4.1 Business conduct

Our business principles are the cornerstone of our operations, guiding our decisions when engaging in business activities or forming partnerships. We expect that everyone associated with PostNL – employees, third parties, business partners, and suppliers – adheres to these principles. The business principles also outline the standards we uphold and what our stakeholders can expect from PostNL.

In line with the requirements of ESRS G1, we integrate our corporate culture with our business conduct, focusing specifically on adherence to the code of conduct and business principles. Key aspects of our corporate culture include promoting and communicating our business principles, whistleblowing and incident reporting mechanisms, integrity-focused e-learning programme, employee engagement monitoring, due diligence for delivery partners, integrity workshops, and reviewing Board of Management expenses.

More information on our corporate culture and business conduct can be found on pages 131-133 in the Business conduct and integrity approach section of the Corporate governance chapter.

4.1.1 Our strategy

Using our Double materiality assessment, we assessed and identified the most material sustainability topics, including those relating to the governance domain. More information on how our material topics relate to our value chain can be found in the Our value chain and material topics section within the General disclosures. Identifying our most material impacts helps us prioritise actions to prevent and mitigate sustainability issues we have identified.

Within the governance domain, we identified (potential) material impacts, risks or opportunities on the following topics:

• Corporate culture
• Protection of whistle-blowers
• Management of relationships with suppliers including payment practices
• Corruption and bribery.

More information on how we address these material topics can be found in the Our policies and Our performance later in this Business conduct section.

Connection to our strategy

As an organisation committed to sound business conduct, PostNL's business principles and integrity process provide the framework to conduct business ethically and responsibly. More information can be found in the Corporate governance chapter, specifically on pages 136-141, which provide a detailed explanation of how we uphold and foster an ethical and responsible business culture.

4.1.2 Our governance

PostNL’s supplier relationship management forms a strategic element of our operational and sustainability initiatives. By implementing a transparent procurement policy, consistent payment practices, and a comprehensive supplier evaluation framework, PostNL ensures its partnerships with suppliers align with corporate goals and regulatory requirements.

Supplier relationship management approach

PostNL maintains supplier relationships based on its procurement strategies with the company’s operational goals and sustainability commitments. Supplier interactions are governed by PostNL’s procurement policy, which highlights how supplier engagements are managed and how PostNL tries to minimise associated risks to avoid supply chain disruptions.

Procurement approach

PostNL adopts a hybrid procurement model, with centralised procurement by the Procurement and Services department overseeing most activities, while specialised areas such as (inter)national transport and contracting delivery partners handle specific sourcing needs. This approach enables departments to utilise their expertise in supplier management effectively while ensuring alignment with PostNL’s strategic objectives.

Risk mitigation through supplier assessments

To manage risks related to its supply chain, PostNL’s Procurement and Services departments uses several methods, such as risk workshops, plotting (essential) suppliers in Krajic matrices and a risk assessment matrix. This matrix categorises suppliers based on sustainability risk levels (green, yellow, red) and tailors follow-up actions accordingly. For instance, suppliers identified as “red” face on-site audits or visits, either by PostNL or third-party evaluators. Suppliers in high-risk regions are subject to more stringent checks, including regular visits or audits.

Ongoing monitoring and continuous improvement

PostNL continuously monitors supplier performance through evaluations, sustainability ratings, and improvement plans. For suppliers with identified risks or low sustainability ratings, PostNL works collaboratively to draw up improvement plans. Failure to comply with these plans may result in termination of the partnership. In this way, PostNL tries to professionalise its supply chain. More information on PostNL’s procurement policy can be found later in this section.

Timely payment practices

PostNL is committed to ensuring the timely payment of all supplier invoices, including those from both small and medium enterprises (SMEs) and non-SMEs, wherever possible. To achieve this, PostNL has introduced measures to streamline the payment process in a standardised manner. This includes the use of an automated system for invoice processing and payments, which operates on a weekly payment-run schedule. While the majority of payments are processed automatically, a defined procedure is in place to manage exceptions that require manual handling. Payment terms for suppliers are aligned with contractual agreements. Specifically, for SMEs, payment periods comply with Dutch legislation, which stipulates a maximum of 30 days.

Sustainable procurement

PostNL prioritises sustainability in its procurement processes. Through the sustainable procurement policy, PostNL emphasises both supplier selection and ESG criteria and support for local and certified suppliers.

