3.2 Workers in the value chain

At PostNL, we recognise that fostering a responsible value chain not only drives business success but also contributes to societal value by addressing sustainability challenges, such as reducing carbon emissions, promoting fair labour practices, and ensuring efficient resource use.

In this section, we elaborate on material topics such as health and safety, working hours, and safeguarding against violence and harassment in the workplace. Our workers in the value chain consist of delivery partners with personnel providing services in accordance with a transport agreement signed with PostNL, and self-employed delivery partners providing services in accordance with a transport agreement signed with PostNL.

3.2.1 Our strategy

With help of our Double materiality assessment, we assessed and identified the most material sustainability matters, also those relating to our workers in the value chain. For further information on how our material topics relate to our value chain, please see section Our value chain and material topics within the General disclosures. For more information on how we engage in a dialogue with our workers in the value chain, please see section Interests and views of stakeholders within the General disclosure. Identifying our most material impacts helps us to prioritise our actions to prevent and mitigate identified sustainability matters.

For our workers in the value chain, we identified (potential) material impacts, risks or opportunities on the following topics:

• Working time
• Health and safety
• Measures against violence and harassment in the workplace.

More on how we address these material topics can be found in Our policies and in Our performance later in this Workers in the value chain section.

Connection to our strategy

PostNL, a people-centric company, relies on its workforce and supplier relationships to stay competitive and achieve its strategic goal of being the preferred delivery provider. To safeguard its future, PostNL's corporate strategy focuses on delivering a distinctive customer experience through nine strategic priorities. This includes focusing on key ESG topics from the Double Materiality Assessment, while also improving human rights due diligence.

For a more elaborate explanation on how we invest in our people, please see pages 31-35 in Our strategy chapter.

PostNL identifies various categories of value chain workers:

• Workers working for upstream suppliers that (can) work on our site providing purchased services, which could include logistics, consulting, marketing services, or maintenance activities.
• Workers working for contractors hired by PostNL working in our operations to deliver work or services. Services outsourced by PostNL to subcontractors and third-party providers.
• Workers working for downstream customers as direct end-user's of PostNL's service and business clients of PostNL, categorized by risk levels.

The visual on the previous page provides a detailed depiction of our material impacts and risks relating to our workers in the value chain; as discussed above, these are only applicable to delivery partners (work contracted out). No material risks or impacts related to child labour, forced labour, or compulsory labour were identified. Also, no material positive impacts on value chain workers were identified.

3.2.2 Our governance

At PostNL, we aim to create a safe and inclusive environment for everyone working with or for us, including the employees of our delivery partners who represent us daily. Through direct and indirect engagement, structured interactions, and accessible grievance mechanisms, we work collaboratively to improve conditions, minimise risks, and foster a respectful, transparent partnership across our value chain.

Engagement with our workers in the value chain

We aim to create a culture where everyone working for or with PostNL feels safe and empowered to share their views. A key part of our operations involves delivery partners, whose workers represent us daily. While responsibility for worker engagement rests with these partners, we ensure engagement to gain insights into their workers’ conditions and satisfaction. This is central to our due diligence, informing decisions and managing impacts.

Direct engagement

Collaboration barometer

Each year, PostNL conducts a collaboration barometer survey to systematically assess the satisfaction of our delivery partners and their workers regarding their collaboration with PostNL. This survey serves as our primary form of direct engagement with delivery workers, who are invited to share their perspectives through a set of targeted questions. The survey covers a wide range of operational topics, allowing us to identify areas of dissatisfaction, evaluate the effectiveness of existing measures, and pinpoint where further improvements are needed.

Ability to raise concerns
The survey allows delivery partners and their workers to raise concerns about PostNL’s processes and interactions, helping us address potential issues and improve collaboration. The director of Sourcing Netherlands oversees the process for all Dutch delivery partners, while the director of Sourcing Belgium manages it for the Belgian networks. Effectiveness is measured by participation rates and annual reviews of survey content. In 2024, we prioritised increasing participation through newsletters and on-site engagement with delivery partners and workers.

Indirect engagement

Sounding board group

PostNL has established a delivery partner sounding board group within Parcels Netherlands, who act as representatives of themselves and their workers, including women and migrant workers, on matters related to their collaboration with PostNL. The topics discussed within this forum can include any material negative impacts identified for workers in our value chain, such as measures to prevent violence and harassment in the workplace, health and safety protocols, and working hours. In line with our commitment to transparency and due diligence, a member of this sounding board group was invited to participate in the PostNL double materiality external stakeholder validation meeting, offering their insights and perspectives on various issues.

Group agenda
The group meets three times a year, covering all stages of engagement and focusing on informing or consulting delivery partners about decisions or developments that may affect them. Agenda items for discussion can be proposed by both PostNL and the sounding board members, ensuring a balanced and collaborative approach. The director of Sourcing Netherlands oversees this process, ensuring that the outcomes of these discussions inform PostNL’s broader strategic approach as part of their operational responsibilities.

