2 462 1 960
Hazardous waste diverted from disposal 2 5
Hazardous waste diverted from disposal due to preparation for reuse - -
Hazardous waste diverted from disposal due to recycling 1 2
Hazardous waste diverted from disposal due to other recovery operations 1 3
Non-hazardous waste diverted from disposal 2 447 1 943
Non-hazardous waste diverted from disposal due to preparation for reuse 5 -
Non-hazardous waste diverted from disposal due to recycling 1 529 1 173
Non-hazardous waste diverted from disposal due to other recovery operations 913 770
Hazardous waste directed to disposal 0 0
Hazardous waste directed to disposal by incineration - -
Hazardous waste directed to disposal by landfilling 0 0
Hazardous waste directed to disposal by other disposal operations - -
Non-hazardous waste directed to disposal 13 12
Non-hazardous waste directed to disposal by incineration 1 0
Non-hazardous waste directed to disposal by landfilling 12 12
Non-hazardous waste directed to disposal by other disposal operations - -
Non-recycled waste 927 785
Percentage of non-recycled waste 37.66% 40.06%
Disclosure of composition of waste - -
Disclosure of waste streams relevant to undertaking’s sector or activities - -
Disclosure of materials that are present in waste - -
Total amount of hazardous waste 2 5
Total amount of radioactive waste - -
and chemical- containing items. As a result, we have reclas-
sified our estimated data from 2024. Previously reported
hazardous waste figures are adjusted from 293 tonnes to 5,
to align with the updated categorisation and definitions.
> For list of KPI metrics that are subject to uncertainty and
more information on external validation of metrics, see ESRS
2 BP-2
Resource outflow
In Komplett Group’s operations, waste materials include
recyclable metal and glass, packaging plastics, and paper
and cardboard. Electronic waste, including mixed EE waste,
contains valuable components and requires careful disposal.
Mixed, residual, and organic waste, such as packaging
remnants, are mainly managed through recycling and energy
recovery to minimise environmental impact. This is very
similar to waste streams in our sector and for companies
with similar activities.
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Komplett Group is committed to providing equal opportunities for all employees and
promoting an inclusive workplace where diversity and respect are fundamental values.
We ensure fair treatment, equal access to development, and a culture of belonging across
all operations.
Material ESRS topics
Material ESRS
sub-topics Part of the value chain where impact was material
Impact
materiality
Financial
materiality
S1: Own workforce Equal treatment and
opportunities for all
Upstream Own operations Downstream High High
OWN WORKFORCE
INTEGRATION INTO STRATEGY AND BUSINESS MODEL
(S1.SBM-3)
Equal treatment and opportunities for all are material to our
business and embedded in our core strategic focus areas,
HR and sustainability strategies. Diversity, competence
development and employee engagement are key enablers
of our business model, which depends on skilled logistics,
technology and customer-service personnel. These topics
influence our ability to attract and retain talent, drive
innovation and ensure operational excellence.
Our governing bodies monitor workforce-related matters
through annual reports from group HR, employee-survey
results and performance indicators such as turnover, gender
balance and training participation. The board of directors,
through its ESG oversight, reviews workforce topics as part
of the group’s sustainability agenda and long-term value
creation.
> For more information on our strategic focus areas,
ambitions, and targets, see ESRS 2 SBM-1
Disclosures cover all employees; permanent, temporary,
trainees and employees on non-guaranteed hours, across
Norway and Sweden. Individuals engaged through staffing
agencies or as independent contractors, including our
China-based team, are considered non-employees and
are therefore outside the scope of this reporting topic.
Individuals subject to material impacts, regardless of
contract type, carry out a variety of roles, including
warehouse management, customer service, administrative
duties, and IT development.
We operate in a traditionally male-dominated sector, which
results in an imbalance in gender representation across our
workforce. This may limit diversity and equal opportunities.
While training and development initiatives are in place, there
is room to further develop learning materials and improve
the structure and implementation of training programmes
across the group. Promoting equal opportunities and access
to training is viewed as a key opportunity that supports
competence development and enhances our position as an
attractive employer.
The risk of forced or child labour is assessed as low, given
that our own workforce operates in countries with strong
labour legislation. No material impacts from green transition
plans were identified for our own workforce.
SOCIAL INFORMATION
POLICIES RELATED TO OWN WORKFORCE (S1-1)(MDR-P)
Our commitment to employee-well-being, safety, and
develop ment is anchored in the following group-wide
policies:
X Code of conduct – defines ethical behaviour, equality
and respect in the workplace.
X HR policy – sets standards for recruitment, diversity and
inclusion, skills development and working conditions,
with local HR procedures ensuring consistent
application across subsidiaries.
X Sustainability policy – affirms our commitment to
human rights, prohibiting forced and child labour,
human trafficking, and is aligned with the UN Global
Compact, OECD Guidelines, United Nations Convention
against Corruption (UNCAC), and ILO Conventions.
These policies are available and apply to all employees and
support our strategic focus area of being an attractive,
responsible employer.
> For more details about key contents, scope and
implementation of the policies, see ESRS 2 MDR-P
Material impacts on our own workforce are identified
through regular HR risk assessments, employee surveys and
workplace-safety evaluations. Results are reviewed by group
HR and local management to identify corrective actions
and areas for improvement. Implementation of our policies
is ensured through management accountability, annual
performance dialogues and inclusion of relevant KPIs in
business-unit objectives.
The effectiveness of our HR and diversity policies is
assessed using indicators such as turnover, absence, gender
balance, training hours, and employee-satisfaction scores.
Progress is monitored continuously, forming the basis for
improvement actions and resource allocation.
Policies are communicated to all employees through
onboarding training, intranet, e-learning modules, and
leader briefings. Managers are responsible for ensuring that
employees understand and apply the policies in their daily
work.
To enable remedy for human-rights impacts, we maintain
a confidential whistleblower channel open to employees,
suppliers and customers. Reports are investigated promptly,
independently and objectively, and corrective measures
are implemented in cooperation with unions or relevant
authorities. Our Code of Conduct and HR Policy explicitly
prohibit discrimination and harassment based on gender,
nationality, ethnicity, disability, sexual orientation, age or
religion. All employees receive training on these policies to
ensure awareness and accountability.
Through strong governance, clear policies, transparent
communication and systematic monitoring, Komplett Group
fosters a safe, inclusive and respectful workplace. These
measures ensure compliance with international standards
and the effective management of workforce-related
impacts, risks and opportunities, supporting our long-term
strategic goals.
> For more details about how the group’s policies outline
procedures and ways of working related to human rights and
material impacts in own workforce, see ESRS 2 MDR-P
> For more details about the group’s policies related to
human rights and material impacts in own workforce, see
“Embedding sustainability in our policies and processes” in
ESRS 2 MDR-P
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PROCESSES FOR ENGAGING WITH OWN WORKFORCE AND
WORKERS’ REPRESENTATIVES (S1-2)
Communication and collaboration with our employees and
their representatives are integral to our commitment to
transparency and inclusivity. Our engagement processes
enable open dialogue and active participation in decision-
making on matters affecting employees’ well-being and
development. Through these processes, we gain valuable
insights from all parts of the organisation, including margin-
alised and particularly vulnerable employees. The chief HR
officer is responsible for ensuring that these engagement
processes are implemented, monitored and that their
outcomes inform strategic and operational decisions.
PROCESSES TO REMEDIATE NEGATIVE IMPACTS AND
CHANNELS FOR EMPLOYEES TO RAISE CONCERNS (S1-3)
All employees at Komplett Group, as well as business
partners and suppliers, are encouraged to report suspected
breaches of our code of conduct, policies or laws related to
our operations or supply chain. There is a strict protection
of whistleblowers in line with our whistleblower policy.
Reports can be made through our whistleblower channel,
with the option to remain anonymous, or by any other means
preferred by the whistleblower. Through regular interactions
with employees and close monitoring of the whistleblower
channel, we consider our process for raising concerns and
ensuring employees’ trust to be robust.
Addressing negative impacts and providing channels for our
employees to voice their concerns are integral components
of our social responsibility. We have established effective
mechanisms for reporting and addressing concerns in
addition to the whistleblower programme, including bi-
weekly pulse surveys and regular forums where employees
can express their thoughts and bring attention to any
issues they may encounter. These are all vital measures
and components in remediation if we were to cause or
contribute to negative impacts on our employees.
When Komplett Group causes or contributes to a material
negative impact on our own workforce, remedial actions are
determined on a case-by-case basis. Typical steps include
assessing the situation, creating a tailored remediation plan,
allocating appropriate resources and monitoring the out-
come until it is resolved. Throughout the process, we remain
committed to tracking the effectiveness of all actions taken
to ensure continuous improvement and accountability.
> For more information on whistleblower policy and
principles describing the follow-up process of concerns
raised and protection against retaliation, see G1-1
TAKING ACTION (S1-4)(MDR-A)
Employee satisfaction and well-being are top priorities for
Komplett Group. Actions are designed to mitigate negative
material impacts and dependencies on our own workforce
while pursuing opportunities for development and inclusion.
Priorities are based on our materiality assessment and
employee-survey results, focusing on diversity, inclusion,
and continuous learning.
All key workforce actions follow the time horizons defined
in our ESRS reporting framework: short-term actions are
implemented within the next reporting year, medium-term
actions within one to five years, and long-term actions
beyond five years. Current actions are primarily short- and
medium-term and are expanded or adjusted annually based
on employee feedback and HR monitoring.
For more information about the processes for engaging with
our own workforce and workers’ representatives, including
the working environment committee and Winningtemp, see
S1-2.
Actions to manage the material impacts, risks and
opportunities related to our own workforce are taken both
at group level and by each company. At group level, the chief
HR officer has the overall responsibility for material impacts
on our own workforce. This includes, but is not limited to,
operational responsibility for monitoring Winningtemp.
Most workforce actions are implemented locally by
company management teams. Examples include regular
employee dialogues, workplace check-ups in stores, non-
discrimination in recruitment, preventive health services
through occupational-health partners, and voluntary health
insurance. Social events always offer non-alcoholic options,
and dietary, cultural and religious needs are respected. A
notable initiative, Mental Health Awareness Week (“Psykt
bra på jobb”), held at Komplett Services in connection with
World Mental Health Day, featured lectures and activities to
promote mental well-being. Positive effects were observed
through improved scores in the Winningtemp survey.
WORKFORCE REPRESENTATION AND ITS ENGAGEMENT PROCESS
Description and approach
Employee representatives Komplett Group values social dialogue and collective bargaining. Employees are given platforms to
contribute to decision-making regarding compensation, well-being, inclusion, and working conditions.
The group upholds human rights principles, including freedom of association and collective
bargaining, as defined by the Universal Declaration of Human Rights (1948), the two international
covenants on civil and political rights (1966) and economic, social and cultural rights (1966), and the
core conventions of the International Labour Organization (ILO).
Collective bargaining
agreements
Komplett Group is part of employer associations NHO Service and Virke (Norway) and Svensk Handel
(Sweden). Agreements between Svensk Handel and relevant unions apply in Sweden, while the EL & IT
Forbundet and Abelia agreements apply in Norway.
Working environment
committee (AMU)
AMU is a decision-making body for workplace safety and environmental matters at Komplett
Services, consisting of six representatives (three from the employer, three from employees), plus an
occupational health service representative. The committee meets quarterly to oversee health, safety,
and welfare initiatives.
Employee board At Komplett Services, an employee-led board, facilitated by HR, meets regularly to implement
measures improving the psychosocial work environment. Employees can provide input on workplace
issues. At NetOnNet and Webhallen, similar initiatives called Eventpatrullen and Event-committee
organise social activities for both office staff and warehouse employees.
Employee surveys Bi-weekly pulse surveys via Winningtemp assess employee satisfaction and engagement, enabling
real-time tracking of workplace conditions and identifying areas for improvement. Ironstone is not
using this platform.
Information meetings Townhall and subsidiary-level meetings with top management provide employees with direct
communication channels to express concerns and contribute with ideas. The frequency may vary,
from monthly in certain periods, to weekly in peak periods.
Leadership engagement Leadership teams across the group meet annually to discuss strategy, culture, and employee
engagement. Regular appraisals and performance reviews ensure open dialogue between employees
and leaders.
Stage at which engagement with relevant stakeholders occurs, type of engagement and frequency.
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> For more information and description of the employee
board, see processes for engaging with own workforce and
workers’ representatives in S1-3
Resources
Komplett Group allocates organisational, financial, and
technological resources to manage the material impacts,
risks and opportunities related to our own workforce. The
chief HR officer and subsidiary HR teams form the core
operational capacity, supported by line managers who
ensure day-to-day follow-up of employees.
Resources include dedicated HR personnel, training and
upskilling initiatives, digital tools such as Winningtemp,
health and safety services, and systems for recruitment,
reporting and competence management. Each company
allocates annual budgets for employee development,
working-environment measures and well-being activities,
ensuring that actions can be implemented in line with
strategic priorities. These resources ensure that identified
impacts can be addressed effectively and that the group
maintains sufficient capacity for monitoring, follow-up and
continuous improvement.
Komplett Group assesses whether actions related to our
own workforce require significant operational or capital
resources by applying the same materiality and governance
principles used in our financial planning and management
processes. Resources are considered significant where
actions require dedicated funding beyond ordinary HR
operations, entail substantial organisational change, or
require approval through senior management or board-level
governance.
Actions related to our own workforce are primarily resourced
through existing organisational capacity, internal expertise
and standard HR budgets. No workforce-related actions in
the reporting period have required significant operational
or capital expenditure beyond ordinary business operations.
Consequently, no separate disclosure of financial resources
under ESRS S1-4 is required for the reporting year.
Monitoring and evaluation of effectiveness
The effectiveness of workforce actions is monitored
continuously through the Winningtemp engagement
platform and regular HR reporting. Indicators such as
engagement score, turnover, absenteeism, and training
participation are reviewed monthly. Results are discussed by
Group HR and executive management and feed into action
plans and the next year’s HR priorities.
To ensure clarity between actions, measurement methods
and results, Komplett Group distinguishes between what
is implemented (actions), how effectiveness is assessed
(measurement methods) and what is observed (results).
Measurement methods
Effectiveness is assessed through a defined set of tools.
These include Winningtemp for employee satisfaction, HR
operational metrics such as turnover, absenteeism, training
participation, recruitment statistics, and incident and
whistleblowing records. These data sources form the basis
for evaluating whether actions have the intended effect.
> For more information about external validation of metrics,
see ESRS2 BP-2
Results
Results disclosed in this sustainability statement reflect
data collected through these tools, for example, improved
Winningtemp scores following Mental Health Awareness
Week, gender balance metrics derived from payroll data, and
the absence of confirmed discrimination cases. By reporting
actions and outcomes separately, Komplett Group ensures
transparency in how effectiveness is measured.
All actions are aligned with Komplett Group’s strategic
goal of being an attractive and responsible employer. They
contribute directly to the group’s long-term sustainability
objectives and strengthen its ability to attract and retain
talent in a competitive industry. Lessons learned from group
and company initiatives are evaluated annually to ensure
continual improvement.
No material negative impacts on employees have been
identified during the year, and no remediation actions were
required. Moreover, no negative impact on employees from
the transition to a greener climate-neutral economy has
been identified. Nevertheless, preventive measures and
employee feedback remain central to maintaining a positive
work environment and supporting the group’s culture of
openness and respect.
TRACKING EFFECTIVENESS OF POLICIES AND ACTIONS
THROUGH TARGETS (S1-5)(MDR-T)
To maintain and strengthen our position as an attractive
and inclusive employer, Komplett Group has established two
strategic targets for our own workforce: Industry-leading
employee temperature and gender balance in leadership
positions. Both targets are derived from our materiality
assessment and align with our HR policy and code of
conduct, addressing the material impacts and opportunities
linked to equal treatment and inclusion. Target-setting
involves HR representatives from the business units, and
the target is overseen by the chief HR officer. In developing
the targets, HR leaders and workers’ representatives were
consulted to ensure that the ambitions reflect workforce
expectations and local working conditions.
ATTRACTIVE AND
INCLUSIVE EMPLOYER
Industry-leading
employee temperature
Gender balance in
leadership positions
Industry leading employee temperature
Our goal is to achieve a Winningtemp score above the
industry index for retail companies. The target is relative
and measured through our employee satisfaction survey
and gives an indication of how our employees feel about
our company. The scale ranges from 1 to 10 and measures
engagement, leadership, teamwork, and personal
development.
Surveys are conducted bi-weekly among all employees
(except Ironstone) and benchmarked externally to ensure
objectivity. The survey covers a broad range of questions
related to key engagement drivers, such as personal
development, leadership, and team dynamics. The
temperature score is designed not only to track overall
satisfaction but also to identify potential risks and areas for
improvement.
Baseline year 2023
7.7 vs. industry index 7.7 equivalent to industry index
Performance 2024
7.7 vs. industry index 7.6 relative improvement
Performance 2025
7.9 vs. industry index 7.85 maintaining scores above
industry average
The target has no fixed end-year but is evaluated annually,
with continuous tracking through the Winningtemp platform.
The platform is AI-powered, and it is used to ensure
neutrality and eliminate internal bias in the measurement
process. Results are discussed by managers and HR,
and action plans are developed for areas scoring below
expectations. No changes in the target or underlying
measurement methodologies, significant assumptions,
limitations, sources or process to collect data were made in
2025. Hence, the results are comparable.
Through focused efforts in 2025 we have experienced
an increase in employee satisfaction to 7.9, compared to
an industry average of 7.85. The industry index was 7.9 in
Norway and 7.8 in Sweden. In 2024, performance was 7.7/10
for Komplett Group against an industry index of 7.6. The
highest scores for all companies are related to leadership,
team, and engagement. The weakest area for all companies
is personal development.
