Unaudited
sustainability
statement
81     About the Group
102 Environmental information
111 Social information
122 Governance information
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About the Group
Group’s profile
Eleving Group has driven innovation in financial technology
worldwide since its foundation in Latvia in 2012. Currently,
the Group operates in 16 markets and three continents,
encouraging financial inclusion and upward social mobility
in underserved communities around the globe. Eleving
Group has developed a multi-brand portfolio for its vehicle
and consumer finance business lines, with around 2/3 of
the portfolio comprising secured vehicle loans and mobility
products, with Mogo as the leading brand, and around
1/3 of the portfolio including unsecured consumer finance
products, with Kredo and Tigo as the segment’s flagship
brands. Currently, 53% of the group's portfolio is located
in Europe, 34% in Africa, and 13% in the rest of the world.
The Group’s registered customer base exceeds 1.3 million
customers worldwide, while the total volume of loans issued
goes beyond EUR 2.0 billion. Headquartered in the Baltics
and domiciled in Luxembourg, the Group runs efficient and
transparent operations, employing 2793 employees.
Our mission
Our values
To facilitate upward social mobility across diverse
communities worldwide by creating access to
innovative and sustainable financial solutions.
Driven by Success
We are hungry for success and strive for excellence. While
we revel in the process of dealing with any challenges
encountered along the way, it is the result that truly
matters and drives us. We define and measure our success,
allowing it to be the driving force for new achievements.
Geared Towards Growth
We have a business owner’s mindset. We take full
responsibility for our actions and decisions, encouraging
others to do the same. We take the initiative rather than
react to events—we take calculated risks, boost efficiency,
and keep improving.
Powered by Teamwork
We are open, honest, and caring. We lead by example and
are trusting and trustworthy. We care for and support each
other in reaching our common goals. We work with passion,
celebrate our victories, and have fun along the way. We
thrive on equality and diversity. An individual can achieve a
great deal, but even more with a strong team.
Open to changes
We challenge and elevate everything we touch and are
eager to find out-of-the-box solutions. Change is our driving
force, and we face it head-on. We take on whatever comes
our way, showing strength in a changeable environment.
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Organizational structure
Vehicle and Consumer financing businesses have separate management teams. Having the largest operational scale and
geographical outreach, vehicle business operations are managed through two regional hubs - Europe; and Africa & Asia.
Mogo (Kenya)
Baltics (HQ locations)
Luxembourg (domiciled)
Kredo (Albania)Mogo, Renti, Primero (Latvia)
Mogo (Romania)
Mogo (Uganda) Tigo (North Macedonia)
Mogo, Renti (Lithuania)
Mogo (Moldova)
Mogo (Uzbekistan) Sebo (Moldova)
Express Credit (Botswana)
Express Credit (Namibia)
Express Credit (Zambia)
Express Credit (Lesotho)
Mogo (Estonia)
Mogo (Armenia)
Mogo (Georgia)
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Eleving Group is a public limited liability company. It
is subject to and complies—among the others - with
the Luxembourg law of 10 August 1915 on commercial
companies, as amended, and the law of 11 August 2008
on transparency requirements for issuers of securities,
as amended (the “Luxembourg Company Law”), as well
as the Rules and Regulations of the Frankfurt and Riga
Stock Exchanges. The Group does not apply additional
requirements in addition to those required above. In
2024, the Group continued to operate in 16 countries.
Each country’s subsidiary can make operational decisions
regarding its business activities. Countries in a particular
region are organized in clusters (“Hubs”) coordinated by
sub-holding companies controlled by the parent company.
Corporate governance
Group
functions
HUB oversight
Strategy
Reporting
Compliance
Fundraising
Consolidation
Hub
functions
Operational excellence
Reporting
Risk management
Compliance
Analysis and data management
Countries oversight 
Country-level 
functions 
Sales
Operational execution
(debt collection and 
customer service)
Policy implementation
Administration
Local regulatory compliance
Eleving Group
HUBs
Countries
Car
dealerships
Debt
collection
Administration
Customer
service
Partner
account
management
Accounting
IT Finance
 
HRLegal BI PRESD
Risk and
Analytics
OperationsFinance
IT HR
Business
Development
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Mārcis Grīnis
Appointed as the Chairman of
the Supervisory Board of the
Group on 6 June 2024. He holds
a Bachelor's degree in Economics
and Business, a post-graduate
degree in Management, and a
Master's degree in Finance and
Strategic Management. Graduating
from the Stockholm School of
Economics in Riga and Copenhagen
Business School, Mārcis has
showcased exceptional expertise
in various domains, including data
intelligence, Business Strategy,
Operations Scaling, Financial &
Risk Management, and Corporate
Finance. With a track record of
founding and developing several
start-ups and businesses within the
MarTech, IT, and FinTech sectors,
Mārcis stands as one of the early
co-founders and shareholders of
the Issuer.
Lev Dolgatšjov
Appointed as a Member of the
Supervisory Board of the Group on
6 June 2024. Lev is an investment
community and start-up ecosystem
activist. Outside his new role as a
Member of the Supervisory Board,
he is a managing partner of an
Estonian investment company
Meemaeger Capital OÜ and a
founding partner of the Estonian
company Syda Ventures OÜ. He
has previously served as a board
member and president of the
Estonian Business Angels Network
(EstBAN) and as a member of the
board of directors of the European
Business Angels Network (EBAN).
In addition, he has advised and
mentored numerous start-up
projects and businesses.
Derek Bryce Urben
Appointed as a Member of the
Supervisory Board of the Group
on 6 June 2024. Derek is an
investor from the United States
who previously spent five years at
the company Left Lane Capital, a
USD 2.0 billion growth equity fund.
At Left Lane Capital, he led over
a dozen investments representing
over USD 200.0 mln into
companies worldwide, including
Moove, Freetrade, Jackpocket,
Salad, and others across the
fintech, software, and consumer
internet categories. Before working
with Left Lane Capital, he was
the CFO of a trading technology
software business. Today, he
is the founder of a new private
investment firm focusing on
activism in emerging markets. He
currently serves on the board of
Moove, a global mobility fintech,
and Salad, a distributed AI
computing company.
In 2024, Eleving Group appointed a Supervisory Board. The Supervisory Board's functions are executed by Lev Dolgatšjov,
Derek Urben, and Mārcis Grīnis, the Supervisory Board's Chairman. The new governance structure's responsibilities include
contributing to the company’s future strategy, overseeing external capital raises, advising management on business
decisions, and further enhancing the quality of corporate governance.
The share capital of the Group is indirectly held by the four
founders of the Group (approximately 75%) and by present
and former employees of the Group. The share capital of
Eleving Group is held by the following shareholders (see the
table on the right).
In its decision making and administration, the Group
applies the Luxembourg Company Law, the Luxembourg
law of 24 May 2011 on the exercise of certain rights of
shareholders in general meetings of the shareholders of
listed companies and implementing Directive 2007/36/EC
of the European Parliament and of the Council of 11 July
2007 on the exercise of certain rights of shareholders in
listed companies, as amended and the Group’s Articles of
Association.
The general shareholders' meeting also determines
the number of members of the Supervisory Board, the
Supervisory Board members' remuneration, and the 
terms of their office (which may not exceed five years).
Supervisory Board
Group's shareholders
AS ALPPES Capital 37.31%
AS Obelo Capital 12.44%
SIA EMK Ventures 12.44%
Other shareholders 25.37%
AS Novo Holdings 12.44%
37.3%
12.4%12.4%
12.4%
25.3%
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The Group is managed by the Management Board, whose
members have been appointed as Category A members
and Category B members by the shareholders’ general
meeting of the Group. By the Luxembourg Company Law,
each category A member and category B member may be
removed at any time without cause (révocation ad nutum).
The Management Board consists of two executive members
and two non-executive members.
Meetings of the Management Board are convened upon
request of the chairman of the Management Board or any
two members of the Group as often as the interest of the
Group so requires. The meetings of the Management Board
are validly held if, at the commencement of the meeting, at
least one category A member and one category B member
is present or represented, and decisions are validly taken
by most of the members present or represented (including
at least one category A member and at least one category
B member). Any member may represent one or more other
members at a board meeting. The Management Board of
the Group may, from time to time, delegate its power to
conduct the daily management (gestion journalière) of
the Group to one or more members, i.e., the managing
director(s) (administrateur(s) délégué(s)), commit the
management of the affairs of the Group to one or more
members or give special powers for determined matters to
one or more proxy holders.
The Group is currently managed by the Management
Board composed of two members of Category A and
two of Category B, elected pursuant to resolutions of
the shareholders of the Group. Based on the articles of
association of the Group, members of each category
are vested with the same individual powers and duties.
The members of Category B are Luxembourg residents,
whereas the members of Category A are not Luxembourg
residents and, at the same time, hold the positions of CEO
and CFO within the Group. The Management Board has not
appointed a chairperson among its members. The company
does not have employee or worker representation within its
administrative, management, or supervisory bodies.
Management Board
Modestas Sudnius
Appointed as CEO of Eleving Group in November
2018 and as Director of the Group in March 2019.
A Stockholm School of Economics graduate, Mr.
Sudnius held the position of Country Manager in
Lithuania, followed by Regional CEO of Eleving
Group in charge of the Baltic states, Georgia, and
Armenia. He has several years of experience in
financial assurance in Ernst and Young and project
management and business development experience
in financial technology company EPS LT.
Sébastien François  
Appointed as a B Director in 2022. Mr. François
is also a Group Head of Corporate Services at
Centralis S.A.; previously, he held a Client Service
Manager position at AIB Administrative Services
Luxembourg Sàrl. Mr. François holds a Université
Catholique de Louvain (U.C.L.) post-graduate
degree in Financial Economics and a Université
Catholique de Louvain (U.C.L.) bachelor’s degree in
Business Administration.
Māris Kreics
Appointed as A Director in 2018 and as CFO of the
Group in 2015. Mr. Kreics spent two years in a
corporate finance role at Tet (previously Lattelecom),
Latvia's biggest telecommunication services company.
Before that, he spent seven years at PwC and two
years in New York working exclusively on one of the
largest (top 5 by market capitalization) S&P 500
Tech company’s lead audit team. Mr. Kreics is a
CFA (Chartered Financial Analyst) certificate holder
and a member of ACCA (Association of Chartered
Certified Accountants), the global body for professional
accountants. He holds a bachelor’s and master’s
degree in Finance from the BA School of Business and
Finance in Riga.
Delphine Marie-Paul Glessinger
Appointed as director in 2023. Ms. Glessinger
is currently also a senior legal administrator at
Centralis S.A. She has previously held a legal trust
officer position at Citco Corporate and Trust for over
8 years. Ms. Glessinger holds a Université de Haute-
Alsace Mulhouse-Colmar degree in law, a University
of Lincoln Bachelor's degree in administrative and
legal studies, and a Université Nancy 2 Bachelor’s
degree in international business.
The Management Board and executive management
members possess or have access to sustainability-related
expertise, either through the direct knowledge of its
members or by leveraging internal and external experts and
dedicated training programs. This expertise aligns directly
with the Group’s material impacts, risks, and opportunities,
ensuring that sustainability considerations are integrated
into the company’s strategic decision-making process. To
support compliance with evolving sustainability regulations,
the Group has appointed an ESG Lead responsible for
providing strategic insights and leading ESG strategy
development across all markets. This role ensures that
the Group remains proactive in addressing sustainability
challenges while continuously refining its approach to risk
management, regulatory adherence, and sustainability
performance. The Management Board ensures sustainability
governance by assigning management responsibilities to a
dedicated ESG function, which is closely monitored through
status reviews, performance tracking, and alignment with
the company’s strategic objectives.
Functional leaders provide weekly updates to Management
Board members regarding material risks, impacts, and
opportunities in their respective areas. Additionally, country
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leaders assess ESG risks as part of their responsibilities,
ensuring that relevant matters are integrated into local
operations throughout the reporting period. All these
measures are incorporated in financial planning processes,
including budget planning and mid-year reviews, to ensure
that sustainability risks and opportunities are included
in business decision-making and compliance overseen
by internal audit and the Supervisory Board, ensuring
that sustainability-related risks, controls, and reporting
processes align with regulatory and corporate governance
requirements.
The company manages sustainability-related impacts,
risks, and opportunities through its existing governance
frameworks, ensuring alignment with financial, operational,
and regulatory requirements.
In 2019, the Group established an audit committee. The
audit committee oversees the Group’s financial reporting
process to ensure transparency and integrity of the
published financial information, the effectiveness of the
Group’s internal control and risk management system,
the effectiveness of the internal audit function and
independent audit process of the Group, including providing
recommendations for the appointment and evaluating the
performance of the external auditor and the effectiveness
of the procedure for ensuring compliance with regulations
and legislation related to financial reporting and the code of
business conduct (where applicable).
The audit committee is set up and its members are
appointed by Eleving Group’s Management Board. The
committee is comprised of two members: Lev Dolgatsjov
and Derek Urben, both appointed in 2024 for three years.
The audit committee reports directly to the Company’s
Supervisory Board.
Sustainability matters addressed by administrative,
management, and supervisory bodies
The Supervisory and Management Board oversees corporate
strategy and sustainability governance, ensuring that
material sustainability-related impacts, risks, opportunities
are addressed, and goals are aligned with the company’s
long-term strategic priorities and business model. This
includes assessing sustainability-related targets and
performance indicators, policies and actions to ensure
strategic alignment across all markets and maintaining
compliance with evolving regulatory requirements.
To monitor progress, the Management Board receives
updates on sustainability-related goals during regular
functional meetings, the frequency of which varies based
on the topic's relevance. Additionally, the Board oversees
the development and implementation of sustainability
frameworks to support regulatory compliance and value
creation, and also approves the budget for sustainability
matters.
During the reporting period, sustainability-related matters
were overseen at strategic and operational levels,
with functional leaders providing regular reports to the
Management Board. This ensured continuous assessment
of material impacts, risks, and opportunities across Eleving
Group's key environmental, social, and governance areas.
The Management Board reviewed and approved the annual
Integrated report, including the sustainability information,
to ensure transparent communication that reflects the
company’s commitment to responsible business practices.
During the double materiality assessment process,
the Management Board was involved in reviewing and
approving of material impacts, risks, and opportunities,
reinforcing the integration of sustainability considerations
into corporate risk management and strategic planning.
Through these activities, the Management Board ensures
that sustainability-related risks and opportunities are
managed and embedded within the Group’s long-term
vision, contributing to creating sustainable value for
stakeholders.
Incentive schemes and remuneration policies
Eleving Group has not incorporated sustainability-related
performance criteria into the incentive structures or
remuneration policies for the company’s administrative,
management, or supervisory bodies. Sustainability
commitments are integrated across relevant functions
within the organization, and implementation is led by
relevant experts and C-suite executives who are responsible
for their respective ESG areas. During the development of
the ESG strategy for the 2026-2031 period, ESG-related
incentive schemes may potentially be expanded to include
the company’s administrative, management, or supervisory
bodies.
Audit Committee
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Risk management at Eleving Group is defined as a process
of identifying, monitoring, and managing potential risks to
mitigate the negative impact they may have on the Group.
To ensure efficient significant risk management at all
stages, Eleving Group describes the general framework and
duties in its internal policies and guidelines. Internal policies
and guidelines set out the following objectives for each of
the Group’s operating companies:
  To establish the framework required for the
identification of significant risks
  To assess exposure to significant risks
  To establish the techniques and indicators to be used
for the management of significant risks, including with
reference to the adequacy of the limits system
  To allocate the risk management duties within the entity  
  To establish the framework required for risk reporting
(reporting typology - indicators, content, frequency,
users)
  To establish the entity’s risk profile in line with the
entity’s business strategy
  To establish the measures required for addressing the
conflicts of interests at the level of the risk management
function and the conditions required for the independent
exercise of the risk management function.
The risk management process at Eleving Group consists of
four main parts:
  risk identification,
  risk management,
  risk monitoring,
  and risk control.
Eleving Group has defined the following significant risks:
(i) financial risk, (ii) legal risk, (iii) operational risk, (iv)
reputational risk, and (v) ESG risk. The Group’s activities
are exposed to liquidity risk, credit risk, and market risk
(including currency risk and interest rate risk).  
The Group’s overall risk management focuses on financial
markets and seeks to minimize potential adverse effects
on the Group’s financial performance. The Group uses
derivative financial instruments to hedge specific risk
exposures carried out by the central treasury department
(the Group’s treasury).
The Group controls its liquidity by managing the amount
of funding it attracts through peer-to-peer marketplace
platforms for loans, which provides the management
with greater flexibility to manage the level of borrowings
and available cash balances. Also, the Group manages
its longer-term liquidity needs by obtaining funding from
international capital markets, in particular by issuing the
Bonds.
The Group is exposed to credit risk through its finance lease
receivables, loans, and advances, as well as cash and cash
equivalents. The key areas of credit risk policy cover the
lease and loan granting process (including the solvency
check of the lessee or the borrower), monitoring methods,
and decision-making principles. The Group uses financed
vehicles as collateral to reduce the credit risk significantly.
The Group operates by applying a clear set of finance lease
and loan granting criteria. These criteria include assessing
the customer’s credit history, lease and loan repayment
means, and understanding the lease object. The Group
considers both quantitative and qualitative factors when
assessing the customer’s creditworthiness. Based on this
analysis, the Group sets the credit limit for each customer.
When the lease agreement has been signed, the Group
monitors the lease object and the customer’s solvency.
The Group has developed a lease monitoring process that
helps quickly spot any possible non-compliance with the
provisions of the agreement. The receivable balances
are monitored continuously to ensure that the Group’s
exposure to bad debts is minimized and, where appropriate,
sufficient provisions are made. The Group does not have a
significant credit risk exposure to any single counterparty
but is exposed to risks to counterparties with similar
characteristics.
Risk management and internal controls
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The Group takes on exposure to market risks, which are the
risks that the fair value or future cash flows of a financial
instrument will fluctuate because of changes in market
prices. Market risks arise from open positions in the interest
rate and currency products, all of which are exposed to
general and specific market movements and changes in the
level of volatility or market rates or prices, such as interest
rates and foreign exchange rates.
Currency risk is defined as the risk that the value of a
financial instrument will fluctuate due to changes in foreign
exchange rates. The Group is exposed to the effects of
fluctuations in prevailing foreign currency exchange rates
on its financial position and cash flows. The most significant
foreign currency exposures currently arise from Kenya,
Uganda, Namibia, Lesotho, Zambia, Georgia, Armenia,
Uzbekistan, and Moldova. To mitigate this risk, the Group
actively hedges its exposures in key markets - Kenya,
Uganda, Namibia, Lesotho (both via EUR/ZAR hedge),
and Zambia. In other markets, the Group has evaluated
potential hedging strategies but, due to associated
costs, has opted to manage currency risk through pricing
mechanisms and by assuming potential short- to mid-term
fluctuations. Where applicable, currency risk is priced into
product offerings, particularly in the more volatile markets,
to safeguard margins and reduce exposure.
In addition, the Group is making substantial progress
in issuing as many loans as possible in EUR and USD
currencies. Having a significant portfolio of USD loans and
leases, mainly linked to Kenya and Uganda, the Group has
started proactively managing the foreign currency exposure
risk towards USD. The proactive management of USD
exposure can be observed by forward contract purchases
that began in 2020 and have continued since then.
Cash flow interest rate risk means the risk that future cash
flows of a financial instrument will fluctuate due to changes
in market interest rates. Fair value interest rate risk is the
risk that the value of a financial instrument will fluctuate
due to changes in market interest rates, in particular, that
the Group’s income or the value of its portfolios of financial
assets might be affected as a result. The management of
Eleving Group believes that interest rate risk is not material
for the Group since the vast majority of loans are issued
and received at fixed rates, and most of the borrowings and
loans issued to customers are long-term.
Legal risks are mainly derived from regulatory changes,
which the Group successfully manages with the help of
an in-house legal department and external legal advisors
that closely follow the latest developments and the legal
environment. While most of Eleving Group’s operating
entities are financial institutions, the Group is not regulated
as a bank, payment institution, or e-money institution in
any of its operating jurisdictions. The regulatory framework
applicable to the Group’s operating entities varies
depending on the jurisdiction in which they operate. The
relevant regulations relate to, inter alia, lending and leasing
activities, consumer rights protection, the processing of
personal data, debt collection, and the prevention of money
laundering and financing of terrorism.
The Group’s operational risks are managed by rigid
underwriting procedures in the loan issuance process and
efficient debt collection procedures.
Reputational risk is concerned with the exposure of Eleving
Group to events that could adversely affect customers’
trust in its products, could decrease its customer portfolio,
or could lead to: (i) an increased difficulty in attracting
new customers; (ii) difficulty raising finance; (iii) difficulty
in retaining employees; (iv) non-compliance with the
requirements set forth by local authorities. The Group’s
reputational risk monitoring is performed, e.g., by
monitoring the local and central media, monitoring Eleving
Group’s activity with the focus on the events that could
expose the Group to a reputational risk (specifically those
related to customer relations and the relationships with
the supervisory authority), and monitoring the number of
complaints received from customers.
For Eleving Group, ESG risks include the following:
  Climate change - changes in the policy and regulatory
context; timely development of innovative products
and services, supporting the reduction of CO
2
emissions
and customer preferences; business interruption due to
chronic (e.g., temperature increase, etc.) or extreme
(e.g., floods, etc.) events on key company assets, i.e.,
physical risk.
  Responsible use of natural resources - optimization
of material cycles, in terms of recycling, waste, etc.,
management; sustainable resource (water, electricity,
etc.) management.
  Human resources management - diversity, equal
opportunities; health, safety, and well-being of
employees; attraction, retention, and development of
talent; employee training and development.
  Responsible lending - compliance with legal and
voluntary regulations.
  Customers - customer relations (e.g., conduct, non-
discrimination, mislabelling products); customer data
protection; evolving customer preferences regarding
sustainable products; increasing use of digitalization and
automation; affordable/accessible financial products.
  Impact on local communities - providing access to
finance for diverse groups.
  Business ethics and integrity - prevention, detection,
and countering unlawful behavior by employees, clients,
and/or suppliers (incl. corruption, AML) and compliance
with related international and national legislation.
Main features of internal control and risk
management systems in relation to the process of
consolidated financial statements
The employees involved in the accounting process meet
qualitative standards and receive regular training. Duties
and responsibilities are clearly assigned to different
roles. Complex evaluations are assigned to specialized
service providers who involve qualified in-house staff.
Separating administrative, executive, settlement, and
report preparation functions reduces the possibility of
fraud. Internal processes also ensure that changes in the
Group’s economic or legal environment are mapped and
that new or amended legal provisions are applied in the
Group’s accounting. The Group’s accounting rules also
govern specific formal requirements placed on consolidated
financial statements. These include the mandatory use
of a standardized and complete reporting package. The
Group’s Accounting Department assists the Regional units
in resolving complex accounting issues. Additional data
for the presentation of external information in the notes
and the Group’s management report is also prepared
and aggregated at the Group level. Reporting packages
containing errors are identified and corrected at the
Regional or Group level. Impairment tests are conducted
centrally for the specific cash-generating units, known
as CGUs, from the Group’s perspective to ensure that
consistent, standardized evaluation criteria are applied.
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Description of business
model and value chain
Eleving Group is a leading global financial technology
company with a presence in 16 markets across three
continents. Founded in Latvia in 2012, the company has
built a scalable, technology-driven, and diversified business
model that enables seamless geographic expansion,
business volume growth, and product innovation.
The Company is focused on reinforcing its footprint in
established markets, where it has deep market knowledge
and operational expertise. However, its scalable business
model, supported by technology-driven IT and operational
infrastructure, allows for rapid expansion beyond these
regions when strategic opportunities arise. Eleving Group
also benefits from a strong corporate governance structure,
a diversified funding base, and an experienced management
team rooted in Baltic talent and global know-how.
Eleving Group operates through a multi-brand portfolio
designed to serve diverse financial needs. The Company
manages two business lines - vehicle finance and consumer
finance, designed to support financial inclusion and upward
social mobility.
Vehicle finance composes 2/3 of the Group's portfolio,
offering secured vehicle loans and mobility solutions under
the Mogo, Primero, and Renti brands. Eleving Group has
invested in sustainable mobility through Carguru, an electric
car-sharing platform operating in Latvia, reinforcing its
commitment to environmentally responsible transportation
solutions. The vehicle finance business is split into two
segments – traditional vehicle finance and flexible and
subscription-based products.
Traditional vehicle finance segment represents 45% of the
portfolio, providing tailored financing solutions through
Mogo and Primero brands. In European and Central Asian
markets, Eleving Group inspects and purchases a vehicle
selected by the customer. The customer uses the vehicle
during the lease period, making installment payments.
Ownership is transferred to the customer once the loan is
fully repaid, while Eleving retains legal ownership during the
financing period. In Africa, the customer is the legal owner
of the vehicle, and Eleving Group issues credit against the
vehicle collateral.
Flexible and subscription-based products hold 20% of
the portfolio and are provided under the Renti brand in
Lithuania and boda-boda financing under the Mogo brand
in Kenya and Uganda. In Lithuania, the Group offers
rent-to-buy solutions, granting customers the flexibility
to return or exchange vehicles anytime. In Eastern Africa,
the Group focuses on productive lending through vehicle
loans, targeting self-employed riders and SMEs with ICE
and electric motorcycle and three-wheeler financing for
passenger transport or deliveries.
The remaining 1/3 of the portfolio consists of unsecured
consumer finance products with the Kredo, Tigo, Sebo,
and ExpressCredit brands. These products are specifically
designed to serve underserved populations, offering
alternative financing options to those typically excluded by
traditional financial institutions. The Company maintains
high standards of credit provisioning to ensure quality and
reliability in its lending practices. Eleving Group’s business
model is strongly supported by an extensive branch
network, allowing the Company to provide financing to
customers when and where it is needed most. The Group
frequently finances the purchase of consumer goods and,
in certain African markets, offers long-term credit to
government employees through deduction codes, where
repayments are facilitated directly by the employer rather
than the customer.
Strategy and business model
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The typical client of Eleving Group mobility products is an
economically active person who frequently uses a vehicle
for daily commuting and as an instrument to make a living
for themselves and his family. It is a person looking for
a convenient and easy-to-understand financial product
with fast onboarding and simple use. Our mobility clients
prefer to drive pre-owned quality vehicles since such
vehicles perform better, depreciate less, and have cheaper
maintenance costs due to a well-developed aftermarket.
For most customers, a car is not a nice-to-have item but
a necessity to travel to work or generate income. The
Group also serves small and medium enterprises that need
quick financial solutions to solve mobility issues in their
businesses.
The Company’s consumer segment includes people who
need financial solutions for specific situations, often to
cover urgent or unexpected expenses. These customers are
often underserved by traditional banks due to small loan
amounts, slow approval processes, or complex applications.  
As part of its long-term growth vision, Eleving Group
remains committed to driving digital transformation. The
first phase of the Group’s digitalization journey has been
successfully completed with the implementation of a next-
generation “2.0” self-service platform in all established
European vehicle finance markets. The project is facilitating
the seamless onboarding of existing clients and providing
them with 24/7 access to their accounts. It offers real-time
updates on agreements, customer details, payment history,
and plans. Initially piloted in Romania, this platform has
been continuously enhanced to provide customers with a
broader range of digital financial and customer services.
Looking ahead, Eleving Group is actively exploring the
integration of AI-driven tools into its processes to further
improve automation, risk management, and customer
experience. This continued investment in technology aligns
with the Company’s strategic goal of nearly doubling its
business within the next two years.
Eleving Group offers a diverse range of financing products
across 16 countries, utilizing a variety of sales channels
to ensure accessibility and efficiency. These channels
include an online platform managed by the Group, third-
party online car sales portals, physical branches, and
used car dealerships. As of the end of 2024, the Company
maintains a strong offline presence through 1,786 active
partner dealerships and 282 physical branches, providing
broad accessibility and efficient service delivery in all of its
markets.
Eleving Group also has a dynamic online presence that
strengthens market reach and customer interaction via
25 product websites and over 50 integrations with sales
partners on digital channels. This reach has enabled Eleving
Group to serve about 326,800 active customers as of the
end of 2024 and over 1.3 mln since inception.
The Group’s financial services are designed to promote
financial inclusion and upward social mobility, especially
in underserved communities. By combining advanced IT
architecture, a technology-driven approach, and a wide
sales channel network, Eleving Group ensures streamlined
customer experiences and operational efficiency in all its
markets.
Customer segments
Enhancing existing financial
solutions and exploring
innovative lending
approaches that align with
evolving market demands
and technology-driven
opportunities.
Strengthening market
positions in established
regions (primarily Europe
and Africa) by optimizing
operations, improving product
quality, and increasing
customer penetration.
Entering new markets with
proven financial solutions,
leveraging the Group’s
regional management team
to ensure swift market
penetration and maintain
high operational efficiency.
Eleving Group’s existing strategy is
anchored in three core pillars:
New product 
development
Organic growth in 
current markets
Geographic
expansion
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Global scope
Eleving Group has a
geographically diverse portfolio
across three continents.
Over 53% of the business is
concentrated in Continental
Europe with resilient economies
and strong currencies. The
Group’s African markets account
for over 34% of the portfolio,
while 13% of the portfolio is
located in other geographies.
1
Including Primero product portfolio in total portfolio balance
2
Population data source: Eurostat and World bank
3
Passenger vehicle data source: ACEA VEHICLES IN USE REPORT and Nation Master
Traditional
vehicle 
financing
Consumer
lending
products
Flexible lease
& subscription-
based products
Portfolio balance
1
as per December 2024
20.3%
34.3%
45.4%
Kenya (KE) 
Population: 55.3 mln 
Passenger vehicles: 0.96 mln 
Operations launched: 2019 
Share of portfolio: 12.9%
Botswana (BW)  
Population: 2.5 mln 
Business acquired: 2023  
Share of portfolio: 4.8%
Zambia (ZM) 
Population: 20.7 mln 
Business acquired: 2023  
Share of portfolio: 2.6%
Continental
Europe
Rest of
the World
Africa
53% 13%
34%
Vehicle Finance Consumer
Finance
34%
66%
(Lease, leaseback, flexible
lease and subscription)
Latvia (LV) 
Population
2
: 1.9 mln 
Passenger vehicles
3
: 0.66 mln 
Operations launched: 2012 
Share of portfolio: 3.2% (10.1%
1
)
Lithuania (LT) 
Population: 2.9 mln  
Passenger vehicles: 1.26 mln 
Operations launched: 2013 
Share of portfolio: 7.9%
Estonia (EE) 
Population: 1.4 mln 
Passenger vehicles: 0.79 mln 
Operations launched: 2013 
Share of portfolio: 3.3%
Romania (RO) 
Population: 19.1 mln 
Passenger vehicles: 6.90 mln 
Operations launched: 2016 
Share of portfolio: 12.0%
Moldova (MD)  
Population: 2.5 mln 
Passenger vehicles: 0.58 mln 
Operations launched: 2017 
Share of portfolio: 4.9%
Moldova (MD) 
Population: 2.5 mln 
Business acquired: 2020  
Share of portfolio: 4.9%
Albania (AL)  
Population: 2.7 mln 
Business acquired: 2020  
Share of portfolio: 10.8%
North Macedonia (MK) 
Population: 1.8 mln 
Business acquired: 2020  
Share of portfolio: 6.1%
Georgia (GE)  
Population: 3.7 mln 
Passenger vehicles: 1.01 mln 
Operations launched: 2014 
Share of portfolio: 5.2%
Armenia (AM) 
Population: 3.0 mln 
Passenger vehicles: n.a. 
Operations launched: 2017 
Share of portfolio: 4.6%
Uzbekistan (UZ)  
Population: 35.7 mln 
Passenger vehicles: n.a. 
Operations launched: 2018 
Share of portfolio: 3.3%
Namibia (NM) 
Population: 3.0 mln 
Business acquired: 2023  
Share of portfolio: 4.2%
Lesotho (LS) 
Population: 2.3 mln 
Business acquired: 2023  
Share of portfolio: 0.7%
Uganda (UG)  
Population: 48.7 mln 
Passenger vehicles: 0.17 mln 
Operations launched: 2019 
Share of portfolio: 8.3%
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Eleving Group's product universe
Financing products include traditional lease and leaseback products as well as
consumer financing products that accounted for 80% of the Group’s total net
portfolio as of December 31, 2024.
Services products include flexible lease and subscription-based products that
accounted for 20% of the Group’s total net portfolio as of December 31, 2024.
BODA
LOANS
Well accessible and
affordable mobility
product for customers
in underserved market
segments
EUR 168.3 mln
EUR 24.9 mln
EUR 50.7 mln
EUR 7.6 mln
EUR 127.4 mln
EUR 28.3 mln
Net portfolio
Fleet value
Net portfolio
Fleet value
Net portfolio
Net portfolio
A rent-to-buy product
with ultimate flexibility
A solution for self-employed
who use mobility as a
source of income
Investment
1
in sustainable car-
sharing in Latvia (Riga)
Accessible financing
through traditional
consumer loan
products
Flexible Premium car
leasing for people
interested in the high-
quality vehicles
1
In August 2024, OX Drive merged its operations with SIA Slyfox and is now operating under the Carguru brand, with Eleving Group holding 36.24% of SIA Slyfox.
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Productive lending
Access to reliable financial services helps people increase
their income, gain access to asset ownership, and
better manage financial challenges. Eleving Group has
transformed the used vehicle market by providing financing
to individuals with limited access to capital. In 2021, Mogo,
the Group’s flagship brand, introduced its first productive
lending product—financing vehicles that customers can
use to earn income or grow their businesses. In Kenya
and Uganda, this primarily includes financing boda-bodas
(motorcycle taxis) and tuk-tuks (three-wheel taxis).
Boda-bodas are widely used by self-employed individuals
and small entrepreneurs in Kenya and Uganda for both
passenger transport and deliveries, creating economic
opportunities for a significant portion of the local
population.
With Mogo leasing, riders can pay similar—or even lower—
monthly installments compared to renting. But unlike
renting, once the payments are complete, the motorcycle
becomes their own. This approach empowers riders to
gain financial independence while making mobility more
accessible and sustainable.
Responsible lending
Responsible and productive lending promoting economic
inclusion lies at the core of Eleving Group’s operations in
the mobility and consumer segments. Eleving Group and all
its subsidiaries always fully comply with the local regulatory
regulations (Financial Services Supervisory authorities,
Central Banks, Consumer Right Protection authorities, and/
or Ministries of Finance/ Economy). Eleving Group also
follows its internal standards on responsible lending and
fair treatment; one of the fundamental principles of these
standards is transparency. Eleving Group ensures that all
the relevant information, including fees, key terms and
conditions, legal documentation, and advertising, is clear,
understandable, and accessible to clients. Eleving Group
has two main business lines: secured lending via car loans,
flexible vehicle loans, and subscription-based products
against the title of the vehicle, and unsecured consumer
lending. The Group’s core focus remains on secured lending,
which comprises around 66% of the consolidated net loan
portfolio at the end of 2024. Consumer loans issued by
Eleving Group are primarily used for everyday expenses or
purchasing consumer goods and electronics. Eleving Group
provides consumers with easy access to finance since it has
both- a brick-and-mortar and online presence.
Fostering responsible
access to finance
Eleving Group empowers diverse communities across the
globe by promoting financial inclusion and enabling upward
social mobility. At the core of the Group’s business lies a
commitment to helping customers make informed financial
decisions. By offering access to innovative and sustainable
financial solutions, Eleving Group strives to create
meaningful social and economic impact. The Company
is also dedicated to improving financial literacy in every
market in which it operates.
Eleving Group’s corporate strategy is impact-driven.
By advancing financial inclusion, the Group supports
underserved communities across its regions of operation,
providing them with the tools needed to improve their
financial well-being. Its products are designed for simplicity,
convenience, and transparency—delivered both online
and through a strong offline presence. With clear fee and
interest structures and a firm commitment to data privacy,
Eleving Group ensures that customers can access funding
with confidence and ease.
