21 Additional information

Step 1: Identifying potential material ESG topics 

An important first step in the DMA was to gain insight into Gasunie’s value chain and the company’s position within it. Based on this analysis, we identified relevant impacts, risks and opportunities in the subsequent steps of the DMA.

We compiled a longlist of potential material topics. In addition to Gasunie’s business context, we also took into account the corporate and sustainability strategy, the results of the 2024 DMA, material topics reported by peers in their annual reports and input from internal stakeholders. 

Step 2: From longlist to medium list – screening for relevance and IROs

The second step saw us screen the longlist down to a medium list by assessing the potential material topics for relevance to Gasunie and its stakeholders. Topics that did not involve a potential impact, risk or opportunity (IRO) were excluded. To identify potential material IROs, we interviewed internal experts, i.e. colleagues with specific expertise, such as an ecologist, local community manager, procurement consultant, HR consultant and a corporate legal affairs and corporate governance expert. Their insights were a valuable basis for further narrowing down the medium list.

Step 3: from medium list to shortlist of material topics and identifying inside-out and outside-in impact 

The third step consisted of whittling the medium list down to a shortlist. The items on the medium list were validated with internal and external stakeholders, which saw us interview the Natuur & Milieu environmental organisation, the Dutch Ministry of Finance and members of the Executive Board and Supervisory Board. This produced a shortlist.

We held workshops to gather input on the inside-out and outside-in impact of the shortlisted topics and IROs. We selected participants for these workshops based on their areas of expertise to ensure they could provide relevant input. Based on the input that emerged from the workshops, we assessed both the impact materiality and financial materiality of the IROs. As part of our DMA, we also looked at how impacts, dependencies, risks and opportunities for the organisation relate to each other. These interrelations were taken into account in determining which sustainability topics are material for our reporting.

Impact materiality and financial materiality were determined based on the following factors:

Impact materiality:

• Scale: How bad is the impact? 
• Scope: How big is the impact? 
• Remediability: To what extent are we able to mitigate or repair the adverse impacts by taking corrective measures? 
• Likelihood: how likely is it that the impact will occur?

Financial materiality: 

• Financial impact: What are the financial consequences attached to the opportunity or risk? These can be direct costs or monetary benefits, but also indirect costs, such as reputational damage or potential revenue losses or increases. 
• Likelihood: How likely is it that the risk will materialise?

By setting a threshold, we were able to separate material from non-material IROs. We consider an IRO to be ‘material’ if it scores high from an impact perspective and/or a financial perspective. To obtain external validation of the DMA results, we asked our key external stakeholders to provide feedback. The material topics were subsequently submitted internally for validation to the CSRD steering committee consisting of six department managers. Finally, the DMA results were approved by the Executive Board.

Energy transition

Our contribution to the National Transition Pathway

We have calculated the extent of Gasunie’s influence over the coming years on the Dutch ‘transition pathway’, i.e. on the way to full decarbonisation. This is our fifth time calculating this.

Under Our contribution to the National Transition Pathway in the ‘Energy transition’ section of this report, we show the impact of the investments we intend to make between now and 2030, and through to 2035 on greenhouse gas emissions in the Netherlands. We show what our influence on the transition pathway is and the average carbon emissions reduction rate the Netherlands must maintain to become net-zero by 2050. 

The more Gasunie’s sustainability projects are completed on time, the greater the volume of green energy and captured CO₂ we can start transporting for our customers. This increased sustainability will likely be accompanied by a decrease in the amount of fossil energy we transport. In the visuals presented in the section referred to above, we show the net emissions¹⁷ (the carbon footprint) of all the energy and the negative emissions from the CO₂ we transport to and from parties in the Netherlands on behalf of third parties. Reducing these emissions is made possible in part by feed-in parties, customers and project partners of Gasunie.

We only take into account the gases transported through the Gasunie network; we have not taken into account the contribution made by biomethane in the networks of the regional network operators, for example. Nor do we include any negative emissions from biomethane production. For hydrogen we have only included green hydrogen and imports; to avoid any double counting with CCS projects we have disregarded blue hydrogen.

To determine the contribution that will be made through our investments in biomethane and hydrogen, we assume that these will replace natural gas. This assumption results in a somewhat conservative estimate given that, if biomethane and hydrogen were to replace oil and/or coal, for example, the emission reduction contribution would be greater still. For CCS projects, the expected transport volumes of captured CO₂ from the Netherlands have been used; we have not included any storage of CO₂ from neighbouring countries in our calculations. Upstream emissions in the value chain are not included.

The emission reduction is determined relative to the situation in the base year 2023. We use the Climate and Energy Outlook report of current and intended policy published by the Netherlands Environmental Assessment Agency PBL as a reference for all external developments (outside Gasunie’s sustainability projects). For the years up to 2030, we use the 2025 edition of the Climate and Energy Outlook (link). For the years beyond 2030, we used the 2024 edition of the Climate and Energy Outlook (link), as the latest edition does not provide data for the post-2030 period. We use a natural gas emission factor of 56.2 kg/GJ (link).

In the figures, we only take into account the emission savings in the Netherlands. Gasunie’s energy transition investments can also contribute to emission reduction abroad, for example, through the transport of foreign CO₂ for storage in the Netherlands (cutting 1.5 Mt in emissions by 2030). 

Because Gasunie is also active in Germany, we have also included the emission reduction effect of our proposed investments for the German hydrogen network (Hyperlink) in the table. However, we do not include this effect when calculating our impact on the national transition pathway for the Netherlands. We have not calculated or visualised Gasunie’s impact on Germany’s national transition pathway, because the impact we can make in Germany is much smaller than in the Netherlands, where we are the sole natural gas TSO. 

In this report we only consider the impacts of our investments between 2020 and 2030 or 2035. A new series of Gasunie investments for the period after that could lead to a steeper decline along the Dutch transition pathway. 

The following two visuals provide a detailed forecast of our expected contribution to carbon emission reduction across Dutch society, as currently projected (2025 annual report), compared to the previous year (2024 annual report). 

We now expect our energy transition projects to enable users to cut 7.8 Mt of carbon emissions by 2030, compared to our estimate of 16.4 Mt in last year’s annual report.

The following two visuals provide a detailed forecast of our expected contribution to carbon emission reduction across German society, as currently projected (2025 annual report), compared to the previous year (2024 annual report). 

We now expect Hyperlink, i.e. our share in Kernnetz, to be able to facilitate a reduction of 1.3 Mt by 2030 (forecast from last year’s annual report: 4.4 Mt by 2030).

Taxonomy

The EU Taxonomy tables are based on the consolidated financial statements. All of our eligible activities are allocated to activities associated with the climate change mitigation objective, meaning that there is no question of claiming multiple climate objectives for one and the same activity. We have chosen not to apply the Delegated Regulation amending the Delegated Taxonomy Regulations of 4 July 2025 earlier than proposed in the European Commission’s Questions and Answers on EU Taxonomy simplifications.

Capex KPI 

We calculated the share of Taxonomy-eligible economic activities in our investments in capital goods (CAPEX) by dividing the CAPEX of these activities (numerator) by the total CAPEX (denominator). The numerator and denominator include our investments in property, plant and equipment and intangible assets. In addition, we have described our investments in joint ventures through which Taxonomy-eligible activities are realised. The items mentioned above are further explained in note 4 ‘Property, plant and equipment’, note 5 ‘Intangible assets’ and note 7 ‘Investments in joint ventures’ to the consolidated financial statements. 

Opex KPI 

We calculated the share of Taxonomy-eligible economic activities in our OPEX by dividing the OPEX of these activities (numerator) by the total OPEX (denominator). We included the personnel expenses and other expenses in the denominator, corrected for costs attributed to investments and overhead costs.

The other costs also include the cost of network operations, which mainly concerned the procurement of nitrogen production capacity and electricity for the production of nitrogen and the cost of electricity and gas for gas transport and storage operations. These costs are inextricably linked to the uninterrupted and effective operation of our assets.