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KOMPLETT
TEMPERATURE
7.90
Average value in
Komplett Group 2025
INDEX
7.85
Compared with other
organisations within the
same industry
The target is monitored twice a month in Winningtemp
by all managers and is overseen by the chief HR officer.
All employees have the opportunity to add comments
anonymously, which will always be answered. The response
rate of 59 per cent is a decrease from 70 per cent last
year. We still consider this response rate to be sufficient
to provide a representative assessment of employee
satisfaction but will monitor and work to improve the
response rate going forward. Lessons learned from the
ongoing monitoring include the need to continue to
strengthen initiatives on personal development, and these
insights guide yearly adjustments to HR priorities and
training efforts.
Gender balance in leadership positions
Komplett Group aims for gender balance, defined as 40-60
per cent representation of both genders, in all leadership
positions by 2030. This ambition reflects our commitment
to diversity and our efforts to attract and retain talent in a
male-dominated industry. The target was developed through
consultation with HR leaders and employee representatives
across subsidiaries to ensure alignment with local condi-
tions and workforce aspirations. Progress is measured
annually, and the results are discussed with HR and manage-
ment teams to identify barriers, such as recruitment pipeline
challenges or uneven promotion patterns, and to update
action plans where needed.
In 2025 the share of female leaders in the group in total was
22 per cent. The share at top management level was 12.5 per
cent, while the share at subsidiary management level was
26.9 per cent.
SHARE OF FEMALE LEADERS
31.12.2025 31.12 .20 24
Group top management level 12.5% 25%
Subsidiary management level 26.9% 36%
Komplett Group 22.0% 28%
Monitoring, review and revision
Progress toward all workforce targets is reviewed at least
once a year as part of the HR strategy review. Data from
Winningtemp and gender balance reporting are analysed for
trends. Any methodology or scope change is documented to
ensure comparability across years.
The workforce is indirectly engaged in the tracking process
through continuous survey input, annual HR dialogues
and representation through the working environment
committees. This provides a structured channel for
employees to influence follow-up actions and improvements.
Insights from the tracking process feed into annual HR
planning, and recurring issues, such as development needs
or representation gaps, inform adjustments to policies,
training and leadership expectations.
Through clear and measurable workforce targets, Komplett
Group monitors the effectiveness of its policies and
actions and drives continuous improvement in employee
engagement and diversity. These goals reinforce our
long-term strategy to be an inclusive, high-performing and
sustainable organisation.
CHARACTERISTICS OF OUR EMPLOYEES (S1-6)
Komplett Group’s own workforce consists of all employees
under contractual obligations with the group or our
subsidiaries. Employees hired through third-party providers
are counted as non-employees and therefore excluded from
these figures. This category includes hired labour resources
at our offices in China.
At the end of 2025, Komplett Group employed 1 459 people in
total, of whom 95 were temporary employees and 237 were
new hires during the year. This represents a slight decrease
in the workforce compared to 2024, with 1 482 total
employees, of which 155 were temporary employees and 172
were new hires.
The gender balance at group level was 68.9 per cent
men, 31.0 per cent women and 0.1 per cent other in 2025,
compared to 68.2 per cent men, 31.7 per cent women and 0.1
per cent other in 2024.
EMPLOYEE HEADCOUNT BY GENDER
2025 2024
Male 1 005 1 011
Female 453 470
Other 1 1
Not reported - -
Total employees 1 459 1 482
In 2025, the share of permanent employment was 90 per
cent in total, 90 per cent for men and 91 per cent for women.
This represents an increase from 2024, when the share was
88 per cent in total, with 81 per cent for men and 88 per cent
for women.
Komplett Group’s employees work in Norway and Sweden,
with the main share of 1 014 in Sweden in 2025, compared to
1 026 employees in 2024.
EMPLOYEE HEADCOUNT IN COUNTRIES
2025 2024
Norway 445 456
Sweden 1 014 1 026
Employee headcount in countries where the Komplett Group has
at least 50 employees representing at least 10 per cent of the
total number of employees.
Two hundred and ninety-four employees left the group
during 2025, representing a total turnover of 20 per cent rel-
ative to the average number of employees for the year. This
is an increase compared to 2024 figures, were 123 employ-
ees left the group, representing a total turnover of 9 per cent
relative to the average number of employees for the year.
To ensure consistency, individual workshops were held
with HR management representatives from all subsidiaries
to align definitions, counting methods and data quality.
Employee numbers are reported as headcount as at 31
December 2025, based on data extracted from each
company’s HR system. This method may yield higher figures
than annual averages because of temporary staff employed
during seasonal peaks.
No changes to definitions, boundaries or data-collection
methods have been made compared to the previous
reporting year. Consequently, results are fully comparable
year over year.
> For more numbers on employees, see note 7 in the financial
statements
DIVERSITY METRICS (S1-9)
Komplett Group defines top management as the members
of group management. As at 31 December 2025, group
management consisted of eight members, of whom one
was a woman, corresponding to a female representation of
12.5 per cent. This represents a decrease from 25 per cent
in 2024. More broadly, across the group, the distribution of
employees by age, in accordance with the ESRS-defined age
classifications, showed that 546 employees were below the
age of 30, 774 employees fell within the age range of 30 to 50,
and 139 employees were above the age of 50. Comparisons
with 2024 figures can be seen in the table below.
AGE DISTRIBUTION ACROSS THE GROUP
Number of employees (headcount) 2025 2024
Below 30 years 546 546
30 – 50 years 774 823
Above 50 years 139 113
REMUNERATION METRICS (S1-16)
The gender pay gap represents the difference in average
gross hourly earnings between women and men, expressed
as a percentage of men’s average pay. In 2025, Komplett
Group’s overall gender pay gap was 0.96 per cent, meaning
that, on gross hourly average, women earn about 99.04 per
cent of what men earn on average per hour. This essentially
balanced distribution of wages between genders aligns with
our strategic focus area related to gender balance in the
group.
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The ratio between the annual total compensation of
the highest-paid individual and the median annual total
compensation for all employees in 2025 was 16.5. This means
that the median annual total compensation represents 6 per
cent of the highest paid individual’s total compensation.
Data for both indicators are compiled at group level using
a harmonised methodology. Both figures include fixed pay,
variable remuneration, and benefits in kind. Each company
provides payroll data in a standardised format to ensure
consistent comparisons across countries, employment
types, and compensation components. For the gender
pay gap indicator, hourly pay is extracted directly from the
HR systems for all employees. Group compliance, group
finance, and HR apply uniform definitions for earnings, full-
time equivalence, and remuneration elements. Currency
conversions follow the same principles as in the financial
statements, and the results for the highest paid individuals
are aligned with the reported figures in the remuneration
report. 2025 is the first year Komplett Group report on
remuneration metrics, hence no comparative figures are
relevant for disclosure.
INCIDENTS, COMPLAINTS AND SEVERE HUMAN RIGHTS
IMPACTS (S1-17)
Komplett Group takes all incidents, complaints and potential
human-rights impacts seriously. Our processes ensure
thorough investigation, documentation and corrective
action whenever needed. Employees are encouraged to use
open communication channels to raise concerns, and our
commitment to respecting human rights in line with the UN
Guiding Principles and the OECD Guidelines for Multinational
Enterprises remains firm.
We have established whistleblower channels both at the
group level and for our subsidiaries. Employees can voice
their concerns through the whistleblower channel, the
Winningtemp platform or other preferred channels. In 2025,
51 complaints related to equal treatment and opportunities
were filed through the different available channels, mainly
Winningtemp. Out of these, one case was identified as actual
discrimination. Any complaints from Webhallen employees
filed between 1 January and 14 November are not included
in these 51 complaints, as system changes in Winningtemp
has resulted in deletion of historical data. The number of
complaints in 2025 represents a decrease from 2024, in
which 147 complaints related to potential discrimination
were filed through our platforms, with one case being
identified as actual discrimination.
No cases related to severe human rights issues and incidents
connected to own workforce have occurred in 2025,
including cases of non-respect of UN Guiding Principles and
OECD Guidelines for Multinational Enterprises. Neither have
any such cases been reported to Komplett Group or to the
National Contact Points for OECD Multinational Enterprises
during the year. We have not received any fines or penalties,
nor been subjected to any compensation claims for damages
due to violations regarding social or human rights factors or
incidents.
Confirmed cases are handled by HR and compliance
departments in cooperation with management. Corrective
actions may include training, policy updates, or disciplinary
measures. Learnings from each case feed into annual
reviews of the Code of Conduct and HR policies and
procedures.
EMPLOYEE HEADCOUNT BY CONTRACT TYPE AND GENDER
Female Male Other
Not
disclosed Tota l
Number of employees 2025 453 1 005 1 1 459
2024 470 1 011 1 1 482
Number of permanent employees 2025 413 906 1 319
2024 412 894 1 306
Number of temporary employees 2025 30 65 95
2024 58 97 155
Number of non-guaranteed hours employees 2025 10 32 42
2024 - - -
Number of full-time employees 2025 265 580 845
2024 274 596 870
Number of part-time employees 2025 178 391 569
2024 415 196 611
EMPLOYEE HEADCOUNT BY CONTRACT TYPE AND COUNTRY
Norway Sweden Tot a l
Number of employees 2025 445 1 014 1 459
2024 456 1 026 1 482
Number of permanent employees 2025 430 889 1 319
2024 371 935 1 306
Number of temporary employees 2025 5 90 95
2024 4 151 155
Number of non-guaranteed hours employees 2025 8 34 42
2024 - - -
Number of full-time employees 2025 372 473 845
2024 360 510 870
Number of part-time employees 2025 63 506 569
2024 15 596 611
CHARACTERISTICS OF OUR EMPLOYEES
1 459
Employees
total
68.9%
Men
237
New hires
0.1%
Other
95
Employees
temporary
31.0%
Women
EMPLOYEE CHARACTERISTICS
(ESRS S1-6)
GENDER BALANCE AT GROUP LEVEL
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Operating across diverse markets and cultures, Komplett Group prioritises responsibility,
fairness and integrity throughout the value chain. We maintain a clear stance against
corruption and unethical behaviour and work continuously to promote transparency and
sound governance. Corporate culture and whistleblower protection are considered material
governance topics. Additional information on corporate governance is presented in our
corporate governance report.
Material ESRS
topics
Material ESRS
sub-topics Part of the value chain where impact was material
Impact
materiality
Financial
materiality
G1: Business
conduct
G1: Corporate
culture
Upstream Own operations Downstream Low High
G1: Protection of
whistleblowers
Upstream Own operations Downstream Low High
BUSINESS CONDUCT
THE ROLE OF THE ADMINISTRATIVE, MANAGEMENT AND
SUPERVISORY BODIES (ESRS 2 GOV-1)
The board of directors is responsible for the oversight of
material matters, including business conduct, while the
group CEO is accountable for implementation and day-
to-day management. The board approves and oversees
key governance policies such as the code of conduct,
sustainability policy and corporate governance policy. The
effectiveness of these policies is monitored through regular
reporting processes.
> For more details about key contents and scope of the
policies, see ESRS 2 MDR-P
The board and group management collectively possess
expertise in areas such as compliance, data protection,
corporate ethics, and sustainability. Moreover, several
board members have undergone training in ethical business
conduct, enhancing their oversight of compliance matters
and contributing to a culture of integrity within the
organisation. The board has participated in ESG training
covering regulations, responsibility, and material topics.
In addition, through regular discussions on sustainability-
related matters, the board has continued to strengthen its
understanding and maturity in ESG topics.
> For more details about the relevant expertise and
sustainability-related experience of our board of directors
and group management, see ESRS 2 GOV-1
> For additional information related to the board of directors
and group management, see the board and management
presentation
BUSINESS CONDUCT POLICIES AND CORPORATE CULTURE
(G1-1) (ESRS 2 MDR-P)
Komplett Group has identified corporate culture as a
material factor for long-term value creation. Our policies
addressing business conduct and corporate culture
include the code of conduct, sustainability policy, supplier
code of conduct, anti-corruption and bribery policy, and
whistleblower policy. These policies guide how we identify,
assess and manage risks and opportunities related to
responsible business conduct. In 2025, we initiated
e-learning modules covering business conduct, including
corporate culture, whistleblowing and anti-corruption.
> For more details about how we embed sustainability in
our policies and processes to manage material IRO’s, see
“embedding sustainability in our policies and processes”
Establishing, promoting and evaluating culture
We foster a culture of openness and accountability
through regular town-hall meetings, leadership check-ins,
employee surveys and intranet channels that enable direct
communication across the organisation. Results from
employee engagement surveys and HR metrics are used
to evaluate our corporate culture and to identify areas for
improvement.
Training on business conduct
Mandatory onboarding training covers our code of conduct,
anti-corruption and bribery, and whistleblower policies and
shall be provided to all employees across our organisation.
In addition, employees have access to information, training
and guidance on our standards and procedures for ethical
business conduct through our subsidiaries’ intranet pages
and e-learning platforms.
Whistleblowing
Our whistleblower channel is available to all employees,
customers, business partners and the public. Reports can
be submitted online, by phone, or in writing, anonymously
and in any language. All reports are initially received by an
independent third party before being handled by our internal
whistleblower team.
We prohibit retaliation against whistleblowers and ensure
confidentiality in all cases. Designated staff who receive
reports are trained in secure handling, investigation and
communication procedures, and all employees receive
information on how to report concerns.
All reported incidents are investigated promptly, indepen-
dently, and objectively. Findings and corrective actions are
documented and monitored until they are resolved. Lessons
learned are shared with relevant functions to strengthen
preventive measures.
In 2025, 19 cases were reported in our whistleblower
channel, compared to six cases in 2024.
Whistleblower principles
Komplett Group has established a common policy and
system for whistleblowing, where the basic principles for
handling reports are as follows:
X All reports are taken seriously
X All reports will be sufficiently investigated within a
reasonable time in a fair, open-minded and objective
manner
X Confidentiality and information security
X Protection of whistleblowers
X Whistleblowers reporting in good faith will not be
subject to reprisals
X Whistleblowers will get timely feedback and information
about the process
X Right to be informed of the nature and basis of any
allegation, and to be heard
X Process documented in writing
Risk management
All operations at Komplett Group are assessed for com-
pliance risks through the Enterprise Risk Management
process. Key risks with respect to business conduct
and corporate culture identified in 2025 were related to
regulatory compliance and reputation.
Procurement and supplier-management functions,
particularly those engaging with suppliers in higher-risk
regions such as China, are considered most exposed to
corruption and bribery risks. Targeted training, contractual
clauses, and supplier audits are implemented to mitigate
these risks.
Through clear policies, effective reporting mechanisms and
continuous training, Komplett Group promotes a culture
of integrity and transparency. These measures enable
the group to manage business-conduct risks proactively
and to embed ethical behaviour across all operations and
relationships.
GOVERNANCE INFORMATION
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Komplett Group, which is listed on the Oslo
Stock Exchange, must comply with Norwegian
legislation, namely the Transparency Act
and the Equality and Anti-Discrimination
Act. These statements are available on our
website, together with our Climate Report for
2025.
TRANSPARENCY ACT ACCOUNT
The Transparency Act supports the protection of basic
human rights and fair working conditions related to
the production of goods and the provision of services.
Komplett ASA and four of its subsidiaries, Komplett
Services AS, Komplett Distribusjon AS, Ironstone AS and
NetOnNet AB, are obliged by the act to carry out and
report on due diligence in accordance with the OECD
Guidelines for Multinational Enterprises on Responsible
Business Conduct.
Webhallen AB, Komplett Services AB and Komplett
Distribution AB are not directly subject to the act.
However, all activities within Komplett Group are
assessed as part of the group’s due diligence. The
Transparency Act Account for 2025 gives an overview
of the companies’ ongoing work to meet their
responsibilities within their own operations, with their
business partners and throughout their supply chain.
> Read more in the Transparency Act Account
EQUALITY AND ANTI-DISCRIMINATION
STATEMENT
The act requires Norwegian companies to disclose
information on gender equality and anti-discrimination.
The act applies to Komplett Services AS, and therefore
the Komplett Services related numbers and statements
are disclosed in this report. Further, information and
numbers regarding Komplett Group in total are disclosed
in our Sustainability statement.
> Read more in the Equality and Anti-Discrimination
Statement
CLIMATE REPORT
The Sustainability statement provides a summary of
Komplett Group’s greenhouse gas (GHG) emissions. In
addition, we publish a climate report, which explains and
accounts for our emissions, estimations, calculations
and data capture in more detail. Tracking our GHG
emissions is a vital part of our climate change strategy,
helping to understand our impacts and identify areas for
reducing GHG emissions. It also allows us to compare our
performance and monitor progress over time.
> Read more in the GHG emissions in our Climate Report
OTHER REPORTING
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We confirm that the financial statements for the period 1 January up to and including 31 December 2025 have,
to the best of our knowledge, been prepared in accordance with applicable accounting standards and give a
true and fair view of the assets, liabilities, financial position and profit or loss of the company and the group as a
whole, and that the board of directors’ report includes a fair review of the development and performance of the
business and the position of the company and the group as a whole, together with a description of the principal
risks and uncertainties that they face.
Sandefjord, 17 March 2026
Board of directors, Komplett ASA
The statement from the board has been signed electronically.
