Double materiality analysis and impacts, risks, and opportunities

In 2024, Enexis identified, assessed, and categorised impacts, risks, and opportunities (hereafter referred to as IROs), 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, among other factors. ^{(ESRS 2 SBM-2 par. 45a en c)}

The CSRD requires a double materiality analysis (DMA) to be carried out periodically. Enexis has chosen to perform a comprehensive DMA every two years, with a validation of the identified IROs in the intervening year. Following the initial DMA in 2024, the next full DMA is scheduled for 2026. ^{(ESRS 2 IRO-1 par. 53h)} For the 2025 financial year, Enexis therefore carried out a validation of the 2024 DMA to assess its continued relevance and adequacy. This validation confirmed that the 2024 DMA remains fully applicable for 2025, with no additions to or changes in the material sustainability topics compared with the previous year. The validation process for 2025 comprised several elements, including peer benchmarking, a trigger analysis, and validation by the CSRD Steering Group and the EB. ^{(ESRS 2 SBM-3 par. 46 en 48g)}

The peer benchmarking exercise revealed only minimal differences between Enexis’ DMA outcomes and those of other grid operators. The trigger analysis assessed whether there had been any significant changes in areas such as the business model, strategic processes, organisational structure, or broader social developments. This analysis concluded that no such changes had occurred that would affect Enexis’ material sustainability topics. Validation by the CSRD steering group likewise indicated that no adjustments were required for 2025. The validation and its conclusions were subsequently approved by the EB.

Methodology for DMA and IROs

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 Enexis 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 Taskforce on Nature-related Financial Disclosures (TNFD) sector guide ‘Electric utilities and power generators’;

  • Enexis’ SRA, Strategic Risk Analysis (also known as TRA, TOP Risk Analysis, from 2025 onwards).

• Interviews and follow-up talks with individual internal experts (after the work sessions).

• Preparation of an overview of material sustainability topics and associated 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’.

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)topic it concerns and whether it concerns an impact, opportunity, or risk. ^{(ESRS 2 SBM-3 par. 46 en 48a)} These (sub)topics are further elaborated in the following chapters of the sustainability statement.

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 an *. The material IROs per topic are presented in a table at the beginning of the related chapter ^{(ESRS 2 SBM-3 par. 48a)}and are related to Enexis' strategy and business model. ^{(ESRS 2 SBM-3 par. 48c(ii) (ESRS 2 SBM-3 par. 48c(iv))} In the following chapters, the IROs are further explained, including their financial implications.^{(ESRS 2 SBM-3 par. 48c(i) (ESRS 2 SBM-3 par. 48c(ii) (ESRS 2 SBM-3 par. 48d)}

Entity specific KPIs

The table below presents the KPIs per ESRS and indicates whether each KPI is entity-specific or not.

Decision-making processes, control procedures, and integration into existing processes

On behalf of the EB, the External Reporting department coordinated the double materiality analysis (DMA) in 2024, as well as its validation in 2025. Key decisions included identifying stakeholders, scoring impacts, risks, and opportunities, and determining material sustainability topics and the related disclosure requirements. These decisions were made by the CSRD steering group based on a detailed internal record of the considerations and supporting documentation. The outcomes were subsequently presented to the Executive Board for validation and discussion. ^{(ESRS 2 IRO-1 par. 53d)}

In 2024, the identification, assessment, and management of impacts and risks arising from the DMA had not yet been integrated into the risk management process. In 2025, specific attention was given to sustainability-related risks, resulting in improved integration. Further information on how Enexis Groep has structured its risk management is provided in the section ‘Risk management and internal control for the Sustainability Statement’. ^{(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 DMA had not yet been formally integrated into the overall management system. The same applies to integration into the overall management processes. In 2024, the identification, assessment, and management of impacts, risks, and opportunities arising from the DMA had not yet been formally embedded in the integrated management system. Further improvements were made in 2025, including the establishment of an ESG sponsor group with underlying ESG working groups. The impacts, risks, and opportunities included in this Sustainability Statement now form part of this structure, with periodic reporting to both the EB and SB. ^{(ESRS 2 IRO-1 par. 53f)}

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)}

The validation of the DMA for the 2025 financial year resulted in a modification to one of the IROs. ^{(ESRS 2 SBM-3 par. 48g)} Specifically, the IRO under ESRS G1 ‘Political influence and lobbying activities’ was supplemented with the following sentence (see the sentence in italics and bold): ‘ Due to the political-administrative climate with many changing majorities, policy changes or amendments to laws and regulations may be delayed or change direction. This may result in a risk of non-compliance, which could lead to enforcement action, sanctions or legal proceedings (including claims for damages). 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.’