Evaluation of group
The effectiveness of the sounding board group is evaluated by asking participating delivery partners to assess its functioning after each meeting, allowing us to make any necessary improvements to the process.

Structural conversation with local sourcing specialists

Direct interaction between PostNL’s local sourcing specialists and delivery partners is key to maintaining strong partnerships. Delivery partners represent both their business interests and those of their workers within our operations. In the Netherlands and Belgium, structured meetings are held at least annually between sourcing specialists, depot or process managers, and delivery partners, ensuring alignment and addressing specific needs. Additional meetings can be arranged as needed by either PostNL or the delivery partners throughout the year.

Evaluations and reviews
These interactions cover a wide range of topics, including potential material negative impacts for workers within the value chain, encompassing all stages and forms of collaboration. For instance, one aspect of these annual conversations is the joint review by the sourcing specialist and delivery partner of the structure of delivery routes. This evaluation ensures that routes can be completed within the legal working time limits, with adjustments made as required. The local sourcing specialists are operationally responsible for ensuring these discussions take place and that their outcomes guide the approach to delivery partner engagement at a site level. Within Transport, adherence to regulations concerning rest and driving times is embedded into our planning systems.

Monitoring the process
The overall responsibility for overseeing this process lies with the director of Sourcing Netherlands for our Dutch business units (Transport, time critical (TGN), Extra@Home, Mail in the Netherlands, and Operations Netherlands) and the director of Sourcing Belgium for our Belgian networks (Parcels Belgium and Logistics Solutions Belgium). Local sourcing specialists are required to document the outcomes of these discussions in our internal systems to enable the Sourcing department to monitor their completion and effectiveness.

Grievance and remedy

At PostNL, we want to ensure that our operations and those of our partners and suppliers respect and uphold human rights standards and labour practices. This includes acknowledging our responsibility to provide or support in remediation when our actions or policies result in or contribute to material negative impacts on workers in our value chain. Our commitment to providing access to remedy is set out in our Human Rights policy. 

PostNL is committed to ensure all workers in the value chain that may be negatively affected are able to access our grievance mechanism and channels to raise concerns in relation to each material impact identified as part of our Double materiality assessment in the General disclosures. Any external stakeholder of PostNL has access to our central grievance mechanism and all grievances raised through this mechanism are assessed.

Grievance mechanisms and channels to raise concerns

PostNL provides a central grievance mechanism where workers in the value chain can report (suspected) violations or other potential human rights issues in our own operations or our value chain. The process to file a report is outlined in our Group Procedure on Incident reporting. PostNL management is required to report any (suspected) integrity-related violations occurring within PostNL in the central incident reporting system, including those involving workers in the value chain (Group Procedure on Incident Reporting). Further details on incident reporting and investigations can be found in Our policies within the Governance disclosures.

In addition, delivery partners and their workers can also share concerns or grievances directly with locally responsible PostNL management or Sourcing specialists. In case of health and safety incidents and complaints involving delivery partner workers working for PostNL, PostNL expects its delivery partners to enable their workers to report such incidents, register the incident themselves and, where necessary implement remediating measures to avoid reoccurrence. In case of general complaints or concerns shared by delivery partner workers not related to (severe) human rights issues, the report can be addressed directly by local management in collaboration with the local Sourcing specialist. They define the follow-up actions. In case of an (alleged) breach of our business principles or relevant laws and regulations responsible management is required to report these in our central incident reporting system (IRIS).  

Providing remedy

Responsible operational management and Sourcing develop a specific remediation plan tailored to the nature and severity of the specific case based on Security’s investigation findings (where applicable) and any additional information collected by the Sourcing department. In case of severe violations of a worker’s rights by one of our delivery partners, PostNL can exercise the right to terminate the business relationship. Where appropriate, affected workers are involved in the design of remediation measures to ensure their needs and perspectives are adequately addressed. 

In case of proven violations of law or policy PostNL will, where appropriate and permitted by law, take immediate appropriate corrective action (Human Rights policy). More information on the Human Rights Policy can be found in Our policies within the Own Workforce section.

Transparent communication

A person filing a report through the central grievance mechanism is informed that their report has been successfully received within a period of seven days. Within three months they will receive information on the assessment of their report by local operational management or Security and informed of its main findings. In case the report was made directly to local operational management or Sourcing, the local Sourcing specialist will inform the reporting party on the status of their report. 

In line with privacy protection and information confidentiality we ensure that information is shared on a ‘need to know’ basis or when the parties involved have a right to receive it. During an investigation restraint and careful consideration is given to the (timing of) communication towards both the person(s) involved and other stakeholders. In urgent cases, immediate action is taken to address the situation and mitigate potential risks. If the investigation confirms that a violation has occurred, the affected parties are informed of the next steps and the remediation measures to be implemented.

