1.2 CSRD governance

CSRD programme structure

We established a programme structure to implement the CSRD, with an expanded ESG and CSRD governance setup that includes a temporary CSRD Steering Committee. This committee, mandated by the Board of Management (BoM), oversees CSRD implementation, supports decision-making, and manages discussions related to, for example, materiality, policy, and target-setting. The CSRD implementation is temporarily integrated into structural consultation bodies and task forces for as long as needed to ensure successful and timely implementation.

Task forces, comprising members from Group Reporting, Group ESG Strategy, and the Business, with support from Risk Management and Internal Control (RMIC), work collaboratively and report to the CSRD Programme Manager on the progress and status. Group Reporting and Group ESG Strategy are together accountable for the organisation-wide CSRD compliance programme and, along with the programme manager, provide monthly updates to the Steering Committee, which is chaired by the CFO, the ESG topic owner for the BoM.

The Executive Committee (EC) receives quarterly updates on progress, and the BoM is the decision-making body for topics such as ESG KPIs and strategy, reporting these directly to the Supervisory Board (SB) committees. The SB has an ESG Committee focused on oversight of ESG in a broad sense, while the Audit Committee focuses on oversight of risk management, internal control, reporting and auditing of financial and non-financial information.

The general governance processes, controls, and procedures we have in place to monitor, manage and oversee sustainability topics are described in the Governance. More information on the BoM and the SB of PostNL, including their composition and diversity, roles and responsibilities, expertise and skills, and the information provided on, and sustainability matters addressed, are described on pages 118-126 in the Report of the Supervisory Board chapter and on pages 128-131 in the Corporate governance chapter.

Integration of sustainability-related performance in incentive schemes

More information on the integration of sustainability-related performance in the incentive schemes and the application of our Remuneration Policy during the year can be found on pages 144-154 in the Remuneration report chapter.

Statement on due diligence

PostNL is committed to responsible business conduct and due diligence, in line with our commitment to the UN Global Compact, which is embedded into the governance, strategy, and business model by ensuring that administrative, management, and supervisory bodies receive relevant information on sustainability matters. Sustainability performance is linked to incentive schemes, and material impacts, risks, and opportunities are thoroughly assessed in connection to the strategy and business model. More information can be found on pages 144-154 in the Remuneration report chapter and the Double materiality assessment.

Due diligence is an ongoing process that responds to and may trigger changes in our strategy, business model, activities, business relationships, operating, sourcing and selling contexts. Our process of due diligence involves an ongoing analysis of the actual and potential impacts of our business activities on people or the environment through consultations with impacted stakeholders, feedback mechanisms and desk researches on publicly available information. The outcome of our due diligence process is incorporated in our double materiality assessment. The sustainability statement may not include every impact, risk and opportunity or additional entity-specific disclosure that each individual stakeholder may consider important.

Yet, by involving affected stakeholders at every key step of the due diligence process, we ensure that these perspectives inform our decisions and actions. Information on how we capture stakeholders' interests and views can be found in the Interest and views of stakeholders. As part of responsible business conduct and due diligence, we identify and assess adverse impacts on people and the environment. How we pinpoint these adverse impacts can be found in the Double materiality assessment.

Addressing negative impacts on people and the environment is a priority as part of our commitment to responsible business conduct. The actions are taken to mitigate these impacts, and the effectiveness of these responsible business and due diligence efforts is closely monitored, tracked and communicated in Our performance subsections in the Environmental, Social and Governance disclosures throughout the Sustainability statement.

Risk management and internal controls over sustainability reporting

Senior management (first line) is responsible for the internal control environment within their area of responsibility and are required to perform self-assessments on the design and operating effectiveness of our internal control environment. This is monitored by risk management and compliance functions (second line) and the results are discussed in the Internal Control Committee (ICC), which includes senior executives and is attended by the external auditor. The information related to risk management and internal controls over sustainability reporting and the relation between the DMA and ERM, including our risk prioritisation methodology can be found in Basis for preparation , Double materiality assessment and on page 84 in the Risk and opportunity management chapter.