GROUP MANUAL Sustainability Environment Management Valid from: Page: 1 of 10

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1 Page: 1 of 10 Manual owner: Approver: SVP and Head of Group Sustainability EVP and Head of Group Corporate Affairs 1 PURPOSE AND SCOPE Purpose Scope MAIN PRINCIPLES Climate Emissions and Energy Consumption Other Emissions to Water, Soil and Air Waste Management and Recycling Installations and Radio Wave Emissions Sustainable Sourcing ACTION STEPS Stepwise approach Planning Implementation, operation and local procedures Verification and corrective actions Management Review KEY ROLES AND RESPONSIBILITIES SUMMARY OF REPORTING REQUIREMENTS Attachments External regulation Other Telenor Governing document DEFINITIONS CHANGE LOG... 10

2 Page: 2 of This Group Manual sets out mandatory requirements for the Business Units in Telenor to support the implementation of the principles in Group Policy Sustainabiity. An Environmental Management System will enable the Business Unit to: Set targets and manage the Business Unit's Environmental Impact, in accordance with the Group's Key Performance Indicator (KPI) on climate and any other relevant non-financial Group KPIs and local BU KPIs Serve customers who request documentation regarding the Business Unit s environmental performance Report relevant and accurate data to investors, governments and analysts who seek information on the Group s environmental performance This manual provides requirements for the identification of any significant Environmental Aspects, as well as outlining the overall principles, based on ISO 14001:2015, for how such aspects shall be managed, monitored and reported. 1.2 This Group Manual shall be developed, implemented, monitored and enforced as part of Governance in Telenor in accordance with requirements in the Governing Principles document. 2 Telenor is committed to minimize its environmental impact and the Business Unit shall make all reasonable efforts to minimize use of resources including energy, water and raw materials. The Business Unit shall adhere to local and internationally recognized environmental and energy efficiency standards, as adhered to by Telenor Group. Our commitments shall be based on continuous improvement in the Business Unit.

3 Page: 3 of 10 The Business Unit hall also support business initiatives using communications services to develop eco-efficient solutions. The most important environmental aspects within Telenor: 2.1 As the threat of climate change increases, so does the risks to the Business Units. Climate Change increases risks for potential damages to vital infrastructure for the Business Unit and the other sectors in society through impact of more extreme weather events. The Business Unit shall have an updated risk assessment for its operations focusing on extreme weather events related to climate change. The results from this risk assessment shall be used proactively in planning of network expansion as well as reactively with regard to protecting existing infrastructure. The Business Units will risk continued growth in their total energy consumption and carbon footprint as The BUs continue to increase their coverage, acquire more customers and develop more mobile broadband services due to market needs. Telenor Group s key focus is to stabilise its total energy consumption by improving the energy efficiency in the BU s network operations, as these represent around 80% of its total energy consumption. All Business Units shall therefore focus on choosing cost-efficient energy-efficiency initiatives: network swaps, the sourcing of energy-efficient technologies, infrastructure-sharing and more energy-efficient data centres and buildings. Climate change also represent business opportunities to enable greenhouse gas (GHG) emission reductions in key sectors of society by offering solutions that contribute to energy efficiency and increased use of renewable energy sources. The Business Unit shall investigate potential business initiatives and partnerships for offering such eco-efficient solutions to key sectors of the economy; such as innovative products and services for the power sector, transportation sector, manufacturing sector, service and consumer sector, agricultural sector and building sector. The Businss Unit shall seek to minimize CO2 emissions from transport and travel. Environmentally friendly telecommunications solutions shall be considered as an alternative to travel. If travel is required, the environmental impact of alternative

4 Page: 4 of 10 means of transportation must be considered, and the most environmentally friendly alternative shall be the preferred option. 2.2 Telenor shall seek to minimize the level of harmful emissions to water, soil and air. 2.3 Telenor shall secure sustainable waste management, including reducing resource consumption, reusing equipment rather than dispose of it, and promoting recycling. All electronic waste shall be reused, recycled or safely disposed and the Business Units shall ensure that these processes are conducted according to internationally recognised standards and regulations. A Group Guideline for E-waste and Recycling has been developed and it sets out guidance for how the Business Unit shall carry out waste management to follow up the overall Group requirements. 2.4 Telenor shall seek to minimize any visual, aesthetic or noise related impact on the local environment when locating and constructing its buildings, structures and equipment Telenor is committed to the health and safety of our customers, employees and communities where Telenor operates. Whenever Telenor installs new network equipment, we shall ensure public health and safety by adhering strictly to the electromagnetic exposure guidelines of the International Commission on Non-Ionizing Radiation Protection (ICNIRP). These guidelines are endorsed by the World Health Organisation (WHO). Telenor shall seek to provide our stakeholders with objective information regarding any health concerns related to our installations, services and products. 2.5 Implementation of sustainable criteria in procurement processes for large contracts is mandatory and shall be conducted in line with guidance and governing documents from Group Sustainability and Global Sourcing.

