Annual Report
LINK Mobility Group Holding ASA
www.linkmobility.com
2025
Annual Report 2025 | LINK overview
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LINK
overview
LINK Mobility is a leading European provider of
mobile communications and CPaaS solutions,
enabling businesses to engage effectively with
their audiences through mobile messaging,
customer communication, and digital
interaction services across multiple channels.
LINK employs approximately 700 people
across 21 countries, primarily in Europe, with
additional operations in South Africa, Mexico,
and Colombia. LINK serves more than 65,000
customers worldwide and sent 23 billion
messages last year, averaging over 350,000
messages per customer annually. In 2025, the
company expanded its presence to South Africa
through the milestone acquisition of SMSPortal.
More advanced CPaaS solutions like multichannel
conversational OTT solutions are growing
rapidly and currently account for approximately
40% of newly won contracts measured by
gross profit value, while representing around
6% of the total gross profit run-rate.
7.1 billion
2024 revenue in NOK
821 million
Adjusted EBITDA in NOK
margin of 10.3%
Adjusted EBITDA
1138
1348
1528
1649
2022 2023 2024 2025
+14%
486
316
718
821
2022 2023 2024 2025
+19%
Gross Profit NOKm
Overview of gross profit & EBITDA adj:
Adjusted EBITDA NOKm
Annual Report 2025 | LINK overview
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LINK Mobility celebrated its 25th anniversary in July 2025, marking a significant milestone in the
company’s journey. Since its founding, the company has experienced substantial growth, evolving from
a small regional player into a leading provider of international mobile messaging and communication
services. Over the past 25 years, LINK Mobility has expanded its geographic footprint, strengthened its
technology platform, and built a large and diverse customer base across multiple industries.
The company’s development has been particularly dynamic in recent years, with continued international
expansion, strategic acquisitions, and growing demand for mobile communication solutions. This period
has been characterized by innovation, rapid scaling, and an increasing role in enabling businesses to
connect with their customers through secure and reliable messaging services.
Below is a timeline highlighting some of the key milestones and developments in LINK Mobility’s history.
PSWinCom AS
Fivestarday AB
Cool Group ApS
Responsfabrikken
Linus
Labyrintti
Whatever Mobile
Globalmouth
Netmessage
SMSAPI/Comvision
VoiceCom
Global Messaging Solutions
Vianett AS
Didimo
SMS.it
Totalconnect/Archynet
Simple SMS
Horisen Messaging
SeeMe/Dream Interactive
Hay Systems
Multiwizz
Aspiro Mobile Solution AS
Aspiro Mobile Solutions AB
Aspiro Mobile Solutions SIA
The focus shifted from a content business to B2C as a
technical provider, helping customers to enhance sales
through the mobile channel. LINK Mobility AB: Continued
its business, but with a broader product portfolio.
Focused on selling in-house content and in-house services through partners.
Business in Norway was increasing and business outside Norway was decreasing.
Ememess AS
Soprano Design
Re-listing on
Oslo Stock Exchange
Tismi
MarketingPlatform
81% of
AMM S.p.A
Soprano Design
Tismi
MarketingPlatform
81% of
AMM S.p.A
Net Real Solutions
EZ4U
The SMS Works
Reach Interactive
FireText Communications
SMSPortal
InTouch
from Eniro Norway AS
Chess
LINK Messaging AB
formerly Telenor LINK AB
2001
2015
2016
2017
2019
2020
2021
2014
2009
2008
2002
2003
2004
2018
2024
2023
2022
2025
LINK was acquired by
Abry Partners
2005
2006
2007
2013
2012
2011
2010
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The company has a strong focus
on growth through both organic and
inorganic initiatives.
In the last 2 years, LINK Mobility has
acquired 6 new companies,
of which, 3 were acquired in 2025.
These are:
Firetext Communications (UK)
SMSPortal (South Africa)
2021
2025
SMSWorks
(UK)
Firetext Communications s
(UK)
SMSPortal
(South Africa)
Altiria
(Spain)
Chatbot Xenioo
(Italy)
AMM
(Italy)
MarketingPlatform
(Denmark)
Tismi
(Netherlands)
Reach Interactive
(UK)
Net Real Solutions S.L.
(Spain)
EZ4U
(Portugal)
2024
2022
2023
SMSWorks (UK)
Annual Report 2025 | Message from the CEO
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2025 has been a transformative year for LINK Mobility,
with clear progress across profitability, cash generation,
and strategic execution. We strengthened the business
operationally and financially while continuing to scale
our footprint across markets. This has positioned us
with strong local presence combined with scale and
advanced capabilities, outcompeting local providers
with more sophisticated solutions, while being at par
with global players on products and functionality,
outcompeting them on local customers reach in ways
more centralized competitors cannot.
The year’s key highlight is our strong operating
earnings growth. On a pro forma basis, reflecting the
full-year contribution from acquisitions completed in
2024 and 2025, adjusted EBITDA increased from NOK
740 million to NOK 1.1 billion, representing a year-on-
year growth of 48%. Over the same period, leverage
increased only modestly, from 1.35x to 1.49x adjusted
EBITDA, demonstrating strong profit growth alongside
financial discipline and a robust balance sheet.
Organic gross profit growth has been, and remains, our
number one priority. We delivered 5% pro forma gross profit growth
and 7% pro forma adjusted EBITDA growth in 2025, which was below
our targets given the opportunities we see in the market. The year
was negatively impacted by a softer fourth quarter as a handful of
clients reduced consumption. In 2026, we expect a gradual return to
growth, supported by easing comparables, a high contract backlog to
be implemented during the year, and continued healthy momentum
across the broader customer base.
In 2025, we maintained strong M&A momentum. The acquisition of
SMSPortal, announced in June, represents a transformative step for
LINK and expands our footprint beyond Europe. As the leading provider
in South Africa, SMSPortal serves more than 5,400 customers and
processes around 16 billion messages annually, strengthening LINK’s
scale and capabilities in the global messaging market. The transaction
closed in November 2025, and we are pleased to welcome 32 new
colleagues in South Africa to the LINK team.
Cash generation remained strong in 2025, with more than NOK 400
million in free cash flow. With the full year effect of SMSPortal, cash
generation would be significantly higher, at over 600 million. We expect
A message from the CEO
Thomas Berge
CEO
Annual Report 2025 | Message from the CEO
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cash generation to strengthen further in the years ahead. During the
year, we introduced our first shareholder distribution policy, underlining
our commitment to disciplined capital allocation and consistent capital
returns.
This strong financial position provides flexibility to invest in our core
business and conversational messaging solutions, pursue selective
bolt-on acquisitions, and return capital to shareholders through
dividends or share buybacks, while maintaining a healthy leverage ratio.
Looking ahead, we remain confident in LINK Mobility’s long-term
opportunities, strategy and localized go-to-market approach. Demand
for digital messaging and conversational communication continues
to grow across industries, and we are well positioned to capture
this growth through our strong platform and scalable operations.
Our strategy is centered on expanding higher-value, data-driven
communication use cases, while building on our strong position in
mission-critical messaging. This is supported by our localized go-to-
market approach, combining scale with local presence and expertise
to serve customers with increasingly sophisticated communication
needs. We will continue to strengthen commercial execution and
drive adoption of more advanced conversational solutions across our
markets.
At the same time, we will pursue selective bolt-on acquisitions that
complement our organic growth strategy and further strengthen
our position within our existing geographic footprint. Our long-term
strategy of combining organic growth with disciplined acquisitions
remains firmly in place as we evaluate opportunities that support
sustainable value creation. With a solid financial foundation, strong
cash generation, and a clear strategic direction, LINK Mobility is
well positioned to continue creating long-term value for customers,
partners, and shareholders.
Finally, I would like to extend my sincere gratitude to our employees
across all markets. Their dedication, expertise, and commitment
to delivering value for our customers form the foundation of LINK
Mobility’s continued success over the past 25 years. I would also like
to thank our customers, partners, and shareholders for their continued
trust and support.
Thomas Berge, CEO
Oslo, April 28, 2025
Executive summary
Annual Report 2025
Reimagine
communications
as you know it
Annual Report 2025 | Executive summary
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Executive Summary – LINK Mobility
LINK Mobility is Europe’s leading provider of digital messaging, operating at the center of a rapidly
evolving customer communication landscape. As businesses shift from one-way messaging towards
more data-driven, interactive, and outcome-oriented communication, LINK plays a critical role in enabling
reliable, scalable, and compliant engagement across the full customer journey.
The company’s competitive position is built on a unique combination of local presence and global scale.
With operations across European markets and additional presence in LATAM and Africa, LINK combines
deep regulatory and market understanding with a scalable platform and strong operator relationships.
This positions LINK between global, centralized providers and smaller local players, offering broader
reach and proximity than the former, and more advanced capabilities than the latter.
Organic gross profit growth is the company’s primary strategic priority. LINK is focused on driving growth
through increased customer usage, upselling of higher-value solutions, and continued expansion within
its existing customer base. This is supported by a structurally recurring business model anchored in
mission-critical communication use cases such as notifications, authentication, and operational
messaging, which provide stable demand, low churn, and long-term customer relationships.
At the same time, LINK is evolving its platform to capture the increasing value in customer communication.
As complexity grows across channels and use cases, demand is shifting towards solutions that enable
orchestration, automation, and data-driven decision-making. Rather than competing directly with full-
scale CRM or marketing platforms, LINK is strengthening its position in the interaction layer, where
reliable delivery meets intelligent communication.
As communication becomes more automated and AI-driven, the importance of robust, compliant, and
locally adapted messaging infrastructure increases. Delivering real-time, personalized communication
at scale requires more than software, it depends on deep, long-standing relationships with telecom
operators, direct connectivity, and the ability to manage routing, quality, and compliance across markets.
These capabilities are complex, regulated, and built over time, creating a structural barrier to entry.
In this context, LINK’s infrastructure and local presence are not displaced by AI; rather, they become
increasingly critical to enabling it.
AI will not replace this infrastructure; rather, we believe it will activate it at an entirely new level. With
a robust, locally adapted messaging foundation in place, AI can orchestrate communication across
channels in real time, ensuring that the right message is delivered through the right channel based
on user preferences, context, and behavioral signals. AI-driven agents, chatbots, and advanced
conversational flows can handle a large share of customer interactions autonomously, continuously
learning and optimizing engagement. As these agents scale and operate persistently across use cases,
we expect them to drive a structural increase in interaction volumes on LINK’s platform. Each of these
interactions relies on reliable message delivery, routing, and compliance, which in turn is expected to
have a positive effect on traffic and revenue, further amplifying the need for high-quality messaging
infrastructure to support more personalized and efficient communication at scale.
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Execution is supported by a diversified and scalable go-to-market model. LINK combines localized
enterprise sales, a growing partner ecosystem, and scalable self-service platforms to drive customer
acquisition, expansion, and retention. Growth is further supported by a strong pipeline of contract wins,
continued product development across the MyLINK platform, and increasing adoption of multichannel
and conversational messaging solutions.
Mergers and acquisitions remain a core component of LINK’s growth strategy. Building on a strong
track record, the company continues to pursue disciplined, value-accretive bolt-on acquisitions within its
existing footprint in the near term, reflecting current market conditions and valuation levels. At the same
time, larger strategic acquisitions remain an important part of LINK’s long-term growth ambition, as the
company continues to evaluate opportunities that can further strengthen its market position, expand its
capabilities, and support sustained value creation.
Looking ahead, LINK Mobility is well positioned to capture the continued expansion of digital and
conversational communication. With a strong foundation in mission-critical messaging, a clear strategic
focus, and a scalable platform, the company is positioned to deliver sustainable growth and long-term
value creation.
Our ESG criteria forms an integral part of
LINK’s strategy.
ESG remains an integral part of LINK’s strategy and long-term value creation.
LINK’s Environmental, Social and Governance strategy was first established in 2021 and further refined
in 2024. As part of this development, LINK has committed to reducing emissions in line with Science
Based Targets for the period 2025–2027. The company also continues to align its reporting with the
European Sustainability Reporting Standards (ESRS), including reporting of Scope 1, 2, and 3 emissions.
LINK’s employees are central to the company’s continued development and success. Their expertise,
collaboration, and commitment are essential to delivering high-quality products and services to
customers. LINK aims to remain an attractive employer for ambitious and purpose-driven individuals
who want to contribute to the company’s development as a leading CPaaS provider.
Diversity, equity, and inclusion are viewed as important enablers of innovation, long-term value creation,
and sustainable growth. These principles guide how LINK works with colleagues, customers, and
partners, and form part of the company’s broader organizational culture.
Further information is provided in the Sustainability Statement in this report.
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Market development and industry trends
Customer communication continues to evolve rapidly, driven by rising expectations for immediacy,
relevance, convenience, and responsiveness. Across industries, businesses are moving beyond one-
way transactional messaging towards more dynamic and interactive communication across the full
customer journey.
This development is being enabled by advances in automation, data, and artificial intelligence, as well as
the growing adoption of richer messaging formats such as RCS and OTT channels including WhatsApp.
Customers increasingly expect to interact with businesses in the same intuitive and responsive ways
they experience in their everyday digital lives.
As communication becomes a more integrated part of how businesses operate, serve, and grow,
enterprises increasingly require solutions that enable:
• real-time, multi-channel communication
• two-way customer interaction
• contextual and personalized messaging
• consistent experiences across channels and touchpoints
At the same time, the increasing number of channels and use cases creates greater complexity for
businesses. This complexity supports demand for platforms that can manage communication flows
across channels while maintaining reliability, compliance, and performance visibility.
Industry-specific communication trends
Communication needs continued to evolve across LINK’s core industry segments during 2025.
Retail and e-commerce companies increasingly relied on direct, permission-based communication to
deliver real-time updates, personalized offers, and seamless customer journeys.
Financial institutions expanded the use of secure messaging for authentication, fraud alerts, and
regulatory communication, reinforcing trust while improving operational efficiency.
In the leisure sector, customer experience remained a key differentiator, driving adoption of automation,
chatbots, and rich media messaging.
Logistics providers continued prioritizing proactive and automated communication to improve
operational efficiency and customer satisfaction through real-time notifications and interactive delivery
updates.
Technology companies increasingly sought integrated communication solutions capable of supporting
scalable, transparent, and automated customer interactions.
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LINK’s positioning
LINK is positioned at the center of this development, enabling businesses to manage customer
communication across the full customer lifecycle while maintaining a strong foundation in mission-
critical messaging.
The company’s competitive position is supported by several structural strengths. As well as its
international presence in LATAM and Africa, LINK combines a strong local presence across European
markets with scalable platform capabilities, allowing it to support customers through both local
expertise and international delivery. This differentiates LINK from more centralized global competitors.
LINK also benefits from long-standing operator and carrier relationships, which support reliable delivery
quality, optimized routing, and early access to emerging technologies such as RCS Business Messaging.
In addition, LINK’s customer base is anchored in previously identified mission-critical messaging
communication use cases such as authentication, notifications, and operational messaging. These use
cases contribute to recurring traffic, low churn, and long-term customer relationships.
Taken together, these strengths position LINK well to support customers as communication becomes
more omnichannel, interactive, and data-driven.
Product and platform
LINK’s product portfolio supports customer communication across a broad range of use cases and
channels, with an increasing focus on automation, orchestration, and data-driven communication.
The company’s MyLINK solutions enable customers to manage communication across their full
customer journey. Key solutions include MyLINK Connect, which supports conversational customer
support and automated service interactions, MyLINK MarketingPlatform, which enables multichannel
orchestration based on customer segmentation and behavioral data; and MyLINK Studio, which allows
enterprises to design, automate, and manage customer communication journeys across channels
within a unified interface.
Together, these solutions provide a scalable platform for managing customer engagement workflows,
improving response times, operational efficiency, and the relevance of communication.
Across its portfolio, LINK integrates multiple communication channels, including SMS, RCS, email, and
OTT messaging, enabling customers to manage communication across different touchpoints while
maintaining visibility and control.
LINK’s continued investment in analytics, automation, and artificial intelligence is intended to further
strengthen platform capabilities, improve scalability, and support more adaptive and efficient
communication. The company’s solutions have also received external recognition for innovation in areas
such as RCS Business Messaging, reflecting LINK’s continued development within next-generation
communication technologies.
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LINK’s recurring and growing business model
LINK operates a fundamentally recurring business model, as customers rely on continuous
communication solutions to engage with end users. Once onboarded, customers typically recognize the
value of reliable and timely messaging, resulting in low churn and long-term relationships. Over time,
many customers expand their usage rather than discontinue services.
Notifications Mobile marketing
Revenue by use case
Customer service
70%
22%
8%
Approximately 70% of LINK’s revenue is derived from notification-based communication. These services
are mission-critical across sectors such as healthcare, utilities, and logistics, enabling reminders, alerts,
and operational updates. Due to their critical nature, this segment is highly resilient and supports stable,
predictable demand.
Mobile marketing accounts for approximately 20% of revenue. While this segment has historically been
driven by larger retailers, adoption is expanding as richer communication channels such as RCS and
OTT messaging enable higher engagement and more interactive customer experiences. Compared with
notification traffic, this segment is more sensitive to changes in consumer demand, but it also offers
attractive growth potential.
LINK also sees opportunities within Contact Center as a Service (CCaaS), where communication
solutions can improve efficiency and support automation of customer interactions. The increasing use
of AI-powered chatbots and digital self-service tools is expected to support continued development in
this area.
Overall, LINK’s business model combines stable, recurring revenue from mission-critical use cases with
growth opportunities driven by richer channels, increased usage, and expanding customer needs.
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LINK’s go-to-market strategy
LINK employs a diversified go-to-market model designed to support customer acquisition, expansion,
and long-term retention across markets and customer segments.
The company’s go-to-market approach is structured around three complementary channels: enterprise
sales, partner distribution, and self-service platforms (SSU). Together, these channels enable LINK to
combine strong local presence with scalable access to a broad customer base.
Enterprise sales
The enterprise sales model remains the core of LINK’s commercial approach. It is built around localized
sales teams operating across European markets, enabling close customer relationships, native-language
support, and a strong understanding of local requirements. This model is particularly effective for large
enterprise and public sector customers, where communication solutions are often business-critical and
require tailored implementation.
In addition to new customer acquisition, the enterprise model supports upselling and cross-selling of
additional services, which represent an important driver of growth. A significant share of gross profit
growth is expected to come from expansion within the existing customer base.
Partner ecosystem
LINK is continuously expanding its partner ecosystem, where partners integrate LINK’s communication
capabilities into their own products and services. This approach enables indirect distribution and access
to new customer segments, while also strengthening LINK’s position within broader digital ecosystems.
The partner model builds on LINK’s strong track record in selected markets and has been further
structured into a scalable framework across Europe. By enabling partners to embed LINK’s solutions
into their own offerings, the company can extend its reach while maintaining an efficient and asset-light
distribution model.
Official
Platinum Partner
Official
Gold Partner
Official
Certified Partner
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Self-service platforms (SSU)
LINK’s self-service platforms represent a scalable and high-margin go-to-market channel, primarily
targeting small and medium-sized enterprises. Through intuitive digital onboarding and user-friendly
interfaces, customers can quickly access and utilize LINK’s services without the need for direct sales
involvement.
The company operates several established SSU brands across European markets, including SMSAPI,
Spot-Hit, and WebSMS. These platforms play an important role in broadening LINK’s customer base and
enabling efficient customer acquisition at scale.
The SSU model complements the enterprise and partner channels by providing a standardized and
efficient offering for smaller customers, while also supporting international reach through localized
platforms and multi-language capabilities.
LINK’s diversified go-to-market model allows the company to balance local presence with scalability,
supporting both deep customer relationships and efficient customer acquisition across segments. This
structure also enables LINK to adapt its commercial approach to different customer needs, industries,
and market conditions.
LINK’s three GTM approaches have led to strong gross profit contribution from new contract wins, up
16% year-over-year.
powered by
Gross Profit contribution from new contract wins
A2P CPaaS
NOKm
Q1 24
0
50
40
30
20
10
36
14
22
11
16
16
32
14
24
16
24
15
27
13
30
26
24
Q2 24
48
Q3 24
28
Q4 24
38
Q1 25
42
Q2 26
50
Q3 26
43
Q4 26
40
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Mergers & acquisitions
An integral part of LINK’s strategy
M&A has been a key pillar in LINK’s growth journey and has played a significant part in becoming
the leading European A2P (Application-to-Person) messaging player. LINK has historically leveraged
acquisitions to drive accretive growth and has over the last 10 years completed 36 acquisitions. Going
forward, M&A will continue to play a key role in LINKs growth journey.
Following the divestment of Message Broadcast in Q1 2024, LINK accelerated M&A activity, completing
three acquisitions during the same year. This momentum continued into 2025, with a total of three
acquisitions closed during the year, consisting of two bolt-on acquisitions: 1) The SMS Works, 2) FireText
Communications and one level-up transaction: 3) SMSPortal.
Acquisition of The SMS Works:
On the 1st of April 2025, LINK Mobility UK acquired the UK company The SMS Works. The acquisition
helped to solidify LINK Mobility’s UK presence.
The SMS Works was founded in 2017 and specializes in SMS services through a developer- friendly
API and a web-based messaging service. The company serves over 500 customers, with a particularly
strong presence among software integration customers.
FireText Communications:
On the 17th of April 2025, LINK Mobility UK acquired FireText Communications, significantly expanding
reach and presence in the UK market, and added several strategic public sector customers and a proven
SSU marketing platform to LINK's portfolio.
Established in 2007 and headquartered in Falmouth, UK, FireText offers SMS solutions through an SSU
platform, enabling users to send SMS’ on the web or by using FireText’s API. FireText has approximately
2,700 customers, and in 2024 the company sent over 850 million SMS.
SMSPortal:
On the 28th of November 2025, LINK Mobility acquired the South African company SMSPortal and thus
entered South Africa and the African continent. The acquisition unlocks a new geography and offers
opportunities in upselling more advanced CPaaS solutions to SMSPortal’s enterprise customer base.
SMSPortal was established in 2003 and is headquartered in Cape Town, South Africa and has grown to
be the number one A2P SMS player in the country with c.35% market share. The company offers SMS
solutions to predominantly large local enterprises and a number of international corporations through
its highly advanced technology platform. In the last twelve months ending April 2025, SMSPortal had
over 5,100 customers with less than 1% revenue churn.
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Forward strategy:
LINK expects to maintain an active acquisition strategy in 2026. As previously communicated, the near-
term M&A focus will be on bolt-on acquisitions rather than larger transactions, reflecting current valuation
conditions. Should valuation levels become more attractive, larger transactions may be reconsidered,
subject to an overall assessment of capital allocation priorities.
The company’s medium-term capital allocation framework remains unchanged, with a continued focus
on value creation through organic growth and accretive M&A. Within this framework, accretive M&A
represents the primary capital allocation priority in the medium term.
With a pro-forma NIBD/LTM adjusted EBITDA of 1.49x, LINK is well-positioned to execute on M&A
opportunities going forward. The short-term focus is on bolt-on acquisitions in geographies where
LINK has an existing presence, opening up for synergies through cost efficiencies and upselling new
solutions to the target’s customer base. On the back of LINK's extensive M&A experience, a structured
M&A playbook has been developed outlining key criteria for evaluating potential acquisition targets a:
• Strong local market position and strong telecom operator relationships
• Cash EBITDA positive and cash accretive to LINK from day one
• Solid, well-diversified customer portfolios with low churn
• ~80% overlapping technology and strong commercial enterprise focus
• Synergy potential to create further value
• Target valuations between 6-9x cash EBITDA before synergies pending growth momentum
We remain committed to executing our Forward M&A strategy while adhering to our leverage policy,
maintaining a maximum leverage ratio of max 2.0x–2.5x adjusted EBITDA.
Report from the
Board of Directors
Annual Report 2025
Reimagine
communications
as you know it
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Report from the Board of Directors
LINK Mobility Group Holding ASA (LINK) is headquartered in Oslo and listed on the Oslo Stock Exchange
(OSE). The group has around 700 employees, primarily in Europe, with additional operations in two
LATAM countries and South Africa following the acquisition of SMSPortal.
LINK has over 25 years of experience delivering mobile messaging services and solutions for businesses,
public sector organizations, and other institutions. For decades, the company has operated across the
Nordics, one of the world’s most innovative markets for digital mobile solutions, and in recent years has
used this expertise to establish itself as a clear European market leader in enterprise mobile messaging.
With its extensive experience and broad reach, LINK is uniquely positioned to benefit from the growing
global adoption of mobile messaging solutions.
Market position and development
In 2025, LINK Mobility further strengthened its position as Europe’s leading provider of digital messaging
services. The company continued to maintain a strong market presence, holding a dominant share in
key regions, including approximately 46% in Norway, and securing top three positions across several
European markets.
LINK operates in 18 European countries and also has a presence in Latin America, including Mexico
and Colombia, following the acquisition of Net Real Solutions in Spain in 2024. In 2025, the company
further expanded its global footprint with entry into South Africa through the acquisition of SMSPortal,
one of three strategic acquisitions completed during the year. The two additional acquisitions in the UK,
SMSWorks and FireText Communications, further strengthened LINK’s position in the British market.
Adoption of selected Communications Platform as a Service (CPaaS) products is accelerating rapidly,
as evidenced by LINK’s strong performance in new contract wins within this segment, which increased
by 27% year over year. In parallel, progress toward enabling RCS support on Apple devices is broadening
both the reach and demand for advanced messaging solutions across LINK’s ecosystem.
As RCS and OTT capabilities continue to evolve, they are unlocking new use cases and creating additional
commercial opportunities across multiple industries. LINK’s continued emphasis on innovation,
scalability, and customer-centric solutions further strengthens its ability to drive growth, attract new
enterprise customers, and deepens partnerships to accelerate sales expansion.
With businesses, public institutions and organizations increasingly prioritizing digital messaging as
their primary communication channel, LINK is well positioned to capitalize on these structural growth
trends and reinforce its leadership position in the European market.
Comments related to the financial statements
In accordance with the Norwegian Accounting Act §3-3a, the Board confirms that the company fulfils
the requirements necessary to operate as a going concern and the 2025 financial statements have been
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prepared based on that assumption. As a listed company, LINK Mobility Group Holding ASA prepares
the consolidated financial statements for the financial year 2025 in accordance with the International
Financial Reporting Standards (IFRS) as adopted by the European Union.
Revenue, costs, and profits
In 2025, LINK reported revenue of NOK 7 083 million, an increase of approximately 1% from NOK 6 994
million in 2024. LINK’s gross profit was NOK 1 694 million (NOK 1 528 million).
Operating costs (including payroll and related services and other operating expenses) were NOK 976
million (NOK 929 million) and included non-recurring costs of NOK 103 million. The non-recurring costs
include a share-based compensation program of NOK 21 million, restructuring costs of NOK 16 million,
and expenses related to acquisitions of NOK 66 million. Depreciation and amortization were NOK 400
million (NOK 334 million).
Net financial items amounted to a negative NOK 187 million (negative NOK 43 million) and constituted
a net interest expense of NOK 106 million linked to an outstanding bond, net other financial income of
NOK 3 million, and a negative currency effect of NOK 84 million. LINK’s outstanding EUR 125 million
bond (LINK02) carries a coupon of 3-month EURIBOR + 2.35% per annum and matures in October 2029,
and the outstanding EUR 100 million bond (LINK03) carries a coupon of 3-month EURIBOR + 2.75% per
annum and matures in June 2030.
Income tax expense is NOK 44 million (NOK 50 million), resulting in a net profit from continuing
operations of NOK 87 million (NOK 172 million).
Annual result and allocation
The board proposes that the 2025 net profit will be transferred to accumulated losses.
Financial position, cash flow, and liquidity
As of December 31, 2025, LINK’s total assets amounted to NOK 10 965 million (NOK 10 722 million),
of which intangible assets were NOK 8 119 million (NOK 6 435 million). Intangible assets are mainly
comprised of goodwill equal to NOK 5 388 million (NOK 4 673 million). Trade receivables and other
receivables amounted to NOK 1 604 million (NOK 1 610 million) and cash and cash equivalents to
NOK 1 032 million (NOK 2 479 million). Total equity was NOK 5 747 million (NOK 5 378 million) and
is comprised of NOK 1.5 million in share capital, a share premium of NOK 6 131 million, and NOK 573
million in other reserves. Negative NOK 321 million relates to own shares; the remainder of the total
equity amount is related to accumulated losses.
Long-term liabilities were NOK 3 150 million (NOK 1 744 million) and consisted mainly of the EUR 125
million LINK02 and EUR 100 million LINK03 bonds; LINK01 was classified as a current liability in the
prior year.
LINK’s cash flow from operating activities was NOK 701 million (NOK 622 million). Cash flow from
investing activities was negative NOK 1 353 million (negative NOK 333 million). Cash flows from
financing activities amounted to negative NOK 969 million (negative NOK 1 234 million), mainly related
to proceeds from the LINK03 bond (NOK 1 162 million), repayment of borrowings (negative NOK 1 998
million), and interest payments (negative NOK 137 million).
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Comments related to the Sustainability Statement
LINK’s obligation to include a Sustainability Report in its annual report is based in the Norwegian
Accounting Act (Regnskapsloven) §2-3. The requirement to provide a Sustainability Report based on
the ESRS is stated in the Accounting Act §2-4(5). As head of a group of companies, LINK Mobility
Group Holding ASA provides a consolidated sustainability report, Cf. Accounting Act §2-3(2). LINK’s
Sustainability Statement for 2025 is a clearly identifiable and distinguishable part of the Annual Report,
as required in Accounting Act §2-4(1), and shows the steps taken in LINK Mobility to reach compliance
with the sustainability reporting requirements included in the Accounting Act Chapter 2.
Sustainability in LINK
LINK’s board of directors has adopted a policy to reflect the company’s commitment to integrate ESG
factors into its daily operations and as a part of its strategic processes. LINK’s Environmental, Social
and Governance (ESG) strategy was initially concluded in 2021. In 2024, an updated strategy was
adopted by the Board of Directors, with a commitment for LINK to reduce emissions based on Science
Based Targets during the term 2025-2027. This commitment is further implemented in LINK’s updated
strategy. The commitment to integrate a sustainability statement fully based on the ESRS in the annual
report, and to include carbon data from Scope 1, 2 and 3, remains in the updated strategy. LINK’s ESG
policy is available at www.linkmobility.com/legal.
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The board has considered the ESG factors in relation to LINK’s business operations and reviewed factors
based on the UN Sustainable Development Goals (SDGs), the Ten Principles of the UN Global Compact,
and the OECD Guidelines for Multinational Enterprises.
In 2021, LINK confirmed it committed to integrating the Ten Principles of the UN Global Compact in
its operations by becoming a signatory. The participation in the UN Global Compact has continued,
reflecting constant efforts to incorporate sustainability factors into our operations. In line with the UN
Global Compact, LINK is committed to continuous progress in the four focus areas: Anti-Corruption,
Human Rights, Environment and Labor.
• LINK’s reports under UN Global Compact can be found here:
https://www.unglobalcompact.org/what-is-gc/participants/145208-LINK-Mobility-Group-Holding-ASA .
In 2024, LINK Committed to developing targets for reducing its emissions under the Science Based
Targets initiative (SBTi). SBTi provides companies with a clearly defined path to reduce emissions in line
with the Paris Agreement goals.
• LINK’s commitment to Science-Based Targets can be found here:
Companies taking action - Science Based Targets Initiative
In 2025, LINK’s efforts in sustainability were recognized by EcoVadis, an assessment platform that rates
businesses' sustainability performance. With a score of 69, LINK Mobility is now ranked among the top
17% of all assessed companies, earning LINK the EcoVadis Bronze Medal.
This recognition highlights LINK Mobility’s strong management system and commitment to sustainability.
The assessment is based on EcoVadis’ comprehensive methodology, which evaluates companies
across four key areas: Environment, Labor & Human Rights, Ethics and Sustainable Procurement.
• LINK’s rating with EcoVadis can be found here: Ecovadis Bronze Medal | LINK MOBILITY
GROUP HOLDING ASA
Materiality assessment
Since the global understanding of ESG as important factors affecting businesses across markets and
industries gains ground, it is crucial for LINK, as any other business, to understand and manage impacts,
risks and opportunities related to these topics, not only when making strategic decisions but also in its
daily operations.
In a context that is constantly evolving, LINK recognizes that the areas affected by ESG factors may
vary over time and it therefore performs an annual materiality assessment. The first materiality
assessment was performed in 2020. For 2025, the materiality assessment was performed for the third
time in accordance with the ESRS requirements. The detailed methodology and results are visible in the
Sustainability Statement.
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Diversity
The rules regarding composition, included in the Instructions for the Nomination Committee for LINK
Mobility Group Holding ASA (Resolved by the General Meeting on May 29th 2024), and the Norwegian
Public Limited Liability Companies Act (PLLCA) § 6-11 and §6-11a, are applied by the Nomination
Committee, thus ensuring that the board has a composition appropriate to the company’s operations,
phase of development, gender balance, independence and other elements of relevance to board
composition.
The ESG policy’s statements regarding diversity, inclusion and belonging form the policy for recruitment.
The considerations for diversity with regard to gender, disabilities and ethnicity are basis for recruitment
on all levels, including group management.
Further disclosures regarding diversity are available in the Sustainability Statement.
Greenhouse Gas (GHG) emissions
To understand energy consumption and greenhouse gas emissions related to LINK’s activities, detailed
information from LINK’s entities is collected each year. LINK will continue to expand its data collection
methodology with improvements to the data quality and availability. 2025 is the fourth year LINK has
mapped and calculated its climate impact from scope 1 and scope 2 emissions, and the third year LINK
has included scope 3 emissions. The calculations have been made according to the Greenhouse Gas
Protocol (GHGP).
The table below summarizes the GHG-account for LINK Mobility in 2025, 2024 and 2023. LINK reports on
direct emissions (Scope 1), indirect emissions from electricity and district heating (Scope 2) and other
indirect emissions (Scope 3). Indirect emissions linked to energy use (electricity and district heating)
and the purchase of goods and services that characterize emissions from LINK Mobility. When location-
based calculation method is used for emissions related to energy use (scope 2), approximately 85 % of
LINK’s total footprint comes from other indirect emissions (scope 3). When market-based calculation
method is used, the share is 84 %. As an office-based business not producing physical goods, it is
expected that indirect emissions from scope 3 are the most significant sources of emissions. In 2025
SaaS/cloud-based services and air travel are estimated to be the largest sources, accounting for
approximately 65 % percent of total scope 3 emissions.
Estimated total GHG-emissions in 2025 is 1 021.2 tons of CO2eq using the location-based approach,
and 1 032.9 tons of CO2eq using the market-based approach for estimating scope 2 emissions.
Respectively a 12.6 % increase (location-based) and 9.9 % increase (market-based) in emissions when
compared to 2024 levels. It is a result of increases in estimated scope 3 emissions in 2025 compared
to 2024. A more detailed breakdown of the GHG-account and a comparison of 2023, 2024 and 2025 are
described in the GHG-report for 2025, available on LINK’s webpage.
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2025 2024 2023
Scope Activity
Activitity
data
Unit of
measure
Tonnes
CO2e
Activitity
data
Unit of
measure
Tonnes
CO2e
Activitity
data
Unit of
measure
Tonnes
CO2e
Scope 1
Stationary combustion
Natural gas
consumption
25 214.5
kWh ICV/
year
5.2 26 204.5
kWh ICV/
year
5.4 43 824.7
kWh ICV/
year
9.0
Transportation
Gasoline 1 106.9 liters/year 2.6 1 428.2 liters/year 3.3 638.1 liters/year 1.5
Diesel 3 177.7 liters/year 8.5 11 847. liters/year 31.5 5 113.6 liters/year 13.6
Diesel car
(distance
travelled)
58 305.0 km/year 8.5 107 238 km/year 15.5 113 794 km/year 16.5
Gasoline
car(distance
trav-elled)
20 401.0 km/year 2.7 85 772.0 km/year 11.4 73 667.0 km/year 9.8
Scope 1 In total 27.5 67.1 50.4
2025 2024 2023
Scope Activity
Activitity
data
Unit of
measure
Tonnes
CO2e
Activitity
data
Unit of
measure
Tonnes
CO2e
Activitity
data
Unit of
measure
Tonnes
CO2e
Scope 2
Power
consumption -
office
413 445.9 kWh/year 80.4 495 434 kWh/year 120.1 546 599 kWh/year 142.0
Power
consumption
- data center/
servers
15 319.0 kWh/year 0.1
Amended
(described
in text)
kWh/year -
Amended
(described
in text)
kWh/year -
District
Heating /
cooling
192 821.2 kWh/year 42.7 284 339,5 kWh/year 36.9 339 948.4 kWh/year 48.2
EV Vehicle 35 000.0 km/year 0.3 60 720,0 km/year 0.8 49 172.0 km/year 1.4
Scope 2 In total 123.5 157.8 191.6
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2025 2024 2023
Scope Activity
Activitity
data
Unit of
measure
Tonnes
CO2e
Activitity
data
Unit of
measure
Tonnes
CO2e
Activitity
data
Unit of
measure
Tonnes
CO2e
Scope 3
Upstream
emissions
fuel
Scope 1 activities 5.7 Scope 1 activities 14.4 - - -
Air travel 715
Passenger
trips
273.5 742
Passenger
trips
257.0 501
Passenger
trips
143.5
Commuting
(incl. walk/
bike)*
3 009 823
passenger
km
252.5 2 556 518
passenger
km
212.9
2 284
608
passenger
km
204.6
IT
equipment
400 units 45.1 569 units 88.0 391 units 46.1
SaaS/cloud-
services
n/a n/a 293.3 n/a n/a 109.4 n/a n/a 193.3
Waste 11 026 kg 0.1 17749 kg 0.1 47853 kg 1.0
Scope 3 In total 870.2 681.8 588.5
In total
Scope 1+ 2
(location based)
+ 3
1021.2 906.7 830.5
Scope 1+ 2 (market
based) + 3
1032.9 940.1 881.1
Table 1 Detailed GHG account LINK Mobility 2025, 2024 and 2023.
*Commuting km includes private transport (car etc.), public transport (train, bus etc.) and walking/
biking. Numbers are rounded to nearest 1 decimal place.
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Management of Risks
Risk Management
Awareness of the risk exposure that may potentially negatively impact LINK and to opportunities
that may positively impact LINK is necessary to identify such risks and opportunities and implement
necessary and adequate management. LINK has therefore implemented a Risk Management
Framework with the objective to enable alignment of risk management for LINK Mobility as a group
of companies, by identifying and managing risks and opportunities under defined areas and allowing
separate processes in each team while ensuring overview through a single framework, facilitating each
team’s risk management work, and maintaining oversight of Risks facing LINK as a group. The Risk
Management Framework allows LINK as a group to meet its objectives, monitoring, reporting, and
providing advice on risk exposure to top management in LINK Mobility and continuously reviewing and
improving identification, management and treatment of risks and opportunities.
LINK’s Risk Management Framework is not limited to specific risks but recognizes both risks to enterprise
(inward-facing approach, also referred to as Financial Materiality) and risks of adverse impacts on
people, the environment and society (outward- facing approach, also referred to as Impact Materiality).
The Risk Management Framework thus reflects the concept of Double Materiality.
LINK Mobility’s Risk Management Framework is set out in alignment with the Due Diligence Process
defined in the OECD Due Diligence Guidance for Responsible Business Conduct.
Source: OECD Due Diligence Guidance for Responsible Business Conduct, ref
https://mneguidelines.oecd.org/due-diligence-guidance-for-responsible-business-conduct.htm
1
5
2
4 3
EMBED
RESPONSIBLE
BUSINESS CONDUCT
INTO POLICIES &
MANAGEMENT
SYSTEMS
COMMUNICATE
HOW IMPACTS ARE
ADDRESSED
TRACK
IMPLEMENTATION
AND RESULT
IDENTIFY & ASSESS
ADVERSE IPACTS
IN OPERATIONS, SUPPLY CHAINS
& BUSINESS RELATIONSHIPS
CASE, PREVENT OR MITIGATE
ADVERTISE IMPACTS
PROVIDE FOR OR
COOPERATE
IN REMEDIATION
WHEM APPROPRIATE
6
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The Risk Management framework defines ten risk areas under which risks are identified. Management of
risk is vital to ensure that potential threats to LINK’s objectives are identified and managed. Successful
implementation of LINK’s business strategy and effective management of growth relies on management
of potential risks affecting LINK’s objectives.
Key steps in the Risk Management Process
Definition of objectives and risk profile
Clear objectives and a defined risk profile are an essential basis for the risk management process.
Annual assessment of objectives is therefore performed to ensure alignment with the risk management
process. Objectives in LINK are set out based on LINK’s Strategy and market situation. In addition,
LINK’s Material Topics, as defined in the annual Materiality Assessment, constitute objectives for LINK.
Objectives considered by the CEO, CFO, or the board of directors as highly significant in the current
situation are defined as main objectives with a specific focus.
The Board of Directors in LINK Mobility further define the risk profile for LINK Mobility, to ensure
acceptable risk levels.
Risk identification and assessment
The identification and assessment of risks and opportunities are performed separately for each risk
area and aggregated to a group-wide overview for review by management.
Assessment is performed by considering Probability and Consequence for each risk over four defined
levels, and calculating the final level of risk as High, Medium, or Low.
Risk Management
Specification of management for each identified risk is performed in alignment with the risk profile set
for each risk area. The goal is to reduce exposure to an acceptable level. Management type is chosen
for each risk or opportunity based on risk profile, risk level, and risk focus.
Management types for risks in LINK 2025 are to Avoid, Mitigate, Transfer and Accept. Management
types for opportunities in LINK 2025 are to Avoid, Increase, Pursue and Accept.
Measures for managing risks and opportunities are defined and followed up for all risk areas annually.
Risk reporting and aggregation
The risk and mitigation actions are defined per risk area and reported to a centralized function for
aggregation and creation of a group-wide risk picture.
The aggregated risk picture is prepared annually and presented to management in LINK Mobility.
The Audit Committee in LINK Mobility is presented with status of the risk management process
throughout the year, and the board is provided with annual overview of the risk picture.
The section below describes the ten risk areas and provides a general overview of risks and management
for each of the areas.
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Commercial Risk
LINK risks related to its products, customers, and competition, here under loss of contracts and
opportunities, are managed under the headline of commercial risk. Risks under the area of Commercial
Risk are mainly inward facing (Financial Materiality).
LINK’s revenue, costs, and profits are subject to the risk of changes in customer requirements, prices
from Operators and OTT providers, changes in technology, competitor products and market expectations,
and LINK’s ability to adapt to market changes following technology, climate or other factors. Certain
simple use cases like One-Time Passwords (OTPs) or Two-Factor Authentication (2FA), wholesale SMS
trading, and basic mobile payment services are exposed to margin pressure, and therefore particularly
vulnerable.
The timeline to reach critical mass is uncertain and a risk for growth in the CPaaS industry. LINK,
however, believes its channel-agnostic approach limits this risk as the company is versatile to adapt to
channels and solutions as they mature and gain traction in the market.