Supplier selection and ESG criteria

Sustainability criteria are embedded within PostNL’s supplier selection process through a comprehensive evaluation of ESG performance. For instance, suppliers engaged by the Procurement and Services department are required to participate in assessments such as EcoVadis and comply with PostNL’s business principles as well as the set of guidelines for suppliers. Suppliers that do not meet these standards are required to submit improvement plans. Failure to comply may result in the termination of their contracts.

Support for local and certified suppliers

PostNL’s Procurement and Services department actively encourages suppliers to certify to foster long-term relationships. This aligns with PostNL’s circular economy goals by ensuring that suppliers operate sustainably and contribute to PostNL’s overall environmental targets.

Training and capacity building

At PostNL, the Procurement and Services department has conducted a series of training sessions to enhance engagement and dialogue with suppliers. These sessions and workshops have centred on sustainability, ethical procurement, and adherence to environmental laws and regulations. The sessions included guidance on integrating sustainability criteria into the supplier selection process.

Supplier code of conduct

PostNL has developed a code of conduct for its suppliers, which outlines the expected behaviour and compliance with ethical and sustainability standards. This code is incorporated into supplier contracts, and compliance is monitored through regular evaluations and audits.

Integration into supplier contracts

PostNL’s business principles and set of guidelines for suppliers are integral to our supplier contracts. Suppliers are required to comply with these guidelines, which cover a wide range of ethical, social, and environmental standards. For new suppliers, signing the business principles and guidelines is a prerequisite for entering into a business relationship with PostNL.

Ongoing compliance monitoring

PostNL assesses its suppliers’ adherence to the code and identifies areas for improvement. If a supplier is found to be in non-compliance, PostNL works with them to implement corrective actions. Suppliers that consistently fail to meet these standards may face contract termination.

Vulnerable suppliers

PostNL identifies vulnerable suppliers—those at significant economic or environmental risk—through its risk assessment processes. These suppliers may include those in high-risk geographical areas or industries facing significant ESG challenges.

More information on the skills, expertise and composition of the Board of Management and Supervisory board can be found on pages 128-131 in the Corporate governance chapter and pages 118-122 in the Report of the Supervisory Board.

4.1.3 Our policies

At PostNL, we are dedicated to maintaining the highest standards of business conduct. To support this, we have implemented a comprehensive integrity policy, a whistleblowing policy, and the group procedure for fraud prevention, alongside other group-wide procedures, and codes of conduct. These measures enable us to manage our operations in alignment with our business principles and core values, ensuring integrity and transparency across all levels of our business.

Additionally, PostNL’s supplier relationship management forms a strategic element of our operational and sustainability initiatives. By implementing a transparent procurement policy, consistent payment practices, and a comprehensive supplier evaluation framework, PostNL ensures its partnerships with suppliers align with corporate goals and regulatory requirements.

Integrity policy

PostNL is dedicated to conducting its operations responsibly and adheres to the PostNL business principles and core values. This entails an ethical and transparent approach to business practices. At PostNL, integrity is defined as compliance with the PostNL business principles. The aim of this group policy on integrity, applicable to all PostNL entities and it’s suppliers, is to establish the mandate and responsibilities regarding integrity-related matters. A well-functioning integrity framework must be maintained, which incorporates:

• Establishing and upholding the PostNL business principles
• An integrity office overseeing the integrity programme
• An Integrity Committee advising the Board of Management
• Handling integrity-related incidents and reporting.

Our integrity programme focuses on governance, training, awareness, and response. The integrity office manages the integrity programme on a daily basis. As part of the programme, policies are reviewed and updated annually to align with laws, regulations, and best practices, ensuring transparency for all stakeholders and maintaining a robust speak-up mechanism. The office is also responsible for the monitoring of the integrity e-learning. All employees in managerial, procurement, sales and head office functions are required to perform the mandatory bi-annual integrity e-learning, including the BoM and EC members, and is part of the onboarding process for new employees. While the e-learning is not mandatory for SB members, the director Audit & Security has regular meetings with the Chairs of the SB and the AC where integrity-related topics, policies and issues are addressed. The training is also accessible to other employees and they are invited to follow the training on a voluntary basis.

Whistleblowing policy

PostNL's whistleblowing policy, developed in accordance with the Dutch law on 'Wet Bescherming Klokkenluiders' and the Belgian implementation of the EU directive, serves as a critical mechanism for maintaining transparency, combating fraud, bribery, and corruption, and protecting whistleblowers. This policy outlines the procedures for reporting any suspected misconduct, whether it involves current or former employees, flexible workers, interns, subcontractors, or any other stakeholders associated with PostNL group companies. Both the integrity and whistleblowing policies are applicable to both internal and external stakeholders. The integrity policy also refers to the whistleblowing procedure, both of which are publicly available on our website.

