General information

About this report

For the first time, the report has been drawn up in accordance with the structure and requirements of the European Sustainability Reporting Standards (ESRS), as prescribed by the EU's Corporate Sustainability Reporting Directive (CSRD), which applies to Royal Heijmans N.V. from 2024. This report marks our first step in complying with the CSRD, for which we have adopted a phased approach. We expect our reporting to grow in maturity and depth in the coming years.

ESRS structure and requirements

According to the ESRS, companies are required to disclose their environmental, social and governance information in a special section called the ‘Sustainability Report’, which is included in the management report. To comply with this requirement, the section containing sustainability data has been integrated into the chapters on ‘Climate’, ‘Water’, ‘Biodiversity’, ‘Resource use and circular economy', 'Social information' and '(Business) Conduct and integrity'.

In the first chapter of the Sustainability Report, we provide a detailed description of our double materiality assessment and an overview of the ESRS topics that we have identified as material. In the following sections, we report on our impact, ambitions, policy, strategies, actions, resources and progress towards targets for each of these material topics. See ‘Notes’ for more detailed information and a detailed overview of all ESRS disclosure requirements.

Inclusion via references

To streamline our sustainability reporting, we have included certain information by referring to other parts of this integrated report. Below you will find a summary of the ESRS requirements and specific data points that have been included via reference to other parts of the report or the financial statements, so that stakeholders can easily find the relevant information:

• 'In dialogue with stakeholders'

• Information on the composition and diversity of the members of the Executive Board, senior management (sub-top) and the Supervisory Board in Governance – 'Organisation of corporate governance' and 'Diversity'

• 'Risk management'

• Information on the remuneration schemes and the remuneration policy, linked to sustainability themes, in the

• Entity-specific KPI information, related to our strategy, is included in 'KPI table’ appendix

Reporting methodology

Scope
Heijmans and its activities are focused entirely on the Netherlands. This annual report presents sustainability information that specifically relates to these activities, with attention paid to the value chain: from the supply chain (upstream) and our own operations to the impact of end users (downstream).

The sustainability information in this report is reported on a consolidated basis. The consolidation scope here is equal to that of the financial statements, supplemented with specific requirements for operational control in sustainability information. This is because the reporting requirements for certain material topics state that Heijmans is responsible for the sustainability impact of entities over which it has operational control, even if it does not fully own these entities.

Definition of operational control according to Annex 2:

Operational control (over an entity, location, activity or asset) is the situation in which the company has the ability to direct the operational activities and relationships of the entity, location, activity or asset. We distinguish four categories of associate, differentiating between full operational control, shared operational control, no operational control and situations without operational control, but with influence. This framework enables transparent and proportional reporting of scope 1, 2 and 3 emissions, and ensures consistency with previous years and future developments. This system lays the foundation for a robust and reliable reporting infrastructure that is flexible enough to be evaluated and adjusted in subsequent cycles.

The information in the sustainability report is in accordance with the information prescribed by the ESRS. There is no (partial) application of other reporting standards or frameworks.

Recent acquisitions

Van Wanrooij

Van Wanrooij has been a 100% subsidiary of Heijmans since the autumn of 2023. The 2024 reporting year should be seen as a transition year with regard to sustainability policy, action plans and targets in view of the relatively recent acquisition of the company. In 2024, Van Wanrooij had no policy, actions or targets available with regard to the material topics in line with CSRD. As a subsidiary of Heijmans, Van Wanrooij is expected to follow Heijmans’ policy wherever possible. Heijmans will draw up a plan for policy integration for the 2025 reporting year.

This annual report includes all financial and non-financial data. The data required for the KPIs related to the material topics are largely available to Van Wanrooij, and the remaining data will be supplemented by estimates. The availability of data and estimation methods will be explained in 'Notes'. 

Van Gisbergen

Van Gisbergen has been a wholly owned subsidiary of Heijmans since September 2024. Van Gisbergen's financial data is included in these financial statements from the date of acquisition. In view of the fact that the acquisition took place recently, there is currently limited insight into Van Gisbergen's sustainability information. Heijmans will develop a step-by-step plan for further integration of KPIs, action plans, targets and policy in accordance with CSRD legislation in early 2025. The basic principle is to report on a fully consolidated basis for the 2025 reporting year.