STATEMENT FROM THE BOARD OF DIRECTORS
Jaan Ivar Semlitsch
Chair
Fabian Bengtsson
Director
Susanne Ehnbåge
Director
Ingvild Næss
Director
Jan Ole Stangeland
Director
Anders Odden
Worker director
Emelie Victorin
Worker director
Vebjørn Torsetnes
President and CEO
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CONSOLIDATED STATEMENT OF COMPREHENSIVE INCOME
For the year ended 31 December
Amounts in NOK million | Note | 2025 | 2024 |
| Operating revenues | |||
Revenues from sale of goods | |||
Other operating revenues | |||
| Tota l r even ue s | 6 | ||
| Operating expenses | |||
| Cost of goods sold | 15 | ( | ( |
| Employee benefit expenses | 7 | ( | ( |
| Depreciation and amortisation | 11, 12, 19 | ( | ( |
| Impairment | 11, 12, 19 | ( | |
| Other operating expenses | 19, 21 | ( | ( |
Total operating expenses | ( | ( | |
Operating profit | ( | ( | |
| Finance income and expenses | |||
| Share of results of equity-accounted investments | 13 | ||
| Finance income | 8 | ||
| Finance expenses | 8, 19 | ( | ( |
Net finance income and expenses | ( | ( | |
| Profit before tax | 5 | ( | ( |
| Tax expense | 9 | ||
Profit for the year | ( | ( |
Amounts in NOK million | Note | 2025 | 2024 |
| Other comprehensive income | |||
| Items that may be reclassified to profit or loss: | |||
Exchange gains arising on translation of foreign operations | |||
Total comprehensive income | ( | ( | |
| Profit for the year attributable to: | |||
Owners of the parent | ( | ( | |
Tota l | ( | ( | |
| Total comprehensive income attributable to: | |||
Owners of the parent | ( | ( | |
Tota l | ( | ( | |
| Earnings per share | |||
| Continued operation (basic and diluted) - in NOK | 10 | ( | ( |
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CONSOLIDATED STATEMENT OF FINANCIAL POSITION
At 31 December
Amounts in NOK million | Note | 31.12.2025 | 31.12.20 24 |
| NON-CURRENT ASSETS | |||
| Intangible assets | |||
| Goodwill | 11 | ||
| Software | 11 | ||
| Customer relationships | 11 | ||
| Brand names | 11 | ||
Total intangible assets | |||
| Property, plant, and equipment | |||
| Right-of-use assets | 3,19 | ||
| Leasehold improvements | 12 | ||
| Machinery and fixtures | 12 | ||
Total property, plant, and equipment | |||
| Other non-current assets | |||
| Deferred tax asset | 9 | ||
| Investments in equity-accounted associates | 13 | ||
| Other receivables | 4,14 | ||
Total other non-current assets | |||
Total non-current assets | |||
| CURRENT ASSETS | |||
| Inventories | 15 | ||
Total inventories | |||
| Other current assets | |||
| Trade receivables - regular | 4,14 | ||
| Trade receivable from deferred payment arrangements | 4,14 | ||
| Other current receivables | 4,14,19 | ||
Total other current assets | |||
| Cash and bank deposits | |||
| Cash and bank deposits | 4,16 | ||
Total cash and bank deposits | |||
Total current assets | |||
Tota l a s se t s |
Amounts in NOK million | Note | 31.12.2025 | 31.12.20 24 |
| EQUITY | |||
| Share capital | 17 | ||
| Share premium | 17 | ||
Other equity | ( | ( | |
Total equity | |||
| LIABILITIES | |||
| Non-current liabilities | |||
| Deferred tax liabilities | 9 | ||
Provisions and other liabilities | |||
| Interest-bearing loans and borrowings | 4,20 | ||
| Non-current lease liabilities | 19,20,23 | ||
| Other non-current liabilities | 20 | ||
Total non-current liabilities | |||
| Current liabilities | |||
| Short-term loans | 4,16,22,23 | ||
| Trade payables | 4 | ||
| Public duties payable | 4 | ||
| Current income tax | 9 | ||
| Current lease liabilities | 3,19 | ||
| Other current liabilities | 4,6,20,21 | ||
Total current liabilities | |||
Total liabilities | |||
Total equity and liabilities |
91
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CONSOLIDATED STATEMENT OF CASH FLOWS
For the year ended 31 December
Amounts in NOK million | Note | 2025 | 2024 |
| Cash flows from operating activities | |||
Profit before tax | ( | ( | |
Income taxes paid | ( | ( | |
| Depreciation and amortisation | 11, 12, 19 | ||
Impairment | |||
| Share of post-tax profits from equity accounted investments | 13 | ( | ( |
| Finance items | 8 | ||
Changes in inventories, trade payables, and trade receivables | |||
Currency effects | ( | ||
Other changes in accruals | |||
Net cash flows from operating activities | |||
| Investing activities | |||
| Investments in property, plant, and equipment | 11, 12 | ( | ( |
Dividend from associated company | |||
Net cash used in investing activities | ( | ( | |
| Financing activities | |||
| Proceeds from loans and borrowings | 20, 22 | ||
| Repayment of loans and borrowings | 20, 22 | ( | ( |
| Principal paid on lease liabilities | 19 | ( | ( |
| Interest paid on lease liabilities | 8, 19 | ( | ( |
| Interest paid on loans and overdrafts | 8 | ( | ( |
Net cash used in financing activities | ( | ( | |
Net increase in cash and bank deposits | |||
| Cash and bank deposits at beginning of year | 16 | ||
| Cash and bank deposits at end of year | 16 |
CONSOLIDATED STATEMENT OF CHANGES IN EQUITY
For the year ended 31 December
Amounts in NOK million Note Share capital
Share
premium Other equity
Foreign
currency
changes
Tota l
equity
At 1 January 2024 | ( | |||||
Net income of the year | ( | ( | ||||
Other comprehensive Income | ||||||
Total comprehensive income for the period | ( | ( | ||||
| Long-term incentive programme | 18 | |||||
| Issue of share capital | 17 | |||||
Contributions by and distributions to owners | ||||||
Ending balance 2024 | ( | |||||
At 1 January 2025 | ( | |||||
Net income of the year | ( | ( | ||||
Other comprehensive Income | ||||||
Total comprehensive income for the year | ( | ( | ||||
| Long-term incentive programme | 18 | ( | ( | |||
| Issue of share capital | 17 | |||||
Contributions by and distributions to owners | ( | ( | ||||
Ending balance 2025 | ( |
92
BROWSE PAGESEARCHABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
Sandefjord, 17 March 2026
Board of directors, Komplett ASA
Jaan Ivar Semlitsch
Chair
Fabian Bengtsson
Director
Susanne Ehnbåge
Director
Ingvild Næss
Director
Jan Ole Stangeland
Director
Anders Odden
Worker director
Emelie Victorin
Worker director
Vebjørn Torsetnes
President and CEO
The statement from the board has been signed electronically.
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NOTE 02 Critical accounting
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NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
Note 01 General information
headquartered at Østre Kullerød 4, 3241 Sandefjord,
Komplett Group, with its 10 webshops, three differen-
tiated retail brands and 47 stores, is the largest Nordic
online-first electronics retailer. The group offers a
broad range of products and services for consumers,
the business market, and the public sector, and the
product assortment differs between the stores. The
risk profile is relatively similar, but the return profile
varies depending on the main focus of the individual
store. The group has established distribution networks
based on deliveries to the various markets from
warehouses and stores in Norway and Sweden.
The financial statements for 2025 have been prepared
and presented in full compliance with applicable
International Financial Reporting Standards (IFRS), as
adopted by the EU, and the financial statements have
been prepared under the going concern assumption.
The following describes the material accounting
policies used in the preparation of the consolidated
financial statements. These policies are applied in the
same way in all periods presented, unless otherwise
stated in the description.
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NOTE 05 Segment information
NOTE 06 Revenues from contracts
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NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
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NOTE 02 Critical accounting
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NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
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NOTE 01 General information
NOTE 02 Critical accounting
estimates and judgements
NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
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CONTENTS
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NOTE 02 Critical accounting
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NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
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NOTE 02 Critical accounting
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NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
All figures in local currencies in million | 2025 |
| Currency | |
EUR | +/- 241 |
USD | +/- 148 |
Total | +/- 389 |
| Functional | ||
| 31.12.20 25 | currency | |
All figures in local currencies in million | NOK | SEK |
| Exposed currency | ||
NOK | N/A | (91.2) |
SEK | 5.5 | N/A |
EUR | 0.7 | 15.5 |
USD | (1.1) | 15.9 |
DKK | (1.2) | 1.8 |
GBP | 0.0 | 0.0 |
PLN | (0.7) | - |
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NOTE 04 Financial instruments –
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NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
| 0-6 | 6-12 | 1-3 | 3-5 | After 5 | |||
Amounts in NOK million | Tot al | months | months | years | years | years | |
| 31 December 2025 | |||||||
Long-term loans 1) | 915 | 29 | 29 | 857 | - | - | |
Other non-current liabilities 1) | 124 | 1 | 1 | 121 | - | - | |
Short-term loans | - | - | - | - | - | - | |
Trade payables | 2 661 | 2 661 | - | - | - | - | |
Public duties payable | 551 | 551 | - | - | - | - | |
Other short-term liabilities 1) | 652 | 572 | 80 | - | - | - | |
Tota l | 4 903 | 3 815 | 111 | 978 | - | - | |
| 1) | Including future interest payments. |
| 0-6 | 6-12 | 1-3 | 3-5 | After 5 | ||
Amounts in NOK million | Tot al | months | months | years | years | years |
| 31 December 2024 | ||||||
Long-term loans 1) | 995 | 33 | 33 | 930 | - | - |
Other non-current liabilities 1) | 278 | 4 | 3 | 271 | - | - |
Short-term loans | - | - | - | - | - | - |
Trade payables | 2 073 | 2 073 | - | - | - | - |
Public duties payable | 490 | 490 | - | - | - | - |
Other short-term liabilities 1) | 491 | 415 | 77 | - | - | - |
Tota l | 4 328 | 3 015 | 113 | 1 200 | - | - |
| Financial | Financial | Financial | ||
| Financial | assets at | liabilities | liabilities at | |
| assets at | amortised | at fair | amortised | |
| Amounts in NOK million | fair value | cost | value | cost |
| 31 December 2025 | ||||
| Assets | ||||
Non-current receivables | - | 8 | - | - |
Trade receivables | - | 176 | - | - |
Trade receivables - deferred payment arrangements | - | 21 | - | - |
Other current receivables | - | 921 | - | - |
Cash and cash equivalents | - | 814 | - | - |
Liabilities | - | - | - | |
Long-term loans | - | - | - | 800 |
Other non-current liabilities | - | - | - | 120 |
Provisions and other liabilities | - | - | 36 | 16 |
Trade payable, public duties payable, and other current liabilities | - | - | - | 3 852 |
Forward currency contracts 1) | - | - | 10 | - |
| Financial | Financial | Financial | ||
| Financial | assets at | liabilities | liabilities at | |
| assets at | amortised | at fair | amortised | |
| Amounts in NOK million | fair value | cost | value | cost |
| 31 December 2024 | ||||
| Assets | ||||
Non-current receivables | - | 9 | - | - |
Trade receivables - regular | - | 153 | - | - |
Trade receivables - deferred payment arrangements | - | 27 | - | - |
Other current financial assets | - | 709 | - | - |
Cash and cash equivalents | - | 726 | - | - |
Liabilities | - | - | - | 800 |
Long-term loans | - | - | - | 263 |
Other non-current liabilities | - | - | 34 | 11 |
Provisions and other liabilities | - | - | - | 3 053 |
Trade payable, public duties payable, and other current liabilities | 2 | - | - | - |
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NOTE 06 Revenues from contracts
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NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
Note 05 Segment information
Through its well-known brands, Komplett, NetOnNet, Webhallen, Itegra, and Ironstone, the group is serving customers
in the B2C, B2B, and distribution segments. Building on decades of know-how, expertise, and deep customer
commitment, the group enjoys industry leading customer satisfaction and a loyal and growing customer base.
The customers are served from 10 webshops, 13 physical shops, and 34 complementary self-service, logistics and
warehouse shops. With its flexible logistics and delivery platform, the group is at the forefront when it comes to same-
day delivery and last-mile service from its warehouses in Sandefjord, Norway and Borås, Sweden.
For management purposes, the segments are divided relative to whether the customer is a consumer (B2C) or a
company. Further, sales to companies are divided into sale to resellers (Distribution) and sales to companies as the
end user (B2B). The segmentation is independent of the legal structure of Komplett Group and does not necessarily
reflect the legal company in a different country. The main reason for the segmentation is the characterisation of the
consumer, how to drive sales, different gross margins, and different cost structure.
Komplett Services has a significant infrastructure serving all three segments. The cost related to the infrastructure is
allocated to the different segments in proportion to the usage. Webhallen and NetOnNet have since the middle of 2025
been supported by the same infrastructure in Borås. Costs for these operations are allocated between NetOnNet and
Webhallen, but both entities are fully reporting under the B2C segment.
B2C
Komplett Group’s operations in the B2C segment cover sales to private consumers across Norway, Sweden, and
Denmark through the brands Komplett, NetOnNet, and Webhallen.
The group serves the private consumer market for electronics, technology products, and consumer goods through
six online shops, selling products sourced from third-party brands and its own private labels. Komplett serves its
B2C customers on the platforms Komplett.no, Komplett.se and Komplett.dk. Komplett also operates one pick-up
point located at the warehouse in Sandefjord, while the pick-up point in Oslo was closed in 2025. Webhallen is an
omnichannel provider within consumer electronics, with the online platform Webhallen.com and 13 retail stores in
Sweden, located strategically around Stockholm and other bigger cities. NetOnNet has two online shops in Sweden
and Norway, NetOnNet.se and NetOnNet.no, and a total of 34 complementary self-service, logistics and warehouse
shops located in Sweden and Norway.
B2B
Komplett B2B is an online market player for corporate customers in the Nordics focusing on the small and medium-
sized enterprises and small office home office segments.
Komplett B2B offers its customers a fully digital customer journey through its web shops Komplettbedrift.no and
Komplettforetag.se serving the Norwegian and Swedish market, respectively.
Ironstone is a pure cloud technology company offering IT services to corporate customers that complement
traditional hardware purchases. The services Ironstone provides are “Your Employees” and “Your IT-system” and they
are serving both the Norwegian and Swedish markets. The operations in Ironstone are reflected in the B2B segment.
Distribution
The group’s activities in the distribution segment consist of large-scale distribution contracts for sale to resellers and
other big entities not covered by B2B, which are operated under the Itegra brand and its own platform. Itegra is present
in Norway and Sweden and serves its customers through the websites Itegra.no and Itegra.se, respectively.
Other
The “Other” segment represents group costs not allocated to the business segments. Typical cost elements under this
segment include management costs and group strategic initiatives.
IFRS
The different effects of “IFRS 16” (International Financial Reporting Standards) are not part of the operational
measures and the effects of IFRS 16 are captured in this segment.
The segmentation above is according to the internal reporting with the segments having separate management and
employees to run their business.
Transactions between the segments and the legal companies in the group are on arm’s length terms. In all internal and
external reporting, these transactions are eliminated.
Information about the group’s segments is presented on the following page.
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NOTE 06 Revenues from contracts
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NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
PROFIT AND LOSS - 2025
Amounts in NOK million | B2C | B2B | Distribution | Other | IFRS 16 | To t al |
| Operating income | ||||||
Revenues from contract with customers | 11 201 | 1 409 | 2 795 | - | - | 15 405 |
Other operating revenues | 234 | 133 | 2 | 0 | 0 | 370 |
Total operating income | 11 435 | 1 542 | 2 798 | 0 | 0 | 15 775 |
| Operating expenses | ||||||
Cost of goods sold | (9 609) | (1 269) | (2 640) | (1) | - | (13 518) |
Employee benefit expenses | (825) | (87) | (58) | (124) | - | (1 094) |
Depreciation and amortisation | (108) | (16) | (14) | (55) | (215) | (408) |
Impairment | - | - | - | (536) | (3) | (538) |
Other operating expenses | (831) | (78) | (50) | (52) | 239 | (772) |
Total operating expenses | (11 373) | (1 449) | (2 762) | (767) | 21 | (16 330) |
Operating result | 62 | 93 | 35 | (767) | 21 | (556) |
| Financial income and financial expenses | ||||||
Share of profit or loss from associates | - | - | - | 1 | - | 1 |
Financial income | - | - | - | 22 | - | 22 |
Financial expenses | - | - | - | (171) | (22) | (192) |
Net financial items | - | - | - | (148) | (22) | (169) |
Profit or loss before taxes | 62 | 93 | 35 | (914) | (0) | (725) |
| NON-CURRENT OPERATING ASSETS BASED ON GEOGRAPHIC LOCATION – 2025 | ||||||
Amounts in NOK million | Tota l | |||||
Norway | 619 | |||||
Sweden | 2 689 | |||||
Tota l | 3 307 |
PROFIT AND LOSS - 2024
Amounts in NOK million | B2C | B2B | Distribution | Other | IFRS 16 | To t al |
| Operating income | ||||||
Revenues from contract with customers | 10 636 | 1 392 | 2 904 | - | - | 14 932 |
Other operating revenues | 241 | 128 | 3 | (0) | (2) | 369 |
Total operating income | 10 877 | 1 519 | 2 907 | (0) | (2) | 15 301 |
| Operating expenses | ||||||
Cost of goods sold | (9 199) | (1 259) | (2 753) | (1) | - | (13 211) |
Employee benefit expenses | (759) | (89) | (62) | (103) | - | (1 013) |
Depreciation and amortisation | (103) | (14) | (10) | (53) | (204) | (384) |
Impairment | - | - | - | - | - | - |
Other operating expenses | (812) | (83) | (56) | (32) | 222 | (760) |
Total operating expenses | (10 873) | (1 445) | (2 881) | (188) | 18 | (15 368) |
Operating result | 4 | 74 | 26 | (188) | 16 | (67) |
| Financial income and financial expenses | ||||||
Share of profit or loss from associates | - | - | - | 1 | - | 1 |
Financial income | - | - | - | 14 | - | 14 |
Financial expenses | - | - | - | (162) | (23) | (185) |
Net financial items | - | - | - | (147) | (23) | (169) |
Profit or loss before taxes | 4 | 74 | 26 | (335) | (7) | (236) |
NON-CURRENT OPERATING ASSETS BASED ON GEOGRAPHIC LOCATION – 2024
Amounts in NOK million | Tota l |
Norway | 906 |
Sweden | 2 885 |
Tota l | 3 791 |
| Non-current assets for this purpose consist of intangible assets, leasehold improvements, machinery and fixtures and |
right-of-use assets. These are broken down by geographical markets based on the companies’ location.
