Voluntary Disclosure. Intermediary AS does not meet the CSRD size thresholds (fewer than 10 employees, annual revenue below €40M, total assets below €20M) and is therefore not legally required to report under the Corporate Sustainability Reporting Directive. This report is prepared voluntarily, aligned with the European Sustainability Reporting Standards (ESRS), to demonstrate our commitment to transparency and sustainable business practices.
1 General Information ESRS 2
1.1 Basis for Preparation
This report covers Intermediary AS (org. nr. NO 925 615 471 MVA), domiciled in Stavanger, Norway. The reporting boundary encompasses all activities operated directly by Intermediary AS through its platforms registercompany.no and norwegiancompany.com.
1.2 Business Model & Value Chain
Intermediary AS provides digital company formation and compliance solutions for international clients establishing legal entities in Norway. Our value chain:
| Stage | Description | Key Partners |
|---|
| Upstream | Cloud infrastructure, identity verification, regulatory APIs | Microsoft Azure, Criipto, Brønnøysundregistrene |
| Core operations | Digital platform development, customer service, AML/KYC | Internal team (incl. two international interns, Stockholm, Sweden; Haoyu Wang (male, Chinese citizen), both started 2026) |
| Downstream | Company registration delivery, ongoing compliance support | International founders, corporate clients |
1.3 Governance Structure
| Role | Name | ESG Responsibility |
|---|
| CEO / Styreleder | Morten Ims | Overall ESG strategy, Transparency Act, reporting approval |
| CTO / ISA | Torben Wind Meyhoff | Data ethics, information security, green infrastructure |
| Board Member | Jorun Ims | Board oversight of sustainability strategy |
1.4 Stakeholder Engagement
- Clients: Surveyed via platform feedback and direct communication
- Team: Continuous dialogue through remote collaboration tools
- Regulators: Active monitoring of Norwegian and EU regulatory developments
- Suppliers: Annual risk assessment per R-48 (Third Party Risk Management)
2 CSRD Applicability Assessment
Under Directive (EU) 2022/2464 (CSRD), the following thresholds determine reporting obligations:
| Criterion | CSRD Threshold | Intermediary AS 2025 | Status |
|---|
| Number of employees |
> 250 (large) / > 10 (SME) |
0 FTE (4 team members) |
Below threshold |
| Net revenue |
> €40M (large) / > €700K (SME) |
NOK 105 483 (~€9 100) |
Below threshold |
| Total assets |
> €20M (large) / > €350K (SME) |
NOK 48 832 (~€4 200) |
Below threshold |
| Listed on regulated market |
Yes |
No — private limited (AS) |
Not applicable |
Conclusion: Intermediary AS is classified as a micro-enterprise and is not subject to mandatory CSRD reporting. This report is prepared voluntarily to align with best practices and prepare for potential future requirements as the company scales.
3 Double Materiality Assessment ESRS 2 IRO-1
In accordance with ESRS 1 §3, we have conducted a simplified double materiality assessment considering both impact materiality (how we affect people and planet) and financial materiality (how sustainability matters affect our financials).
| Topic | ESRS | Impact Materiality | Financial Materiality | Material? |
|---|
| Climate change — own operations | E1 |
Low |
Low |
Voluntary |
| Climate change — value chain (Scope 3) | E1 |
Medium |
Low |
Voluntary |
| Pollution | E2 |
N/A |
N/A |
Not material |
| Water & marine resources | E3 |
N/A |
N/A |
Not material |
| Biodiversity | E4 |
N/A |
N/A |
Not material |
| Circular economy | E5 |
Low |
N/A |
Not material |
| Own workforce | S1 |
Medium |
Medium |
Material |
| Workers in value chain | S2 |
Medium |
Low |
Voluntary |
| Affected communities | S3 |
Low |
Low |
Not material |
| Consumers & end-users | S4 |
Medium |
Medium |
Material |
| Business conduct | G1 |
Medium |
Medium |
Material |
🌱 Environmental — Low impact (digital-only)
🤝 Social — Material (workforce, consumers)
⚖️ Governance — Material (conduct, compliance)
4 Environment — Climate Change ESRS E1
4.1 GHG Emissions Overview
As a fully digital, remote-first company with no physical offices, manufacturing, or fleet, our greenhouse gas emissions are minimal. We report the following:
| Scope | Category | Source | Estimated Emissions | Status |
|---|
| Scope 1 |
Direct emissions |
No owned facilities, vehicles, or equipment |
0 tCO₂e |
Zero |
| Scope 2 |
Indirect — energy |
Cloud hosting (Azure EU — renewable energy), team home offices |
~0.2 tCO₂e |
Minimal |
| Scope 3 |
Value chain |
Business travel, supplier operations, purchased services |
Not yet quantified |
Mapping planned |
4.2 Climate Targets
- Short-term (2026): Maintain zero Scope 1 emissions; continue green hosting
- Medium-term (2027): Complete Scope 3 mapping for top 10 suppliers
- Long-term: Deliver a fully CO₂-neutral company registration process
4.3 Climate Actions Taken
| Action | Impact | Status |
|---|
| 100% remote workforce — no commuting | Eliminates daily transport emissions | Active |
| Azure EU data centers (renewable energy) | Low-carbon cloud infrastructure | Active |
| Paperless operations | Zero paper, printing, shipping | Active |
| Trefadder partnership | CO₂-neutral website certification | Active |
| Scope 3 emissions mapping | Full value chain visibility | Planned 2027 |
5 Environment — Pollution, Water, Biodiversity & Circular Economy ESRS E2–E5
Not material. As a fully digital services company, Intermediary AS has no material impact on pollution, water/marine resources, biodiversity, or circular economy. We have no physical production, no chemical usage, and no waste streams beyond standard electronics recycling.