Reporting principles applied

Time horizon

Heijmans has deviated from the medium-term and long-term time horizon defined by ESRS 1 6.4 Definition of short, medium and long term for reporting purposes. This is in line with our new strategy, which covers the period 2024-2030. This strategy is at the heart of our vision for the future and our bold statements are also specifically geared to this time frame. Furthermore, to offer transparency and make our progress measurable, when presenting our outlook to the market, we identified an important intermediate moment: the year 2027. This intermediate moment will enable us to carry out interim evaluations and adjust our strategy if necessary, so that we remain on course to achieve our long-term targets.

The definitions of the time horizons used: short, medium and long term, are as follows:

Classified and sensitive information

The company has not used the option not to report specific information elements focusing on intellectual property, know-how or innovation results. In addition, there are currently no developments or issues pending that would require exemption from reporting.

Estimates and sources of uncertainty and assumptions

In the Notes section, we indicate whether there are any elements of estimation, measurement uncertainty and assumptions with regard to our KPIs, including in the value chain. By reporting this information, our aim is to increase transparency and help users to better understand the context of the KPIs. This enables stakeholders to interpret the figures with due caution and to take into account any limitations in the accuracy of the measurements.

Going forward, our aim is to continue to improve the accuracy of these estimates. We will do this by optimising data collection, refining the methods used and applying more advanced analysis techniques. This will enable us to continue increasing the reliability of our KPIs and provide even greater insight into the performance of the value chain.

Comparative figures

For previously reported KPIs, we report comparative figures for the 2023 reporting year. For gross scope 1, 2 and 3 emissions and total greenhouse gas emissions, we also report figures for the 2019 baseline year. There are no comparable data available or published for new KPIs.

Reporting errors in previous years

We report transparently on any reporting errors from previous years. We explain the nature of the material error, the correction and, if a correction is not possible, the circumstances that led to the error. In 2024, one situation occurred that led to a correction in the 2023 figures. This involves the reported impact of delivered infrastructure assets on scope 3 category 11, for which no data was available in 2023. In 2024, this impact was mapped for the first time and applied retroactively to both the baseline year 2019 (+81 ktonnes) and the reporting year 2023 (+79 ktonnes).

Expertise in sustainability issues and the role of the Executive Board and Supervisory Board

Our organisation's Executive Board has a high level of expertise in the field of sustainability, based on knowledge and experience. For the material sustainability themes, there are both internal experts at the holding level and within the business areas, who are consulted as needed on specific impacts, risks and opportunities.

When there is a mismatch between the required and available knowledge, the Executive Board takes proactive steps to bridge this gap. Hiring external experts and working closely with advisory committees and sustainability networks provides valuable input and helps shape sustainability strategies. By actively exerting influence through these bodies, the Executive Board can effectively steer sustainable development and ensure that the organisation continues to excel in terms of its sustainability targets.

Business model and strategy

The overview on the following page aims to provide insight into the differences and similarities between the double materiality analysis (DMA) and the ‘Together towards 2030’ strategy. In the overview below, the various pillars of Well-being, Sustainability, Team, Connection and Producibility are linked to the various ESRSs from the CSRD. In this way, we make the link between what has emerged from the DMA and the strategy we have developed. For the most important information per theme, please see ‘Notes’.

Strategy in relation to sustainability themes

It is essential that our strategy and reporting focus on the sustainability themes that are most relevant to us and our business. We evaluate whether we are operating in line with the material topics that have the greatest impact on Heijmans, together with the material topics that Heijmans has the greatest impact on in our operating environment. We will evaluate these regularly to ensure that they reflect the most relevant developments within our organisation and in our value chain. We aim for an annual assessment of the impact of the material topics on our business model, value chain, strategy and decision-making. We will also assess how the interests of our own workforce and those of workers in the value chain are incorporated into our strategy and business model. We did not do this in 2024 due to the timing of the double materiality analysis and strategy development. However, in the coming years, a steering committee with representation from the Strategy and Sustainability departments, among others, will oversee this coordination. Actions that influence the strategy and/or the business model will be included under the relevant material topics with the associated methodology and assumptions. Heijmans has currently formulated targets for the themes of Climate change, Biodiversity and Our own workforce. We aim to embed these ambitions more deeply in the business model by making the connection with our products, services and stakeholders and vice versa more explicit.

