FULLTEXT DEL 2 AV 4
Årsredovisning 2025
Annual report
Page
65
KEY STAKEHOLDER
HOW WE ENGAGE
WHY WE ENGAGE
VALUE CREATION
OWN WORKFORCE
We participate in two
-
way responsive dialogue. We engage through:
•
Intranet updates
•
Performance and development dialogues
•
Annual workplace survey
•
Manager check
-
ins
•
Group
-
wide “town halls”
•
Social events
•
Informal communication channels to raise open questions to the
group or in specific work group form
People are the core of our business, and we engage to:
•
Learn about employees’ values, engagement, and concerns
•
To understand employees’ perceptions and experiences
•
Professional development
•
Sense of inclusion
•
Job satisfaction and well
-
being
•
To maintain a fair workplace for all
•
Internal policy
•
Employee
-
driven initiatives
•
Career advancement and skills development
•
Enhancing employee well
-
being, inclusion, and a safe work environment
USERS
We engage with our users in various ways through:
•
Our sports media, like articles, commentary, communities,
videos, and podcasts
•
Through website feedback tools
•
Analysis of user behavior and feedback
•
User interaction with products
We engage to:
•
Building trust
•
Understand users’ preferences and behavior
•
Enhancing users’ experience and safety
•
User education and empowerment
•
Safeguarding users
•
Community building
•
Offering safer gambling resources, including a Betting Academy and Mindway AI solutions
•
Data collection and processing within the GDPR framework
•
Ensure quality in Better Collective’s deliveries
PARTNERS AND SUPPLIERS
We engage through formal and informal channels:
•
Daily operations and collaborative projects
•
Reviews
•
Industry networking and conferences
•
Through contracts and partner / supplier due diligence
As a digital sports media group relying on our partnerships we
engage to:
•
Build trusted partnerships
•
Ensure compliance with our partners and suppliers
•
Learn about trends and insights related to our industry.
•
Streamlined operations and alignment on sustainability standards with partners
•
Fostering shared responsibility for advancing sustainability and safer gambling practices
•
Supporting partners by holding them to high standards during the customer acquisition and ongoing CRM
process
•
The development and integration of AdVantage ensures unparalleled engagement and value for both our
partners and audiences
CAPITAL PROVIDERS
(SHAREHOLD-
ERS AND FINANCIAL INSTITUTIONS)
We engage through formal and informal channels through a dedicated
Investor Relations team and the Executive management:
•
Quarterly roadshows
•
Conference calls
•
Regular 1
-
1 meetings
•
Capital Markets Day
•
Annual general meeting
As a dual
-
listed company, we
naturally engage with our share-
holders to:
•
Ensure efficient financial allocation
•
Understand shareholders’ interests
•
Ensure accurate communication
•
Ensure shareholder value
•
Secure financing
•
Increased investor confidence
•
Building and maintaining strong relationships and transparency
INDUSTRY ASSOCIATIONS AND
REGULATORS
We participate in industry
-
wide dialogue through:
•
Joint initiatives and programs
•
Conferences and meetings
•
Inputs into strategic directions
•
Knowledge sharing
•
Promoting and implementing safer gambling frameworks
•
Ensure compliance
•
Educating regulators about the affiliate business model and
its role in the sports and iGaming ecosystem
•
Contributing to voluntary frameworks and best practices
•
Safer gambling week
•
Co
-
founder of RAiG (Responsible Affiliates in Gambling) and RGAA (Responsible Gamblig Affiliate Association)
•
Systemized regulatory compliance through our Legal team
===== SIDA 66 =====
Annual report
Page
66
DMA results
(SBM
-
3)
Better Collective’s material IROs are defined through
our DMA and detailed under each topic in the Sustaina-
bility Statements. The IROs reflect the nature of our
business model as a digital sports media group, posi-
tioned between users and licensed sportsboo
ks in the
gambling and sports entertainment ecosystem.
M
aterial IROs primarily occur within our own operations
and downstream activities, reflecting our position as a
digital sports media group connecting users to licensed
sportsbooks. They are closely linked to our strategic ob-
jectives, including promoting saf
er gambling, delivering
transparent and engaging content, ensuring workforce
well
-
being and
inclusiveness
, championing responsible
business conduct, and minimizing environmental im-
pact.
We operate in a digital first ecosystem, where the utili-
zation of data
center
services plays a fundamental role
in our infrastructure. While we do not identify environ-
mental risks or opportunities explicitly relating to the
environment, we recognize our actual negative
environ-
mental impact. Our upstream activities impact our
over-
all environmental footprint, highlighting the importance
of working with sustainable data
center
providers.
In
practice, this means selecting providers that operate
data
centers
tha
t
match electricity consumption with
renewable energy
or
work to
reduce energy intensity
using
energy
-
efficient hardware and system design.
Although our direct emissions are limited, our overall
impact relates to the strain our operations and business
models
put on the environment regarding carbon emis-
sions and energy consumption. The negative effect of
these environmental impacts cannot be limited to the
countries where we operate, as climate change is a
global phenomenon.
The identified social impacts for Better Collective are
both negative and positive, actual and potential, and are
primarily shaped by industry
-
specific challenges and
opportunities. Possible negative impacts arise from our
proximity to gambling and sports
betting, work environ-
ments, and gaps in diversity and inclusion. Mitigating ac-
tions are in place to address these risks, including re-
sponsible gambling initiatives, flexible work models, and
diversity and inclusion efforts. For the purposes of the
DMA, we
have considered only the gross risk, before
mitigating actions. If these measures were discontinued,
potential negative impacts could affect employees’
well
-
being, user trust, and safety.
As a digital sports media group, we also generate posi-
tive social impacts. We provide value to employees
through inclusivity, continuous learning, and flexible
working opportunities while fostering a culture of re-
sponsible and ethical engagement.
Additionally, we enhance transparency in the sports me-
dia and betting industry, helping consumers and end
-
us-
ers make informed decisions through educational con-
tent, community
-
driven insights, and compliance
-
driven
marketing practices.
Our business is built on strict data privacy protocols,
ethical marketing standards, and a commitment to safer
gambling. By prioritizing ethical practices and sustaina-
ble operations, we aim to create a positive and lasting
impact on our employees, users, a
nd the wider industry.
Better Collective’s governance and business conduct
also have a direct influence on our IROs.
A strong corporate culture fosters engagement, produc-
tivity, and cohesion across offices and regions, while
maintaining ethical standards, compliance, and account-
ability. Potential risks related to corruption, bribery, or
inconsistent culture are mitigated
through policies, and
ongoing monitoring. Our approach to tax transparency
and contribution to local communities further supports
ethical conduct, stakeholder trust, and long
-
term value
creation.
The ESRS disclosure requirements cover all identified
material IROs. However, Better Collective also reports
entity
-
specific metrics on impacts not explicitly cap-
tured under ESRS, reflecting our commitment to leading
practices in the industry:
•
The material positive impact and opportunity re-
lated to safer gambling is reported as an entity
-
specific disclosure under “Consumers
&
end
-
users”.
•
The material positive impact and opportunity from
contribution to local communities is reported as an
entity
-
specific disclosure under “Governance”.
•
Tax transparency is reported as an entity
-
specific
disclosure under “Governance”.
In summary, our material IROs are categorized under S1
(Our workforce), S4 (Consumers and end
-
users), G1
(Business conduct), and E1 (Climate change). By embed-
ding our sustainability strategy into daily operations,
governance structures, and partnerships,
we
ensure that
our approach to double materiality strengthens resili-
ence, drives ethical and responsible business conduct,
and creates long
-
term value for our employees, users,
stakeholders, and the wider industry.
===== SIDA 67 =====
Annual report
Page
67
IMPACT
MATERIALITY
IMPACT AREA
TYPE OF
IMPACT
WHERE IN
VALUE CHAIN
ORIGINATES FROM
OR CONNECTS TO
REASONABLE
TIME HORIZON
INVOLVED
THROUGH
DESCRIPTION OF LINK
S1
–
OWN WORKFORCE:
WORKING CONDITIONS
Secure and transparent employment
Positive potential
Own operations
Impact originates from busi-
ness model
Short
-
medium term
Own operations
Arises from Better Collective’s employment model, which provides employees with long
-
term stability
and compensation structures that strengthen their financial security and overall well
-
being
Work
-
life balance
Positive potential
Own operations
Impact originates from busi-
ness model
Short
-
medium term
Own operations
Derives from Better Collective’s strategic focus on flexibility and employee welfare, enabling healthy
work
-
life boundaries that impact employee satisfaction
Health and safety
Negative potential
Own operations
Impact connects to business
model
Short
-
medium term
Own operations
and business rela-
tionships
Connects to Better Collective’s operations and partnerships where limited social interaction and expo-
sure to betting
-
related content may negatively influence employees’ mental health and social con-
nectedness
S1
–
OWN WORKFORCE:
EQUAL TREATMENT AND
OPPORTUNITIES FOR ALL
Gender equality and equal pay for
work of equal value
Negative potential
Own operations
Impact connects to business
model
Short
-
medium term
Own operations
Connects to Better Collective’s operating context in a male
-
dominated industry. Gender imbalance
can affect recruitment, pay equity, and promotion opportunities, reducing equal treatment and ad-
vancement prospects for employees
Diversity
Positive potential
Own operations
Impact originates from busi-
ness model
Short
-
medium term
Own operations
Stems from Better Collective’s commitment to creating an inclusive workplace that values diverse
perspectives. This
foster
belonging, innovation, and motivation among employees, strengthening
both individual development and collective success
S4
–
CONSUMERS AND END
-
USERS:
INFORMATION RELATED IM-
PACT
Privacy
Negative potential
Upstream and own
operations
Impact connects to business
model
Sh
o
rt term
Own operations
and business rela-
tionships
Connects to Better Collective’s affiliate business model, where at
-
risk users may access betting
-
re-
lated content or be referred to partner sportsbooks. Such exposure can lead at
-
risk users or end
-
users
to develop or worsen harmful gambling behaviours
Access to information
Positive potential
Downstream
Impact originates from busi-
ness model
Short term
Own operations
and business rela-
tionships
Originates from Better Collective’s focus on education, harm prevention, and responsible engagement
across its platforms and partnerships. Through advanced monitoring, intervention measures, and edu-
cational initiatives, these efforts drive positive impacts
that help reduce gambling
-
related harm and
promote responsible engagement among users across the betting ecosystem
S4
–
CONSUMERS AND END
-
USERS:
PERSONAL SAFETY
Security of a person
Negative potential
Upstream and own
operations
Impact connects to business
model
Short term
Own operations
and business rela-
tionships
Connects to Better Collective’s affiliate business model, where at
-
risk users may access betting
-
re-
lated content or be referred to partner sportsbooks. Such exposure can lead at
-
risk users or end
-
users
to develop or worsen harmful gambling behaviours
Safer gambling
Positive actual
Upstream and own
operations
Impact originates from busi-
ness model
Short
-
medium term
Own operations
and business rela-
tionships
Originates from Better Collective’s focus on education, harm prevention, and responsible engagement
across its platforms and partnerships. Through advanced monitoring, intervention measures, and edu-
cational initiatives, these efforts drive positive impacts
that help reduce gambling
-
related harm and
promote responsible engagement among users across the betting ecosystem
===== SIDA 68 =====
Annual report
Page
68
IMPACT
MATERIALITY
IMPACT AREA
TYPE OF
IMPACT
WHERE IN
VALUE CHAIN
ORIGINATES FROM
OR CONNECTS TO
REASONABLE
TIME HORIZON
INVOLVED
THROUGH
DESCRIPTION OF LINK
S4
–
CONSUMERS AND
END
-
USERS:
SOCIAL INCLUSION
Responsible marketing
Negative potential
Own operations
Impact originates from
business model
Short
-
medium term
Own operations
Connects to Better Collective’s marketing and affiliate activities. If not carefully managed, advertising
may expose users to misleading or overly persuasive content that can influence betting behaviour or
encourage excessive play
G1
-
BUSINESS CONDUCT
Corporate culture
Positive actual
Own operations
Impact originates from
business model
Short term
Own operations
Strong and consistent shared culture enhances employees’ sense of belonging and purpose, support-
ing well
-
being, inclusion, and responsible governance practices across the group
Corporate culture
Negative potential
Own operations
Impact connects to busi-
ness model
Short term
Own operations
Connects to Better Collective’s growth and acquisition activities, where cultural misalignment or
weak internal cohesion could reduce employee engagement and collaboration, creating disconnects
across offices and negatively affecting workplace cohesion and
well
-
being
Corruption and bribery
Negative potential
Own operations
Impact connects to busi-
ness model
Short term
Own operations
and business re-
lationships
Connects to Better Collective’s global operations and relationships with partners in regions with var-
ying corruption risk. Employees may face unethical proposals, potentially cause discomfort, reputa-
tional harm, and erosion of trust if not properly address
ed
Tax transparency
Positive potential
Downstream
Impact originates from
business model
Short
-
medium term
Own operations
Paying taxes in all operating countries supports public services and economic development,
strengthens community well
-
being, and builds stakeholder trust
Contribution to development of
local communities
Positive actual
Own operations
and downstream
Impact originates from
business model
Short
-
medium term
Own operations
Through educational academies, local partnerships, and employee volunteer initiatives, Better Collec-
tive supports job creation, skills development, and community well
-
being. These activities improve
livelihoods, enhance social inclusion, and foster employe
e pride in the areas where the company op-
erates
E1
-
CLIMATE CHANGE
Climate change mitigation
Negative actual
Upstream, own op-
erations, and down-
stream
Impact connects to busi-
ness model
Short
-
medium
-
long
term
Own operations
and business re-
lationships
GHG emissions generated across Better Collective’s value chain
—
primarily from data
-
centre opera-
tions, digital infrastructure, and international travel contribute to global warming and the intensifica-
tion of climate change
Energy
Negative actual
Upstream, own op-
erations, and down-
stream
Impact connects to busi-
ness model
Short
-
medium
-
long
term
Own operations
and business re-
lationships
Energy used to power operations results in indirect GHG emissions that contribute to climate change
===== SIDA 69 =====
Annual report
Page
69
The
financial
effect
The current financial effects of the identified material
risks and opportunities are limited. As our material IROs
are primarily related to our core business activities and
ability to grow, our initiatives to improve opportunities
and mitigate impacts and
risks are embedded in already
established governance structures.
Consequently
, our
resilience is deemed high within the time horizons ap-
plied in our DMA.
Our financial resilience analysis is
based on qualitative input by internal subject
matter ex-
perts, in
cluding an overall assessment of the mitigating
factors across all IROs, gathered in the DMA process.
Changes to material IROs
In 2024, we updated our DMA process to ensure align-
ment with the European Sustainability Reporting Stand-
ards (ESRS), marking our first year with a fully compliant
Double Materiality Assessment. The material topics de-
scribed were assessed considering sub
-
a
nd sub
-
sub
-
topics as required. Since the 2024 assessment, there
have been no changes to the identified material IROs,
and our methodology and focus areas remain con-
sistent.
While the IROs themselves have not changed, we con-
tinue to monitor and evaluate emerging trends, risks,
and opportunities within our industry. Moving forward,
our focus
is
on deepening our understanding of poten-
tial sector
-
specific impacts and
enhancement
of
the
FINANCIAL
MATERIALITY
RISK OR
OPPORTUNITY
DESCRIPTION OF RISK/OPPORTUNITY
WHERE IN
VALUE CHAIN
S1
–
OWN WORKFORCE
Diversity
Opportunity
A diverse and inclusive workforce fosters innovation, collaboration, and stronger decision
-
mak-
ing. This enhances competitiveness, profitability, and global talent attraction and retention
Own operations
S4
–
CONSUMERS AND
END
-
USERS
Privacy
Risk
Risks from cybercrime and unauthorized access that could compromise user data and disrupt
services. Data breaches may expose users to privacy violations and result in regulatory fines
and loss of stakeholder trust, directly affecting financial performance
Upstream and own
operations
Access to information
Opportunity
Reliable content strengthens user trust and retention, directly supporting recurring revenue
and long
-
term business growth
Own operations
Safer gambling
Opportunity
Integrating safer
-
gambling tools and messaging across platforms and partnerships strengthens
Better Collective’s reputation, attracts investors and employees, and supports long
-
term, re-
sponsible growth by enhancing regulatory trust and industry standards
Own operations and
downstream
G1
-
BUSINESS CONDUCT
Corporate culture
Opportunity
Integrating rather than imposing culture during acquisitions ensures smooth M&A transitions,
preserves key leadership, and secures engagement and continuity across the group
Own operations
Tax transparency
Opportunity
Responsible tax practices strengthen stakeholder trust and reinforce Better Collective’s reputa-
tion as an accountable business. Transparent tax payments across all operating markets pro-
vide a competitive advantage by securing favorable banking relationship
s and investor confi-
dence
Own operations and
downstream
Contribution to development
of local communities
Opportunity
Community engagement strengthens Better Collective’s social license to operate and supports
the development of local talent pipelines. Investing in community well
-
being and employability
enhances reputation, secures access to skilled labor, and reinforces
sustainable growth in the
regions where Better Collective operates
Own operations and
downstream
===== SIDA 70 =====
Annual report
Page
70
management of existing IROs, ensuring that our sustain-
ability practices remain responsive and aligned with our
strategic priorities. While the set of material IROs re-
mained unchanged, we have introduced new KPIs to en-
hance monitoring and measurement of mat
erial IROs
and their effectiveness. The KPIs in question
ar
e clearly
introduced alongside their respective topics.
Identification
&
assessment
of
material IROs
(IRO
-
1)
Since
2022, we have conducted an annual DMA
. In
2024
,
we conducted a comprehensive DMA in accordance with
CSRD and ESRS requirements, including the implemen-
tation of a structured methodology for identifying and
assessing material IROs.
For
the
2025 Sustainability
Statements
,
the results of
last year’s
DMA
were carried
over
following a structured review.
The review was per-
formed to confirm
whether
the
2024 DMA
conclusions
remain valid and applicable
,
considering
developments
in
our
business model, strategy, opera
tions, value chain,
stakeholder landscape, geographic footprint and key
dependencies.
1.
Revisiting 2024 DMA
As
the 2024 DMA forms the foundation for the current
reporting period, it was revisited as part of the 2025
DMA review. The structured scoring system, thresholds,
and assessment criteria implemented in 2024 were re-
tained to ensure methodological consistency a
nd com-
parability.