Revenue KPI

We calculated the share of Taxonomy-eligible economic activities in our total revenue by dividing the revenue from Taxonomy-eligible activities (numerator) by the total net revenue (denominator) as specified in the consolidated statement of profit or loss for 2025. The accounting policies used with regard to net revenue are explained in more detail in the consolidated financial statements.

Emissions

For the consolidation of our GHG emissions (Scopes 1, 2 and 3) we use the operational control approach, which means that, in addition to including our group companies and joint operation (BBL Company) in the consolidation, we also include the GHG emissions of our EemsEnergyTerminal joint venture. We have included the emissions of joint ventures over which we have no operational control in Scope 3 (category 15).

To be able to add up the impact of the various GHG emissions, emissions relating to each particular gas are converted to CO2e (carbon dioxide equivalent). The emission factors we use for this are taken from reputable databases, such as emissiefactoren.nl for the Netherlands and international equivalents, where applicable, such as DEFRA (the UK’s Department for Environment, Food & Rural Affairs) and DEHst (German Emissions Trading Authority). Our greenhouse gas emissions are not just strictly methane emissions: they include CO₂ emissions caused by combustion of fossil fuels and, to a minor degree, also refrigerants, SF6 and diesel. 

Scope 1 and 2 emissions 

We use Guarantees of Origin (GOs) to prove the renewable source of the electricity. In the Netherlands, Gasunie purchased GOs from European wind farms in 2025. In Germany, Gasunie procured green electricity directly from its electricity supplier. In total, we compensated 99.1% of our total Scope 2 emissions (2024: 99.7%).

In 2025, we decarbonised 9,000 MWh of our natural gas consumption using Guarantees of Origin (GOs) (2024: 40,873 MWh). We have not deducted this amount from our Scope 1 emissions disclosed in the Scope 1, 2 and 3 ESRS tables¹⁸.

Scope 3 emissions

The following will provide a more detailed explanation of the Scope 3 categories that are significant to Gasunie. Categories 8, 9, 10, 11 and 14 are not part of our Scope 3 emissions because they do not apply to Gasunie’s business operations.

Category 2: Capital goods 

This category includes all upstream (cradle-to-gate) emissions from the extraction, production and transport of capital goods (pipelines, equipment, IT hardware, buildings, facilities and vehicles) procured by Gasunie. Emissions for capital goods relate to all capital expenditures and therefore cannot be related to operating expenses that occur on an annual basis. Emissions associated with capital goods are attributed to the year when the expenditures occurred to guarantee consistency with financial reporting.

Category 1: Purchased goods and services 

For Gasunie, this category is the second most prominent one of the Scope 3 categories. In this category, we record the emissions generated from the procurement of our goods (other than capital goods) and services. Emissions related to the procurement of nitrogen are also included in this category. Where possible, we make arrangements with suppliers for them to decarbonise their energy usage, including through the purchase of GOs, which pushes down emissions for the value chain as a whole. Other goods and services (pipeline materials, engineering and maintenance services, odorant, inspections using helicopters) are also significant contributors to emissions across the value chain. For the most dominant of these goods and services, i.e. pipelines, valves, IT, engineering services and contracting, we are in talks or will commence talks with suppliers on emission reduction.

Category 3: Fuel- and energy-related activities 

This category includes emissions related to the extraction, production and transport of fuels and electricity purchased and consumed in the reporting year, which are not included in Scope 1 or Scope 2. All upstream emissions and transport and distribution losses of purchased fuel and electricity (wheel-to-tank) are reported in this category. This category also covers emissions caused by losses during the transmission and distribution of electricity and upstream emissions from methane leaks (as part of Scope 1).

Scope 3 emission calculation

For our Scope 3 emission calculations for 2025, we were able to obtain primary data that covers 48% of our Scope 3 emissions (2024: 35%, 2023 (base year): 41%). Wherever primary data was not available or not available in time, we used secondary data. The increase in the percentage of primary data is the result of the fact that in 2025 we procured more (capital) goods and services (categories 1 and 2) for which primary data was available. Implementation of our supplier engagement programme has also led to us receiving more primary data for our Scope 3 reporting this year. The aim in the long term is to keep improving data quality and reducing data uncertainty, so that we can ultimately track our performance as effectively as possible.

The methodology we applied in 2025 has not changed compared to 2024 and 2023 (base year). Given that the recent update to the DEFRA database has a material impact on our Scope 3 emissions, we have recalculated the comparative figures for the 2024 and 2023 (base year) emission years. We applied three different methods to map our Scope 3 emissions:

1. Spend method: Emissions are determined based on the spend of the relevant categories. Procurement data (in euros) is combined with emission factors from the most recent DEFRA database (2022), corrected for inflation based on data from Statistics Netherlands. 
2. Volume basis: Emissions are determined based on the actual ‘volume’ of the product or service (for example: kilograms, distance travelled, amount of energy used). Data from our suppliers is combined with emission factors from CO₂-emissiefactoren.nl (2025).
3. Supplier specific: Emissions are calculated by our suppliers. Emissions from publicly available annual reports or sustainability statements are multiplied by the ratio of our spend to a supplier’s total revenue. In 2025, we received emission data for several of our suppliers directly from those suppliers. Our aim is to get more data directly from suppliers over the coming years. 

Policy

Our current biodiversity policy focuses on nature-inclusive design, construction, operation and decommissioning. Gasunie has drawn up guidelines to ensure that biodiversity-enhancing measures are implemented at the various project stages.

We embrace biodiversity as a material topic. At the same time, however, we recognise that further steps are needed to fully develop our biodiversity policy. In 2025, we began drafting a biodiversity action plan to align goals, policy and action plans. We will also seek to align this plan with our existing sustainability strategy.

Action plans

The actions needed to achieve our biodiversity goals will be detailed in the aforementioned biodiversity action plan.

Resources

In 2026, we will work out the resources we will need to implement the action plan.

Measurable targets 

In 2026, we will determine which measurable targets we aim to achieve. In 2028, i.e. in our 2027 annual report, we want to publish our first comprehensive biodiversity disclosures in accordance with the ESRS E4 standard.

Circularity

Assumptions in calculating the kilograms of steel and recycled materials used for the steel procured

At the Procurement department, we record the amount of steel purchased (in kilograms) where possible, as well as the percentage of secondary reused or recycled materials contained within that steel. We calculate the weight of purchased pipelines based on available data. If weights for certain items are unknown and cannot be calculated, we extrapolate a figure based on expenditure.

The following assumptions were used in calculating the amount of steel purchased (in tonnes) and the proportion of secondary reused or recycled materials (in percentages and tonnes):

Assumptions in calculating kilograms of steel

• To determine the total weight in kilograms of procured steel, the following products were used: pipes, flanges, valves, pressure equipment and pressure vessels, bends and couplings.
• The assumption for calculating the weight of these products in kilograms is that they are made fully of steel.
• For pipes, the following method was used to calculate the weight in kilograms of a metre of pipe procured: Kg/meter = (R² - (R -2 x WD) ²)  x (π/4) x 1000 x 7850/1.000.000.000
  R = outer radius; WD = wall thickness, π = pi (the mathematical constant, approx. 3.14159); 7850 = the density of steel; with 1000 and 1000000000 being conversion factors used to calculate the correct units.
• The weights of flanges, valves, pressure equipment and pressure vessels, bends and couplings in kilograms was determined by linking the numbers of purchased items to the weights listed in the corresponding design drawings. 
• If the weight of certain components cannot be determined or calculated due to missing information, an estimate is made by extrapolating from the calculated figures by product.

Assumptions for the kilograms of secondary reused or recycled materials used for procured steel

• Where available, Environmental Product Declarations (EPDs) are used to report the percentage of secondary materials.
• If no EPD is available, we use the percentage of secondary materials provided by the supplier (Mokveld).
• In the absence of supplier information, the EPD by Mannesmann Line Pipe is used. This pipe manufacturer also supplies to Gasunie through other suppliers. The percentage used (18%) is conservative compared to the typical amount of scrap added to the blast furnace process (15–25%).

Diversity

Actions

Inclusive and diverse leadership (MT)

Gasunie invests in HARRIE training courses 
Gasunie has set itself the goal of creating permanent positions for talented people with poor prospects of finding a fulfilling job on the regular job market. Offering HARRIE training courses through CNV Jongeren is one way of providing the right guidance to achieve this. HARRIE is offered to anyone who would like to make themselves available as a buddy for a colleague with otherwise poor prospects of finding a fulfilling job, who perhaps needs different or just a little more guidance in their daily work compared to other employees. So this facility is explicitly not just for Gasunie managers. HARRIE is a Dutch initialism that stands for ‘Helpful, Alert, Calm, Realistic, Instructing and Honest’. By having multiple ‘HARRIES’, we ensure an inclusive and diverse organisation where the principle of equity is given a high priority.

Room for talent (MT)

Referral bonuses
Gasunie uses its own employees to attract talent through our referral programme. Our colleagues can give family, friends and acquaintances first-hand information about the jobs available at Gasunie and how they can also contribute to the energy transition. The referral programme is particularly useful as a tool for finding the right people for hard-to-fill positions. Our employees receive a bonus for bringing in new talent and can choose to either keep the bonus for themselves or donate it to charity.

Talent pools
In the rapidly changing environment in which Gasunie operates, managers have to satisfy demanding requirements. To ensure that they can meet those requirements, specific training programmes have been developed for them. We have training and educational programmes in various areas. These include traineeships, LEAD (Leadership, Empowerment and Development) courses for senior management, HighTech courses for managers in technical positions, and a campus recruiter who focuses on students in BBL9 apprenticeship training programmes at secondary vocational level.

Recruitment and selection procedures
Gasunie applies the following principles in recruitment, selection, advancement and promotion:

• In our company, everyone with the same competencies, agility and potential has an equal chance of being selected for a position.
• We do our best to ensure that no one feels discriminated against and we apply relevant and objective criteria when recruiting and selecting.
• We value differences.
• Our aim is to build a workforce that representatively reflects diversity in society.
• We offer people with poor job prospects additional opportunities.

People with poor job prospects
We want every talent to have the opportunity to develop. Gasunie offers internal budgets to have people with poor job prospects join departments on top of normal staffing levels for a maximum of two years, along with job coaching and support for both employees and their mentors. This allows us to take ample time to assess whether we can offer people with poor job prospects a workplace for the long term, in collaboration with Randstad RiseSmart.

Executive Board, Supervisory Board and management gender balance
In Gasunie’s view, an Executive Board and Supervisory Board should have a diverse and balanced composition. Having a balanced and diverse Executive Board and Supervisory Board contributes to the quality of the decision-making process and is also important from an equity perspective. A diverse board can have a positive impact on equity. Through job profiles and recruitment agency search queries, we explicitly request and focus on candidates who provide diversity.

Promotion of further education and training
At Gasunie, we offer everyone scope and equal opportunities to pursue personal and professional development. Through our offer of further education and training courses and our focus on personal development, we strive diligently to create equal opportunities for all. We collectively use a Sustainable Employability budget for programmes and investments that contribute to making and keeping employees healthy, such as ‘Master your Energy’. Gasunie wants fit, agile employees who can continue to adapt in a world that is constantly changing, and for this lifelong learning is essential. By employees honing their skill set and learning new skills, they increase their eligibility for career advancement and can take advantage of more opportunities.

Connected (LT)

Training
To engage all Gasunie employees in Gasunie’s DEI statement and policy, and to create awareness and commitment, employees need to have their attention focused on DEI on an ongoing basis. A few examples of how this is accomplished are: 

• eLearning courses on DEI within Gasunie
• unconscious bias courses, general DEI training and guidance on dealing with diversity
• DEI during recruitment.

Workplace
Gasunie carefully weighs as many interests as possible in developing premises. For example, Gasunie sees to it that there are multiple restrooms for colleagues with reduced mobility. Premises are designed based on a vision that ensures an accessible workplace, quiet rooms, lactation rooms and low-stimulation spaces. Working from home is another option that can be used for employees with a neurodiverse condition, based on the principle that low-stimulation working environments are conducive to health and work.

Implementation of the new operating model

As soon as the very first outlines of the design of the new operating model emerged, the Works Council engaged in intensive and frequent consultations with the Executive Board and with the Transformation Team that prepared the implementation of the new operating model. This early, constructive involvement allowed us to raise points for attention during the design phase and exert real influence on the new organisational structure, both in terms of its setup and the conditions for collaboration, governance and decision-making. This aligns with the approach established in our responses to requests for advice on the operating model, which was to ensure clear roles and responsibilities, consistent processes and a management philosophy that promotes decisive action, with a specific focus on culture and conduct.

There is more to a change of this scale than just drawing lines on an organisational chart. Since behavioural and cultural aspects are critical for success, the Works Council consistently stressed the importance of the interconnection between structure, leadership and collaboration. In addition, we advised the management to lead by example, to ensure that the new ways of working actually take hold in practice. 

Culture and conduct: start of the culture programme

The first of October saw the launch of the culture programme associated with the implementation of the new operating model, in which the Works Council fulfils a sounding board role. We provide feedback, both solicited and unsolicited, and help interpret signals from the organisation at an early stage. Our approach has remained consistent throughout, as we called on the management to make clear choices, embed them in simple, workable agreements and ensure visible, consistent follow-up, especially where value chain collaboration and mandates intersect.

Regular employee participation

In addition to the transformation, we handled a series of regular requests for advice and consent in 2025. These processes saw the Works Council, as per usual, assess the necessity, proportionality, support and feasibility of changes proposed by the management. Where necessary, we formulated preconditions and mitigating measures.

Talks with employees across the country 

To stay connected with all employees in the company, the Works Council organises various meetings at locations across the Netherlands. These meetings always take the form of an employee lunch, during which we can talk personally with employees and discuss various matters at length. This provides valuable insights we can use when handling requests for advice and requests for consent and which, when appropriate, we raise in consultations with the management of a particular department or with HR. Topics that come up repeatedly in these consultations include workload, change fatigue, the growth of the company and, of course, implementation of the new operating model. In addition, we always ask about the current state of affairs with respect to safety, accommodation and efficiency. After all, these continue to be our key focus areas. In 2025, we held 8 meetings with employees (2024: 7).

Executive Board changes

The year 2025 saw significant changes at the top of the organisation. In January, the Works Council welcomed interim CFO Jan Boekelman to the company. Over the course of the year, the Works Council issued a positive advisory opinion on the appointments of COO Marc van der Linden and CTO Bart Leenders. Finally, the Works Council also issued a positive advisory opinion on the appointment of CFO Katie Slipper, effective January 2026.

• he introductory meetings with Jan Boekelman were positive. The appointment of an interim CFO aligned seamlessly with the need for continuity in the financial domain.
• Regarding the appointment of COO Marc van der Linden, the Works Council issued a positive advisory opinion following consultations that focused on the management of capital-intensive projects, delivering predictable results, and attention to culture and leadership. 
• The Works Council also issued positive advisory opinions on CTO Bart Leenders and CFO Katie Slipper. These appointments address the need to strengthen our technical and financial leadership for the next phase of the energy transition.

What the Works Council considered essential

• Early involvement in design choices and the implementation approach, ensuring feasibility and workability for employees;
• Interconnection of structure, culture and behaviour. Without clear leadership and leading by example, the operating model will not take hold. The Works Council has made a point of highlighting this throughout the year; 
• Continuity in governance amidst board changes, balancing internal knowledge with external renewal. 

Outlook for 2026

The coming period will be about making the new operating model and working method work in practice. This includes optimising processes, improving role clarity, actually using mandates and aiming for predictable results while allowing space to learn and adjust. The Works Council will continue to be a critical ally in this process. We will be constructive where possible, and tenacious when we have to be. We will continue to pursue the culture programme, monitor the effects of the reorganisation on workload and employee well-being, and maintain close dialogue with colleagues, the Executive Board and the Transformation Team.

A word of thanks

The Works Council would like to thank all colleagues for their openness and commitment, the Executive Board and the Transformation Team for their close collaboration, and fellow employee representatives for their professional support. The transition posed considerable challenges for all of us, and so we truly value the resilience and professionalism shown in 2025.