EU taxonomy on sustainable activities

Since 2021, the EU Taxonomy on Sustainable Economic Activities applies to PostNL, which includes mandatory disclosures in the Report of the Board of Management. The EU Taxonomy is the EU's dictionary of sustainable economic activities designed to promote transparency, counters greenwashing, and drives the shift of capital towards a future sustainable economy.

An economic activity is considered Taxonomy eligible if it is described in the Taxonomy Delegated Acts, irrespective of whether that activity meets any or all of the technical screening criteria laid down in the Delegated Acts. An economic activity is considered Taxonomy aligned if it additionally meets technical screening criteria for the activity, provided that companies operate in compliance with a set of minimum social safeguards.

To date, technical screening criteria have been developed for only two environmental objectives set by the EU. These criteria relate to how an economic activity can contribute substantially to one or more of the environmental objectives, in combination with criteria for doing no significantly harm to the other environmental objectives.

So far, the technical screening criteria for substantial contribution has been specified by the EU for environmental objectives: climate change mitigation (CCM) and climate change adaptation (CCA). For 2021 the requirements applied to Taxonomy Eligibility only, and this was expanded from 2022 to assess both eligibility and alignment on the two above mentioned objectives.

The content and timing of the implementation of screening criteria for the other four environmental objectives, as well as the objectives and criteria for social and governance objectives, is currently uncertain.

The applicable conditions for the assessment of EU Taxonomy-aligned economic activities and the six environmental objectives in scope of the current requirements are summarised below.

Conditions

  • Substantially contribute to one or more of the environmental objectives of the EU Taxonomy

  • Do no significant harm (DNSH) to any of the other environmental objectives

  • Comply with minimum social safeguards (MSS).

Environmental objectives

  • Climate change mitigation (CCM)

  • Climate change adaptation (CCA)

  • Sustainable use and protection of water and marine resources

  • Transition to a circular economy

  • Pollution prevention and control

  • Protection and restoration of biodiversity and ecosystems

The EU Taxonomy prescribes quantitative and qualitative reporting on predefined key performance indicators (KPIs). In this section we present the share of PostNL’s consolidated total operating revenue and capital expenditure (capex) for the reporting period 2022. The disclosures are associated with Taxonomy-eligible economic activities related to the environmental objectives in accordance with the Regulation (EU) 2020/852 as supplemented with Commission Delegated Regulation (EU) 2021/2139 and Commission Delegated Regulation (EU) 2021/2178 (EU Taxonomy).

Basis of preparation

The alignment with relevant financial statement line items is the starting point of our Taxonomy allocation methodology. The reported figures have been determined based on the allocation of activities to the Taxonomy, derived bottom-up for all reporting units of PostNL.

For the two KPIs in PostNL's reporting scope, turnover and capex, the figures are based on the actual amounts represented in the general ledger accounts as included in PostNL's consolidated financial statements. In addition, the split between transport by road and air in our international business is based on expected transport modes between countries for our trade lanes.

To avoid double-counting, we eliminated inter-company transactions, which are separately specified in our general ledger accounts and consolidated financial statements. We did not identify any other risk of overlapping activities that could lead to double-counting for our 2022 reporting.

The EU Taxonomy prescribes reporting on predefined key performance indicators

The Taxonomy requirements prescribe use of a predefined reporting template in tabular form for the quantitative disclosures. Within the predefined template, not all information elements are applicable for 2022 or for PostNL. For the purpose of readability of our quantitative disclosure, PostNL slightly simplified the table by removing:

  • The four environmental objective columns from the substantial contribution section as no criteria are yet available

  • The columns with comparative figures, as this is not yet required for 2022

  • Columns related to enabling and transitional activities as these do not apply for PostNL eligible activities

PostNL has implemented the Taxonomy-related requirements based on the detailed regulatory documents, frequently asked questions (FAQs) from the European Commission and, where needed, our own interpretation of the criteria. Although the requirements are detailed, on specific areas they leave room for interpretation. On relevant elements where interpretation is needed, PostNL applied due care in its approach by focusing on maximum transparency and through engagement with dedicated professional consultants and peers, for example a PostEurope working group. We are aware that views on the interpretation by the European Commission may change over time and that this may lead to different conclusions on the reported eligibility and alignment in the future.

Our assessment on compliance with the relevant EU Taxonomy criteria included the following key steps:

  • Evaluation of PostNL's activities in relation to the EU Taxonomy classification of economic activities

  • Assessment and preparation of appropriate interpretation of the requirements in the context of PostNL for the areas where the EU Taxonomy criteria are not clear or specific enough

  • Evaluation of technical specifications of activities and related assets in relation to substantial contribution criteria

  • Evaluation of meeting the DNSH and MSS criteria based on existing policies and business practices

  • Performing a specific climate risk assessment for the DNSH criteria on climate adaptation

EU Taxonomy KPIs

For 2022, PostNL reported on the KPIs total operating revenue (turnover) and capital expenditures. In the following tables the amounts which are in scope and the percentage of eligibility and alignment are presented per KPI for the EU Taxonomy activities PostNL has recognised.

