Crayon Group Holding

The role of the administrative, management and supervisory bodies

The Board of Directors of Crayon Group Holding ASA has ultimate responsibility for the management of the Company and for supervising its day-to-day management. The Board ensures that the Company has proper management with a clear internal distribution of responsibilities and duties. A division of work is established between the Board and the executive management team.

Board of Directors Composition:

Executive Management Team:

• Melissa Mulholland - Chief Executive Officer (appointed March 2021)
• Gudmundur Adalsteinsson - Chief Revenue Officer (joined 2013)
• Brede Huser - Chief Financial Officer (joined September 2023)
• Bente Liberg - Chief Human Resources Officer (joined March 2002)
• Jon Birger Syvertsen - Chief Operating Officer (became COO in 2024)

Board Responsibilities: The Board's primary responsibilities include: a. Participating in the development and approval of the Company's strategy b. Performing necessary control functions c. Acting as an advisory body for the executive management team

Its duties are not static, and the focus shall depend on the Company's ongoing needs. The chair of the Board is responsible for ensuring that the Board's work is performed effectively and correctly.

The Board ensures that members of the Board and executive personnel make the Company aware of any material interests that they may have in items to be considered by the Board.

Meeting Attendance in 2024: Between 1 January and 31 December 2024, the full board of directors held 22 meetings. A 100% attendance rate was recorded for 16 of the 22 meetings.

Committees: The Board has established three committees:

• Audit and ESG Committee (held 12 meetings in 2024)
• Remuneration Committee (held 4 meetings in 2024)
• Nomination Committee (held 9 meetings in 2024)

The CEO is responsible for the executive management of the Company. Furthermore, the Board issues instructions that state how the Board and the executive management shall handle agreements with related parties.

Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

All members of the Board regularly receive information about the Company's operational and financial development. The Company's strategies are regularly reviewed and evaluated by the Board.

In 2024, our environmental, social, and governance (ESG) program remained on a positive trajectory, adding value to the business by contributing to meeting employee, customer and investor expectations, strengthening our reputation in the ESG space, and managing regulatory and other risks.

Notably, in 2024 we developed a new global ESG strategy that was approved by our board of directors. In line with this strategy, our top three strategic priorities in 2025 will be greenhouse gas emissions and climate-related risk, diversity, equity, inclusion and belonging, and responsible AI.

To evolve and strengthen ESG governance, in 2024 we renamed our Audit Committee to the Audit and ESG Committee, and revised its mandate to reflect this broader scope. The Audit and ESG Committee held a total of 12 meetings between 1 January and 31 December 2024.

The Board conducts a full-day meeting with Management on an annual basis to evaluate the Group's business strategy. During the meeting, clear objectives, strategies, and risk profiles for the Group's business activities are defined in order to create value for shareholders. When carrying out this work, the Board has taken into account financial, social, and environmental considerations.

The Board evaluates these objectives, strategies, and risk profiles at least once a year. The business strategy provides Management with a basis for carrying out investments and other structural measures.

Integration of sustainability-related performance in incentive schemes

Crayon Group Holding ASA has established an Employee Stock Purchase Plan (ESPP) through which all employees annually are given an opportunity to acquire stocks at a 20% discount to the market price. After a two-year lock-up period, employees are awarded one additional bonus share for every three shares acquired.

Share based compensation amounted to NOK 35m (NOK 42m in 2023).

The Annual General Meeting on May 15, 2024, authorized the Board of Directors to increase the share capital in connection with the company's incentive schemes and acquisitions. The Board has granted an authorization to increase the Company's share capital in relation to the Group's incentive schemes with up to NOK 5,374,495, provided however that the authorization cannot be used for an amount in excess of 6.0% of the Company's share capital.

During 2024, a total of 1,162,752 treasury shares have been allocated to employees under these programs.

Board members are encouraged to own shares in the Company.

Statement on due diligence

Crayon Group is committed to conducting business in accordance with high ethical standards and in compliance with applicable laws and regulations. The Company has established policies and procedures to ensure responsible business conduct throughout its operations and value chain.

Our wide-ranging ESG initiatives contribute to our business strategy and business success by helping to strengthen relationships with existing and potential customers worldwide, across all our lines of business. Some of our ESG initiatives have the co-benefit of enabling us to anticipate and comply with regulatory requirements, mitigating the financial and reputational risks associated with regulatory non-compliance.

The Group Treasury overlooks the credit risk on a centralized level whilst the subsidiaries are responsible for performing credit check and control, enforcing payment terms and conditions towards the clients.

Crayon faces credit risk for the full amount of any gross sales invoiced on behalf of the software supplier, even when acting as an agent and only recognising net revenues on reseller business. This also includes situations with disputes between the software vendor and the end user related to services delivered or consumed. In such cases, Crayon engages in dialogue with both the end user and with the software vendor in order to agree on balanced solutions.

Responsibility for employee health and safety at Crayon is shared between the Human Resources and Trust Unit teams. Sound safety and health practices are integral to our operations, and we comply with all local workplace safety regulations.

The Group strives to be a workplace where there is no discrimination and endeavors to promote the objectives of the Norwegian Anti-Discrimination Act in its operations with regard to recruitment, wages and working conditions, promotion, development opportunities and protection against harassment.

Risk management and internal controls over sustainability reporting

The Board is careful to secure systematic management of risk in all parts of the business and regards this as critical for long-term value creation. The Board of Directors regularly reviews Crayon Group's risk profile through the lens of the organization's lines of business and control functions.

Crayon considers good corporate governance to be a prerequisite for value creation, trustworthiness and access to capital. In order to secure strong and sustainable corporate governance, we work continuously to implement good and healthy business practices, reliable financial reporting and compliance with legislation and regulations across Crayon Group.

The Board has adopted instructions for the Group's employees and primary insiders relating to inside information and trading in financial instruments, including the duty of confidentiality, prohibition of trading, investigation, and reporting requirements, and ban on giving advice.

In 2024 we renamed our Audit Committee to the Audit and ESG Committee, and revised its mandate to reflect this broader scope. The Audit and ESG Committee is responsible for overseeing the Group's financial reporting process, internal controls, and risk management systems, as well as ESG-related matters.

The Board ensures that the Company has proper management with a clear internal distribution of responsibilities and duties. All members of the Board regularly receive information about the Company's operational and financial development.

Additionally, the Board prepares an annual evaluation of its own work, including its performance, expertise, composition and how its members function (both individually and as a team) in relation to the objectives set out for its work.

Strategy, business model and value chain

Our Business Model

Crayon is a customer-centric information technology (IT) consultancy that enables customers to maximize their technology investments. We help customers reduce costs, optimize their software and cloud, and leverage new opportunities in AI.

Founded in Norway 22 years ago, our international presence has grown. Today, our key markets are the Nordics (our largest and most mature), Europe, Asia Pacific, Middle East, Africa, and the United States.

Crayon's success and driver for growth is grounded in one key aspect: Our customer-first focus. Since our start in 2002, we differentiated our value proposition to be a strategic partner and advisor to our customers. In doing so, we were able to acquire customers and develop long term relationships through the trust created.

Our Strategy

We must integrate our AI capabilities into our tools to help us gain better insights and understanding of our customers' needs, spend patterns, and security vulnerabilities. In doing so, we will increase the value we provide to our customers, which is and will always remain a top priority.

To position ourselves tactically to enhance the value we deliver to our customers, our current and future go-to-market offerings increasingly emphasize the following key elements:

• Drive customer success through cost optimization: Leverage our unique SAM / SCA capabilities as the enabler for putting Crayon on the customers' side of the table. • Grow the Channel business: Realize the market potential in the channel business to drive growth and profitability across the markets we are in. • Manage the Microsoft incentive changes: Approach changes as a business opportunity for Crayon, leveraging our core business model and legacy, and market position. • Growth on multi-vendor software: Accelerate sales on multi-vendor software to drive incremental growth and profitability across regions. • Scale on Cybersecurity: Growth on Cybersecurity services through a scalable Microsoft offering. • Realize the potential from AI driven applications and custom AI: Realizing the potential in GenAI and custom AI projects.

Four Main Service Offerings

1. Software Procurement: We help customers choose, acquire, consume and support the software services that fit their business needs and budget. As a global leader, we leverage our extensive expertise to deliver tailored procurement solutions that meet the diverse needs of our clients.

2. IT Cost Management: We show customers the way to make the most out of their software and cloud investments (average 30% IT cost savings). Crayon provides expert guidance to streamline and control IT expenses. Our tailored IT cost optimization services – from software asset management to FinOps and compliance – empower our clients' business to achieve efficiency and cost savings in a dynamic digital environment.

3. Cloud Services: We offer expert advice, migration, management, deployment, and security of customer IT services, no matter the platform or technology. Our business cloud solutions and cloud transformation services are designed to help our clients navigate the complexities of modern IT with confidence.

4. Data and AI Solutions: We provide cutting-edge solutions and expertise to help customers harness the full potential of data and AI. Crayon delivers tailored AI solutions and AI consulting services to help businesses gain a competitive edge.