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NOTE 06 Revenues from contracts
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NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
Note 06 Revenues from contracts with customers
Amounts in NOK million | B2C | B2B | Distribution | Other | To t a l |
Sale to consumers (B2C) | 11 435 | - | - | - | 11 435 |
Sale to corporates (B2B) | - | 1 542 | - | - | 1 542 |
Sale to resellers (Distribution) | - | - | 2 798 | - | 2 798 |
Other | - | - | - | - | - |
Tota l | 11 435 | 1 542 | 2 798 | - | 15 775 |
REVENUES BASED ON GEOGRAPHIC LOCATION OF CUSTOMERS 2025
Amounts in NOK million | B2C | B2B | Distribution | Other | To t a l |
Norway | 3 596 | 1 367 | 2 593 | - | 7 557 |
Sweden | 7 561 | 175 | 205 | - | 7 940 |
Denmark | 279 | - | - | - | 279 |
Tota l | 11 435 | 1 542 | 2 798 | - | 15 775 |
REVENUES BY PRODUCT OR SERVICE 2025
Amounts in NOK million | B2C | B2B | Distribution | Other | To t a l |
Sale of goods | 11 201 | 1 409 | 2 795 | 0 | 15 405 |
Consumer finance | 123 | 2 | 2 | - | 127 |
Commision from insurance | 80 | 1 | - | - | 81 |
Services | 31 | 130 | - | - | 161 |
Other | 0 | - | - | 0 | 0 |
Tota l | 11 435 | 1 542 | 2 798 | 0 | 15 775 |
Amounts in NOK million | B2C | B2B | Distribution | Other | To t a l |
Sale to consumers (B2C) | 10 877 | - | - | - | 10 877 |
Sale to corporates (B2B) | - | 1 519 | - | - | 1 519 |
Sale to resellers (Distribution) | - | - | 2 907 | - | 2 907 |
Other | - | - | - | (2) | (2) |
Tota l | 10 877 | 1 519 | 2 907 | (2) | 15 301 |
| REVENUES BASED ON GEOGRAPHIC LOCATION OF CUSTOMERS 2024 |
Amounts in NOK million | B2C | B2B | Distribution | Other | To t a l |
Norway | 3 214 | 1 353 | 2 734 | (2) | 7 299 |
Sweden | 7 358 | 166 | 173 | - | 7 698 |
Denmark | 305 | - | - | - | 305 |
Tota l | 10 877 | 1 519 | 2 907 | (2) | 15 301 |
REVENUES BY PRODUCT OR SERVICE 2024
Amounts in NOK million | B2C | B2B | Distribution | Other | To t a l |
Sale of goods | 10 636 | 1 392 | 2 904 | - | 14 932 |
Consumer finance | 127 | 0 | - | - | 127 |
Commision from insurance | 74 | 1 | - | - | 76 |
Services | 40 | 126 | 3 | - | 168 |
Other | 0 | - | - | (2) | (2) |
Tota l | 10 877 | 1 519 | 2 907 (2) 15 301 |
103
BROWSE PAGESEARCH
NOTE 01 General information
NOTE 02 Critical accounting
estimates and judgements
NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
Important assessments
The group used the following assessments which have a significant impact on the amount and time of recognition of
income from contracts with customers:
Sale of goods
Liabilities and assets related to sales to consumers with open purchase rights: In the event of ordinary sales to
customers, the group allows the customer to return the item for a full refund. The terms vary from brand to brand and
from country to country depending on the markets but are within the range of 10-90 days (open purchase). Based on
this, a refund liability is recognised (included in the line “Revenues from sale of goods”) and a right to returned goods
(included in the line “cost of goods sold”). Historical data is used to estimate the extent of returns at the time of sale.
Since the proportion of returns has been stable over time it is very unlikely that a significant reversal of income will
occur because of changes in the return grade. The estimates of returns are reassessed on each balance sheet day.
The group’s liabilities for repair and/or exchange of defective products under ordinary guarantees are recognised as a
liability included in the line “Other current liabilities” in the financial statements (see note 21).
Customer loyalty programmes
Komplett has a customer loyalty programme related to sales to consumers where the customer accumulates points
based on completed purchases. Total vested points will put the customer at different levels, which give different
benefits.
Club members in Klubbhyllan, with the NetOnNet card, vest bonus points when they purchase products either in the
stores or online. These points can be exchanged to vouchers and used as discounts on future purchases. The provision
depends on estimates on which discount the points will be generated when they are applied and the likelihood of
actually being applied. These parameters are based on historical experience.
Commissions
The group receives commissions for the distribution of financing via partners Walley and Resurs Bank. The
consideration consists of a fixed part based on volume and a variable part based on the funding period. Since the
finances are not timed, the income recognition of the variable part is postponed until the group is entitled to the
consideration.
All the three brands offer insurance when purchasing specific products, and Komplett acts as an agent in these
transactions and receive a commission from the insurance companies.
Gift certificates & vouchers
Gift certificates can be purchased in webshops and physical stores. The value and the expiration time of the gift
certificates may vary. Until the gift certificate has been used to purchase products, or expired, the value is recognised
as a liability in the balance sheet.
Vouchers are issued to customers when they return a product to the physical stores and, as for gift certificates, these
are recognised as a liability in the balance sheet until they have been used to purchase a new product or expired.
CONTRACT BALANCES FOR CONTRACTS WITH CUSTOMERS
Amounts in NOK million | 2025 | 2024 |
Net refund liabilities | 9 | 9 |
Customer loyalty programme | 5 | 6 |
Gift certificates & vouchers | 32 | 27 |
Tota l | 46 | 42 |
104
BROWSE PAGESEARCH
NOTE 01 General information
NOTE 02 Critical accounting
estimates and judgements
NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
Amounts in NOK million | 2025 | 2024 |
Statutory audit | 5 | 5 |
Other assurance services 1) | 2 | 1 |
Other non-assurance services | 0 | 0 |
Tota l | 7 | 6 |
Amounts in NOK million | 2025 | 2024 |
Salaries | 694 | 666 |
Social security expenses | 192 | 179 |
Contribution to pension schemes | 54 | 48 |
Fees for external staff | 82 | 90 |
Share option plan (see note 18) | (1) | 8 |
Bonuses | 22 | 11 |
Other expenses | 50 | 11 |
Tota l | 1 094 | 1 013 |
The number of full-time equivalents that has been employed during the financial year | 1 122 | 1 157 |
105
BROWSE PAGESEARCH
NOTE 01 General information
NOTE 02 Critical accounting
estimates and judgements
NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
2025 | 2024 | |||||||||||||
| Extra- | Value of | Extra- | Value of | |||||||||||
| Bonuses | ordinary | Other | options | Bonuses | ordinary | Other | options | |||||||
Amounts in NOK million | Salary | earned | items | Pension | benefits | granted | Tot a l | Salary | earned | items | Pension | benefits | granted | Tot a l |
Ros-Marie Grusèn, group CEO | 3.00 | 0.89 | - | 0.58 | 0.40 | 4.36 | 9.23 | - | - | - | - | - | - | - |
Thomas Røkke, group CFO | 4.02 | 1.20 | - | 0.69 | 0.47 | 1.21 | 7.60 | 3.87 | 0.58 | - | 0.65 | 0.47 | 2.36 | 7.93 |
Trygve Hillesland, managing director Webhallen / group CCO | 2.44 | 0.25 | - | 0.30 | 0.20 | 0.69 | 3.89 | 2.12 | 0.33 | - | 0.24 | 0.20 | 0.91 | 3.80 |
Markus Solvik, group CSO | 2.52 | 0.75 | - | 0.33 | 0.19 | 0.76 | 4.55 | 2.43 | 0.36 | - | 0.31 | 0.19 | 1.00 | 4.29 |
Kristian Kjernsmo, group COO | 1.65 | 0.74 | - | 0.20 | 0.13 | 0.74 | 3.46 | - | - | - | - | - | - | - |
Morten Johnsen, managing director Komplett Services | 3.10 | 1.26 | - | 0.45 | 0.01 | 0.94 | 5.75 | - | - | - | - | - | - | - |
Kim Andersson, managing director Webhallen | 0.43 | 0.0 1 | - | 0.09 | - | 0.21 | 0.74 | - | - | - | - | - | - | - |
Robin Malmqvist, managing director NetOnNet | 0.64 | 0.01 | 0.26 | 0.12 | - | - | 1.03 | - | - | - | - | - | - | - |
Josefin Dalum, managing director NetOnNet | 2.64 | - | 0.66 | 0.79 | 0.08 | - | 4.17 | 2.52 | 0.37 | - | 0.88 | 0.08 | 0.99 | 4.83 |
Jaan Ivar Semlitsch, group CEO | 3.94 | - | 1.00 | 0.75 | 0.11 | - | 5.81 | 6.76 | - | - | 1.34 | 0.19 | 4.13 | 12.41 |
Andreas Westgaard, group CCO | 3.77 | - | 4.30 | 0.62 | 0.42 | - | 9.11 | 3.95 | 0.59 | - | 0.66 | 0.19 | 2.41 | 7.81 |
Kristin H. Torgersen, group CHRO | 2.42 | - | 0.83 | 0.30 | 0.16 | - | 3.71 | 2.33 | 0.35 | - | 0.29 | 0.16 | 0.96 | 4.08 |
Erlend Stefansson, managing director Komplett Services | 1.82 | - | 2.08 | 0.26 | 0.13 | - | 4.30 | 3.12 | 0.46 | - | 0.47 | 0.19 | 1.29 | 5.53 |
Anders Torell, managing director Webhallen | - | - | - | - | - | - | - | 0.25 | - | 0.05 | 0.01 | - | 0.30 | |
Tota l | 32.39 | 5.12 | 9.13 | 5.49 | 2.31 | 8.89 | 63.33 | 27.34 | 3.04 | - | 4.88 | 1.67 | 14.05 | 50.97 |
| Opening | Average exercise | Ending | Average exercise | Average | ||||
balance | Granted | Forfeited | Exercised | price (A) | balance | price (B) | maturity | |
Ros-Marie Grusén, group CEO (Aug-Dec) | - | 1 000 000 | - | - | - | 1 000 000 | 11.13 | 3.59 |
Jaan Ivar Semlitsch, group CEO (Jan-Jul) | 1 672 279 | (1 672 279) | - | - | - | - | - | |
Thomas Røkke, group CFO | 1 031 988 | 244 620 | - | - | - | 1 276 608 | 12.29 | 3.17 |
Andreas Westgaard, group CCO (Jan-Nov) | 1 101 113 | (880 891) | (220 222) | 9.20 | - | |||
Markus Solvik, group CSO | 478 348 | 153 340 | - | - | - | 631 688 | 12.73 | 3.16 |
Kristian Kjernsmo, group COO (May-Dec) | - | 150 465 | - | - | - | 150 465 | 15.68 | 3.73 |
Kristin H. Torgersen, group CHRO | 775 583 | (775 583) | - | - | - | - | - | |
Morten Johnsen, managing director Komplett Services (Feb-Dec) | - | 189 677 | - | - | - | 189 677 | 15.68 | 3.73 |
Erlend Stefansson, managing director Komplett Services (Jan) | 620 167 | (445 296) | (174 871) | 9.20 | - | - | - | |
Josefin Dalum, managing director NetOnNet (Jan-Aug) | 281 209 | (281 209) | - | - | - | - | - | |
Trygve Hillesland, group CCO | 258 059 | 139 096 | - | - | - | 397 155 | 11.72 | 3.49 |
Kim Andersson, managing director Webhallen (Oct-Dec) | - | 39 211 | - | - | - | 39 211 | 15.68 | 3.73 |
Tota l | 6 218 746 | 1 916 409 | (4 055 258) | (395 093) | - | 3 684 804 | - | - |
106
BROWSE PAGESEARCH
NOTE 01 General information
NOTE 02 Critical accounting
estimates and judgements
NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
Amounts in NOK million | Role | Committee | 2025 | 2024 |
Jaan Ivar Semlitsch, group CEO (2025-2027) | Chair | - | 0.28 | - |
Jo Lunder (2022-2024) | Chair | - | 0.38 | 0.63 |
Jan Ole Stangeland (2023-2027) | Director | Audit and remuneration | 0.57 | 0.57 |
Ingvild Næss (2023-2027) | Director | Audit | 0.45 | 0.45 |
Fabian Bengtsson (2022-2026) | Director | Audit and remuneration | 0.63 | 0.63 |
Susanne Ehnbåge (2023-2026) | Director | Remuneration | 0.46 | 0.48 |
Anders Odden (2019-2027) | Worker director | - | 0.17 | 0.16 |
Emelie Victorin (2024-2027) | Worker director | - | 0.17 | 0.10 |
Anna Fernmo (2021-2024) | Worker director | - | - | 0.07 |
Ingrid Haugen Fougner (2025-2026) | Observator | - | 0.10 | - |
Sverre Kjær (2021-2026) | Chair | Nomination | 0.08 | 0.08 |
Nina C. Hagen (2021-2026) | - | Nomination | 0.04 | 0.04 |
Martin Bengtson (2023-2026) | - | Nomination | 0.04 | 0.04 |
Tota l | 3.38 | 3.23 |
| Number of shares | |
Ros-Marie Grusén, group CEO (Aug-Dec) | 218 000 |
Trygve Hillesland, group CCO | 45 000 |
Jaan Ivar Semlitsch, chair | 180 000 |
Jan Ole Stangeland, director | 76 296 |
Fabian Bengtson, director (SIBA Invest AB) | 55 581 404 |
Tota l | 56 100 700 |
Amounts in NOK million | 2025 | 2024 |
Interest income | 20 | 12 |
Foreign exchange gains | 1 | 2 |
Other finance income | 1 | 0 |
Total financial income | 22 | 14 |
Amounts in NOK million | 2025 | 2024 |
Interest on debts and borrowings | 154 | 120 |
Interest on leases | 22 | 23 |
Foreign exchange losses | 11 | 0 |
Other finance expenses | 6 | 41 |
Total finance expenses | 192 | 185 |
107
BROWSE PAGESEARCH
NOTE 01 General information
NOTE 02 Critical accounting
estimates and judgements
NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
Note 09 Income tax
TAXABLE INCOME
Amounts in NOK million | 2025 | 2024 |
Profit before tax | (725) | (236) |
Non taxable items 1) | 577 | 31 |
Use of tax loss carried forward | 62 | (4) |
Changes in temporary differences | 183 | 66 |
Taxable income | 96 | (144) |
| Income tax expense: | ||
Current income tax | 3 | - |
Correction of previous years current income taxes | 0 | (3) |
Changes in deferred tax | (69) | (41) |
Total income tax expense | (65) | (44) |
Income tax expense Norwegian operations | (32) | (29) |
Income tax expense foreign operations | (33) | (15) |
Total income tax expense | (65) | (44) |
1)
Includes non-deductible costs such as transaction costs, representation, gifts and non-taxable income such as capital gains and dividends
from associated companies. The majority of non-deductible cost in 2025 relates to impairment.
RECONCILIATION OF EFFECTIVE TAX RATE
Amounts in NOK million | 2025 | 2024 |
Profit before tax | (725) | (236) |
Income tax based on applicable tax rate (22%) | (159) | (52) |
Effect from foreign currency and different tax rates | 2 | 1 |
Changes in not recognised tax loss carried forward | (35) | 1 |
Effect of income from associated company after tax | 0 | - |
Correction of previous years current income taxes | (1) | (4) |
Effect of double tax on branch | 3 | 3 |
Not deductible expenses | 127 | 7 |
Effect of used not capitalised deferred tax asset | (1) | - |
Income tax expense | (65) | (44) |
Effective tax rate | 9.0% | 18.6% |
Amounts in NOK million | 2025 | 2024 |
Intangible assets | 1 483 | 1 449 |
Property, plant, and equipment | (58) | (58) |
Inventories | (12) | (26) |
Receivables | (6) | (5) |
Provisions | (77) | (32) |
Tax losses carried forward 2) | (626) | (535) |
Total temporary differences and tax positions | 704 | 794 |
Temporary differences and tax positions not included in the basis for deferred tax 2) | 79 | 227 |
Basis for deferred tax | 782 | 1 021 |
Net deferred tax | 154 | 206 |
| Specification in the statement of financial position: | ||
Deferred tax asset | 107 | 270 |
Deferred tax | 261 | 63 |
Net deferred tax | 154 | 206 |
| Tax payable in the statement of financial position: | ||
Current income tax payable | 3 | 0 |
Prepaid tax/prior income tax payable | (1) | 8 |
Net tax payable | 2 | 8 |
not been recognised as deferred tax assets.
