2.1 EU Taxonomy on sustainable activities

Since 2021, the EU Taxonomy on sustainable economic activities applies to PostNL. The EU Taxonomy is the EU's dictionary of sustainable economic activities designed to promote transparency, counter greenwashing, and drive the shift of capital towards a future sustainable economy. In this chapter, PostNL provides the mandatory disclosures required.

The Taxonomy is a classification system for companies to disclose the extent to which business activities are covered by and aligned with specific sustainability criteria. The main objectives of the EU taxonomy are to provide a reference framework aimed at orienting financial and business investment strategies towards sustainable activities and to accelerate the green and sustainable transition of economic players. Reaching these objectives is essential to meet the EU's ambition of becoming climate neutral by 2050.

2.1.1 EU Taxonomy statements

This chapter contains an elaboration of the assessment on the classification of eligible and aligned activities in accordance with the EU Taxonomy, following the summary provided in the EU Taxonomy on sustainable activities section of the Environmental value chapter. Given the evolving nature of legislation, our eligibility and alignment assessments follow an iterative approach. These efforts lay the groundwork for future EU Taxonomy implementation and reporting.

The EU Taxonomy prescribes quantitative and qualitative reporting on predefined KPIs. In this section, we present the share of PostNL’s consolidated total operating revenue (turnover), capital expenditure (capex) and operating expenses (opex) for the reporting period 2024. 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, Commission Delegated Regulation (EU) 2021/2178 (EU Taxonomy), Delegated Regulation (EU) 2023/2486 of 27 June 2023 (Environmental Delegated Act) and the Delegated Regulation (EU) 2023/2485 of 27 June 2023 amending the Climate Delegated Act.

Basis of preparation

Our approach to report in accordance with the relevant EU Taxonomy regulation includes the following key steps:

• Evaluation of PostNL's activities in relation to the EU Taxonomy classification of economic activities
• Evaluation of technical specifications of activities and related assets in relation to substantial contribution and Do No Significant Harm (DNSH) criteria
• Evaluation of Minimum Safeguards (MS) criteria based on existing policies and business practices
• Calculation and reporting of the KPIs.

Identification of economic activities

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 when the activity contributes substantially to one of the six environmental objectives, DNSH to the other five objectives in accordance with the DNSH criteria, and complies with Minimum Safeguards.

Assessment of technical screening criteria

In 2021 and 2022, the technical screening criteria for substantial contribution was specified by the EU for 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.

These criteria relate to how an economic activity can contribute substantially to one or more of the environmental objectives, in combination with criteria for DNSH to the other environmental objectives. There have been no changes in the criteria of the environmental objectives for 2024. In 2023, only eligibility was mandatory for the four new environmental objectives. As of 2024, alignment is also mandatory.

Minimum 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 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 Governance disclosures.

EU Taxonomy KPIs

For 2024, PostNL reported on the KPIs total operating revenue (turnover), capital expenditures (capex) and operating expenditures (opex). The starting point of our Taxonomy allocation methodology are the financial statement line items. The reported figures have been determined based on the allocation of activities to the Taxonomy, derived bottom-up for all PostNL reporting units. 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. Only the road activities are eligible for PostNL, transport by air is considered to be a non-eligible activity for PostNL. 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.

Significant estimates and judgements

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. 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 PostEurop 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.

For CCM 6.4 (Operation of personal mobility devices, cycle logistics) and CCM 6.5 (Transport by motorbikes, passenger cars and light commercial vehicles), 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.

The share of Taxonomy-aligned activities for CCM 6.5 is currently built up from electric scooters. For small e-trucks 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.

2.1.2 Performance

The EU Taxonomy prescribes quantitative and qualitative reporting on predefined KPIs. On the previous page we present the share of PostNL’s consolidated total operating revenue (turnover) and capital expenditure (capex) for the reporting period 2024.

Turnover

This KPI reflects the external revenue recognised in accordance with IAS 1 par. 82(a), and as such aligns with the ‘Total operating revenue’ reported in the consolidated income statement. To determine the portion of net turnover derived from Taxonomy-eligible activities for each revenue-generating stream, PostNL evaluated the extent to which these activities are encompassed by the EU Taxonomy framework.

The revenue deemed eligible under the EU Taxonomy primarily originates from activities related to the collection, sorting, and delivery of parcel and mail items. Accordingly, the eligible and aligned turnover under the EU Taxonomy pertains entirely to these logistics operations. Conversely, revenue not eligible under the EU Taxonomy is linked to the transportation of mail and parcels by air, services provided by external operators, and the coordination of logistics activities.

The allocation of revenue across various EU Taxonomy economic activities is determined based on the proportional operational costs associated with each activity. A detailed breakdown of turnover by EU Taxonomy activity can be found in the previous section.

The EU taxonomy-aligned turnover 2024 is in line with prior years.

Capital expenditures

This KPI covers the additions to Property, plant and equipment (PPE) 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 CCM 6.4 (Operation of personal mobility devices, cycle logistics) of €2 million (2023: €2 million) relates for €1 million to PPE and €1 million to RoU-assets. The breakdown of the aligned capex for activity CCM 6.15 (Infrastructure enabling low-carbon road transport and public transport) shows expenditures for PPE of €26 million (2023: €80 million) and for RoU assets of €8 million (2023: €15 million). The decrease in expenditures for PPE is following the completion of some NLI's in 2023 which caused less capital expenditure for 2024. The full table regarding the capex can be found in the previous section.

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 €64 million (2023: €59 million), which represents around 2% (2023: 2%) of PostNL's total €3,218 million operating expenses in 2024 (2023: €3,090 million). 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 exempt from the calculation of the numerator of the opex KPI for the EU Taxonomy and is therefore reported as being equal to zero. The full table regarding the opex can be found in the previous section.

Looking ahead

The current technical screening criteria offer limited scope for postal operators to achieve progress in alignment. In-depth analysis and discussions within a working group facilitated by PostEurop have demonstrated that meeting certain DNSH criteria is both practically and economically unfeasible. To address this, PostEurop, on behalf of its members, including PostNL, submitted a proposal to the European Commission for postal-specific economic activities and screening criteria. This proposal aims to establish criteria that are realistic and appropriate within the context of postal business models.

By introducing sector-specific criteria, European postal operators would be able to make meaningful investments in sustainable activities that align with their operational frameworks. Simultaneously, this would enable postal companies to achieve greater alignment in their EU Taxonomy reporting, fostering sustainable growth within the industry.