Schibsted

Schibsted Marketplaces' governance structure is composed of the Board of Directors (hereafter 'the Board') and the Executive Leadership Team, which together constitute the administrative, management and supervisory bodies. The Executive Leadership Team is considered the management and administrative body, while the Board is considered the supervisory body. The Board is responsible for oversight, ensuring strategic direction and monitoring financial and sustainability-related risks and opportunities. Board committees such as the Audit Committee and Nomination Committee play a supporting role to the Board.

Schibsted Marketplaces' Board comprises 10 regular members and three deputy members; seven shareholder-elected and six employee-elected (of which three are deputies). The shareholder-elected members serve one-year terms, while the employee-elected representatives serve two-year terms. With a 1:1 (50%) ratio of female to male Board members, excluding deputies, the Board's composition adheres to the Norwegian Public Limited Liability Companies Act.

The Board has experience with the sectors, products and geographic reach of the company. Members bring deep experience in marketplaces, technology, digital industries and real estate, contributing with critical insights into global marketplace dynamics and technology operations.

The Executive Leadership Team is composed of nine members, of which three are female (33 per cent) and six male (66 per cent). Their collective experience spans strategic leadership, data and technology innovation, financial management, marketing and sales and people-focused organisational development.

The Board oversees and governs Schibsted Marketplaces' sustainability performance (impacts, risks and opportunities). The Board has the final decision on actions to take and approves the sustainability-related ambitions and targets by signing the Board of Directors' report, which includes the sustainability statement.

Board Responsibility for IROs:

As an integral part of Group performance and strategy management, the members of the Executive Leadership Team, their respective management teams and the Head of Sustainability monitor progress on material sustainability matters. This work includes evaluating the results and effectiveness of policies, actions, metrics and targets adopted to address these matters. The Head of Sustainability also monitors the overall progress in relation to actions and targets and reports to the Board and the Executive Leadership Team on a need-to-know basis and at least annually. During 2024, three such updates were provided. The progress on ambitions, targets and actions and their effectiveness are reviewed at least three times per year by the Executive Leadership Team. The implementation of policies and their effectiveness is reviewed annually. The annual sustainability statement, which is integrated into the annual report, forms the main report to the Board on sustainability.

Critical concerns relating to Schibsted Marketplaces' material social and environmental impacts, risks and opportunities can also be addressed and communicated to the Board on a need-to-know basis or through the whistleblower or risk management processes. For all potential investments in new companies, a sustainability due diligence is performed that informs the bodies about the impacts, risks and opportunities related to the target company.

Schibsted Marketplaces' Executive Leadership Team reviews risk assessments of strategic, market-related, legal, sustainability, compliance-related and ethical issues as well as operational and organisational risk assessments. Risk assessments are also reported to and reviewed by the Audit Committee and the Board. During 2024, all material impacts, risks and opportunities except Waste generated in own operations and delivery services were addressed by the Board and the Executive Leadership Team.

No specific incentives linked to sustainability matters are currently offered to the Board or the Executive Leadership Team. However, such incentives have previously been offered and the need for them is reviewed annually. Schibsted Marketplaces has no sustainability or climate-related performance indicators included in incentive schemes.

Schibsted Marketplaces has a process for due diligence at both Group and subsidiary level. The process is based on the OECD due diligence model as described in the Guidelines for Multinational Enterprises. Responsibility for the due diligence processes is shared between the sustainability and compliance functions at Group level. Responsibility for due diligence processes also lies with each subsidiary, with oversight provided by the Group sustainability team. To manage identified risk areas, subsidiaries have developed their own specific internal follow-up processes. The internal processes are adapted to the company's size and identified risk areas. According to our Code of Conduct, all companies must conduct third-party due diligence in accordance with internal procedures when deemed necessary and must comply with applicable regulations, including sanction regimes and import and export regulations.

Schibsted Marketplaces' began to formalise its Internal Control over Sustainability Reporting (ICSR) system during 2024. Our ICSR system is an integral part of the sustainability reporting process and is based on the key elements of the COSO internal control integrated framework. The first step in formalising our internal control over sustainability reporting was to perform a risk assessment for the 2024 sustainability reporting. The primary objective of the risk assessment was to identify and manage the critical reporting risks. As part of this process, several key controls were identified, performed and documented.

The main features and components of the risk management and internal control processes in relation to sustainability reporting are upskilling for people who report sustainability data, segregation of duties and harmonisation of processes.

The main risks identified in relation to the quality of our reporting include potential inaccuracies in the double materiality assessment, errors in data collection, mistakes in compilation and reporting, and lack of sustainability competence in the organisation and among suppliers. Strategies for mitigating these risks are:

• Providing training sessions for sustainability data reporters aimed at minimising potential misunderstandings and human errors, • Integration of data verification in the general calculation processes (Group-level analysis and key controls, such as completeness and reasonableness of data), and • Creation of an internal framework and guidance for sustainability reporting.

The internal controls and risk management of our sustainability reporting is subject to review by the Audit Committee and when needed this is elevated to the Executive Leadership Team to address those issues.

Schibsted Marketplaces provides diverse digital services across its business units, including online marketplaces (e.g., FINN, Blocket, Tori and DBA) and delivery services. In 2024, we carved out our news media operations into a stand-alone company (Schibsted Media) privately owned by the Tinius Trust. Schibsted Marketplaces operates a vertical-based business model. The operating segments are Mobility, Real Estate, Jobs, Recommerce, Delivery and HQ/Other.

Operating primarily within Nordic markets, Schibsted Marketplaces serves a vast customer base across Norway, Sweden, Finland and Denmark. With more than 300 million visits per month, many consumers in the Nordics engage with our services. We will continue to expand our marketplace offerings to cater to evolving customer needs through the development of innovative services such as Qasa (transactional rentals) and Wheelaway (customer-to-business car sourcing). Several of the marketplace verticals (including Recommerce, Mobility and Real Estate) play a role in enabling the circular economy and their business model is linked to this development.

Schibsted Marketplaces employs 3,884 individuals distributed across its Nordic operations, with a presence mainly in Norway, Sweden, Finland and Denmark. These employees contribute to various segments, including marketplaces and delivery services, aligning with our strategic focus on our geographic core.

Our business model in relation to sustainability matters Several elements of Schibsted Marketplaces' strategy impact sustainability matters. In general, sustainability serves as input for shaping the business strategy at various levels. In particular, our Delivery business operates a fleet of vehicles that emit GHG emissions from energy use (fuel and electricity). The Delivery business is among the largest in Norway and a key project is the transition to low-emission vehicles. For the marketplace verticals (Mobility, Real Estate, Jobs, Recommerce) the main challenge ahead is to adapt their strategies to address the relevant sustainability matters in each area.

Overview of how our business model relates to sustainability matters:

Interests and views of stakeholders

Stakeholder engagement approach

Our brands actively engage with stakeholders through market research, partner dialogue and interviews, recognising that our operations rely heavily on the trust of our users and partners. Such interactions, and stakeholder engagement in general, serve the purpose of shaping our business strategies, product development and for understanding our impact. Engagement methods are determined by the stakeholder group categories and their direct and indirect influence on Schibsted Marketplaces.

Value chain workers have been identified as a material key stakeholder group, but were not included in the centrally organised stakeholder dialogue from 2022. Instead, engagement occurred directly with worker's union representatives, suppliers and business partners. Value chain workers will be considered for inclusion in future stakeholder dialogue.

The latest stakeholder dialogue was performed as Schibsted, before the carve-out of Schibsted Media. A new stakeholder dialogue is planned for 2025-2026.

Governance of stakeholder engagement

The Board has entrusted the Executive Leadership Team with responsibility for stakeholder interaction. This team engages with stakeholders through various channels, including employee committees, employee representatives, industry associations, dialogue with key corporate customers, regulatory discussions, media interviews and investor relations. The outcome of this engagement, and the views and interests of affected stakeholders with regard to sustainability-related impacts, are reported to the Board on a regular basis.

Integration into strategy and business model

The outcome of our engagement with stakeholders is used in multiple ways; from a sustainability perspective these interests and views of our key stakeholders, including their relation to the strategy and business model, are included in the DMA process to identify and assess IROs. They are also regularly taken into account when (re-)defining strategies, most recently in defining the new strategy for Schibsted Marketplaces presented at Capital Markets Day 2024 on 19 November 2024.

While several of the interests and views are covered in the new strategy, no major changes of direction in the strategy were made in response to the interests and views of stakeholders and no further steps are currently planned.

Key stakeholder groups and their interests

Affected stakeholders in relation to sustainability impacts:

Own workforce (S1)

Schibsted Marketplaces' strategy and business model take the interests, views and rights of people into consideration through the processes for engaging with its own workforce described in section S1-2 – Processes for engaging with own workforce and workers' representatives about impacts.

Due to the carve-out of Schibsted Media in 2024, a new strategy and reorganisation was necessary and input from these engagement processes was considered as one of several perspectives informing the strategy and reorganisation deliberations. More specifically, several communication efforts and employee and manager support initiatives were set up as a result of this engagement.

Value chain workers (S2)

The interests, views and rights of value chain workers are considered by us when defining our strategy and business models. Value chain workers can be impacted by our business models, especially in relation to employment forms and agreements, the structure of our subcontractors and in consideration of vulnerable workers.

In cases where the current business model has significant actual negative impacts on value chain workers, actions are taken on multiple levels to mitigate and/or avoid this impact. The most recent example of this is within the Delivery value chain, where subsidiaries have recently shifted towards a business model with more permanent staff, which improves Delivery's ability to directly influence and improve workers' rights.

Consumers and end-users (S4)

Our strategy and business model are deeply informed by the interests, views and rights of our consumers and end-users, as they represent a key group of stakeholders whose feedback shapes our decision making. Through ongoing stakeholder dialogue and UX research embedded in our daily operations, we ensure that their perspectives are consistently integrated into our processes.

This includes addressing their human rights concerns, identifying their evolving needs and incorporating these insights into product development, service delivery and broader strategic initiatives. By maintaining this consumer-centric approach, we strive to align our business objectives with their expectations and enhance value creation for all stakeholders.

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

Overview

For an overview of all material impacts, risks and opportunities resulting from the materiality assessment, see the table below. The table also includes information on where in our business model, own operations and our upstream and downstream value chain these material impacts, risks and opportunities are concentrated.

Schibsted Marketplace has not identified any significant current or anticipated effects of its material impacts, risks and opportunities on its business model, value chain, strategy and decision making. While we have deemed it unlikely that our business models, value chain, strategy or decision making should fundamentally shift in response to IROs, some changes are likely to occur as we and actors in our value chain adapt to address these issues. The IROs give direction to our future sustainability work and will inform our general decision-making processes. Due to our business model, pursuing our business objectives is in many cases aligned with achieving positive sustainability-related outcomes. While we continuously address identified IROs, we have not yet decided whether to make any significant changes to our strategy and business model in response to them. However, this will be considered as part of our ongoing work on addressing these IROs.

Following an assessment of our IROs, we have determined that our material risks and opportunities will not have significant effects or cause material adjustment to the carrying amounts of assets and liabilities reported in the related financial statements within the next annual reporting period. These risks and opportunities will be taken into consideration when making financial plans and provisions for the future and this assessment might change as we adapt to our material risks and opportunities. Schibsted Marketplaces has not quantified the current financial effects of our material risks and opportunities, including the impact on our financial position, performance and cash flow.

Material IROs table

Aggregated material impacts on people and environment

Interaction with strategy and business model

E1 Climate change

The carve-out of Schibsted Media presented a major shift for Schibsted Marketplaces' strategic sustainability work. As a result, key sustainability analyses and strategic elements have been deemed as outdated during 2024 and will be updated going forward. The climate risk analysis was used as input to the DMA process. The DMA showed that no climate-related risks were material. Overall, as the operator of digital marketplaces and delivery services with no major sites in specific climate-related risk areas, we have a robust business model with limited direct exposure to climate-related physical or transitional risks.

S1 Own workforce

Schibsted Marketplaces operates in a fast-moving digital environment characterised by intense competition, necessitating frequent strategic and business model adaptations. A significant portion of the cost base is linked to personnel and changes in strategy or direction often result in adjustments to organisational structures to achieve business objectives. For instance, the carve-out of Schibsted Media in 2024 required a comprehensive review of the cost base, leading to a cost reduction programme as part of reorganisation efforts. This adjustment resulted in negative impacts on the workforce, including diminished work-life balance and health concerns for some employees. These outcomes highlight the connection between our strategy and its effects on the workforce. Looking ahead, it will be an important priority for 2025 to avoid a similar situation.

The impacts and dependencies on our own workforce generate risks of poor work–life balance, unclear roles and lower productivity. The main opportunity identified is to create an organisation with a clear purpose, culture and performance related to sustainability in order to enhance attractiveness and retain talent. By recognising the dependencies between workforce impacts and our strategy we can adapt our business model to foster a resilient and engaged workforce while meeting competitive and sustainability objectives.

The DMA process revealed that employees within Delivery are at greater risk of being negatively impacted by poor working conditions due to our operational model, with services performed during limited nighttime hours. No other people with particular characteristics or working in particular contexts or undertaking particular activities were found to be at greater risk of being affected by the other negative impacts. Schibsted Marketplaces has no activities that are connected to operations with significant risk of forced labour or child labour nor activities in geographies with significant risk of forced labour or child labour. The material negative impacts identified in connection with Schibsted Marketplaces' own workforce are not widespread or systemic in the context of Schibsted Marketplaces' operations but rather are related to isolated incidents. All three material risks and opportunities related to our own workforce affect the entire workforce to an equal extent. No specific groups of people (such as age groups) are disproportionately affected.