See the 'Strategy 2030' and 'How we create value' sections for an explanation of our business model.

In the year under review, we did not carry out a formal resilience assessment for all sustainability topics. This process includes a comprehensive evaluation of how our business strategy can withstand and adapt to various challenges and changes in the external environment, including economic, environmental and social factors. We aim to carry out this resilience assessment in the coming years.

We have not identified any direct financial impacts, partly because all the opportunities from the double materiality analysis are medium-term to long-term, and partly because we have not identified any risks.

For the year 2024, there were no changes in the material impacts, risks and opportunities compared with the previous reporting period. This is because 2024 is the first year in which we are reporting according to ESRS requirements. Since this reporting obligation was not previously in force, it is not possible to compare these with previous reporting periods.

We are Heijmans, creators of the healthy living environment

Our role in the chain

Our value chain encompasses a wide range of activities that together contribute to the development, realisation and maintenance of construction projects. This chain extends from the extraction of raw materials to waste management and reuse at the end of a project's lifespan. The value chain is divided into three main segments: upstream, our own operations and downstream.

1. Upstream

In the upstream phase, we focus on the extraction of raw materials and the procurement of required materials and services. This is a crucial link in our value chain, in which sustainability and labour rights are key. We carefully consider the risks surrounding labour rights so that we can operate ethically and contribute to a fair and safe working environment.

In addition, we process various types of materials such as steel, timber, concrete, bricks, asphalt bitumen and installation components. The sustainability of materials is playing an increasingly important role. The majority of these materials are purchased from suppliers in the Netherlands, while a smaller portion comes from other European countries and only a fraction from outside Europe.

Our supply chain consists of a wide range of partners, including suppliers, research institutes, building material producers and employees in the transport and raw materials extraction sectors. To realise our projects, we utilise technical services and know-how that are essential in the preparatory phases of any construction project.

By taking this careful approach in the upstream phase, we are taking steps towards a more sustainable construction process, actively striving for responsible procurement and a positive impact on the environment and society.

2. Our own operations

The phase of our own operations is at the core of our business operations and includes design, engineering and the actual construction. This is the phase in which we combine our expertise and innovative power to realise and manage projects. This phase offers opportunities to integrate sustainable solutions in areas such as water management. At the same time, the health and safety of our employees remains a top priority, as do ensuring fair working conditions, maintaining strong relationships with our suppliers and protecting whistleblowers.

Our operations are carried out by a combination of our own workforce and independent professionals. Various activities in this phase are carried out in close cooperation with business partners. These partners provide support in areas such as project management, strategic advice, process optimisation and the development of sustainable tools.

In addition, the efficiency of material flows plays an important role in reducing waste and optimising processes. By making smart use of resources and innovative techniques, we ensure that our projects are not only economically profitable, but also environmentally friendly and future-proof.

3. Downstream

In the downstream phase, the focus shifts to the management and maintenance of construction projects, or to dismantling or repurposing. This part of the value chain plays a crucial role in extending the lifespan of projects and minimising their ecological impact. Promoting reuse and circular processes remains an important focus. Through responsible waste management (the careful separation of our residual waste streams, which we manage proactively) and the smart reuse of materials (during demolition work, materials are released that can be taken apart and reused; we reuse these materials in the design and realisation phase wherever possible) we contribute to a more sustainable end result and reduce the amount of residual waste.

Upon delivery of the end product, various stakeholders come into play, such as clients, end users, local residents and local communities. Project management and careful delivery are essential to meet the expectations of all parties involved. Our clientele consists of both private homeowners and business clients, such as real estate developers, companies and government bodies. End users, including people and organisations, play a major role in the final utilisation of buildings and infrastructure.

