Alliander

Alliander uses a Dutch two-tier system with a Management Board of executive directors and a Supervisory Board of non-executive directors that supervises, advises and acts as the Board's employer; both are accountable to the General Meeting of Shareholders. The CEO assigns duties to departments for managing material impacts, risks and opportunities. In 2024 the Management Board had three men and one woman (25% women, below the 33% target), while the Supervisory Board had two men (40%) and three women (60%), meeting the target. A diversity policy covers gender ratio, complementary experience and balanced age. All Supervisory Board members are independent under the Dutch Corporate Governance Code, and the majority are independent under the Electricity Act and Gas Act. An Executive Committee of six members supports the Board. A Works Council with 13 members (14 after December 2024 elections) represents employees.

The Management Board integrates the sustainability agenda into business strategy and monitors performance through the Planning and Control Cycle. Sustainability is on the Supervisory Board's agenda quarterly, and the Audit Committee is kept informed of developments in sustainability reporting. The corporate dashboard, using the Objective, Goals, Strategies and Measures (OGSM) method with qualitative and quantitative indicators, is reviewed by the Management Board and discussed with the Supervisory Board quarterly. Both boards have or can access the expertise to understand and decide on sustainability topics, using external specialists and self-evaluations. Deep-dive sessions are organised as needed; in 2024 one focused on CSRD implementation and its disclosure requirements. The Works Council meets a Management Board delegation twice a year to discuss developments, risks, results and the effectiveness of policy, targets and measures, based on a quarterly business review.

Management Board members do not receive variable pay. They receive a fixed gross annual salary including holiday allowance, which does not exceed 130% of the limit under Dutch legislation on high income earners (WNT) and is adjusted annually to the current WNT remuneration limit. Sustainability is described as an essential part of the objectives Alliander works towards and against which the Management Board's performance is appraised. However, the text states there is no direct link between sustainability performance and directors' remuneration.

Alliander describes due diligence as the process of identifying, preventing and mitigating potential negative impacts and accounting for its response to the impacts of its activities on people and the environment, covering its own activities and the upstream and downstream value chain. The statement provides a table mapping the core elements of due diligence to where they appear in the sustainability statement: embedding due diligence in governance, strategy and business model; engaging with affected stakeholders in important steps; identifying and assessing adverse impacts; taking action to address adverse impacts; and tracking the effectiveness of efforts and communicating about them. These elements are cross-referenced to paragraphs on governance and the Management Board's role, the market context, stakeholder interests, the materiality assessment, risk management and internal control, and objectives and results.

Risk management is described as the deliberate handling of uncertainties that can negatively affect the strategy adopted by the Management Board. Alliander applies a 'three lines' model: the first line identifies, manages and monitors risks and defines and safeguards the quality of quantitative data points; the second line supports, advises and sets frameworks, draws up the double materiality assessment and EU taxonomy accountability, and decides which data points to disclose; the third line gives an objective, independent opinion and selects quantitative data points. Sustainability is being integrated into the risk management system, including in risk sessions at ExCo and unit level. Risks are classified on the Alliander risk matrix with six impact scales including sustainability, and recorded in the Alliander Management System (ABS). The risk report and quarterly 'in control' update are prepared by Risk Management and Compliance and approved by the Management Board.

Alliander is an energy infrastructure company (NACE 3513) ensuring reliable, affordable and sustainable energy access across six regions of the Netherlands, and considers accelerating the greening of the Dutch energy system part of its core task. Its main activities are electricity distribution, gas distribution (including repurposing the gas grid for renewable gases), and district heating network development. Operating income totalled 3.9 billion euros in 2024, with segments Liander (2.9 billion) and Other (0.7 billion); gas operating income was 0.6 billion. Two customer groups are served: low-volume consumers (households and small businesses) and high-volume consumers (large providers and industries), defined by the Dutch Energy Act. The value chain has an upstream side (direct and indirect suppliers) and a downstream side (contractors carrying out outsourced work). The business model is based on the Nbility model. Alliander does not supply banned products or use banned substances.

Alliander involves stakeholders in strategy development and in defining and valuing material topics. It identifies four core stakeholder groups: customers, employees, shareholders and investors, and local and regional authorities, plus a range of societal stakeholders and partners. It engages three broad clusters: customers, partners in the implementation chain, and public authorities and policymakers. Engagement uses surveys, account managers, questionnaires, pilots, social media and a complaints procedure. The Management Board delegates responsibility for incorporating stakeholder views to departments including Corporate and Social Affairs, Customer and Design, Strategic Resource Management, Asset and Product Management, High-Volume Connections, and Major Work Packages. A stakeholder table maps each group to items for discussion, type of interaction and topics. To limit stakeholder bias, consultations are monitored by a CSRD working group and steering committee and reviewed by the Management Board, and a youth Future Leader Board and an annual stakeholder panel review the annual report.