S2 Workers in the value chain

Schibsted Marketplaces acknowledges that its impacts on value chain workers are connected to its business model and strategy. Specifically, this encompasses the reliance and dependency on subcontractors for delivery services and investments which operate in high-risk sectors. Issues include potential poor working conditions for subcontractors and human rights risks in certain investments (e.g., medical equipment and consumables, and food and drink). These impacts directly inform Schibsted Marketplaces' strategy and business model by driving efforts to improve oversight of subcontractors and assess human rights implications, thereby further aligning practices in our value chain with ethical labour standards and help mitigating risks. The strategic shift of focus to the four marketplace verticals is expected to reduce these impacts over time, as they are mainly related to Delivery and our investments.

For Schibsted Marketplaces, the material negative impacts identified are systemic in both the delivery context and in the context of value chain workers connected to investments. They are deemed as systemic since the negative impacts apply to these industries in general. We have not been notified of any specific incidents related to human rights violations, but will continue to work on due diligence to ensure we receive accurate and reliable information about conditions in the supply chain.

S4 Consumers and end-users

The identified actual and potential impacts on consumers and end-users are directly connected to our business model, since we are reliant on connecting consumers with other consumers or businesses to transact within mobility, real estate or recommerce categories or to find job opportunities. This exposes consumers to risks of being treated negatively and with our scale of reaching millions of consumers this becomes an important issue to address. The process to identify and assess these impacts follows the same DMA process as in other areas described above. The outcome of that process is used to inform and adapt our strategy and business model.

Since we can perform our role as a marketplace in a better way if consumers are treated fairly and without negative impacts on our platforms, there are in many cases corresponding risks or opportunities for the material impacts identified. This creates an alignment with our strategy and business model(s) and the rationale for increasing positive impacts and mitigating or avoiding negative impacts, while reducing risks and pursuing opportunities. One concrete example is in Recommerce, where our work to reduce fraud on our platforms directly improves users' trust in the platform, which has multiple positive benefits for us.

Except for the negative impact connected to cybersecurity, all of the negative impacts (especially fraud attempts, lack of price transparency in real estate markets and discrimination in hiring processes) are common in the markets in which we operate and could be considered systemic. Several mitigating actions and systems (such as automatic and manual moderation of ads and user interactions) have been put in place by Schibsted Marketplaces to limit these negative impacts, including the impact related to cybersecurity. Cybersecurity is considered to be related to isolated incidents. Negative impacts connected to specific users are limited to isolated incidents and are treated on a case-by-case basis. As part of this analysis, no consumers or end-users with particular characteristics were identified as being at greater risk of harm. However, some services are specifically connected to the negative impacts listed above, such as jobs or rental marketplaces. These were identified through direct user feedback, as well as through the stakeholder engagement process. Schibsted Marketplaces has not identified any of the material risks and opportunities arising from impacts and dependencies on consumers and end-users as relating to specific groups of consumers or end-users.

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

Overall methodology

The double materiality assessment (DMA) conducted by Schibsted Marketplaces aligns with ESRS and encompasses two main perspectives: financial materiality (how sustainability issues affect the company's financial performance) and impact materiality (how the company's operations impact the environment and society).

Schibsted Marketplaces' DMA process followed four key phases:

Phase one: Context and IRO sourcing

This initial phase involved identifying impacts, risks and opportunities (IROs) through various inputs, such as stakeholder dialogue, expert interviews and sustainability ambition documents. A longlist of IROs was created based on these sources and mapped against macrotrends, value chain analysis and external sustainability documentation. The process leveraged AI assistance to categorise and define IROs aligned with ESRS definitions.

Phase two: Structuring IROs

In this phase, the Group sustainability team conducted workshops to refine the longlist of IROs by categorising them into positive and negative impacts, risks and opportunities. The aim was to ensure that all stages of the value chain were adequately covered and that the relevant IROs were mapped against ESRS topics.

Phase three: Assessment of IROs

This phase focused on assessing the materiality of the IROs by applying a rating system based on factors such as impact on environment, society, people and economy, as well as on financial, reputational and regulatory impacts. Both opportunities and risks were weighted based on their potential revenue impact and risk scores, respectively. The likelihood and magnitude of each IRO were assessed to prioritise those with the most significant impact. Potential or actual negative impacts were scored on severity and likelihood, while potential or actual positive impacts were scored on scale, scope and likelihood. This assessment closely followed the method prescribed in ESRS 1.

Phase four: Defining material IROs and statement scope

The final phase involved setting thresholds for materiality based on the assessment scores of IROs. These thresholds were determined through workshops with the sustainability team and validated by the Board. For risks and opportunities, the weighted total opportunity/risk score was used. The same threshold was used for both risks and opportunities to ensure positive and negative effects are treated equally. For positive and negative impacts, the threshold was set as a matrix based on likelihood and severity. The same threshold was used for positive and negative impacts to ensure equal treatment. The limits for risk/opportunities and negative/positive impacts, respectively, are based on the team's previous experience in working on sustainability in Schibsted Marketplaces, previously covered topics in external reporting (GRI) and on the balance between the number of risks/opportunities/impacts considered as material. IROs that exceed these thresholds were classified as material and included in the sustainability reporting, forming the basis for the sustainability statement.

Inputs to the assessment

Data sources

Several data sources were used to understand the relevant scope, map the value chain(s) and source IROs:

Sector benchmarks and ESRS guidance

The process leveraged AI assistance to categorise and define IROs aligned with ESRS definitions.

Internal experts and external consultants

The Group sustainability team prepared a draft assessment during 2024 which was iterated using internal and external experts (incl. Position Green and Sweco Sverige AB) and presented to the CFO, Executive Leadership Team and the Board.

Stakeholder consultation

Stakeholder dialogue, expert interviews and sustainability ambition documents were key inputs. The process identified the impact of Schibsted Marketplaces mainly through the stakeholder dialogue, as well as in consultation with external experts.

The latest stakeholder dialogue was performed as Schibsted, before the carve-out of Schibsted Media. A new stakeholder dialogue is planned for 2025-2026.

Scoring criteria for impact materiality

Positive impacts

Potential or actual positive impacts were scored on scale, scope and likelihood.

Rating scale for assessing positive impacts:

Negative impacts

Potential or actual negative impacts were scored on severity (scale, scope, irremediable character) and likelihood.

Rating scale for assessing negative impacts:

Scoring criteria for financial materiality

Risks and opportunities

To assess the likelihood and magnitude of effects of identified risks and opportunities, the following scale was used:

Rating scale for assessing risks and opportunities:

The rating scale was applied to the revenue stream of each business segment, giving a score per segment. The sum was then used as the total score to assess the overall materiality of the risk/opportunity to Schibsted Marketplaces.

To assess financial materiality, revenues for FY 2023 per relevant business segment were used.

Threshold for materiality

For risks and opportunities, the weighted total opportunity/risk score was used. The same threshold was used for both risks and opportunities to ensure positive and negative effects are treated equally.

For positive and negative impacts, the threshold was set as a matrix based on likelihood and severity. The same threshold was used for positive and negative impacts to ensure equal treatment.

The limits for risk/opportunities and negative/positive impacts, respectively, are based on the team's previous experience in working on sustainability in Schibsted Marketplaces, previously covered topics in external reporting (GRI) and on the balance between the number of risks/opportunities/impacts considered as material.

IROs that exceed these thresholds were classified as material and included in the sustainability reporting.

Frequency and when last reviewed

The DMA process, especially phases two to four, changed significantly from previous years to align with the process described in ESRS 1. The latest revision was carried out on 20 December 2024 and future revisions are planned annually.

The IROs identified as material through this process will be continuously monitored and reviewed at least annually.

Use of value chain mapping

The scope for the value chain mapping was based on Schibsted Marketplaces including subsidiaries, their upstream and downstream value chain as well as other business relationships. Notably, given the high value of the financial minority stake in Aurelia Netherlands Topco B.V., the indirect parent of Adevinta, its operations and value chains were considered in the value chain mapping of Schibsted Marketplaces.

Value chain mapping was used in:

• Context and IRO sourcing (Phase one)
• Structuring IROs (Phase two)

Core assumptions

Several core assumptions were applied throughout the process, most importantly that the sources used to generate the longlist of IROs (e.g., stakeholder dialogue, expert interviews and sustainability ambition documents) accurately reflected the full scope of potentially relevant areas to include. A secondary core assumption was that using revenue as a benchmark to assess financial materiality adequately captures how sustainability issues affect Schibsted Marketplaces' financial performance for various types of risks and opportunities across the Group.

The process above aimed to capture the totality of material impacts (potential or actual) and therefore did not focus especially on specific activities, business relationships or geographies, but rather on capturing a broader scope. However, it did consider the impacts with which we are involved through our own operations or as a result of our business relationships.

Internal control procedures

The internal control procedures related to decision making included the approval of the DMA by the CFO and the Board, after incorporating feedback from external experts (incl. Position Green and Sweco Sverige AB). To this end, an interim version was discussed and approved by the CFO and the Board in October 2024. Another internal control procedure was that interim updates were provided regularly to the Audit Committee. The final version was approved by the CFO and the Board as part of approving the overall sustainability statement.

Integration with risk management

While the DMA process uncovers several important impacts and risks that are considered in risk management procedures, it was not an integrated part of the overall risk management process in 2024. There are no formal centralised opportunity mapping procedures in place at Group level, but the opportunities identified in the DMA process are used as input when considering opportunities across the Group. The process to identify, assess and manage opportunities is planned to be integrated into our overall management process during 2025-2026, but this was not done in 2024.

The risks identified in this process are not yet prioritised in relation to other risks identified in other risk assessment procedures.

Topic-specific considerations

E1 Climate change

Climate-related impacts, risks and opportunities were identified as an integrated element in the DMA analysis, leveraging the stakeholder analysis, expert interviews and the value chain mapping to identify and assess climate-related IROs. The TCFD report from 2021 and the updated risk mapping performed in 2023 were used as input to the DMA process to identify material impacts, risks and opportunities. The GHG emissions addressed include those from Scopes 1, 2 and 3, and thereby cover both own operations and value chain.

Due to the material changes to operations during 2024 (the carve-out of Schibsted Media), an updated climate risk analysis is considered necessary to ensure relevant information on climate-related physical and transitional risks going forward. We plan to conduct an updated climate risk and scenario analysis during 2025.

E2 Pollution

Schibsted Marketplaces did not screen site locations and business activities in order to identify actual and potential pollution-related impacts, risks and opportunities in its own operations and upstream and downstream value chain. However, during the DMA process, a potential pollution-related impact in the Delivery value chain was identified through the stakeholder dialogue and consultations with experts. This was not deemed to be material to Schibsted Marketplaces. No affected communities were identified during this process and no consultations were therefore needed.

E3 Water and marine resources

Schibsted Marketplaces considered actual and potential water and marine resources-related IROs in its own operations and upstream and downstream value chain during the DMA process. However, no material IROs were identified during the process, and this topic is therefore not subject to reporting requirements.

E4 Biodiversity and ecosystems

Schibsted Marketplaces did not conduct a dedicated process specifically focused on biodiversity for identifying material impacts, risks, dependencies and opportunities. Instead, biodiversity considerations were addressed within the broader stakeholder engagement process. During this process, biodiversity matters were considered, but ultimately deemed non-material to Schibsted Marketplaces. Therefore, no specific considerations were made with regards to our i) impacts and dependencies, ii) transition and physical risks and opportunities, iii) systemic risks or iv) consultation with affected communities.

While biodiversity was acknowledged in the stakeholder engagement process, it was not identified as a material priority for any of Schibsted Marketplaces' site locations and therefore did not warrant further dedicated analysis or specific measures. However, for Schibsted Media, which was owned by Schibsted Marketplaces during the period January–May 2024, ESRS E4 is a material topic.

Schibsted Marketplaces has no sites located in or near biodiversity-sensitive areas and as such has not deemed it necessary to implement any biodiversity mitigation measures.

For Schibsted Media (January–May 2024):

Schibsted Media conducted a double materiality assessment (DMA) after the carve-out from Schibsted Marketplaces. This DMA was finalised in January 2025. Schibsted Media's DMA process followed the principles used by Schibsted Marketplaces for our DMA, as well as those prescribed by ESRS. Schibsted Media has one material IRO connected to E4 Biodiversity and ecosystems.

Schibsted Media's DMA process made the following considerations:

• Impacts and dependencies: No stand-alone assessment was conducted to identify and assess impacts or dependencies on biodiversity and ecosystems, either at our own site locations or in the upstream and downstream value chain.
• Transition and physical risks and opportunities: Specific transition or physical risks and opportunities related to biodiversity and ecosystems were not separately assessed. These aspects were evaluated within the general context of stakeholder feedback, which did not prioritise biodiversity as a material topic.
• Systemic risks: Systemic risks relating to biodiversity and ecosystems were considered, but not deemed material during the stakeholder engagement process.
• Consultation with affected communities: No targeted consultations were conducted with affected communities specifically regarding biodiversity and ecosystems. Broader community engagement efforts did not highlight significant negative impacts or dependencies on ecosystems that would necessitate further action or mitigation.

While biodiversity was acknowledged in the stakeholder engagement and DMA process, it was not identified as a material priority for Schibsted Media's stakeholders and, therefore, did not warrant further dedicated analysis or specific measures yet. However, it was still deemed a material topic for Schibsted Media, given the impact of Schibsted Media's printing operations. Schibsted Media has no sites located in or near biodiversity-sensitive areas and as such has not deemed it necessary to implement any biodiversity mitigation measures.