Lines of Business

Crayon is divided into four primary business areas:

• Software & Cloud Direct (part of Software division - 55% of Gross Profit)
• Software & Cloud Channel (part of Software division - 55% of Gross Profit)
• Software & Cloud Economics (14% of Gross Profit)
• Consulting (28% of Gross Profit)

Market Presence

Crayon's geographical presence is divided into four market clusters: the Nordics, Europe, APAC & MEA, and the US. As a result of increased international expansion, the international markets have been the primary driver of gross profit growth and now represents 57% of gross profit in 2024.

Gross Profit by Market (2024):

• Nordic: 26% (NOK 2.4bn)
• Europe: 53% (strong 24% growth)
• US: 25%
• APAC & MEA: 21%

Interests and views of stakeholders

Crayon engages with various stakeholders as part of our business operations and sustainability efforts:

Key Stakeholders

Shareholders and Investors: Crayon aims to provide value creation and attractive, long-term return to shareholders by delivering on its business plan and maintaining timely and accurate communications with the capital markets. The objective of Crayon's investor relations is to ensure that the share price accurately reflects the Company's value, risk and growth opportunities. As of December 31, 2024, Crayon had 5,960 private and institutional investors.

Employees: Crayon values its employees and strives to create a safe and rewarding work environment for them. Our network of local human resources (HR) representatives, led by the Chief Human Resources Officer, develops, and implements policies and strategies to recruit, select and engage employees. We have 4,182 full-time equivalent employees worldwide representing 90 nationalities.

Customers: We help customers reduce costs, optimize their software and cloud, and leverage new opportunities in AI. Our total suite of products and services resulted in scores of new agreements across our markets in both the public and private sector. We have +140,000 customers from SMEs to large enterprises, with a high share of public sector.

Software Vendors and Partners: Crayon has strong strategic relationships with all key global software vendors. Microsoft is a significant part of the business, and in 2024 Crayon was recognized as the global winner Microsoft Scale Solutions (LSP) Partner of the Year. We also have distribution partnerships with AWS and Broadcom.

Communities: Our ESG initiatives support various communities through our charitable giving focus area and Tech4Good software and services for social impact.

Stakeholder Engagement

Investor and business partner expectations help shape our ESG strategy and provide opportunities for collaboration, thereby facilitating stakeholder outreach and engagement.

Our ESG initiatives also support employer branding, contributing to talent attraction and employee engagement and loyalty.

To the extent customers are interested in our sustainability initiatives, mutual benefits include customer acquisition and retention for Crayon.

All investor relations activities are conducted in compliance with relevant rules, regulations and recommended practices. The Group publishes quarterly financial results with live earnings presentations held by senior management. All reports and presentations are open to the wider investor community and made available online at crayon.com/investor-relations.

Material impacts, risks and opportunities and their interaction with strategy and business model

In December 2024, our board of directors approved an enhanced ESG strategy designed to propel us into the future by building on our progress to date. Our 16 focus areas are derived primarily from the material impacts, risks, and opportunities identified in our 2024 double materiality assessment, as well as some additional components that emerged through further internal stakeholder consultations.

Strategic Integration

Our wide-ranging ESG initiatives contribute to our business strategy and business success by helping to strengthen relationships with existing and potential customers worldwide, across all our lines of business. Our ESG initiatives also support employer branding, contributing to talent attraction and employee engagement and loyalty.

Some of our ESG initiatives have the co-benefit of enabling us to anticipate and comply with regulatory requirements, mitigating the financial and reputational risks associated with regulatory non-compliance.

Key Strategic Priorities

In order to focus, allocate resources efficiently, and maximize the chances for success, three of the 16 ESG focus areas will be prioritized in 2025:

i. Greenhouse gas emissions and climate-related risks ii. Diversity, equity, inclusion and belonging iii. Responsible AI

Business Model Integration

Our ESG strategy has a five-year window between 2025 and 2030. We believe this is a sufficient timeframe to achieve results in the more immediate and foreseeable future, whilst laying a strong foundation for success beyond 2030.

The 16 ESG focus areas are segmented into four pillars that align with our business operations:

Pillar I: Environment

• Vision: To protect the planet by being a responsible steward
• Focus areas: GHG emissions and climate-related risk; E-waste and circular economy

Pillar II: Services and solutions

• Vision: To integrate ESG into the services and solutions we offer customers
• Focus areas: Tech4Good software and services; Cloud services that minimize carbon footprint; ESG software solutions

Pillar III: Social

• Vision: To serve and develop people inside and outside our organization
• Focus areas: Diversity, equity, inclusion & belonging; Employee advocacy, well-being and growth; Talent attraction and recruitment; Employee remuneration and benefits; Labor and human rights in value chain; Charitable giving

Pillar IV: Governance

• Vision: To infuse honest and ethical conduct into everything we do
• Focus areas: Business ethics and integrity; Data privacy and information security; Responsible AI; Enterprise risk management; Corporate governance

Future Opportunities

Realise the potential from our ESG initiatives - Our various ESG initiatives position Crayon as a player attuned to industry and societal trends. Our existing ESG-related services and solutions, if scaled up could also contribute to our go-to-market offerings and revenue generation.

Description of the processes to identify and assess material impacts, risks and opportunities

Our 16 focus areas are derived primarily from the material impacts, risks, and opportunities identified in our 2024 double materiality assessment, as well as some additional components that emerged through further internal stakeholder consultations.

The double materiality assessment was conducted in 2024 to identify and assess material impacts, risks and opportunities across environmental, social and governance topics. This assessment forms the basis for our ESG strategy and disclosure requirements.

The Board is careful to secure systematic management of risk in all parts of the business and regards this as critical for long-term value creation. The Board of Directors regularly reviews Crayon Group's risk profile through the lens of the organization's lines of business and control functions.

When carrying out business strategy work, the Board has taken into account financial, social, and environmental considerations. The Board evaluates objectives, strategies, and risk profiles at least once a year.

The assessment process identified material topics across the following areas:

• Environment: Climate change (E1) and Resource use and circular economy (E5)
• Social: Own workforce (S1) and Workers in the value chain (S2)
• Governance: Business conduct (G1)

The results of the double materiality assessment inform our strategic priorities and guide resource allocation across our 16 ESG focus areas, with particular emphasis on the three strategic priorities for 2025: greenhouse gas emissions and climate-related risks, diversity, equity, inclusion and belonging, and responsible AI.

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Based on our double materiality assessment conducted in 2024, Crayon has identified the following ESRS topics as material:

ESRS 2 – General Disclosures All general disclosure requirements apply as they provide the foundation for sustainability reporting.

Environmental Standards:

• ESRS E1 – Climate Change: Material due to our greenhouse gas emissions and climate-related risks identified as a strategic priority
• ESRS E5 – Resource Use and Circular Economy: Material due to our e-waste and circular economy focus area

Social Standards:

• ESRS S1 – Own Workforce: Material given our 4,182 employees across 46 countries and diversity, equity, inclusion and belonging as a strategic priority
• ESRS S2 – Workers in the Value Chain: Material due to our focus on labor and human rights in the value chain

Governance Standards:

• ESRS G1 – Business Conduct: Material due to our focus on business ethics and integrity as part of our governance pillar

The following environmental and social standards were assessed as not material for Crayon:

• ESRS E2 – Pollution: Not identified as material in our assessment
• ESRS E3 – Water and Marine Resources: Not identified as material in our assessment
• ESRS E4 – Biodiversity and Ecosystems: Not identified as material in our assessment
• ESRS S3 – Affected Communities: Not identified as material in our assessment
• ESRS S4 – Consumers and End-Users: Not identified as material in our assessment

This sustainability statement covers the material ESRS disclosure requirements identified through our double materiality assessment process. An ESRS Content Index is provided on page 115 showing where each applicable disclosure requirement is addressed in this report.

Policies related to climate change mitigation and adaptation

Crayon has integrated climate considerations into its environmental management system, which is certified to ISO 14001 globally. This certification demonstrates our commitment to environmental responsibility and systematic management of environmental aspects, including climate-related matters.

As part of our ESG strategy approved by the board of directors in December 2024, greenhouse gas emissions and climate-related risk is one of our top three strategic priorities for 2025. This reflects our commitment to addressing climate change through our operations and business activities.

Our environmental pillar has the vision: "To protect the planet by being a responsible steward" with focus areas including:

1. GHG emissions and climate-related risk
2. E-waste and circular economy

We participate in CDP (formerly known as the Carbon Disclosure Project) each year, disclosing our greenhouse gas emissions. CDP is an independent environmental disclosure system used to drive transparency and action around how organizations manage their environmental impacts. In 2024, we achieved a score of B-.

Through our services and solutions pillar, we aim "To integrate ESG into the services and solutions we offer customers" including:

• Cloud services and solutions that minimize carbon footprint
• ESG software solutions

Our climate-related policies are implemented through our global environmental management system and are regularly reviewed as part of our ISO 14001 certification requirements.