Based on the double materiality assessment, Alliander defined five ESRS themes as material topics, elsewhere listed as six standards: Climate change (E1), Circular economy (E5), Own workforce (S1), Workers in the value chain (S2), Consumers and end-users (S4) and Business conduct (G1). These are material from both an impact and a financial perspective and align with strategic priorities of driving the energy transition, delivering a sustainable energy supply, ensuring security of supply and communicating with customers. Material impacts, risks and opportunities are directly or indirectly linked to the strategy, and the 'Information on sustainability topics' paragraph explains the interaction. Alliander states it has a solid financial position and therefore a resilient business model and strategy. Current financial impacts are recognised in the financial statements; no further IRO-specific qualitative or quantitative assessments were performed. Targeted financial effects are included in business plans, and scenario analyses form part of the business plan process.

Alliander first performed a broad topic-oriented double materiality assessment in 2023 and brought it further into line with the CSRD and ESRS for the 2024 report, drawing on prior experience, dialogue, network meetings and a peer review. The methodology combines an inside-out perspective (impact on people, environment and society across all ESRS topics and subtopics) and an outside-in perspective (risks and opportunities and their financial impact). A topic is material if material in at least one perspective. Impacts, risks and opportunities were assessed for own operations and the value chain, focusing on first-line suppliers for S2, E1 and E5. The process ran in six steps: identify and validate topics using sources such as a peer review, the Alliander Trend Report, strategy and risk assessment; determine impacts, risks and opportunities using scale, scope, recoverability and probability; determine materiality via the CSRD working group; validate relevance with stakeholders; plot topics in the materiality matrix; and implement. Financial impact was assessed for short (up to 1 year), medium (1 to 5 years) and long term (over 5 years).

The double materiality assessment led Alliander to report in detail on the following ESRS: E1 Climate change, E5 Circular economy, S1 Own workforce, S2 Workers in the value chain, S4 Consumers and end-users, and G1 Business conduct. The non-material topics are Pollution (E2), Water and marine resources (E3), Biodiversity and ecosystems (E4) and Affected communities (S3), which are not material from either an impact or a financial perspective; Alliander did not screen assets and activities for these topics or engage with affected communities, but discussed them with internal subject matter experts. The statement notes that a reference table at the end lists topic references to the various CSRD disclosures and indicates which disclosure requirements are included by reference. Certain disclosure requirements are included by reference in other sections of the annual report. As 2024 is the first ESRS reporting year, 2023 comparatives are generally unavailable unless prior NFRD or GRI reports contained the same indicators.

Alliander states it is working on an overall climate transition plan as referred to in the CSRD, consolidating its planning for energy transition, climate mitigation and climate adaptation. The plan will be presented for board approval in 2025. Starting points include alignment with Alliander's strategy, drawing it up in line with the SBTi framework (with a decision on possible SBTi accreditation in 2025), and alignment with the planning and budget cycle so targets, activities and measures are incorporated into the multi-year budget. A summary of allocated financial resources (OpEx and CapEx) will be adopted as part of the plan, with more detail promised in the 2025 annual report. Alliander confirms it has no fossil coal or oil activities. A full transition plan for managing climate impact on assets is part of its 2025 planning.

Alliander has a mitigation policy aimed at limiting the CO2e under its immediate control and greening the remainder of its emissions, covering scope 1 (gas leak losses, owned and leased vehicles), scope 2 (electricity network losses, buildings) and scope 3 (commuting). It aligns work with the Science Based Targets initiative (SBTi) and the 2015 Paris Agreement and Dutch Climate and Energy Agreement. Climate policy is managed by a CO2 steering group and reported quarterly; the carbon KPI sits on the top management dashboard. An Energy Management Plan forms part of the CO2 performance ladder, on which Alliander achieved level 5 (highest) in 2024. Green finance (green bonds, green ECP, a Sustainability Linked credit facility) supports the policy. For adaptation, climate risks are part of the risk management framework and annual risk sessions, though Alliander notes it lacks a full CSRD-compliant risk analysis, to be reassessed in 2025.

Actions to reduce emissions include purchasing Guarantees of Origin (the biggest lever) to green electricity network losses, monitoring and limiting gas leak losses through repair and replacement, replacing diesel with HVO in generators since 2023, and clean mobility (an 'EV unless' policy, all-electric leased cars required since July 2023, 217 electric vans ordered, EV share up to 41.1% of the fleet). Other actions cover energy-efficient buildings and sites, reducing SF6 usage, the OGMP 2.0 methane programme, replacing grey cast iron pipes, and IT energy reductions. Supplier actions include sustainable purchasing policy with carbon reduction as a tender criterion, carbon pricing in procurement, and use of recycled and circular materials. In 2024 Alliander spent EUR 5 million on greening CO2e emissions. Resource allocation detail is deferred to the forthcoming transition plan.

Alliander adopted 2021 as the base year for scope 1, scope 2 (market-based) and scope 3 own mobility. The target for 2024 was a maximum of 416 kt CO2 from operations, offset through greening, and this target including greening is maintained for 2025. There are reduction targets by topic for scopes 1 and 2, and for scope 3 only own mobility. Alliander intends to align targets with the 1.5 degree Paris scenario. Its zero-emissions (net zero) target has been moved to 2050 at the latest, with targets for 2030 (medium term) and intervening years (short term). SBTi verification is scheduled for 2025. Alliander states it does not currently have specific 2030 targets set but plans to set SBTi-aligned targets in 2025. The 2025 GO greening target is 270,779 tonnes.

Total energy usage rose 19% from 1,557,097 MWh in 2023 to 1,849,648 MWh in 2024, mainly due to higher gas consumption in the network. The renewable share fell from 79% to 74% and the non-renewable share rose from 21% to 26% (nuclear 0%). In 2024, non-renewable energy included natural gas 428,121 MWh, crude oil and petroleum products 51,381 MWh, and purchased non-renewable electricity/heat 378 MWh (total non-renewable 479,880 MWh). Renewable sources totalled 1,369,768 MWh, comprising 1,368,542 MWh purchased renewable electricity/heat and 1,226 MWh self-generated. Energy intensity rose from 571 to 608 MWh per million euros of revenue (revenue EUR 3,043 million). Net revenue from high climate impact sectors under the EU taxonomy was EUR 709 million (mainly natural gas), versus EUR 2,334 million from non-high-impact activities.

Alliander reports emissions per the GHG Protocol using the operational control method. Scope 1 was 171,525 tonnes CO2e in 2024 (up 28 kt from 144,017 in 2023), driven by higher gas network losses; it comprises CO2, CH4 and SF6. Market-based scope 2 was 32,575 tonnes CO2e (versus 32,597 in 2023); GOs bring electricity-consumption emissions to 0, offsetting 268,683 tonnes in 2024. Location-based scope 2 total was 369,939 tonnes. Upstream scope 3 rose 3% to 545,829 tonnes CO2e (base year 2021: 506,654), led by C1 purchased goods and services (304,192) and C2 capital goods (205,265). Total market-based emissions were 717,376 tonnes and location-based 1,166,762 tonnes in 2024. Downstream use of sold products (combustion of distributed gas) was 8,860,745 tonnes CO2e, reported voluntarily. Categories C8, C9, C10, C12, C13, C14 are excluded as not applicable. Base year 2021 total was 523 kt (before GO offsetting).

Alliander greens emissions using Guarantees of Origin (GOs) and Gold Standard Carbon Credits. In 2024 it greened 261 kt CO2 of network electricity losses with Dutch wind GOs and greened 100% of total electricity network losses. The GO-to-Gold-Standard ratio in 2024 was 61% GOs to 39% Gold Standard, with a total of 446 carbon credits used. Scope 1 and 2 footprint after greening in 2024 was 0 kt CO2e. Alliander states it does not take part in external carbon storage or removal projects and does not acquire carbon credits originating from them, and has no long-term contractual commitments for Gold Standard certificates. Gold Standard certificates are used outside the value chain. Under the planned SBTi switch, Gold Standard certificates will no longer be permitted, so methane emissions can no longer be offset. Alliander has no information on Article 6 Paris Agreement corresponding adjustments.

Alliander uses an internal CO2 price as a shadow price and weighting factor in investment assessments, giving greater weight to energy savings and methane leak reductions. In 2020 Alliander led a sector-wide agreement among network operators, who resolved in 2021 to use a common CO2 price of EUR 50 per tonne, raised to EUR 100 in 2022 and EUR 150 per tonne in 2023; in 2024 it remained at EUR 150. The EUR 150 price forms part of the Price of Network Losses and is based on the CO2 'prevention price', higher than the EU ETS market price and consensus-based within the sector. The internal carbon price has no impact on the financial statements. Examples where the Price of Network Losses influenced 2024 decisions include the MSR-gateway proposal, distribution and grounding transformer tenders, Picarro gas leak detector vehicles, and the MV+ cable tender.

Alliander states it currently has no formally defined circularity policy, though it has established a circularity policy framework that it will implement in 2025 to make circularity a permanent feature of procurement. The Procurement business unit is working on implementing the draft CSR policy in the procurement function, and the 'Alliander CSR from the perspective of General Prosperity' policy framework applies to material inflows and use. The approach centres on applying circularity measures such as reuse after repair and overhaul to increase availability of existing inventories, support the energy transition and reduce long-term costs. Alliander uses the R ladder methodology to measure circular impact, with 10 rungs from refuse (0, highest impact) to recover (10, least impact). It works with other network operators, suppliers, customers and sheltered work enterprises to set the circular economy chain in motion.

Alliander requires suppliers to provide raw material passports (RMPs) stating the quantity of each raw material and the recycled, reused or recovered percentage, validated at the Centre of Excellence using the CE Delft methodology, checked against a central database, compared with DNVL data (using the lower value), and verified through supplier audits. In 2023 cable suppliers TKF and Prysmian received KIWA certification for circular cable. A Circular team screens incomplete material flows through an intake process assessing reuse suitability for Alliander, other network operators, suppliers, commercial sales and charities. Actions in 2024 included an evaluation session on cable assets, a pilot for overhauling multi-joints with a sheltered work enterprise (over 90% found suitable for reuse), 76 overhauled compact stations, a circular materials warehouse in SAP, and 1,624 reused tools issued to operations. Tender conditions for cables and distribution transformers aimed to increase recycled material use.

Alliander has set a self-chosen voluntary ambition focused on both purchasing recycled core assets and end-of-life recyclability of core assets, aiming that by 2027, 45% of core assets will be circular purchases or recyclable at the end of their lives. The company states this is a voluntary target and that an official target has not yet been set. The CSRD requirements established a new KPI in 2024 for the percentage of purchased materials that is recycled, but a target for that percentage had not been set for 2024. The scope covers core assets: low, medium and high-voltage cables, gas pipes, distribution and power transformers, (smart) electricity and gas meters, and switchgear. Alliander intends to set a target for the percentage of circular procurement in relation to core assets in 2025.

Inflows include raw or processed materials required to produce Alliander's most important components and equipment, such as copper, aluminium and plastic used in cables, transformers and gas pipes. The company currently disregards items needed to mine or process these materials, such as water. In 2024 Alliander purchased 6.8% of its materials on a circular basis. The reported table shows total weight and circularity of materials used: cables 18,911 tonnes with 1,165 tonnes circular (6.2%); meters 344 tonnes with 105 tonnes (30.5%); pipes 1,521 tonnes with 57 tonnes (3.8%); transformers 7,398 tonnes with 699 tonnes (9.0%); switchgear 1,289 tonnes with none circular (0.0%); total 29,462 tonnes with 1,996 tonnes circular (6.8%). Weights and recycled percentages come from raw material passports and SAP, with recycled percentages assumed nil where an RMP is unavailable.

Alliander's policies on its own workforce apply to all directly employed staff and to agency workers where stated, with distinctions by position and authority approved by the Management Board. The company commits to Dutch labour law and to international human rights and labour standards in the Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work, which frame but are not explicitly incorporated into policy. It emphasises freedom of association, the right to collective bargaining, prevention of discrimination and diversity. HR is responsible for personnel policy (440 employees, 58 million euro budget) and SEQ for safety policy (150 employees, over 20 million euro budget). Specific policy documents include the Safety Vision, a diversity, inclusion and equality policy approved in 2023, a code of conduct and the 'Spreek je uit' (Speak Up) policy. A Learning and Development policy document was still being drafted for completion in 2025.

Alliander engages workers mainly through a single Works Council at the level of Alliander N.V., directly elected by employees and covering over 99% of permanent staff. The Works Council draws input from organisational unit committees, permanent committees and preparatory committees, and can appoint committees to handle formal advice or consent requests. Elections took place in late 2024 with new members seated. The Works Council holds monthly consultation meetings with the CEO, also attended by the CHRO, and Supervisory Board members attend twice a year. In 2024 the Executive Committee and Works Council ran 'Get to the Point' sessions to speak directly with staff at all sites. Employee views are also measured via the Central Employee Barometer and the employee Net Promotor Score (eNPS), whose results are shared with organisational units and teams as a basis for improvement.

