Telia Co AB

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The Group Executive Management (GEM) collectively owns Telia's environmental agenda, and its members are responsible for assessment and management of climate-related matters, including strategic business decisions, goal-setting and target execution. In addition, a sustainability steering committee facilitates continuous strategic work, finds solutions related to sustainability barriers, risks and opportunities, and engages GEM as needed."
"Telia's EVP, Head of Corporate Affairs is responsible for oversight of the company's political influence and lobbying activities. (G1-5-29a) [...] Telia monitors development of legislative files and initiatives related to telecommunication, digital and media policies, data protection and data economy, cybersecurity and sustainability. These include, inter alia, the following: the Digital Services Act, Digital Markets Act, AI Act, ePrivacy Regulation, General Data Protection Regulation, Network and Information Security Directive, Roaming Regulation, European Media Freedom Act, EU Taxonomy, Child Sexual Abuse Material Regulation and upcoming legislative proposals within the telecommunication space. Given the potential impact of these initiatives on Telia's business model and operations, the company aims to promote a balanced approach between new regulation and its business objectives. (G1-5-29c) [...] Telia Company is registered in the EU Transparency Register. REG number: 381805014604-45 (G1-5-29d)

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Telia has established a group-level Governance, Risk & Compliance (GRC) function to help ensure that the company takes an integrated and strategic approach to aligning governance and policies with its objectives, while managing risks and promoting ethical and responsible decision-making through compliance with policies, laws and regulations. [...] The Head of the GRC function reports to the Group CFO and acts as the owner of Telia's common GRC process. [...] The GRC function's responsibilities include: Overseeing the Group-wide Governance Framework, owning the Group Policy Framework, Group Enterprise Risk Management (ERM) Framework, and policies and instructions within the GRC's areas of responsibility, monitoring compliance and supporting Group-wide implementation. Overseeing the operational effectiveness of ERM processes across the Group and proposing actions for improvement. Monitoring the risk level as well as specific risk matters across the Group. As part of that responsibility, the Head of the GRC function collects and aggregates reports from countries and Group functions in order to provide the CEO and the Board of Directors with a consolidated and holistic overview of the Group's risk level and individual material risks. Facilitating and organizing the Governance, Risk, Ethics & Compliance (GREC) Committee at Group level. Promoting a culture that encourages ethical conduct and commitment to compliance, as well as assisting, advising and providing objective and reasonable assurance that the company is managing compliance risks in an appropriate way."
"Telia's EVP, Head of Corporate Affairs is responsible for oversight of the company's political influence and lobbying activities. (G1-5-29a) [...] Telia monitors development of legislative files and initiatives related to telecommunication, digital and media policies, data protection and data economy, cybersecurity and sustainability. These include, inter alia, the following: the Digital Services Act, Digital Markets Act, AI Act, ePrivacy Regulation, General Data Protection Regulation, Network and Information Security Directive, Roaming Regulation, European Media Freedom Act, EU Taxonomy, Child Sexual Abuse Material Regulation and upcoming legislative proposals within the telecommunication space. Given the potential impact of these initiatives on Telia's business model and operations, the company aims to promote a balanced approach between new regulation and its business objectives. (G1-5-29c) [...] Telia Company is registered in the EU Transparency Register. REG number: 381805014604-45 (G1-5-29d)

Freedom of expression and surveillance privacy

- Law enforcement requests are logged by local companies. Local company systems might differ because they are designed to meet the requirements for reporting to, or interaction with, local law enforcement authorities. A very limited number of employees have access to the information and there are strict security controls in place. Statistics are reported on a six-monthly basis to the Group focus area owner. A local security manager coordinates the collection of local statistics which are approved by the Group impact area owner.

- Escalated potentially unconventional requests are recorded manually in a log by the Group impact area owner. The log contains classification of the cases (what type of unconventional request) including the applicable assessments, escalations and approvals on if and how a point of challenge was established, as well as further context. An unconventional request is considered closed when it has been assessed, escalated and actions to be taken by Telia Company have been approved. Information in the log undergoes periodic internal review by the Head of Risk and Compliance for possible guidance and to ensure that not just only the Group impact area owner has access to and understands the information in the log and the learnings that are made.

