4.1 General disclosures

4.1.1 Our impacts, risks and opportunities

In the table below, we disclose our material impacts, risks, and opportunities per topic, including their time horizon and where in the value chain they occur.

4.1.2 Our strategy

PostNL maintains high standards of corporate governance, business ethics, and regulatory compliance. Our governance framework supports the delivery of our refreshed strategy – Connected to deliver what drives us all forward – by ensuring transparency, accountability, and responsible decision-making across all levels of the organisation. It is guided by three focus areas: fostering an ethical culture based on integrity and compliance, strengthening transparency and reliability and building trust in the value chain through dialogue and strategic partnerships.

Our strategy focuses on growing our business, creating sustainable value and driving innovation that makes a positive impact for our customers, our people and society. Governance plays a key role in embedding these ambitions within our day-to-day operations. This includes robust oversight mechanisms, clear lines of responsibility, and processes that ensure alignment with our strategic objectives and stakeholder expectations.

4.1.3 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 and delivery partners align with corporate goals and regulatory requirements. This section outlines our governance approach to managing these relationships.

For our governance of material impacts, risks and opportunities (IROs) related to corporate culture, protection of whistleblowers and corruption and bribery we refer to pages - in the Corporate Governance chapter, including the paragraphs Integrity Committee, Business conduct and integrity approach, and Prevention of fraud, bribery and corruption.

Supplier relationship management approach

PostNL maintains supplier relationships based on its procurement strategies with the company’s operational and sustainability goals. Supplier interactions are governed by PostNL’s Procurement Policy, which highlights how supplier engagements are managed, how PostNL tries to minimise associated risks to avoid supply chain disruptions, and how sustainability is prioritised in its procurement processes. More information on PostNL’s Procurement Policy can be found later in this section.

Procurement approach

PostNL adopts a hybrid procurement model, with centralised procurement by the Procurement and Services department overseeing most activities, while specialised departments 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. Procurement is working increasingly closely with other procurement units across PostNL to ensure that supplier contracting is consistently aligned with our Procurement Policy and to minimise potential procurement- and ESG-related risks. Ensuring compliance with the Procurement Policy remains a key focus.

Supplier selection and ESG criteria

Procurement actively involves (potential) suppliers into its sustainability ambitions by embedding environmental, social, and governance (ESG) criteria throughout the supplier selection, evaluation and performance process. We do this by including our Code of Conduct and Set of Guidelines for Suppliers as part of our supplier contracts, refer for more information to the Procurement Policy later in this section. Supplier contracts include sustainability criteria for the supplier, if necessary through assessments by independent parties such as EcoVadis or the Dutch foundation MVO Register.

Support for contracted suppliers

PostNL's Procurement department actively encourages suppliers to become certified, have their sustainability assessed, and improve as needed.

As part of performance evaluations of suppliers, we discuss how we can achieve sustainable improvements. We offer our knowledge and expertise to help them take the necessary steps. We increasingly rely on each other to gain clear insights into our supply chain and implement improvements, such as reducing CO2 emissions, optimising material use, waste reduction, and being a good employer. This aligns with PostNL's sustainable procurement objectives by ensuring that suppliers operate sustainably and contribute to PostNL's overall environmental goals.

Risk mitigation through supplier assessments

To manage risks within our supply chain, PostNL’s Procurement department applies a range of instruments, including risk workshops, the use of Kraljic matrices to assess the importance and dependency of (essential) suppliers, and a structured ESG risk assessment matrix. This matrix classifies suppliers into sustainability risk categories (green, yellow or red), with corresponding follow-up actions. For example, suppliers classified as ‘red’ are subject to on-site audits or visits, conducted either by PostNL or by independent third-party assessors.

For the sourcing of delivery partners, we have developed and rolled out a dedicated Third-Party Risk Management (TPRM) tool to monitor compliance with our requirements. This tool forms part of our broader TPRM framework, which ensures that risks related to delivery partners are systematically identified, assessed and managed.

Ongoing monitoring and continuous improvement

PostNL monitors supplier performance through regular evaluations, sustainability ratings and targeted improvement plans. For suppliers with identified risks or low(er) sustainability scores, we work collaboratively to develop and implement improvement actions. Where suppliers do not demonstrate sufficient progress or fail to meet agreed requirements, we may ultimately decide to end the partnership. Through this structured approach, we aim to further professionalise and strengthen our supply chain.

Timely payment practices

PostNL aims to ensure the timely payment of all supplier invoices, including those from both small and medium-sized enterprises (SMEs) and larger companies, wherever possible. To achieve this, we have 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.

4.1.4 Our policies

At PostNL, we uphold high standards of business conduct through a robust framework of policies and procedures with the Code of Conduct as cornerstone. To safeguard the highest standards of integrity, PostNL has implemented a comprehensive Integrity Policy, a Whistleblowing procedure, and anti-corruption and anti-bribery measures. These cover key areas such as fraud prevention, conflicts of interest, the acceptance and offering of gifts and hospitality and whistleblower protection. Our Procurement Policy defines the standards we expect from our suppliers, requiring them to uphold ethical, legal, and social responsibilities and to operate sustainably and in compliance with local and international laws and regulations. Collectively, these policies and procedures address our material topics corporate culture, protection of whistleblowers, management of relationships with suppliers and corruption and bribery. More information on our business conduct and integrity approach, including related policies and procedures, can be found on pages - in the Business conduct and integrity approach paragraph in the Business Conduct - Policies and procedures section of the Corporate governance chapter.

Code of Conduct

Our Code of Conduct is the foundation of how we operate, guiding our actions and decisions in all business activities and partnerships. We expect everyone associated with PostNL, including employees, third parties, business partners and suppliers, to comply with the Code. It defines the standards we uphold and clarifies what our stakeholders can expect from PostNL.