108
BROWSE PAGESEARCH
NOTE 01 General information
NOTE 02 Critical accounting
estimates and judgements
NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
Note 10 Earnings per share
Amounts in NOK million | 2025 | 2024 |
| Result allocated to the holders of ordinary shares | ||
Profit for the year | (660) | (192) |
Result allocated to the holders of ordinary shares | (660) | (192) |
| Average number of shares | ||
Shares at the beginning of the period | 175 341 161 | 175 341 161 |
Effect of new shares | - | - |
Average number of shares | 175 341 161 | 175 341 161 |
Earnings per share (basic and diluted) - in NOK | (3.76) | (1.10) |
The basic earnings per share are calculated as the
ratio of the profit for the period that is due to the
shareholders of the parent divided by the weighted
average number of ordinary shares outstanding.
Diluted earnings per share
The group has an option programme (see note 18),
but since earnings per share are negative, this has no
dilutive effect. There are also no other instruments that
will have a dilutive effect on earnings per share at 31
December 2025.
| Customer | Brand | ||||
Amounts in NOK million | Goodwill | Software | relationships | names | Tot al |
Cost at 31 December 2023 | 2 389 | 878 | 527 | 1 207 | 5 002 |
Additions | - | 102 | - | - | 102 |
Disposals | - | (143) | - | - | (143) |
Foreign currency effects | 15 | 3 | 6 | 19 | 43 |
Cost at 31 December 2024 | 2 404 | 839 | 533 | 1 227 | 5 003 |
Cost at 31 December 2024 | 2 404 | 839 | 533 | 1 227 | 5 003 |
Additions | - | 86 | - | - | 86 |
Disposals | - | (21) | - | - | (21) |
Foreign currency effects | 41 | 17 | 22 | 77 | 157 |
Cost at 31 December 2025 | 2 445 | 921 | 555 | 1 304 | 5 225 |
Acc. amortisation and impairments at 31 December 2023 | (1 051) | (569) | (262) | - | (1 882) |
Amortisation charge | - | (80) | (52) | - | (132) |
Disposals | - | 143 | - | - | 143 |
Impairments | - | - | - | - | - |
Foreign currency effects | 0 | (1) | (2) | - | (3) |
Acc. amortisation and impairments at 31 December 2024 | (1 051) | (506) | (316) | - | (1 874) |
Acc. amortisation and impairments at 31 December 2024 | (1 051) | (506) | (316) | - | (1 874) |
Amortisation charge | - | (89) | (53) | - | (142) |
Disposals | - | 21 | - | - | 21 |
Impairments | (534) | (1) | - | - | (536) |
Foreign currency effects | (4) | (9) | (11) | - | (23) |
Acc. amortisation and impairments at 31 December 2025 | (1 589) | (584) | (381) | - | (2 554) |
Carrying amount at 31 December 2023 | 1 338 | 309 | 265 | 1 207 | 3 120 |
Carrying amount at 31 December 2024 | 1 353 | 333 | 217 | 1 227 | 3 130 |
Carrying amount at 31 December 2025 | 856 | 337 | 174 | 1 304 | 2 671 |
Carrying amount of assets with indefinite life | 856 | - | - | 1 304 | 2 160 |
Amortisation rate | 15–25% | 14–20% |
109
BROWSE PAGESEARCH
NOTE 01 General information
NOTE 02 Critical accounting
estimates and judgements
NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
2025 | 2024 | |
Customer relationships | 5 - 7 years | 5 - 7 years |
Software | 3 - 7 years | 3 - 7 years |
| Customer | Brand | ||||
Amounts in NOK million | Goodwill | Software | relationships | names | Tota l |
| Cash generating units | |||||
Komplett B2C | 153 | 80 | - | - | 233 |
Komplett B2B | 218 | 30 | - | - | 248 |
Itegra | 68 | 60 | - | 5 | 133 |
Webhallen | - | 63 | - | 56 | 119 |
Ironstone | 78 | 12 | 2 | 5 | 98 |
NetOnNet | 339 | 91 | 173 | 1 237 | 1 840 |
Total at 31 December 2024 | 856 | 337 | 174 | 1 304 | 2 671 |
| Customer | Brand | ||||
Amounts in NOK million | Goodwill | Software | relationships | names | Tota l |
| Cash generating units | |||||
Komplett B2C | 164 | 79 | - | - | 243 |
Komplett B2B | 218 | 33 | - | - | 251 |
Itegra | 68 | 69 | - | 5 | 141 |
Webhallen | 86 | 63 | - | 53 | 203 |
Ironstone | 78 | 15 | 5 | 5 | 103 |
NetOnNet | 739 | 74 | 212 | 1 164 | 2 188 |
Total at 31 December 2025 | 1 353 | 333 | 217 | 1 227 | 3 130 |
| Long term | EBIT-margin | Discount rate | |
| Cash generating unit | growth rate in sales | terminal value | (after tax) |
NetOnNet | 2.0% | 3.5% | 10.0% |
Webhallen | 2.0% | 1.7% | 10.0% |
Ironstone | 2.0% | 10.0% | 12.0% |
Komplett B2C | 2.0% | 4.0% | 11.5% |
Komplett B2B | 2.0% | 6.0% | 11.5% |
Itegra | 2.0% | 1.5% | 11.5% |
110
BROWSE PAGESEARCH
NOTE 01 General information
NOTE 02 Critical accounting
estimates and judgements
NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
Amounts in NOK million | Growth in terminal value | EBIT-margin in TV | Discount rate | |||
Changes in assumptions | -0.5 pp | -1.0 pp | - 0.5 pp | - 1.0 pp | + 0.5 p | + 1.0 p |
NetOnNet | (89) | (1 691) | (237) | (473) | (132) | (249) |
Webhallen | (9) | (17) | (74) | (148) | (18) | (35) |
| Leasehold | Machinery and | ||
| Amounts in NOK million | improvements | equipment | To t al |
Cost as at 31 December 2023 | 52 | 431 | 483 |
Additions | 7 | 60 | 67 |
Disposals | (1) | (110) | (111) |
Impairment | - | - | - |
Foreign currency effects | 0 | (3) | (3) |
Cost as at 31 December 2024 | 58 | 378 | 436 |
Cost as at 31 December 2024 | 58 | 378 | 436 |
Additions | 1 | 43 | 44 |
Disposals | - | (6) | (6) |
Impairment | - | - | - |
Foreign currency effects | 1 | 20 | 20 |
Cost as at 31 December 2025 | 60 | 436 | 495 |
Acc. depreciation and impairments as at 31 December 2023 | (35) | (319) | (354) |
Depreciation | (6) | (42) | (48) |
Disposals | 1 | 109 | 110 |
Foreign currency effects | (0) | 4 | 4 |
Acc. depreciation and impairments as at 31 December 2024 | (41) | (248) | (289) |
Acc. preciation and impairments as at 31 December 2024 | (41) | (248) | (289) |
Depreciation | (7) | (45) | (51) |
Disposals | - | 6 | 6 |
Foreign currency effects | (0) | (15) | (15) |
Acc. preciation and impairments as at 31 December 2025 | (48) | (303) | (350) |
Carrying amount as at 31 December 2023 | 16 | 112 | 128 |
Carrying amount as at 31 December 2024 | 17 | 130 | 147 |
Carrying amount as at 31 December 2025 | 12 | 133 | 145 |
Economic life | 3 - 5 years | 3 - 7 years | |
Depreciation rate | 20% | 15 - 25% | |
Depreciation method | Linear | Linear |
111
BROWSE PAGESEARCH
NOTE 01 General information
NOTE 02 Critical accounting
estimates and judgements
NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
Name | Country | Industry | Proportion of ownership |
Fabres Sp. Z.o.o. | Poland | Consulting | 40.0% |
Amounts in NOK million | 2025 | 2024 |
At 1 January | 8 | 12 |
Share of profit after tax | 1 | 1 |
Dividend | (2) | (5) |
At 31 December | 8 | 8 |
Amounts in PLN million | 2025 | 2024 |
Assets | 10 | 11 |
Liabilities | 1 | 1 |
Equity | 9 | 9 |
Revenues | 18 | 19 |
Total operating expenses | (16) | (17) |
Net financial items | (0) | (0) |
Profit of the year | 1 | 2 |
Amounts in NOK million | 2025 | 2024 |
Trade receivables at face value at 31 December | 183 | 160 |
Less: Provision for expected credit loss | (6) | (7) |
Net trade receivables | 176 | 153 |
Receivables written off during the years | 8 | 11 |
Collected on receivables written of in prior periods | (7) | (5) |
Changes in provision during the year | (2) | (3) |
Net write off during the year | (0) | 2 |
At 31 December 2025 | To t al | Current | 0-30d | 30-60d | 60-90d | >90d |
Trade receivables at face value | 183 | 103 | 55 | 6 | 2 | 17 |
Provision for expected credit loss | (6) | - | - | (0) | (0) | (6) |
Net trade receivables | 176 | 103 | 55 | 6 | 2 | 11 |
At 31 December 2024 | Tot a l | Current | 0-30d | 30-60d | 60-90d | >90d |
Trade receivables at face value | 160 | 95 | 33 | 4 | 5 | 22 |
Provision for expected credit loss | (7) | (0) | - | - | - | (6) |
Net trade receivables | 153 | 95 | 33 | 4 | 5 | 16 |
112
BROWSE PAGESEARCH
NOTE 01 General information
NOTE 02 Critical accounting
estimates and judgements
NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
Amounts in NOK million | 2025 | 2024 |
Gross amount receivable at 1 January | 56 | 107 |
Less provision at 1 January | (29) | (28) |
Carrying amount 1 January | 27 | 79 |
Additions during the year | - | 0 |
Down payments | (8) | (52) |
Interest income | 1 | 3 |
Net losses during the year | (1) | (2) |
Change in loss provision | 2 | (1) |
Carrying amount 1) at 31 December | 21 | 27 |
Receivables due during next twelve months | 50 | 49 |
Receivables due after twelve months | - | 7 |
Less provision for losses | (29) | (29) |
Tota l | 21 | 27 |
OTHER CURRENT RECEIVABLES
Amounts in NOK million | 2025 | 2024 |
Public duties receivable (VAT)/Tax | 22 | 39 |
Receivables from suppliers | 523 | 567 |
Prepaid payroll element on option | 1 | 1 |
Other receivables and prepaid expenses | 374 | 102 |
Sum | 921 | 709 |
NON-CURRENT RECEIVABLES
Amounts in NOK million | 2025 | 2024 |
Rent deposits | 0 | 1 |
Warranty - The Swedish Customs | 4 | 4 |
Pension premium fund | 4 | 4 |
Sum | 8 | 9 |
Note 15 Inventories
Amounts in NOK million | 2025 | 2024 |
Inventories carried at cost | 2 321 | 2 088 |
Provision not allocated to specific goods | (25) | (40) |
Booked value | 2 297 | 2 048 |
Amounts in NOK million | 2025 | 2024 |
Write-down of inventories included in cost of cost sold | 6 | 1 |
The group makes provision for obsolescence. These provisions are based on a detailed assessment of the age
distribution of inventory items, whether the goods are part of an active or expired product range, if items are likely to
be sold with negative product margin and historical scarping rates. These provisions are estimate-based and require
in-depth knowledge about goods and markets as well as historical data.
The decrease in provision for inventory obsolescence is partly due to a minor adjustment in the calculation model,
resulting in less risk being allocated to this provision and more to the provision for service and guarantee obligations,
see note 21.
Amounts in NOK million | 2025 | 2024 |
Cash at hand and on demand bank deposits | 814 | 726 |
Amounts in NOK million | 2025 | 2024 |
Bank deposits bound for payment of tax due | 8 | 5 |
113
BROWSE PAGESEARCH
NOTE 01 General information
NOTE 02 Critical accounting
estimates and judgements
NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
Number of shares | 2025 | 2024 |
Ordinary shares | 175 341 161 | 175 341 161 |
| Number | Nominal | Type of | Share premium | ||
| Date/year | of shares | value NOK | change | Share capital | reserve |
31 December 2019 | 14 451 031 | 2.00 | 29 | 1 075 | |
31 December 2020 | 14 451 031 | 2.00 | 29 | 1 075 | |
May 2021 | 72 255 155 | 0.40 | Split 1) | 29 | 1 075 |
31 December 2021 | 72 255 155 | 0.40 | 29 | 1 075 | |
04 April 2022 | 107 497 579 | 0.40 | 43 | 2 780 | |
16 November 2022 | 134 997 579 | 0.40 | 54 | 3 170 | |
08 December 2022 | 175 297 579 | 0.40 | 70 | 3 741 | |
03 February 2023 | 175 341 161 | 0.40 | 70 | 3 741 |
Shareholder | Holding | % of capital | Type of account | |
1 | Canica Invest AS | 74 376 317 | 42.42 % | Ordinary |
2 | Siba Invest AB | 55 581 404 | 31.70 % | Ordinary |
3 | Sole Active AS | 6 165 112 | 3.52 % | Ordinary |
4 | The Bank Of New York Mellon Sa/Nv | 6 116 715 | 3.49 % | Ordinary |
5 | Verdipapirfondet Alfred Berg Gamba | 5 478 731 | 3.12 % | Nominee |
6 | The Northern Trust Comp, London Br | 4 232 010 | 2.41 % | Nominee |
7 | Verdipapirfondet Holberg Norge | 4 226 644 | 2.41 % | Ordinary |
8 | Verdipapirfondet Storebrand Norge | 2 349 136 | 1.34 % | Ordinary |
9 | Skandinaviska Enskilda Banken AB | 2 306 840 | 1.32 % | Ordinary |
10 | Wenaasgruppen AS | 877 943 | 0.50 % | Nominee |
11 | Verdipapirfondet Storebrand Norge | 581 918 | 0.33 % | Ordinary |
12 | Emis AS | 550 000 | 0.31 % | Ordinary |
13 | Euroclear Bank S.A./N.V. | 505 778 | 0.29 % | Ordinary |
14 | Verdipapirfondet Storebrand Norge | 491 321 | 0.28 % | Nominee |
15 | Cigalep AS | 391 777 | 0.22 % | Ordinary |
16 | Lt Invest AS | 378 646 | 0.22 % | Ordinary |
17 | Storebrand Livsforsikring AS | 353 972 | 0.20 % | Ordinary |
18 | Nordnet Livsforsikring AS | 319 435 | 0.18 % | Ordinary |
19 | Nordea Bank Abp | 308 500 | 0.18 % | Ordinary |
20 | Verdipapirfondet Storebrand Aksje | 295 845 | 0.17 % | Ordinary |
Total top 20 | 165 888 044 | 94.61 % | ||
Other | 9 453 117 | 5.39 % | ||
Total number of shares | 175 341 161 | 100.00 % |
| SHARES HELD BY BOARD DIRECTORS AND CEO AT 31 DECEMBER 2025 | ||
Shareholder | Title | Number of shares |
Ros-Marie Grusén | CEO | 218 000 |
Fabian Bengtsson (SIBA Invest AB) | Director | 55 581 404 |
Jan Ole Stangeland (Stangeland Invest AS) | Director | 76 296 |
Jaan Ivar G. Semlitsch | Chair | 180 000 |
114
BROWSE PAGESEARCH
NOTE 01 General information
NOTE 02 Critical accounting
estimates and judgements
NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
Note 18 Share option plan
The company has a long-term incentive programme, implemented as a share option programme, for members of the
management, key employees and certain identified young talents. The programme has been adopted by the board of
directors of Komplett ASA (“the company”) to reward employees by enabling them to acquire shares of the company.
At 31 December 2025, 23 employees were included in the option programme.
The strike price for the options granted are based on the final offer price including a premium of 3 per cent annually
from grant date until the options are vested.
The programme is measured at fair value at the date of the grant and the value of the issued options is expensed over
the vesting period, which in this case is gradually over three years after grant. The Black-Scholes option-pricing model
has been used to calculate the fair value.
The cost of the employee share-based transaction is expensed over the average vesting period. The value of the
issued options of the transactions that are settled with equity instruments (settled with the company’s own shares)
is recognised as salary and personnel cost in profit and loss and in other equity. Social security tax on options is
recorded as a liability and is recognised over the estimated vesting period.
As a result of the termination of unvested options, a reversal of previously recognised costs has been recorded,
resulting in a negative expense for 2025.