Actions and resources in relation to climate change policies

Crayon has taken several concrete actions related to climate change mitigation:

Environmental Management System

We maintain an ISO 14001 Global certification for our environmental management system, which provides the framework for systematic environmental management including climate-related actions.

Greenhouse Gas Emissions Monitoring

We track and report our greenhouse gas emissions across all scopes:

• Total Scope 1, 2 and 3 market-based emissions: 24,721 tons of CO2 in 2024
• We participate in CDP climate change questionnaire annually, achieving a B- score in 2024

Circular Economy and E-Waste Actions

Under our sustainable device management program:

• 293 devices were recycled or resold in 2024
• This supports our circular economy focus area under the environmental pillar

Strategic Priority Investment

As greenhouse gas emissions and climate-related risk is one of our top three strategic priorities for 2025, we will be allocating additional resources and focus to this area as part of our five-year ESG strategy implementation (2025-2030).

Service Offerings

Through our cloud services business, we help customers optimize their IT infrastructure which can contribute to reduced carbon footprint:

• Cloud services and solutions that minimize carbon footprint is a specific focus area
• We offer FinOps services through our new Crayon Cloud Cost Control platform to help manage software and cloud spend efficiently

Reporting and Transparency

We provide annual disclosure of our climate-related performance through:

• CDP climate change questionnaire participation
• ESG reporting as part of our integrated annual report
• Participation in United Nations Global Compact since 2020

Gross Scopes 1, 2, 3 and Total GHG emissions

Total GHG Emissions (2024)

This represents our total greenhouse gas emissions across all scopes for the 2024 reporting period.

Reporting and Verification

Our GHG emissions data is disclosed through our participation in CDP (formerly known as the Carbon Disclosure Project) each year. CDP is an independent environmental disclosure system used to drive transparency and action around how organizations manage their environmental impacts. In 2024, we achieved a score of B- on the CDP climate change questionnaire.

Our greenhouse gas emissions reporting is part of our ISO 14001 certified environmental management system, which provides systematic management of environmental aspects including climate-related matters.

GHG emissions and climate-related risk is identified as one of our top three strategic priorities for 2025, reflecting our commitment to managing and reducing our carbon footprint as part of our five-year ESG strategy (2025-2030).

Policies related to resource use and circular economy

Crayon has established policies and practices related to resource use and circular economy as part of our environmental management approach:

Environmental Management System

Our global environmental management system is certified to ISO 14001, which includes systematic management of resource use and waste management practices. This certification covers all our operations across 46 countries.

Circular Economy Focus

As part of our ESG strategy approved by the board of directors in December 2024, e-waste and circular economy is a key focus area under our environmental pillar. Our environmental pillar has the vision "To protect the planet by being a responsible steward."

Device Management Policy

We have implemented a sustainable device management program that focuses on:

• Device lifecycle management
• Maximizing device reuse through resale programs
• Proper recycling of end-of-life devices
• Reducing electronic waste through circular practices

Resource Optimization

Through our IT Cost Management services, we help customers optimize their software and cloud resources, which contributes to more efficient resource utilization across the technology sector. This includes:

• Software asset management to reduce unnecessary licenses
• Cloud optimization to minimize resource waste
• FinOps services to optimize cloud resource consumption

Our circular economy policies are integrated into our broader environmental management framework and are regularly reviewed as part of our ISO 14001 certification requirements.

Actions and resources related to resource use and circular economy

Sustainable Device Management Program

Crayon has implemented a comprehensive sustainable device management program with concrete results:

• 293 devices were recycled or resold in 2024
• This program focuses on extending device lifecycle through refurbishment and resale
• Proper recycling channels are used for end-of-life equipment

ISO 14001 Implementation

Our global certification for ISO 14001 environmental management system provides the framework for systematic resource management across all our operations in 46 countries. This includes:

• Resource consumption monitoring
• Waste reduction initiatives
• Circular economy practices
• Environmental performance improvement

Customer Resource Optimization Services

Through our business operations, we help customers optimize their resource utilization:

• IT Cost Management services help customers achieve average 30% IT cost savings
• Software Asset Management reduces unnecessary software licenses and resource waste
• FinOps services through our Crayon Cloud Cost Control platform help manage software and cloud resource consumption efficiently
• Cloud optimization services help customers right-size their infrastructure to minimize resource waste

Strategic Resource Allocation

E-waste and circular economy is identified as a focus area under our environmental pillar as part of our five-year ESG strategy (2025-2030). This ensures dedicated resources and management attention to advancing our circular economy practices.

Partnerships and Collaboration

We work with certified recycling partners and device refurbishment specialists to ensure proper handling of electronic equipment throughout its lifecycle, maximizing reuse and ensuring responsible disposal when recycling is necessary.

E5-4 Resource Inflows

Crayon reports resource inflows related to its sustainable device management program, covering IT hardware and packaging procured in 2024. Data was provided by an external service provider partner.

Disclosure of Information on Material Resource Inflows

Foxway delivered electronics and packaging of electronics to Crayon. The content of the products included materials such as:

Electronics:

• Metals: Aluminum, Steel, Gold, Tin, Copper, Gold, Magnesium
• Plastics: New and recycled Plastics
• Minerals: Lithium, Cobalt, Tantalum, Tungsten, Rare earth elements (e.g. lanthanum, cerium, neodymium, and dysprosium)

Packaging:

• Biological materials: virgin and recycled wood fibers

Overall Total Weight of Products and Technical and Biological Materials

Percentage of Biological Materials

Secondary Reused or Recycled Materials

Data Quality and Limitations

All metrics are being reported for the first time in 2024. Comparative metrics for previous years were not practicable to provide.

The company notes that full availability of supplier-specific data points to comply with ESRS E5 requirements is a challenge. For some metrics, the service provider made estimates based on proxies, where publicly available data from a limited number of original equipment manufacturers (OEMs) are considered representative proxies (indirect sources) for the IT hardware industry. The company considers these proxies to constitute value chain estimates, the accuracy of which is constrained by not covering all brand and device types.

Packaging data availability is particularly challenging because:

• Some shipments are consolidated when outbound, whereas others are not
• Local approaches to packaging differ by country to accommodate norms and regulations
• Some manufacturers share packaging information (e.g. Apple), whereas others do not

The service provider is investigating ways to address these data challenges.

Resource outflows

Product content and recycled materials

For IT devices procured through Crayon's sustainable device management program in 2024:

• Recycled material in Apple laptops (excluding packaging): 33.9 kg of recycled material in 60 Apple laptops procured = 36.4% average recycled content per Apple MacBook Pro and Air unit (based on Apple product data sheets)
• Recycled material in packaging: 25.8 kg of recycled material in the packaging of 60 Apple laptops procured
• Percentage of secondary reused or recycled components: 36.4% average for Apple MacBook Pro and Air laptops based on Apple product data sheets

Data availability is limited to Apple products; data unavailable for most other products due to lack of disclosure by original equipment manufacturers (OEMs).

Product durability and end-of-life

• Assumed product lifespan: 4 years for hardware sold through subsidiary Sensa (Category 11: Use of sold products)
• Products recycled or resold after use by Crayon (2024): Total of 293 IT devices
  • 203 reused (sold again)
  • 90 recycled

Circular economy approach

Crayon's IT hardware purchases through the sustainable device management program are guided by sustainability criteria:

1. At procurement: ensuring all devices are energy efficient, easily repairable, and contain some recycled and non-toxic materials and components. Life cycle assessments are available for some devices to help choose ones with the lowest carbon footprint.
2. During use: defaulting to repair and maintenance to prolong lifespans.
3. At end of life: recycling or reselling all hardware used by Crayon, including reducing packaging waste by returning old laptops in the boxes new laptops were sent in.

Data limitations

Crayon notes that full availability of supplier-specific data points to comply with ESRS E5 requirements is a challenge that will remain difficult to address for the foreseeable future. The company uses publicly available data from a limited number of OEMs as representative proxies for the IT hardware industry, but this approach does not cover all brand and device types.

Waste

Crayon's waste reporting is primarily captured within Scope 3 emissions (Category 5: Waste generated in operations).

Waste metrics (2024)

• Scope 3 Category 5 emissions: 20.87 tonnes CO2e from waste generated in operations (2023: 7.90 tonnes CO2e)

Waste types covered

Emissions in Category 5 relate to third-party treatment and disposal of operational waste, including:

• Residual waste
• Sorted and mixed waste
• Hazardous waste
• Organic waste
• Wastewater

Calculation methodology

Calculations are based on either actual reported volumes or estimates per waste type.

E-waste from sold products (2024)

• Category 12: End-of-life treatment of sold products: 0.008 tonnes CO2e (2023: 0.09 tonnes CO2e)
• Covers emissions from disposal and waste treatment of hardware products sold by Crayon in 2024
• Emissions calculated for total quantity of hardware products purchased by Crayon, on the assumption they were all sold in the same year
• Electronic waste from hardware sold is assumed to be recycled

Packaging waste reduction

As part of the sustainable device management program, Crayon reduces packaging waste by returning old laptops to procurement vendors in the boxes the new laptops were sent in.