| ESRS | Topic | Assessment |
|---|
| E2 | Pollution | No emissions to air, water, or soil. No hazardous substances. |
| E3 | Water & marine resources | No water consumption beyond domestic use (home offices). |
| E4 | Biodiversity & ecosystems | No operations in or near biodiversity-sensitive areas. |
| E5 | Resource use & circular economy | Digital-only model. Minimal hardware (laptops, monitors). E-waste recycled. |
6 Social — Own Workforce ESRS S1
6.1 Workforce Composition
| Metric | 2025 | Note |
|---|
| Full-time equivalent (FTE) | 0 | Founder-operated; no salaried employees |
| Active team members | 4 | Founders + interns (all male) |
| Gender distribution | 100% male / 0% female | Board: 100% male / 0% female |
| Nationalities | 4 | Norwegian, Danish, Chinese (Haoyu Wang, intern, Stockholm), Lithuanian (intern, Stockholm; begge startet 2026) |
| Age range | 20–47 | Founders: 43 & 47 (born 1982, 1978) |
| Remote workers | 100% | Fully distributed (NO, DK, SE) |
6.2 Working Conditions & Policies
- Code of Conduct (R-18): Covers anti-discrimination, harassment, ethics
- Equality Plan (R-19): Gender balance targets for future hiring
- HMS (Occupational Health & Safety): CEO completed HMS-opplæring §3-5 (Q2 2026)
- Flexible work: Remote-first, autonomous scheduling, work-life balance focus
- Training: 7 E-Learning modules mandatory for all team members, incl. GDPR, Compliance & Governance, and Sustainability & ESG
6.3 Health, Safety & Well-being
| Indicator | 2025 |
|---|
| Work-related accidents | 0 |
| Work-related fatalities | 0 |
| Sick leave rate | N/A (no FTE) |
| Whistleblower reports received | 0 |
| Discrimination complaints | 0 |
7 Social — Workers in the Value Chain ESRS S2
Intermediary AS has conducted due diligence on its supply chain in accordance with the Norwegian Transparency Act (Åpenhetsloven). Detailed findings are documented in R-16.
7.1 Supplier Overview
| Category | Count | Geography | Risk Level |
|---|
| Government & regulatory | 11 | Norway | Low |
| Critical ICT suppliers | 6 | EU/EØS, Nordics, USA/EU | Medium |
| Payment solutions | 3 | Norway, EU | Low |
| Accounting & finance | 3 | Norway | Low |
| Events & marketing | 5 | Norway, EU | Low |
| Transport & travel | 6 | Nordics | Low |
| Freight & logistics | 1 | EU | Low |
| Hardware | 2 | Global (ad hoc) | Low |
7.2 Due Diligence Results
- No actual negative impacts identified in the reporting period
- No complaints or whistleblower reports related to supply chain working conditions
- All critical ICT suppliers are established companies with documented sustainability policies
- OECD 6-step due diligence process applied (documented in R-16 §5)
8 Social — Communities & Consumers ESRS S3–S4
8.1 Community Impact
By enabling foreign entrepreneurs to establish legal entities in Norway, Intermediary AS contributes to:
- Cross-border entrepreneurship and economic growth
- Increased tax revenue for Norway through new company formations
- Reduction of barriers to international business establishment
- Since 2026, Intermediary AS has been a Gold Sponsor for Clean Shores Global (1 year, auto-renew), supporting environmental and social responsibility for clean oceans and coastlines.