Feedback from end users is very important because it reflects the quality of our projects and has a direct influence on our reputation and client satisfaction. By actively listening and responding to their experiences, we continue to improve our processes and projects and build sustainable relationships with clients and communities.

4. Across the entire chain

Certain themes, such as climate and biodiversity, corruption and bribery, play a role throughout the entire value chain of our construction company. These topics require constant monitoring and close cooperation with various stakeholders to limit risks and minimise the impact on both the environment and wider society. Transparency and ethics form the backbone of our business operations and contribute to trust and integrity in the sector.

Industry organisations play an essential role in supporting and strengthening the construction chain. Their influence extends across the entire value chain and includes representing interests, sharing knowledge, training and promoting cooperation between parties. These organisations contribute to a well-organised and efficiently functioning construction sector, stimulating innovation and sustainable development.

By taking an integrated approach to the entire chain – from raw material extraction to waste management – we are able to not only reduce our ecological footprint, but also strengthen our competitive position. This enables us to respond to opportunities for sustainable growth, innovation and value creation for all our stakeholders.

Double materiality

The ‘Material Topics’ figure provides insight into the analysis of material topics for Heijmans. The analysis is displayed based on two dimensions: financial materiality and impact materiality.

Financial materiality indicates the extent to which risks and opportunities related to sustainability topics arise for Heijmans and could have a potentially material financial impact on the company. Impact materiality indicates the extent to which a topic affects people and the environment, both within Heijmans’ own activities and in the upstream and downstream value chain, for example through Heijmans’ products, services or business relationships.

Definitions of material topics

Climate adaptation

This represents an opportunity for Heijmans to make communities more resilient by designing climate-adaptive buildings and infrastructure. The growing demand for these types of solutions stimulates investments in sustainable construction, service and maintenance projects. This offers us the opportunity to make a significant contribution to a future-proof living environment and can lead to more construction, service and maintenance activities and higher revenue for Heijmans. 

Climate mitigation, Energy

The impact that Heijmans has on climate change consists of two main aspects. The first is the indirect emissions that result from the purchase of raw materials, the design of the built environment and the delivery of products for living, working and connecting. In this regard, we can specifically focus on product concepts aimed at climate mitigation and energy efficiency. Secondly, it involves the direct and indirect emission of greenhouse gases in our own operations, such as the use of electricity and fossil fuels, the production and transport of building materials by suppliers and the emissions that arise during the lifespan of our products. 

Water

This is the impact on the water system due to our activities in public areas and in our own offices and building sites in terms of water balance/quantity, water quality, water safety and water use. In addition, there are also impacts further down the chain, for example during the production of materials that we use. These direct and indirect impacts influence the natural environment, agriculture, water supply and the urban climate. 

Direct drivers of biodiversity loss

This is the impact on biodiversity and ecosystems through the use of space, natural resources, pollution, greenhouse gas emissions and the introduction of invasive species. This contributes to the loss of biodiversity and ecosystems. Among other things, we look at how our activities near biodiversity-sensitive areas affect the natural habitats of fauna and flora. 

Material outflows related to products and services

The impact of buildings and infrastructure designed and built according to circular principles is positive for the natural environment and the climate. Circular principles such as extending lifespan, repairability and recycling contribute to the more efficient use of materials. By choosing CO₂-negative or biobased materials, buildings can store CO₂ for a prolonged period of time. In addition, any environmental impact is reduced even further by using primary raw materials consciously. So sustainable buildings play a key role in creating a more climate-friendly future.

Labour terms and employment conditions

This is the impact that offering equal treatment and opportunities for everyone in the workplace has on employees. Ensuring gender equality and equal pay, promoting equal employment and inclusion of people with disabilities and diversity in age, gender and cultural background creates a working environment in which everyone feels valued. Maintaining this environment is also an opportunity, because it attracts talent, encourages ethical behaviour, reduces absenteeism and ensures more committed and productive employees. All of this ultimately leads to business growth, innovation and higher revenue through the development and retention of a diverse workforce with the skills to meet current and future needs. 