E5 Resource use and circular economy

As part of the DMA process, all assets were screened on a general level to identify actual and potential impacts, risks and opportunities related to resource use and circular economy. However, no specific analysis of resource inflows, outflows or waste was conducted during 2024. The screening utilised no specific methodologies, assumptions or tools beyond those specified in the DMA process. Several IROs related to resource use and circular economy were identified and were deemed material during the DMA process. No consultations with affected communities related to this topic were conducted during 2024. Future assessments may include targeted analyses and stakeholder consultations where appropriate.

G1 Business conduct

The process to identify material impacts, risks and opportunities in relation to business conduct matters followed the overall approach for the DMA described above and considered locations (e.g., value chain location), activity, sector and the structure and type of transaction. This process included criteria for financial, reputational and regulatory impacts and each criterion was considered for all value chain steps to identify potentially material impacts, risks and opportunities. To assess materiality for business conduct-related topics, the same method was used as described in the overall DMA process.

Transition plan for climate change mitigation

Status of transition plan

In 2023, we introduced our Climate Roadmap to 2040, which outlined our climate ambitions and pinpointed critical areas for reducing our negative climate impact, as well as addressing associated risks and opportunities. This roadmap established specific actions and trajectories designed to support the transition to a low-carbon society. After the carve-out of Schibsted Media, however, the transition plan is no longer fully applicable and Schibsted Marketplaces therefore currently has no transition plan for climate change mitigation in accordance with ESRS requirements.

The absence of a transition plan stems from the carve-out of Schibsted Media in 2024, resulting in the establishment of Schibsted Marketplaces as an independent entity on 7 June 2024. Consequently, sustainability analyses have yet to be performed and strategies are to be developed. A transition plan for climate change will be developed during 2025–2026.

Previous climate ambitions (under review)

Following the carve-out of Schibsted Media and the changes this presented to Schibsted Marketplaces' strategic sustainability work, previous ambitions need to be reviewed and potentially revised. We have therefore not tracked these ambitions during 2024.

The previous ambitions were:

• GHG emission reductions throughout our operations and value chain by at least 55 per cent by 2030, from the 2018 base year
• At least 90 per cent reduction throughout our operations and value chain, net zero by 2040

Future targets

Updated Group targets for climate change mitigation and GHG emission reductions will be developed and set during 2025-2026. These targets will address our climate-related impacts and potential future risks and opportunities. The targets will be based on a new base year that will be calculated during 2025-2026, based on 2024 data.

Key decarbonization actions (2024)

Our business segment Delivery performed three actions during 2024 that focused on climate change mitigation:

1. Order and implement lightweight EV vehicles for last-mile distribution (called 'Paxsters')
2. Implement HVO routes for inbound logistics from Sweden
3. Plan new HVO routes within Norway

These actions were taken to reduce the use of fossil fuels in our Delivery services and connect to the decarbonisation levers of electrification and fuel switching. No dedicated resources (e.g., people or CapEx investments) have been defined to ensure implementation. Achieved and expected outcomes of GHG emissions reductions have not yet been defined for these actions and are therefore not reported on.

Policies related to climate change mitigation and adaptation

Schibsted Marketplaces has four policies in place to manage material impacts, risks and opportunities related to climate change mitigation and adaptation:

Group Environmental Policy

Connection to IROs:

• GHG emissions from own operations and value chain
• Energy consumption from own operations
• Promoting and selling travel services that have negative impact on GHG emissions

Scope:

• Value chain: Own operations, downstream and upstream business partners
• Geography: All geographies where Schibsted Marketplaces or our business partners operate

Governance:

• Most senior responsible level: Board of Directors and Executive Leadership Team
• The Head of Sustainability is responsible for monitoring compliance with this policy

Key content: The policy addresses climate change mitigation through requirements for renewable energy prioritisation, carbon footprint measurement and management, and responsible transportation options. It mandates that products should not use more resources or production energy than necessary, waste should be sent for recycling or to modern waste plants to minimise direct environmental impact, and encourages the development and adoption of environmentally friendly technologies.

Schibsted Marketplaces' Code of Conduct

Connection to IROs:

• GHG emissions from own operations and value chain

Scope:

• Value chain: Own operations
• Geography: All geographies where Schibsted Marketplaces operates

Governance:

• Owned by CEO
• Delegated to EVP People & Communications to ensure that all employees are aware of the policy
• Group Compliance Officer is responsible for establishing and implementing the Code of Conduct for the Group and shall prepare and facilitate for the establishing and implementation of overall governing documents and procedures to monitor and ensure compliance

Key content: The Code emphasises the importance of reducing negative impact on the environment and underscores the promotion of environmental responsibility across operations. It mandates the measurement and management of carbon footprint, the prioritisation of renewable energy and the adoption of environmentally responsible transportation options, ensuring that these principles are communicated and enacted throughout the organisation.

Business Partner Code of Conduct

Connection to IROs:

• GHG emissions from own operations and value chain

Scope:

• Value chain: Own operations, downstream and upstream business partners
• Geography: All geographies where Schibsted Marketplaces or our business partners operate

Governance:

• Owned by CFO
• Delegated to Head of Legal to follow up on compliance

Key content: The policy extends environmental commitments to the supply chain, requiring suppliers to adhere to practices that minimise their environmental impact. This includes the efficient use of energy, the reduction of emissions and the responsible management of waste and materials. By incorporating these requirements into the Business Partner Code of Conduct, Schibsted Marketplaces ensures that environmental standards are upheld not only within own operations but also among partners and suppliers.

Global Travel Policy

Connection to IROs:

• GHG emissions from own operations and value chain

Scope:

• Value chain: Own operations
• Geography: All geographies where Schibsted Marketplaces operates

Governance:

• Owned by EVP People & Communications
• Delegated to a dedicated Travel Manager to oversee implementation

Key content: The policy addresses climate impacts through managing travel-related emissions.

Note on transition plan: Following the carve-out of Schibsted Media in 2024, Schibsted Marketplaces currently has no transition plan for climate change mitigation in accordance with ESRS requirements. A transition plan for climate change will be developed during 2025–2026.

Actions and resources in relation to climate change policies

Context

In 2024, Schibsted Marketplaces underwent a major reorganisation, creating a need to update and review key sustainability plans and actions. During the autumn, new structures for reporting and internal control routines for climate and energy data were set up. This will enable further targeted actions to reduce climate impact and energy use.

Looking ahead, the company will develop a new climate transition plan for Schibsted Marketplaces and set targets for climate mitigation, focusing on GHG reductions.

Actions taken by Delivery segment

The Delivery business segment performed three actions during 2024 that focused on climate change mitigation:

1. Ordering and implementing lightweight EV vehicles for last-mile distribution (called 'Paxsters')

• Related IRO: GHG emissions from own operations and value chain (negative impact)
• Scope: Value chain: Own operations (Delivery); Geography: Norway
• Time horizon: 2024
• Expected outcome: Reduce the use of fossil fuels and tail-pipe emissions in Delivery services
• Decarbonisation lever: Electrification
• Resources allocated: No dedicated resources (e.g., people or CapEx investments) have been defined to ensure implementation
• Outcomes/KPIs: Achieved and expected outcomes of GHG emissions reductions have not yet been defined for this action and are therefore not reported on

2. Implementing HVO routes for inbound logistics from Sweden

• Scope: Value chain: Own operations (Delivery)
• Decarbonisation lever: Fuel switching
• Resources allocated: No dedicated resources defined
• Outcomes/KPIs: Not yet defined

3. Planning new HVO routes within Norway

• Scope: Value chain: Own operations (Delivery); Geography: Norway
• Decarbonisation lever: Fuel switching
• Resources allocated: No dedicated resources defined
• Outcomes/KPIs: Not yet defined

Future actions

Support the subsidiaries, such as Delivery, with implementing actions to reduce their GHG emissions.

Linkage to policies and targets

Information on how the actions contribute to the implementation and achievement of policy objectives and targets is not reported on, since Schibsted Marketplaces' sustainability targets are subject to upcoming revision.

The IRO 'Promoting and selling travel services that have negative impact on GHG emissions' did not have a related key action during 2024.

Targets related to climate change mitigation and adaptation

Status of Climate Targets

Due to the carve-out of Schibsted Media, Schibsted Marketplaces currently has no active Group-level GHG emission reduction targets in place.

Previous Climate Ambitions (Under Review)

Schibsted Marketplaces' previous climate ambitions aimed to:

• Double our improvements in energy efficiency (Scope 2) across all our business operations by 2030, from the 2018 base year
• Reduce GHG emissions throughout our operations and value chain by at least 55 per cent by 2030, from the 2018 base year
• At least 90 per cent reduction throughout our operations and value chain, net zero by 2040

Note: Following the carve-out of Schibsted Media and the changes this presented to Schibsted Marketplaces' strategic sustainability work, these ambitions need to be reviewed and potentially revised. These ambitions were not tracked during 2024.

Future Target Development

Updated Group targets for climate change mitigation and GHG emission reductions will be developed and set during 2025-2026. These targets will:

• Address climate-related impacts and potential future risks and opportunities
• Be based on a new base year that will be calculated during 2025-2026, based on 2024 data
• Be measurable, outcome-oriented and time-bound in accordance with ESRS

Performance Measurements (2024)

In place of targets, the company tracked five performance measurements related to climate change mitigation and adaptation during 2024. These relate to the Code of Conduct commitment: 'We are committed to minimising any adverse impact that our operations may have on the environment and we work to run our business as sustainably as possible.'

Notes:

• 'Emission-free routes' are defined as those routes within the delivery network that are operated using EV-only vehicles or by walking/cycling
• 'Fossil-free routes' is defined as those routes within the delivery network that are operated using HVO-only vehicles
• These performance measurements are not based on conclusive scientific evidence
• The company currently does not track the effectiveness of climate change mitigation policies with regard to material sustainability-related impact
• No progress data or actual values are reported for these performance measurements

Energy consumption and mix

Schibsted Marketplaces has operations in high climate impact sectors, specifically transportation within the Delivery segment. The data covers the period following the carve-out of Schibsted Media (discontinued operations reported separately).

Total energy consumption and mix (2024)

Energy intensity per net revenue (high climate impact sectors)

Net revenue reconciliation (2024)

Discontinued operations (Schibsted Media, first five months of 2024)

Total energy consumption and mix:

Energy intensity (Schibsted Media):

• Total energy consumption from high climate impact sectors per net revenue: 3.99 MWh/NOK m (2024)

Methodology notes

Energy data collection and verification:

• Fuel consumption (crude oil and petroleum products): Data from delivery services collected centrally in kilometres driven per fuel type. Vehicle-specific fuel intensity sourced from Norwegian Public Roads Administration using licence plate data. ~5% of routes lack licence plate data; median fuel consumption applied. Energy conversion uses DEFRA factors.

• Purchased electricity, heat, cooling: Data collected in kWh, converted to MWh. Conservative approach: energy reported as renewable only if supported by certificate of origin. Non-renewable electricity split between fossil and nuclear using country-specific residual mix (AIB 2023).

• District heating/cooling: Emission factors based on country-level data; specific district network factors not used.

Scope: Energy consumption covers own operations and includes the business segment Delivery (high climate impact sector). Data on purchased electricity collected centrally for larger office buildings; local collection for subsidiaries not in central system. Consolidated approach based on operational control.

Gross Scopes 1, 2, 3 and Total GHG emissions

Overview

Schibsted Marketplaces reports GHG emissions in accordance with ESRS E1-6, following the GHG Protocol Corporate Standard. The consolidation approach is based on operational control. Emissions from joint ventures and associates are calculated based on the extent of Schibsted Marketplaces' ownership. Emission factors are primarily sourced from DEFRA, aligned with IPCC Fifth Assessment Report (AR5) global warming potential (GWP) values.

Due to the carve-out of Schibsted Media in 2024, direct comparisons with previous years are not feasible. Schibsted Media is reported separately as discontinued operations for the five months of ownership (January–May 2024). Optional activities defined by the GHG Protocol have not been included in Scope 3 reporting.

Scope 1, 2 and 3 emissions – Schibsted Marketplaces

Table: Scope 1, 2 and 3 emissions and total GHG emissions (tCO2eq)

GHG intensity per net revenue

Table: GHG intensity based on net revenue (Total emissions, all scopes)

Table: Connectivity of GHG intensity with financial reporting

Discontinued operations (including Schibsted Media)

Schibsted Media's emissions are reported separately as discontinued operations for January–May 2024.

Table: Scope 1, 2 and 3 emissions – Discontinued operations

Table: GHG intensity – Discontinued operations

Table: Connectivity with financial reporting – Discontinued operations

Biogenic CO2 emissions

No biogenic CO2 emissions are reported separately for 2024.

Share of primary data

The share of primary data used in Scope 3 based on the volume of emissions is 16% for Schibsted Marketplaces and 40% for Schibsted Media. The spend-based method is not included as primary data. Schibsted Marketplaces shows lower primary data percentage mainly due to the categorisation of emissions; Schibsted Media includes both Print and Delivery operations in Scope 3, accounting for primary data related to these activities. Primary sources for estimations where primary data is not available include consultants (Category 1) and investments (Category 15).

Methodology notes

Scope 1: Emissions from company-owned, leased and controlled vehicles. Data collected on vehicle type, distance driven and fuel type from Delivery services (centrally) and from other companies (locally). Distance-based method used with emission factors from Norwegian Public Roads Administration (licence plate data) or DEFRA where unavailable.

Scope 2: Office electricity calculated using location-based and market-based methods. Market-based approach uses country-specific residual mixes (AIB 2023) for electricity without certificates of origin. Location-based uses production mixes. Electric vehicles and district heating/cooling also included.

