Sustainability report 2021 - Cision

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Sustainability report 2021 - Cision
Sustainability
report
2021
CONTENTS                                    Contents
01 INTRODUCTION

02 ABOUT KOMPLETT

03 SUSTAINABILITY AT KOMPLETT
                                            01 INTRODUCTION                                  3    04 CORPORATE GOVERNANCE               24   07 KOMPLETT TOLERANCE                    48
04 CORPORATE GOVERNANCE                     A message from our Chief Executive Officer        4   Governance                            26   Our People                               49
                                            Sustainability performance at a glance            6   Business conduct                      28   Health, safety and employee wellbeing    52

05 KOMPLETT CIRCULAR                        About this report                                 7   Customer privacy and product safety   29   Learning and development                 55
                                                                                                  Supply chain engagement               30   Strategic principle: digital inclusion   56
                                                                                                                                             Plans and aims for 2022                  58
06 KOMPLETT ENVIRONMENT
                                            02 ABOUT KOMPLETT                                8
                                            Vision, mission, and values                      10   05 KOMPLETT CIRCULAR                  32
07 KOMPLETT TOLERANCE
                                            Our growth journey                               11   Waste management                      34   08 APPENDIX                              59
                                            Our 2025 business strategy                       12   Material use                          37   Our numbers and stats                    60
08 APPENDIX                                                                                                                                  Organizational structure                 64
                                            Economic value generation and distribution       13   Circular innovation and development   38
                                            Board of Directors                               15   Plans and aims for 2022               39   GRI Index                                65
                                            Executive management team                        16

                                                                                                  06 KOMPLETT ENVIRONMENT               40
                                            03 SUSTAINABILITY AT KOMPLETT                    17   Our carbon footprint                  42
                                            Our sustainability pillars                       19   Environmental impact                  44
                                            Materiality and stakeholder dialogue             21   Plans and aims for 2022               46
                                            Materiality assessment                           22
                                            Our value chain and key sustainability impacts   23

2     KOMPLETT SUSTAINABILITY REPORT 2021
CONTENTS

01 INTRODUCTION

02 ABOUT KOMPLETT

03 SUSTAINABILITY AT KOMPLETT

04 CORPORATE GOVERNANCE

                                            01 INTRODUCTION
05 KOMPLETT CIRCULAR

06 KOMPLETT ENVIRONMENT

07 KOMPLETT TOLERANCE

08 APPENDIX

3     KOMPLETT SUSTAINABILITY REPORT 2021
CONTENTS                                     A message from
01 INTRODUCTION                              our CEO
    A message from our CEO
    Sustainability performance
    at a glance
                                             This year has brought many developments and much exciting news
                                             for Komplett Group. The two biggest highlights include the listing on
    About the report
                                             the Oslo Stock Exchange and the acquisition of Ironstone Holding in
                                             June. Ensuring that sustainability is part of everything we do is one
02 ABOUT KOMPLETT
                                             of the pillars of Komplett’s business strategy, and in 2021 we started
                                             implementing the actions of our sustainability plan. Entering 2022,
03 SUSTAINABILITY AT KOMPLETT                we continue to make improvements when it comes to incorporating
                                             sustainability into our daily operations.
04 CORPORATE GOVERNANCE

05 KOMPLETT CIRCULAR
                                             In 2021, we celebrated our 25th anniversary.       us to reduce our carbon footprint and to in-
                                             As I write this, I am proud of the journey we’ve   crease the transparency of our supply chain.
06 KOMPLETT ENVIRONMENT                      been on since Komplett was established as
                                             an e-commerce business on the Norwegian            There are several sustainability challenges
                                             market in 1996. There have been many trans-        facing the elec­tronic retail industry, with the
07 KOMPLETT TOLERANCE
                                             formational shifts in the market and prefe-        sourcing and disposal of minerals, used in
                                             rences of consumers since then. Komplett           electronic components and computer pro-
08 APPENDIX                                  has continually adapted and matured with           ducts, being the most crucial. Therefore,
                                             the times, leading the way in the development      our sustainability pillar, “Komplett Circular”,
                                             of online retailing of electronic products in      aims to minimize the environmental impact
                                             the Nordic market. In more recent years, we        of mineral use by increasing our commitment
                                             have intensified our sustainability commit-        to the recycling and reuse of electronic
                                             ment to ensure that business growth does           components. In 2021, we launched the pro-
                                             not compromise the wellbeing of society            duct subscription service FLEX to facilitate
                                             and the environment. Last year we identified       the resale of products in the secondhand
                                             sustainability as one of the key pillars of our    market after use. FLEX represents a solid
                                             2025 business strategy. Following Komplett’s       circular economy imitative supporting our
                                             listing in 2021, this work has become even         sustainability agenda making it easier for
4      KOMPLETT SUSTAINABILITY REPORT 2021   more important with higher expectations of         consumers to dispose of their products re-
CONTENTS

01 INTRODUCTION                              Overall, I am happy to see the many right steps taken by
    A message from our CEO                   our companies in 2021; while I also recognize that we are
    Sustainability performance               only at the start of our sustainability journey, with much
    at a glance
    About the report
                                             work still ahead.

02 ABOUT KOMPLETT

03 SUSTAINABILITY AT KOMPLETT
                                             sponsibly. Since the initiative’s introduction   Again in 2021, the Covid-19 pandemic led to        will require much time and effort from many
                                             in May 2021, sales from FLEX have increased      component shortages and supply chain con-          areas of the organization. However, I am
04 CORPORATE GOVERNANCE
                                             to 10 percent of our revenue from the B2C        straints as well as posing challenges to pro-      confident in my competent and hardworking
                                             segment in Komplett Norway and Sweden.           viding a safe work environment for our             team, and I anticipate that we all will gain
05 KOMPLETT CIRCULAR                         We are very satisfied with this development,     employees. Taking care of our employees is         valuable insight into our supply chain through
                                             and it motivates us to work hard to reach our    a key focus area of our sustainability strategy,   this process.
                                             goal of growing FLEX to 50 percent of our        and in 2021 we launched several intiatives
06 KOMPLETT ENVIRONMENT                      revenue in the coming years.                     to improve employee motivation and well-           Overall, I am happy to see the many right
                                                                                              being. One in particular, is the Employee          steps taken by our companies in 2021; while
                                             Our business strategy also includes an am-       Board, which was established to secure             I also recognize that we are only at the start
07 KOMPLETT TOLERANCE
                                             bitious plan to reduce greenhouse gas (GHG)      input from employees and improve commu-            of our sustainability journey with much work
                                             emissions from our operations. Notably, our      nication with management. I am very                still ahead. I would like to extend my thanks
08 APPENDIX                                  goal of offering zero-emission deliveries by     encouraged with the outcomes of these in-          to our team of motivated employees for their
                                             2026 requires us to adapt our business to        itiatives, which is noticeable by the improved     dedication and efforts so far. In 2022, I look
                                             new solutions. Throughout 2021, I learned        results from our employee surveys this year.       forward to increasing our internal efforts as
                                             how challenging it can be to implement these                                                        well as cooperating more closely with our
                                             strategies and see significant improvements.     Further, we are laying the foundations of          suppliers and customers to lead the way in
                                             We continually strive to gain a better over-     ensuring decent work in our supply chain.          making the electronic retail business more
                                             view of our carbon footprint, and to identify    With the implementation of the Transparen-         sustainable.
                                             reduction measures. The Komplett team is         cy Act in Norway this coming July, we will
                                                                                                                                                                                                  LARS OLAV OLAUSSEN
                                             ready to consolidate its commitment to the       enhance our work with supplier due diligen-
                                                                                                                                                                                                  CEO
                                             reduc­tion of GHG emissions, and I am certain    ce to ensure compliance with these new
                                             that we can refine our efforts to meet our       standards. Having learned more about what
5      KOMPLETT SUSTAINABILITY REPORT 2021   goals in the coming year.                        this entails, I acknowledge that this work
CONTENTS                                     Komplett’s Sustainability                                     Diversity