Operating expenditures

For operating expenses (opex), where the operational expenditure is not material for the business model, the EU Taxonomy allows for an exemption (Article 8 Delegated Act Annex I section 1.1.3.2). PostNL is a people driven and asset-light company. The denominator of the total opex in scope for the EU Taxonomy amounts to €50 million, which represents around 1.6% of the total operating expenses of PostNL of €3,085 million of 2022 (excluding the settlement expense related to the change in pension accounting classification). As PostNL applies a materiality threshold of 5%, the relative share of opex in scope of the EU Taxonomy compared to the total operating expenditures of PostNL is deemed not material for PostNL's business model. As a consequence, the amount of eligible opex is exempted from the calculation of the numerator of the opex kpi for the EU Taxonomy and is therefore reported as being equal to zero.

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PostNL Turnover taxonomy aligned activities
2022, as indicated

    

Substantial contribution

Do not significantly harm

Safeguards

Economic activities

Codes

Absolute turnover (in million)

Proportion of turnover

Climate change mitigation

Climate change adaptation

Climate change mitigation

Climate change adaptation

Water and marine resources

Circular economy

Pollution

Biodiversity and ecosystems

Minimum social safeguards

Transport by personal mobility devices

6.4

234

7%

7%

0%

Y

Y

Y

Y

Y

Y

Y

Transport by light commercial vehicles

6.5

105

3%

3%

0%

Y

Y

Y

Y

Y

Y

Y

Freight transport

6.6

0

0%

0%

0%

Y

Y

Y

Y

Y

Y

Y

Sorting activities

6.15

645

21%

21%

0%

Y

Y

Y

Y

Y

Y

Y

Real estate activities

7.7

0

0%

0%

0%

Y

Y

Y

Y

Y

Y

Y

Total Taxonomy aligned activities

 

985

31%

         
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PostNL Turnover taxonomy eligible but not aligned activities
2022, as indicated

Economic activities

Codes

Absolute turnover (in million)

Proportion of turnover

Transport by personal mobility devices

6.4

0

0%

Transport by light commercial vehicles

6.5

1,012

32%

Freight transport

6.6

751

24%

Sorting activities

6.15

0

0%

Real estate activities

7.7

1

0%

Total eligible but not aligned activities

 

1,764

56%

Download spreadsheet

PostNL Turnover taxonomy total eligible and non-eligible activities
2022, as indicated

Economic activities

Codes

Absolute turnover (in million)

Proportion of turnover

Transport by personal mobility devices

6.4

234

7%

Transport by light commercial vehicles

6.5

1,117

36%

Freight transport

6.6

751

24%

Sorting activities

6.15

645

21%

Real estate activities

7.7

1

0%

Total taxonomy eligible activties

 

2,749

87%

Taxonomy non-eligble activities

 

395

13%

Total turnover

 

3,144

100%

Turnover

This KPI covers the external revenue recognised in line with IAS 1 par. 82(a) and therefore reconciles to the 'Total operating revenue' as included in the consolidated income statement and note '2.5 Cash flow performance'download. To determine which part of the net turnover was earned by Taxonomy-eligible activities per revenue-generating activity, we assessed to which extent this activity is included in the EU Taxonomy. The turnover considered to be eligible under the EU Taxonomy almost entirely consists of revenue streams primarily related to collecting, sorting and delivering mail and parcel items. Therefore, the eligible and aligned turnover under the EU Taxonomy is entirely related to these logistic activities. The non-eligible revenue under EU Taxonomy consist of revenue related to the transportation of mail and parcels by air, service provider activities, and the organisation of logistic activities. The allocation of revenue over the different EU Taxonomy economic activities is based on the relative operational costs of the individual activities.

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PostNL Capex taxonomy aligned activities
2022, as indicated

    

Substantial contribution

Do not significantly harm

Safeguards

Economic activities

Codes

Absolute capex (in million)

Proportion of capex

Climate change mitigation

Climate change adaptation

Climate change mitigation

Climate change adaptation

Water and marine resources

Circular economy

Pollution

Biodiversity and ecosystems

Minimum social safeguards

Transport by personal mobility devices

6.4

2

1%

1%

0%

Y

Y

Y

Y

Y

Y

Y

Transport by light commercial vehicles

6.5

2

1%

1%

0%

Y

Y

Y

Y

Y

Y

Y

Freight transport

6.6

0

0%

0%

0%

Y

Y

Y

Y

Y

Y

Y

Sorting activities

6.15

104

47%

47%

0%

Y

Y

Y

Y

Y

Y

Y

Real estate activities

7.7

0

0%

0%

0%

Y

Y

Y

Y

Y

Y

Y

Total Taxonomy aligned activities

 

108

49%

         
Download spreadsheet

PostNL Capex taxonomy eligible but not aligned activities
2022, as indicated

Economic activities

Codes

Absolute capex (in million)