2.
Evaluation of core
elements
Core
elements crucial to conducting our DMA were re-
assessed by the sustainability reporting team. These in-
cluded our business model, strategy, value chain, stake-
holders, geographic locations, and dependencies
, to
identify any material changes that could affect the out-
come of the review
.
3.
DMA
review for
each
topical ESRS
The sustainability team led the
review
process
for each
topical ESRS.
The Head of Sustainability conducted in-
terviews with internal stakeholders across Finance, Le-
gal, Technology, People
&
Culture,
IR
&
Communica-
tions
. All
topics
were reviewed to assess
whether the un-
derlying
IROs
remain valid, whether new IROs should be
considered, and whether any additional
sustainability
matters
should be
identified
as material.
4.
Internal review
The
outcomes of the DMA review were subject to inter-
nal review by the
Head of Sustainability in close dialogue
with the Sustainability Board, prior to
escalating
to
the
Audit
Committee
.
5.
Audit Committee
review
&
approval
The Audit Committee was presented with
the results of
the DMA review, including
the list of material IROs and
supporting documentation.
The
methodology,
review
process, and
outcomes were discussed, enabling
the
Audit Committee to
raise
questions and feedback be-
fore approving the
DMA for the
2025
reporting period.
Methodology
&
thresholds
Better Collective’s
DMA methodology encompasses the
Group’s own
operations as well as
its
upstream and
downstream value chain. The process identifies and as-
sesses
actual and potential positive and negative im-
pacts
, as well as
sustainability
-
related risks and oppor-
tunities
,
across short
-
,
medium
-
and long
-
term time ho-
rizons.
In line with ESRS requirements, the methodology
combines qualitative and quantitative inputs derived
from internal data, expert judgement, external research,
and stakeholder insights.
The assessment considered the sustainability matters
prescribed in
ESRS 1 (Article 16)
,
as well as other rele-
vant topics identified through the DMA process.
Impacts were assessed based on their
severity
and,
where applicable, their
likelihood.
Severity was assessed
for both actual and potential impacts
,
based on their
scale, scope, and remendability.
Likelihood was as-
sessed only for potential impacts
, reflecting the proba-
bility of their occurrence. Each impact was rated on a
scale from 1 to 5.
In line with ESRS requirements, the
methodology combines qualitative and quantitative
in-
put
derived from internal data, expert judgment, exter-
nal research, and stakeholde
r insights. In our DMA we
considered the topics prescribed in the regulation ESRS
1 (Article 16) and other relevant topics when assessing
IROs.
Risks and opportunities
were
assessed separately
according to their probability of occurrence and poten-
tial financial magnitude.
Ratings were informed by internal data and, where avail-
able and feasible, third
-
party quantitative data, as well
as qualitative input from internal and external stake-
holders. Location
-
specific factors were considered
where relevant. Additional sources, inc
luding pre
-
exist-
ing records, self
-
assessments, document analysis, and
academic research, were used to further substantiate
the assessment.
===== SIDA 71 =====
Annual report
Page
71
Financial risks and opportunities
were
identified and as-
sessed
in relation to
the identified actual and potential
impacts.
The assessment considered impacts from past
events, informed by Better Collective’s own financial
data, as well as
potential impacts from future events
af-
fecting
assets, performance, and value creation, based
on scientific peer
-
reviewed publications, best practices,
and available guidance.
This approach ensures that ma-
terial gross risks and opportunities are assessed in align-
ment with o
ur ERM framework and financial perfor-
mance evaluations
(page
s
47
-
48
).
Decisions making process
In accordance with Better Collective’s sustainability
governance framework, the sustainability reporting
team managed the double materiality assessment
(DMA) process in close collaboration with internal sub-
ject
-
matter experts and, where relevant, external
advis-
ers. The DMA methodology and process are centrally
defined and overseen by the sustainability team to en-
sure consistent application of scoring criteria, thresh-
olds, and expert judgement across the group.
To ensure a shared understanding of the CSRD regula-
tory framework and the identified IROs, the Audit Com-
mittee was provided with a comprehensive walkthrough
of the DMA methodology, thresholds, process, and out-
comes prior to approving the final DMA for the
reporting
period
.
Stakeholder perspectives remain a key component of
Better Collective’s DMA process. The approach distin-
guishes between stakeholders directly affected by the
group’s activities, such as users, employees, and busi-
ness partners, and stakeholders with a broade
r interest
in the group’s sustainability performance, including in-
vestors, regulators, and industry peers.
While the
2025 DMA review did not include new direct
consultations with
external
stakeholders
,
insights from
internal subject
-
matter experts who maintain continu-
ous engagement with these stakeholder groups were
considered
. This ensured that evolving stakeholder ex-
pectations, sector
-
specific impacts, and emerging sus-
tainability
-
related risks were appropriately reflected in
the evaluation of material sustainability matters.
The DMA process
is depicted
on the next page
to
pro-
vide an overview of the ESRS sustainability matters as-
sessed, the responsible internal functions involved, and
the key input parameters applied. The DMA covers the
entire Better Collective group.
When preparing disclo-
sures under
the
ESRS
,
we
assess
all data points on a
point
-
by
-
point basis
, mapping material disclosure re-
quirements.
Non
-
material
data points are also evalu-
ated
,
considering their
significance
to
the group’s activ-
ities
, and
relevance
for
reader
s
of
the
Annual Report
.
===== SIDA 72 =====
Annual report
Page
72
ESRS
DMA PERFORMED
BY
INTERNAL SUBJECT
MATTER EXPERTS
EXTERNAL ADVISORY
& INPUT
INPUT
PARAMETERS USED
FIRST REVIEW
CONDUCTED BY
FINAL REVIEW &AP-
PROVAL BY
MATERIALS FOR AC
APPROVED BY
FINAL DMA
APPROVED BY
E1, E2, E3,
E4, E5
Sustainability team
SVP Technology, IT team, Di-
rector of Group Finance
External expertise developing
environmental analysis and
consultations with server host-
ing facilities
Policies, interviews, workshops
and questionnaires
Head of Sustainability
Director of Group Finance
SVP Finance and CFO
Audit Committee and Board of Di-
rectors
S1
Sustainability team
SVP People & Culture, HR
managers
N/A
Policies, interviews, workshops
and questionnaires
Head of Sustainability
Director of Group Finance
SVP Finance and CFO
Audit Committee and Board of Di-
rectors
S2, S3
Sustainability team
N/A
Advisory by external expert
Policies and interviews
Head of Sustainability
Director of Group Finance
SVP Finance and CFO
Audit Committee and Board of Di-
rectors
S4
Sustainability team
SVP technology, VP IR &
Comms., VP Legal, Director of
Regulatory Compliance, Direc-
tor IT
N/A
Policies, interviews, workshops
and questionnaires
Head of Sustainability
Director of Group Finance
SVP Finance and CFO
Audit Committee and Board of Di-
rectors
G1
Sustainability team
VP Legal, Director of Regula-
tory Compliance,
VP IR & Comms., SVP People &
Culture
N/A
Policies, hard and soft law ap-
plying to the Better Collective
Group and value chain actors
Head of Sustainability
Director of Group Finance
SVP Finance and CFO
Audit Committee and Board of Di-
rectors
===== SIDA 73 =====
Annual report
Page
73
Polic
y
overvie
w
(MDR
-
P)
Our policies
for our
identified material sustainability
matters
are in place to prevent, mitigate, and remediate
actual and potential impacts, address risks, and pursue
opportunities.
The most senior person accountable for implementation
continuously monitors effectiveness, with actions re-
ported alongside
the
relevant disclosures. Policies re-
lated to specific sustainability matters are disclosed un-
der each topic on the following pages.
Annual report
Page
73
===== SIDA 74 =====
Annual report
Page
74
POLICY
SCOPE OF COVERAGE
SCOPE OF POLICY
RESPONSIBLE FOR
IMPLEMENTATION
INTERNATIONALLY
RECOGNIZED
INSTRUMENTS
AVAILABILITY
MATERIAL TOPIC COVERED
ANTI
-
HARASSMENT
•
Zero
-
tolerance stance on discrimination and harassment
•
Framework addressing/preventing workplace harassment (verbal, visual or physical)
•
Emphasizes confidentiality and allows anonymous reporting
•
Protects affected and reporting parties
•
Disciplinary actions
Group
SVP People & Culture
Corporate intranet •
Working conditions
•
Equal treatment and opportunities
for all
•
Corporate culture
CODE OF CONDUCT •
Sets minimum standards for integrity based on international principles
•
Violations reported through various channels, including anonymous whistleblower
system
•
Respects human and labour rights
•
Promotes anti
-
discrimination and anti
-
harassment standards
•
Prohibits corruption and complies with anti
-
bribery laws
•
Prioritizes data privacy and confidentiality in adherence to relevant laws
•
Ensures the highest standards of ethical behavior
•
Fosters a respectful, inclusive, and safe working environment
•
Promotes and supports safer gambling and prevention of gambling
-
related harm
Group, business partner-
ships
Board of Directors •
The OECD Guidelines for
Multilateral Enterprises
•
The UN Guiding Principles
on Business and Human
Rights
•
The International Bill of
Human Rights
•
ILO Declaration on
Fundamental principles and
Rights at work
•
General Data Protection
Regulation (GDPR)
Corporate intranet and
corporate website
•
Working conditions
•
Equal treatment and opportunities
for all
•
Corporate culture
•
Corruption and bribery
•
Information related impacts
consumers and end
-
users
•
Personal safety of consumers and
end
-
users
•
Safer gambling
•
DATA ETHICS •
Commits to legal compliance, ethical values, and transparency in all data practices
•
Prioritizes user welfare, dignity, fairness, and non
-
discrimination in data processing
•
Protects privacy and both personal and non
-
personal data in line with EU and
national laws
•
Implements robust technical and organizational measures to ensure data security
•
Establishes clear accountability and integrates data ethics values into IT services and
partnerships
•
Promotes responsible innovation and safer gambling through ethical data use
Group
Board of Directors
The group’s voluntary commit-
ment to ethical principles re-
garding data use. Influenced by
OECD principles, existing pri-
vacy legal framework and cor-
porate social responsibility.
Corporate intranet and
corporate website
•
Corporate culture
•
Information related impacts
consumers and end
-
users
•
Personal safety of consumers and
end
-
users
•
Social inclusion of consumers and
end
-
users
•
Safer gambling
D
IVERSITY, EQUITY
AND INCLUSION
•
Promote
diversity, equity, and inclusion across all entities within
the
Better Collective
group
•
Gender balance at Board and management levels
•
Equal opportunity and non
-
discrimination
•
Inclusive
recruitment, development, and workplace practices
•
Comply with the Danish Gender Balance Act and Danish Recommendations on Cor-
porate Governance
Group
Board of Directors
Corporate intranet and
corporate website
•
Working conditions
•
Equal treatment and opportunities
for all
GAMBLING ADVERTISING •
Ensures adherence to all compliance and regulatory requirements in all active
regions
•
Upholds the highest standards of social responsibility and prohibits targeting of
vulnerable groups
•
Requires transparency, honesty, and clarity in all advertising
•
Prohibits misleading claims, false information, and any suggestion of guaranteed
winnings
•
Provides oversight and guidance with monitoring and enforcement by compliance
teams
Group
Director of Regulatory
Compliance
Varies based on local regula-
tions
Corporate intranet •
Corporate culture
•
Personal safety of consumers and
end
-
users
•
Social inclusion of consumers and
end
-
users
===== SIDA 75 =====
Annual report
Page
75
POLIC
Y
SCOPE OF COVERAGE
SCOPE OF POLICY
RESPONSIBLE FOR
IMPLEMENTATION
INTERNATIONALLY
RECOGNIZED
INSTRUMENTS
AVAILABILITY
MATERIAL TOPIC
COVERED
HEALTH AND SAFETY •
Ensures a safe and healthy working environment for employees
•
Committed to compliance with relevant health and safety legislation and regulations
•
Focuses on preventing workplace injuries: both physical and sociopsychological
Local level
SVP People & Culture
Local laws related to labor, em-
ployment, etc.
Corporate i
ntranet •
Working conditions
HUMAN RIGHTS •
Respects human and labor rights: prohibits forced labor, child labor, and human traffick-
ing
Group and business part-
ners
SVP People & Culture •
The OECD Guidelines for
Multilateral Enterprises
•
The UN Guiding Principles
on Business and Human
Rights
•
The International Bill of
Human Rights
•
ILO Declaration on
Fundamental principles and
Rights at work
Corporate intranet
and
corporate website
•
Working conditions
•
Equal treatment and opportunities
for all
•
Personal safety
•
Corporate culture
•
Social inclusion
PRIVACY EXTERNA
L •
Safeguards individual privacy: Outlines measures to protect individuals' privacy rights
and freedoms by ensuring responsible data handling
•
Transparent data practices: Describes the processes for collecting and using personal
data with transparency, aiming to secure consent whenever feasible
•
Data protection framework: Establishes the mechanisms and arrangements in place to
ensure the secure and lawful handling of personal data
Group
Director of Regulatory
Compliance
•
General Data Protection
Regulation (GDPR)
Corporate website •
Information
-
related impacts
•
Corporate culture
PRIVACY INTERNAL •
Empowers employee privacy rights: Outlines the rights of employees under GDPR, en-
suring they are informed about how their personal data is collected, used, and pro-
tected within the organization.
•
Outlines employee responsibilities: Provides clear guidelines on employees’ roles in
safeguarding personal data, emphasizing the importance of compliance with GDPR
principles when handling data.
•
Ensures compliance and accountability: Establishes procedures and practices to align
with GDPR requirements, promoting a culture of compliance and accountability in data
processing activities.
•
Promotes security and best practices: Highlights the need for robust data security
measures and encourages adherence to best practices, ensuring the protection of per-
sonal data in all business operations.
Group
Director of Regulatory
Compliance
•
General Data Protection
Regulation (GDPR)
Corporate intranet •
Working conditions
•
Corporate culture
SAFER GAMBLING EXTERNAL •
Educates users on safer gambling, emphasizing gambling as entertainment, not income
•
Provides guidance and resources to identify and prevent gambling
-
related harm
•
Promotes responsible gambling through educational content, disclaimers, and age
-
gat-
ing
•
Uses Mindway AI tools to monitor, profile, and identify at
-
risk users, supporting safer
gambling interventions
•
Collaborates with operators, regulators, and suppliers to enhance user protection and
industry standards
•
Supports industry
-
wide initiatives and partnerships to promote safer gambling globally
•
Encourages users showing signs of gambling harm to seek professional help
Group and business part-
ners
Senior Director of Group
Media
Varies
based on local regula-
tions
Corporate website •
Safer gambling
•
Personal safety
===== SIDA 76 =====
Annual report
Page
76
POLIC
Y
SCOPE OF COVERAGE
SCOPE OF POLICY
RESPONSIBLE FOR
IMPLEMENTATION
INTERNATIONALLY
RECOGNIZED
INSTRUMENTS
AVAILABILITY
MATERIAL TOPIC
COVERED
SAFER GAMBLING INTERNAL •
Educates employees about gambling risks and how to seek support
•
Encourages responsible gambling practices, emphasizing entertainment over finan-
cial necessity
•
Provides resources for employees to recognize signs of problem gambling
•
Offers tools like self
-
exclusion and self
-
tests to help manage gambling habits
•
Promotes a supportive environment for employees to discuss gambling concerns
confidentially
•
Supports employees struggling with gambling issues via HR and management assis-
tance
•
Regular training on safer gambling for all employees, including new hires
•
Ensures continuous improvement of the policy through the Safer Gambling Compli-
ance Council
•
Provides access to external help through country
-
specific resources
Group
Senior Director of Group
Media
Corporate intranet •
Working conditions
•
Safer gambling
SUSTAINABILITY •
Commitment to sustainable actions across environmental, social, and governance ar-
eas
•
Contributes positively to societies we operate in
•
Fosters an inclusive, fair and diverse workplace, eliminating discriminatory practices
•
Support user welfare through education, safer gambling support and partnerships
•
Helps users navigate the iGaming world responsibly
•
Contributes positively to local communities through engagement and education
•
Ensures ethical operations and compliance with laws and standards
•
Maintains transparency and long
-
term ESG performance
Group
Board of Directors •
UN Global Compact
•
OECD Guidelines for
Multinational Enterprises
•
UN Guiding Principles on
Business and Human Rights
Corporate website and
corporate
intranet
•
Working conditions
•
Equal treatment and opportunities
for all
•
Corporate culture
•
Personal safety of consumers and
end
-
users
•
Information related impacts
•
Social inclusion
•
Safer gambling
•
Tax transparency
•
Contribution to local communities
TAX POLICY •
Ensures full compliance with national and international tax laws and guidelines
•
Manages and mitigates financial and reputational tax risks through transparent tax
governance
•
Pursues a responsible, competitive tax level aligned with genuine business activities
and economic substance
•
Prohibits tax avoidance, use of tax shelters, or high
-
reputation
-
risk structures
•
Promotes open communication and engagement with tax authorities, ensuring trans-
parency of the group’s effective tax rate
•
Reviewed annually, material risks reported periodically
•
Developed considering stakeholder expectations for transparency and responsible
conduct
Group
Board of Directors
Corporate website and
corporate
intranet
•
Tax transparency
•
Corporate culture
•
Contribution to local communities
WHISTLEBLOWER •
Encourages confidential reporting of legal violations and misconduct
•
Covers issues like fraud, harassment, and financial crimes
•
Excludes personal employment matters
•
Allows anonymous reports, but names are encouraged for follow
-
up
•
Protects whistleblowers from retaliation
•
Reports are handled by the Chair of the Audit Committee
Group
Board of Directors
Corporate website and
corporate
intranet
•
Working conditions
•
Equal treatment and opportunities
for all
•
Corporate culture
•
Personal safety of consumers and
end
-
users
•
Corruption and bribery
===== SIDA 77 =====
Annual report
Page
77
Workforce IROs (SBM
-
3)
78
Policies (S1
-
1)
78
Engaging with our workforce about impacts
(S1
-
2)
80
Process to remediate impacts (S1
-
3)
80
Acting on material IROs (S1
-
4)
81
Targets (S1
-
5)
83
Gender distribution (S1
-
6)
84
Geographic distribution (S1
-
6)
84
Employment characteristics (S1
-
6)
85
Employee turnover (S1
-
6)
86
Gender distribution other management (S1
-
9)
87
Age distribution (S1
-
9)
87
Health & safety (S1
-
14)
88
Work
-
life balance (S1
-
15)
89
Compensation (S1
-
16)
90
Discrimination reports & complaints filed (S1
-
17)
91
Consumers & end
-
users IROs (SBM
-
3)
92
Policies (S4
-
1)
93
Engaging with consumers & end
-
users (S4
-
2)
93
Process to remediate impacts & channels to
raise concern (S4
-
3)
94
Acting on material IROs (S4
-
4)
94
Targets (S4
-
5)
97
Social
===== SIDA 78 =====
Annual report
Page
78
W
orkfor
ce
(S1)
Workforce IROs
(SBM
-
3)
Our business is based on specialized expertise and inno-
vation,
which
is why we
consider
people a core element
in everything we do. Therefore, we are committed to
fostering and
upholding
an inclusive, professional, and
diverse workplace by implementing socially responsible
conduct
and eliminating all discriminatory practices.