Financial market risk
LINK’s business activities expose the group to financial market risks related to equity, interest rates,
currency, tax, liquidity, and changes in cost. Cost is mainly related to prices set by Mobile Network
Operators and OTT channels. Overall, these risks are regarded as low and manageable.
As a leading provider, LINK has the leverage to obtain competitive SMS pricing from Mobile Network
Operators (MNOs) and provide high quality deliverability for its customers as a trusted MNO partner.
Over time the growth in new OTT channels competing with MNOs could be beneficial for channel
agnostic CPaaS companies in terms of leverage on pricing from channel owners.
The group undertakes business in foreign currencies and is consequently exposed to fluctuations
in exchange rates. Foreign exchange risk arises from transactions related to operations conducted,
and assets and liabilities arising in foreign currencies. LINK’s subsidiaries operate using their local
currencies with revenue and costs for transactions usually conducted in the same currency. This natural
hedge reduces the currency risk and protects margins. There is, however, a translation effect to LINK’s
reporting currency (NOK) as changes in NOK to underlying currencies will impact reported figures.
In June 2025, LINK refinanced the remainder of its outstanding LINK01 bond and changed the maturity
profile of its debt to EUR 125 million (LINK02) maturing October 2029 and EUR 100 million (LINK03)
maturing June 2030. The bond issuance in June 2025 was placed at an interest spread of 275bps and
had high investor interest, demonstrating LINK’s ability to manage its debt maturity either through cash
pay-down or partial or full refinancing ahead of maturity. The EUR bond exposes LINK to additional
exchange rate risk. This currency risk is, however, mitigated by LINK’s significant cash flow exposure
to EUR. Through its operations, LINK expects to continue to generate free cash flows which will further
improve its financing capacity. LINK has a financial policy to maintain net debt in the 2 - 2.5x adjusted
EBITDA range, well below the current incurrence test level of 3.5x adjusted EBITDA.
LINK’s credit risk is limited to trade and other receivables and mitigated by the group's guidelines to
ensure that credit sales are only made to customers with a sufficient credit rating. Customers with a low
credit rating are required to prepay for services rendered by the group.
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LINK considers its liquidity risk to be limited and has more than sufficient liquidity available on bank
accounts to fund its operations and strategy for growth. LINK has established efficient routines to
monitor and handle overdue trade receivables across its footprint. Losses in 2025 are slightly lower
compared to the previous year and were mainly driven by isolated cases.
LINK manages financial market risk with an emphasis to minimize its exposure and holds no financial
assets or liabilities for speculative purposes.
Acquisition risk
Acquisition risk refers to the risks related to not achieving the planned value creation from performed
acquisitions. Risk of insufficient value creation may come from elements in the acquisition process
itself, meaning the time leading up to closing date. Risk may also come from elements in the integration
of the acquired company, meaning the time after closing. Risks under the area are mainly inward facing
(Financial Materiality).
Management of risks involves successful purchase of suitable companies at sound multiples and well-
managed integrations to realize synergies and scale advantages. Failure to realize synergies or winner’s
curse through overpayment for acquired companies may lead to significant value destruction. The
results of the prior year’s acquisitions confirm that LINK has such expertise.
The board has established routines and procedures regarding possible takeovers. This procedure does
not include any content regarding countermeasures like poison pills or other defense measures to
hinder a possible takeover of the group.
IT risk
IT risk includes risks of higher cost, lower profitability or loss due to issues related to LINK’s architecture,
data management, software development, internal infrastructure and IT Services, and business IT and
processes. Risks under this area are mainly inward facing (Financial Materiality).
IT risk is managed by central IT functions under the authority of LINK’s Senior VP Tech. LINK’s central
IT function cooperates closely with local IT teams and defines policies and procedures for subsidiaries
to implement locally.
LINK is taking steps to enhance and increase focus on the efforts to minimize the potential loss caused
by inadequate or failed internal processes, or from external or internal incidents. Processes to manage
the causes or mitigate the impacts of risks in these areas are therefore continuously implemented.
Information security risk
Information security risk includes inward-facing risks related to potential loss, cost, and loss of income
due to the threats and vulnerabilities associated with the operation and use of information systems and
the internal and external environments in which those systems operate, hereunder cyber incidents. Non-
compliance with regulatory requirements and contractual requirements regarding Information security
will also be relevant for inward-facing risks. The introduction of new regulatory frameworks effective in
2024, such as EU NIS2, are seen as relevant on the risk area.
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Furthermore, the risk area includes outward-facing risks related to negative effects on individuals
and society following from LINK’s operation and use of information systems or non-compliance with
regulatory requirements regarding Information security.
Information security risk 2024 was managed by a centralized function under the authority of the
CEO. Starting 2025, a CISO has been appointed under the same authority. LINK’s Information Security
Policy, available on LINK Mobility homepage, is revised annually, and since 2023, has been aligned
with the EU NIS2 directive and the IEC/ISO 27001:2022. Compliance with both internal LINK Mobility
Information Security Policy and external regulations is critical to maintaining the integrity and security
of LINK’s systems. LINK’s subsidiaries are subject to annual internal audits of their information security
compliance. Results of those audits are presented to the relevant stakeholders and are considered while
identifying and assessing risks for information security in LINK Mobility.
LINK’s processes are based on a top-down approach, where LINK defines policies and procedures for
subsidiaries to implement locally. The centralized Information Security function provides support and
counselling to local entities depending on requirements in the covered areas. To ensure compliance
with the LINK Mobility Information Security Policy, subsidiaries are subject to annual internal audits
where non-compliance and potential for improvement is identified. Results of audits are communicated
to the relevant stakeholders in each entity and implemented locally as part of the Information Security
process.
Legal risk
Legal risk includes inward-facing risk of financial loss, reputational damage or loss of right to operate,
incurred by unintentional or negligent failure to meet obligations in laws, regulations and commitments
that apply to LINK. Regulatory changes in several areas in recent years add to such risk. Furthermore,
the risk area may include outward-facing risks related to negative effects on individuals and society
following LINK’s failure to meet obligations.
Legal risk at LINK is managed by a group function under the authority of the CEO. LINK’s processes
are based on a top-down approach, where policies, templates and procedures are defined to the extent
possible, taking local jurisdictions into account. The group function provides support and counselling to
group management and local entities depending on requirements.
HR risk
The area includes the inward-facing risk of financial loss, inability to operate and lower profitability
incurred by lack of sufficient personnel on all levels, key competencies and industry knowledge.
LINK’s ability to operate effectively, sustain profitability, and drive growth depends on having the
right people with the right skills in the right roles. Risks such as workforce shortages, gaps in critical
competencies, and loss of industry expertise can lead to financial setbacks and operational inefficiencies.
To mitigate these risks, LINK prioritizes building a skilled, resilient organization with strong leadership
and expertise in key areas.
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Recruitment, retention, and fostering a safe, inclusive, and engaging workplace is fundamental to
our strategy, ensuring alignment from headquarters to every local subsidiary. We actively address
risks related to corporate culture, employee engagement, and talent management by continuously
strengthening our hiring, training, succession planning, and people development capabilities. A firm
commitment to diversity, equity, and inclusion further enhances our ability to attract and retain top
talent, reinforcing LINK’s long-term growth and success.
ESG risk / Sustainability risk
Risks related to environmental, social, and corporate governance factors (ESG) cover risks in the market
where LINK operates (inward-facing approach / Financial Materiality), and risks related to LINK's impact
on environment and society through its operations (outward-facing approach / Impact Materiality).
ESG risks include any identified threat to LINK’s ability to reach its objectives in the ESG area. The main
objectives within the ESG area are defined annually through Materiality Assessment as described in the
Sustainability Statement. Further information about LINK’s management of ESG matters is included in
the Sustainability Statement.
Privacy risk
LINK processes different scopes of personal data as part of its business and therefore manages risks
related to the processing of such data. These risks include both inward-facing risks that may lead to
direct or indirect loss for LINK, and outward-facing risks that may cause harm to individuals. Privacy
risk management is integrated into LINK’s enterprise risk framework, where Privacy Risk is a defined
risk area subject to structured identification, assessment, and follow-up. LINK applies Privacy by Design
and Default principles across product development and operations, supported by a DPIA methodology,
privacy-engineering guidelines and mandatory assessments for initiatives likely to result in high risks to
individuals’ rights and freedoms.
Data protection and privacy risks in LINK are documented by the Data Protection Officer and managed
by LINK group departments and local units under the authority of the LINK Group CEO. LINK applies a
top-down governance model, with group-wide policies, templates and procedures forming the basis
for consistent risk identification and control across the organization. The group function performs
annual audits and provides support and counselling to group management and local entities depending
on requirements. LINK monitors compliance and risk development through recurring KPIs and
documentation processes, including reviews of processing activities, breach registers, training coverage,
and organizational changes. This ensures continuous improvement, consistent implementation of
mitigations and accountability across units.
AI technologies introduce new privacy, security, and ethical considerations, and LINK addresses these
proactively. An AI governance framework has been applied, ensuring AI use in compliance with GDPR
and the EU AI Act, including mandatory AI risk assessments for AI-related activities. Depending on the
risk level, AI initiatives may require enhanced controls or executive approval. Existing GDPR and security
processes, such as privacy-by-design practices and information security controls, form the foundation
for responsible AI deployment, enabling consistent oversight across privacy, security, and technology
domains.
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Operational risk
Operational risks include risks related to human rights, health and safety, leadership, organization,
security, and the geopolitical situation. The area thus covers organization, buildings, assets, internal
structures, and external events.
LINK is taking steps to enhance and increase focus on its efforts to minimize potential losses from
inadequate or failed internal processes or from external events. Processes to manage the causes or
mitigate the impacts of risks in these areas are implemented as necessary.
Adequate insurance on group level to mitigate risks is an important measure, and includes General and
Product liability, professional indemnity, Cyber liability, Crime insurance, Directors and Officers insurance
and Property insurance.
Increased global tensions and financial uncertainty could pose a risk to global economic growth
and indirectly impact LINK’s global operations. However, LINK benefits from a strong diversification
effect, with a broad customer base of over fifty thousand companies across numerous industries and
geographies. Given that different industries and markets are likely to be affected in different ways by
global shifts, this diversification helps mitigate overall risk exposure. While LINK may still experience
some effects, its diversified revenue streams and market presence should provide resilience against
broader economic volatility.
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Shareholders and shares
Throughout the year, the number of shares in the company increased from 298,706,464 shares to
305,900,968 shares. And the increase was related to an issuance of ordinary shares in April 2025 and
November 2025. On December 31, 2025, LINK Mobility Group Holding ASA held 13,732,431 (4.49%) of
its own shares. A LINK share represents one vote at the company’s general meeting. LINK does not
have multiple share classes. The shares are freely tradable and to the knowledge of the Board there are
no shareholders’ agreements in the company regarding the exercise of voting power or limiting trading
in the shares in general. However, in connection with company acquisitions, major shareholders and
shares issued to majority sellers can be subject to customary 12 – 18 months lockups from the time of
completion.
At year-end 2025, LINK had 9,909 shareholders, representing an increase of approximately 125%
compared to year-end 2024. The 20 largest shareholders collectively held 67.2% of the Company’s
shares. Abry Partners remained the largest shareholder with a 13.51% ownership stake, down from
28.64% at the end of 2024. The reduction reflects Abry Partners’ partial divestment in August 2025, with
the majority of the shares acquired primarily by large Norwegian institutional asset managers.
At the end of 2025, the share price of LINK Mobility Group Holding ASA closed at NOK 33.55 on the Oslo
Stock Exchange, representing an increase of 45.9% during the year. The strong share price development
was supported by the acquisition of SMSPortal, which significantly strengthens the Group’s earnings
potential.
Organization, workforce, and management
LINK’s performance is dependent on its people, leadership, and ability to execute the strategy across
markets. In 2025, the company continued to adjust its organization to support faster product and
technology development, improved commercial execution, and more efficient operations.
A key priority has been to strengthen product development and technology execution. This includes
clearer prioritization, stronger alignment between product, technology, and commercial teams, and
more focused use of development capacity. Organizational complexity has been reduced to enable
faster decision-making and a shorter time-to-market. Improving development speed and time-to-market
remains a key focus.
Commercial capabilities have also been strengthened through more structured sales development,
clearer performance expectations, and improved follow-up. Regional structures have been further
refined to increase synergies and ensure more consistent execution across markets.
These changes support a more focused, performance-driven organization with clearer ownership, faster
execution, and better coordination across functions and markets. The changes are expected to improve
productivity and support cost efficiency going forward.
At year-end 2025, LINK had more than 690 permanent employees across 20 countries.
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Gender balance improved slightly. Women represented 35% of the workforce, compared to 34.4% in
2024 and 34.1% in 2023. Diversity remains an area of focus.
The working environment is considered healthy and positive, with stable employee engagement and
collaboration across teams. Health and safety remain a priority. In 2025, no work-related accidents
resulting in personal injury or material damage were recorded.
Board statement on corporate governance
This statement forms part of the board of directors’ report and describes the foundation and principles
for LINK’s corporate governance structure.
Applicable legislation and principles
LINK is subject to Corporate Governance reporting requirements under the Norwegian Accounting
Act §2-9, EURONEXT OSLO BØRS / EURONEXT EXPAND RULE BOOK II – Issuer Rules 1. August 2025
(“RulebookII”) Chapter 4.4, and the Norwegian Code of Practice for Corporate Governance from August
25th 2025 (“NUES Code”). The regulations are openly available on www.lovdata.no, https://www.
euronext.com/en/regulation/euronext-regulated-markets, and www.nues.no, respectively.
The structure of this statement shall, as instructed in RulebookII, follow the structure of the NUES Code
and will specify under each section either how the board of LINK adheres to the NUES Code or provide
explanations in areas where it does not fully comply.
The Board has accounted for how LINK adheres to the NUES Code in this Annual report. The following
sections provide information under each of the NUES Code requirements.
1. Implementation and reporting on corporate governance
LINK believes in transparent corporate governance processes, and that good corporate governance
will strengthen confidence, and help to ensure sustainable value creation in the best interests of
shareholders, employees, and other stakeholders.
Key governing documents
LINK Mobility’s articles of association were last updated by the General Meeting on February 3rd, 2026.
The articles are available on linkmobility.com.
LINK has adopted and implemented a corporate governance policy to safeguard the interests of the
company’s shareholders, employees, customers, and other stakeholders. The policy and associated
rules and practices are intended to create increased predictability and transparency and thus reduce
uncertainty related to the business. The latest version of LINK’s Corporate Governance Policy is dated
December 9th 2025.
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Authority Policy
LINK has adopted an Authority Policy covering authority limits group-wide. The Authority policy is
revised annually and approved by the Board of Directors. The latest version of LINK’s Authority Policy is
dated December 9th 2025.
Code of Conduct and Whistleblowing channel
LINK Mobility’s Code of Conduct helps ensure that all employees carry out their activities in an ethical
manner and in accordance with current legislation and LINK standards. All employees are required to
complete a training program covering the Code of Conduct at least once per year.
All employees are encouraged to report any suspected or discovered breach with the Code of Conduct
through the Whistleblowing channel, allowing for the anonymous reporting of concerns.
Supplier Code of Conduct
The Supplier Code of Conduct provides the minimum standards applicable to all suppliers LINK has a
direct contractual relationship with.
Further information about LINK Mobility’s governance structure can be found at LINK mobility’s website
(Sustainability - Legal | LINK Mobility) and in the “Sustainability statement” in this report.
LINK Policies
LINK has developed group policies that set out mandatory requirements all LINK entities must adhere
to, for a number of areas. Hereunder sustainability, information security, diversity, fundamental human
rights, decent working conditions, anti-slavery and human trafficking, anti-corruption and anti-bribery,
antitrust, sanctions, accounting, taxation, financial reporting, Information Security and processing of
personal data.
LINK Risk Management Framework and Compliance Management System
LINK has implemented a group-wide framework for managing risk, and a group-wide compliance
management framework.
See also chapters 1.1.3 to 1.1.7 in the Sustainability Report
2. Business
The board of directors defines objectives, strategies, and risk profiles for LINK’s business by annual
approval of strategy and strategy execution, and annual approval of revised risk profile.
The Board of Directors evaluates the objectives, strategies, and risk profiles through deep dives into the
strategy and business throughout the year, to ensure that the company creates value for shareholders in
a sustainable manner. The board takes financial, social, and environmental considerations into account
when performing such deep dives.
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LINK’s Articles of Association provide a description of the business activities LINK Mobility is engaged
in, and are published in full on the company’s website (https://www.linkmobility.com/investors/
governance).
“The Company's business is to own shares in other companies, and either itself or through other
companies, develop and operate software for mobile telephone services to private and public businesses.”
See also chapters 1.1.8 to 1.1.10 in the Sustainability Report
LINK fully complies with the NUES Code.
3. Equity and dividends
LINK has a capital structure appropriate to the company’s objective, strategy, and risk profile.
LINK Mobility’s Dividend Policy is published on LINK’s homepage under corporate governance, key
documents. The most recent dividend policy is dated November 4th 2025, and is available on https://
www.linkmobility.com/investors/governance. The background for changes in Dividend Policy was
publicly disclosed in a stock exchange announcement on www.newsweb.com on November 5th.
Mandates were granted to the board of directors at General meeting to increase the company’s share
capital and to acquire treasury shares. The mandate was given for the purpose of acquisition, employee
incentives, and strengthening of equity. All mandates were given for specific purposes.
LINK fully complies with the NUES Code.
4. Equal treatment of shareholders
All LINK shareholders are treated equally. If the board of directors was to carry out an increase in
share capital and waive the pre-emption rights of existing shareholders, the reasoning would be fully
transparent and publicly disclosed in a stock exchange announcement on www.newsweb.com. Any
transactions the company carries out in its own shares will be carried out either through the stock
exchange or at prevailing stock exchange prices. In the case of limited liquidity in the company’s shares,
LINK will consider other ways to ensure equal treatment of all shareholders.
See also chapter 1.1.3 in the Sustainability Report
LINK fully complies with the NUES Code.
5. Shares and negotiability
LINK does not limit any party’s ability to own, trade, or vote for shares in the company. In the unlikely
event that this was not the case, LINK will provide an account of any restrictions on owning, trading or
voting for shares in the company.
LINK fully complies with the NUES Code.
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6. General meetings
In accordance with the Public Limited Liability Companies Act (Allmennaksjeloven), all shareholders
with shares acquired before the fifth business day ahead of the general meeting have a right to attend
the general meeting. The annual general meeting shall resolve the annual accounts and other matters
that the general meeting is required by law or the articles of association to resolve. All shareholders
are invited to the general meeting within the deadlines that follow from law and regulations, and all
documentation required for the shareholders to sufficiently prepare for the general meeting is shared in
the invitation and/or by reference to the documents publicly available at LINK’s website. Deadlines for
shareholders to give notice of their intention to attend the meeting are set as close to the date of the
meeting as possible.
Members of the board of directors attend the general meeting to the extent it is practically possible and
in accordance with the goal of minimizing travel. The CEO and the Chair of the board of directors shall
attend the general meeting, unless represented in alignment with the Public Limited Liability Companies
Act §5-5. The Chair of the nomination committee shall attend the general meeting in person or by
representative.
The general meeting elects a Chair for the general meeting and shall be able to elect an independent
Chair. Shareholders can vote on each individual matter, including on each individual candidate nominated
for election. Shareholders who cannot attend the meeting in person are given the opportunity to vote
beforehand or give proxy to do so, through a form provided with the invitation, where each individual
matter can be voted over separately.
LINK has not adopted any special procedures regarding the general meeting that deviates from provisions
applicable for Norwegian public limited liability companies that are listed on the Oslo Stock Exchange.
See also chapter 1.1.3 in the Sustainability Report
LINK fully complies with the NUES Code.
7. Nomination committee
LINK’s Articles of Association provide that LINK shall have a nomination committee comprising of two
to three members elected for two years by the general meeting of LINK, which shall be independent
of the board and executive management to ensure that all shareholders’ interests are considered. The
current members of the nomination committee were elected by the Annual General Meeting on May
27th 2025, and are Tor Malmo (Chair, independent), Oddny Svergja (member, independent) and Håvard
Nilsson (member, Representing Sundt AS, holding 4,0% of the Voting Shares at the time of voting). The
members are not part of LINK’s board or personnel.
The general meeting sets guidelines for the duties of the nomination committee, as well as its
remuneration. A code of conduct for the nomination committee was defined by Extraordinary General
Meeting in LINK on September 7th, 2020, with latest revision made by the Annual General Meeting
on May 29th, 2024. The nomination committee’s duties are to propose candidates for election to the
board, to make assessments of proposed candidates, and to propose remuneration to be paid to such
members. The justification for the committee’s proposal is provided separately.
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The nomination committee is in contact with shareholders, the board of directors and the company’s
executive personnel as part of its work on proposing candidates for election to the board.
See also chapter 1.1.3 in the Sustainability Report
LINK fully complies with the NUES Code.
8. Board of directors’ composition and independence
The composition of the board of directors shall ensure that the board can attend to the common interests
of all shareholders and meet the company’s need for expertise, capacity, and diversity.
LINK’s Articles of Association stipulated in 2025 that the company shall have a board consisting of 5 to
9 members elected by the general meeting. The Articles of Association do not include deviations from
the requirement in the Public Limited Liability Companies Act with regard to duration, so the Chair and
the board members are elected for a term of two years by the general meeting.
The composition of the board of directors shall ensure that it can operate independently of any special
interests. The majority of the shareholder-elected members of the board of directors shall thus be
independent of the company’s executive personnel and material business connections. In addition, at
least two of the members of the board must be independent of the company’s major shareholders. For
the purposes of the LINK Corporate Governance Policy, a major shareholder shall mean a shareholder
that controls 10% or more of the company’s shares or votes. Members of the board are, however,
encouraged to own shares in the company.
The board of directors does not include executive personnel.
There were 6 members on the board after the Annual General Meeting on May 27th, 2025. 3 women
and 3 men. The Chair was elected for two years in 2024, and each board member was elected for one
year in 2025.
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Name Position Served since Term expires Independence
André Christensen
Chair 2022 2027 Yes
Jens Rugseth
Board member 2005 2027 -
Robert Joseph Nicewicz Jr
Board member 2018 2027 -
Sabrina Gosman
Board member 2022 2027 -
Grethe Viksaas
Board member 2020 2027 Yes
Sara Murby Forste
Board member 2020 2027 Yes
Overview of the Board of Directors
The names and positions of the Board members through 2025 are set out in the table below.
See also chapter 1.1.3 in the Sustainability Report
LINK fully complies with the NUES Code
9. The work of the Board of directors
The Board of directors has issued instructions for its own work and the CEO’s work, the current version
is dated December 9th, 2025. The board and CEO instructions have a particular emphasis on clear
internal allocation of responsibilities and duties.
The instructions state how the board of directors and executive management handle agreements
with related parties, including whether an independent valuation must be obtained, and that any such
agreement will be presented in the annual report.
The Board of directors considers any material interests held by board members or executive personnel. If
the Chair should be personally involved in a matter, another board member would chair the consideration
of such matter. No such matters have been managed in 2025.
The Board of directors evaluates its performance and expertise annually.
The board held twenty-two (22) meetings in 2025, of which 13 had 100% attendance by board members.
The average board meeting attendance by members was 92%.
The board called one general meeting in 2025, the annual general meeting was held on May 27th.
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The Board of directors has set out three sub-committees, as described below.
The table shows the board members’ memberships in the committees per December 31st, 2025.
No. Name Position
Audit
committee
Remuneration
committee
M&A
committee
1 André Christensen
Chair Chair Chair Member
2 Jens Rugseth
Board member Member
3 Robert Joseph Nicewicz Jr
Board member Member Member
4 Sabrina Gosman
Board member
5 Grethe Viksaas
Board member Member
6 Sara Murby Forste
Board member Member
Audit committee
In accordance with the Public Limited Liability Companies Act, LINK has established an audit committee
consisting of board members who are independent of management, and who are appointed for a two-
year term.
The audit committee’s obligations are defined in instructions defined by the Board. The instructions
were updated on February 12th, 2025. The committee is a preparatory and advisory body for the Board
and support the Board in the exercise of its responsibility for financial reporting, sustainability reporting,
internal control and risk management. Furthermore, the committee is a preparatory body for the Board in
relation to LINK’s election of a statutory auditor and make recommendations to the Board in accordance
with requirements in law, regarding the appointment or removal of statutory auditor and the statutory
auditor's remuneration and other terms of engagement.
Remuneration committee
LINK has a remuneration committee that consists of Board members who are independent of
management, and who are appointed for a two-year term. The remuneration committee’s obligations
are defined in instructions defined by the board. The current version of the remuneration committee’s
instructions is from December 7th, 2022. The remuneration committee prepares remuneration
guidelines for executive personnel including the main principles for the company’s remuneration policy.
The guidelines are communicated to the AGM. The remuneration committee may liaise with external
compensation consultants. The remuneration of senior executives is currently threefold; an individual
fixed salary, variable salary elements based on a group-wide set of KPIs, and incentives linked to share
price performance.
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M&A committee
LINK has an M&A committee that consists of board members and members of the company’s
management, chairperson is the Company CEO. The M&A Committee’s obligations are defined in
instructions defined by the Board. The current version of the M&A Committee’s instructions is from
February 16th, 2021. The committee acts as a preparatory and advisory body to support the Board in the
process of mergers and acquisitions.
Directors and Officers Insurance
LINK has a Directors and Officers Liability Insurance in place. The insurance covers the members of the
Board of Directors, the CEO and group management, in addition to any employee acting in a managerial
capacity. The insurance includes all LINK’s subsidiaries, including acquisitions.
The insurance policy is issued by a reputable, specialized insurer with appropriate rating, and protects
LINK’s directors, officers and any employees that can incur personal liability from claims made against
them in respect of actual or alleged acts in their capacity as directors and officers.
See also chapters 1.1.3, 1.1.4 and 1.1.7 in the Sustainability Report
LINK fully complies with the NUES Code.
10. Risk management and internal control
LINK’s risk management and internal control activities are integrated with its corporate strategy, and
part of the business planning processes in all areas. GLT is responsible for risk management at LINK,
subject to directions and approval from the Board of directors.
Risk management is an integral part of LINK’s business, and it is therefore performed in cooperation
with operative teams in all parts of the organization. The daily management activities that form part of,
and follow, the risk management processes are held by the operative teams in LINK.
LINK’s audit committee and Board are informed on the process through the year, and the Board annually
supervises the risk management process output and approves the risk profile for each of the six risk
areas defined by LINK. LINK’s risk profile defines the level acceptable in order to reach its objectives.
The definition forms the basis for management execution, controls, and resource allocation within each
risk area.
LINK’s operative processes for risk management are based on an approach where the group organization
defines policies and procedures enabling entities to implement locally or within a specific area. Internal
controls are implemented by the functional areas, and each area provides support and information
from group level to local entities or specific areas depending on requirements. Internal annual audits
are performed for some areas. Policies are accessible to employees at the LINK Intranet, and training
is provided by area.
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For further details with regard to LINK Mobility’s Risk Management process, please refer to the section
“Management of Risks” in this Report.
See also chapter 1.1.7 in the Sustainability Report
LINK fully complies with the NUES Code.
11. Remuneration of the board of directors
The remuneration of the Board of directors reflects the Board’s responsibility, expertise, time commitment,
and the complexity of the company’s activities. The specific remuneration is listed in note 9 payroll.
The remuneration of the board members is not linked to the company’s performance, and share options
are not granted.
The Chair of the Board was in an Extraordinary General Meeting on July 12th, 2022, granted a right to
2,000,000 share options, where 1 option shall give the right to subscribe for 1 share in LINK. The share
option agreement was entered into in accordance with the decision, and the grant of shares was made
public on the Oslo Stock Exchange on September 1st, 2022.
LINK deviates from the NUES Code regarding grant of share option to Chair.
12. Salary and other remuneration for executive personnel
The Board of directors has set out guidelines for remuneration for executive personnel, that contribute
to the company’s commercial strategy, long-term interests, and financial viability.
The guidelines aim to promote alignment of interests between shareholders and executive personnel.
The current guidelines for remuneration of executive management were approved by the general
meeting on May 27th, 2025. The guidelines are published and available on LINK’s website https://www.
linkmobility.com/investors/governance Remuneration report following the guidelines is made available
on LINK’s website annually on https://www.linkmobility.com/investors/governance
LINK’s performance-related remuneration is defined annually by the Board and is subject to an absolute
limit.
LINK fully complies with the NUES Code.
13. Information and communication
The Board of directors has established guidelines for LINK’s reporting of financial and other information
based on openness and equal treatment of all stakeholders. The Board has established guidelines for
LINK’s contact with shareholders beyond general meetings, including a monthly newsletter, a dedicated
investor relations professional and management meeting in relation to quarterly reporting.
See also chapter 1.1.4 and 4.1.1 in the Sustainability Report
LINK fully complies with the NUES Code.
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14. Takeovers
The Board of directors has established guidelines for the event of a take-over bid. In the case of a bid,
the Board has an independent responsibility to ensure that shareholders are treated equally and that
business activities are not disrupted unnecessarily. If an offer were to be made for LINK’s shares, the
Board would issue a statement making a recommendation as to whether shareholders should or should
not accept the offer. The Board will ensure shareholders are given sufficient information and time to form
a view of the offer. The Board’s statement on the offer will make it clear whether the views expressed
are unanimous or specify the basis on which specific members excluded themselves. Any final decision
to go ahead with a potential offer will be made by the shareholders in Extraordinary General Meeting.
LINK fully complies with the NUES Code.
15. Auditor
The auditor submits the main features of the plan for the audit of the company to the audit committee
annually, in time for the committee to review before processing by the Board.
The auditor is invited to board meetings where the annual accounts are dealt with. At these meetings, the
auditor reports on any material changes in the company’s accounting principles and key aspects of the
audit, comment on any material estimated accounting figures, and report all material matters on which
there has been disagreement between the auditor and the executive management of the company.
The Audit Committee and the Board of directors review the company’s internal control procedures and
risk management regarding financial and sustainability reporting with the auditor annually, including
weaknesses identified by the auditor and proposals for improvement.
The Audit Committee and the Board of directors have guidelines in respect of the use of the auditor by
the company’s executive management for services other than the audit.
PWC has been the auditor of LINK since 2019. In the last decade, the group has had 2 auditors.
See also chapter 1.1.3 in the Sustainability Report
LINK fully complies with the NUES Code.
Forward looking statement
LINK’s medium-term ambition remains to deliver high single-digit gross profit growth, supported by
favorable structural market trends and a strong underlying demand for our solutions. While current
headwinds are expected to impact the start of 2026, we anticipate a gradual normalization in growth
momentum during the year, supported by continued order intake and growth in OTT messaging.
Reflecting the scalability of our platform and operating model, adjusted EBITDA is expected to grow
faster than gross profit over time.
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Capital allocation remains guided by a disciplined and value-focused approach, with accretive M&A
representing a key long-term priority while maintaining LINK’s leverage policy within a max range of
2.0–2.5x adjusted EBITDA. At present, the Board has decided to temporarily pause larger acquisitions in
new geographies and instead prioritize share buybacks, reflecting the view that this currently represents
the most attractive capital allocation opportunity.
At the same time, we will continue to pursue selective value-accretive bolt-on acquisitions that
complement our organic growth strategy and further strengthen our market position within our existing
geographic footprint. This should be viewed as a short-term prioritization rather than a change in strategic
direction, as we continuously monitor capital allocation opportunities while remaining committed to our
long-term strategy of combining organic growth with disciplined acquisitions.
The board of directors appreciates and emphasizes uncertainty in relation to assessments of expected
future development.
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Sustainability statement
Introductory note 47
1. General information 47
1.1. [ESRS 2] 47
1.1.1. [BP-1] General basis for preparation of the sustainability statements 47
1.1.2. [BP-2, MDR-P, MDR-A, MDR-M, MDR-T] Disclosures in relation to specific circumstances 50
1.1.3. [GOV-1, G1.GOV-1] The role of the administrative, management and supervisory bodies 58
1.1.4. [GOV-2] Information provided to and sustainability matters addressed by LINK’s
administrative, management and supervisory bodies
64
1.1.5. [GOV-3, E1.GOV-3] Integration of sustainability-related performance in incentive schemes 64
1.1.6. [GOV-4] Statement on due diligence 64
1.1.7. [GOV-5] Risk management and internal controls over sustainability reporting 65
1.1.8. [SBM-1] Strategy, business model and value chain 66
1.1.9. [SBM-2] Interests and views of stakeholders 79
1.1.10. [SBM-3] Material impacts, risks and opportunities and their interaction with strategy and
business model
82
1.1.11. [IRO-1, E1-E5.IRO-1] Description of the process to identify and assess material impacts,
risks and opportunities (IROs)
89
1.1.12. [IRO-2] Disclosure Requirements in ESRS covered by LINK’s sustainability statement 101
2. Environmental information 111
2.1. Disclosures pursuant to Article 8 of Regulation (EU) 2020/852 (Taxonomy Regulation) 111
2.1.1. Assessment of LINK’s compliance with the EU Taxonomy 112
2.1.2. Disclosures under EU Taxonomy 116
2.2. [ESRS E1] 121
2.2.1. [E1-1] Transition plan for climate change mitigation 121
2.2.2. [E1.SBM-3] Material impacts, risks and opportunities and their interaction with strategy
and business model
121
2.2.3. [E1-2, MDR-P] Policies related to climate change mitigation and adaptation 123
2.2.4. [E1-3, MDR-A, MDR-M, MDR-T] Actions and resources in relation to climate change
policies
124
2.2.5. [E1-4, MDR-T] Targets related to climate change mitigation and adaptation 126
2.2.6. [E1-5] Energy consumption and mix 127
2.2.7. [E1-6] Gross Scopes 1, 2, 3 and total GHG emissions 129
3. Social information 142
4. Governance information 142
4.1. [ESRS G1] 143
4.1.1. [G1-1, MDR-P, MDR-A, MDR-M, MDR-T] Business conduct policies and corporate culture 143
4.1.2. [G1-2] Management of relationships with suppliers 150
4.1.3. [G1-3] Prevention and detection of corruption and bribery 153
4.1.4. [G1-4] Incidents of corruption or bribery 155
Sustainability statement
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Sustainability statement
Introductory note
LINK is subject to social responsibility reporting requirements according to the Norwegian Accounting
Act, including its chapter 2 on the annual report, where sustainability reporting is specified in chapter 2.
The regulations are openly available on www.lovdata.no.
LINK’s sustainability statement is based on the European Sustainability Reporting Standards (ESRS), as
provided by the European Financial Reporting Advisory Group (EFRAG- see https://www.efrag.org/), and
adopted by the Commission Delegated Regulation as regards sustainability reporting standards. As far
as the structure is concerned, it follows the ESRS, and more specifically the implementation guidance
“EFRAG IG 3: List of ESRS datapoints”. The structure is in principle the same as last year.
LINK has adopted and implemented an ESG policy to safeguard the interests of the company’s
shareholders, employees, customers, and other stakeholders. The main ESG figures are also available
on the Euronext pages: https://live.euronext.com/en/product/equities/NO0010894231-XOSL/esg
1. General information
1.1. [ESRS 2]
1.1.1. [BP-1] General basis for preparation of the sustainability statements
The sustainability statement has been prepared on a consolidated basis. The scope of consolidation is
the same as for the financial statements.
LINK Mobility Group Holding ASA (the “Holding Company”) is the parent company of LINK Mobility
Group AS. LINK Mobility Group Holding ASA owns 100% of LINK Mobility Group AS, which in turn owns,
directly or indirectly, 100% of 40 LINK subsidiaries located across 14 EU countries, as well as in Norway,
the United Kingdom, Switzerland, the Republic of North Macedonia, Colombia, Mexico and South Africa
(the “Group”, the “Company”).
Comparing to the previous reporting period:
• Marketing Platform Aps and Tismi AS, located in Denmark, were merged with LINK Mobility A/S,
located in Denmark (effective January 1st 2025);
• Labyrintti International Oy, located in Finland, is under liquidation;
• Allterpay EOOD, located in Bulgaria, was liquidated;
Sustainability statement
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• Curiosity Layer - Investigacao e Comunicacao, Unipessoal, LDA, located in Portugal, was renamed to
LINK Mobility Portugal, Unipessoal LDA;
• FireTextCommunications Ltd, located in the United Kingdom, was acquired;
• The SMS Works Ltd, located in the United Kingdom, was acquired;
• LINK Mobility South Africa (PTY) Ltd was established and it’s subsidiary, SMSPortal Proprietary Ltd,
was acquired; both are located in South Africa.
No LINK entity Place of business/ country of registration
1
LINK Mobility Group Holding ASA
Oslo, Norway
2
LINK Mobility Group AS
Oslo, Norway
3
LINK Mobility AS
Oslo, Norway
4
LINK Mobility USA AS
Oslo, Norway
5
Tismi AS
Oslo, Norway
6
BK Invest GmbH
Vienna, Austria
7
LINK Mobility Austria GmbH
Graz, Austria
8
Simple SMS GmbH
Vienna, Austria
9
LINK Mobility Bulgaria EAD
Sofia, Bulgaria
10
Atenea Mobile SAS
Medellin, Antioquia, Colombia
11
Kronos Mobile SAS
Medellin, Antioquia, Colombia
12
LINK Mobility Holding Aps
Copenhagen, Denmark
13
LINK Mobility A/S
Copenhagen, Denmark
14
LINK Mobility Oy
Tampere, Finland
15
Labyrintti International Oy
Tampere, Finland
16
LINK Mobility SAS
Boulogne- Billancourt, France
17
LINK Mobility Holding SAS
Boulogne- Billancourt, France
18
LINK Mobility GmbH
Hamburg, Germany
All LINK's subsidiaries included in the consolidation, as listed in a table below, are covered by this
sustainability statement and therefore shall be exempted from the sustainability reporting pursuant to
Articles 19a(9) or 29a(8) of Directive 2013/34/EU.
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No LINK entity Place of business/ country of registration
19
GfMB Gesellschaft für Mobiles Bezahlen
Hamburg, Germany
20
LINK Mobility Hungary Kft.
Budapest, Hungary
21
LINK Mobility Italia Srl
Milan, Italy
22
Pandora Mobile Group S de R.L. de C.V.
Mexico City, Mexico
23
Tismi B.V.
Breukelen, Netherlands
24
Tismi Mobile B.V.
Breukelen, Netherlands
25
LINK Mobility Poland Sp.z.o.o.
Gliwice, Poland
26
LINK Mobility Portugal, Unipessoal LDA
Matosinhos, Portugal
27
LINK Mobility Development Center DOOEL
Kumanovo, Republic of North Macedonia
28
Tera Communications DOOEL
Skopje, Republic of North Macedonia
29
LINK Mobility SRL
Bucharest, Romania
30
Teracomm RO SRL
Bucharest, Romania
31
LINK Mobility Spain S.L.U.
Madrid, Spain
32
Net Real Solutions S.L.
Castelló, Spain
33
LINK Mobility AB
Stockholm, Sweden
34
LINK Messaging AG
Rorschach, Switzerland
35 LINK Mobility UK Ltd London, United Kingdom
36 HSL Messaging Limited Edinburgh, United Kingdom
37 Reach-Data Ltd Doncaster, United Kingdom
38 The SMS Works Ltd Bristol, United Kingdom
39 FireTextCommunications Ltd Penryn, United Kingdom
40 LINK Mobility SouthAfrica(PTY) LTD Gauteng, South Africa
41 SMSPortal ProprietaryLimited Cape Town, South Africa
The sustainability statement covers LINK’s own operations, as well as direct business relationships in
its upstream and downstream value chain where it has been indicated or when it clearly results from the
context. The value chain information has been included based on its materiality, identified in the process
described under disclosure ESRS 2 IRO-1 (chapter 1.1.11). Description of how LINK understands its
value chain is included under disclosure ESRS 2 SBM-1 (chapter 1.1.8).
No specific piece of information corresponding to intellectual property, know-how or results of innovation
has been omitted. No further omissions allowed by Member State have been used.
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1.1.2. [BP-2, MDR-P, MDR-A, MDR-M, MDR-T] Disclosures in relation to
specific circumstances
1.1.2.1. Time horizons
The sustainability statement complies with time horizons defined in ESRS 1 section 6.4:
• (a) short-term: one year (the period adopted as the reporting period in LINK’s financial statements);
• (b) medium-term: from the end of the short-term reporting period (one year) above to five years;
• (c) long-term: more than five years.
1.1.2.2. Disclosures related to metrics that include value chain data estimated using
indirect sources
The energy and GHG emissions data included in the environmental part of the statement is partly based
on indirect sources, such as emission factors. The details regarding scope, sources and accuracy of
such data, are described under disclosures E1-5 and E1-6 (chapters 2.2.6 and 2.2.7). LINK has been
working on improving the methodology of energy and GHG emissions’ data collection and relevant
calculations, and aims to continue to implement incremental improvements within this area. No other
metrics disclosed directly in this sustainability statement include value chain data estimated with the
use of indirect sources.
1.1.2.3. Disclosures related to measurement uncertainty
The energy and GHG emissions data included in the environmental part of the statement is subject to
some level of uncertainty. The details regarding scope and sources of measurement uncertainty, as well
as related assumptions, approximations and judgements, are described under disclosures E1-5 and
E1-6 (chapters 2.2.6 and 2.2.7). No other quantitative metrics or monetary amounts disclosed directly
in this sustainability statement are subject to a high level of measurement uncertainty.
1.1.2.4. Changes in the sustainability information comparing to previous reporting periods
The structure of LINK’s sustainability statement is, in principle, the same as in the previous year, with
some minor exceptions resulting from enhancing the readability of the report.
As far as the content of this sustainability statement is concerned, qualitative and quantitative changes
to the environmental part have been introduced, as described in chapters 2.1.6 and 2.2.7. No other
metric or target has been significantly redefined or replaced and no further need for revisions of figures
disclosed last year have been identified.
1.1.2.5. Errors and corrections for previous reporting periods
Compared to last year, an amendment has been made regarding reporting carbon emissions related
to data centre activity, which resulted in adjusting Scope 2 and Scope 3 data from previous year. The
details are described under disclosures E1-6 (chapter 2.2.7).
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1.1.2.6. Disclosure of other legislation or generally accepted sustainability reporting
standards and frameworks based on which information has been included in
sustainability statement
The sustainability statement covers information prescribed by the ESRS, including- in chapter 2.1- the
disclosures pursuant to Article 8 of Regulation 2020/852 of the European Parliament and the Council (EU
Taxonomy) and to the relevant Commission Delegated Regulations. No further information stemming
from other legislation or generally accepted sustainability reporting standards or frameworks have been
included. Hence, no verification by external assurance provider has been performed in order to confirm
compliance with any ISO/IEC or CEN/CEMELEC standard.
1.1.2.7. Incorporation by reference (list of DRs or DPs mandated by a DR)
No information has been incorporated by reference.
1.1.2.8. Materiality assessment of topics (among E4, S1, S2, S3, S4)
LINK has assessed certain topics included in ESRS S1 and ESRS S4 as material, which is specified in
sec. a) below. No matters covered by ESRS E4, ESRS S2, or ESRS S3 have been assessed as material.
