Dialog Axiata PLC: Telecommunications Sustainability Profile

From FY2025, Sri Lanka’s largest listed companies are no longer choosing whether to report on sustainability the way the country’s new standards require — they are required to. Dialog Axiata PLC sits squarely inside that first mandatory cohort. The question this profile answers is not whether Dialog discloses, but how completely, how credibly, and with what candour — and whether its reporting meets the standard it is now bound by.

On the substance, Dialog’s 2025 integrated report is one of the more complete on the exchange: a paragraph-level SLFRS S1 and S2 content index, external limited assurance, and quantified emissions across all three scopes. On the claim it makes about its own compliance, it is more careful — and that gap between substance and claim is the story.

Dialog Axiata PLC is Sri Lanka’s largest telecommunications group and a subsidiary of Axiata Group Berhad of Malaysia. In FY2025, it served a subscriber base of 22.3 million (up 2.5%), grew group revenue by 4.9%, and reported company (mobile) revenue of Rs. 135.8 billion — roughly 76% of group revenue. Normalised group net profit after tax was about Rs. 22.1 billion, and the group remitted Rs. 54.7 billion to state revenues. Its infrastructure footprint — 5,509 network sites, some 6,872 km of fibre, and 1,067 solar-powered sites — is both the source of its emissions profile and the lever for reducing it. By market capitalisation, it ranks among the top five listed companies on the Colombo Stock Exchange, which is what places it in the first SLFRS S1/S2 cohort.

This is the core of the profile, and where Dialog is strongest and most nuanced. The report is built against an unusually broad set of recognised frameworks: the GRI Standards, SLFRS S1 and S2, SASB, the GSMA Sustainability Standards, the TNFD (at its “Locate” phase), the Integrated Reporting <IR> Framework, and the UN SDGs. Crucially, it carries a full paragraph-to-page content index for SLFRS S1 and S2 — mapping governance (pp.171–174), strategy (pp.185–192), risk management (pp.175–192) and metrics and targets (pp.302–306) to specific disclosures. That index is not decorative; it is the architecture of a company reporting to the standard, not gesturing at it.

Two words carry the assessment. Dialog states it has reported “in accordance with” the GRI Standards (Statement of Use, p.291) — GRI’s higher, full-adoption tier. But every reference to the new national standards — in the basis of preparation and in the independent assurance conclusion — is framed “with reference to” SLFRS S1 and S2 (pp.311–312). There is no unreserved statement of compliance with SLFRS S1 anywhere in the report.

Under SLFRS S1, a full-adoption reporter makes an explicit, unreserved statement of compliance. “With reference to” is the qualifier that signals partial application — the same phrasing used to bundle a mixed set of frameworks under a single limited-assurance conclusion. That is a legitimate way to report in a phase-in year. But it means readers cannot yet treat Dialog’s sustainability statements as a full-compliance baseline, and it is the first thing a regulator or an investor comparing across years should note. Materiality is described and guided by SLFRS S1 and GRI 3: Material Topics 2021; the report does not evidence independent facilitation of that process.

Assurance is a genuine strength — and a bounded one. Deloitte Partners Sri Lanka provided limited assurance under SLSAE 3000 over selected sustainability disclosures (pp.311–312). Limited assurance is materially less rigorous than reasonable assurance, and the engagement explicitly excludes forward-looking and prospective information, which is precisely where the net-zero targets sit.

Dialog quantifies emissions across all three scopes on the GSMA basis (2025): Scope 1 of 3,680 tCO₂e, down 46% year-on-year; Scope 2 of 111,066 tCO₂e, up about 5%; and Scope 3 of 17,113 tCO₂e, up about 5%. Disclosing Scope 3 at all puts Dialog ahead of many listed issuers; the limitation is that the report does not enumerate which Scope 3 categories are captured, so the completeness of value-chain coverage cannot be independently assessed. (A minor inconsistency exists between the narrative emissions figures and the assured content-index figures; the assured index values are used here.)

On the transition, renewable energy reached 6,090 MWh, lifting the renewable contribution to operations to 2.45% (from a prior “N/A”), supported by 1,067 solar-powered network sites. Water consumption was 46,400 m³, and the group runs an e-waste programme. The headline target is a Board-approved Net Zero ambition by 2050, built on a 2022 base year and aligned to the Axiata group’s SBTi-approved targets, with interim milestones through 2030 — a dated, science-aligned target rather than an open-ended aspiration. Note that the assurance does not extend to these forward-looking figures.

Dialog reports a workforce of 2,865 (2025) and mandatory anti-bribery and corruption training coverage across active employees. Turnover is disclosed at a granular level, including 14 terminations during the year (seven male, seven female) — the kind of specificity that marks fuller social disclosure. Community investment was Rs. 446 million in 2025, a marked increase from the Rs. 100 million and Rs. 127 million of the two prior years, reflecting cyclone-response and digital-inclusion activity during the year. The company does not state a fixed percentage-of-profit CSR commitment; the disclosure is of absolute spend. Workforce diversity and health-and-safety data are disclosed within the report’s people and GRI sections; where specific figures are not broken out, that absence is itself the finding rather than a gap to be filled by estimate.

As at 31 December 2025, the Board comprised nine directors: eight non-executive and one executive (the Group CEO). The company states three are independent non-executive directors — a board that is one-third independent — and that the composition complies with the CSE Listing Rules. (The report also states six non-independent non-executive directors; that figure, added to the three independent, implies nine non-executives against a stated eight, so its board sub-totals do not fully reconcile — a small data-quality point in the disclosure itself, not in the headline independence ratio.) The predominance of non-independent seats reflects Dialog’s status as a subsidiary of a controlling parent; it is a well-disclosed structural feature, not a hidden one. Sustainability governance is anchored in the Board Charter, under which the Board retains overall accountability for sustainability-related risks and opportunities, with the Board Risk and Compliance Committee reviewing them quarterly and escalating to the Board (pp.155–156). Supporting policies on anti-bribery and corruption, whistle-blowing and corporate disclosures are in place.

ESGNexus grades disclosure completeness against a published, equal-weighted, page-referenced checklist of seven criteria drawn from SLFRS S1 and S2 (Disclosure Grading Methodology v1.0). We assess what the report does and does not disclose — not the company’s underlying performance. Each criterion is marked Present, Partial or Absent (or N/A where it genuinely does not apply); the score is elements present divided by applicable elements, mapped to a band. The full checklist below is reproducible: the same report and this rubric should yield the same result.

Alongside the checklist, we characterise the disclosure on four qualitative dimensions — completeness, comparability, credibility and candour — each rated against cited evidence. These carry the nuances the checklist score does not, including the qualified compliance basis.

Where it leads: substantive participation in the mandatory regime, not a token gesture; external limited assurance; complete Scope 1–3 reporting; a dated, SBTi-aligned Net Zero target; early TNFD adoption; full “in accordance with” GRI reporting; and structured board-level oversight through a committee that reviews sustainability risks quarterly.

Where it lags: the central limitation is that SLFRS S1 and S2 are applied “with reference to” rather than through an unreserved statement of compliance, despite Dialog being in the mandatory cohort. Beyond that, Scope 3 is disclosed, but its categories are not enumerated; a minor inconsistency exists between the narrative and assured emissions figures; the independence of the materiality process is not evidenced; and the assurance is limited rather than reasonable and excludes the forward-looking targets. None of these is a failure of transparency so much as the distance still to travel from strong disclosure to asserted full compliance.