Social information

At Heijmans, we create healthy living environments. This means that we not only build sustainable infrastructure and homes, but we also take responsibility for the people who contribute to this. In this chapter, we will discuss our own operations and the role of employees within our value chain. We will address issues such as working conditions, diversity and inclusion, equal treatment and fair labour practices. We will also explain what Heijmans' value chain looks like and how our human rights due diligence is organised.

This chapter uses various terms:

Our own personnel: our own personnel consists of our own employees and self-employed workers.

Our own employees: employees with a direct employment contract with Heijmans, including employees working at joint ventures and special purpose vehicles.

Self-employed workers: these employees do not have an employment contract, but have a contract with a party that is involved in job placement, for example, or have a contract for services. These are hired-in employees such as those on secondment, temporary agency workers, self-employed workers, etc. Subcontracting is not part of this group.

Employee in the value chain: a person who performs work within the Heijmans value chain, regardless of the existence or nature of any kind of contractual relationships with that company.

Heijmans’ value chain

Below you will find an overview of the most important groups of people who perform work within the entire Heijmans value chain, both in the company's own operations and upstream. These are employees and workers on whom Heijmans has a material impact, regardless of the existence or nature of any contractual relationships with Heijmans. This overview is based on the results of the stakeholder analysis conducted for the double materiality analysis. You will find Heijmans' value chain and activities in the ‘General Information’ section.

Upstream

Our supply chain consists of a wide range of partners, including suppliers, research institutes, building materials producers, and employees in transport and raw materials extraction. In the year under review, we focused on the parties in tier 1 that we have insight into. These are contract parties that work at Heijmans locations, suppliers and subcontractors at our own company locations. 

Our own operations

Our own personnel consists of our own employees and self-employed workers. In addition, we have various activities in our own operation that we perform in collaboration with business partners, but these fall outside the scope used for this year.

Downstream

Our downstream includes clients and end users, local communities and those living in the vicinity. At the moment, we are not focusing on the downstream value chain.

In the year under review, we focused on the employees of partners and subcontractors in the upstream value chain and our own operations. Due to the phased introduction of the new reporting requirements, we are not reporting any information on self-employed workers for 2024. . 

Human rights due diligence

The process

In 2023, Heijmans started a due diligence on human rights in the value chain. We focused on our own operations and employees in the value chain. The DMA performed in 2024 confirmed the importance of these themes, so we continued our efforts targeting these groups. This means that issues such as local communities and clients have been left out of consideration. This pertains to both our own operations and the employees in the value chain. We identify human rights risks based on the principles of the human rights due diligence process and supporting measures as described in the OECD guidelines. The due diligence report distinguishes between human rights in the areas of labour, safety and the environment. These are in line with the principles of the Universal Declaration of Human Rights, which emphasises fundamental human rights.

Integrating our human rights policy is a dynamic process. Our (human rights) policy will be adjusted when necessary as Heijmans gains more experience in identifying human rights.

For our extensive report, please see our corporate website.

1. Governance

Many topics related to human rights receive daily attention from management and are embedded in various policy documents. We integrate due diligence into decision-making, facilitated by the Risk Office and Audit and formally raised in the management teams, Group Council and the Executive Board. This means that human rights risks are assessed in the standard risk register. When addressing risks, we discuss the implementation of (management) measures, the monitoring and follow-up of the (management) measures taken. Furthermore, we assess the effectiveness of the (management) measures taken and, if necessary, we tighten these (management) measures.

2. Risk analysis

Heijmans has been working to gain a better understanding of the risks associated with purchased products since 2018. The most recent assessment of potential risks for due diligence purposes was in 2023. We used a spend analysis to determine our most important types of materials, namely concrete, metal and steel, asphalt and plastic. To get a more complete picture of possible risks, we included natural stone and timber in the analysis. We also included these materials based on knowledge from the sector. This analysis looks at Heijmans' own activities, as well as the activities in our chain. We used the CSR risk checker to identify the potential risk factors relevant to these specific types of materials from specific regions. This is an online tool that helps provide insight into the risks associated with corporate social responsibility (CSR). We then formulated control measures to manage the identified risks. The results provide initial insights into the types of risks, as well as their prioritisation. We can then use this analysis as the basis for a systematised approach from 2025 and to help compile the CSRD's double materiality analysis.

