Publication requirements
European Sustainability Reporting Standards (ESRS) covered by the Royal Heijmans N.V. Sustainability Report
Norm |
Description |
Section |
Page numbers |
---|---|---|---|
ESRS 2 |
|||
ESRS 2 BP-1 |
General basis for the preparation of sustainability statements |
About this report; Reporting principles applied; Business model and strategy |
163, 165, 166 |
ESRS 2 BP-2 |
Disclosures in relation to specific circumstances |
Reporting principles applied; Metric requirements |
165, 281 |
ESRS 2 GOV-1 |
The role of administrative management and supervisory bodies |
Executive Board; Supervisory Board; Reporting principles applied |
116, 117, 165 |
ESRS 2 GOV-2 |
Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies |
Integration of CSRD-driven impacts, risks and opportunities; Double materiality analysis; Policy, actions, key performance indicators and targets |
161, 175, 178 |
ESRS 2 GOV-3 |
Integration of sustainability-related performance in incentive schemes |
Remuneration report ; Inclusion via references |
133, 164 |
ESRS 2 GOV-4 |
Statement on due diligence |
Due diligence statement ; Human rights due diligence |
178, 242 |
ESRS 2 GOV-5 |
Risk management and internal controls over sustainability reporting |
Integration of CSRD-driven impacts, risks and opportunities |
161 |
ESRS 2 SBM -1 |
Strategy, business model and value chain |
Business model and strategy; Value creation model; We are Heijmans, creators of the healthy living environment |
166, 169, 170 |
ESRS 2 SBM -2 |
Interests and views of stakeholder |
In dialogue with stakeholders |
174 |
ESRS 2 SBM-3 |
Material impacts, risks and opportunities and their interaction with strategy and business model |
Business model and strategy |
166 |
ESRS 2 IRO-1 |
Description of the processes to identify and assess material impacts, risks and opportunities |
Integration of CSRD-driven impacts, risks and opportunities; In dialogue with stakeholders; Double materiality analysis |
161, 174, 175 |
ESRS 2 IRO-2 |
Disclosure requirements in ESRS covered by the undertaking’s sustainability statement |
Policy, actions, key performance indicators and targets; List of data points derived from other EU legislation; Metric requirements |
178, 274, 281 |
ESRS 2 MDR-P |
Policies adopted to manage material sustainability matters |
Policy, actions, key performance indicators and targets; Thematic chapters - Policy |
178, 185, 206, 217, 225, 245, 255, 259 |
ESRS 2 MDR-A |
Actions and resources in relation to material sustainability matters |
Policy, actions, key performance indicators and targets; Thematic chapters - Actions |
178, 190, 208, 219, 225, 247, 257, 259 |
ESRS 2 MDR-M |
Metrics in relation to material sustainability matters |
Requirements of the criteria; Thematic chapters - Metrics |
209, 226, 250, 259, 281 |
ESRS 2 MDR-T |
Tracking effectiveness of policies and actions through targets |
Policy, actions, key performance indicators and targets; Thematic chapters - Targets |
178, 187, 209, 221, 225, 250, 258, 259 |
ESRS E1 |
|||
ESRS 2 GOV-3 |
Integration of sustainability-related performance in incentive schemes |
Remuneration report; Inclusion via references |
133, 164 |
ESRS 2 SBM-3 |
Material impacts, risks and opportunities and their interaction with strategy and business model |
Climate - Impacts, risks and opportunities |
181 |
ESRS 2 IRO-1 |
Description of the processes to identify and assess material climate impacts, risks and opportunities |
Climate - Impacts, risks and opportunities |
181 |
ESRS E1 -1 |
Transition plan for climate change mitigation |
Climate - Policy; Targets; Actions |
185, 187, 190 |
ESRS E1 -2 |
Policies related to climate change mitigation and adaptation |
Climate - Policy |
185 |
ESRS E1- 3 |
Actions and resources in relation to climate change policies |
Climate - Actions |
190 |
ESRS E1 -4 |
Targets related to climate change mitigation and adaptation |
Climate - Targets |
187 |
ESRS E1 -5 |
Energy consumption and mix |
Climate - Energy use |
193 |
ESRS E1 -6 |
Gross scope 1, 2 and 3 and total GHG emissions |
Climate - Greenhouse gas emissions |
194 |
ESRS E1 -7 |
GHG removals and GHG mitigation projects financed through carbon credits |
Climate - Greenhouse gas removals; Offsetting with carbon credits |
202, 203 |
ESRS E1 -8 |
Internal carbon pricing |
Climate - Internal carbon pricing |
204 |
ESRS E1 -9 |
Anticipated financial effects from material physical and transition risks and potential climate-related opportunities |
Phasing-in applied |
- |
ESRS E3 |
|||
ESRS 2 IRO-1 |
Description of the processes to identify and assess material water and marine resources-related impacts, risks and opportunities |
Double materiality; In dialogue with stakeholders |
172, 174 |
ESRS E3 -1 |
Policies related to water and marine resources |
Water - Policy |
206 |
ESRS E3 -2 |
Actions and resources related to water and marine resources |
Water - Actions |
208 |
ESRS E3 -3 |
Targets related to water and marine resources |
Water - Targets |
209 |
ESRS E3 -4 |
Water consumption |
Water - Metrics |
209 |
ESRS E3-5 |
Anticipated financial effects from water and marine recources-related impacts, risks and opportunities |
Not material |
- |
ESRS E4 |
|||
ESRS 2 SBM-3 |
Material impacts, risks and opportunities and their interaction with strategy and business model |
Biodiversity - Impacts, risks and opportunities |
212 |
ESRS 2 IRO-1 |
Description of processes to identify and assess material biodiversity and ecosystem-related impacts, risks and opportunities |
Biodiversity - Impacts, risks and opportunities |
212 |
ESRS E4 -1 |