PostNL strongly encourages all stakeholders to promptly report any concerns regarding suspected fraud, questionable accounting practices, or other forms of misconduct. This helps to safeguard our operational integrity and supports compliance with contractual obligations to our customers. More information on these actions and initiatives can be found on pages 136-141 in the Ethics and compliance section of the Corporate governance Chapter.

Procurement policy

PostNL is a large enterprise with global operations, which adds complexity to its procurement and sourcing landscape. While PostNL has a centralised Procurement and Services department responsible for managing procurement practices and supplier relations, in certain cases, it has pragmatically decentralised processes to specialist departments or functions for more effective management.

The general aim of the policy is to enhance the professionalism of purchasing within PostNL by leveraging consolidated purchasing power, reducing the supplier base, emphasising sustainable procurement practices, mitigating risks, and ensuring adherence to applicable laws and regulations. This approach is designed to optimise service delivery to our internal customers. By integrating diverse procurement and sourcing methodologies into a cohesive group-wide policy, PostNL seeks to simplify purchasing processes and ensure alignment across the organisation with the company’s strategic priorities and governance framework.

The procurement policy outlines the following:

• Different approaches of procurement used in the organisation
• Compliance with all applicable laws and regulations and appropriate social and governance practices governing our local and global businesses
• Promotion of procurement procedures in a way that reduces environmental impact while selecting suppliers and procurement of goods and services
• Suppliers are provided with equal opportunities for transactions with the PostNL group.

The enforcement of this group policy across our upstream value chain helps create a positive impact through cooperation with our suppliers. This policy mandates that all procurement activities should be carried out in accordance with the PostNL business principles and the set of guidelines for suppliers. PostNL is committed to reducing the number of suppliers and fostering long-term partnerships. As part of the contract renewal process, suppliers are informed of updates to the procurement policy and its accompanying annexes. These documents are publicly available on PostNL’s website, ensuring transparency and accessibility. Key documents, such as the PostNL business principles and the set of guidelines for suppliers, are integral components of supplier contracts.

Group procedure on fraud prevention

At PostNL, we are committed to upholding the highest standards of integrity and ethical conduct across all aspects of our business. To safeguard our operations and reputation, we have established comprehensive fraud prevention, anti-bribery, and anti-corruption policies, procedures, and reporting mechanisms. These measures ensure compliance with applicable laws and regulations, both in the Netherlands and the international markets in which PostNL operates.

Given the global scope of our activities, we recognise the importance of adhering to international anti-bribery and anti-corruption legislation, including the UK Bribery Act 2010, the U.S. Foreign Corrupt Practices Act (FCPA), and the UN convention of anti-corruption and bribery (UNCAC). Our internal procedures are developed in alignment with these frameworks, as well as relevant Dutch legislation, to ensure that PostNL's business practices are in compliance with legal requirements.

This approach is especially critical when interacting with third parties globally, ensuring that all interactions, particularly those within jurisdictions governed by the UK Bribery Act and FCPA, adhere to these stringent standards. PostNL's policies guide our conduct and mitigate risks related to corruption and bribery, supporting our commitment to business integrity across the value chain.

Monitoring policies

The implementation of these group policies throughout our value chain establishes a robust foundation for conducting business ethically, fostering positive impact, and reducing potential regulatory, legal, and reputational risks associated with misconduct. The policies and business principles are communicated to various stakeholders via tailored channels: for employees, these are accessible through addenda to employment contracts, integrity e-learning, or the intranet; for suppliers and delivery partners, they are incorporated into contracts or available via our website. Responsibility for these policies, including their execution, implementation, and monitoring, has been delegated by the BoM to the director of Audit & Security. This delegation, and thus ownership, also encompasses the PostNL business principles, the PostNL group procedure on fraud prevention, and the PostNL group procedure on whistleblowing. Monitoring involves ongoing review and reporting by the Corporate Security Officer, regular audits, compliance checks, and the reporting of incidents. The Integrity Committee evaluates the reports and processes on a quarterly basis.

More information on our business principles, alongside other group-wide procedures and codes of conduct, can be found on pages 131-133 and pages 136-137 in the Corporate governance chapter, while more information on the group procedure for fraud prevention is available in the Prevention of fraud, bribery and corruption section in the Corporate governance chapter.

