S2 Workers in the value chain

To carry out our core tasks, we use the expertise and capacity of contractors and install components in the network. Enexis aims to comply with international human rights and labour standards. As a result of the energy transition, employees in our value chain may experience increased work pressure. This can lead to unsafe situations and health problems. Enexis aims to manage these risks and opportunities through targeted measures and cooperation in the sector.^{(ESRS S2 par. 9)}

In this report, we report on two value chains: first, the supplier chain, which includes workers of companies from which we buy components for our electricity and gas grid, such as cables, gas pipes and transformers. And second, the contractor chain, which includes the people we work with to build and maintain our grid. Currently, we have limited insight into the other value chains. In the coming years, we plan to map these additional chains (for example, other components, equipment and services). Where relevant, we will include them in future reports. ^{(ESRS S2 SBM 3 par. 11)}

Our relationship with the two groups of workers is not identical. In the supply chain, we do not work directly with employees. In the contractor chain, however, there is close cooperation as Enexis employees and contractor employees carry out the same type of work. As far as health and safety are concerned, the interests and risks are the same. ^{(ESRS S2 SBM 3 par. 11)}

 For workers of suppliers and contractors, we see the following negative impact:

Social	Impact, risk or opportunity	Value chain	Time frame
Material topic
Working conditions Health and safety (components)	Potential negative impact: Lack of safety measures and/or awareness could lead to health risks and absenteeism among supply chain workers.
Working conditions Health and safety (contractors)	Potential negative impact: A lack of safety measures and/or awareness among contractors could lead to health risks and absenteeism among contractor employees.

Energy transition creates heavier workload

Due to the energy transition, our work package is growing, and we are forced to rely on the (timely) delivery of components and the use of contractors. We believe this is creating a heavier workload for our partners. This can lead to unsafe working conditions and stress-related health problems. This observation has not led to any changes in our strategy and business model, but it has led us to take action (see below). ^{(ESRS S2 par. 10)}

We currently do not have sufficient understanding whether workers across the value chain are at risk of harm. We have carried out a study using industry data under the guidance of a specialist consultancy. This study found that the extraction of raw materials such as copper and aluminium carries a risk of negative impacts on workers, including human rights violations (including child, forced and bonded labour). ^{(ESRS S2 par. 11/12}  We continue to monitor the potential effects and dependencies as part of our risk management and (sustainability) strategy. This is necessary in the context of responsible business and sustainable value creation. ^{(ESRS S2 par. 13)}

Working on health and safety

Our policy

Our socially responsible procurement (SRP) policy addresses the health and safety of workers in the supply chain (see G1-2 for further explanation). This policy forms the basis for European tenders, and monitoring and discussing developments in this area is part of the work of contract managers at Enexis. ^{(ESRS 2 par. 65a, b & c en ESRS S2-1 par. 14)}All stakeholders have access to our SRP policy via our website; suppliers and partners are essential for the implementation of this policy. ^{(ESRS 2 par. 65 f)}

In addition to the SRP policy, we have a code of conduct for suppliers. This code is incorporated into the general purchasing conditions or, when the purchasing conditions do not apply (for example, with European Tenders), it is provided as a separate document. In the latter case, the supplier must agree to its application.^{(ESRS S2-1 par. 16)} The code of conduct includes provisions for respecting human rights and labour rights. It requires suppliers to ensure that working conditions comply with all (supra)national laws, regulations and applicable collective labour agreements (CLAs). ^{(ESRS S2-1 par. 14, 16 en 17)} The code specifically addresses child labour but does not explicitly address human trafficking, forced labour or compulsory labour. In preparation for the implementation of the Corporate Sustainability Due Diligence Directive (CSDDD), we will amend the code of conduct accordingly in 2025. ^{(ESRS S2-1 par. 18 )} No cases of non-compliance with the code of conduct were reported in 2024. ^{(ESRS 2 par. 65a en S2-1  par. 19)}

We support the United Nations’ Universal Declaration of Human Rights and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work. Both the SRP policy and the code of conduct cover workers in the value chain and include elements consistent with the UN Guiding Principles on Human Rights and Business, the ILO Declaration and the OECD Guidelines for Multinational Enterprises.^{(ESRS 2 par. 65d & e)}

Consultation and interaction

We recognise the importance of consulting with workers in our value chain about the impact of our operations, but we do not currently have direct contact in this regard. ^{(ESRS S2-2 par. 20, 22a, 22b en 22e, 24).}We do interact in the following cases, however:

• Tendering processes with (potential) suppliers.

• Drafting new contracts and contract renewals (occasional, on average every 4-8 years). The focus during these discussions may include safety and working conditions.

• Regular structural consultations (ongoing). These operational and strategic discussions may also address safety and working conditions.

• Regular evaluations (periodic), such as reviews and discussions focused on compliance with contractual agreements and safety standards.