Our
workforce may be and are exposed to different impacts
due to our operations, as shown in the IRO
overview on
pages
67
-
69
. Particularly, the challenges and opportuni-
ties of our industry may introduce potential negative im-
pacts, while our initiatives aim to benefit our workforce.
Most of our impacts originate from our business model,
which is built on direct employment and kn
owledge
-
based work, while others connect to the operational
context of a fast
-
paced, digital, and male
-
dominated in-
dustry.
The material topics covered in this ESRS include secure
and transparent employment, work
–
life balance, health
and safety, gender equality, and diversity, all identified
as impacting our workforce. Secure and transparent em-
ployment and work
–
life balance imp
acts originate from
our business model, which
emphasizes
long
-
term em-
ployment relationships and flexibility, whereas health
and safety and gender
-
equality impacts connect to our
business model through the industry environment in
which we operate.
We priori
tize secure and transparent
work opportunities that align with regional and local
conditions and legal requirements. This approach im-
pacts job stability
and
foster
s
a supportive and moti-
vated work environment.
Our approach aligns
with our
core values and allow our group to reduce turnover
rates, increase employee satisfaction, reduce reputa-
tional risks, and enhance productivity.
Our workforce benefits from high flexibility in choosing
when and where to work, supported by clear workplace
guidelines and remote work options. These practices
produce positive impacts such as improved work
–
life
balance and job satisfaction for employees
. These rela-
tionships illustrate how workforce
-
related risks and op-
portunities directly influence our strategic resilience and
operational performance.
While insights from the iden-
tified impacts inform how we adapt our employment
practices and strengthen f
lexibility to ensure that our
business model continues to evolve with workforce ex-
pectations.
Understanding the importance of health and safety, we
are committed to continuously fostering safe working
environments. Our potential negative health
-
and
-
safety
impacts connect to our business model through expo-
sure to betting
-
related content and limited
social inter-
action in remote roles
.
Better Collective has assessed
that employees working daily with sports
-
and betting
-
related content may face higher risks of harm. While the
overall negative impact on physical health is low, the de-
mands of a high
-
paced
work environment may also neg-
atively impact mental well
-
being. These impacts interact
with our strategy and business model, potentially influ-
encing employee satisfaction and productivity. Findings
from our DMA are used to adjust workload management
and we
llbeing programmes, thereby integrating work-
force
-
impact results into
our
strategic planning
and op-
erations
.
Operating in the digital sports
-
media sphere, we are
part of a male
-
dominated industry, which presents im-
pacts related to gender equality and diversity. These im-
pacts interact with our strategy and highlight structural
challenges in
recruitment and
guide our diversity and in-
clusion initiatives to attract and retain talent. At the
same time,
our strategic commitment to diversity en-
hances our competitive edge by leveraging creativity
and innovation from diverse perspectives.
We have as-
sessed our business mode
l, activities, and geographic
operations and found no risks of
labor
or child
labor
, and
none of the identified negative impacts are assessed to
be systemic. The scope of this disclosure includes all
Better Collective employees
—
both full
-
time and part
-
time
,
who can be materially impacted by our operations
and business relationships.
Policies
(
S1
-
1
)
Anchored in our values is a steadfast commitment to re-
specting and protecting the human and labor rights of
our workforce. Our human
-
rights commitments are set
out in the Human Rights Policy, Sustainability Policy,
and Code of Conduct, which together defin
e the princi-
ples that guide employment
-
related decisions. Further
information on our human rights commitments is pro-
vided on pages
62
and
1
97
of the appendices
.
O
ur workforce
-
related policies collectively govern
the
material topics identified
—
secure and transparent em-
ployment, work
-
life balance, health and safety, gender
equality, and diversity.
For a ful overview of our
policies
see
pages
74
-
76
.
Our policy framework applies group
-
wide and governs how we manage workforce IROs
, and
w
e are committed to ensuring that our policies adhere
to internationally recognized standards.
===== SIDA 79 =====
Annual report
Page
79
Ou
r
Code of Conduct sets expectations of integrity, re-
spect, and accountability in daily operations, including
fair and transparent employment conditions and the
promotion of
inclusion and diversity.
Our
Human Rights
Policy explicitly recognizes our corporate responsibility
to operate with respect for human rights, ensuring equal
treatment and dignity for all employees and prohibiting
any form of discrimination.
Our
Sustainability Policy em-
beds social responsibility in our business model, com-
mitting us to long
-
term employment stability and flexi-
bility that
supports
work
-
life balance.
We take all re-
ports of discrimination, harassment, unlawful actions, or
any misconduct that does not align with our Code of
Conduct and Human Rights Policy seriously. Where ad-
verse human
-
rights impacts are identified, we seek to
provide or enable access to remedy.
This is supported by the Whistleblower Policy, which of-
fers confidential, anonymous reporting channels under
the oversight of the Audit Committee Chair and guaran-
tees protection from retaliation. Reports can also be
submitted through HR representatives. Th
rough both
channels, investigations are conducted, impacts are mit-
igated, and insights are integrated into our policies and
management systems to support future prevention.
We
maintain a management system for workplace accident
prevention and well
-
being th
rough the Health and
Safety Policy and our Safer Gambling Policy, which spe-
cifically mitigate risks associated with exposure to gam-
bling
-
related content. These policies directly address
the negative potential impacts connected to our busi-
ness model and outline preventive measures, training,
and access to professional support for employees.
We also uphold our Internal Privacy Policy, which de-
fines employees’ rights and responsibilities regarding
personal data in compliance with the GDPR. The policy
ensures that data processing related to employment,
performance, and well
-
being follows strict
standards of
confidentiality and security.
Our Anti
-
Harassment
Policy, together with the Code of Conduct and Human
Rights Policy, demonstrates our zero
-
tolerance ap-
proach to discrimination, harassment, and any form of
disrespectful behaviour.
These policies establish clear principles for appropriate
workplace conduct, reporting and investigation proce-
dures, and managerial responsibilities. Inclusion and
equal
-
opportunity commitments are further embedded
in the Sustainability Policy and the DEI
Policy
, which
articulates our shared commitment to fostering a di-
verse workforce and inclusive culture where all perspec-
tives are welcomed and respected.
We
hav
e
not identified specific groups within
our
work-
force at particular risk of vulnerability and therefore
no
additional policies
are established
in this regard. All em-
ployees are covered by the policies described above,
which together govern the management of material
IROs identified under ESRS S1.
POLICY
SCOPE
SECURE AND TRANSPARENT
EMPLOYMENT
WORK
-
LIFE BALANCE
HEALTH AND SAFETY
GENDER EQUALITY
DIVERSITY
Anti
-
harassment
Group
X
X
X
Code of Conduct
Group
X
X
X
X
X
Diversity, equity
and inclusion
Group
X
X
Health and safety
Group
X
X
Human rights
Group
X
X
X
X
Privacy internal
Group
X
Safer gambling
internal
Group
X
Sustainability
Group
X
X
X
X
Whistleblower
Group
X
X
X
X
X
===== SIDA 80 =====
Annual report
Page
80
E
ngag
ing with our
workforce
about
impacts (
S1
-
2)
W
e are committed to continuous engagement with our
workforce, ensuring that employees have a voice in
shaping our workplace environment and informing de-
cisions that affect them. Our approach is built on struc-
tured engagement processes, transparency, and ope
n
communication, allowing us to identify and address ac-
tual and potential impacts on our workforce. Engage-
ment occurs through formal and informal channels
,
in-
cluding surveys, events, and workshops. Regular touch-
points such as
our quarterly “Huddle”,
onboarding
as
well as
exit surveys, and leadership Q&A sessions further
strengthen our commitment to listening and acting on
employee input.
New employees, including those welcomed from ac-
quired companies, are introduced to Better Collective
and our policies through an extensive onboarding pro-
gram.
We conduct biannual development dialogues
(Better Development Dialogue BDD)
between
managers
and
employees
to discuss
each employee's
performance
and further development. Our leadership development
initiative ensures
our
managers’
continuous professional
development
, enabling
them to identify and
address
challenges in their teams.
By investing in lead
ership ca-
pabilities, we strengthen communication and the quality
of engagement at team level. The
People & Culture
team
, supported by
Group
Management, holds opera-
tional responsibility for
employee engagement and
en-
sures
that feedback is integrated into
decision
-
making
.
Engagement survey
We use multiple channels to gather insights directly
from employees. The Better Workplace Evaluation,
which is common for all our offices, helps determine im-
provement areas and shape our people
-
focused priori-
ties. In 2025, participation reached 82%, exceed
ing
benchmarks for similar
-
sized companies, and produced
an engagement score of 52%
indicating mixed employee
experiences, which provide valuable input for prioritiz-
ing improvement actions.
Following the survey, the People & Culture team consol-
idates results into actionable reports shared with man-
agement and employees. The
consolidated
report is dis-
tributed
group
-
wide, while managers with four or more
team respondents receive team
-
level reports and guid-
ance on discussing results. Workshops are optional but
encouraged. Feedback is incorporated into project plan-
ning, workplace priorities, and strategic decision
-
mak-
i
ng by the People & Culture team in collaboration with
the Executive
team
. Effectiveness
of these
actions
are
assessed by comparing
year
-
on
-
year results, tracking
trends and
participation rates
over time.
Engagement groups
We have
four Employee Resource Groups (ERGs) fo-
cused on
mental
well
-
being and community building
,
culture
and celebrations
, gender
balance
, and the
iGam-
ing industry and partnerships
.
These groups
have been
temporarily inactive while we
strengthen our sustaina-
bility framework
and establish new structures for
meas-
uring success and
impact.
We acknowledge their value in fostering employee
-
driven initiatives and are assessing how to relaunch
structured engagement groups aligned with our strate-
gic priorities. Currently, we do
not have
dedicated
mechanisms
to
gather insights
specifically
from poten-
tially vulnerable or
marginalized
groups.
Process to
remediate
impacts
(S1
-
3)
We maintain structured processes to remediate nega-
tive impacts on our workforce and to ensure that em-
ployees have accessible and confidential channels to
raise concerns. These processes include internal griev-
ance mechanisms and an externally operated whist
le-
blower system, both designed to address issues related
to working conditions, conduct, or other employment
matters in a fair and timely
manner. Grievance
mecha-
nisms are managed by the People & Culture team, allow-
ing employees to raise concerns directly o
r through local
HR representatives. Employees can also submit feed-
back through the Better Workplace Evaluation or con-
tact People & Culture at any time. Each case is assessed
individually, and the Legal team is involved when appro-
priate. All cases are tracked and documente
d, and ag-
gregated data is periodically reviewed to identify trends
and strengthen preventive measures.
Our Whistleblower System, operated by an independent
third party, provides a confidential and anonymous
channel for reporting serious concerns such as discrimi-
nation, harassment, or breaches of the Code of Conduct.
The system is available via the intranet,
company web-
site, and employee handbooks, ensuring equal access
across all locations. The Audit Committee Chair over-
sees the process and ensures that cases are docu-
mented, investigated, and
remediate
in collaboration
with the People & Culture and Legal tea
ms.
We apply a
zero
-
retaliation policy that protects all employees who
raise concerns in good faith. Managers and leaders are
required to report any concerns they observe or are
made aware of, ensuring consistent accountability
throughout the
organization
. Effectiveness of our griev-
ance and whistleblower channels is monitored through
employee surveys, qualitative feedback, and training
completion data, which help assess awareness, trust,
and accessibility. Results are reviewed annually by the
People & Cult
u
re and Legal teams to ensure continuous
improvement and compliance with local legislation.
===== SIDA 81 =====
Annual report
Page
81
Acting
on material
IROs
(
S1
-
4)
We manage our material impacts, risks, and opportuni-
ties through coordinated actions that align with our
group policies and engagement processes, ensuring
that workplace practices support employee well
-
being,
inclusion, and transparency. The following sect
ions de-
scribe key actions, how effectiveness is monitored, and
how resources are allocated to address the identified
IROs. While we have
not yet established formalized ac-
tions across all material IROs
, we intend
to implement
these
,
where relevant
,
in the coming years.
Working conditions
We
are committed to ensuring good working conditions
and
safe
-
guarding work
-
related rights in compliance
with existing regulations and
recognized
human rights
standards. Our focus
is
on maintaining a high standard
of workplace practices that align with legal require-
ments and ethical guidelines, ensuring that all employ-
ees are treated fairly and
respectfully
.
Secure
&
transparent employment
Our business model supports secure and transparent
employment by providing long
-
term stability, fair com-
pensation, and opportunities for professional growth.
This impact originates from how we operate, ensuring
that employment relationships contribute posi
tively to
employees’ financial security and overall well
-
being.
Most
of our workforce consists of full
-
time, trained em-
ployees on long
-
term contracts, which minimizes poten-
tial negative impacts on employment security. All em-
ployees receive written contract
s with clear terms and
benefits aligned with local legislation and market bench-
marks. Compensation structures are tailored to regional
economic realities and support financial stability, includ-
ing hybrid
-
working arrangements adapted to local con-
ditions.
We maintain transparency in employment terms
through consistent communication and biannual devel-
opment dialogues, which align professional ambitions
with company goals. Managers are trained to support
performance and career progression, promoting a cul-
ture
o
f feedback and continuous learning.
We
monitor
job stability through
employee
turnover
and
qualitative
employee feedback.
In 2025, we ex-
panded our reporting on workforce turnover to distin-
guish between
dismissals and voluntary resignations
,
providing a more nuanced understanding of employ-
ment dynamics and working conditions. This distinction
supports a clearer assessment of whether workforce
changes are primarily driven by organizational decisions
or employee
-
initiated mobility, which is rele
vant for
evaluating job security and employment pra
ctices.
I
n-
sights guide improvements in our HR processes and are
reviewed by the People & Culture team. Resources for
these initiatives are embedded within the
People & Cul-
ture
budget and managed locally to ensure
consistency.
Work
-
life balance
We promote a work culture that enables employees to
maintain healthy boundaries between their professional
and personal lives while supporting productivity and
collaboration. Our approach is structured through
group
-
wide Work
-
from
-
Home (WFH) Guiding Princi
ples
that define expectations for hybrid work. These princi-
ples ensure that flexibility is applied consistently across
teams, balancing individual preferences with collective
efficiency. Employees coordinate remote work with
their managers, spend at least
part of the week in the
office, and uphold
our
values and policies regardless of
work location.
To support a sustainable home
-
working environment,
employees receive office equipment such as screens,
keyboards, and chairs, and a monthly internet allow-
ance. Our WFH Abroad Policy allows employees to work
temporarily from another country under clearly de
fined
conditions regarding eligibility, insurance, and compli-
ance, ensuring that flexibility remains compatible with
legal and tax frameworks.
E
mployees are also entitled to
family
-
related leave in accordance with their employ-
ment terms and conditions.
N
o
new initiatives were
launched in 2025,
however,
we continue to apply and
refine our established framework for flexibility and
work
-
life balance, which contributes to high satisfaction,
retention, and reduced turnover costs. Effectiveness is
monitored through engagement surveys, employee
feedback, absent
eeism, and turnover metrics.
Health
&
safety
We promote a safe, healthy, and supportive workplace
that prioritizes the physical and mental well
-
being of
employees. As a digital company without physical pro-
duction activities, the overall risk of work
-
related inju-
ries is low, yet health and well
-
being
remain essential for
engagement and retention. Our groupwide health and
safety approach combines global governance with local
implementation. Each office follows policies aligned
with national regulations and market standards, while
trained staff oversee f
irst
-
aid preparedness, fire preven-
tion, workplace evaluations, and evacuation procedures.
Managers receive training to recognize early signs of
stress and to promote balanced workloads through reg-
ular check
-
ins and open dialogue, supporting early in-
tervent
ion and a healthy work culture.
Our People & Culture team manages a centralized
health
-
and safety management system that tracks inci-
dents across all offices and maintains a shared reposi-
tory for documentation. Local office teams optimize
workspace arrangements to meet safety standards,
and,
where legally required, employee
-
elected representa-
tives support compliance and a culture of prevention.
Health management includes mandatory insurance cov-
erage and collaboration with external experts to ensure
legal compliance and competitive benefit
s. In certain re-
gions, additional coverage is provided to match local
market standards.
===== SIDA 82 =====
Annual report
Page
82
In 2025 we continued to strengthen our approach
through the Better Workplace Evaluation, and through
the Workplace Assessment (APV) in our Copenhagen
office. Both surveys identify risks and improvement op-
portunities related to psychosocial and physical con
di-
tions. Results are reviewed by the People & Culture team
with Senior Management, leading to action plans shared
with employees. Confidentiality is ensured through
anonymized reporting.
Mental
-
health protection remains a key focus, especially
for employees exposed to gambling
-
related content. To
mitigate these risks, all employees complete mandatory
Safer Gambling training and have access to the Gama-
lyze self
-
assessment tool, confidential
HR support, and
anonymous whistleblowing channels. Absence and well
-
being indicators are monitored to identify trends and
guide action. Where needed, HR and managers hold di-
alogues to adjust workloads or conditions. All data col-
lected through health, safe
ty, and well
-
being programs
is processed under our Internal Privacy Policy to ensure
compliance with GDPR and to protect employees’ per-
sonal information, thereby reinforcing trust and psycho-
logical safety.
Equal treatment
&
opportunities for all
Gender equality
&
equal pay for work of
equal value
Operating within a male
-
dominated industry, we con-
tinue to address gender imbalance and promote trans-
parency in pay and progression. Actions include uphold-
ing the DI Gender Diversity Pledge and UN Women’s
Empowerment Principles and conducting periodic pay
-
gap analyses to identify areas for improvement. Recruit-
ment practices emphasize inclusivity through gender
-
neutral job language, structured assessments, and man-
datory bias
-
awareness training for hiring managers.
In 2025, we strengthened
the quality and comparability
of our pay transparency disclosures by introducing
ad-
justed gender pay gap and adjusted annual remunera-
tion ratio calculations
. These adjusted measures normal-
ize the data by excluding outliers, including the Execu-
tive Leadership Team and non
-
standard severance pay-
ments that are not representative of regular remunera-
tion practices. This approach improves the reliability of
pay gap
insights and supports a clearer assessment of
pay equity across the workforce.
To further enhance comparability and actionability, the
adjusted gender pay gap is
disaggregated by country
,
reflecting differences in local labor markets, role com-
position, and pay practices that influence the overall
group average.
Th
ese
refinements provide
a more accu-
rate basis for identifying structural drivers of pay differ-
ences
, and the
enhanced breakdown supports more tar-
geted dialogue and actions at the local level, while main-
taining an aggregated group
-
level overview.
Diversity criteria are also integrated into succession
-
planning to strengthen equal access to advancement.
Progress is tracked through diversity metrics, leadership
representation, and employee
-
survey results. While no
new gender
-
specific initiatives were
introduced in 2025,
our established framework continues to guide gender
equality practices and to support measurable progress
toward gender balance at all levels of the Better Collec-
tive group.
Diversity
We advance diversity through structured, ongoing ac-
tions that foster a diverse and inclusive workplace where
different perspectives strengthen creativity, collabora-
tion, and collective success. Building on our DEI
Policy
,
we embed inclusivity into every stage of
the employee
experience, from recruitment and onboarding to devel-
opment and engagement.
Key actions include diversity
-
aware recruitment prac-
tices that ensure inclusive job advertisements, balanced
shortlists, and bias
-
free assessments through structured
interviews and personality testing. Hiring managers and
HR teams receive mandatory unconsc
ious
-
bias training,
while all employees complete mandatory unconscious
-
bias and anti
-
harassment training within their first year
of employment, reinforcing inclusive conduct across all
levels. While no new global initiatives were introduced
in 2025, we mai
ntained our established framework of di-
versity actions and awareness initiatives such as diver-
sity campaigns
,
ensuring continuous progress through
engagement tracking and leadership accountability.
Despite our efforts, gender representation in
“
other
management
level
”
remains below our target, with 14%
of leadership positions held by the underrepresented
gender, while women made up 3
2
% of our total work-
force in 2025. Results that underscore the need for con-
tinued action.
Our
targets are aligned with policy goals to improve di-
versity and gender equality. The developments are
available for all employees to track the status of the tar-
gets on the intranet. However, they are not involved oth-
erwise. Nevertheless, by embedding gende
r equality
and diversity into our business strategy, we remain com-
mitted to fostering a workplace where all employees
have equal opportunities to succeed while we seek to
leverage the benefits of diversity to drive long
-
term
business growth and innovati
on.
===== SIDA 83 =====
Annual report
Page
83
Targets
(S1
-
5)
Targets have been established to address the identified
IROs related
to the topic
of
equal treatment and oppor-
tunities for all
. Better Collective has updated its targets
for gender diversity at Board and “Other management”
levels to align with Danish statutory requirements, as
described in the Corporate Matters chapter.
Accord-
ingly, Better Collective has set a target of at least
40%
representation of the underrepresented gender on the
Board
and
35% representation of the underrepresented
gender at “Other management” levels by 2026
, bringing
the timeline forward from the previously stated target
year of 2027. The gender diversity target for the group
remains
unchanged
.
The Executive Management, the Sustainability Board,
and the respective policy owners conduct qualitative re-
views to assess the effectiveness of policies and actions
addressing IROs. These reviews ensure ongoing align-
ment with evolving priorities and suppor
t continuous
improvement in the management of sustainability
-
re-
lated matters.
We have
not established specific targets
for other identified IROs as priorities and strategic focus
may evolve over time in response to business needs and
industry
-
specific deve
lopments. This approach reflects
our
commitment to maintaining a targeted and materi-
ality
-
driven sustainability strategy
.
===== SIDA 84 =====
Annual report
Page
84
Gender distribution
(S1
-
6)
Geographic
distribution (S1
-
6)
Number of own employees (head count) by gender
2025
2024
Male
943
1,079
Female
44
8
478
% of underrepresented gender
32%
31%
Total
e
mployees
1,391
1,557
Number of own employees (head count)
2025
2024
United States
197
202
Serbia
368
422
Denmark
187
229
Others
639
704
Total
e
mployees
1,391
1,557
Accounting
principles
Gender distribution
The total headcount of employees at Better Col-
lective is determined by summing the
active
em-
ployee numbers across all countries of operation,
excluding freelancers and contractors.
Active em-
ployee
s
include employees whose contract has
been terminated and
employees
on garden leave.
This data is as of 31 December 202
5
.
Gender distribution refers to the number of em-
ployees whose legally recognized gender is female
or male. At Better Collective A/S, the gender dis-
tribution is calculated by adding the total head-
count of women and men separately across all
countries of opera
tion while excluding freelancers
and contractors. These totals are then divided by
the overall headcount for women and men, re-
spectively. This data is as of 31 December 202
5
.
Geographic distribution
The total number of employees by country for
countries
where
Better Collective
has 50 or more
employees
represents
at least 10% of its total num-
ber of employees.
“
Other
s
” covers
countries with
less than 50 employees and representing less than
10% of the total number of employees combined.
The geographic distribution of employees is deter-
mined by summing the total headcount across the
specific geographical locations where
we
operate
and is
based on data from 31 December 202
5
.
===== SIDA 85 =====
Annual report
Page
85
Employment
characteristics (S1
-
6)
Our workforce consists of permanent employees, which
helps attract and retain top talent, creating a knowl-
edgeable and experienced team. This allows us
to invest
continuously in employee development,
and the recip-
rocal approach ensures continuity and operational ef-
fectiveness.
Accounting principles
Employment characteristics
Permanent employees are defined as employ-
ees with an indefinite employment contract.
This category includes student assistants and
trainees but excludes freelancers and contrac-
tors. The total number of permanent employees
at Better Collective is calculated
by summing
the count of permanent employees across all
our locations. This calculation is based on data
from 31 December 202
5
.
Temporary employees are
categorized
as em-
ployees whose employment is tied to the com-
pletion of a specific project or has a predeter-
mined duration. This category includes interns
but excludes freelancers and contractors. The
total number of temporary employees at Better
Collective is calcula
ted by aggregating the num-
bers of temporary employees across all our lo-
cations. This calculation is based on data from 31
December 202
5
.
Non
-
guaranteed employees are defined as em-
ployees who are employed without a guarantee
of a minimum or fixed number of working hours.
Employment characteristics
2025
2024
Total employees (head count)
1,391
1,557
-
Female
448
478
-
Male
943
1,079
Permanent employees (head count)
1,372
1,556
-
Female
439
478
-
Male
933
1,078
Number of temporary employees (head count)
19
1
-
Female
9
0
-
Male
10
1
===== SIDA 86 =====
Annual report
Page
86
Employee turnover
(S1
-
6)
Overall employee turnover was lower compared to
2024, during which a reorganization was initiated, and
workforce reductions were implemented.
In 2025, Bet-
ter Collective enhanced its reporting methodology by
introducing a breakdown of total employee turnover
into dismissals and resignations. As 2025 represents the
base year for this revised categorization yoy compari-
sons by exit type are not avai
lable for 2024.
D
ismissals and resignations occurred at broadly compa-
rable levels.
Dismissals primarily reflect organizational
changes related to
the
reorganization initiated
during
2024 and
further
implemented in 2025
.
This distribution
indicates that workforce changes
during 2025
were in-
fluenced
both
by organizational adjustments and by
employee
-
driven transitions
.
Employee turnover
(head count)
2025
2024
Employee turnover
378
441
Dismissals
191
-
Resignations
187
-
Employee turnover %
26%
28%
Accounting principles
Employee turnover
Employee turnover is defined as the cumulative
headcount of employees who have departed
from Better Collective
g
roup, whereas the em-
ployee turnover rate is defined as the proportion
of employees who have left
the group
expressed
as a percentage.
The total
turnover
is calculated by aggregating
departures across all locations of operation dur-
ing the reporting period, including
resignations,
dismissals and retirement or death in service.
Employee turnover
is further presented by
res-
ignations
or
dismissals
.
R
esignations
are defined
as
e
mployees who leaves
the group
either
vol-
untarily
,
due to
retirement or death in
s
ervice.
Dismissals
are defined as employees
who leaves
the group
involuntarily
.
To determine the
employee turnover rate
, the
total number of departing employees (the "turn-
over number") is divided by the average number
of employees (the "average headcount") during
the same period
. Aligned
with the annual report-
ing method
, t
he average headcount is calculated
by aggregating the month
-
end headcount of ac-
tive employees (permanent employees) for each
month in the reporting period and dividing by
the total number of months in the reporting pe-
riod.
===== SIDA 87 =====
Annual report
Page
87
Gender distribution
other management
(S1
-
9)
Age distribution (S1
-
9)
2025
2024
Gender distribution in top management
Head count
Share
Head count
Share
Male
12
86%
12
86%
Female
2
14%
2
14%
Total
e
mployees
14
100%
14
100%
Age distribution of employees (head count)
2025
2024
Unknown
1
0
Under 30 years old
408
510
Between 30 and 50 years old
948
1,017
Above 50 years old
34
30
Total employees
1,391
1,557
Accounting principles
Gender distr
ibution
“
Other
management
”
is defined as executive
management and their direct reports. Executive
management comprises the highest administra-
tive and supervisory level. Direct reports are
employees reporting directly to executive man-
agement with managerial responsibilities at the
v
ice president and senior vice president job lev-
els who are part of the group management
team.
Gender distribution within
“other
management
”
is calculated by dividing the number of male and
female employees in
the
management by the to-
tal number of employees in management, re-
spectively.
Accounting principles
Age distribution
The age distribution of employees is determined
by summing the total headcount of employees
under 30 (29 or younger), those between 30 and
50 (30 to 49), and those aged 50 or older, ex-
cluding freelancers and contractors.
This calculation is based on data from 31 Decem-
ber 202
5
.
===== SIDA 88 =====
Annual report
Page
88
Health & safety (S1
-
14)
Work
-
related injuries are infrequent in our workplace, as
the nature of our tasks does not impose significant phys-
ical demands on employees. No occupational fatalities
were reported among our employees or any personnel
working on our sites during 2025.
Health and safety
2025
2024
Percentage of people in own workforce (head count basis) who are covered by health and safety
management system based on legal requirements and (or) recognised standards or guidelines
100%
100%
Number of fatalities as result of work
-
related injuries and work
-
related ill health
0
0
Number of fatalities as result of work
-
related injuries and work
-
related ill health (other workers
working on undertaking's sites)
0
0
Number of recordable work
-
related accidents for own workforce
0
3
Rate of recordable work
-
related accidents for own workforce
0.0%
1.3%
Accounting principles
Health
&
safety
Number of work
-
related accidents: a shared
document serves as the central record for health
and safety documentation. Local HR teams con-
tribute relevant input in the designated docu-
ment that then consulates into the group over-
view reported, this ensures ac
curate and com-
prehensive reporting. The consolidated number
of accidents occurred for employees within the
reporting period are based on the numbers re-
ported by local HR.
The work
-
related accident rate is expressed as
the number of recorded incidents per one mil-
lion hours worked. It is determined by dividing
the total number of registered cases during the
reporting period by the cumulative hours
worked across Better Collect
ive, then multiply-
ing the result by one million.
Percentage of people covered by
H&SMS
The percentage covers the employees who are
covered by our Health and safety management
system, which as a minimum contains the legal
requirements
===== SIDA 89 =====
Annual report
Page
89
Work
-
life balance
(S1
-
15)
All employees
–
except from
our US interns
-
are entitled
to take family
-
related leave in accordance with employ-
ment terms and conditions described in employee hand-
books and contracts.
Work
-
life balance
Men
Women
2025
Men
Women
2024
Percentage of employees entitled to take family
-
related leave
-
-
100
%
-
-
100%
Percentage of entitled employees that took fam-
ily
-
related leave by gender
5%
10%
7%
7%
9%
8%
Accounting principles
Work
-
life balance
Family
-
related leave refers to time off granted
for responsibilities such as maternity or pater-
nity leave, parental leave, caring for sick rela-
tives. It does not include time off for personal
medical appointments, pregnancy
-
related ill-
nesses outside of par
ental leave, or absences
due to funerals or bereavements. Additionally,
unspecified leave of absence is not considered
part of family
-
related leave.
The calculation for family
-
related leave is based
on the number of unique individuals of each
gender who have taken this type of leave, di-
vided by the total number of eligible employees
of the same gender. Eligible employees refer to
employees who have the
legal right, as defined
by applicable national laws and Better Collective
policies, to temporarily step away from their
professional duties to address family
-
related re-
sponsibilities covered by the definition of fam-
ily
-
related leave.
Eligible employees are determined using the
same criteria as the "total headcount" as all em-
ployees in Better Collective
,
except for
interns in
the United States,
are eligible for family related
leave. Employees who take family
-
related leave
in multiple months within the same reporting
year are counted only once.
As family
-
related leave is not consistently reg-
istered in our internal system, data is gathered
from responsible members of the People & Cul-
ture team
.
All instructed to provide reported
figures broken down by gender
.
Account-
ing principles
===== SIDA 90 =====
Annual report
Page
90
Compensation
(S1
-
16)
The reported gender pay gap at Better Collective
g
roup
is
influenced by
the
employee population
being
pre-
dominantly male which inherently skews the average
pay gap. This effect is particularly pronounced due to
the concentration of male employees in upper
-
level
roles. The higher compensation associated with these
roles contributes to a higher average pay
for male em-
ployees.
The annual total remuneration ratio
was
1:39
,
amplified by geographical differences.
Adjusted pay gap and adjusted annual remuneration ra-
tios have been included to normalize the data by ac-
counting for outliers. As positions and pay practices
vary by country and affect the overall
g
roup average,
the adjusted pay gap is further broken down by country,
showing the countries with greater than 10% employee
populations with the Rest of World (Row) in aggregate.
Adjusted gender pay gap by country
2025
United States
23%
Serbia
18%
Denmark
9%
Rest of World (RoW)
2
1
%
Compensation
2025
2024
Gender pay gap
36%
33%
Adjusted gender pay gap
3
3
%
-
Annual total remunera-
tion ratio
1:39
1:45
Adjusted annual total re-
muneration ratio
1:3
6
-
Accounting princip
les
Gender pay gap
The gender pay gap is defined as the difference
in average gross hourly pay between male and
female employees at Better Collective. The gen-
der pay gap is calculated by subtracting the av-
erage gross hourly pay level for female employ-
ees from the average gro
ss hourly pay level for
male employees, dividing the result by the aver-
age gross hourly pay level for male employees,
and then multiplying by 100.
The average gross hourly pay level is calculated
by aggregating gross pay (the sum of guaran-
teed, short
-
term, and non
-
variable cash com-
pensation) and variable pay (benefits in cash,
which is the sum of cash allowances, bonuses,
commissions, cash profit
-
sha
ring, and other
forms of variable cash payments) and dividing
by the total number of paid hours. "Paid hours"
are defined as the aggregate of the number of
paid hours in the reporting period, which include
worked hours, and any
hours paid at the gross
hour
ly rate, such as vacation, sick leave, or other
types of paid time off.
The adjusted pay gap
calculations exclude the
executive leadership team as well as non
-
stand-
ard severance payments, which is severance
paid to an individual beyond what is required by
law, internal policy, standard market practice, or
similar. These payments often include one
-
time
leave agreement bonuses, payout settlements,
or similar contractual leave payout agreements
not typically provided to employees. The ad-
justed pay gap uses the same gender pay gap
calculation as presented in the accounting prin-
cipl
e and with these exclusions applied.
Accounting pr
inciples
Remuneration ratio
Annual total remuneration ratio is defined as the
ratio of the annual total remuneration of the
highest
-
paid employee to the median annual to-
tal remuneration of all other employees at Bet-
ter Collective Group. The ratio is calculated by
dividing the annual
total remuneration of the
highest
-
paid employee by the median annual
total remuneration of all other employees (ex-
cluding the highest
-
paid employee).
Annual total remuneration includes direct remu-
neration, which is the sum of benefits in cash
(variable pay, which is the sum of cash allow-
ances, bonuses, commissions, cash profit
-
shar-
ing, and other forms of variable cash payments),
benefits in kind (employ
er
-
paid benefits, such as
cars, private health insurance, life insurance,
wellness programs, pension contributions, and
any other employer
-
paid benefits), and the total
fair value of all annual long
-
term incentives
granted during the reporting period (for
exam-
ple, stock option awards, performance stock
shares or units
).
The adjusted annual total remuneration ratio
uses the same remuneration ratio calculation as
presented in the accounting principles
and in-
clude
the same
exclusions applied
in the ad-
justed gender pay gap
.
===== SIDA 91 =====
Annual report
Page
91
Discrimination
repor
ts
&
complaints
filed
(S1
-
17)
We had
19
cases reported in the Better Workplace eval-
uation covering the period from summer 202
4
to sum-
mer 202
5
. An internal policy for handling these cases
has been
established.
We handle every discrimination
and
harassment
incident and complaint within our or-
ganization through our internal procedures. Due to the
sensitive nature of these matters, we do not share any
specific details about the incidents. Each report or com-
plaint is treated with utmost confidentiality. Our pr
oce-
dures are designed to ensure that empl
oyees can confi-
dently and securely report any incident.
In 202
5
,
0
records of fines or penalties were
associated
with discrimination. Furthermore,
no human rights inci-
dents involving our workforce took place in 202
5
, and as
a result, no fines, penalties, or compensations related to
such incidents were recorded.