Heijmans sees the fact that Dutch suppliers must adhere to Dutch legislation and any signed agreements as risk-mitigating factors. However, the rest of the value chain may be exposed to such risks. Heijmans tries to reduce the risk by purchasing certified products and working with certified suppliers. One example of this is the aim to only purchase sustainably certified timber, where specific human and labour rights are also guaranteed (both FSC and PEFC). You can read more about our policy on certified timber in the 'Biodiversity' chapter.

3. Measures to prevent, avoid or limit risks

We used the risk analysis to make an initial assessment of which actions are necessary to prevent, avoid and/or limit risks as part of the human rights due diligence process. One risk-mitigating factor for Heijmans is that our organisation only works in the Netherlands and most raw materials and products are sourced in Europe.

4. Monitoring

We monitor the practical application and results, including the extent to which the negative impacts have been adequately addressed, by establishing and measuring quantitative and qualitative indicators. Examples of this are the internal employee engagement survey, external independently conducted audits at building sites and at subcontractors (Safety Culture Ladder) and external supplier assessments. We do this periodically, as an integral part of our reporting process. The responsibility for monitoring has been assigned to various officers, under the supervision of the Group Council and the Executive Board. Monitoring enables us to assess whether the measures taken within our organisation are effective or whether improvements are needed.

5. Communications

We will keep stakeholders informed of our due diligence process via our website www.heijmans.nl. Communications will remain a key focus in the coming years, with the involvement, informing and active participation of employees and external stakeholders as our main priorities. We will also keep stakeholders informed via our annual report, which is drawn up according to CSRD guidelines.

6. Remediation measures

Affected stakeholders, including employees, can report abuses to the company under the existing Procedure for Reporting Inappropriate Behaviour and Abuses, which includes provisions for violations of EU law. You can read more about this in the (Business) Conduct and Integrity section.

Own workforce

Our people make the difference. We know that each employee makes a unique and valuable contribution. Our efforts create an environment that is healthy, safe and attractive. We do this together, with our own operation and employees in the value chain.

Impacts, risks and opportunities

As described in the ‘General Information’ section, for the CSRD we performed a double materiality analysis. Based on the double materiality analysis, we defined impacts and an opportunity for Our own workforce:

Policy

Because we recognise the employees in our own operation as the most important driving force behind the success of our organisation and as one of our most important stakeholders, we have implemented policies to manage potential negative impacts, to stimulate positive impacts and make use of opportunities. We describe all policy documents for the management of our most important IROs for our own employees in this chapter. We have also linked this to policies that focus on employees of subcontractors and partners, as shown in the table. All policies are available on our website.

The following policy documents are relevant to our own operation:

1. Code of Conduct

2. Reporting Procedures

3. Human Rights

4. Anti-Discrimination

5. Heijmans GO!

Code of conduct | This is how we work

We safeguard human and labour rights in our company's fundamental policy documents. Heijmans has a code of conduct that is mandatory for everyone who has anything to do with Heijmans: the Executive Board, our colleagues and temporary staff, as well as our partners, subcontractors and suppliers. The policy is based on four principles:

1. We treat others equally and with respect.

2. We work safely or we do not work at all.

3. We are honest and have integrity.

4. We make things better, smarter and more sustainable.

All internal employees follow an e-learning course on business integrity (Zakelijk Zuiver), which deals extensively with these themes. For more information, please see the (Business) Conduct and Integrity’ section.

Reporting procedures | inappropriate behaviour, Integrity and misconduct

Any affected stakeholders, including subcontractors‘ employees and partners’ employees, can report abuses to Heijmans under the existing Reporting Procedure for Inappropriate behaviour and Misconduct, which includes provisions for violations of EU law. The reporting procedure for external stakeholders can be found on the Heijmans website, and for employees it can be found on an internal portal. Heijmans uses this reporting procedure to address human trafficking, forced or compulsory labour and child labour. The procedure offers the opportunity to take remedial measures and/or to mitigate the consequences of human rights violations. For more information, please see the (Business) Conduct and Integrity’ section.