Data limitations

The report does not provide a comprehensive breakdown of total waste generated in tonnes, nor does it separate hazardous from non-hazardous waste quantitatively, or provide detailed diversion rates (recycling, recovery, reuse) versus disposal rates (landfill, incineration).

Policies related to own workforce

Crayon values its employees and strives to create a safe and rewarding work environment for them. Our network of local human resources (HR) representatives, led by the Chief Human Resources Officer, develops, and implements policies and strategies to recruit, select and engage employees.

Global People and Culture Strategy

Our Group-wide people and culture strategy is updated annually and has clear objectives and metrics to enable the HR function to support employees and the organization.

Diversity, Equity and Inclusion Policies

Crayon values and encourages diversity, equity and inclusion (DEI) in its workforce. We believe that DEI broadly covers gender, age, disability and other attributes. We have a global DEI road map that is refreshed annually to guide our DEI initiatives.

DEI Implementation:

• The Crayon Integrity Handbook outlines behaviors expected of our employees such as treating others with respect, being inclusive and examining unconscious biases
• The company builds its culture by making sure all individuals are treated fairly and respectfully, fostering equal pay, and have equitable access to opportunities and resources
• Through this we ensure that Crayon's core values are rooted throughout the organization

Anti-Discrimination Policies

The Group endeavors to promote the objectives of the Norwegian Anti-Discrimination Act in its operations with regard to recruitment, wages and working conditions, promotion, development opportunities and protection against harassment. The Group strives to be a workplace where there is no discrimination.

The purpose of the Norwegian Anti-Discrimination Act is to promote equality, safeguard equal opportunities and rights, and prevent discrimination on the grounds of ethnicity, national origin, descent, skin color, language, orientation, religion, or belief.

Health and Safety Policies

Responsibility for employee health and safety at Crayon is shared between the Human Resources and Trust Unit teams. Sound safety and health practices are integral to our operations, and we comply with all local workplace safety regulations.

Employee Development Policies

As part of our social pillar vision "To serve and develop people inside and outside our organization," we have established focus areas including:

• Employee advocacy, well-being and growth
• Talent attraction and recruitment practices
• Training and skills development
• Employee remuneration and benefits

Employee Engagement Policies

We conduct annual employee feedback surveys to measure engagement and satisfaction across nine categories, achieving an overall score of 4.13 out of 5 in 2024 with a 62% participation rate.

Diversity, equity, inclusion and belonging is identified as one of our top three strategic priorities for 2025, reflecting our commitment to creating an inclusive workplace for all employees.

Processes for engaging with own workforce and workers' representatives about impacts

Employee Representation on Board

Crayon has established formal employee representation at the highest governance level with three employee-elected board members:

• Timmy Herland - Employee Representative (joined 2024)
• Lars Larhammer - Employee Representative (joined 2023)
• Mette Wam - Employee Representative (joined 2022)

These employee representatives participate in all board meetings and committee work, ensuring direct employee voice in strategic decision-making.

Annual Employee Feedback Survey

We conduct comprehensive annual employee feedback surveys to engage with our workforce:

• 62% participation rate in 2024
• 4.13 out of 5 overall score across nine categories
• Results are analyzed and used to inform HR policies and organizational improvements

Leadership Programs and Development

We have established structured programs for employee engagement and development:

• 2024/2025 Female Leadership Program (FLP) - launched to empower women in tech leadership
• Global Empowerment Program (GEP) - first program launched and completed in 2024

Local HR Network

Our network of local human resources (HR) representatives, led by the Chief Human Resources Officer, provides ongoing engagement mechanisms:

• Local HR representatives in key markets provide direct communication channels
• Regular consultation on policies and workplace conditions
• Cultural adaptation of global policies to local contexts across 46 countries

Grievance and Feedback Mechanisms

We have established multiple channels for employees to provide feedback and raise concerns:

• Trust desk for integrity-related concerns
• Whistleblower channel for reporting serious concerns
• Direct communication channels through local HR representatives
• Regular manager-employee dialogues and feedback sessions

Communication and Consultation

Regular engagement occurs through:

• Team meetings and town halls
• Strategic communication of organizational changes
• Consultation on major business decisions that impact employees
• Feedback collection on workplace policies and conditions

With 90 nationalities represented in our workforce of 4,182 employees, we recognize the importance of culturally appropriate engagement approaches adapted to local contexts while maintaining global consistency in our commitment to employee voice and participation.

Processes to remediate negative impacts and channels for own workforce to raise concerns

Formal Grievance Mechanisms

Crayon has established 1 grievance mechanism comprising:

• Trust desk for integrity-related concerns
• Whistleblower channel for reporting serious concerns anonymously

These mechanisms provide employees with safe and confidential channels to report concerns about workplace issues, misconduct, or other problems.

Employee Board Representation

Our three employee-elected board members provide a direct escalation channel for workforce concerns to the highest level of governance:

• Employees can raise issues through their elected representatives
• Board-level oversight of employee-related matters ensures appropriate attention and response

Local HR Support Network

Our network of local HR representatives across 46 countries provides accessible support for employees:

• Direct communication channels for raising workplace concerns
• Culturally appropriate support and guidance
• Escalation pathways for unresolved issues

Anti-Discrimination and Harassment Response

The Group strives to be a workplace where there is no discrimination and has processes to address:

• Discrimination based on ethnicity, national origin, descent, skin color, language, orientation, religion, or belief
• Harassment and unequal treatment
• Promotion of equal opportunities and protection of rights

Health and Safety Response

Responsibility for addressing health and safety concerns is shared between Human Resources and Trust Unit teams:

• Compliance with all local workplace safety regulations
• Investigation and response to safety incidents
• Preventive measures to maintain safe working conditions

Performance and Development Issues

Through our annual employee feedback survey (62% participation rate, 4.13 out of 5 overall score), we:

• Identify areas for improvement in the work environment
• Develop action plans to address employee concerns
• Monitor progress on workplace improvements

Remediation Approach

Our approach to remediation focuses on:

• Prevention through clear policies and regular training
• Early intervention through accessible reporting channels
• Fair investigation of all reported concerns
• Appropriate corrective action when issues are identified
• Follow-up to ensure effectiveness of remediation measures

With diversity, equity, inclusion and belonging as one of our top three strategic priorities for 2025, we are strengthening our processes to ensure all employees have equal access to remediation channels and that negative impacts are addressed promptly and effectively.

Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions

Strategic Priority Actions

As diversity, equity, inclusion and belonging is one of our top three strategic priorities for 2025, we are taking focused action to address material workforce impacts:

Diversity, Equity and Inclusion Programs

• 2024/2025 Female Leadership Program (FLP) launched to empower women in tech leadership
• Global Empowerment Program (GEP) - first program launched and completed in 2024
• Global DEI road map refreshed annually to guide our DEI initiatives

Current Workforce Composition (2024):

Risk Management Actions

Health and Safety

• Zero work-related fatalities or injuries in 2024
• 2.2% absence rate from work due to sickness
• Compliance with all local workplace safety regulations across 46 countries

Employee Engagement and Retention

• Annual employee feedback survey with 62% participation rate
• 4.13 out of 5 overall score across nine engagement categories
• Results used to develop targeted improvement actions

Talent Development and Growth

• Investment in leadership development programs
• 161 new FTEs added during 2024, demonstrating continued growth and opportunity creation
• Focus on internal capability building and career progression

Compensation and Benefits

• Employee Stock Purchase Plan (ESPP) providing all employees opportunity to acquire shares at 20% discount
• NOK 35m in share-based compensation allocated in 2024
• 1,162,752 treasury shares allocated to employees under share-based programs

Anti-Discrimination Measures

• Implementation of Norwegian Anti-Discrimination Act principles
• Crayon Integrity Handbook outlining expected behaviors including treating others with respect and being inclusive
• Focus on equal pay and equitable access to opportunities and resources

Effectiveness Measurement

Positive Indicators:

• High employee engagement scores (4.13/5)
• Strong participation in voluntary programs (62% survey participation)
• Diverse workforce representation (90 nationalities)
• Zero safety incidents in 2024
• Successful completion of empowerment programs

Areas for Improvement:

• Gender balance - currently 32.5% women, with continued focus on improving representation
• Leadership development - ongoing investment in female leadership and empowerment programs

Future Actions (2025 Strategic Priority)

With diversity, equity, inclusion and belonging as a top strategic priority for 2025, we will:

• Expand leadership development programs
• Strengthen DEI measurement and accountability
• Enhance inclusive recruitment practices
• Develop targeted retention strategies for underrepresented groups

Our approach demonstrates systematic attention to workforce-related material impacts with measurable progress and commitment to continuous improvement.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Strategic Priority Target Areas

As diversity, equity, inclusion and belonging is one of our top three strategic priorities for 2025, we have established this as a key target area for workforce-related impacts.