• Safety incidents (occasional). This involves communication with the relevant parties, with a focus on incident analysis and preventive measures. ^{(ESRS S2-2 par. 20 en 22b)}

Within our organisation, operational responsibility for carrying out these consultations lies with contract management for contractors, while Supply Chain Management, Asset Management and Procurement collectively manage them for grid components. ^{(ESRS S2-2 par. 22c)}

We do not yet have an overall formalised process for consulting with workers in the value chain and gaining specific insight into vulnerable workers. As part of the CSDDD, we aim to develop a method to assess and improve the effectiveness of interactions. ^{(ESRS S2-2 par. 23 en 24)}

Remediation processes

Our HSEQ department is informed about incidents and accidents involving employees of contractors and is involved in their resolution. Joint investigations are sometimes carried out. These processes are integrated into contract management discussions and our primary operations. HSEQ works with the contractor to address the situation, provide remediation and take measures to prevent recurrence. We regularly analyse (trends in) contractor incidents to ensure the effectiveness of these processes. We do not have specific remediation processes for employees of grid component suppliers beyond regular structural discussions with suppliers. This is expected to change with the introduction and further implementation of the CSDDD. ^{(ESRS S2-3 par. 25 en 27a - d).} 

We do not currently have a dedicated complaints channel for supply chain workers. They can use our general complaint form on the website, but no one has done so to date. If a complaint is received, it will be forwarded to the Procurement department. In addition to the complaints channel, contractors’ workers can voice their concerns or needs during daily interactions, such as workplace visits. ^{(ESRS S2-3 par. 28 en 29)} We do not currently evaluate whether workers in the supply chain are aware of or trust the structures and processes to express their concerns or needs. Establishing a grievance remediation mechanism for supply chain workers will be part of implementing the CSDDD. ^{(ESRS S2-3 par. 27b/c en 29)}

For safety incidents involving employees of contractors, we have put in place specific measures (see below) to report such incidents. We also have a whistleblower scheme, and the Whistleblower Protection Act applies in the Netherlands. ^{ESRS S2-3 par. 28}

Our measures

As part of continuous improvement, we consider what measures are necessary and appropriate when there is a negative impact on employees in the value chain. Measures will depend on the severity of the effect. ^{(ESRS S2-4 par. 30, 32 en 33)} For employees of component suppliers, there are currently no measures in place to prevent adverse impacts other than general health and safety requirements. ^{(ESRS S2-4 par. 30 en 32, ESRS 2 MDR-A 62)} The situation is different for contractors' employees, including subcontractors, temporary workers, and self-employed workers. For them, we take measures based on safety provisions in laws and regulations, collective labour agreements and industry codes of practice. Examples of measures:

• Before hiring a contractor, we check their safety certification. Without this certification, we do not commission any work. We also process the expiry date in our systems. When a certificate expires, we are notified and contact the contractor.

• We only work with contractors who are at least level 3 on the safety ladder. This tool promotes safety awareness and measures conscious, safe behaviour in organisations.

• We promote voltage-free and gas-free working to reduce safety risks.

• We continuously analyse the risk of unsafe situations in the electricity and gas grid. We have a maintenance and replacement policy to minimise the risk of hazardous situations for contractor (and other) workers.

Safety has been a key issue in the sector for many years. Therefore, we have the necessary capacity in place (in the form of our HSEQ department) and do not expect to require significant investment in capacity expansion or collaboration with other parties in the short to medium term. Necessary measures to ensure or facilitate remediation will be taken on a case-by-case basis, depending on the severity of the incident. ^{(ESRS S2-4 par. 30 en 32b)}Across the sector, we take initiatives in the areas of health, workload and ergonomics. ^{(ESRS S2-4 par. 33 en 38)}

Our targets

Every accident is one too many, and that includes our contractors. ^(80e)We measure the effectiveness of our safety measures for our own employees (see S1) and those of our contractors and other business partners by the number of serious incidents, the number of lost time accidents and the Lost Time Injury Frequency (LTIF). The methodology is the same in both cases. The LTIF reflects the number of incidents resulting in absence (at least 24 hours of complete absence, excluding fatal accidents while commuting) per million hours worked. HSEQ analyses all safety reports and reports to the EB. The SB also discusses the reports regularly. ^{(ESRS 2 MDR-T 75a – 80d). ESRS 2 MDR M 75 / 77 a-b / ESRS 2 par. 68e en ESRS S2-4 par. 30 en 32d)}

We compare our performance with that of other similar companies. Reported accidents and SAVE reports (near misses) are always investigated to identify lessons or improvements for ourselves and the contractor. ^{(ESRS S2-5 par. 42).} Despite all measures, accidents can never be prevented entirely. Therefore, we have not formally set a target for the number of (fatal) accidents.

In practice, the target is always zero accidents, and the number of incidents and near-miss reports are tracked daily. Our LTIF target for contractors is <2^(80c), which is less than two lost time incidents per one million hours worked^(80b). We set this target independently, without consulting contractors. ^(80f) We did not meet our target by 2024. Our focus on safety will continue unabated in the coming years.