The reporting procedure also includes the Whistleblower Protection Act, which deals with the protection of those who report misconduct, breaches of integrity and abuses.

For a more detailed explanation of this policy, please see the ‘(Business) Conduct and Integrity’ section. The Remedial Measures for negative impacts section in the Employees in the value chain chapter below explains in more detail how the employees of subcontractors and partners are familiarised with this procedure and its effectiveness.

Human rights policy

At Heijmans, we are committed to ensuring the welfare and fair treatment of employees throughout the value chain, including our own operations and the employees of subcontractors and partners. Human rights cover a wide range of topics, including employment, health and safety, education, participation, diversity, social security, living wages and fair contracts.

These policies stipulate, among other things, that Heijmans uses the general principles of the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business & Human Rights (UNGPs) as a framework, thereby endorsing the Universal Declaration of Human Rights and the core principles of the International Labour Organization (ILO).

Anti-discrimination policy

In 2024, Heijmans drew up an anti-discrimination policy to prevent discrimination and intimidation, which applies to our entire operation. By offering equal treatment and equal opportunities to employees, we promote diversity and inclusion across the organisation.

At Heijmans, discrimination is defined as making direct or indirect distinctions based on personal characteristics. These include race and ethnicity, skin colour, sexual orientation, gender identity, disability, religion, political beliefs, national or social origin, age or other forms of discrimination that fall under the regulations of the European Union and national law.

Heijmans' position on discrimination is as follows:

• We reject all forms of discrimination and intimidation. We want to ensure that everyone feels safe at work and is treated fairly and equally.

• Nor do we tolerate our employees being subjected to discrimination or intimidation by third parties.

Heijmans GO! policy

Policies related to safety risks are firmly embedded in the Heijmans organisation through various documents and procedures. They apply to all staff and employees who fall under the coordination of the Health & Safety department. Safety is part of all of our processes.

Heijmans has the H&S coordination for all employees at its own company locations, apart from subcontractors and the direct contractors of our clients. It is possible that we may have a coordinating role at our building sites with regard to subcontractors. Heijmans appoints a dedicated H&S coordinator who is present at our building sites for a predetermined period of time and who is responsible for all health and safety aspects.

Heijmans is committed to ‘the right to a healthy and safe working environment’ as a human right, as it has endorsed the UN Guiding Principles on Business & Human Rights. In our human rights policy, we refer to our Heijmans GO! (No Accidents) programme, which focuses on developing proactive safety behaviour, and our vision on safety.

The Heijmans GO! policy consists of the GO! Compass and our GO! strategy. The GO! Compass is a concise explanation of the agreements we make on the work floor. The GO! strategy includes the safety targets and principles. The policy applies to all employees who perform work on our building sites. This policy was not drawn up with the ESRS in mind, which is why we have not tested the targets against CSRD standards. However, it does reflect how risk management is embedded in Heijmans' business operations. We recognise that the work we do involves safety risks. This is why we want to continue to improve our risk management and care. We use our control measures to try to make the benefits of working safely more concrete to prevent so-called safety fatigue.

Within our organisation, safety is also considered from the perspective of health and well-being. We have a Safety Vision: ‘Safety. The Heijmans Vision’ and a Royal Heijmans N.V. Quality-Safety-Sustainability Policy Statement, which is endorsed and signed every three years.

Limitations of our policy

• There are safety risks in most of our activities at production sites. We do our utmost to mitigate these risks. That is why we have detailed policies, which are often fleshed out in the form of work instructions. Because there are so many policies, it is possible that not everyone is equally aware of each policy's implications. We try to compensate for this with training.

• Safety is the foundation of our strategy and our work, so the actions we take to reduce safety risks are certainly in place. However, these actions, or targets, were not formulated with the CSRD in mind.

• In 2024, we developed an anti-discrimination policy, which has not yet been widely distributed internally. This policy is an umbrella for previous policy documents and actions to prevent discrimination. Employees are familiar with the underlying processes and actions.

We are developing a diversity and inclusion programme. This programme focuses on promoting equal treatment in the organisation. We may continue to develop the policy in 2025 to support equal treatment in line with the positive impact. In this programme, we want to work out how we can embed positive measures for equal treatment in our working methods. We hope this will help us gain a better understanding of how we recognise and monitor the positive impact on equal treatment. In addition to this programme, we also offer a training course on this subject.