Incidents, complaints and severe human rights impacts
2025
2024
Number of incidents of discrimination including harrasment
19
13
Number of complaints filed through channels for people in own workforce to raise concerns
0
0
Number of complaints filed to National Contact Points for OECD Multinational Enterprises
0
0
Amount of fines, penalties, and compensation for damages as result of incidents of discrimination,
including harassment and complaints filed
0
0
Number of severe human rights issues and incidents connected to own workforce
0
0
Number of severe human rights issues and incidents connected to own workforce that are cases
of non respect of UN Guiding Principles and OECD Guidelines for Multinational Enterprises
0
0
Amount of fines, penalties, and compensation for severe human rights issues and incidents con-
nected to own workforce
0
0
Accounting principles
Discrimination incidents reported
and complaints filed
Number of complaints filed through channels for
people in our own workforce to raise concerns:
Channels for own workforce follow the local le-
gal requirements. Common for all countries are
the Better Workplace Evaluation, HR, and own
manager.
Whistleblower cases are included in these num-
bers. Based on the current available data collec-
tion methodology, we include all cases raised in
the Better Workplace evaluation as of end of
survey.
Human rights, complaints, fines, and penalties:
We monitor these elements locally and data
from each location are reported into
g
roup HR
where the numbers are consolidated based on
the input given at the end of year
.
===== SIDA 92 =====
Annual report
Page
92
Consumers
&
end
-
user
s
(S4)
Consumers
&
end
-
users
IROs
(SBM
-
3)
Our business model directly involves consumers and
end
-
users who interact with our platforms and may be
referred to partnering sportsbooks. All user groups that
may be materially affected are included in the scope of
this disclosure.
None of the identified
IROs
are consid-
ered widespread or systemic, and
the
impacts and de-
pendencies
identified under ESRS 2 IRO
-
1, including pri-
vacy, access to accurate information, security of a per-
son, safer gambling, and responsible marketing inform
our
strategic priorities
and guide adjustments to our
business model.
Thesre
impacts and dependencies
give
rise to material risks and opportunities for Better Collec-
tive arising from our interactions with consumers and
end
-
users.
Users
potentially affected include individuals engaging
with gambling
-
related content, users whose personal
data we process, users dependent on reliable infor-
mation to avoid harmful decisions, and individuals who
may be particularly vulnerable to gambling harm o
r mar-
keting influence.
Our understanding of which users may
be at greater risk of harm is informed by internal
assessments, regulatory
expectations
, and behavioral
insights from Mindway AI. Where potential negative im-
pacts occur, these are man
-
aged through
GDPR compli-
ance structures, responsible
-
communication frame-
works, and content and advertising controls. Positive
impacts include access to accurate information and
safer
-
gambling resources, supported by educational in-
itiatives and tools such as Mindway AI
’s GameScanner
and Gamalyze, ben
ef
iting users across our brands and
partnerships.
Where risks or opportunities specific to certain user
groups
arise,
these are incorporated into our operational
and strategic response
.
From a risk and opportunity, the
risk relating to cybercrime and unauthorized access to
personal data arises primarily from impacts on users
whose personal data we process, as incidents affecting
this group may result in legal or reputational conse-
quences
.
The opportunity relating to safer gambling ap-
plies across
our
broader user base but arises more di-
rectly from positive
impacts on
vulnerable
users engag-
ing with
safer gambling content and tools
,
ultimately
support
ing
user trust, regulatory alignment, and long
-
term value creation for Better Collective.
Through this approach, consumer and end
-
user
IROs
are
systematically integrated into Better Collective’s strat-
egy and business model, supporting responsible en-
gagement and long
-
term value creation.
Annual report
Page
92
===== SIDA 93 =====
Annual report
Page
93
Policies (S4
-
1)
We have established a set of group
-
wide policies to
manage the material IROs related to consumers and
end
-
users. These policies apply across our operations
and relevant business relationships and cover all mate-
rial consumer topics identified in our assessm
ent.
The policies governing these topics are also listed and
further described in the “Policy Overview” on pages
74
-
76
.
These policies outline the principles for managing
the negative potential impacts associated with privacy
breaches, misleading or inappropriate marketing, and at
risk
-
users’ exposure to betting related content, as well
as the positive potential impact linked to access to ac-
curate information, and the positive actual impact iden-
tified for safer gambling. Togeth
er, these policies estab-
lish how we
manage material IROs across all consumer
and end
-
user groups.
The policies further define our general approach to en-
gaging with consumers and end
-
users, including re-
quirements for transparent communication about data
use, content classification, and the nature of commercial
relationships. Better Collective’s policy f
ramework is
aligned with internationally
recognized
instruments.
Better Collective has not identified material human
-
rights
-
related IROs specifically relating to consumers or
end
-
users, why it is not relevant to have developed des-
ignated policies on human
rights commitments related
to consumers and end
-
users.
We have had no reported cases of non
-
respect
for
these
international instruments. Should a human
-
rights im-
pact
relate
to consumers or end
-
users occur, Executive
Management will assess and address the matter.
E
nga
ging with
consumers
&
end
-
users
(
S4
-
2
)
At present, we have not implemented standardized gen-
eral processes for consumer and end
-
user engagement
across all our operations. However, we acknowledge the
importance of consumer and end
-
user input in shaping
our strategies and products. We engage indir
ectly
through data analytics, user behavior tracking, and ad-
herence to regulatory feedback mechanisms. Better Col-
lective actively explores structured consumer engage-
ment initiatives, including user feedback platforms, con-
sumer advisory panels, and direct s
urveys.
These measures enhance our understanding of con-
sumer expectations, improve safer gambling practices,
and align with evolving regulatory and ethical stand-
ards. Our commitment remains to ensuring transpar-
ency, accountability, and continuous improvement in
co
nsumer and end
-
user interactions.
POLICY
SCOPE
PRIVACY
ACCESS TO
INFORMATION
SECURITY OF A PERSON
RESPONSIBLE MARKETING
SAFER GAMBLING
Code of Conduct
Group
X
X
X
X
X
Data ethics
Group
X
Gambling advertising
Group
X
X
X
Human rights
Group
X
Privacy external
Group
X
Safer gambling external
Group
X
X
X
X
Sustainability
Group
X
X
X
X
X
Whistleblower
Group
X
X
X
X
X
===== SIDA 94 =====
Annual report
Page
94
Process to remediate
impacts
&
channels to
raise concern (S4
-
3)
We have processes in place to provide for and cooper-
ate in the remediation of negative impacts on consum-
ers and end
-
users.
If
we identify that we relate to
a
ma-
terial
negative impact, our general approach is to assess
the issue, address it in line with our policy commitments,
and cooperate with relevant partners or regulatory bod-
ies when appropriate.
Consumers and end
-
users have access to specific chan-
nels to raise concerns directly with Better Collective’s
brands, including dedicated contact forms, support
email addresses, and our Whistleblower channel, which
also offers independent and confidential r
eporting op-
tions. We support the availability of these channels
through group
-
wide policies, internal guidelines, and re-
quirements for all business units to maintain accessible
complaint and reporting mechanisms.
All issues raised through these channels are logged and
monitored, and we regularly review the operation and
effectiveness of these processes to ensure concerns are
handled in a timely and consistent manner. Effective-
ness assessments include reviewing resp
onse times,
tracking trends in reported concerns, and adjusting pro-
cesses where needed. We communicate the availability
of these channels through our websites, privacy notices,
help center articles, partnerships with consumer advo-
cacy groups and policy dis
closures. We further assess
whether consumers and end
-
users are aware of and
trust these mechanisms by monitoring engagement lev-
els with available channels and reviewing feedback
where available. In areas where a remediation frame-
work has not been establis
hed,
we
work
to develop
structured processes that align with
industry
best prac-
tice and consumer protection standards.
Acting on material
IROs (S4
-
4)
As a global digital sports media group with sports bet-
ting affiliate operations, we interact directly with con-
sumers and end
-
users through digital content, targeted
advertisements, and affiliate partnerships. Our services
and operations create actual and p
otential impacts,
which we work actively to manage through policies,
technological solutions, and industry collaboration.
In
addition to managing impacts, we act on positive im-
pacts and
pursue
opportunities relating to consumers
and end
-
users through actions that are already under-
way and embedded in operations, rather than through
separate standalone action plans
.
The material actual
and potential negative and positive effects we address
relate to safer gambling, personal safety, data privacy,
social inclusion, and access to accurate information.
Resources allocated to the management of impacts on
consumers and end
-
users are embedded within Better
Collective’s existing operational and governance
struc-
tures. These include dedicated compliance, legal, data
protection, editorial, product, and technology functions,
as well as resources allocated to the development and
maintenance of safer
-
gambling tools, content govern-
ance processes, and data
-
protect
ion systems. Re-
sources are allocated on an ongoing basis through busi-
ness
-
as
-
usual activities rather than through separately
defined budgets for individual IROs
.
Information related impacts
Privacy
We take action to ensure that personal data is handled
responsibly and securely across our operations. To pro-
vide users with tailored and educational experiences, we
process various categories of user
-
related and personal
data. This processing is governed
by our Data Ethics Pol-
icy
-
developed in accordance with
s
ection 99d of the
Danish Financial Statements Act
-
and supported by our
GDPR compliance framework.
We assess and identify
where data handling may carry elevated exposure to
cyberattacks, human erro
r, or other vulnerabilities. We
act by implementing and maintaining our Data Ethics
Policy, reinforcing GDPR compliance structures, and
strengthening internal data
-
processing and cybersecu-
rity controls across relevant operations and business re-
lationships.
Information collected from users varies by
brand, reflecting differences in services offered and the
extent to which registration is required. Our larger
global sites operate with fully automated end
-
of
-
year
data deletion processes, whereas more local bra
nds fol-
low the same data
-
protection principles, although dele-
tion procedures require more manual effort. In all cases,
users have the possibility to manage their data through
cookie consent settings, and data collection is per-
formed only when users allow i
t.
Effectiveness is monitored through periodic internal au-
dits, incident reporting systems, and continuous evalua-
tion of IT and data
-
management processes. Incident
monitoring enables us to identify patterns or system
weaknesses, and corrective actions are tak
en to reduce
the likelihood of recurrence. Where concerns or
breaches arise, users may seek remedy through estab-
lished contact channels or our Whistleblower line, which
provides a structured escalation mechanism that en-
sures matters are addressed appropria
tely. Where
breaches occur, remediation includes timely notification
to affected users and implementation of corrective
measures. These measures mitigate privacy
-
related
risks and support responsible data use across our oper-
ations.
Access to
information
For access to accurate and transparent information, we
take action to ensure that users receive reliable, educa-
tional and fact
-
based content across all platforms. These
===== SIDA 95 =====
Annual report
Page
95
actions form part of our broader content strategy and
are supported by structured editorial and compliance
processes that guide planning and resource allocation.
Our content strategy prioritizes transparency, educa-
tion, and user empowerment.
Access to high
-
quality,
fact
-
based information is a material opportunity that en-
ables users to make informed decisions while reducing
misinformation. Through editorial guidelines, content
-
verification procedures, and regulatory compliance
checks, we ensure
that informat
ion published across our
platforms is accurate, unbiased, and aligned with appli-
cable legal requirements. This includes delivering edu-
cational and explanatory content on betting mechanics,
gambling risks, and safer play, as well as supporting re-
sources suc
h as our Betting Academy, which assists us-
ers in understanding betting strategies and contextual
information.
These initiatives are undertaken with the primary pur-
pose of delivering positive outcomes for consumers and
end
-
users by strengthening informed decision
-
making
and reducing information asymmetries. Over recent
years, we have also expanded our editorial cap
abilities
and product development, enabling us to provide more
newsworthy, investigative, and locally tailored content.
This development enhances relevance for sports fans
and increases the quality and accessibility of infor-
mation across different markets,
supported further by
using local languages on our local brands.
Effectiveness is monitored through quality reviews,
compliance checks, and user
-
engagement metrics and
analysis. These insights inform further improvements to
editorial processes, content governance, and platform
functionality, ensuring that content remain
s accurate,
relevant, and accessible over time. Across these actions,
we reinforce transparency and user empowerment while
leveraging the positive potential impact as an oppor-
tunity to strengthen user trust and ensure long
-
term
value creation across our pl
atforms.
Personal safety
Security of a person
We have identified a potential negative impact relating
to security of a person, where individuals with harmful
or at
-
risk gambling
behaviors
may access betting
-
re-
lated content on our platforms or be referred to partner-
ing sportsbooks. As Better Collective is not a sportsbook
and does not have access to betting data, we cannot ob-
serve or track whether a user subsequently develops,
escalates, or
recovers from gambling
-
related harm. For
this reason, our actions focus on mitigating the risk of
exacerbating har
mful gambling
behaviors
through safer
practices across our operations.
Our approach includes applying responsible communi-
cation standards, implementing age
-
gating controls,
and collaborating only with licensed sportsbooks that
maintain defined player
-
protection frameworks.
These
measures are designed to ensure that our practices do
not cause or contribute to negative impacts on consum-
ers and end
-
users. As part of our preventative efforts,
we provide explanatory and educational information
across our websites, including material re
lated to legal
gambling age requirements, gambl
ing risks, and safer
play principles. These actions are taken with the objec-
tive of supporting safer decision
-
making for all users,
also the ones who may be vulnerable.
To address the broader systemic dimensions of this po-
tential negative impact, we participate in several indus-
try and multi
-
stakeholder initiatives. These include the
Responsible Affiliates in Gambling (RAiG), through
which members undergo third
-
party annua
l social re-
sponsibility audits, and the Responsible Gambling Affili-
ate Association (RGAA). We are active members of var-
ious national associations such as the Danish Online
Gambling Association (DOGA), the German Association
for Telecommunication and Media
(DVTM), and the US
National Council on Problem Gambling (NCPG).
Through these initiatives, we seek to contribute to the
development and promotion of safer gambling frame-
works designed to mitigate harm across the wider in-
dustry.
Effectiveness is monitored through internal
checks, assessments of user
-
facing information, and in-
sights from external audits such as the RAiG social re-
sponsibility review.
Remedy channels, including user
contact points and the Whistleblower line, are available
for concerns relating to this impact. Through our ac-
tions, we seek to reduce the likel
ihood that our opera-
tions contribute to harmful
behaviors
, while acknowl-
edging the limitations inherent in our business model.
Safer gambling
Safer gambling constitutes a positive actual impact for
consumers and end
-
users, as well as an opportunity for
Better Collective. The impact originates from our focus
on education, harm prevention, and responsible en-
gagement across our platforms and partne
rships. As
Better Collective is not a sportsbook and does not have
visibility into users’ subsequent betting behaviour, our
actions are designed to strengthen user protection at
the points where we can influence outcomes, while ac-
knowledging our position a
s an upstream actor in the
value chain.
Our actions include maintaining responsible communi-
cation standards, applying age
-
gating controls, embed-
ding safer
-
gambling information across our platforms,
and collaborating exclusively with licensed sportsbooks
that uphold robust player
-
protection frame
works. By di-
recting users only to sportsbooks that meet defined
safer
-
gambling expectations, we help ensure that those
who choose to place
a
bet do so where intervention sys-
tems such as deposit limits, affordability checks, and
self
-
exclusion tools are ava
ilable. These actions
strengthen our positive impact by contributing to safer
===== SIDA 96 =====
Annual report
Page
96
end
-
user journeys and supporting informed decision
-
making.
A central part of our approach is the integration of safer
-
gambling educational resources across our brands.
These include sections dedicated to understanding
gambling risks, legal gambling
-
age requirements, and
safer
practices. Supplementing this is our Betting Acad-
emy, which provides accessible explanations of betting
mechanics and contextual information to help users un-
derstand the risks associated with gambling.
These
measures improve user awareness and autonomy and
reduce the likelihood of uninformed o
r harmful gam-
bling behaviours.
Mindway AI plays a central role in enabling us to extend
our positive impact beyond our direct operations. As a
subsidiary operating independently, Mindway AI pro-
vides AI
-
based tools such as GameScanner and Gama-
lyze that support monitoring, early detection
, and pre-
vention of at
-
risk and problem gambling. Because these
capabilities sit at the sportsbook level, Mindway AI al-
lows Better Collective to influence user protection fur-
ther downstream in the value chain, where the risk of
harm materializes and where
Better Collective would
otherwise have no operational control. Through
our
tools, sportsbooks can identify harmful play patterns
and intervene earlier, thereby exceeding minimum com-
pliance obligations and strengthening user protection
across jurisdictions.
GameScanner is a behavioural
-
monitoring system that
performs automated
,
early detection of potentially
harmful
play
patterns. GameScanner allows sportsbooks
to identify signs of risk and intervene before harmful be-
haviour escalates. Gamalyze, another Mindway AI solu-
tion, is a gamified self
-
assessment test that analyses us-
ers’ decision
-
making patterns and provides perso
nal-
ized feedback on gambling behaviour.
We
integrate
Gamalyze across selected brands, enabling users to vol-
untarily assess their risk profile
before engaging with
sportsbooks.
To further strengthen
our
positive impact o
n
safer gam-
bling,
we
participate in
industry and multi
-
stakeholder
initiatives. These include Responsible Affiliates in Gam-
bling (RAiG), where membership requires compliance
with annual third
-
party social
-
responsibility audits and
the Responsible Gambling Affiliate Association (RGAA),
promo
ting responsible affiliate standards globally, as
well as annual participation in Safer Gambling Week
.
Through these platforms
and initiatives
, we contribute
to raising industry standards and strengthening safer
gambling m
easures across the betting ecosystem.
Effectiveness
of
our
actions is monitored through usage
and performance data from Mindway AI tools, adoption
levels among sportsbooks, and assessments
of the visi-
bility and accessibility of safer
-
gambling resources
across our brands. Internal compliance reviews and ex-
ternal audit
s
, including RAiG’s annual social
-
responsibility review, support continuous improvement
of our safer
-
gambling controls and initiatives.
Overall, our
combined
actions
enhance user protection,
promote responsible engagement, and extend our posi-
tive influence into the downstream parts of the ecosys-
tem where harm can occur and support sustainable
value creation through responsible
-
growth practices
and industry leadership.