01 INTRODUCTION                              performance at a glance
    A message from our CEO                                                                                       25%
    Sustainability performance
    at a glance
                                                                                                                 Women
    About the report

02 ABOUT KOMPLETT

03 SUSTAINABILITY AT KOMPLETT

04 CORPORATE GOVERNANCE
                                                755             2.13%                 4539        tonnes
                                                                                                  CO2e

05 KOMPLETT CIRCULAR                          Total number         Return               GHG
                                              of employees          rate              emissions
06 KOMPLETT ENVIRONMENT

07 KOMPLETT TOLERANCE
                                                                                                                                     75%
                                                 3,6                                     11
                                                                Share of sales from
08 APPENDIX                                                      circular services:                                                  Men

                                               million           10%                  billion                     38 years
                                                Number        from B2C segment        Revenue
                                                of orders    in Komplett Norway                                        Average age
                                                                 and Sweden
6      KOMPLETT SUSTAINABILITY REPORT 2021
CONTENTS                                     About the report
01 INTRODUCTION
    A message from our CEO
    Sustainability performance
    at a glance
    About the report
                                             In this annual sustainability report, we disclose updated information on
02 ABOUT KOMPLETT                            the sustainability efforts Komplett Group has undertaken throughout
                                             2021. We present to you a comprehensive summary of our activities and
03 SUSTAINABILITY AT KOMPLETT                our approach to the sustainable development of Komplett as a business.

04 CORPORATE GOVERNANCE
                                             The report covers activities within our wholly-    due to improved data quality. Our reports        As part of the development of this report,
05 KOMPLETT CIRCULAR                         owned subsidiaries in Norway and Sweden.           are part of our sustainability journey. As we    we have also used for inspiration the indica-
                                             The content is structured around Komplett’s        develop and learn, our data collection proces-   tors from the Sustainability Accounting Stan-
                                             three sustainability pillars: Komplett Circular;   ses become more structured, and our data         dards Board and the World Economic Forum’s
06 KOMPLETT ENVIRONMENT                      Komplett Tolerance and Komplett Environ-           more precise. We always strive in Komplett       indicators for sustainability reporting. In
                                             ment. This is in addition to material topics       Group, to present the most complete num-         addition, we strive to follow the Euronext
                                             identified through our stakeholder dialogue        bers and information on sustainability.          guidance on Empowering Sustainable Growth       Any questions relating to this
07 KOMPLETT TOLERANCE
                                             and materiality assessment.                                                                         (ESG) reporting as launched in January 2020.    report, or the sustainability
                                                                                                REPORTING FRAMEWORK                                                                              work carried out by Komplett
08 APPENDIX                                  Data gathered from different parts of the          The report is prepared in accordance with        This report follows the same framework as       Group, can be directed to:
                                             organization is the foundation for this report.    the Global Reporting Initiative (GRI) Stan-      the previous sustainability report for 2020,
                                             Although much emphasis has been placed             dards: Core option. The GRI index at the end     published in March 2021. Komplett Group         Kristin Hovland,
                                             on ensuring that the data is complete and          of this report provides an overview of           reports on our sustainability work and en-      Head of Communications
                                             correct, some of the information may be            disclosures according to the GRI Standards,      gagement annually, to provide insight and
                                                                                                                                                                                                 kristin.hovland@komplett.com
                                             subject to some uncertainty. In the course         including references to where in the report      transparency to our stakeholders and so-
                                             of the data collection for this year’s report,     information related to each of the disclosu-     ciety at large.
                                             some of the 2020 data has been corrected           res can be found.

7      KOMPLETT SUSTAINABILITY REPORT 2021
CONTENTS

01 INTRODUCTION

02 ABOUT KOMPLETT

03 SUSTAINABILITY AT KOMPLETT

04 CORPORATE GOVERNANCE

                                            02 ABOUT KOMPLETT
05 KOMPLETT CIRCULAR

06 KOMPLETT ENVIRONMENT

07 KOMPLETT TOLERANCE

08 APPENDIX

8     KOMPLETT SUSTAINABILITY REPORT 2021
CONTENTS                                    About Komplett
01 INTRODUCTION
                                                                                                                                       Swedish omnichannel retailer,        Leading Norwegian pure play online
                                                                                                                                       with physical footprint.             retailer, with attractive positions in
02 ABOUT KOMPLETT                                                                                                                                                           SE/DK, capitalizing on NO set-up.
                                                                                                                                       Lean and cost-effective set-up.
                                                                                                                                                                            Strong position particulary amongst
03 SUSTAINABILITY AT KOMPLETT                                                                                                          Strong position particulary amongs   Gamers, Tech enthusiasts, Quality
                                                                                                                                       Gamers, Tech enthusiasts, Quality    of life conscience customers.
                                                                                                                                       of life conscience customers.
04 CORPORATE GOVERNANCE
                                            Komplett Group is a leading on­line              Komplett Group comprises four brands

05 KOMPLETT CIRCULAR                        electronics company in Scandi-                   • Webhallen: Swedish omnichannel
                                            navia offering one of the market’s                 retailer with 20 physical stores.

06 KOMPLETT ENVIRONMENT
                                            broadest selections of consumer                    Strong position among gamers,
                                                                                               tech enthusiasts, and quality-of-life
                                                                                                                                                                  22%
                                            electronics and business soluti-
                                            ons. Our business solutions include
                                                                                               conscience customers.                                                              36%
07 KOMPLETT TOLERANCE                                                                        • Itegra: Distribution business with
                                            sales to public and private enter-                 a number of A-brands and attractive
                                            prises, large and small, as well as                partners, expanding into Sweden.
08 APPENDIX
                                            to wholesalers and retailers.                    • Komplett Bedrift: Norway’s largest
                                                                                                                                                             14%
                                                                                               online B2B player for small and
                                                                                               medium-sized enterprises and

                                            We operate within three reporting segments,
                                                                                               small office/home office, expanding
                                                                                               into Sweden.                                                                 28%
                                            corresponding to our three different custo-
                                            mer types. These are: business to consumers      • Komplett: Leading Norwegian pure
                                            (B2C); business to business (B2B); and re-         play online retailer, based in Norway
                                            sellers (distribution). We serve our customers     with attractive positions in Sweden
                                            through our eight web shops, in addition to        and Denmark. Strong position among
                                            eighteen retail stores in Sweden. The Group        gamers, tech enthusiasts and
                                            operates out of the head office in Sandefjord,     quality-of-life conscience customers.   Norway's largest B2B online          Distribution business with number
                                            Norway, supported by offices in Oslo, Stock-       Komplett Services is responsible        player in SME/SOHO segment.          of A-brands and attractive partner.
                                            holm, and Göteborg.                                for the largest share of our revenue.   Expanding into Sweden.               Expanding into Sweden.

9     KOMPLETT SUSTAINABILITY REPORT 2021
CONTENTS                                      Vision, mission values
01 INTRODUCTION

02 ABOUT KOMPLETT
     Vision, mission, and values
     Our growth journey
     Our 2025 business strategy                                   Vision                                       Mission                            Values
     Economic value generation
     and distribution
     Board of Directors
     Executive management team
                                              To be “the obvious choice”. This expresses    To develop complete solutions   Our values are fundamental to our corporate
                                              how Komplett Group would like to be percei-   that make life simpler.         culture. Our values tell us how to work, how
03 SUSTAINABILITY AT KOMPLETT                 ved and where we are heading. Our vision                                      to treat each other, and (not least) how we
                                              provides guidance and energy. Each and                                        are perceived by the world around us.
04 CORPORATE GOVERNANCE                       every day, we strive to be “the obvious
                                              choice” for customers, suppliers and                                          PRECISION. Keep our promises, meet deadlines,
05 KOMPLETT CIRCULAR                          employees, and for the community                                              keep up, be clear and accurate. Have respect
                                              around us.                                                                    for and confidence in each other.
06 KOMPLETT ENVIRONMENT
                                                                                                                            SIMPLICITY. Think smart, find simple solutions.
                                                                                                                            Make life easier for our customers and ourselves.
07 KOMPLETT TOLERANCE

                                                                                                                            ENTHUSIASM. Get involved and wish each other
08 APPENDIX
                                                                                                                            well. Create enthusiasm and gain pleasure from
                                                                                                                            our work.

10      KOMPLETT SUSTAINABILITY REPORT 2021
CONTENTS                                      Our growth journey
01 INTRODUCTION

02 ABOUT KOMPLETT
     Vision, mission, and values
     Our growth journey
     Our 2025 business strategy
     Economic value generation
     and distribution
     Board of Directors                       2021 was an exciting year for Kom-
                                              plett, culminating with the listing
     Executive management team
                                              on the Oslo Stock Exchange in
                                              June. The listing was an important
03 SUSTAINABILITY AT KOMPLETT
                                              step for our continuous growth.

04 CORPORATE GOVERNANCE

                                              Komplett was previously wholly-owned for        sustainability report, however our aim is to   es. The various web stores allow customers
05 KOMPLETT CIRCULAR                          ten years by Canica, one of the largest         fully integrate Ironstone insight into our     to choose their own components using the
                                              privately-owned investment companies in         sustainability records in 2022.                online Komplett PC builder.
                                              Norway. Canica is still the largest investor
06 KOMPLETT ENVIRONMENT
                                              with 59.9% ownership alongside several ot-      PRODUCTS AND CUSTOMERS                         At the end of 2021, the web stores had a total   Another important milestone
                                              her shareholders.                               Our product range comprises more than          base of 3,658,831 orders. The group sales        for Komplett Group this past
07 KOMPLETT TOLERANCE                                                                         35,000 items including the latest computer     sur­passed 11 billion NOK, to end-users bu-
                                              Another important milestone for Komplett        components, PCs, household electronics,        sinesses, schools, public enterprises, and       year, was the aquesition of
                                              Group this past year was the aquesition of      and other computer-related prod­ucts. We       wholesalers across Scandinavia. This was
08 APPENDIX                                   Ironstone Holding AS also in June. The cloud    feature the main brands, carry the latest      an increase of 11.9% compared to 2020. The       Ironstone Holding AS
                                              technology and IT services offered by Iron-     products and make it easy for our customers    company positions itself as the direct link
                                              stone fits strategically well with Komplett's   to compare prices and models.                  between manufacturers and customers,
                                              extensive customer base, and we are very                                                       providing efficient operations and highly
                                              excited to welcome Ironstone and their twen-    Every year we assemble close to 40,000 PCs;    competitive prices. In 2021, we served a total
                                              ty employees to the Komplett family. Data       each model is tailored to customer specifi-    of 1.6 million customers in Scandinavia.
11      KOMPLETT SUSTAINABILITY REPORT 2021   from Ironstone has not been included in this    cations and provides the latest technologi-
CONTENTS                                      Our 2025 business
01 INTRODUCTION                               strategy
                                                                                                                                                            1. Superior cost 		            2. Accelerate growth
02 ABOUT KOMPLETT                                                                                                                                              position                       with M&A
     Vision, mission, and values
     Our growth journey
     Our 2025 business strategy
     Economic value generation
                                              Since 2018, Komplett Group has experienced significant growth,                                                               Komplett
     and distribution
     Board of Directors
                                              gaining market share across all our brands. Our 2025 business stra-
                                              tegy is intended to facilitate future growth and establish Komplett as                                                         2025
                                              a leading electronics retailer for the whole Nordic region. We aim to
     Executive management team                strengthen our core, expand with our customers into new services,                                   5. Next-gen SC and 		                                3. Sustainability
                                              and significantly shape the development of the Nordic B2C market.                                      tech as growth                                       in everything
03 SUSTAINABILITY AT KOMPLETT                                                                                                                        enabler                                              we do

04 CORPORATE GOVERNANCE                       With the current climate and environmental         the principle of Enjoyable Product Lifecycles.
                                              challenges, we experience increased awa-           Emphasis has been placed on developing

05 KOMPLETT CIRCULAR
                                              reness and expectations from our customers         the areas within sustainability that we beli-                            4. Brand improvement
                                              and other stakeholders regarding circular-         eve will have the most impact on our business
                                                                                                                                                                             and innovation
                                              economy-oriented offerings and the redu-           and on our stakeholders. We aim to develop
06 KOMPLETT ENVIRONMENT                       ction of our climate footprint. In line with our   new circular business concepts and provide
                                              values, we have high ambitions for growing         green outbound logistics. These new ser-
                                              our business responsibly and considering           vices and solutions will help us engage with
07 KOMPLETT TOLERANCE                         both the environmental and the social as-          new customers who share our desire to live
                                              pects of our operations.                           and consume more responsibly, thus posi-
                                                                                                 tioning us to reach our goals of increasing
08 APPENDIX                                   Our 2025 business strategy is built on five        our market share in the different Nordic co-
                                              strategic pillars; one of these is to promote      untries.                                         Our 2025 business strategy is built on five
                                              sustainability in everything we do. In 2020,                                                        strategic pillars; one of these is to promote
                                              after analyzing our operations and potenti-        More information on our business strategy
                                              al for growth over the next three years, we        for 2025 can be found in our Annual Report.      sustainability in everything we do.
                                              defineda new sustainability plan based on
12      KOMPLETT SUSTAINABILITY REPORT 2021
CONTENTS                                      Economic value generation                                                                       KOMPLETT GROUP 2021

01 INTRODUCTION                               and distribution                                                                                ECONOMIC CONTRIBUTION
                                                                                                                                              Purchased goods and services                   9,581 million NOK
                                                                                                                                              Profit (ex. tax)                                300 million NOK
02 ABOUT KOMPLETT                                                                                                                             Operating costs                                  453 million NOK
     Vision, mission, and values                                                                                                              Salary (and other compensation) to employees      511 million NOK
     Our growth journey                                                                                                                       ENVIRONMENTAL TAXES
     Our 2025 business strategy                                                                                                               Water and sewage                                     93,000 NOK
                                              Since 2018, Komplett Group has experienced significant growth, gai-
     Economic value generation                                                                                                                Electricity fee                                    5 million NOK
     and distribution                         ning market share across all our brands. Our 2025 business strategy is
                                              intended to facilitate future growth and establish Komplett as a leading                        TOTAL TAX AND PAYMENTS TO GOVERNMENT
     Board of Directors
                                              electronics retailer for the whole Nordic region. We aim to strengthen                          NORWAY
     Executive management team                our core, expand with our customers into new services, and significa-                           Corporate tax                                     48 million NOK
                                              ntly shape the development of the Nordic B2C market.
                                                                                                                                              MVA                                            567.7 million NOK
03 SUSTAINABILITY AT KOMPLETT
                                                                                                                                              Employee withholding tax                          74 million NOK

04 CORPORATE GOVERNANCE                       Komplett Group’s growth and success have       we report the various tax categories paid        Employer tax                                    34.6 million NOK
                                              positive economic ripple effects beyond our    country-by-country with the aim of indicating    SWEDEN
                                              own business. Through our business activi-     our scale of activity and the contributions
05 KOMPLETT CIRCULAR                          ties, Komplett stimulates economic growth      we make through taxation in each jurisdicti-     MVA                                            302.2 million SEK
                                              by creating employment, increasing govern-     on. It is fundamental for us to live up to our   MVA (Denmark)                                   90.3 million SEK
06 KOMPLETT ENVIRONMENT                       mental revenue and distributing capital to     obligation to comply with tax legislation and
                                                                                                                                              Employee withholding tax                          4.1 million SEK
                                              shareholders. It is important for Komplett     to adhere to good tax practices.
                                              to be open and transparent about our finan-                                                     Employer tax                                      3.6 million SEK
07 KOMPLETT TOLERANCE                         cial activities, expenses, and government      Disclosures on the creation and distribution
                                                                                                                                              COMMUNITY INVESTMENT
                                              payments.                                      of economic value, presented in the table
                                                                                             below, provide a basic indication of how Kom-    Sponsor funds                                        45,000 NOK
08 APPENDIX                                   Taxes are a key mechanism by which orga-       plett contributed to value creation for sta-
                                                                                                                                              FINANCIAL INVESTMENT CONTRIBUTION
                                              nizations contribute to the economies of the   keholders in 2021.
                                              countries in which they operate, i.e. Norway                                                    Investments (Capex)                               56 million NOK
                                              and Sweden for Komplett Group. This year,                                                       Dividends to owners                            2.9 NOK per share

13      KOMPLETT SUSTAINABILITY REPORT 2021
CONTENTS

01 INTRODUCTION                               Every year, employees of Komplett
                                              Group can apply for funds that are
02 ABOUT KOMPLETT                             to be distributed to good causes
     Vision, mission, and values
                                              within local culture and sports.
     Our growth journey
     Our 2025 business strategy
     Economic value generation                In 2021, Komplett paid a total of 616 million NOK and 392
     and distribution                         million SEK in taxes to the Norwegian and Swedish govern-
     Board of Directors                       ments. Employer tax amounted to approximately 34.6 mil-
                                              lion NOK and 3.6 million SEK. Environmental taxes relating
     Executive management team                to the use of water, sewage and electricity paid to the Nor-
                                              wegian government totaled 5.9 million NOK. Our profit after
03 SUSTAINABILITY AT KOMPLETT                 taxes was 300 million NOK.

                                              Property, plant and equipment investments in 2021 totaled
04 CORPORATE GOVERNANCE                       56 million NOK and included investments in IT and supply
                                              chain projects. Dividends of 2.9 NOK per share were paid by
                                              Komplett Group to its shareholders in 2021. The complete
05 KOMPLETT CIRCULAR                          details of our financial information can be found in our
                                              Annual Report.
06 KOMPLETT ENVIRONMENT
                                              As a visible actor in the local community – especially in Sande­
                                              fjord, where Komplett was established over 25 years ago – we
07 KOMPLETT TOLERANCE                         want to contribute to a healthy and thriving community

                                              through community investments. In the period between
08 APPENDIX                                   2010 and 2021, Komplett donated 746,000 NOK to charitable
                                              causes through our sponsor fund “Sponsoratet”. Every year,
                                              employees of Komplett Group can apply for funds that are
                                              to be distributed to good causes within local culture and
                                              sports, and that will not be given to individuals. The funds
                                              will be used for activities that create enthusiasm and support
14      KOMPLETT SUSTAINABILITY REPORT 2021   the community. The distribution of these funds also takes
                                              place annually.
CONTENTS                                      Board of directors
01 INTRODUCTION

02 ABOUT KOMPLETT
     Vision, mission, and values
     Our growth journey
     Our 2025 business strategy
     Economic value generation                Nils Kloumann Selte                              Jennifer Geun Koss                                  Lars Bjørn Thoresen                                 Jo Olav Lunder
     and distribution                         Chair                                            Board Member                                        Board Member                                        Board Member
     Board of Directors                       Nils Kloumann Selte has held the position of     Jennifer Geun Koss has been a board member          Lars Bjørn Thoresen has been a board member         Jo Olav Lunder has been a board member
     Executive management team                chair of the board since 2014. He is the Chief   since 2020. She currently holds the role of         since 2019. He has years of directorial experien-   since 2018. He has more than 25 years of broad
                                              Executive Officer of Canica AS, where he         Founding Partner at investment fund Spring-         ce, from serving as chair and board member          directorial and executive experience, from
                                              previously served as Chief Financial Officer.    bank Collective. She is the founder of the retail   of various private and public companies, and        multiple private and public companies within
03 SUSTAINABILITY AT KOMPLETT                 Selte also serves as a board member for          agency BRIKA. Koss holds various other board        is also the CEO of the investment company           telecommunications, IT services, business
                                              Orkla ASA and Arcus ASA.                         positions.                                          LT Invest.                                          solutions, and e-commerce.

04 CORPORATE GOVERNANCE

05 KOMPLETT CIRCULAR

06 KOMPLETT ENVIRONMENT

07 KOMPLETT TOLERANCE
                                              Sarah Willand                                    Carl Erik Hagen                                     Nora Elin Eldås                                     Anders Odden
                                              Board Member                                     Deputy Board Member                                 Employee Representative                             Employee Representative
08 APPENDIX
                                              Sarah Willand has been a board member since      Carl Erik Hagen has held the positions of board     Nora Elin Eldås joined the Group in 2016, as a      Anders Odden joined the Group in 2007,
                                              2021. She is currently Organization and          member and deputy board member since 2013.          salesperson at Webhallen AB in Täby, Sweden,        as Nordic Product Manager for PC Components,
                                              Communications Director at TV2, and holds        He currently works in the financial investment      and has been a board member since 2021. Eldås       and has been a board member since 2018.
                                              various board positions at companies such        arm of Canica International, and is an active       currently holds the position of Store Manager       He currently holds the position of Sales
                                              as RiksTV AS and Norges Televisjon AS.           board member for Canica, through several            at Webhallen AB Fridhemsplan in Stockholm.          Director at Komplett Group.
                                                                                               board positions within the Canica Group.
15      KOMPLETT SUSTAINABILITY REPORT 2021
CONTENTS                                      Executive
01 INTRODUCTION                               management
02 ABOUT KOMPLETT                             team
     Vision, mission, and values
     Our growth journey
     Our 2025 business strategy
     Economic value generation
     and distribution
     Board of Directors
     Executive management team

03 SUSTAINABILITY AT KOMPLETT                 Lars Olav Olaussen        Krister A. Pedersen   Trine-Lise Jensen             Kristin Hovland          Kristin Hodal Torgersen
                                              Chief Executive Officer   Chief Financial       Chief Information Officer     Head of Communications   HR Director (Interim)
                                                                        Officer               and Chief Operating Officer   and Adivsor to the CEO
04 CORPORATE GOVERNANCE

05 KOMPLETT CIRCULAR

06 KOMPLETT ENVIRONMENT

07 KOMPLETT TOLERANCE

08 APPENDIX                                                             Kjetil Wisløff        Jon Martin Klafstad           Jan Erik Svendsen        Henri Mikael Blomqvist
                                                                        Category and          Director B2C (Interim)        Director B2B & Integra   Managing Director Webhallen
                                                                        Buying Director                                     (Interim)

16      KOMPLETT SUSTAINABILITY REPORT 2021
CONTENTS

01 INTRODUCTION

02 ABOUT KOMPLETT

                                            03 SUSTAINABILITY
03 SUSTAINABILITY AT KOMPLETT

04 CORPORATE GOVERNANCE

                                               AT KOMPLETT
05 KOMPLETT CIRCULAR

06 KOMPLETT ENVIRONMENT

07 KOMPLETT TOLERANCE

08 APPENDIX

17    KOMPLETT SUSTAINABILITY REPORT 2021
CONTENTS                                    Sustainability
01 INTRODUCTION                             at Komplett
02 ABOUT KOMPLETT

03 SUSTAINABILITY AT KOMPLETT

04 CORPORATE GOVERNANCE

05 KOMPLETT CIRCULAR
                                            As Komplett continues to grow and develop,
06 KOMPLETT ENVIRONMENT                     we strive to ensure that our business is aligned
                                            with safeguarding both the environment and
07 KOMPLETT TOLERANCE                       the people impacted by our operations. To
                                            lead the way in making the electronic retail
                                            business more sustainable, we must adapt our
08 APPENDIX
                                            operations to comply with new regulations and
                                            new expectations from our customers.

                                            Ensuring that sustainability is part of everything we do is
                                            one of the pillars of Komplett’s business strategy, and 2021
                                            was the year we started implementing the actions of our
                                            sustainability plan. Our initiatives are gradually becoming
                                            integrated into our everyday business operations, as we aim
                                            to have a positive impact on the communities around us.
                                            We seek to contribute to creating a more just and green
                                            society for all. By adapting and improving the footprint
                                            of our operations today, we will ensure that Komplett as a
                                            business thrives in the future.

18    KOMPLETT SUSTAINABILITY REPORT 2021
Our
CONTENTS                                       sustainability
01 INTRODUCTION                                pillars                 Komplett Circular                                    Komplett Tolerance                               Komplett Environment

02 ABOUT KOMPLETT
                                                            Komplett Circular is our path for developing          Komplett Group is committed to creating              The Komplett Environment principle aims to
                                                            new and circular business concepts, focusing          and upholding a healthy workspace where our          guide us toward decreasing the environmental
03 SUSTAINABILITY AT KOMPLETT                               on recycling, durability and reusability.             employees feel included and valued. Another          impact of our operations. This commitment is

     Our sustainability pillars
                                                 What       A special emphasis is put on minerals and
                                                                                                                  important part of our tolerance strategy is the
                                                                                                                  work to better document and demand decent
                                                                                                                                                                       focused on reducing GHG emissions associated
                                                                                                                                                                       with the transportation of our products. We

     Materiality and stakeholder                 it is      materials used in electronics that have
                                                            significant environmental footprints. We aim to
                                                                                                                  work standards among our suppliers. Further,
                                                                                                                  a focus area within the tolerance path is to
                                                                                                                                                                       intend to offer zero-emission deliveries to
                                                                                                                                                                       all customers by 2026.
     dialogue                                               develop methods for salvaging these resources         promote digital inclusion in all parts of society.
                                                            so that they can be reincorporated into the
     Materiality assessment                                 lifecycle of electronic products.

     Our value chain and key
     sustainability impacts                                 • Strive to increase the durability and reusability   • Foster an inclusive work environment by            • Map, document, and limit our emissions
                                                              of everything we sell.                                developing and caring for our employees.             through several environmental programs
                                                            • Ensure that products purchased from Komplett        • Promote digital inclusion in all areas we            and ISO certifications.
04 CORPORATE GOVERNANCE
                                               What we        will consist of more recycled materials.
                                                            • Create solutions for customers to easily choose
                                                                                                                    are present.
                                                                                                                  • Develop a complete overview of our value
                                                                                                                                                                       • Cooperate with suppliers to find
                                                                                                                                                                         transportation solutions with a reduced

                                                will do
                                                              repairment or reuse electronic devices.               chain – tending to people and resources              climate footprint.
05 KOMPLETT CIRCULAR                                                                                                at all levels.                                     • Guide our customers towards more
                                                            • Establish longer warranties, upgrade solutions,
                                                              and further enhance our buy-backs and leasing                                                              environmentally conscious products.
                                                              options.
06 KOMPLETT ENVIRONMENT

07 KOMPLETT TOLERANCE
                                                            Invest in developing new services to promote          Initiate mechanism for measuring and managing        Continue to map and monitor our GHG emissions
                                                            increased recycling and reuse of products.            the level of employee satisfaction and wellbeing     closely. Cooperate with our suppliers to find
                                                            In addition, improve management of these              at all levels of our operation.                      the most effective and environmentally friendly
08 APPENDIX
                                               What it      initiatives by implementing tools and systems
                                                            for easy handling.                                    Implement procedures to improve transparency
                                                                                                                                                                       transportation solutions. Prioritize suppliers
                                                                                                                                                                       committed to reducing GHG emissions, and

                                               will take
                                                                                                                  in our value chain, in addition to securing coope-   push our existing partners towards this goal.
                                                            Strengthen our service- and circularity-oriented      ration with suppliers on this issue.
                                                            business models and promote the importance                                                                 In case of no CO2 reduction, offsetting emissions
                                                            of circularity to our customers and suppliers.        Promote digital inclusion by creating awareness      would cost 0.7-1.7 million NOK.
                                                                                                                  on this important topic, enter partner­ships, and
                                                                                                                  arrange fundraisers together with suppliers and      Promote sustainable products in our inventory.
                                                                                                                  customers.
19       KOMPLETT SUSTAINABILITY REPORT 2021
CONTENTS                                       Sustainable Development Goals
01 INTRODUCTION                                In the course of the development of our sustainability plan    The following highlighted goals are those that are most re-
                                               in 2020, we identified five of the seventeen sustainable       levant for our operations and where we have a significant       SDG 5
                                               development goals (SDGs) Komplett contributes to solving,      social or environmental impact, both in our own organiza-       GENDER EQUALITY
02 ABOUT KOMPLETT                              and with which Komplett has had challenges. The SDGs are       tion and throughout our value chain. In 2022, we will strive
                                               important guidelines that highlight the challenges that face   to further develop our work with the SDGs by prioritizing key
03 SUSTAINABILITY AT KOMPLETT                  society but also promote solutions going into the future.      SDG sub-goals and linking them to our targets and actions.      As we operate within what is seen as a typically male-
                                                                                                                                                                              dominated sphere, with our main activities being
     Our sustainability pillars                                                                                                                                               warehouse-related, SDG 5 is a priority for Komplett
     Materiality and stakeholder                                                                                                                                              Group. To meet the challenges that may arise from
     dialogue                                                                                                                                                                 this imbalance, we work wholeheartedly to secure
                                                                                                                                                                              equality at all levels of our business. Our priorities are
     Materiality assessment                                                                                                                                                   to recruit and retain female employees as well as
     Our value chain and key                                                                                                                                                  ensuring that all our people are treated fairly, both
     sustainability impacts                                                                                                                                                   in opportunities and remuneration, and that they
                                                  SDG 12                                                         SDG 8                       SDG 10                           feel secure and protected from discrimination and
                                                  RESPONSIBLE CONSUMPTION                                        DECENT WORK AND             REDUCED                          harassment.
04 CORPORATE GOVERNANCE                           AND PRODUCTION                                                 ECONOMIC GROWTH             INEQUALITIES

05 KOMPLETT CIRCULAR
                                                  In our work with SDG 12, and the essence of Komplett           To consolidate and communicate our commitment to
                                                  Circular, we strive to contribute to increased reuse,          secure decent work conditions and the safeguarding
06 KOMPLETT ENVIRONMENT
                                                  repair and sustainable handling of electronic produ-           of fundamental workers’ and human rights, both in
                                                  cts. Electronic waste is a massive international chal-         our organization and throughout our value chain, we
07 KOMPLETT TOLERANCE                             lenge, which Komplett must contribute to minimizing.           emphasize SDGs 8 and 10. A priority is to improve            SDG 13
                                                  Many electronic components are highly dependent                our systems for performing due diligence assess-             CLIMATE ACTION
                                                  on minerals that are scarce, and that will be increa-          ments, to control the impacts of our business through
08 APPENDIX                                       singly required. This is another reason we must work           our suppliers, especially those relying on labor in
                                                  with our partners to develop solutions to increase             regions with a high risk of human and labor rights           We consider it crucial to focus on SDG 13, as our
                                                  the recycling and recovery of these scarce minerals.           breaches. Through this work, we can contribute to            operations contribute to GHG emissions, largely from
                                                  Komplett acknowledges that there are many chal-                reducing both regional and global inequality and push        the transportation of goods. It is therefore important
                                                  lenges connected to the production of electronics,             for better work and economic conditions for all work-        for us to map our current climate footprint and initi-
                                                  and we strive to secure responsible consumption                ers impacted by our value chain.                             ate measures that reduce our emissions in the coming
                                                  and production of all our products to reduce our                                                                            years.
                                                  material footprint.
20       KOMPLETT SUSTAINABILITY REPORT 2021
CONTENTS                                       Materiality and                                                  Our stakeholder's
                                                                                                                main concerns
01 INTRODUCTION                                stakeholder dialogue                                                                             High profitability, taking
                                                                                                                                                a leadership role within
                                                                                                                                                                                      Information on sustainability
                                                                                                                                                                                      issues, transparent ESG
                                                                                                                                                the market, sustainability,           repor­ting on risks and
02 ABOUT KOMPLETT                                                                                                                               ambitious goals and                    opportun­ities, financial
                                                                                                                                                execution strategies.                 gains with a focus on social
                                                                                                                                                                                      and environmental impact.
03 SUSTAINABILITY AT KOMPLETT
     Our sustainability pillars
     Materiality and stakeholder                                                                                      Visible sustaina­bility                                                                         Customer service
     dialogue                                                                                                         projects, “Walk the                                               Other                         and “no hassle”
                                                                                                                      Talk” initiatives,                            Majority          investors                       deliveries, high-quality
     Materiality assessment                                                                                           competence develop-                            owner                                            products with long
     Our value chain and key                   As part of the development of our sustainability strategy in           ment, tolerance, and                                                                            lifetime, convenient
                                               2020, we performed a materiality assessment, identifying               developing working                                                                              return solutions,
     sustainability impacts
                                               the most important topics for Komplett and our stake­holders.          environment.                Employees                                        B2C customers      efficient packaging.
                                               In 2021, we have further mapped where our material topics                                                                   Our
04 CORPORATE GOVERNANCE                        are most pressing to gain insight into our broader impact.
                                               Komplett is a company that is in continuous development;                                                                stakeholders
                                               in addition to navigating an increased landscape of regula-
05 KOMPLETT CIRCULAR                           tory ESG requirements, we see the need to annually assess,             Transparent value                                                                               Product lifetime,
                                               both our main priorities within sustainability and their im-           chain, local value          Community                                        B2B customers      return and upgrade
                                               pact. In 2022, our materiality assessment will be revisited            creation, local job                                                                             solutions, responsible
06 KOMPLETT ENVIRONMENT                                                                                               creation.                                                                                       disposal, responsible
                                               and updated to reflect the changes in the markets we ope-
                                               rate, the concerns of our stakeholders, and our impact on                                                                                                              supply chain, recycled
                                                                                                                                                                 Government                                           metals and plastics.
07 KOMPLETT TOLERANCE                          both social and environmental conditions.                                                                          (The Norwegian       Suppliers
                                                                                                                                                                Environment Agency)
                                               Open and honest dialogues with our stakeholders – through
08 APPENDIX                                    day-to-day interactions, customer surveys, employee sur-
                                               veys, social media inquiries, and critical feedback from in-                                     Product safety, report                Partnership to strengthen
                                               vestors –lay the foundation for insight into our prioritized                                     on e-waste, comply                    common sustainability
                                               areas of sustainability. As part of our materiality assessment                                   with ESG regulations.                 goals.
                                               in 2020, we also conducted interviews with several members
                                               from each stakeholder group. Going forward, we plan to
                                               expand our work towards important stakeholders and to
                                               develop a plan for a structured annual stakeholder dialogue.
21       KOMPLETT SUSTAINABILITY REPORT 2021   The table to the right summarizes their main concerns.
CONTENTS                                                          Materiality
01 INTRODUCTION                                                   assessment
02 ABOUT KOMPLETT
                                                      Very
                                                                                                                                                  1.   Circular business concepts
03 SUSTAINABILITY AT KOMPLETT                    important
                                                                         10                                                             1        2.    Sustainable packaging
     Our sustainability pillars
                                                                                                                        2                        3.    Innovative solutions with partners
     Materiality and stakeholder
     dialogue                                                                                                                                    4.    Circular value chain

     Materiality assessment                                                                              3                                        5.   Zero emissions logistics

     Our value chain and key                                                                                                                      6.   Responsible supply chain
     sustainability impacts                                                                                                                       7.   Competence development
                                                                                                     5              4
                                                                                                                                                 8.    Inclusive workplace
                                               Material for key
04 CORPORATE GOVERNANCE                         stakeholders
                                                                                                                                  6
                                                                                                                                                 9.    Climate impact
                                                                                         11
                                                                    12                                                      9                    10.   Digital inclusion
05 KOMPLETT CIRCULAR                                                                                            7
                                                                                                                                                 11.   Sustainable products
                                                                              13
06 KOMPLETT ENVIRONMENT                                                                                                                          12.   Renewable energy
                                                                                                                                                 13.   Business ethics
07 KOMPLETT TOLERANCE                                             15                                                              8              14.   Employee health
                                                                                   14

                                                 Important                                                                                       15.   Community engagemnet
08 APPENDIX
                                                                                        Material for Komplett
                                                                  Important                                                     Very important

22       KOMPLETT SUSTAINABILITY REPORT 2021
CONTENTS
                                               Our value chain and key
01 INTRODUCTION                                sustainability impacts
                                                                                                   Producer        Sourcing   Warehouse        Sales     Packaging        Logistics   Customer   End of line
02 ABOUT KOMPLETT
                                               1.    Circular business concepts

03 SUSTAINABILITY AT KOMPLETT                  2.    Sustainable packaging

     Our sustainability pillars                3.    Innovative solutions with partners
     Materiality and stakeholder               4.    Circular value chain
     dialogue
                                               5.    Zero emissions logistics
     Materiality assessment
     Our value chain and key                   6.    Responsible supply chain
     sustainability impacts                    7.    Competence development

                                               8.    Inclusive workplace
04 CORPORATE GOVERNANCE
                                               9.    Climate impact

05 KOMPLETT CIRCULAR                           10.   Digital inclusion

                                               11.   Sustainable products
06 KOMPLETT ENVIRONMENT
                                               12.   Renewable energy

07 KOMPLETT TOLERANCE                          13.   Business ethics

                                               14.   Employee health
08 APPENDIX                                          Community engagemnet
                                               15.

                                                                                                                                                       IMPACT:

                                                                                                                                                                 Significant Impact

                                               Komplett Circular                Komplett Tolerance                      Komplett Environment                     Impact
23       KOMPLETT SUSTAINABILITY REPORT 2021
                                               We will contribute to            We will take care of people             We will reduce our
                                               a circular economy               at all levels of our value chain        emissions
CONTENTS

01 INTRODUCTION

02 ABOUT KOMPLETT

03 SUSTAINABILITY AT KOMPLETT

04 CORPORATE GOVERNANCE

05 KOMPLETT CIRCULAR

06 KOMPLETT ENVIRONMENT                     04 CORPORATE
07 KOMPLETT TOLERANCE

08 APPENDIX
                                               GOVERNANCE

24    KOMPLETT SUSTAINABILITY REPORT 2021
CONTENTS                                    Corporate
01 INTRODUCTION                             governance
02 ABOUT KOMPLETT

03 SUSTAINABILITY AT KOMPLETT

04 CORPORATE GOVERNANCE

05 KOMPLETT CIRCULAR

06 KOMPLETT ENVIRONMENT

07 KOMPLETT TOLERANCE

08 APPENDIX                                 The way our companies are governed is vital
                                            for value creation and achieving sustainable
                                            profitability. Komplett Group relies on stable and
                                            efficient organizational structures, routines, and
                                            management mechanisms to ensure the good
                                            functioning and progress of our companies.

                                            To secure good corporate governance, we have adopted a
                                            set of governance documents setting out principles for how
                                            our business should be conducted. All shareholders and
                                            employees are responsible for following Komplett Group’s
                                            regulations and ethical principles. We strive to ensure good
                                            and healthy business practices, reliable financial reporting,
                                            and an environment of compliance with applicable legisla-
25    KOMPLETT SUSTAINABILITY REPORT 2021   tion and regulations.
CONTENTS                                      Governance
01 INTRODUCTION

02 ABOUT KOMPLETT

03 SUSTAINABILITY AT KOMPLETT
                                              The CEO is responsible for the company’s business development, as
04 CORPORATE GOVERNANCE                       well as leading and coordinating day-to-day operations in accordance
                                              with the instructions and decisions of the Board of Directors (BoD).
     Governance
     Business conduct
                                              The BoD decides, at its meetings, on the          dence principles. Independence shall            RISK MANAGEMENT                                    GROUP POLICIES
     Customer privacy
                                              company strategy and it reviews progress.         ensure that all decisions are made on an        Risk management is part of the annual ste-         Several group policies are available on the
     and product safety
                                              Once the strategy is decided, the CEO and         unbiased and neutral basis.                     ering wheel for Komplett Group. The purpose        company’s intranet sites, including guide­lines
     Supply Chain Engagement                  the group management are responsible for                                                          is to identify and document the most impor-        for delegation of authorities, the employee
                                              its implementation. All divisions in Komplett   • Equal treatment. A fundamental objective        tant risk areas that can potentially threaten      handbook (including country-specific ver-
                                              Group are represented in the group mana-          for good corporate governance is equal          the business, its goals and its objectives.        sions), ethical and harassment guide­lines,
05 KOMPLETT CIRCULAR                          gement, and all divisions have their own lo-      treatment and equal rights for all the          The risk assessments are conducted on both         the General Data Protection Regulation
                                              cal management.                                   company's shareholders.                         group level and per segment, including risk        (GDPR) policy, guidelines for remuneration
06 KOMPLETT ENVIRONMENT                                                                                                                         exposures for all business units. Key risk         of executives, and more.
                                              When honoring the company’s corporate           • Control and management. Sound control           areas identified and the associated miti­
                                              governance policy, the BoD and executive          and corporate governance mechanisms             gating actions are reported and discussed          In addition, each department and subsidiary
07 KOMPLETT TOLERANCE                         management shall contribute to achieving          shall contribute to predictability and re-      annually with the BoD.                             within the group has established relevant
                                              the following core objectives.                    duce the level of risk for the company's                                                           management systems and processes accor­
                                                                                                shareholders, stakeholders, and other           The main areas identified in the 2021 risk         ding to local legislation and practice.
08 APPENDIX                                   • Transparency. Communication with the            interest groups.                                assessment for Komplett Group were: the
                                                company’s shareholders, stakeholders                                                            potential shortage in product availa­bility dri-   Komplett Group operates within well-known
                                                and other interest groups shall be based      The development and improvement of the            ven by the global shortage of electronic           standards for quality and environmental
                                                on transparency and openness on issues        company’s corporate governance principles         components and microchips; lower growth            management, and we are certified according
                                                relevant to the evaluation of the develop-    are ongoing. In the coming year, we will re-vi-   in consumer markets as a post-effect of            to ISO 9001 and ISO 14001.
                                                ment and position of the company.             sit the management system established             Covid-19; increased competition; and cyber
                                                                                              through our strategy process in 2020 to en-       security. Mitigating actions for each of the
                                              • Independence. The relationship between        sure that all members of our executive ma-        identified risks are monitored on a regular
                                                the BoD, executive management, and            nagement team are held responsible for            basis, and the risk assessment will be revi-
26      KOMPLETT SUSTAINABILITY REPORT 2021     share­holders shall be based on indepen-      securing progress.                                ewed in 2022.
CONTENTS                                      Business conduct
01 INTRODUCTION

02 ABOUT KOMPLETT

03 SUSTAINABILITY AT KOMPLETT

04 CORPORATE GOVERNANCE                       It is crucial for our Group to comply with and promote ethical   Importantly, the updated code of conduct states clearer stan-   employee ethical guidelines, and any violations of these can
                                              business conduct across our organization. We must take           dards and expectations on activities affecting the natural      lead to termination of employment. Development of new
     Governance
                                              precautions and active steps to make sure that no operati-       environment, including GHG emissions, land use and waste        manuals and training programs for anti-corruption is plan-
     Business conduct                         ons connected to our business are entangled in fraud or          management. The improved code of conduct will also put          ned for 2022. Further, plans to update our anti-trust and
                                              corruption. To achieve this, we must also follow up and ma-      more emphasis on expectations for business integrity and        anti-corruption manual have been established.
     Customer privacy
                                              nage our supply chains and ensure compliance with our code       anti-corruption measures as well as the importance of ma-
     and product safety
                                              of conduct which covers human rights, workers’ rights, the       naging and monitoring suppliers.                                Employees are encouraged to report any possible violations
     Supply Chain Engagement                  environment, and corruption. Komplett’s code of conduct                                                                          of laws and regulations, or possible violations of Komplett’s
                                              covers regulations and requirements for the following:           An important aspect of the renewal of our code of conduct       corporate social responsibility policy, in accordance with
                                                                                                               is to integrate standards and obligations for our companies     established whistle-blower routines. Violations can be re-
05 KOMPLETT CIRCULAR                             • Upholding local and national requirements                   and their suppliers to comply with the expectations and         ported anonymously, and alerts are protected from retalia-
                                                 • Decent labor conditions                                     regulations of the Transparency Act which will come into        tion. In 2021 there were no reported cases of breaches of
06 KOMPLETT ENVIRONMENT                          • No use of forced and/or child labor                         force in Norway in July 2022. In addition to our code of con-   business conduct or corruption.
                                                 • Freedom of association and collective bargaining            duct, employees and suppliers can find information and
                                                 • Corruption                                                  guidance about our standards and procedures for ethical         ANTI-COMPETITIVE BEHAVIOR
07 KOMPLETT TOLERANCE                            • Protection against discrimination,                          business conduct in our manual for ethical principles and       In 2020, Komplett developed a manual with guidelines on
                                                   and personal integrity                                      guidelines for communication available on our intranet.         anti-competitive behaviour. This manual started rolling out
                                                 • Wages and working hours                                     During their onboarding, new employees are presented with       throughout the organisation in 2021, and relevant personnel
08 APPENDIX                                                                                                    Komplett’s standards for business conduct.                      will receive training on the topic. The work will continue in
                                                 • Health and safety standards
                                                                                                                                                                               2022. Komplett has not had any confirmed or reported cases
                                                 • Management systems
                                                                                                               ANTI-CORRUPTION                                                 or legal action for anti-competitive behaviour, anti-trust or
                                                                                                               Komplett is committed to complying with anti-corruption         monopoly practices in 2021.
                                              In 2021 we started the work of reviewing and updating our        laws and regulations and to conducting our business acti-
                                              code of conduct to match our increased sustainability stan-      vities openly and transparently, thus supporting efforts to
                                              dards and commitment to environmental protection as well         fight corruption worldwide. Corruption undermines legiti-
                                              as new regulations concerning due diligence and transpa-         mate business activities, distorts competition, jeopardizes
                                              rency. The update will be finalized and approved by our BoD      reputations, and exposes companies and individuals to
27      KOMPLETT SUSTAINABILITY REPORT 2021   in 2022.                                                         great risk. We include guidance on anti-corruption in our
CONTENTS                                      Customer privacy
01 INTRODUCTION                               and product safety
02 ABOUT KOMPLETT

03 SUSTAINABILITY AT KOMPLETT                 PRIVACY AND DATA PROTECTION
                                              Komplett is committed to protecting the privacy rights of
                                              our employees and of everyone with whom we do business,
04 CORPORATE GOVERNANCE                       especially our customers. Personal data is only used for
                                              appropriate purposes, and processed in accordance with
     Governance
                                              binding rules set forth by the EU’s GDPR that came into
     Business conduct                         effect in 2018.
     Customer privacy
                                              Our management team takes very seriously the risks
     and product safety
                                              connected to data security. Most of our IT operations are
     Supply Chain Engagement                  outsourced, meaning that external suppliers manage our
                                              computer systems. Strict requirements established through
                                              data processor agreements are in place for all suppliers with      131,641 customers accepted the collection of customer            and regulations before being launched on our websites and
05 KOMPLETT CIRCULAR                          specific instructions to follow up on, and regularly report        information for secondary purposes. Furthermore, 7% of           stores. Continuous improvement of processes, and constant
                                              on, safety risks. Komplett conducts random sampling, audits        active accounts consented to cookies. The use of marketing       competence development are high on our agenda in order
06 KOMPLETT ENVIRONMENT                       reports, and if necessary, orders safety tests from external       cookies was approved by 78,595 visitors, and 78,677 appro-       to meet customer, regulatory and internal quality require-
                                              independent suppliers.                                             ved personalized cookies.                                        ments.

