Transparency Report on Human Rights Risks in Telenor Linx

Telenor Linx is a part of Telenor Group and this transparency report in accordance with the Transparency Act is a supplement to the report by Telenor ASA which can be found here.

At Telenor Linx, we recognize the importance of addressing human rights risks and promoting responsible business practices in our global operations. As part of our commitment to promotion of human rights – an integral part of our mission in ‘connecting societies to what matters most’, this report aims to provide insight into our human rights and due diligence assessments, key findings, and how we work to promote human rights throughout our business relations.

Telenor Linx is a newly established company within Telenor Group, born out of Telenor Global Services and Telenor Digital, we provide global connectivity services – combining the traditional world of telecom with software flexibility.

We are located in offices in Norway (HQ), Sweden, Poland, Dubai, Pakistan, Thailand and Singapore, operating as a fully owned subsidiary of Telenor ASA. We offer a range of products and services, including voice, messaging, roaming, Direct Carrier Billing, Millom, Phone number verification, and telecommunications infrastructure solutions. As an international wholesale provider, Telenor Linx engages telecommunication operators and digital services providers globally, operating in the businessto-business market.

As part of Telenor Group, Telenor Linx adheres to Telenor’s governing policies and guidelines through governance programmes and have developed internal guidelines and routines to address and mitigate negative consequences for human rights and decent working conditions. This governance framework guides our decision-making processes and ensures responsible business conduct throughout our operations.

To facilitate reporting and whistleblowing processes aimed at helping us uncover negative consequences and address concerns, we utilize Telenor’s hotline channel available here. These whistleblowing mechanisms provide opportunities for stakeholders to voice their concerns, helping us identify risks and contribute to our continuous improvement efforts.

Identified risks and impacts
Through our due diligence and risk assessments, we have identified risks which may arise that can impact basic human rights. These risks include:

Privacy and data protection
As an international telecommunications-and software company, we recognize the importance of safeguarding the privacy and personal data of our customers. However, in certain jurisdictions, there are risks associated with country-specific surveillance practices and other potential privacy infringements impacting the right to private life. These risks may include unauthorized access to communications data, monitoring of online activities, and restrictions on access to certain websites or platforms. Further, in countries of conflict, Telenor Linx has observed reports of human rights abusive actions being taken against vulnerable groups based on unauthorized surveillance of their international communications.

Freedom of Expression and Access to Information
Operating in diverse markets means we encounter varying degrees of restrictions on freedom of expression and access to information. In some jurisdictions, there may be challenges related to censorship, content filtering, or limitations on the free flow of information. We strive to navigate these risks while upholding our commitment to promoting open and safe communications and access to information.

Supply Chain Risks
Telenor Linx recognizes the importance of ensuring that promotion of decent working conditions and upholding labor rights extends throughout our supply chain. As we engage with suppliers internationally, we observe risks in some jurisdictions – predominantly relating to privacy and data protection. Through our business partner screening and monitoring processes, we seek to address those risks on a case-by-case basis deploying our mitigation toolkit described below.

Customer/Partner Risks
Through our international services, we sometimes engage customers and business partners in jurisdictions where international human rights standards are not recognized or adhered to. Moreover, we have found cases where customers or business partners have track records which gives rise to human rights concerns. Our engagement towards these partners is always considered on a case-by case basis as the risks must be balanced against the opportunity and promotion of human rights that our services entail.

Mitigation measures
In response to the risks identified, we have implemented- and are continually working with a range of measures to prevent, stop, or limit their impact. These measures can be split into general mitigations aimed at preventing and reducing human rights risks as a whole, and tailored mitigations based on specific risk elements identified. The general measures include:

Robust whistle blowing channels
Robust whistle blowing channels, including ‘speak up’ codes of conduct that allow us to foster transparency and identify risks throughout our operations. We thrive to promote these values both internally and externally to our partners in all our engagements.

Stakeholder engagement
Stakeholder engagement, particularly towards our business partners, industry organizations, market peers, regulatory bodies and other broader stakeholder institutions. These engagements enable us to understand and adapt human rights measures specific to our industry and the services we deliver.

Due diligence processes
Due diligence processes, enable us to identify, assess and act on human rights issues on case-bycase basis, allowing us take specific action as needed depending on the identified risks.

Securing connectivity
Securing connectivity, especially in areas of conflict. Recognizing that the confidentiality of communications data may be at risk in certain jurisdictions – Telenor Linx believes that securing the ability to stay connect – is a vital mitigation to the protection of freedom of expression and the right to receive and impart information and ideas. In particular, where the dilemmas involve striking a balance between making available connectivity services against the potential jurisdictional risks faced in a market, we believe that our position to secure connectivity as far as possible, has broader societal recognition i.e., through legislations aimed specifically at ensuring the availability of communications services.

In combination with these general mitigations, we have implemented and are continually working to prevent, stop or limit the specific risk elements that we face within the industry and markets we operate. These measures are described in the following:

Privacy and data protection
  • Evaluations on ‘no-routing’ vis-à-vis certain destinations.
  • Implementation of robust encryption protocols to secure communications and protect user data.
  • Regularly review and update security measures to adapt to evolving threats, including adaption of industry best-practices.
  • Comply with relevant data protection laws and regulations, both at the international level (e.g., GDPR) and in specific countries to which we may be subject.
  • Establish partnerships with trusted network operators and service providers that prioritize data security and privacy.
  • Maintaining robust fraud prevention systems, securing individuals quality of service, security and digital trust.
  • Challenge legal intercept requests. More information on how Telenor works towards authority requests can be found here.

Freedom of expression and access to information
  • Implementation of clear policies and guidelines that promote freedom of expression, respect for users’ rights to access information and the right to net neutrality.
  • Advocate for free and open ICT services, including promotion of technology roll-out to ensure best in class connectivity services ensuring our users can stay connected to what matters most.
  • Challenge and uphold principles on open communication and freedom to access and disseminate information when faced with conflicting legal requirements in certain jurisdictions.

Supply Chain Risks
  • Maintain close relationships with our suppliers and partners to ensure that supply chain risks addressed.
  • Contractually require our suppliers to enter into Telenor’s supplier conduct principles to ensure our suppliers are committed to uphold international human rights and decent working conditions.
  • 24/7 monitoring of all suppliers to enable swift response to emerging risks.
  • Strong privacy and security supplier management measures to ensure that the right to private life guarantees is sufficiently managed and maintained throughout our supply chain, including the suppliers’ sub-processors.

We believe that a key part of our societal responsibility is inherent linked to our mission, connecting societies to what matters most – in that all have a right to communication- and engage digital services, regardless of race, ethnicity and nationality. As such, Telenor Linx looks to not only mitigate human rights risks – but embody the promotion of these rights in our mission.

Fornebu, 26.06.2023
Signed by the board of Telenor Linx AS

Ove Fredheim

Chairman of the board

Marianne Moe

Member of the board

Asle Svanøe

Member of the board

Ruza Sabanovic

Member of the board

Fridtjof Rusten

Member of the board

Yasir Azman

Member of the board

Kjetil Hanshus

Member of the board

Mona Børøen

Member of the board

Stig Atle Waagbø

General Manager

We create value by simplifying and building long term trusted partnerships.

Get in touch with one of our experts and discuss next steps.