Assessing effectiveness of remedy

PostNL monitors effectiveness of remediation at certain stages in the follow-up process, depending on the specific issue and the remediation plan. Remediation is covered by the regular risk inventarisation and evaluation procedures (as part of our health and safety management system), allowing us to monitor the effectiveness of remediating measures. PostNL Sourcing also keeps track of incidents reported per delivery partner, where multiple incidents of the same nature can lead to increasingly stringent remediating actions. In addition, we perform analysis across integrity related incidents reported through our central grievance mechanism to identify areas where action is required.

Operational-level grievance mechanism

PostNL offers an operational-level grievance mechanism in the form of our Group Whistleblowing Procedure and our Group Procedure on Incident reporting, both of which are applicable to all PostNL entities. Any (suspected) violation of the PostNL business principles, human rights or applicable laws and regulations are to be reported through this grievance mechanism. This mechanism allows any affected individual – or their representative - across the value chain to file a report directly through mail, chat or phone with the Integrity Office or the Security Office of PostNL. These channels are publicly available to all internal and external stakeholders on our website. In addition to the availability of direct channels, PostNL managers can also file a report in the incident registration tool (IRIS) on behalf of workers in the value chain, see earlier in this section. Reports can also be made anonymously through these channels.

All grievances and follow-up actions reported through these channels are centrally logged into IRIS to maintain a single source of truth with regards to reported incidents. In case of a grievance raised by a delivery partner worker concerning their employer, operational management and Sourcing log relevant information and follow-up actions in their local system (LPM) as well. This allows Sourcing to maintain complete and more detailed records for each delivery partner in their domain and keep track of incidents per delivery partner over time.

PostNL monitors and evaluates its procedures and reported incidents to safeguard compliance and continuous improvement and provide a safe and respectful working environment for those working for and with us. A procedure has been developed for our Sourcing specialists in our Operations NL and Parcels Belgium networks explaining what steps to take when an incident is reported by delivery partner (workers). In addition, we use training to ensure awareness of this grievance mechanism among PostNL management and staff. The PostNL integrity e-learning training is mandatory for all management and staff and includes a module on incident reporting. Explaining the procedure and importance that managers report any suspected violation of business principles, including human rights issues among workers in the value chain.  

Channels to raise concerns for delivery partner workers

PostNL’s Parcel’s delivery partners and their workers in the Netherlands and Belgium can turn directly to the locally responsible Sourcing specialist or operational manager to share concerns or report incidents or (suspected) violations. Every operational site has a dedicated Sourcing specialist who is accessible to workers. Sourcing specialists and local operational management are available in case a delivery partner worker wants to initiate a conversation or report something. 

In Belgium, a central coordinator was installed in line with the new Belgian Parcel Delivery Act, providing all delivery partners and their workers with a central channel to raise concerns, report incidents or receive guidance as to their rights and duties. To ensure awareness of this channel, posters were placed in all Belgian operational sites explaining its purpose and how to access it through a central e-mail address managed by the coordinator. The rest of the process is the same as mentioned above in operational-level grievance mechanisms for PostNL.

In case an incident is reported through these local channels, operational management is required to file a report in PostNL's central incident reporting system (IRIS) in line with the Group Procedure on Incident Reporting mentioned earlier. In parallel to any potential investigation by the Security department, the local Sourcing specialist will also assess the reported incident, collect additional information and discusses their findings with the Manager Sourcing. Collected information and findings are logged in the Sourcing system (LPM). Sourcing and operational management decide if and what remediating measures are required depending on the nature and severity of the incident. Where applicable, the Sourcing specialist informs the delivery partner in question and documents the outcomes of this conversation in the LPM system.

Safeguarding trust and protection

PostNL has clear policies in place to protect individuals, including workers in the value chain, using listed processes and channels against retaliation. Our commitments to protection against retaliation are included in our Human Rights policy and Group Procedure on Whistleblowing. All reports of suspected misconduct and potential investigations as a result of those are handled in a confidential manner. Any form of external or internal publicity is to be avoided unless allowed under applicable law. 

As described in our Whistleblowing procedure, any PostNL Stakeholder who reports an (alleged) breach of our business principles or relevant laws and regulations, which the PostNL Stakeholder reasonably believes, or may reasonably believe, to be true, will be given protection for such reporting. This protection means that PostNL will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any PostNL Stakeholder in the terms and conditions of employment. PostNL does not tolerate any form of threat, retaliation or other action against a PostNL Stakeholder who has made or assisted in the making of a report of suspected misconduct. Any such threat, retaliation or other action must immediately be reported to the director Audit & Security.

Respecting the privacy of individuals who are involved in, or witness to, an incident is an important consideration in dealing with incident reports, which often contain personal and other sensitive information. PostNL staff must comply with the PostNL Group Policy on Privacy whenever personal and/or medical information about employees or others is collected, stored, transmitted, used or disclosed. Consistent with the PostNL Group Policy on privacy, appropriate security safeguards must be in place when transmitting and storing information. 

There is currently no structural method in place for PostNL to assess the extent workers in the value chain are aware of, and trust, the listed channels or processes as a way to raise their concerns and have them addressed.

3.2.3 Our policies

At PostNL, we prioritise the protection and well-being of all individuals within our value chain through several important policies, including our human rights policy, health and safety policy, business principles, and the PostNL group procedure on whistleblowing. These policies foster a safe and inclusive working environment, ensuring that the rights of all employees, contractors, suppliers, and stakeholders are safeguarded.

Human rights policy

Our human rights policy sets clear expectations for ethical conduct across PostNL’s global operations. This applies to our employees, contractors, suppliers, business partners, and other stakeholders formally associated with our business activities. More information on this policy can be found in Our policies within the Own workforce section.

Health and safety policy

The PostNL health and safety policy is designed to ensure that our workforce, including those in our value chain, remains safe, healthy, and protected from harm arising from work-related activities. We are committed to continuously improving working conditions, preventing workplace accidents, and reducing risks, all in compliance with Dutch legislation and ISO 45001 standards. More information on this policy can be found in Our policies within the Own workforce section.

Business principles

Our business principles are foundational to how we operate, reflecting the core values and behaviours we expect from all individuals working for or with PostNL. We emphasise respect, equality, and inclusion, fostering a workplace where everyone feels valued and secure. More Information on our business principles can be found in the Governance disclosures, Our policies.

3.2.4 Our performance

In 2024, we implemented various measures aimed at addressing the material impacts on workers within our value chain. These initiatives support our efforts to manage impacts and risks while seizing opportunities. This section provides information on how we measure the effectiveness of our social related disclosures and their related targets.

PostNL acknowledges that understanding negative impacts within the value chain and determining the company’s role in these impacts may take time, as does developing and implementing appropriate response measures. We have therefore adopted the following approach:

General and specific approach to addressing material negative impacts

PostNL uses a structured approach to manage material negative impacts within the value chain. This includes rolling out updated delivery contracts and detailed guidelines for our delivery partners. Compliance checks, audits, and reporting systems support effective compliance management and promote a safe working environment within our value chain.

Initiatives to contribute to additional material positive impacts

In addition to preventing and mitigating negative impacts, PostNL is committed to encouraging positive change. We implement initiatives such as the Right to Work compliance programme, which ensures that all employees of delivery partners possess a valid work permit.

The third-party risk management tool, which we continue to develop, contributes to increased compliance and transparency in our value chain, fostering positive impacts in terms of better working conditions and enhanced safety. This tool allows us to closely monitor risks related to health and safety, working hours, and measures against violence and harassment.

Progress made during the reporting period

In 2024, PostNL made significant progress by implementing new measures in both the Netherlands and Belgium. This included the rollout of updated delivery guidelines and the pilot launch of the third-party risk management tool. Additionally, we took further steps to ensure compliance with the Belgian Postal Act and introduced external audits for our operations in the Netherlands. These initiatives have strengthened compliance and enhanced risk management across our value chain.

Goals for continued improvement

PostNL remains committed to continuously improving the safety and well-being of workers across our value chain. In 2025, we will roll out the third-party risk management tool to enhance visibility into compliance levels and identify areas for improvement among our delivery partners. We monitor the effectiveness of our impact management processes through compliance checks, audits, and structured evaluation meetings between the Sourcing department and delivery partners, ensuring timely identification and resolution of issues. This approach will enable us to monitor the effectiveness of our initiatives on an ongoing basis and make necessary adjustments to further enhance compliance and working conditions.

Cross-cutting actions and targets for all three material topics

Actions

Further implementation of an updated delivery contract, including new guidelines for delivery partners

In 2024, we introduced an updated delivery contract with new guidelines for delivery partners in the Netherlands and Belgium, focusing on health and safety, regulated working hours, payment issues, and preventing workplace violence and harassment. They aim to enhance well-being by ensuring safe and fair working conditions for our delivery partners.

The implementation of the contract and guidelines for all delivery partners at Parcels in the Netherlands took place between January and April 2024, while at Parcels in Belgium, it commenced on 1 February 2024. This reflects our commitment to the OECD guidelines and our business principles. By the end of April, the process was successfully completed, with 100% of delivery partners from Parcels in the Netherlands and Parcels in Belgium signing the document.

The roll-out at other business units, such as TGN, Transport and Logistic Solutions, will continue through 2025 and 2026 to ensure full adoption. While the contract in Belgium remains unchanged, the updated guidelines have been fully implemented.