5 Page: 5 of This manual describes the steps required to develop and maintain an efficient Environmental Management System in all Business Units. The EMS may be a part of a general management system in the Business Unit with references to several external standards. The Business Unit shall operate in accordance with ISO This will enable the Group to demonstrate that the Environmental Management System complies with internationally recognised requirements and to secure alignment of groupwide performance. The key principles in ISO are based on continuous improvement. Main steps include: Preparing an environmental action plan with targets Implement the environmental action plan Check and verify that corrective actions have been taken Management Review on an annual basis to ensure continuous improvement The Business Units are recommended to certify their EMS according to ISO The Local Environment Coordinator shall: Identify and outline all significant Environmental Aspects relating to the Business Unit s activities, products and services. These Environmental Aspects shall be quantified and documented. Energy consumption and all types of travel shall always be included. A local system for compiling relevant data shall be implemented Identify the most significant Environmental Aspects, based on the findings above Establish relevant Local Environmental Key Performance Indicators (KPIs) for the most significant Environmental Aspects. The Local Environmental KPIs should provide incentives in line with the Group s strategy, the Group s Climate Key Performance Indicator and any other relevant non-financial KPIs

6 Page: 6 of 10 Identify all local legal and other relevant requirements related to the Environmental Aspects identified. All such requirements shall be listed, and lists shall be reviewed and updated at least on an annual basis, together with a short evaluation of compliance The Local Environment Coordinator together with the Local CEO shall: Establish targets and programmes for improvements in the environmental performance for the most significant Environmental Aspects identified. Targets must be quantified and programmes must be clearly set out with respect to responsibilities and timelines 3.3 The Local Environment Coordinator shall: Ensure that relevant personnel receive clear information and relevant training regarding local Environmental Aspects Ensure that environmental requirements for Suppliers are established and implemented, ref. Group Manual Procurement Establish local manuals and guidelines where this manual and Group Policy Sustainability is insufficient (e.g. waste management, energy consumption etc.) Local manuals and guidelines should be based on a risk assessment and be approved by local CEO, or a responsible as delegated by the CEO. Ensure that local manuals and guidelines for handling environmental emergency situations are established (e.g. on how to manage a leakage from a diesel generator). Local procedures should be based on a risk assessment and be approved by local CEO, or a responsible as delegated by the CEO. 3.4 The Local Environment Coordinator shall: On a regular basis, report significant local environmental data in the Non- Financial Reporting system. Any significant information relating to local Environmental Aspects that are not included in the Non-Financial Reporting system shall be reported separately to the Local CEO

7 Page: 7 of 10 Ensure that both corrective and preventive action steps are taken whenever deviations are observed. Significant or material breach shall be reported to the Head of Group Sustainability and the Group General Counsel. 3.5 The Local CEO shall: Ensure continuous improvements of the local environmental performance by conducting Management Reviews at least once a year. This review shall be documented and reported to the Head of Group Sustainability. The management review shall include consideration of: a) The status of actions from previous reviews: b) Changes in: 1) External and internal issues that are relevant to the environmental management system; 2) The needs and expectations of interested parties, including compliance obligations; 3) Its significant environmental aspects: 4) Risks and opportunities; c) The extent to which environmental objectives have been achieved d) Information on the organisations s environmental performance, including trends in: 1) Nonconformities and corrective actions; 2) Monitoring and measurement results; 3) Fulfilment of its compliance obligations; 4) Audit results; e) Adequacy of resources f) Relevant communications from interested parties, including complaints; g) Opportunities for continual improvement. The Business Unit shall retain documented information as evidence of the result of management reviews.

8 Page: 8 of 10 4 Local CEO The Local CEO is responsible for implementing environmental management and maintaining the Environment Management System in the Business Unit. Group Sustainability Group Sustainability shall provide guidance on approaches and processes relating to environmental issues throughout the Group. In order to ensure that the manual is effective and understood, Group Sustainability will contribute with necessary information. The Group Environment Manager is organised in Group Sustainability. Local Environment Coordinator A Local Environment Coordinator shall be appointed in each Business Unit. This person shall be the coordinator for all local environmental matters and responsible for implementation of this manual. 5 On a regular basis, the local Environment Coordinator shall report significant local environmental data in the Non-Financial Reporting system. Any significant information relating to local Environmental Aspects that are not included in the Non-Financial Reporting system shall be reported separately to the Local CEO 6 The local Environment Coordinator shall report the status of implementation and system development to the annual survey on management systems. 6.1 Group Guideline E-waste & Recycling 6.2 Local Environmental legislation

9 Page: 9 of 10 Environmental management systems Requirements with guidance for use - ISO 14001: Group Policy Sustainability Group Policy Sourcing Group Policy Supply Chain Sustainability 7 ENVIRONMENTAL ASPECTS Activities, services and products that interact or can interact with the environment ENVIRONMENTAL IMPACT Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organisation s environmental aspects ISO The International Organization for Standardization s standard for Environmental Management Systems KEY PERFORMANCE INDICATOR (KPI) A set of quantifiable measures that a company can use to measure or compare performance in terms of meeting their strategic and operational goals MANAGEMENT REVIEW Regular evaluation and discussion by the Group and Local Management, respectively, to ensure the continued suitability, adequacy and effectiveness of the Management System, including opportunities for improvement and need for change MANAGEMENT SYSTEM A set of interrelated or interacting elements of an organisation to establish policies and objectives and processes to achieve those objectives. ENVIRONMENTAL MANAGEMENT SYSTEM (EMS)

10 Page: 10 of 10 Part of the managements system used to manage environmental aspects, fulfil compliance obligations and address risks and opportunities ENVIRONMENTAL POLICY Intentions and direction of an organisation related to environmental performance as formally expressed by its top management SUPPLIER Suppliers are to be understood as any person and/or entity with a direct contractual relationship with the Business Unit and offering products and/or services to the Business Unit. This includes any manufacturer, vendor, contractor, consultant, middleman, service or facilities provider, dealer, distributor or other partner that is, or potentially will be, directly cooperating with the Business Unit. For the avoidance of doubt, customers are not included in the definition of Supplier. Other Business Units already covered by this Policy are also excluded from the definition. 8 Revision Category Placement Description of main revisions Approval date New requirement/ Chapter/ Update/Wording Subchapter (YYYY.MM.DD) Update/Wording Updated in line with new ISO 14001: