Strategy and Materiality

At Tele2 we believe that working with CR is profitable and that it enables us to deliver the best results to our shareholders. Well governed CR helps us reduce risks, strengthens our business proposal and is therefore a prerequisite for our long term success.

Below is a description of the long term CR-strategy that was launched in 2012. Now we have taken new steps as a part of our journey to continue to make CR a natural part of all business decisions. In spring 2015 we decided to leave the CR strategy, as an individual strategy, and merge it with our corporate strategy. That resulted in that Responsible Challenger, our CR work, was included as the foundation of the Tele2 House. Hence what is material to us is then integrated into core business processes through the group (corporate) strategy. Results are measured and reported in the Annual Report and on the Tele2 web page. The work, or transformation, that started in spring 2015 has continued in 2016 and will go on until everything is fully implemented and becomes an ongoing process.

Strategy house

Leadership team decision

It was a decision in the Leadership team during spring 2015 that started the transformation into the new Responsible Challenger strategy. Tele2’s previous Focus areas (Privacy & Integrity, Child Protection and CO2) were included as they have been and are still material to us. The earlier “Comply” areas consisting of fields such as Human Rights, Labor Rights, Anti-corruption, Tax Compliance and more, were merged into a headline called Ethics & Compliance. Finally Diversity was added as a new key focus area to further be developed, stressed and strengthened, see the figure below. The two top fields are seen as Tier 1 and the bottom fields Tier 2. Tier 1 is our primarily priority but all fields are material hence of high importance.


For consistency and to demonstrate that our material matters remain material we have decided to keep the previous information about them as it is still valid. We see our work as part of our journey which includes standard processes such as stakeholder dialogues, risk assessments and follow up, materiality analysis and keeping track of our boundary. Below you will find the 2012 year’s description of the areas we are covering to make us a Responsible Challenger. Diversity is on the radar as our newest Tier 2 material area and we will include information on our work there as it develops.

Our journey and material areas

Tele2’s long term CR strategy, launched in 2012, was developed to reflect priorities in the next coming years to strengthen Tele2‘s position and to meet the growing expectations from stakeholders. These were our prior, yet current, priorities. We have been and are responsive to changes and development in the world around us, and our strategy will guide us forward.
For enhanced clarity, in 2012, we did merge our strategy and materiality analysis, focusing on risks - where we shall comply - and opportunities - where we will focus, everything within our sphere of influence. All material CR areas were integrated into business processes and controls, either fully or as work in progress. We have constantly, during that period of time, reported on our work in progress in regular reporting, e.g. the Annual Report and on the Tele2 web page.

The 2012 year’s merged materiality and Strategy figure; 



It is valuable for Tele2 to have a position/profile in the defined “Focus” areas in order to strengthen our offer to the market. Well managed, these matters may put us in a better position compared with industry peers in terms of offering, reputation and stakeholder trust. These “Focus” areas are:

• Child protection
• Privacy/integrity
• Environment/CO2


Children’s safety and wellbeing are core issues to us, our owners (Kinnevik), and to our customers.

What does Tele2’s core business have to do with child protection?
Tele2 develop and provide solutions/measures to encourage a positive and safe online experience and to raise awareness of online safety. Our industry as a whole has an opportunity to be instrumental in the fight against child abuse online, for instance child pornography, and we want to be part of the solution.

How can Tele2 decide what is child pornography and what actions do you take when discovering abusive content?
Tele2 rely on INTERPOL to classify what domains contain child sexual abuse content, and Tele2 reduce the availability of such material on the web by redirecting anyone trying to access these domains to a “stop page” hosted on our server.


It is fundamental to Tele2 to act with respect for customers’ right to privacy and integrity: it is part of our culture and our formal Code of Conduct.

How can Tele2 ensure protection of customer data?
Tele2 complies with applicable laws and regulations on the freedom of expression, the right to privacy and personal integrity as well as on personal data retention, wherever we operate. We are in favor of the development of a common set of rules with regard to data protection for all markets, where by law all would be obliged to act under the same conditions.

Tele2 have stringent procedures on how to provide historical data to governmental authorities only upon authorized and lawful request. Should Tele2 have any suspicion of abuse or fraudulent requests we will report such to the relevant authorities, e.g. the state prosecution authority.

In cases of legal interception, this is exercised by an authority and the legal aspects are controlled by a supervisory authority in the same country. The authorities are not always obliged to report to us that legal interception, and partly data retention, has taken place as it usually concern a matter of state security. Legal interception may occur in any of the countries where Tele2 is operating, and is a matter of the lawful exercise to control state security.

What is Tele2 doing to protect privacy and integrity in non-democratic regimes?
Tele2 complies with applicable laws and regulations on the freedom of expression, the right to privacy and personal integrity as well as on personal data retention, wherever we operate. We are obliged to obey the law where we operate, regardless of the form of government. In countries with a record of weak human rights protection we encourage the Swedish state, through the Foreign Ministry, to engage in dialogue to strengthen a positive development.

Through our participation in the Global e-Sustainability Initiative (GeSI), we partner with other ICT organizations and companies to enhance practices related to human rights and other areas of relevance to our industry, such as Conflict Minerals.


Tele2 is committed to reducing our environmental footprint, and our main focus is reducing CO2 emissions. We encourage our partners and suppliers to reduce their environmental impact as well. Through our products and services, Tele2 help reducing customers’ environmental footprint as increased digitalization can substitute unnecessary traveling or transport and use of paper.

What is Tele2’s environmental impact?
Tele2 do not have manufacturing, hence our direct environmental impact is relatively low. The most important aspects are energy use, in particular to cool base stations.

At the same time, Tele2 contributes to reducing global carbon dioxide emissions by providing services that can reduce our customers’ environmental impact. This includes offering alternatives to travelling and/or reduces transports.

What is Tele2’s environmental responsibility?
In addition to continuously reduce our direct environmental impact, we forward/impose demands on our partners and suppliers to take environmental aspects into consideration in the extraction of raw materials and assembly of components for devices.


In order to ensure our license to operate – hence protecting our assets - we must evidence commitment and preparedness to deal with a number of issues that we have chosen to refer to as “baseline areas”. It is not our ambition to make these issues profile questions, however failure to manifest that we are in control of these matters may have severe negative effect on the perception of our company and our brand:

  • Sector specifics
  • Labor rights & employment
  • Human rights
  • Anti-competitive behavior
  • Anti-corruption
  • Tax compliance
  • Product responsibility


There are some issues that are specific to telecom operations including manufacture of telecommunication products, rollout of telecommunication infrastructure, operation of sites and corporate/commercial premises, and use of telecommunication products and services. These are matters that Tele2 is monitoring and following up on.


Tele2 are committed to being a fair and equal opportunity employer and to respect and comply with labor rights and regulations, including occupational health and safety, freedom of association and the right to collective bargaining (which are both human rights as well as labor/employment rights).


Tele2 supports and respects all fundamental human rights and our Code of Conduct is based on the United Nations Global Compact and the Universal Declaration of Human Rights. This means that we do not condone for instance discrimination, child labor, forced labor, violations of the freedom of association or freedom of expression in our operations.


Tele2 is committed to free and fair competition, and open markets. We have a tradition of breaking up monopoly power and firmly believe that fair competition is beneficial for our business and our offer. All Tele2 employees are expected to protect the interests of Tele2’s final consumers anywhere in the world.


Tele2 takes a clear stand against corruption, and all our employees are instructed to never offer, ask, give or accept any unjustified advantage for personal gain in relations with a third party. This being said, we do allow for reasonable hospitality, having a threshold of 50 EUR as guidance, or representation within sound boundaries.


Tele2 comply with national tax laws and the OECD guidelines in all countries were we operate, as tax revenues are important to build and develop society. We want to give a fair contribution to the development of the countries where we operate.


Marketing: In all our communication with Tele2 customers and the market about our offering, our marketing or advertising material shall always be frank and accurate, and sensitive to norms and the law. EMF: Our network, as all electric equipment, emits radiation and creates electromagnetic fields (EMF), hence Tele2 comply with the recommendations by relevant authorities when handling our networks.


There are a number of CR issues that are not considered material or relevant to our business hence these are not being prioritized on the same basis as our material areas. In cases of questions however, we are transparent and “inform” on the following issues:

  • Materials
  • Sponsoring
  • Bio-diversity
  • Water
  • Local community


As Tele2 does not operate any manufacturing or production plants this is not of direct importance to us. We do however encourage our suppliers to be resource efficient and take environmental consideration in production process: this is specified in our Environmental Policy. The use of materials may be critical from a sustainability perspective for a company that is very resource demanding, for instance processes enormous masses of ore in order to extract iron ore, or that uses input material that may be controversial from an environmental perspective by being non-renewable, such as coal.


While at Tele2 we believe that sponsoring may have positive influence on the perception of our company, or build pride among our employees, it is not a Group strategy. Therefore this is not a prioritized subject for Tele2 to monitor on group level, from a CR strategy perspective. In order for sponsoring activities to be relevant they shall be decided and managed on a local level.


The only aspect of Tele2’s own operations where bio-diversity is material is in respect to the placement of base stations, which hypothetically may be in locations of high biodiversity value. However, the land owner has the responsibility to stay informed of any sensitive species and report to the relevant authorities, who then issues construction permits. Only then Tele2 can place a base station on the land slot. Tele2 never owns the land and relies on the land owner having investigated the impact to receive the permit.


As Tele2 does not operate any manufacturing or production plants this is not of critical importance to us. Our water consumption could mainly be referred to “office use” and we are not present in regions with water scarcity. Very little water also goes into the processes in our supply chain. We do however encourage our suppliers to be resource efficient and take environmental consideration in production process, including the sensible use of water. This issue may be material to a company whose processes is very water demanding, for instance how many liters of water it actually takes to produce a liter of a soft drink beverage or a pair of jeans, and/or that operates in an area that suffers from water scarcity.


While at Tele2 we believe that engagement with the local community is important, we also believe that such activities in order to be relevant shall be decided and managed on a local level. Therefore this is not a prioritized subject for Tele2 to monitor on group level, from a CR perspective. We do however strive to bring values to the communities where we operate, through our offering and by bridging the digital divide to help stimulate positive development.


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