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Integrity Availability Care Transparency
Eleving Group’s responsible lending principles
Risk management as a core competence
Eleving Group has over 70 employees in risk management
roles. The Group’s organizational framework is built
around a hub structure: Vehicle Finance Europe, Vehicle
Finance Africa & Asia, and Consumer Finance. Each of
these business segments is supported by experienced and
knowledgeable risk management teams, complemented by
centralized risk management functions at the headquarters
level.
These highly skilled leaders work closely with senior
management to ensure a comprehensive risk management
framework is implemented across the organization. This
framework ensures that all risk-related activities are
effectively monitored and aligned with Eleving Group’s
strategic objectives, even as the Company continues to
expand into new markets and product categories.
The management team plays an active role in overseeing
risk mitigation, ensuring that business decisions are both
strategically sound and responsible. This structure enables
the Group to support its growth with flexibility while
maintaining a disciplined approach to risk—ensuring long-
term sustainability and organizational resilience.
Risk management in client relations
The Group’s goal is not only to reject high-risk applicants
but also to educate customers throughout the loan
application process. This ensures that customers fully
understand the implications of taking out a loan, including
their ability to meet financial obligations. Eleving Group
proactively works to enhance financial literacy among
borrowers, guiding them through the decision-making
process to assess whether a loan is a sustainable choice
for their personal or business finances. For this reason,
Eleving Group maintains a conservative loan application
conversion rate, while for high-value vehicle finance loans
customers are also required to contribute some of their own
funds. As a result, the Group's conversion rate for vehicle
finance loans is 8.3%, but for consumer finance, it stands
at 33.8%.
Once a customer applies for a loan, their creditworthiness
is determined through a sophisticated underwriting process
that relies on data-driven statistical analysis, incorporated
into Eleving Group’s proprietary vehicle and consumer
finance scoring models. Across all its products, Eleving
Group assesses customers’ creditworthiness using public
and private databases, for example, vehicle registries,
government institution records, debt collection agency
databases, industry and peer company blacklists, and bank
statement providers, to name a few. Each applicant is
allocated a risk score based on this data.
The automated scoring models are developed in-house and,
depending on the country, are either integrated into the
customer relationship management systems or run on third-
party cloud solutions. These models help ensure objective
and accurate risk assessment while promoting financial
stability among borrowers.
Loan Application Process
Each loan application undergoes a comprehensive multi-
step assessment:  
By following this structured approach, Eleving Group
ensures that counterparty risk is properly assessed
while maintaining responsible lending practices. The
rigorous approval criteria are a key factor in the Group’s
commitment to financial stability, customer protection, and
long-term business sustainability.
Through its responsible lending approach, robust risk
management framework, and dedication to financial
literacy, Eleving Group ensures long-term value creation for
customers.
  Loan application processing
and preliminary assessment 
– Initial customer information is
collected and evaluated.
  Risk assessment and scoring 
– The applicant’s financial profile
is analyzed using data-driven
models.
  Vehicle inspection (for car
loans, flexible vehicle loans,
and subscription-based
products) and finalization
of loan terms – The asset is
assessed to ensure compliance
with financing criteria.
  Loan approval and
disbursement of funds
Approved loans are processed and
disbursed to customers.
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ESG framework
Environment
  Climate impact monitoring and
data collection system in place
  Climate neutrality of
administrative operations
  User-friendly tools for measuring
vehicle CO
2
emissions
Social
  At least 8 hours of professional
development training for
employees per year
  Infrastructure for healthy work-
life balance
  Fair and equal internal
progression of employees with
10% vacant management
positions occupied by employees
  Gender pay gap maximum 2%
(HQ)
  Employee recommendation score
(eNPS) at >50
  Public programs and tools to
improve the financial literacy of at
least 500,000 people
Governance
  Gender diversity in senior
leadership roles
  Zero unaddressed whistle-blower
reports
  Structured ESG framework in
place
  Key suppliers assessed according
to ESG criteria
Practicing
responsible
business
  Sustainable
procurements
  Fair and
transparent
business
operations
Striving
for climate
impact
reduction and
adaptation
  Portfolio
environmental/  
climate impact
  Climate
impact of own 
admin activities
Ensuring
growth
& well-
being of
employees
  Learning and
development
  Health and
well-being
  Engagement,
diversity
& equal
opportunities
Fostering
responsible
access to
finance
  Responsible
lending
  Enabling access
to finance
  Privacy, data
protection,
cybersecurity
  Financial
literacy
Eleving Group  
ESG priority
topics
ESG goals 2022-2025
A Way 
Way Up
The findings of this year’s double materiality assessment will be integrated into the strategic decision-making process
when setting the ESG strategy for the next period (2026-2031) to ensure the business model's long-term resilience. In this
process, sustainability-related goals will be considered in relation to significant groups of products and services, customer
categories, geographical areas, and relationships with stakeholders to ensure that ESG priorities are aligned with key
business segments, market needs, and stakeholder expectations.
To demonstrate compliance with the ethical standards of
the industry and the national and international frameworks
on corporate sustainability and sustainable development,
the Group has aligned its practices and environmental,
social, and governance goals with the United Nations
Sustainable Development Goals (SDGs). Based on an
analysis of its contributions to the SDGs, since 2021,
Eleving Group has prioritized 8 of the 17 SDGs. The Group’s
established processes and targets are integrated within the
functions to ensure compliance with commitments.
In Eleving Group’s ESG framework 2022-2025, developed in
2021, the Group’s management has set the following goals:
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Interests and views of stakeholders
Eleving Group understands the importance of engaging with
stakeholders across its value chain, including employees,
customers, suppliers, business partners, financial
institutions, investors, and regulators. Open communication
helps build trust, strengthen relationships, and create value
for both the Company and its stakeholders.
Stakeholder engagement is conducted through various
customized approaches for each stakeholder group. These
approaches include direct communication channels such
as meetings and e-mail communication, feedback surveys
like Eleway Pulse or the reporting platform FaceUp, and
participation in events such as seminars and corporate
gatherings to facilitate meaningful dialogue. Insights
gathered from stakeholder engagement are incorporated
during the Company’s decision-making processes, ensuring
alignment with stakeholder expectations and strategic goals.
Eleving Group operates through its subsidiaries across three
continents: Africa, Asia, and Europe. As a financial service
provider, the Company’s operations play a central role in
the value chain. 2793 employees are a key stakeholder
group, so most material sustainability matters are directly
linked to the Company's operations.
Eleving Group provides vehicle and consumer loans to
customers and end-users, so its downstream value chain
primarily relates to issued vehicle loans and mobility
products.
The Company's upstream value chain includes institutions
that shape the regulatory landscape, set listing standards,
and promote adherence to financial regulations. It also
includes critical Eleving Group's suppliers who provide IT
infrastructure, like hardware, software, and data centers,
and who have strategic importance in ensuring the delivery
of services to customers across diverse markets.
Material
stakeholders and
their relation with
strategy and/or
business model
Topics addressed Engagement method
Purpose & outcome
of the stakeholder
engagement
Employees  
All employees across
all subsidiaries in the
Group's active markets
  Training &
Development
  Health & Safety
  Social dialogue &
Corporate culture
  Company's strategy,
plans, and results
  Well-being and
working conditions
  Regular meetings
  Workplace assessments
  Monthly Group-level All-hands
meetings
  Non-formal internal events
  Surveys
  Corporate employee events
  Personal development
dialogues
  Training
  Human and intellectual capital
  Improved social dialogue
  Higher engagement &
satisfaction
  Legal and safety compliance
Customers
& local
communities
All customers across the
Group's active markets
and product segments
  Access to finance
  Service quality
  Improved mobility &
low-carbon products
  Financial literacy
  Engagement with
local communities
  Online surveys
  Direct communication via sales
agents
  Website
  Marketing campaigns
  Newsletter
  CRM channels
  Providing access to finance to
individuals or self-employed
individuals, utilizing financial
products in the regions where
Eleving Group operates
  Customer service
improvements, product
adjusting to consumer needs
Business
partners  
Business partners
(vehicles & consumer
loans)
  Service quality
  Business ethics
  Meetings
  E-mails, and other direct
communication channels
  Webinars
  Seminars
  Corporate events
  New sales tools generation
  Transparency
  Client onboarding
  Enabling access to the
pre-owned vehicle market 
and its clients
Suppliers  
Technology and software
service providers,
insurance, recruitment,
office service providers,
other administrative
support service providers
  Service availability
and quality
  Responsible business
activities and
governance
  Supplier due diligence
  Direct  communication  channels
  Periodic service quality reviews  
  Meetings
  Responsible and sustainable
business activities
  Legal compliance
Stakeholder engagement in the value chain
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Material
stakeholders and
their relation with
strategy and/or
business model
Topics addressed Engagement method
Purpose & outcome
of the stakeholder
engagement
Financial
Institutions &
Investors
Banks, investment funds,
financial advisors, family
offices, institutional
investors, hedge funds,
sales agents in capital
markets markets
  Regulatory landscape
  Business ethics
  Financial and
operational
compliance
  Market trends
  Meetings,
  E-mails and other direct
communication channels
  Webinars
  Seminars
  Corporate events
  Round table discussions
  Capital market days
  Financial reports
  Shaping regulatory landscape
  Listing standards
  Fostering transparency and
promoting adherence to
financial regulations
  Market data & platform for
listing shares
  Capital raising
  Compliance with regulatory
requirements
Regulators
Central banks, Financial
supervisory authorities,
Consumer protection
authorities, Stock
exchanges
  Regulatory landscape
  Business ethics
  Financial and
operational
compliance
  Market trends
  Meetings
  E-mails and other direct
communication channels
  Corporate events
  Round table discussions
  Direct discussions and working
groups
  White papers
  Research
  Product development and
market entry
The Management Board is informed about stakeholders'
views and interests regarding sustainability-related impacts
through structured engagement, reporting when relevant
and material, and integration into decision-making.
Stakeholder consultations, materiality assessments, and
ESG reporting provide insights, while dedicated function
leaders ensure operational updates. Furthermore,
grievance mechanisms and feedback channels facilitate
continuous input, enabling the incorporation of stakeholder
perspectives into the Company's risk assessment and
sustainability strategy.
Description of the process to identify and assess
material impacts, risks, and opportunities
As part of the Eleving Group's impact materiality
assessment process, the Company prioritizes stakeholder
engagement to ensure that its environmental, social, and
governance goals and actions align with the expectations
and priorities of those directly or indirectly impacted by
business operations.
In 2024, the methodology had been evolved, incorporating
the principles of double materiality. The scope of the
assessment was expanded to include a more comprehensive
view of the value chain, encompassing also upstream
and downstream operations. This assessment considered
both impact materiality, assessing the Company’s broader
environmental and social positive or negative impacts,
and financial materiality, evaluating how sustainability
factors influence the Company’s financial performance, and
it allowed to identify the most significant sustainability-
related risks, opportunities, and impacts across the value
chain. Double materiality assessment will be reviewed and
updated on an annual basis.
Principles for Stakeholder Selection
The previous year’s materiality matrix and stakeholder
engagement records were revisited before the double
materiality assessment was performed. Subsequently, an
online survey was conducted to gather insights on the areas
stakeholders perceive as most material for the Eleving
Group, prioritizing engagement with the most affected
stakeholders.
Stakeholder groups included investors, employees,
customers, suppliers, partners, NGOs, media, C-level
management and the Supervisory Board, banks and funds,
and regulators. Their insights are vital in identifying ESG
issues that matter most to Eleving Group’s business and
stakeholders alike. Recognizing the environment as a
silent stakeholder, the Company also considered the wider
environmental footprint of its operations.
Market representation
Given that Eleving Group operates across 16 markets,
to ensure a focused and efficient survey, only markets
contributing 5% or more to the Group’s total portfolio were
included, reflecting their significance in the operations
and potential to drive meaningful impact. Eleving Group
is a Baltic-listed company, so Estonia was selected as an
exception. This approach allowed to gather actionable
insights efficiently while accommodating participants across
multiple geographies.
Impacts, risks, and opportunities identification
The Company created a comprehensive list of topics and
systematically assessed them, guided by the following
factors:  
  stakeholder perspectives, as gathered through the
online survey,
  industry benchmarks to compare sustainability practices
across the financial sector and
  regulatory requirements set by relevant institutions to
ensure alignment with compliance requirements and
industry standards.
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The Company analyzed the Employee Net Promoter Score
(eNPS) to understand employee engagement, areas for
development, and sentiment regarding own operations
across all geographies of operation. To identify potential
risk areas, the Company also analyzed whether any social
and human rights risks across various geographies and
stakeholder groups were reported through the FaceUp
platform — an anonymous reporting system for concerns
related to misconduct, unethical behavior, or illegal
activities within or in connection to the Eleving Group.
Scoring and thresholds
All relevant topics and sub-topics across the own
operations, upstream, and downstream value chains were
evaluated as part of the double materiality assessment.
This comprehensive approach ensured that both direct
and indirect sustainability risks and opportunities were
considered. The severity of actual or potential negative
impacts was assessed from the perspective of the affected
people – employees, customers, communities, and others,
or - the environment.
All identified topics were assessed against predefined
thresholds, as determined by the internal assessment
team involving both subject matter experts and external
advisory, ensuring a consistent and structured approach
to defining issues as material for the Eleving Group. As a
result of this process, a list of material topics was set and
classified as material either from an impact and/or financial
materiality perspective.
Materiality threshold and characteristics
To establish thresholds for materiality determination, the
following characteristics were applied:
1. Scale – the gravity of the impact, considering its
magnitude and intensity.
2. Scope – the extent of the impact, assessing how
widespread it is across stakeholders or ecosystems.  
3. Irremediable Character – the degree to which the impact
can be reversed or remediated.
The impact scale ranged from 0 - no impact, to 5 - absolute
impact, to measure the severity of the impact. A minimum
score means no or minor positive or negative effect,
while 5 signifies severe, often irreversible damage to
the environment, company assets, reputation, employee
well-being, and human rights, with significant societal
consequences.
The scope of impact ranged from no material effect or
local impacts affecting specific countries or regions to
broader influences across multiple markets, employee
groups, customers, and communities. At the highest level,
the impact is widespread across all operational markets,
encompassing the entire value chain.
For the negative impacts, irremediability to which an impact
can be reversed was assessed. Lower scores indicate
minimal effort required for remediation, with no significant
harm to people, communities, or the environment. As
severity increases, remediation demands more time, cost,
and effort, involving short-term (up to 1 year) to long-term
(beyond 5 years) impacts.
The likelihood of an impact occurring was categorized on
a scale from 0 to 5, ranging from no probability to near
certainty.
The determination of financial materiality thresholds
was based on the assessment that considered both the
likelihood of occurrence and the potential magnitude
of financial impacts on the Company across the short-,
medium-, and long-term horizons giving a comprehensive
perspective on how these factors influence the Company’s
financial resilience. Financial materiality refers to the extent
to which economic, regulatory, environmental, social,
or market risks and opportunities impact a Company’s
financial performance and operations in a range from small
administrative costs with negligible financial consequences
to absolute impacts, where fundamental regulatory changes
or market shifts can lead to severe financial losses.
Topics have been identified as material, if they were
associated with one or more material impacts, risks, or
opportunities assessed with the highest score exceeding
3.2. Setting the materiality threshold above 3 ensured
that the Company prioritizes topics with material
impact or financial risks and opportunities, balancing
risk management, strategic alignment, and regulatory
compliance with the severity or likelihood of the specific risk
or opportunity.
To ensure a structured and objective approach, internal
risk management processes for threshold-setting were
leveraged, determining whether an impact meets the
materiality criteria for sustainability reporting. This
approach allowed to identify and prioritize material issues
in alignment with regulatory standards and corporate
responsibility objectives.
As the final part of the materiality assessment, an
internal review was conducted, involving both subject
matter experts and external advisory. The assessment
was conducted by the Group ESG Lead, Group Internal
Auditor, Group Chief Corporate Affairs Officer, Group
Accounting Process Supervisor, and External Advisory
experts. Upon completion of the evaluation, the findings
and recommendations underwent a formal review and
approval process by the Chief Executive Officer (CEO) and
Chief Financial Officer (CFO) to ensure alignment with the
Company's corporate strategy and regulatory compliance.
Subsequently, the methodology, process, and outcomes
were presented to the External Audit Committee for further
review and approval.
By integrating these insights, the Company developed a
clear and strategic understanding of the most material
sustainability issues, as illustrated in the matrix below,
which are crucial for ensuring that sustainability efforts
drive long-term business resilience while creating a positive
impact on the environment, employees, and society or
reducing negative impacts in a short-, mid-, or long-term
perspective.
Eleving Group systematically evaluates the connections
between sustainability-related impacts and dependencies
on natural, human and social resources, recognizing how
these factors influence associated risks and opportunities
and integrating these considerations into the risk
assessment framework to anticipate potential financial,
operational, and reputational effects. This assessment
is based on a structured analysis of their impact and
likelihood and includes both quantitative and qualitative
methodologies to ensure a comprehensive understanding
of potential sustainability-related impacts. Identified
risks and opportunities are evaluated against financial,
regulatory, and market-related factors to determine their
material significance and are integrated into the overall risk
management process.
Internal control procedures guide decision-making
processes related to sustainability risks and opportunities,
including oversight by executive leadership and the
Management Board.
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Cross-functional teams ensure that material risks and
opportunities are effectively monitored and managed,
integrating sustainability considerations into the broader
enterprise risk management framework to have a holistic
view. The identification, assessment, and management of
sustainability-related opportunities are embedded within
our strategic planning and operational decision-making
processes, ensuring long-term value creation.
Key input parameters in the Company’s risk and
opportunity assessment process include regulatory trends
and standards assessments, stakeholder expectations
gathered via online stakeholder surveys or in-person
communication, climate-related desk-top scenario analyses,
supply chain dependencies, and financial modeling of
sustainability impacts.
Compared to the previous reporting period, the process for
identifying, assessing, and managing sustainability-related
risks and opportunities has been enhanced by ensuring
assessment both from an impact and financial perspective.
Sustainability-related risks were monitored and analyzed
within the overall risk management framework based on
their potential impact on business continuity, compliance,
and stakeholder expectations. These risks are assessed
in relation to other types of risks, such as financial,
operational, and strategic risks, ensuring an integrated
approach to risk prioritization.