Transition plan and consideration of biodiversity and ecosystems in strategy and business model |
Biodiversity - Resilience analysis |
215 |
ESRS E4 -2 |
Policies related to biodiversity and ecosystems |
Biodiversity - Policy |
217 |
ESRS E4 -3 |
Actions and resources related to biodiversity and ecosystems |
Biodiversity - Actions |
219 |
ESRS E4 -4 |
Targets related to biodiversity and ecosystems |
Biodiversity - Targets |
221 |
ESRS E4 -5 |
Impact metrics related to biodiversity and ecosystems |
Phase-in applied |
- |
ESRS E4 -6 |
Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunities |
Phase-in applied |
- |
ESRS E5 |
|||
ESRS 2 IRO-1 |
Description of the processes to identify and assess material resource use and circular economy-related impacts, risks and opportunities |
Double materiality; In dialogue with stakeholders; |
172, 174 |
ESRS E5 -1 |
Policies related to resource use and circular economy |
Resource use and circular economy - Policy |
225 |
ESRS E5 -2 |
Action and resources related to resource use and circular economy |
Resource use and circular economy - Actions and targets |
225 |
ESRS E5 -3 |
Targets related to resource use and circular economy |
Resource use and circular economy - Actionss and targets |
225 |
ESRS E5 -4 |
Resource inflows |
Not material |
- |
ESRS E5 -5 |
Resource outflows |
Resource use and circular economy - Metrics |
226 |
ESRS E5 -6 |
Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities |
Phase-in applied |
- |
ESRS S1 |
|||
ESRS 2 SBM-2 |
Interests and views of stakeholder |
In dialogue with stakeholders |
174 |
ESRS 2 SBM-3 |
Material impacts, risks and opportunities and their interaction with strategy and business model |
Social information |
240 |
ESRS S1 -1 |
Policies related to own workforce |
Own workforce - Policy |
245 |
ESRS S1 -2 |
Processes for engaging with own workers and workers' representatives about impacts |
Social Information -Human rights due diligence; Own employees - Actions |
242, 247 |
ESRS S1 -3 |
Channels for own workers and workers' represenatatives to raise concerns |
Own workforce - Actions |
247 |
ESRS S1 -4 |
Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities |
Own workforce - Actions |
247 |
ESRS S1 -5 |
Taking action on material impacts on own workforce and effectiveness of those actions |
Own workforce - Targets |
250 |
ESRS S1 -6 |
Characteristics of the Undertaking's Employees |
Own workforce - Metrics |
250 |
ESRS S1- 7 |
Characteristics of non-employee workers in the undertaking's own workforce |
Own workforce - Metrics |
250 |
ESRS S1 -8 |
Collective bargaining coverage and social dialogue |
Own workforce - Metrics - Representation |
251 |
ESRS S1 -9 |
Diversity metrics |
Own workforce - Metrics |
250 |
ESRS S1- 10 |
Adequate wages |
Own workforce - Metrics - Remuneration |
251 |
ESRS S1- 11 |
Social protection |
Not material |
- |
ESRS S1- 12 |
Persons with disabilities |
Phase-in applied |
- |
ESRS S1- 13 |
Training and skills development metrics |
Not material |
- |
ESRS S1 -14 |
Health and safety standards |
Own workforce - Metrics - Accidents and sickness |
252 |
ESRS S1- 15 |
Work-life balance metrics |
Not material |
- |
ESRS S1 -16 |
Compensation metrics (pay gap and total compensation) |
Not material |
- |
ESRS S1 -17 |
Incidents, complaints and severe human rights impacts |
Own workforce - Metrics - Incidents and complaints |
252 |
ESRS S2 |
|||
ESRS 2 SMB-2 |
Interests and views of stakeholders |
In dialogue with stakeholders |
174 |
ESRS 2 SBM-3 |
Material impacts, risks and opportunities and their interaction with strategy and business model |
Workers in the value chain |
254 |
ESRS S2 -1 |
Policies related to value chain workers |
Workers in the value chain - Policy |
255 |
ESRS S2 -2 |
Processes for enganging with value chain workers about impacts |
Workers in the value chain - Involving employees in the value chain in the process and decision-making |
256 |
ESRS S2 -3 |
Processes to remediate negative impacts and channels for value chain workers to raise concerns |
Workers in the value chain - Actions |
257 |
ESRS S2 -4 |
Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions |
Workers in the value chain - Actions |
257 |
ESRS S2 -5 |
Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities |
Workersin the value chain - Targets |
258 |
ESRS G1 |
|||
ESRS 2 GOV-1 |
The role of administrative, supervisory and management bodies |
Executive Board; Supervisory Board; Reporting principles applied |
116, 117, 165 |
ESRS 2 IRO-1 |
Description of the processes to identify and assess material impacts, risks and opportunities |
Integration of CSRD-driven impacts, risks and opportunities; Double materiality; In dialogue with stakeholders |
172, 174, 161 |
ESRS G1 - 1 |
Corporate culture and business conduct policies and corporate culture |
(Business) Conduct and Integrity - Culture and structure |
261 |
ESRS G1 - 2 |
Management of relationships with suppliers |
(Business) Conduct and Integrity - Dealing with suppliers and subcontractors |
267 |
ESRS G1 - 3 |
Prevention and detection of corruption or bribery |
(Business) Conduct and Integrity - Prevention and detection of corruption and bribery |
266 |
ESRS G1 - 4 |
Confirmed incidents of corruption and bribery |
(Business) Conduct and Integrity - Prevention and detection of corruption and bribery |
266 |
ESRS G1 - 5 |
Political influence and lobbying activities |
Not material |
- |
ESRS G1 - 6 |
Payment practices |
(Business) Conduct and Integrity - Dealing with suppliers and subcontractors - Payment term |
268 |
List of data points derived from other EU legislation