The director of Procurement and Services is responsible for the execution, implementation and monitoring of the procurement policy. The monitoring process includes periodic review and checks to ensure that group-wide procurement practices are in line with the latest standards. The effectiveness of the policy is monitored and improved by:

• Ensuring that the different departments and personnel in the organisation responsible for procurement are from time to time informed and are aware of the procurement policy and procedure(s) and apply it effectively in practice
• Ensuring that procurement spend is compliant (according to the outlined contractual agreements)
• Having regular evaluations, including sustainability assessments, with contracted suppliers to ensure they comply to the procedures/KPIs/agreements mentioned in the contracts.

These checks facilitate ratings for sustainability assessments such as the Carbon Disclosure Project (CDP), Ecovadis, the MVO-Register foundation/Fira, the Workforce Disclosure Initiative (WDI) and the International Post Corporation (IPC) and compliance with various international certifications such as ISO 14001, ISO 45001 and BREEAM.

4.1.4 Our performance

In 2024, we conducted a range of initiatives aimed at addressing the key material impacts, risks and opportunities related to our business conduct. In this section, we highlight our robust processes to monitor, measure and assess the effectiveness of these actions, ensuring continuous improvement and alignment with our strategic objectives.

Corporate culture

Actions

To support the execution of our policies, we have undertaken the following actions:

• Conducted an annual update and approval of integrity and security-related policies and procedures
• Promoted awareness of integrity-related policies and procedures, such as business principles
• Discussed integrity and security-related issues in the Integrity Committee and recommended improvements
• Reported on integrity to the Board of Management, Executive Committee, and Supervisory Board
• Developed a code of conduct
• Implemented due diligence for delivery partners.

Annual update and approval of integrity and security-related policies and procedures

In line with our commitment to uphold the highest standards of integrity and security, PostNL regularly reviews and updates its policies and procedures. The PostNL business principles were last updated in November 2023, with a comprehensive renewal process currently underway. These updated principles are expected to be ready for implementation in 2025.

Promoting awareness of integrity-related policies and procedures

At PostNL, integrity is at the heart of our operations. We actively promote awareness of our integrity-related policies, including the business principles, among employees, suppliers, and business partners. These principles are accessible through various platforms such as employee contracts, integrity e-learning modules, and the company intranet. In 2024, the director of HR and the corporate security officer visited each BU management team to raise awareness and promote adherence to corporate policies.

By January 2024, almost 99% of the target group, or 2,850 employees, had successfully completed the integrity training. Additionally, our policies and principles are readily available to suppliers and delivery partners through contractual agreements and our website.

Development of the code of conduct

We are currently developing an enhanced code of conduct, which will provide a comprehensive framework that incorporates the business principles alongside the existing codes of conduct. The new code of conduct will be rolled out in 2025 and is applicable to all PostNL entities, suppliers, and business partners, ensuring a consistent approach to integrity and ethical behaviour across the entire organisation.

Mitigation of potential integrity risks in the value chain

At PostNL, maintaining and strengthening integrity across the entire value chain is a key priority. We recognise the importance of robust integrity practices not only for our own workforce but also for the broader network of value chain partners. To ensure that integrity risks are effectively mitigated, PostNL's Integrity Committee convenes quarterly to review and resolve any reported breaches or issues.

Based on these discussions, lessons are extracted, and recommendations for improvements are formulated. Our administrative, management, and supervisory bodies play a crucial role in promoting a strong corporate culture and mitigating integrity risks in the value chain. More information on the skills, expertise and composition of the Board of Management and Supervisory board can be found on pages 128-131 in the Corporate governance chapter and pages 118-122 in the Report of the Supervisory Board chapter.

This proactive approach enables PostNL to address potential integrity-related risks and ensure consistent standards throughout the value chain. In line with our commitment to integrity, PostNL continuously updates its policies and frameworks. The integrity policy was most recently revised in August 2019.

Targets

Currently, no formal strategic or corporate-level targets have been established specifically for managing corporate culture. However, PostNL is committed to continuously improving its integrity programme. This includes regular reviews and updates to the integrity policy and procedures, as well as ongoing monitoring of progress in key areas, such as the completion rates of mandatory integrity e-learning courses. These actions safeguard our commitment to integrity and promote a culture of accountability and openness within the organisation.