Health & Safety

Exposing employees to safety risks at production sites increases their risk of injury. These injuries can range from serious to fatal and can have long-term consequences, including occupational disability. Ensuring safety in the workplace is therefore crucial to protecting the health and well-being of employees. 

Other labour rights

This is the impact on the employees of subcontractors and partners who have poor working conditions and terms of employment. This mainly affects the job security of certain groups, such as migrants, vulnerable minorities and part-time employees. These employees can face insecure work, low wages and unsafe working conditions, which can seriously affect their health and well-being. 

Protecting whistleblowers

This is the impact on whistleblowers in the company due to the lack of sufficient protective policies and mechanisms. This leads to an unsafe working environment, as a result of which whistleblowers do not feel protected and it is no longer possible to effectively prevent human rights violations. 

Corruption and bribery

This is the impact on society due to the risk of corruption and bribery when Heijmans collaborates with suppliers and (public) policymakers. This collaboration can take place through industry associations, personal meetings, written contact or participation in public hearings and conferences. This increases the risk of undue influence and unfair practices. 

Managing relationships with suppliers

How Heijmans manages its relationships with suppliers in its own operations has an impact on people and the environment. This includes fair behaviour and fair payment practices, such as paying suppliers on time. In addition, events and programmes are used to promote cooperation and innovation in the field of sustainability within the supply chain, which has a positive impact on both people and the environment. 

In dialogue with stakeholders

Stakeholder engagement

Stakeholder engagement is an essential part of our double materiality analysis. In this process, we identify which stakeholders are most affected by our activities and therefore need to be included when defining our impact on people and the environment. In addition, we identify stakeholders who have a significant influence on Heijmans and therefore entail risks or opportunities. These stakeholders are represented in the process, both directly and indirectly.

Because stakeholder engagement is of great importance to Heijmans, we organised a stakeholder meeting on 1 October 2024 at our head office in Rosmalen. This meeting had a two-fold purpose: to inform our stakeholders about our strategy ‘Together towards 2030’, and to present and discuss the results of the double materiality analysis within the framework of the CSRD.

Results and integration in our strategy

During this meeting, we asked for input from various stakeholders to validate the results of the materiality analysis from their diverse perspectives. This helps us to ensure that our strategy is not only financially sound, but also focused on creating value for all stakeholders, taking into account their views and interests as identified in the materiality analysis.

This means that stakeholder input is structurally integrated into strategy development and into compliance with other sustainability requirements. We will refine our double materiality analysis in 2025.

In addition, the results of the stakeholder meeting have been fed back to the Executive Board, the Group Council and the Supervisory Board, which means that these insights can now contribute directly to future strategic decisions. The section of the management report entitled 'In dialogue with stakeholders' explains how we engage in a dialogue with our stakeholders.

Double materiality analysis

Introduction

The 2024 annual report will be prepared on the basis of CSRD for the first time.

In early 2024, we performed a double materiality analysis (DMA) in preparation for CSRD-compliant reporting to assess which sustainability impacts, risks and opportunities have a significant impact on our organisation, as well as on people and the environment. This materiality analysis differs from the analysis of previous years because it is based on the concept of double materiality.

Firstly, we identified topics that provide insight into how sustainability affects Heijmans' financial performance, such as profitability, capital utilisation, equity and reputation (financial materiality). Secondly, we included subjects that provide insight into Heijmans' impact on the environment and people (impact materiality). The subjects that are considered material for Heijmans will be explained below based on their impact, risks and opportunities for both the organisation and the world around us.

Results

We combined the results for each ESRS topic and found that Climate Change (E1), Water and Marine Resources (E3), Biodiversity and Ecosystems (E4), Resource use and Circular Economy (E5), Own Workforce (S1), Workers in the value chain (S2) and Business behaviour (G1) are the material sustainability topics for Heijmans.

We also included the topics Affected communities (S3) and Consumers and End users (S4) in the DMA, but they remained below the threshold based on studies and the assessment of impacts, risks and opportunities. This is partly because the sub-topics do not fully align with Heijmans' business operations. Topics such as civil and political rights or the rights of indigenous peoples (S3) and the impact on consumer information (S4) are less relevant to our core activities. In addition, we operate in a sector that is heavily regulated by the government, with product requirements in the B2B market being strictly prescribed. Nevertheless, we feel it is important to take the needs of end users into account in our designs and projects and to make optimal use of the opportunities available to us.

Our DMA in brief

We took the following steps to determine which sustainability topics are most significant for Heijmans:

1. Gain insight into the context

2. Identify impact, risks and opportunities

3. Assess impact, risks and opportunities

4. Prioritise sustainability topics

Material impacts, risks and opportunities

For each theme, we provide an overview of the material impacts, risks and opportunities in the relevant chapter. The general information consists of: the material theme, the shortlisted theme and its place in the value chain. In addition, we describe the impact materiality based on the type of impact (current and intended), the nature of the impact (positive or negative) and the description of the impact. Finally, we describe the financial materiality by outlining the risk and/or opportunity.

Methodology and assumptions

In this section, we explain the methodology we use to identify the relevant sustainability topics. 

The process 

We start by drawing up a list of sustainability topics, from which we then compile a longlist of potential themes and structure these according to a specific framework. We map out the entire value chain and identify the most important impact areas, risks and opportunities. We then distil a shortlist of the most relevant (material) themes from this. We then assess the impacts, risks and opportunities we have identified using a scoring model. For impacts, we assess the severity of the impact and the likelihood of the impact occurring. For risks and opportunities, we assign a score to assess the magnitude of the risk or opportunity and the likelihood that its financial impact will occur. We then determine the threshold values to establish which sustainability themes are material.

Process steps

We go through the following four steps to identify the material sustainability issues for Heijmans.

1. Gaining insight into the context

The first step in the process is to gain insight into the organisation and our business operations and describe the context. To this end, we drew up an overview of the value chain, with the value creation model playing a central role in determining the upstream and downstream activities. In addition, we have identified and classified stakeholders to determine who the most important stakeholders are. These stakeholders are then involved in the materiality analysis so we can also take their perspective into account.

Employees working in the areas of Sustainable Development, Finance, HR, Procurement, Strategy and Safety are involved in this step.

2. Identification of impacts, risks and opportunities

We start with a longlist of sustainability topics based on the ESRS topics, sub-topics and sub-sub-topics included in the ESRS 1 appendix. We then added insights from ongoing discussions with internal and external stakeholders to this longlist.

We then supplemented the list and assessed its relevance based on Heijmans‘ strategy, Heijmans’ risk assessment, the 2022 materiality analysis, a peer comparison, international examples, sector standards, ESG ratings and benchmarks.

When assessing the relevance of specific topics, it was decided that, in the event of any doubts, these would still be included in the analysis of impacts, risks and opportunities. A more detailed specification would enable us to evaluate, with the appropriate substantiation, which topics are or are not material for Heijmans. All relevant topics have been included on the shortlist for further analysis.

The shortlist was drawn up in collaboration, and we determined in which parts of the value chain the (provisional) material topics manifest themselves. We subdivided the entire value chain into the following categories: upstream, our own operations, downstream and across the entire value chain, highlighting multiple aspects. We completed the mapping of the value chain and validated it with input from subject matter experts from the various business areas.

This step involved employees working in the areas of Sustainable Development and the Risk Office. The Executive Board validated the shortlist.

We identified the impacts, risks and opportunities for all topics on the shortlist. For the impacts, we describe the type of impact (current/intended), the nature (positive/negative), a description of the impact and the timeframe in which the impact will occur (short, medium or long term). For each shortlist topic, we also describe the risks and/or opportunities that may be linked to the impact, indicating whether it is an opportunity or a risk and what the potential financial impact may be.