Safer gambling
2025
No. of active players per month scanned
by GameScanner
14,
3
82
,101
Accounting
principles
To
evaluate
of our safer gambling actions, we
monitor
“Number of active players per month
scanned by GameScanner”.
Th
e
metric measures the volume of player ac-
counts monitored through Mindway AI’s tech-
nology and serves as an indicator of the scale at
which early
-
detection measures are applied
across partnering sportsbooks. Its purpose is to
help assess the reach and effect
iveness of our
contribution to harm
-
prevention efforts in the
downstream part of the value chain.
An “Active player” is defined as “
a player who
places at least one real revenue
-
generating bet
or wager in a calendar month on a gambling
platform operated by a sportsbook integrated
with Mindway AI’s GameScanner”. The figure is
reported as of the last day of the reporting pe-
riod
.
The metric is calculated based on aggregated,
anonymized sportsbook data provided directly
by Mindway AI. No personal data is accessed or
processed. The calculation relies on system
-
generated counts of unique active players
scanned monthly, without samplin
g or addi-
tional behavioural analysis.
The metric forms part of our broader monitoring
of safer
-
gambling effectiveness and supports
evaluation of how our actions address material
impacts and opportunities related to consumers
and end
-
users.
===== SIDA 97 =====
Annual report
Page
97
Social
inclusion
Responsible marketing
We have identified a potential negative impact where
advertising and affiliate activities may unintentionally
expose consumers and end
-
users to misleading or
overly persuasive content.
Actions taken to address
these
impacts
form part of our management of material
impacts on consumers and end
-
users. Our comprehen-
sive compliance framework includes internal advertising
guidelines, structured approval workflows, and regula-
tory
-
aligned communication standards. The compliance
team
performs ongoing monitoring of websites and so-
cial media channels, including negative
-
keyword
checks, to identify and correct non
-
compliant material.
Employees involved in marketing complete mandatory
compliance onboarding and training, including short
-
module advertising rules videos, supported by quizzes
to reinforce understanding. An internal Compliance Hub
provides access to advertising standards, re
gulatory up-
dates, and ethical marketing guidance, supporting con-
sistent application of responsible marketing principles.
Effectiveness is monitored through internal audits, qual-
ity
-
assurance checks, and regulatory monitoring. Exter-
nal assessments, includin
g RAiG’s annual social respon-
sibility audit, further inform continuous improvement of
responsible marketing practices. These actions ensure
that our practices do not cause or contribute to material
negative impacts on consumers and end
-
users.
Targets (S4
-
5
)
We have not yet established measurable, outcome
-
ori-
ented targets related to our material impacts on con-
sumers and end
-
users. At present, we assess how such
targets can be meaningfully developed, considering
data limitations inherent to our role as a digita
l media
and affiliate business. These constraints are the primary
reason why there are currently no plans to introduce
quantitative impact targets.
Although no targets have been set, we systematically
track the effectiveness of our actions through qualita-
tive assessments, compliance monitoring, external audit
feedback, and engagement indicators relevant to each
material impact area. These processes en
able ongoing
evaluation of whether existing policies and actions op-
erate as intended. Our current ambition is to strengthen
user protection, transparency, and responsible engage-
ment. As part of this ambition, we intend to develop a
more structured impact
-
m
easurement framework that
may serve as a basis for establishing future qualitative
or quantitative indicators, including the definition of a
baseline for assessing progress.
Annual report
Page
97
===== SIDA 98 =====
Annual report
Page
98
Identification & assessment of material IROs
(IRO
-
1)
99
Business conduct & corporate culture (G1
-
1)
100
Corruption & bribery detection & prevention
(G1
-
3)
101
Bribery & corruption incidents
(G1
-
4)
101
Tax transparency (MDR)
102
Contribution to the development of local
communities (MDR)
103
Governance
===== SIDA 99 =====
Annual report
Page
99
Ident
ification
&
asses
s
ment of
m
aterial
IRO
s
(IRO
-
1)
As a
global digital sports media
group operating in a
regulated and fast
-
evolving industry, Better Collective’s
ability to operate responsibly
depends on maintaining
ethical, transparent, and compliant business conduct.
Responsible business conduct is therefore material to
Better Collective, as it underpins trust with stakeholders,
supports operational resilience, and contributes to long
-
term value creation.
Our commitments to compliance, anti
-
corruption, fair
taxation, and contribution to local communities extend
beyond regulatory requirements and are essential to
maintaining our social license to operate. The impacts,
risks, and opportunities related to busi
ness conduct in-
fluence our governance practices, reputation, and ability
to attract and retain employees. A strong and consistent
corporate culture supports ethical decision
-
making, em-
ployee well
-
being, and inclusion, while reducing the risk
of misconduct
across the group as we operate across
multiple markets
.
Operating across multiple jurisdictions exposes Better
Collective to differing levels of corruption and bribery
risk. Unethical proposals, unclear regulatory environ-
ments, or insufficient controls could negatively affect
trust and reputation if not appropriately managed. Ro-
bust anti
-
corruption procedures and escalation mecha-
nisms form the basis of our approach to mitigating such
risks
.
Responsible tax behaviour is equally central to our gov-
ernance framework. By paying taxes in all the countries
where we operate, we contribute to public services, eco-
nomic development, and community well
-
being. In turn,
transparent and compliant tax practi
ces strengthen
trust and support our credibility with investors, regula-
tors, and financial institutions.
Beyond compliance, our responsibility extends to the
societies in which we operate. Through educational
academies, we support employability and inclusion
while contributing to the resilience of local communities.
These efforts create shared value and reinf
orce our
long
-
term competitiveness by
building talent pipelines
and deepening our connection with the regions where
we are active.
The identification of business conduct
-
related IROs is
anchored in
our
DMA process described
in the General
disclosures chapter
. In this process,
we
consider
ed
loca-
tion
,
activity
,
sector
, and the
structure of business rela-
tionships
when identifying material IROs related to
busi-
ness conduct.
Location
-
related governance risk
was as-
sessed through a country
-
by
-
country screening using
the World Bank Worldwide Governance Indicators.
Activity, sector, and relationship structure
were as-
sessed qualitatively through the DMA process, reflecting
our
operations as a digital sports media group within the
regulated gambling and sports betting ecosystem
. Rel-
evant hard and soft law frameworks, including the
Danish Recommendations on Corporate Governance,
the EU Whistleblower Directive, and the OECD Guide-
lines for Multinational Enterprises, were considered
when assessing current practices and identifying gov-
ernance
-
related
IROs.
POLICY
SCOPE
CORPORATE CULTURE
CORRUPTION AND BRIBERY
TAX TRANSPARENCY
CONTRIBUTION TO
LOCAL COMMUNITIES
Code of Conduct
Group
X
X
X
Human rights
Group
X
Sustainability
Group
X
X
X
X
Tax transparency
Group
X
X
X
Whistleblower
Group
X
X
X
===== SIDA 100 =====
Annual report
Page
100
Business conduct
&
corporate culture
(
G1
-
1)
Better Collective’s business conduct is anchored in a
comprehensive policy framework that establishes ex-
pectations for integrity, respect, and compliance with
laws, serving as the foundation for strong and consistent
business practices across the group.
To address material
IROs related to business conduct, Better Collective has
implemented group
-
wide actions that are embedded in
governance structures, policies, training, monitoring ac-
tivities, and reporting and investigation procedures.
Our policies, including the Code of Conduct, mirror in-
ternationally
recognized
standards and conventions
such as the OECD Guidelines for Multinational Enter-
prises, the UN Guiding Principles on Business and Hu-
man Rights, the UN Declaration of Human Rights, and
the ILO Conventions, as well as relevant national legisla-
tion.
All group
-
level policies are applied across all enti-
ties to ensure consistent implementation while allowing
for adaptation to local regulatory requirements
.
The Code of Conduct outlines the core principles of in-
tegrity, respect, and transparency and is supported by
the Sustainability Policy, Human Rights Policy, Whistle-
blower Policy, and Tax Policy.
These policies are sup-
ported by operational actions, including mandatory
onboarding and refresher training, internal compliance
guidance, and ongoing oversight by Executive Manage-
ment and the Board of Directors
.
Together, these
measures promote ethical behaviour, prevent miscon-
duct, and support responsible business
practices across
the group and its value chain.
Executive Management
and the Board of Directors review and update group
-
wide policies annually.
The review process incorporates
outcomes from the DMA to ensure that identified busi-
ness conduct
-
related
IROs
are addressed through ap-
propriate actions and controls
.
Better Collective’s corporate culture is rooted in four
values
-
Respect, Ambition, Integrity, and Collaboration
-
which guide behaviour and decision
-
making at all lev-
els.
These values are operationalized through onboard-
ing programmes, performance reviews, leadership com-
munication, and targeted training activities.
All employ-
ees receive business conduct training aligned with the
Code of Conduct, with refresher sessions provided when
policies or regulatory requirements change. Employees
in roles with heighte
ned compliance exposure receive
additional guidance through the Compliance Hub and
Regulatory Compliance function.
Monitoring actions
are in place to assess the effective-
ness of business conduct measures. Cultural cohesion,
engagement, and well
-
being are monitored through the
annual Better Workplace Evaluation. Results are re-
viewed by People & Culture and senior management,
and
follow
-
up actions are defined and implemented at
local and group level
to address identified gaps and im-
provement areas. During acquisitions, Better Collective
applies
structured cultural integration actions
, including
alignment with group polici
es, leadership engagement,
and onboarding processes, to ensure continuity and ad-
herence to shared values.
To address risks related to harassment, misconduct, and
unethical behaviour,
preventive actions
include uncon-
scious bias and anti
-
harassment training for all employ-
ees and clear escalation pathways. Employees and ex-
ternal stakeholders are encouraged to report concerns
through the Whistleblower system
.
We
maintain a
w
histleblower system that is accessible
to employees, suppliers, and external stakeholders.
The
system enables confidential and anonymous reporting
of violations of law or internal policies, including fraud,
harassment, corruption, and data misuse.
Safeguards
are in place to ensure secure reporting, independent
handling, and restricted access to case information
.
Re-
ports are managed independently by the Chair of the
Audit Committee, with defined timelines for acknowl-
edgment and follow
-
up.
Reported incidents are investigated promptly, inde-
pendently, and objectively
, and corrective measures are
implemented where necessary
.
Better Collective
prohib-
its retaliation against its own workers who report
concerns in good faith
, and protection measures are ap-
plied in accordance with legislation transposing Di-
rective (EU) 2019/1937.
Functions assessed as being most exposed to corruption
and bribery risk include roles operating in higher
-
risk
geographies, as well as functions within procurement, fi-
nance, and sales, where interaction with third parties,
commercial negotiations, or finan
cial decision
-
making
occurs.
===== SIDA 101 =====
Annual report
Page
101
C
orruption &
bribery
detection &
prevention
(G1
-
3)
At Better Collective, we uphold a zero
-
tolerance policy
towards corruption and bribery. Such acts are not only
unlawful but undermine trust, integrity, and relation-
ships with partners and authorities. Our anti
-
corruption
and bribery commitments are embedde
d in the Code of
Conduct and supported by our internal compliance sys-
tems.
We operate a comprehensive compliance control frame-
work to prevent and detect corruption or bribery. This
includes internal controls, segregation of duties, and
clear approval procedures for financial transactions and
gifts. The group does not engage in cr
yptocurrency pay-
ments and performs due
-
diligence assessments in all
partnership and acquisition processes. Should any risk
of money laundering or fraud be identified, the engage-
ment is not pursued.
All gifts and entertainment are accepted on behalf of
Better Collective as a
group
and must be handed to HR.
Together with management, HR evaluates whether a
gift, meal, or entertainment should be accepted, reim-
bursed, or declined, and whether participation aligns
with company interests. This procedure ensures trans-
parency and prevents
conflicts of interest.
The Audit Committee, chaired by an independent Board
member, oversees investigations to ensure that investi-
gators remain independent of the management respon-
sible for prevention and detection activities. Outcomes
of investigations and compliance reviews ar
e reported
to Executive Management and the Board of Directors at
least annually, or immediately in the case of significant
issues.
All employees are informed of the anti
-
corruption and
bribery policy
-
as incorporated in our Code of Conduct
-
during onboarding and through periodic compliance
updates. The policy and reporting channels are perma-
nently accessible through the intranet and
corporate
websites
, ensuring that they remain
accessible
to
all em-
ployees and stakeholders.
Despite having internal controls, we recognize a key
area for improvement in the form of formalized anti
-
cor-
ruption and bribery training. We acknowledge the im-
portance of further educating our workforce
-
especially
those in “sensitive roles” on ethical bu
siness practices.
To address this gap, we are looking into options for anti
-
corruption education and training to ensure proactive
identification and mitigation of potential threats.
Bribery & corruption
incidents
(G1
-
4)
Better Collective aims for zero reported cases of brib-
ery and corruption, including any behaviour that
abuses entrusted power for personal gain. In the event
of a breach, immediate and appropriate action is taken,
including investigation, corrective measur
es, and disci-
plinary sanctions. Root
-
cause analyses are conducted
to prevent recurrence.
D
uring the reporting period, there were no confirmed in-
cidents of corruption or bribery involving Better Collec-
tive or its value chain and no convictions or fines under
applicable laws.
Accounting principles
Percentage of functions
-
at
-
risk cov-
ered by training programs
There is currently no formalized training for
functions
-
at
-
risk.
Number of convictions
C
onviction of a group entity by a court of law
which is determined during the financial year.
Number of fines
F
ines for a group entity are determined by a
court of law during the financial year.
2025
2024
Percentage of functions
-
at
-
risk
covered by training programmes
0%
0%
Number of convictions for viola-
tion of anti
-
corruption and anti
-
bribery laws
0
0
Amount of fines for violation of
anti
-
corruption and anti
-
bribery
laws
0
0
===== SIDA 102 =====
Annual report
Page
102
Tax transparency
(MDR)
We
recognize that transparent tax practices are funda-
mental to corporate responsibility and sustainable busi-
ness operations. As part of
our
governance
framework,
we
ensure responsible tax management that aligns with
legal compliance, ethical standards, and stakeholder ex-
pectations.
Our approach to tax transparency aligns
with our broader strategy, emphasizing ethical business
practices and accountability. By fulfilling our tax obliga-
tions responsibly and transparently, we contribute to a
stable and sustaina
ble economic environment in the re-
gions where we operate.
Beyond the societal impact, our commitment to tax
transparency presents a strategic opportunity for Better
Collective. As governments, investors, and stakeholders
increasingly value corporate accountability, our trans-
parent tax practices help strengthen tr
ust, enhance our
reputation, and reinforce our position as an industry
leader. Demonstrating our dedication to financial trans-
parency mitigates regulatory risks and gives us a com-
petitive advantage in attracting investors and partners
who prioritize ethica
l business conduct. By integrating
responsible tax practices into our business model, we
align financial success with social impact, ensuring that
our growth contributes positively to the communities
we are part of while securing long
-
term value for our
stakeholder. Our overall guiding principle within taxa-
tion is to have a sustainable tax approach, emphasizing
our business
-
anchored approach to managing the im-
pact of taxes while remaining true to the values of oper-
ating our business in a responsible and t
ra
nsparent man-
ner. Our legal structures are based on business
-
an-
chored considerations and substance.
The overall responsibility for securing tax compliance
rests with Executive Management. Our tax policy has
been evaluated and approved by the Board of Directors
and is governed by the Audit Committee. Group Finance
establishes guidelines for global complia
nce and will in
collaboration with the external group
consultants
moni-
tor that local organizations are complying with their re-
sponsibility both in terms of international and local reg-
ulations.
Our approach to tax transparency is guided by
our Tax policy, a
nd the group must adhere to all relevant
tax regulations in all jurisdictions where it performs its
operations. The policy applies to all entities within the
Better Collective group, including foreign branches and
representations, and covers corporate inco
me tax, indi-
rect taxes, withholding taxes, employee taxes, excise
taxes, import duties, and similar fiscal obligations.
Better Collective does not have formalized actions on
tax;
however, we
always ensure alignment with policy
and ongoing review of tax compliance.
Although no for-
mal
time
-
bound targets are currently defined,
our qual-
itative
objective
is to ensure full compliance with
applicable tax laws and
our policy, as well as maintaining
fair and transparent contribution in all markets of oper-
ation.
Our metrics cover corporate income tax, indirect
taxes, withholding taxes, employee taxes, excise taxes,
import duties and other fiscal allowances resembling a
tax. The metric assists Better Collective in assessment of
compliance with policy and thereby al
l relevant tax reg-
ulations
.
During the year, corporate income tax expenses were
impacted by an increase in withholding taxes. This in-
crease represents a temporary timing difference and is
classified as recoverable, with the amount expected to
be refunded in 2026. Additionally, indire
ct tax costs in-
creased in relation to new regulatory requirements in
the Brazilian market implemented in 2025, reflecting the
associated duties paid during the fiscal year.
We plan to continue assessing whether introducing
measurable disclosure targets such as enhanced coun-
try
-
by
-
country tax reporting would provide additional
stakeholder value in future periods
.
Tax transparency
2025
2024
Corporate income tax (tEUR)
1
6
,
2
03
7,249
Employment taxes (tEUR)
24,044
28,836
Indirect taxes (tEUR)
6,138
-
982
Other taxes (tEUR)
1,415
243
Total taxes (tEUR)
4
7
,
8
00
35,346
Accounting policies
Corporate income taxes
Corporate income tax consists of corporate
income taxes and state income taxes paid or
expensed during the year.
Employment taxes
Employment taxes primarily consist of taxes
collected from employees on behalf of the gov-
ernment and social security costs (part of pay-
roll taxes in some countries).
Indirect taxes
Indirect taxes consist of non
-
refundable VAT,
net VAT collections, customs duties and envi-
ronmental taxes (if any).
Other taxes
Other taxes consist of country
-
specific taxes
not linked to one of the categories and with-
holding taxe
s.
===== SIDA 103 =====
Annual report
Page
103
Contribution to
the
development of
local
communities
(MDR)
Long
-
term business success depends on the well
-
being
and resilience of the communities that surround us. Bet-
ter Collective therefore seeks to contribute positively to
the regions where we operate by enhancing education,
employability, and social inclusion.