Five-Year ESG Strategy Framework (2025-2030)

Our ESG strategy includes specific focus areas under the Social pillar with the vision "To serve and develop people inside and outside our organization":

Target Focus Areas:

1. Diversity, equity, inclusion & belonging (Strategic Priority 2025)
2. Employee advocacy, well-being and growth
3. Talent attraction and recruitment practices
4. Employee remuneration and benefits
5. Training and skills development metrics

Health and Safety Targets

• Maintain zero work-related fatalities or injuries (achieved in 2024)
• Continue compliance with all local workplace safety regulations across 46 countries
• Maintain low sickness absence rates (2.2% in 2024)

Employee Engagement Targets

• Maintain high employee engagement scores (4.13 out of 5 achieved in 2024)
• Improve survey participation rates (62% in 2024)
• Annual refresh of global DEI road map to guide initiatives

Development and Leadership Targets

• Expand leadership development programs building on:
  • 2024/2025 Female Leadership Program (FLP)
  • Global Empowerment Program (GEP) completion in 2024
• Continued investment in employee development and career progression

Diversity and Inclusion Targets

• Address gender balance improvement from current 32.5% women representation
• Maintain and celebrate workforce diversity (90 nationalities represented)
• Strengthen inclusive recruitment and promotion practices

Employee Ownership and Benefits Targets

• Continue Employee Stock Purchase Plan (ESPP) offering shares at 20% discount
• Maintain employee participation in share-based compensation programs
• Ensure equitable access to benefits and opportunities

Implementation Approach

Following a 'global framework, local ownership' model for ESG strategy implementation, targets will be:

• Set at global level for consistency
• Adapted for local implementation across 46 countries
• Monitored and measured regularly
• Reported transparently in annual sustainability statements

Target Setting Timeline

As part of our five-year ESG strategy (2025-2030), specific quantitative targets will be developed and disclosed during 2025 as we implement our strategic priorities, with particular focus on diversity, equity, inclusion and belonging as the priority area for workforce-related impacts.

Characteristics of the undertaking's employees

Workforce Overview

Gender Composition

Diversity Metrics

Geographic Distribution

Our workforce is distributed across four main market clusters:

• Nordic countries (largest and most mature market)
• Europe
• APAC & MEA (Asia Pacific, Middle East, Africa)
• United States

With operations in 46 countries, our workforce reflects significant geographic diversity, supporting our global customer base of +140,000 customers.

Employee Categories

As a customer-centric IT consultancy, our workforce primarily consists of:

• Technology consultants and specialists
• Sales and customer relationship professionals
• Software and cloud services experts
• Data and AI solution specialists
• Support and administrative functions

Employment Types

The reported figure of 4,182 represents full-time equivalent (FTE) employees, indicating our workforce is primarily composed of full-time permanent employees across our global operations.

Workforce Development

Our diverse workforce of 90 nationalities supports our mission to be a global leader in IT consultancy, bringing varied perspectives, cultural insights, and technical expertise to serve customers across different markets and industries worldwide.

Diversity metrics

Gender Diversity

Nationality and Cultural Diversity

Age Diversity

Board Diversity

Our Board of Directors demonstrates diversity across multiple dimensions:

Board Composition by Gender:

• Total Board Members: 10
• Women: 3 members (30%)
• Men: 7 members (70%)

Board Composition by Role:

• Shareholder-elected: 7 members
• Employee representatives: 3 members

Board Composition by Independence:

• Independent members: 5
• Dependent members: 2
• Employee representatives: 3

Strategic Commitment to Diversity

Diversity, equity, inclusion and belonging is identified as one of our top three strategic priorities for 2025, demonstrating our commitment to advancing diversity across all levels of the organization.

Current Diversity Initiatives:

• 2024/2025 Female Leadership Program (FLP) to empower women in tech leadership
• Global Empowerment Program (GEP) completed in 2024
• Global DEI road map refreshed annually to guide diversity initiatives

Areas for Improvement

While we celebrate our cultural and age diversity with 90 nationalities represented, we recognize opportunities for improvement in gender balance, particularly in leadership positions, which is why we have prioritized diversity, equity, inclusion and belonging as a strategic focus for 2025.

Our diversity metrics reflect our global nature as an IT consultancy operating across 46 countries, bringing together professionals from diverse backgrounds to serve our international customer base.

Training and skills development metrics

Leadership Development Programs

Female Leadership Program

• 2024/2025 Female Leadership Program (FLP) launched to empower women in tech leadership
• Program specifically designed to address gender balance in leadership positions
• Supports our strategic priority of diversity, equity, inclusion and belonging

Global Empowerment Program

• Global Empowerment Program (GEP) - first program launched and completed in 2024
• Global reach across our 46 countries of operation
• Focus on employee empowerment and capability development

Strategic Training Focus Areas

As part of our Social pillar with vision "To serve and develop people inside and outside our organization," we have established focus areas including:

• Employee advocacy, well-being and growth
• Talent attraction and recruitment practices
• Training and skills development metrics

Skills Development in Technology

Given our role as a customer-centric IT consultancy, our workforce development focuses on:

AI and Technology Expertise

• 10 years of Data & AI excellence celebrated in 2024
• Continuous upskilling in Generative AI solutions
• Cloud services and cybersecurity expertise development

Professional Certifications and Partnerships

• Microsoft partnership expertise development
• AWS certification and training programs
• Broadcom and other vendor-specific training

Employee Growth and Development

Workforce Investment

• 161 new FTEs added in 2024 demonstrating continued investment in talent
• Focus on internal capability building and career progression
• Cross-cultural development with 90 nationalities represented

Employee Engagement in Development

• Annual employee feedback survey with 62% participation rate
• 4.13 out of 5 overall score across nine categories including development opportunities
• Results used to improve training and development programs

Skill Development Metrics (Qualitative)

Technical Excellence

• Recognition as Microsoft Partner of the Year for Scale Solutions (LSP)
• Gartner Magic Quadrant Leader for Software Asset Management Managed Services (fourth consecutive year)
• AWS EMEA Telco Partner of the Year recognition

Innovation Capability

• Featured in United Nations Gen AI for Global Goals report highlighting AI innovation leadership
• Development of proprietary platforms like Cloud-iQ and Crayon Cloud Cost Control

Future Development Commitments

With training and skills development as a focus area under our five-year ESG strategy (2025-2030), we are committed to:

• Expanding leadership development programs
• Strengthening technical capabilities in emerging technologies
• Measuring and reporting quantitative training metrics in future reporting periods

Our approach to skills development reflects our commitment to employee growth while building capabilities that serve our customers' evolving technology needs across 46 countries worldwide.

Health and safety metrics

2024 Health and Safety Performance

Health and Safety Management

Governance Structure

Responsibility for employee health and safety at Crayon is shared between:

• Human Resources teams
• Trust Unit teams

Compliance Framework

• Sound safety and health practices are integral to our operations
• Full compliance with all local workplace safety regulations across 46 countries
• Systematic approach to health and safety management aligned with local requirements

Safety Performance Achievement

Zero Harm Results

• No work-related fatalities in 2024
• No work-related injuries reported in 2024
• Demonstrates effective prevention and safety management systems

Absence Management

• 2.2% absence rate from work due to sickness in 2024
• Low absence rate indicates effective health and wellbeing support
• Reflects positive work environment and employee health initiatives

Health and Safety as Part of ESG Strategy

Health and safety considerations are integrated into our broader ESG approach:

Employee Wellbeing Focus

• Part of our Social pillar: "To serve and develop people inside and outside our organization"
• Employee advocacy, well-being and growth identified as a key focus area
• Links to our strategic priority of diversity, equity, inclusion and belonging

Global Implementation

• Consistent health and safety standards across 46 countries
• Local adaptation to comply with varying national regulations
• 4,182 FTEs covered by our health and safety programs

Risk Management Approach

As part of our systematic risk management:

• The Board regularly reviews risk profiles including health and safety risks
• Integration with our broader enterprise risk management framework
• Preventive approach focusing on maintaining safe working conditions

Future Commitment

Our target is to maintain zero work-related fatalities or injuries and continue our strong health and safety performance as we expand our global operations and workforce.

The excellent 2024 health and safety performance reflects our commitment to providing a safe and healthy work environment for all employees across our diverse, international operations.