Material impacts, risks, and opportunities and their
interaction with strategy and business model
As a result of the double materiality assessment, Eleving
Group reports on the Climate Change, Own Workforce,
and Governance, as well as the EU Taxonomy. The double
materiality assessment process was conducted considering
the applied time horizons, ensuring a comprehensive
evaluation of short-term (up to 1 year), medium term
(up to 5 years), and long term (beyond 5 years) material
impacts, risks, and opportunities.
Double materiality matrix
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Material
impacts,
risks, and/or
opportunities
Classification
Value chain 
Time horizon
Description and interaction
with business model and/or strategy
Climate change
adaptation and
resilience  building
Physical risks from
extreme weather
events or value chain
disruptions
Negative
potential impact
on
Own operations
in
Medium-term
The growing frequency of extreme weather events
presents significant risks in the medium term. These
include threats to employee safety and well-being,
potential property damage, and loss of critical records.
Such events can also disrupt supply chains and damage
financed vehicles, reducing market value and increasing
the likelihood of loan defaults.
Mitigation and interaction with Eleving Group’s strategy are
described on page 103.
Climate change
mitigation
Transitional risks
of climate change
mitigation related
to resource
efficiency, consumer
trends, regulatory
frameworks, and
technological
advancements
alternatives
Negative actual
impact on
Downstream and
Own operations
in
Medium-term
Carbon pricing and stricter emissions regulations may
reduce the value of high-emission vehicles, impacting loan
portfolios.
Mitigation: Opportunity to further scale up electric vehicle
financing products to support customers transitioning to
low-carbon mobility; reducing the footprint of our own
operations.
Energy  Energy consumption
affects carbon
footprint, and
regulatory or
cost changes in
energy sources can
create financial or
operational risks
when transitioning to
low-carbon
Negative actual
impact on
Own operations &  
Positive potential
impact on
Downstream
operations in
Medium-term
Fluctuations in fossil fuel prices can impact customers'
financial stability and ability to repay loans. Stricter
regulations on internal combustion engines and other
related policies may reduce the value or availability of
vehicles that depend on fossil fuels.
Mitigation: Electric vehicle financing—offering loans for
EVs can address the rising demand for energy-efficient
transportation and reduce the footprint of our own
operations.
Secure
employment &
Adequate wages
Employment type
impacts job security,
financial safety, and
the economic and
psychological stress
of the own workforce
Positive actual
impact on
Own operations
in
Short-term
Eleving Group prioritizes open-ended, full-time, fixed-
fee employment contracts to ensure fair employment
practices. The associated risks may lead to high employee
turnover and increased recruitment and training costs,
disrupting service continuity.
Health & Safety
Unsafe working
conditions can lead
to serious accidents,
particularly for
employees whose
duties involve the use
of transportation
Negative potential
impact on
Own operations in
Short-term
Health and safety training programs and ensuring strict
compliance with safety standards.
Training &
Development
Enhancing the
Company's
competitiveness
by empowering
employees to
continuously update
their knowledge and
develop new skills
that improve job
performance
Positive actual
impact on
Own operations in
Short-term
A continuous learning culture in place, providing all
company’s own employees at least 8 hours of professional
development training per year. The Group also implements
succession planning strategies to prepare talent for
leadership roles, supporting internal promotions and
strengthening organizational capability.
Climate
change
Own
workforce
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Material
impacts,
risks, and/or
opportunities
Classification
Value chain 
Time horizon
Description and interaction
with business model and/or strategy
Work-life balance
& Working time
Promoting work-
life balance and
employee well-being
Positive actual
impact on
Own operations in
Short-term
Eleving Group is dedicated to supporting its employees
in achieving a healthy work-life balance through flexible
working arrangements, including hybrid work models,
flexible hours, and a "work from anywhere" policy. The
Company also offers a wide range of paid and unpaid
leave options to accommodate personal needs and life
events.
Diversity  Diverse and inclusive
workplace
Positive potential
impact on
Own operations in
Short-term
The Group is committed to maintaining a diverse and
inclusive workplace, ensuring equal opportunities for all
employees regardless of ethnicity, gender, age, disability,
or background. The Group employs individuals from over
20 different nationalities, reinforcing its commitment to
fair treatment and non-discrimination.
Social dialogue  Promotion
of employee
engagement
and transparent
communication
through social
dialogue
Positive potential
impact on
Own operations in
Short-term
Eleving Group is committed to open and transparent
communication with employees through internal
meetings, feedback sessions, and surveys, and provides
grievance mechanisms to address concerns.
Anti-Corruption
and Anti-Bribery
Implementation
of robust anti-
corruption  measures
Positive potential
impact on
Own operations in
Short-term
Eleving Group's implementation of robust anti-corruption
measures ensures compliance with international
standards. Comprehensive training programs helps to
equip employees to identify and mitigate risks proactively,
ensuring adherence to regulations and ethical standards.
Whistle-blower
Protection
Protection of
whistle-blowers and
promoting grievance
reporting tools
Positive potential
impact on
Own operations in
Medium-term
Eleving Group is committed to the highest standards of
ethics and integrity. To support this, the Company has
established an anonymous reporting system, FaceUp,
enabling employees and stakeholders to report concerns
safely. The Whistle-blowing Policy encourages individuals
to speak up, promotes awareness of their rights, and
protects whistle-blowers from retaliation or discrimination.
Own
workforce
Governance
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Environmental
information
“Eleving Group is driving further green
mobility in Africa, with its East African
motorcycle business firmly establishing
itself as one of the frontrunners in the
e-motorcycle financing segment. In
2024, Eleving Group financed around
2,000 e-motorcycles, and its customers
commuted around 20 mln kilometers on
pure electricity, with an estimated 1000mt
of CO
2
saved during this year alone.”
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Climate change
The Environmental section provides an overview of how
Eleving Group evaluates and manages the impacts, risks,
and opportunities associated with climate change mitigation
and adaptation. It highlights the most significant areas
across the value chain and outlines key actions, targets,
and metrics, with a particular focus on greenhouse gas
emissions. Looking ahead, it also presents the Company’s
commitments and planned strategic initiatives to reduce
emissions and support the transition to a low-carbon
economy.
Eleving Group empowers diverse communities worldwide
by promoting financial inclusion, thereby enabling upward
social mobility. While the Company’s primary focus is on
economic empowerment, the Company also acknowledges
that the loan portfolio contributes to the scope 3 indirect
carbon footprint. This requires the Company to measure
the impact and make proactive efforts toward reducing it.
Eleving Group continuously monitors and works to reduce
the environmental impact of its own operations, and as
a service-based company, the scope 1 and 2 emissions
remain relatively low – contributing only around 1% of the
total emissions, with the most significant environmental
impact coming from the services provided, particularly -
through the vehicles financed.
Transition plan for climate change mitigation
Based on the results of the double materiality process,
Eleving Group will initiate the development of a transition
plan for climate change mitigation. This plan, which will
be prepared and adopted in 2025 for the next strategic
period (2026-2031), will evaluate the Company’s strategy
and business model alignment with the transition to a
sustainable economy and contribute to limiting global
warming to 1.5°C in accordance with the Paris Agreement.
To meet these targets, the plan is to assess decarbonization
strategies, such as adopting renewable energy sources
and enhancing energy efficiency. Clear governance
structures will be established to oversee implementation,
ensuring accountability and mechanisms for monitoring
and transparently reporting progress, enabling us to track
developments and make informed adjustments as needed.
Climate-related risks
Climate-related risks are an integral part of the Eleving
Group’s broader risk management framework, ensuring
a comprehensive understanding of both its impact on
climate change and the risks climate change poses to its
operations.
Climate-related risks were also assessed during the double
materiality process and covered two main categories:
physical and transition risks. Analysis included all
subsidiaries of Eleving Group across geographies, primarily
focusing on the own operations and analyzing downstream
operations related to consumers and end-users. An
assessment was conducted in line with the internal risk
assessment to evaluate the physical risks identified and
outlined accordingly as part of the double materiality
assessment. The desktop analysis focused on identifying
risks to business operations and accounted for regional
specifics.
Climate-related risks were assessed as limited in the
medium term – in a 5-year period. While historically, these
risks have not been material, and their effects are expected
to be limited and location-specific, more comprehensive
climate scenarios and resilience analyses will be carried out
in the future to assess potential financial and operational
impacts, vulnerabilities, and opportunities under different
climate scenarios. In 2025, Eleving Group will evaluate
how to adjust or adapt the strategy and business model
to climate change over the short-, medium- and long term
to ensure the business model's long-term resilience and a
strategy and business model concerning climate change.
Regarding transition risks, the primary impact is linked to
downstream operations, specifically related to vehicle loans
and potential environmental and regulatory developments.
No other material physical or transition risks were identified
during the double materiality assessment, which was
conducted based on stakeholder opinions, internal risk
review processes, and management evaluations.
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Physical/
transitional risk
Risks and/or Opportunities
Classification
Value chain 
Time horizon
Management
approach
Physical risk
Climate change
adaptation
and resilience building
addressing risks from
extreme weather events
or value chain disruptions
Risk: The growing frequency of extreme weather
events presents potential risks in the medium
term. These include threats to employee well-
being (i.e., labor productivity due to heat
stress), potential property damage, or loss of
critical records. Events like heavy rain and flood
can disrupt supply chains or damage financed
vehicles, reducing market value and increasing the
likelihood of loan defaults.
Negative
potential impact
on
Upstream and
Own operations
in
Medium-term
The identified risks
are addressed through
Eleving Group’s ESG
framework 2022-2025 &
Internal climate impact
goals
Transitional risk
Climate change
mitigation through
resource efficiency,
employee awareness,
consumer trends,
regulatory frameworks,
and technological
advancements
Risk: Increased pricing of GHG emissions and
enhanced emissions reporting obligations may
reduce the value of high-emission vehicles,
impacting loan portfolios.
Opportunity: Further scale up electric vehicle
financing products to support customers
transitioning to low-carbon mobility. Reducing the
footprint of the Company’s operations through
renewable energy.
Negative actual
impact on
Downstream and
Own operations
in
Medium-term
The identified risks
are addressed
through Eleving
Group’s Strategic ESG
framework 2022-2025 &
Internal climate impact
goals
Transitional risk
Energy consumption
affects carbon footprint,
and regulatory or cost
changes in energy
sources can create
financial or operational
risks when transitioning
to low-carbon
alternatives.
Risk: Fluctuations in fossil fuel prices (increased
cost of raw materials). Cost of transition of lower
emissions technology - stricter regulations on
internal combustion engines and other related
policies may reduce the value or availability of
vehicles that depend on fossil fuels.
Opportunity: Electric vehicle financing - loans
for EVs to address the rising demand for energy-
efficient transportation. Since the financed EV fleet
primarily drives downstream energy consumption,
investing in renewable-powered charging
infrastructure can further support this transition.
Negative actual
impact on
Own operations
&
Positive potential
impact on
Downstream
operations in
Medium-term
Area to focus on when
implementing ESG
strategy for the next
period (2026-2031)
Description of process in relation to impacts on
climate change
Climate-related transition risks were internally evaluated
over the short term (up to 1 year), medium term (up to
5 years), and long term (beyond 5 years) in line with the
internal risk assessment process conducted across all
Group countries of operations. This assessment involved
identifying climate-related hazards, screening their potential
impact on the Group’s assets and business activities, and
analyzing their financial and operational implications over
different time horizons. An additional evaluation will be
conducted in 2025 to assess how these definitions align
with the expected lifetime of assets, strategic planning
horizons, and capital allocation plans.
Eleving Group's material environmental impact on climate
change comes from its vehicle loan portfolio, which
contributes to greenhouse gas (GHG) emissions. The Group
is committed to reducing these emissions by promoting
low-emission mobility solutions, primarily through financing
fuel-efficient, hybrid, and electric vehicles and further
scaling up the electric motorcycle segment in Africa.
While previous targets have focused on monitoring CO
2
emissions per kilometer for issued loans, GHG emissions
calculations were not conducted in the past. 2025 is the
first year the Group calculates GHG emissions from both
its own operations and downstream activities, specifically
emissions associated with financed vehicles.
Eleving Group also assessed potential climate-related risks,
including transition and physical risks, to ensure that the
Company’s operations and services remain resilient and
aligned with evolving consumer trends. A comprehensive
internal risk assessment, conducted across all countries in
collaboration with the internal auditor, indicates that current
exposure to these risks is low. However, it is recognized
that the likelihood of long-term risks to own operations and
downstream activities is increasing.
While high-emission climate scenarios were not assessed in
2024, the rising frequency and severity of climate-related
hazards - such as floods or heatwaves - may pose physical
risks to Eleving Group's operations in the medium to long
term. These conditions could jeopardize employee well-
being, compromise IT infrastructure, disrupt operations,
Material climate-related physical and transitional impacts, risks and opportunities on climate change
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and lead to financial losses. Additionally, financed consumer
vehicles may incur climate-related damages, diminishing
their market value and increasing the risk of loan defaults.
Beyond physical risks, transitioning to a low-carbon
economy introduces regulatory, economic, and market-
related challenges that could affect the Company’s
operations and financial products while presenting new
opportunities. Climate-related transition risks involve GHG
pricing that could lower the value of high-emission vehicles,
impacting loan portfolios. Rising fossil fuel prices and
regulatory restrictions on internal combustion engines may
increase costs and limit vehicle availability. At the same
time, further scaling up electric vehicle financing supports
customers in shifting to sustainable mobility while reducing
portfolio exposure to high-emission assets.
Although internal analyses suggest that climate-related
impacts will remain limited in the medium term, Eleving
Group is committed to conducting more detailed climate
scenario and resilience analyses in the future, in particular,
considering a climate scenario in line with limiting global
warming to 1.5°C to evaluate potential financial and
operational impacts, vulnerabilities, and opportunities
associated with various climate scenarios. To ensure the
long-term resilience of the business model, these findings
will be integrated into the strategic decision-making while
developing the ESG strategy for the 2026-2031 period.
Policies
While delivering innovative financial solutions across
diverse communities, Eleving Group recognizes its climate
responsibilities and has embedded key principles within the
Code of Business Conduct and Ethics. Eleving Group aims to
become climate-neutral in its administrative operations and
constantly works to maintain high environmental standards
in all its offices, addressing the material impact of the
Company’s own operations.
To demonstrate compliance with the industry's ethical
standards and the national and international frameworks
on corporate sustainability and sustainable development,
the Group has aligned its practices with the United Nations
Sustainable Development Goals (SDGs). Based on analyzing
its contributions to the SDGs, the Group prioritizes SDGs 9,
12, 13, and 15 in the environmental area.
As of December 2024, the Group has not developed policies
related to climate change mitigation and adaptation. The
Group addresses material sustainability areas across all
geographies in alignment with internally established targets
outlined in the ESG Framework 2022–2025. The current
ESG framework covers the Company's own operations as
actions related to energy efficiency (reducing the climate
impact of HQ offices through energy efficiency and the use
of renewable energy at a Group-wide level), as well as the
downstream value chain in relation to consumer vehicle
loans (reducing the CO
2
intensity of the funded fleet). It
applies across all geographies and considers the impact on
key stakeholder groups, including the Group’s employees,
consumers and end users, and suppliers.
In line with the changing regulatory environment, in 2025,
Eleving Group will develop and adopt a policy related to
climate change mitigation and adaptation and ESG strategy
for 2026-2031. It will expand the current scope regarding
the value chain and climate change mitigation efforts and
adaptation, further integrate renewable energy solutions,
and address energy efficiency to contribute effectively to
global climate change mitigation efforts.
When the initial ESG framework was set in 2021, Eleving
Group conducted a materiality analysis considering business
operations, the value chain, and various environmental,
social, and governance impacts. Stakeholder interests
were prioritized through an online survey, interviews,
management workshops, and peer reviews. Around
150 stakeholders from 130 organizations contributed to
shaping the Group's approach to sustainability, preventing,
mitigating, and remediating actual and potential impacts,
addressing risks, and pursuing opportunities.
The Supervisory and Management Board oversees policies,
corporate strategy, and sustainability governance. It will
be involved in transition plan development and approval
in 2025, ensuring that material sustainability matters
are integrated into decision-making processes and that
sustainability-related impacts, risks, opportunities,
and goals are aligned with the Company’s long-term
strategic priorities and business model and employees–
engaged. The Group educates and involves its team in
sustainable practices, fostering a culture of environmental
responsibility. This collective effort ensures that
sustainability is a shared value, driving continuous
improvement in the Group’s operations and services.
The Code of Business Conduct and Ethics and Eleving
Group's strategic ESG framework for 2022-2025 are
publicly accessible on the Company's website, ensuring
transparency and availability to all stakeholders.
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Targets related to climate
change mitigation and
adaptation
Eleving Group is committed to contributing to the transition toward a
low-carbon economy and sustainable mobility. The Group encourages
customers to make sustainable decisions by introducing more low-carbon
products. These efforts have led to a 2.27% reduction in the average CO
2
intensity of its car portfolio in 2024 compared to 2023 (read more about
the additional targets and results in the section Actions and resources in
relation to climate change policies).
Eleving Group has set reducing the CO
2
intensity of its funded fleet as
one of the primary goals in the ESG framework 2022–2025. It intends to
reach its ambitions by promoting green vehicle financing and focusing on
productive lending. In this framework, developed in 2021, the Group’s
management has set the following targets for emission reduction and
monitoring: 
  To measure average gCO
2
/km tailpipe emissions and reduce the CO
2
emissions intensity of the funded fleet annually.
  Educate customers and society about CO
2
emissions intensity and
provide incentives to move to green mobility vehicles.
  Reach climate neutrality of the Group’s HQ administrative operations
by 2025.
The Group’s established processes and targets are integrated within the
functions that ensure daily commitment compliance. Until now, Eleving
Group has monitored the average CO
2
emission levels from its financed
fleet and the level of CO
2
reduction across regions and years. In 2024,
the achieved CO
2
intensity of the funded fleet was 81.3 gCO
2
/km, pro-
gressing toward the target of 80 gCO
2
/km by 2025.
After a thorough double materiality process, Eleving Group has started
developing plans to accelerate efforts in minimizing impact; therefore,
environmental targets will be reviewed in 2025, with an assessment
of all areas deemed material, focusing on the impact across the value
chain. 2024 marks the first time reporting on greenhouse gas emissions,
establishing a baseline for future assessments. In alignment with this,
Eleving Group will define and adopt targets for the next ESG strategic
period, 2026–2031, later in 2025, to effectively manage significant
climate-related impacts, risks, and opportunities.
