Methodologies and assumptions (ESRS 2 IRO-1 par. 53c)
in 2024, Enexis Groep identified and assessed impacts, risks and opportunities materiality for the first time, in line with ESRS requirements. This approach is referred to as ‘double materiality’. It considers factors such as the value chain, relevant stakeholders, the context of activities, key business relationships and the geographical dimension, as explained above. This process did not result in any changes to the strategy. (ESRS 2 SBM-2 par. 45a en c)
The double materiality analysis determined, on the one hand, which sustainability topics Enexis Groep has a positive or negative impact on (‘impact materiality’). On the other hand, it determined which topics present a financial opportunity and/or risk (‘financial materiality’). A topic is considered ‘material’ if it is significant from either an impact and/or a financial perspective.
The following steps were used to identify the material sustainability topics for 2024:
Identification of sustainability topics (creation of a ‘long list’) based on the list of topics in the thematic ESRS (as outlined in TV16 of ESRS 1), supplemented by potential entity-specific topics derived from previous reports and peer disclosures.
Analysis of sustainability topics that are clearly irrelevant for Enexis Groep and their subsequent exclusion from the assessment (creation of a ‘medium list’).
Analysis of impacts, risks and opportunities per sustainability topic based on existing internal/external documentation and knowledge of internal experts, as well as an initial assessment of materiality.
Work sessions with internal experts in daily contact with key stakeholders. Aim: To refine the impacts, risks and opportunities and discuss the materiality assessment. This included the use of:
the climate risk analysis;
a study of the degree of circularity of components. The study is based on, among other things, the amount of raw materials in our components and the outflow of materials;
a risk scan (human and environmental) of the main value chain, based on OECD guidelines;
the TNFD sector guide ‘Electric utilities and power generators’;
Enexis’ SRA.
Interviews and follow-up talks with individual internal experts (after the work sessions).
Preparation of an overview of material sustainability topics and association impacts, risks and opportunities (‘shortlist’).
Validation of the ‘shortlist’ by the EB, after which the SB is informed of the outcomes.
Validation of the results by internal stakeholder representatives.
Enexis Groep uses quantitative and qualitative thresholds to determine which impacts, risks and opportunities are material and which sustainability topics to report. All impacts, risks and opportunities are scored as ‘gross’ and considered material if the score exceeds the impact or financial materiality threshold.(ESRS 2 IRO-1 par. 53a) (ESRS 2 IRO-1 par. 53b)The applied model was developed with the Risk Management department. It scores all negative impacts on a five-point scale. Positive impacts have two variables (scale and scope) in addition to likelihood, so the maximum score for positive impacts is 10. Negative impacts also consider irreversibility, resulting in a maximum score of 15. To ensure a balanced report (based on prudence), the threshold for materiality is set at ≥ 8 for both types of impacts. This means that all negative impacts with a score of ‘medium’ and all positive impacts with a score of ‘high’ are considered ‘material’. We have followed the existing SRA methodology with a three-point scale for financial materiality.(ESRS 2 SBM-3 par. 46 en 48h) The results therefore fall between 0 and 3. This means that if the threshold is set at ≥ 1.5, all topics with a ‘high’ score are considered ‘material’.
Decision-making process and internal control procedures
At the request of the EB, the External Reporting department coordinated the 2024 double materiality process. Key decisions included identifying stakeholders, scoring impacts, risks and opportunities, and determining material sustainability topics and associated disclosure requirements. The CSRD Steering Committee made these decisions based on a detailed internal record of deliberations and supporting documentation. The results were discussed and validated with the EB. (ESRS 2 IRO-1 par. 53d)
Integration into processes
The identification, assessment and management of impacts and risks arising from the double materiality analysis have not yet been formally integrated into the risk management process; this is scheduled for 2025. See the note under ‘Risk management and internal control for the sustainability statement’ for more information on how Enexis Groep has designed its risk management. (ESRS 2 IRO-1 par. 53e)
The same applies to the risk management process for integration into the overall management process: the identification, assessment and management of opportunities arising from the double materiality analysis have not yet been formally integrated into the overall management system; this is also scheduled for 2025. However, the opportunities identified in this report are already included. This means that they are reported to the EB and SB regularly. (ESRS 2 IRO-1 par. 53f)
Input parameters
Enexis used various sources in the study, as summarised above under methodologies and assumptions, and has taken into account all of Enexis’ activities.