ESRS |
DR |
Requirement |
Description |
Section |
Legislation |
Page number |
---|---|---|---|---|---|---|
ESRS 2 |
GOV-1 |
21 (d) |
The role of administrative, management and supervisory bodies |
Executive Board; Supervisory Board; Reporting principles applied |
SFDR & BRR |
116, 117, 165 |
ESRS 2 |
GOV-1 |
21 (e) |
The role of administrative, management and supervisory bodies |
Executive Board; Supervisory Board; Reporting principles applied |
BRR |
116, 117, 165 |
ESRS 2 |
GOV-4 |
30 |
Statement on due diligence |
Due diligence statement; Human rights due diligence |
SFDR |
178, 242 |
ESRS 2 |
SBM-1 |
40 (d) i |
Strategy, business model and value chain disclosure |
Phase-in applied |
SFDR, Pillar 3 & BRR |
- |
ESRS 2 |
SBM-1 |
40 (d) ii |
Strategy, business model and value chain disclosure |
Phase-in applied |
SFDR & BRR |
- |
ESRS 2 |
SBM-1 |
40 (d) iii |
Strategy, business model and value chain disclosure |
Phase-in applied |
SFDR & BRR |
- |
ESRS 2 |
SBM-1 |
40 (d) iv |
Strategy, business model and value chain disclosure |
Phase-in applied |
BRR |
- |
E1 |
E1-1 |
14 |
Transition plan for climate change mitigation |
Climate - Policy; Targets; Actions |
EU Climate Law |
185, 187, 190 |
E1 |
E1-1 |
16 (g) |
Transition plan for climate change mitigation |
Climate - Policy; Targets; Actions |
Pillar 3 & BRR |
185, 187, 190 |
E1 |
E1-4 |
34 |
Targets related to climate change mitigation and adaptation |
Climate - Targets |
SFDR, Pillar 3 & BRR |
187 |
E1 |
E1-5 |
37 |
Energy consumption and mix |
Climate - Energy use |
SFDR |
193 |
E1 |
E1-5 |
38 |
Energy consumption and mix |
Climate - Energy use |
SFDR |
193 |
E1 |
E1-5 |
40-43 |
Energy consumption and mix |
Climate - Energy use |
SFDR |
193 |
E1 |
E1-6 |
44 |
Gross scope 1, 2 and 3 and total GHG emissions |
Climate - Greenhouse gas emissions |
SFDR, Pillar 3 & BRR |
194 |
E1 |
E1-6 |
53-55 |
Gross scope 1, 2 and 3 and total GHG emissions |
Climate - Greenhouse gas emissions |
SFDR, Pillar 3 & BRR |
194 |
E1 |
E1-7 |
56 |
GHG removals and GHG mitigation projects financed through carbon credits |
Climate - Greenhouse gas removals; Offsetting with carbon credits |
EU Climate Law |
202, 203 |
E1 |
E1-9 |
66 |
Anticipated financial effects from material physical and transition risks and potential climate-related opportunities |
Phase-in applied |
BRR |
- |
E1 |
E1-9 |
66 (a) & 66 (c) |
Anticipated financial effects from material physical and transition risks and potential climate-related opportunities |
Phase-in applied |
Pillar 3 |
- |
E1 |
E1-9 |
67 (c) |
Anticipated financial effects from material physical and transition risks and potential climate-related opportunities |
Phase-in applied |
Pillar 3 |
- |
E1 |
E1-9 |
69 |
Anticipated financial effects from material physical and transition risks and potential climate-related opportunities |
Phase-in applied |
BRR |
- |
E2 |
E2-4 |
28 |
Pollution of air, water and soil |
Not material |
SFDR |
- |
E3 |
E3-1 |
9 |
Policies related to water and marine resources |
Water - Policy |
SFDR |
206 |
E3 |
E3-1 |
13 |
Policies related to water and marine resources |
Water - Policy |
SFDR |
206 |
E3 |
E3-1 |
14 |
Policies related to water and marine resources |
Water - Policy |
SFDR |
206 |
E3 |
E3-4 |
28 (c) |
Water consumption |
Water - Metrics |
SFDR |
209 |
E3 |
E3-4 |
29 |
Water consumption |
Water - Metrics |
SFDR |
209 |
E4 |
E4.SBM-3 |
16 a i |
Material impacts, risks and opportunities and their interaction with strategy and business model |
Biodiversity - Impacts, risks and opportunities |
SFDR |
212 |
E4 |
E4.SBM-3 |
16 b |
Material impacts, risks and opportunities and their interaction with strategy and business model |
Biodiversity - Impacts, risks and opportunities |
SFDR |
212 |
E4 |
E4.SBM-3 |
16 c |
Material impacts, risks and opportunities and their interaction with strategy and business model |
Biodiversity - Impacts, risks and opportunities |
SFDR |
212 |
E4 |
E4-2 |
24 b |
Policies relatied to biodiversity and ecosystems |
Biodiversity - Policy |
SFDR |
217 |
E4 |
E4-2 |
24 c |
Policies relatied to biodiversity and ecosystems |
Biodiversity - Policy |
SFDR |
217 |
E4 |
E4-2 |
24 d |
Policies relatied to biodiversity and ecosystems |
Biodiversity - Policy |
SFDR |
217 |
E5 |
E5-5 |
37 (d) |
Resource outflows |
Not material |
SFDR |
- |
E5 |
E5-5 |
39 |
Resource outflows |
Not material |
SFDR |
- |
S1 |
S1.SBM-3 |
14 f |
Material impacts, risks and opportunities and their interaction with strategy and business model |
Not material |
SFDR |
- |
S1 |
S1.SBM-3 |
14 g |
Material impacts, risks and opportunities and their interaction with strategy and business model |
Not material |
SFDR |
- |
S1 |
S1-1 |
20 |
Policies related to our own workforce |
Own workforce - Policy |
SFDR |
245 |
S1 |
S1-1 |
21 |
Policies related to our own workforce |
Own workforce - Policy |
BRR |
245 |
S1 |
S1-1 |
22 |
Policies related to our own workforce |
Own workforce - Policy |
SFDR |
245 |
S1 |
S1-1 |
23 |
Policies related to our own workforce |
Own workforce - Policy |
SFDR |
245 |
S1 |
S1-3 |
32 c |
Processes to remediate negative impacts and channel for own workers to raise concern |
Own workforce - Actions |
SFDR |
247 |
S1 |
S1-14 |
88 b & 88 c |
Health and safety metrics |
Own workforce - Metrics - Accidents and sickness |
SFDR & BRR |
252 |
S1 |
S1-14 |
88 e |
Health and safety metrics |
Own workforce - Metrics - Accidents and sickness |
SFDR |
252 |
S1 |
S1-16 |
97 a |
Compensation metrics (Pay gap and total remuneration) |
Not material |
SFDR & BRR |
- |
S1 |
S1-16 |
97 b |
Compensation metrics (Pay gap and total remuneration) |
Not material |
SFDR |
- |
S1 |
S1-17 |
103 a |
Incidents, complaints and severe human rights impacts |
Own workforce - Metrics - Incidents and complaints |
SFDR |
252 |
S1 |
S1-17 |
104 a |
Incidents, complaints and severe human rights impacts |
Own workforce - Metrics - Incidents and complaints |
SFDR & BRR |
252 |
S2 |
S2.SBM-3 |
11 b |
Material impacts, risks and opportunities and their interaction with strategy and business model |
Workers in the value chain - Impacts, risks and opportunities |
SFDR |
254 |
S2 |
S2-1 |
17 |
Policies related to value chain workers |
Workers in the value chain - Policy |
SFDR |
255 |
S2 |
S2-1 |
18 |
Policies related to value chain workers |
Workers in the value chain - Policy |
SFDR |
255 |
S2 |
S2-1 |
19 |
Policies related to value chain workers |
Workers in the value chain - Policy |
SFDR & BRR |
255 |
S2 |
S2-4 |
36 |
Taking action on material impacts on value chain workers, and approaches to mitigating material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions |
Workers in the value chain - Actions |
SFDR |
257 |
S3 |
S3-1 |
16 |
Policies related to affected communities |
Not material |
SFDR |
- |
S3 |
S3-1 |
17 |
Policies related to affected communities |
Not material |
SFDR & BRR |
- |
S3 |
S3-4 |
36 |
Taking action on material impacts on affected communities, and approaches to mitigating material risks and pursuing material opportunities related to affected communities, and effectiveness of those actions |
Not material |
SFDR |
- |
- |
||||||
S4 |
S4-1 |
16 |
Policies related to consumers and end-users |
Not material |
SFDR |
- |
S4 |
S4-1 |
17 |
Policies related to consumers and end-users |
Not material |
SFDR, BRR |
- |
S4 |
S4-4 |
35 |
Taking action on material impacts on consumers and end-users, and approaches to mitigating material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions |
Not material |
SFDR |
- |
G1 |
G1-1 |
10 b |
Corporate culture and business conduct policies |
(Business) Conduct and Integrity - Culture and structure |
SFDR |
261 |
G1 |
G1-1 |
10 d |
Corporate culture and business conduct policies |
(Business) Conduct and Integrity - Culture and structure |
SFDR |
261 |
G1 |
G1-4 |
24 a |
Confirmed incidents of corruption or bribery |
(Business) Conduct and Integrity - Prevention and detection of corruption and bribery |
SFDR, BRR |
266 |
G1 |
G1-4 |
24 b |
Confirmed incidents of corruption or bribery |
(Business) Conduct and Integrity - Prevention and detection of corruption and bribery |
SFDR |
266 |
BRR = Benchmark Regulation Reference |
Biodiversity appendices
Results of biodiversity analysis scoping
Heijmans first looked at which economic activities occur in our direct operations. We compared our own operations from SAP wiht the International Standard Industrial Classification of All Economic Activities standard. We then performed an analysis in the ENCORE database based on our economic activities. The ENCORE (Exploring Natural Capital Opportunities, Risks and Exposure) database maps the relationship between sectors, subsectors and activities, and records the potential impacts on and dependencies of nature. ENCORE assigns a materiality level to each economic activity, ranging from ‘Not Material’ to ‘Very High Materiality’, for different impact and dependency categories. To determine whether a location with economic activity is considered potentially material and requires a more detailed analysis, Heijmans has taken the averages of all the materiality scores of the impacts and dependencies. This enabled us to determine an overall score for the potential impacts and dependencies, and determine potential materiality. Based on these overarching materiality scores, we have identified seven economic activities within our direct operations that require a more detailed impact analysis because they have the potential to have a materially negative effect on biodiversity-sensitive areas. We have also identified three economic activities that require a more thorough dependency analysis because they have the potential to be materially dependent on biodiversity and ecosystems.
ISIC Group |
Impact score |
Dependency score |
Construction of buildings |
3,0 |
2,4 |
Construction of roads and railways |
2,9 |
2,8 |
Construction of utility projects |
3,1 |
2,6 |
Construction of other civil engineering projects |
3,1 |
2,8 |
Demolition and site preparation |
2,9 |
2,2 |
Electrical, plumbing and other construction installation activities |
2,5 |
2,3 |
Building completion and finishing |
2,7 |
2,4 |
Other specialized construction activities |
2,9 |
2,2 |
Real estate activities with own or leased property |
1,6 |
1,7 |
Real estate activities on a fee or contract basis. |
1,6 |
1,7 |
Activities of head offices |
1,4 |
1,1 |
Architectural and engineering activities and related technical consultancy |
1,2 |
2,0 |
Other land transport |
2,3 |
2,3 |
Cargo handling |
2,1 |
1,3 |
Other transportation support activities |
2,2 |
1,4 |
Warehousing and storage |
1,7 |
1,4 |
Materiality score |
Result |
Higher than 2.5 |
Materiel Economic Activity |
Lower than or equal to 2.5 |
Non-Material Economic Activity |
Although ENCORE only considers something to be material with an impact or dependency score of Medium, High or Very High (score 3 or higher), Heijmans takes a different approach and considers an average score of the economic activities above 2.5 to be material. This is because combining the scores per impact or dependency category often dampens outliers by working with averages, while these can actually be relevant.
Scope & limitations of the policy and the vision
-
Our current policy is not linked to material dependencies, risks and opportunities.
-
Our current policy is not yet geared towards ensuring that the production, purchase or consumption of products originating from ecosystems are managed in such a way as to maintain or improve the conditions for biodiversity. The only exception to this is the purchase of FSC-certified and PEFC-certified timber, which guarantees that the timber comes from responsibly managed forests.
-
Heijmans does not currently take into account the social consequences of biodiversity and ecosystem-related impacts.
-
The vision and associated policy have been created with an eye to the future and are therefore relevant to the entire Heijmans value chain. However, for the time being, the policy is only being implemented in our direct operations. Because Heijmans only carries out its direct operations in the Netherlands, the vision and its impact factors are therefore also geographically limited to the Netherlands.
-
Heijmans does not currently have a specific policy on sustainable oceans, seas and waterways related to biodiversity and ecosystems. However, Heijmans does adhere to the latest legal and regulatory requirements for coastal protection areas and waterways, where we are currently carrying out a number of projects.
Scope and limitations of actions
-
Heijmans does not currently have any specific actions in place, apart from the climate actions in the climate chapter, to alleviate, support or compensate for impacts on biodiversity that are deemed material.
-
Heijmans does not currently have any insight into whether the measures involve significant operational costs and/or capital expenditures. The reason for this is that the financial year under review is the first time that all actions have been combined in one place. Heijmans aims to identify these costs for the coming years.
-
Heijmans does not currently use biodiversity offsets to compensate for its impact on biodiversity and ecosystems. Nor does Heijmans make use of local and indigenous knowledge when devising and setting up actions.
Method for setting targets and assumptions used
The targets for the Space for Nature and Species Richness impact factors were set using the following method:
-
Integration with the four impact factors: the first step in the process was to align the biodiversity targets with Heijmans‘ four biodiversity impact factors. These impact factors served as a guideline and ensured that the targets were anchored in Heijmans’ established biodiversity vision. Consequently, the targets are also aligned with the scientific pressure factors on which these pillars are based.
-
Alignment with scientific and international targets: in the next step, we looked at relevant international targets and frameworks, such as the Global Biodiversity Framework and the Science Based Targets for Nature (SBTN) framework, to inspire us when setting our own targets. For example, target 1 aligns well with SBTN targets under ‘No Conversion of Natural Ecosystems’ and ‘Land Footprint Reduction’, and target 2 aligns well with Target 1 of the Global Biodiversity Framework ‘Plan and Manage all Areas To Reduce Biodiversity Loss’.
-
Integration with measurement methods and monitoring: we then looked at the feasibility of measuring and monitoring the set targets. Heijmans has estimated the available resources and how we can use these optimally to actually measure progress to achieve the targets we have set. This includes the use of satellite data, the biobuddy and other relevant resources.
-
Targets have been made SMART: as a final step, the targets have been made SMART. SMART methodology ensures that your targets are clear, achievable and measurable, and enables you to work systematically towards achieving those targets. We have chosen the year 2030 as the timeframe, because this is in line with the ‘Nature Positive Initiative’ of, among others, the WWF and the Global Biodiversity Framework, and our own bold statement on sustainability: ‘We give more than we take’.
-
Internal evaluation: the targets were then evaluated internally by subject experts, theme leaders, the Executive Board and those responsible for sustainability within the company's processes. So far, we have not involved external stakeholders in setting the targets.
Scope and limitations of the targets
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When setting our biodiversity and ecosystem targets, Heijmans did not use ecological thresholds. However, we recognise the importance of integrating ecological thresholds into future targets and ambitions and we will continue to explore how we can effectively implement these concepts to continue to increase our contribution to the conservation of biodiversity and ecosystems.
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As these targets have only recently been set and we have not yet conducted a full impact analysis, we have not yet determined the baseline value or the baseline year. However, Heijmans does not consider this information necessary for setting the targets, as they are aimed at realising a positive impact in relation to the specific situation of each project.
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The geographical scope of the defined targets is limited to the Netherlands, as our direct operations are also exclusively within Dutch borders. This means that the targets are specifically aimed at the context of the Dutch market and the business activities carried out within it.
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Heijmans has not made use of biodiversity offsets in setting its targets. The targets set are based on the four pillars of biodiversity and underlying scientific insights as mentioned above, with a focus on reducing the negative impact on biodiversity through other actions. The targets are thus primarily aimed at preventing damage to ecosystems and promoting biodiversity in the long term, rather than compensating for losses after the fact.
Method used for targets related to our own employees
IRO |
Target |
Methodology |
Assumptions |
Equal treatment |
At least 15.5% of our employees are women. |
We look at the total number of employees and determine how many of them are women. |
In this case, we using the gender as stated by the employee themselves. |
In 2024, we will add 50 newcomers to our workforce |
We record the type of residence permit when the person starts working. We can filter these based on the definition set for the annual report. |
We only look at employees who started working in 2024. |
|
Employee engagement |
The rolling rate of absenteeism in 2024 is 4.75%. |
The rolling absenteeism rate means that the average absenteeism rate of the past 12 months is used (in this case, every month of 2024). The absenteeism rate is calculated by dividing the total number of days missed in a month by the potentially available days in a month. This number is then multiplied by 100%. |
None. |
25% of our new colleagues joined the company via a referral. |
When an employee introduces a new colleague, they receive a referral bonus. We keep track of how many new colleagues have been hired through referrals based on the payment of these bonuses. |
We assume that everyone who refers a new colleague will receive the referral bonus. |
Metric requirements
We did not use an external assurance provider for any of our metrics, except for data points 48, 49 and 51, related to climate change E1. KIWA tests these annually for our CO2 Performance Ladder certification and they were tested once in 2024 by the Science Based Targets Initiative (SBTi).
Climate change (ESRS E1) |
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Disclosure requirement |
KPI Definition |
Methodology |
Assumptions |
Limitation |
|
E1-5 |
37 (a) |
Total energy consumption from fossil sources. |
The total energy consumption from fossil fuels is calculated as the sum of the various fossil energy sources. |
No assumptions are made for the calculation of this data point. |
No specific limitations identified on this data point; additional explanations are mentioned in DR 38 A to E |
37 (b) |
Total energy consumption from nuclear energy. |
Checking Guarantees of Origin has led to the conclusion that no nuclear energy was used in 2024. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
37 (c) i. |
Total energy consumption from renewable fuels (fuel). |
Underlying data for Green Gas and HVO 100 is obtained from the respective suppliers. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
37 (c) ii. |
Total energy consumption from renewable fuels (purchased). |
The Shared Service Centre collects invoices from energy suppliers, which are then converted to MWh. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
37 (c) iii. |
Total energy consumption from renewable fuels (non-fuel). |
Energy consumption from solar panels: |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
38 (a) |
Fossil Fuel consumption from coal and coal products. |
Heijmans is not involved in coal consumption. This figure is therefore 0. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
38 (b) |
Fossil fuel consumption from crude oil and petroleum products. |
Invoicing data from suppliers (e.g. LeasePlan and Oliecentrale Nederland) is used to calculate how much fossil fuel is consumed. This is received in litres and converted to MWh. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
38 (c) |
Fossil fuel consumption from natural gas. |
Natural gas consumption is compensated with Guarantees of Origin, so this figure is 0. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
38 (d) |
Fossil Fuel consumption from other non-renewable sources. |
Invoicing data from suppliers (e.g. LeasePlan and Oliecentrale Nederland) is used to calculate how much fossil fuel is consumed. This is received in litres and converted to MWh. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
38 (e) |
Fossil Fuel consumption from purchased or acquired electricity. |
|
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
39 |
Production of (non-)renewable energy. |
Heijmans does not produce any fossil energy. This figure is therefore 0. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
40 |
Energy intensity of activities in activities with a major impact on the climate. |
Energy intensity: |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
E1-6 |
48 (a) |
Gross scope 1 emissions. |
Heijmans measures scope 1 emissions based on the actual quantities of purchased fuels, which means that we include greenhouse gas emissions from stationary combustion, mobile combustion, process emissions and fugitive emissions in our reporting. We have carried out this inventory according to the Greenhouse Gas Protocol Corporate Standard (version 2004), supplemented by the requirements of the SBTi. |
In scope 1, the tank-to-wheel (TTW) emission factor will be used from 2025, and in scope 3, the well-to-tank (WTT) factor will be used. |
There are no limitations when calculating this data point. |
48 (b) |
Percentage of scope 1 emissions as part of ETS. |
Not applicable, Heijmans is not subject to an ETS system. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
49 (a) |
Gross location-based scope 2 emissions. |
For Heijmans, gross location-based scope 2 emissions occur in the emissions related to purchased electricity, kerosene consumption when flying and fuel consumption of private cars. |
Specifically for Van Wanrooij data, a full estimate has been made for all years prior to 2024 based on the figures for 2024. |
There are no limitations when calculating this data point. |
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49 (b) |
Gross market-based scope 2 emissions. |
See calculation for 49(a). Specifically, a separate conversion factor is used (market-based vs. location-based) |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
50 (a) |
Breakdown of scope 1 and 2 emissions by scope of consolidation and underlying subsidiaries. |
See the methodology for scope 1 and 2 emissions. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
50 (b) |
Breakdown of scope 1 and 2 emissions by collaborations not fully part of consolidation. |
See the methodology for scope 1 and 2 emissions. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
51 |
Breakdown of scope 3 emissions by category. |
Total scope 3 emissions = 1. Purchased goods and services + 2. Capital goods + 3. Fuel and energy + 4. Transport (up) + 5. Waste + 6. Business transport + 7. Commuting + 11. Use of sold products + 12. End-of-life of sold products. |
Exclusion of categories: |
Category 3.11 Property development: |
|
53 |
Greenhouse gas intensity. |
Greenhouse gas emission intensity (total greenhouse gas emissions per net revenue) : [total greenhouse gas emissions]/[net revenue in millions of euros]. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
54 |
Greenhouse gas intensity. |
Greenhouse gas emission intensity (total greenhouse gas emissions per net revenue) : [total greenhouse gas emissions]/[net revenue in millions of euros]. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
E1-7 |
58 (a) |
Total amount of greenhouse gases sequestered and removed. |
Greenhouse gas removal is carried out within projects. The removal is calculated using the Centrum Hout calculation module CO₂ storage in wood based on the calculation method from the EN 16449 standard ‘Wood and wood based products - Calculation of sequestration of atmospheric carbon dioxide’. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
59 (a) |
The total number of carbon credits outside the company's value chain that have been tested against recognised quality standards (in tonnes of CO₂e). |
Total number of carbon credits: [total number of purchased credits including credits not yet destroyed] |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
59 (b) |
The total number of carbon credits outside the company's value chain that are planned for the future. |
Planned carbon credits: CO₂ credits purchased in 2024 - [scope 1 consumed in 2024 + scope 2 consumed in 2024]. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
E1-8 |
63 (c) |
Price for a tonne of CO₂e in euros. |
The price in 2020 was determined once on the basis of a study into the price of carbon credits. No direct source was used here, but prices were compared from different providers and project types. The distribution is 100% on scope 1 and 0% on scope two, since the scope 2 footprint is 0 due to the exclusive use of electricity from renewable sources. |
No assumptions are made for the calculation of this data point. |
This estimate does not take into account planned measures to reduce these emissions. Scope 3 emissions are not included in this system. |
63 (d) |
|
Gross emissions volumes related to internal carbon pricing: [estimated scope 1 emissions] + [estimated scope 2 emissions for 2024]. |
No assumptions are made for the calculation of this data point. |
This estimate does not take into account planned measures to reduce these emissions. Scope 3 emissions are not included in this system. |
Water and marine resources (ESRS E3) |
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Disclosure requirement |
KPI Definition |
Methodology |
Assumptions |
Limitation |
|
E3-4 |
28 (a) |
Total water use. |
Total water usage is calculated and extrapolated from period invoices from the water suppliers in the accounting programme. Total water usage is then the sum of the water usage from 1 January to the end date of the invoice period and the end date of the invoice period up to and including 31 December of the reporting year. |
For the offices where we do not use water, we assume that the water consumption is comparable to our other office locations. For this purpose, we have calculated the usage back to water consumption in m3 per m2. |
Water use for production is out of scope for the year under review. |
28 (b) |
Total water use in water risk areas (including areas with severe water stress). |
The total water use has been calculated as equal to DR 28a, and for each location, an Excel workbook is loaded into a GIS programme. This contains maps from Aqueduct, namely Water Stress Areas and Water Risk Areas. The total use is then added up per risk or stress area per category: Low, Low-Medium, Medium-High, High, Extremely High. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
28 (c) |
The total amount of recycled and reused water. |
Heijmans does not reuse water, so this figure is 0. |
No assumptions are made for the calculation of this data point.. |
There are no limitations when calculating this data point. |
|
28 (d) |
Stored water. |
Heijmans does not engage in water storage, so this figure is 0. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
29 |
Water intensity. |
Water intensity: [total water use] / [million euros net revenue]. The revenue is taken from the 2024 financial statements. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
Biodiversity and ecosystems (ESRS E4) |
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Disclosure requirement |
KPI Definition |
Methodology |
Assumptions |
Limitation |
|
E4-5 |
35 |
Number and surface area of company locations that are located in or near biodiversity-sensitive areas that they have a negative impact on. |
Biodiversity-sensitive areas refer to the Natura 2000 network of protected areas, UNESCO World Heritage Sites and Key Biodiversity Areas (KBAs), as well as other protected areas as referred to in Annex II, Appendix D, to Commission Delegated Regulation (EU) 2021/2139. A company site is in or near a biodiversity-sensitive area if it is located within a radius of 10 kilometres. |
Number: All projects with revenue are active projects. |
The GPS coordinates are not known for a very limited number of locations, so there may be a small margin of error in the final figures. |
Resource use and circular economy (ESRS E5) |
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---|---|---|---|---|---|
Disclosure requirement |
KPI Definition |
Methodology |
Assumptions |
Limitation |
|
E5-5 |
36 (a) |
The expected sustainability of products. |
A qualitative approach was used. For more information, see Use of materials and circular economy - Criteria - Lifespan. |
Key products: buildings, homes, houses, infrastructure and engineering structures. |
Tailor-made agreements that are recorded at project level are not included. |
36 (b) |
Repairability of products. |
A qualitative approach was used. For more information, see Use of materials and circular economy - Criteria - Repairability |
Key products: buildings, homes, houses, infrastructure and engineering structures. |
Tailor-made agreements that are recorded at project level are not included. |
|
36 (c) |
Recyclability of products. |
A qualitative approach was used. For more information, see Use of materials and circular economy - Criteria - Recycling |
Key products: buildings, homes, houses, infrastructure and engineering structures. |
Tailor-made agreements that are recorded at project level are not included. |
Own workforce (ESRS S1) |
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Disclosure requirement |
KPI Definition |
Methodology |
Assumptions |
Limitation |
|
S1-6 |
50 (a) |
Total headcount of employees, broken down by gender and country. |
Total headcount of employees: [total headcount/FTE men in the Netherlands] + [total headcount/FTE women in the Netherlands] + [total headcount/FTE other in the Netherlands]. This information has been consolidated from the HR systems used within Heijmans. |
We use gender as indicated by the employee themselves. |
There are no limitations when calculating this data point. |
50 (b) i. |
Total headcount of employees, broken down by gender and FTE. |
Total headcount of staff members with a permanent contract: [total headcount/FTE men] + [total headcount/FTE women] + [total headcount/FTE other] |
We use gender as indicated by the employee themselves. |
There are no limitations when calculating this data point. |
|
50 (b) ii. |
Total headcount of temporary employees, broken down by gender and FTE. |
Total headcount of staff members with a temporary contract: [total headcount/FTE men] + [total headcount/FTE women] + [total headcount/FTE other] |
We use gender as indicated by the employee themselves. |
At the moment, there are still a number of employees for whom we have no data. These are employees who have yet to start and have yet to fill in their gender. |
|
50 (b) iii. |
Total headcount of non-guaranteed hours employees, broken down by gender and country. |
Total headcount non-guaranteed hours employees: [total number of male non-guaranteed hours employees] + [total number of female non-guaranteed hours employees] + [total number of other non-guaranteed hours employees] |
We use gender as indicated by the employee themselves. |
There are no limitations when calculating this data point. |
|
50 (c) |
Headcount and percentage of employee turnover in the reporting period. |
Headcount and percentage of employee turnover in the reporting period: |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
S1-8 |
60 (a) |
Percentage of employees covered by a collective labour agreement (CLA). |
Percentage of collective labour agreement (CLA) coverage = [employees covered by the CLA for the construction & infrastructure sector + employees covered by the collective CLA for the metal & technology sector + employees covered by the CLA for the wholesale trade in building materials (Hibin) + employees covered by the CLA for the carpentry sector] / [total number of own employees] |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
60 (b) |
Percentage of CLA coverage per country. |
The percentage of collective labour agreement coverage is calculated as stated in 60 (a). We break this down per country, which in our case is only the Netherlands. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
63 (a) |
Percentage of employees covered by workers' representatives. |
Percentage of employees with employee representation: [employees with employee representation] / [total number of employees] |
By active representation, we mean the departments or teams at Heijmans that actively receive a call to sign up for the works council when (re)elections take place. |
There are no limitations when calculating this data point. |
|
S1-9 |
66 (a) |
The number and percentage of men and women in Heijmans' senior management. |
Number of men and women in Heijmans‘ senior management: [men in Heijmans’ senior management] / [total number of senior managers] and [women in Heijmans' senior management] / [total number of senior managers]. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
66 (b) |