Alliander operates several channels for raising concerns, anchored in its code of conduct and the 'Spreek je uit' (Speak Up) policy. These include a scheme for reporting suspected misconduct, a complaints procedure for inappropriate behaviour, a general complaints regulation, a regulation on complaints related to employment conditions, and a whistleblower policy. Employees can also raise concerns in confidence with nominated officers; in 2024 eight people, including one outside the company, served as confidential advisers for reports such as discrimination, sexual harassment, bullying, aggression and violence. An aggression help desk supports employees facing aggression from customers or the public, offering training, toolboxes and a reporting form in the safety management system. The Internal Audit department runs a fraud disclosure desk that investigates reported incidents under an investigation protocol. Code of conduct violations may lead to disciplinary measures from a warning to dismissal.

Alliander takes action across employment conditions, health and safety, and equal treatment. To address labour market scarcity it runs conversion programmes for technicians, industry-wide training for refugees with TenneT, Enexis and Refugee Talent Hub, objective hiring, and explores becoming a skills-centred organisation. It uses 'engineering promoters', a job match platform, target group campaigns and talent pooling; in 2024 it welcomed 246 IT staff and 515 new technicians. Safety action centres on three aspects: safety controls, broad safety expertise and safe behaviour, supported by a safety management system, ISO 45001 certification for higher-risk units, mandatory training, Life-Saving Rules and tool testing. Health measures include the Sustainably Fit programme, a Sustainably Fit Coach scheme, Periodic Medical Checks and reintegration support. Diversity work includes six employee networks and inclusion initiatives. Effectiveness is tracked via OGSM targets monitored monthly with the Management Board and via the employee barometer.

Alliander sets targets using the OGSM model (Objectives, Goals, Strategies, Measures), with HR and SEQ each having their own OGSMs and progress monitored monthly with the Management Board. Reported targets and results include: employees feeling inspired and proud at 84% against a target of 81%; women in senior management at 38%, exceeding the 33% target for 2024; a sickness absence rate of 4.1% against the 2024 target of 4.3%, with the aim of keeping it below 4.3% in coming years. For safety no LTIF target is set because accidents leading to time off should ideally be zero; the aim is 'Everyone safely home! With zero avoidable accidents' and remaining consistently at level 4 on the Safety Culture Ladder. For participation jobs the 2024 internal target of 145.0 FTEs was met, below the statutory target of 207.8 FTEs, which it aims to meet by 2029.

Alliander employs about 9,900 people (over 9,400 FTEs), including agency workers, mostly in the Netherlands. Measured by headcount on the last day of the year, there were 7,736 employees on employment contracts (6,015 male, 1,718 female, 3 other) and 2,151 agency or contract staff (1,636 male, 436 female, 79 other), for a total of 9,887. Of the 7,736 employment contracts, 6,276 were full-time and 1,460 part-time. In FTE terms, employees with an employment contract totalled 7,736, of which 6,456 were permanent and 1,280 temporary, plus 2,151 agency or contract staff, giving 9,887 in total. In 2024, 863 employees left Alliander (675 men, 188 women), including 390 due to the sale of Kenter, a turnover of 11.7%. Departing employees receive a questionnaire and in-depth interviews on their reasons for leaving.

Non-employee workers consist of agency and contract staff. Measured by headcount on the last day of the year, there were 2,151 agency or contract staff, comprising 1,636 male, 436 female and 79 other; 967 were full-time and 1,184 part-time. In FTE terms agency and contract staff totalled 2,151 (1,484 male, 383 female, 72 other, 1,939 total FTE). Work is increasingly outsourced to contractors with whom Alliander has long-term working relationships in order to scale up. Agency staff are covered by company policies where stated, and all temporary staff are covered by the Alliander safety management system, with 31% of temporary staff working for a business unit holding an ISO 45001 certificate. Agency and contract staff also feature in accident figures, participation job data and health and safety coverage reporting.

Employees with contracts under the collective labour agreement make up 99.6% of the workforce. A collective labour agreement for network companies, agreed between employers and unions, runs until 1 July 2025 and includes structural wage increases, additional parental leave for partners, a sustainable employability budget, diversity and inclusion measures, and extensions of the Vitality Scheme and Sectoral Social Plan. In 2024 a new Alliander collective labour agreement was agreed with the unions, covering a job classification system with linked salary scales, delinking pay from performance assessments and a new remuneration policy. Employees of the German businesses are covered by an equivalent German agreement; the remainder are Management Board members and TReNT employees. Employee participation via the Works Council represents over 99% of permanent staff. A Sectoral Social Plan running from 1 January 2024 to 1 July 2025 covers employees affected by organisational change, aiming to prevent redundancy and find alternative work.