Scope 3:

• Category 1 (Purchased goods and services): Includes SaaS and cloud computing (using provider data, electricity-based or spend-based methods) and consultants (estimated using Schibsted 2023 GHG intensity per employee).
• Category 2 (Capital goods): User devices calculated using average-product method with supplier data or embodied carbon report.
• Category 3 (Fuel and energy-related activities): Upstream emissions calculated using DEFRA UK-based factors.
• Category 5 (Waste): Average-data method; waste by treatment type or assumptions based on Swedish waste treatment data (Avfall Sverige 2023). If no data, 200 kg/employee/year assumption used.
• Category 6 (Business travel): Distance-based method for air, rail, bus, taxi and car rental using DEFRA factors. Hotel nights omitted (optional).
• Category 7 (Employee commuting): Average-data method using Stockholm commuting patterns (15 km/day, survey data on mode split). Assumes commuting all workdays. Remote working omitted (optional).
• Category 15 (Investments): Emissions estimated based on number of employees in joint ventures and associates, using Schibsted 2023 market-based GHG intensity per employee and ownership share.

Categories 4, 8, 9–14 are not in scope.

Contextual information

The large increase in Scope 1 emissions stems from Delivery emissions being moved from Scope 3 Category 9 to Scope 1. The decrease in market-based Scope 2 emissions primarily results from discontinued operations being presented separately. Total Scope 3 emissions are relatively similar to 2023, as Categories 9 and 11 were removed and Categories 3, 5, 7 and 15 were added. Future reporting will enable comparative quantitative data and recalculation methods where needed.

Measurement uncertainties are significant in Scope 3 Categories 1, 5, 7 and 15 due to high use of secondary data sources and estimations. Metrics have been prepared using the best available data, ensuring satisfactory accuracy for sector average value chain metrics. Schibsted Marketplaces will strive to improve data accuracy and increase the level of primary data in future reporting.

Due to the sale of Schibsted Media in 2024, biodiversity and ecosystems was only material for the media operations. This section covers information pertaining to Schibsted Media only.

Schibsted Media's main impact on biodiversity and ecosystems is resource consumption for paper production, both virgin pulp and recycled paper. The company's policy framework addresses this by requiring that all newsprint is sourced in a responsible way and to take part in the development of the industry by addressing challenges related to recycling. The company follows the Nordic Swan certification scheme and PEFC (Programme for the Endorsement of Forest Certification) standards for newsprint sourcing.

Schibsted Media's actions and resources related to biodiversity and ecosystems focus on responsible sourcing of newsprint. The company requires suppliers to provide certification that newsprint meets Nordic Swan and PEFC standards. This ensures that paper products are sourced from responsibly managed forests that maintain biodiversity and ecosystem services.

Schibsted Media had established targets related to maintaining certification standards for newsprint sourcing to ensure continued protection of biodiversity and ecosystems in forest management practices.

Policies related to resource use and circular economy

Schibsted Marketplaces identifies resource use and circular economy as a material topic. The main policy in place to manage material impacts, risks and opportunities related to resource use and circular economy is the Group Environmental Policy. In addition, Delivery's Supplier Code of Conduct addresses waste in the Delivery value chain.

Schibsted Marketplaces' Code of Conduct

Connection to material impacts, risks and opportunities:

• Positive impact: By driving sustainability in the recommerce market, the company contributes to enabling a more circular economy
• Opportunity: Expansions, investments and partnerships within the area of circular economy can increase revenues
• Negative impacts:
  • Waste generated in own operations and delivery services
  • Facilitation of second-hand consumption might lead to increased linear consumption, which increases natural resource and energy use
  • By facilitating and upholding trade of fossil-fuel vehicles in the traditional private car ownership models, the company contributes to prolonging their lifetime

Scope:

• Value chain: Own operations
• Geography: All geographies where Schibsted Marketplaces operates

Governance:

• Owned by CEO
• Delegated to EVP People & Communications to ensure all employees are aware of the policy

Delivery's Supplier Code of Conduct

Addresses the topic of waste in the Delivery value chain, which relates to the material impact, risk or opportunity of waste generated in own operations and delivery services.

Note: The excerpts reference a "Group Environmental Policy" as the main policy but do not provide detailed information about this policy in the table.

Actions and resources related to circular economy

During 2024, Schibsted Marketplaces conducted four key actions related to resource use and circular economy. These actions were taken within business segments Recommerce and Mobility.

For all actions listed: No identified significant CapEx or OpEx – except for the action 'Launch of transactional marketplace on Tori.fi'. However, for confidentiality reasons, the amount invested for this particular action is not disclosed.

IROs without related key actions in 2024

• Waste generated in own operations and delivery services
• Our display advertising products can enable linear consumption, which would increase natural resource and energy use
• By facilitating and upholding trade of fossil-fuel vehicles in the traditional private car ownership models, we contribute to prolonging their lifetime and hindering the transition to low-emission mobility
• By integrating a sustainability perspective in our Real Estate vertical, we can improve utilisation of existing properties and contribute to environmental sustainability

Recommerce segment actions

Two key actions focused on promoting the trade of second-hand goods:

1. Launch of Transactional marketplace on Tori.fi

• Related IRO: Positive impact: By driving sustainability in the recommerce market, we contribute to enabling a more circular economy
• Future actions: Launch transactional marketplace on dba.dk and blocket.se
• Expected outcome: Consolidated platforms with improved ability to drive increased numbers of transactions
• Scope: Value chain - Downstream (consumers)
• Geography: Finland
• Time horizon: 2024
• Resources: CapEx/OpEx not disclosed (confidentiality reasons)

2. Second-Hand Effect Report

Released the 'Second-Hand Effect Report', which investigates the climate impact and benefits of second-hand transactions across Schibsted Marketplaces' platforms.

Mobility segment actions

The document references actions within the Mobility segment but detailed information is not provided in the excerpts.

Targets related to circular economy

Schibsted Marketplaces explicitly states that it does not have sustainability targets related to resource use and circular economy as of 2024. The company has redefined its targets as performance measurements following the carve-out of Schibsted Media.

Key disclosure statements:

• "Schibsted Marketplaces' sustainability targets will be revised during 2025-2026, following the carve-out of Schibsted Media."
• "The targets presented in the 2023 sustainability statement have been redefined as performance measurements."
• "Schibsted Marketplaces currently has no overarching performance measurements covering waste, as this was only recently identified as material. The need for performance measurements or targets focusing on this topic will be reviewed in 2025-2026."

Performance measurements (not targets):

The company had five performance measurements in 2024 related to resource use and circular economy, primarily focused on:

• Increasing the number of transactions of second-hand goods
• Strengthening the preference for buying used items
• External publications/media releases to showcase active voice in sustainable vehicle trade

These performance measurements:

• Are not required by law
• Are not based on conclusive scientific evidence
• Do not include quantified targets, baseline years, or target years
• Relate to policy objectives in the Code of Conduct: "We empower circular and sustainable consumption through our products and services"

The company does not disclose any quantified targets with target values, target years, or baseline years for E5-3.

Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

Schibsted has applied the phase-in exemption for disclosure requirement E5-6 (Anticipated financial effects from material resource use and circular economy-related risks and opportunities). This disclosure requirement is thereby not included in this year's sustainability statement.

Waste

Total waste generated

For the reporting period 2024, Schibsted Marketplaces generated a total of 2,160 tonnes of waste from own operations (including offices and delivery operations). For discontinued operations including Schibsted Media (first five months of 2024), total waste generated was 1,071 tonnes.

Waste diverted from disposal - Schibsted Marketplaces

Waste directed to disposal - Schibsted Marketplaces

Non-recycled waste - Schibsted Marketplaces

Waste composition

Schibsted Marketplaces' waste is composed of: office waste, packaging waste and some electronic waste. Materials present include food waste, recyclable cans, recyclable plastic and glass bottles, paper waste, recyclable cardboard and mixed combustible waste.

Hazardous waste: Total hazardous waste for Schibsted Marketplaces was 1 metric tonne. Types include mixed electronic waste and batteries. Radioactive waste was 0 metric tonnes.

Waste management methodology

To calculate waste data, local data was collected from subsidiaries, covering offices and Delivery services (including packaging material).

Data collection approach:

• Where exemplary data was available: subsidiaries provided total waste in metric tonnes plus split by recovery/treatment type
• Where only total waste data available: split of recovery/treatment assumed based on Swedish waste treatment report (2023)
• Where no data available: estimates made based on employee headcount, assuming 200 kg waste per employee per year, using Swedish waste treatment split

Data sources:

• Emission factors for waste treatment from DEFRA (2023)
• Waste treatment split assumptions from Avfall Sverige report (2023)

Measurement uncertainties: Lack of available data from waste treatment providers contributes to large measurement uncertainties for office-generated waste. The metrics have not been validated by an external body.

Discontinued operations (Schibsted Media, Jan-May 2024)

Waste diverted from disposal:

Waste directed to disposal:

Non-recycled waste: 161 metric tonnes total (15% of total waste)

Hazardous waste: 7 metric tonnes. Radioactive waste: 0 metric tonnes.

Policies related to waste

Group Environmental Policy: States that Schibsted Marketplaces shall use products made from renewable raw materials or recycled materials where possible, limit packaging use, and recycle/reuse materials. Waste produced will be sent for recycling or modern waste plants to minimise environmental impact.

Delivery's Supplier Code of Conduct: Requires waste material to be reused and recycled wherever possible and minimises air in packaging while ensuring use of environmentally friendly packaging.

Code of Conduct: Adopts precautionary approach to materials and processes, runs initiatives promoting environmental responsibility, and encourages development of environmentally friendly technologies.

Policies related to own workforce

Schibsted Marketplaces has identified the following policies to manage material impacts, risks and opportunities related to own workforce. These policies do not emphasize specific groups within the workforce, but cover all employees. The geographic scope covers all geographies where Schibsted Marketplaces has employees, totaling ten countries.

Code of Conduct

Scope:

• Value chain: Own operations
• Geography: All geographies where Schibsted Marketplaces operates

Governance:

• Owned by CEO
• Delegated to EVP People & Communications to ensure all employees are aware of the policy
• General managers of each company are responsible for supporting and monitoring rollout and implementation
• Group Compliance Officer is responsible for establishing and implementing the Code of Conduct

Key content:

• Commits to operating lawfully, with high degree of integrity and transparency
• Outlines ethical norms, responsibilities and expectations for all employees, leaders and Board members
• Covers forced labour (as part of labour rights), child labour and trafficking (though trafficking not explicitly addressed)
• States: "We strive to foster an environment in which our employees feel respected, valued and empowered"
• Emphasizes importance of reducing negative environmental impact
• Mandates employees to read, understand and implement the principles, undergo relevant training, and report suspected violations
• Violations may result in liability for individuals and the company

Link to international standards:

• Based on principles of the UN Global Compact (Ten Principles)
• Aligns with UN Guiding Principles on Business and Human Rights
• Adheres to ILO Conventions (all conventions in general, no specific conventions mentioned)
• Guided by OECD Guidelines for Multinational Enterprises, including human rights due diligence

Public availability:

• Available on Schibsted Marketplaces' website (not specified for Code of Conduct specifically, but noted for Group Environmental Policy)

Monitoring:

• Employees encouraged to raise concerns via designated reporting channels including Speak Up whistleblower channel
• Processes based on reactive action to issues and proactive action from EVP People & Communications team to ensure all employees and managers receive adequate training
• Compliance monitored by Group Compliance Officer
• Last revised in 2022

Discrimination, Bullying and Harassment Policy

Scope:

• Value chain: Own operations
• Geography: All geographies where Schibsted Marketplaces operates

Governance:

• Owned by EVP People & Communications

Key content:

• Commits to fostering a professional and inclusive workplace where diversity is embraced
• Addresses risks such as employee ill-health and exclusion due to inappropriate behaviours
• Requires managers to act immediately upon witnessing or being informed of issues
• Employees encouraged to report concerns to trusted individuals or through anonymous Speak Up channel
• Addresses discrimination grounds: racial and ethnic origin, skin colour, sex, sexual orientation, gender identity, disability, age, religion, political opinion, national extraction and social origin

Monitoring:

• People team investigates reports
• Covers all subsidiaries

Diversity and Inclusion Policy

Scope:

• Value chain: Own operations
• Geography: All geographies where Schibsted Marketplaces operates

Governance:

• Owned by CEO
• Delegated to EVP People & Communications to ensure all employees are aware of the policy
• Implementation is responsibility of top management with necessary resource allocation
• Leaders throughout company responsible for ensuring inclusive organizational culture
• Most senior level accountable is Executive Leadership Team

Key content:

• Defines diversity as unique differences and similarities among individuals, including ethnicity, gender, age, functional capacity, sexual orientation, culture, religion, background, language and cognitive abilities
• Defines inclusion as cultivating corporate culture where all individuals can be themselves, feel belonging and fully participate
• Addresses risks such as discrimination and bias
• Employees responsible for creating and maintaining environment of mutual respect
• Applies to all activities within Schibsted Marketplaces, encompassing employees across all subsidiaries regardless of role or location

Monitoring:

• Processes include encouraging employees to report non-compliance through various channels

Recruitment Policy

Scope:

• Value chain: Own operations
• Geography: All geographies where Schibsted Marketplaces operates

Governance:

• Owned by EVP People & Communications

Key content:

• Outlines commitment to attracting and hiring the right people for the right positions
• Emphasizes transparency and unbiased process aligned with values and goals
• Emphasizes diversity, inclusion and fairness
• Fosters internal mobility
• Strengthens Schibsted Marketplaces' reputation as attractive employer

Global Travel Policy

Scope:

• Value chain: Own operations
• Geography: All geographies where Schibsted Marketplaces operates

Governance:

• Owned by EVP People & Communications
• Delegated to dedicated Travel Manager to oversee implementation and monitor adherence

Key content:

• Highlights preference for low-emission travel options
• Advocates for safe, smart and sustainable travel
• Emphasizes environmental responsibility and employee well-being
• Digital-first approach encourages reduced physical travel
• Promotes responsible travel choices (economy class within Europe, sustainable hotels and transport modes)

Group Environmental Policy

Scope:

• Value chain: Own operations
• Geography: All geographies where Schibsted Marketplaces operates

Governance:

• Board of Directors and Executive Leadership Team have duty and responsibility to ensure policy's content, intentions and directives are communicated, understood and acted upon
• Head of Sustainability responsible for monitoring compliance

Key content:

• Based on principles of UN Global Compact
• Initiatives to promote greater environmental responsibility, use of environmentally friendly technologies, and application of precautionary approach
• Addresses climate change mitigation by prioritizing reduction of energy consumption and GHG emissions
• Promotes use of renewable and recycled materials
• Minimizes waste through effective recycling and reuse strategies

Link to international standards:

• Based on principles of UN Global Compact

Public availability:

• Publicly available on Schibsted Marketplaces' website

Policy commitments on human rights and labour rights:

The Code of Conduct commits to respect for human rights and labour rights, stating: "We work actively to integrate respect for human rights and labour rights into our practices and business activities." The company commits to:

• Providing all employees full freedom of association
• Ensuring collective bargaining agreements or working environment committees in all operations
• Preventing discrimination against employees
• Adhering to UN Global Compact, UN Guiding Principles on Business and Human Rights, ILO Conventions, and OECD Guidelines

The policies address the following ILO fundamental conventions topics (though specific convention numbers are not always cited):

• Freedom of association and collective bargaining
• Elimination of forced labour
• Abolition of child labour
• Elimination of discrimination in employment and occupation

While the policies do not put emphasis on specific groups within the workforce, several internal and external events were organized in 2024 to advance diversity and inclusion in general.