Since LINK does not exceed on its balance sheet date the average number of 750 employees during
the financial year, it has decided to omit the information required by ESRS S1 and ESRS S4 respectively,
as allowed in the first three years of reporting by provisions of Appendix C of ESRS 1 and the relevant
Norwegian law (phase-in). Nevertheless, for each such material topic, LINK discloses below information
on relevant policies, actions, metrics and targets.
a. List of sustainability matters (among E4, S1, S2, S3, S4) assessed to be material
(phase-in)
The following sustainability matters, covered respectively by ESRS S1 and ESRS S4, have been assessed
as material:
• ESRS S1: Topic “Own workforce” – Sub-topic “Equal treatment and opportunities for all” – Sub-sub-
topic “Training and skills development”
• ESRS S4: Topic “Consumers and end users” – Sub-topic “Information-related impacts for consumers
and/or end-users” – Sub-sub-topic “Privacy”
No sustainability matters covered by ESRS E4, ESRS S2, or ESRS S3 have been assessed as material. The
results of the materiality assessment are described in detail under disclosure ESRS 2 SBM-3 (chapter
1.1.10).
b. Disclosures relevant to the material sustainability matter “Employees’ training
and skills development”
• Disclosure of how business model and strategy take account of impacts related to the
material sustainability matter (phase-in)
LINK strives to be an attractive employer that regards diversity, equity and inclusion as levers for
innovation, development and profitability. Dedicated, enthusiastic and united employees are recognized
as one of LINK’s most valuable assets, which is reflected in LINK’s strategy and business model.
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• Policies related to the material sustainability matter (phase-in)
The material sustainability matter: “Employees’ training and skills development” is managed under
LINK’s ESG policy, which includes chapters on “Engagement, training and development”. The ESG policy
is described in chapter 4.1.1.1.
• Actions, metrics and targets related to the material sustainability matter (phase-in)
All actions relevant for IROs related to each of the material matter are listed in a table included in
chapter 1.1.10.2. The main actions related to the “Employees’ training and development”-related IROs,
together with their corresponding metrics and targets, are described in a table below.
No Action Metric Target
1
Employees’ training
(general compliance,
GDPR, InfoSec)
• implemented with an
aim to raise employees’
awareness on various
compliance issues
• includes privacy (GDPR
& InfoSec) and general
compliance (covering
inter alia ESG and
whistleblowing policy,
conduct towards third
parties)
• obligatory for all
employees, repeated
annually
• has been implemented on
a rolling bases for several
years, regularly revised
Percentage of employees
to complete employees’
training
• reflects LINK’s progress
in disseminating
knowledge, raising
awareness and promoting
a variety of ESG matters
among its workforce
• calculated as a
percentage of employees
that completed the
required training in relation
to all employees (with
some exceptions e.g. long-
time absences etc.)
100% as of November 1st
each year
• monitored in an internal
electronic system on a
rolling bases
• covers all employees
group-wide (with minor
exceptions)
• related to objectives set
out in LINK’s ESG Policy,
Personal Data Protection
Policy, Information Security
Policy and Whistleblowing
Policy
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No Action Metric Target
2
myLINKjourney
• implemented with an aim
to provide a comprehensive
framework of employees’
development
• all employees are required
to complete a review once
a year
• has been implemented on
a rolling bases for several
years
Percentage of eligible
employees who had
performance review under
myLINKjourney
• reflects LINK’s progress
in ensuring development of
its workforce
• calculated as
a percentage of
employees that had
performance review
within the framework of
myLINKjourney in relation
to all eligible employees
(some exceptions refer e.g.
to long-time absences etc.)
90% as of December 31st
each year
• monitored in an internal
electronic system on a
rolling bases
• covers all employees
group-wide (with minor
exceptions)
• related to objectives set
out in LINK’s ESG Policy
The described actions have been implemented in the course of a day-to-day business. No separate
financial resources have been allocated to them. Moreover, no actions have been taken to provide for or
cooperate in or support provision of remedy, as no harmed ones by actual material impacts have been
identified.
All metrics are monitored internally. They have not been validated by an external body so far.
All targets apply to the period, for which LINK’s strategy is set, that is until 2028. The baseline is defined
to 2024. No milestones or interim targets have been set. The targets were set out based on the internal
expertise. Stakeholders were not directly involved.
Progress in implementing the actions, measured by the performance against the disclosed targets, is
presented in a table below.
No Metric
Performance against target Target
2024 2025 2028
1 Percentage of employees to
complete employees’ training
83.80% 85.13% 100%
2 Percentage of eligible employees who had
performance review under myLINKjourney
93% 100% 90%
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c. Disclosures relevant to the material sustainability matter “Consumers and end
users’ privacy”
• Disclosure of how business model and strategy take account of impacts related to the
material sustainability matter (phase-in)
LINK’s ambition is to provide to its customers state-of-the art electronic communication solutions
that enable them to reach end users globally. Ensuring adequate level of privacy with regard to the
transmitted data, including end users’ personal data, is embedded in LINK’s core values and reflected in
LINK’s strategy and business model.
• Policies related to the material sustainability matter (phase-in)
The material sustainability matter: “Consumers and end users’ privacy” is managed, at a general level,
under LINK’s ESG policy, which includes chapters on data privacy and on information security. The
ESG policy is described in chapter 4.1.1.1. Moreover, detailed notions relating to consumers and/or
end-users privacy are extensively described in LINK’s Personal Data Protection Policy and Information
Security Policy. Both policies are described below.
• Personal Data Protection Policy
1. Key contents of policy
LINK’s Personal Data Protection Policy (PDPP) aims to ensure that any information containing personal
data is processed by LINK in line with the principles expressed in the relevant laws and regulations,
including primarily the EU General Data Protection Regulation (GDPR). Such principles concern
compliance with law, reliability and transparency, purpose limitation, data minimization, regularity,
storage restriction, integrity and confidentiality, as well as accountability. Furthermore, the privacy and
security by design and default principles are taken into account. The policy regulates LINK’s governance
and conduct related to the personal data, covering description of mandates of Data Protection Officer
and Local Privacy Board, as well as matters such as how to ensure compliance with relevant laws and
protection of the rights of relevant stakeholders, security of data processing, the principles of privacy
and security by design and by default, data retention principles, issues related to breach reporting etc.
The policy is complemented with several specific policies, procedures and guidelines relevant to the
detailed topics.
2. Scope of the policy or of its exclusions
LINK’s Personal Data Protection Policy has been adopted by the Board of Directors of LINK Mobility
Group Holding ASA. The policy applies to the Holding Company as well as to all its subsidiaries. It
covers all personal data processed by LINK irrespective of whether the Company acts as a Controller
or as a Processor, and regardless if the data is processed in paper or in an electronic form. The policy
is therefore relevant to own operations of the Group, as well as- to a limited extent- its value chain. It
applies to all users who have access to personal data collected, processed or stored by LINK, regardless
of the position held and place of employment, as well as the nature of employment or cooperation with
LINK.
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3. Most senior level in organisation that is accountable for implementation of the policy
The Global Leadership Team (GLT) has overall responsibility for the implementation of the Personal
Data Protection Policy.
4. Third-party standards or initiatives that are respected through
implementation of the policy
The following documents and frameworks form basis of LINK’s Personal Data Protection Policy:
• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the
protection of natural persons with regard to the processing of personal data and on the free movement
of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);
• other relevant EU and national laws and regulations on the protection of personal data.
5. Consideration given to interests of key stakeholders in setting the policy
Key stakeholders’ interests are taken into consideration during LINK’s materiality assessment and due
diligence processes that form basis for setting out and updating all LINK’s policies.
6. How the policy is made available to stakeholders
Full version of the Personal Data Protection Policy is available to all LINK employees through an internal
system. A whistleblowing channel is available to report any suspected, potential or actual breaches.
All employees must complete a GDPR training annually. The privacy statement is publicly available on
LINK’s webpage: https://www.linkmobility.com/legal/privacy.
• Information Security Policy
1. Key contents of the policy
LINK’s Information Security (InfoSec) Policy aims to ensure the Company’s compliance with the
principles expressed in the laws and regulations relevant to the security of information, including primarily
Directive NIS2 and GDPR, as well as industry standards, best practices, and other guidelines. It sets
out rules on how to secure information and ensure that relevant systems preserve their confidentiality,
integrity, availability, and authenticity. The policy regulates LINK’s governance and conduct related to
the security of data, covering notions such as the classification of information, access control, incident
management, network security, physical and environmental security etc. It includes topics relevant to
specific LINK’s departments, as well as to third parties.
2. Scope of the policy or of its exclusions
LINK’s Information Security Policy has been adopted by the Board of Directors of LINK Mobility Group
Holding ASA. The policy applies to the Holding Company as well as to all its subsidiaries, and is relevant
to own operations of the Group, as well as- to a limited extent- its value chain. The policy aims to ensure
confidentiality, integrity, availability, and authenticity of information by providing organizational and
technical security measures to be used within LINK.
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Among others, the following topics are described:
• definition of information security and information security management systems;
• information security objectives or the framework for setting information security objectives;
• principles to guide all activities relating to information security;
• commitment to satisfy applicable requirements related to information security;
• commitment to continual improvement of the information security management system;
• assignment of responsibilities for information security management to defined roles;
• procedures for handling exemptions and exceptions.
3. Most senior level in organisation that is accountable for implementation of the policy
The Global Leadership Team (GLT) has overall responsibility for the implementation of the Information
Security Policy.
4. Third-party standards or initiatives that are respected through implementation of the policy
The following documents and frameworks form basis of LINK’s Information Security Policy:
• Directive (EU) 2022/2555 of the European Parliament and the Council of 14. December 2022 on
measures for a high common level of cybersecurity across the Union (NIS2);
• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the
protection of natural persons with regard to the processing of personal data and on the free movement
of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
• other relevant EU and national laws and regulations on the protection of personal data;
• best practices and guidelines described in ISO 27001:2022.
5. Consideration given to interests of key stakeholders in setting the policy
Key stakeholders’ interests are taken into consideration during LINK’s materiality assessment and due
diligence processes that form basis for setting out and updating all LINK’s policies.
6. How the policy is made available to stakeholders
Full version of the Information Security Policy is available to all LINK employees through an internal
system. A whistleblowing channel is available to report any suspected, potential or actual breaches. All
employees must complete an InfoSec training annually. The public version of the policy is available on
LINK’s webpage: https://www.linkmobility.com/legal/privacy/information-security.
• Actions, metrics and targets related to the material sustainability matter (phase-in)
All actions relevant for the IROs related to each of the material matter are listed in a table included in
chapter 1.1.10.2. The main actions related to the “Consumers and end users’ privacy”-related IROs,
together with their corresponding metrics and targets, are described in a table below.
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No Action Metric Target
1
GDPR audit
• internal audit conducted
annually in all LINK geographical
areas (countries) and concluded
with a set of recommendations
• implemented with an aim
to ensure that privacy and
information security matters
are adequately managed
and relevant processes are
documented
• has been conducted in all LINK
subsidiaries for several years
Percentage of LINK
geographical regions
(countries) subjected to
the internal GDPR audit
(% of total revenues)
• reflects LINK’s
progress towards
ensuring that privacy
and information security
matters are adequately
managed and relevant
processes documented
• calculated as a percent
of revenues generated
by LINK’s entities
located in geographical
regions (countries) that
have been subject to the
internal GDPR audit, in
relation to LINK’s total
revenue
100% as of December
31st each year
• monitored on annual
bases
• covers all LINK
countries
• related to certain
objectives set out in the
ESG Policy, Personal
Data Protection Policy
and InfoSec Policy
2
Appointing DPO
• implemented with an aim
to ensure that privacy and
information security matters
are adequately managed
and relevant processes are
documented
• each LINK entity, after being
fully integrated in the Group’s
operations, has a person
dedicated to handle privacy
issues- either a formal DPO
appointed in case of the GDPR
requirements, or an internal
person with in principle the
same function as the formally
appointed DPO
• has been implemented on a
rolling bases for several years
The described actions have been implemented in the course of a day-to-day business. No separate
financial resources have been allocated to them. Moreover, no actions have been taken to provide for or
cooperate in or support provision of remedy, as no harmed ones by actual material impacts have been
identified.
All metrics are monitored internally. They have not been validated by an external body so far.
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All targets apply to the period, for which LINK’s strategy is set, that is until 2028. The baseline is defined
to 2024. No milestones or interim targets have been set. The targets were set out based on the internal
expertise. Stakeholders were not directly involved.
Progress in implementing the actions, measured by the performance against the disclosed targets, is
presented in a table below.
No Metric
Performance against target Target
2024 2025 2028
1 Percentage of LINK geographical regions
(countries) subjected to the internal
GDPR audit (% of total revenues)
99.71% 98.54% 100%
1.1.3. [GOV-1, G1.GOV-1] The role of the administrative, management and
supervisory bodies
1.1.3.1. Composition and diversity of members of administrative, management and
supervisory bodies
The number of executive and non-executive members of the administrative, management and supervisory
bodies, as of December 31st 2025, their diversity and composition, is presented in tables below.
All members of the below listed administrative, management and supervisory bodies have experience
relevant to sectors, products and geographic locations of the Group. Such experience includes, among
others, several years of serving as members of the respective LINK’s bodies, or holding other functions
across the Group.
Apart from the below listed bodies, LINK ensures the operational management on the local level through
relevant bodies appointed in its subsidiaries. Such bodies report to the Group bodies, mostly to the GLT,
and have not been included separately in deliberations covered by this sustainability statement.
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Number of members of the administrative, management and supervisory bodies [Dec 31st 2025]
No.
The administrative,
management or
supervisory body
Number of
members
Executive
Non-executive
Independence
Male
Female
Representatives
of employees/
other workers
1 Board of Directors 6
6
100%
0
0%
3
50%
3
50%
3
60%
0
0%
2 Nomination Committee 3
0
0%
3
100%
3
100%
2
67%
1
33%
0
0%
3
Global Leadership Team
(GLT), including Chief
Executive Officer (CEO)
7
7
100%
0
0%
0
0%
6
86%
1
14%
0
0%
Diversity of the administrative, management and supervisory bodies
No. Index
Board
All bodies
(Board, Nomination
Committee, GLT)
Dec 31t,
2024
Dec 31st,
2025
Dec 31st,
2024
Dec 31st,
2025
1
Gender diversity ratio
[females as a percentage of total]
50% 50% 37.5 0% 31.25%
2
Percentage of independent members
[independent as a percentage
of total]
50% 50% 31.25% 37.5 0%
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No. Name Position
Executive/ Non-
executive [E/ nE]
Independence
Gender [M/F]
Audit committee
Remuneration
committee
M&A committee
1 André Christensen
Chairman of
the Board
nE M
2 Jens Rugseth(1) Board member nE M
3
Robert Joseph Nicewicz
Jr(1)
Board member nE M
4 Sabrina Gosman(1) Board member nE F
5 Grethe Viksaas Board member nE F
6 Sara Murby Forste Board member nE F
7 Tor Malmo
Chair of the
Nomination
Committee
nE M
8 Oddny Svergja
Member of the
Nomination
Committee
nE F
9 Håvard Nilsson(2)
Member of the
Nomination
Committee
nE M
10 Thomas Martin Berge
CEO / GLT
member
E M
11 Morten Løken Edvardsen GLT member E M
12 Rune Eivind Strandli(3) GLT member E M
13 Pål Marius Brun GLT member E M
14 Benoit Bole GLT member E M
15 Ina Rasmussen(4) GLT member E F
16 Eirik Pedersen(5) GLT member E M
17 Riccardo Dragoni GLT member E M
18 Arnhild Sivertsen GLT member E F
(1) until February 3rd, 2026
(2) since May 27th 2025
(3) until August 1st, 2025
(4) until October 30th, 2025
(5) since November 1st, 2025
Composition of the administrative, management and supervisory bodies
[Jan 1st– Dec 31th 2025]
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1.1.3.2. Roles and responsibilities of administrative, management and supervisory bodies
The general roles and responsibilities of the administrative, management and supervisory bodies are
as follows:
• Board of Directors – has the ultimate responsibility for the management and control of the Group and
its operations, as well as for the oversight of impacts, risks and opportunities. The Board of Directors’
responsibility is defined in the Norwegian Public Limited Liability Companies Act (Allmennaksjeloven),
chapter 6. In addition, the Norwegian Code of Practice for Corporate Governance, issued by the
Norwegian Corporate Governance Board (NUES) provides important guidelines for LINK as a
Norwegian listed company, and is implemented into LINK’s Corporate Governance. The Board of
Directors defines objectives, strategies, and risk profiles for LINK’s business through deep dives into
the strategy and business throughout the year, to ensure that the Group creates value for shareholders
in a sustainable manner. Financial, social, and environmental considerations are taken into account
when performing such deep dives. The objectives, strategies, and risk profiles are evaluated annually.
• Audit Committee – a preparatory and advisory body for the Board to support the Board in the
exercise of its responsibility for financial reporting, internal control, risk management, and choice
of the statutory auditor.
• Remuneration committee – prepares remuneration guidelines for executive personnel, including
main principles of LINK’s remuneration policy.
• M&A committee – preparatory and advisory body to support the Board in the process of mergers
and acquisitions, composed of some members of the Board of Directors and certain members
of LINK’s management.
• Nomination Committee – proposes candidates for election to the Board of Directors, makes
assessments of proposed candidates, and proposes remuneration to be paid to such members. It
is in contact with shareholders, the Board and the Group’s executive personnel as part of its work on
proposing candidates for the election to the Board.
• Chief Executive Officer – is in charge of the day-to-day management of the business and shall
follow the orders and guidelines given by the General Meeting or the Board. The CEO shall provide
necessary information and recommendations for the Board’s required deliberations and decisions,
and is responsible for carrying out and implementing the direction, goals and policies, which have
been approved and/or defined by the Board, and then reporting on operational outcomes. It is also
the responsibility of the CEO to ensure that everyone within the Group is aware of the agreed strategic
direction, goals and policies.
• Global Leadership Team – supports CEO in day-to-day management of the business and other tasks.
Responsibilities related to impacts, risks and opportunities
LINK’s ESG policy, adopted by the Board of Directors, sets out general principles regarding responsibility
for its implementation. The policy includes, inter alia, notions of materiality assessment based on
double materiality rule, as well as notions related to risk management. It specifies that the policy applies
to the holding company as well as to all subsidiaries, and that GLT has overall responsibility for its
implementation in LINK’s processes.
The ultimate responsibility for the oversight of impacts, risks and opportunities lies within the Board
of Directors, which sets out the strategic ESG principles and reviews them in case of need. The Audit
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Committee has a control function. On the operational level, all GLT members are responsible for the
management of IROs within their functional areas. Furthermore, a function dedicated to the general
oversight and support on the operational level, who reports directly to CEO, has been appointed.
The ESG Policy includes a diagram specifying the division of responsibilities regarding sustainability
issues, namely:
• non-financial reporting;
• risk management;
• materiality assessment;
• other sustainability issues.
Board of Directors
Audit Commitee
Decision making
Control
Consultation
Recommendation,
coordination,
supervision,
analyses, control
Decision making
and implementation
Decision making
and implementation
Global
Leadership Team
Legal and
Compliance
Chief Executive Officer
Senior management responsible for
vrious functional areas/regions
Principles associated with the governance of the sustainability-related IROs are covered by LINK’s
ESG policy, adopted by the Board of Directors. The policy is regularly reviewed in order to monitor its
effectiveness and to introduce updates when needed. The control and monitoring procedures include
a regular update of the Board of Directors on relevant sustainability issues, either by the CEO or by the
function dedicated to the general oversight and support of sustainability and risk-related issues. On the
operational level, the GLT members are responsible for the implementation, monitoring and control of
the ESG policy, and it is the responsibility of every LINK manager to implement the policy within their
functional area, to lead by example, and to provide guidance to employees reporting to them. They
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shall also collect ESG best practices from key stakeholders. Oversight over management-level positions
is exercised through direct meetings (including online), whereas the general reporting lines are kept.
Furthermore, anonymous whistleblowing channel enables to report any misconduct, where the cases
are handled by the Integrity Audit Committee, set out in accordance with the whistleblowing policy.
So far, LINK has set out targets related to material IROs to a limited extent. These include providing
regulatory updates on the sustainability issues and adjusting relevant internal processes accordingly,
as well as a set of targets described under minimum disclosure requirements relevant to each of the
material sustainability matters (chapters 1.1.2.8, 2.2.5, 4.1.1.2). The general oversight and progress
monitoring is exercised by the CEO, to whom a dedicated sustainability and risk-related function reports.
1.1.3.3. Sustainability-related skills and expertise
As the body responsible for defining clear objectives, strategies and risk profiles for the company’s
business activities, such that the company creates value for shareholders in a sustainable manner (Cf.
the Norwegian Code of Practice for Corporate Governance, section 2), it is the responsibility of the
Board of Directors to ensure that appropriate skills and expertise are available to oversee sustainability
matters, based on the information provided by the GLT members or other functions in accordance with
general reporting lines.
The existing compliance function, reporting directly to CEO, has been tasked with managing and
overseeing the sustainability area, hereunder development of expertise to the extent reasonable and
required. The function provides support on the sustainability area group-wide. The function has both
formal legal education and solid experience in the legal and compliance area, including, but not limited
to sustainability regulations’ compliance and risk management. The described expertise is leveraged
to LINK governing bodies by regular updates on the developments in the regulatory framework, by
providing recommendations, and by advising on various sustainability-related issues.
A person dedicated to provide support in sustainability-related issues has been part of the Company’s
workforce for several years, with a cross-functional experience and a group-level perspective. Moreover,
the function has many years of experience in the ICT sector, which LINK operates in, and hence,
demonstrates broad knowledge in the IROs specific to that sector. Both company-level and sector-
specific skills and knowledge ensure expertise relevant to LINK's specific material impacts, risks and
opportunities.
1.1.3.4. [G1.GOV-1] The role and expertise of the administrative, management and
supervisory bodies related to business conduct
The ultimate responsibility for the oversight of business conduct matters lies within the Board of
Directors, which sets out the strategic ESG principles and reviews them in case of need. Business
conduct matters are managed by the Human Resources department on a group level, supervised by one
of the GLT members, as well as by local human resources units. All members of the bodies responsible
for the business conduct matters have relevant expertise.
Sustainability statement
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1.1.4. [GOV-2] Information provided to and sustainability matters addressed
by LINK’s administrative, management and supervisory bodies
The Board of Directors is informed through the year on material sustainability issues, including
materiality assessment and due diligence results, either by the CEO or by the function dedicated to the
general oversight and support of sustainability and risk-related issues. GLT members are provided with
quarterly status. They shall also be informed on the ESG issues resulting from LINK’s own operations
and its value chain by LINK managers in their respective areas of responsibility. Information is provided
through direct meetings (including online), whereas the general reporting lines are kept.
In accordance with LINK’s ESG policy, the ESG factors shall be taken into consideration upon making
business decisions- in procurement, in daily operations and in strategic decisions. LINK managers, with
Human Resources function’s support, shall also seek to structure incentives and conduct performance
assessments accordingly.
The material impacts, risks and opportunities that were identified during 2025, with the purpose to
address them since 2025 and through 2026, are listed under disclosure ESRS 2 SBM-3 (chapter 1.1.10).
The GLT has overall responsibility to address material IROs on the operational level- each member within
their functional area. No further disaggregation of responsibility has been introduced so far.
1.1.5. [GOV-3, E1.GOV-3] Integration of sustainability-related performance in
incentive schemes
1.1.5.1. Incentive schemes and remuneration policies linked to sustainability matters
LINK has not introduced specific sustainability-related incentive schemes or remuneration policies for
members of administrative, management and supervisory bodies. The detailed datapoints included
under this disclosure requirement are therefore not material.
1.1.5.2. [E1.GOV-3] Integration of sustainability-related performance in incentive schemes-
climate-related considerations
LINK has not introduced specific climate-related incentive schemes or remuneration policies for
members of administrative, management and supervisory bodies. No GHG emission reduction targets
have been set. Hence, no remuneration is recognized as linked to climate-related considerations (0%).
1.1.6. [GOV-4] Statement on due diligence
In its ESG policy LINK has committed to conduct due diligence with regard to sustainability matters, as
required by relevant laws, guidelines and standards. In principle, LINK follows due diligence framework
proposed in the OECD Due Diligence Guidance for Responsible Business Conduct¹. The scope of such a
process reflects the double materiality principle and includes assessing LINK’s impacts on sustainability
matters, and how sustainability matters affect LINK’s development, performance and position. LINK’s
due diligence is inter-connected with both the materiality assessment process and the risk management
framework in the following way:
• the results of the materiality assessment set out basis for the reviews and updates of the sustainability
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due diligence process; at the same time, impacts, risks and opportunities identified within the due
diligence process are taken into consideration within the materiality assessment;
• deliberations derived from the risk management framework, within which LINK identifies, assesses,
manages and reports risk in a wide sense, form basis and shall be taken into consideration during the
detailed risk assessment performed within the due diligence process.
LINK’s long-term goal is that due diligence covers LINK’s own operations as well as its value chain,
including its products and services, its business relationships and its supply chain. In the first step,
LINK has introduced due diligence of its upstream value chain (supply-side). The next step shall include
LINK’s own operations. In the future, due diligence shall also cover LINK’s downstream value chain
(demand-side). LINK’s due diligence process shall include short- and long- term analyses, understood in
line with how these terms are defined for the purposes of the sustainability reporting.
The public communication on due diligence includes primarily the Norwegian Transparency Act report,
as well as the sustainability statement forming part of the annual report, as required by the CSRD. The
Transparency Act Report is available on LINK’s corporate website: https://www.linkmobility.com/legal/
sustainability/transparency-report.
The parts of the sustainability statement relevant to the core elements of LINK’s sustainability due
diligence processes are listed in a table below.
No
Core elements of the sustainability
due diligence
Paragraph in the sustainability statement
1
Embedding due diligence in
governance, strategy and business
model
• ESRS 2 GOV-2 (chapter 1.1.4)
• ESRS 2 GOV-3, E1.GOV-3 (chapter 1.1.5)
• ESRS 2 SBM-3, E1.SBM-3 (chapter 1.1.10, 2.2.2)
2
Engaging with affected stakeholders
in all key steps of the due diligence
• ESRS 2 GOV-2 (chapter 1.1.4)
• ESRS 2 SBM-2 (chapter 1.1.9)
• ESRS 2 IRO-1, E1-E5.IRO-1 (chapter 1.1.11)
• ESRS 2 MDR-P (chapters 1.1.2.8.b indent 2,
1.1.2.8.c indent 2, 4.1.1.1, 4.1.1.3.c (see also
references in 2.2.3, 4.1.2, 4.1.3, 4.1.4))
Sustainability statement
¹ OECD (2018), OECD Due Diligence Guidance for Responsible Business Conduct, OECD Publishing.
mneguidelines.oecd.org/OECD-Due-Diligence-Guidance-for-Responsible-Business-Conduct.pdf, p. 21
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No
Core elements of the sustainability
due diligence
Paragraph in the sustainability statement
3
Identifying and assessing adverse
impacts
• ESRS 2 IRO-1, E1-E5.IRO-1 (chapter 1.1.11)
• ESRS 2 SBM-3 (chapter 1.1.10), E1.SBM-3
(chapter 2.2.2)
4
Taking actions to address those
adverse impacts
• ESRS 2 MDR-A (chapters 1.1.2.8.b indent 3,
1.1.2.8.c indent 3, 2.2.4.1, 4.1.1.2.a (see also
references in 4.1.2, 4.1.3, 4.1.4))
5
Tracking the effectiveness of these
efforts and communicating
• ESRS 2 MDR-M (chapters 1.1.2.8.b indent 4,
1.1.2.8.c indent 4, 2.2.5.1.a, 4.1.1.2.b (see also
references in 4.1.2, 4.1.3, 4.1.4))
• ESRS 2 MDR-T (chapters 1.1.2.8.b indent 5,
1.1.2.8.c indent 5, 1.1.2.8.c indent 5, 2.2.5.1.b,
4.1.1.2.c (see also references in 4.1.2, 4.1.3, 4.1.4))
1.1.7. [GOV-5] Risk management and internal controls over sustainability
reporting
Within its risk management framework LINK has defined 10 risk areas: commercial risk, financial
market risk, acquisition risk, IT risk, information security risk, legal risk, HR risk, ESG/ sustainability
risk, privacy risk and operational risk. Risk related to the sustainability reporting is managed within the
ESG/sustainability risk area. Identification and assessment of risk is performed regularly, within the
framework and schedule applied group-wide. The division of responsibilities is presented in the diagram
included in chapter 1.1.3.2 above.
LINK’s risk assessment processes are based on a top-down approach, where the holding company
defines policies and procedures for subsidiaries to implement locally. The group function provides
support and counselling to local entities depending on the requirements in the covered areas, including
sustainability reporting. ESG/ sustainability risk is managed by a group function under the direct
authority of the CEO.
As far as the sustainability reporting is concerned, LINK has identified a high-level risk related to ensuring
compliance with laws and regulations, and financial or reputational damage that may result from non-
compliance. On a detailed level, it encompasses risk related to the completeness and consistency of
the reporting, risk associated with the accuracy of the consolidated data, especially related to data
stemming from multiple systems and sources, as well as risk resulting from potential errors in manual
data input processes.
After identifying risks related to the sustainability reporting, in order to mitigate it, LINK assigned to a
group function under the direct authority of the CEO a task to follow relevant regulatory changes and to
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disseminate necessary knowledge across the organization. Following that, in H2 2023 a project “LINK’s
road to CSRD compliance” was commenced, including people from a variety of LINK’s departments.
Various actions taken within the project in the following years resulted in preparation of the sustainability
statement compliant with CSRD, from FY 2024 onwards.
Administrative, management and supervisory bodies are regularly informed about the sustainability
issues, including sustainability reporting, by a group function under the direct authority of the CEO. Such
an information is provided through regular formal and informal meetings.
1.1.8. [SBM-1] Strategy, business model and value chain[EJ1.1][BN1.2]
1.1.8.1. Key elements of general strategy that relate to or affect sustainability matters
The below presented disclosures constitute information about key elements of LINK’s general strategy
that relate to or affect sustainability matters.
a. Significant groups of products and (or) services offered
LINK is part of a broadly understood information and telecommunications (ICT) industry, and more
specifically a digital messaging industry. Services rendered by LINK are split into the following groups
(also referred to as business lines):
• mobile messaging transactions;
• payment services;
• licences;
• consulting services.
LINK recognizes one of the above groups of products (services) as significant:
• “Mobile messaging transactions” – the group is recognized as significant based on the fact that in
2025 it accounted for 95.6% of LINK’s revenue (which is more than the 10% required by ESRS 2 SBM
1 AR 13 (a)); it is also connected with material impacts, related mostly to material topics of “Climate
change mitigation”, “Energy”, “Management of relationships with suppliers”, as well as “Consumers’
and end-users’ privacy” (ESRS 2 SBM 1 AR 13 (b)).
Significant products’ group “Mobile messaging transactions” covers a variety of electronic
communication services provided via telecom networks, including channels such as SMS, MMS, VoIP
or rich communication services (RCS), as well as communication services provided by OTT channels
like WhatsApp, Facebook Messenger, WeChat, Viber and others. While rendering mobile messaging
services, LINK usually acts as an aggregator that connects private (business) and public customers with
operators (carriers), RCS providers, over-the-top (OTT) providers or others. In certain cases LINK may
act as a mobile network operator (MNO), mobile virtual network operator (MVNO), or provide its services
in several other roles. To certain extent, the significant product group also covers provision of access
to LINK’s platforms and other software solutions. Such solutions include chatbots, conversational
services, notifications, marketing automation and others.
Sustainability statement
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LINK’s product portfolio, focused on the significant group of products described above, has been
transitioning from basic one-way A2P messaging to conversational CPaaS solutions. The shift
towards conversational interfaces is primarily based on utilization of more advanced messaging
channels and implementation of state-of-the art software solutions. LINK strives to create products
that allow customers to choose their preferred communication with end users. LINK’s product portfolio
continued to evolve during 2025, supporting customers in delivering efficient, scalable, and data-driven
communication. LINK remains focused on strengthening platform capabilities, expanding automation
and AI functionality, and supporting customers in managing increasingly complex omnichannel
engagement needs.
No major changes to the significant group of products offered in 2025 in comparison with the previous
reporting period are recognized.
b. Significant markets and (or) customer groups served
LINK Mobility Group Holding ASA is based in Oslo, Norway, and operates through its subsidiaries
located in 14 EU countries, Norway, the United Kingdom, Switzerland, the Republic of North Macedonia,
Colombia, Mexico and South Africa.
In 2025 LINK has identified five operating segments, which can be differentiated based on market
maturity and product development, as well as on geography (comparing to the previous reporting period,
South Africa segment has been added):
• Northern Europe is comprised of enterprise traffic in Denmark, Finland, Norway and Sweden;
• Central Europe is comprised of enterprise traffic in Austria, Bulgaria, Germany, Hungary, North
Macedonia, Italy, Poland and Romania;
• Western Europe is comprised of enterprise traffic in France, Portugal, Spain (including subsidiaries in
Columbia and Mexico), and the United Kingdom;
• Rest of the World is comprised of enterprise traffic in South Africa and it’s international business;
• Global Messaging is comprised of non-enterprise traffic and is representative of either stand-alone
business or as a component of revenues in countries included above; if a business is comprised
of both enterprise and wholesale/aggregator transactions, the latter is segregated here; the Swiss
operation Horisen Messaging is included here. The segment also includes Tismi and certain global
customers.
For the purposes of this statement LINK defines “market” as an area and/or a sector where it belongs,
which should not be automatically regarded as equal to a notion of a “relevant market” as understood
e.g. under the competition law. On a general level, LINK is part of the information and telecommunication
(ICT) industry and provides services with a global reach. LINK determines that the operating segments
described above represent market “clusters” and therefore may constitute basis for identifying
significant markets on a more specific level. As of December 31st 2025, LINK recognizes four of the
above operating segments as significant:
• Northern Europe is recognized as significant based on the fact that in 2025 it accounted for 22.60 %
of LINK’s revenue (which is more than the 10% required by ESRS 2 SBM 1 AR 13 (a));
• Central Europe is recognized as significant based on the fact that in 2025 it accounted for 29.20 % of
LINK’s revenue (which is more than the 10% required by ESRS 2 SBM 1 AR 13 (a));
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• Western Europe is recognized as significant based on the fact that in 2025 it accounted for 23.77 %
of LINK’s revenue (which is more than the 10% required by ESRS 2 SBM 1 AR 13 (a));
• Global Messaging is recognized as significant based on the fact that in 2025 it accounted for 22.97
% of LINK’s revenue (which is more than the 10% required by ESRS 2 SBM 1 AR 13 (a)).
The significant markets are identified based on two criterions: (1) the geographical location and (2) the
group of customers served/ type of products delivered.
• Geographical markets: LINK provides services with a global reach, operating through entities located
in 21 countries. The European market, including Northern, Central and Western Europe, together
with Global Messaging that is also based in Europe- as described above- accounted for 98.54
% of LINK’s revenue in 2025. The Rest of the World accounted for only 1.46 % of LINK’s revenue
in 2025, as the acquisition of the South African subsidiaries was closed on November 20, 2025.
LINK aims to reach beyond markets where it has its offices, by offering global connectivity through
local MNOs and other entities, and by ensuring that its customers get communication solutions with
a worldwide range. Moreover, with the Global Sales Team, LINK targets to gain traction on global
clients and to benefit from the increased usage of mobile messaging solutions globally.
• Product markets: LINK provides one significant group of products, namely messaging services
(“Mobile messaging transactions”), to private (business) and public customers. Two significant
markets are identified based on the group of customers served/ type of products delivered:
• Enterprise market includes business where LINK renders services to private (business) and
public customers other than LINK’s competitors from the electronic communication industry;
LINK’s role is to provide communication services via telecom networks or OTT channels and/or
to provide access to LINK’s platforms and other software solutions; within the described market
LINK acts as a quasi intermediary between MNOs and LINK’s customers, enabling the customers
to effectively communicate with end-users;
• Non-enterprise (wholesale/ aggregator) market includes business where services are provided
by LINK to entities active in the electronic communications industry- in fact LINK’s competitors-
with the purpose of ensuring connections with MNOs, mainly in locations where such entities do
not have connections themselves.
The major change to the markets identified in 2025, in comparison with the previous reporting period,
includes identification of the “Rest of the World” market, which results from the acquisition of the South
African entity (this market, however, shall in 2025 be considered insignificant). Other adjustments
include composition of “Central Europe”, “Western Europe”, and ”Global Messaging” markets, which
result from organisational changes, and follow updates in segment reporting made for the needs of the
financial reporting.
In 2025 LINK has served more than 65 000 customers globally, meeting needs of both private (business)
and public sectors, including public entities, large corporations, as well as small and medium-sized
enterprises.
LINK does not disaggregate the Group’s revenues depending on the specific customers’ group. It
therefore recognizes one significant customer group:
Sustainability statement
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• Private (business) and public customers, including:
• large corporations and multinationals, which are handled by the Global Sales Team, typically
offering LINK’s solutions for a worldwide deployment;
• large and medium enterprises as well as public entities, which are served locally by dedicated sales
teams situated across multiple offices, sometimes through various partnership programmes;
• smaller enterprises or SMEs, which are targeted through Self-Sign Up (SSU) portals, with top-
three including brands such as SMSAPI, Spot-Hit and WebSMS.
LINK recognizes no major changes to the significant groups of customers served in 2025 in comparison
with the previous reporting period.
c. Headcount of employees
The number of LINK’s employees (headcount) as of December 31st, 2025, disaggregated according to
gender and to the geographical areas, is presented in a table below. The headcount includes persons
with the employment contracts. It does not cover neither consultants nor self-employed.
No Country Female Male Other Total number of employees
1 Austria 15 17 0 32
2 Bulgaria 33 50 0 83
3 Colombia 2 4 0 6
4 Denmark 8 17 0 25
5 Finland 4 8 0 12
6 France 28 49 0 77
7 Germany 11 15 0 26
8 Hungary 0 4 0 4
9 Italy 16 27 0 43
10 Mexico 0 0 0 0
11 Netherlands 1 7 0 8
12 North Macedonia 11 23 0 34
13 Norway 31 69 0 100
14 Poland 27 48 0 75
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No Country Female Male Other Total number of employees
15 Portugal 1 4 0 5
16 Romania 2 3 0 5
17 South Africa 8 22 0 30
18 Spain 25 44 0 69
19 Sweden 8 24 0 32
20 Switzerland 2 0 0 2
21 United Kingdom 12 19 0 31
Total 245 454 0 0
[%] 35% 65% 0 100%
d. Description of products and services that are banned in certain markets
Within LINK’s product portfolio, no products or services have been recognized that are banned in the
markets the Group operates on.
e. Total revenue and revenue by ESRS Sectors
LINK’s total revenue, as well as its disaggregation by operating segments and business lines, and the
preliminary proposal of its relation to the ESRS sectors², is presented in the tables below. Beyond these
sectors, no additional significant ESRS sectors have been identified, in which LINK develops significant
activities or in which LINK is or may be connected to material impacts (datapoint subject to phase-in).
No
Operating
segment (ISRS 8) Revenue 2025
ESRS sector group
(initial proposal)
ESRS sector
(initial proposal)
1 Northern Europe 1 600 710
Technology
Media and
Communication
(TMC)
/
Information
technology (TIT)
2 Central Europe 2 068 127
3 Western Europe 1 683 747
4 Rest of the World 103 546
5 Global messaging 1 626 960
Total [NOK 1000] 7 083 091
²In accordance with a paper from EFRAG SRB meeting of 17 September 2024 “European Sustainability Reporting Standards – SEC 1. Sector
Classification, General Requirements and Disclosure – Exposure Draft”
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No
Group of products
(business line)
Revenue 2025
ESRS sector group
(initial proposal)
ESRS sector
(initial proposal)
1
Mobile messaging
transactions
6 769 865
Technology
Media and
Communication
(TMC)
/
Information
technology (TIT)
2 Payment services 24 390
3 Licences 244 208
4
Consulting
services
44 629
Total [NOK 1000] 7 083 091
f. Statement on activity within certain sectors
LINK is not active in fossil fuel (coal, oil and gas), chemicals production, controversial weapons, or
cultivation and production of tobacco sectors. Hence, LINK generates no revenue from this sectors
(neither from coal, oil, gas, Taxonomy-aligned economic activities related to fossil gas, nor from
chemicals production, controversial weapons, or cultivation and production of tobacco).
g. Sustainability-related goals in terms of significant groups of products and
services, customer categories, geographical areas and relationships with
stakeholders
The 17 Sustainable Development Goals (SDGs)³, developed within the United Nations, are recognized
in LINK’s ESG policy as a general guide on its road to the responsible business conduct and sustainable
value creation. LINK has identified certain SDGs as the most relevant to its own operations and to
its value chain. All of them are found to be to a certain degree relevant to LINK’s significant group of
products, four significant markets, and the significant group of customers as described above, as well
as to a variety of stakeholders within LINK’s value chain. More specific objectives are distinguished
based on various environmental, social and governance factors and are included in LINK’s ESG policy,
as described in chapter 4.1.1.1. Furthermore, the sustainability-related targets are described in chapters
1.1.2.8.b, 1.1.2.8.c, 2.2.5 and 4.1.1.2.
High-level sustainability-related goals relevant to LINK’s significant groups of products, geographical
markets, customers and other stakeholders include:
• SDG 5: achieve gender equality and empower all women and girls;
• SDG 7: ensure access to affordable, reliable, sustainable and modern energy for all;
• SDG 7.2: by 2030, increase substantially the share of renewable energy in the global energy mix;
• SDG 7.3: by 2030, double the global rate of improvement in energy efficiency;
• SDG 8: promote sustained, inclusive and sustainable economic growth, full and productive employment
and decent work for all;
³ https://sdgs.un.org/
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• SDG 8.2: achieve higher levels of economic productivity through diversification, technological
upgrading and innovation, including through a focus on high value added and labour-intensive
sectors;
• SDG 8.7: take immediate and effective measures to eradicate forced labour, end modern slavery
and human trafficking and secure the prohibition and elimination of the worst forms of child
labour, including recruitment and use of child soldiers, and by 2025 end child labour in all its
forms;
• SDG 8.8: protect labour rights and promote safe and secure working environments for all workers,
including migrant workers, in particular women migrants, and those in precarious employment;
• SDG 9: build resilient infrastructure, promote sustainable industrialization, and foster innovation;
• SDG 9.c: significantly increase access to information and communications technology and strive
to provide universal and affordable access to the Internet in least developed countries by 2020;
• SDG 13: take urgent action to combat climate change and its impacts;
• SDG 16: promote peaceful and inclusive societies for sustainable development, provide access to
justice for all and build effective, accountable and inclusive institutions at all levels;
• SDG 16.5: substantially reduce corruption and bribery in all their forms;
• SDG 16.10: ensure public access to information and protect fundamental freedoms, in accordance
with national legislation and international agreements.