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Actions and resources in relation
to climate change policies
The Company recognizes its primary climate impact through
scope 3 emissions associated with consumer vehicle
loans and is committed to mitigating these emissions by
monitoring CO
2
reductions and expanding access to low-
carbon mobility solutions following annual progress in line
with the ESG Framework 2022–2025, with defined targets
to be achieved by 2025.
As a key action, the Company is tracking the emissions of
its financed fleet and expanding the share of low-emission
vehicles. The scope of this action includes measuring,
analyzing, and reducing emissions from financed vehicles as
well as monitoring the proportion of low—and zero-emission
vehicles in the loan portfolio.
Before 2025, the Eleving Group monitored CO
2
reductions
within the financed fleet as part of its sustainability
efforts and did not analyze GHG emissions. To ensure
accountability and continuous improvement, in 2025, the
Company will adopt GHG-related targets, with progress
tracking and reporting starting for the 2025 reporting
period. The Company plans to assess climate change
mitigation actions through key decarbonization levers to
ensure a structured and transparent approach to emission
calculations and reductions. The outcomes of these
initiatives will include both achieved and expected GHG
emission reductions, aligning with the Company's long-term
strategy.
In line with the key action, in East Africa, the Group has
expanded its electric vehicle financing portfolio, supporting
green mobility initiatives in Kenya and Uganda by providing
electric motorcycle financing to self-employed individuals
and small entrepreneurs. This initiative positively impacts
the climate and fosters economic inclusion, as motorcycles
in these regions serve as vital income-generating tools for
passenger transport, delivery services, and other small
businesses. To further support customers, the Company
collaborates with partners to offer battery-swapping
services, enhancing the circular economy and helping
clients save on costs and energy. Instead of charging
batteries themselves, customers can exchange depleted
batteries for fully charged ones at designated swapping
stations. The empty batteries are then recharged and given
to the next customer.
Eleving Group primarily focuses on financing electric
motorcycles and in the East Africa region, with over 2,000
units financed and an investment of approximately 2 million
euros to expand this product line. As a result, in 2024, the
target was exceeded by more than double surpassing the
2025 goal of at least 1,000 leased cars in the Company’s
portfolio with zero CO
2
tailpipe emissions. Eleving Group is
remaining focused on further scaling up the electric vehicle
financing segment primarily in the Group's Eastern Africa
markets that possess the largest headroom for organic and
meaningful growth.
At the same time, the Company is not missing out on
the electric car-sharing segment, where it has invested
around 4 million euros (since the launch in summer 2022)
in developing its OX Drive, a car-sharing app in Latvia. In
mid-2024, OX Drive merged with Carguru, a pioneering
Latvian car-sharing company, resulting in Eleving Group
holding a 36% stake in the merged entity. This merger has
strengthened Carguru's market position, expanding its fleet
to over 420 vehicles, including more than 200 electric cars
provided by Eleving Group. The rest of the Carguru fleet
comprises hybrid cars, meaning that the Eleving Group
continues to invest in a sustainable and green car-sharing
service even after the transfer of OX Drive operations to
Carguru.
Also, Eleving Group's portfolio includes hybrid vehicles,
totaling 5,697 units by the end of 2024, and the value
of the Company's loans in the hybrid segment exceeds
21 million euros since inception. The Group promotes
sustainability by educating customers through regular
communication and has introduced a CO
2
metric on all its
sales portals, encouraging clients to consider vehicles with
lower carbon footprints. These efforts have led to a 2.27%
reduction in the average CO
2
intensity of its car portfolio vs
2023.
The average CO
2
emissions generated by the vehicle loan
data have been calculated using the following conversion
factors: the emission factors for vehicle loans were derived
from the Road Traffic Safety Directorate of Latvia (vehicle
fuel type, year, engine capacity, transmission type, brand,
and model). For Boda-Boda electric motorcycles in Kenya
and Uganda emissions have been estimated at 40g per
km used (EPA Emission Factors for Greenhouse Gas
Inventories). Calculations are performed using the entire
active loan portfolio at the end of the reporting period,
categorized by vehicle type, and determining the average
CO
2
emissions (g) per kilometer driven.
Average CO
2
emissions (g/km) of the
portfolio by loan issued date
Eleving Group
Excluding Africa
and Asia hub
(g/km)
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By financing electric and hybrid vehicles, the Company
contributes to reducing CO
2
emissions in urban areas
where internal combustion engine vehicles are prevalent.
The transition to electric mobility enhances public health
by decreasing air and noise pollution, potentially reducing
respiratory illnesses and associated healthcare costs.
In its operations, Eleving Group implements targeted
measures to reduce office emissions by renting eco-friendly
class-A office spaces and purchasing energy-efficient
technologies. The Group monitors electricity, heating, and
water usage to identify opportunities for reduction. While
the Group focuses on reducing resource consumption, waste
reduction and recycling are also prioritized. The Group’s
HQ has already implemented a range of waste optimization
initiatives, such as a zero-paper policy and reducing plastic
waste.
In 2024, a waste management system was introduced in
the operations in Kenya. The Mogo Sustainable Waste and
Residue Management (SWARM) Program was developed
to reduce the amount of waste sent to landfills by 80%
while generating revenue from recyclable materials,
with the target to be achieved by the end of October
2025. This program aims to promote responsible waste
management practices within Mogo Kenya and engage
surrounding communities in the circular economy. In its
initial phase, the program was launched at the Company’s
headquarters, where more than 300 employees are based,
and it achieved 100% traceability for all waste produced
across its properties, giving a comprehensive overview
of the environmental impacts. The introduction of waste
management systems in other markets, such as offices in
the Baltic States, is also progressively being rolled out.
The Group's financial resources for managing climate-
related physical risks are integrated within the relevant
business functions, as the assessed risks are considered
low. Resources allocated for climate change mitigation,
specifically concerning the decarbonization of vehicle loans,
are incorporated into the business plan. Additionally, in the
annual budget planning, the Company anticipates allocating
further resources to support implementing carbon offsetting
projects. From 2025, the Company plans to define a
separate ESG budget, with a 10% yearly indexation until
2030.
Energy consumption and mix
As jurisdictional requirements vary across the regions
where Eleving Group operates, data from the Company's
operations are unavailable in all locations. The data
required for scope 2 energy-related calculations and
emissions are estimates, as supplier-specific information
on energy sources, emission factors, and consumption
data is not accessible for all subsidiaries. As part of the
double materiality assessment and reporting process, the
Company has identified such challenges and will establish a
centralized reporting process in 2025 to ensure consistency
across all markets.
In 2024, most purchased energy for Eleving Group's own
operations in countries was classified as originating from
non-renewable sources. CO
2
emissions were calculated
using the Harmonized Grid Emission Factor dataset from
the IFI Interim Dataset of Grid Factors (Version 1.0, July
2016), aligned with the Partnership for Carbon Accounting
Financials guidelines (IFI, 2016).
Due to data limitations and missing information from
Botswana and Namibia, the energy mix data is based
on available information and covers 91% of the Group’s
operations while still providing a reliable representation.
GHG Emissions Assessment
In the first year of reporting, scope 1 calculations account
only for fuel-related emissions from the Eleving Group’s
own fleet, specifically the carbon emissions generated by
its use in two of Eleving Group's markets. The calculations
were based on the amount of fuel combusted using the
spend-based method. The direct GHG emissions displayed
represent the total of the greenhouse gases carbon dioxide
(CO
2
), methane (CH
4
), and nitrous oxide (N
2
O) converted
into carbon dioxide equivalents by applying emission
factors to each energy source in line with emissions and
methodology issued by the U.S. EPA Center for Corporate
Climate Leadership – GHG Inventory Guidance. This
guidance was used due to its thorough methodology and
detailed scenarios for calculating vehicle-related impacts
based on available data, ensuring the least uncertainty in
emissions estimations.
Scope 2 greenhouse gas emissions refer to indirect
emissions resulting from the energy purchased by the
Eleving Group. These emissions are linked to electricity,
heating, and cooling consumption. They are calculated
as a sum of total consumption (MWh) times the location-
based or market-based emission factor for each country.
Energy consumption and mix 2024
Total energy consumption from fossil sources (MWh)  1520
Total energy consumption from nuclear sources (MWh)  0
Total energy consumption from renewable sources (MWh)  202
Fuel consumption for renewable sources including biomass (MWh)  0
Consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources (MWh)  202
Consumption of self-generated non-fuel renewable energy (MWh) 0
Total energy from fossil fuels (MWh) 1520
Total energy consumption (MWh) 1722
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The market-based method was used in Latvia based
on the certificate and emission factor provided by the
supplier. To calculate GHG emissions for energy for entities
where supplier-specific information is not available, UN
Harmonized Grid Emission factor location data has been
used.
The following Scope 3 categories, as defined by the GHG
Protocol, are included in Eleving Group’s greenhouse gas
emissions assessment:
Scope 1, 2 and 3 GHG emissions are disclosed in a
consolidated Group format.
Investments
Eleving Group calculates the environmental footprint
associated with vehicle financing, including cars and
motorcycles. As the sole financing provider for these loans,
100% of the annual emissions from these vehicles are
attributed to Eleving Group’s scope 3 emissions.
The Company assesses the environmental footprint
associated with vehicle financing, covering both cars and
motorcycles. Since vehicle loans are issued to individual
consumers, precise data on distance driven or fuel
consumed is not available. As a result, the calculations rely
on the average-data method, using estimates based on
general commuting patterns, which introduce significant
uncertainty.
The GHG emissions associated with the Group's vehicle loan
data have been calculated using emission factors derived
from the Road Traffic Safety Directorate of Latvia (CSDD).
These factors consider various factors, including fuel type,
manufacturing year, engine capacity, transmission type,
brand, and model. For the initial reporting period (up to
2024), the calculations account solely for CO
2
emissions, as
methane (CH
4
) and nitrous oxide (N
2
O) emissions from on-
road vehicles less than 20 years old typically contribute less
than one percent of total greenhouse gas (GHG) emissions.
In 2025, the methodology will be adjusted to include
CH
4
and N
2
O emissions, ensuring a more comprehensive
assessment of transportation-related greenhouse gas
emissions. For Boda-Boda electric motorcycles in Kenya
and Uganda, EPA Emission Factors for Greenhouse Gas
Inventories are used.
Calculations are based on the average-data method, which
involves estimating emissions from commuting using
average data on commuting patterns. For the average
distance travelled, the Central Statistical Bureau of Latvia
Mobility Statistics is used (CTP01, 2022). These statistical
data have been compared to internal customer mobility
data, revealing a similar trend. For the motorcycle segment
in Africa, data from the Company’s consumer mobility
in Kenya is used for calculations, and based on this, an
average is applied to other countries in Africa.
Purchased goods and services
Scope 3 GHG emissions include those generated from
the cloud computing and data center services company
procures based on one supplier’s information. It covers key
Tier 1 supplier and accounts for purchased IT services in 15
of the Company’s 16 markets.
Waste generated in operations
Based on the GHG Protocol methodology, the calculations
were performed using the average-data method, which
involves collecting the total mass of waste generated in
operations and applying the average emission factor based
on the waste treatment method assuming 100% of the
waste was landfilled.
Business travel
In 2024, in the first year of calculating emissions from
employees’ business travel, the total distance traveled in
kilometers is converted into corresponding CO
2
emissions.
This information includes only air travel and covers all of
Eleving Group's subsidiaries. For calculations, the average
mass of CO
2
emitted per passenger-kilometer is used,
based on data from the European Union Aviation Safety
Agency's European Aviation Environmental Report 2025.
Eleving Group does not apply internal carbon pricing
schemes and, in 2024, did not have GHG removal or
mitigation projects financed through carbon credits.
GHG intensity based on net revenue
GHG intensity is calculated on a consolidated basis across
all operations by dividing the total significant scope 1,
scope 2, and scope 3 greenhouse gas (GHG) emissions
by net revenue. Net revenue is obtained from the Group's
consolidated financial statements.
GHG intensity on net revenue 2024
Total GHG emissions (location-based) per net revenue (tCO
2
eq / mln EUR)  716.56
Total GHG emissions (market-based) per net revenue (tCO
2
eq / mln EUR)  714.32
Purchased goods and
services
Category 1:
Waste generated 
in the operations
Category 5:
Business
traveling
Category 6:
InvestmentsCategory 15:
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GHG emissions 2024
Scope 1 GHG emissions 
Gross Scope 1 GHG emissions (tCO
2
eq) 803
Percentage of Scope 1 GHG emissions from regulated emission trading schemes (%) 0
Scope 2 GHG emissions 
Gross location-based Scope 2 GHG emissions (tCO
2
eq) 515
Gross market-based Scope 2 GHG emissions (tCO
2
eq)  30
Scope 3 GHG emissions
Total Gross indirect (Scope 3) GHG emissions (tCO
2
eq) 153888
Purchased goods and services (cloud computing and data centre services) 4
Waste generated in the operations 76
Business traveling 96
Investments 153712
Total GHG emissions 309927
Total GHG emissions (market-based; tCO
2
e) 154721
Total GHG emissions (location-based; tCO
2
e) 155206
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Social
information
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Own Workforce 
The Own Workforce section outlines Eleving Group's
approach to managing its workforce and the related
significant impacts, risks, and opportunities. It describes
the policies implemented to promote a safe and inclusive
work environment, ensure compliance with legislative
requirements, foster employee’s engagement, and provide
information about the remediation tools for effective risk
management. The section also offers insights into key
metrics and results related to employee characteristics and
diversity, training and development, health and safety,
and overall employee well-being, ensuring transparency in
workforce management efforts.
Material impacts, risks and opportunities
Eleving Group’s success depends on its team and the
Company aims to be an employer of choice, constantly
developing a working environment in all markets where
it operates to assure every employee feels safe, healthy,
and comfortable. Eleving Group is committed to promoting
responsible and sustainable business practices across its
operations, creating an organizational culture that fosters
inclusion, openness, and a sense of belonging.
Most of Eleving Group's workforce is permanent, full-time
employees. The Company provides long-term employment
contracts, where workplace health and safety are always
prioritized. All employees within the Company’s own
workforce are materially impacted by the Company and are
included in its disclosure scope. These impacts arise from
the Company’s operations, such as working conditions,
job security, health and safety, well-being, and access
to benefits, as well as from the value chain, including its
services and business relationships.
Eleving Group also engages non-employees, such as
service contractors, who may be involved in specific tasks
or provide ongoing services, bringing skills or expertise
in particular areas. The Company balances the risks and
opportunities associated with non-employees by ensuring
fair treatment, compliance, and workplace standards and
mitigates risks, ensuring that all workers - employees, and
contractors - are treated fairly and in line with legislative
standards and regulatory requirements.
Material
impacts,
risks, and/or
opportunities
Classification
Value chain 
Time horizon
Description and interaction
with business model and/or strategy
Secure
employment &
Adequate wages
Employment type
impacts job security,
financial safety, and
the economic and
psychological stress
of the own workforce
Positive actual
impact on
Own operations in
Short-term
Eleving Group prioritizes open-ended, full-time, fixed-
fee employment contracts to ensure fair employment
practices. The associated risks may lead to high employee
turnover and increased recruitment and training costs,
disrupting service continuity.
Health & Safety
Unsafe working
conditions can lead
to serious accidents,
particularly for
employees whose
duties involve the
use of transportation
Negative potential
impact on
Own operations in
Short-term
Health and safety training programs and ensuring strict
compliance with safety standards.
Training &
Development
Enhancing the
Company's
competitiveness
by empowering
employees to
continuously update
their knowledge and
develop new skills
that improve job
performance
Positive actual
impact on
Own operations in
Short-term
A continuous learning culture in place, providing all
company’s own employees at least 8 hours of professional
development training per year. The Group also
implements succession planning strategies to prepare
talent for leadership roles, supporting internal promotions
and strengthening organizational capability.
Work-life balance
& Working time   
Promoting work-
life balance and
employee well-being
Positive actual
impact on
Own operations in
Short-term
Eleving Group is dedicated to supporting its employees
in achieving a healthy work-life balance through flexible
working arrangements, including hybrid work models,
flexible hours, and a "work from anywhere" policy. The
Company also offers a wide range of paid and unpaid
leave options to accommodate personal needs and life
events.
Own
workforce
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Material
impacts,
risks, and/or
opportunities
Classification
Value chain 
Time horizon
Description and interaction
with business model and/or strategy
Diversity  Diverse and inclusive
workplace
Positive potential
impact on
Own operations in
Short-term
The Group is committed to maintaining a diverse and
inclusive workplace, ensuring equal opportunities for all
employees regardless of ethnicity, gender, age, disability,
or background. The Group employs individuals from over
20 different nationalities, reinforcing its commitment to
fair treatment and non-discrimination.
Social dialogue  Promotion
of employee
engagement
and transparent
communication
through social
dialogue
Positive potential
impact on
Own operations in
Short-term
Eleving Group is committed to open and transparent
communication with employees through internal
meetings, feedback sessions, and surveys, and provides
grievance mechanisms to address concerns.
Own
workforce
Operating in developing regions presents challenges that
can affect workforce availability and business operations.
Economic uncertainty may lead to difficulties in talent
retention, reduced employee satisfaction, and a shrinking
talent pool, making it harder to find and retain skilled
professionals. Understanding well the challenges of local
markets is crucial to maintaining a resilient and high-
performing workforce.
Eleving Group is committed to upholding human rights and
unequivocally opposes any violations, including child labor.
As a result, the likelihood of such risks occurring within
the Company’s operations is assessed to be very limited.
Eleving Group upholds a zero-tolerance policy toward forced
labor both in its own operations and in the value chain and
is committed to ensuring that all employment practices are
voluntary and free from coercion. The Company strictly
adheres to relevant national standards and international
labor standards, including the International Labor
Organization's Declaration on Fundamental Principles and
Rights at Work, to protect human rights and promote
ethical working conditions across all its business operations.