Taking action on material impacts on own workforce

Overview

Throughout 2024, Schibsted Marketplaces mainly focused on the reorganisation and the creation of a secure and supportive environment for employees during this transition. To take action on material IROs related to our own workforce, Schibsted Marketplaces worked along two main axes: the People team and through all leadership layers. While the People function can identify issues and implement systemic solutions and process, leaders at every level play an important role in taking action on and monitoring the effectiveness of such actions to minimise actual and potential negative impacts.

Resources allocated: The main resources allocated are personnel from our People & Communications function, consisting of circa 100 FTEs. No significant CapEx or OpEx were identified in relation to any of these actions.

Key Actions 2024

1. Launch of Diversity, Inclusion and Belonging (DIB) playbook and crash course

• Related IROs:
  • Negative impact: Potential discrimination and lack of opportunities in the workplace based on gender, age and skin colour
  • Opportunity: A clear purpose, culture and performance on sustainability will increase the likelihood of attracting and retaining talent
• Scope: All employees in own workforce
• Time horizon: 2024
• Expected outcome: Improved awareness on DIB topics
• Future actions: Continue to increase awareness of the DIB playbook and increase course participation grade
• Results: We launched the Diversity, Inclusion and Belonging (DIB) playbook and a related training programme with 1,587 participants. We track progress using the associated performance measurements.

2. Implementation of an updated Health, Security and Environment (HSE) system available to all managers

• Related IROs:
  • Risk: Poor work-life balance and unclear expectations on employees may lead to employee ill-health, resulting in sick leave, increased employee turnover and financial loss
  • Negative impact: Potential poor working conditions for employees
• Scope: All employees in own workforce
• Time horizon: 2025
• Expected outcome: Improved awareness of HSE topics, reducing risk of workplace-related injuries or accidents (physical or mental)
• Future actions: Continue implementation of the updated HSE system

3. Courses on AI prompting implemented

• Related IROs: Negative impact: Potential discrimination and lack of opportunities in the workplace based on gender, age and skin colour
• Scope: All employees in own workforce with a need for ChatGPT or daily work
• Time horizon: 2025
• Expected outcome: Improved upskilling of employees, which could boost their career growth and skills development
• Future actions: Implement increasingly specific courses related to AI to adapt to needs of specific functions/teams
• Links to training: Our commitment to employee development saw the launch of an extensive AI training programme, equipping teams with the skills to harness these tools effectively. The Executive Leadership team was in 2024 measured on AI training completion rates, ensuring accountability and alignment in driving AI adoption.

Actions Related to Specific IROs

Actual negative impact: Reorganisation and cost reduction programme in 2024

• Impact: Reorganisation and cost reduction programme in 2024 might have negative impact on employees and lead to employee ill-health
• Remediation actions: Job counselling, coaching, intra-company placements and severance packages offered to affected individuals
• Monitoring: Progress tracked by regularly including the reorganisation as an agenda item in the People management team meetings, as well as through three employee engagement surveys conducted during the year
• Future actions: Share insights from the reorganisation effort with employees via a retrospective on the reorganisation process. Onboard temporary consultants to handle workload peaks

Risk: Poor work-life balance and unclear expectations

• Actions: Working with specific areas of the organisation where the risk level is higher (e.g., the Finance and Foundations functions). Providing training sessions to all managers to spot and address work-life balance issues. Hiring consultants on a temporary basis to reduce peak workloads and merging/moving teams to improve collaboration
• Future actions: Focus in 2025 will be placed on creating one unified culture for the new Schibsted Marketplaces

Opportunity: Attracting and retaining talent

• Actions planned: Actions to build an engaging vision and employee value proposition for Schibsted Marketplaces are planned for 2025

Approach to Assessment

To assess what action is needed and appropriate in response to a particular actual or potential negative impact on our own workforce, we leverage the engagement channels described in section S1-2. In connection with the reorganisation process and its actual negative impact on employees, the employee engagement survey as well as direct manager feedback were reviewed in regular People team meetings and discussed with the project steering committee (consisting mainly of members of the Executive Leadership Team, including the CEO). This resulted in several adjustments to the process, content and communication of the reorganisation effort to reduce negative impacts on employees.

Enterprise Risk Management

In 2021, we implemented a Group-wide enterprise risk management (ERM) process which also covers material risks related to our workforce. However, due to the carve-out of Schibsted Media, this process was not performed to its full extent during 2024. An updated ERM process adapted to Schibsted Marketplaces' scope is planned for implementation in 2025.

Effectiveness Tracking

To track the effectiveness of the above actions, the same engagement channels as described in section S1-2 – Processes for engaging with own workforce and workers' representatives about impacts are used. Progress is monitored through:

• Employee engagement survey (sent out in January 2024) with scores of 85/100 on 'I feel safe to address bullying, harassment and discrimination' and 78/100 on 'I know the routines for alerting about bullying, harassment and discrimination'
• Regular People management team meetings
• Feedback from direct managers

Targets related to own workforce

Schibsted Marketplaces' sustainability targets will be revised during 2025-2026, following the carve-out of Schibsted Media. The targets presented in the 2023 sustainability statement have been redefined as performance measurements.

Performance Measurements for 2024

For the year 2024, Schibsted Marketplaces had four performance measurements related to own workforce. These were set during the annual target-setting cycle and approved by the Executive Leadership Team. The focus was to enhance the well-being of employees.

Relationship to policy objectives: These performance measurements relate to the Code of Conduct: 'We strive to foster an environment in which our employees feel respected, valued and empowered'

Period: These performance measurements were valid for 2024

Note: The excerpt indicates four performance measurements exist, but only two are shown in the provided text. No quantified target values, baseline years, or target years are disclosed.

Characteristics of the undertaking's employees

Total headcount and FTE

Total employees (headcount): 3,884
Total employees (FTE): 3,387

Headcount by gender

Headcount by country

Countries with 50 or more employees representing at least 10% of total employees:

Headcount by contract type and gender (FTE)

Employee turnover

Total number of employees who left: 1,839
Employee turnover rate: 47%

Note: The turnover rate includes employees within Delivery, which has a significantly higher turnover rate. Excluding Delivery, the turnover rate was 21%.

Discontinued operations (Schibsted Media, January-May 2024)

Headcount by gender (discontinued operations):

Headcount by country (discontinued operations):

Headcount by contract type (discontinued operations, FTE):

Methodology notes

• Headcount: Average total number of employees for each month in the reporting period
• FTE: Average of scheduled work hours divided by default work hours
• Data covers own operations across all geographies where Schibsted Marketplaces operates
• Scope includes permanent, temporary and non-guaranteed hours employees
• Discontinued operations reflect Schibsted Media ownership period (January-May 2024)
• Data accounts for movements between Schibsted Marketplaces and Schibsted Media following carve-out

Collective bargaining coverage and social dialogue

Overall coverage

Of our total employees, 66 per cent are covered by collective bargaining agreements. As stipulated in our Code of Conduct, Schibsted Marketplaces' employees have full freedom of association and may organise as they choose. Collective bargaining agreements or working environment committees are in place in all operations to ensure decent working conditions and to prevent discrimination against employees.

Collective bargaining agreements by geography

Schibsted Marketplaces has eight collective bargaining agreements within the EEA. We have no significant employment outside the EEA and therefore no collective bargaining agreements outside the EEA.

Coverage by country (EEA)

S1 - Table 11: Coverage rate of employees with collective bargaining for Schibsted Marketplaces

Discontinued operations (including Schibsted Media)

S1 – Table 12: Coverage rate of employees with collective bargaining for discontinued operations, including Schibsted Media

Social dialogue arrangements

Our European Works Council (EWC) meets biannually to conduct dialogue between employees and Schibsted Marketplaces' Executive Leadership Team. Two Group employee representatives are also elected to act on behalf of all employees, both unionised and non-unionised. They protect all employees' interests in matters that are dealt with at Group level. These representatives serve as discussion partners for management to assure the quality of decisions and processes.

Methodology

Data on collective bargaining coverage was collected from each company within the scope of reporting. All data from all companies was collected via forms. The data reflects the situation for 2024 as an average. The companies reported average headcount for each existing agreement. One person can be covered by more than one agreement, but in that case, each company will define which contract overrides the others for each individual.

Diversity metrics

Gender distribution at top management level

Our top management is composed of 33 per cent women (a total of 3 women and 6 men). The top management is defined as the members of the Executive Leadership Team.

Distribution of employees by age group

S1 – Table 13: Age distribution of employees for Schibsted Marketplaces

Note: For percentage of employees, headcount numbers are used in this table

S1 – Table 14: Age distribution of employees for discontinued operations, including Schibsted Media

Note: For percentage of employees, headcount numbers are used in this table

Adequate wages

All of Schibsted Marketplaces' employees are paid an adequate wage, in line with applicable benchmarks. This applies to both Schibsted Marketplaces as well as discontinued operations.

Coverage

100% of own workforce.

Data collection methodology

Data for reporting on adequate wages was collected separately from other people-related data, from each company within the scope of reporting.

For entities using Workday HR platform: Data was collected directly from the system.

For companies not using Workday: Reported directly to the central Compensation and Benefits team, who verified their data.

For Delivery operations employees: Salary data not available in Workday. Compensation is strictly governed by collective agreements. The salary level mandated by the applicable collective agreement was used in the calculation.

Snapshot date

• Workday data: snapshot of wages on 31 December 2024
• Other reporting companies: snapshot on 31 December 2024, plus wages for employees who left during the year (where available)
• Discontinued operations data (Schibsted Media): represents 31 December 2024, assumed representative for January–May 2024

Components included

Wage-related data includes, where applicable:

• Base salary
• Commission-based pay
• Short-term incentive schemes
• Long-term incentive schemes

No specific living wage benchmark is disclosed. The disclosure states compliance with "applicable benchmarks" and notes that Delivery operations compensation is "strictly governed by collective agreements."

Social protection

Schibsted Marketplaces has used the phase-in option for ESRS S1-11 (Social protection). This disclosure requirement is therefore not included in this year's statement.

Pension information disclosed

While S1-11 is omitted under phase-in, the company provides the following pension-related information in Note 27:

Defined benefit plans: The Group has funded defined benefit plans in Norway covering approximately 80 working members as at 31 December 2024 (524 in 2023). Benefits are mainly dependent upon number of years of employment, salary level at retirement age and the amount of benefits from the National Insurance pension. The majority of funded defined benefit plans comprise retirement pension for life from 67 years, with full retirement pension amounting to approximately 66% of the basis (limited to 12G) including assumed pension from the National Insurance pension.

Plan coverage: The plans include disability pension. In addition to funded defined benefit plans, Norwegian companies have unfunded defined benefit obligations related to:

• Disability pensions (if not covered by other pension plans or insurances)
• Supplementary pensions for salaries above 12G
• Agreement-based pension (AFP)
• Early retirement pensions

Defined contribution plans: Companies outside Norway have pension plans, mainly defined contribution plans, in accordance with local practice and local legislation.

Multi-employer plans: The Group has certain pension schemes in Norway and Sweden established as multi-employer plans. These are defined benefit plans but are accounted for as defined contribution plans due to lack of necessary information.

Pension expenses (NOK million):

Persons with disabilities

S1-12 omitted due to phase-in criteria.

Schibsted Marketplaces has used the phase-in option for S1-12 (Persons with disabilities). This disclosure is therefore not included in this year's statement.

Training and skills development metrics

S1-13 (Training and skills development metrics) has been omitted due to phase-in criteria and is therefore not included in the 2024 sustainability statement.

Schibsted Marketplaces has elected to use the phase-in option available under CSRD for this disclosure requirement, alongside S1-7 (Characteristics of non-employee workers), S1-11 (Social protection), S1-12 (Persons with disabilities), and S1-15 (Work-life balance metrics).

Performance reviews

While comprehensive S1-13 metrics are not disclosed, the company mentions having "a system for conducting development/performance reviews with each employee during the year" as part of its engagement processes.