Proportion of capex

Transport by personal mobility devices

6.4

0

0%

Transport by light commercial vehicles

6.5

24

11%

Freight transport

6.6

3

1%

Sorting activities

6.15

0

0%

Real estate activities

7.7

1

0%

Total eligible but not aligned activities

 

28

13%

Download spreadsheet

PostNL Capex total eligible and non-eligible activities
2022, as indicated

Economic activities

Codes

Absolute capex (in million)

Proportion of capex

Transport by personal mobility devices

6.4

2

1%

Transport by light commercial vehicles

6.5

26

12%

Freight transport

6.6

3

1%

Sorting activities

6.15

104

47%

Real estate activities

7.7

1

0%

Total taxonomy eligible activties

 

136

62%

Taxonomy non-eligble activities

 

84

38%

Total capex

 

221

100%

Capital expenditures

This KPI covers the additions to Property, plant and equipment under IAS 16, Intangible assets under IAS 38, as well as additions (including reassessments) to Right-of-use assets under IFRS 16 (see notes 3.2-3.4 to the Consolidated financial statements for more information). From the total capital expenditures, it is assessed which portion is Taxonomy eligible by assessing per asset category to which economic activity this asset category relates and to what extent this activity is included in the EU Taxonomy. The capital expenditures that are considered to be eligible under the EU Taxonomy include transport, infrastructure for transshipments (sorting activities) and real estate activities. The non-eligible capex under EU Taxonomy mainly relate to software and other equipment.

The aligned capex for activity 6.4 is broken down to €1 million for Property, plant and equipment (PPE) and to €1 million for Right-of-use (RoU) assets. The aligned capex for activity 6.5 relates entirely to RoU assets. The breakdown of the aligned capex for activity 6.15 shows expenditures for PPE of €65 million and for RoU assets of €39 million.

EU Taxonomy Activities and key interpretation elements

PostNL has identified the following EU Taxonomy economic activities applicable for its 2022 reporting.

6.4 Operation of personal mobility devices, cycle logistics

All transport devices where the propulsion comes from the physical activity of the user, from a zero-emissions motor and combined with physical activity (i.e. bicycles, electric bicycles, or cargo bikes) are categorised under activity 6.4. This means that the kilometres of the delivery process, using a personal mobility device like a (e-)bike and/or (electric) cargo bikes, in combination with physical activities are categorised under activity 6.4.

For the calculation of the share of aligned activities, PostNL allocated the proportion of turnover based on the kilometres driven by the Taxonomy-aligned activities relative to the total kilometres driven by vehicles attributed to this economic activity.

6.5 Transport by motorbikes, passenger cars and light commercial vehicles

The purchase, financing, renting, leasing and operation of vehicles designated as category M1, N1, or L (2- and 3-wheel vehicles and quadricycles). In PostNL terminology, all activities with small trucks are attributed to this category, as well as with motorised scooters and light electric freight vehicles.

For the calculation of the share of aligned activities, PostNL allocated the proportion of turnover based on the kilometres driven by the Taxonomy-aligned activities relative to the total kilometres driven bij vehicles attributed to this economic activity.

The share of Taxonomy-aligned activities for 6.5 is currently built up from electric scooters. For the electric small trucks in our fleet (13% of the total vehicles in our fleet), we concluded that these cannot yet be reported as Taxonomy aligned, because PostNL has not yet been able to substantiate the DNSH criteria for the environmental objective Pollution. All other technical screening criteria are being met for the activities with these vehicles.

6.6 Freight transport services by road

This activity concerns power-driven vehicles having at least four wheels and which are used for the carriage of goods. In PostNL terminology the activities with large trucks are attributed to this economic activity.

6.15 Infrastructure enabling low-carbon road transport and public transport

PostNL links its sorting activities PostNL to a specific sub-activity described in the EU Taxonomy, infrastructure dedicated to transshipment. Our interpretation of this activity is that infrastructure and related activities in the sorting centres of PostNL are related to transshipment of freight between the modes (Delegated act Annex 1 art. 6.15: 1.b of the technical screening criteria). This infrastructure is fundamental to enable efficient transport of letters and parcels and is therefore indispensable to minimise the required transport activities in our business. Other alternatives would imply a significant expansion of transport movements and related environmental impact, resulting in increased GHG emissions.

7.7 Acquisition and ownership of buildings

Buying and owning real estate. PostNL considers rent and leasing buildings as ‘exercising ownership of that real estate’, which is a specific part of this economic activity. PostNL has renting and leasing activities of its own buildings on a small scale.

Minimum social safeguards

PostNL has assessed its compliance on the minimum social safeguards the EU Taxonomy requires in relation to human rights, anti-bribery, fair competition and taxation matters. PostNL's has included relevant aspects of business conduct in relation to these topics in formal policies and procedures as part of our business conduct and integrity programme. The assessment provided PostNL a sufficient basis to conclude that the Company met the minimum social safeguards criteria. More details about business conduct and integrity in general can be found in the chapter Risk and opportunity managementdownload.