How we involve employees in the process and decision making

The Works Council is Heijmans' employee representation body. The Works Council discusses various topics including safety and working conditions. They also have various committees that actively focus on themes such as safety, strategy and more. These committees (indirectly) represent the voices of our employees. Our employee representatives have not concluded a Global Framework Agreement or any other agreement regarding the observance of the human rights of their own staff. A dialogue model has been set up with the Works Council that establishes how the Works Council and the management discuss topics from the Works Councils Act. The Works Council is also in regular contact with its own personnel. This represents an opportunity to share signals noticed during work visits in consultation meetings that the CEO attends as a board member. We do not measure the effectiveness of the dialogue between the works council and our own employees.

We try to keep the dialogue between the employees and the Works Council as accessible as possible. The Works Council does this through workplace visits, among other things. We have not developed a specific approach for approaching potentially highly vulnerable groups. We also conduct an employee engagement survey every two years, in which employees can anonymously give their opinion on various topics, including safety and working conditions. The Executive Board has final responsibility for this survey and employee engagement. If an employee has a complaint, they can report it via our complaints mechanism.

With specific regard to safety risks, we encourage our employees to discuss safety. They can do this with a manager, but also via our GO! programme. This has the aim to lower the treshold for reporting incidents.

Actions

Heijmans has taken various actions to cover the identified impacts and opportunities. These are explained in more detail in this section.

Employee engagement

One reason to increase engagement is to develop talent. One of Heijmans' bold statements is: “By 2030, 50% of our employees will have a job that did not yet exist in 2020”. We use this statement to try to encourage our employees to grow with the activities that are changing due to our efforts to become more climate neutral. For example, by harnessing the power of digitalisation and production technology. This is why transitions are currently taking place within our company.

The following are a number of the specific actions that we take to increase employee engagement, which apply to all our employees:

We conduct an employee engagement survey once every two years. The survey is completely anonymous. We use this survey to monitor the effectiveness of our actions, but also to look for new ways to increase engagement. The survey was last conducted in 2023 and will be repeated in 2025. The survey looks at employee satisfaction, engagement, happiness at work and commitment to the organisation (eNPS; score 2023: +35). The survey devotes a great deal of attention to inappropriate behaviour, diversity and inclusion and whether employees experience equality and equal opportunities. Following the survey, the results are discussed per department and we identify actions/areas for improvement. Some areas for improvement are addressed centrally, others by managers and the teams.

We also believe it is important to have insight into the preferences of various (vulnerable) groups within our workforce. This is why we can also create reports based on age and gender in the engagement survey. Due to privacy-related legal requirements, we choose not to request more variables from our employees. These could include cultural background or physical limitations.

Equal treatment

We believe that equal treatment begins with the prevention of discrimination. This applies to our own operations. In line with the positive impact, the right to equal treatment (non-discrimination) is also included in our human rights policy.

We try to promote equal treatment through positive behaviour. This is interwoven into our code of conduct and the accompanying business integrity e-learning course (Zakelijk Zuiver). At Heijmans, we work together to create a healthy living environment. For Heijmans, a healthy living environment also means healthy and sustainable business operations. We are currently developing a Diversity and Inclusion programme, and on the basis of this programme, we want to develop actions relating to equal treatment in 2025. This means that we did not define actions for 2024 related to this positive impact as defined by the ESRS. In the ‘Diversity’ chapter of the management report, we discuss how we shape diversity and inclusion in our organisation. Below, we would also like to highlight some actions we have taken to increase the positive impact:

To also increase equal opportunities outside the workplace, we believe it is important to support employees in various situations. Our employees can call on the services of Bouwend Nederland Social Support (formerly Stichting Sociale Bemiddeling). Here, advisors offer a helping hand with a wide range of problems. These include financial problems (debts), divorce or separation, social issues related to disability, illness and death, and personal or psychological problems (including those of family members). They also have specific knowledge in the areas of debt counselling and mediation (divorce). Where necessary, they refer people to relevant support organisations. These advisors do not handle matters related to employment conditions or other issues directly related to the work situation.

Our agreements are recorded in the HR manual so that employees can also view them. They can also access our intranet to view the code of conduct, the reporting procedure for inappropriate behaviour and misconduct and the information about anonymous reporting via SpeakUp.

Exposing employees to safety risks

With every assignment we take on (sale), we increase the impact on the safety risks of our employees. However, we demand certain safety standards before we start work, to limit the actual risks. We consider it important that our employees return home safely from work, every single day. We are the creators of a healthy living environment. A healthy living environment is also a safe working environment. We do this in a number of different ways, which apply to all employees and workers who fall under our H&S coordination.

We have various actions in place to manage safety risks. In 2013, we developed a programme to motivate our employees to develop proactive safety behaviour. This programme is called Heijmans GO! (Géén Ongevallen, or No Accidents). Part of this programme is the GO! App or geenongevallen.nl, where our employees can submit reports or make suggestions to improve safety. Any reports submitted are sent directly to the project manager. In addition, we can take actions based on trend analyses of the reports. The principle of our GO! Compass is: We work safely or we do not work at all. In 2024, we trained more than 1,250 employees in the organisation in various aspects of safety. That represents an increase of 25% compared with 2023.

Heijmans as a whole is SCC (VCA in Dutch) certified, which stands for Safety, Health and Environment Checklist for Contractors. It is a list of points for attention and working methods and the most common way to demonstrate that as both a company and as an employee you meet the requirements of the Working Conditions Act. At Heijmans, we therefore also apply a safety policy in line with the SCC. This means, among other things, that:

• Every project has a toolbox meeting at least once a month in which employees actively participate.

• Every project and every supervisor carries out a Workplace Inspection (WPI) at least once a month. Managers do this once every quarter.

• Every employee is obliged to use the personal protective equipment (PPE) they are provided with and to maintain it properly.

• Unsafe situations should always be reported to a supervisor. These can be recorded using the ‘GO! App’ or at geenongevallen.nl.

We have carried out a Risk Inventory and Evaluation at all Heijmans work locations, and we drew up a Health and Safety Plan based on this evaluation. This plan includes the risks that exist and how to deal with them. Every employee has insight into this and Heijmans has appointed prevention officers to organise the health and safety policy. Periodic reports are made to the various management levels on the occupational health and safety performance, such as absenteeism due to sickness, accidents and the frequency index, toolbox meetings, workplace inspections, etc. This information is available to everyone. If an accident does occur, Heijmans has procedures in place. For example, there is an action list for emergencies and online information is available on the GO!-App or at geenongevallen.nl. For each emergency and incident, there are separate procedures for each person responsible for taking action that are detailed in this action list. These actions are also subdivided into the different stages of dealing with a disaster or incident. These include providing assistance, informing, investigation and action, and reporting and handling.

When an accident occurs that results in injury, a number of remedial actions are taken. We obviously provide first aid and call in emergency services when necessary. If an employee is unable to continue working as a result of an accident, we will always look for other suitable work. In addition, we offer absenteeism counselling, mediation on the waiting list and victim support if necessary. Our colleagues in the Safety department are closely involved in these procedures and their handling. We evaluate the effectiveness of the remediation offered per incident by conducting evaluation interviews with those involved. The lessons learned are included in the structural consultations that are planned between the Safety department and the operational management teams. In addition, employees can always file a complaint via our reporting procedure. These complaints and reports are monitored by our confidential counsellors and the compliance officer. To test whether employees are satisfied with our safety actions, this topic is also included in our biennial employee engagement survey.

Targets

To respond to the material impacts and opportunities, we set a number of targets for our own employees for 2024. The targets were set for one year (without a baseline year) and can be linked to our ‘Team’ strategic pillar. They were drawn up by Human Resources and progress is monitored every quarter. The Works Council is also involved to ensure that our employees' perspectives are included in this process.

We do formulate ambitions and assess our policies in terms of the negative impact on safety, but in line with the ESRS, we have not set targets for the negative impact. Our goal is to minimise the number of safety incidents. The focus is therefore on policy and actions. In 2025, we want to look at how we can better harmonise our ambitions to align with the ESRS. The ‘Safety’ chapter in the management report provides additional information on safety beyond the requirements of the ESRS.