Apart from the SDGs listed above, LINK aims to adhere to the Ten Principles of the United Nations
Global Compact. LINK Mobility Group Holding ASA joined the UN Global Compact in 2021 as part of an
increased focus on sustainability. It annually provides the “Communication on Progress” which reflects
the development in the implementation of the Ten Principles within LINK’s operations and value chain.
The report is available on the UN Global Compact homepage: https://unglobalcompact.org/what-is-
gc/participants/145208-LINK-Mobility-Group-Holding-ASA. LINK’s commitment to adhere to the Ten
Principles is reflected in its ESG policy.
h. Assessment of current significant products and (or) services, and significant
markets and customer groups, in relation to sustainability-related goals
The assessment of the identified significant groups of products, markets and customers in relation to
the most relevant of the above specified high-level sustainability-related goals, is as follows:
• significant group of products: “Mobile messaging transactions” – most relevant SDGs:
• SDG 5: LINK aims to take ESG criterions under consideration when developing its services; the
significant group of LINK products include provision of effective electronic communication
solutions, which play an important role in the digital transformation processes and in the process
of dissemination of free and unbiased information; such processes- on a more general level- may
positively contribute to achieve gender equality;
• SDG 7: LINK is part of the global ICT sector, which is heavily dependent on the energy consumption,
but may also trigger digitalization processes that foster dissemination of the energy-efficient
solutions across multiple other sectors; as a result LINK may play a role in the global rate of
improvement in energy efficiency (SDG 7.3);
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• SDG 8: LINK strives to develop conversational CPaaS solutions, based on utilization of more
advanced messaging channels and implementation of state-of-the art software solutions;
through the development and implementation of innovative solutions, LINK contributes to the
increase in the levels of economic productivity (SDG 8.2);
• significant markets: “Northern Europe”, “Central Europe”, “Western Europe” and “Global Messaging”
– most relevant SDGs:
• SDG 7: LINK operates mostly through its European- based subsidiaries that are subject to strict
environmental legalisation aimed at promoting increase in the share of renewable energy in the
global energy mix; as a consequence, LINK may positively contribute to such an increase (SDG
7.2);
• SDG 8: LINK operates mostly through its European- based subsidiaries that are subject to strict
human rights and labour legislation, including laws on value chain due diligence; as a consequence
LINK may play a role in global efforts to eradicate forced labour, end modern slavery and human
trafficking and eliminate worst forms of child labour (SDG 8.7), as well as in global efforts to
protect labour rights and promote safe and secure working environments for all workers (SDG
8.8);
• SDG 9: by offering global connectivity through local MNOs and other entities, LINK achieves a
global reach, beyond markets where it has its offices; as a consequence, it may contribute to the
increased usage of mobile messaging solutions globally and therefore positively affect access to
information and communications technology worldwide (SDG 9.c);
• SDG 13: LINK operates mostly through its European- based subsidiaries that are subject to strict
environmental legislation aimed at taking action to combat climate change and its impacts; as a
consequence, LINK may positively contribute to such action;
• SDG 16: a global reach of LINK’s services may positively affect the dissemination of information
in a free and unbiased way; at the same time, LINK operates mostly through its European-
based subsidiaries that are subject to strict anti-corruption and anti-bribery legalisation; as a
consequence, LINK may positively contribute to reducing corruption and bribery in all their forms
(SDG 16.5);
• significant customer group: “Private (business) and public customers” – most relevant SDGs:
• SDG 16: LINK’s largest share of traffic comes from notification use cases, which are linked
to its customers’ essential activities like healthcare, utilities and critical supplies, and include
reminders, alerts, updates and mission critical communication; by serving such customers LINK
may positively contribute to ensuring public access to information and protection of fundamental
freedoms (SDG 16.10).
i. Elements of strategy that relate to or impact sustainability matters
LINK’s ambition, directly expressed in its ESG policy, is to integrate environmental, social, and governance
factors (ESG) into its strategy of offering to private businesses and public entities state-of-the-art
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communication solutions that increase customer engagement, satisfaction and loyalty, while using
sustainable and innovative technologies that support processes of digital transformation. The following
elements of strategy relate to or impact sustainability matters:
• Innovative and sustainable product portfolio.
LINK strives to develop and bring to the market innovative solutions in a responsible manner. On the one
hand, LINK aims to consider environmental factors while developing its own technology. On the other
hand, while introducing advanced communication solutions to the market, LINK takes part in triggering
digitalization processes that foster dissemination of the environment-friendly solutions across multiple
other sectors. Main challenge ahead includes developing innovative solutions that will be competitive
on the market, while embedding energy-related factors into the product development and procurement
processes.
• Responding to customers’ needs. Global reach with local markets’ adaptation.
By setting a goal to become a worldwide CPaaS provider, with a global reach and products adapted to
local markets’ requirements, LINK recognizes its role in the social and economic change that is driven
by the digital transformation. Identifying and anticipating customers’ and end-users’ needs, and creating
an offer that meets or exceeds market expectations, forms a backbone of LINK’s business strategy, and
a at the same time- one of main challenges ahead.
• Responsible business conduct.
LINK’s goal is to conduct business in a responsible manner. It expects that ESG factors are taken
into consideration upon making business decisions, both in daily operations and on a strategic level.
LINK regards diversity, equality and inclusion as levers for innovation, development and profitability.
Dedicated, enthusiastic and united employees are recognized as one of LINK’s most valuable assets.
Main projects that are relevant to this strategic element include “LINK Voice” and “myLINKjourney”.
“LINK Voice” is a platform for collecting anonymous feedback from LINK employees twice per year, to
give management and the employees themselves a tool for following the development in engagement
statistics and a variety of other topics.
“myLINKjourney” constitutes a framework for employee development, with aligned processes for annual
goal setting, annual performance reviews, and regular follow-up through the year.
1.1.8.2. List of ESRS sectors that are significant for LINK
both ESRS sectors covered by the “Technology” group, namely “Information Technology” (TIT) and
“Media and Communication” (TMC). Further explanation with regard to ESRS sector groups are included
in chapter 1.1.8.1.e.
Classification, General Requirements and Disclosure – Exposure Draft”
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1.1.8.3. Business model and value chain
a. Inputs and approach to gathering, developing and securing inputs
Main input factors that are required for LINK’s delivery of services include:
• skilled workforce, which is reflected in LINK’s approach to create an attractive workplace;
• connectivity, which is secured by contracts with electronic communication sector entities around
the world, such as mobile operators, aggregators, OTT providers etc.; additionally, in several markets
LINK is registered as an electronic communication sector provider, sometimes including a status of
MNO/MVNO;
• data storage solutions that are ensured by contracts with hosting, server & storage solutions’
providers, and- to a very limited extent- by LINK’s own data storage units;
• software solutions that are developed internally or secured through contracts with external developers
and providers of a standardized or customized software, using a variety of licensing models.
b. Outputs and outcomes in terms of current and expected benefits for customers,
investors and other stakeholders
Main outputs and outcomes of LINK’s activity include delivering to its customers state-of-the-art
solutions that enable them to effectively communicate with their customers and ultimately to reach
end users worldwide by the most suitable communication channel, with the use of automation and
personalization. By implementing LINK’s solutions, private business and public entities can greatly
improve their customer satisfaction. In a wider scale, LINK products may contribute to a global digital
transformation, dissemination of innovation and technological progress. LINK is in a position to further
scale up the business and to strengthen its leading position within the CPaaS industry, with the aim of
bringing a significant value creation for the benefit of not only its customers, but also investors and
other stakeholders.
c. Main features of upstream and downstream value chain and LINK’s position in
value chain
LINK recognizes itself as a part of the global electronic communication value chain. In general, the
significant group of LINK’s products enable sending, receiving and/or circulating any electronic
message (i.e. exchanging information/ content) between LINK’s customer and an end-user, as shown
on the figure below. This is achieved either by rendering a variety of electronic communication services
via telecom networks and OTT channels, or by provisioning an access to LINK’s platforms and other
software solutions. In order to provide its services, LINK relies on electronic communication sector
providers (“telco” providers) such as mobile operators, aggregators, OTT providers etc. These are
entities that enable connectivity and the transmission of content to recipients- mostly holders of mobile
handsets. Furthermore, LINK’s services require data storage. This means that IT providers who offer
hosting, server & storage solutions are of relevance. Other providers are most notably in the IT area, but
also other sectors.
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The high-level overview of the described value chain and LINK’s position within it is presented on the
figure below.
Customers
(private/business/ &
public)
(brand/ content providers
etc.)
LINK
(electronic communication
services’ provider)
End users
(subscribers/ consumers)
„TELCO” providers
•
operators (MNO/MVNO)
•
aggregators
•
OTT vproviders
•
RCS providers
•
other telco providers
IT providers
•
hosting, server &
storage solutions’
providers
•
software solution/
development providers
Other providers
•
non-minor (finance, legal,
HR support, lessors,
electronic equipment etc.)
•
minor (office, postage,
food, events etc)
Main business actors within the relevant value chain, and their relative contribution to LINK’s performance
and position, include:
• Upstream value chain actors – suppliers and business partners, including three main groups:
• electronic communication (“telco”) providers – within the value chain of delivering a message
from a customer to an end user, LINK acts primarily as an aggregator that connects private
(business) and public customers with operators (MNO/MVNO), RCS providers, over-the-top
(OTT) providers, or other electronic communication services’ providers. In some cases, LINK
cooperates with other aggregators that directly or indirectly ensure connection to certain
operators. In certain cases LINK may also act as an operator itself. Electronic communication
sector providers, including MNOs, MVNOs, aggregators, OTT, RCS and other “telco” providers,
have therefore been identified as “suppliers”.
• IT providers – in order to be able to act effectively and to provide its services, LINK must ensure
it has access to necessary infrastructure, equipment and software. LINK therefore cooperates-
firstly- with entities that provide hosting, server and other storage solutions, making it possible
to store, secure, manage and access digital data. Secondly, LINK purchases standardized or
customized software, using a variety of licensing models- ranging from “On-Premises”, through
“IaaS”, “PaaS” to “SaaS”. Furthermore, LINK develops certain software, relying only on its own
capacities or on external providers. Hence, IT sector providers form a vital part of LINK’s value
chain as they are necessary for both enabling LINK’s delivery of services, as well as ensuring LINK’s
operational excellence in managing its own organization. IT sector entities LINK cooperates with,
that provide input factors included in LINK’s delivery of services, shall be regarded as “suppliers”,
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while the ones that do not deliver such input factors shall be regarded as “business partners”
(these may include e.g. providers of a software that is used for payroll purposes, accountancy,
office suites etc.).
• Other providers – in its daily activity, LINK cooperates with a variety of other providers, such
as property landlords, providers of electronic equipment for office use, office-related products/
services providers financial and legal advisors, HR support, postage services providers, event
organizers etc. They shall be considered as “business partners” rather than “suppliers”, as none
of these entities provide input factors necessary for LINK’s delivery of services.
The division of upstream value chain actors into “suppliers” and “business partners” is derived from
the Norwegian Transparency Act.³ “Suppliers” are understood as entities that deliver input factors
included LINK’s delivery of services, while “business partners” are entities that do not deliver such
input factors.
• Downstream value chain actors – customers and end users:
• private (business) and public customers – LINK’s customers form part of both public and private
sectors, and include public entities, large corporations, as well as small and medium-sized
enterprises;
• end users – LINK solutions typically enable its customers to communicate with their end users,
namely the recipients of a message;
• Distribution channels, including three go-to-market (GTM) approaches:
• Enterprise – large and medium enterprises as well as public clients are served by local sales
people who are able to provide superior service and value by being present, speaking the language,
and knowing LINK’s customers; global clients that typically use LINK’s solutions worldwide are
served by the Global Sales Team;
• SSU – the needs of smaller enterprises or SMEs are covered through the Self-Sign Up (SSU)
portals, where onboarding can be done in minutes with off the shelf product offerings; LINK’s top
three SSU brands are SMSAPI, Spot-Hit and WebSMS;
• Partners – the partner network, consisting of partners ranging from independent software
vendors to large-scale software integration providers, resellers, telecommunication operators
and other entities, enable to embed LINK solutions into their own product offerings and to scale
the business.
³https://lovdata.no/dokument/NLE/lov/2021-06-18-99
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1.1.9. [SBM-2] Interests and views of stakeholders
1.1.9.1. Stakeholder engagement
a. Key stakeholders
LINK has identified the following key stakeholder groups, including external and internal ones:
• Customers – the group includes private (business) and public customers (described in chapter
1.1.8.1.b);
• End users – the group includes ultimate recipients of messages transmitted through LINK’s services,
typically customers of LINK’s customers (described in chapter 1.1.8.3.c);
• Suppliers and supply-side business partners – the group includes “telco” providers, IT providers, and
other providers (described in chapter 1.1.8.3.c);
• Partners – the group includes LINK’s partner network, consisting of business entities ranging
from independent software vendors to large-scale software integration providers, resellers,
telecommunication operators and others (described in chapter 1.1.8.3.c), partners may be either
downstream or upstream value chain actors;
• Competitors – the group includes other entities present on the global CPaaS market, mainly other
aggregators, but also MNOs/ MVNOs, OTT/ RCS providers, IT solutions’ providers etc.; competitors
may in certain cases be simultaneously LINK’s customers- mostly on a wholesale/ aggregator market
(described in chapter 1.1.8.1.b);
• Public bodies – the group includes administrative bodies such as electronic communication offices,
data protection offices, business registers, tax offices etc., in countries where LINK operates;
• Investors – the group includes institutional and retail investors with ownership stakes in the company’s
stock exchange listed equity and bonds;
• Employees – the group includes LINK’s workforce.
b. Description of how stakeholder engagement is organised for different
categories of stakeholders
LINK aims to engage most of the above identified stakeholder groups. For each group, the engagement
is organised differently:
• Customers – LINK has a direct contact with its customers, either through local salesforce and
customer service people, or through the Global Salesforce Team, with an aim to collect customer
feedback in order to better understand market requirements and to be able to adjust product portfolio
accordingly;
• End users – typically LINK does not engage end users in its operations, as they are most often not
even aware of LINK’s participation in the process of message transmission; LINK however conducts
market analyses aimed at understanding the end users’ behaviour and preferences, and takes their
results into consideration in product development and offering;
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• Suppliers and supply-side business partners – LINK mostly has a direct contact with its 1st tier
suppliers and supply-side business partners, typically during contract negotiation and execution
phases; LINK is open to collect feedback it gets through this direct contacts and to adjust its
operations when relevant.
As far as the sub-suppliers are concerned, it must be noted that in case of the electronic communication
industry, identification of the “simply understood” supply chain in its entirety is not practically feasible.
Electronic communication is a highly regulated sector that enables world-wide communication via a
variety of channels. In order to ensure that systems and devices located in different countries are
able to connect and work together, electronic communication laws are based on the principles of
“interconnection” and “interoperability”. As the termination of a message is in practice controlled
by the recipient’s subscription and location, LINK has no influence on where (in which network) the
message is in fact terminated. Furthermore, all entities through which the message ultimately reaches
an end-user operate on a highly regulated electronic communication market and are therefore subject
to regulations that require each entity to fulfil certain requirements. It should therefore be expected
that such entities adhere to at least basic standards of the responsible business conduct. LINK
recognizes that, even though a variety of electronic communication sector entities (Tier 1 and further
one) form part of its supply chain, numerous factors related to these entities are imposed on LINK,
which means LINK cannot in fact contribute to them or influence them. At the same time LINK strives
to establish as many direct business relations with respected and well-recognized companies as
practically and commercially possible.
• Partners – LINK has a direct contact with its partner network through dedicated partner managers,
with an aim to collect partners’ feedback in order to better understand market requirements and to be
able to adjust product portfolio accordingly;
• Competitors – being aware of the fair competition rules embedded in the competition law, LINK is
cautious in relations with its competitors and therefore their engagement is limited; LINK however
conducts market analyses aimed at understanding the market on which it operates, and takes their
results into consideration in product development and offering;
• Public bodies – LINK aims to ensure full compliance with relevant laws and regulations and seek
relevant public authority opinion when necessary; moreover, LINK actively follows the development
of relevant laws and regulations, analyses how they can influence LINK’s operations, and includes
results of such analyses in the decision making processes on a strategic and operational level;
• Investors – LINK, in association with various investment banks, hosts quarterly result presentations
for investors; in between quarters, function dedicated to investor relations is available on a daily basis
for enquiries, and also facilitates management meetings on request;
• Employees – LINK regularly conducts a company-wide survey for all employees to express satisfaction
or areas for improvement across a spectrum of issues; “LINK Voice” is a survey to measure employee
engagement, which provides action plans for managers to improve employee engagement within
their departments.
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c. Purpose of stakeholder engagement and how its outcome is taken into account
LINK recognizes stakeholder engagement as a vital part of its corporate social responsibility (CSR) that
allows the organisation to better understand how its activity may affect people and the planet in the
short- medium- and long term, to adjust to the ever changing market requirements, and to strengthen its
market position in a responsible and sustainable manner.
Crucial element of stakeholder engagement is an ability to hear the voice of relevant stakeholder groups
and to take their opinions into consideration when making business decisions. LINK takes actions to
disseminate feedback it gets from various stakeholder groups across the organisation. Such actions
include regular group-wide meetings of all employees (“All-hands”), as well as various meetings
in smaller teams. Views of LINK stakeholders are taken into consideration in annual materiality
assessment, product development, sales and customer care activities, peoples’ management, as well
as in the strategic decision making, including M&A processes.
1.1.9.2. LINK’s understanding of interests and views of key stakeholders as they relate to
the strategy and business model
Interests and views of key stakeholders’ groups are taken into consideration when making strategic
decisions in LINK, as external and internal feedback is recognized as an important factor in identifying
impacts, risks and opportunities that are ahead of the company. Both the materiality assessment and due
diligence processes include, to a certain extent, stakeholder engagement. Details have been described
under disclosure requirements ESRS 2 GOV-4 (chapter 1.1.6) and ESRS 2 IRO-1 (chapter 1.1.11).
1.1.9.3. Amendments to strategy and (or) business model
LINK takes stakeholder voice into consideration when making business decision on both strategic and
operational level on a rolling bases. Any changes in LINK’s strategy or business model result however
from a wide variety of factors. LINK recognizes no specific amendments that address solely interests
and views of stakeholders.
At the moment LINK has no specific plans to take further steps to amend its strategy and (or) business
model to address interests and views of stakeholders. No modification of relationship with stakeholders
is therefore expected.
1.1.9.4. Description of how administrative, management and supervisory bodies are
informed about views and interests of affected stakeholders with regard to
sustainability-related impacts
LINK’s administrative, management and supervisory bodies are informed about sustainability-related
impacts, including views and interests of affected stakeholders, by relevant LINK managers responsible
for specific operational areas. Such information is provided in the framework of both formal and informal
meetings.
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1.1.10. [SBM-3] Material impacts, risks and opportunities and their interaction
with strategy and business model
1.1.10.1. Material IROs resulting from materiality assessment
During the materiality assessment process performed in 2025 the identified material IROs were limited
when relevant, and no new IROs were identified. Consequently, LINK selected as material the same 8
ESG matters as in the previous reporting period. LINK has not identified material IROs related to ESG
matters not covered by the list derived from AR.16, included in Appendix A to ESRS 2, and therefore does
not include any entity-specific disclosures in this sustainability statement. The ESG matters assessed
as material in 2025, as well as a description of IROs related to them, are listed in a table below.
No ESG matter Impact Risk/ Opportunity
1
Climate
change
mitigation
• Negative impact (actual):
LINK may contribute to
the increase in the global
carbon footprint, because
of the greater need for
infrastructure (cooling
systems, backup power
solutions), resulting from the
climate warming or extreme
weather conditions.
• Transition risk: legal and policy risk resulting from the
introduction of regulatory changes that impose strict
requirements related to reducing emissions and energy
consumption, and achieving “greener” energy mix
(identified transition event: enhanced emissions- and
energy-related regulatory obligations). It may lead to the
increased operating costs related to the necessity to
ensure compliance.
• Transition risk: technology risk resulting from the
necessity to catch up with a transition to lower-carbon,
energy efficient solutions, including the ones affecting
ICT infrastructure (identified transition event: costs of
transition to lower emissions technology). It may lead
to efficiency loses related to the implementation of
new uncertain solutions and the reduced infrastructure
redundancy.
•Transition risk: reputation risk related to the growing
awareness of climate related issues and uncertain
stakeholders’ perception of the company’s attitude to
the environmental issues (identified transition event:
negative stakeholder feedback). It may lead to the
increased operating costs related to the necessity to
ensure relevant training and marketing activities.
• Opportunity to build resilience and gain competitive
advantage by raising employees' awareness on
environmental issues.
• Opportunity to gain competitive advantage, resulting
from the reduction in the energy consumption and
carbon footprint.
2 Energy
• Negative impact (actual):
LINK may contribute to
the increase in the global
energy consumption,
because of the greater need
for infrastructure (cooling
systems, backup power
solutions), resulting from the
climate warming or extreme
weather conditions.
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No ESG matter Impact Risk/ Opportunity
3
Employees’
training
and skills
development
• Negative impact
(potential): LINK may
negatively people by
applying unfavourable HR
practices or lowering people
management standards
(such as not ensuring
the effective training and
development programs).
•Risk of productivity loses due to not sufficient training
of LINK's employees.
• Opportunity to attract skilled people and to boost
LINK's productivity by offering attractive training and
development opportunities.
4
Consumers
and end users’
privacy
• Negative impact
(potential): LINK may
negatively impact
consumers/ end-users'
privacy rights by any
irregularities concerning
the security of data within
LINK's systems or privacy
of information disseminated
via LINK’s services (such as
an unintentional disclosure
of their personal data).
• Risk of non-compliance, resulting from insufficient
protection of consumers/ end-users' privacy.
• Opportunity to gain competitive advantage by ensuring
high level of the protection of consumers/ end-users'
privacy.
5
Corporate
culture
• Negative impact: LINK
may negatively impact
the society by lowering
corporate culture standards.
• Risk of productivity loses due to poor corporate culture.
• Opportunity to ensure LINK’s smooth operation
(achieving higher level of internal integration, gaining
new customers, effectively managing the value chain)
by setting up clear corporate standards and adhering to
corporate culture.
6
Protection
of whistle-
blowers
• Negative impact: LINK may
negatively impact its internal
and external stakeholders-
and in a broader sense-
society, by neglecting the
area of whistleblowers’
protection.
• Risk of ignoring information provided by a
whistleblower, leading to a disruption in LINK’s operation,
higher costs and/or reputational damages.
• Opportunity to effectively handle information provided
by a whistleblower, leading to a prevention and/or a
detection of any irregularity, and consequently to savings
in costs and/or preserving LINK’s reputation.
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7
Management
of
relationships
with suppliers
• Negative impact: LINK may
have a negative impact on
its supply chain, and in a
broader sense- on people
and the environment, by
applying unfair or anti-
competitive practices.
• Risk of cooperation with an unreliable supplier, leading
to a potential disruption in LINK’s operation, higher costs
and/or reputational damages.
• Risk of insufficient insight into supply chain, leading to
unvoluntary relationship with unfavourable entity in the
chain.
• Opportunity to boost LINK’s reliability and productivity
by the effective supplier management.
8
Corruption
and bribery
•Negative impact: LINK
may negatively impact the
society by being involved in
an incident of corruption or
bribery.
• Risk of being involuntarily engaged in a corruption/
bribery scandal, resulting in reputational damages.
• Risk of not detecting any corruption/ bribery behaviour,
leading to higher costs and/or disruption in LINK’s
operation.
• Risk of poor incident management, leading to higher
costs and/or a disruption in LINK’s operation.
• Opportunity to gain competitive advantage by providing
compliance training to LINK’s employees.
• Opportunity to boost LINK’s reliability by effective
corruption/bribery incident management.
1.1.10.2. Interaction of material IROs with LINK’s strategy and business model
LINK’s strategy and business model are taken into account in the materiality assessment process,
during which each potentially material ESG matter is analysed and described in LINK’s specific context.
Moreover, the materiality assessment process includes involvement of certain stakeholders’ groups,
among which the Group’s senior management is represented. In case any impact is identified as
material, it therefore originates inter alia from LINK’s strategic position, and/ or is connected to LINK’s
strategy and business model. On the other hand, material IROs are taken into consideration in the annual
review and update of LINK’s policies, which ensures they are embedded in the decision making on both
strategic and operational level.
The identified current or anticipated effects of the material IROs on LINK’s business model, value chain,
strategy and decision-making, as well as steps taken to respond to them, are described in a table below.
LINK has so far assessed the financial materiality on a general level, without detailed quantitative
analysis. As a result of such a general assessment, LINK has not identified significant current financial
effects of any of the identified material risk or opportunity on the Company’s financial position, financial
performance, or cash flows, nor has it identified a need to make significant risk of material adjustment
within next annual reporting period to carrying amounts of assets and liabilities reported in the financial
statements.
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No
Impact/ Risk/
Opportunity
(IRO)
[current/ anticipated]
Effects on LINK’s busi-
ness model/ value chain/
strategy/ deci-sion-
making
Reasonably
expected
time hori-
zons
Nature of
LINK’s involve-
ment (where
IROs concen-
trated?) LINK’s response
1
IROs related to
the ESG matter
“Climate
change
mitigation”
• Need of collecting
carbon and energy
data and considering
optimization..
• Need of having business
continuity plans.
• Need of ensuring
regulatory compliance.
• Need of engaging in
relevant training and
marketing activities.
• Need of participating
in various climate-
related initiatives and
benchmarks.
• medium-
term
• long-term
• own
operations
• value chain
• LINK has included energy matters
in the ESG Policy.
• LINK has prepared the GHG
reports.
• LINK has been part of the United
Nations Global Compact (UNGC).
• LINK has submitted a
commitment letter to the Science
Based Targets Initiative (SBTi),
has been accepted, and will
work towards developing its
environmental goals within this
framework.
• LINK has included certain
environment-related topics in
employees’ training.
• LINK aims to take energy
consumption/ energy mix/ carbon
footprint into consideration in
procurement (certain IT suppliers)
and has taken first steps towards it
(Supplier Due Diligence process).
• LINK aims to take energy
consumption/ energy mix/ carbon
footprint into consideration in
own operations, including product
development and data storage/
infrastructure.
• LINK has developed business
continuity plans in certain areas.
2
IROs related to
the ESG matter
“Energy”
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No
Impact/ Risk/
Opportunity
(IRO)
[current/ anticipated]
Effects on LINK’s busi-
ness model/ value chain/
strategy/ deci-sion-
making
Reasonably
expected
time hori-
zons
Nature of
LINK’s involve-
ment (where
IROs concen-
trated?) LINK’s response
3
IROs related to
the ESG matter
“Employees’
training
and skills
development
• Need of ensuring
relevant training and
development programs for
LINK’s workforce.
• short-term
• medium-
term
• long-term
• own
operations
• LINK has included “Engagement,
training and development” matters
in the ESG Policy.
• LINK has developed and
implemented basic training
for all its employees (general
compliance, privacy, InfoSec).
• LINK has implemented phishing
training for its employees.
• LINK provides additional training
corresponding with particular
needs of its employees.
• LINK has developed and
started to implement training
and development programme
“myLINKjourney”.
4
IROs related to
the ESG matter
“Consumers
and end users’
privacy”
• Need of taking privacy
and information security
matters into consideration
in own operations.
• Need of taking privacy
and information security
matters into consideration
in procurement.
• Need to adequately
manage privacy and
information security
matters.
• Need to document
certain processes related
to privacy and information
security.
• Need of appointing Data
Protection Officer.
• short-term
• medium-
term
• long-term
• own
operations
• value chain
• LINK has included privacy and
information security matters in the
ESG Policy.
• LINK has developed the Personal
Data Protection Policy.
• LINK has developed the Infor-
mation Security Policy.
• LINK has included privacy and
information security topics in
employees’ training.
• LINK has appointed the Data Pro-
tection Officer.
• LINK takes privacy and infor-
mation security topics into con-
sideration in procurement (Sup-
plier Due Diligence process).
• LINK takes privacy and infor-
mation security topics into
con-sideration in own operations
(GDPR audits).
• LINK has developed and docu-
mented a variety of specific
pro-cesses related to adequate
man-agement of privacy and infor-
mation security issues.
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No
Impact/ Risk/
Opportunity
(IRO)
[current/ anticipated]
Effects on LINK’s busi-
ness model/ value chain/
strategy/ deci-sion-
making
Reasonably
expected
time hori-
zons
Nature of
LINK’s involve-
ment (where
IROs concen-
trated?) LINK’s response
5
IROs related to
the ESG matter
“Corporate
culture”
• Need of ensuring
relevant training and
development programs for
LINK’s workforce.
• short-term
• medium-
term
• long-term
• own
operations
• LINK has included business
culture matters in the ESG Policy.
• LINK has defined its core values
and has embedded them in its
strategy.
• LINK has introduced the
Employee’ Code of Conduct.
• LINK has conducted “LINK Voice”
survey.
• LINK has included certain ESG
topics in employees’ training.
• LINK provides training on
the “Social Styles” model to
employees and managers with
communication to a wider group.
6
IROs related to
the ESG matter
“Protection
of whistle-
blowers”
• Need to ensure adequate
policies and processes on
whistleblowing.
• short-term
• medium-
term
• long-term
• own
operations
• LINK has included whistleblowing
matters in the ESG Policy.
• LINK has developed the
Whistleblowing Policy.
• LINK has introduced adequate
whistleblowing channel.
• LINK has included whistleblowing
topics in employees’ training.
7
IROs related to
the ESG matter
“Management
of
relationships
with suppliers
• Need to adequately
manage supply chain.
• Need to document
certain processes
related to the supplier
management.
• short-term
• medium-
term
• long-term
• own
operations
• value chain
• LINK has included due diligence
matters in the ESG Policy.
• LINK has prepared its first
Transparency Act report.
• LINK has included certain
supplier-related topics in
employees’ training.
• LINK has introduced the Supplier
Code of Conduct.
• LINK has developed and
introduced the Supplier Due
Diligence process.
8
IROs related to
the ESG matter
“Corruption
and bribery”
• Need to ensure adequate
policies and processes on
anti-corruption and anti-
bribery.
• short-term
• medium-
term
• long-term
• own
operations
• value chain
• LINK has included anti-corruption
and anti-bribery matters in the ESG
Policy.
• LINK has introduced the
Employee’ Code of Conduct.
• LINK has included anti-corruption
and anti-bribery topics in
employees’ training.
• LINK has adopted a zero-
tolerance approach to corruption
and bribery.
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Adequate policies and actions taken to address material matters are described under minimum
disclosure requirements relevant for each of the material sustainability matters (chapters 1.1.2.8, 2.2.4,
4.1.1.1., 4.1.1.2, 4.1.1.3). The overview of these actions is presented in a table below.
No
Actions
addressing the identified
IROs:
Chapter
in the
report
IROs related to the following material matters:
Climate change mitigatio
Energy
Employees’ training and skills
development
Consumers and end users’ privacy
Corporate culture
Protection of whistle-blowers
Management of relationships with
suppliers
Corruption and bribery
1
Employees’ training
(general compliance,
GDPR, InfoSec)
1.1.2.8.b
2 myLINKjourney 1.1.2.8.b
3 LINK Voice 4.1.1.2
4
Promoting Employee Code
of Conduct among LINK’s
workforce
4.1.1.2
5 Whistleblowing channel 4.1.1.2
6
Promoting Supplier Code
of Conduct among LINK
stakeholders
4.1.1.2
7
Supplier Due Diligence
process
4.1.1.2
8 GDPR audit 1.1.2.8.c
9 Appointing DPO 1.1.2.8.c
10 GHG reporting 2.2.4
11
Participation in the Science
Based Targets initiative
2.2.4
related action main action addressing the IROs
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1.1.10.3. Resilience of LINK’s strategy and business model regarding capacity to address
material impacts and risks and to take advantage of material opportunities
The material IROs have been addressed by embedding them in certain internal processes, among
which the risk management framework and the Compliance Management System (CMS) are of key
importance. The risk management framework includes processes that allow to identify and assess
impacts and risks annually, to develop measures to mitigate them, and to take advantage of material
opportunities. The processes are monitored as part of the CMS and risk management framework.
Regular review is conducted and relevant administrative, management and supervisory bodies are
provided with information necessary to update LINK’s strategy and business model if needed, which
ensures adequate level of resilience regarding LINK’s capacity to address material impacts and risks,
and to take advantage of material opportunities. Further details regarding LINK’s strategy and business
model are described under disclosure SBM-1 (chapter 1.1.8). The description of climate-related scenario
and resilience analyses are described under disclosure E1.SBM-3 (chapter 2.2.2) and E1.IRO-1 (chapter
1.1.11.9). No further analysis regarding LINK’s resilience have been conducted.
1.1.11. [IRO-1, E1-E5.IRO-1] Description of the process to identify and assess
material impacts, risks and opportunities (IROs)
1.1.11.1. Methodologies and assumptions applied in process to identify IROs
LINK’s materiality assessment process follows a double materiality principle, covering both impact
and financial perspective. The top-bottom approach is applied, with an assessment performed at a
group level, while engaging internal stakeholders from all geographic regions, in which LINK operates,
as well as the ones relevant to various departments and for the Company as a whole. To a very limited
extent, external stakeholders have also been invited to take part in the process (no external responses,
however, have been obtained so far). The assessment considers all entities included in the scope of
consolidation, as well as value chain related matters. LINK recognizes that materiality assessment and
due diligence processes are inter-connected. On the one hand, the materiality of impacts, risks and
opportunities identified within the due diligence process shall be taken into consideration within the
materiality assessment. On the other hand, the results of the materiality assessment are seen as basis
for the sustainability due diligence. Since LINK operates within one sector, with a fairly homogenous
groups of significant products, markets and customers (see chapter 1.1.8), the materiality assessment
has not been disaggregated, as that was found not needed for a proper understanding of material
impacts, risks and opportunities. During the process, short-, medium- and long- term time horizons,
understood in line with how these terms are defined for the purposes of the sustainability reporting
(see chapter 1.1.2), were taken into account. The process consisted of the following phases and steps
(carried out in 2023 or 2024, and reviewed or repeated in 2025):
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Phase 1: Preliminary assessment
• Step 1: Identification of stakeholder groups – with an aim to identify affected stakeholders as well as
users of sustainability statements and other users, whose views should be taken into consideration;
• Step 2: Description of ESG matters and their context to LINK – with an aim to understand LINK’s
specific context of the topics included in the list of ESG matters derived from AR.16, included in
Appendix A to ESRS 2 (a possibility to add further matters existed during Step 6);
• Step 3: Defining a short-list of potentially material ESG matters – screening the list of ESG matters
derived from AR.16 included in Appendix A to ESRS 2 with an aim to identify ESG matters that may
potentially be material in LINK’s specific context (a possibility to add further matters existed during
Step 6).
Phase 2: Defining impacts, risk and opportunities
• Step 4: Identification and description of IROs related to the short-listed ESG matters – specifying
IROs connected with the short-listed ESG matters that may be material to LINK’s own operations and
its value chain in a short-, medium- and/or long- term, with an aim to further assess and analyse them
in subsequent steps (both actual and potential, positive and negative impacts have been considered);
identification of risks and opportunities was proceeded by deliberations on dependencies on natural
and social resources from which certain risks and opportunities may be derived.
Phase 3: Impact and financial assessment
• Step 5: Preparation of a template for collecting data from stakeholders – in 2023 stakeholders
were provided with an extensive template covering short-listed ESG matters and corresponding IROs,
together with a dedicated space for adding next entries. It was prepared as a comprehensive .xls file,
covering the short-listed materiality matters, with an embedded assessment criteria. The description
of the matters and IROs was provided, and the possibility was given to add further matters and IROs.
Stakeholders were provided with instructions on how to fill in the template, and one-to-one help was
provided when needed.
Since in 2025 the short-list of material matters with their corresponding IROs was the same as in 2023
and 2024, it was decided that a simplified survey will be conducted among stakeholders to get their
insight into any potential changes they may identify. The extent of further steps was dependent on the
results of this simplified survey. The survey was prepared in a user-friendly format. Stakeholders were
provided instructions on how to fill in the survey, and were advised to familiarize themselves with the
results of the 2023 and 2024 assessment. One-to-one help was provided when needed, in particular to
the persons that were new to the process.
• Step 6: Stakeholders’ assessment – with an aim to collect data from stakeholders, including:
• a) Initial assessment – in 2023 short-listed material matters were assessed by stakeholders by
answering the question if they are/may be important to LINK, with an aim to choose matters for
further assessment; there was a possibility to add further matters; in 2024 and 2025 the initial
assessment was provided in a user-friendly survey, as described in Step 5 above;
• b) Impact assessment – impacts related to the topics chosen during initial assessment were
assessed against the given criteria and on a provided scale; there was a possibility to add further
impacts; since initial assessment performed in 2025 showed no major changes to the previous
year, impact assessment has relied on the data collected in 2023 and 2024;
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• c) Financial assessment – risks and opportunities related to the topics chosen during initial
assessment were assessed against the given criteria and on a provided scale; there was a
possibility to add further risks and opportunities; since initial assessment performed in 2025
showed no major changes to the previous year, financial assessment has relied on the data
collected in 2023 and 2024.
Phase 4: Identifying results and their implications
• Step 7: Summary of the stakeholders’ assessment in the form of a materiality matrix – data collected
from stakeholders was extensively analysed; impact and financial materiality was calculated;
materiality matrix was prepared, which was followed by specification of qualitative and quantitative
thresholds for the identification of material matters; the results relied to a certain extent on the data
collected in 2023, the changes in the final formulation of impacts in 2024 was based on the internal
and external expertise and results from the intention to focus on the negative impacts, no major
changes were identified in 2025;
• Step 8: Identification of LINK’s material matters – the choice of material matters was made based
on the pre-defined criterions; adapted thresholds, and their critical analyses;
• Step 9: Identification of strategic implications of the materiality assessment – materiality
assessment results were included in LINK’s risk management framework and formed basis for the
process of annual review and update of LINK’s policies; initial scope of sustainability reporting was
identified and communicated to the chosen internal stakeholders (as described in chapters 1.1.7.3
and 1.1.7.4).
1.1.11.2. Process to identify, assess, prioritise and monitor potential and actual impacts on
people and environment, informed by due diligence process
Impact materiality assessment was performed as part of the above outlined materiality assessment
process, as deliberated below.
a. Description of how process focuses on specific activities, business
relationships, geographies or other factors that give rise to heightened risk of
adverse impacts
LINK’s materiality assessment included specification of a short-list of potentially material ESG matters
in step 3 of the above described process. For the short-listed matters, actual and potential impacts on
people and environment were identified during step 4. The ESG matters and corresponding impacts were
described in LINK’s specific context, which took into consideration the market, on which the company
operates, its product portfolio, and key stakeholder groups. Focus was than put on the short listed
matters and corresponding impacts, which were assessed by the involved stakeholders during step 6a-
b. Having in mind relatively homogenous nature of LINK’s operations and its position in the value chain,
as described under disclosure requirement ESRS 2 SBM 1 (chapter 1.1.8), the top-bottom approach was
applied, with no disaggregation.
b. Description of how process considers impacts with which LINK is involved
through own operations or as result of business relationships
Impact assessment process involved identification and assessment of ESG matters and corresponding
impacts in the context specific for LINK’s own operations and its position in the relevant value chain, as
described above.
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c. Description of how process includes consultation with affected stakeholders to
understand how they may be impacted and with external experts
In 2025 the same stakeholder groups have been identified as in the previous year. The stakeholder
groups include:
• internal stakeholders – the choice of internal participants took into consideration representation of
various seniority, geographical regions and functional areas;
• external stakeholders – representatives from the upstream and downstream value chain have been
invited to participate in the assessment already in 2023 and 2024, but no responses have been
obtained; to compensate on that:
• involvement of voices from a variety of internal stakeholders, including product, sales, investor
relations, data protection, information security, and other departments, representing different
seniority levels, enabled to understand and take into consideration perspectives of not only
internal, but also key external stakeholder groups;
• the desk research was carried out by the L&C team to include perspective of the external
stakeholders;
silent stakeholders – “nature” has been identified as a silent stakeholder and analysed in 2024 more
broadly than in 2023; it was further taken into consideration during climate-related scenario and
resilience analyses (see disclosure E1.SBM-3- chapter 2.2.2, and E1.IRO-1- chapter 1.1.11.9).
d. Description of how process prioritises negative impacts based on their relative
severity and likelihood and positive impacts based on their relative scale, scope
and likelihood and determines which sustainability matters are material for
reporting purposes
During step 6b of the above outlined process, stakeholders were assigned to assess against the given
criteria positive and negative impacts related to the ESG matters chosen as potentially material in step
6a. The assessment was within a range of [1] to [4] and the criteria included:
• (1) scale, (2) scope and (3) likelihood of positive impacts;
• (1) scale, (2) scope, (3) likelihood and (4) irremediable character of negative impacts.
Furthermore, (1) scale, (2) scope, (3) likelihood and (4) irremediable character of each impact was
calculated as an average note given by relevant stakeholder groups (including executives and senior
management, as well as other employees from various departments and geographical regions).
Impact materiality was calculated as an average of the notes (1), (2), (3) and (4) (for positive impacts
without (4)), and impacts were assigned with notes according to the following quantitative thresholds:
•
•
•
•
•
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The matter has been chosen as material if either its impact or financial materiality accounted to more
than 2.5. Additionally, analyses were performed in cases for which the average of impact and financial
materiality for a given matter accounted to more than 2.0, and decision was made based on qualitative
analyses if such a matter is supposed to be deemed material. The final formulation of impacts is based
on the internal and external expertise and results from the intention to focus on the negative impacts.
1.1.11.3. Process used to identify, assess, prioritise and monitor risks and opportunities
that have or may have financial effects
Financial materiality assessment was performed as part of the above outlined materiality assessment
process, as deliberated below.
a. Description of how connections of impacts and dependencies with risks and
opportunities that may arise from those impacts and dependencies have been
considered
LINK’s materiality assessment included specification of a short-list of potentially material ESG matters
in step 3 of the above described process. For the short-listed matters, LINK’s specific context was
described and impacts identified, followed by deliberations concerning dependencies on natural and
social resources, from which certain risks and opportunities may be derived. The corresponding risks
and opportunities were than identified during step 4, having in mind LINK’s context, identified impacts,
and dependencies. The ESG matters, dependencies, as well as corresponding impacts, risks and
opportunities were described in LINK’s specific context, which took into consideration the market, on
which the company operates, its product portfolio, and key stakeholder groups. Focus was than put
on the short listed matters and corresponding impacts, risks and opportunities, which were assessed
by the involved stakeholders during step 6. Having in mind relatively homogenous nature of LINK’s
operations and its position in the value chain, as described under disclosure requirement ESRS 2 SBM 1
(chapter 1.1.8), the top-bottom approach was applied, with no disaggregation.
b. Description of how likelihood, magnitude, and nature of effects of identified
risks and opportunities have been assessed
During step 6c of the above outlined process, stakeholders were assigned to assess against the given
criteria risks and opportunities related to the ESG matters chosen as potentially material in step 6a.