Protection of whistleblowers

Actions

Whistleblowing reporting and investigation process

The whistleblowing reporting process at PostNL encourages all stakeholders, including current and former employees, contractors, interns, and volunteers, to report any suspected misconduct, including legal violations, threats to public safety, fraud, and irregularities concerning company management. Reports can be made to line managers, the director of Audit & Security, or directly to the Audit Committee for accounting-related issues. Specific procedures are in place for allegations involving senior executive management or Audit & Security staff, requiring reports to be made to the chair or vice chair of the Supervisory Board or the chair of the Audit Committee. Confidentiality is maintained, and retaliation against whistleblowers is strictly prohibited.

The intention remains to provide clarity for all internal and external stakeholders about approved desired and undesirable behaviour, including speak-up mechanisms. This is an ongoing action and has existed since the integrity policy and whistleblowing procedure were formed in May 2011. This procedure was last updated in June 2023.

Targets

Currently, no formal strategic or corporate-level targets have been established specifically for managing protection of whistleblowers. Given the delicate nature of whistleblower protection, it is considered unsuitable to set a specific target for this. Effectiveness is assessed through the timely resolution of 100% of received reports within an appropriate time frame. Whistleblowers are provided with updates at least quarterly.

Management of relationships with suppliers including payment practices

Actions

Sustainable procurement training/workshop

To develop knowledge-sharing and raise awareness of sustainable procurement, PostNL’s Procurement and Services department periodically organises workshops. These sessions aim to enhance expertise in sustainable purchasing and promote the dissemination of best practices throughout the organisation, supporting the professionalisation of our engagement with suppliers. This ongoing activity is embedded across various procurement functions within PostNL, reflecting its relevance across our operations.

Supplier ESG ratings collection

We work closely with our suppliers to continuously enhance the sustainability of the supply chain. Supplier performance is monitored through evaluations and external sustainability assessments, including platforms such as EcoVadis and the MVO-Register. Where necessary, improvement plans are developed to address identified gaps. PostNL strongly advocates for contracted suppliers to achieve recognised certifications, such as ISO standards, actively participate in sustainability initiatives like CDP and SBTi, and demonstrate positive outcomes in independent sustainability assessments.

The objective of this initiative is to steadily increase the proportion of certified or audited sustainable suppliers within our supply chain. This is achieved both by collaborating with new suppliers and by engaging with existing suppliers to support their development. Through constructive dialogue, we identify areas for improvement and jointly establish improvement plans. Suppliers who are unable or unwilling to meet our sustainability expectations may face the risk of non-renewal of their contracts or, ultimately, termination of the partnership. This approach underlines our commitment to embedding sustainability throughout our supply chain.

Development of code of conduct

Our business principles describe what we expect from our business relations and everyone who works with or for PostNL, including delivery partners, suppliers and so on, as well as what they can expect from us. The principles, or code of conduct, provide guidance on how to manage and maintain relationships with business partners (suppliers) through contractual agreements as well as shared expectations.

The updated code of conduct, which provides integral coverage of the business principles, and the existing code of conduct, is currently being developed and will be rolled out in 2025, and will apply all PostNL entities and their suppliers and business partners.

Implementation of due diligence delivery partners

PostNL is committed to upholding good social working conditions for everyone who collaborates with us, including our business partners. We adhere to applicable laws, regulations, and our internal business principles. To strengthen our approach, we introduced due diligence guidelines for our delivery partners at Parcels in the Netherlands between January and April 2024, while at Parcels in Belgium, it commenced on 1 February 2024.

More information can be found in Our policies within this section.

Targets

No strategic or corporate-level targets have been defined to manage the topic of management of relationship with suppliers. However, the effectiveness of the procurement policy and related actions is tracked using internal departmental targets such as increasing the share of contracted suppliers with certification or satisfactory assessment/evaluation on sustainability to foster better supplier relations and ensure value chain sustainability.

Metrics

PostNL Payment practices as indicated
2023 - 2024

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Across all categories, the average time taken to pay an invoice is below our standard payment term, at 29 days. In total, 85% of invoices are allocated to the Netherlands, 8% to Belgium, and 7% to Spring. In the Netherlands, the largest supplier categories relate to transport and fleet (34%) and human resources (26%). Of these, 74% of transport and fleet invoices and 62% of human resources invoices are settled within the standard payment term of 30 days. At present, there are no outstanding court cases concerning our payment practices. These payment practices represent newly introduced metrics as part of the 2024 implementation of the CSRD. As a result, no comparative data from previous periods is available.

Corruption and bribery

Actions

Alignment with ISO 37001 management system

In 2024, PostNL aligned its fraud prevention and anti-bribery and anti-corruption procedures with the ISO 37001 standard for anti-bribery management systems, reinforcing our commitment to ethical business practices. The ISO 37001 standard is designed to enhance risk assessment and due diligence procedures, improving our ability to identify and mitigate bribery and corruption risks.