In line with ESRS G1, we ensure that our corporate culture and business conduct are closely integrated, with a strong emphasis on compliance with our Code of Conduct. In 2025, we renewed and implemented our Code of Conduct, which replaces the previous Business Principles. The updated Code of Conduct reflects the expectations of our customers, the market and society, ensuring our behaviour and decisions remain responsible, transparent and in line with today’s world. The Code of Conduct is available internally and publicly on our website.

Group Integrity Policy

At PostNL, integrity is defined as compliance with our Code of Conduct. The Integrity Policy applies to all PostNL entities and suppliers and establishes responsibilities on integrity matters. We maintain a well-functioning integrity framework, which includes:

• Establishing and maintaining the Code of Conduct
• An integrity office overseeing the integrity programme
• An integrity committee advising the Board of Management
• Handling and reporting of integrity-related incidents
• Awareness and training for management, procurement, sales and head office functions.

Group Whistleblowing procedure

The Group Whistleblowing procedure provides clear methods for reporting any suspected misconduct by employees, former employees, interns, flexible workers, delivery partners or other stakeholders associated with PostNL Group companies. This procedure has been updated in 2025 to comply with current laws and regulations, respectively the ‘Wet Bescherming Klokkenluiders' in the Netherlands and equivalent legislation in other EU countries where PostNL operates.

The Integrity Policy and the Whistleblowing procedure apply to both internal and external parties, and are both publicly available on our website.

Group procedures for fraud prevention, conflicts of interest, and gifts and hospitality

To manage corruption and bribery, we have established a comprehensive framework including anti-bribery and anti-corruption policies, group procedures for fraud prevention, conflicts of interest, gifts and hospitality, and reporting mechanisms. This framework ensures compliance with applicable laws and regulations such as the UK Bribery Act 2010, the U.S. Foreign Corrupt Practices Act, and the UN Convention against Corruption, both in the Netherlands and in the international markets in which PostNL operates. These procedures apply to all employees, delivery partners and other third parties acting on behalf of PostNL. They are communicated through mandatory e-learning, onboarding materials, internal guidelines and regular compliance updates, and the group procedures for fraud prevention, conflicts of interest, and gifts and hospitality are available internally and publicly on our website.

Procurement Policy

At PostNL, we aim to ensure that our procurement activities align with our Procurement Policy, applicable legislation and regulations, social and ethical standards, and sustainability requirements. In collaboration with our suppliers, we continuously strive to strengthen and enhance the supply chain, with the aim of making it as sustainable as possible. This reflects our focus on protecting the environment, promoting social responsibility, and upholding robust governance standards.

The general aim of the Procurement Policy is to enhance the professionalism of procurement 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.

PostNL aims to limit the number of suppliers and foster long-term partnerships. As part of the contract (renewal) process, suppliers are informed of updates to the procurement documents and its accompanying annexes.

In addition, we have an internal Group Procurement Policy in place. This Policy provides governance and control over the procurement process and ensures that suppliers are selected based on quality, reliability and continuity, as well as their adherence to social and environmental standards.

In 2025, both the publicly available Procurement Policy and the Group Procurement Policy were updated to reflect the latest data, methodologies and interpretations.

Set of Guidelines for Suppliers and Guidelines for Delivery Partners

PostNL has developed two codes of conduct for its suppliers and delivery partners: the Set of Guidelines for Suppliers and the Guidelines for Delivery Partners. Both outline the expected behaviour and requirements for compliance with ethical and sustainability standards for suppliers and business partners.

PostNL’s Code of Conduct and the Set of Guidelines for Suppliers are an integral part of the supplier contracts of the Procurement & Services department. Suppliers are required to comply with these guidelines, which cover a wide range of ethical, social, and environmental standards. For new suppliers, signing the Code of Conduct and Guidelines for Suppliers are a prerequisite for entering into a business relationship with PostNL. Delivery partners have to sign the Guidelines for Delivery Partners before they can become a delivery partner for PostNL.

Public access procurement documents

The Procurement Policy is published on our corporate website. It contains, for example, guidelines, risk classification, follow-up measures and checklists. Documents such as Our Purchasing Terms & Conditions, Code of Conduct and Set of Guidelines for Suppliers are publicly available on PostNL’s website, ensuring transparency and accessibility. The Guidelines for Delivery Partners is available internally and for delivery partners.

Ongoing compliance monitoring

PostNL assesses its suppliers’ adherence to the Set of Guidelines for Suppliers and the Guidelines for Delivery Partners and identifies areas for improvement through regular evaluations or audits. 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.

Suppliers with increased ESG risk

Procurement identifies suppliers with increased ESG risks through its risk assessment processes. These suppliers are situated in geographical areas or industries facing significant ESG challenges. Vulnerable suppliers with significant economic, environmental and/or social risks have not been identified.

Monitoring of 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. Responsibility for the implementation, execution and monitoring of the Code of Conduct, Integrity Policy, whistleblowing procedure, and anti-corruption and anti-bribery measures covering fraud prevention, conflicts of interest, and gifts and hospitality has been delegated by the Board of Management to the Director of Audit & Security. More information can be found on pages - in the Corporate Governance chapter, including the paragraphs Integrity Committee, Business conduct and integrity approach, and Prevention of fraud, bribery and corruption.

The Director of Procurement & Services is the (mandated) owner of the (group) Policy on procurement, responsible for defining, executing, implementing 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. Effectiveness of the Policy is ensured by informing of the relevant departments responsible for procurement and creating awareness of the Procurement Policy and procedures, by verifying compliance of procurement spend with contractual agreements and by evaluating contracted suppliers, including sustainability assessments, to ensure they comply to the procedures, KPIs, and contractual agreements.