The assessment was within a range of [1] to [4] and the criteria included:
• (1) magnitude and (2) likelihood of risks and opportunities.
Furthermore, (1) magnitude and (2) likelihood of each risk and opportunity was calculated as an average
note given by relevant stakeholder groups (including executives and senior management, as well as other
employees from various departments and geographical regions). Financial materiality was calculated
as an average of the notes (1) and (2), and risks and opportunities were assigned notes in according to
the following quantitative thresholds:
•
•
•
•
•
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The matter has been chosen as material if either its impact or financial materiality accounted to more
than 2.5. Additionally, analyses were performed in cases for which the average of impact and financial
materiality for a given matter accounted to more than 2.0, and decision was made based on qualitative
analyses if such a matter is supposed to be deemed material.
c. Description of how sustainability-related risks relative to other types of risks
have been prioritised
Sustainability-related risks identified inter alia during the materiality assessment are included in LINK’s
general framework for risk management, mainly under the group consisting of “ESG/ sustainability risk”
(see chapter 1.1.7.1). Such risks are therefore prioritised depending on their assessment in line with
how this is done for other risk areas. Since “Climate change mitigation” was identified as a material
topic in the materiality assessment performed in 2024, the climate-related scenario and resilience
analyses followed materiality assessment (see disclosure E1-SBM-3- chapter 2.2.2, and E1.IRO-1-
chapter 1.1.11.9).
1.1.11.4. Decision-making process and related internal control procedures
The materiality assessment process is supervised by a designated function that reports to the group
CEO (see chapters 1.1.3.2, 1.1.3.3). The process is performed within the Legal & Compliance Team, with
the involvement of various stakeholders’ groups. Internal expertise is extensively utilized. The process is
inter-related with risk management framework, and its results are embedded in LINK’s policies forming
basis for decision making (see chapter 1.1.6). The materiality process is regularly reviewed.
1.1.11.5. Extent to which and how process to identify, assess and manage impacts and risks
is integrated into overall risk management process and used to evaluate overall
risk profile and risk management processes
LINK recognizes that materiality assessment process and LINK’s general framework for risk management
are inter-related (see chapter 1.1.6). On the one hand, general risks are taken into consideration when
creating a short-list of ESG matters that need materiality assessment. On the other hand, the results of
the materiality assessment are included in LINK’s risk management framework.
1.1.11.6. Extent to which and how process to identify, assess and manage opportunities is
integrated into overall management process
The results of the materiality assessment are included in LINK’s risk management framework and form
basis for the process of annual review and update of LINK’s policies (see chapter 1.1.6). Such policies
constitute than guidance in making decisions on both strategic and operational levels.
1.1.11.7. Input parameters used in process to identify, assess and manage material
impacts, risks and opportunities
CSRD and ESRS set out a general framework of LINK’s materiality assessment process and are seen
as a main input factor in designing the process. As far as the scope of topics covered is concerned, the
list of ESG matters derived from AR.16, included in Appendix A to ESRS 2, constitutes basis, with the
possibility to add further matters. Moreover, desk research is carried out based on the CSRD/ ESRS/
relevant guidelines, as well as various online sources, and internal expertise is extensively utilized.
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1.1.11.8. Description of how process to identify, assess and manage impacts, risks and
opportunities has changed compared to prior reporting period
LINK has conducted the materiality assessment for several years now, starting from a very simple
process in 2020, up to the introduction of the extensive, ESRS-compliant process in 2023.
As the non-financial reporting is performed on annual basis, the company shall revise its materiality
assessment each year. It is however allowed to use the outcomes of the prior reporting period if the
undertaking concludes that there have been no internal or external material changes that could generate
new or modify existing impacts, risks and opportunities.
Having this in mind, in 2025 LINK completed the simplified materiality assessment process, which to
a great extent uses the outcomes of the prior reporting periods, namely 2023 and 2024. During the
process, following desk research made within the Legal & Compliance Team, and a survey conducted
among various stakeholders’ groups, it has been decided that there have been no material changes that
could generate new or modify existing IROs.
1.1.11.9. [E1.IRO-1] Description of the processes to identify and assess material climate-
related IROs
Description of the process to identify and assess material IROs (materiality assessment), covering
also the ones related to climate, is included above. Following the materiality assessment, a simplified
climate-related scenario and resilience analyses were carried out in 2024 in order to understand how
LINK might perform under different hypothetical future climate states, and how its strategy resilience to
climate change might be improved. This resulted in expanding and supplementing IROs’ analyses made
during the materiality assessment. In 2025 no material changes were identified that would result in the
need to review the climate-related analyses performed in 2024.
The climate-focused analyses were aimed at better understanding how the climate-related risks and
opportunities might plausibly develop in the future and how they may impact LINK in short-, medium-
and long- term horizons. It must be noted that 2024 was the first year when such scenario analyses
were carried out, which resulted in their limited scope and only qualitative nature. The process took into
consideration recommendations and guidelines developed by the Task Force for Climate Disclosures,
namely 2017 “Recommendations of the Task Force on Climate related Financial Disclosures”, 2017
“Technical Supplement on The Use of Scenario Analysis in Disclosure of Climate-Related Risks
and Opportunities”, and 2020 “Guidance on Scenario Analysis for Non-Financial Companies”. As
recommended by the TCFD, organization in the initial stage of implementation of scenario analyses or
with limited exposure to climate-related issues, may limit its discloses to qualitative information on how
the company’s strategy and financial position may differ in various climate scenarios. LINK’s materiality
assessment demonstrates that although climate change matters may be of importance to the company,
as to almost each entity operating in today’s world, its exposure is not critical. The company operates
mainly in the digital world, with no production facilities, and its relation to the environment results mainly
from usual office operations, as well as from its dependence on data storage, and consequently energy
supply. Having this in mind, considering also initial stage of implementing scenario analyses at LINK,
and limited resources available, LINK’s simplified scenario analyses shall be viewed as just a starting
point in framing potential environmental issues that are worth addressing. Performing more in-depth
analyses will be considered in the future.
Sustainability statement
https://www.fsb-tcfd.org/publications/
TCFD’s 2017 Recommendations of the Task Force on Climate related Financial Disclosures, p.28
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The climate-specific analyses consisted of the following steps:
1. Describing LINK’s context in relation to climate change (above)
2. Deliberation on climate-related impacts, risks, and opportunities outlined during materiality
assessment (sec. b) below)
3. Climate-related scenario and resilience analyses
a. Defining purpose and scope of the analyses (above, and sec. a), c) below)
b. Choice of relevant scenarios, formulating their main assumptions and objectives
(sec. c) below)
c. Defining focal questions and driving forces (sec. c) below)
d. Identification of major climate factors and their impact on LINK-specific IROs (sec. c) below)
e. Resilience analyses and LINK’s response (chapter 2.2.2.)
a. Time horizons
The time horizons applied to climate analyses are the same as time horizons defined in ESRS 1 section
6.4 (see chapter 1.1.2.1). It must be noted however, that climate-related impacts, risks and opportunities
have implications mostly in a longer period of time. Therefore the climate analyses focused on medium-
and long- term, with long term spanning to as long as 2050 which is consistent with the 2050 net zero-
emission target specified in the European Green Deal.
b. Disclosures related to the identification of climate-related hazards and
transition events, and how LINK’s assets and business activities may be exposed
to them and are sensitive to them
The climate-related hazards and transition events identified during climate-specific analyses, and how
LINK is exposed to them, are described in a table below. Having in mind current regulatory environment,
and LINK’s type of business, no assets or activities have been identified that are incompatible with
or need significant efforts to be compatible with transition to climate-neutral economy. No further
quantitative assessments were performed.
https://climate.ec.europa.eu/eu-action/climate-strategies-targets/2050-long-term-strategy_en
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Climate-
related hazard/
transition
event
Related risk Potential effects on LINK
LINK assets/
activity
potentially
affected
Transition
event:
enhanced
emissions- and
energy-related
regulatory
obligations
Transition risk: legal and policy
risk resulting from the introduction
of regulatory changes that impose
strict requirements related to
reducing emissions and energy
consumption, and achieving
“greener” energy mix
It may lead to the increased
operating costs related to
the necessity to ensure
compliance
Overall
(increased
operating
costs)
Transition
event:
costs of
transition
to lower
emissions
technology
Transition risk: technology risk
resulting from the necessity to catch
up with a transition to lower-carbon,
energy efficient solutions, including
the ones affecting ICT infrastructure.
It may lead to efficiency
loses related to the
implementation of new
uncertain solutions and
the reduced infrastructure
redundancy.
Data centres
Transition
event:
negative
stakeholder
feedback
Transition risk: reputation risk
related to the growing awareness
of climate related issues and
uncertain stakeholders’ perception
of the company’s attitude to the
environmental issues.
It may lead to the increased
operating costs related to
the necessity to ensure
relevant training and
marketing activities.
Overall
(increased
operating
costs)
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c. Disclosures related to the climate-related scenario analyses
LINK’s scenario analyses involve three simple scenarios that are inspired by the publicly available
scenarios developed by International Energy Agency (IEA). IEA’s scenarios have been chosen because
they focus on issues most relevant to LINK, namely energy and emissions. The IEA’s Global Energy and
Climate (GEC) Model is designed to analyse various aspects of the energy system and how it might
evolve over time. It allows to analyse and compare the chosen scenarios build on different assumptions
on the energy system’s development, in order to understand how different factors might impact the
company and to which outcomes they may lead. These scenarios are:
• the Stated Policies Scenario (STEPS),
• the Announced Pledges Scenario (APS),
• the Net Zero Emissions by 2050 Scenario (NZE Scenario) – aligned with limiting global warming to
1.5°C with no or limited overshoot.
LINK’s scenario analyses are of qualitative nature, and constitute just a starting point to potential
future more in-depth analyses. Therefore, IEA’s scenarios have formed just an inspiration for the three
scenarios analysed on a company level. The description of these scenarios, their assumptions and
objectives, is provided in a table below.
Scenario Scenario 1
-inspired by the
IEA’s Stated Policies
Scenario (STEPS)
Scenario 2
-inspired by the IEA’s
Announced Pledges
Scenario (APS)
Scenario 3
-inspired by the IEA’s Net Zero
Emissions by 2050 Scenario (NZE
Scenario)
Type of scenario
Exploratory scenario
that defines starting
conditions (policies/
targets etc), and see
where they lead.
Exploratory scenario
that defines starting
conditions (policies/
targets etc), and see
where they lead.
Normative scenario that defines
outcomes (net zero emissions
from the energy sector by 2050,
emissions trajectory consistent
with keeping the temperature rise
in 2100 below 1.5 °C), and shows
a pathway to reach them.
Assumptions
• No strengthening or
weakening of policies
and regulations – the
EU energy policies
and regulatory
requirements will
remain at their current
state.
• Strengthening
of policies and
regulations – new
EU energy policies
and regulations will
be implemented that
reflect the announced
ambitions and targets
(net zero or carbon
neutrality pledges
achieved in the long-
term).
• The energy sector will achieve
net zero emissions by 2050.
• The global temperature rise will
be limited to 1.5 °C.
• Key energy-related Sustainable
Development Goals (SDGs)
will be achieved (universal
energy access by 2030, major
improvements in air quality,
action to tackle climate change).
• A pathway to achieve these
goals will include:
- deployment of clean energy
technologies,
https://iea.blob.core.windows.net/assets/89a1aa9a-e1bd-4803-b37b-59d6e7fba1e9 GlobalEnergyandClimateModelDocumentation2024.pdf
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Assumptions
• The energy sector
will go without a major
additional steer from
policy makers.
• The energy sector
will be affected by the
policies and regulations
requiring emissions
reductions aimed at
achieving net zero
emissions by 2050.
- incentives supporting larger
share of renewable energy in the
energy mix,
- penalties for to large share of
energy from fossil sources in the
energy mix,
- strict requirements to lower GHG
emissions.
Geographical
scope
• European Economic
Area (EEA)
• European Economic
Area (EEA)
• European Economic Area (EEA)
Time horizons
(defined above)
• Medium term
• Long term
• Medium term
• Long term
• Medium term
• Long term
Objectives
The scenario is aimed
to understand how
LINK’ s business will
be affected by climate
change in current
regulatory conditions.
The scenario is aimed
to understand how
LINK’ s business
will be affected by
climate change in
case the regulatory
requirements are
stricter than currently.
The scenario is aimed to
understand how LINK as a
business will be affected by
climate change in conditions
where the targets of net zero
emissions by 2050 and global
achieved in due time.
Having in mind the context in which LINK operates, climate analyses have been focused on answering
the following questions:
1. How the conditions in a given scenario might affect LINK’s requirements to reduce its energy
consumption and emissions?
2. How the conditions in a given scenario might affect LINK’s requirements to achieve “greener”
energy mix?
Following the choice of scenarios, most important climate factors that may affect LINK, depending on
the given scenario, were identified. The search for these factors was focused on the focal questions as
described above. The analyses took into consideration LINK’s own operations as well as its value chain,
in the medium and long term time horizons. The goal was to answer the question “What major climate
factors might affect LINK in a given scenario?”.
Following the identification of main climate factors that may affect LINK in each scenario, they were
related to the identified risks specific to LINK’s business. The goal was to answer the question “How
climate factors may impact identified risks?”.
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The analyses are presented in a table below.
Scenario Scenario 1
inspired by the IEA’s
Stated Policies Scenario
(STEPS)
Scenario 2
inspired by the IEA’s
Announced Pledges Scenario
(APS)
Scenario 3
inspired by the IEA’s Net Zero
Emissions by 2050 Scenario
(NZE Scenario)
Main climate
factors that may
affect LINK
• In the long term, the
price of energy from
fossil sources will
slightly increase.
• In the medium term, ensuring
regulatory compliance will
require significant resources.
• In the medium term, energy
mix will have to be “greener”
• In the medium term,
emissions will need to be
reduced.
• In the long term, the price of
energy from fossil sources will
significantly increase.
• In the long term, some
penalties for non reducing GHG
emissions will be introduced.
• In the medium term, energy
mix will have to be “greener”
(even more than in Scenario 2).
• In the medium term,
emissions will need to be
reduced (even more than in
Scenario 2).
• In the long term, the price of
energy from fossil sources will
significantly increase (even
more than in Scenario 2).
• In the medium term, some
penalties for non reducing GHG
emissions will be introduced.
• In the long term, significant
penalties for non reducing GHG
emissions will be introduced.
How climate factors may impact identified risks?
• Legal and policy
risk (regulatory
changes)
No changes comparing
to the current state.
LINK will have to ensure
compliance with existing
climate-related laws and
regulations.
LINK will have to bear
significant cost related to
ensuring compliance with
stricter climate-related laws
and regulations.
LINK may need to bear
significant cost related to
ensuring compliance with
stricter climate-related laws
and regulations.
• Technology
risk (transition
to low carbon,
energy efficient
solutions)
LINK will have to
consider implementing
energy-efficient
solutions leading to
decrease in energy
consumption and
“greener” energy mix,
resulting in some
reductions in GHG
emissions.
LINK will need to implement
energy-efficient solutions
leading to significant decrease
in energy consumption and
“greener” energy mix, leading
to considerable reductions in
GHG emissions.
LINK will need to implement
state-of-the-art energy-
efficient solutions leading to
fast and significant decrease
in energy consumption and
“greener” energy mix, leading
to major reductions in GHG
emissions.
• Reputation
risk (growing
awareness and
demands
LINK will need to
continue its current
training and marketing
schemes.
LINK will need to continue its
current training and marketing
schemes.
LINK will need to continue its
current training and marketing
schemes.
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d. Explanation of how climate scenarios used are compatible with critical climate-
related assumptions made in financial statements
No climate-related assumptions have been made in financial statements.
1.1.11.10. [E2-E5.IRO-1] Description of the processes to identify and assess material IROs
related to certain environmental topics.
LINK operates in the ICT industry, providing mostly messaging services as an electronic communication
services’ provider, on a B2B basis. As the Group takes part in creating a digital rather than a physical
world, no material pollution, water and marine resources, diversity and ecosystem, or resource use and
circular economy related impacts, risks or opportunities have been identified.
The process to identify and assess material IROs (materiality assessment) is described in chapters
1.1.11.1-1.1.11.8 above. The described process is comprehensive in its nature and covers environmental,
social and governance related IROs. No separate process focused on the above mentioned environment
topics (E2-E5) has been performed, and no further screening performed, as this is not material to the
homogenous nature of LINK’s operation in its respective sector, with presence mainly in the digital
world. No site locations relevant to the assessment of biodiversity sensitive areas, or relevant to other
mentioned environmental topics, have been identified.
Description of how stakeholders have been included in the materiality assessment process is described
in chapter 1.1.11.2.c above. No specific consultations related to the above mentioned environment
topics, including the ones with affected communities, have been conducted.
1.1.11.11. [G1. IRO-1] Description of the processes to identify and assess material IROs
related to business conduct.
The process to identify and assess material IROs (materiality assessment) is described in chapters
1.1.11.1-1.1.11.8 above. The described process is comprehensive in its nature and covers environmental,
social and governance related IROs. No separate process focused solely on business conduct (G1) has
been performed, as the governance-related IROs have already been covered by the general process. The
homogenous nature of LINK’s operation in its respective sector does not justify to further distinguish the
IROs related to business conduct matters in relation to criterions such as location, activity, sector or the
structure of the transaction, other than described in the previous chapters.
1.1.12. [IRO-2] Disclosure Requirements in ESRS covered by LINK’s
sustainability statement
1.1.12.1. List of data points that derive from other EU legislation and information on their
location in sustainability statement
The list of datapoints derived from Appendix B to ESRS 2 and information on their location in this
sustainability statement is specified in a table below.
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No
Disclosure Requirement
and related datapoint
Where the datapoint can be found in
this sustainability statement
/or “not material”/
1 ESRS 2 GOV-1 Board’s gender diversity; paragraph 21 (d) ESRS 2 GOV-1 (chapter 1.1.3.1)
2
ESRS 2 GOV-1 Percentage of board members who are
independent; paragraph 21 (e)
ESRS 2 GOV-1 (chapter 1.1.3.1)
3 ESRS 2 GOV-4 Statement on due diligence; paragraph 30 ESRS 2 GOV-4 (chapter 1.1.6)
4
ESRS 2 SBM-1 Involvement in activities related to fossil fuel
activities; paragraph 40 (d) i
ESRS 2 SBM-1 (chapter 1.1.8.1.f)
5
ESRS 2 SBM-1 Involvement in activities related to chemical
production; paragraph 40 (d) ii
ESRS 2 SBM-1 (chapter 1.1.8.1.f)
6
ESRS 2 SBM-1 Involvement in activities related to
controversial weapons; paragraph 40 (d) iii
ESRS 2 SBM-1 (chapter 1.1.8.1.f)
7
ESRS 2 SBM-1 Involvement in activities related to cultivation
and production of tobacco; paragraph 40 (d) iv
ESRS 2 SBM-1 (chapter 1.1.8.1.f)
8
ESRS E1-1 Transition plan to reach climate neutrality by
2050; paragraph 14
ESRS E1-1 (chapter 2.2.1)
9
ESRS E1-1 Undertakings excluded from Paris-aligned
Benchmarks; paragraph 16 (g)
Not material (no transition plan, as
explained in chapter 2.2.1)
10 ESRS E1-4 GHG emission reduction targets; paragraph 34
ESRS E1-4 (no GHG emissions
reduction targets set, as explained in
chapter 2.2.5)
11
ESRS E1-5 Energy consumption from fossil sources
disaggregated by sources (only high climate impact
sectors); paragraph 38
Not material (no operation in high
climate impact sectors, as explained
in chapter 2.2.6.2)
12 ESRS E1-5 Energy consumption and mix; paragraph 37 ESRS E1-5 (chapter 2.2.6.1)
13
ESRS E1-5 Energy intensity associated with activities in high
climate impact sectors; paragraphs 40 to 43
Not material (no operation in high
climate impact sectors, as explained
in chapter 2.2.6.2)
14
ESRS E1-6 Gross Scope 1, 2, 3 and Total GHG emissions;
paragraph 44
ESRS E1-6 (chapter 2.2.7.1)
15
ESRS E1-6 Gross GHG emissions intensity; paragraphs 53
to 55
ESRS E1-6 (chapter 2.2.7.6)
16 ESRS E1-7 GHG removals and carbon credits; paragraph 56 Not material
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17
ESRS E1-9 Exposure of the benchmark portfolio to climate-
related physical risks; paragraph 66
Phased-in in accordance with ESRS
1 Appendix C (see chapter 2.2.8)
18
ESRS E1-9 Disaggregation of monetary amounts by acute
and chronic physical risk; paragraph 66 (a)
ESRS E1-9 Location of significant assets at material
physical risk; paragraph 66 (c).
Phased-in in accordance with ESRS
1 Appendix C (see chapter 2.2.8)
19
ESRS E1-9 Breakdown of the carrying value of its real estate
assets by energy-efficiency classes; paragraph 67 (c).
Phased-in in accordance with ESRS
1 Appendix C (see chapter 2.2.8)
20
ESRS E1-9 Degree of exposure of the portfolio to climate-
related opportunities; paragraph 69
Phased-in in accordance with ESRS
1 Appendix C
21
ESRS E2-4 Amount of each pollutant listed in Annex II of
the E-PRTR Regulation (European Pollutant Release and
Transfer Register) emitted to air, water and soil; paragraph
28
Not material
22 ESRS E3-1 Water and marine resources; paragraph 9 Not material
23 ESRS E3-1 Dedicated policy; paragraph 13 Not material
24 ESRS E3-1 Sustainable oceans and seas; paragraph 14 Not material
25 ESRS E3-4 Total water recycled and reused; paragraph 28 (c) Not material
26
ESRS E3-4 Total water consumption in m3 per net revenue
on own operations; paragraph 29
Not material
27 ESRS 2- IRO 1 - E4; paragraph 16 (a) i
ESRS 2 E2-E5.IRO-1 (chapter
1.1.11.10)
28 ESRS 2- IRO 1 - E4; paragraph 16 (b)
ESRS 2 E2-E5.IRO-1 (chapter
1.1.11.10)
29 ESRS 2- IRO 1 - E4; paragraph 16 (c)
ESRS 2 E2-E5.IRO-1 (chapter
1.1.11.10)
30
ESRS E4-2 Sustainable land / agriculture practices or
policies; paragraph 24 (b)
Not material
31
ESRS E4-2 Sustainable oceans / seas practices or policies;
paragraph 24 (c)
Not material
32
ESRS E4-2 Policies to address deforestation; paragraph 24
(d)
Not material
33 ESRS E5-5 Non-recycled waste; paragraph 37 (d) Not material
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34
ESRS E5-5 Hazardous waste and radioactive waste;
paragraph 39
Not material
35
ESRS 2- SBM3 - S1 Risk of incidents of forced labour;
paragraph 14 (f)
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
36
ESRS 2- SBM3 - S1 Risk of incidents of child labour;
paragraph 14 (g)
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
37 ESRS S1-1 Human rights policy commitments; paragraph 20
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
38
ESRS S1-1 Due diligence policies on issues addressed by the
fundamental International Labor Organisation Conventions
1 to 8; paragraph 21
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
39
ESRS S1-1 processes and measures for preventing
trafficking in human beings; paragraph 22
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
40
ESRS S1-1 workplace accident prevention policy or
management system; paragraph 23
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
41
ESRS S1-3 grievance/complaints handling mechanisms;
paragraph 32 (c)
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
42
ESRS S1-14 Number of fatalities and number and rate of
work-related accidents; paragraph 88 (b) and (c)
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
43
ESRS S1-14 Number of days lost to injuries, accidents,
fatalities or illness; paragraph 88 (e)
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
44 ESRS S1-16 Unadjusted gender pay gap; paragraph 97 (a)
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
45 ESRS S1-16 Excessive CEO pay ratio; paragraph 97 (b)
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
46 ESRS S1-17 Incidents of discrimination; paragraph 103 (a)
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
47
ESRS S1-17 Non-respect of UNGPs on Business and Human
Rights and OECD; paragraph 104 (a)
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
48
ESRS 2- SBM3 – S2 Significant risk of child labour or forced
labour in the value chain; paragraph 11 (b)
Not material
49 ESRS S2-1 Human rights policy commitments; paragraph 17 Not material
50
ESRS S2-1 Policies related to value chain workers;
paragraph 18
Not material
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51
ESRS S2-1 Non-respect of UNGPs on Business and Human
Rights principles and OECD guidelines; paragraph 19
Not material
52
ESRS S2-1 Due diligence policies on issues addressed
by the fundamental International Labor Organisation
Conventions 1 to 8; paragraph 19
Not material
53
ESRS S2-4 Human rights issues and incidents connected to
its upstream and downstream value chain; paragraph 36
Not material
54 ESRS S3-1 Human rights policy commitments; paragraph 16 Not material
55
ESRS S3-1 non-respect of UNGPs on Business and Human
Rights, ILO principles or and OECD guidelines; paragraph 17
Not material
56 ESRS S3-4 Human rights issues and incidents; paragraph 36 Not material
57
ESRS S4-1 Policies related to consumers and end-users;
paragraph 16
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
58
ESRS S4-1 Non-respect of UNGPs on Business and Human
Rights and OECD guidelines; paragraph 17
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
59 ESRS S4-4 Human rights issues and incidents; paragraph 35
Phased-in in accordance with ESRS
1 Appendix C (see chapter 1.1.2.8)
60
ESRS G1-1 United Nations Convention against Corruption;
paragraph 10 (b)
ESRS G1 G1-1 (chapter 4.1.1.3.a)
61 ESRS G1-1 Protection of whistle- blowers; paragraph 10 (d) ESRS G1 G1-1 (chapter 4.1.1.3.c)
62
ESRS G1-4 Fines for violation of anti-corruption and anti-
bribery laws; paragraph 24 (a)
ESRS G1 G1-4 (chapter 4.1.4)
63
ESRS G1-4 Standards of anti- corruption and anti- bribery;
paragraph 24 (b)
ESRS G1 G1-4 (chapter 4.1.4)
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1.1.12.2. List of ESRS Disclosure Requirements complied with in preparing sustainability
statement following outcome of materiality assessment
Based on the results of the materiality assessment, the following ESRS Disclosure Requirements have
been complied with in preparing this sustainability statement:
No ESRS Disclosure Requirement (DR) complied with
Where the DR can be found in
this sustainability statement
1
[ESRS 2] [BP-1] General basis for preparation of the
sustainability statements
chapter 1.1.1
2 [ESRS 2] [BP-2] Disclosures in relation to specific circumstances chapter 1.1.2
3
[ESRS 2] [GOV-1] The role of the administrative, management
and supervisory bodies
chapter 1.1.3
4
[ESRS 2] [GOV-2] Information provided to and sustainability
matters addressed by the undertaking’s administrative,
management and supervisory bodies
chapter 1.1.4
5
[ESRS 2] [GOV-3] Integration of sustainability-related
performance in incentive schemes
chapter 1.1.5
6 [ESRS 2] [GOV-4] Statement on due diligence chapter 1.1.6
7
[ESRS 2] [GOV-5] Risk management and internal controls over
sustainability reporting
chapter 1.1.7
8 [ESRS 2] [SBM-1] Strategy, business model and value chain chapter 1.1.8
9 [ESRS 2] [SBM-2] Interests and views of stakeholders chapter 1.1.9
10
[ESRS 2] [SBM-3] Material impacts, risks and opportunities and
their interaction with strategy and business model
chapter 1.1.10, 2.2.2
11
[ESRS 2] [IRO-1] Description of the process to identify and
assess material impacts, risks and opportunities
chapter 1.1.11
12
[ESRS 2] [IRO-2] Disclosure Requirements in ESRS covered by
LINK’s sustainability statement
chapter 1.1.12
13
[ESRS 2] [MDR-P] Policies adopted to manage material
sustainability matters
chapters 1.1.2.8.b, 1.1.2.8.c,
4.1.1.1, 4.1.1.3.c (see also
references in 2.2.3, 4.1.2, 4.1.3,
4.1.4)
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14
[ESRS 2] [MDR-A] Actions and resources in relation to material
sustainability matters
chapters 1.1.2.8.b, 1.1.2.8.c,
2.2.4, 4.1.1.2 (see also
references in 4.1.2, 4.1.3, 4.1.4)
15
[ESRS 2] [MDR-M] Metrics in relation to material sustainability
matters
chapters 1.1.2.8.b, 1.1.2.8.c,
2.2.4, 4.1.1.2 (see also
references in 4.1.2, 4.1.3, 4.1.4)
16
[ESRS 2] [MDR-T] Tracking effectiveness of policies and actions
through targets
chapters 1.1.2.8.b, 1.1.2.8.c,
2.2.5, 4.1.1.2 (see also
references in 4.1.2, 4.1.3, 4.1.4)
17
Disclosures pursuant to Article 8 of Regulation (EU) 2020/852
(Taxonomy Regulation)
chapter 2.1
18
[ESRS E1] [E1-2] Policies related to climate change mitigation
and adaptation
chapter 2.2.1
19
[ESRS E1] [E1-3] Actions and resources in relation to climate
change policies
chapter 2.2.3
20
[ESRS E1] [E1-4] Targets related to climate change mitigation
and adaptation
chapter 2.2.4
21 [ESRS E1] [E1-5] Energy consumption and mix chapter 2.2.5
22 [ESRS E1] [E1-6] Gross Scopes 1, 2, 3 and Total GHG emissions chapter 2.2.6
23 [ESRS S1] all DR chapter 2.2.7
24 [ESRS S4] all DR
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.8)
25
[ESRS G1] [G1-1] Business conduct policies and corporate
culture
Phased-in in accordance with
ESRS 1 Appendix C (see chapter
1.1.2.8)
26 [ESRS G1] [G1-2] Management of relationships with suppliers chapter 4.1.1
27
[ESRS G1] [G1-3] Prevention and detection of corruption and
bribery
chapter 4.1.2
28 [ESRS G1] [G1-4] Incidents of corruption or bribery chapter 4.1.3
29 [ESRS G1] [G1-4] Incidents of corruption or bribery chapter 4.1.4
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1.1.12.3. Explanation of negative materiality assessment for certain ESRS
Based on the results of the materiality assessment, the following ESRS have been identified as not
material:
No ESRS Explanation of the egative materiality assessment
1 ESRS E2 Pollution
LINK operates in the ICT industry, providing mostly messaging services
on B2B basis. The topic of “pollution” has been assessed as not material
because LINK takes part in creating a digital rather than a physical world.
2
ESRS E3 Water
and marine
resources
LINK operates in the ICT industry, providing mostly messaging services on
a B2B basis. The topic of “water and marine resources” has been assessed
as not material because LINK takes part in creating a digital rather than a
physical world.
3
ESRS E4
Biodiversity and
ecosystems
LINK operates in the ICT industry, providing mostly messaging services on
a B2B basis. The topic of “biodiversity and ecosystems” has been assessed
as not material because LINK takes part in creating a digital rather than a
physical world.
4
ESRS E5 Circular
economy
LINK operates in the ICT industry, providing mostly messaging services
on a B2B basis. The topic of “circular economy” has been assessed as not
material because LINK takes part in creating a digital rather than a physical
world.
5
ESRS S2 Workers
in value chain
LINK acts mainly as an electronic communication aggregator, being a link
between mobile telecommunication operators (MNO)/ OTT providers, and
the customers. In provision of its services LINK relies on certain suppliers,
including IT, “telco” and others. As far as IT suppliers are concerned, LINK
mainly cooperates with global players, and the cooperation is often based
on adhesive-like contracts, with potential LINK’s impact on their workforce
that is close to zero. When it comes to telco suppliers, they are either large
MNOs or other entities falling under the telco regulations. It must be noted
that in case of the electronic communication industry- identification of the
“simply understood” value chain in its entirety is not practically feasible.
Electronic communication is a highly regulated sector that enables world-
wide communication via a variety of channels.
Example: an SMS-message sent by a Norway-based company who is LINK’s
customer, shall reach an end-user with a Norwegian mobile subscription,
but who may be located in any country at the time the SMS is sent, on
travel for private or business. It is impossible to specify that country when
sending the message.
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No ESRS Explanation of the egative materiality assessment
5
ESRS S2 Workers
in value chain
In order to ensure that systems and devices located in different networks and
countries are able to connect and work together, electronic communication
laws are based on the principles of “interconnection” and “interoperability”.
As the termination of a message is in practice controlled by the recipient’s
subscription and location, LINK has no influence on where (in which network)
the message is in fact terminated. Furthermore, all entities through which
the message ultimately reaches an end-user operate on a highly regulated
electronic communication market and are therefore subject to regulations
that require each entity to fulfil certain requirements. It should therefore
be expected that such entities adhere to at least basic standards of the
responsible business conduct. LINK recognizes that, even though a variety
of electronic communication sector entities form part of its value chain,
numerous factors related to these entities are imposed on LINK, which
means LINK cannot in fact contribute to them or influence them. At the
same time LINK strives to establish as many direct business relations with
respected and well-recognized companies as practically and commercially
possible.
Having in mind the above, the topic “workers in value chain” has been
assessed as not material.
6
ESRS S3 Affected
communities
LINK operates in the ICT industry, providing mostly messaging services on
a B2B basis. The topic of “affected communities” has been assessed as not
material because LINK takes part in creating a digital rather than a physical
world.
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1.1.12.4. Explanation of how material information to be disclosed in relation to material
impacts, risks and opportunities has been determined
Based on the results of the materiality assessment, certain disclosure requirements included in the
ESRS, listed in a table below, have been identified as material. The explanation of how LINK decided
on the materiality topics, including the applied criterions and thresholds, is described under disclosure
requirement ESRS 2 IRO-1 (chapter 1.1.11).
No ESRS Explanation of how the scope of the disclosure was determined
1
ESRS E1 Climate
change
The following sub-topics covered by topic “Climate change” have been
assessed as material: “Climate change mitigation”, “Energy”. LINK is not
active in any of the high climate impact sectors. Being part of the ICT
industry, LINK is however, heavily dependent on the energy consumption,
and leaves certain carbon footprint. Hence, the disclosures include basic
datapoints related to the energy mix and GHG emissions. Having in mind the
above, certain disclosures covered by ESRS E1 (E1-1, E1-2, E1-3, E1-4, E1-5,
E1-6) are included in chapter 2. The disclosures under E1-7, E1-8 have been
assessed as not material. The disclosures under E1-9 have been phased-in,
as 2025 is the first year of preparation of LINK’s sustainability statement fully
compliant with CSRD.
2
ESRS S1 Own
workforce
The topic “Own workforce” – sub-topic “Equal treatment and opportunities
for all” – Sub-sub-topic “Training and skills development” has been assessed
as material. However, as LINK does not exceed on its balance sheet date the
average number of 750 employees during the financial year 2024, it omits
information required by ESRS S1. For the identified material topic covered by
ESRS S1, the required disclosures are included in chapter 1.1.2.8.
3
ESRS S4
Consumers and
end-users
The topic “Consumers and end users” – sub-topic “Information-related
impacts for consumers and/or end-users” – sub-sub-topic “Privacy” has
been assessed as material. However, as LINK does not exceed on its balance
sheet date the average number of 750 employees during the financial year
2024, it omits information required by ESRS S4. For the identified material
topic covered by ESRS S4, the required disclosures are included in chapter
1.1.2.8.
4
ESRS G1 Business
conduct
The following sub-topics covered by topic “Business conduct” have been
assessed as material: “Corporate culture”; “Protection of whistle-blowers”;
“Management of relationships with suppliers”; “Corruption and bribery”.
Therefore, corresponding disclosures covered by ESRS G1 (G1-1, G1-2, G1-3,
G1-4) are included in chapter 4.
The disclosures [G1-5] „Political engagement and lobbying activities” and
[G1-6] “Payment practices” are omitted, as the related impacts, risks, and
opportunities have been assessed as not material.
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2. Environmental information
This chapter includes:
• disclosures pursuant to Article 8 of Regulation (EU) 2020/852 (Taxonomy Regulation);
• certain disclosures resulting from the materiality assessment.
As far as the materiality assessment is concerned, LINK has assessed the following topics included in
ESRS E1 as material:
• ESRS E1: Topic “Climate change mitigation”
• ESRS E1: Topic “Climate change” – Sub-topic “Energy”
Hence, LINK reports in this chapter the disclosure requirements covered by E-1 (including, E1-2, E1-3,
E1-4, E1-5 and E1-6), alongside the minimum disclosure requirements covered by ESRS 2 MDR, relevant
to each of the above listed material topics. The disclosures under E1-9 have been phased-in. The
disclosures under E1-7 and E1-8 have been assessed as not material.
No sustainability matters covered by ESRS E2, ESRS E3, ESRS E4, ESRS E5 have been assessed as
material. Hence, these topical standards have not been included.
The description of how LINK identified the scope of the sustainability reporting is provided under
disclosure requirements ESRS 2 IRO-2 (chapters 1.1.12.3 and 1.1.12.4).
The disclosures E1.SBM-3 are included in this chapter. The disclosures E1.GOV-3 are included under
ESRS 2 GOV-3. The disclosures E1-E5.IRO-1 are included under ESRS 2 IRO-1.
2.1. Disclosures pursuant to Article 8 of Regulation
(EU) 2020/852 (Taxonomy Regulation)
EU Taxonomy establishes the criteria for determining whether an economic activity qualifies as
environmentally sustainable for the purposes of establishing the degree to which an investment is
environmentally sustainable. Any undertaking that is obliged to publish non-financial information
pursuant to CSRD shall include, in its (consolidated) non-financial statement, information on how and
to what extent the undertaking’s activities are associated with ‘environmentally sustainable activities’.
Since the EU Taxonomy is applicable in Norway, LINK hereby reports relevant Key Performance Indicators.
Having in mind article 4 of the Commission Delegated Regulation (EU) 2026/73, LINK reporting is based
on the regulations as applicable on December 31st 2025, hence the same as in the previous reporting
period. The scope of consolidation is the same as for the financial statements.
The reported KPIs include proportion of the EU Taxonomy- eligible and aligned turnover, capital
expenditure (CaPex) and operating expenditure (OpEx) derived from products (services) associated
with relevant economic activities, as well as disclosures as specified in Annex XII to the Disclosures
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Delegated Act. The low level of the disclosed indicators results from the assessment that majority of
LINK activities is not covered by the EU Taxonomy.
Activities contributing to environmental objectives covered by the Climate Delegated Act and the
Environmental Delegated Act are included. It must be however noted that the delegated acts published
so far do not include activities in the field of the electronic communication, which constitute a vast
majority of LINK’s operations. In principle, activities within the information and communication sector
are included to a very limited extent. As such, non-eligible activities are not synonymous with un
sustainable activities.
2.1.1. Assessment of LINK’s compliance with the EU Taxonomy
Assessment of LINK’s operations under the EU Taxonomy has been performed in line with a four-steps
process, included in “A User Guide to navigate the EU Taxonomy for sustainable activities¹,” published
by the EU Commission. These steps include:
Step 1. Identify the activities that are covered by the EU Taxonomy (Taxonomy-eligible activities)
Step 2. Assess whether the activities meet the technical screening criteria (Taxonomy-aligned
activities)
Step 3. Check compliance of the activities with minimum safeguards
Step 4. Apply the relevant reporting rules
The assessment process was carried out in LINK in 2023 for the first time, and it has been later revised
annually. The results are described below.
a. Step 1: Identify the activities that are covered by the EU Taxonomy (Taxonomy-
eligible activities)
In the first step, the assessment was made concerning which, if any, LINK’s operation can be considered
as “taxonomy-eligible”. The aim of this step was to answer the question: “Which of activities performed
by LINK are covered by the EU Taxonomy.“
Four LINK’s activities were found as falling under the ones described in the Climate Delegated Act.
These activities have been identified as “taxonomy-eligible”. No activity was found as falling under the
ones described in the Environmental Delegated Act. For details see the table below.
¹ https://ec.europa.eu/sustainable-finance-taxonomy/assets/documents/Taxonomy%20User%20Guide.pdf
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Basis
No. of the
activity
Description of the activity
Description of
LINK’s activity
Climate
Delegated
Act,
Annex I &
Annex II
6.5.
Transport by
motorbikes,
passenger
cars and
commercial
vehicles
Purchase, financing, renting, leasing and
operation of vehicles (categories: M1, N1, L).
The economic activities in this category could be
associated with several NACE codes, in particular
H49.32, H49.39 and N77.11 in accordance with the
statistical classification of economic activities
established by Regulation (EC) No 1893/2006.
Annex I: Where an economic activity in this category
does not fulfil the substantial contribution criterion
specified in point (a)(ii) and (b) of this Section, the
activity is a transitional activity as referred to in Article
10(2) of Regulation (EU) 2020/852, provided it complies
with the remaining technical screening criteria.
LINK leases
company cars
(category M1).
Climate
Delegated
Act,
Annex I &
Annex II
7.7.
Acquisition
and
ownership of
buildings
Buying real estate and exercising ownership of
that real estate.
The economic activities in this category could be
associated with NACE code L68 in accordance with
the statistical classification of economic activities
established by Regulation (EC) No 1893/2006.
LINK leases its
offices.
Climate
Delegated
Act,
Annex I &
Annex II
8.1. Data
processing,
hosting
and related
activities
Storage, manipulation, management, movement,
control, display, switching, interchange,
transmission or reception of diversity of data
through data centres, including edge computing.
The economic activities in this category could be
associated with NACE code J63.1.1 in accordance with
the statistical classification of economic activities
established by Regulation (EC) No 1893/2006.
Annex I: An economic activity in this category is a
transitional activity as referred to in Article 10(2) of
Regulation (EU) 2020/852 where it complies with the
technical screening criteria.
LINK stores,
manages and
transmits data
through its servers
(that may be
regarded as a data
centre).
Climate
Delegated
Act,
Annex II
8.1. Data
processing,
hosting
and related
activities
Providing expertise in the field of information
technologies: writing, modifying, testing and
supporting software; planning and designing
computer systems that integrate computer
hardware, software and communication
technologies; on-site management and operation
of clients’ computer systems or data processing
facilities; and other professional and technical
computer-related activities.
The economic activities In this category could be
associated with NACE code J62 in accordance with
the statistical classification of economic activities
established by Regulation (EC) No 1893/2006.
LINK provides
expertise in the
field of information
technologies
through writing,
testing and
supporting software
that is used for
rendering LINK’s
services.
Choice of the Taxonomy-eligible activities
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c. Step 3: Check compliance of the activities with minimum safeguards
The third step includes assessment of compliance with the minimum safeguards as set out in art. 18(1)
and (2) of the EU Taxonomy. However, since step 2 showed that no LINK’s activity may be recognized as
“taxonomy-aligned”, performing step 3 was not necessary. It was only performed voluntarily, in order to
demonstrate extent to which LINK aligns with minimum safeguards i.e. with:
• the OECD Guidelines for Multinational Enterprises (OECD Guidelines) and
• the UN Guiding Principles on Business and Human Rights (UNGPs), including the principles and rights
set out in the eight fundamental conventions identified in the Declaration of the International Labour
Organisation on Fundamental Principles and Rights at Work and
• the International Bill of Human Rights.