This commitment is
anchored in our Sustainability Policy, which defines our
role in society as creating transparency, supporting ed-
ucation, and generating shared value in the regions
where we are active.
This topic is material because it
manages a key IRO
for Better Collective. The positive
impact stems from our ability to close educational gaps
by providing relevant, market
-
driven learning where
formal education may fall short. The opportunity lies in
building a sustainable talent pipeline that supports e
m-
ployability, inclusion, and long
-
term growth of our
group and related industries.
Our main initiative, the Better Collective Academies, re-
flects this commitment in practice. The academies
-
lo-
cated in Niš, Serbia, and Paris, France
-
provide free, spe-
cialized education in disciplines such as SEO, SEM, full
-
stack development, WordPress,
business intelligence,
and design. Courses are designed and delivered by in-
ternal experts who combine theoretical instruction with
practical, hands
-
on experience, and structured curricula
are developed and reviewed by experienced mentors.
Each participant
receives individual mentoring, continu-
ous feedback, and a final joint examination conducted
by HR and mentors. Graduates receive certificates rec-
ognizing their achievements. The programme targets
students, jobseekers, and early
-
career professionals in
our
host communities, thus covering own operations
and downstream community beneficiaries
.
In 2025, one SEM academy was hosted in Niš, with eight
graduates. Since 2021
,
when we launched our first acad-
emy
,
99% of academy participants have finalized their
education, 68% have acquired new skills in a field differ-
ent from their formal education, and 70% have received
or accepted a job offer after completing an academy
with Better Collective.
The number of academies deliv-
ered during
each
year reflects internal capacity and pri-
oritization given the resource
-
intensive nature of the
academies and the nee
d to ensure high
-
quality delivery.
Each academy requires significant involvement from in-
ternal subject
-
matter experts, mentors, and HR re-
sources, as well as structured curriculum development
and individual participant support. During 2024 and
2025, Better
Collective has undergone
extensive
organ-
izational restructuring, reduc
ing
internal capacity avail-
able to support academy delivery. As a result, priority
was given to core operational activities, and delivery
was therefore concentrated on one academy in 202
5 to
maintain programme quality and alignment with
organ-
izational
priorities
To evaluate progress, we track the number of annual
graduates as our primary metric.
W
e also review quali-
tative insights such as participant and mentor feedback
to ensure that the programmes remain relevant and ef-
fective. Despite the temporary reduction in scale, feed-
back confirmed continued high satisfaction and align-
ment with local needs.
These evaluations help ensure
that the Academies remain effective and supportive of
Better
Collective’s long
-
term social objective.
Our Academies are financed by
our
local entities as part
of
their
operational expenditures
.
This ensures that ini-
tiatives are sustainably funded without reliance on ex-
ternal grants or short
-
term funding schemes. While we
have only established one measurable, quantitative tar-
get for this topic, we maintain clear qualitative ambi-
tions. Our goal is
to strengthen employability through
education and skills transfer and ensure the long
-
term
sustainability of our
host
communities
.
Continuous
re-
view of outcomes informs our
ambitions
to define meas-
urable impact indicators in future reporting periods.
Number of annual graduates
2025
2024
Graduates from a BC academy
8
15
Accounting principles
Number of graduates from a BC Academy
tracks
the total number of individuals who successfully
graduated from BC Academies in the reporting
year, specifically focusing on our locations in
Paris and Nis. The calculation includes all gradu-
ates who completed their training within the
year 202
5
.
To ensure accuracy, the reported figure is de-
rived from a comparison with the graduate an-
nouncements published on our intranet. Since
our academies are locally owned, we consolidate
the graduate data from both locations to arrive
at the final count.
===== SIDA 104 =====
Annual report
Page
104
Climate change (E1)
105
Transition plan for climate change mitigation
(E1
-
1)
105
Climate
-
related risks (SBM
-
3)
105
Identification & assessment of
106
material IROs (IRO
-
1)
106
Policies (E1
-
2)
106
Actions (E1
-
3)
107
Targets (E1
-
4)
107
Energy consumption & mix (E1
-
5)
108
Gross Scope 1, 2, 3 & total GHG emissions (E1
-
6)
108
EU Taxonomy
112
Environment
===== SIDA 105 =====
Annual report
Page
105
Climate change (E1)
As a global digital sports media group operating in a
data
-
driven ecosystem, we recognize the need to miti-
gate the negative climate
-
related impacts of our busi-
ness. Our operations result in CO₂ emissions primarily
from daily business activities, including
business travel,
the use of data
centers
in our upstream value chain, and
downstream activities related to the distribution of our
services.
These impacts are closely tied to the nature of our busi-
ness model and reflect our reliance on digital infrastruc-
ture for global operations and value delivery
-
activities
that, while essential to our business model, have an as-
sociated climate impact.
Although our direct emissions are limited, these impacts
make climate change a material topic for Better Collec-
tive. They highlight our connection to the broader en-
ergy demand of the digital economy and underline the
importance of addressing our environmen
tal footprint
to minimize our consumption and related impacts to the
extent possible while ensuring the long
-
term resilience
of our business.
Transition plan for
climate change
mitigation (E1
-
1)
We do not currently have a transition plan for climate
change mitigation, but we are ensuring our strategy and
business model are compatible with the transition to a
sustainable economy and limiting global warming to 1.5
degrees in line with the Paris Agre
ement. However, we
have initiated work to assess how to best approach this
based on insight and improved data quality on our GHG
disclosures.
Climate
-
related risks
(SBM
-
3)
In our DMA and related analysis, we have assessed the
identified IROs, specifically evaluating potential climate
-
related risks or hazards.
To identify and assess potential
outcomes of future events under conditions of uncer-
tainty, an environmental analysis was conducted across
E1 to E5
topics
. The environmental analysis considered
our offices’ geographical locations and key upstream
value
-
chain operators, as well as temperature changes
in alignment with the Representative Concentration
Pathways (RCPs) asses
sed by the IPCC in its Fifth As-
sessment Report. Additional inputs were drawn from
sources such as the WWF Risk Filters. The scenarios in
the environmental analysis are centered around the
temperature changes and how those will impact climate
change, including water, pollution, biodiversity, and re-
source use.
The environmental analysis was conducted in connec-
tion with
the 2024 DMA
and has been carried forward to
the current reporting period. The results continue to be
considered representative, as there have been no mate-
rial changes to
our
business model, core activities, geo-
graphical footprint, or upstream value
-
chain structure
during the reporting period.
Based on these scenarios, internal sessions were held to
understand and evaluate if this indicated any physical or
climate
-
related risks or additional IROs not already iden-
tified and assessed. This was particularly relevant to
evaluate whether the data
centers
in our value chain
pose a risk to the environment or to Better Collective.
We consider our business model and current assets and
locations to be exposed to a low degree of climate
-
re-
lated risks and hazards and therefore assess our resili-
ence to be high. We have not identified any physical or
transition risks related to our busine
ss model, locations,
or activities, which forms the basis of our high resilience
assessment derived from the environmental analysis.
As
detailed in the following section,
internal
dialogues in-
form our analysis
, advice from external specialists, and
the
sce
nario
analysis
using bespoke tools to
assess our
situation
.
As we have done in the DMA in general, we have focused
on the short
-
to medium
-
term and the activities we
know and understand well. We have fewer insights into
the potential value chain risks that could indirectly affect
us but generally consider these les
s likely to pose a real
risk to our performance and financials. We
do not con-
sider our identified impacts to directly influence our
overall business model or strategy over the short
-
or
medium
-
term. As an online business with a flexible busi-
ness model, we
can adapt to varying geographical and
environmental conditions, ensuring further resilience in
the face of climate change
.
The resilience
assessment
is subject to uncertainties re-
lated to long
-
term climate developments and limited
upstream data, and while potentially exposed assets and
activities are considered at a strategic level, they are not
yet systematically embedded in investment decisions or
f
ormal mitigation planning
.
===== SIDA 106 =====
Annual report
Page
106
Identification
&
asse
ssment
of
material
IROs
(IRO
-
1)
As described, we have used a combination of internal
dialogues and
advisories
from external environmental
experts to adequately assess our situation. We conclude
that we have an impact on climate change, but it is not
major, considering our GHG footprint.
As part of this as-
sessment, we reviewed our business model, key activi-
ties, and value
-
chain dependencies to identify the main
sources of GHG emissions associated with our opera-
tions. This review was conducted at a qualitative level
and focused on understan
ding where emissions arise
across our own operations and upstream and down-
stream activities, rather than on a detailed quantifica-
tion of emissions by activity.
We supplemented our DMA with an environmental anal-
ysis using bespoke tools to assess environmentally re-
lated IROs. As such, establishing a solid understanding
of our current situation. In this regard, it was also dis-
cussed and evaluated whether scenarios f
or the future
would further expose risks to our business, including ac-
tivities and assets. Using this analysis, we have not iden-
tified any significant future risks.
The discussions and
analyses also considered whether foreseeable develop-
ments in our activi
ties could give rise to additional or in-
creased GHG emission sources in the future. Based on
this high
-
level assessment, no material future emission
sources or related risks were identified beyond those al-
ready understood in relation to our current business
model.
The climate scenarios applied in the environmental anal-
ys
is
were used to identify and assess climate
-
related im-
pacts, risks, and resilience and were not applied as direct
inputs into the preparation of the financial statements.
However, the outcomes of the scenario analysis were
considered at a high level to asses
s whether they indi-
cated potential inconsistencies with climate
-
related as-
sumptions applied in the financial statement
s
. Based on
this assessment, no material inconsistencies were iden-
tified
.
As pa
rt of the DMA and related analysis, we con-
sidered the climate
-
related hazards and transition
events listed
in the climate
-
change application require-
ments. This approach was adequate to assess and un-
derstand our situation, especially considering our po-
tential exposures are limited. We will continue to evalu-
ate the potential benefits of future analytical upgrades
,
including additional scenario parameters or extended
time horizons, to ensure that emerging physical and
transition risks are captured.
Policies (E1
-
2)
W
e are committed to minimizing our environmental
footprint through our overarching Sustainability Policy.
While we do not maintain a standalone Environmental
Policy, our sustainability approach incorporates a long
-
term commitment to the precautionary principle
—
ad-
dressing environmental challenges and reducing carbon
emissions wherever possible.
Our mitigation efforts fo-
cus on reducing operational and value
-
chain emissions,
particularly from business travel and data
-
center
energy
use. As an online business wit
h limited physical infra-
structure, our environmental impact is relatively small,
and climate change currently poses little risk to our op-
erations.
Nevertheless, we aim to reduce our carbon
footprint and related energy consumption and are in the
process of identifying areas for reduction actions. To
support this ambition, we are conducting a comprehen-
sive carbon
-
footprint assessment across our operati
ons
to gain a detailed understanding of our actual environ-
mental impact.
This foundational work is intended to guide future sus-
tainability initiatives, ensuring that we can make more
informed decisions beyond our current focus areas, en-
abling us to make the right choices.
In addition, our
Travel Policy functions as a cross
-
cutting policy instru-
ment that indirectly supports climate change mitigation.
It encourages employees to travel only, when necessary,
to consider virtual meetings as an alternative, and to
pri-
oritize
lower
-
emission options such as trains and public
transportat
ion where feasible. Travel bookings are con-
solidated through Navan, which also supports CO₂
tracking for business travel.
Environmental analysis
We have collaborated with external spe-
cialists as part of our DMA across all envi-
ronmental
-
related topics. This resulted in
the development of an environmental
analysis assessing our largest sites and up-
stream data centers. The environmental
analysis is al
igned with requirements set
forth in the ESRS related to resilience anal-
ysis and scenario analysis.
The environmental analysis ultimately
concluded no transitional or physical risks
related to climate change as well as no ac-
tual or potential pollution
-
related IROs.
The environmental analysis also found no
actual or potential biodiversity and eco-
systems
-
r
elated IROs, nor any transitional,
physical or systemic risks. The analysis
also assessed actual and potential IROs re-
lated to circular economy and water and
marine resources, concluding both topics
are immaterial for Better Collective.
===== SIDA 107 =====
Annual report
Page
107
Actions (E1
-
3)
We are committed to acting as responsible corporate
citizens. We recognize the importance of climate
change mitigation and are dedicated to expanding our
efforts across our operations in the future. Currently, no
formalized climate action programme with de
fined per-
formance indicators is in place, as we are in the process
of developing a data
-
driven baseline and
prioritizing
fo-
cus areas before implementing specific reduction initia-
tives. We aim to formalize our climate
-
related actions,
monitoring processes,
and performance indicators
within a short
-
to medium
-
term timeframe.
A key exist-
ing mitigation action is our Travel Policy, which governs
all business travel across the group. Through this Policy,
we seek to limit avoidable travel
-
related emissions while
ensuring that necessary travel remains safe, efficient,
and aligned wi
th business needs.
One of the primary sources of carbon emissions in our
business is travel, particularly business
-
related travel.
This significantly influences our ambition to lower our
carbon footprint. To address this, our travel decisions
must consider both environmental
and economic im-
pacts, balancing them against the benefits of in
-
person
meetings.
Beyond travel, our procurement choices con-
tribute to our carbon footprint, particularly in server
hosting, IT infrastructure, and office equipment. When
selecting
data center
suppliers, we
try to
integrate envi-
ronmental considerations
alongside technical, security,
and commercial criteria. These include
the
extent to
which data centers
have
efforts
in place
to reduce en-
ergy intensity through efficient infrastructure and hard-
ware design, and initiatives related to resource effi-
ciency
.
This approach supports the reduction of up-
stream emissions associated with our digital operations
while maintaining operational resilience and perfor-
mance.
Targets (E1
-
4)
We recognize our material impact on climate change
and acknowledge the importance of tracking and miti-
gating our environmental footprint. At present, we do
not plan to set measurable emission
-
reduction targets,
as our operations have a relatively low carbo
n footprint
and immaterial exposure to climate
-
related risks. In-
stead, our focus is on maintaining low
-
impact opera-
tions and improving efficiency where feasible.
We continue to assess our environmental performance
to ensure our operations remain aligned with responsi-
ble business practices. The effectiveness of our ap-
proach is tracked through periodic internal reviews of
business travel, data
-
center
energy use, and supplier
practices. Our qualitative ambition is to preserve a low
emissions profile and to enhance awareness and ac-
countability across the
organization
rather than pursu-
ing quantitative reduction goals
.
===== SIDA 108 =====
Annual report
Page
108
Energy consumption
&
mix (E1
-
5)
Gross
S
cope 1, 2, 3 & total GHG emissions (E1
-
6)
Energy consumption and mix
2025
2024
Total fossil energy consumption (MWh)*
2,313
2,677
Consumption from nuclear sources (MWh)
0
0
Fuel consumption for renewable sources, including biomass (also comprising industrial and municipal waste
of biologic origin, biogas, renewable hydrogen, etc.) (MWh)
55
131
Consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources (MWh)
0
0
The consumption of self
-
generated non
-
fuel renewable energy (MWh)
0
0
Total renewable energy consumption (MWh)
55
131
Total energy consumption (MWh)*
2,368
2,807
*Restated to reflect proportional office use in Serbia, resulting in a 25% decrease versus 2024 reported data.
Scope 1 GHG emissions
2025
2024
Gross Scope 1 GHG emissions (tCO2eq)
79
74
Percentage of Scope 1 GHG emissions from regulated emission trading schemes (%)
0%
0%
Scope 2 GHG emissions
Gross location
-
based Scope 2 GHG emissions (tCO2eq)*
541
629
Gross market
-
based Scope 2 GHG emissions (tCO2eq)*
812
940
Significant scope 3 GHG emissions
Total Gross indirect (Scope 3) GHG emissions (tCO2eq)**
22,828
22,720
1. Purchased goods and services
3,629
4,363
2. Capital goods
61
461
3. Fuel and energy
-
related Activities**
186
218
6. Business
traveling
1,472
3,406
7. Employee commuting**
505
545
11. Use of sold products**
16,975
13,727
Total GHG emissions
Total (with location
-
based GHG emissions (tCO2eq)***
23,447
23,423
Total (with market
-
based GHG emissions (tCO2eq)***
23,718
23,734
GHG emission intensity
Location based
-
(total GHG emissions per net revenue)
0.0696
0.0631
Market based
-
(total GHG emissions per net revenue)
0.0704
0.0639
*
Restated following energy data corrections and emissions recalculations, resulting in 53% and 49% reductions in gross locatio
n
-
and
market
-
based Scope 2 emissions, respectively, versus 2024 reported data.
**
Restated to reflect corrected energy data and updated 2025 methodologies, resulting in a 14% reduction in total gross Scope 3
emissions and reductions of 49%, 5%, and 21% in the specified categories compared to 2024 reported data.
***
Revisions to Scope 2 and Scope 3 GHG emissions resulted in decreases of 16% and 17% in total location
-
based and market
-
based
GHG emissions, respectively, compared to 2024 reported data.
===== SIDA 109 =====
Annual report
Page
109
Scope 1
Our scope 1 emissions derive from
direct fuel combustion for
heating and
from the use of
g
as refrigerants to cool the
offices
.
Better Collective are presenting greenhouse gas (GHG) emissions data starting from 2024 baseline year. Prior
-
year figures are not disclosed due to the acquisition of PMKR, which prevents reliable recalculation of historical emis-
sions.
Scope 2
Our scope 2 accounts for
office
electricity and district heating
.
Better Collective are
presenting
greenhouse gas (GHG)
emissions data starting from 2024 baseline year.
Prior
-
year figures are not disclosed
due to
the
ac
quisition of PMKR
,
which prevents reliable recalculation of historical emissions.
Accounting principles
Scope 1 emissions in our offices arise from the combustion of natural gas, oil, and wood pellets used for space
heating, as well as from the use of cooling gases in air conditioning and refrigeration equipment.
The input is
based on consumption data from external sources or estimates, which
were
converted into tons CO2 equivalents
(tCO2e) using generic and/or specific emission factors.
The emission factors used in
S
cope 1 are the newest available from DEFRA (2025). The cooling gases from
DEFRA uses the 100
-
year time horizon global warming potential (GWP) values from the IPCC fifth Assessment
Report (AR5), and not the values from the IPCC Sixth Assessment Report, 2020
(AR6).
The estimated numbers are either based on the number of employees at the office or the size of the office and
calculated based on emission in comparable offices we have in the area
,
or the headquarters.