Alliander reports several diversity metrics. Women in senior management, defined as positions immediately below the top level reporting directly to the Management Board (N-2), stood at 38% (11 women and 18 men out of 29), meeting the 33% target for 2024. The age structure, based on permanent employees at year-end (7,736 total), was 14.1% aged under 30 (1,093), 57.0% aged 30 to 50 (4,411) and 28.9% aged over 50 (2,232). By headcount the workforce on employment contracts was 6,015 male, 1,718 female and 3 other. Inclusion policy focuses on five areas: gender, cultural background, LGBTQ+, people with poor employment prospects and age. In 2024 Alliander investigated how best to measure cultural diversity, to implement and monitor interventions from 2025.

Alliander includes people with poor employment prospects under the Dutch Labour Participation Act, offering long-term work and work experience placements to the target group under the government's job promise scheme ('banenafspraak'). In 2024 it met its internal target of 145.0 FTEs for participation jobs, below the statutory target of 207.8 FTEs, and aims to comply with the statutory target by 2029. Jobs for persons with poor employment prospects as a share of the workforce were: own staff 1.2% total (male 1.4%, female 1.9%, other 0.0%) and agency or contract staff 1.1% total (male 1.2%, female 0.9%, other 0.0%). The figure counts employees with a target group registration at UWV as at 31 December, including those on the practical route. The Mission Possible employee network supports people with occupational disabilities and in 2024 ran a webinar on neurodiversity for more than 500 colleagues.

In 2024 there were 41 lost-time accidents and 71 accidents without sickness absence, giving an LTIF of 2.9. These figures include contractor accidents (12 with lost time and 12 without). Coverage of the health and safety management system was 100%; there were 0 fatalities, 90 cases of absence due to work-related ill health, 501 days lost to work-related accidents and 52,048 days lost to work-related ill health. Splitting accidents between own and agency/contract staff: accidents with no lost time were 68 own and 3 agency/contract; lost-time accidents were 39 own and 2 agency/contract; LTIF was 3.4 for own staff and 0.7 for agency/contract. Falls and trips were the most common lost-time incidents, followed by traffic-related injuries; three lost-time accidents resulted from electric arcing, one causing very serious injuries. LTIF is expressed per million man-hours using average FTEs and a standard 1,600 hours per employee. 49% of employees and 31% of temporary staff work in ISO 45001 certified units.

Alliander supports work-life balance by enabling staff to work remotely, set their own hours and use the Sustainable Employability Budget. All employees under the collective labour agreement have a right to family leave. The percentage of entitled employees who took family-related leave in 2024 was 15.9% for men, 18.3% for women, 0.0% for other, and 16.4% in total. The collective labour agreement includes making additional parental leave more attractive for partners. Health-related work-life metrics include a sickness absence rate of 4.1% in 2024 (2023: 4.4%), below the 4.3% target, reported for permanent staff over a rolling 12-month period excluding pregnancy-related absence. Around 10% of employees take sick leave three or more times a year, described as 'frequent absence'.

Alliander reports a gender pay gap of -1.3%, defined as the difference between the average pay of male and female employees, meaning women are paid slightly more on average than men. The pay gap is calculated based on the number of staff employed at year-end and gross monthly pay in December. The ratio of the total annual pay of the best-paid person to the median annual pay of all employees is 4.2, based on gross annual salary. Under the new Alliander collective labour agreement, pay has been delinked from performance assessments, with a job classification system, linked salary scale and a new remuneration policy. My Energy Plan is the new approach for setting agreements and targets with permanent staff, under which pay is no longer linked to performance assessments.

The number of reports submitted to confidential advisers rose from 83 in 2023 to 116 in 2024, of which ten were discrimination cases. The number of serious human rights incidents remained at zero, and no cases of non-compliance with the UN Guiding Principles on Business and Human Rights were found. These reports did not give rise to fines or compensation for discrimination or human rights breaches; the rise is attributed partly to the growth in employee numbers. The fraud disclosure desk completed 31 investigations into fraud and incident reports, leading management to impose measures or sanctions in 23 cases, including terminating employment via settlement agreement. Separately, there were 80 cases in which managers imposed sanctions ranging from an official warning to a settlement agreement. The employee barometer showed 87% (2023: 86%) view Alliander as a socially safe workplace, while 6.7% (2023: 6.4%) reported experiencing inappropriate behaviour.

Alliander's approach to value chain workers is set out mainly in its Supplier Code of Conduct, which establishes criteria for circularity, carbon emissions, working conditions and the social performance of suppliers. The code is based on OECD guidelines and respects the international treaties on employment conditions and working environments drawn up by the International Labour Organization (ILO). It sets requirements for suppliers on matters such as the ban on child labour, human trafficking, forced labour, discrimination, safety, the environment and employment conditions. Alliander expects suppliers and contractors to comply with the code in their own operations and in dealings with their own upstream suppliers, and states it is not aware of any cases of non-compliance. Alliander also endorses the Safe Energy Networks Governance Code. The stated aim is for workers everywhere to work in humane, decent and safe conditions, with ethical and honest business practices treated as paramount.

The text describes limited engagement with value chain workers to date. In interviews with some large suppliers, Alliander noted that those suppliers, like Alliander itself, try to ask questions of their own suppliers about compliance with the code of conduct. Alliander states it aims to promote reporting and the visibility of abuses, which requires forming a reliable and equal partnership with its direct suppliers. Safety incidents are evaluated and discussed on the contractors platform so that work processes can be improved and safety at work continuously increased. Looking ahead, Alliander says structural consultation with workers throughout the value chain is important, including on the information channels to be maintained and on regular reporting, indicating that broader direct engagement with value chain workers is still being developed rather than fully established.

The disclosure indicates that formal remediation processes and grievance channels for value chain workers are still being developed. Alliander's incident reporting system provides the technical means for incidents and near-misses involving supply chain partners and members of the public to be systematically logged. For the future, Alliander states it will work on policies and processes to contribute to rectification where it has caused or contributed to a material negative impact on workers in the value chain, with regular evaluations including of the effectiveness of measures taken. It also aims to contribute to transparent procedures, instruments, culture and awareness to increase the likelihood that misconduct will be resolved, and wants to put safeguarding measures in place so workers can report abuses anonymously or obtain legal assistance. From 2025 it intends to improve supplier audit processes so reports of abuse can be identified and acted on.

Alliander sets criteria for suppliers through its Supplier Code of Conduct and has audits performed to monitor compliance with agreements on labour rights; these are pre-planned snapshots. Each year it reviews whether direct suppliers of components regarded as critical recognise and comply with correct working and environmental conditions under the code. In 2024 it began expanding the code of conduct to state its expectations of suppliers more explicitly, using procurement criteria and vetting of suppliers as instruments of corporate social responsibility. Also in 2024, based on an externally led review and advice, it began an improvement approach to some high-risk core activities affecting the supply chains for contract work, cables and transformers. Safety incidents are evaluated and discussed on the contractors platform to improve work processes. Alliander notes external research shows risks to workers' rights in its supply chains, which it will investigate further in 2025, and it applies safety protocols such as VIAG and BEI to contractors.

Alliander states it has not yet set specific objectives regarding workers in the value chain, and that current actions are being defined more precisely in connection with the ESRS. It describes an outlook and planned actions rather than established targets. Over the coming years it aims to improve audit processes and increase transparency across the value chain, working over the long term towards a fully transparent supply chain in which all environmental and social impacts are visible. It plans to draw up an inventory of the types of workers in the whole value chain, including downstream workers and those in joint ventures, mapped geographically and examined product-by-product for structurally increased human rights risks such as child or forced labour. Alliander also aims to develop KPIs with percentage targets for strategic suppliers and external contractors that have safety certification and a transparent, safe reporting procedure for abuses, drawing on sector best practices and stakeholder input. From 2025 it intends to strengthen supplier audits in line with the stricter code of conduct.

Alliander identifies three material subtopics for consumers and end users: privacy, personal safety of consumers and end users, and access to products and services. Its main policy for privacy is the Alliander Privacy Policy, approved by the Management Board and evaluated annually to keep it up to date, fair and complete. It covers the GDPR and uses a risk register with ISO 27701 measures and privacy maturity levels; a Privacy Control Framework was due in the first quarter of 2025. For personal safety, behaviour is governed by the Electricity Network Code and the Dutch Gas Act, with value-focused maintenance. For access to energy, conduct follows the Dutch Gas Act, Dutch Electricity Act and ACM energy codes, including a duty of connection and non-discrimination. Cybersecurity follows the Strategic Alliander Security Policy, drawn up by the Management Board based on ISO 27000. The company notes it does not yet have a fully developed human rights policy for consumers and end users.

The text says customers are regarded as stakeholders within stakeholder management and are among Alliander's most important stakeholders, distinguishing business customers from consumers. It describes gathering feedback rather than a formal engagement process on impacts. Immediately after a job is completed, customers are asked for feedback, and the Net Effort Score is calculated to express the convenience they experienced. On access to energy, Alliander consults with government, authorities and industry partners, and disconnection policy operation is discussed in a Flanking Policy working group at Netbeheer Nederland involving ministries and the Energie Nederland association. Liander ran joint pilot projects with the local authorities in Amsterdam in 2023 and Arnhem in 2024 on supply terminations caused by payment difficulties. The company also engages in coalitions with network operators, the scientific community, industry and knowledge institutions on cybersecurity and digital products.