The Group implements strict recruitment and employment
screening processes to ensure fair and ethical hiring
practices, reducing the risk of forced or bonded labor. This
includes providing clear, legally compliant contracts in a
language employees understand and upholding their rights
to freedom of movement and voluntary job termination
without penalties. Additionally, ongoing monitoring
and grievance mechanisms allow workers to report any
concerns, ensuring transparency and accountability in the
hiring process.
Eleving Group's commitment to responsible business
practices helps to raise its awareness of these risks and
encourages the implementation of proactive measures
to mitigate them. By following relevant policies like the
Code of Business and Ethics and human rights policies
or processes, the Company addresses fair employment
practices, meets employees' training and development
needs, and fosters a work environment that enhances
employee well-being and operational sustainability.
Policies
To effectively manage the material impacts, risks, and
opportunities within its own workforce, Eleving Group has
implemented policies to ensure human and labor rights,
fair treatment, and professional development across all
geographies. The following section outlines the key policies
established to achieve these objectives.
The Company’s policies apply to all employees, ensuring
a consistent commitment to ethical business practices
across all operations. Senior management oversees their
implementation, ensuring alignment with corporate values
and regulatory requirements. They also oversee the
effective communication of these policies to employees
and relevant stakeholders through training, awareness
programs, and regular updates, fostering a culture of
compliance and accountability.
Code of Business Conduct and Ethics
The Company has embedded key principles within the
Code of Business Conduct and Ethics, defining main
principles and standards to promote fair and transparent
business practices, respect for human and labor rights,
and adherence to business ethics. To demonstrate
compliance with the ethical standards of the industry and
the national and international frameworks on corporate
sustainability and sustainable development, Eleving Group
has aligned its practices with the United Nations (UN)
Sustainable Development Goals (SDGs) in the social aspect,
contributing to SDGs 3, 4, 5, and 8. The code outlines
its commitment to human and labor rights, emphasizing
adherence to international standards. The Code prohibits
child and forced labor and discrimination and ensures safe
and healthy working conditions. Human rights policy applies
equally and universally in all countries, irrespective of the
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Employee engagement
Open communication is crucial for identifying and
addressing both actual and potential impacts on the
workforce. It ensures that employees’ concerns are
considered, and that appropriate measures are taken.
Building on this foundation, employees’ engagement
processes facilitate meaningful dialogue and foster a culture
of transparency and accountability.
One of the engagement formats with employees is through
bi-annual Eleway Pulse surveys. These surveys evaluate the
Company’s own employee experience, assess satisfaction,
and identify areas for improvement. They include questions
about the resources and tools available for productive
work, learning and professional development opportunities,
work-life balance, and overall satisfaction. In 2024, 1352
employees participated in the survey and provided their
feedback. This input contributes to management decision-
making and helps shape activity plans and initiatives to
address actual and potential impacts on employees.
Engagement occurs directly with employees rather than
through representatives, ensuring a broad and inclusive
approach across all Eleving Group subsidiaries. The
anonymity of survey responses allows for open and honest
feedback across different workforce segments.
Eleving Group adheres to applicable labor laws and internal
policies that are aligned with the Universal Declaration of
Human Rights, including non-discrimination, prohibition
of child and forced labor, and safe and healthy working
conditions. The effectiveness of workforce engagement
is assessed through survey participation rates, trends in
engagement scores, and employee feedback on the key
areas. The Human Resources department has operational
responsibility for overseeing the engagement process, while
the Management Board ensures that insights from these
activities contribute to the Company’s strategic direction.
Additionally, Eleving Group actively engages with its
workforce every quarter through All-Hands meetings, where
the Management Board provides updates on the Company’s
strategic plans, financial results, ESG-related commitments,
and other key developments while addressing employee
questions.
With the above-mentioned measures in place, the Company
ensures consistent communication, engagement, and
the protection of employee rights; therefore, additional
instances for collective bargaining are not established.
Reporting system
The Company is committed to addressing issues related to
its material impacts, risks, and opportunities through its
established grievance mechanisms. It allows employees to
raise concerns or report incidents of occupational health
and safety risks, human rights risks, harassment, and
discrimination. Employees may submit their concerns
directly to their local Human Resources representative or
the Group Human Resources department. Additionally, the
Eleving Group provides a whistle-blowing tool, FaceUp,
which serves as an independent reporting channel for cases
that involve a special department that is responsible for
security and pertain to severe instances of discrimination
or harassment. Employees also have the option to report
concerns anonymously. When a potential non-compliance
issue is reported, the respective department conducts a
thorough investigation. Appropriate actions are taken based
on the findings and the scale of the problem.
In 2024, a total of 20 reports concerning potential
misconduct were received, recording an increase of 6
compared to a year ago. None of them were related to
human rights misconduct or discrimination. All whistle-
blowing reports were solved. This reflects stakeholders'
growing awareness of the whistle-blowing tool, increased
trust in using it, and greater attentiveness to general
matters. To further strengthen this awareness and
engagement, the Company is organizing campaigns to
inform employees about the tool and encourage its use for
reporting potential concerns.
Eleving Group upholds the highest standards of ethics and
integrity in its business practices. The Company fosters
a strong corporate culture through ethical governance,
well-defined values, and active employee engagement.
By fostering a culture of integrity, collaboration, and
accountability, the Company ensures its corporate values
remain embedded in its daily operations and long-term
strategy.
legal framework. The Group provides and enables remedy
for human rights impacts through the process defined
in a Whistleblowing Policy that allows confidential and
anonymous reporting of any suspected violations.
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Targets related to managing material
negative impacts, advancing positive
impacts, and managing material risks
and opportunities
To effectively manage risks and opportunities within its own
workforce and mitigate material negative impacts, Eleving
Group has set targets to promote long-term sustainability
and employee well-being.
These workforce-related targets were set in 2021 as part
of the development of the initial ESG framework, with
active involvement from representatives of the relevant
functions. To maintain engagement and accountability,
employees are regularly informed about progress and
the Company’s commitments, ensuring transparency
in tracking performance against these targets. This is
done through multiple channels, including discussions
of employee engagement survey results, the Company’s
year-end reviews, and monthly management meetings - a
platform for employees to discuss results, raise concerns,
and contribute to identifying improvements based on the
Company’s performance.
The Company uses outcome-oriented targets to drive
and measure its progress in addressing material negative
impacts, advancing positive implications on its workforce,
and managing material risks and opportunities related to
its employees. This approach ensures a structured and
measurable framework for continuous improvement and
accountability.
Eleving Group uses the Employer Net Promoter Score
(eNPS) system to measure employee satisfaction and
loyalty. The employee survey is conducted biannually. In
the first half of 2024, the score was 30.9, increasing slightly
to 31.3 in the second half of the year.
eNPS, which ranges from -100 (all Detractors) to 100 (all
Promoters), is widely used to gauge employee sentiment.
A score in the range of 10 to 30 is commonly interpreted
as a positive indicator of employee engagement, reflecting
a generally favorable perception of the workplace. Scores
above 50 are viewed as excellent and reflect outstanding
employee loyalty and satisfaction. Acknowledging this
standard, the Group has set an ambitious target of
achieving an eNPS of 50 or higher by 2025. To support
this goal, Eleving Group engages employees in results
discussions and defines follow-up actions, maintaining a
commitment to support continuous improvement.
To maintain gender diversity in senior leadership roles,
Eleving Group set a target of achieving 40% female
representation by 2025. This goal was met at the end
of 2024, when the ratio of women to men in the senior
leadership team (C-Suite) was 40% to 60%. Looking ahead,
Eleving Group remains committed to gender diversity and
aims to maintain or improve current balance by developing
internal talent and encouraging qualified female candidates
to pursue leadership roles.
Aligned with the social commitments, the Company has set
goals to support employees' professional growth and career
progression. This includes providing at least 8 hours of
professional training per employee annually. Eleving Group
offers a wide range of training opportunities to support
professional and personal growth for all employees, which
is also reviewed in regular performance and development
evaluations. The annual target of 8 training hours per
employee is consistently achieved.
By creating a safe and growth-oriented working
environment that focuses on employees' well-being,
human and labor rights compliance, and development
opportunities, Eleving Group strengthens its workforce and
fosters sustainable organizational growth. To ensure these
commitments are effectively implemented, the Group has
established action plans and allocated resources to manage
material impacts, risks, and opportunities related to its own
workforce.
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Action plans and resources to manage
material impacts, risks, and opportunities
related to its own workforce
Eleving Group is committed to fostering a secure, fair, and
supportive work environment by actively preventing and
mitigating negative impacts on its workforce across all
jurisdictions in which it operates. The Company ensures
secure employment, promotes work-life balance, maintains
fair working hours, and provides competitive wages. Health,
safety, and social dialogue remain top priorities, supported
by structured career development programs and fair
employment practices. The Group’s Personnel Management
Policy focuses on developing a skilled, engaged, and high-
performing workforce, empowering employees at every
stage of their careers.
To enhance employee well-being, Eleving Group implements
various initiatives, including health and safety training,
awareness programs on work-life balance, and employee
engagement activities. The Company also provides
remedies through grievance mechanisms and corrective
actions, ensuring that employee concerns are addressed
promptly and effectively.
Tracking Effectiveness and Risk Mitigation
The Company continuously assesses the effectiveness of
its workforce-related initiatives through key performance
indicators (KPIs), employee engagement surveys, training
completion rates, health and safety incident reports,
and social dialogue outcomes. Employee feedback
and compliance monitoring help identify necessary
improvements, ensuring that policies remain effective and
aligned with regulatory standards.
To mitigate material risks related to workforce stability
and retention, the Company closely monitors labor market
trends, strengthens retention strategies, and evaluates
HR performance through incident reporting systems.
This proactive approach allows Eleving Group to adapt to
workforce challenges efficiently.
Workforce Development and Well-Being Initiatives in
2024
In 2024, Eleving Group introduced diverse training,
development, and well-being programs across its operations
to support employees in strengthening their skills,
leadership abilities, and overall resilience. Key initiatives
included: 
  Cybersecurity and digital literacy webinars, along with
an AI masterclass series, to equip employees with
critical knowledge of emerging technologies.
  Organizational leadership programs and experience-
sharing forums for functional leaders, enhancing
managerial and leadership competencies.
  Well-being programs, such as webinars on emotional
intelligence and stress management, to foster a
balanced and supportive work environment.
  Team-building training to promote collaboration and
strengthen workplace culture. 
Commitment to Ethical and Sustainable Workforce
Practices
Eleving Group ensures that its business practices do
not cause or contribute to material negative impacts
on employees. The Company aligns its policies with
international labor standards, maintains grievance
mechanisms, and conducts regular internal evaluations to
uphold workplace integrity.
Resources for workforce management are strategically
allocated through dedicated HR and functional budgets,
supporting occupational health and safety programs,
employee benefits, and workforce well-being initiatives.
Additionally, to mitigate potential workforce disruptions
due to the transition to a climate-neutral economy, the
Company provides employee training and raises awareness
about sustainability-related challenges and opportunities.
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Characteristics of
the employees
Eleving Group employs people of various cultural backgrounds, genders,
and ages. The Group is represented by employees form 20 different
nationalities. Therefore, diversity and equal opportunities are essential
to Eleving Group’s human resources strategy. The Group ensures that
employees are treated fairly and given equal opportunities. Eleving
Group is committed to creating and maintaining an open, inclusive
work environment free from discrimination and harassment. No internal
employees or external candidates should feel discriminated against or
harassed during the recruitment, promotion, or employment processes.
As of December 31, 2024, 2793 employees were working in Eleving
Group. This number includes all employees with active employment on
that date, including permanent, temporary, and part-time employees.
The data is based on the headcount as of the end of 2024, using actual
employment records from the year-end reporting date. The other table
provides an overview of all Eleving Group countries, detailing the number
of employees by country and gender.
In 2024, the average number of employees
was 2589, and 870 employees left the
Company during the year, resulting in
a turnover rate of 33.6%. This rate is
calculated by dividing the number of
employees who left the company in 2024
by the average number of employees
during the year, providing a more accurate
measure that accounts for workforce
fluctuations.
Employee turnover is primarily driven by
frontline positions and customer service
entry-level roles, which typically experience
higher turnover rates across industries. The
turnover rate also highlights workforce-
related risks from a regional perspective,
particularly in certain markets such as
Uganda and Botswana, where local labor
dynamics and market conditions contribute
to higher employee mobility. As part of
the ESG strategy development for 2026-
2031, dedicated goals and measures will be
established in 2025 to enhance employee
retention and workforce stability.
Number of employees 
(headcount) on 31.12.2024.
Characteristics of Eleving Group
employees (headcount)
Country
Number of
employees 
Albania 222
Armenia  71
Botswana 77
Estonia 19
Georgia 73
Kenya 688
Latvia 265
Lesotho 13
Lithuania 83
Moldova 152
Namibia
214
North Macedonia
191
Romania
64
Uganda
431
Uzbekistan
65
Zambia
165
Characteristics
of employees
Male Female Total
Permanent employees 1274 1428 2702
Temporary employees 31 52 83
Non-guaranteed hours employees 2 6 8
Total: 2793
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Diversity metrics
The Company's workforce is primarily composed
of employees between the ages of 30 and 50, who
represent 52% of the total. Younger employees, under
30 years old, represent 44% of the workforce, while
those over 50 account for 4%.
To maintain gender diversity in senior leadership roles,
Eleving Group set a target of achieving 40% female
representation by 2025 and as of December 31, 2024,
women accounted for 40% and men for 60% of the
Group's gender diversity ratio in senior-level positions.
Within the Management Board, 75% of representatives
were men, while 25% were women.
Management board
Men
Women
75%
Senior level
Men
Women
60%
40%
25%
Distribution of employees
Employees, <30 years old
Employees, >50 years old
Employees, between 30 and 50 years old
44%
4%
52%
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Employees' well-being
Employees' health, safety, and well-being have always been
important to Eleving Group. The Company is committed to creating
a safe working environment in all its countries. Compliance with
local laws, adherence to the Group’s policy and standards, and
working towards health and safety objectives are all essential
components of the Group’s efforts to reduce risks and improve its
health and safety record.
Health and Safety
The Company’s health and safety management system
covers the entire workforce, ensuring compliance with
workplace safety regulations. All employees are included
in health and safety programs, training sessions, and risk
prevention measures. Workplace safety risks and hazards
are prevented by implementing proper measures. First,
as the law requires, workplace risks are assessed within
the labor protection management system framework.
All employees are regularly instructed on general work
safety and during test fire alarms. At employee onboarding
and annually, employees are provided with information,
instructions, and training to work safely and take steps to
protect themselves from hazards.
The Company tracks and reports on work-related accidents,
and fatalities. These incidents are monitored through
an internal reporting system, and corrective actions are
implemented to mitigate risks and enhance workplace
safety. Regular assessments and preventive measures are
in place to continuously improve employee well-being and
minimize occupational hazards.
During 2024, the Group registered 69 recordable accidents
among the Company’s employees, compared to 57 a year
ago. Out of all accidents, one recorded case in Kenya and
one in Namibia resulted in casualties. The Company has
ensured its full support to those affected by the incident.
Immediate measures were taken to assist the employees’
families. Comprehensive actions have been implemented to
strengthen health and safety standards, and the Company
remains fully committed to maintaining a safe and secure
working environment for all employees.
The reported health and safety incidents involved
employees who were injured while performing duties with
motorcycle taxis—either during field debt collections,
boda-boda verification, or GPS Tracker installation. These
incidents were influenced by regional factors, including
infrastructure challenges and location-specific driving
culture in Uganda, Kenya and Namibia. To mitigate risks
and enhance health and safety within the workforce,
additional safety training, including safe driving practices,
is provided in these high-incident regions, along with the
necessary health and safety equipment. As a part of these
efforts, all field officers are consistently supplied with safety
riding gear, and all motorcycle users benefit from enhanced
medical coverage. Furthermore, the Company complies
with the Work Injury Benefits Act (WIBA), the regulatory
framework governing workplace accidents in Kenya, which
ensures that employees are covered in the event of work-
related injuries or illnesses—providing access to medical
care, compensation, and rehabilitation support.
No health and safety cases or injuries were recorded in
other markets.
To mitigate health and safety risks and reduce the number
of incidents, particularly in high-risk roles and regions with
reported incidents, the Company has implemented H&S
training programs. In 2025, H&S targets will be established
to develop a structured action plan and integrate safety
considerations into strategic decision-making. These
initiatives will be part of the company's ESG strategy for the
2026-2031 period, with a commitment to striving for zero
accidents. Its effectiveness will be monitored through key
performance indicators, including incident rates and training
completion.
Health and safety 2024
Percentage of employees covered by health and safety management system  100%
Number of work-related accidents 69
Rate of recordable work-related accidents 2.47%
Number of fatalities as result of work-related injuries 2
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Adequate wages
Eleving Group has always stood up for fair pay and social
and health guarantees. The Group rewards employees
based on their performance and contribution to the
Company while considering factors like location and cost
of living. Employees are also provided with competitive
benefits packages and are encouraged to use development
opportunities offered by the Company. The Group’s
Remuneration policy states that each employee is entitled
to a salary review once per calendar year as a part of the
performance review. Employees who have worked for a
full calendar year are eligible for a bonus equivalent to two
salaries, which is paid in addition to their regular salary.
Eleving Group believes a fair and transparent tax system
is vital to a well-functioning society. The Group pays
maximum attention to all tax-related procedures, complying
with local and international legislation, legal requirements,
and acceptable business standards. This applies to labor
taxes, where the Group maintains a rigorous tax discipline.
In 2024, the Company revised its remuneration ratio and
pay gap reporting metrics and reports on two key pay
equity metrics: the gender pay gap and remuneration ratio.
The gender pay gap represents the percentage difference
in average pay levels between male and female employees,
expressed as a percentage of the average pay level of male
employees. This calculation is based solely on gender and
does not consider factors such as job roles, seniority, skills,
or other elements essential for ensuring equal pay for work
of the same or equal value.
The composition of job categories within the Company
primarily influences the gender pay equity. Certain roles
or functions tend to be predominantly occupied by either
male or female employees, which affects the average
pay levels across genders. Furthermore, remuneration
levels can vary between different job categories, driven
by the nature of the roles rather than by gender. Eleving
Group addresses pay equity through compensation
transparency and data-driven reviews. Managers have
access to clear remuneration frameworks, and annual
audits help ensure salaries align with roles, experience, and
market benchmarks - ensuring fairness and equity in pay
throughout the organization.