Expected outcomes

The implementation of these guidelines and updated contracts is expected to improve working conditions, reduce the risk of overwork, and strengthen protections against workplace violence, enhancing employee morale and reducing legal and reputational risks. To manage these material risks, we enforce strict compliance with delivery partners, who must adhere to these standards. Our approach includes engagement and integrating the guidelines into sourcing and operations, with effectiveness monitored through audits, compliance checks, and the collaboration barometer feedback tool. By engaging with delivery partners and sharing best practices, we demonstrate our commitment to corporate social responsibility and sustainable business practices in line with OECD guidelines. We prioritise worker safety, ensuring alignment with CSR objectives while safeguarding our workforce. These efforts reflect our commitment to responsible business practices, fostering a safer, more compliant working environment across our value chain.

Building and piloting a third-party risk management tool

In 2023, we launched a pilot project to implement a third-party risk management (TPRM) tool, aimed at enhancing safety, compliance, and sustainable business practices with delivery partners. The TPRM tool is designed to monitor delivery partners' adherence to the Guideline for Delivery Partners and to log instances of non-compliance, as well as other potential risk indicators, such as questionnaires, relevant news articles, and inquiries from government agencies. This comprehensive system provides an overview of the risks tied to each delivery partner, enabling us to manage and mitigate these risks more effectively. This tool focuses on health and safety, working hours, and safeguarding against workplace violence, aligning with our business principles and OECD guidelines.

In 2024, we tested the tool as a pilot in multiple locations, across the Netherlands and Belgium, offering improved monitoring of health and safety, working time compliance, and incidents of workplace harassment. The use of the TPRM tool also helps reduce operational disruptions, mitigate legal and reputational risks, and control operational costs. Following the pilot phase, the aim is to roll-out the tool at Parcels in the Netherlands in 2025. The TPRM tool strengthens oversight, reduces risks, and fosters better relationships with delivery partners, enhancing our approach to managing material impacts on value-chain workers.

Targets

We have not yet set strategic or corporate-level targets for our cross-cutting actions. PostNL currently monitors the signing of updated delivery contracts and tracks adherence to specific terms on individual level. Our engagement is primarily with delivery partners, who employ and manage the parcel deliverers directly. While PostNL does not manage deliverers directly, we acknowledge our responsibility within the value chain to address concerns raised by deliverers regarding health and safety, working hours, or workplace conditions.

At the contract level, quality KPIs are monitored through a dedicated dashboard, with performance discussed at least yearly between the sourcing advisor and the delivery partner. Operational checks are also conducted to ensure compliance with requirements relating to vehicles and clothing. In alignment with our commitment to responsible chain management, all delivery partners must hold the PayChecked certification. This certification, audited annually by an independent third party, verifies adherence to collective labour agreements, supporting compliance with employment standards and fair labour practices.

Our TPRM tool (detailed above) will enable tracking of compliance, allowing the sourcing department to systematically evaluate the effectiveness of our policies and actions across the delivery network.

Working time

Actions

PostNL’s compliance measures aim to achieve several outcomes, positively impacting working conditions and aligning with regulatory objectives. These are:

Strengthening legal compliance

By introducing a new contract addendum in Belgium and the Netherlands, focusing on health and safety, regulated working hours, payment issues and preventing workplace violence and harassment, and through regular communications and updates, delivery partners are required to align with laws intended to improve working conditions for parcel deliverers and to demonstrate ethical business conduct. This mitigates legal risks and reinforces adherence to regulations without interfering with the operational independence of delivery partners.

Improving worker conditions and safety

Compliance with working time regulations ensures fair working hours, adequate rest periods, and adherence to social security obligations. This reduces fatigue-related risks, creating a safer and healthier work environment for delivery partner workers. Therefore we provide our delivery partners with a fair compensation to cover operating costs, pay remunerations to delivery drivers that exceed what is stipulated in the sector's collective labour agreement, and ensure our partners retain a margin to manage a healthy and sustainable business. We continuously monitor payments and, when necessary for example in case of indexation, refine our pricing model. To meet the requirements of the Belgium Postal Act, we additionally review the time registrations done by our delivery partners for their deployment in Belparcel, the online tool launched mid July by the Belgian government. Awareness efforts are supported by informative posters and routine inquiries to ensure delivery partners are adhering to time registration protocols.

Enhancing oversight and reducing labour exploitation

In the Netherlands and, prior to the amendments of 2023 to the Belgian Postal Act, also in Belgium, PostNL exercises oversight over delivery partners’ compliance, by the use of daily access controls to validate delivery drivers’ identity and work, residence and driver's permit and monitoring Right to Work certifications (RTW). RTW forms one component of our Registration of New Persons (RNP) procedure, which was introduced to prevent unauthorised employment and labour exploitation, safeguarding worker rights across the supply chain. More information on RTW and RNP can be found in Measures against violence and harassment in the workplace later in this section.