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Governance, Risk, Ethics & Compliance (GREC) committee is the primary governing body for risk management and compliance throughout Telia Company. [...] On group level, the GREC meeting is chaired by the CEO and consists of Group Executive Management, the Head of ERM, the Chief Ethics & Compliance Officer as well as the Head of Group Internal Audit. The purpose, agenda and participants of local GREC meetings mirror the group-level meetings."
"Telia Company monitors closely the development of the EU taxonomy. During the year, we have together with other European telcos gathered in an ETNO workstream with the purpose of improving the EU taxonomy technical screening criteria for the telecommunications sector as these are currently challenging or impossible to apply, or completely lacking for parts of our operations. ETNO's position paper lays out the organization's views on the criteria, highlighting in particular the need to develop criteria regarding "greening by" activities, i.e. products and services that help other industries reduce their environmental impact, as such criteria currently do not exist. Going forward, ETNO will continue to actively engage with relevant stakeholders in the EU institutions and groupings such as the High-level expert group on sustainable finance. [...] The Audit and Responsible Business Committee to the Board of Directors receives regular updates on risks, including climate-related risks when relevant. [...] Going forward, we see a continued need to actively engage in national and international industry organizations and platforms such as ETNO and GSMA, in particular related to future legislation and guidance such as the EU Taxonomy.

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The ultimate responsibility for sustainability oversight lies with the Board, which also decides on the overall sustainability direction and policy commitments. The Board receives updates on sustainability performance twice a year and more often if needed as part of the CEO's monthly updates to the Board. The Board's Audit Committee receives risk reports from management twice a year, covering Principal Risk areas that incorporate Telia's sustainability impact areas, and decides on acceptable risk levels (see the section on Telia Company's risk universe). Group Executive Management (GEM) and Governance, Risk, Ethics and Compliance (GREC) meetings are the primary decision-making forums at management level for sustainability-related topics. GEM adopts and follows up on Telia's sustainability goals, while GREC monitors sustainability-related risks via Telia's Enterprise Risk Management Model. Within GEM and GREC, the Head of Communication, Brand and Sustainability has the overall responsibility for sustainability-related topics. [...] The Head of Governance, Risk and Compliance is in charge of the company's Enterprise Risk Management model, has operational responsibility and oversight over the anti-bribery and corruption program, and reports to the CFO. The Special Investigations Office manages the company's whistleblowing system (the Speak-Up Line) with a direct reporting line to the Audit Committee of the Board. At the local level, local management teams and local GRECs have similar responsibilities as the GEM and Group GREC.

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reduction progress, actions and gaps is done in the Quarterly Sustainability Reviews in GEM. This Climate Transition Plan was approved by the Board of Directors in Q1 2025. Each year, we report progress on our climate and environmental targets in our Annual Report, under the Sustainability Statements, which are limited assured. [...] The Group Policy – Environment is Telia's guiding document for management of our climate work. The main purpose of the Policy is to help ensure that Telia manages environment-related impacts, risks and opportunities throughout our value chain, while meeting legal and stakeholder requirements and expectations. The Policy applies to Telia Company AB, its subsidiaries and joint operations, and is signed by the Telia Company Board of Directors. Telia applies a structured management approach through ISO 14001 and other management standards. Telia's Group-wide Governance Framework is approved by the Board of Directors. The main governing bodies are: - The shareholders at the General Meeting - The Board of Directors - The Chief Executive Officer (CEO), assisted by the Group Executive Management (GEM). The Delegation of Obligations and Authority (DOA) is the governing document that sets out the governance principles and decision-making process at Telia. The DOA is issued by the Telia Group CEO, defines how the Group CEO delegates obligations and authority, and sets expectations for GEM. GEM collectively owns Telia's environmental agenda, and its members are responsible for assessment and management of climate-related matters, including strategic business decisions, goal-setting and target execution. In addition, a sustainability steering committee facilitates continuous strategic work, finds solutions related to sustainability barriers, risks and opportunities, and engages GEM as needed. The integration of the transition plan into the business strategy is ongoing, as well as its integration with financial planning. Telia's overall sustainability agenda and ambitions are thoroughly integrated into the company's business strategy. We are adjusting our strategy and business model to ensure compatibility with the transition to a sustainable economy. Each of Telia's country operations are responsible for contributing to GHG emissions reduction, relative to the size of their business and volume of emissions, including securing the necessary resources as part of the business and financial planning process. Follow up on GHG emissions.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Telia Company shares the importance to address climate goals on the strategic level of the companies. The EGDC commitments are aligned with Telia strategy and environmental goals.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes