The Board of Directors of LINK has adopted a policy to reflect the company’s commitment to integrate environmental, social and governance (ESG) factors into its daily operations and as a part of its strategic processes


  • Sustainability

  • Developing sustainable technologies

  • Minimizing emissions

  • Waste management

  • Energy efficiency

  • Climate change


  • Corporate Social Responsibility

  • Respect for human rights

  • Labor/ Health and Safety

  • Equality and Diversity

  • Data Security and Privacy


  • Organizational Structure

  • Board composition

  • Corruption

  • Competition

  • Incentive programs/Remuneration

  • Tax

The Board has considered ESG in relation to LINK’s business operations and reviewed factors based on the UN sustainable development goals (SDG), the Ten Principles of the UN Global Compact and the OECD Guidelines for Multinational Enterprises. LINK has concluded that the factors in the table below represents the most significant risks and opportunities for the company.

Significant ESG factors for LINK

Sustainable technologiesUN SDG 9LINK strives to contribute to the development of more sustainable technologies
Energy efficiencyUN SDG 7As a significant consumer of data storage, LINK is able to positively affect energy consumption
Climate changeUN SDG 13Take urgent action to combat climate change and its impacts, including mitigating business risks
Respect for human rightsTen Principles of the UN Global CompactLINK conducts its business in compliance with the Ten Principles of the UN Global Compact
Labour, health and safetyUN SDG 8LINK seeks to be a preferred employer through ensured standards
Climate changeUN SDG 13Take urgent action to combat climate change and its impacts, including mitigating business risks
Equality and diversityUN SDG 5LINK is operating in many countries and can influence gender equality through best practices
Data security and privacyUN SDG 16Heighten security to better manage cyber-attacks and other issues related to breaches of information privacy
CorruptionOECD Guidelines for Multinational EnterprisesEnhance due diligence to limit scope for corruption

EU taxonomy regulation

In accordance with the Paris agreement goals, the global community must define measures for sustainability and how to reach agreed reductions in the environmental impact. The EU has created a classification system for environmentally sustainable activities, the EU taxonomy regulation. To align with the regulation a company must relate to six environmental objectives:

I Climate change mitigation – A company’s impact on the environment

II Climate change adaptation – The environment’s impact on a company

III Sustainable use and protection of water and marine resources

IV Transition to a circular economy, waste prevention and recycling

V Pollution prevention and control

VI Protection of healthy ecosystems

The Board has considered the taxonomy regulation and concluded the environmental objectives I, II and IV to be the most relevant for LINK’s digital messaging business.The objectives are commented together with the ESG factors below.

Environmental factors

Developing sustainable technologies

The mobile communications industry is exposed to rapid technological changes that may be accelerated by increased focus on sustainability. LINK strives to contribute to the development of more sustainable technologies, which will be positive for the environment and give the company a competitive advantage. LINK develops software for digital messaging solutions which enable smartphone notifications and marketing services. Notifications facilitate for online distribution, making it easy for customers to track orders and delivery times. Digital notifications also lessen the need for paper-based mail systems in relation to appointments and confirmations. Digital marketing engages customers seamlessly through to purchase on their smartphones, freeing up time and reducing pollution related to transportation. In addition to this, we see traction for two products that will reduce paper consumption:

  • Mobile Invoice is a LINK innovation that allows companies to take their existing paper invoicing flows and move them completely into a mobile only digital environment

  • Our Mobile KYC (Know You Customer) antifraud solutions. KYC procedures are currently time-consuming and paper intensive, but with this specialized innovation we provide a fully digitalized KYC flow

Minimizing emissions

LINK contributes to reduced carbon emissions by prioritizing video conferencing to travel. LINK started with group-wide meetings for all employees in 17 countries well before the pandemic. All subsidiaries are further encouraged to consider the environmental impact of its activities and to implement processes to reduce their environmental footprint.

Waste management

The LINK Code of Conduct requires all subsidiaries to ensure that activities to reduce waste are implemented, hereunder recycling.

Energy efficiency

LINK can influence energy consumption through choice of server sites and hosting providers. By only working with established suppliers and requiring documented energy efficiencies, LINK contributes to reduced consumption. LINK will enhance its due diligence processes related to procurement in 2021. The company operates in several countries and continuously assesses opportunities to optimize the use of or merger of server sites to further minimize energy consumption.

Climate change

LINK’s suppliers might be affected by issues resulting from climate change, hereunder flooding and loss of power. Risks are mitigated through server site redundancies and working with established hosting providers that can document backup and continuity routines.

Social factors

Corporate social responsibility

LINK has initiated a corporate social responsibility (CSR) program based on the UN sustainable development goals (SDG). The following goals were considered when LINK selected its CSR initiative:

SDG 5: Gender Equality

SDG 7: Ensure access to affordable, reliable, sustainable, and modern energy

SDG 7.3: By 2030, double the global rate of improvement in energy efficiency

SDG 8: Promote inclusive and sustainable economic growth, employment, and decent work for all

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 9: Build resilient infrastructure, promote sustainable industrialization, and foster innovation

SDG 9.8: 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 13.1: Strengthen resilience and adaptive capacity to climate-related hazards and natural disasters in all countries

SDG 13.2: Integrate climate change measures into national policies, strategies and planning

SDG 16: Promote just, peaceful, and inclusive societies

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

LINK employees have voted Climate Action to be LINK’s number one common CSR initiative, on which the company will have full focus and engagement across all countries. This represents SDG 13 above. CSR at LINK is fully described in the LINK Mobility CSR strategy document.

Respect for human rights

Respect for human rights is vital for upholding the fundamental fabric between all human beings. The LINK Code of Conduct ensures that all managers and employees commit to operate consistent with the UN Guiding Principles on Business and Human Rights and the Ten Principles of the UN Global Compact. LINK complies with all applicable laws and respect internationally recognized human rights wherever it operates. LINK has applied to join the UN Global Compact as part of its increased focus on sustainability.

Labor, health and safety

LINK, including all subsidiaries, respects the right of its employees to establish or join trade unions and representative organizations of their own choosing. Currently there are no union agreements at the group level, while the French subsidiary has a Work Council as required. LINK observes and ensures that standards of employment and industrial relations are aligned with comparable employers. LINK takes adequate steps to ensure occupational health and safety in its operations.

Equality and diversity

LINK aims for its workforce to be truly representative of all sections of society and for each employee to feel respected and able to perform at their best. It is LINK’s purpose to:

Provide equality, fairness and respect for all employees.

Not unlawfully discriminate because of characteristics of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality and ethnic or national origin), religion or belief, sex and sexual orientation.

Oppose and avoid all forms of unlawful discrimination. This includes in pay and benefits, terms and conditions of employment, dealing with grievances and discipline, dismissal, redundancy, leave for parents, requests for flexible working, selection for employment, promotion, training or other developmental opportunities.

LINK is committed to encourage equality, diversity and inclusion in the workplace and believes it to facilitate for better business results. LINK considers focus on equality and diversity an important element in attracting, recruiting and retaining skilled employees. As an international company located in several geographies with extensive use of online work methods, LINK has a country agnostic advantage in its talent search.

Data security and privacy

Proliferation of cyber-attacks and other issues related to breaches of information privacy are key risk factors and an important motivation for LINK’s heightened focus on security.

Personal Data Protection

LINK operates in accordance with GDPR regulations. Our platforms are under constant care of a Data Protection Officer, who takes an active part in consulting and planning all our projects in terms of GDPR compliance. Our portfolio is built and designed with privacy in mind while constantly undergoing improvements. To satisfy the dynamic nature of Data Protection, LINK applies external testing to ensure maximum level of protection.

Information Security

LINK’s position is to always ensure compliance with applicable legislation and do what is technically and financially possible to ensure the security of the data processing. Information security is paramount at all levels of the organization. Our objective for information security is that LINK performs all necessary activities:

  • Availability: Availability of all services with a high percentage of up-time and a minimized risk of down-time

  • Integrity: Reliable and correct function of the services and minimized risk of incorrect data usage e.g., due to human or systemic errors or due to external incidents

  • Confidentiality: Confidential processing and transmission or storing of data, to which solely authorized users have access

To ensure this, LINK has built an Information Security Management System based on best practices outlined by ISO 27001.


LINK operates in tier-3 certified data centers that feature redundant connectivity, restricted physical access, video surveillance, fire protection and 24/7 NOC monitoring. All nodes are connected via high-speed MPLS networks to satisfy high availability scalable solutions.

LINK’s processes for managing IT security and data protection are fully described in the LINK IT Security Policy and the LINK Personal Data Protection Policy.


Organizational structure

LINK is organized as a Norwegian holding company with several subsidiaries in various European countries. The holding company, LINK Mobility Group Holding ASA, is listed on the Oslo Stock Exchange.

LINK Mobility Group Holding ASA – Norway

LINK Mobility Pecunia AS – Norway

LINK Mobility Group AS – Norway

LINK Mobility – European Subsidiaries

Board composition

The composition of the Board must ensure that it can attend to the common interests of all shareholders and meet the needs of the company. The Board of Directors of LINK has adopted the LINK Corporate Governance Policy to reflect the company’s commitment to good corporate governance. Through good governance of the business, the company intends to create profitability and increased shareholder value. For specifics on the Board and its governance work, please refer to the “Report form the Board of Directors” section later in this report.


Corruption undermines any legitimate business operation. Bribery and corruption are therefore a risk for any sustainable business. LINK will enhance its due diligence processes related to procurement in 2021. LINK’s approach to corruption is fully described in the LINK Anti-Bribery and Anti-Corruption Policy.


LINK complies with all applicable antitrust laws and managers are required to take action to avoid even the appearance of any wrongdoing. All LINK employees must demonstrate their awareness of antitrust laws when engaging with competitors, customers, resellers, partners, distributors or suppliers and seek further guidance from the LINK’s Legal Function when in doubt. LINK’s approach to competition is fully described in the LINK Anti-Trust Policy.

Incentive programs and remuneration

LINK has a Compensation Committee that prepares guidelines for incentive programs and renumerations. LINK’s Nomination Committee proposes remuneration for Board members. For further details, please refer to the “Report form the Board of Directors” section later in this report.


LINK consists of more than 40 entities in 17 countries, where each entity has its tax residence in the country where it is located. The parent company, LINK Mobility Group Holding ASA, is registered in Norway and thus has its tax residency there.

Implementation of ESG

To ensure implementation of and compliance with ESG policies, LINK follows the compliance standard ISO19600. External and internal issues of relevance to compliance have been assessed by the compliance function since its establishment in 2019 and with mandate given by the Global Leadership Team (GLT). From 2020, compliance is part of LINK’s long-term strategy, and the approval of main policies has consequently been lifted to the Board level.

The boundaries for the compliance management system (CMS) are set out in the compliance team mandate. Unless otherwise instructed by GLT for specific projects, the compliance function will cover the LINK group organization and systems. LINK subsidiaries will be accountable for compliance in their organizations, with support from the group compliance function. LINK’s Legal and Compliance team will prioritize key focus area in conjunction with GLT.

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To learn more about Sustainability in 2022 at LINK, go here.