To ensure compliance with the Belgian Postal Act, PostNL Belgium has proactively introduced new compliance checklists for our delivery partners, including the mandatory registration of parcel delivery companies with the BIPT. This registration serves as a quality label, offering an initial indication of a company's reliability. Additionally, we have appointed a dedicated coordinator—a key figure in strengthening oversight and ensuring compliance. The coordinator serves as the primary point of contact for delivery partners and drivers, to address concerns. In line with legal requirements, PostNL’s coordinator has also drafted a vigilance plan, as mandated for all parcel delivery companies. This plan outlines measures to prevent and address violations related to working conditions and social security not only within the organisation itself but also in the value chain. PostNL will continue to monitor the plan’s implementation, providing regular updates to ensure alignment with evolving regulations.

Increasing awareness and transparency

Newsletters and compliance checks ensure delivery partners are informed about legal updates and responsibilities, promoting better adherence to the regulations. Additionally, ensuring compliance with the Belgian Postal Act, parcel deliverers who work for and with PostNL, are informed about their rights and obligations regarding working conditions, remuneration and other regulations. Therefore every deliverer receives an information document, drafted by the transport associations and validated by the social partners. The most recent version can be consulted on postnl.be in three languages.

Mitigating risks and protecting reputation

Through these measures, PostNL mitigates the negative impacts of inadequate mechanisms for regulating working hours and resting times, while reducing reputational risks. By ensuring delivery partners respect fair labour standards, PostNL reinforces its commitment to ethical and responsible operations within the value chain.

Corrective actions are promptly taken when material risks related to non-compliance are identified. These actions may include providing guidance, implementing stricter controls, or working collaboratively with delivery partners to resolve issues. The effectiveness of these measures is regularly reviewed to ensure continued compliance and to mitigate potential negative impacts.

External audits for irregularities

In early 2024, PostNL introduced an additional measure to strengthen oversight of its delivery partners in the Netherlands, particularly in response to any warning signs of irregularities. This involves external audits conducted by third-party experts to ensure compliance with regulatory standards, especially regarding payment practices and working hours.

The audits are primarily aimed at verifying compliance with the Wet Aanpak Schijnzelfstandigheid (WAS) and the Wet Arbeid Vreemdelingen (WAV). Each external audit is tailored to address specific risks identified. For instance, audits may include a thorough review of contracts between delivery partners and their personnel, payment practices, or compliance with legal standards.

A key component of this initiative is the PayChecked certificate, which is obtained by delivery partners through official channels and certifies compliance with wage payment and employee contract regulations. If PostNL detects warning signs that a delivery partner, despite holding a PayChecked certificate, may not have their operations fully in order, an additional external audit is commissioned. This audit rechecks all the points covered under the PayChecked certification and carries out additional investigation, depending on the specific risks identified.

Since the introduction of this initiative, four audit points had been conducted by the end of 2024. These audit points play a critical role in identifying and mitigating risks associated with non-compliance, thereby enhancing the integrity of our operations and contributing to the improvement of working conditions for value-chain workers.

The need for action is assessed through our compliance monitoring processes. If a delivery partner reports an issue regarding working hours or labour conditions, it is reviewed by the Sourcing department and escalated to headquarters if necessary. Each report is evaluated to determine required actions, the scale of the issue (local or national), and the party responsible for addressing it.

Targets

No strategic or corporate level targets have been defined to manage the topic of Working time.

Compliance with laws designed to improve working conditions and promote ethical business practices

The vigilance plan PostNL drafted in line with the legal requirements of the Belgian Postal Act provides a framework for further internal tracking and reporting on compliance actions. Compliance is assessed through both qualitative and quantitative measures, with 2024 serving as the baseline year.

External audit for irregularities

The effectiveness of policies related to managing irregularities with delivery partners is internally managed through several established steps, with further compliance monitoring systems in development:

Independent audits and certification

All delivery partners of PostNL in the Netherlands are required to hold a PayChecked certificate, achieved through an external audit by an independent firm to verify compliance with wage payments and contract standards. This serves as an initial control mechanism.

Supplemental audits based on warning signs

When reports of irregularities, such as unauthorised working hours or labour issues, arise, PostNL may initiate an additional audit through one of two external companies. If non-compliance is found, the delivery partner is required to implement corrective actions within a set timeframe, with PostNL monitoring to ensure resolution. The effectiveness of each audit is measured by its ability to address the initial concerns, and insights gained are used to enhance future audit objectives. Currently, there is no formal process or defined ambition level for tracking audit effectiveness.