The assessment was carried out in accordance with the recommendations included in the “Final Report
on Minimum Safeguards¹¹”.
b. Step 2: Assess whether the activities meet the technical screening criteria
(Taxonomy-aligned activities)
In the second step, assessment was made if LINK’s activities identified as the “taxonomy-eligible”, meet
the “technical screening criteria” set out in the Climate Delegated Act, and can therefore be recognised
as “taxonomy-aligned”. For that reason, the following was performed:
• Assessment of the “substantial contribution” criterion – LINK’s taxonomy-eligible activities were
assessed against the “substantial contribution” criterions, specified in points 6.5., 7.7., and 8.1. of
Annex I, as well as points 6.5, 7.7, 8.1. and 8.2. of Annex II of the Climate Delegated Act, respectively.
None of LINK’s activities were found to fulfil this criterion. Hence, none of LINK’s activities shall be
recognized as the “taxonomy-aligned”.
• Substantial contribution to climate change mitigation: LINK’s activity does not fulfil the criterion,
as (1) it does not have sufficient data to demonstrate the energy performance criterions of its
leased offices, as specified in Annex I, point 7.7.; (2) it does not collect detailed environmental
data on company cars and therefore may not assures to fulfil criterion relevant to emission, as
specified in Annex I, point 6.5.; and furthermore, (3) it has neither implemented relevant practices,
listed in the Climate Delegated Act, nor has it assessed the global warming potential (GWP) of
refrigerants used in the data centre cooling system, as specified in Annex I, point 8.1.
• Substantial contribution to climate change adaptation: LINK’s activity does not fulfil the criterion,
as it has neither implemented adaptation solutions, nor has it performed specific risk and
vulnerability assessment related to this activity, as specified in Annex II, points 6.5, 7.7, 8.1 and
8.2.
• Assessment of the “do no significant harm” criterion – the “DNSH” criterion was not assessed, as
none of LINK’s activities were found to fulfil the first criterion. None of these activities may therefore
be recognized as the “taxonomy-aligned” ones.
11 https://finance.ec.europa.eu/system/files/2022-10/221011-sustainable-finance-platform-finance-report-minimum-safeguards_en.pdf, p. 63-64
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Topic LINK’s compliance
Human
rights
LINK has established and implemented a human rights-focused due diligence process
within its process to ensure compliance with the Norwegian Transparency Act. The Act
obliges companies to perform a due diligence process on fundamental human rights
and decent labour conditions, and is in principle aligned with major requirements of the
UNGPs and OECD Guidelines. LINK published its first report under the Transparency
Act in 2023, where it explained its relevant due diligence processes. Furthermore, LINK
implemented Employee Code of Conduct and provides a whistleblowing channel to
report any misconduct.
In 2025 LINK was not found to be in breach of labour law or human rights.
Corruption
LINK has a zero-tolerance principle to corruption, which is reflected in its anti-corruption
and anti-bribery policy, being part of the ESG policy. The principle is also reflected in the
Employees’ Code of Conduct, which shall be observed by all its employees. Moreover,
anti-corruption is part of a regular training that is obligatory for all employees.
In 2025 LINK was not convicted in court on corruption.
Taxation
LINK acts in accordance with its internal policies and procedures on accounting,
taxation and financial reporting. It aims to observe all relevant international and local tax
laws.
Fair
competition
LINK acts in accordance with its antitrust policy, being part of the ESG policy.
The fair competition principle is also reflected in the Employees’ Code of
Conduct, which shall be observed by all its employees. Moreover, antitrust is
also part of a regular training that is obligatory for all employees.
In 2025 LINK was not convicted in court on violating competition laws.
LINK’s compliance with minimum safeguards
d. Step 4: Apply the relevant reporting rules
The reporting requirements under the EU Taxonomy are specified in the Disclosures Delegated Act,
which- for non-financial companies- defines key performance indicators (KPIs) related to turnover,
capital expenditure (CapEx), and operational expenditure (OpEx). As LINK identified four activities as
“taxonomy-eligible”, it discloses the following KPIs:
• the proportion of a turnover derived from products or services associated with “taxonomy-eligible”
and “taxonomy non-eligible” activities;
• the proportion of a capital expenditure related to assets or processes associated with “taxonomy-
eligible” and “taxonomy non-eligible” activities;
• the proportion of an operating expenditure related to assets or processes associated with “taxonomy-
eligible” and “taxonomy non-eligible” activities.
Since LINK has not identified any of activities listed in sections 4.26- 4.31 of Annexes I and II to Climate
Delegated Act, nor does it engage in any nuclear energy related activities, the templates set out in Annex
XII of the Disclosures Delegated Act shall be reported with “0”/ “NO” answers.
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2.1.2. Disclosures under EU Taxonomy
Following the assessment described above, the below presented conclusions have been made and
relevant KPIs calculated.
a. Taxonomy- eligible activities
Four activities listed in the Climate Delegated Act have been identified in LINK as “taxonomy-eligible”:
• 6.5. Transport by motorbikes, passenger cars and commercial vehicles – LINK leases company cars
(category M1).
• 7.7. Acquisition and ownership of buildings – LINK leases its office space.
• 8.1. Data processing, hosting and related activities – LINK stores, manages and transmits data
through its servers (that may be regarded as a data centre).
• 8.2. Computer programming, consultancy and related activities – LINK provides expertise in the
field of information technologies through writing, testing and supporting software that is used for
rendering LINK’s messaging services.
No activity listed in the Environmental Delegated Act has been identified in LINK.
b. Taxonomy- aligned activities
No LINK’s activity has been recognized as “taxonomy-aligned”, as the identified “taxonomy-eligible”
activities do not meet the “technical screening criteria” (“substantial contribution” criterion and “do no
significant harm” criterion) set out in the Climate Delegated Act. However, LINK complies with minimum
safeguards.
c. Key Performance Indicators (KPIs)
KPIs related to turnover, CapEx and Opex, are presented in the tables below. No major changes compared
to last year have been introduced.
Accounting methodology note:
For disclosure in compliance with Article 8 of the Taxonomy, turnover, CapEx, and OpEx are defined
below. These definitions differ from how CapEx and OpEx are defined in LINK’s financial reports.
• Turnover corresponds to revenue in the consolidated income statement in the annual report. Further
information is provided in notes 3 and 7 of the financial statements.
• CapEx, or capital expenditure, are cumulative costs recognised as intangible assets and property,
plant, and equipment during the year. These include assets arising from business combinations
and they exclude goodwill. Further information is provided in notes 3, 8, 14, and 15 of the financial
statements.
• OpEx, or operating expenses, refer to direct costs arising from expenditures associated with
maintaining assets, costs related to research and development, short-term leases, repairs and
maintenance, and other expenditures related to the day-to-day operation of LINK’s business.
• The double counting in the allocation in the numerator of turnover, CapEx and OpEx was avoided by
the fact that they refer to different activities, which are independent. Moreover, the double counting
was avoided by eliminating the intra-group transactions where needed (as in the financial reporting).
No Taxonomy-aligned activities were identified.
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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Financial year: 2025
Substantial
contribution criteria
DNSH criteria (“Does
Not Significant Harm”)
Minimum safeguards
Proportion of taxonomy-aligned (A.1) or-eligible
(A.2) turnover, year 2024
Category enabling activity
Category transitional activity
Economic activities
Code(s)
Absolute turnover
Proportion of turnover,, year 2025
Climate change mitigation
Climate change adaptation
Water
Pollution
Circular economy
Biodiversity
Climate change mitigation
Climate change adaptation
Water
Pollution
Circular economy
Biodiversity
Tex t
NOK 1000
%
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y/ N
Y/ N
Y/ N
Y/ N
Y/ N
Y/ N
Y/ N
%
E
T
A. TAXONOMY-ELIGIBLE ACTIVITIES
A.1. Environmentally sustainable activities (Taxonomy-aligned)
none
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Turnover of environmentally sustainable activities
(Taxonomy-aligned) (A.1)
0
0%
0%
0%
0%
0%
0%
0%
-
-
-
-
-
-
-
0%
of which enabling
0
0%
0%
0%
0%
0%
0%
0%
-
-
-
-
-
-
-
0%
E
of which transitional
0
0%
0%
0%
T
A.2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)
E; N/EL
E; N/EL
E; N/EL
E; N/EL
E; N/EL
E; N/EL
6.5. Transport by motorbikes, passenger cars
and commercial vehicles *
CCM
6.5/ CCA
6.5
0
0%
EL
EL
N/EL
N/EL
N/EL
N/EL
-
0%
7.7. Acquisition and ownership of buildings**
CCM 7.7/
CCA 7.7
0
0%
EL
EL
N/EL
N/EL
N/EL
N/EL
-
0%
8.1. Data processing, hosting and related
activities*
CCM
8.1/ CCA
8.1
0
0%
EL
EL
N/EL
N/EL
N/EL
N/EL
0%
8.2. Computer programming, consultancy
and related activities*
CCA 8.2
0
0%
N/EL
EL
N/EL
N/EL
N/EL
N/EL
0%
Turnover of Taxonomy-eligible but not
environmentally sustainable activities
(not Taxonomy-aligned activities) (A.2)
0
0%
0%
0%
0%
0%
0%
0%
0%
Turnover of Taxonomy-eligible activities (A.1 + A.2)
0
0%
0%
0%
0%
0%
0%
0%
0%
B. TAXONOMY NON-ELIGIBLE ACTIVITIES
Turnover of Taxonomy-non-eligible activities 7 083 091
100%
TOTAL 7 083 091
100%
* Activities under “6.5. Transport by motorbikes, passenger cars and commercial vehicles “, “7.7 Acquisition and ownership of buildings”, “8.1. Data processing,
hosting and related activities” and “8.2. Computer programming, consultancy and related activities” have been recognized as not bringing an external turnover
to LINK.
Proportion of turnover from products or services associated with Taxonomy-aligned economic activities –
disclosure covering year 2025 (NOK 1000)
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Proportion of CapEx from products or services associated with Taxonomy-aligned economic activities – disclosure
covering year 2025 (NOK 1000)
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Financial year: 2025
Substantial
contribution criteria
DNSH criteria (“Does
Not Significant Harm”)
Minimum safeguards
Proportion of taxonomy -aligned (A.1) or
-eligible (A.2) CapEx, year 2024
Category enabling activity
Category transitional activity
Economic activities
Code(s)
CapEx
Proportion of CapEx, year 2025
Climate change mitigation
Climate change adaptation
Water
Pollution
Circular economy
Biodiversity
Climate change mitigation
Climate change adaptation
Water
Pollution
Circular economy
Biodiversity
Tex t
NOK 1000
%
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y/ N
Y/ N
Y/ N
Y/ N
Y/ N
Y/ N
Y/ N
%
E
T
A. TAXONOMY-ELIGIBLE ACTIVITIES
A.1. Environmentally sustainable activities (Taxonomy-aligned)
none
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
CapEx of environmentally sustainable activities
(Taxonomy-aligned) (A.1)
0
0%
0%
0%
0%
0%
0%
0%
-
-
-
-
-
-
-
0%
of which enabling
0
0%
0%
0%
0%
0%
0%
0%
-
-
-
-
-
-
-
0%
E
of which transitional
0
0%
0%
0%
T
A.2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)
E; N/EL
E; N/EL
E; N/EL
E; N/EL
E; N/EL
E; N/EL
6.5. Transport by motorbikes, passenger cars
and commercial vehicles
CCM
6.5/ CCA
6.5
0
0.0%
EL
EL
N/EL
N/EL
N/EL
N/EL
-
0.9%
7.7. Acquisition and ownership of buildings
CCM 7.7/
CCA 7.7
535
0.1%
EL
EL
N/EL
N/EL
N/EL
N/EL
-
10.5%
8.1. Data processing, hosting and related
activities*
CCM
8.1/ CCA
8.1
0
0 %
EL
EL
N/EL
N/EL
N/EL
N/EL
0%
8.2. Computer programming, consultancy
and related activities* CCA 8.2
0
0 %
N/EL
EL
N/EL
N/EL
N/EL
N/EL
0%
CapEx of Taxonomy-eligible but not environmentally
sustainable activities (not Taxonomy-aligned activities)
(A.2)
0
0%
0%
0%
0%
0%
0%
0%
0%
CapEx of Taxonomy-eligible activities (A.1 + A.2)
0
0%
0%
0%
0%
0%
0%
0%
0%
B. TAXONOMY NON-ELIGIBLE ACTIVITIES
CapEx of Taxonomy-non-eligible activities 681 433
99.92%
TOTAL 681 968
100%
* Activities under “6.5. Transport by motorbikes, passenger cars and commercial vehicles“, “8.1. Data processing, hosting and related activities” and “8.2.
Computer programming, consultancy and related activities” have been recognized as not associated with any CapEx dedicated separately to them.
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* Activities under “6.5. Transport by motorbikes, passenger cars and commercial vehicles“, “7.7 Acquisition and ownership of buildings”, “8.1. Data processing,
hosting and related activities” and “8.2. Computer programming, consultancy and related activities” have been recognized as not associated with any OpEx
dedicated separately to them.
Proportion of OpEx from products or services associated with Taxonomy-aligned economic activities – disclosure
covering year 2025 (NOK 1000)
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 18 19 20
Financial year: 2025
Substantial
contribution criteria
DNSH criteria (“Does
Not Significant Harm”)
Proportion of taxonomy -aligned (A.1) or
-eligible (A.2) OpEx, year 2024
Category enabling activity
Category transitional activity
Economic activities
Code(s)
OpEx
Proportion of OpEx, year 2025
Climate change mitigation
Climate change adaptation
Water
Pollution
Circular economy
Biodiversity
Climate change mitigation
Climate change adaptation
Water
Pollution
Circular economy
Biodiversity
Minimum safeguards
Tex t
NOK 1000
%
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y; N; N/EL
Y/ N
Y/ N
Y/ N
Y/ N
Y/ N
Y/ N
%
E
T
A. TAXONOMY-ELIGIBLE ACTIVITIES
A.1. Environmentally sustainable activities (Taxonomy-aligned)
none
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
OpEx of environmentally sustainable activities
(Taxonomy-aligned) (A.1)
0
0%
0%
0%
0%
0%
0%
0%
-
-
-
-
-
-
-
0 %
of which enabling
0
0%
0%
0%
0%
0%
0%
0%
-
-
-
-
-
-
-
0 %
E
of which transitional
0
0%
0%
0 %
T
A.2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)
E; N/EL
E; N/EL
E; N/EL
E; N/EL
E; N/EL
E; N/EL
6.5. Transport by motorbikes, passenger cars
and commercial vehicles*
CCM 6.5/
CCA 6.5
0
0%
EL
EL
N/EL
N/EL
N/EL
N/EL
-
0 %
7.7. Acquisition and ownership of buildings*
CCM 7.7/
CCA 7.7
7.1
0.1%
EL
EL
N/EL
N/EL
N/EL
N/EL
-
0.1 %
8.1. Data processing, hosting and related
activities*
CCM 8.1/
CCA 8.1
0
0 %
EL
EL
N/EL
N/EL
N/EL
N/EL
0 %
8.2. Computer programming, consultancy
and related activities* CCA 8.2
0
0 %
N/EL
EL
N/EL
N/EL
N/EL
N/EL
0 %
OpEx of Taxonomy-eligible but not
environmentally sustainable activities (not
Taxonomy-aligned activities) (A.2)
0
0%
0%
0%
0%
0%
0%
0%
0 %
OpEx of Taxonomy-eligible activities (A.1 +
A.2)
0
0%
0%
0%
0%
0%
0%
0%
0 %
OpEx of Taxonomy-non-eligible activities 9 395
99.92%
TOTAL 9 402
100%
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Row Nuclear energy related activities LINK’s answer
1
The undertaking carries out, funds or has exposures to research, development,
demonstration and deployment of innovative electricity generation facilities that
produce energy from nuclear processes with minimal waste from the fuel cycle.
NO
2
The undertaking carries out, funds or has exposures to construction and safe operation
of new nuclear installations to produce electricity or process heat, including for the
purposes of district heating or industrial processes such as hydrogen production, as
well as their safety upgrades, using best available technologies.
NO
3
The undertaking carries out, funds or has exposures to safe operation of existing
nuclear installations that produce electricity or process heat, including for the purposes
of district heating or industrial processes such as hydrogen production from nuclear
energy, as well as their safety upgrades.
NO
Row Fossil gas related activities LINK’s answer
4
The undertaking carries out, funds or has exposures to construction or operation of
electricity generation facilities that produce electricity using fossil gaseous fuels.
NO
5
The undertaking carries out, funds or has exposures to construction, refurbishment,
and operation of combined heat/cool and power generation facilities using fossil
gaseous fuels.
NO
6
The undertaking carries out, funds or has exposures to construction, refurbishment
and operation of heat generation facilities that produce heat/cool using fossil gaseous
fuels.
NO
Nuclear and fossil gas related activities
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2.2. [ESRS E1]
2.2.1. [E1-1] Transition plan for climate change mitigation
LINK has so far not adopted a transition plan for climate change mitigation. Hence, detailed datapoints
related to the transition plan have been omitted. LINK will consider adopting a transition plan by 2026,
which corresponds with its plans to adopt Science Based Targets by that time.
2.2.2. [E1.SBM-3] Material impacts, risks and opportunities and their
interaction with strategy and business model
Description of climate-related risks has been included in chapter 1.1.10.1. The climate-related material
risks that have been identified are related to the sustainability matters “Climate change-mitigation” and
“Energy”, and include only transition risks.
The general description on the resilience of LINK’s strategy and business model regarding material
IROs has been included in chapter 1.1.10.3. Moreover, the climate-related resilience analyses and
deliberation on potential LINK’s response, formed last step of the scenario analyses, as described in
chapter 1.1.11.9. The scope and time horizons were the same for all steps of the scenario analyses.
During the process, the potential effects of different conditions in the three scenarios, LINK’s resilience
and potential response to them, were briefly analysed. The goal was to answer the question “What might
be the consequences of climate change to LINK, how is LINK resilient to them, and how it could respond
to them?”. The analyses are presented in a table below.
Scenario Scenario 1
-inspired by the IEA’s
Stated Policies Scenario
(STEPS)
Scenario 2
-inspired by the IEA’s
Announced Pledges Scenario
(APS)
Scenario 3
-inspired
by the IEA’s
Net Zero
Emissions
by 2050
Scenario
(NZE
Scenario)
What may
be most
considerable
consequences
for LINK?
• Need of ensuring
regulatory compliance
with current requirements.
• Need of taking energy
consumption, energy
mix and carbon footprint
into consideration in
own operations and
procurement.
• Need of having business
continuity plans.
• Need of engaging in
relevant training and
marketing activities.
• Need of participating
in various climate-
related initiatives and
benchmarks.
• Need of ensuring regulatory
compliance with strengthened
requirements.
• Need of meeting energy and
emissions’ targets.
• Need of implementing energy
consumption, energy mix
and carbon footprint targets
into own operations and
procurement.
• Need of having business
continuity plans.
• Need of engaging in relevant
training and marketing
activities.
• Need of participating in
various climate-related
initiatives and benchmarks.
The same as
in Scenario 2
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Scenario Scenario 1
-inspired by the IEA’s Stated
Policies Scenario (STEPS)
Scenario 2
-inspired by the IEA’s
Announced Pledges
Scenario (APS)
Scenario 3
-inspired
by the IEA’s
Net Zero
Emissions
by 2050
Scenario
(NZE
Scenario)
How is LINK
resilient to such
consequences?
•LINK has taken steps to ensure
adequate response to the
current regulatory requirements
(implementing policies, GHG
reporting, participation in the
UNGC, SBTi etc.).
• LINK would need
to ensure additional
resources to
adequately respond
to strengthened
regulatory
requirements.
• LINK’s resilience
also depends on
effective management
of its value chain.
• LINK
would need
to ensure
additional
resources
to meet
ambitious
emission
and energy
related
targets.
• LINK’s
resilience
also depends
on effective
management
of its value
chain.
What may be
LINK’s strategy
response
to such
consequences?
• Developing current strategy,
following ESG maturity path.
• Continuous work on the GHG
report.
• Developing Science Based
Targets.
• Changing the
strategy in order
to meet ambitious
emissions- and energy
related targets.
• Allocating additional
resources to climate-
related issues.
• Continuous work on
the GHG report.
• Developing Science
Based Targets.
The same as
in Scenario 2
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Scenario Scenario 1
-inspired by the IEA’s Stated Policies
Scenario (STEPS)
Scenario 2
-inspired by the IEA’s
Announced Pledges
Scenario (APS)
Scenario 3
-inspired
by the IEA’s
Net Zero
Emissions
by 2050
Scenario
(NZE
Scenario)
Actions
/potential or
actual/
• Including energy and carbon
related matters in the ESG Policy.
• Preparing GHG report.
• Participation in the United Nations
Global Compact (UNGC).
• Developing environmental goals
within the Science Based Targets
Initiative (SBTi).
• Employees’ training on the
environmental issues.
• Energy consumption/ energy
mix/ carbon footprint taken into
consideration in procurement
(Supplier Due Diligence).
• Energy consumption/ energy
mix/ carbon footprint taken into
consideration in own operations
(product development, data
storage).
• Business continuity plans.
The same as in
Scenario 1 +
• Implementing
technologies allowing
reductions in energy
consumption.
• Purchase of larger
share of energy from
renewable sources
(“greener” energy
mix).
• Allocating additional
resources to climate
issues.
The same as
in Scenario 2
Targets
/potential or
actual/
• GHG report in place.
• Targets developed within Science
Based Targets initiative.
• GHG report in place.
• “Greener” energy
mix.
• Reduction in energy
consumption.
• Reduction in GHG
emissions.
• Targets developed
within Science Based
Targets initiative.
The same as
in Scenario 2
2.2.3. [E1-2, MDR-P] Policies related to climate change mitigation and
adaptation
Impacts, risks and opportunities related to climate change are managed under LINK’s ESG policy, which
includes a chapter “LINK Mobility’s approach to Environmental Factors”. The ESG policy is described in
chapter 4.1.1.1. The public version of the policy is available online: https://www.linkmobility.com/legal/
sustainability/esg-policy
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No Action Metric Target
1
GHG reporting
• created with an aim to calculate
LINK’s climate impact, based
on the principles included in the
Greenhouse Gas Protocol (GHGP)
• covers emissions from Scope 1
and Scope 2 sources, as well as- to
a limited extent- from Scope 3
• has been published annually
for several years
Including Scope 1 and
Scope 2 in the GHG report
• reflects LINK’s progress
towards calculating climate
impact from own activities,
based on the principles
included in the Greenhouse
Gas protocol (GHGP)
• the metric of a qualitative
nature, with [yes/no] values
“YES” as of December
31st each yeart
• monitored on annual bases
• related to certain
objectives set out in the
“E” part of the ESG Policy
Including Scope 3 in
the GHG report
• reflects LINK’s progress
towards calculating climate
impact from its value chain,
based on the principles
included in the Greenhouse
Gas Protocol (GHGP)
• the metric of a qualitative
nature, with [yes/no] values
“YES” as of December
31st each year
• monitored on annual bases
• related to certain
objectives set out in the
“E” part of the ESG Policy
LINK’s ESG policy addresses a variety of sustainability matters, including e (1) EU Taxonomy, (2) energy,
(3) climate change, and (4) waste management. During the materiality assessment conducted in 2024,
two sustainability matters related to the environment have been assessed as material i.e.: “Climate
change mitigation” and “Energy”.
2.2.4. [E1-3, MDR-A, MDR-M, MDR-T] Actions and resources in relation to
climate change policies
All actions relevant for the IROs related to each of the material matter are listed in a table included
in chapter 1.1.10.2. The main actions related to the climate change-related IROs, together with their
corresponding metrics and targets, are described in a table below. The described actions are of a basic,
initial character. No further, detailed analyses regarding decarbonisation and GHG emission reductions
have been conducted so far. Hence, the related datapoints, included under this disclosure requirement,
have been assessed as not material.
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No Action Metric Target
2
Participation in the Science Based Targets initiative
• created with an aim to calculate LINK’s climate
impact, based on the principles included in
the Greenhouse Gas Protocol (GHGP)
• covers emissions from Scope 1 and Scope 2
sources, as well as- to a limited extent- from Scope 3
• has been published annually for several years
Setting targets within
the SBT initiative
• reflects LINK’s
progress towards
defining quantitative
climate-related targets
• the metric of a
qualitative nature,
with [yes/no] values
“YES” as of December
31st each year
• monitored on
annual bases
• related to certain
objectives set out
in the “E” part of
the ESG Policy
The actions have been implemented in the course of a day-to-day business with no separate resources
allocated to them. No further analyses regarding significant CapEx and OpEx have been conducted. No
significant CapEx or OpEx necessary to implement the proposed actions is recognized at the moment.
Hence, the related datapoints, included under this disclosure requirement, have been assessed as not
material. Moreover, no actions have been taken to provide for or cooperate in or support provision of
remedy, as no harmed ones by actual material impacts have been identified.
All metrics are monitored internally. They have not been validated by an external body so far.
All targets apply to the period, for which LINK’s strategy is set, that is until 2028. The baseline is defined
to 2024. No milestones or interim targets have been set. The targets were set out based on the internal
expertise. Stakeholders were not directly involved.
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No Metric
Performance against target Target
2024 2025 2028
1 Including Scope 1 and Scope 2 in the GHG report YES YES YES
2 Including Scope 3 in the GHG report YES YES YES
3 Setting targets within the SBT initiative NO NO YES
LINK is not active in any of the high climate impact sectors and it has not yet set GHG emissions
reduction targets. The detailed datapoints, included under the related disclosure requirement, have
been assessed as not material.
LINK intends to set its climate-related targets in line with its schedule for participation in the Science
Based Targets initiative, for which it submitted the commitment letter in 2024. More information is
provided in chapter 2.2.4.
2.2.5. [E1-4, MDR-T] Targets related to climate change mitigation and
adaptation
LINK tracks effectiveness of its climate-related policies and actions by assessing them against the
targets, with the use of relevant metrics, which are described in chapter 2.2.4. Progress in implementing
the actions, measured by the performance against the disclosed targets, is presented in a table below.
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2.2.6. [E1-5] Energy consumption and mix
2.2.6.1. Datapoints on the energy consumption related to own operations
LINK is active in the “Information and Communication” sector, as listed in NACE Section J. Its energy
consumption results mainly from the office operations, the use of data centres/ servers, the use of
company cars, and- to a minor degree- from stationary combustion. The energy consumption and mix is
presented in a table below, where 2024 constitutes a base year. The scope of data collection is the same
as for data on emissions, as explained in chapter 2.2.7 below.
The total energy consumption is the sum of the following: Scope 1 data, covering (1) stationary
combustion (natural gas) and (2) transportation, including diesel and petrol (gasoline), as well as Scope
2 data (location-based method), covering (1) electricity, steaming from offices, datacentres/ servers,
and BEVs, and (2) district heating /cooling. The total energy use has been disaggregated into the energy
coming from the renewable sources, nuclear sources and fossil fuels. Since LINK has no operations in
high climate impact sectors, the use of energy from fossil fuels has not been further disaggregated.
The calculation of the energy mix uses indirect data derived from several sources, with the main use of
AIB (Association of Issuing Bodies) . Due to the lack of certain data covering district heating/ cooling,
it was impossible to categorize the source of approximately 9.8 % of the total energy use. In cases
where such categorization was not possible, it was assumed that such energy comes from fossil fuels.
It must however be noted that the use of indirect sources, and further assumptions regarding 9.8 %
of the energy coming from unknown sources as the fossil energy, is associated with some level of
uncertainty. It should also be noted that estimation of energy mix of district heating is based on several
sources making the estimated share of renewables uncertain, since such sources may have different
approaches on how energy shares are calculated. Percentage of renewable energy associated with
Guarantees of Origin, is however disclosed in chapter 2.2.7.5 below.
LINK’s GHG report has been published on its corporate webpage: https://www.linkmobility.com/legal/
sustainability/ghg-report. The calculations are based on the principles, requirements and guidance
provided by the Green House Gas protocol, as prescribed by the ESRS.
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Energy consumption and mix
Comparative
[2024]
2025
(1) Fuel consumption from coal and coal products (MWh)
omitted (no
operations in
high climate
impact
sectors)
omitted (no
operations in
high climate
impact
sectors)
2) Fuel consumption from crude oil and petroleum products
(MWh)
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)
(6) Total fossil energy consumption (MWh) (calculated as the
sum of lines 1 to 5)
612.3 332.6
Share of fossil sources in total energy consumption (%) 50% 45%
(7) Consumption from nuclear sources (MWh) 122.0 107.2
Share of consumption from nuclear sources in total energy
consumption (%)
10% 15%
(8) Fuel consumption for renewable sources, including
biomass (also comprising industrial and municipal waste of
biologic origin, biogas, renewable hydrogen, etc.) (MWh)
17.2 6.0
(9) Consumption of purchased or acquired electricity, heat,
steam, and cooling from renewable sources (MWh)
474.6 291.4
(10) The consumption of self-generated non-fuel renewable
energy (MWh)
0 0
(11) Total renewable energy consumption (MWh) (calculated
as the sum of lines 8 to 10)
491.8 297.4
Share of renewable sources in total energy consumption (%) 40% 40%
Total energy consumption (MWh) (calculated as the sum of
lines 6, and 11)
1 226.1 737.2
2.2.6.2. Datapoints relevant to undertakings with operations in high climate impact sectors
LINK has no operations in any of the high climate impact sectors, as listed in NACE Sections A to H and
Section L (as defined in Commission Delegated Regulation (EU) 2022/1288). LINK does not produce
energy. The detailed datapoints related to such operations/ energy production have therefore been
assessed as not material and consequently- omitted.
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2.2.7. [E1-6] Gross Scopes 1, 2, 3 and total GHG emissions
2.2.7.1. Gross Scopes 1, 2, 3 and total GHG emissions
LINK’s GHG reporting includes Scope 1, 2 and Scope 3 emissions. The data on LINK’s GHG emissions,
and how each scope was included, is presented in a table below. The scope of the data and its limitations
have been explained in chapters 2.2.7.2 and 2.2.7.4 below.
Scope 1 data covers direct emissions related to (1) Stationary combustion and (2) Transportation. Since
LINK does not operate any installations that are subject to regulated Emission Trading Schemes (ETS),
no GHG emissions from regulated emission trading schemes have been identified.
Scope 2 data covers indirect emissions related to (1) Power consumption- office, (1) Power consumption-
data centres/ servers, (3) District heating /cooling, and (4) EV Vehicle. Both location-based and market-
based emissions have been calculated.
Scope 3 data covers activities LINK believes are the most significant sources of indirect emissions from
its value chain, namely: (1) Upstream emissions related to fuel consumption, (2) Business (air) travel,
(3) Employee commuting, (4) Purchased goods and services, which includes (a) IT equipment and (b)
SaaS/ cloud services, as well as (5) Waste generated in operations.
Compared to last year, an amendment has been made regarding data centre activity, which was
previously reported under scope 2. The re-assessment of that activity lead to the identification that LINK
does not have operational control over the reported data centres and this activity shall be considered
a service (SaaS). Such a re-assessment resulted in inclusion of the activity reported previously as data
centre under scope 3 (SaaS), and in adjusting 2024 numbers accordingly. Moreover, certain numbers
in a table below, previously wrongly reported under “Upstream transportation and distribution”, were
moved to “Fuel and energy related activities”.
LINK’s GHG report has been published on its corporate webpage: https://www.linkmobility.com/legal/
sustainability/ghg-report. The calculations are based on the principles, requirements and guidance
provided by the Green House Gas protocol, as prescribed by the ESRS.
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Retrospective
Milestones and target
years**
Base year*
Comparative
[2024]
N = 2025
% N/ N-1
2028
2030
(2050)
Annual % target /
Base year
Scope 1 GHG emissions
Gross Scope 1 GHG emissions
(tCO2eq)
n/a 67.1 27.5 41% n/a n/a n/a n/a
Percentage of Scope 1 GHG
emissions from regulated emission
trading schemes (%)
n/a 0% 0% - n/a n/a n/a n/a
Scope 2 GHG emissions
Gross location-based Scope 2 GHG
emissions (tCO2eq)
n/a
157.8
***
123.5 78% n/a n/a n/a n/a
Gross market-based Scope 2 GHG
emissions (tCO2eq)
n/a
191.2
***
135.2 71% n/a n/a n/a n/a
Significant scope 3 GHG emissions
Total Gross indirect (Scope 3) GHG
emissions (tCO2eq)
n/a
681.8
***
870.2 128% n/a n/a n/a n/a
1) Purchased goods and services n/a
197.4
***
338.4 171% n/a n/a n/a n/a
[optional]
incl. cloud computing and data
centre services
n/a
109.4
***
293.3 268% n/a n/a n/a n/a
2) Capital goods n/a 0 0 - n/a n/a n/a n/a
3) Fuel and energy-related activities
(not included in Scope 1 or Scope 2)
n/a 14.4 5.7 40% n/a n/a n/a n/a
4) Upstream transportation and
distribution
n/a 0 0 - n/a n/a n/a n/a
5) Waste generated in operations n/a 0.1 0.1 100% n/a n/a n/a n/a
6) Business traveling n/a 25 7.0 273.5 106% n/a n/a n/a n/a
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Retrospective
Milestones and target
years**
Base year*
Comparative
[2024]
N = 2025
% N/ N-1
2028
2030
(2050)
Annual % target /
Base year
7) Employee commuting n/a 212.9 252.5 119% n/a n/a n/a n/a
8) Upstream leased assets n/a 0 0 - n/a n/a n/a n/a
9) Downstream transportation n/a 0 0 - n/a n/a n/a n/a
10) Processing of sold products n/a 0 0 - n/a n/a n/a n/a
11) Use of sold products n/a 0 0 - n/a n/a n/a n/a
12) End-of-life treatment of sold
products
n/a 0 0 - n/a n/a n/a n/a
13) Downstream leased assets n/a 0 0 - n/a n/a n/a n/a
14) Franchises n/a 0 0 - n/a n/a n/a n/a
15) Investments n/a 0 0 - n/a n/a n/a n/a
Total GHG emissions
Total GHG emissions (location-
based) (tCO2eq)
n/a 906.7*** 1021.2 113% n/a n/a n/a n/a
Total GHG emissions (market-
based) (tCO2eq)
n/a 940.1 1032.9 110% n/a n/a n/a n/a
* Base year will be defined by 2026 as the latest, within the framework of the Science Based Targets initiative.
** Targets will be defined by 2026 as the latest, within the framework of the Science Based Targets initiative.
*** numbers amended
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2.2.7.2. Scope of the GHG emissions’ data and its disaggregation
Emissions were allocated using operational control as the consolidation approach. The GHG numbers
are based on data collected from entities that are covered by the scope of consolidation. The calculations
are based on material climate and energy data from LINK’s offices and activities, as described in detail in
a table below. Certain limitations result from the availability and materiality of the data. To some extent,
estimations have been made to address the missing data. Having in mind relatively homogenous nature
of LINK’s operations and its position in the value chain, as described under disclosure requirement
ESRS 2 SBM 1 (chapter 1.1.8), the information has not been further disaggregated by country, segment,
activity, subsidiary or GHG category, as that was found not needed for a proper understanding of LINK’s
GHG emissions and its impact on climate change. Similarly, the total GHG emissions have not been
further disaggregated showing their split across the value chain (Upstream, Own operations, Transport,
Downstream), as that was found not necessary for a proper understanding of LINK’s GHG emissions
and its impact on climate change.
Country Location LINK entity Inclusion Comments
Austria
Graz LINK Mobility Austria GmbH Included
Vienna BK Invest GmbH not mate-rial
No office, therefore
not material in total
emission profile
Vienna Simple SMS GMbH not mate-rial
No office, therefore
not material in total
emission profile
Bulgaria Sofia LINK Mobility Bulgaria EAD Included
Colombia
Medellin Atenea Mobile SAS Included Office with Kronos
Medellin Kronos Mobile SAS Included Office with Atenea
Denmark
Copenhagen All Danish entities Included
Kolding All Danish entities Included
Finland Helsinki All Finnish entities Included
France
Boulogne-
Billancourt
All French entities Included
Roanne All French entities Included
Germany
Hamburg LINK Mobility GmbH Included
Hamburg
GfMB Gesellschaft für
Mobiles Bezahlen
not mate-rial
No office, therefore
not material in total
emission profile
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Country Location LINK entity Inclusion Comments
Hungary Budapest LINK Mobility Hungary Kft. Included
Italy
Arezzo LINK Mobility Italia Srl Included
Belluno LINK Mobility Italia Srl Included
Bologna LINK Mobility Italia Srl Included
Milan LINK Mobility Italia Srl not material
Co-working space
leased, few staff,
therefore not material in
total emission profile
Rome LINK Mobility Italia Srl not material
Co-working space
leased, few staff,
therefore not material in
total emission profile
Turin LINK Mobility Italia Srl not material
No office, therefore
not material in total
emission profile
Mexico Mexico City
Pandora Mobile Group S de
R.L. de C.V.
Included
No office- only Scope
3 /Air Travel, IT
Equipment, and SaaS/
Netherlands Breukelen All Dutch entities Included
No office- only scope 3 /
electricty usage for data
centers/
Norway
Bergen All Norwegian entities Included
Oslo All Norwegian entities Included
Operations
team
N/A LINK Mobility Group ASA Included
Group level Saas/Cloud
services
Poland Gliwice LINK Mobility Sp.z.o.o Included
Portugal Porto
LINK Mobility Portugal,
Unipessoal LDA
Included
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Country Location LINK entity Inclusion Comments
North
Macedonia
Kumanovo
Link Mobility Development
Center DOOEL
Included
Kumanovo
Link Mobility Development
Center DOOEL
Included
Skopje
Tera Communications
DOOEL
Included
Romania Bucharest All Romanian entities Included
South Africa
Cape Town
SMSPortal Proprietary
Limited
Included New entity
Gauteng
Link Mobility South Africa
(PTY) Limited
not material
No office, therefore
not material in total
emission profile
Spain
Madrid LINK Mobility Spain S.L.U. Included
Castellon Net Real Solutions S.L. Included New company
Sweden Stockholm LINK Mobility AB Included
Switzerland Rorschach LINK Messaging AG Included No permanent office
UK
London LINK Mobility UK Limited Included
No permanent office -
only Scope 3 /Air Travel
and IT Equipment/
Doncaster Reach-Data Ltd. Included New company
Penryn
FireText Communications
Ltd
Included New entity
Bristol The SMS Works Ltd not material
No office, therefore
not material in total
emission profile
Edinburgh HSL Messaging Limited not mate-rial
No office, therefore
not material in total
emission profile
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2.2.7.3. Significant changes in definition of what constitutes reporting undertaking and
its value chain and their effect on year-to-year comparability of reported GHG
emissions
The scope of carbon reporting is the same as for the consolidated financial statements. Changes
compared to last year are explained in chapter 1.1.1. The main changes include acquisitions in the
United Kingdom and in South Africa.
Some amendments have also been made to the reporting of activity related to data centres, which is
explained in chapter 2.2.7.1.
2.2.7.4. Methodologies, significant assumptions and emissions factors used to calculate
or measure GHG emissions
Methodology and significant assumptions
LINK’s emissions are calculated based on the international standard known as the Greenhouse Gas
Protocol (GHGP). The standard has been developed for measuring and reporting greenhouse gases
and is based on private initiatives through the World Resource Institute (WRI) and the World Business
Council for Sustainable Development (WBCSD). The GHG protocol consists of an accounting modelling
that explains how the company can quantify its direct and indirect greenhouse gas emissions, and
distinguishes between direct and indirect emissions within three scopes:
• Scope 1: direct sources of GHG emissions that are owned or controlled by the company, such as fuel
for cars or heating energy from combustion processes.
• Scope 2: indirect emissions from purchased energy such as electricity and district heating/cooling,
as well as energy used in electric vehicles.
• Scope 3: other indirect emissions that lie along the value chain and therefore also within the
responsibility of the company, such as emissions from purchased goods and services. Emissions
related to the company's activities, but which occur from sources not owned or controlled by the
business. This includes, among other things, data equipment, office furniture, business flights, waste,
and goods transport.
LINK has calculated its climate impact from scope 1, scope 2 and scope 3 emissions. The emission
factors and sources used for calculating emission from electricity, district heating and combustion of
natural gas (for heat at office), use of other fossil energy sources and scope 3 related activities are
described below, in section “Emission factors and sources”.
Scope 1
• Transportation: emissions from ICE cars owned/leased by LINK are calculated on either the amount
of fuel used, or distance travelled. For distance travelled average WLTP emission factors (gCO2/
km) for cars sold in the EU (published by the European Environment Agency) have been used.
Emission related to EV cars is calculated based on total energy use times electricity emission factor
in respective country. Total energy use is calculated based on average energy use per km, and total
distance travelled.
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Scope 2
• Electricity consumption: GHG emissions from electricity consumption in each affiliate/country are
calculated based on country-specific emission factors, gathered and published by AIB (Association
of issuing bodies)¹² and other sources. Emission from the use of electricity is calculated with both
location-based and market based approach, in accordance with the GHG-protocol. AIB also provides
information on the split between the various energy sources for the given countries. This information
have been used to split energy into three categories: renewable (wind, sun, hydro etc.), nuclear and
fossil (gas, oil, coal etc.), to estimate respective shares of energy sources under scope 2, with both
the location-based and marked-based approach.
• Location-based method reflects the average emissions intensity of grids on which energy
consumption occurs (using mostly grid-average emission factor data).
• Market-based method reflects emissions based on the electricity that organizations have
chosen to purchase, often spelled out in contracts or instruments like Guarantees of Origin (GOs)
or Renewable Energy Certificates (RECs). For some countries market-based emission factors for
electricity are not available- in such cases the same emission factor is used in both methods.
• District heating and cooling: the emission factors for district heating and cooling are based on
specific data provided by each energy supplier and reported by different offices using this type of
energy. In some countries specific emission factors for district heating are missing, and therefore
the electricity emission factors have been used as a proxy to calculate emissions from district heat.
Scope 3
• For indirect emissions from activities classified under scope 3, different methods and sources have
been used, depending on respective activity and data availability. The below table disclose the full list
of the categories included and excluded from the inventory. Categories included are assumed to be
the most significant sources of scope 3 GHG-emissions from LINK. The remaining categories have
been assessed as not bringing any material emissions. Factors used to estimate scope 3 emissions
are presented below, in section “Emission factors and sources”.
It must be noted that estimated scope 3 emissions are generally uncertain, because of large variations
and uncertainties in emission factors used, which are usually based on several assumptions and
approximations.
