3.3 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 safe working conditions and promoting fair labour practices. 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.

The material negative impacts identified for workers in the value chain relate to working time, health and safety, and violence or harassment. These impacts are not associated with systemic issues such as child labour or forced labour in specific countries or regions. Due to the nature of subcontracted delivery operations, risks related to these topics may occur in a widespread manner if not adequately managed. However, actual material negative impacts typically arise as isolated incidents at individual delivery partner level, rather than as recurring or structural violations across the value chain. PostNL therefore applies preventive, cross-cutting measures alongside incident-based remediation to address and prevent such impacts.

“We recognise that fostering a responsible value chain not only drives business success but also contributes to societal value by addressing safe working conditions and promoting fair labour practices”

3.3.1 Our actions

Health & safety, working time, and violence & harassment

Cross-cutting actions for all three material topics

PostNL avoids causing harm to value chain workers through its Human Rights Policy, guidelines for delivery partners, and due diligence processes. These include risk assessments, safe working conditions, fair labour standards, and inclusion. When a material negative impact occurs, PostNL uses grievance channels, remediation steps, and effectiveness reviews. A Human Rights Saliency Assessment identifies priority issues for targeted action. PostNL applies third-party risk management tools, audits, and stakeholder dialogues to address risks like safety, and diversity. Through our DMA and ESG strategy, PostNL considers external trends and dependencies to manage risks proactively.

PostNL aims to reduce risks of litigation, regulatory sanctions and reputational damage by embedding contractual requirements, monitoring third‑party compliance, and improving access to grievance and remedy mechanisms. These actions also help prevent operational disruptions, remediation costs and strained relations with delivery partners. By promoting safe, fair and respectful working conditions, they further support worker morale and retention across the value chain, strengthening service continuity and revenue stability.

Implementation of guidelines for delivery partners

PostNL expanded its guidelines for delivery partners to more business segments in 2025. After rollouts in Operations NL and BE in 2024, TGN followed in the first quarter of 2025. All delivery partners within these three business units have signed the guidelines as part of their contract. These guidelines promote safe working conditions, regulated hours, and protection against harassment. Full implementation across other business units is planned by 2026.

Third-Party Risk Management tool

The Third-Party Risk Management (TPRM) tool monitors delivery partners’ compliance with PostNL’s safety and working standards. It tracks among others: health and safety risks, human rights violations and incidents of violence or harassment. Following a 2024 pilot, it was rolled out to Operations NL, TGN, Extra@Home, and Transport by year-end 2025. In Belgium, the first assessments began in 2025. The TPRM tool enables structured registration and monitoring of third-party risks, including grievances raised by value chain workers. It supports PostNL in identifying patterns, ensuring timely follow-up, and improving transparency in how incidents are handled. By integrating this system into key operational domains, we have taken a step forward in safeguarding worker rights and strengthening our risk governance. Where findings cannot be sufficiently explained within the TPRM framework, an audit will be initiated to ensure corrective measures. Data in the TPRM tool is not available for delivery partners or their employees, but solely for sourcing specialists.

Implementing due diligence within Cross Border Solutions

In 2025, Cross Border Solutions (CBS) launched an action to strengthen health and safety conditions for subcontracted workers. CBS distributed a Supplier Code of Conduct to delivery partners, clarifying expectations around safe workplaces, fair scheduling to ensure reasonable working hours and enough rest, and respectful behaviour. More information on these guidelines can be found on page in the Governance disclosures, in the paragraph Set of Guidelines for Suppliers and Guidelines for Delivery Partners.

A complaints mechanism is under development. Looking ahead, implementation will continue in 2026, with outcomes expected to include a functioning complaints system and stronger supplier alignment with PostNL standards.

3.3.1.1 Working conditions

Working time

Delivery in accordance with working time legislation

PostNL aims to ensure fair working conditions and regulatory compliance for subcontracted delivery workers. As a responsible client to our delivery partners, we take proactive measures to ensure compliance with working time legislation. This action addresses reputational and legal risks linked to working time and labour standards, as well as supports managing working times effectively. It contributes to PostNL’s broader objective to promote responsible conduct in the value chain.

Designing delivery routes that enable our partners to deploy their delivery drivers in full accordance with collective labour agreements and working time regulations are a key measure. Routes are further refined based on forecasts, operational experience and close consultation with our delivery partners. In the coming years we aim to maintain this compliance.

Audits

PostNL introduced (external) audits to strengthen compliance and risk management across its delivery network. These audits helped verify adherence to labour standards and operational guidelines. External audits, introduced in 2024, continued in 2025 as part of business as usual. In addition, external audits are now triggered in cases where signals of irregularities are identified, ensuring timely investigation and corrective action.

3.3.1.2 Equal treatment and opportunities for all

Measures against violence & harassment

Guidance on desirable behaviour

In 2025, PostNL translated its internal policy on (un)desirable behaviour into external guidance for delivery partners. This ensures consistent standards across the value chain. Awareness materials and complaint procedures are shared to ensure workers know how to report violence or misconduct safely. Looking ahead, the guidance will be further embedded into daily operations, with continued monitoring through sourcing systems.

Right to Work Compliance Initiative

In 2025, compliance with Right to Work requirements remained embedded in our standard processes, ensuring that all workers across our value chain are employed in line with legal and regulatory obligations.

We allocate resources to manage the impacts on value chain workers, focusing on compliance, oversight, and continuous improvement, as part of our strategic and operational processes.

3.3.2 Our performance

3.3.2.1 Working conditions

Working time

No targets were set in 2025. Compliance with CLAs and working time regulations must be met at all times and is therefore not suited to incremental or performance-based targets.

Internal and external audits are applied as a separate and complementary control mechanism and are conducted when deemed necessary with a tailor-made scope.

Health & safety

PostNL did not define corporate-level health and safety targets in 2025, as delivery partner workers are employed and managed by independent delivery partners. Instead, PostNL focuses on setting minimum safety requirements through delivery contracts, which are monitored via compliance checks, audits and third-party risk management tools.

3.3.2.2 Equal treatment and opportunities for all

Measures against violence & harassment

No formal targets were set in 2025 for preventing violence and harassment, as potential negative impacts typically occur as isolated incidents at individual delivery partner level. PostNL therefore focuses on prevention, awareness and access to remedy through updated contracts, the Code of Conduct, behavioural guidance and grievance mechanisms.

Alternative effectiveness trackers

For working time, health and safety, and measures against violence and harassment, PostNL assesses the effectiveness of its policies and actions through a combination of compliance monitoring, external (PayChecked) audits, partner evaluations, grievance mechanisms, and follow-up of identified incidents. This includes reviewing adherence to contractual requirements, analysing signals from audits and monitoring systems, and evaluating the handling and remediation of reported issues. The TPRM tool provides consistent data to strengthen oversight. By embedding these trackers into our enterprise risk management cycle, we ensure continuous improvement and accountability.

While no formal targets are set, PostNL’s level of ambition is to ensure full compliance with applicable laws and internal standards, prevent material negative impacts where possible, and take timely corrective action when issues arise. Through this approach, PostNL aims to continuously strengthen safe, fair and respectful working conditions across the value chain, in line with the actions described.