Regular monitoring ensures that our anti-bribery framework remains current and effective amidst evolving risks and regulations. This initiative supports compliance with the ESRS G1 Business Conduct standard, contributing to a more robust approach to fraud prevention.

Promote awareness with integrity-related policies and procedures

PostNL promotes awareness of its integrity policies and procedures through the PostNL integrity programme, which has been in place since the introduction of the fraud prevention procedure in 2017. This programme is built on a strong foundation of risk management and an internal control framework, supported by the PostNL business principles, the group policy on integrity, the group procedure on whistleblowing, and other relevant policies.

To ensure employees, contractors, and associated third parties understand and adhere to these policies, PostNL provides ongoing awareness training, including integrity e-learning, conducts regular risk assessments, and carries out investigations when necessary. Other trainings include:

• Special training for purchasing and services (real estate and procurement)
• Special training for sales (primarily on anti-cartel)
• Training for the security investigators
• Professional education requirements for chartered professionals, such as auditors, risk managers and compliance officers.

Training is also given to members of the administrative, management and supervisory bodies. Business principles are explained to new members who join the Supervisory Board. For senior management, there is a security screening and an introductory meeting where an explanation is given on relevant areas such as the integrity policy and business principles.

Our integrity policies are publicly accessible via our website and on the intranet for employees, reflecting our commitment to a transparent and ethical operational environment. This continuous action ensures all stakeholders are well-informed and contributes to minimising fraud risks.

Incident reporting and investigation process

PostNL's incident reporting process ensures that employees, contractors, agents, and associated third parties can report suspected fraud, bribery, or corruption promptly and confidentially. Reports can be made either through line managers or directly to the PostNL integrity office. All reports are thoroughly investigated by the Integrity Committee, which monitors the investigation process and reports findings to the Board of Management and the Audit Committee. Special procedures are in place for cases involving executive management or Audit & Security staff, as outlined in the PostNL group procedure on whistleblowing.

All allegations and incidents are investigated by security and reported to the BoM and the SB through the Integrity Report, with corruption and bribery always treated as priority cases. Line managers are required to report any breaches of PostNL’s business principles via the PostNL incident reporting system to the director of Audit & Security, who is responsible for overseeing annual reviews and ensuring compliance with the procedure. This measure has been in place since the introduction of the fraud prevention procedure in 2017 and is subject to continuous evaluation for improvement. More information on the incident reporting and investigation process can be found on pages 136-141 in the Ethics and compliance section in the Corporate governance chapter.

Security investigators and internal auditors are separated from the chain of management. Internal Audit & Security is part of Audit and Security, and as such reports directly to the CEO and the Chairs of the Audit Committee and the Supervisory Board. This structure is codified in our integrity policy, which encompasses both the whistleblowing procedure and the group’s anti-fraud and anti-corruption framework.

Whistleblower protection and process timeliness

PostNL’s whistleblowing procedure includes specific measures to protect whistleblowers from retaliation. The confidentiality of whistleblowers is strictly maintained, and their identity is safeguarded. Whistleblowers receive updates at least quarterly, and general information on the investigation's progress and outcome is provided within three months, unless it could harm the investigation. The aim is to ensure that all reported incidents are fully investigated, and fact-based outcomes are provided for relevant breaches.

Records of investigations are retained for seven years unless otherwise required by law. This process has been in place since the formation of the integrity policy and whistleblowing procedure in May 2011, with the most recent update implemented in June 2023. This action is continuously evaluated and updated to reflect best practices.

Targets

PostNL has not established formal strategic or corporate targets related to the prevention and detection of corruption and bribery. Instead, effectiveness is measured through the management of the integrity approach framework. This framework ensures that all reported breaches of business conduct and integrity-related policies are investigated, with appropriate actions taken for remediation, sanctioning, and process improvements.

In terms of training, PostNL’s business principles are delivered through an e-learning platform, developed in collaboration with an external learning and development consultant. Progress is periodically tracked to monitor the completion of the training modules, reinforcing the company's commitment to integrity and ethical conduct.

Metrics

PostNL Confirmed incidents of corruption and bribery as indicated
2023 - 2024

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During 2024, PostNL or its employees were not convicted and were not fined for violation of anti-corruption and anti-bribery laws. This represents a new metric introduced as part of the 2024 implementation of the CSRD. As such, no comparative data from previous periods is available.