¹² https://www.aib-net.org/
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Scope 3
category
Included
Type of data
/primary data?/
Emissions
primary data
Emissions
estimated (tCO2)
In total
(tCO2)
48.9 821.3 870.2
1
Purchased
goods and
services
YES- IT
equipment
Units
/No, emissions estimated
based on EPDs/
45.1 45.1
Cloud
computing
and data
centre
services
Yes
Primary data and
estimations based on
activity data
/Yes, some values are
primary data from supplier./
48.9 244.4 293.3
2 Capital goods
No - no new
machinery/
buildings/
vehicles (offices
are leased)
3
Fuel and
energy-related
activities not
included in
scope 1 and
2 (upstream
emis-sions)
Yes, partly-
upstream
emissions for
scope 1 activities
included
Estimated based on
consumption numbers
/No, estimates based on
consumption numbers/
5.7 5.7
4
Upstream
trans-portation
and distribution
Transportation
of IT equipment
included in
calculation in
category 1
Activity data: units of IT
equipment bought.
/No, see category 1/
5
Waste
generated in
operations
Yes
Estimated numbers
/No, values based on
reported waste numbers in
kg/
0.1 0.1
Disclosure of scope 3 data included/excluded and type of data used to estimate scope 3 emissions.
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6
Business
traveling
Yes
Estimated numbers based
on travel activity
/No, use of ICEC emission
calculator and trip data, and
factors from UK DESNZ./
273.5 273.5
7
Employee com-
muting
Yes
Estimated based on survey
data
/No, survey data/
252.5 252.5
8
Upstream
leased assets
not relevant
Emission related to use of
vehicles, data centers and
offices (leased) is included
in scope 1 and 2
9
Downstream
transportation
Not relevant -
10
Processing of
sold products
Not relevant -
11
Use of sold
prod-ucts
Not relevant -
12
End-of-life
treat-ment of
sold products
Not relevant -
13
Downstream
leased assets
No assets leased
to others
-
14 Franchises Not relevant -
15 Investments Not included -
Share of primary Scope 3 emissions 5.6 %
• For the waste disposal emission factors from Department for Energy Security and Net Zero (UK)
are used. When estimating emissions from procurement of IT equipment, the reported emissions
from suppliers/producers of IT equipment are used, together with the EPDs (Environmental Product
Declaration) where they exist. Air travel is calculated using ICAO (International Civil Aviation
Organization) emissions calculator (ICEC) for specified trips¹³. When trip is not specified, emissions
are calculated based on length, expressed as pkm (passenger km) and emission factor from
Department for Energy Security and Net Zero (UK). Emissions from commuting are based on survey
of travel/commuting habits and average emission factors for different modes of transportation.
Emissions related to server/data center services are either based on emissions provided by service
provider (i.e. primary data) or calculated based on reported energy use for data center/server services
purchased and used. Emission or energy data are reported by each affiliate/office and used to give
¹³ A detailed description of the methodology used in ICEC can be found here: Methodology ICAO Carbon Emissions Calculator_v13_Final.pdf
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an estimate of emissions from this type of services. When energy use is reported the same electricity
factor (location based) is used as when calculating emissions from electricity use at the office.
Emissions factors and sources
Emission factors and sources have been mostly derived from:
Scope 1 emissions:
• Norwegian Environment Agency
• European Environment Agency
• Transport and Environment initiative
Scope 2 emissions:
• AIB (Association of Issuing Bodies)
• JRC EU
• IRENA
• Fjernkontrollen.no
• Energiföretagen.se
• South Africa’s 2023 Grid Emission Factors Report
Scope 3 sources:
• Department for Energy Security and Net Zero (UK)
• European Environment Agency
• ICEC calculator- ICAO
• Product information of various devices (laptops, workstations, monitors, docking stations, handheld
devices, accessories and peripheral devices)
Energy mix:
• AIB
• IEA
• IEA DHC
• Finnish Energy
• Norsk Fjernvarme
• Energiföretagen
• ePURE
• miljodirektoratet.no
• energy providers
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1 Scope 1
a
Biogenic emissions of CO2 from
combustion or bio-degradation of biomass
not included in Scope 1 GHG emissions
Not relevant (no data on biogenic emissions
availa-ble).
2 Scope 2
b
% of contractual instruments, Scope 2
emissions
Purchase of electricity with Guarantees of
Origin by some of LINK’s offices results
in 40.3% share of such renewable energy
in the total scope 2 energy use (including
office, datacentres/server, DH/DC, but
excluding EV).
c
Type of contractual instruments, Scope 2
emissions
Guarantees of Origin
d
% of market-based Scope 2 GHG emissions
linked to purchased electricity bundled with
instruments
Not included (voluntary disclosure).
e
% of contractual instruments used for
sale and purchase of energy bundled with
attributes about energy generation in
relation to Scope 2 GHG emissions
Not included (no data regarding the
energy attributes of energy bundeled with
GoO; energy mix under disclosure E1-5 is
calculated based on AIB numbers.
f
% of contractual instruments used for
sale and purchase of unbundled energy
attribute claims in relation to Scope 2 GHG
emissions
See point b. above.
g
Types of contractual instruments used for
sale and purchase of energy bundled with
attributes about energy generation or for
unbundled energy attribute claims
Not relevant.
h
Biogenic emissions of CO2 from
combustion or bio-degradation of biomass
not included in Scope 2 GHG emissions
Not relevant (no data on biogenic emissions
available).
2.2.7.5. Specific disclosures related to Scope 1, Scope 2 and Scope 3
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3 Scope 3
% of GHG Scope 3 calculated using
primary data
Approximately 5.6%
i
Disclosure if why Scope 3 GHG emissions
category has been excluded
Scope 3 data covers activities LINK
believes are the most significant sources of
indirect emissions from its value chain. The
remaining categories have been excluded
based on this assumption, and the lack of
available data.
j
List of Scope 3 GHG emissions categories
included in inventory
(1) Business (air) travel, (2) Employee
commuting, (3) Purchased goods and
services, which includes (a) IT equipment
and (b) SaaS/ cloud services, (4) Waste
generated in operations, and (5) Upstream
transportation and distribution.
k
Biogenic emissions of CO2 from
combustion or bio-degradation of biomass
that occur in value chain not included in
Scope 3 GHG emissions
Not relevant (no data on biogenic emissions
available).
l
Disclosure of reporting boundaries
considered and calculation methods for
estimating Scope 3 GHG emissions
Described in chapter 2.2.7.4
GHG intensity per net
revenue
Comparative
[2024]*
N = 2025 N – 1 [2024]
Total GHG emissions
(location-based) per net
revenue (tCO2eq/1000
NOK)
0.00013
tCO2eq/1000
NOK
1021.2 / 7 083
tCO2eq/1000 NOK
889.3 / 6 993 807
tCO2eq/1000 NOK
Total GHG emissions
(market-based) per net
revenue (tCO2eq/1000
NOK)
0.00013
tCO2eq/1000
NOK
1032.9 / 7 083
tCO2eq/1000 NOK
940.0 / 6 993 807
tCO2eq/1000 NOK
2.2.7.6. Disclosures related to the GHG emissions intensity
Net revenue
Amount
[1000 NOK]
Line in the financial statement
(reference)
Net revenue used to calculate GHG intensity
7 083 091 Consolidated income statement
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3. Social information
LINK has assessed the following topics included in ESRS S1 and ESRS S4 as material:
• ESRS S1: Topic “Own workforce” – Sub-topic “Equal treatment and opportunities for all” – Sub-sub-
topic “Training and skills development”
• ESRS S4: Topic “Consumers and end users” – Sub-topic “Information-related impacts for consumers
and/or end-users” – Sub-sub-topic “Privacy”
No sustainability matters covered by ESRS S2, or ESRS S3 have been assessed as material.
Since LINK does not exceed on its balance sheet date the average number of 750 employees during
the financial year, it has decided to omit the information required by ESRS S1 and ESRS S4 respectively,
in accordance with Appendix C of ESRS 1, as allowed by the Norwegian law in the first 3 years of the
reporting (phase-in). Nevertheless, for each such material topic LINK discloses the required information
on relevant policies, actions, metrics and targets. Such an information is reported under disclosure
requirement ESRS 2 BP-2 (chapter 1.1.2.8).
The description of how LINK identified the scope of the sustainability reporting is provided under
disclosure requirements ESRS 2 IRO-2 (chapters 1.1.12.3 and 1.1.12.4).
4. Governance information
LINK has assessed the following topics included in ESRS G1 as material:
• ESRS G1: Topic “Business conduct” – Sub-topic “Corporate culture”
• ESRS G1: Topic “Business conduct” – Sub-topic “Protection of whistle-blowers”
• ESRS G1: Topic “Business conduct” – Sub-topic “Management of relationships with suppliers”
• ESRS G1: Topic “Business conduct” – Sub-topic “Corruption and bribery”
Hence, LINK reports in this chapter the disclosure requirements covered by G1-1, G1-2, G1-3 and G1-4,
alongside the minimum disclosure requirements covered by ESRS 2 MDR, relevant to each of the above
listed material topics. The disclosures E1.GOV-1 are included under ESRS 2 GOV-1.
Since no sustainability matters covered by ESRS G1-5 “Political influence and lobbying activities” and
G1-6 “Payment practices” have been assessed as material, the disclosure requirements G1-5 and G1-6
are not included.
The description of how LINK identified the scope of the sustainability reporting is provided under
disclosure requirements ESRS 2 IRO-2 (chapters 1.1.12.3 and 1.1.12.4).
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4.1. [ESRS G1]
4.1.1. [G1-1, MDR-P, MDR-A, MDR-M, MDR-T] Business conduct policies and
corporate culture
4.1.1.1. [MDR-P] Policies in place to manage material IROs related to business conduct
matters and how LINK fosters its corporate culture.
Business conduct matters, including- among others- notions related to corporate culture, are managed
under LINK’s ESG policy. It encompasses issues related to all material sustainability matters. Some
notions related to business conduct are also included in other LINK’s policies, as described in chapters
1.1.2.8.c and 4.1.1.3.c.
• ESG Policy
1. Key contents of the policy
LINK ESG policy reflects its approach to environmental, social and governance factors and covers a
wide range of topics that have been identified as the most relevant to the company. The choice of the
focus areas that are included in the policy, is based on the materiality assessment and due diligence
processes, as well as on the risk and opportunities identified within LINK’s risk management framework.
The policy describes general principles of the materiality assessment and due diligence processes, as
well as sets out- to a different extent and with certain exclusions- high-level objectives covering the
following sustainability matters:
• Environmental factors: EU Taxonomy, Energy, Climate change, Waste management;
• Social factors: Decent working conditions; Respect for Human Rights; Diversity, inclusion and
belonging; Engagement, training and development; Corporate culture; Data privacy; Information
security; Consumer interests; Science, technology and innovation;
• Governance Factors: Anti-corruption; Fair competition; Sanctions against certain countries, industries,
companies or individuals; Accounting, taxation and financial reporting; Compliance with laws;
Corporate governance; Whistleblowing.
• Moreover, the policy includes a separate chapter on a variety of issues related to its enforcement.
2. Scope of the policy or of its exclusions
LINK ESG policy has been adopted by the Board of Directors of LINK Mobility Group Holding ASA. The
policy applies to the Holding Company as well as to all its subsidiaries. It applies to all directors, officers,
managers, employees, as well as to consultants and contractors to the extent applicable. It covers own
operations of the Group, as well as- to a limited extent- its value chain.
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The policy covers a wide range of environmental, social and governance topics. Among others, the
following policies, statements and principles are incorporated as part of the ESG policy:
• Due Diligence Policy;
• Fundamental human rights and decent working conditions principles;
• Anti-slavery and human trafficking statement;
• Diversity Policy;
• Anti-Corruption and Anti-Bribery Policy;
• Antitrust Policy;
• Sanctions Policy;
• Environmental Policy.
The ESG policy has its limitations- separate policies cover certain other areas, such as:
• personal data protection/ privacy;
• information security;
• accounting, taxation and financial reporting;
• corporate governance;
• whistleblowing.
3. Most senior level in organisation that is accountable for implementation of the policy
The Global Leadership Team (GLT) has overall responsibility for the implementation of the ESG policy.
4. Third-party standards or initiatives that are respected through implementation of the policy
The following documents and frameworks form basis of LINK’s ESG policy (the extent to which the
policy is aligned with them is explained in the policy itself):
• UN Goals for Sustainable Development (“SDGs");
• UN Guiding Principles on Business and Human Rights (“UN Guiding Principles”);
• UN Global Compact;
• OECD Guidelines for Multinational Enterprises (“OECD Guidelines”);
• OECD Due Diligence Guidance for Responsible Business Conduct (“OECD DD Guidance”);
• European Sustainability Reporting Standards (“ESRS”);
• ISO 37301:2021.
5. Consideration given to interests of key stakeholders in setting the policy
Key stakeholders’ interests are taken into consideration during LINK’s materiality assessment and due
diligence processes that form basis for setting out and updating the ESG policy.
6. How the policy is made available to stakeholders
Full version of the ESG policy is available to all LINK employees through an internal system. A
whistleblowing channel is available to report any suspected, potential or actual breaches. All employees
must complete a compliance training annually that covers inter alia notions related to the ESG policy.
The public version of the policy is available on LINK’s webpage: https://www.linkmobility.com/legal/
sustainability/esg-policy.
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4.1.1.2. [MDR-A, MDR-M, MDR-T] Description of how LINK establishes, develops, promotes
and evaluates its corporate culture
The principal themes that are promoted and communicated as part of LINK’s corporate culture- mostly
through the Employee Code of Conduct- include notions related to the people (e.g. human rights, equality,
diversity etc.), LINK’s business (e.g. anti-corruption, conflict of interest, privacy, intellectual property,
environment etc.), as well as LINK’s business partners (e.g. gifts, hospitality etc.). The Code reflects
LINK’s values: United, Dedicated and Enthusiastic, and is based on the ten principles provided by the
United Nations (UN) Global Compact.
LINK establishes, promotes, and evaluates its corporate culture by implementing relevant policies, as
described above, and furthermore, by taking actions that are assessed against the targets with the use
of relevant metrics. All actions relevant for the IROs related to each of the material matter are listed in
a table included in chapter 1.1.10.2. The main actions related to the governance-related IROs, together
with their corresponding metrics and targets, are described in a table below.
No Action Metric Target
1
LINK Voice
• Implemented with an aim
to measure employees’
engagement, collect employees’
opinions and feedback
• available to all employees,
delivered by an external provider
• has been conducted
annually for several years
LINK Voice participation rate
• reflects the reliability of
the results of “LINK Voice”
employee engagement survey
• calculated as a percentage of
employees that took part in LINK
Voice in relation to all invited
employees (some exceptions refer
e.g. to long-time absences etc.)
75% as of December
31st each year
• monitored in an internal
electronic system on annual
bases (the year-end survey)
• available to all employees group-
wide (with minor exceptions)
• related to objectives set
out in LINK’s ESG Policy
Employee engagement score
• reflects employees’ engagement
in a workplace (people’s
connection and commitment
to the company and its goals)
• calculated in the external system
75 as of December 31st each year
• monitored in an internal
electronic system on annual
bases (the year-end survey)
• available to all employees group-
wide (with minor exceptions)
• related to objectives set
out in LINK’s ESG Policy
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No Action Metric Target
2
Promoting Employee Code of
Conduct among LINK’s workforce
• implemented with an aim to
raise employees’ awareness
on compliance issues, to
embed LINK’s core values and
to build ethical foundation
for LINK’s daily operation
• binding for all employees,
available in an internal system
• has been promoted on
a rolling bases for several
years, regularly revised
Percentage of non-handled
incidents of corruption/ bribery
• reflects LINK’s progress in
ensuring implementation of
a zero-tolerance approach
to corruption and bribery
• calculated as a percent of
incidents of corruption/ bribery
that have been reported/
discovered and not addressed, in
relation to all such incidents that
have been reported/ discovered
(addressing an incident means
taking up an action to investigate
it, and implementing adequate
measures to resolve it in
accordance with relevant laws
and regulations, LINK’s codes
of conduct and LINK’s values)
0% as of December
31st each year
• monitored on annual bases
• includes all incidents reported/
discovered group-wide
• related to certain objectives
set out in the ESG Policy, namely
“zero-tolerance approach”
to corruption and bribery (all
incidents of corruption/ bribery
shall be adequately addressed)
3
Whistleblowing channel
• Implemented with an aim to
provide LINK’s workforce with a
secure and anonymous channel
to raise their concerns, to enable
reporting of any suspected,
potential or actual breach of
applicable law, policies, codes
of conduct or LINK’s values
• available to all employees,
delivered by an external provider
• has been available
for several years
Percentage of non-handled
whistleblowers’ notifications
• reflects LINK’s progress in
handling whistleblowers’ reports
• calculated as a percentage of
whistleblowers’ reports that have
not been addressed, in relation
to all whistleblowers’ reports
(addressing a whistleblower’s
report means taking up an action
to investigate it in line with
LINK’s whistleblowing policy,
and implementing adequate
measures to resolve it in
accordance with relevant laws
and regulations, LINK’s codes
of conduct and LINK’s values)
0% as of December
31st each year
• monitored on annual bases
• includes all whistleblower’s
reports group-wide
• related to certain objectives
set out in the ESG Policy and
Whistleblowing Policy (no
whistleblowers’ report may
remain unaddressed)
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No Action Metric Target
4
Promoting Supplier
Code of Conduct among
LINK stakeholders
• implemented with an aim
to convey a clear message
of LINK’s expectations within
areas covered by the ESG
policy, to raise stakeholders’
awareness and to contribute
to improving sustainability
through LINK’s value chain
• aimed at all supply-side entities,
available on LINK’s webpage:
https://www.linkmobility.
com/legal/value-chain/
supplier-code-of-conduct
• has been available for several
years, regularly revised
Preparation of the
Transparency Report
• the report describes how
LINK fulfils its duties to carry
out, account for and provide
information on its supplier due
diligence practices, with focus
on fundamental human rights
and decent working conditions
• the report has been published
since 2023 (https://www.
linkmobility.com/legal/
sustainability/transparency-
report), and has been regularly
revised and updated
• metric of a qualitative
nature, with [yes/no] values
YES” as of December
31st each year
• monitored on annual bases
• reflects LINK’s progress towards
documenting processes related
to suppliers’ management and
ensuring compliance with the
Norwegian Transparency Act
5
Supplier Due Diligence process
(further information under
disclosure G1-2, chapter 4.1.2)
• implemented with an aim to
collect information on third
parties and to integrate the
principles of responsible business
conduct into the company’s
relation with various third parties
• ultimate goal is to include all
new supply-side entities, the
scope however varies depending
on the risk associated with
specific entities, based on
the chosen risk indicators
• has been implemented on
a rolling bases for several
years, regularly revised
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The described actions have been implemented in the course of a day-to-day business. No separate
financial resources have been allocated to them. Moreover, no actions have been taken to provide for or
cooperate in or support provision of remedy, as no harmed ones by actual material impacts have been
identified.
All metrics are monitored internally. They have not been validated by an external body so far.
All targets apply to the period, for which LINK’s strategy is set, that is until 2028. The baseline is defined
to 2024. No milestones or interim targets have been set. The targets were set out based on the internal
expertise. Stakeholders were not directly involved.
Progress in implementing the actions, measured by the performance against the disclosed targets, is
presented in a table below.
No Metric
Performance against target Target
2024 2025 2026
1 LINK Voice participation rate 95% 93% 75%
2 Employee engagement score 70 75 75
3
Percentage of non-handled incidents of
corruption/ bribery
0% 0% 0%
4
Percentage of non-handled
whistleblowers’ notifications
0% 0% 0%
5 Preparation of the Transparency Report YES YES YES
4.1.1.3. Mechanisms for identifying, reporting and investigating concerns about unlawful
behaviour or behaviour in contradiction of its code of conduct or similar internal
rules
LINK has implemented the Whistleblowing Policy and has provided the whistleblowing channel available
for all its workforce. The whistleblowing-related policies and actions are seen as a mechanism for
identifying, reporting and investigating concerns about the behaviour that contradicts or may contradict
the law, ethical standards, LINK’s codes or any LINK’s values. Detailed information on relevant policies,
actions, metrics and targets are described in chapters 4.1.1.1, 4.1.1.2, and 4.1.1.3.c.
a. Policies on anti-corruption or anti-bribery consistent with United Nations
Convention against Corruption (or timetable for their implementation)
LINK ESG Policy incorporates anti-corruption and anti-bribery policy and aims at ensuring consistency
with UN Convention against Corruption. In the future LINK will consider auditing relevant chapters of its
ESG policy to ensure the Convention is respected.
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b. Safeguards for reporting irregularities including whistleblowing protection
LINK has implemented the Whistleblowing Policy and has provided the whistleblowing channel available
for all its workforce. Detailed information on relevant policies, actions, metrics and targets are described
in chapters 4.1.1.1, 4.1.1.2, and 4.1.1.3.c.
c. Policies on protection of whistle-blowers (or timetable for their implementation)
As mentioned above, LINK has implemented the Whistleblowing Policy, which is regularly reviewed and
updated if needed. The policy is described below.
• Whistleblowing Policy
1. Key contents of the policy
LINK’s Whistleblowing Policy constitutes an implementation of the principles included in LINK’s ESG
policy and aims to provide a channel for all employees to safely and anonymously raise their concerns
by reporting any suspected, potential or actual breach of applicable law, any of LINK’s policies, codes of
conduct or LINK’s values.
2. Scope of the policy or of its exclusions
LINK’s Whistleblowing Policy applies to the Holding Company as well as to all its subsidiaries. It applies
to all LINK’s workforce, who can report incidents related to the Company’s own operations, as well as to
its value chain. The whistleblowing channel may be utilised for reporting of any misconduct, covering
also ESG matters.
3. Most senior level in organisation that is accountable for implementation of the policy
The Whistleblowing Policy was set up by the Chief People and Strategy Officer, who is part of the GLT, in
cooperation with the VP for Legal & Compliance, who reports directly to the CEO. It is the responsibility
of LINK’s HR team and Legal & Compliance team to make the whistleblowing channel available to all
employees through LINK’s internal communication channels.
4. Third-party standards or initiatives that are respected through
implementation of the policy
The following documents and frameworks form basis of LINK’s Whistleblowing Policy:
• Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the
protection of persons who report breaches of Union law (the “Whistleblower Directive”);
• the Norwegian Work Environment Act (its Chapter 2A regarding Whistleblowing, added 16th June
2017).
5. Consideration given to interests of key stakeholders in setting the policy
Key stakeholders’ interests are taken into consideration during LINK’s materiality assessment and due
diligence processes that form basis for setting out and updating all LINK’s policies.
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6. How the policy is made available to stakeholders
Full version of the Whistleblowing Policy is available to all LINK employees through an internal system.
A whistleblowing channel is available through the online system delivered by an external provider.
All employees must complete a compliance training annually that covers inter alia notions related to
whistleblowers.
d.Information on commitment to investigate business conduct incidents
LINK is committed to investigate business conduct incidents promptly, independently and objectively.
The relevant mechanisms are described in LINK’s ESG policy and Whistleblowing Policy, in chapters
4.1.1.1 and 4.1.1.3.c.
e. Policies with respect to animal welfare are in place
LINK has not implemented policies with respect to animal welfare as it has assessed this as not material
(LINK operates in a digital rather than physical world).
f. Information about policy for training within organisation on business conduct
LINK provides its employees’ with a training on a variety of ESG matters, including notions covered by
the Employee Code of Conduct. Detailed information on relevant policies, actions, metrics and targets
are described in chapter 1.1.2.8.b.
g. Disclosure of the functions that are most at risk in respect of corruption and
bribery
LINK has not conducted detailed analysis regarding specifically the identification of functions that are
most at risk in respect of corruption and bribery.
4.1.1.4. Entity is subject to legal requirements with regard to protection of whistleblowers
LINK is subject to the following legal acts concerning protection of whistleblowers:
• regulations that result from the Directive (EU) 2019/1937 of the European Parliament and of the
Council of 23 October 2019 on the protection of persons who report breaches of Union law (the
“Whistleblower Directive”);
• the Norwegian Work Environment Act (its Chapter 2A regarding Whistleblowing, added 16th June
2017).
• Detailed information on relevant policies, actions, metrics and targets are described in chapters
4.1.1.1, 4.1.1.2 and 4.1.1.3.
4.1.2. [G1-2] Management of relationships with suppliers
4.1.2.1. Policy to prevent late payments, especially to SMEs
LINK has not adopted a specific policy to prevent late payments, because it not identified a high risk
related to late payments. LINK endeavours to remunerate suppliers per the terms of the supplier
contract. Baring any dispute, payments are made on time. At the moment, LINK has no concrete plan to
adopt policy to prevent late payments.
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4.1.2.2. LINK’s approach to relationships with suppliers
LINK is committed to avoid causing adverse impacts on people, the environment and society in its daily
operations, as well as to avoid contribution to such adverse impacts in its relations with stakeholders,
including suppliers and business partners.
Within the process of providing its services, LINK depends on several groups of supply-side actors, as
described in chapter 1.1.8.3. Since 2021, certain actions have been taken up, aimed at identifying and
organizing LINK’s relations with suppliers, enabling the Company to act responsibly and to create added
value throughout its value chain. The Supplier Due Diligence (SDD) process that reflects an outward-
facing approach to risk management was designed in 2021 and has been implemented since 2022, with
an aim to integrate the principles of responsible business conduct into the company’s relation to various
stakeholders. The focus areas of the process include a variety of sustainability matters, covering inter
alia fundamental human rights and decent working conditions, as well as other areas such as data
privacy, anti-corruption and antitrust.
The process follows in principle the methodology proposed by the OECD Due Diligence Guidance
for Responsible Business Conduct, which reflects standards set up in the OCED Guidelines for
Multinational Enterprises. It also fulfils LINK’s obligation to carry out due diligence in accordance with
the Transparency Act that came into force in 2022. The framework is available to all LINK affiliates, with
a stepwise approach to ensure that categorization of risk level is performed before commitment.
General risk assessment within the SDD process
The actual and potential adverse impacts within LINK’s relations with suppliers and business partners
have been identified as part of the general risk assessment performed within the SDD process. The
assessed suppliers and business partner groups include the categories identified during the suppliers’
mapping (as described under in chapter 1.1.8.3). For all categories, apart from minor providers, the risk
has been assessed as “medium”. The general risk assessment process that was performed is shown
on the figure below.
Identification
of risks
within supply chain/
business partners
• based on
deliberations
from LINK’s risk
management
framework
• considers
corporate policies
• in accordance
with LINK’s risk
assessment
template
• separately for
each providers’
group (category)
• relevant for each
identified and
assessed risk
• used later for
the individual
providers’
assessment
• depending on
the value of risk
indicators
• used later for
the individual
providers’
assessment
Assessment
of each
identified risk
Formulation
of
risk indicators
Formulation
of
risk categories
OECD (2018), OECD Due Diligence Guidance for Responsible Business Conduct, OECD Publishing.
mneguidelines.oecd.org/OECD-Due-Diligence-Guidance-for-Responsible-Business-Conduct.pdf
OECD (2018), OECD Due Diligence Guidance for Responsible Business Conduct, OECD Publishing.
mneguidelines.oecd.org/OECD-Due-Diligence-Guidance-for-Responsible-Business-Conduct.pdf
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During the general risk assessment performed within the SDD process, certain risk indicators were
chosen, that are later used for the assessment of individual providers. Such indicators cover the
following areas:
• type of a provider (suppliers’/ business partners’ group);
• geographical location of a provider;
• characteristics of personal data processing;
• total value of all contracts with a provider in the financial year.
Individual risk assessment within the SDD process
The scope of the SDD process depends on the individual provider’s risk assessment, during which
certain indicators are taken into account, as mentioned above. Depending on a type of vendor, its
characteristics, and the scope of cooperation, questionnaires are set out in order to identify and address
potential risk for the assessed suppliers/business partners.
4.1.2.3. Disclosure of how social and environmental criteria are taken into account for
selection of supply-side contractual partners
Depending on the risk category the individual provider is assigned to during the individual risk assessment
performed within framework of the Supplier Due Diligence process, different actions need to be
performed. The risk categories are based on criterions that include social (data processing, location in a
high risk country regarding corruption/ social indexes etc) and environmental (type of provider- hosting/
data storage) aspects, as outlined in chapter 4.1.2.2 above. The main tool used during the process is an
internal SDD questionnaire, where an employee that onboards a provider gets a checklist of tasks that
need to be performed before the contract is signed. The implemented measures include:
• Supplier Code of Conduct – implemented with the aim to raise stakeholders’ awareness; introduced
firstly in 2021, and applied ever since, it conveys a clear message of LINK’s expectations within areas
covered by ESG policy, and hence, it contributes to improving sustainability through LINK’s value chain;
• Employee Code of Conduct – implemented with the aim to raise employees’ awareness; has been a
part of the LINK DNA for multiple years, embedding LINK’s core values and building ethical foundation
for LINK’s daily operation;
• Employees training – implemented with the aim to raise employees’ awareness of various compliance
issues, including the required conduct towards third parties; privacy training (GDPR and InfoSec
training) has been obligatory for all LINK employees for several years now, and in 2021 the company
additionally launched a general compliance training, covering sustainability, anti-corruption, and
competition policies;
• SDD questionnaire – implemented with the aim to raise employees’ awareness of compliance issues,
and to collect relevant knowledge on third parties; acts as a primary guidance tool in the SDD process,
by instructing an employee on steps that should be performed when onboarding an individual provider,
depending on the associated risk that is assessed based on the embedded indicators (e.g. if a
provider is assessed as «high risk with red flags» the commitment must be deliberated and approved
on a higher authority level);
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• Contract measures – implemented with the aim to ensure a binding commitment of third parties to
adhere to standards set out in the Supplier Code of Conduct; application depends on the specificity
of particular contractual relationship;
• Privacy/ InfoSec questionnaires – implemented with the aim to mitigate risks related to the
processing of personal data in vendors’ systems; used for several years already.
The relevant actions, metrics and targets are also described in chapters 4.1.1.2.
4.1.3. [G1-3] Prevention and detection of corruption and bribery
4.1.3.1. Procedures in place to prevent, detect, and address allegations or incidents of
corruption or bribery
Issues related to corruption and bribery are addressed in LINK’s ESG policy, which includes a separate
chapter on anti-corruption and anti-bribery rules. Main actions in place include employees’ training
programme as well as promoting relevant codes of conduct (Employee Code of Conduct and Supplier
Code of Conduct). Moreover, in 2025 the Governance Incident Management Policy was introduced. The
whistleblowing channel, the contact form on LINK’s webpage, and other forms of contact may be used
for reporting any incidents. The description of the ESG Policy, as well as information on corresponding
actions, are provided in chapters 4.1.1.1, 4.1.1.2, 4.1.1.3.
a. Investigators or investigating committee are separate from chain of
management involved in prevention and detection of corruption or bribery
Prevention and detection of corruption and bribery lies under the responsibility of LINK managers in their
respective functional areas. Whistleblowing channel, contact form on LINK’s webpage, and other forms
of contact, are available to enable anonymous or non-anonymous reporting of any non-compliance. All
reports are managed in line with the Governance Incident Management Policy. The incidents detected
through the whistleblowing channel are managed by the Integrity Audit Committee that is composed
of persons not involved in the daily operations of commercial areas in which corruption and bribery
incidents may arise.
b. Process to report outcomes to administrative, management and supervisory
bodies
All governance reports, including the ones related to corruption and bribery, are managed in line with
the Governance Incident Management Policy. Depending of the nature of the information (negligeable,
event, incident), the process includes reporting to L&C Team, GLT, CEO and/or Integration Committee.
If corruption or bribery is reported through the Whistleblowing channel, reporting to administrative,
management and supervisory bodies is managed depending on each case. If it does not include
elements that might prevent such information, the Integrity Audit Committee shall inform CEO as part
of the investigation process, and the Board of Directors shall be informed on any incidents of corruption
or bribery by the CEO.
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4.1.3.2. Information about how policies are communicated to those for whom they are
relevant (prevention and detection of corruption or bribery)
LINK’s ESG policy, that incorporates inter alia the anti-corruption and anti-bribery policy, is adopted by the
Board of Directors and communicated to all LINK’s workforce through internal electronic systems. The
compliance training relevant to the policy is provided, and must be completed annually by all employees.
The policy is described in chapter 4.1.1.1.
4.1.3.3. Nature, scope and depth of anti-corruption or anti-bribery training programmes
The general compliance training that covers notions of LINK’s ESG policy, including a part on anti-
corruption and anti-bribery, is provided to all employees and is revised annually. The action is described
in chapter 1.1.2.8.b.
a. Percentage of functions-at-risk covered by training programmes
All LINK employees (100%) must complete the general compliance training and revise it annually.
b. Members of administrative, supervisory and management bodies relating to
anti-corruption or anti-bribery training
All GLT members, including CEO, must complete the general compliance training and revise it annually.
4.1.3.4. Analysis of LINK’s training activities related to anti-corruption and
anti-bribery
The general compliance training, covering part on anti-corruption and anti-bribery, is provided via a
dedicated electronic system to all LINK employees. Participants are able to rate the training and give
feedback. The content of the training is revised annually and it is annually repeated by all employees.
The Company monitors the completion rate for the training by country and in total through an electronic
system, in which the training is provided. In case the training is not completed by a particular employee,
they get adequate reminders electronically, and later their supervisors are informed. Further disciplinary
actions are decided individually on ad hoc basis. The action and relevant metrics and targets are
described in chapter 1.1.2.8.b.
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4.1.4. [G1-4] Incidents of corruption or bribery
4.1.4.1. Action plans and resources to manage material IROs related to corruption and
bribery
LINK has implemented the ESG Policy with a dedicated chapter on anti-corruption and anti-bribery.
The ESG policy is described in chapter 4.1.1.1. The actions taken to manage material IROs related to
corruption and bribery are listed in a table included in chapter 1.1.10.2. These actions are assessed
against the targets with the use of relevant metrics, as described in chapters 1.1.2.8.b and 4.1.1.2.
4.1.4.2. Numerical indicators related to incidents related of corruption and bribery
In 2025 LINK did not detect any cases related to corruption or bribery.
• Number of convictions for violation of anti-corruption and anti- bribery laws: 0
• Amount of fines for violation of anti-corruption and anti- bribery laws: 0
• Number of confirmed incidents of corruption or bribery: 0
• Information about nature of confirmed incidents of corruption or bribery: no incidents
• Number of confirmed incidents in which own workers were dismissed or disciplined for corruption or
bribery-related incidents: 0
• Number of confirmed incidents relating to contracts with business partners that were terminated or
not renewed due to violations related to corruption or bribery: 0
• Information about details of public legal cases regarding corruption or bribery brought against
undertaking and own workers and about outcomes of such cases: no such public legal cases
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Oslo, April 28, 2026
The Board of Directors of LINK Mobility Group Holding ASA
Andre Alexander Christensen
Chairman of the board
Grethe Helene Viksaas
Board Member
Sara Katarina Murby Forste
Board Member
Thomas Martin Berge
Chief Executive Officer
Per Kristian Hove
Board Member
Financial statements
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Board of Directors report
We confirm that, to the best of our knowledge, the Board of Directors report has been prepared in
accordance with the Norwegian Accounting Act and that it gives a true and fair view of the development,
performance and financial position of the Company and the Group including a description of the principle
risks and uncertainties that they face.
Sustainability statements
We confirm that, to the best of our knowledge, the sustainability statements are prepared in compliance
with the Norwegian Accounting Act including compliance with European Sustainability Reporting
Standards (ESRS) and Article 8 of EU Regulation 2020/852 (the EU Taxonomy Regulation). In our
opinion, the Sustainability Statements give a true and fair view of the Group’s sustainability performance
in accordance with the stated reporting requirements.
Financial statements
We confirm that, to the best of our knowledge, the consolidated financial statements for the year ended
December 31, 2025 have been prepared in accordance with IFRS® Accounting Standards as adopted
by the EU and the additional requirements of the Norwegian Accounting Act, and that the financial
statements for the parent company for the year ended December 31, 2025 have been prepared in
accordance with IFRS® Accounting Standards as adopted by the EU, that they give a true and fair view
of the Company’s and Group’s assets, liabilities, financial position and results of operations, and that
the Report of the Board of Directors gives a true and fair review of the development, performance, and
financial position of the Company and the Group and includes a description of the principal risks and
uncertainties that they face.
ESEF regulation
We confirm that, to the best of our knowledge, the annual report of LINK Mobility Group Holding ASA for
the financial year January 01 – December 31, 2025 with the file name: tel-2024-12-31-0-en.zip has been
prepared in compliance with the ESEF Regulation.
Responsibility
statement
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Andre Alexander Christensen
Chairman of the board
Per Kristian Hove
Board Member
Thomas Martin Berge
Chief Executive Officer
Grethe Helene Viksaas
Board Member
Sara Katarina Murby Forste
Board Member
April 28, 2026
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Consolidated income statement
For the period ended December 31
(Amounts in NOK 1000)
Note 2025 2024
Revenue 7 7,083,091 6,993,807
Total operating revenue 7,083,091 6,993,807
Direct cost of services rendered -5,389,124 -5,466,166
Payroll and related expenses 9 -587,848 -555,051
Other operating expenses 10 -387,910 -373,932
Depreciation and amortization 8, 14, 15 -400,373 -334,103
Total operating expenses -6,765,255 -6,729,253
Operating profit (loss) 317,836 264,555
Finance income and finance expenses
Net currency exchange gains (losses) 11 -83,522 36,678
Net interest expense 11 -106,393 -64,097
Net other financial income (expenses) 11 3,081 -15,951
Total finance income (expense) -186,835 -43,370
Profit (loss) before income tax 131,001 221,185
Income tax 23 -43,865 -49,641
Profit (loss) from continuing operations 87,136 171,544
Profit from discontinued operations 5 -2,491 84,025
Profit (loss) for the period 84,646 255,569
Profit attributable to:
Owners of the company 84,646 255,569
Earnings per share (NOK/share):
Basic earnings (loss) per share from total operations 12 0.28 0.86
Diluted earnings (loss) per share from total operations 12 0.28 0.83
Basic earnings (loss) per share from continuing operations 12 0.29 0.58
Diluted earnings (loss) per share from continuing operations 12 0.29 0.56
The accompanying notes are an integral part of these financial statements.
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Consolidated statement of Comprehensive Income
For the period ended December 31
(Amounts in NOK 1000)
Note 2025 2024
Profit (loss) for the period 84,646 255,569
Other comprehensive income
Items that may be reclassified to profit or loss
Translation differences of foreign operations 72,287 154,040
Reclassification of foreign currency
translation reserve (US subsidiary)
5 - -197,071
Gains and losses net investment hedge -4,560 -52,678
Tax on OCI that may be reclassified to P&L 1,003 11,589
OCI that may be reclassified to P&L 68,730 -84,120
Remeasurement of defined benefit pension plans 1,966 -1,821
OCI that will not be reclassified to P&L 1,966 -1,821
Other comprehensive income for the period 70,696 -85,941
Total comprehensive income for the period 155,342 169,628
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Consolidated statement of financial position
(Amounts in NOK 1000)
Note 2025 2024
ASSETS
Goodwill 14 5,388,390 4,673,114
Other intangible assets 14 2,730,898 1,762,119
Deferred tax asset 23 150,587 139,072
Equipment and fixtures 15 23,537 22,339
Right-of-use assets 8 18,763 29,924
Other non-current assets 16,517 6,870
Total non-current assets 8,328,692 6,633,438
Trade and other receivables 16, 19 1,604,323 1,610,024
Cash and cash equivalents 17, 19 1,032,212 2,478,701
Total current assets 2,636,535 4,088,725
TOTAL ASSETS 10,965,227 10,722,163
EQUITY AND LIABILITIES
Share capital 1,530 1,494
Share premium 6,131,023 5,952,203
Other reserves 573,124 490,148
Own shares -320,716 -344,574
Retained earnings (accumulated losses) -638,331 -721,011
Total equity 18 5,746,630 5,378,260
Liabilities
Long-term borrowings 19, 20 2,636,939 1,457,520
Lease liabilities 8, 19, 20 9,667 19,608
Deferred tax liabilities 23 288,496 256,480
Other long-term liabilities 215,311 10,037
Total non-current liabilities 3,150,414 1,743,645
Short-term borrowings 19, 20 14,152 2,019,655
Lease liabilities 8, 19, 20 10,760 11,948
Trade and other payables 19, 22 1,939,521 1,475,100
Income tax payable 23 103,751 93,554
Total current liabilities 2,068,184 3,600,257
Total liabilities 5,218,598 5,343,903
TOTAL EQUITY AND LIABILITIES 10,965,227 10,722,163
The accompanying notes are an integral part of these financial statements.
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Andre Alexander Christensen
Chairman of the board
Per Kristian Hove
Board Member
Thomas Martin Berge
Chief Executive Officer
Grethe Helene Viksaas
Board Member
Sara Katarina Murby Forste
Board Member
Consolidated statement of
financial position
Oslo, April 28, 2026
The Board of Directors of LINK Mobility Group Holding ASA
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Consolidated statement of Changes in Equity
For the period ended December 31
(Amounts in NOK 1000)
Note
Share capital
Own shares
Share premium
Other reserves
Retained earnings
(accumulated
losses)
Total equity
Balance at 01 January 2024 1,485 - 5,937,788 553,220 -978,401 5,514,093
Profit (loss) for the period - - - - 255,569 255,569
Other comprehensive
income (loss) for the
period, net of income tax
Total comprehensive
income for the period
Issue of ordinary shares 8 - 14,415 - - 14,423
Acquisition of treasury shares - -344,574 - - - -344,574
Share based payment 9 - - - 24,691 - 24,691
Balance at 31 December 2024 18 1,494 -344,574 5,952,203 490,148 -721,011 5,378,260
Balance at 01 January 2025 1,494 -344,574 5,952,203 490,148 -721,011 5,378,260
Profit (loss) for the period - - - - 84,646 84,646
Other comprehensive
income (loss) for the
period, net of income tax
Total comprehensive
income for the period
Issue of ordinary shares 36 - 178,820 - - 178,856
Distribution of treasury shares - 23,858 - - - 23,858
Share based payment 9 - - - 10,313 - 10,313
Balance at 31 December 2025 18 1,530 -320,716 6,131,023 573,124 -638,331 5,746,630
The accompanying notes are an integral part of these financial statements.
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Note 2025 2024
Cash flows from operating activities
Profit (loss) before income tax from continuing operations 131,001 221,185
Adjustments for:
Taxes paid -119,305 -95,260
Finance expense (income) 11 184,065 43,480
Depreciation and amortization 8, 14, 15 400,203 334,983
Share based payment expense 10,313 24,691
Net gain from disposals -4 -205
Change in trade and other receivables 15,631 110,419
Change in trade and other payables 62,653 -127,286
Change in other provisions 16,177 110,156
Net cash flows from operating activities from continuing operations 700,734 622,163
Cash flows from investing activities
Payment for equipment and fixtures 15 -7,637 -9,083
Payment for intangible assets 14 -198,676 -141,349
Payment for acquisition of subsidiary, net of cash acquired 6 -1,094,344 -182,894
Proceeds from sale of equipment and fixtures 4 170
Payment of earn-out -44,338 -
Purchase (disposal) of other investments -8,050 -
Net cash flows from investing activities from continuing operations -1,353,042 -333,156
Net cash flows from investing activities from discontinued operations 217,638 2,211,993
Cash flows from financing activities
Proceeds on issue of shares 23,858 14,423
Repayment of equity - -344,574
Other financial items 20 -8,146 -15,008
Proceeds from borrowings 20 1,162,331 1,463,856
Repayment of borrowings 20 -1,997,736 -2,212,376
Interest paid 8, 20 -137,208 -125,582
Principal elements of lease payments 8 -11,827 -14,734
Dividends received - -
Net cash flows from financing activities from continuing operations -968,729 -1,233,995
Effect of foreign exchange rate changes -43,091 103,464
Net change in bank deposits, cash and equivalents -1,446,489 1,370,470
Cash and equivalents at beginning of period 2,478,701 1,096,596
Cash and equivalents at beginning of the period (held for sale) - 11,636
Cash and equivalents at end of the period (held for sale) - -
Cash and equivalents at end of the period from continuing operations 1,032,212 2,478,701
The accompanying notes are an integral part of these financial statements.