A note in the reporting states:

Note 3: The performance review is a discussion between the employee and its manager. In the review, past performance and future growth opportunities are discussed.

However, no quantitative data on the percentage of employees receiving performance reviews (overall or by gender/category) is provided in the 2024 statement.

Health and safety metrics

Coverage of health and safety management system

100% of Schibsted Marketplaces' own workforce is covered by a health and safety management system. All companies within the scope of reporting have a health and safety management system to register and follow up health and safety metrics.

Fatalities

During 2024, Schibsted Marketplaces had zero (0) fatalities as a result of work-related injuries or work-related ill-health.

Work-related accidents

Methodology note

Data for work-related incidents and fatalities as a result of work-related injuries or work-related ill-health among employees was collected by email from each Human Resources Business Partner (HRBP) for each company within the scope of reporting.

Phase-in

Schibsted Marketplaces is phasing in parts of S1-14 (Health and safety metrics) in this year's report.

Work-life balance metrics

Disclosure status

ESRS S1-15 (Work-life balance metrics) has been omitted due to phase-in criteria for the 2024 reporting period.

As stated in the ESRS content index:

"S1-15 Work-life balance metrics - S1-15 omitted due to phase-in criteria."

Context on work-life balance

While quantitative metrics are not disclosed, the report provides qualitative information on work-life balance:

• Work-life balance is identified as a material risk: "Poor work-life balance and unclear expectations on employees may lead to employee ill-health, resulting in sick leave, increased employee turnover and financial loss"

• Several work-life balance arrangements are mentioned as being in place, though varying across countries of operation:

  • Paid vacation
  • Parental leave
  • Flexible working hours
  • Flexible workplace schemes
  • Fitness activities and wellness grants

• The Travel Policy is designed to "enhance work-life balance" by encouraging digital meetings and reduced physical travel

• Actions planned for 2025 include working with specific organizational areas where work-life balance risk is higher (e.g., Finance and Foundations functions) and providing training to managers

Expected future disclosure

Schibsted Marketplaces indicates that metrics related to family-related leave entitlement, uptake rates by gender, and return-to-work rates will be disclosed in future reporting periods once the phase-in period concludes.

Compensation metrics

Pay gap

The gender pay gap as a percentage (unadjusted headline figure) for Schibsted Marketplaces is 9.20% for 2024.

For discontinued operations, including Schibsted Media, the gender pay gap is 6.37% for 2024.

Gender pay gap metrics:

Remuneration ratio

The annual total remuneration ratio (highest-paid individual to median employee) for Schibsted Marketplaces is 12.40 for 2024.

For discontinued operations, including Schibsted Media, the total remuneration ratio is 7.88 for 2024.

Total remuneration ratio metrics:

Methodology

The methodology used to collect, compile and analyse remuneration data was the same as that used for adequate wages reporting. For entities using the HR platform Workday, data was collected from the system. Companies not using Workday reported directly to the central Compensation and Benefits team, who verified their data. For Delivery operations employees, whose salary data is not available in Workday, compensation governed by collective agreements was used. The data from Workday is a snapshot of wages on 31 December 2024, while data for other reporting companies is a snapshot of wages on 31 December 2024 as well as wages for any employees who left during the year, where available.

Wage-related data includes, where applicable, base salary, commission-based pay, short-term incentive schemes and long-term incentive schemes. For discontinued operations (Schibsted Media), data was collected using the same procedure with all data available from Workday.

Gender pay gap formula:

(Average pay level male - Average pay level female) / (Average pay level male) × 100

Where 'average pay level male' equals the average hourly gross pay level of male employees and 'average pay level female' equals the average gross hourly pay level of female employees.

Total remuneration ratio formula:

Annual total remuneration for the undertaking's highest paid individual / Median employee annual total remuneration (excluding the highest-paid individual)

Important contextual note: Schibsted Marketplaces largely sets salaries based on individual circumstances, role and applicable salary benchmarks in the relevant market and industry. Consequently, the gender pay gap and total remuneration ratio are influenced by shifts in the gender and role distribution across different countries. As a result, summarising pay disparities into a single metric may not fully capture underlying structural factors or differences in workforce composition.

For discontinued operations, while data represents the situation at 31 December 2024, it is assumed this is representative for the period January–May 2024.

Incidents, complaints and severe human rights impacts

During 2024, Schibsted Marketplaces had a total number of 18 reported incidents of discrimination, including harassment. We had a total number of 13 complaints filed through our channels for people in the workforce to raise concerns. We paid no fines, penalties or compensation for damages as a result of the incidents and complaints disclosed above. We have not identified any cases of severe human rights incidents in our own workforce during 2024.

Methodology

Data for incidents, complaints and severe human rights impact from each company within the scope of reporting was collected from all companies via forms. The data was complemented with input from the Group Compliance Officer on cases registered through the Speak Up whistleblowing channel.

Summary of metrics

Policies related to value chain workers

Schibsted Marketplaces has adopted two policies to manage material impacts on value chain workers: the Code of Conduct and the Business Partner Code of Conduct. Both policies cover all value chain workers rather than focusing on specific groups.

Code of Conduct

Scope: All value chain workers, own operations, all geographies where Schibsted Marketplaces operates

Governance: Owned by CEO, delegated to EVP People & Communications to ensure all employees are aware of the policy. The Group Compliance Officer is responsible for establishing and implementing the Code of Conduct.

Key content and principles:

• Commitment to respect human rights and labour rights in own operations and those of suppliers and business partners
• Expectations that partners, contractors and other hired personnel working in the value chain meet Schibsted Marketplaces' standards and respect values
• Covers forced labour (as part of labour rights), child labour and trafficking (the latter not explicitly addressed)
• Principles related to human rights, labour rights, anti-corruption and environment

Link to international standards:

• Aligned with the UN Guiding Principles on Business and Human Rights
• Aligned with ILO Conventions

Monitoring: The Group Compliance Officer strengthens the process to monitor compliance with the frameworks connected to the Code, including checking that updates adhere to mentioned standards and following up with each company on their approach and processes to implement the Code.

Related IROs addressed:

• Poor working conditions in the distribution value chain, such as low pay, injury risks and night shifts, might negatively affect workers
• Potential negative impact on human rights in downstream value chain related to investments

Business Partner Code of Conduct

Scope: Own operations, downstream and upstream business partners, all geographies where Schibsted Marketplaces or business partners operate

Governance: Owned by CFO, delegated to Head of Legal to follow up on compliance

Key content and principles:

• Ensures all business partners, including suppliers, are aware of and uphold Schibsted Marketplaces' expectations on human rights, labour rights, environmental protection and combating corruption
• Business partners shall respect human rights and minimum social safeguards as defined in international conventions on human rights and working conditions

Related IROs addressed:

• Poor working conditions in the distribution value chain, such as low pay, injury risks and night shifts, might negatively affect workers
• Potential negative impact on human rights in downstream value chain related to investments

Taking action on material impacts on value chain workers

During 2024, Schibsted Marketplaces took action to address material impacts on value chain workers. The actions are presented in the table below.

Company-wide actions

Creation of the Business Partner Code of Conduct (2024)

• Scope: All of Schibsted Marketplaces' business partners, all geographies
• Time horizon: 2024 (implementation ongoing)
• Related impacts and risks:
  • Potential negative impact on human rights in downstream value chain related to investments
  • Poor working conditions in the distribution value chain (low pay, injury risks, night shifts)
• Expected outcome: Improved assurance of partners' adherence to the standards set out in the Business Partner Code of Conduct
• Future planned actions: Roll out the Business Partner Code of Conduct and monitor its implementation
• Resources allocated: No identified significant CapEx, OpEx or dedicated resources disclosed

Delivery segment specific actions

Remediation of contractual deviations with subcontractors (2023-2024)

In 2023, deviations from contractual agreements with subcontractors were identified in the Delivery segment. Existing routines and internal controls were not fully followed, resulting in contractors being subject to indecent working conditions.

Key remedial actions taken during 2024:

• Transition to new operational model: Employing drivers directly instead of using subcontractors
• Enhanced monitoring: Daily checks at terminals
• Cooperation with A-krim: Partnership with inter-agency initiative to combat work-related crime
• Improved due diligence: Enhanced periodic supplier reviews and risk assessments
• Resources allocated: No identified significant CapEx, OpEx or dedicated resources disclosed
• Effectiveness evaluation: Not yet evaluated; planned for future

S2 – Table 3: Actions related to value chain workers

Other risk management actions

Supplier compliance risk assessment framework (2024)

Rolled out initial supplier compliance risk assessment covering:

• Anti-corruption
• Human and/or labour rights (supplier signature of Business Partner Code of Conduct)
• IT Security
• Privacy/GDPR
• Sanctioned parties
• Financial Services Regulation

Implementation: Ongoing during 2025

Additional context

No severe incidents identified: During 2024, Schibsted Marketplaces did not identify any severe human rights issues or incidents related to the upstream and downstream value chain.

Business Partner Code of Conduct criteria:

Social criteria:

• Respect for human rights and labour conditions
• Prohibition of discrimination and harassment
• Provision of healthy, safe and secure work environment
• Implementation of whistleblowing and grievance processes

Environmental criteria:

• Environmentally friendly business practices
• Precautionary approach to environmental challenges
• Greater environmental responsibility
• Development and diffusion of environmentally friendly technologies
• Data sharing on environmental performance

Targets related to value chain workers

Schibsted Marketplaces' sustainability targets will be revised during 2025-2026, following the carve-out of Schibsted Media. The targets presented in the 2023 sustainability statement have been redefined as performance measurements (not targets).

Performance measurements for 2024

Three time-bound and outcome-oriented performance measurements aimed at reducing negative impacts on workers within the value chain and improving oversight of working conditions:

Policy relationship: These performance measurements relate to the Code of Conduct statement: 'We work actively to integrate respect for human rights and labour rights into our practices and business activities'

Period: Valid for 2024

Stakeholder involvement: Stakeholders were not involved in setting these performance measurements

Note: No quantified target values, baseline years, or baseline values are disclosed for these performance measurements.

Policies related to consumers and end-users

Schibsted Marketplaces has the following policies in place to manage material impacts, risks and opportunities related to consumers and end-users:

Privacy and Cookie Policy

Connection to IROs:

• Negative impact: Cybersecurity breaches could potentially compromise the privacy of users by exposing their sensitive data
• Risks:
  • Privacy breaches might lead to breach of GDPR and result in financial penalties and harm reputation
  • Reduced trust and brand reputation caused by not prioritising private consumers' rights and their access to data over professional customers can reduce usage of platforms, leading to reduced revenue

Scope:

• Value chain: Own operations
• Geography: All EEA countries where Schibsted Marketplaces operates

Governance:

• Most senior responsible level: CFO, delegated to Head of Legal

Implementation and monitoring:

• Privacy and integrity are managed by the Chief Information Officer, supported by a team of privacy experts and a Data Protection Officer (DPO)
• Employees receive privacy training to ensure necessary awareness and competence
• The privacy programme has the following key objectives:
  • Ensure compliance with legal obligations on a continuous basis
  • Guide Schibsted Marketplaces' data-driven approach by executing on privacy by design across product and tech organisation, embedding privacy into corporate culture, tech stack and products
  • Provide efficient and automated tools to empower users' control over their personal data
  • Maintain and increase end-user and public competence, knowledge and trust related to use of data
• Reporting procedures in place for handling complaints and data breaches
• Measures for detecting vulnerabilities and preventing breaches
• Ongoing dialogue with regulators and legislators
• Continuous collaboration with other companies on developing industry standards

Schibsted Marketplaces' Security Policy

Connection to IROs:

• Negative impacts:
  • Cybersecurity breaches could potentially compromise the privacy of users by exposing their sensitive data
  • Fraud attempts on platforms could cause financial losses, distress and need for legal action, negatively impacting consumers
• Opportunity: Strengthened trust in brand due to increased market transparency, market efficiency and consumer safety can increase revenue in the long term

Scope:

• Value chain: Own operations
• Geography: All geographies where Schibsted Marketplaces operates

Governance:

• Most senior responsible level: EVP Foundation, delegated to Chief Information Security Officer

Schibsted Marketplaces' Code of Conduct

Connection to IROs:

• The document mentions this policy is in place but does not provide detailed information about its connection to specific IROs, scope, or governance structure in the context of consumers and end-users.

Link to international standards

The document references compliance with UNGPs on Business and Human Rights and OECD guidelines in relation to S4-1 policies (as shown in the SFDR/Pillar 3 cross-reference table), though specific implementation details are not elaborated in the excerpts provided.

Taking action on material impacts on consumers

Overview

The S4 Consumers and end-users area saw the most actions performed during 2024, closely connected to core business. Actions focused on improving cybersecurity, mitigating fraud and harassment risks, and advancing positive impacts. Follow-up on effectiveness is performed through consumer engagement activities including interviews, large-scale feedback gathering, and customer support insights (see S4-2).

Note on resources: For all actions listed, there are no identified significant CapEx, OpEx or dedicated resources defined, except for the action 'Launch of transactional marketplace on Tori.fi'. However, for confidentiality reasons, the amount invested for this particular action is not disclosed.