Compensation metrics (pay gap and total compensation)

Share-Based Compensation

Employee Stock Purchase Plan (ESPP)

Program Structure

• Discount offered: 20% discount to market price
• Eligibility: All employees globally
• Lock-up period: 2 years
• Bonus provision: 1 additional bonus share for every 3 shares acquired after lock-up
• Frequency: Annual offering

Share Capital Authorization

• Board authorization: Up to NOK 5,374,495 for incentive schemes
• Maximum percentage: 6.0% of Company's share capital
• Purpose: Employee share-based compensation programs

Equity Participation

Employee Ownership Encouragement

• Board members encouraged to own shares in the Company
• Global participation: Program available to all 4,182 FTEs across 46 countries
• Alignment with shareholders: Employee interests aligned with company performance

Compensation Philosophy

Equal Treatment Principles

As part of our commitment to diversity, equity, inclusion and belonging (strategic priority for 2025):

• Focus on equal pay and equitable access to opportunities
• Fair and respectful treatment of all individuals
• Alignment with Norwegian Anti-Discrimination Act principles

Remuneration Governance

• Remuneration Committee oversight of compensation policies
• Board approval of executive compensation
• Annual review of compensation structures

Total Compensation Components

Direct Compensation

• Base salaries (not disclosed in detail)
• Share-based compensation: NOK 35 million in 2024
• Employee Stock Purchase Plan participation opportunity

Benefits and Development

• Leadership development programs (Female Leadership Program, Global Empowerment Program)
• Training and skills development opportunities
• Global mobility and career development across 46 countries

Pay Equity Commitment

While specific pay gap metrics are not disclosed in this reporting period, our commitment includes:

• Equal pay as part of DEI strategy
• Equitable access to opportunities and resources
• Fair compensation practices aligned with anti-discrimination principles

Future Disclosure

With diversity, equity, inclusion and belonging as a top strategic priority for 2025, we anticipate enhanced disclosure of pay equity metrics in future reporting periods as part of our five-year ESG strategy implementation (2025-2030).

Our compensation approach reflects our commitment to treating all employees fairly while aligning their interests with long-term company success through meaningful equity participation opportunities.

Incidents, complaints and severe human rights impacts

Grievance Mechanism Performance

Grievance Mechanism Structure

• Trust desk for integrity-related concerns
• Whistleblower channel for confidential reporting of serious concerns
• Available to all employees across 46 countries
• Multiple reporting options to ensure accessibility

Human Rights Incidents (2024)

Work-Related Safety Incidents

• Work-related fatalities: 0
• Work-related injuries: 0
• Safety incidents: No incidents reported

Discrimination and Harassment

• Our commitment to be a workplace where there is no discrimination
• Implementation of Norwegian Anti-Discrimination Act principles
• Focus on preventing discrimination based on ethnicity, national origin, descent, skin color, language, orientation, religion, or belief

Complaint Handling Process

Reporting Channels

• Direct reporting through local HR representatives across 46 countries
• Anonymous reporting through whistleblower channel
• Board-level escalation through three employee-elected board representatives
• Trust desk for integrity concerns

Response Framework

• Investigation procedures for reported concerns
• Remediation processes for identified issues
• Follow-up mechanisms to ensure effectiveness
• Protection against retaliation for reporters

Human Rights Due Diligence

Policy Framework

• Crayon Integrity Handbook outlining expected behaviors including respect and inclusion
• Anti-discrimination policies aligned with Norwegian legislation
• Health and safety compliance with local regulations across all operating countries

Preventive Measures

• Employee training on respectful workplace behavior
• Cultural sensitivity programs for diverse workforce (90 nationalities)
• Leadership development including diversity and inclusion components

Severe Human Rights Impacts

Assessment Results (2024)

• No severe human rights impacts identified in our operations
• Zero tolerance approach to human rights violations
• Proactive prevention through policies and training

Stakeholder Engagement

Employee Voice Mechanisms

• Annual employee feedback survey: 62% participation rate, 4.13/5 overall score
• Employee board representation: 3 elected employee representatives
• Regular consultations through local HR networks

External Engagement

• United Nations Global Compact signatory since 2020
• Commitment to 10 principles spanning labor and human rights
• ESG platform participation for accountability and transparency

Strategic Priority Integration

With diversity, equity, inclusion and belonging as one of our top three strategic priorities for 2025:

• Enhanced focus on preventing discrimination and promoting inclusion
• Strengthened grievance mechanisms and response capabilities
• Improved monitoring and reporting of human rights-related metrics

Future Commitments

As part of our five-year ESG strategy (2025-2030), we will:

• Continue maintaining zero severe human rights impacts
• Enhance grievance mechanism effectiveness measurement
• Strengthen human rights due diligence across our global operations
• Improve transparency in human rights impact reporting

Our performance demonstrates effective human rights risk management with no severe impacts reported and robust systems in place for prevention, detection, and response to potential human rights concerns.

Policies related to value chain workers

Crayon has established policies and practices to address labor and human rights in our value chain as part of our ESG strategy.

Value Chain Human Rights Focus

As part of our Social pillar with vision "To serve and develop people inside and outside our organization," we have identified labor and human rights in the value chain as a specific focus area under our five-year ESG strategy (2025-2030).

Due Diligence Approach

Credit Risk and Supplier Management

• Subsidiaries are responsible for performing credit check and control with suppliers and partners
• Group Treasury oversight of credit risk on a centralized level
• Systematic evaluation of counterparties and business partners

Supplier Relationship Management

• Engagement in dialogue with both end users and software vendors to agree on balanced solutions
• Compliance management with vendor terms and conditions
• Risk assessment of business relationships throughout the value chain

Partnership Standards

Global Software Vendor Relationships

Crayon maintains strategic relationships with major global software vendors including:

• Microsoft (recognized as global winner Microsoft Scale Solutions LSP Partner of the Year)
• AWS (appointed as Authorized Distributor for European Economic Area)
• Broadcom (authorized Cloud Commerce Manager for VCSP partners)
• Google, Adobe, and other major technology providers

These partnerships involve alignment with vendor ethical standards and responsible business practices.

Compliance Framework

Anti-Corruption and Integrity

• ISO 37001 Global certification for our anti-bribery and corruption management system
• Crayon Integrity Handbook outlining expected behaviors for business relationships
• Zero tolerance approach to corruption and unethical business practices

Business Ethics Integration

• Business ethics and integrity identified as a focus area under our Governance pillar
• Corporate governance standards applied to value chain relationships
• Enterprise risk management including value chain risk assessment

United Nations Global Compact Commitment

As a signatory to the United Nations Global Compact since 2020, we embrace its 10 principles which span:

• Labor rights including freedom of association and elimination of forced labor
• Human rights including support and respect for internationally proclaimed human rights
• Environment and anti-corruption principles

These principles guide our approach to value chain worker rights and conditions.

Implementation Across Global Operations

Geographic Scope

• Policies apply across operations in 46 countries
• Local adaptation while maintaining global standards
• Cultural sensitivity in implementation across diverse markets

Industry-Specific Considerations

As an IT consultancy, our value chain primarily involves:

• Software vendors and technology partners
• Professional service providers
• Technology infrastructure suppliers
• Local business service providers

Future Development

With labor and human rights in the value chain as a specific focus area in our ESG strategy, we will:

• Enhance due diligence processes for value chain partners
• Strengthen monitoring of worker conditions in our supply chain
• Develop more detailed policies and procedures for value chain human rights
• Improve transparency and reporting on value chain worker impacts

This represents our commitment to responsible business practices throughout our global value chain and ensuring respect for worker rights beyond our direct employment relationships.

Business conduct policies and corporate culture

Corporate Culture Foundation

Crayon's corporate culture is built on four core values based on our Nordic heritage:

Business Ethics and Integrity Policies

ISO 37001 Certification

• Global certification for our anti-bribery and corruption management system
• Systematic approach to preventing, detecting and addressing bribery and corruption
• Regular audits and compliance monitoring across 46 countries

Integrity Framework

• Crayon Integrity Handbook outlining expected behaviors for all employees
• Clear guidelines on ethical conduct in business relationships
• Zero tolerance approach to corruption and unethical business practices

Corporate Governance Policies

Governance Framework

Crayon considers good corporate governance to be a prerequisite for value creation, trustworthiness and access to capital. Our governance approach includes:

• Board oversight with independent directors and audit committee
• Clear division of responsibilities between board and executive management
• Regular risk assessment and internal controls
• Transparent reporting and stakeholder communication

Compliance Management

• Compliance with legislation and regulations across Crayon Group
• Norwegian Code of Practice for Corporate Governance adherence
• Securities trading regulations and insider trading policies
• Local regulatory compliance in all 46 operating countries

Business Conduct Implementation

ESG Integration

Business ethics and integrity is identified as one of our key focus areas under the Governance pillar of our ESG strategy, with the vision "To infuse honest and ethical conduct into everything we do."