GHG
emission
intensity
GHG intensity based on net revenue
was
calculated as gross
S
cope 1, Scope 2 location
-
based / market
-
based,
and gross
S
cope 3 emissions divided by reported net revenue in tEUR.
Accounting principles
Scope 2 greenhouse gas (GHG) emissions refer to indirect emissions resulting from the generation of purchased
energy used by an organization. Scope 2 emissions occur at the facility where the energy is generated, thus
being classified as indirect emissions
.
The emissions in
S
cope 2 are linked to electricity and district heating consumption related to Better Collective
’
s
office activities. The input is based on consumption data from external sources or estimates, which
were
con-
verted into tons of CO2 equivalents (tCO2e) using generic and/or specific emission factors.
The estimated numbers are either based on the number of employees at the office or the size of the office and
calculated based on emission in comparable offices we have in the area
, or the headquarters
.
Emission factors used in
S
cope 2 are from IEA and AIB for location
-
and market
-
based electricity. Where appli-
cable, more locally available sources
were
used, such as “Energinet” for Denmark. For district heating, DEFRA
2025
was
used internationally, and where applicable, locally available sources
were
used as well, such as
“Miljødeklaration” for local Danish district heating, “Stockholm Exergi” for district heating in Sweden, etc.
Energy consumption
and mix
Energy consumption covers the same energy as
S
cope 1 and 2. Energy from purchased electricity, heat and
cooling is assumed to originate from fossil sources as renewable or nuclear energy has not been actively pro-
cured. Biomass fuels are reported as renewable.
===== SIDA 110 =====
Annual report
Page
110
Scope 3
Scope 3 emissions are the indirect greenhouse gas emissions attributed to
our
value chain.
The
accounting principles for the reported categories
are as
follows:
Accounting principles
1 Purchased goods and services
GHG emissions associated with the
g
roup’s purchase of goods and services
were
calculated as the direct cost associated with a specific type multiplied by a matching emission factor from
Conerstone (2025) v1.4,
direct
-
spend
-
based emission
factors. The direct cost
was
converted to EUR using the average exchange rate for the year to align with the currency used in the spend
-
based emission factors.
2 Capital goods
GHG emissions associated with the
g
roup’s additions to tangible assets
were
calculated as the capitalized cost associated with a specific type multiplied by a matching emission factor
from
Conerstone (2025) v1.4,
direct
-
spend
-
based
emission factors. The capitalized amount
was
converted to EUR using the average exchange rate for the year to align with the currency used in the spend
-
based emissions factors.
3 Fuel
-
and energy
-
related activities
GHG emissions related to fuel and energy
-
related activities not accounted for in Scope 1 or 2 comprise indirect emissions associated with producing purchased fuels an
d electricity. The GHG emissions in fuels and energy
-
related activities
were
calculated using the consumption from Scope 1 and 2 and emission factors
from DEFRA (2025) and IEA (2025).
6 Business travel
GHG emissions associated with the
g
roup’s business travel activities
were
calculated as the direct cost associated with flight, taxi, train, bus, and accommodation multiplied by a matching emission f
actor from
Conerstone (2025) v1.4,
or EPA
(2024) v1.3 direct
-
spend
-
based emission factors.
The direct cost
was
converted to EUR using the average exchange rate for the year to align with the currency used in the spend
-
based emission factors. For the category of flight and
h
otel
stays, emissions
were
based on supplier
-
specific data. To avoid double counting, the part of the direct cost related to supplier
-
specific data
was
subtracted from the direct cost base of the spend
-
based emission calculation
. 34.3% of the
emissions is based on supplier specific data.
7 Employee commuting
GHG emissions related to employee commuting are linked to the emissions generated from employee’s transportation between thei
r homes and their place of work. Emissions have been calculated based on answers to a
g
roup
-
wide survey
distributed
in
November 2025
, with a
response rate
of
41
%.
The survey included questions regarding
m
eans of transportation and type, distance to work, and average weekly days spent working in the office. These average commuti
ng weeks
were
multiplied by the average number of working weeks. The emissions related to working from home
were
calculated based on the assumed energy consumption related to working from home. To calculate the GHG emissions, the
2025
version of DEFRA’s
business travel
-
land emission fac
tors
were
used.
11 Use of sold product
Use of sold products covers the scope 1 and 2 emissions associated with the use of sold products in the reporting year. For B
etter Collective, this means user activity emissions
across
our
sites.
I
nformation on the number of hours and type
of device used to access our sites
were collected and
applied to the average data on electricity consumption per hour of
the
devices. Th
e
energy consumption related to the use of our sites was applied to the
Global IEA (2025)
electricity
factor to c
alculate emissions from the use of our products.
===== SIDA 111 =====
Annual report
Page
111
Scope 3
non
-
material
categories
We have assessed all categories in
S
cope 3 to determine
whether they are material or
non
-
material
. The following
categories are not relevant to our business model or ac-
tivities:
4. Upstream transportation
&
distribu-
tion
This category has been deemed non
-
material. As a
digi-
tal sports m
edia
group
, we primarily deliver services ra-
ther than physical goods.
5. Waste
This category has been deemed non
-
material
since
we
are
a
digital sports m
edia
group
primarily deliver ser-
vices and
thus
do not have material waste from produc-
tion
,
etc.
8. Upstream leased assets
This category has been deemed non
-
material
as w
e do
not have any leased assets that are not in our control.
9. Downstream transportation
&
distri-
bution
This category has been deemed non
-
material, as we do
not distribute materials to clients.
10. Processing of sold products
This category has been deemed non
-
material. As
a
digi-
tal sports
m
edia
group
our business model is based on
the delivery of services, meaning we do not sell physical
products that require further processing by our clients.
12. End
-
of
-
life treatment of sold products
This category has been deemed non
-
material. End
-
of
-
life treatment of
products sold
is not applicable to our
operations. We do not sell physical products that require
disposal or treatment at the end of their lifecycle.
13. Downstream leased assets
This category has been deemed non
-
material, as we do
not act as a lessor. The group has subleases at the office
in Copenhagen, but the
emissions
are included in
S
cope
1 and 2.
14. Franchises
This category has been deemed non
-
material, as we do
not operate with franchises.
15. Investments
This category has been deemed non
-
material
a
s we do
not have investments.
===== SIDA 112 =====
Annual report
Page
112
EU Taxonomy
The EU Taxonomy is a regulatory
framework introduced by the
European Union as a tool to aid in
the transition towards a greener and
more sustainable economy
.
The EU Taxonomy addresses six environmental objec-
tives:
•
Climate change mitigation
•
Climate change adaptation
•
Sustainable use and protection of water and marine
resources
•
Transition to a circular economy
•
Pollution prevention and control
•
Protection and restoration of biodiversity and
eco
-
systems
We have reviewed and assessed which economic activ-
ities are eligible under the EU Taxonomy definition and
subsequently allocated financial numbers to these activ-
ities.
The annual process for assessing compliance with the
criteria
outlined
in Article 3 of Regulation (EU)
2020/852 has been conducted in three stages:
1. Screening of eligible economic activi-
ties
We
reviewed
the technical annexes from the Climate
Delegated Act, the Complementary Climate Delegated
Act, the Environmental Delegated Act, and amendments
to the Climate Delegated Act. Our goal was to identify
any potentially eligible economic activities relevant to
the revenue KPI
and
categories (a) and (c) of the CAPEX
and OPEX KPIs. During our evaluation period, we
out-
lined
areas with eligible economic activities
that
re-
quired
further eligibility assessment
.
2. Assessment of eligible economic activ-
ities
Each identified economic activity was evaluated to de-
termine how well the description in the annex corre-
sponds to Better Collective’s operations.
3. Assessment of the alignment of eco-
nomic activities
For each eligible economic activity, we identified key in-
ternal stakeholders to assist in locating and gathering
the necessary documentation to satisfy the alignment
criteria.
Eligible activities
Our eligible economic activit
y
for the financial year 202
5
is
:
Climate change mitigation
7.7. Acquisition and ownership of buildings
Aligned activities
Based on the screening process, we determined that
Better Collective’s current activities do not align with
any of the activities specified under the EU Taxonomy.
The eligible activit
y
does
not live up to the technical
screening criteria.
Revenue
Better Collective’s main activities within sports media
and entertainment are excluded from the taxonomy un-
der 13.1 Creative, arts
,
and entertainment activities.
However, to
ascertain whether Better Collective has any
other economic activities
that
could be eligible for
tax-
onomy
, the group has
analyzed its
business
, which
shows that the Group has
no
activities that are eligible
under the taxonomy.
OPEX
Based on the screening process, we concluded that the
OPEX for Better Collective’s current activities
do
not
meet the
EU Taxonomy
eligibility criteria
.
However, we
will continue to monitor updates to the framework to as-
sess any future alignment opportunities as the
taxono-
my's
scope evolves.
CAPEX
Eligible CAPEX consists of additions to tangible assets,
such as property, plant, and equipment (including addi-
tions to leased assets), that are associated with Taxon-
omy
-
eligible activities.
Minimum safeguards
The minimum safeguards are part of the Taxonomy Reg-
ulation and are based on the recommendation from the
Technical Expert Group
.
They were included to ensure
that entities
that
are carrying out environmentally sus-
tainable activities that are
labeled
as Taxonomy
-
aligned
meet certain minimum governance standards and do
not negativ
ely
impact human rights
,
including labor
rights, corrupt practices, or are linked to non
-
compli-
ance with letter or spirit of tax laws or anti
-
competitive
practices.
Practically, this means that undertakings whose eco-
nomic activities are to be considered as Taxonomy
-
aligned
must
align with the standards for responsible
business conduct mentioned in:
• The OECD Guidelines for Multinational Enterprises
• The UN Guiding Principles on Business and Human
Rights, including the principles and rights set out in the
eight fundamental conventions identified in the Decla-
ration of the International Labor Organi
z
ation on Funda-
mental Principles and Rights at Work
• The International Bill of Human Rights
Since Better Collective does not claim alignment based
on other technical criteria, the assessment of
compli-
ance with minimum safeguards
has
not been assessed
.
===== SIDA 113 =====
Annual report
Page
113
Accounting principles
Revenue
The proportion of revenue is calculated as the part of the net revenue derived from products or services associ-
ated with Taxonomy economic activities divided by the net revenue (Note 4 in the Financial Statements). Better
Collective do not have any eligibl
e revenue.
OPEX
Non
-
capitalized costs that relate to research and development, building renovation measures, short
-
term lease,
maintenance and repair, and any other direct expenditures relating to the day
-
to
-
day servicing of assets of
property, plant and equipment by the
undertaking or third party to whom activities are outsourced that are
necessary to ensure the continued and effective functioning of such assets. Better Collective do not have any
eligible OPEX.
CAPEX
CAPEX is calculated as the 'Addition of tangible and intangible assets', which is generated from note 12 and 14
of the consolidated financial statements. Included in the figures is the value from leasing of office buildings
(Capitalized under IFRS16). The
CAPEX KPI is defined as Taxonomy
-
eligible capex (numerator) divided by total
CAPEX accounted based on IAS 16, IAS 38, IAS 40, IAS 41, IFRA 16 (denominator) which include additions to
business combinations without considering goodwill.
Double counting
For the allocation of the numerator for CAPEX, we have first identified the relevant figures and then allocated
the primary related economic activity in the Climate Delegated Act. In this way, we ensure that no CAPEX is
considered more than once.
Contribution to multiple objectives
Regarding our identified economic activities, we note that none of these contribute to multiple objectives, as
there is only one eligible activity related to CAPEX.
Disaggregation of KPIs
There has been no disaggregation of KPIs for any economic activity assessed
.
===== SIDA 114 =====
Annual report
Page
114
Breakdown by environmental objectives of Taxonomy aligned acitivities
KPI (1)
Total (2)
Proportion
of Taxon-
omy eligi-
ble activi-
ties (3)
Taxonomy
aligned ac-
tivities (4)
Proportion
of Taxon-
omy
aligned ac-
tivities (5)
Climate
change
mitigation
(6)
Climate
change ad-
aptation
(7)
Water (8)
Circular
economy
(9)
Pollution
(10)
Biodiver-
sity (11)
Proportion
of Taxon-
omy ena-
bling activ-
ities (12)
Proportion
of Taxon-
omy transi-
tional ac-
tivities (13)
Not as-
sessed ac-
tivities
considered
non
-
mate-
rial (14)
Taxonomy
aligned ac-
tivities in
2024 (N
-
1)
(15)
Proportion
of Taxon-
omy
aligned ac-
tivities in
2024 (N
-
1)
(16)
tEUR
%
tEUR
%
%
%
%
%
%
%
%
%
%
tEUR
%
Revenue
3
36
,
669
0%
0
0%
n/a
n/a
n/a
n/a
n/a
n/a
0%
0%
0%
0
0%
CapEx
25
,
174
10
%
0
0%
n/a
n/a
n/a
n/a
n/a
n/a
0%
0%
0%
0
0%
OpEx
2
34
,6
16
0%
0
0%
n/a
n/a
n/a
n/a
n/a
n/a
0%
0%
0%
0
0%
Environmental objective of Taxonomy aligned activities
Economic activities (1)
Code (2)
Proportion
of Taxon-
omy eligi-
ble reve-
nue (3)
Taxonomy
aligned
revenue
(4)
Proportion
of Taxon-
omy
aligned
revenue (5)
Climate
change
mitigation
(6)
Climate
change ad-
aptation
(7)
Water (8)
Circular
economy
(9)
Pollution
(10)
Biodiver-
sity (11)
Enabling
activities
(12)
Transi-
tional ac-
tivities (13)
Proportion
of Taxon-
omy
aligned in
Taxonomy
eligble (14)
Revenue
%
tEUR
%
%
%
%
%
%
%
%
Acitivity
0%
0
0%
n/a
n/a
n/a
n/a
n/a
n/a
0%
Sum of alignment per objective
0%
0
0%
n/a
n/a
n/a
n/a
n/a
n/a
0%
Total revenue
0%
0
0%
n/a
n/a
n/a
n/a
n/a
n/a
0%
===== SIDA 115 =====
Annual report
Page
115
Environmental objective of Taxonomy aligned activities
Economic activities (1)
Code (2)
Proportion
of Taxon-
omy eligi-
ble CapEx
(3)
Taxonomy
aligned
CapEx (4)
Proportion
of Taxon-
omy
aligned
CapEx (5)
Climate
change
mitigation
(6)
Climate
change ad-
aptation
(7)
Water (8)
Circular
economy
(9)
Pollution
(10)
Biodiver-
sity (11)
Enabling
activities
(12)
Transi-
tional ac-
tivities (13)
Proportion
of Taxon-
omy
aligned in
Taxonomy
eligble (14)
CAPEX
%
tEUR
%
%
%
%
%
%
%
%
Acquisition and ownership of buildings
7.7
10
%
0
0%
n/a
n/a
n/a
n/a
n/a
n/a
0%
Sum of alignment per objective
0%
0
0%
n/a
n/a
n/a
n/a
n/a
n/a
0%
Total CapEx
10
%
0
0%
n/a
n/a
n/a
n/a
n/a
n/a
0%
Environmental objective of Taxonomy aligned activities
Economic activities (1)
Code (2)
Proportion
of Taxon-
omy eligi-
ble OpEx
(3)
Taxonomy
aligned
OpEx (4)
Proportion
of Taxon-
omy
aligned
OpEx (5)
Climate
change
mitigation
(6)
Climate
change ad-
aptation
(7)
Water (8)
Circular
economy
(9)
Pollution
(10)
Biodiver-
sity (11)
Enabling
activities
(12)
Transi-
tional ac-
tivities (13)
Proportion
of Taxon-
omy
aligned in
Taxonomy
eligble (14)
OPEX
%
tEUR
%
%
%
%
%
%
%
%
Acitivity
0%
0
0%
n/a
n/a
n/a
n/a
n/a
n/a
0%
Sum of alignment per objective
0%
0
0%
n/a
n/a
n/a
n/a
n/a
n/a
0%
Total OpEx
0%
0
0%
n/a
n/a
n/a
n/a
n/a
n/a
0%
===== SIDA 116 =====
Annual report
Page
116
Statement by Management
117
Independent Auditors’ Report
118
Independent Auditors’ limited assurance report
on Sustainability Statements
122
Statements
===== SIDA 117 =====
Annual report
Page
117
Statement by
M
anagement
The Board of Directors and the Executive Board have to-
day discussed and approved
Better Collective A/S's
202
5
annual report
.
The annual report has been prepared in accordance with
International Financial Reporting Standards as adopted
by the EU and additional requirements of the Danish Fi-
nancial Statements Act.
It is our opinion that the consolidated financial state-
ments and the parent
company's
financial statements
give a true and fair view of the
group and parent com-
pany's financial position
on
December 31, 202
5
,
and of
the results of the
g
roup’s and the
p
arent
c
ompany’s op-
erations and cash flows for the financial year January 1
–
December 31, 202
5
.
Further, in our opinion, the
m
anagement’s review gives
a fair review of the development in the
g
roup’s and the
p
arent
c
ompany’s activities and financial matters, re-
sults of operations, cash flows
, and financial position,
as
well as a description of material risks and uncertainties
that the
g
roup and the
p
arent
c
ompany face.
The Sustainability Statements
are
prepared in accord-
ance with the European Sustainability Reporting
Standards
(ESRS), as required by the Danish Financial
Statements Act and article 8 of
the EU Taxonomy regu-
lation.
In our opinion, the annual report for the financial year
January
1
–
December 31
,
202
5
,
with the file name
bet-
tercollective
-
202
5
-
12
-
31
-
en.zip
,
is
prepared, in all mate-
rial respects, in compliance with the ESEF Regulation.
We recommend that the annual report be approved at
the annual general meeting.
Copenhagen,
February
2
5
, 202
6
Executive Management
Jesper Søgaard
Co
-
CEO & Co
-
founder
Executive Vice President
Christian Kirk Rasmussen
Co
-
CEO
& Co
-
founder
Executive Vice President
Flemming Pedersen
CFO
Executive Vice President
Board of Directors
Jens Bager
Chair
Therese Hillman
Vice Chair
Britt Boeskov
Todd Dunlap
Leif Nørgaard
René Rechtman
Thomas Stig Plenborg
===== SIDA 118 =====