The Eleving Group pays all its employees an adequate
wage that is in line with industry benchmarks. Additionally,
during 2024, the Group's entity in Latvia received the
Equal Pay Award, issued by the remuneration research and
management consultancy company Figure Baltic Advisory.
This award recognized the Company’s commitment to
ensuring equal pay across all levels of the organization. This
acknowledgment reinforces the Company’s dedication to
fair compensation practices and workplace equity.
Gender pay gap 2024
Total:  25.25%
Remuneration ratio 2024
Total:  8.54
The annual total remuneration ratio compares the total
annual remuneration of the highest-paid individual to
the median annual total remuneration for all employees
(excluding the highest-paid individual).
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Secure employment
The Group offers its employees benefits to foster an
inclusive working environment. Among other things, Eleving
Group focuses on solutions that prevent working parents
from choosing between career and family. Eleving Group
provides working parents with a support package that
includes a room designated for children at the Company
office, flexible working hours, additional leave according
to the Company’s internal policies, and professional
childcare service once a year for three weeks in July at
the Company’s HQ. Eleving Group has also developed and
implemented a re-onboarding plan for colleagues returning
from parental leave. The plan aims to promote a smoother
return to the work environment, design an adapted work
schedule for the first month of return, and determine the
duties of direct managers during the reintegration process.
These efforts, along with the Group’s broader initiatives
to secure employment and support employee well-being,
contributed to the Company in Latvia being named a
Family-Friendly Workplace for the second consecutive time
in 2024. The Society Integration Foundation of Latvia runs
the Family-Friendly Workplace program, and its goal is
to promote a family-friendly work environment in Latvia
and to increase the public awareness. Involvement in the
Family-Friendly Workplace program motivates companies
to introduce new solutions to enhance the well-being
of working parents. In addition, the program provides
an excellent opportunity to draw inspiration from other
program participants and inspire change for those Latvian
companies that are still considering joining the program.
Incidents, complaints, and severe human rights
impacts
During the reporting period, Eleving Goup recorded no
work-related incidents of discrimination on the grounds
of gender, racial or ethnic origin, nationality, religious
belief, disability, age, sexual orientation, or other relevant
forms of discrimination involving internal and/or external
stakeholders across operations in the reporting period,
complaints, or severe human rights impacts within its
own workforce. No fines, sanctions, or compensation
were also issued concerning such matters. The Company
remains committed to maintaining a safe and fair working
environment, ensuring compliance with labor laws and
human rights standards.
Managing a diverse and skilled workforce is essential for
ensuring quality, innovation, and growth. To support this,
Eleving Group enforces its Equality, Inclusion, and Non-
Discrimination Policy across all companies, guided by the
following principles: 
  Equality—all humans are born equal. Therefore, equal
treatment of all individuals, regardless of ethnicity,
cultural background, sex, gender identity, sexual
orientation, religion, disability, age, or other factors, is
our overriding priority.
  Zero-tolerance against discrimination, harassment,
sexual harassment, and victimization.
  Respect for individual differences concerning ethnicity,
sex, gender identity, sexual orientation, culture,
religion, and other factors.
This policy applies to the Group's management, employees,
agency workers, contractors, business partners, and
suppliers. The policy applies to all work-related activities,
including but not limited to recruitment and selection,
conditions and benefits, training and promotion, task
allocation, shifts, hours, leave arrangements, workload,
equipment, as well as interpersonal relationships at work,
related situations such as travel, events, and after-work
gatherings. To ensure full compliance and adherence to the
policy throughout the Group, continuous work is being done
to raise employee awareness of diversity issues.
Incidents of discrimination 2024
Number of incidents of discrimination 0
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Governance
information
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Governance
Eleving Group strives for transparency, trust, and integrity.
This approach applies to all its business entities, markets,
customers, and business relations. The Group is committed
to initiating and maintaining collaboration across the
financial industry and promoting ethical behavior within the
business environment.
During the double materiality assessment, the Company
identified material impacts, risks, and opportunities related
to business conduct. This process considered various
criteria, such as high-risk job categories, geographic
location, and business activities, to ensure a comprehensive
understanding of where the most significant impacts may
arise.
The Company has implemented mechanisms to mitigate
potential risks, including publicly available compliance
policies for all stakeholders and regular training for
employees. To address any potential violations, the Group
has established robust grievance mechanisms, reinforcing
transparency and accountability across operations. The
table below outlines the key governance-related risks and
opportunities, along with their classification and activities
implemented to address them.
Policies
Eleving Group upholds the highest ethical standards in its
business practices, promoting a strong corporate culture
through ethical governance and employee engagement.
By fostering collaboration and accountability, it ensures its
values are integrated into daily operations and long-term
strategy.
Code of Business Conduct and Ethics
The Company has developed the Code of Business
Conduct and Ethics as a cornerstone of its commitment to
conducting business responsibly, with transparency and
respect for human rights, ensuring that its actions align
with the highest ethical standards. It aligns with the United
Nations Guiding Principles on Business and Human Rights,
the United Nations Global Compact, and the International
Labor Organization’s principles, reflecting the Company’s
commitment to these frameworks and standards.
The Code prohibits child and forced labor, discrimination,
ensures safe and healthy work conditions, and mandates
compliance with anti-corruption, anti-money laundering,
and regulatory requirements applicable in all jurisdictions
where Eleving Group operates.
The policy is published on Eleving Group's website and
internal systems, ensuring that it is accessible to all
stakeholders. It applies universally to all Eleving Group
entities, employees, and operations without exclusions
and covers all activities within the organization, extending
to interactions with clients, partners, suppliers, and other
stakeholders throughout the entire value chain, both
upstream and downstream. All new employees undergo
mandatory training to ensure its effective implementation
and adherence: and regular training programs are
conducted and tailored to specific roles and responsibilities,
reinforcing compliance and promoting ethical business
practices across the organization.
Material
impacts,
risks, and/or
opportunities
Classification
Value chain 
Time horizon
Description and interaction
with business model and/or strategy
Anti-Corruption
and Anti-Bribery
Implementation
of robust anti-
corruption  measures
Positive potential
impact on
Own operations in
Short-term
Eleving Group's implementation of robust anti-corruption
measures ensures compliance with international
standards. Comprehensive training programs helps to
equip employees to identify and mitigate risks proactively,
ensuring adherence to regulations and ethical standards.
Whistleblower
Protection
Protection of
whistleblowers and
promoting grievance
reporting tools
Positive potential
impact on
Own operations in
Medium-term
Eleving Group is committed to the highest standards of
ethics and integrity. To support this, the Company has
established an anonymous reporting system, FaceUp,
enabling employees and stakeholders to report concerns
safely. The Whistleblowing Policy encourages individuals
to speak up, promotes awareness of their rights, and
protects whistleblowers from retaliation or discrimination.
Governance
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Whistle-blowing policy, reporting system, and
protection of whistle-blowers
Eleving Group is committed to its business's highest
levels of ethics and integrity. To identify and investigate
concerns regarding potential unlawful behavior or actions
that contradict the Company’s Code of Business Conduct
and Ethics, Eleving Group has established the reporting
system FaceUp, an anonymous form to report concerns
about potential misconduct or improper and/or illegal
activity within or in relation to Eleving Group. This solution
allows sharing concerns regarding violations of the Group’s
policies, local laws, regulations, fraud, and corruption
without fear of negative consequences or retributions.
Eleving Group ensures that the reporting on actual and
potential conflicts of interest is confidential and that
reporting employees, clients, and suppliers are protected
from discrimination and retaliation. Additionally, employees
may submit their concerns directly to their local Human
Resources representative or the Group Human Resources
department.
The Whistle-blowing policy guides how Eleving Group will
support whistle-blowers so that they:  
  Are encouraged to express their concerns
  Know how to report their concerns
  Know their rights, including their right to remain
anonymous
  Know what will happen if they report their concerns
  Feel safe in reporting their concerns
  Will not be subject to retaliation, detriment, or
victimization in response to reporting their concerns.  
Anyone with evidence or suspicion that an Eleving Group
employee or business partner has violated the established
norms or that Eleving Group commits systematic procedural
violations can report it through the whistle-blowing system.
A dedicated Whistle-blower Report Coordinator monitors
the system 24 hours a day, seven days a week, and
handles reports in accordance with internally established
procedures. More detailed information is provided in the
section Prevention and Detection of Corruption and Bribery.
The Company remains committed to continuously
monitoring the effectiveness of the whistle-blowing system
to ensure that all reports are handled confidentially and
without any retaliation against the individuals who report
concerns.
Management of relationships
with suppliers
Eleving Group is committed to managing its relationships
with suppliers responsibly and transparently, ensuring that
its cooperation across the value chain—with entities such as
banks, local consumer credit agencies, IT service providers,
and debt collection agencies—contributes to a sustainable
and resilient supply chain. This includes mitigating potential
material risks and adverse impacts across its value chain
while fostering long-term responsible business practices.
Eleving Group has drawn up its internal procurement
guidelines in line with the Group’s strategic direction and
internal and external regulations. Employees must verify
suppliers against the economic sanctions list, conduct
due diligence checks including tax liabilities and overall
reputation, and research whether suppliers adhere to
the Code of Business Conduct and Ethics and maintain
responsible corporate practices.
Eleving Group follows the standard payment terms set by
each supplier. The Company recognizes the importance
of preventing delayed payments to small and medium-
sized enterprises and ensures fair payment terms and
practices. In 2024 the average payment period was 23
days, reflecting its commitment to timely payments and
supporting small and medium-sized partners. Additionally,
there are no outstanding legal proceedings related to late
payments.
Payment practices 2024
Average days for payment to suppliers 23
Percentage of payments aligned with
agreed terms
100%
Number of legal proceedings currently
outstanding for late payments
0
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Data protection and privacy
Eleving Group protects the privacy of its suppliers,
customers, employees, and partners and ensures
compliance with applicable personal data protection laws
and regulations. 326 862 active customers globally,
2793 employees, and almost 1800 dealerships have
entrusted Eleving Group with their personal data, and the
Group ensures that this information is processed securely
and follows applicable laws and regulations.
Data protection procedures are held to the highest
standard, even in countries where the legislation imposes
lower-level obligations. This approach includes full
alignment with the provisions of the EU General Data
Protection Regulation (GDPR). Eleving Group’s general
data protection counsel, local data protection officers,
and legal and IT teams ensure compliance with applicable
laws and regulations. All Eleving Group business entities
have adopted the same general privacy framework,
complemented by additional local requirements. Eleving
Group strives to achieve a unified approach and provide
high-quality technical and organizational security measures.
Eleving Group continuously reviews existing procedures and
educates its employees on applicable laws and regulations
about privacy, data protection, and other relevant matters
such as information security.
Privacy and data protection activities are coordinated by the
Group’s general data protection counsel, with the assistance
of local data protection officers, legal, risk, business
development, and IT teams. Such a governance model
ensures overreaching support and a common approach to
the Group’s privacy objectives and standards and addresses
the local legal requirements. In 2024, no data breaches
involving consumers or end-users were recorded.
Respect the
individual’s rights
to privacy
Process data
only for the
purposes it was
collected
Use minimum
amount of data
necessary
Provide honest
and transparent
information to the
individual
Ensure data
security, integrity
and confidentiality
at every step
Ensure legal
basis to process
personal data
Use only
accurate and
precise data
Retain personal
data for the
shortest time
possible
Retain personal
data for the
shortest time
possible
Eleving Group’s data processing principles
Security measures’
common approach
General privacy
framework
Improvement
audits
Staff education
& training
Privacy management
system “OneTrust”
Local data protection
officers
Legal team Risk officers Business development
experts
IT team
Eleving Group’s employees are bound by strict
confidentiality requirements and must not intentionally or
accidentally disclose sensitive information while performing
their work duties. The information is protected, regardless
of whether it belongs to Eleving Group or its stakeholders.
Employees are precluded from using confidential
information obtained during their employment in Eleving
Group for personal gain or the advancement of private
interests.
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Cybersecurity
Prevention and detection of
corruption and bribery
Cybersecurity is crucial for the Eleving Group as the
Company manages highly sensitive financial data, requiring
strict safeguards to uphold customer trust and meet
regulatory requirements. Robust cybersecurity measures
safeguard against unauthorized access and fraudulent
transactions and ensure business continuity by mitigating
the risks of cyberattacks. Protecting intellectual property
from theft or unauthorized access highlights the importance
of strong cybersecurity measures in maintaining the long-
term success of fintech companies.
To maintain the highest security standards, Eleving Group’s
Information Security department collaborates closely with
the Infrastructure and Development teams. They conduct
regular system scans and assessments to proactively
identify vulnerabilities before they can be exploited.
Additionally, the Company performs annual security
assessments, both internally and with external experts, to
enhance its resilience and overall security. During 2024, the
Eleving Group conducted annual mandatory cybersecurity
training for all employees. The training covered essential
areas such as phishing awareness, password security, data
protection, and threat detection. It educated employees
on the nature of cyberattacks, attackers' objectives, and
associated risks. Annually, the Information Security Team
organizes a phishing simulation test involving the Eleving
Group employees in all countries and subsidiaries and has
implemented advanced security monitoring and Security
Information and Event Management (SIEM) solutions.
They are continuously improved so that the Company can
respond promptly when an incident happens. Ongoing
enhancements to infrastructure and network safety sensors
further reinforce the Company’s cybersecurity framework.
As a result of these proactive measures, the number of
external incidents significantly declined. During 2024, 27
external incidents were reported, representing an almost
44% decrease compared to 2023.
To prevent, detect, investigate, and respond to allegations
or incidents relating to corruption and bribery, Eleving
Group has developed and adopted an Anti-corruption, Anti-
bribery, and Anti-fraud Policy. It aims to ensure a common
understanding of the problems arising from corruption
and fraud and their types, responsibilities, and action
models to prevent corrupt and fraudulent activities within
Eleving Group and in relations with external partners and
those involved in the political process. This policy applies
and is binding to all employees of Eleving Group and its
subsidiaries, regardless of their position. Eleving Group is
committed to complying with all applicable anti-bribery and
corruption laws and regulations in the jurisdictions in which
it operates, and it promotes transparency in lending, fair
business practices, and responsible partnerships. Eleving
Group has zero-tolerance against bribery, corruption,
and other activities that are unethical, unacceptable, and
inconsistent with the Group’s values. Eleving Group strives
to operate with transparency, trust, and integrity. This
approach applies to all its markets of operation and all
business relations. The sole purpose of the policy is to set
out the responsibilities of Eleving Group and its personnel
regarding zero-tolerance against bribery and corruption.
Reporting tool FaceUp is monitored and reviewed by the
Whistle-blower Report Coordinator, who:  
  Establishes independent and autonomous external
reporting channels for receiving and handling reports.
  Promptly, and in any event within seven days of
receipt of a Report, acknowledges that receipt of the
report, unless the reporting person explicitly requested
otherwise, or the competent authority reasonably
believes that acknowledging receipt of the report would
jeopardize the protection of the reporting person's
identity.
  Diligently follows up on the reports and investigates the
concerns set out in those reports.
  In well-justified cases, provides feedback to the
reporting person within a reasonable timeframe not
exceeding three or six months.
  Communicates to the reporting person.
  Notifies the person of the outcome of investigations
triggered by the report following the procedures
provided for under national law.
  Transmits in due time the information in the report to
competent institutions, bodies, offices, or agencies, as
appropriate, for further investigation, where provided
for under EU or applicable national law.
These mechanisms reflect Eleving Group's commitment to
maintaining ethical standards and proactively addressing
potential violations. Furthermore, to mitigate potential
fraudulent activities, Eleving Group is now prioritizing the
automation of specific decision-making processes and the
optimization of its fraud detection systems, including the
enhancement of security underwriting metrics.
In 2024, the Company received one whistle-blower report
concerning potential bribery through the whistle-blowing
tool FaceUp. A thorough field investigation discovered that
the employee did not breach any procedures and acted
transparently, and the claim was unsubstantiated.
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During the 2024, Eleving Group organized anti-fraud trainings for all employees, including at-risk employees, in Lithuania,
Latvia, Moldova, Romania, Estonia, Georgia, Kenya, and Uganda. Details of the training during the year are as follows:
Anti-money laundering, countering
terrorism and proliferation financing,
sanctions compliance
Eleving Group has approved and follows its Anti-
Money Laundering, Countering Terrorism Financing,
and Proliferation Financing (AML/ CTF/PF) Policy, which
formulates Eleving Group’s general principles and
methods to determine measures for the assessment
and management of money laundering, terrorism, and
proliferation financing and international sanctions risks
inherent in Eleving Group. The Group has developed
processes to mitigate those risks and to protect Eleving
Group’s customers and employees from money laundering,
terrorism, proliferation financing, and international
sanctions violation risks. The Group also pays close
attention to breaches of sanctions or other illegal activities.
Eleving Group and its subsidiaries do not deal with
sanctioned companies or individuals. Compliance with this
standard is strictly monitored.
Given that Eleving Group entities operate in multiple
jurisdictions, their policies and procedures are adjusted
to comply with the regulations of each jurisdiction where
the Group’s subsidiaries operate and consider not only
the specific local legal requirements but also product
nuances, Eleving Group’s AML/CTF/PF best practices,
and international recommendations and guidelines, thus
ensuring the highest level of AML/CTF/PF and global
sanctions compliance reasonably possible.
The country managers in each jurisdiction are responsible
for preventing money laundering and ensuring compliance.
AML team works closely with various internal departments
and committees, including the legal department and client
support, to achieve AML-related goals and adhere to
international and local legal requirements.
Along with the internal know-your-client (KYC) investigative
practices, Eleving Group uses a special information
technology solution that enhances compliance and
provides faster and more efficient AML checks. This
allows performing the required client due diligence and
KYC checks, monitoring and screening transactions,
and reporting suspicious transactions or sanctions
infringements. It enables the effective evaluation of the
potential risks associated with each client and ensures that
the Group adheres to the Group’s policies and standards.
To ensure full compliance with the AML legal requirements,
internal AML practices are reviewed and amended at least
once every 18 months according to globally consistent
policies, standards, and local legal requirements.