Distribution of employees by age group. |
Distribution of employees by age group: [number of employees] and [age], taken from HR systems. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
S1-10 |
70 |
Adequate wages. |
We determine whether the employee will be paid in accordance with the collective labour agreement based on the collective labour agreement, contract type and age. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
S1-14 |
88 (a) |
Percentage of our own personnel who are covered by the health and safety management system. |
The Heijmans safety policy applies to everyone. |
No assumptions are made for the calculation of this data point.. |
There are no limitations when calculating this data point. |
88 (b) |
Number of fatalities as a result of recordable work-related accidents. |
All cases are registered via the incident system based on the safety policy, specifically a subcategory based on the number of deaths. This is entered into the safety dashboard in PowerBI. This information pertains to Heijmans employees. Van Wanrooij keeps track of its reports via a different system and submits them separately at the end of the year. |
No assumptions are made for the calculation of this data point. |
The fatalities at Brabotech do not fall under the category of ‘own employees’, but rather under ‘subcontractors’. |
|
88 (c) |
Number of recordable work-related accidents. |
We make a printout from the incident register of the total number of reports with filtering based on categories as stated in the definition. Van Wanrooij keeps track of its reports via a different system and submits these separately at the end of the year. Van Wanrooij classifies its reports based on the above accidents. The accidents are categorised as ‘own employee’ (salaried employees), ‘temporary staff’ and ‘subcontractors’. We use this to calculate the percentage of occupational accidents among salaried employees = ([Number of occupational accidents among salaried employees] / Number of hours worked ) x 1,000,000. |
Hours worked have been estimated by extrapolating them using the number of FTEs employed by Heijmans. We calculate this as [Number of FTEs] x 40 x [total number of weeks - holidays]. |
We cannot make the division between our own employees and employees who are not our own, as requested by the ESRS, with the current categorisation in our incident register. As a result, we can only report on the categories ‘our own employee’, ‘temporary worker’ and ‘subcontractor’. These categories are based on how the work is directed and are therefore not the same as the contractual agreement. |
|
88 (d) |
Number of recordable work-related ill health cases. |
The number of reports to the company doctor is obtained from the relevant occupational health and safety service. |
No assumptions are made for the calculation of this data point. |
This information is not available for non-salaried employees via the company doctor. This group does not go to the Heijmans company doctor, but if there is a case of an occupational sickness in the workplace, HR and H&S will include them in the occupational sickness reporting procedure as described in the HRM Manual. |
|
S1-16 |
97 (a) |
Pay gap between men and women (%). |
Pay gap = [Average gross hourly wage M] - [Average gross hourly wage F] / [Average gross hourly wage M] |
No assumptions are made for the calculation of this data point. |
The 100% subsidiary BraboTech (25 FTEs) is not part of this calculation. |
97 (b) |
Pay ratio (not including the highest paid person). |
We obtain the information for this KPI from our personnel and payroll records with reference date 31-12-2024. The annual remuneration per employee is calculated on gross salary including all bonuses and allowances. The highest paid person is the CEO. For this, we use the total remuneration package received by the CEO, which is explained in detail in the existing management report and remuneration report. All salaries are ranked from high to low (excluding the highest paid person), which is used to calculate the median. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. The 100% subsidiary Brabotech is not included in this calculation. |
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103 (a) |
Number of incidents of discrimination, including inappropriate behaviour, in the most recent reporting period. |
Number of incidents related to discrimination: [Reports in the category of discrimination, as reported to the risk office for the 2024 financial year]. |
No assumptions are made for the calculation of this data point. |
However, the statement on discrimination does not distinguish between the types of discrimination, something the ESRS requests in Article 102. |
|
103 (b) |
Number of complaints submitted through channels for persons who are among Heijmans' own employees to raise concerns (including complaint mechanisms). |
For the 2024 financial year (and prior to that) confidential counsellors must report all reports they have received to the compliance officer. The report to the compliance officer contains the numbers per category of report (i.e. the nature of the report). The compliance officer provides a quarterly report of the number of reports (to the compliance officer and confidential counsellors combined) to the Risk department for inclusion in the quarterly CRO report. |
No assumptions are made for the calculation of this data point. |
The only limitation is when a colleague does not report an incident to Heijmans. |
|
103 (c) |
Total amount in fines related to reported incidents and complaints. |
As soon as a fine is imposed, we add up the amount in euros to arrive at a total. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
Business conduct (ESRS G1) |
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Disclosure requirement |
KPI Definition |
Methodology |
Assumptions |
Limitation |
|
G1-3 |
21 (b) |
The percentage of high-risk positions covered by training programmes. Number of high-risk positions: |
Percentage of high-risk positions covered by training programmes: [high-risk positions who have participated in training programmes (Zakelijk Zuiver business integrity programme)] / [total number of high-risk positions]. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
G1-4 |
24 (a) |
The number of convictions and the amount in fines for violations of anti-corruption and anti-bribery legislation. |
The number of convictions and the amount in fines for violations of anti-corruption and anti-bribery legislation: |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
G1-6 |
33 (a) |
The average payment term from the start of the contractual payment term. |
Average payment term: [number of days in which each invoice was paid] / [total number of invoices]. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
33 (b) |
Percentage of payments that are made in accordance with standard terms. |
Percentage of payments made within the standard terms: [total number of invoices paid on time] / [total number of invoices] |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |
|
33 (c) |
Number of legal proceedings for late payments. A legal proceeding is a structured series of steps taken to resolve a dispute or deal with a legal matter. |
The total number of legal proceedings initiated by a contracting party to bring a civil action against Heijmans for late payment, which were then referred to the Legal Affairs department. |
No assumptions are made for the calculation of this data point. |
There are no limitations when calculating this data point. |