Consolidated statement of cash flows
For the period ended December 31
(Amounts in NOK 1000)
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Notes to the financial statements for the period ended
December 31, 2025
1 Subsidiaries
2 Adoption of new and revised International Financial Reporting Standards (IFRS)
3 Summary of significant accounting policies
4 Critical accounting judgments and key sources of estimation variances
5 Discontinued operations
6 Business combinations
7 Segment reporting
8 Leases
9 Payroll and related expenses
10 Other operating expenses
11 Net finance and income expenses
12 Earnings per share
13 Transactions with related parties
14 Intangible assets
15 Equipment and fixtures
16 Trade and other receivables
17 Cash and cash equivalents
18 Share capital and shareholder information
19 Classes and categories of financial instruments
20 Interest-bearing liabilities
21 Financial instruments, risk management objectives, and policies
22 Trade and other payables
23 Income tax
24 Contingencies and legal claims
25 Events after the reporting date
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Note 1 Subsidiaries
the LINK subsidiaries. The Group’s subsidiaries as at 31 December 2025 are listed below.
Name of entity Date of
acquisition
Place of business /
country of registration
Ownership
interest
LINK Mobility Group AS 10/9/2018 Oslo, Norway 100 %
LINK Mobility AS 10/9/2018 Oslo, Norway 100 %
LINK Mobility USA AS 5/27/2021 Oslo, Norway 100 %
Tismi AS 7/1/2021 Oslo, Norway 100 %
BK Invest Alpha GmbH 11/16/2020 Vienna, Austria 100 %
LINK Mobility Austria GmbH 11/16/2020 Graz, Austria 100 %
Simple SMS GmbH 10/9/2018 Vienna, Austria 100 %
LINK Mobility Bulgaria EAD 7/29/2019 Sofia, Bulgaria 100 %
Atenea Mobile SAS 9/24/2024 Medellin, Columbia 100 %
Kronos Mobile SAS 9/24/2024 Medellin, Columbia 100 %
LINK Mobility Holding Aps 3/11/2020 Copenhagen, Denmark 100 %
LINK Mobility A/S 10/9/2018 Copenhagen, Denmark 100 %
LINK Mobility Oy 10/9/2018 Tampere, Finland 100 %
Labyrintti International Oy 10/9/2018 Tampere, Finland 100 %
LINK Mobility SAS 10/9/2018 Paris, France 100 %
LINK Mobility Holding SAS 11/2/2023 Paris, France 100 %
LINK Mobility GmbH 10/9/2018 Hamburg, Germany 100 %
GfMB Gesellschaft für Mobiles Bezahlen 10/9/2018 Hamburg, Germany 100 %
LINK Mobility Hungary Kft. 12/18/2018 Budapest, Hungary 100 %
LINK Mobility Italia Srl 10/9/2018 Milan, Italy 100 %
Pandora Mobile Group S de R.L. de C.V. 9/24/2024 Mexico City, Mexico 100 %
Tismi B.V. 3/10/2021 Breukelen, Netherlands 100 %
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Tismi Mobile B.V. 3/10/2021 Breukelen, Netherlands 100 %
LINK Mobility Sp.z.o.o 10/9/2018 Gliwice, Poland 100 %
Curiosity Layer - Investigacao e
Comunicacao, Unipessoal, LDA
5/29/2024 Porto, Portugal 100 %
LINK Mobility Development Center DOOEL 6/7/2021 Kumanovo, Republic of
North Macedonia
100 %
Tera Communications DOOEL 7/29/2019 Skopje, Republic of
North Macedonia
100 %
LINK Mobility SRL 10/2/2017 Bucharest, Romania 100 %
Teracomm RO SRL 7/29/2019 Bucharest, Romania 100 %
SMSPortal Proprietary Limited 11/28/2025 Cape Town, South Africa 100 %
LINK Mobility South Africa (PTY) Limited 7/21/2025 Gauteng, South Africa 100 %
LINK Mobility Spain S.L.U. 10/9/2018 Madrid, Spain 100 %
Net Real Solutions S.L. 9/24/2024 Castellon, Spain 100 %
LINK Mobility AB 10/9/2018 Stockholm, Sweden 100 %
LINK Messaging AG 10/9/2018 Rorschach, Switzerland 100 %
HSL Messaging Limited 11/14/2018 Edinburgh, Scotland 100 %
LINK Mobility UK Limited 12/14/2018 London, United Kingdom 100 %
Reach-Data Ltd. 10/30/2024 Doncaster, United Kingdom 100 %
The SMS Works Ltd. 4/1/2025 Bristol, United Kingdom 100 %
FireText Communications Ltd. 4/14/2025 Penryn, United Kingdom 100 %
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.Note 4 Critical accounting judgements and key sources of estimation
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Income Statement
For the period ended December 31
(Amounts in NOK 1000)
Note 2025 2024
Other operating expenses 6 -13,382 -10,564
Total operating expenses -13,382 -10,564
Operating loss -13,382 -10,564
Finance income and finance expenses
Net currency exchange gains (losses) -32,189 -16,550
Net interest expense -66,717 -40,540
Net other financial income (expenses) -27,138 -38,391
Total finance income 7 -126,044 -95,481
Profit before income tax -139,426 -106,046
Income tax 14 26,121 23,293
Profit for the period -113,305 -82,753
The accompanying notes are an integral part of these financial statements.
LINK Mobility Group Holding ASA
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Statement of financial position
(Amounts in NOK 1000)
December 31 December 31
ASSETS Note 2025 2024
Investment in LINK Mobility Group AS 5 8,151,807 8,141,494
Long-term receivables - intercompany 5 2,662,602 1,919,812
Total non-current assets 10,814,410 10,061,306
Prepaid expenses 1,390 1,553
Other short-term receivables 619 619
Deferred tax 14 49,566 23,445
Cash and cash equivalents 8, 10 73,489 1,203,718
Total current assets 125,064 1,229,336
TOTAL ASSETS 10,939,474 11,290,642
EQUITY AND LIABILITIES
Share capital 1,530 1,494
Share premium and other reserves 6,190,187 6,001,053
Own shares -320,716 -344,574
Retained earnings (accumulated losses) 1,234,527 1,347,832
Total equity 9 7,105,527 7,005,805
Liabilities
Long-term borrowings 11 2,636,939 1,457,521
Loans and borrowings - intercompany 1,182,307 805,193
Total non-current liabilities 3,819,246 2,262,714
Short-term borrowings 10, 11 14,152 2,019,655
Trade payables and other payables 10, 13 548 2,468
Current tax liabilities 14 - -
Total current liabilities 14,700 2,022,123
Total liabilities 3,833,946 4,284,837
TOTAL EQUITY AND LIABILITIES 10,939,474 11,290,642
The accompanying notes are an integral part of these financial statements.
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Statement of Comprehensive Income
For the period ended December 31
(Amounts in NOK 1000) 2025 2024
Profit (loss) for the period -113,305 -82,753
Other comprehensive income
Items that may be reclassified to profit or loss
Translation differences of foreign operations - -
Other comprehensive income for the period - -
Total comprehensive income for the period -113,305 -82,753
Statement of financial position
Oslo, April 28, 2026
The Board of Directors of LINK Mobility Group Holding ASA
Andre Alexander Christensen
Chairman of the board
Per Kristian Hove
Board Member
Thomas Martin Berge
Chief Executive Officer
Grethe Helene Viksaas
Board Member
Sara Katarina Murby Forste
Board Member
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Statement of Changes in Equity
For the period ended December 31
(Amounts in NOK 1000)
Note
Share
capital
Own
shares
Share
premium
Retained
earnings
(accumulated
losses)
Total
equity
Balance at January 01, 2024 1,485 - 5,961,948 1,430,585 7,394,018
Profit for the period - - - -82,753 -82,753
Other comprehensive income (loss)
for the year, net of income tax
- - - - -
Total comprehensive
income for the year
- - - -82,753 -82,753
Issue of ordinary shares 8 - 14,415 - 14,423
Treasury shares - -344,574 - - -344,574
Share based payment - - 24,691 - 24,691
Balance at December 31, 2024 9 1,494 -344,574 6,001,053 1,347,832 7,005,805
Balance at January 01, 2025 1,494 -344,574 6,001,053 1,347,832 7,005,805
Profit for the year - - - -113,305 -113,305
Other comprehensive income (loss)
for the year, net of income tax
- - - - -
Total comprehensive
income for the year
- - -113,305 -113,305
Issue of ordinary shares 36 - 178,820 - 178,856
Treasury shares - 23,858 - - 23,858
Share based payment - - 10,313 - 10,313
Balance at December 31, 2025 9 1,530 -320,716 6,190,187 1,234,527 7,105,527
The accompanying notes are an integral part of these financial statements.
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Statement of cash flows
For the period ended December 31
(Amounts in NOK 1000)
Note 2025 2024
Cash flows from operating activities
Profit before income tax -139,426 -106,046
Adjustments for:
Finance income (expense) 126,044 95,481
Changes in trade and other receivables - -619
Change in trade and other payables 10, 13 -1,920 1,252
Change in other provisions 48,429 181,547
Net cash flows from operating activities 33,128 171,615
Cash flows from investing activities
Net cash inflow, loan repayments from subsidiaries 922,596 4,295,965
Net cash (outflow), loan to subsidiaries -1,381,048 -2,847,405
Net cash (outflow) inflow, intercompany loan interest 47,307 24,071
Net cash flows from investing activities 5 -411,145 1,472,632
Cash flows from financing activities
Proceeds on issue of shares 9 23,858 14,423
Repayment of equity - -344,574
Other financial items - -15,008
Proceeds from borrowings 11 1,162,331 1,463,856
Intercompany debt, inflow 293,182 775,615
Repayment of borrowings 11 -1,997,736 -2,212,376
Intercompany debt, outflow -10,313 -11,589
Interest paid -131,859 -120,692
Intercompany interest paid -91,675 -58,600
Net cash flows from financing activities -752,212 -508,945
Net change in bank deposits, cash and equivalents -1,130,229 1,135,301
Effect of foreign exchange rate changes - -40
Cash and equivalents at beginning of period 1,203,718 68,456
Cash and equivalents at end of the period 73,489 1,203,718
The accompanying notes are an integral part of these financial statements.
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Notes to the financial statements for the period ended
31 December 2025
Contents notes
1 General information
2 Adoption of new and revised International Financial Reporting Standards (IFRSs)
3 Summary of significant accounting policies
4 Critical accounting judgments and key sources of estimation variances
5 Investment in subsidiaries
6 Other operating expenses
7 Net finance income and expenses
8 Cash and cash equivalents
9 Share capital and shareholder information
10 Classes and categories of financial instruments
11 Interest-bearing liabilities
12 Financial instruments, risk management objectives, and policies
13 Trade and other payables
14 Income tax
15 Contingencies and legal claims
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Note 1 General information
LINK Mobility Group Holding ASA owns 100% of LINK Mobility Group AS, which in turn owns 100% the
LINK subsidiaries. The Group’s subsidiaries as at December 31, 2025 are listed below.
Name of entity Date of acquisition
Place of business /
country of registration
Ownership
interest
LINK Mobility Group AS 12/6/2021 Oslo, Norway 100%
Note 2 Adoption of new and revised International Financial Reporting
Standards (IFRS)
Several amended IFRS Accounting Standards issued by the International Accounting Standards Board
(IASB) and interpretations issued by the IFRS Interpretations Committee (IFRS IC) became effective
for accounting periods commencing on or after January 01, 2025. The Company has applied the
relevant amendments from their effective date. The requirements arising from revised standards and
interpretations have been incorporated into the recognition, measurement and disclosure principles
applied in the consolidated financial statements. The accounting policies adopted are described in Note
3 – Summary of significant accounting policies.
Standards and interpretations affecting amounts reported in the current period
The accounting policies and methods of computation applied in 2025 are consistent with those applied
in the previous financial year. No new or amended standards effective from January 01, 2025 had a
material impact on the Company’s financial statements.
Standards and interpretations issued but not yet effective
At the date of authorization of these financial statements, certain new and amended standards and
interpretations had been issued by the IASB but were not yet effective for the financial year ended
December 31, 2025. These include:
- IFRS 18 Presentation and Disclosure in Financial Statements.
- Amendments to IFRS 9 and IFRS 7 – Classification and Measurement of Financial Instruments
The Company has commenced its assessment of the potential impact of these standards and
amendments. At this stage, the assessment is ongoing. IFRS 18 is expected to affect the presentation
and disclosure within the financial statements. The impact of the amendments to IFRS 7 and IFRS 9 is
being evaluated. The Company will finalize its assessment during 2026.
Management continues to monitor new and amended IFRS Accounting Standards and interpretations
issued by the IASB and will evaluate their impact on the Company’s financial reporting in future periods.
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3.1 General information
LINK Mobility Group Holding ASA is the parent company of LINK Mobility Group AS, and is headhquartered
in Oslo, Norway. LINK is Europe’s leading provider of mobile and CPaaS solutions specializing in
messaging, digital services, and intelligent data usage.
LINK Mobility Group Holding ASA (“the Company”) is a limited liability Company incorporated and
domiciled in Norway. The address of the registered office is Gullhaug Torg 5, 0484 Oslo, Norway. LINK
Mobility Group Holding ASA is the parent company of the LINK Mobility Group AS. LINK Mobility Group
AS provides services in mobile communication and specialises in mobile messaging services, mobile
solutions, and mobile intelligence. LINK Mobility Group Holding ASA and its subsidiaries are regarded
as “the Group”.
These financial statements were approved for issue by the Board of Directors on date April 28, 2026.
Minor rounding differences may be present, and the total may deviate from the total of the individual
amounts. This is due to the rounding of whole figures to thousands for presentation purposes.
3.2 Basis for preparation
The financial statements of the Company and the Group have been prepared in accordance with
IFRS® Accounting Standards as adopted by the EU and the Norwegian Accounting Act. The financial
statements have been prepared on the historical cost basis.
The preparation of financial statements in conformity with IFRSs requires the use of certain critical
accounting estimates. It also requires management to exercise its judgments in applying the Group’s
accounting policies. Areas involving a high degree of judgment or complexity, and areas in which
assumptions and estimates are significant to the financial statements are disclosed in Note 4 Critical
accounting judgements and key sources of estimation variances. The financial statements have been
prepared on a going-concern basis.
The presentation currency of the financial statement is Norwegian kroner (NOK). Amounts are rounded
to nearest thousand, unless otherwise stated.
An asset is classified as current when it is expected to be realised, or is intended for sale or consumption,
in the Company’s normal operating cycle, it is expected/due to be realised or settled within next twelve
month after the reporting date. The normal operating cycle for trade receivables is between 30 - 90 days.
Other assets are classified as non-current. A liability is classified as current when it is expected to be
settled in the Company’s normal operating cycle, the liability is due to be settled within twelve months
after the reporting period or if the Company does not have an unconditional right to defer settlement of
the liability for at least twelve months after the reporting period. The normal operating cycle for trade
payables is between 30 - 45 days. All other liabilities are classified as non-current.
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3.4 Foreign currency translation
The consolidated financial statements are presented in NOK, which is theCompany’s functional currency.
In preparing the financial statements of the individual companies, transactions in currencies other than
the entity’s functional currency are recognised at the rate of exchange on the date of the transaction.
At each reporting date, monetary assets and liabilities that are denominated in foreign currencies are
retranslated at the balance sheet date. Non-monetary items carried at fair value in foreign currencies
are translated using the exchange rate at the date when the fair value was measured. Non-monetary
items that are measured in terms of historical cost in a foreign currency are not retranslated after the
transaction date.
Foreign exchange gains and losses that relate to borrowings and cash and cash equivalents are
presented in the income statement as financial items. All other foreign exchange gains and losses are
presented on a net basis in the income statement as other operating expenses. Exchange differences
are recognised in the income statement in the period in which they arise.
For the purposes of presenting consolidated financial statements, the assets and liabilities of the
Company’s foreign operations are translated to NOK at exchange rates on the reporting date. Income
and expense items are translated to NOK at the average exchange rates for the period, unless
exchange rates fluctuate significantly during that period, in which case the exchange rates at the date
of transactions are used. Exchange differences arising, if any, are recognised in other comprehensive
income and accumulated in a separate component of equity.
3.5 Impairment of non-financial assets
At each reporting date, the Company reviews if there are any indicators that the carrying amounts of its
tangible and intangible assets may be impaired. If any such indication exists, the recoverable amount of
the asset is estimated to determine the extent of the impairment loss (if any). Where the asset does not
generate cash flows that are independent from other assets, the Company estimates the recoverable
amount of the cash-generating unit to which the asset belongs. When a reasonable and consistent basis
of allocation can be identified, corporate assets are also allocated to individual cash-generating units, or
otherwise they are allocated to the smallest group of cash-generating units for which a reasonable and
consistent allocation basis can be identified.
Recoverable amount is the higher of fair value less costs of disposal and value in use. In assessing value
in use, the estimated future cash flows are discounted to their present value using a pre-tax discount
rate that reflects current market assessments of the time value of money and the risks specific to the
asset for which the estimates of future cash flows have not been adjusted.
If the recoverable amount of an asset (or cash-generating unit) is estimated to be less than its carrying
amount, the carrying amount of the asset (or cash-generating unit) is reduced to its recoverable amount.
An impairment loss is recognised immediately in the income statement.
Where an impairment loss subsequently reverses, the carrying amount of the asset (or cash-generating
unit) is increased to the revised estimate of its recoverable amount, but so that the increased carrying
amount does not exceed the carrying amount that would have been determined had no impairment loss
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been recognised for the asset (or cash-generating unit) in prior years. A reversal of an impairment loss
is recognised immediately in profit or loss, unless the relevant asset is carried at a revalued amount, in
which case the reversal of the impairment loss is treated as a revaluation increase.
3.6 Financial Instruments
Financial assets and financial liabilities are initially measured at fair value. Transaction costs that are
directly attributable to the acquisition or issue of financial assets and financial liabilities (other than
financial assets and financial liabilities at fair value through profit or loss) are added to or deducted
from the fair value of the financial assets or financial liabilities, as appropriate, on initial recognition. The
Company has classified the financial instruments into the following categories of financial assets and
liabilities: Financial assets and liabilities at fair value through profit and loss (FVTPL), financial assets at
amortised cost (FAAC), financial assets at fair value through other comprehensive income (FVTOCI) and
Financial liability at cost (FLAC). Currently the Company does not have any assets in the classification
of FVTOCI.
The categorisation of financial instruments (financial assets and liabilities) for measurement purposes
is based on the nature and purpose of the financial instrument and is determined on initial recognition.
The Company presents financial assets and liabilities in the following classes: trade and other receivables
(FAAC), cash and cash equivalents, trade and other payables (FLAC), and borrowings (FLAC).
Trade receivables and other current and non-current financial assets
The financial assets held by the Company, primarily trade and other receivables, are held within a
business model whose objective is to hold financial assets in order to collect contractual cash flows
and are thus measured subsequently at amortised cost less loss allowances. The impairment model in
IFRS 9 Financial Instruments requires the recognition of impairment provisions based on expected credit
losses (ECL). The Company recognises an allowance for expected credit losses on trade receivables.
The amount of expected credit losses is updated at each reporting date to reflect changes in credit risk
since initial recognition. The impairment is calculated by taking into account the historic evidence of
the level of credit losses experienced and the ageing profile of the trade receivables. Individual trade
receivables are impaired when management assesses them not to be wholly or partially collectible.
Cash and cash equivalents
Cash and cash equivalents include cash, bank deposits and commercial papers with original maturities
of three months or less.
Financial liabilities
Trade and other payables include trade payables and other current and non-current, non-interest-bearing
financial liabilities. Borrowings (non-current and current) include bank loans and overdrafts. These
liabilities are initially recognised in the statement of financial position at fair value (net of any transaction
costs), and subsequently measured at amortised cost using the effective interest rate method.
The effective interest method calculates the amortised cost of a financial liability and the allocation of
interest expense over the relevant period. The effective interest rate is the rate that discounts estimated
future cash payments, including all fees and points paid or received that form an integral part of the
effective interest rate, transaction costs and other premiums or discounts, through the expected life of
the financial liability, or (where appropriate) a shorter period, to the amortised cost of a financial liability.
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The Company derecognises financial liabilities when, and only when, the Company’s obligations are
discharged, cancelled, or have expired. The difference between the carrying amount of the financial
liability derecognised, and the consideration paid and payable is recognised in profit or loss.
3.7 Cash flow
The Company presents the statement of cash flows using the indirect method. Cash inflows and
outflows are shown separately for investing and financing activities, while operating activities include
both cash and non-cash line items. Interest received and paid, and dividends received, are reported as
a part of operating activities. Dividends distributed are included as a part of financing activities. Value
Added Tax and other similar taxes are regarded as collection of tax on behalf of authorities.
3.8 Taxation
Income tax in the income statement includes both taxes payable for the period and the change in
deferred taxes. The change in deferred taxes reflects future taxes payable resulting from the year’s
activities. Deferred taxes are determined based on the accumulated result, which falls due for payment
in future periods. Deferred taxes are calculated on net positive timing differences between accounting
and tax balance sheet values, after offsetting negative timing differences and losses carried forward
under the liability method.
A deferred tax asset is recognized only to the extent that it is probable that future taxable profits will be
available against which the asset can be utilised. Deferred tax assets are reduced to the extent that it is
no longer probable that the related tax benefit will be realized.
Deferred tax assets and liabilities
Deferred tax assets and liabilities are presented net of their respective tax effect using tax rate of the
applicable jurisdiction applied to amounts representing future tax deductions or taxes payable and
consist of the following as of 31 December.
Negative and positive timing differences, which reverse or may reverse in the same period, are offset.
Deferred taxes are calculated on the basis of timing differences and losses carried forward that are
offset. Timing differences between different subsidiaries have not been offset. During the period that
these differences reverse, the companies will have a taxable net income that is sufficient to realize the
deferred tax allowance. The losses carried forward are all in countries where future taxable profits are
expected.
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Note 4 Critical accounting judgements and key sources of estimation
variances
In the application of the Company’s accounting policies, as described in Note 3 - Summary of significant
accounting policies, management is required to make judgments, estimates and assumptions that
affect the reported amounts of assets and liabilities, income and expenses. Estimates and judgments
are evaluated on an ongoing basis and are based on historical experience and other factors, including
expectations of future events that are considered to be relevant. Future events may cause these
estimates to change and actual results may differ from these estimates. Estimates and underlying
assumptions are reviewed on an ongoing basis.
Changes in accounting estimates are recognised in the period when the changes occurred, if they apply
to that period. If the changes also apply to future periods, the effect will be distributed between the
current period and future periods.
Investment in subsidiaries
Subsidiaries are valued at cost. Dividends, group contributions and other distributions from subsidiaries
are recognized in the same year as they are recognized in the financial statement of the provider. If
dividends or group contribution exceed withheld profits after the acquisition date, the excess amount
represents repayment of invested capital, and is recognized as a reduction in carrying value of the
investment.
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Note 5 Investment in subsidiaries
LINK Mobility Group AS is the immediate subsidiary of LINK Mobility Group Holding ASA.
The Company has the following investment in a subsidiary:
Entity Country Industry Date of acquisition
Proportion of
voting equity
acquired
LINK Mobility Group AS Norway
Mobile messaging
services and
solutions
December 06, 2021 100%
The total amortized cost as of December 31, 2025:
(Amounts in NOK 1 000) LINK Mobility Group AS
Total amortized cost (01.01) 8,151,807
Total amortized cost (31.12) 8,151,807
LINK Mobility Group AS provides mobile communication services and specializes in messaging, digital
services and data intelligence. 100% of the voting equity interest of the company was acquired on
December 06, 2021 when LINK Mobility Pecunia AS was merged with LINK Mobility Group AS.
As at year-end, the Company has outstanding long-term intercompany loans with its subsidiaries totaling
NOK 2 662 602 thousand. These loans are unsecured and interest bearing.
Management has assessed the recoverability of these amounts and has determined that there is no
credit risk or impairment associated with these intercompany loans.
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Note 6 Other operating expenses
(Amounts in NOK 1000)
2025 2024
Advisors and consultants 2,648 2,368
Stock exchange listing expenses¹ 6,009 4,432
Insurance premiums² 2,881 3,351
Travel expenses - -
Other expenses³ 1,843 413
Total other operating expenses 13,382 10,564
¹ These costs are representative of stock exchange listing fees, registration fees for
increases in share capital, management of insider logs, and share register analysis.
² Insurance premiums includes the cost of insurance brokerage services in addition to insurance policy covers.
³ Other expenses are representative of license fees, insurance related to merger
and acquisition activities, and external accounting services.
Auditor’s fees
The table below summarises audit fees for 2025 (2024) and fees for audit related services, tax services
and other services incurred by the Company during the period. These expenses are included in advisors
and consultants expenses above.
2025 2024
Audit fee 910 1,126
Other attestation services 900 300
Tax consulting services - -
Other services - 43
Total fee to auditor 1,810 1,468
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Net financial income and expenses 2025 2024
Net currency exchange gains (losses)¹ -32,189 -16,550
Net interest expense -66,717 -40,540
Net other financial expense -27,138 -38,391
Total finance income -126,044 -95,481
Net interest expense 2025 2024
Interest expense financial institutions -131,860 -138,194
Interest expense from related parties -47,308 -24,057
Other interest income (expense) 20,768 62,992
Interest income from related parties 91,683 58,718
Total net interest expense -66,717 -40,540
Net other financial expenses 2025 2024
Amortized loan set-up costs -18,439 -22,663
Currency option premium -8,146 -15,008
Other financial (expenses) income -552 -721
Total net other financial expenses -27,138 -38,391
¹ Foreign currency gain/loss is presented on a net basis here and in the Statement of Profit and Loss. Exposure
to fluctuations in foreign currency comes from external lending denominated in EUR. Refer to note 11 (interest-
bearing liabilities) and note 12 (financial instruments, risk management objectives, and policies) for further
details.
Note 7 Net finance income and expenses
(Amounts in NOK 1000)
The Company’s finance income and expense is comprised of gains (losses) from foreign exchange and
from exposure to interest expenses related to loans from financial institutions. Interest amounts are
presented as a sum of interest on borrowings offset by amortised cost recognised in the profit and loss.
All categories of financial income and expense are presented on a net basis.
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Note 8 Cash and cash equivalents
(Amounts in NOK 1000)
2025 2024
Cash and cash equivalents 73,489 1,203,718
Total cash and cash equivalents 73,489 1,203,718
Restricted cash 2025 2024
Restricted cash - -
Bank balance in escrow account - -
Total cash and cash equivalents 73,489 1,203,718
If applicable, cash and cash equivalents include amounts classified as restricted cash.
There are no restricted amounts as at December 31, 2025.
Note 9 Share capital and shareholder information
Share capital as at December 31, 2025 is KNOK 1 530 (2023: KNOK 1 494), being 305 900 968 ordinary
shares (2024: 298 706 434 ordinary shares) at a nominal value of NOK 0.005/share (2024: NOK 0.005/
share). There are no preference shares in FY2025 (FY2024: nil).
All shares were fully paid; each ordinary share carries one vote at any general meeting.
The movement in the number of shares during the year was as follows:
Ordinary shares opening balance on January 01, 2024 297,059,271
Issue of ordinary shares (April 04, 2024) 1,647,163
Ordinary shares opening balance on January 01, 2025 298,706,434
Issue of ordinary shares (April 14, 2025) 1,340,304
Issue of ordinary shares (November 28, 2025) 5,854,230
Total number of shares at the end of the period 305,900,968
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LINK Mobility Group Holding ASA has the following major shareholders as at December 31, 2025:
Name of shareholder Type of account Ownership interest
ABRY Partners LLC Nominee 13.51%
DNB Asset Management AS Ordinary 7.81%
ODIN Fonder Ordinary 7.75%
Folketrygdfondet Ordinary 7.28%
Alfred Berg Kapitalforvaltning Ordinary 5.02%
Sundt AS Ordinary 4.81%
LINK Mobility Group Holding ASA Ordinary 4.49%
UBS AG Ordinary 2.51%
BRED Banque Populaire Nominee 1.73%
KLP Kapitalforvaltning AS Nominee 1.57%
BlackRock Ordinary 1.50%
Dimensional Fund Advisors Ordinary 1.33%
Storebrand Asset Management Ordinary 1.32%
Handelsbanken Fonder Ordinary 1.24%
Sverre Bjerkeli and Companies Nominee 1.23%
Frode Teigen Nominee 0.98%
Bill Potter Nominee 0.87%
Kverva AS Nominee 0.76%
Eric Johansson Ordinary 0.74%
Tigerstaden AS Ordinary 0.73%
67.18%
Name of shareholder
Total number
of shares
Victory Partners VIII Limited via a nominee account in Citibank
(controlled by Abry who had 2 Board members)
40,540,774
LINK Mobility Group Holding ASA
13,732,431
HDR Srl (controlled by Riccardo Dragoni)
664,215
Thomas Berge
457,900
Morten Løken Edvardsen
40,691
Sara Murby Forste
15,957
Pål Marius Brun
11,155
Riccardo Dragoni
8,612
Grethe Helene Viksaas (Board member)
6,382
Benoit Bole
1,217
The company’s trustees (Board Members, management) hold ownership interests and rights to shares:
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Note 10 Classes and categories of financial instruments
(Amounts in NOK 1000)
Carrying value
2025 2024
Current financial assets
Cash and cash equivalents 73,489 1,203,718
Non-current financial liabilities
Borrowings 2,636,939 1,457,521
Current liabilities
Borrowings and interest 14,152 2,019,655
Trade payables 511 2,050
The financial assets held by the Company are held within a business model with the objective to hold
financial assets in order to collect contractual cash flows and are thus measured subsequently at
amortised cost less loss allowances.
All financial liabilities are measured at amortized cost.
The carrying amounts of financial assets and liabilities approximate their fair value as at December 31,
2025. Arrangements with financial institutions are entered into on market terms, and the carrying value
at the reporting date has been assessed as approximating fair value.
The recognised amounts consitute a reasonable approximation of fair value.
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Note 11 Interest-bearing liabilities
(Amounts in NOK 1000)
Interest bearing liabilities are measured at amortised cost.
Non-current financial liabilities 2025 2024
Bond loan 2,636,939 1,457,521
Holdback - -
Total 2,636,939 1,457,521
Current liabilities 2025 2024
Bond loan/debt to financial institutions* 14,152 2,019,655
Total 14,152 2,019,655
*Bond principal and instalments falling due within a 12 month period, including non-capitalised interest, are
classified as current.
Contractual maturities of financial
liabilities at December 31, 2025
< 3
months
3 months
- 1 year
1 - 2
years
2 - 5
years Total
Bond loan (issue October 23, 2024) 15,992 47,975 127,934 1,544,342 1,736,243
Bond loan (issue June 17, 2025) - 57,237 162,486 1,285,854 1,505,577
Total 15,992 105,212 290,420 2,830,196 3,241,820
Contractual maturities of financial
liabilities at December 31, 2024
< 3
months
3 months
- 1 year
1 - 2
years
2 - 5
years Total
Bond loan (issue December 15, 2020) - 12,193 - - 12,193
Bond loan (issue June 23, 2021) - 2,072,824 - -
Bond loan (issue October 23, 2024) - 80,914 161,827 1,636,202 1,878,944
Total - 2,165,931 161,827 1,636,202 1,891,137
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Covenants
'Under the LINK01, LINK02, and LINK03 bond terms, the Group is required to comply with the following
financial covenants at the respective quarterly and annual test dates:
Financial Reporting:
- Publish interim accounts (quarterly reports) in the English language on the Group website (or other
relevant platform) no later than 60 days (LINK01) and 2 months (LINK02 and LINK03) after the end of
the relevant interim period.
- Publish annual financial statements in the English language on the Group website (or other relevant
platform) no later than 120 days (LINK01) and 4 months (LINK02 and LINK03) after the end of the fiscal
year.
A compliance certificate is to be provided with a copy of the financial reports; the compliance certificate
is to be signed by the Chief Executive Officer or the Chief Financial Officer to certify that the financial
reports are fairly representative of its financial condition as at the date of those financial statements
(LINK01, LINK02, and LINK03).
Accounting standards are to be consistently applied (LINK01, LINK02, and LINK03).
Financial Indebtedness:
Except as permitted, the Issuer shall not, and shall procure that no other Group Company will, incur any
additional Financial Indebtedness or maintain or prolong any existing Financial Indebtedness (LINK01,
LINK02, and LINK 03).
Negative Pledge:
Excluding Permitted Security, the Issuer shall not, and shall procure that no other Group Company will,
create or allow to subsist, retain, provide, prolong or renew any Security over any of its/their assets
(whether present or future) (LINK01, LINK02, and LINK03).
Disposals of Business:
The Issuer shall not, and shall ensure that no other Group Company will, sell, transfer or otherwise
dispose of all or substantial part of its assets or operations unless the transaction is carried out at fair
market value, on terms and conditions customary for such transaction and such transaction would not
have a Material Adverse Effect (LINK01, LINK02, and LINK03).
Distribution:
Except as permitted, the Issuer shall not, and shall procure that no other Group Company will make any
Distribution (LINK01). Except as permitted, the Issuer shall not, and shall ensure that no other Group
Company will, make any Distribution, other than any Permitted Distribution (LINK02 and LINK03).
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Collateral and guarantees
On 29 October 2024, LINK successfully placed a EUR 125 million senior unsecured bond due 29 October
2029 (“LINK02”). The bond will have a coupon of 3-month EURIBOR + 2.35% per annum. The bond is
listed on the Oslo Stock Exchange and the Frankfurt Open Market.
Following the new bond issue, the company bought back EUR 125 million of LINK01 (ISIN: NO0010911506)
(“LINK01”) due December 2025 which was subsequently cancelled. The EUR 74 million of LINK01 bonds
held by LINK were also cancelled. Cancellations were executed on October 23, 2024.
On June 17, 2025, LINK successfully placed a EUR 100 million senior unsecured bond due June 17, 2030
(“LINK03). The bond has a coupon of 3-month EURIBOR + 2.75% per annum. The bond is listed on the
Oslo Stock Exchange and the Frankfurt Open Market.
With the issue of LINK03, the company has repaid the remainder of LINK01 (ISIN: NO0010911506)
(“LINK01”) and the bond is cancelled. Cancellation was executed on June 25, 2025.
Until cancellation of LINK01, the nominal outstanding amount was EUR 171 million, which was classified
as a current liability at year-end in 2024.
Incurrence Test:
The incurrence test is met if the Leverage Ratio is less than, for any additional Financial Indebtedness
(3.50x) (LINK01, LINK02, and LINK03) or for Distributions (1.50x) (LINK01).
The Interest Coverage Ratio exceeds 3.0x (LINK01).
Compliance with the Incurrence Test is subject to in each case, that no Event of Default is outstanding or
would result from the relevant event for which compliance with the Incurrence Test is required (LINK01,
LINK02, and LINK03).
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Movements in borrowings
See table below for changes in liabilities arising from financing activities, both cash flows and no cash
flow changes.
Bond loan
December 31, 2023 4,011,061
Reclassification of bond re-purchase (prior year)* 117,960
Opening balance December 31, 2024 4,129,021
New debt** 1,481,563
Cancellation of debts*** -2,358,648
Effects of foreign exchange 205,130
Transaction costs** -17,707
Amortization 22,663
Interest and fees paid -123,039
Interest and fee expenses 138,194
December 31, 2024 3,477,176
Bond loan
December 31, 2024 3,477,176
New debt** 1,178,200
Cancellation of debts*** -1,997,736
Effects of foreign exchange -5,376
Transaction costs** -15,869
Amortization 18,439
Interest and fees paid -135,604
Interest and fee expenses 131,860
December 31, 2025 2,651,091
* On 06 December 2023, LINK repurchased EUR 10 million of LINK01; this was converted to NOK at an exchange
rate of 11,7960 (Norges Bank). After this date, the amount is currency adjusted at the end of each month.
Presentation of this amount is as bond re-purchase in 2023 and this classification is incorrect.
The bond repurchase amount, and the effect of the currency adjustment is removed from the presentation of
movements in borrowings in 2024. Prior year figures are not restated as there is no impact to the consolidated
income statement or to retained earnings; this is strictly classification.
** The sum of new debt and transaction costs is equal to proceeds from borrowings as presented in the
consolidated statement of cash flows.
*** In 2024, cancellation of debts less the effect of foreign exchange specific to the cancellation of debts (NOK
146 272 million), is equal to repayments of borrowings as presented in the consolidated statement of cash flows.
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Note 12 Financial instruments, risk management objectives,
and policies
Through its operations LINK Mobility Group Holding ASA is exposed to the the following
financial risks;
All categories of financial income and expense are presented on a net basis.
• Interest rate risk
• Foreign exchange risk
• Credit risk
• Liquidity risk
Interest rate risk
Interest rate risk arises as a consequence of long-term debt.
On 29 October 2024, LINK successfully placed a EUR 125 million senior unsecured bond due 29 October
2029 (“LINK02”). The bond has a coupon of 3-month EURIBOR + 2.35% per annum. With the new bond
issue, the company has bought back EUR 125 million of LINK01 (ISIN: NO0010911506) (“LINK01”) due
December 2025 which was cancelled. The EUR 74 million of LINK01 bonds held by LINK were also
cancelled. Cancellations were executed on 23 October 2024.
On 17 June 2025, LINK successfully placed a EUR 100 million senior unsecured bond due 17 June 2030
(“LINK03). The bond has a coupon of 3-month EURIBOR + 2.75% per annum.
With the issue of LINK03, the company has repaid the remainder of LINK01 (ISIN: NO0010911506)
(“LINK01”) and the bond is cancelled. Total outstanding long-term bond debt is EUR 225 million.
The sensitivity analysis below is based on the exposure to changes in interest rates for non-derivative
instruments at the reporting date. For floating rate liabilities, the analysis is prepared assuming the
amount outstanding at reporting date was outstanding for the whole year. A one percent increase or
decrease represents management’s assessment of reasonable and possible changes in interest rates.
If interest rates had been one percent higher/lower and all other variables were held constant, the
Company’s profit (and corresponding equity) for the period ended December 31, 2025 would decrease/
increase by KNOK 26 647 (FY2024 KNOK 34 900). This is mainly attributable to the Company’s exposure
to interest rates on its variable rate borrowings.
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December 31, 2025
(amounts in NOK 1000) NOK/EUR impact NOK/SEK impact NOK/CHF impact
Borrowings 26,647 - -
Foreign exchange risk
The Company is a holding company and does not actively undertake business in foreign currencies; as
a consequence, exposure to fluctuations in exchange rates is limited. Foreign exchange risk arises from
transactions related to operations conducted, and assets and liabilities arising in foreign currencies.
Credit Risk
The Company is a holding company and owns all shares in LINK Mobility Group AS; credit risk is deemed
to be low.
Liquidity risk
Liquidity risk is the risk that the Company is unable to meet its financial obligations when they mature,
resulting in default.
The Company considers its liquidity risk to be limited, and has sufficient liquidity available on bank
accounts as of year-end. Obligations are covered by transfer of cash from subisidiaries.
The Company has financial debt covenants related to the senior unsecured bonds. Refer to note 11 for
information about the bond convenants.
The Company does not have any credit facilities.
Trade payables and accruals principally comprise amounts outstanding for trade purchases and ongoing
costs.
Trade and other payables are due within three months.
Note 13 Trade and other payables
(Amounts in NOK 1000)
Trade and other payables 2025 2024
Trade payables 511 2,050
VAT payable 37 188
Other accruals - legal fees - 230
Total trade and other payables 548 2,468
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Note 14 Income tax
(Amounts in NOK 1000)
Specification of income tax expense
The tax benefit/(expense) is calculated based on profit before income tax and consists of current tax
and deferred tax.
2025 2024
Deferred tax expense (income) -26,121 -23,293
Current tax expense - -
Income tax (income) -26,121 -23,293
Income tax payable (balance sheet) 2025 2024
Income tax payable - -
Current tax liabilities (balance sheet) - -
Effective Tax Rate
The difference between income tax calculated at the applicable income tax rate and
the income tax exepense attributable to loss before income tax was as follows:
2025 2024
Profit/(loss) before income tax -139,426 -106,046
Statutory income tax rate* 22% 22%
Expected income tax benefit -30,674 -23,330
Tax effect on non-taxable income/expenses 4,553 37
Effect of changes in tax rules and rates* - -
Prior year adjustment - -
Non deductible interest, interest cap rules - -
Current tax expense, interest cap rules - -
Change in deferred tax asset not recognized - -
Income tax expense/income (-) for the year -26,121 -23,293
Effective tax rate 19% 22%
* The statutory income tax rate based on the currently enacted tax rate in Norway.
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Specification of the tax effect of temporary differences and losses carried forward
Tax losses carried forward 2025 2024
Unused tax loss carry forward 389,949 100,921
Interest cap 69,441 69,441
Potential tax benefit unused tax losses @ 22 % 85,789 22,203
Potential tax benefit interest cap @ 22 % 15,277 15,277
The benefit from the interest cap carried forward is uncertain and the tax asset
is not recognised. The amount can be carried forward for 10 years.
Tax effect of temporary differences and tax losses carried forward as of 31 December
Deferred tax liabilities: 2025 2024
Long term receivables and debt in foreign currency 37,965 -
Other provisions -1,742 -1,242
Tax loss to carry forward (-) -85,789 -22,203
Deferred tax liabilities -49,566 -23,445
Unrecognised temporary differences
2025 2024
Temporary differences for which deferred tax
liabilities have not been recognised
69,441 -
Unrecognised tax liabilities relating to the above
temporary differences @ 22 %
15,277 -
The temporary differences are related to unrealized gains from currency translation. Deferred tax
liability has not been recognised as it is deemed unlikely that the company will generate taxable
income in the foreseeable future.
Note 15 Contingencies and legal claims
The Company is not involved in any disputes or litigation as at the balance sheet date or
of a liability or require additional disclosure. Management and the Board of Directors are
not aware of any such incidents that may have a negative impact on the Company.
LINK Mobility Group
Office: Gullhaug Torg 5, 0484 OSLO
Email: info@linkmobility.com
Tel: +47 22 99 44 00
www.linkmobility.com