Enexis relied primarily on existing internal data (reports, figures), supplemented by internal experts with knowledge of the current situation to identify and assess the impacts, opportunities and risks. This included support from various departments, including Strategy, Internal Audit & Risk and Business Control. (ESRS 2 IRO-1 par. 53g)
Changes from previous reporting periods
In 2024, Enexis conducted its first double materiality analysis conform ESRS. Previous materiality analyses were based on the Global Reporting Initiative (GRI) standards and focused mainly on impact materiality. The double materiality analysis will be reviewed periodically and published in the sustainability statement. (ESRS 2 IRO-1 par. 53h)(ESRS 2 SBM-3 par. 46 en 48g)
Material impacts, risks and opportunities
In the figure below, the ESRS topics identified as material for Enexis are positioned in the quadrants
belonging to Impact material, Dual material and Financial material. The corresponding notes below the figure detail for each category which ESRS (sub)subject it concerns and whether it concerns an impact, opportunity or risk. (ESRS 2 SBM-3 par. 46 en 48a)
Entity-specific impacts, risks and opportunities
In addition to the material topics directly linked to the ESRS, Enexis has identified several entity-specific topics. These entity-specific topics are listed below, with a reference to their respective locations in the report.
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Entity specific material impacts, risks and opportunities |
Classified as |
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Transition infrastructure |
Environmental information (ESRS E1) |
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Attracting talent |
Social information (ESRS S1) |
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Public health and safety |
Social information (ESRS S3) |
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Data security |
Governance information (ESRS G1) |
The material IROs summarised in the tables below relate to Enexis’ strategy and business model. (ESRS 2 SBM-3 par. 48c(iii) (ESRS 2 SBM-3 par. 48c(iv) In the remaining sections of the sustainability statements, the IROs are further explained, including the financial implications.(ESRS 2 SBM-3 par. 48c(i) (ESRS 2 SBM-3 par. 48c(ii) (ESRS 2 SBM-3 par. 48e)
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Environmental |
Impact, risk or opportunity |
Value chain |
Time frame |
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Material topic |
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Climate change adaptation |
Potential negative impact: Flooding and/or extreme rainfall can disrupt the supply of materials needed for investments and grid expansion, cause equipment failure or damage, and lead to delays or interruptions in energy supply to customers. |
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Potential risk: Flooding and/or extreme rainfall can cause damage to above-ground assets (particularly pipes, cables and transformer stations). This may result in higher operating costs, the deployment of emergency response services and/or potential reputational damage. |
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Climate change mitigation |
Actual negative impact: GHG emissions from gas leakages, grid losses and emissions from value chain components and internal operations have a negative impact on climate and biodiversity. |
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Potential risk: Reducing GHG emissions requires investment in measures that put pressure on achieving the ‘affordable |
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Potential opportunity: Reducing GHG emissions could have a positive impact on attracting financing by demonstrating environmental responsibility. |
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Energy |
Actual negative impact: Grid losses are associated with greenhouse gas emissions. |
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Actual positive impact: Expanding the electricity grid helps improve the energy mix, resulting in lower GHG emissions. |
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Actual positive impact: The transition from fossil fuels to sustainably generated electricity requires grid expansion as well as alternatives such as district heating. |
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Actual risk: The inability to meet the growing demand for green energy transmission and the expansion of the electricity grid could result in the loss of investors and/or access to capital. |
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Climate change |
Actual negative impact: Accelerating the replacement of infrastructure leads to higher costs and increased waste for society in the short term. |
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Potential negative impact: Delays in upgrading or reinforcing infrastructure could have a negative impact on the pace of the energy transition and the achievement of Europe's climate change targets. |
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Potential positive impact: Expanding and reinforcing the electricity grid enables the phasing out of fossil fuels, contributing to the sustainability of the Netherlands. |
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Environmental |
Impact, risk or opportunity |
Value chain |
Time frame |
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Material topic |
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Circular economy |
Actual negative impact: Enexis procures resource-intensive components, resulting in a significant raw material footprint and potential environmental impacts within the upstream value chain. |
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Circular economy |
Actual negative impact: Waste of materials leads to the unnecessary loss of resources, downcycling and the generation of waste that must be transported and processed. This results in avoidable greenhouse gas emissions and potential other environmental damage. |
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Actual opportunity: Reusing materials reduces the cost of purchasing new materials (avoided procurement costs) and extends the life of previous investments. |
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Social |
Impact, risk or opportunity |
Value chain |
Time frame |
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Material topic |
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Working conditions |
Actual negative impact: Safety incidents can lead to serious or fatal accidents among employees. |
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Working conditions |
Potential risk: A significant shortage of technically skilled employees threatens the ability to cope with an increasing large work package as a result of the energy transition. |
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Equal treatment and opportunities for all |
Actual positive impact: In order to maintain the quality of work, Enexis offers training programmes to all its employees. These programmes increase the knowledge and skills of employees for current and future tasks and improve their position on the labour market. |
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Equal treatment and opportunities for all |
