Business conduct and integrity approach

The focus of our integrity approach is to regularly ensure our employees are familiar with and are working in accordance with the PostNL Business Principles.

Our Business Principles inform how we act and make our decisions and as early as 2012, PostNL signed up to the ten principles of the United Nations Global Compact on such issues as human rights, labour, climate and anticorruption. We further endorse the OECD guidelines for multinational enterprises on responsible business conduct, while our sustainability strategy aligns us with the United Nations’ Sustainable Development Goals (SDGs). At the same time, our Orange compass influences our culture and behaviour and helps us steer our organisation in the way we want to do business, supporting us as we create the right environment for people to carry out their work effectively and feel connected.

Due to the approved changes in the law “Wet Bescherming Klokkenluiders”, all PostNL policies and procedures have been assessed to make sure that all changes are still in alignment with the approved law. Changes relate to aligning the reporting channels for the Netherlands, Belgium and International, specifying in which cases the confidentiality will be lifted, opportunities for reporting externally, and various other process-related changes.

In 2023, we introduced a revised process of receiving and processing integrity-related incident reports. All integrity-related reports are now received at a single point and are checked for whether an alleged breach of the law has occurred, a formal whistleblowing report is received, or any other type of reported breach or indicator. These other reports and signals are evaluated for further handling by responsible functions (such as the Integrity Office, line management or HR). This provides a smoother follow-up of reported incidents, cases and indicators, and ensures the best care for our employees.

During the year, we initiated 606 investigations in response to integrity-related issues. These investigations covered issues such as the theft of parcels or mail, bribery and corruption, or failure to follow workplace practices. The investigations resulted in 207 discontinued work relationships. At year-end 2023, 78 investigations were ongoing.

Integrity-related investigations include cases of alleged (sexual) harassment and discrimination. In 2023, we investigated 274 reported incidents connected to previously mentioned allegations. The number of reported sexual offences and harassment incidents are comparable to 2022. We have experienced that the trend in the number of reported (sexual) harassment incident reports follows the increased societal attention on this subject.

We are continuously working to improve awareness on these topics, such as by supporting employee communication on the issue of inappropriate conduct, dialogue with line management and HR representatives, and following up on reported integrity-related incidents. We use the outcomes of the ‘Employee engagementmonitor’, results of investigations, and signals to identify potential for continuous improvement of our integrity approach and our activities at the PostNL Group companies. Since October 2023, we have used a new e-learning module on integrity aimed at educating management and employees about our Business Principles, desired behaviour based on these principles, and reporting methods. This mandatory module is part of our regular onboarding programme. In 2023, we added a more explicit reference in our Business Principles on discrimination, (sexual) harassment, bullying, aggression and violence, and included a section on sustainability.

We work continually to create a company environment where people feel safe and empowered to speak up. In addition to case-specific investigations, we apply trend analysis on all reported incidents to identify structural issues that require further preventive actions. In 2023 we received one report of an alleged bribery case, which was promptly investigated. This case did not have a significant impact on our business. Furthermore, we did not receive any report related to alleged corruption cases.

After a brief period of candidate membership, as of January 2023 we became a member of the Business Integrity Forum of Transparency International. This initiative aims to stimulate the exchange of knowledge on the subject of integrity.

From 2024, we will align topics and metrics as much as possible in accordance with the new CSRD requirements, such as ESRS G1 ‘Business Conduct’.