Stakeholders can report complaints or misconduct relating to Alliander and work carried out on its behalf through Liander.nl and the telephone customer service. Alliander's online privacy statement includes detailed information on data processing and the procedure for making complaints. Alliander also has a whistleblower policy. When misuse of personal data occurs, usually through a data leak, measures are taken to seal the leak, inform affected persons and where necessary notify the Dutch Personal Data Protection Authority. For payment difficulties, customers for whom Liander receives a supply termination notice are referred again to debt counselling, and network operators aim to stop receiving termination notices for vulnerable households. During outages, customers are informed by text message about the nature, extent and probable duration. On cybersecurity, security incidents can be reported directly on a CISO office intranet page, with liaison officers acting as contacts.

Alliander describes several actions. On privacy, data protection impact assessments are performed by Privacy Officers, a risk register prescribes measures, and a Privacy Control Framework with dashboards was planned for the first quarter of 2025. On personal safety, an active Incident Review Group discusses incidents, accidents and near-misses to learn from them, an internal crisis organisation is mobilised in major outages, major incidents are evaluated, and mandatory training including VCA and life-saving actions was completed on time. On access to energy, measures include the Disconnection Policy Regulation, referral to debt counselling, alternative supply termination models, going beyond legal requirements in extreme winter weather, and congestion management using flexibility, transmission restrictions and capacity-limiting contracts (CBCs). A congestion management control framework is active though key instruments are not yet in the Alliander Management System. A new Liander website went live at the end of January 2024, improving accessibility and performance.

Alliander uses several KPIs. For uninterrupted electricity delivery, the 2024 target for outage consumption minutes was 23 minutes and the result was 24.6 minutes. Average gas outage per connection in 2024 was 104 seconds. For congestion management, transmission restrictions had a 2024 target of 8,122 and 6,862 were imposed; capacity-limiting contracts (CBCs) had a 2024 target of 1,300 and 104 were concluded, with the shortfall attributed to a mid-year narrowing of the KPI definition. For customer convenience, the Net Effort Score target was at least 48% for consumers and 42% for business customers, and the 2024 results were 54.3% for consumers and 32.3% for business customers. On safety, the objective is a level 4 score on the Safety Culture Ladder. For privacy, the text states no significant ESRS objectives and actions have yet been formulated.

Alliander's policy for good business conduct is laid down in its Code of Conduct, which aims for a healthy corporate culture with a high level of integrity. The Management Board defines desirable business conduct and makes it happen, with Supervisory Board oversight; the Internal Audit department independently investigates reports and incidents. Under the Code, the Chief HR Officer is responsible for dealing with business partners, interests, assets, information, safety and personal conduct. Corporate culture is assessed at least once a year. Supporting policies include the screening policy (with re-screening introduced in 2024 for highest-risk jobs), onboarding and the 'Speak up' ('Spreek je uit') policy, plus the Confidential Advisers Regulation and Investigation Protocol. Alliander has a whistleblower policy based on applicable laws, open to staff and external parties, allowing reports of fraud, deception or irregularities to the Fraud Disclosure Desk or an independent third party. Persons making reports are protected and reports are investigated confidentially under the Investigation Protocol.

The policy in the codes of conduct for employees and suppliers is designed to prevent corruption and bribery. Alliander expects suppliers and employees not to succumb to bribery or kickbacks and to show restraint with business gifts. All jobs are assigned a risk class from 1 to 3, with screening measures set for each class; screening takes place on recruitment and on transfers to another position and covers internal employees and agency workers. All employees are invited once a year to take the Integrity e-learning course, which tests knowledge of the code of conduct using practical dilemmas, and management is informed of participation. The text notes Alliander has no specific training programme on preventing corruption and bribery and no separate courses for high-risk jobs. Alliander works with an independent fraud disclosure desk so employees can report suspected incidents separately from management. Reports are investigated, resolved and reported under the Investigation Protocol, and disciplinary measures may follow.

Alliander reports zero confirmed incidents in its anti-corruption KPIs for 2024: the number of convictions for violation of anti-corruption laws was 0, and the number of fines for violation of anti-corruption laws was 0. These figures are described as the numbers recorded by the legal affairs department. Alliander states it already reports serious incidents and any resulting convictions and terminated business relationships to the Supervisory Board. The report also provides Integrity e-learning participation data, with completion rates of 78% for functions at risk, 86% for the N-12 level, 100% for Management Board members and 76% for other own employees; this e-learning covers matters related to corruption and bribery to a limited extent.