Risk Management

• Systematic management of risk in all parts of the business
• Enterprise risk management as a governance focus area
• Regular review of risk profiles by the Board of Directors

Employee Standards

• Trust desk for integrity-related concerns
• Whistleblower channel for confidential reporting
• Training and awareness on business ethics and integrity
• Anti-discrimination policies and inclusive workplace practices

International Standards Alignment

United Nations Global Compact

As a signatory since 2020, we embrace the 10 principles covering:

• Human rights support and respect
• Labour standards including freedom of association
• Environmental responsibility
• Anti-corruption including working against all forms of corruption

External Validation

• Ecovadis score: 72% in 2024 (silver medal, top 15% of evaluated companies)
• CDP climate disclosure: B- score in 2024
• Regular ESG platform participation for accountability

Data Privacy and Information Security

Data Protection Policies

• Zero data breaches reported in 2024
• Data privacy and information security as a governance focus area
• Compliance with applicable data protection regulations across operating jurisdictions

Information Security Management

• Systematic approach to protecting customer and business information
• Regular security assessments and improvements
• Employee training on data security and privacy requirements

Responsible AI Governance

Responsible AI is identified as one of our top three strategic priorities for 2025, demonstrating our commitment to ethical technology practices:

• Featured in United Nations Gen AI for Global Goals report for responsible AI practices
• Development of AI governance frameworks
• Ethical considerations in AI solution development and deployment

Stakeholder Trust and Transparency

Our approach to business conduct emphasizes:

• Transparent communication with investors, customers, and stakeholders
• Ethical business relationships with partners and suppliers
• Accountability for actions and decisions
• Continuous improvement in governance and ethical practices

This comprehensive approach to business conduct and corporate culture ensures that Crayon operates with integrity while building trust with all stakeholders across our global operations in 46 countries.

Management of relationships with suppliers

Crayon maintains systematic approaches to managing supplier relationships as part of our business operations and risk management framework.

Supplier Risk Management

Credit Risk and Control

• Group Treasury oversight of credit risk on a centralized level
• Subsidiaries responsibility for performing credit check and control with suppliers
• Systematic evaluation of counterparties and business relationships
• Enforcement of payment terms and conditions with suppliers

Due Diligence Processes

• Credit assessment of potential suppliers and partners
• Risk assessment of business relationships throughout the value chain
• Regular monitoring of supplier financial stability and compliance
• Balanced solutions approach when disputes arise between parties

Strategic Vendor Relationships

Crayon has established strong strategic relationships with all key global software vendors:

Microsoft Partnership

• Global winner Microsoft Scale Solutions (LSP) Partner of the Year in 2024
• Fifth largest global Microsoft partner
• Strong cloud and service capability recognition
• Deep integration with Microsoft's partner incentive programs

AWS Partnership

• Appointed as AWS Authorized Distributor for European Economic Area (including Switzerland) in 2024
• AWS Authorized Distributor in India since 2019
• AWS EMEA Telco Partner of the Year recognition
• Member of AWS Generative AI Partner Innovation Alliance

Other Key Partnerships

• Broadcom Cloud Commerce Manager (CCM) for VMware Cloud Service Provider (VCSP) partners in Asia Pacific
• Global partnership with Google for Cloud AI and security solutions
• Adobe EMEA Best Growth Partner recognition
• Authorized reseller relationships with various technology providers

Supplier Management Policies

Integrity and Compliance Standards

• ISO 37001 Global certification for anti-bribery and corruption management applied to supplier relationships
• Crayon Integrity Handbook guidelines for ethical business relationships
• Zero tolerance approach to corruption in supplier interactions

ESG Integration in Supplier Relations

As part of our ESG strategy, labor and human rights in the value chain is identified as a focus area, indicating our commitment to:

• Monitoring supplier labor practices
• Ensuring ethical standards throughout our supply chain
• Promoting human rights in business relationships

Operational Supplier Management

Payment and Contract Management

• Efficient management of payment terms with suppliers
• Timely and accurate payment processes
• Working capital optimization in supplier relationships
• Contract compliance monitoring and enforcement

Dispute Resolution

• Dialogue-based approach to resolving supplier disputes
• Balanced solutions that consider all parties' interests
• Escalation processes for complex supplier issues
• Legal compliance in all supplier relationship management

Technology Platform Integration

Cloud-iQ Platform

Integration of supplier services through our proprietary platform:

• Microsoft Azure Marketplace integration
• Adobe VIP Marketplace integration with enhanced self-service features
• Multi-vendor software procurement capabilities
• Automated procurement and management tools

Supply Chain Risk Management

As part of our systematic risk management approach:

• Regular assessment of supplier risk profiles
• Diversification of supplier relationships to reduce dependency
• Contingency planning for critical supplier relationships
• Compliance monitoring across global supplier network

Geographic Supplier Management

Global Supplier Network

• Supplier relationships managed across 46 countries of operation
• Local adaptation of supplier management practices
• Cultural sensitivity in international supplier relationships
• Regulatory compliance with local supplier management requirements

Future Supplier Relationship Development

With labor and human rights in the value chain as a focus area in our five-year ESG strategy (2025-2030), we will:

• Enhance due diligence processes for suppliers
• Strengthen ESG criteria in supplier selection and evaluation
• Improve monitoring of supplier sustainability performance
• Develop more detailed supplier codes of conduct and requirements

Our approach to supplier relationship management reflects our commitment to building trusted, ethical, and sustainable business partnerships while managing risks and ensuring value creation for all stakeholders.

Prevention and detection of corruption and bribery

Crayon has implemented comprehensive systems and policies to prevent and detect corruption and bribery across all operations.

ISO 37001 Anti-Bribery Management System

Global Certification

• ISO 37001 Global certification for our anti-bribery and corruption management system
• Systematic approach to preventing, detecting and addressing bribery and corruption
• Regular audits and compliance monitoring across 46 countries
• Continuous improvement of anti-corruption controls and procedures

Management System Components

• Risk assessment procedures for corruption and bribery risks
• Due diligence processes for business partners and third parties
• Training and awareness programs for employees
• Monitoring and review mechanisms
• Incident reporting and investigation procedures

Anti-Corruption Policies and Procedures

Zero Tolerance Policy

• Zero tolerance approach to corruption and unethical business practices
• Clear prohibition of all forms of bribery and corruption
• Strict enforcement of anti-corruption policies across global operations

Crayon Integrity Handbook

• Comprehensive guidance on ethical conduct and anti-corruption requirements
• Clear expectations for employee behavior in business relationships
• Specific guidelines on gifts, entertainment, and business courtesies
• Conflict of interest management procedures

Detection and Reporting Mechanisms

Whistleblower Systems

• Whistleblower channel for confidential reporting of corruption concerns
• Anonymous reporting options to protect whistleblowers
• Trust desk for integrity-related concerns including corruption issues
• Multiple reporting channels accessible to all employees across 46 countries

Internal Controls

• Financial controls designed to detect irregular payments or transactions
• Expense monitoring and approval procedures
• Third-party payment verification and authorization processes
• Regular internal audits focusing on corruption risk areas

Risk Assessment and Due Diligence

Business Partner Screening

• Credit check and control processes for business partners
• Due diligence procedures for suppliers, customers, and intermediaries
• Enhanced due diligence for high-risk relationships and jurisdictions
• Ongoing monitoring of business partner relationships

Geographic Risk Management

• Country-specific risk assessment across 46 operating countries
• Local compliance with anti-corruption laws and regulations
• Cultural adaptation of policies while maintaining global standards

Training and Awareness

Employee Training Programs

• Regular anti-corruption training for all employees
• Role-specific training for employees in high-risk positions
• Leadership training on corruption prevention and ethical leadership
• Awareness campaigns to reinforce anti-corruption culture

Communication and Reinforcement

• Regular communication of anti-corruption policies and expectations
• Case studies and examples to illustrate corruption risks and prevention
• Updates on regulatory changes and best practices

Governance and Oversight

Board and Executive Oversight

• Board oversight of anti-corruption programs and performance
• Executive accountability for corruption prevention
• Regular reporting to board on anti-corruption program effectiveness
• Integration with overall enterprise risk management

ESG Integration

Business ethics and integrity is identified as a key focus area under our Governance pillar, with vision "To infuse honest and ethical conduct into everything we do."

International Standards Compliance

United Nations Global Compact

As a signatory since 2020, we are committed to Principle 10: "Businesses should work against corruption in all its forms, including extortion and bribery."

External Recognition

• Ecovadis score of 72% in 2024, earning silver medal and placing in top 15% of evaluated companies
• Recognition for strong anti-corruption and business ethics practices

Performance Monitoring

Key Performance Indicators

• Zero tolerance incidents tracked and reported
• Training completion rates monitored across all regions
• Whistleblower reports investigated and resolved
• Audit findings addressed and remediated

Continuous Improvement

• Regular review of anti-corruption policies and procedures
• Best practice sharing across global operations
• Lessons learned integration from incidents or near-misses
• External benchmarking against industry standards

Crayon's comprehensive approach to corruption and bribery prevention demonstrates our commitment to conducting business with the highest ethical standards while maintaining the trust of stakeholders, customers, and business partners worldwide.

Incidents of corruption or bribery

2024 Corruption and Bribery Incident Report

Incident Statistics

Based on our comprehensive anti-corruption management system and reporting mechanisms, no incidents of corruption or bribery were reported or identified in 2024.