TOTAL COSTS AND SOCIAL SECURITY PROVISIONS
Amounts in NOK million | 2025 | 2024 |
Total IFRS cost | (0.77) | 8.34 |
Total social security provisions | 0.65 | - |
GRANTED INSTRUMENTS 2025
Instrument | Option |
Quantity 31 December 2025 (instruments) | 2 277 374 |
Quantity 31 December 2025 (shares) | 2 277 374 |
Contractual life 1) | 4.00 |
Strike price 1) | 13.60 |
Share price 1) | 13.06 |
Expected lifetime 1) | 3.23 |
Volatility 1) | 0.51 |
Interest rate 1) | 0.04 |
Dividend 1) | - |
FV per instrument 1) | 4.74 |
1)
Weighted average parameters at grant of instrument
115
BROWSE PAGESEARCH
NOTE 01 General information
NOTE 02 Critical accounting
estimates and judgements
NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
QUANTITY AND WEIGHTED AVERAGE PRICES 2025
Activity | Number of instruments | Weighted average strike price |
Outstanding options 1.1 | 7 485 205 | 13.44 |
Granted | 2 277 374 | 13.68 |
Exercised | (395 093) | 11.34 |
Terminated | (4 132 117) | 12.37 |
Outstanding options 31.12 | 5 235 369 | 14.55 |
Vested CB | 836 823 | 24.12 |
OUTSTANDING INSTRUMENTS OVERVIEW AT 31 DECEMBER 2025
Outstanding instruments | Vested instruments | ||||||
| Weighted | Weighted | Vested | Weighted | ||||
| Vesting/ | Strike | Number of | average remaining | average | instruments | average | |
| expiry date | price | instruments | contractual life | strike price | 31.12.20 25 | strike price | |
2025/2029 | 9.20 | 242 694 | 3.36 | 9.20 | 242 694 | 9.20 | |
2026/2029 | 9.48 | 242 697 | 3.36 | 9.48 | - | - | |
2027/2029 | 9.76 | 1 188 012 | 3.36 | 9.76 | - | - | |
2027/2029 | 10.98 | 66 932 | 3.67 | 10.98 | - | - | |
2026/2029 | 11.10 | 150 000 | 3.59 | 11.10 | - | - | |
2027/2029 | 11.10 | 150 000 | 3.59 | 11.10 | - | - | |
2028/2029 | 11.10 | 450 000 | 3.59 | 11.10 | - | - | |
2026/2029 | 11.20 | 50 000 | 3.59 | 11.20 | - | - | |
2027/2029 | 11.20 | 50 000 | 3.59 | 11.20 | - | - | |
2028/2029 | 11.20 | 150 000 | 3.59 | 11.20 | - | - | |
2024/2028 | 14.40 | 145 170 | 2.42 | 14.40 | 145 170 | 14.40 | |
2024/2028 | 14.83 | 145 173 | 2.42 | 14.83 | 145 173 | 14.83 | |
2026/2029 | 15.04 | 255 471 | 3.73 | 15.04 | - | - | |
2026/2028 | 15.28 | 435 519 | 2.42 | 15.28 | - | - | |
2027/2029 | 15.49 | 255 473 | 3.73 | 15.49 | - | ||
2028/2029 | 15.95 | 766 430 | 3.73 | 15.95 | - | - | |
2024/2028 | 17.86 | 62 670 | 2.30 | 17.86 | 62 670 | 17.86 | |
2025/2028 | 18.40 | 62 670 | 2.30 | 18.40 | 62 670 | 18.40 | |
2026/2028 | 18.95 | 188 012 | 2.30 | 18.95 | - | - | |
2022/2026 | 61.80 | 48 535 | 0.48 | 61.80 | 48 535 | 61.80 | |
2023/2026 | 63.65 | 41 193 | 0.48 | 63.65 | 41 193 | 63.65 | |
2024/2026 | 65.56 | 88 718 | 0.48 | 65.56 | 88 718 | 65.56 | |
Tota l | 5 235 369 | 836 823 | |||||
QUANTITY AND WEIGHTED AVERAGE PRICES 2024
Activity | Number of instruments | Weighted average strike price |
Outstanding options 1.1 | 3 619 588 | 20.12 |
Granted | 4 561 699 | 9.63 |
Exercised | - | - |
Terminated | (696 082) | 23.19 |
Outstanding options 31.12 | 7 485 205 | 13.44 |
Vested CB | 753 904 | 28.97 |
OUTSTANDING INSTRUMENTS OVERVIEW AT 31 DECEMBER 2024
Outstanding instruments | Vested instruments | |||||
| Weighted | Weighted | Vested | Weighted | |||
| Vesting/ | Strike | Number of | average remaining | average | instruments | average |
| expiry date | price | instruments | contractual life | strike price | 31.12.20 24 | strike price |
2025/2029 | 9.20 | 798 205 | 4.36 | 9.20 | - | - |
2026/2029 | 9.48 | 798 211 | 4.36 | 9.48 | - | - |
2027/2029 | 9.76 | 2 898 351 | 4.36 | 9.76 | - | - |
2027/2029 | 10.98 | 66 932 | 4.67 | 10.98 | - | - |
2024/2028 | 12.73 | 83 156 | 4.59 | 12.73 | 83 156 | 12.73 |
2025/2028 | 13.11 | 83 156 | 4.59 | 13.11 | - | - |
2026/2028 | 13.51 | 249 469 | 4.59 | 13.51 | - | - |
2024/2028 | 14.40 | 233 899 | 4.42 | 14.40 | 233 899 | 14.40 |
2025/2028 | 14.83 | 233 903 | 4.42 | 14.83 | - | - |
2026/2028 | 15.28 | 701 710 | 4.42 | 15.28 | - | - |
2024/2028 | 16.07 | 100 000 | 4.11 | 16.07 | 100 000 | 16.07 |
2025/2028 | 16.55 | 100 000 | 4.11 | 16.55 | - | - |
2026/2028 | 17.05 | 300 000 | 4.11 | 17.05 | - | - |
2024/2028 | 17.86 | 125 340 | 4.30 | 17.86 | 125 340 | 17.86 |
2025/2028 | 18.40 | 125 340 | 4.30 | 18.40 | - | - |
2026/2028 | 18.95 | 376 024 | 4.30 | 18.95 | - | - |
2022/2026 | 61.80 | 55 147 | 2.48 | 61.80 | 55 147 | 61.80 |
2023/2026 | 63.65 | 47 805 | 2.48 | 63.65 | 47 805 | 63.65 |
2024/2026 | 65.56 | 108 557 | 2.48 | 65.56 | 108 557 | 65.56 |
Tota l | 7 485 205 | 753 904 |
116
BROWSE PAGESEARCH
NOTE 01 General information
NOTE 02 Critical accounting
estimates and judgements
NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
Note 19 Leases
SUMMARY OF THE RIGHT-OF-USE ASSETS
Amounts in NOK million | Land and buildings | Vehicles | To t al |
At 1 January 2024 | 597 | 3 | 600 |
Additions incl.adjustments to existing contracts | 108 | 1 | 109 |
Amortisation | (204) | (1) | (204) |
Foreign currency effects | 9 | - | 9 |
At 31 December 2024 | 511 | 3 | 514 |
At 1 January 2025 | 511 | 3 | 514 |
Additions incl. adjustments to existing contracts | 168 | 1 | 169 |
Amortisation | (214) | (1) | (215) |
Impairment | (3) | - | (3) |
Foreign currency effects | 26 | - | 9 |
At 31 December 2025 | 490 | 1 | 491 |
Economic life/lease term | 1-9 years | ||
Amortisation method | Straight line | ||
| The group’s leased assets include offices, stores, warehouses and vehicles. | |||
| The group’s right of use assets are categorised and presented in the table above. |
An impairment charge of NOK 3 million was recognised in 2025 for a lease agreement, as operations at the premises
have ceased and the location is now vacant. Further impairment charges were evaluated, particularly with respect to
impairment charges for goodwill, but no additional need for impairment was identified.
The additions of right-of-use assets, and the corresponding increase in lease liabilities, do not involve any cash flow
transactions.
LEASE LIABILITIIES
Amounts in NOK million | 31.12.2025 | 3 1.12.20 24 |
| Undiscounted lease payments and year of payment | ||
Less than 1 year | 216 | 212 |
1-2 years | 169 | 161 |
2-3 years | 108 | 97 |
3-4 years | 49 | 63 |
4-5 years | 20 | 41 |
More than 5 years | 12 | 12 |
Total undiscounted lease payments | 574 | 586 |
SUMMARY OF THE LEASE LIABILITIES
Amounts in NOK million | 2025 | 2024 |
At 1 January | 518 | 608 |
Additions | 174 | 111 |
Interest expenses | 22 | 23 |
Lease payments | (238) | (230) |
Foreign currency effects | 23 | 6 |
Total lease liabilities at 31 December | 498 | 518 |
| Whereof: | ||
Current lease liabilities | 194 | 186 |
Non-current lease liabilities | 304 | 331 |
Total cash outflows for leases | 238 | 230 |
The lease contracts do not include any restrictions with regards to the group’s dividend policy or financing
opportunities.
SUMMARY OF OTHER LEASE EXPENSES RECOGNISED IN STATEMENT OF COMPREHENSIVE INCOME
Amounts in NOK million | 2025 | 2024 |
Expensed lease payments for short-term leases and low value leases | 12 | 12 |
Variable lease payments | 30 | 26 |
The material part of the variable lease payments is related to turnover-based rent.
117
BROWSE PAGESEARCH
NOTE 01 General information
NOTE 02 Critical accounting
estimates and judgements
NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
Amounts in NOK million | 2025 | 2024 |
Provision for service and guarantee obligations | 46 | 32 |
Accrued employee benefit expenses | 135 | 118 |
Provision for contracts with customers | 83 | 89 |
Tax deferred payment - Sweden | 160 | 150 |
Other short term liabilities | 226 | 99 |
Total other current liabilities | 650 | 487 |
Amounts in NOK million | 2025 | 2024 |
Long-term loans | 800 | 800 |
Lease liabilities | 304 | 331 |
Tax deferred payment - Sweden | 120 | 263 |
Total long term debt | 1 224 | 1 394 |
Amounts in NOK million | 2025 | 2024 |
At 1 January | 32 | 30 |
Utilised during the year | (36) | (28) |
Additions services and guarantee obligations for the year | 45 | 30 |
At 31 December | 40 | 32 |
Note 22 Notes supporting the cash flows
Transactions without cash flow effects from financing activities are presented in the reconciliation of the movement
in financial liabilities in the subsequent tables.
At end of 2025 the group holds currency forwards, measured at fair value, with an unrealised loss of NOK 10 million (see
note 4). These are reported as other current liabilities
2025
| Non-current | Other non- | Current | Financial | ||
| loans and | current | loans and | liabilities at | ||
| Amounts in NOK million | borrowings | liabilities | borrowings | fair value | Tot a l |
| At 1 January 2025 | (800) | (263) | - | (34) | (1 097) |
Net cash flow | - | 154 | - | - | 154 |
| Non-cash flows | |||||
Foreign currency effects | - | (11) | - | - | (11) |
Miscellaneous provisions | - | - | - | - | - |
Fair value adjustments | - | - | - | (2) | (2) |
At 31 December 2025 | (800) | (120) | - | (36) | (956) |
2024
| Non-current | Other non- | Current | Financial | ||
| loans and | current | loans and | liabilities at | ||
| Amounts in NOK million | borrowings | liabilities | borrowings | fair value | Tot a l |
| At 1 January 2024 | (800) | - | - | (37) | (837) |
Net cash flow | - | 41 | - | - | 41 |
| Non-cash flows | |||||
| Reclassification from other current | - | (304) | - | - | ( 3 0 4) |
| liabilities | |||||
Miscellaneous provisions | - | - | - | - | - |
Fair value adjustments | - | - | - | 3 | 3 |
At 31 December 2024 | (800) | (263) | - | (34) | (1 097) |
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NOTE 01 General information
NOTE 02 Critical accounting
estimates and judgements
NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
| MORTGAGE-BACKED LIABILITIES | |||||
| Utilised | Utilised | ||||
Amounts in NOK million | Classification | Total facility | Covenants (C) /Pledge (P) | 31.12.2025 | 31.12.20 24 |
| Type | |||||
| Revolving | Long-term | NOK 1 300 million | C - leverage ratio < 3.00 and | 800 | 8 0 0 |
| credit facility | equity ratio > 25% | ||||
| P - receivables, inventory and | |||||
| tangible fixed assets | |||||
Overdraft facility | Short-term | NOK 400 million | C - leverage ratio < 3.00 and | - | - |
| equity ratio > 25% | |||||
| P - receivables, inventory and | |||||
| tangible fixed assets | |||||
Tota l | 800 | 800 |
Amounts in NOK million | 2025 | 2024 |
Guarantees related to leases | 24 | 27 |
Guarantees to the tax collector | 12 | 12 |
Guarantees related to suppliers | 27 | 25 |
Tota l | 63 | 64 |
Total mortgage-backed liabilities and financial guarantees | 863 | 864 |
Note 24 Related party transactions
In addition to subsidiaries and associated companies, the group’s related parties include its majority shareholders,
all members of the board of directors, and key management, as well as companies in which any of these parties
have either controlling interests, board appointments or are senior staff. All transactions have been entered into in
accordance with the arm’s length principle, meaning that prices and other main terms and conditions are deemed to
be commercial.
All significant transactions with related parties that are not eliminated in the group accounts are presented below:
PARTIES
Amounts in NOK million | 2025 | 2024 | |
Kullerød Eiendom AS¹ | Lease of office and warehouse | 30 | 29 |
F&H Asia Limited¹ | Purchase of products for resale | 16 | 23 |
Resurs Bank & Solid² | Sales of products | 9 | 9 |
Resurs Bank & Solid² | Commision of services sold | 165 | 168 |
Resurs Bank² | Purchase of factoring services | 35 | 39 |
SIBA Fastigheter AB² | Lease of office and warehouse | 26 | 25 |
Tota l | 281 | 294 |
1)
Related entities owned by the company’s ultimate parent company in the greater Canica group of companies.
2)
Related entities owned by the company’s ultimate parent company in the greater Siba group of companies.
Komplett Services leases both offices and warehouse from Kullerød Eiendom AS at the premises in Sandefjord and
source private label products from the company F&H Asia Limited.
NetOnNet sells products from its normal assortment to both Resurs Bank and SOLID Försäkringar.
In addition, group companies act as agents for Resurs Bank related to consumer finance in Sweden and Komplett
Services has a factoring agreement with Resurs Bank for customers in the B2B and Distribution segments. NetOnNet
also acts as an agent for SOLID Försäkringar and rents premises for some of its physical stores from SIBA Fastigheter.
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NOTE 01 General information
NOTE 02 Critical accounting
estimates and judgements
NOTE 03 Accounting policies
NOTE 04 Financial instruments –
risk management
NOTE 05 Segment information
NOTE 06 Revenues from contracts
with customers
NOTE 07 Employee benefit
expenses and audit fees
NOTE 08 Finance income and
expenses
NOTE 09 Income tax
NOTE 10 Earnings per share
NOTE 11 Intangible assets
NOTE 12 Property, plant and
equipment
NOTE 13 Investments in associates
NOTE 14 Trade and other
receivables
NOTE 15 Inventories
NOTE 16 Cash and bank deposits
NOTE 17 Share capital, shareholder
information, and dividend
NOTE 18 Share option plan
NOTE 19 Leases
NOTE 20 Other current liabilities
and long-term debt
NOTE 21 Provision for service and
guarantee obligations
NOTE 22 Notes supporting the cash
flows
NOTE 23 Pledges and guarantees
NOTE 24 Related party transactions
NOTE 25 Consolidated companies
NOTE 26 Events after the reporting
date
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
CONTENTS
Note 25 Consolidated companies
The following companies are included in the consolidated financial statement for 2025:
| Parent company |
| Komplett ASA |
Subsidiaries | Country of incorporation | Proportion of ownership |
Komplett Services AS | Norway | 100.0% |
Komplett Services Sweden AB | Sweden | 100.0% |
Komplett Distribusjon AS | Norway | 100.0% |
Komplett Distribution Sweden AB | Sweden | 100.0% |
NetOnNet AB | Sweden | 100.0% |
Webhallen Sverige AB | Sweden | 100.0% |
Ironstone Holding AS | Norway | 7 3.1% |
Ironstone AS 1) | Norway | - |
Ironstone AB 1) | Sweden | - |
| Subsidiaries without activity | ||
Marked Gruppen AS | Norway | 100.0% |
1)
100 per cent owned by Ironstone Holding AS.
Note 26 Events after the reporting date
Webhallen’s store in Fruängen, Stockholm closed in January 2026, when its lease agreement ended.This
closure did not result in any material restructuring costs.
Vebjørn Torsetnes was appointed CEO of Komplett ASA effective from 16 March 2026, succeeding Ros-Marie Grusén.