07 KOMPLETT TOLERANCE                         An e-commerce platform has been developed with instruc­            Regarding newsletter subscriptions, Komplett Bedrift’s blog      Komplett had no non-compliance incidents concerning the
                                              tions for how developers should assess privacy, and the need       currently has 5,000 subscribers registered, while 61% of         health and safety impacts of products in 2021. During the
                                              for the storage of personal data, when developing new sys-         active accounts have signed up for the Komplett Club. Every­     year, we reclaimed two products from our private label due
08 APPENDIX                                   tems. A contingency plan has been prepared which is to be          one who receives an email regarding a blog or newsletter         to incidents reported by customers where the products had
                                              used in the event of serious incidents. Further, a separate        has signed up voluntarily. Through personalized “My Pages”       malfunctioned. Both incidents were connected to overhe-
                                              routine is in place in the event of a breach of personal data      on all our online stores, customers can change their prefe-      ating and the products were collected for testing. The inci-
                                              security. In 2021 we had no substantiated complaints con-          rences at any time.                                              dents were handled according to our procedures for produ-
                                              cerning breach of customer privacy, or loss of data.                                                                                ct quality and safety. The examination concluded that the
                                                                                                                 PRODUCT SAFETY                                                   incidents were caused by defects in the individual product.
                                              Information is collected via Google Analytics for online visi-     Every day we work hard to meet our customer's needs. This        Therefore, the products were not removed from our product
                                              tors; presently, it is not possible to opt out of this. However,   includes product quality and product mix as well as service      lines. However, we take these incidents seriously and follow
                                              other cookies and tracking pixels, e.g. for Facebook and           and support. All our products undergo health and safety          them up very carefully.
28      KOMPLETT SUSTAINABILITY REPORT 2021   personalization, must be accepted by the visitor. In 2021,         evaluations, and are required to comply with all relevant laws
CONTENTS                                      Supply Chain
01 INTRODUCTION                               Engagement
02 ABOUT KOMPLETT

03 SUSTAINABILITY AT KOMPLETT

04 CORPORATE GOVERNANCE
     Governance
     Business conduct
     Customer privacy
     and product safety
     Supply Chain Engagement                  Our operations depend on several suppliers,
                                              and our value chain consists of both national
                                                                                                             Number of suppliers                    Top 10 suppliers based
05 KOMPLETT CIRCULAR                          and international producers. Improving our
                                                                                                             per category*                          on revenue
                                              value chain mapping is essential to ensure
06 KOMPLETT ENVIRONMENT                       sustainable practices and decent work con-                                              2021   2020   1.    Samsung
                                              ditions among all our suppliers.                               Gaming                    186     83   2.    Apple
07 KOMPLETT TOLERANCE                                                                                        White goods & Home        166    114   3.    Asus
                                                                                                             Hand held accessories     129    121   4.    Iiglo
                                              Through continuous dialogue, we cooperate with both ma-
08 APPENDIX                                                                                                  Components                 77     86   5.    Lenovo
                                              terial and product providers and delivery services to ensure
                                              that business conduct, quality, and health, safety and en-     Brown goods               74      61   6.    Corsair
                                              vironment (HSE) standards are upheld.
                                                                                                             Peripherals               65      78    7.   HP
                                                                                                             PC                        17      30    8.   Philips
                                              In 2021, Komplett Group worked with over 570 suppliers.
                                              Based on revenue, the most popular product categories in                                               9.   Sony
                                              2021 were computer components, handheld accessories,           *Suppliers present                     10.   Logitech
                                              and PCs. Gaming is a category that is important for us and     in multiple categories
                                              our customers; sales have expanded in other categories,
29      KOMPLETT SUSTAINABILITY REPORT 2021   such as peripherals, brown goods, and white goods & home.
PRIVATE LABEL
CONTENTS                                      Our private label lines and products continue to grow in po-
                                              pularity among our customers. Currently, we offer carefully
                                              selected private label products under the brand names Svive,
01 INTRODUCTION                               Iiglo, Intono, Khameleon, Komplett PC, 3241, and Protech,
                                              which is a sub-brand of 3241. These products are sourced
                                              through our trusted sourcing partners F&H, CBK and Calisto.
02 ABOUT KOMPLETT
                                              Strict procedures and routines are in place for sourcing from
03 SUSTAINABILITY AT KOMPLETT                 our partners, in the selection of products and to ensure
                                              product quality. Komplett has initiated a project to further
                                              monitor sourcing partners by performing audits on comp-
04 CORPORATE GOVERNANCE                       liance to standards and requirements established in our
                                              code of conduct and in the EU’s Registration, Evaluation,
     Governance
                                              Authorization, and Restriction of Chemicals regulations.
     Business conduct                         This compliance project is at a starting phase and will be
                                              strengthened in the coming year with the implementation
     Customer privacy
                                              of the management system, 4human TQM. This new system
     and product safety
                                              provides us with a platform for managing our suppliers and
     Supply Chain Engagement                  ensuring that we uphold routines to discover and manage           siness practices. All purchases must follow our suppliers’       Complying with the standards put forth in the new law is of
                                              potential breaches.                                               code of conduct and vendor agreement, and we require our         great importance to our business. The organization is cur-
                                                                                                                partners, our suppliers, and their sub-suppliers to comply       rently preparing for increased human rights due diligence
05 KOMPLETT CIRCULAR                          Our product line consists of 1790 products within gaming,         with these standards. Upon our request, our partners or          from our suppliers. New systems for audits and visits to
                                              office and accessories, HiFi, high-performance laptops and        suppliers must provide documentation on their compliance         factories must be established and implemented during the
06 KOMPLETT ENVIRONMENT                       custom-build PCs. In 2021, we introduced 234 new products,        with our code of conduct and their implementation of our         first half of 2022 to fulfill our due diligence and transpa­rency
                                              while 9 products were removed from our product portfolio.         standards. If breaches are discovered, the supplier must         obligations. To secure the necessary progress, we will en-
                                              Most of our private label products are sourced from China.        take immediate action or the purchase agreement will be          gage external consultants to assist in the establishment of
07 KOMPLETT TOLERANCE                         One supplier also produces at a factory in Poland.                terminated.                                                      new procedures.

                                              Improving the efficiency of the transportation and packaging      As mentioned above, we are in the process of adopting an         The new regulation requires considerable work for our
08 APPENDIX                                   of our private label products is a high priority, as we aim for   updated code of conduct that was developed in 2021. This         management team and our organization at large; however,
                                              the private label lines to be highly sustainable. For example,    new code of conduct will establish higher requirements for       we consider it a necessary contribution to ensuring that
                                              we strive to reduce plastic packaging and consolidate our         our suppliers and our own companies to conduct due dili-         human and labor rights are respected and upheld in our
                                              transport to reduce emissions, and our suppliers are also in      gence analysis and report on risks and violations in the sup-    entire value chain. Performing this exercise in a structured
                                              the process of implementing new procedures to calculate           ply chain.                                                       manner provides us with an opportunity to improve the risk
                                              and reduce transport emissions.                                                                                                    analysis of our supply chain.
                                                                                                                With the enforcement of the newly established Trans­parency
                                              OUR JOURNEY TO SECURING TRANSPARENCY                              Act in Norway, we continue to focus our efforts on increas-
                                              We cooperate with partners, suppliers, and other businesses       ing transparency and overview at all stages of our value chain
30      KOMPLETT SUSTAINABILITY REPORT 2021   that maintain a high ethical standard and pursue good bu-         to safeguard the people who are impacted by our business.
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