Actual positive impact: Enexis does not discriminate on the basis of gender, sexual orientation or origin and works to create a socially safe working environment. Through the 'An Enexis for everyone' programme, Enexis promotes diversity and inclusion and creates equal opportunities for all. This includes promoting access for different groups, such as refugees with residence status. This approach creates a culture where everyone's contribution counts, where employees can be themselves and where their efforts are valued. |
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Social |
Impact, risk or opportunity |
Value chain |
Time frame |
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Material topic |
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Working conditions |
Potential negative impact: Lack of safety measures and/or awareness could lead to health risks and absenteeism among supply chain workers. |
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Working conditions |
Potential negative impact: A lack of safety measures and/or awareness among contractors could lead to health risks and absenteeism among contractor employees. |
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Social |
Impact, risk or opportunity |
Value chain |
Time frame |
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Material topic |
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Communities' economic, social and cultural rights |
Potential negative impacts: The business activities of Enexis or its subcontractors could lead to harmful and/or dangerous situations that affect public health and safety. |
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Social |
Impact, risk or opportunity |
Value chain |
Time frame |
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Material topic |
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Information-related impacts for consumers and/or end-users |
Access to the grid |
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Social inclusion for consumers and end-users |
Reliability |
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Affordability |
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Access to the grid |
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Access to the grid |
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Reliability |
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Governance |
Impact, risk or opportunity |
Value chain |
Time frame |
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Material topic |
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Management of relationships with suppliers, incl. payment practices |
Actual positive impact: To support the financial stability of its suppliers, including small and medium-sized enterprises, Enexis has a policy of paying for delivered goods and services within 30 days. |
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Corruption and bribery |
Potential negative impact: Bribery of employees (e.g. by criminal organisations or in procurement processes) undermines public confidence in Enexis' independent position. |
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Potential negative impact: Internal pressure on employees to prioritise customers on waiting lists, followed by external pressure/bribery/conflicts of interest, has negative consequences for employees as well as for society's loss of trust in Enexis' independent position. |
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Potential risk: Bribery may result in limited access to financial resources from investors due to reputational damage. |
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Political engagement and lobbying activities |
Potential positive impact: Enexis works to achieve societal goals and needs the right (legal) resources to do so. By influencing new policies, laws and regulations at an early stage, Enexis can ensure that they fit well with the practical needs of a grid operator. In this way, we ensure that social value is optimised. |
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Potential risk: Due to the political-administrative climate with many changing majorities, policy changes or amendments to laws and regulations may be delayed or change direction. As grid operators have to plan their investments well in advance, policy changes/laws and regulations may be delayed or become inappropriate. In the latter case, there is a potential risk of impairment. |
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Potential opportunity: A strong and continuous dialogue with policymakers and stakeholders is essential. The better Enexis aligns laws and policies with the practical needs of a grid operator, the more effectively it can fulfil its role - to develop, manage and maintain energy infrastructure efficiently and at the lowest cost to society. |
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Data security |
Potential negative impact: As a result of inadequate information security, unauthorised persons could gain access to Enexis' systems and customer and employee data, resulting in negative consequences for Enexis, its employees and customers due to misuse of systems and data. |
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Potential negative impact: Inadequate information security could allow unauthorised persons to access the energy infrastructure and potentially disrupt or damage it. This could result in temporary loss of data and/or energy for Enexis and its customers. |
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Potential risk: Unauthorised system access and data breaches could result in high ransomware costs, fines from authorities, customer claims for damages and reputational damage, which could hinder access to capital markets. |
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Application of ESRS disclosure requirements in this report
The reference table and list of data points resulting from other EU legislation are included in the appendix ‘Additional information’. (ESRS 2 IRO-2 par. 54 en 56)
For each disclosure requirement, consideration has been given to the information relevant to the topic and the related material impacts, risks or opportunities. At the same time, the information needs of the most important stakeholders have been taken into account so that they can have a good idea of Enexis’ impact and, if necessary, take this information into account in their decision-making. Departments within Enexis that are in (daily) contact with stakeholders provided input. This included looking at external reports from recent years and giving feedback on them. No direct input from stakeholders was sought. (ESRS 2 IRO-2 par. 59)
This first report only covers the mandatory ‘shall disclose’ ESRS provisions, with the exception of the voluntary ‘may disclose’ reporting items, which Enexis has also reported on in previous reports.
The minimum reporting requirements (MDR) for policies (MDR-P), actions and resources (MDR-A), metrics (MDR-M) and targets (MDR-T) are detailed for the material sustainability topics in the relevant chapters of the sustainability statements. They are specifically mentioned in the reference table as part of the Additional information.
Unless explicitly stated otherwise, the results included in the sustainability statement have not been validated by any external body other than the assurance provider.