120
BROWSE PAGESEARCHABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
STATEMENT OF PROFIT AND LOSS – KOMPLETT ASA
For the year ended 31 December
Amounts in NOK million Note 2025 2024
Operating revenues
Other operating revenues 83 -
Total operating income 83 -
Operating expenses
Employee benefit expenses
8 (161) (78)
Other operating expenses
8 (46) (37)
Total operating expenses (207) (115)
Operating profit (124) (115)
Finance income and expenses
Income from investments in associated companies 2 5
Finance income
9 16 88
Finance expenses
9 (581) (94)
Net finance (564) (1)
Profit before tax (688) (115)
Tax expense
6 41 25
Profit for the year (646) (90)
Attributable to:
Ordinary dividends - -
Other equity (646) (90)
Tota l (646) (90)
121
BROWSE PAGESEARCHABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
STATEMENT OF FINANCIAL POSITION – KOMPLETT ASA
At 31 December
Amounts in NOK million
ASSETS Note 31 December 2025 31 December 2024
NON-CURRENT ASSETS
Intangible assets
Deferred tax asset
6 83 41
Total intangible assets 83 41
Non-current financial assets
Investments in subsidiaries
2, 3 3 317 3 749
Investments in associates
3 5 5
Total other non-current assets 3 321 3 754
Total non-current assets 3 404 3 795
CURRENT ASSETS
Current receivables
Current receivables from group companies
5 32 164
Other current receivables 6 8
Total current receivables 37 171
Cash and bank deposit
Cash and bank deposit
4 717 601
Total cash and bank deposit 717 601
Total current assets 754 772
Tota l a s se t s 4 158 4 567
EQUITY AND LIABILITIES Note 31 December 2025 31 December 2024
EQUITY
Paid in equity
Share capital 70 70
Share premium 3 741 3 741
Other paid in equity 45 46
Total paid in equity 3 856 3 857
Retained earnings
Other equity (1 785) (1 139)
Total retained earnings (1 785) (1 139)
Total equity 2 071 2 718
LIABILITIES
Non-current provisions
Pension liabilities 5 7
Provision for other long-term obligations
2 36 34
Total non-current provision 41 41
Non-current liabilities
Long-term loans
7 800 800
Total non-current liabilities 800 800
Current liabilities
Current payables to group companies
5 1 209 973
Trade payables 2 8
Income tax payable
6 - -
Other current liabilities 35 26
Total current liabilities 1 246 1 008
Total liabilities 2 087 1 849
Total equity and liabilities 4 158 4 567
122
BROWSE PAGESEARCHABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
STATEMENT OF CASH FLOWS – KOMPLETT ASA
For the year ended 31 December
Amounts in NOK million Note 2025 2024
Cash flows from operating activities
Profit for the year (688) (90)
Income tax paid (5) -
Change in fair value of financial liabilities 3 (3)
Group contribution received (15) (84)
Impairment 483 -
Long-term incentive programme (1) 8
Changes in trade payables and trade receivables (11) 6
Other changes in accurals 16 (47)
Net cash flows from operating activities (218) (210)
Investing activities
Investments in subsidiaries
2,3 (54) (0)
Proceeds received from loans to group companies
5 - 1
Net cash (used in)/from investing activities (54) 1
Financing activities
Proceeds from loans and borrowings - -
Changes in bank overdrafts 321 561
Group contributions received 79 131
Group contributions paid (12) -
Net cash (used in)/from financing activities 389 692
Net increase in cash and bank deposit 116 482
Cash and bank deposit at beginning of year 601 118
Cash and bank deposit at end of year 717 601
STATEMENT OF CHANGES IN EQUITY – KOMPLETT ASA
For the year ended 31 December
Amounts in NOK million Share capital Other paid in equity Other equity Total equity
At 1 January 2024 70 37 (1 049) 2 800
Profit for the year - - (90) (90)
Long-term incentive programme - 8 - 8
At 31 December 2024 70 46 (1 139) 2 718
At 1 January 2025 70 46 (1 139) 2 718
Profit for the year - - (646) (646)
Long-term incentive programme - (1) - (1)
At 31 December 2025 70 45 (1 785) 2 071
123
BROWSE PAGESEARCHABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
Sandefjord, 17 March 2026
Board of directors, Komplett ASA
Jaan Ivar Semlitsch
Chair
Fabian Bengtsson
Director
Susanne Ehnbåge
Director
Ingvild Næss
Director
Jan Ole Stangeland
Director
Anders Odden
Worker director
Emelie Victorin
Worker director
Vebjørn Torsetnes
President and CEO
The statement from the board has been signed electronically.
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CONTENTS
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
NOTE 01 Accounting principles
NOTE 02 Corporate changes
NOTE 03 Investments in subsidiaries
and associated companies
NOTE 04 Cash and bank deposits
NOTE 05 Group balances
(receivables and payables)
NOTE 06 Income tax
NOTE 07 Pledges and guarantees
NOTE 08 Employee benefit
expenses
NOTE 09 Items aggregated in the
financial statement
NOTE 10 Financial market risk
NOTES TO THE FINANCIAL STATEMENTS – KOMPLETT ASA
Note 01 Accounting principles
The financial statements have been prepared in
accordance with the Norwegian Accounting Act and
generally accepted accounting principles in Norway.
The following describes the main accounting policies
used in the preparation of the financial statements of
the parent company. These policies are applied in the
same way in all periods presented, unless otherwise
stated in the description.
Subsidiaries and investment in associates
Subsidiaries and investments in associates are valued
at cost in the company accounts. The investment is
valued as cost of the shares in the subsidiary, less any
impairment losses. An impairment loss is recognised
if the impairment is not considered temporary, in
accordance with generally accepted accounting
principles. Impairment losses are reversed if the reason
for the impairment loss disappears in a later period.
Dividends, group contributions and other distributions
from subsidiaries are recognised in the same year as
they are recognised in the financial statement of the
provider. If dividends/group contributions exceed
withheld profits after the acquisition date, the excess
amount represents repayment of invested capital, and
the distribution will be deducted from the recorded
value of the acquisition in the balance sheet for the
parent company.
Distributions
The proposed dividend/group contribution for the
financial year are recognised as current liabilities.
Balance sheet classification
Current assets and short-term liabilities consist of
receivables and payables due within one year, and
items related to the inventory cycle. Other balance
sheet items are classified as fixed assets/long-term
liabilities.
Current assets are valued at the lower of cost and fair
value. Short-term liabilities are recognised at nominal
value.
Fixed assets are valued at cost, less depreciation and
impairment losses. Long-term liabilities are recognised
at nominal value.
Accounts receivable and other receivables
Accounts receivable and other current receivables
are recorded in the balance sheet at nominal value
less provisions for doubtful accounts. Provisions
for doubtful accounts are based on an individual
assessment of the different receivables. For the
remaining receivables, a general provision is estimated
based on expected loss.
Liabilities
Short-term and long-term liabilities are recognised in
the balance sheet at the nominal amount at the time of
establishment.
The purchase liability for the remaining shares in
Ironstone Holding AS, classified as a non-current
provision, is recognised at fair value where change in
value is recognised as a financial income or financial
expense.
Foreign currency translation
Transactions in foreign currency are translated at the
rate applicable on the transaction date. Monetary items
in a foreign currency are translated into NOK using
the exchange rate applicable on the balance sheet
date. Non-monetary items that are measured at their
historical price expressed in a foreign currency are
translated into NOK using the exchange rate applicable
on the transaction date. Non-monetary items that are
measured at their fair value expressed in a foreign
currency are translated at the exchange rate applicable
on the balance sheet date. Changes to exchange rates
are recognised in the income statement as they occur
during the accounting period.
Income tax
The tax expense consists of the tax payable and
changes to deferred tax.
Period tax constitutes the expected tax payable on
this year’s taxable result at the current tax rates on the
balance sheet date and any corrections of tax payable
for previous years.
Deferred tax/tax assets are calculated on all
differences between the book value and tax value of
assets and liabilities.
Deferred tax is calculated as 22 per cent of temporary
differences and the tax effect of tax losses carried
forward. Deferred tax assets are recorded in the
balance sheet when it is more likely than not that the tax
assets will be utilised.
Taxes payable and deferred taxes are recognised
directly in equity to the extent that they relate to equity
transactions.
Cash flow statement
The cash flow statement is presented using the
indirect method. Cash and bank depisits include cash,
bank deposits and other short-term, highly liquid
investments with maturities of three months or less. At
year-end, cash and bank deposits consist of cash and
bank deposits.
Note 02 Corporate changes
There have been several changes in top managment
in Komplett ASA during 2025. As at 17 March 2026, the
management team consists of the following persons:
• Vebjørn Torsetnes, CEO
• Thomas Røkke, CFO
• Trygve Hillesland, CCO
• Karl Eckerdal, MD NetOnNet
• Morten Johnsen, MD Komplett
• Kim Andersson, MD Webhallen
• Markus Solvik, CSO
• Kristian Kjernsmo, COO
• Kristian Torgersen, CTO
• Nikoline Grøterud Jarmann, CHRO
There has not been any material change in the group’s
legal structure in 2025.
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CONTENTS
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
NOTE 01 Accounting principles
NOTE 02 Corporate changes
NOTE 03 Investments in subsidiaries
and associated companies
NOTE 04 Cash and bank deposits
NOTE 05 Group balances
(receivables and payables)
NOTE 06 Income tax
NOTE 07 Pledges and guarantees
NOTE 08 Employee benefit
expenses
NOTE 09 Items aggregated in the
financial statement
NOTE 10 Financial market risk
Note 03 Investments in subsidiaries and associated companies
Amounts in NOK million
Share
capital Currency
Number
of shares
Face
value
Ownership
= voting rights
Carrying amount
(in NOK million)
SUBSIDIARY
Komplett Services AS 900 000 NOK 900 1 000 100.0% 506
Komplett Services Sweden AB 100 000 SEK 1 000 100 100.0% 137
Komplett Distribusjon AS 10 000 000 NOK 100 100 000 100.0% 110
Komplett Distribution Sverige AB 300 000 SEK 3 000 100 100.0% 23
NetOnNet AB 604 068 SEK 6 040 680 0.10 100.0% 2 289
Webhallen Sverige AB 210 000 SEK 210 1 000 100.0% 101
Ironstone Holding AS 410 400 NOK 4 104 100 7 3.10% 152
Marked Gruppen AS 1 000 000 NOK 1 000 000 1 100.0% -
Tota l 3 317
Share
capital Currency
Number
of shares
Face
value
Ownership
= voting rights
Carrying amount
(in NOK million)
ASSOCIATED COMPANY
Fabres Sp. z o.o. 950 000 PLN 19 000 50 40.0% 5
Tota l 5
Information about the subsidiaries’ equity and profit and loss in accordance with the latest financial statements:
Amounts in NOK million
Business
office Equity
Profit or loss
before tax
COMPANY
Komplett Services AS Sandefjord 317 164
Komplett Distribusjon AS Sandefjord 188 (6)
Komplett Services Sweden AB Stockholm in Sweden 53 4
Komplett Distribution Sverige AB Göteborg in Sweden 16 1
NetOnNet AB Borås in Sweden 500 8
Webhallen Sverige AB Stockholm in Sweden 75 (94)
Ironstone Holding AS Oslo 59 (1)
Marked Gruppen AS Sandefjord (80) -
126
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CONTENTS
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
NOTE 01 Accounting principles
NOTE 02 Corporate changes
NOTE 03 Investments in subsidiaries
and associated companies
NOTE 04 Cash and bank deposits
NOTE 05 Group balances
(receivables and payables)
NOTE 06 Income tax
NOTE 07 Pledges and guarantees
NOTE 08 Employee benefit
expenses
NOTE 09 Items aggregated in the
financial statement
NOTE 10 Financial market risk
Note 05 Group balances (receivables and payables)
RECEIVABLES
Amounts in NOK million 2025 2024
Group contribution 20 69
Cash pool balance with subsidiaries - 88
Other current receivables 7 1
Current loans 5 5
Tota l 32 164
LIABILITIES
Amounts in NOK million 2025 2024
Cash pool balance with subsidiaries 1 203 971
Other current liabilities 6 2
Tota l 1 209 973
Note 04 Cash and bank deposits
Komplett ASA is the principal in the group’s multi-currency cash pool, where the top account is classified as bank and
this was NOK 712 million at 31 December 2025. Balances with subsidiaries are classified as current receivables, or
current payables, from group companies.
The company has a restricted bank deposits of NOK 4.8 million bound for payment of tax due at 31 December 2025. At
31 December 2024, there was a restricted bank deposit of NOK 2.9 million.
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CONTENTS
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
NOTE 01 Accounting principles
NOTE 02 Corporate changes
NOTE 03 Investments in subsidiaries
and associated companies
NOTE 04 Cash and bank deposits
NOTE 05 Group balances
(receivables and payables)
NOTE 06 Income tax
NOTE 07 Pledges and guarantees
NOTE 08 Employee benefit
expenses
NOTE 09 Items aggregated in the
financial statement
NOTE 10 Financial market risk
Note 06 Income tax
BASIS FOR CURRENT INCOME TAX
Amounts in NOK million 2025 2024
Profit before tax (688) (115)
Non-deductable income and expenses 500 2
Interest deduction limitations 94 88
Changes in temporary differences 14 7
Loss carried forward 80 19
Basis for current income tax - -
Income tax expense
Current income tax (22%) - -
Use of loss carried forward (41) (25)
Income tax expense (41) (25)
TEMPORARY DIFFERENCES AND TAX POSITIONS
Amounts in NOK million 2025 2024
Receivables - -
Pension (20) (7)
Options (1) -
Total temporary differences (21) (7)
Tax loss carried forward (99) (19)
Interest deductions carried forward (255) (161)
Total basis for deferred tax asset (375) (187)
Deferred tax asset (83) (41)
RECONCILIATION OF EFFECTIVE TAX RATE
Amounts in NOK million 2025 2024
Profit before tax (688) (115)
Income tax based on applicable tax rate (22%) (151) (25)
Income tax expense (41) (25)
Deviation (110) (0)
Reconciliation
Non-deductible expenses (110) (0)
Tax loss not included in deferred tax asset - -
No use of tax loss carried forward - -
Tota l (110) (0)
A portion of the tax income recognised in 2025 relates to the utilisation of tax loss carryforwards that had previously
not been recognised as deferred tax assets.
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CONTENTS
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
NOTE 01 Accounting principles
NOTE 02 Corporate changes
NOTE 03 Investments in subsidiaries
and associated companies
NOTE 04 Cash and bank deposits
NOTE 05 Group balances
(receivables and payables)
NOTE 06 Income tax
NOTE 07 Pledges and guarantees
NOTE 08 Employee benefit
expenses
NOTE 09 Items aggregated in the
financial statement
NOTE 10 Financial market risk
Note 08 Employee benefit expenses
EMPLOYEE BENEFIT EXPENSES
Amounts in NOK million 2025 2024
Salaries 71 33
Social security expenses 14 9
Contribution to pension schemes 6 5
Personnel costs charged from group companies 55 12
Share option plan (1) 8
Bonuses 9 4
Compensations to board members 3 3
Other expenses 3 3
Tota l 161 78
The average number of full-time equivalents employed during the financial year 42 16
Management remuneration
For information concerning remuneration to management, see “Remuneration report for financial year 2025” and
note 7 Employee benefits in the consolidated financial statement.
Audit fees
Audit fees to the auditors in the group entities is as follows (excluding VAT).
Amounts in NOK million 2025 2024
Statutory audit 1 1
Other assurance services 2 1
Other non-assurance services - 0
Tota l 3 2
Note 07 Pledges and guarantees
Amounts in NOK million Classification Total facility Covenants (C) / pledge (P)
Utilised
31.12.2025
Utilised
31.12.20 24
Type
Revolving credit facility Long-term loans 1 300 C - leverage ratio < 3.00
and equity ratio > 25% P -
receivables, inventory and
tangible fixed assets
800 800
Overdraft facility Short-term loans 400 C - leverage ratio < 3.00
and equity ratio > 25% P -
receivables, inventory and
tangible fixed assets
- -
Tota l 800 800
Komplett ASA has a NOK 1.3 billion syndicated revolving credit facility with its two core banks. The agreement was
signed in December 2022 and now matures in December 2027, following the utilisation of both extension options. In
addition, the group has NOK 400 million overdraft limit linked to the group cash pool. In accordance with its financing
partners, the group has assessed that the practice of increasing the overdraft facility to NOK 500 million in the fourth
quarter will no longer be needed, hence this part has been terminated in 2025. As at 31 December 2025 the overdraft
has not been utilised.
The aforementioned agreements with the banks include covenants for a minimum equity ratio and a maximum
ratio of net debt to EBITDA. The equity ratio covenant has in 2025 been amended to 25 per cent, effective until the
termination date of the credit facilities. The leverage ratio covenant is 3.0x for 31 December 2025, which is the same
as for ordinary quarters, but is 3.5x for Q1 due to seasonality in the business. Covenants are measured at consolidated
financial figures.
The banks have pledges in property, plant and equipment, receivables, and inventory. The pledge in Komplett ASA
is NOK 2 160 million in respective companies.
The group was in compliance with financial covenants in 2025.
FINANCIAL GUARANTEES
Amounts in NOK million 2025 2024
The tax collector 12 12
Guarantees related to leases 3 3
Guarantees for suplliers 27 25
Warrenty for account payables (parent company guarantees) 740 524
Tota l 782 565
As of 31 December 2025, guarantees previously issued by Komplett ASA in favor of its subsidiaries, as well as guaran-
tees issued by Komplett entities in favor of Komplett ASA towards SEB, had been terminated. The guarantee from
Komplett ASA in favor of SEB relating to Webhallen of NOK 1 million had not been cancelled as of 31 December 2025.
129
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CONTENTS
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
NOTE 01 Accounting principles
NOTE 02 Corporate changes
NOTE 03 Investments in subsidiaries
and associated companies
NOTE 04 Cash and bank deposits
NOTE 05 Group balances
(receivables and payables)
NOTE 06 Income tax
NOTE 07 Pledges and guarantees
NOTE 08 Employee benefit
expenses
NOTE 09 Items aggregated in the
financial statement
NOTE 10 Financial market risk
Note 10 Financial market risk
Overview
Komplett ASA is a holding company that has investments in subsidiaries. The company expects that future revenues
will be dividends from investments in subsidiaries and associated companies.
Currency risk
The company is exposed to currency risk from investments and loans to subsidiaries. For additional information, see
note 4 to the consolidated financial statement.
Interest rate risk
Interest rate risk occurs in the short and medium term because of the company’s debt having floating interest rates.
The loan portfolio is linked to SEB base rate and fluctuates in relation to fluctuations in this.
Credit risk
The company has no external sales and no external receivables, hence low exposure to credit risk. As at 31 December
2025, the company has a short term loan to Ironstone Holding AS of NOK 5 million classified as Current receivables
from group companies, see note 5.