Base period, ambition level, and indicators

In 2024, PostNL piloted the third-party risk management (TPRM) system and set that year as the base period to measure improvements in compliance and working conditions. The defined level of ambition is to achieve consistent adherence to compliant working standards across the value chain, with the tracking of incidents and corrective actions. Qualitative and quantitative indicators—such as the number of additional audits conducted, resolution rates of non-compliance issues, and trends in compliance requests from labour inspection—are used to evaluate progress effectively.

Health and safety

Actions

At PostNL, ensuring a safe and healthy working environment for our employees and delivery partners remains a top priority. To mitigate risks and promote well-being, we have implemented targeted initiatives, including the mandatory ‘Kennistoets’ health and safety module. By signing the delivery contract and guidelines, the delivery partners are required to comply with PostNL’s comprehensive safety expectations and ensure their drivers undergo training. This includes awareness training on the European Agreement on the International Carriage of Dangerous Goods by Road (ADR) for handling hazardous materials (Bewustwordingstraining in vervoer voor gevaarlijke stoffen).

Delivery partners also agree to a detailed description of PostNL’s health and safety standards, which cover maintaining a safe, clean, and healthy workplace, taking proactive measures to prevent accidents and injuries, providing essential safety and ADR training, addressing safety-related incidents and complaints, and prioritising traffic safety. The delivery contract stipulates that only competent, trained, and qualified drivers may be employed, with successful completion of ADR awareness training and annual follow-up sessions being mandatory.

Additionally, delivery partners are responsible for ensuring safe working practices, adhering to appropriate working hours, and implementing robust measures to combat violence and harassment. Our Sourcing department supports these efforts by distributing newsletters, facilitating discussions with delivery partners, and reinforcing the importance of compliance with legal and regulatory standards. Oversight of these activities falls within the remit of the Operations division, which assesses actions through PostNL’s overarching health and safety policy.

In cases where delivery partners report health and safety issues within PostNL’s sphere of influence, these are forwarded to our headquarters for review. Each report is thoroughly evaluated to determine whether action is required, the scope of the issue (national or local), and the appropriate party to address it. PostNL actively engages with delivery partners and other stakeholders to ensure grievances or complaints are heard and resolved effectively. This includes discussions and updates on legal and compliance matters. Where a material negative impact is identified, PostNL takes immediate corrective actions to mitigate the issue. These measures may include providing additional guidance, introducing stricter controls, or collaborating closely with delivery partners to resolve challenges.

Safety measures, such as dock adjustments and evacuation drills, apply for delivery partners and staff. The Sourcing department aligns with the policies for PostNL staff, while the Operations department (depots) identifies and addresses safety issues. Reported issues are centrally reviewed to ensure our safety protocols remain effective. More information on our health and safety policy can be found in Our policies within the Own workforce section.

Targets

At present, the effectiveness of health and safety initiatives is not systematically monitored due to the absence of specific targets or centralised tracking tools. While local checks are conducted, and feedback on depot safety conditions is gathered from delivery partners during evaluation meetings, there is no integrated dashboard or system to record the volume of feedback, track follow-up actions, or assess the overall impact and effectiveness of these initiatives.

Implementation of updated delivery contract and guidelines

We continue to monitor the implementation of our updated delivery contracts through our LPM IT system. By the end of 2024, we had achieved compliance across all delivery partners operating within Parcels Netherlands and Parcels Belgium. We are on track to ensure the full implementation throughout other smaller organizational departments such as TGN.

Progress is systematically tracked through regular reports generated by the system, ensuring compliance is assessed for all delivery partners within our operations in the Netherlands and Parcels Belgium. This structured approach reinforces adherence to our guidelines, enhancing operational effectiveness across our delivery network.

Development of third-party risk management tool

We launched a pilot for the third-party risk management (TPRM) tool at two locations, leveraging the insights gained to enhance its usability and deliver more actionable intelligence. This pilot serves as a crucial foundation for developing a comprehensive roadmap towards broader implementation. Its initiation establishes a baseline for measuring progress, with the ultimate goal of delivering a fully operational, user-friendly tool that enables the identification of relevant risks and strengthens risk management across the supply chain.

Our health and safety strategy also includes initiatives to improve working hours and reinforce measures against violence and harassment. Both the introduction of updated delivery contracts and the development of the TPRM tool contribute to fostering a safer working environment, ensuring compliance with our safety standards.

Measures against violence and harassment in the workplace

Actions

As part of PostNL’s broader efforts to address material risks related to value-chain workers, we have implemented the Right to Work (RTW) compliance initiative. This forms one component of our Registration of New Persons (RNP) procedure, which was introduced to prevent labour exploitation and ensure that all workers within our value chain are legally employed.

