Working on health and safety

Our policy

Our procurement policy addresses the health and safety of workers in the supply chain. Our socially responsible procurement (SRP) policy and the Supplier Code of Conduct are part of our procurement policy (see G1-2 for further explanation). Both documents contain provisions that monitor health and safety. In addition, we may apply specific health and safety requirements and/or award criteria in European tenders. Responsibility for the procurement policy rests with the Director of Procurement.  ^{(ESRS 2 par. 65a, b & c en ESRS S2-1 par. 14)}All relevant stakeholders can access our SRP policy and Supplier Code of Conduct via our website. Suppliers and partners play a key role in implementing this policy. ^{(ESRS 2 par. 65 f)}

The Supplier Code of Conduct is incorporated into our general purchasing conditions, or referenced as a separate document where those terms do not apply, such as in European tenders. In such cases, suppliers are required to explicitly agree to its application.^{(ESRS S2-1 par. 16)} The Code of Conduct includes provisions on respecting human and labour rights and requires suppliers to ensure that working conditions comply with all applicable supranational, national, and collective labour laws and bargaining agreements. ^{(ESRS S2-1 par. 14, 16 en 17)}In 2025, we strengthened the Supplier Code of Conduct further. It now explicitly prohibits child labour, human trafficking, and forced labour, and includes additional provisions addressing environmental aspects. ^{(ESRS S2-1 par. 18)}In 2025, one of our suppliers was found to be in breach of the UN Guiding Principles on Business and Human Rights (UNGPs). This affected employees at a tier-two supplier who were paid a legal wage that did not meet the living wage standard. The upstream intermediary has since drawn up an improvement plan in line with national legislation.  ^{(ESRS 2 par. 65a en S2-1 par. 19)}The appropriate monitoring approach for this improvement plan is still being determined.

We endorse the United Nations Universal Declaration of Human Rights and the Fundamental Principles and Rights at Work of the International Labour Organization (ILO). Both our SRP policy and Supplier Code of Conduct apply to employees throughout the value chain and align with the UN Guiding Principles on Business and Human Rights, 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).

• 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 these consultations rests 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 insights 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. This is expected to change with the introduction and further implementation of the CSDDD. ^{(ESRS S2-3 par. 25 en 27a - d)}

In 2025, we launched the Misconduct Complaints Desk (klachtenindeketen@enexis.nl), which allows suppliers and their employees to report concerns about potential violations of human, labour, and/or environmental rights^{(ESRS S2-3 par. 27b/c)}. No complaints were received through this channel in 2025.

In addition, employees of contractor partners can raise concerns or share needs during daily interactions, for example during workplace visits. At present, we do not yet assess whether employees in the value chain are aware of, or have confidence in, the available mechanisms for raising concerns or expressing needs.^{(ESRS S2-3 par. 28 )}

We have also implemented specific measures to report safety incidents involving contractor partners’ employees (see below). Furthermore, Enexis has a whistleblowing policy in place, and the Dutch Whistleblower Protection Act (Wet bescherming klokkenluiders) applies in the Netherlands. ^{(ESRS S2-3 par. 28)}

Our measures

As part of continuous improvement, we assess which 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 impact. ^{(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 in accordance with safety provisions in laws and regulations, collective bargaining 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 NEN Safety Culture 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 grid and gas network. 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)}At the end of 2024, Enexis achieved level 4 on the safety ladder, which also entails looking at safety in your chain. This score also applies to 2025.

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 also S1) and those of our contractors and other business partners by the number of serious incidents, the number of accidents resulting in absence and the Lost Time Injury Frequency (LTIF). The LTIF is calculated by dividing the number of incidents resulting in absence (at least 24 hours of complete absence, excluding fatal accidents while commuting) by the number of hours worked and then multiplying by 1 million. The number of hours worked refers to the registered hours of contractors^{(ESRS 2 MDR-M 77a)}. 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)}

The LTIF is a standardised method for calculating workplace safety performance. A lower LTIF score indicates improved safety. Enexis ultimately aims for zero accidents. In practice, however, it is not possible to eliminate the risk of accidents entirely. For this reason, Enexis aims for an LTIF consistently below two for contractors. ^(80a,b,c)This means less than two incidents resulting in absenteeism per one million hours worked.^(80b) This target was established on the basis of historical performance data^{(ESRS 2 MDR-T 80f)}.

We set this target independently, without consulting contractors.^(80h) In 2025, we did not meet this target, and the LTIF for contractors increased compared to 2024. This was mainly due to a rise in incidents involving minor injuries, such as falls and caught-in injuries. Safety will therefore remain a key priority in the years ahead.

We benchmark our performance against that of comparable organisations. All reported accidents and so-called SAVE reports (near misses) are investigated to identify lessons learned and opportunities for improvement for both Enexis and our contractors. ^{(ESRS S2-5 par. 42)}Despite all preventive measures, accidents can never be completely ruled out.