This step involves employees working in the fields of Sustainable Development, Risk, Safety, HR, Procurement, Legal Affairs and Strategy, as well as internal sustainability experts from the company's various departments. In addition, we involve employees who represent specific projects and external stakeholder groups (for example, affected communities and employees in the value chain), who can contribute their expertise regarding the impacts, risks and opportunities. We did not screen assets, activities or company locations or consult with affected communities to identify impacts on water or pollution. The impacts, risks and opportunities related to business conduct and integrity were identified by internal employees (including those working in the areas of Legal Affairs and Strategy) and their knowledge of Heijmans, using existing policy documents and the Heijmans Code of Conduct.

3. Assessment of impacts, risks and opportunities[1]

We assess all impacts, risks and opportunities separately using a scoring model.

Calculation and assessment of the impacts (impact materiality)

When assessing the impacts, we assess factors such as scale, size, remediability (for negative impacts) and likelihood (for intended impacts) and take these into account in the overall score.

Calculation and assessment of sub-risks and sub-opportunities (financial materiality)

When calculating and assessing the risks and opportunities, we take into account the magnitude of the financial impact (such as the impact on resource use and business relations) and the likelihood of its occurrence. The scoring model for risks and opportunities takes into account the risk classification in our Enterprise Risk Management System (COSO).

In addition, we assess the time horizon within which the risk or opportunity arises, as this affects both the magnitude and the likelihood of the financial impact. This ultimately leads to insight into the risk exposure and the financial materiality score per risk and opportunity.

• 1During the identification of the impacts, risks and opportunities, we did not take into account specific elements linked to pollution, as this issue was labelled as not material when moving from the longlist to the shortlist.

Employees working in the fields of Sustainable Development, Risk, Safety, HR, Procurement, Legal Affairs and Strategy are involved in these above steps. In addition, we involve internal sustainability experts from the company's various departments. The Executive Board validated the results. The Audit & Risk Committee (ARC) was also informed.

4. Prioritisation of sustainability topics

Overview of impacts, risks and opportunities and certain threshold values

We drew up an overview of the impacts, risks and opportunities by first compiling ranked lists for negative impacts, positive impacts, and risks and opportunities. Finally, we generated a table summarising all impacts, risks and opportunities, including categorisation (low, medium, high).

We then defined threshold values to determine the material impacts, risks and opportunities. When assessing impacts, risks and opportunities, we decided to use different threshold values for impact and financial materiality. Using these threshold values, we identified seven material themes.

We then determined the information materiality based on this prioritisation. This revealed which (sub)sections should be disclosed on the basis of the ESRS. For a complete overview of the requirements and their place in the annual report, please see the ‘Publication requirements’ table in ‘Notes’.

This step involved employees working in the fields of Sustainable Development and Risk, as well as members of the Executive Board.

Policy, actions, key performance indicators and targets

The ‘Climate’, ‘Water’, ‘Biodiversity’, ‘Resource use and Circular Economy’, ‘Social Information’ and ‘Business Conduct and Integrity’ chapters describe policies and action plans for the management of each material topic. These policies include references to external initiatives, the scope and any exclusions. Heijmans emphasises that all its operations are located exclusively in the Netherlands. The Executive Board is responsible for implementing the policy, action plans, key performance indicators and targets. We monitor our targets based on our reports to the Group Council and other bodies.

In general, we have policies and action plans for the material topics that affect our own operations. At the same time, we still need to understand what resources we allocate to the implementation of our strategy and how we monitor our progress. We do not yet have detailed policies and action plans for topics related to the value chain.

The aforementioned chapters contain brief descriptions of the definitions of the published indicators. The 'Notes' section contains additional information about the methodologies we used, plus any assumptions and limitations and any validation by an external body. The targets set are included in the tables. We are not currently tracking progress in terms of managing impacts, risks and opportunities for themes for which we have not set any targets, but we will devote more attention to these in the coming years. Tracking effectiveness is part of our quarterly reporting. When no quantitative measurements are available, we report on progress based on qualitative information.

Due diligence statement

The table below shows where in our sustainability report we provide information about our due diligence process, including how we apply the most important aspects and steps of our due diligence process.