Note 09 Items aggregated in the financial statement
FINANCE INCOME
Amounts in NOK million 2025 2024
Other interest income 0 0
Interest received from group companies 1 1
Group contribution received 15 84
Changes in financial liabilities - 3
Other financial income 0 1
Tota l 16 88
FINANCE EXPENSES
Amounts in NOK million 2025 2024
Interest expenses 95 88
Impairment of Shares in Subsidiary 483 -
Loss on financial instrument in group companies 0 5
Changes in financial liabilities 3 -
Other financial expenses 1 0
Tota l 581 94
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CONTENTS
ABOUT KOMPLETT GROUP | DIRECTORS’ REPORT | SUSTAINABILITY | FINANCIAL STATEMENTS | CONTACT
NOTE 01 Accounting principles
NOTE 02 Corporate changes
NOTE 03 Investments in subsidiaries
and associated companies
NOTE 04 Cash and bank deposits
NOTE 05 Group balances
(receivables and payables)
NOTE 06 Income tax
NOTE 07 Pledges and guarantees
NOTE 08 Employee benefit
expenses
NOTE 09 Items aggregated in the
financial statement
NOTE 10 Financial market risk
ALTERNATIVE PERFORMANCE MEASURES (APM)
The APMs used by Komplett Group are set out below:
Gross profit: Total operating revenue less cost of goods
sold. The group has presented this item because it con-
siders it to be a useful measure to show the manage-
ment’s view on the overall picture of profit generation
before operating costs in the group’s operations.
Gross margin: Gross profit as a percentage of total
operating revenue. The group has presented this item
because it considers it to be a useful measure to show
the management’s view on the efficiency of gross profit
generation of the group’s operations as a percentage of
total operating revenue.
Gross profit/Gross margin
NOK million 2025 2024
Total operating revenue 15 775 15 301
- Cost of goods sold (13 518) (13 211)
= Gross profit 2 257 2 091
Gross margin 14.3% 13.7%
Total operating expenses (adj.): Total operating
expenses less cost of goods sold and one-off cost.
The group has presented this item because the
management considers it to be a useful measure of the
group’s efficiency in operating activities.
Operating cost percentage (adjusted): Total operating
expenses less cost of goods sold and one-off cost as
a percentage of total operating revenue. The group
has presented this item because the management
considers it to be a useful measure of the group’s
efficiency in operating activities.
Operating costs percentage (adj.)
NOK million 2025 2024
Total operating revenue 15 775 15 301
Total operating expenses 16 330 15 368
- Cost of goods sold (13 518) (13 211)
- One-off cost (62) (20)
- Impairment (538) -
= Operating costs 2 212 2 137
Operating costs % 14.0% 14.0%
EBITDA excl. impact of IFRS 16: Derived from financial
statements as the sum of operating result (EBIT) plus
the sum of depreciation and amortisation for the
segments B2C, B2B, Distribution and Other. The group
has presented this item because it considers it to be
a useful measure to show the management’s view on
the overall picture of operational profit and cash flow
generation before depreciation and amortisation in the
group’s operations, excluding any impact of IFRS 16.
EBITDA excl IFRS16
NOK million 2025 2024
EBIT (556) (67)
- EBIT - IFRS 16 (21) (16)
+ Dep & Impair.B2C, B2B,
Distribution, Other
729 180
= EBITDA excl IFRS 16 152 97
EBIT adjusted: Derived from financial statements as
operating result (EBIT) excluding one-off costs. The
group has presented this item because it considers it
to be a useful measure to show the management’s view
on the efficiency in the profit generation of the group’s
operations before one-off items.
EBIT adjusted
NOK million 2025 2024
Total operating revenue 15 775 15 301
EBIT (556) (67)
+ One-off cost 62 20
+ Impariment 538 -
= EBIT adjusted 44 (47)
EBIT margin adjusted (%) 0.3% (0.3%)
EBIT margin adjusted: EBIT adjusted as a percentage of
total operating revenue. The group has presented this
item because it considers it to be a useful measure to
show the management’s view on the efficiency in the
profit generation of the group’s operations before one-
off items as a percentage of total operating revenue.
EBIT margin: Operating result (EBIT) as a percentage
of total operating revenue. The group has presented
this item because it considers it to be a useful measure
to show the management’s view on the efficiency in
the profit generation of the group’s operations as a
percentage of total operating revenue.
Reconciliation
NOK million 2025 2024
Total operating revenue 15 775 15 301
EBIT (556) (67)
EBIT margin (%) (3.5%) (0.4%)
Net working capital: Comprising inventories, trade
receivables, trade payables and other current assets
and liabilities. The management considers it to be
a useful indicator of the group’s capital efficiency
in its day-to-day operational activities. Part of the
deferred Swedish tax liability is classified as other
current liabilities in accordance with local accounting
principles, while the part which has maturity of more
than 12 months is classified as other non-current
liabilities. At 31 December 2025, NOK 160 million is
shown as part of other current liabilities, while NOK 120
million is included in non-current liabilities.
Net working capital
NOK million 2025 2024
Inventory 2 297 2 048
+ Trade receivables - regular 176 153
+ Trade payables (2 661) (2 073)
+/-Other assets and liabilities (283) (277)
= Net working capital (471) (149)
Net interest-bearing debt: Interest-bearing
liabilities less cash and cash equivalents. The group
has presented this item because the management
considers it to be a useful indicator of the group’s
indebtedness, financial flexibility and capital structure.
As mentioned above, interest-bearing debt only
includes the deferred Swedish tax liability of NOK 120
million with maturity above 12 months. The net interest-
bearing debt incl. IFRS 16 is a useful measure as
indebtedness, including the lease liabilities from IFRS
16, is relevant for the covenants of the group’s credit
facilities.
Net interest bearing debt
NOK million 2025 2024
Long-term loans 800 800
+ Other non-current liabilities 120 263
+ Short-term loans - -
- Cash/bank deposits (814) (726)
= Net interest bearing debt 106 337
+ IFRS 16 liabilities 498 518
= Net interest bearing debt
including IFRS 16 604 854
Operating free cash flow: EBITDA excl. impact of IFRS
16 less investment in property, plant and equipment,
less change in net working capital less change in trade
receivable from deferred payment arrangements.
The group has presented this item because the
management considers it to be a useful measure of the
group’s operating activities’ cash generation.
Operating free cash flow
NOK million 2025 2024
EBITDA excl IFRS 16 152 97
- Investments 130 (168)
+/- Change in net working capital 322 401
+/- Reclassified to other non-
current liabilities
- 304
+/- Change in deferred payment 8 52
= Operating free cash flow 634 686
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INDEPENDENT AUDITOR’S REPORT
•
•
•
•
•
Auditor’s responsibilities for the audit of
Ethics Standards Board for Accountants’
Penneo Dokumentnøkkel: B0FXH-MKMLE-229WT-G96QZ-227AK-L960C
Based on our knowledge obtained in the audit, it is our opinion that the Board of Directors’ report
•
•
Our statement on the Board of Directors’ report applies correspondingly for the statement on Corporate
Our statement that the Board of Directors’ report contains the information required by applicable law does
In preparing the financial statements, management is responsible for assessing the Company’s and the
Group’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern
Auditor’s responsibilities for the audit of the financial statements
free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that
•
•
opinion on the effectiveness of the Company’s and the Group’s internal
•
• Conclude on the appropriateness of management’s use of the going concern basis of accounting
events or conditions that may cast significant doubt on the Company’s and the Group’s ability to
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cash generating units (CGU’s), r
the design over the Group’s impairment
management’s estimates by comparing actual
the Board of Directors’ report and the other information presented with the financial statements. The other
and our auditor’s report thereon. Our opinion on the financial statements does not cover the information in
the Board of Directors’ report and the other information presented with the financial
Board of Directors’ report and for the other information presented with the financial statements. The
inconsistency between the information in the Board of Directors’
ectors’ report and for
misstated. We are required to report if there is a material misstatement in the Board of Directors’ report
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draw attention in our auditor’s report to the related disclosures in the financial statements or, if
evidence obtained up to the date of our auditor’s report. Ho
•
•
ditor’s report unless law or regulation precludes public
Management’s responsibilities
Auditor’s responsibilities
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–“Assurance engagements other than audits or reviews of historical financial
information”. The standard requires us to plan and perform procedures to obtain reasonable assurance
As part of our work, we perform procedures to obtain an understanding of the Company’s processes for
tagging of the consolidated financial statements and assess management’s use of judgement. Our
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"Med min signatur bekrefter jeg alle datoer og innholdet i dette dokument."
Petter Frode Larsen
Statsautorisert revisor
På vegne av: Ernst & Young AS
Serienummer: bankid.no no_bankid:9578-5994-4-4118388
IP: 147.161.xxx.xxx
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INDEPENDENT SUSTAINABILITY AUDITOR’S LIMITED ASSURANCE REPORT
Statsautoriserte revisorer
Ernst & Young AS
Stortorvet 7, 0155 Oslo
Postboks 1156 Sentrum, 0107 Oslo
Foretaksregisteret: NO 976 389 387 MVA
Tlf: +47 24 00 24 00
www.ey.no
Medlemmer av Den norske Revisorforening
A member firm of Ernst & Young Global Limited
To the General Meeting in Komplett ASA
INDEPENDENT SUSTAINABILITY AUDITOR'S LIMITED ASSURANCE REPORT
Limited assurance conclusion
We have conducted a limited assurance engagement on the consolidated sustainability statement of
Komplett ASA («the Group») included in Sustainability Statement of the Board of Directors’ report (the
“Sustainability Statement”), as of 31 December 2025 and for the year then ended.
Based on the procedures we have performed and the evidence we have obtained, nothing has come to
our attention that causes us to believe that the Sustainability Statement is not prepared, in all material
respects, in accordance with the Norwegian Accounting Act section 2-3, including:
compliance with the European Sustainability Reporting Standards (ESRS), including that the
process carried out by the Group to identify the information reported in the Sustainability
Statement (the “Process”) is in accordance with the description set out in General information,
and
compliance of the disclosures in EU Taxonomy of the Sustainability Statement with Article 8 of
EU Regulation 2020/852 (the “Taxonomy Regulation”).
Basis for conclusion
We conducted our limited assurance engagement in accordance with International Standard on
Assurance Engagements (ISAE) 3000 (Revised), Assurance engagements other than audits or reviews of
historical financial information (“ISAE 3000 (Revised)”), issued by the International Auditing and
Assurance Standards Board.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our
conclusion. Our responsibilities under this standard are further described in the Sustainability auditor’s
responsibilities section of our report.
Our independence and quality management
We have complied with the independence and other ethical requirements as required by relevant laws
and regulations in Norway and the International Code of Ethics for Professional Accountants (including
International Independence Standards) issued by the International Ethics Standards Board for
Accountants (IESBA Code), which is founded on fundamental principles of integrity, objectivity,
professional competence and due care, confidentiality and professional behavior.
The firm applies International Standard on Quality Management 1, which requires the firm to design,
implement and operate a system of quality management including policies or procedures regarding
compliance with ethical requirements, professional standards and applicable legal and regulatory
requirements.
Other matter
The comparative information included in the Sustainability Statement was not subject to an assurance
engagement. Our conclusion is not modified in respect of this matter.
Responsibilities for the Sustainability Statement
The Board of Directors and the managing Director (management) are responsible for designing and
implementing a process to identify the information reported in the Sustainability Statement in accordance
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Independent Sustainability Auditor's Limited Assurance Report - Komplett ASA
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with the ESRS and for disclosing this Process in General Information of the Sustainability Statement. This
responsibility includes:
understanding the context in which the Group's activities and business relationships take place
and developing an understanding of its affected stakeholders;
the identification of the actual and potential impacts (both negative and positive) related to
sustainability matters, as well as risks and opportunities that affect, or could reasonably be
expected to affect, the, Group's financial position, financial performance, cash flows, access to
finance or cost of capital over the short-, medium-, or long-term;
the assessment of the materiality of the identified impacts, risks and opportunities related to
sustainability matters by selecting and applying appropriate thresholds; and
making assumptions that are reasonable in the circumstances.
Management is further responsible for the preparation of the Sustainability Statement, in accordance with
the Norwegian Accounting Act section 2-3, including:
compliance with the ESRS;
preparing the disclosures in EU Taxonomy of the Sustainability Statement, in compliance with the
Taxonomy Regulation;
designing, implementing and maintaining such internal control that management determines is
necessary to enable the preparation of the Sustainability Statement that is free from material
misstatement, whether due to fraud or error; and
the selection and application of appropriate sustainability reporting methods and making
assumptions and estimates that are reasonable in the circumstances.
Inherent limitations in preparing the Sustainability Statement
In reporting forward-looking information in accordance with ESRS, management is required to prepare
the forward-looking information on the basis of disclosed assumptions about events that may occur in the
future and possible future actions by the Group. Actual outcomes are likely to be different since
anticipated events frequently do not occur as expected.
Sustainability auditor’s responsibilities
Our responsibility is to plan and perform the assurance engagement to obtain limited assurance about
whether the Sustainability Statement is free from material misstatement, whether due to fraud or error,
and to issue a limited assurance report that includes our conclusion. Misstatements can arise from fraud
or error and are considered material if, individually or in the aggregate, they could reasonably be
expected to influence decisions of users taken on the basis of the Sustainability Statement as a whole.
As part of a limited assurance engagement in accordance with ISAE 3000 (Revised) we exercise
professional judgement and maintain professional skepticism throughout the engagement.
Our responsibilities in respect of the Sustainability Statement, in relation to the Process, include:
Obtaining an understanding of the Process, but not for the purpose of providing a conclusion on
the effectiveness of the Process, including the outcome of the Process;
Considering whether the information identified addresses the applicable disclosure requirements
of the ESRS; and
Designing and performing procedures to evaluate whether the Process is consistent with the
Company’s description of its Process set out in General Information.
Our other responsibilities in respect of the Sustainability Statement include:
Identifying where material misstatements are likely to arise, whether due to fraud or error; and
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Independent Sustainability Auditor's Limited Assurance Report - Komplett ASA
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Designing and performing procedures responsive to where material misstatements are likely to
arise in the Sustainability Statement. The risk of not detecting a material misstatement resulting
from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery,
intentional omissions, misrepresentations, or the override of internal control.
Summary of the work performed
A limited assurance engagement involves performing procedures to obtain evidence about the
Sustainability Statement. The procedures in a limited assurance engagement vary in nature and timing
from, and are less in extent than for, a reasonable assurance engagement. Consequently, the level of
assurance obtained in a limited assurance engagement is substantially lower than the assurance that
would have been obtained had a reasonable assurance engagement been performed.
The nature, timing and extent of procedures selected depend on professional judgement, including the
identification of disclosures where material misstatements are likely to arise in the Sustainability
Statement, whether due to fraud or error.
In conducting our limited assurance engagement, with respect to the Process, we:
Obtained an understanding of the Process by:
o performing inquiries to understand the sources of the information used by management
(e.g., stakeholder engagement, business plans and strategy documents), and
o reviewing the Company’s internal documentation of its Process, and
Evaluated whether the evidence obtained from our procedures with respect to the Process
implemented by the Company was consistent with the description of the Process set out in
General information.
In conducting our limited assurance engagement, with respect to the consolidated Sustainability
Statement, we:
Obtained an understanding of the Group's reporting processes relevant to the preparation of its
Sustainability Statement by
o obtaining an understanding of the Group's control environment, processes, control
activities and information system relevant to the preparation of the consolidated
Sustainability Statement, but not for the purpose of providing a conclusion on the
effectiveness of the Group's internal control; and
o obtaining an understanding of the Group's risk assessment process.
Evaluated whether the information identified by the Process is included in the Sustainability
Statement;
Evaluated whether the structure and the presentation of the Sustainability Statement is in
accordance with the ESRS;
Performed inquires of relevant personnel and analytical procedures on selected information in the
Sustainability Statement;
Performed substantive assurance procedures on selected information in the Sustainability
Statement;
Where applicable, compared disclosures in the Sustainability Statement with the corresponding
disclosures in the financial statements and other sections of the Board of Directors’ report;
Evaluated the methods, assumptions and data for developing estimates and forward-looking
information;
Obtained an understanding of the Group's process to identify taxonomy-eligible and taxonomy-
aligned economic activities and the corresponding disclosures in the Sustainability Statement;
Evaluated whether information about the identified taxonomy-eligible and taxonomy-aligned
economic activities is included in the Sustainability Statement; and
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Independent Sustainability Auditor's Limited Assurance Report - Komplett ASA
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Performed inquiries of relevant personnel, analytical procedures and substantive procedures on
selected taxonomy disclosures included in the Sustainability Statement.
Oslo, 17. March 2026
ERNST & YOUNG AS
This document is signed electronically
Petter Frode Larsen
State Authorised Public Accountant (Norway) – Sustainability Auditor
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"Med min signatur bekrefter jeg alle datoer og innholdet i dette dokument."
Petter Frode Larsen
Oppdragsansvarlig partner
På vegne av: Ernst & Young AS
Serienummer: bankid.no no_bankid:9578-5994-4-4118388
IP: 147.161.xxx.xxx
2026-03-17 16:11:04 UTC
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Komplett ASA
Visiting address:
Vollsveien 4A
NO-1366 Lysaker
Norway
Head office:
Østre Kullerød 4
NO-3241 Sandefjord
Norway
Head office postal address:
P.O. Box 2094
NO-3202 Sandefjord
Norway
T: +47 33 00 50 00
E: ir@komplett.com
www.komplettgroup.com