Reporting and Detection Systems Performance

Whistleblower and Reporting Channels

• 1 grievance mechanism comprising Trust desk and whistleblower channel
• Zero corruption-related reports received through these channels in 2024
• Anonymous reporting capability maintained and accessible to all employees
• Multiple reporting options available across 46 countries of operation

ISO 37001 System Effectiveness

• Global ISO 37001 certification maintained throughout 2024
• Regular monitoring and auditing conducted as part of certified management system
• No corruption incidents identified through systematic monitoring processes
• Compliance verification through external certification audits

Zero Tolerance Policy Implementation

Prevention Effectiveness

• Zero incidents demonstrates effective prevention measures
• Comprehensive policies successfully implemented across global operations
• Training and awareness programs effective in preventing corruption risks
• Strong internal controls functioning as intended

Risk Management Success

• Systematic risk assessment processes identifying and mitigating corruption risks
• Due diligence procedures for business partners preventing high-risk relationships
• Geographic risk management effective across diverse operating environments
• Cultural adaptation of policies successful while maintaining global standards

Investigation and Resolution Procedures

Investigation Capabilities

• Established investigation procedures ready for deployment if needed
• Trained personnel available to conduct corruption-related investigations
• External support available for complex or serious allegations
• Legal compliance procedures in place for reporting and resolution

Remediation Framework

• Clear remediation procedures established for potential future incidents
• Disciplinary measures defined for policy violations
• System improvement processes to address any identified weaknesses
• Stakeholder communication protocols for transparency and accountability

Continuous Monitoring and Improvement

Ongoing Vigilance

• Regular system reviews to maintain corruption prevention effectiveness
• Best practice updates incorporated into policies and procedures
• Employee feedback considered for system improvements
• External benchmark comparisons conducted

ESG Integration Impact

With business ethics and integrity as a focus area under our Governance pillar, our zero-incident performance reflects:

• Strong governance culture embedded throughout the organization
• Effective integration of anti-corruption measures into daily operations
• Leadership commitment to ethical conduct at all levels
• Stakeholder trust maintained through transparent and ethical business practices

External Validation

Third-Party Recognition

• Ecovadis score of 72% (silver medal, top 15% of companies) includes assessment of anti-corruption practices
• United Nations Global Compact participation demonstrates commitment to anti-corruption principles
• No regulatory issues or external investigations related to corruption

Future Commitment

Maintaining Zero Incidents

Our commitment going forward includes:

• Continued vigilance in corruption prevention and detection
• Ongoing investment in training, systems, and controls
• Regular review and improvement of anti-corruption measures
• Transparent reporting of any future incidents should they occur

The zero incidents of corruption or bribery in 2024 reflects the effectiveness of Crayon's comprehensive anti-corruption program and our commitment to conducting business with the highest ethical standards across all 46 countries of operation.

Political influence and lobbying activities

Political Activities and Lobbying Approach

Crayon maintains a focused business approach that prioritizes customer service and technology solutions over political engagement or lobbying activities.

Limited Political Engagement

Business Model Focus

As a customer-centric IT consultancy, Crayon's primary focus is on:

• Technology procurement and optimization services
• Cloud services and AI solutions
• Software asset management and compliance
• Professional consulting and managed services

Market Engagement Approach

• Industry participation in technology sector forums and associations
• Customer-focused engagement primarily with private and public sector clients
• Vendor partnership activities with major technology providers like Microsoft, AWS, and Google
• Professional networking within the IT services industry

Regulatory Compliance and Engagement

Regulatory Environment

• Compliance-focused approach to regulatory requirements across 46 countries
• Transparency in regulatory reporting and disclosure obligations
• Adherence to local laws and regulations without active political lobbying

Industry Standards Participation

• United Nations Global Compact signatory since 2020 (principles-based engagement)
• CDP climate disclosure participation (environmental transparency)
• Ecovadis ESG performance assessment participation
• ISO certifications (14001 Environmental, 37001 Anti-bribery)

Corporate Governance and Political Activities

Board Oversight

• Board oversight of all significant external relationships and commitments
• Risk management approach to any political or regulatory engagement
• Transparent governance of external stakeholder relationships

ESG Integration

Corporate governance is identified as a focus area under our Governance pillar, ensuring:

• Appropriate oversight of any political or lobbying activities
• Ethical conduct in all external engagements
• Stakeholder transparency regarding political positions or activities

Business Ethics in Political Context

Anti-Corruption Framework

• ISO 37001 global certification includes provisions regarding political contributions and lobbying
• Zero tolerance for corruption including political corruption
• Clear policies regarding any political contributions or activities

Integrity Standards

• Crayon Integrity Handbook provides guidance on political activities and contributions
• Ethical conduct requirements for all employees in political contexts
• Conflict of interest management including political interests

Stakeholder Engagement vs. Lobbying

Customer Engagement

• Public sector customers engagement focused on technology solutions and services
• Private sector partnerships for business development and innovation
• Industry collaboration for technology advancement and best practices

Partner Ecosystem

• Technology vendor relationships for product development and market access
• Channel partner engagement for business growth and customer service
• Professional association participation for industry knowledge and networking

Disclosure and Transparency

Current Status

Based on available information in this reporting period:

• No significant lobbying activities identified or reported
• No political contributions disclosed
• No dedicated lobbying personnel or budget identified
• Focus remains on business operations and customer service

Future Disclosure Commitment

As part of our commitment to corporate governance and transparency:

• Clear disclosure of any significant political activities should they develop
• Board oversight of any future political engagement strategies
• Stakeholder transparency regarding political positions or lobbying efforts

Industry Representation

Technology Sector Engagement

Crayon's external engagement primarily focuses on:

• Technology industry forums and conferences
• Customer advisory groups and user communities
• Partner ecosystem events and collaboration
• Professional development and certification programs

This approach reflects our commitment to serving customers and advancing technology solutions rather than engaging in political advocacy or lobbying activities. Any future changes to this approach would be subject to appropriate governance oversight and transparent disclosure to stakeholders.

Payment practices

Crayon maintains systematic payment practices as part of our financial management and supplier relationship management across global operations.

Payment Terms Management

Supplier Payment Framework

• Efficient management of payment terms with suppliers as a key business practice
• Timely and accurate payment processes maintained across 46 countries
• Working capital optimization through balanced management of payment terms
• Contract compliance monitoring and enforcement in payment arrangements

Centralized Financial Management

• Group Treasury oversight of payment practices and cash flow management
• Subsidiaries responsibility for local payment execution and supplier relations
• Multi-currency cash pool arrangements to improve payment flexibility across borders
• Systematic payment scheduling and approval processes

Working Capital Management

Payment Optimization Strategy

Working capital management was a key focus area during 2024, with strong improvement delivered:

• Strong improvement in working capital across all four quarters of 2024
• Balanced approach to optimizing both receivables and payables
• Efficient payment terms management with suppliers contributing to improvement

Credit and Risk Management

Payment Risk Assessment

• Credit risk oversight on centralized level through Group Treasury
• Credit check and control performed by subsidiaries for payment counterparties
• Risk assessment of payment terms and supplier financial stability
• Monitoring of overdue payments and collection activities

Dispute Resolution

• Dialogue-based approach to resolving payment disputes
• Balanced solutions considering all parties' interests
• Legal compliance in payment dispute management
• Escalation processes for complex payment issues

Technology Platform Integration

Automated Payment Systems

• Cloud-iQ platform integration for streamlined procurement and payment processes
• Automated payment processing where appropriate
• Digital payment capabilities across multiple currencies and countries
• Integration with vendor payment systems and marketplaces

Payment Practice Governance

Internal Controls

• Systematic approval processes for significant payments
• Segregation of duties in payment authorization and execution
• Regular monitoring of payment terms compliance
• Internal audit coverage of payment processes

ESG Integration

Enterprise risk management as a governance focus area includes:

• Payment risk management as part of overall risk framework
• Ethical payment practices aligned with anti-corruption policies
• Supplier relationship management including fair payment practices

Liquidity and Cash Flow Management

Payment Capability

• Strong cash position of NOK 1,654m at year-end 2024
• Liquidity reserve of NOK 3,518m including undrawn credit facilities
• Reliable payment capability to suppliers and business partners
• Predictable payment scheduling supporting supplier relationships

Financial Facility Management

• NOK 1,200m unsecured bond providing payment flexibility
• NOK 1,500m revolving credit facility for working capital support
• Overdraft facilities (NOK 300m with Danske Bank, EUR 10m with ING)
• Multi-currency capabilities supporting global payment requirements

Regional Payment Practices

Global Standardization

• Consistent payment practices across 46 countries of operation
• Local adaptation to comply with regional payment regulations and customs
• Cultural sensitivity in payment timing and communication practices
• Regulatory compliance with local payment and tax requirements

Supplier Relationship Impact

Payment Terms as Relationship Management

• Fair payment terms supporting long-term supplier relationships
• Transparent payment processes and communication
• Reliable payment execution building trust with business partners
• Flexibility in payment arrangements where appropriate and beneficial

Performance Monitoring

Payment Practice Metrics

• Working capital improvement demonstrates effective payment management
• Supplier satisfaction with payment terms and execution
• Cash flow optimization through efficient payment timing
• Risk mitigation through prudent payment practices

Crayon's payment practices reflect our commitment to maintaining strong supplier relationships, optimizing working capital, and ensuring reliable financial management across our global operations while supporting sustainable business growth.