The RTW check, carried out via DataChecker, ensures that delivery partners can verify the legal status of their workers before employment. This policy requires all employees of delivery partners in the Netherlands and Belgium to provide a valid Right to Work certificate, ensuring workers are legally eligible to work in their respective countries and preventing labour exploitation. The initiative, which began in the Netherlands in October 2023, had been fully implemented by the end of 2024 in the Netherlands at TGN, Parcels and Mail in the Netherlands, and in Belgium.

Monthly reviews of reported issues allow us to assess the need for any further action and ensure that any risks are effectively mitigated. The need for action is assessed through PostNL’s general policies, including the business principles and the OECD guidelines. PostNL has implemented internal checks and balances to enforce this policy. Delivery partners must verify and provide proof of workers' legal status before employment. Any issues reported by a delivery partner that fall within PostNL’s influence are forwarded to headquarters for review. Each report is carefully evaluated to determine whether action is required, whether the issue is national or local, and which party is responsible for addressing it.

PostNL works closely with delivery partners to ensure they understand the importance of this policy and are capable of implementing it effectively. This includes providing guidance and support to partners to help them comply with the certification requirements. Through ongoing communication, PostNL strengthens its collaboration with delivery partners to enhance compliance and build capacity for effective implementation.

This initiative is expected to lead to improved labour practices, safeguarding workers from discrimination, harassment, and exploitation, while enhancing the overall integrity of our supply chain.

Targets

Right to Work (RTW) initiative

No strategic or corporate level targets have been defined to manage the topic of the Right to Work Compliance Initiative. The effectiveness of the RTW initiative is tracked by monitoring compliance through the Sourcing department, which verifies that each delivery partner employee has a valid RTW certificate. The base period for evaluating the initiative's progress and effectiveness is set as October 2023, when implementation began in the Netherlands. As part of the control system, we also carry out random physical checks.

Compliance tracking for the RTW certificates is ongoing but does not yet include a centralised dashboard or monitoring tool. Instead, checks are conducted as certificates are collected from each delivery partner. The Right to Work (RTW) compliance initiative has been fully implemented, ensuring that all deliverers have the necessary documentation. This initiative is integrated into the broader strategy for preventing labor exploitation and maintaining supply chain integrity. Compliance is continuously monitored through internal systems to ensure adherence to regulatory requirements.

Monitoring and managing impact

At PostNL, we are committed to improving the monitoring and management of working time, health and safety, and anti-violence measures across our value chain. Although local oversight exists, challenges remain in fully implementing a comprehensive monitoring dashboard.

In 2024, the TPRM process was implemented to address issues related to health and safety, measures against harassment and violence, and working time. This process plays a critical role in identifying, managing, and resolving incidents across our value chain. If a signal of misconduct is received, it is reported via the IRIS system by the operational management of the depot. The Sourcing contact person gathers all relevant information and discusses the case with the manager Sourcing Distribution. Together, they decide on the necessary actions and ensure proper documentation. For example, a report of underpayment by a delivery partner led to an additional audit by the Sourcing department. The complaints were subsequently withdrawn, and the audit revealed no irregularities.

The TPRM process is also used to handle severe human rights issues and incidents within the upstream and downstream value chain. When such incidents are reported, they are documented in the IRIS system, and the Sourcing team collaborates with the depot to investigate and resolve the issue. Actions are monitored and documented until the case is closed, ensuring all necessary steps are taken to address and rectify the situation. No severe human rights violations or incidents have been identified that require further disclosure.

Our Sourcing department provides delivery partners with tailored guidance on managing potential risks related to working time, health and safety, and the prevention of violence and harassment. This guidance is delivered through two key channels:

Newsletters: Used to communicate general information, such as updates on regulations, best practices, and guidelines for maintaining safe and compliant operations.

One-on-one conversations: During direct conversations, delivery partners receive case-specific advice on issues such as preventing workplace violence, ensuring proper working hours and resting times, and creating safe environments for workers.

These measures are not mandatory but aim to empower delivery partners to inform their employees effectively and adopt appropriate practices to mitigate risks.

To address gaps, we are developing a third-party risk management tool, focusing on high-risk areas like violence and harassment, child labour and payment practices.

Serious human rights concerns are recorded through the IRIS system, with close collaboration between our Sourcing team and depot staff to ensure timely resolution. No severe human rights violations have required public disclosure, but partnerships with some delivery partners have been discontinued due to unprofessional conduct.

Various resources are dedicated to managing worker impacts, including compliance audits, updated contracts, and continuous partner communication.

PostNL’s approach to addressing material risks related to value chain workers integrates with our existing risk management processes. This ensures a cohesive framework for monitoring and managing risks across all material topics. Specifically, the processes developed, such as compliance audits, the TPRM tool, and the implementation of updated delivery contracts, are aligned with our broader risk management strategy. By embedding these actions into existing structures, we aim to systematically identify, assess, and address risks while ensuring continuous alignment with our corporate responsibility objectives.