05 General

The Sustainability statement is part of the Directors Report.

The information included in the Sustainability Statement with regard to the EU Taxonomy meets the disclosure obligations set out in Article 8 of Regulation (EU) 2020/852. The information on greenhouse gas emissions (Scope 1, 2 and 3) included in the Sustainability Statement has been compiled in accordance with the guidelines of the Greenhouse Gas Protocol (GHG Protocol).

For the consolidation of our GHG emissions (Scope 1, 2 and 3) we use the operational control approach set out in the GHG Protocol. This means that, in addition to the emissions of our group companies, a portion of the emissions of EemsEnergyTerminal and BBL Company are also included in our Scope 1 and 2 emissions. We included the emissions of joint operations and joint ventures over which we have no operational control in our Scope 3 (category 15) emissions.

The Appendix to the Sustainability Statement explains how we have arrived at our forecasts regarding facilitating emission savings.

Due to differences in laws and regulations, we do not always record information on matters like health, safety, the environment and employment conditions in the same way in the Netherlands and Germany. Whenever possible, information from the Netherlands and Germany has been combined; where this is not reasonably possible, this is presented separately. We also do this where we feel displaying this information separately allows a better understanding.

The measurable targets included in the Sustainability Statement are approved annually, prior to the financial year, by the Executive Board, which it does by approving the business plan. The Supervisory Board also approves the business plan. Our Scope 3 target was approved by the Executive Board in mid-2024. Unless we specifically mention this in the relevant section, stakeholders are not explicitly involved in determining policy, setting the measurable targets, monitoring results, or mapping improvements.

Every quarter, the Executive Board receives a quarterly report with an update on the key risks, opportunities and KPIs in the area of sustainability, as included in the business plan. This report covers the strategic pillars set out in our CSR strategy. Every quarter, a consultation on social topics takes place with senior management and the CFO to discuss and analyse the progress, risks and opportunities with regard to these pillars and to make adjustments where necessary. Implementation of the business plan is also evaluated and discussed on a quarterly basis during the regular meetings of the Supervisory Board.

Where necessary to provide the required disclosure, we have included the nature of the judgements and estimates in the Notes to the relevant data or in the Appendix to the Sustainability Report. We review the estimates and underlying assumptions at regular intervals.

The judgements and estimates we have used can be refined in future reporting periods once more relevant information becomes available. We have not yet included comparative figures for all data points in the Sustainability Statement at this time. Adding comparative figures after this first reporting year will make the information more valuable for the users of the annual report.

For each of these topics, we show which impacts, risks and opportunities we see for Gasunie and the policy we have formulated to reduce the negative impacts and risks and to benefit from the opportunities.

Where possible, we show which financial resources we had available to carry out the actions. Additionally, we show which measurable targets we have formulated for each topic and how far we have come in achieving these targets.

This is the first year that we are reporting fully in accordance with the CSRD. We expect that EFRAG will publish new implementation guidance and notes next year, which should provide a better understanding of the reporting requirements. The new omnibus bill will also have an impact on future reporting requirements, and insights from other companies and sectors may also change our interpretation over the coming years.

Results of the materiality assessment

The assessments show that there are six topics that our stakeholders consider material for Gasunie. These are shown in the figure below, along with the estimates that the stakeholders have made for each topic regarding the ‘impact materiality’ and the ‘financial materiality’. There is no ranking among the six topics, which is why we left out the scale value for the estimates.

We report on these topics in the following sections of the Sustainability Statement. We start with the Environmental topics, i.e. Energy transition (section 6) and Emissions (section 7), Circularity (section 8), followed by the Social topics, these being Security of supply (section 9), Safety (section 10) and Employee wellbeing (section 11).

Structure of the materiality assessment

The materiality assessment was carried out at an early stage of the reporting process in 2023. This assessment comprised three steps. We worked together with an external consultancy firm to carry out our materiality assessment.

Step 1: Identify possible ESG topics

The initial focus of the assessment was to draw up a longlist of topics that could possibly be deemed material. We compiled this longlist using sources like previous materiality assessments, various internal and external reports (including risk analyses), annual reports of a number of comparable companies, statements in the media, and trends and developments in our sector. To finalise step 1, 14 ESG topics and their definitions were validated internally in a CSR study group comprising 15 employees drawn from different areas of expertise within Gasunie.

Step 2: Consult stakeholders

In the second step of the assessment, we assessed who Gasunie’s key stakeholders are and gained a better understanding of the extent to which the company is influenced by its stakeholders and the impact Gasunie has on its stakeholders. Fifteen semi-structured interviews were then held with internal and external stakeholders. We selected the people to interview based on their expertise with regard to certain topics on the longlist and their involvement in these topics. We also assessed these topics for their actual relevance to Gasunie and the interviewees working at Gasunie for their ability to provide an understanding of the perspective of external stakeholders.

The people interviewed included various department managers, such as the head of Security, HR, Business Development, Communications, and Government Affairs, as well as members of the Executive Board, the Chair of our Works Council, one of our larger suppliers, a representative of the Ministry of Economic Affairs and our shareholder. Based on the findings, we made a number of adjustments to the longlist to arrive at a shortlist of eleven ESG topics. The shortlist was then submitted for validation to the CSRD steering committee, consisting of four department managers. The insights the stakeholders provided did not result in an adjustment to our business model.

Step 3: Determine inside-out and outside-in impact

The next step was to hold workshops to gather input on the inside-out and outside-in impact of the shortlisted ESG topics. For these workshops, we selected participants who, based on their area of expertise, could provide input on one or both perspectives for these eleven ESG topics. Based on the information gained from the workshops, the topics were plotted in a materiality matrix. When determining the financial materiality, dependencies with regard to impacts and risks that could potentially have a financial impact were also taken into account. The position in the materiality matrix was determined based on the following factors:

Impact materiality

• Scale: The scale factor relates to the severity of the impact: how bad is the impact? 
• Scope: The scope factor relates to how widespread the impact is: how big is the impact? 
• Remediability: The remediability factor concerns whether and to what extent a negative impact can be remediated: to what extent can the impact be reduced or remedied by taking corrective measures? When plotting positive impacts in the materiality matrix this factor is not taken into account. 
• Likelihood: This factor concerns the probability or chance of the impact occurring: how likely is it that the impact will occur?

Financial materiality

• Financial impact: The financial impact factor regards how big the opportunity or risk is in monetary terms: what are the financial consequences associated with the opportunity or risk? This can include direct costs or monetary benefits, but also indirect costs, such as reputational damage, or potential revenue losses or increases. 
• Likelihood: This factor concerns the probability or chance of the opportunity or risk materialising.

By setting a threshold, we were able to separate the material from the non-material topics. We consider a topic material if it scores high from an impact perspective or from a financial perspective. The materiality matrix including the threshold value applied was submitted to the participants at the various workshops for verification and then to the steering committee for validation.

The results of the double materiality assessment were then adopted by the Executive Board.

Step 4: Update for 2024

In 2024, we revised the double materiality assessment of 2023. The reason for this update was that, when the double materiality assessment was carried out in 2023, when assessing the material topics we assumed the remaining impacts and risks after taking control measures. However, later implementation guidelines from EFRAG prescribe that the inherent risks must be assumed.

Over the course of 2024, we identified to what extent any new risks and/or opportunities that were not included in the double materiality assessment of 2023 were present. Then, for each topic, expertise holders were consulted to determine the inside-out and outside-in impact, taking into account the inherent risk. The results of this, including the threshold value used, were validated during the quarterly meeting on social topics and approved by the Executive Board.

The 2024 update brought forth a number of changes compared to the previous results. Given the priority Gasunie places on safety at all times and the fact that preventing and managing risks in the area of safety is an essential part of our business operations, we added this as a separate topic in 2024. In 2023, ‘Safety’ was included in the topics of ‘Security of supply’ and ‘Employee health and safety’.

As a consequence of adding ‘Safety’ as a separate topic, the topic of ‘Employee health and safety’ was dropped in 2024 and the content brought under the topics of ‘Safety’ and ‘Employee wellbeing’. In the 2024 update, the topic ‘Relationship with local communities’ fell below the threshold value for the material topics. This says nothing about the importance of the topic in itself, only about its importance in relation to the other topics on the list.

The double materiality assessment has not yet been fully integrated into Gasunie’s management control structure, as described in the Governance section, though the sustainability risks are already part of the management control structure. We plan to integrate this further in the coming years.

Applying this definition, we arrive at a broad group of stakeholders, such as customers, downstream value chain partners, employees, national government, suppliers, local communities, investors, academia, energy regulators, and NGOs. We regularly engage with these stakeholders at international, national and local level. When carrying out our projects, we find it valuable to actively engage in dialogue with residents, local government representatives and local suppliers. With such engagement, our intention is to make progress, and this can only be done together and in good consultation.

Right now, Gasunie has separate stakeholder policies, each drawn specifically per topic. We are, however, working on a general stakeholder policy that will apply to all parts of our company in the coming years (MT). With our stakeholder policy, we aim to engage in constructive dialogue with stakeholders when determining our strategy (regarding sustainability aspects, among others), determining the material topics for setting our ESG targets, developing energy transition projects (jointly or on our own), and creating synergy with our partners. To this end, effective consultation, maintaining sustainable relationships, and staying up to date on all developments are essential.

With the arrival of European and national legislation and regulations in this area, having a meaningful, long-term relationship with our stakeholders has become a priority in our business. We strive to comply with all applicable laws and regulations on stakeholder engagement, including the Corporate Governance Code, environmental and social regulations (like the CSRD and the Dutch Environment and Planning Act), and legislation on the protection of personal data.

To effectively define the connection between us and our stakeholders, we regularly carry out a stakeholder analysis to determine stakeholder segmentation. After identifying the stakeholder groups, these parties are grouped according to mutual interest and influence. Stakeholders can influence us to a greater or lesser extent and we, in turn, have an impact on stakeholders to a greater or lesser extent. Based on this segmentation, we apply a diversified dialogue, taking into account the different features and needs of stakeholders. With this approach, every Gasunie department can contribute to maintaining the relationship we want to have with our stakeholders, each according to the specific stakeholder group(s) and the department’s role and responsibility within the company.

The group into which particular stakeholders fall determines the degree of consultation and the intensity of our communication with the relevant stakeholders. We are guided by candid, professional discussions, during which we are transparent, honest, respectful, inclusive and impartial, and where we take responsibility for our actions. We do our best to answer all queries and we act in accordance with our Conduct Guidelines for Working Together.

We have already reaped many benefits from stakeholder engagement over the last while. For example, during the Gasunie Stakeholder Dialogue webinars, together with our stakeholders we discussed two topics related to the energy transition with the aim of obtaining in-depth information on these topics. We have also actively engaged in discussions with the local communities around our construction projects, such as concerning the construction of the heat network in The Hague and the underground hydrogen storage facilities in Zuidwending.

Every single Gasunie employee is responsible for seeing that our stakeholder policy is properly implemented, each from the perspective of their own job and responsibilities. The Executive Board is responsible for establishing the policy and making any changes to it, making the policy known, and ensuring compliance. The management and all employees ensure that stakeholders are approached in the manner described in this stakeholder policy. The policy has been discussed with the Works Council, published on our website, and shared with key stakeholders.