8.2 Consumer / End-User Protections
| Measure | Implementation | Document |
|---|
| Privacy Policy | GDPR-compliant, publicly available | R-12 |
| Cookie Policy | Cookie consent management | R-14 |
| Data governance | Internal privacy & data strategy | R-22, R-42 |
| AML/KYC screening | All clients screened before service delivery | Internal procedures |
| Complaint handling | Contact form + direct communication | — |
9 Governance — Business Conduct ESRS G1
9.1 Anti-Corruption & Anti-Bribery
- Ethical guidelines (R-18) explicitly prohibit corruption, bribery, and conflicts of interest
- No incidents of corruption identified in 2025
- All team members complete mandatory Compliance & Governance E-Learning module
9.2 Whistleblower Channel
An internal whistleblower reporting channel is established per R-15, compliant with EU Directive 2019/1937 and the Norwegian Working Environment Act §2A. No reports were received in 2025.
9.3 Regulatory Compliance
| Regulation | Compliance Status |
|---|
| GDPR / Personopplysningsloven | Compliant |
| Åpenhetsloven (Transparency Act) | Compliant — R-16 published |
| Hvitvaskingsloven (AML Act) | Compliant |
| eIDAS (EU) | Aligned — R-27 |
| EU Data Act | Aligned |
| ISO 27001:2022 | Implemented (QMS) |
| NS-EN ISO 9001:2015 | Quality system operational |
9.4 Tax Transparency
| Jurisdiction | Tax ID | Tax Payments 2025 |
|---|
| Norway | NO 925 615 471 MVA | MVA reported quarterly; corporate tax per assessment |
Intermediary AS operates exclusively in Norway and has no subsidiaries, branches, or operations in tax havens.
10 Key Performance Indicators
0
Scope 1 Emissions (tCO₂e)
~0.2
Scope 2 Emissions (tCO₂e)
Financial Context
| Key Figures (NOK) | 2023 | 2024 | 2025 |
|---|
| Revenue | 198 330 | 96 490 | 105 483 |
| Operating result | −7 491 | −21 722 | −30 266 |
| Net result | −10 905 | −22 414 | −30 970 |
| Total assets | — | — | 48 832 |
Early-stage startup with negative equity as of 2025. Going concern confirmed by the Board. YTD Q1 2026 shows positive operating margin (23.7%).
11 ESRS Disclosure Index
Cross-reference of ESRS standards addressed in this report:
| ESRS | Standard | Section | Coverage |
|---|
| ESRS 1 | General Requirements | §1, §2, §3 | Covered |
| ESRS 2 | General Disclosures | §1 | Covered |
| ESRS E1 | Climate Change | §4 | Partial — Scope 3 pending |
| ESRS E2 | Pollution | §5 | Not material |
| ESRS E3 | Water & Marine Resources | §5 | Not material |
| ESRS E4 | Biodiversity & Ecosystems | §5 | Not material |
| ESRS E5 | Resource Use & Circular Economy | §5 | Not material |
| ESRS S1 | Own Workforce | §6 | Covered |
| ESRS S2 | Workers in Value Chain | §7 | Covered |
| ESRS S3 | Affected Communities | §8 | Partial |
| ESRS S4 | Consumers & End-Users | §8 | Covered |
| ESRS G1 | Business Conduct | §9 | Covered |
12 Related Documents
| Doc-ID | Document | ESRS Relevance | Status |
|---|
| R-16 | Redegjørelse etter Åpenhetsloven 2026 | S1, S2, G1 | Published |
| R-17 | Sustainability Report (ESG) 2025 | E1, S1, G1 | Published |
| R-18 | Etiske retningslinjer (Code of Ethics) | G1 | Active |
| R-19 | Likestillingsplan (Equality Plan) | S1 | Active |
| R-15 | Varslingskanal (Whistleblower Channel) | G1, S1 | Active |
| R-12 | Personvernerklæring (Privacy Policy) | S4, G1 | Active |
| R-42 | Intern personvernpolicy | S4, G1 | Active |
| R-48 | Tredjepartsrisikostyring | S2, G1 | Active |
| R-54 | Leverandøroversikt | S2, E1 | Active |
| EXT-01 | Clean Shores Global Gold Sponsor Membership (2026–, 1 year, auto-renew) | E1, S1, S3 | Active |
13 Future Roadmap
| Initiative | ESRS | Timeline | Status |
|---|
| Scope 3 CO₂ emissions mapping (top 10 suppliers) | E1 | 2027 | Planned |
| Internal ESG KPI dashboard | ESRS 2 | 2026 | In progress |
| Remote work sustainability policy | S1 | 2026 | Planned |
| Supplier ESG questionnaire rollout | S2 | 2027 | Planned |
| CO₂-neutral registration process | E1 | 2027–2028 | In progress |
| CSRD readiness review (if thresholds approach) | All | Annual | Active |
⊘ Approval
This report has been reviewed and approved by the CEO of Intermediary AS. As a voluntary disclosure, it has not been subject to external assurance.
Morten Ims
CEO — Intermediary AS
Stavanger, April 2026
Date