Actions – All business segments

1. Launch of common Nordic system to detect and reduce fraud and harassments

• Related IROs:
  • Negative impact: Fraud attempts on platforms could cause financial losses, distress and need for legal action
  • Negative impact: Harassment related to interaction between users might lead to emotional distress, loss of trust and decreased user engagement
  • Risk: Criminal activities might reduce trust and reputation
  • Opportunity: Strengthened trust in brand due to increased market transparency, market efficiency and consumer safety
• Scope: Value chain: Downstream (consumers); Geography: Norway, Sweden, Finland, Denmark
• Time horizon: 2024
• Expected outcome: Further reduction in perceived fraud, adapting to new fraud attempts
• Future actions: Continued work to reduce sources of fraud

2. Launch new advertising platform, enhancing Schibsted Marketplaces' ability to monitor and ensure responsible advertiser behaviour

• Related IROs:
  • Negative impact: Fraud attempts on platforms
  • Negative impact: Reduced trust and brand reputation caused by not prioritising private consumers' rights
• Scope: Value chain: Own operations; Geography: All Schibsted Marketplaces own operations offering advertising solutions, primarily related to marketplace verticals
• Time horizon: 2024
• Expected outcome: Few or no fraud attempts through advertising platform
• Future actions: No future actions defined

3. Cybersecurity trainings held for employees

• Related IROs:
  • Negative impact: Cybersecurity breaches could potentially compromise privacy of users
  • Risk: Privacy breaches might lead to breach of GDPR and result in financial penalties
• Scope: Value chain: Own operations, Downstream; Geography: All Schibsted Marketplaces' sites
• Time horizon: 2024
• Expected outcome: Fewer and less impactful cyber security breaches
• Future actions: No actions planned

Actions – Real Estate segment

4. Rollout of property valuation in Norway

• Related IROs:
  • Negative impact: Lack of price transparency in real estate buy/sell market can be amplified through Real Estate marketplaces
  • Opportunity: Strengthened trust in brand due to increased market transparency
• Scope: Value chain: Own operations; Geography: Norway
• Time horizon: 2024
• Expected outcome: Increase customers' competence and preparedness when buying and selling properties
• Future actions: Continue work to improve information in the real estate market

5. Price insights on property valuation/ownership in Finland

• Related IROs:
  • Negative impact: Lack of price transparency in real estate buy/sell market
  • Opportunity: Strengthened trust in brand due to increased market transparency
• Scope: Value chain: Own operations; Geography: Finland
• Time horizon: 2024
• Expected outcome: Increase customers' competence and preparedness when buying and selling properties
• Future actions: Continue work to improve information in the real estate market

6. Co-created input for tenant rights in Norway

• Related IROs:
  • Negative impact: If non-transparent and unfair practices persist in the rental market, might reinforce unequal treatment of consumers
  • Opportunity: Strengthened trust in brand due to increased market transparency
• Scope: Value chain: Downstream; Geography: Norway
• Time horizon: 2024
• Expected outcome: Establish trust through better protection of tenants
• Future actions: Follow-up on the process and potential impact

7. Acquisition of HomeQ and integration with Qasa

• Related IROs: Same as above (tenant rights and rental market transparency)
• Scope: Value chain: Downstream; Geography: Norway
• Time horizon: 2024
• Expected outcome: Improved protection of tenants
• Future actions: Continue dialogue with market to increase transparency

Actions – Jobs segment

8. Improved anti-discrimination flow in Sweden

• Related IROs:
  • Negative impact: If discriminatory practices persist in hiring processes, our job marketplaces could amplify this issue
  • Opportunity: Strengthened trust in brand due to increased market transparency
• Scope: Value chain: Downstream; Geography: Sweden
• Time horizon: 2024
• Expected outcome: Avoid discrimination in hiring processes on our platforms
• Future actions: Continue this work in all our markets

Actions – Recommerce segment

9. Launch of transactional marketplace on Tori.fi

• Related IROs:
  • Negative impact: Fraud attempts on platforms
  • Positive impact: Enabling transparent C2C trading with consumer protection
  • Opportunity: Strengthened trust in brand
  • Risk: Criminal activities on platforms
• Scope: Value chain: Downstream; Geography: Finland
• Time horizon: 2024
• Expected outcome: Enabled C2C trading with enhanced consumer protection and trust, drive increased numbers of transactions
• Future actions: Continue work to increase reach of these features
• Resources: CapEx and OpEx investments made for this action have been excluded from disclosure for confidentiality reasons

10. Providing digital infrastructure for giveaway goods (same platform as above)

• Related IROs:
  • Positive impact: Providing digital infrastructure for giveaway goods benefits consumers and end-users (both givers and receivers)
• Scope: Same as above
• Time horizon: 2024
• Expected outcome: Strengthened position within Recommerce, enabling continued provision of digital infrastructure for giveaway goods
• Future actions: Same as above

Performance measurements

All business segments:

1. Percentage of Nordic consumers associating Schibsted Marketplaces with 'A safe marketplace' (panel survey)
2. Percentage of employees in scope that completed mandatory security training (four modules: Fire Safety, Social Engineering, AI Tools For Work, NIS2 Incident Reporting)
3. Percentage of employees that completed onboarding security training
4. Share of responses to major cybersecurity incidents within 30 minutes
5. Number of decisions against Schibsted related to personal data breach notifications
6. Number of users' data deletions and takeouts provided within legally required timelines
7. Number of significant incidents and all control mechanisms in place (fraud on websites)
8. Number of cases reported to Advertising Ombudsman (Sweden) and Consumer Authority/Market Council (Norway)
9. Percentage of employees in scope that completed awareness and training programme in privacy and data protection principles (privacy by design)

Real Estate segment:

Performance measurements focused on providing a more transparent rental market and improving tenant rights. Connect to Code of Conduct objective: 'We act with a high degree of transparency and integrity to ensure our actions and decisions are always in the best interest of our customers, our business and society.'

Process for identifying actions and enabling remedy

Schibsted Marketplaces is currently updating key strategies and action plans. No activities were performed during 2024 specifically designed to manage the actual and potential impacts identified in the double materiality assessment. However, several actions were taken that directly relate to these impacts.

The process for identifying needed actions is a direct outcome of engagement described in S4-2. The approach combines user input and feedback with understanding of product design. In some cases (e.g., Tenancy Act initiative) industry collaborations are required. For material negative impacts requiring remedy, effectiveness is ensured by monitoring results against key outcomes (e.g., number of cybersecurity breaches and amount of perceived fraud). Continuous monitoring, regular updates and collaboration with stakeholders ensure remedies remain effective.

Data use and privacy

Schibsted Marketplaces' strategic focus on data aims to create insights benefiting users through building better products and services. Users are informed how data is used and how they can control it. Extensive efforts ensure data processing complies with applicable privacy regulations (such as GDPR) and users' expectations. Privacy and integrity are managed by the Chief Information Officer, supported by a team of privacy experts.

Targets related to consumers

Schibsted Marketplaces explicitly states that it does not have sustainability targets for S4 in 2024. The company discloses:

"Schibsted Marketplaces' sustainability targets will be revised during 2025-2026, following the carve-out of Schibsted Media. The targets presented in the 2023 sustainability statement have been redefined as performance measurements."

Performance measurements (not targets)

Instead of targets, the company reports 17 performance measurements for 2024 related to consumers and end-users. Two examples are disclosed:

No baseline years, target years, or quantified target values are provided for these performance measurements.

The company states these performance measurements were "monitored periodically by the relevant leadership teams throughout the year" but does not disclose progress-to-date values or results achieved.

Business conduct policies and corporate culture

Schibsted Marketplaces has established policies and processes to manage business conduct matters and promote a strong corporate culture. The company actively establishes, promotes and evaluates its corporate culture by engaging employees in defining shared values, strengthening adherence to the Code of Conduct and assessing understanding through employee surveys.

Code of Conduct

Policy scope:

• Applies to all employees, all subsidiaries and the Board of Directors
• Extended expectation for partners, contractors and other hired personnel working in operations
• All geographies where Schibsted Marketplaces operates

Governance:

• Owned by CEO
• Delegated to EVP People & Communications to ensure awareness and onboarding of existing and new employees
• General managers of each company are responsible for supporting and monitoring rollout and implementation
• Group Compliance Officer is responsible for establishing and implementing the Code of Conduct

Key content:

• Reflects commitment to UN Global Compact's Ten Principles for corporate sustainability
• Covers corruption, bribery, trading of influence, facilitation payments, antitrust rules, responsible business partners, conflicts of interest, inside information, insider trading, money laundering and grievance mechanisms
• Emphasises reducing negative environmental impact
• Mandates measurement and management of carbon footprint
• Prioritises renewable energy and environmentally responsible transportation
• Promotes circular and sustainable consumption through products and services
• Covers forced labour (as part of labour rights), child labour, and trafficking (latter not explicitly addressed)
• Addresses privacy and data security

Links to international standards:

• UN Global Compact's Ten Principles for corporate sustainability
• UN Guiding Principles on Business and Human Rights
• ILO Conventions (all conventions in general, no specific conventions mentioned)
• OECD Guidelines for Multinational Enterprises, including human rights due diligence

Public availability:

• Not explicitly stated where the Code of Conduct is publicly available

Monitoring:

• All employees expected to attend relevant training sessions (mainly web-based)
• Mandatory training for all employees as part of onboarding and annual basis
• Monitored and revised periodically (last revised in 2022)
• Speak Up whistleblowing channel available
• Group Compliance Officer monitors compliance

Business Partner Code of Conduct

Policy scope:

• All business partners including suppliers
• Extended to supply chains of business partners
• All geographies where Schibsted Marketplaces or business partners operate

Governance:

• Owned by CFO
• Delegated to Head of Legal to follow up on compliance

Key content:

• Ethical and legal standards including anti-bribery and corruption, data privacy, fair competition, human rights and environmental responsibility
• Mandates adherence to standards higher than legal requirements in some cases
• Covers human rights, labour rights, environmental protection and anti-corruption
• Respect for minimum social safeguards as defined in international conventions
• Covers but does not explicitly address forced labour, child labour and trafficking
• Requires business partners to perform human rights impact assessments and due diligence
• Emphasis on transparency, immediate action on non-compliance and encouragement of whistleblowing
• Requires business partners to ensure employees can report concerns regarding potential breaches

Links to international standards:

• UN Global Compact
• OECD Guidelines for Multinational Enterprises
• Requirements in the Norwegian Transparency Act
• International conventions on human rights and working conditions

Public availability:

• Delivery's Supplier Code of Conduct is publicly available on Delivery's website

Monitoring:

• Currently being rolled out; monitoring processes are yet to be defined and put in place
• Planned next step includes active inquiries with major business partners and sample-based checks
• Business Partner Code of Conduct implementation monitored through supplier reviews and risk assessments

Group Environmental Policy

Policy scope:

• Whole of Schibsted Marketplaces
• Focus on own operations
• All geographies where Schibsted Marketplaces operates

Governance:

• Board of Directors and Executive Leadership Team have duty and responsibility to ensure policy is communicated, understood and acted upon
• Head of Sustainability is responsible for monitoring compliance

Key content:

• Based on principles of UN Global Compact
• Promotes greater environmental responsibility
• Use of environmentally friendly technologies
• Application of precautionary approach
• Prioritises reduction of energy consumption and GHG emissions
• Promotes use of renewable and recycled materials
• Minimises waste through effective recycling and reuse strategies
• Prioritises materials from renewable or recycled origins
• Avoids excessive resource or energy consumption during production
• Commitment to minimise packaging and maximise reuse and recycling
• Prohibits use of wood from old-growth forests or rainforests

Links to international standards:

• UN Global Compact principles

Public availability:

• Publicly available on Schibsted Marketplaces' website

Monitoring:

• Head of Sustainability monitors compliance
• Monitored and revised periodically

Global Travel Policy

Policy scope:

• All employees (own operations)
• All geographies where Schibsted Marketplaces operates

Governance:

• Owned by EVP People & Communications
• Delegated to dedicated Travel Manager to oversee implementation and monitor adherence

Key content:

• Highlights preference for low-emission travel options
• Advocates for safe, smart and sustainable travel
• Emphasises environmental responsibility and employee well-being
• Digital-first approach to reduce physical travel
• Promotes responsible travel choices (economy class within Europe, sustainable hotels, sustainable modes of transport)

Links to international standards:

• Not explicitly stated

Public availability:

• Not explicitly stated

Monitoring:

• Travel Manager oversees implementation and monitors adherence

Discrimination, Bullying and Harassment Policy

Policy scope:

• All organisational activities across Schibsted Marketplaces' subsidiaries
• Covers employees, hired consultants and trainees, regardless of location
• Own operations
• All geographies where Schibsted Marketplaces operates

Governance:

• EVP People & Communications holds primary responsibility for implementing and monitoring
• Managers have responsibility for immediate action
• People team investigates reported incidents

Key content:

• Commits to fostering professional and inclusive workplace where diversity is embraced
• Addresses risks such as employee ill-health and exclusion due to inappropriate behaviours
• Managers required to act immediately upon witnessing or being informed of issues
• Employees encouraged to report concerns to trusted individuals or through anonymous Speak Up channel
• People team investigates reported incidents confidentially and objectively

Links to international standards:

• Not explicitly stated

Public availability:

• Not explicitly stated

Monitoring:

• EVP People & Communications monitors implementation
• People team investigates incidents
• Effectiveness monitored through employee surveys

Diversity and Inclusion Policy

Policy scope:

• All activities within Schibsted Marketplaces
• Encompasses employees across all subsidiaries, regardless of role or location
• Own operations
• All geographies where Schibsted Marketplaces operates

Governance:

• Executive Leadership Team accountable for implementation
• Top management responsible for allocating necessary resources
• Leaders responsible for ensuring inclusive organisational culture
• Employees responsible for creating and maintaining environment of mutual respect

Key content:

• Defines diversity as unique differences and similarities among individuals (ethnicity, gender, age, functional capacity, sexual orientation, gender identity, culture, religion, background, language, cognitive abilities)
• Defines inclusion as cultivating corporate culture where all can be themselves, feel belonging and fully participate
• Addresses risks such as discrimination and bias
• Aims to foster innovation and organisational success through diverse perspectives