Furthermore, internal and external AML and sanctions
compliance audits are performed regularly, and in case
any findings and recommendations are received, those are
implemented in due course to ensure maximum compliance
with the applicable legal regulations.
Training coverage 2024
Total receiving training: Whole team in each country
Delivery method and duration:
Computer-based training  8+ hours
Classroom training 6+ hours
Frequency: On quarterly basis
Topics covered:
Definition of fraud/corruption/bribery
General policy
Procedures on suspicion cases detection
Skip tracing
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Insider trading
Customer experience
Eleving Group`s Policy on Preventing Insider Trading and
the laws of the countries in which it operates prohibit
trading in securities (shares, debt securities or bonds, and
stocks) while possessing material non-public information
regarding the issuer.
According to this policy, all the Group’s employees must
not engage or attempt to engage in insider trading or
circumvent that obligation by any means, which includes:  
  Improperly disclosing inside information or
recommending the third party to trade or cancel or
amend an order while in possession of inside information
(tipping off); 
or
  using such a recommendation as referred to above
where the employee knows or ought to know it is based
on inside information.
Furthermore, the Group’s general principle reiterates
that in case of any doubt, employees should treat non-
public information as inside information and consult with
management before engaging in any transaction. This
approach effectively ensures that employees do not enter
transactions that amount to or create the appearance of
market manipulation.
To enhance compliance with insider trading prevention
policies, the Group uses information technology services
that maintain an up-to-date list of persons who have access
to insider (price-sensitive) information and regularly inform
these persons about their duties and obligations under the
Group’s Policy on Preventing Insider Trading.
In addition to the above, all the Group’s employees must
adhere to specific information barriers to protect insider
(price-sensitive) information. This includes:  
  Prevent confidential information from being shared with
individuals not authorized to know such information.
  Restricting access to potentially material non-public
information to those persons who do not necessarily
need to see it to perform their work duties.
  Addressing actual or potential conflicts of interest
related to business activities.
Failure to comply with this policy may lead to sanctions
imposed by the Group, including dismissal for cause,
whether or not the failure to abide by this policy results in
an actual violation of the law.
The Group’s priority is to ensure a transparent and
convenient customer journey. Customer satisfaction and
operational excellence are essential for Eleving Group to
meet its customers’ needs. Eleving Group has developed
a customer service division, delivering highly efficient
customer support in local languages across all markets.
Eleving Group continuously works to improve customer
satisfaction by creating personal contact with its customers
through telephone calls, e-mails, and chats, among
others, to discuss product options, address customers’
questions, inform customers of their payment due dates
and encourage them to pay on time, discuss late payment
arrangements, and help customers with their applications.
In addition, the Group carefully monitors specific customer
service quality ratios, such as call waiting times and
abandoned calls. Customer service quality is one of the
reasons why customers return to Eleving Group for more
services. In Latvia, this was also reflected externally, as
during 2024 the Consumer Rights Protection Centre has
not received any consumer applications related to financial
services concerning the Company.
Debt collection
Eleving Group has established an efficient, effective, and
responsible debt collection process in each country it
operates. To ensure consistent quality of debt collection
operations across the Group, Eleving Group has developed
group-wide debt collection service standards that include
(i) debt collection principles, (ii) best practices and
requirements for the Debt Collection Departments, and (iii)
internal procedures for each country to ensure practical
knowledge sharing and continuous improvement of
operations.
Eleving Group’s debt collection team in each country utilizes
debt collection measures that comply with local regulations.
If the local regulations set standards lower than in other
countries where the Group operates, Eleving Group applies
the higher standard. Group ensures compliance with
applicable debt collection standards and regulations through
a multi-layered monitoring system, which includes internal
compliance audits, employee training and guidelines, a
whistle-blower mechanism, feedback channels, and risk
assessments with reporting.
Eleving Group’s strategy is focused on maximizing dialogue
with customers. Before the loan becomes overdue, the
Group has an automated reminder process that ensures
that the client is aware of the upcoming payment and
payment details.
On the first day when the payment is overdue, it enters
the early debt collection process, where Eleving Group
launches its automated reminder system (auto-calls,
texts, e-mails) informing the customer about the overdue
amount, further actions if the payment will not be made,
and the Group’s contacts to discuss further scenarios.
Eleving Group constantly monitors the effectiveness of its
automated system. In addition, the Group involves its in-
house debt collection officers who call all debtors according
to a predetermined schedule (as early as Day 1 in some
countries) to recover the payable amount, identify the
reason for the delay, and, if necessary, offer restructuring
possibilities where possible and economically viable. Before
pursuing further debt collection activities, Eleving Group
first aims to agree with a customer to find a solution for
loan repayment. If an agreement is not reached within 30
days, the case moves to the next debt collection stage.
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When Eleving Group ascertains that a customer can
repay their loan, it offers various scenarios and a tailored
repayment schedule. If the customer is unable to continue
fulfilling their contractual obligations, a quick and efficient
repossession of the collateral and subsequent sale of it
is pursued, maintaining complete transparency with the
customer about the process. In the case of unsecured
loans, legal collection or debt sale is initiated.
Eleving Group largely handles all debt collection and car
repossession activities in-house. The Group has gained
substantial expertise in debt collection strategies over the
years. In certain countries, Eleving Group outsources parts
of the debt collection activities to test and compare the
efficiency of internal versus external debt collection.
Eleving Group does not employ controversial debt collection
practices, such as using a continuous payment authority
or siphoning money from customers’ bank accounts. Such
methods are controversial and will or may become illegal
in certain jurisdictions. Due to this fact, and from the
customer relations and loyalty perspective, Eleving Group
firmly believes that its business model is more sustainable,
organic, and transparent.
Debt collection is improved through regular benchmarking,
experience sharing, and targeted projects supervised by the
Group’s operations team to develop best practices across
the Group.
Increasing financial literacy
Eleving Group is committed to fostering financial
literacy and supports various social initiatives that help
local communities, as part of its broader goal to build
a prosperous and sustainable society. In addition to
complying with all applicable local regulations, the Company
implements group-wide practices that strengthen customer
protection and support informed financial decision-making.
In 2022, Eleving Group launched www.smart.eleving.
com, a financial literacy platform designed to enable
customers to evaluate their current financial commitments,
assess the affordability of potential new obligations within
their existing budgets, and access practical guidance on
budgeting, debt management, saving, and overall financial
well-being.
As of 31 December 2024, the platform is available in
Latvia, Lithuania, Estonia, Romania, Moldova, Georgia,
Armenia, Albania, Kenya, and Uganda. Over 35,000 unique
consumers have taken the self-assessment in 2024,
with the vast majority from Tanzania, Latvia, and North
Macedonia. Since its launch, the platform has seen steady
growth in engagement, reaching over 80,000 users by the
end of 2024. In 2025, the platform will be further localized
for users in Uzbekistan, Botswana, Namibia, Zambia, and
Lesotho, supporting the Group’s ambitious target to educate
and positively impact at least 500,000 individuals across all
its markets by the end of the 2025.
In addition to providing an online financial literacy platform,
Eleving Group is committed to promoting financial education
more broadly and supports social initiatives that benefit
local communities. These efforts align with the broader
objective of fostering a more prosperous and sustainable
society. In 2024, Mogo Kenya delivered informative
sessions to vulnerable community groups supported by the
Kenyan non-profit organization Usikimye. These sessions
provided practical financial education, offering participants
the knowledge and tools needed work toward long-term
financial independence. The focus was on building financial
resilience, understanding savings and credit, and exploring
income-generating opportunities within the mobility sector
- empowering community members to pursue economic
stability with confidence. These efforts highlight the critical
role of community support and financial literacy in fostering
long-term self-reliance and inclusive economic growth.
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Profitability
  Eleving Group finished 2024 with the historically strongest
financial performance, recording revenues of EUR 216.6 mln, up
by nearly 15%, compared to the 2023 results.
  The Group maintained a diversified business operations
portfolio, generating a well-balanced revenue stream from all
core business lines:
 - Flexible and subscription-based products contributed EUR
48.0 mln to the revenues.
 - Traditional vehicle financing contributed EUR 73.1 mln to the
revenues.
 - Consumer lending products contributed EUR 95.5 mln to the
revenues.
  The Group’s adjusted EBITDA hit a twelve-month record high,
totaling EUR 89.8 mln, a noteworthy increase of over 16%
compared to the corresponding reporting period a year ago.
  The net portfolio over 2024 increased by EUR 50.9 mln and
reached EUR 371.2 mln at the end of Q4 2024, a rise by an
impressive 16% compared to the corresponding reporting
period a year ago.
  The net profit before FX and discontinued operations landed at
EUR 32.5 mln by the end of 2024, a notable increase of nearly
15% compared to the corresponding reporting period a year
ago.
  Total net profit reached EUR 29.6 mln, a substantial increase of
almost 21% compared to the corresponding reporting period a
year ago. Adjusted for one-off Romanian VAT liability for prior
years, total net profit stands at EUR 32.2 mln, reflecting more
than 31% growth year-over-year.
Growth
  Loan issuance volumes increased to EUR 368.6 mln, an
improvement of 26.8%, compared to the corresponding
reporting period a year ago (12M 2023: EUR 290.6 mln). The
main drivers have been the continuous increase in organic
demand for our products, successful loan product offering
strategy modifications in certain countries, and further
expansion of sales channels, with an increased focus on
digitalization and scalability.
  Loan portfolio reached a new record high of EUR 371.2 mln,
marking a cumulative growth rate of 25% over the last 8
years. The most significant portfolio growth occurred in Q4,
with an increase of EUR 25.0 mln. Growth was primarily driven
by Romania, Uganda, Albania, and the acquired Sub-Saharan
markets.
 - The vehicle finance business line sustained upward
momentum as loan applications over the year leaped by
80.9% compared to the 2023 figures. Significant customer
activity was generated by East Africa’s motorcycle and the
Romanian, Latvian, and Uzbek car financing segments.
 - The Group’s consumer finance business line reached a new
milestone of EUR 56.4 mln worth of loans issued in Q4 2024.
Loans issued in EUR terms grew by 43.7% in 2024 compared
to the previous year. The main growth drivers were Albania,
Namibia, and Zambia.
  During Q4 2024, Lesotho implemented a business activation
strategy, including updated product pricing. These changes led
to significant issuance growth beginning in December. 
Operational Milestones
  Eleving Group has finished the first stage of its digitalization
journey. Our new generation 2.0 digital solution (customer
self-service platform) has been implemented in all established
European vehicle finance markets, finishing with year-end
implementations in Latvia and the Caucasus. Piloted with
Romania at the start of the year, the self-service portal has
been continually updated, now offering a broad range of
services. Key benefits:
 - New records for repeated sales and new loan issuance
growth.
 - A double increase in subscription payment usage.
 - Improved collections, customer reach rates, and operational
efficiency.
  Eleving Group continues to invest in improving its underwriting
and customer risk evaluation processes. Portfolio quality
improvements on a year-on-year basis are evidenced by a
significant reduction of NPL rates in 2024—from 7.5% to 6.1%
for vehicle finance and from 4.5% to 4.3% for the consumer
finance business segment.
  Eleving Group is driving further green mobility in Africa, with
our East African motorcycle business firmly establishing itself
as the frontrunner in the e-motorcycle financing segment. This
year, we financed over 2,000 e-motorcycles, and our customers
commuted around 20 mln kilometers on pure electricity, with
an estimated 1,000 metric tonnes of CO2 saved during this year
alone.
  Eleving Group, in collaboration with Ibis Consulting ESG
advisors and Verdant Capital, a specialist investment bank, is
deploying an Environmental Social Management System across
its vast branch network in Kenya. This initiative will include
scaling up the waste management program, starting from
Nairobi headquarters to Kenyan branches.
Operational and Strategic Highlights
Sustained accelerated
growth backed by
successful IPO
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Sustained accelerated
growth backed by
successful IPO
  Consistent and healthy profitability as evidenced by the
strongest-ever yearly financial performance:
 - Adjusted EBITDA of EUR 89.8 mln (12M 2023: EUR 77.5 mln).   
 - The net profit before FX and discontinued operations of EUR
32.5 mln (12M 2023: EUR 28.3 mln).
 - Total net profit of EUR 29.6 mln (12M 2023: EUR 24.5 mln).
Adjusted for the Romanian VAT liability, total net profit
reached EUR 32.2 mln.
 - Total net loan and pre-owned vehicle rent portfolio of EUR
371.2 mln (31 December 2023: EUR 320.3 mln).
 - 2024 ended with an improved financial position, supported
by the capitalization ratio of 29.3% (31 December 2023:
26.1%), ICR ratio of 2.4 (31 December 2023: 2.3), and
net leverage of 3.3 (31 December 2023: 3.7), providing
sufficient headroom for Eurobond covenants.
  During Q4 2024, Eleving Group accomplished the largest initial
public offering (IPO) in Nasdaq Riga’s history. Immediate short-
term use of the proceeds was allocated to redeeming Eleving
Group’s subordinated bonds and selectively repaying higher-
cost Mintos outstanding loans. The remaining IPO proceeds
were allocated for organic growth, new product rollout, and new
market launches. The medium-term target remains to double
the business and maintain a consistent 50% annual dividend
rate.
  Eleving Group remains focused on its strategic direction to
further diversify its debt profile and funding through various
channels, primarily in local currencies, and optimizing funding
costs both in EUR and USD currencies: 
 - Investments raised through the Kenyan local notes program
increased by around 30%, from EUR 20.5 mln to EUR 26.7
mln during Q4 2024. Most of this funding is secured in the
local currency.
 - Throughout Q4 2024, the Group raised EUR 2.0 mln
in Botswana at favorable rates through the local notes
program. The outstanding total investment amount is around
EUR 8.1 mln. All of this funding is secured in the local
currency.
 - The Group continues using the Mintos platform, a
marketplace for loans. The weighted average annual funding
cost for Mintos was 10.1% over Q4 2024, in line with the
marketplace’s year-end seasonality trends. It represented
a considerable improvement, compared to the end of 2023
11.0% weighted average annual funding cost. At the end
of Q4 2024, Eleving Group had outstanding loans of EUR
60.5 mln on Mintos (compared to EUR 63.9 mln as of 31
December 2024), a reduction of EUR 3.4 mln.
  During Q4 2024, due to IPO equity raise proceeds and
continuous profitability, the Group increased its equity to EUR
108.2 mln (EUR 87.9 mln as of 30 September 2024), further
enhancing its capital base for future growth.
  On 16 December 2024, the Romanian Tax Authority concluded
a tax audit of Eleving Group’s Romania operations. Based
on the audit’s findings, an additional VAT liability of EUR 3.0
million (with an impact on the net profit of EUR 2.6 mln) was
determined for the years 2017-2022. The related penalties and
late payment interest under Romanian tax amnesty rules have
been waived. The Group strongly disagrees with the tax audit
assessment and has submitted a formal contestation to the
Romanian tax authorities.
Financial Highlights and Progress
Maintain existing market positions, with
a focus on growing portfolio across
all markets.
Roll out consumer loan products,
primarily focusing on customer retention
and upselling.
Launch a new market.
Maintain existing market positions, with 
a focus on car and motorcycle
financing products.
Further scale up electric motorcycle 
financing products.
Launch a new financing product across
existing Sub-Saharan markets.
Launch a new market.
Promote higher-ticket, lower-APR
products while preserving continued
organic growth in European markets.
Launch new financing products 
to meet a wider range of customer
demands in African markets.
Continue significant portfolio scaling
in African markets.
Products
and markets
Business outlook (2025)
Accelerating growth through market expansion
and product innovation
Governance and
sustainability
Development of the ESG strategy for
2026-2031.
Achieve carbon neutrality for HQ
operations and implement carbon
compensation exercises at the Group
level.
Implement a carbon emission
monitoring system aligned with ESRS
standards.
Further enhance internal audit
procedures and risk oversight.
Continue to be active in debt capital
markets by raising additional
financing to support business growth in
2025 and beyond.
Proactively address the Eurobonds
maturing in 2026 by having a concrete
refinancing plan in place.
Further improve the company’s credit
profile and place additional emphasis
on aspects necessary for credit rating
improvement.
Further diversify funding sources with
a focus on increasing local financing in
local markets, with the highest priority
the Africa region and the Caucasus.
Maintain a 50% dividend payout
ratio, with semi-annual payments.
Maintain the capitalization ratio at a
sufficient level of 25-30%.
Capital
management
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General information
Report overview 81
About the Group
81
Corporate governance
83
Sustainability matters addressed by the administrative,
management, and supervisory bodies
86
Incentive schemes and remuneration policies
86
Risk management and internal controls
87
Description of business model and value chain
89
Strategy and business model
89
Customer segments
90
Fostering responsible access to finance
93
Risk management
94
ESG framework
95
Interests and views of stakeholders
96
Description of the process to identify and assess
material impacts, risks, and opportunities
97
Material impacts, risks, and opportunities and their
interaction with strategy and business model
99
Social information 111
Own workforce
112
Material impacts, risks, opportunities
112
Policies
113
Employee engagement
114
Reporting system
114
Targets related to managing material negative impacts,
advancing positive impacts, and managing material
risks and opportunities
115
Action plans and resources to manage material impacts,
risks, and opportunities related to its own workforce
116
Characteristics of the employees
117
Diversity metrics
118
Employees' well-being
119
Health and safety
119
Remuneration policy
120
Secure employment
121
Incidents, complaints, and severe human rights impacts
121
Environmental information 102
Climate change
103
Transition plan for climate change mitigation
103
Climate-related risks
103
Material climate-related physical and transitional
impacts, risks and opportunities
104
Description of process in relation to impacts on climate
change
104
Policies
105
Targets related to climate change mitigation and
adaption
106
Actions and resources in relation to climate change
policies
107
Energy consumption and mix
108
GHG Emissions Assessment
108
GHG intensity based on net revenue
109
Governance information 122
Material impacts, risks, and opportunities related to
business conduct
123
Policies
123
Management of relationships with suppliers
124
Data protection and privacy
125
Cybersecurity
126
Prevention and detection of corruption and bribery
126
Anti-money laundering, countering terrorism and
proliferation financing, sanctions compliance
127
Insider trading
128
Customer experience
128
Increasing financial literacy
129
Information related to the previous reporting period is available on Eleving Group website under the Sustainability section.
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