Links to international standards:

• Not explicitly stated

Public availability:

• Not explicitly stated

Monitoring:

• Monitoring processes include encouraging employees to report non-compliance through various channels
• Continuous attention to diversity and inclusion

Recruitment Policy

Policy scope:

• All recruitment activities across Schibsted Marketplaces' locations
• Emphasises internal and external compliance and inclusivity
• Own operations
• All geographies where Schibsted Marketplaces operates

Governance:

• EVP People & Communications accountable for implementation
• Delegated to Talent Acquisition function for oversight, support and ensuring fair and transparent recruitment processes

Key content:

• Commitment to attracting and hiring right people for right positions through transparent and unbiased process
• Emphasises diversity, inclusion and fairness
• Fosters internal mobility
• Encourages development of skills
• Promotes inclusive hiring practices
• Maintains compliance with regulations such as GDPR
• Addresses material risks including unconscious bias, legal non-compliance and potential damage to employer brand

Links to international standards:

• GDPR compliance

Public availability:

• Not explicitly stated

Monitoring:

• Supported through tools like Trustcruit for candidate experience feedback
• Unconscious bias training for recruiters and managers
• Talent Acquisition function oversees adherence

Delivery's Supplier Code of Conduct

Policy scope:

• All suppliers and sub-suppliers
• Activities across Delivery's entire supply chain
• Extends to employees and consultants, regardless of employment type
• Upstream (business partners)
• Own operations (Delivery segment)
• Norway, Sweden, Finland, Denmark

Governance:

• Owned by EVP Recommerce
• General manager of Delivery ensures guidelines are followed by subcontractors

Key content:

• Ensures suppliers uphold sustainability principles related to human rights, labour rights, environmental responsibility and anti-corruption
• Respecting international standards such as UN Global Compact
• Addresses material sustainability risks
• Enforces compliance through supplier monitoring
• Waste material should be reused and recycled wherever possible
• Minimise air in packaging and ensure use of environmentally friendly packaging
• Mentions renewable energy sources and energy-efficient products and services in procurement

Links to international standards:

• UN Global Compact
• International Bill of Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work
• UN Convention Against Corruption

Public availability:

• Publicly available on Delivery's website

Monitoring:

• Suppliers responsible for staying updated on changes
• Delivery provides guidance on corrective actions when non-compliance identified
• Monitored and revised periodically (most recently January 2023)
• Regular random controls of how subcontractors follow policies

Internal Advertising Guidelines

Policy scope:

• Each company in the Group
• External advertising
• Downstream (advertising content)

Governance:

• General manager of each company responsible for ensuring marketing content follows guidelines

Key content:

• Focus on ensuring external advertising is compliant with local regulations
• Ads may not be misleading or illegal
• Content rejected includes inappropriate, violent or discriminatory messages and ads for weapons (except certain legally approved hunting weapons)
• Can refuse ads failing to meet requirements
• Requirements include specific design features to avoid confusion with editorial material
• Ads tested for functionality and compliance
• Reserves right to remove non-compliant ads

Links to international standards:

• Local regulations on advertising

Public availability:

• Not explicitly stated

Monitoring:

• Monitored and adapted continuously to comply with current regulations

Privacy and Cookie Policy

Policy scope:

• Own operations
• All EEA countries where Schibsted Marketplaces operates

Governance:

• Owned by CFO
• Delegated to Head of Legal

Key content:

• Addresses privacy breaches and cybersecurity risks
• Protects consumer privacy by ensuring enterprise practices relating to collection and use of consumer data are lawful, transparent and fair
• Enables consumer participation and choice
• Takes reasonable measures to ensure security of personal data
• Users have legally defined rights relating to personal data
• Schibsted Marketplaces committed to supporting users in accessing and using those rights
• Adapts approach to meet EU and local regulations (GDPR, Digital Markets Act)

Links to international standards:

• GDPR
• Digital Markets Act
• OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (chapter eight on consumer interests)

Public availability:

• Country-specific contact form available on website

Monitoring:

• Dedicated Privacy team (reporting to Head of Legal)
• Technical means (e.g., Consent Management Platform) to respect users' choices
• Manual intervention and root cause analysis in event of privacy breaches

Schibsted Marketplaces' Security Policy

Policy scope:

• Own operations
• All geographies where Schibsted Marketplaces operates
• Applies to brands, Executives, Board members, managers, employees, contractors and suppliers
• Extends to associated companies where Schibsted Marketplaces holds significant influence

Governance:

• Owned by EVP Foundation
• Delegated to Chief Information Security Officer for implementation oversight

Key content:

• Addresses cybersecurity breaches and privacy risks
• Covers fraud prevention
• Server and data storage solutions must meet environmental performance benchmarks
• Data centre energy efficiency requirements

Links to international standards:

• Based on guidance in ISO27001 standard for Information Security Management Systems
• Refers to Security Handbook for detailed implementation

Public availability:

• Not explicitly stated

Monitoring:

• Monitored through manual checks and IT systems
• Employees regularly trained in cybersecurity aspects

Whistleblower Protection and Reporting Mechanisms

Schibsted Marketplaces has established a Speak Up whistleblowing channel as a supplement to internal reporting. This channel:

• Enables anonymous reporting of misconduct, breaches or potential violations of the Code of Conduct
• Is handled through a third party
• Is open to all stakeholders, including individuals working under supervision of contractors, subcontractors and suppliers
• Built to enable people to voice concerns about potential violations of fundamental human rights and failure to provide decent working conditions
• Has clear written procedures for handling reports
• Protects whistleblowers by providing multiple ways to raise concerns with anonymity if needed
• Explicitly prohibits retaliation against anyone reporting concerns in good faith
• Reports handled confidentially; reporter identity not disclosed beyond authorised staff unless explicit consent provided
• Cases involving Executive Leadership Team or Board reviewed by external party
• Oversight responsibility transferred to People team (as of end 2024, previously handled by Speak Up Committee)

Compliance with EU Whistleblower Directive: The EU Directive 2019/1937 on protection of whistleblowers has been implemented in all countries where Schibsted Marketplaces operates except Norway and Poland, where implementation is still being evaluated by authorities.

Training: Mandatory training for all employees as part of onboarding and annual basis (implemented in 2024).

Anti-Corruption and Anti-Bribery Procedures

Schibsted Marketplaces is committed to act professionally and fairly in all business activities and relationships. The company:

• Implements and enforces effective systems to counter corruption
• Investigates any business conduct incidents, including corruption
• Incidents handled by Group Compliance Officer and, if appropriate, by third party
• Incidents investigated promptly, independently and objectively
• Based on risk assessment, likelihood of corruption or bribery within Schibsted Marketplaces is deemed low

Functions at highest risk of corruption/bribery:

1. Sales and business development (high exposure to external clients and partners)
2. Procurement and vendor management (risk in vendor selection and contract awards)
3. Public affairs and government relations (interactions with regulators and policymakers)

Due Diligence Process

Schibsted Marketplaces has a due diligence process at both Group and subsidiary level based on the OECD due diligence model as described in the Guidelines for Multinational Enterprises. Responsibility is shared between sustainability and compliance functions at Group level. Each subsidiary is responsible for its own due diligence process with oversight from Group sustainability team. The process is evaluated annually through reporting related to the Norwegian Transparency Act.

Training and Awareness

• All employees expected to attend relevant training in Code of Conduct
• Training sessions mainly web-based covering full Code of Conduct
• Mandatory for new employees (onboarding), newly appointed managers and ad-hoc as needed
• Applies to all employees, Executive Leadership Team and Board of Directors
• In 2024, mandatory training implemented for all employees as part of onboarding and annual basis
• Employees regularly trained in cybersecurity aspects covered by Security Policy
• Unconscious bias training for recruiters and managers (Recruitment Policy)
• Delivery's Value Chain Managers completed course in labour rights and routines (2024)

Performance and Incidents

2024 Performance:

• No cases of non-respect of UN Guiding Principles on Business and Human Rights or OECD Guidelines reported in upstream or downstream value chain during 2024
• No severe human rights issues or incidents identified related to upstream and downstream value chain during 2024
• Some deviations from contractual agreements with subcontractors identified in Delivery segment in 2023; mitigating actions continued into 2024
• No confirmed incidents of corruption during 2024
• Three performance measurements tracked during 2024 related to business conduct

Governance Oversight:

• During 2024, all material impacts, risks and opportunities except 'Waste generated in own operations and delivery services' were addressed by Board and Executive Leadership Team
• Board and Executive Leadership Team informed of sustainability due diligence on ad-hoc basis and of outcome in connection with potential investment decisions
• Annual sustainability statement forms main report to Board on sustainability
• Critical concerns can be addressed through whistleblower or risk management processes

Incidents of corruption or bribery

Confirmed incidents

Not disclosed.

Convictions and fines

The company states in its ESRS G1-4 indicator mapping table (Indicator number 17, Table #3 of Annex 1) that it reports on "Fines for violation of anti-corruption and anti-bribery laws paragraph 24 (a)" but no specific quantitative data on fines is provided in the excerpts.

Disciplinary actions

Not disclosed.

Contracts terminated

Not disclosed.

Investigation and speak-up procedures

Schibsted Marketplaces has established a whistleblowing channel called Speak Up, which enables anonymous reporting of misconduct or potential violations of the Code of Conduct. The channel is handled by a dedicated third party and is available 24 hours a day via digital channel or telephone. All concerns reported are initially assessed by an external party.

The company states: "Schibsted Marketplaces will not tolerate any negative consequences for anyone who reports a concern in good faith." A Speak Up Committee (which was replaced by a revised procedure at the end of 2024) was responsible for evaluating, coordinating and supervising how cases are followed up.

Employees can also report concerns to Schibsted Marketplaces' Legal department, Group Compliance Officer, or Executive Leadership Team. The company investigates any business conduct incidents, including corruption, which would be primarily handled by the Group Compliance Officer and, if appropriate, by a third party. Incidents are investigated promptly, independently and objectively.

The company states: "Based on the risk assessment described in the DMA process... the likelihood that corruption or bribery would occur within Schibsted Marketplaces is deemed low."

All employees are mandated to attend training in the Code of Conduct, which covers corruption, bribery, trading of influence, facilitation payments, and other business conduct matters. In 2024, mandatory training for all employees was implemented as part of their onboarding and thereafter on an annual basis.

Political influence and lobbying activities

Political engagement approach

Schibsted Marketplaces is actively engaged in public policy (e.g., by providing a consultation response to the draft bill for a new Tenancy Act in Norway, expressing our view on existing and future legislation) and maintains lobbying activities that aim to increase transparency in our industry. We engage with policymakers and contribute to public debate, ensuring that our voice is heard on matters significant to the industry.

Our lobbying activities focus on European (EU) legislation and on legislation in Norway and Sweden, but also covers Finland and Denmark on issues related to online marketplaces. Most of our activities are organised through industry organisations such as Næringslivets Hovedorganisasjon (NHO) in Norway, Svenskt Näringsliv (SN) in Sweden, European Tech Alliance (EUTA) and Classified Marketplaces Europe (CME).

Our work is led by our Director of Public Policy, who frequently interacts with our Executive Leadership Team on our progress and activities. Our CEO holds ultimate responsibility for oversight of our lobbying activities.

Due to the carve-out of Schibsted Media, our membership of some organisations (Mediebedriftenes Landsforening (MBL), Tidningsutgivarna (TU), Coalition for App Fairness (CAF) and the European Publishers Council (EPC)) was terminated during 2024.

None of the newly appointed members of the Executive Leadership Team or the Board has held a position in public administration (or as regulators) in the past two years.

Ethical standards and guidelines

Our involvement in these activities is conducted according to our own Code of Conduct and the EU Transparency Register Code of Conduct. The EU Transparency Register Code of Conduct mandates registrants to identify themselves accurately, declare their interests and objectives, avoid dishonest practices, respect confidentiality and conflict of interest rules and maintain accurate, up-to-date information in the register. Compliance with this Code is essential for registrants to remain on the register and involves adhering to rules regarding client–intermediary relationships, outsourcing to third parties and cooperation with the secretariat.

EU Transparency Register

Schibsted ASA is listed in the EU Transparency Register (ID: 549120892622-67).

Focus areas and main topics

The following table summarizes the main topics covered by our lobbying activities:

Financial and in-kind political contributions

The following table shows our financial and in-kind contributions for 2024:

Note: The organisations listed in this table represent those that received financial contributions exceeding NOK 0.1 million in 2024.

Payment practices

Policy and approach

Schibsted Marketplaces has no formal policy specifically related to payment practices in place, since general policies and processes have been deemed sufficient. For suppliers, the company generally adapts to local market circumstances. In general, the company strives to pay all suppliers promptly while ensuring a practically feasible and robust invoice approval process.

The general payment terms may vary from supplier to supplier. The same general approach applies to all types of suppliers.

Legal proceedings

As of 31 December 2024, Schibsted Marketplaces had no legal proceedings currently outstanding for late payments.

Payment terms and average payment time by country

The table below presents general payment terms and average payment time based on a representative sample of over 16,000 invoices across countries. The percentage of payments aligned with the general terms includes payments made within or before the specified payment deadline. Companies in the sample include Finn.no AS, Schibsted Nova AS, Blocket AB, Schibsted Enterprise Technology AB, Schibsted Suomi OY and Schibsted Denmark ApS.

Additional context from financial statements

Contracts with customers typically have a contract period of one year or less. Payments are normally made with a credit term of 30 to 60 days, which is consistent with market practice. While deferred payment terms exceeding normal credit terms may be agreed in rare circumstances, the deferral never exceeds twelve months.