Metrics

Heijmans has 5,844 employees, which is equivalent to 5,650 FTEs. These employees all work in the Netherlands. In total, 525 employees left us during the year, which means our employee turnover was 8.98%. There were no (major) fluctuations in employee turnover over the course of the year.

Above is the gender distribution of our employees with a more detailed breakdown based on employment status, with the reference date of 31-12-2024. At Heijmans, we have employees with temporary contracts or permanent contracts. We do not have any employees with non-garanteed hours.

A total of 18.1% of our senior management are women. Senior management is defined as all employees who have a senior management contract and are therefore entitled to a variable income for senior managers. This involves a total of 116 employees.¹

Remuneration

In the autumn of 2024, we used a benchmark study to monitor the market conformity of our remuneration. All (relevant) personal data is stored in our HR system, such as gender, age, position and salary. The pay gap looks at the difference in salary between men and women. The total remuneration ratio looks at the median (average salary sorted from low to high) in relation to the highest paid person at Heijmans.

• 1This figure differs from the one in the management report due to the reporting methodology used for the CSRD.

Representation

All Heijmans employees work exclusively in the Netherlands and all employees except the CFO are represented by a Dutch collective labour agreement (CLA or ‘CAO’ in Dutch). At Heijmans, we have four different collective labour agreements: the CLA for the construction and infrastructure sector, the CLA for technical installation companies, the CLA for the wholesale trade in building materials and the CLA for the carpentry industry. The collective labour agreement an employee falls under is determined on the basis of their position.

Converted into a percentage, this means that 99.98% of employees are covered by a collective labour agreement. A trade union, such as the FNV and/or CNV, is always present at the collective bargaining table for the collective labour agreement. We do not have an overview of the total number of employees who are a member of a trade union.

A total of 95.62% of our employees are represented by our Works Council. The Social Dialogue column covers the Works Council's representation of employees. This percentage is not 100% because van Wanrooij and Brabotech do not have their own Works Councils and were unable to nominate candidates for the Heijmans Works Council.

Our employment conditions are aimed at protecting and improving human rights for all employees. We focus on suitable work, freedom of association, sustainable employability, holidays, measures to close the gender pay gap, works councils, collective labour agreements and policies on absenteeism and reintegration. Part of this is an adequate wage. That is why Heijmans always pays its employees at least in accordance with the applicable collective labour agreement (the CLA for the construction and Infrastructure sector, the CLA for technical Installation companies and the CLA for the carpentry industry). The wages in the CLAs are determined during the CLA negotiations by the employers‘ organisation and employees’ organisations (unions). If the wage is not sufficient, and below a government-determined limit, employees can also receive government benefits (such as healthcare and housing allowance) to achieve a living wage. We use the wages prescribed by the collective labour agreement as a living wage.

Accidents and sickness

Our goal is zero accidents in the workplace. We are proud that, as of 2023, all business units – with the exception of recently acquired companies – have been certified on the Safety Culture Ladder at level 4 (out of 5). We encourage our employees to report all (minor) accidents. All of our own employees (100%) fall under the Heijmans management system for health and safety. You can read more about this in the chapter on ‘Our basis’.

The ESRS requires us to divide the accident data for our own employees into the groups ‘our own employees’ and ‘self-employed workers'. Our accident register is organised differently. The group of our own employees is the same, but in the group of self-employed workers we are not fully in line with the ESRS. As soon as an accident occurs, we look at which party is in charge¹ and not at the type of employment contract. When Heijmans is in charge, the accident will be registered as involving a self-employed worker, otherwise it may fall under subcontractors. This means we can present the total number of accidents in these three categories. In 2025, we started looking into how the breakdown according to the ESRS can be tracked in our administration. The total number of accidents in the table below differs from the number in the management report due to the reporting methodology applied for the CSRD.

We calculate an accident rate² based on the total number of accidents and the hours worked by our own employees. Our accident rate for our own employees was 2.75 in 2024. To determine recordable work-related ill health, we consider acute, recurring and chronic health problems caused or aggravated by working conditions, among other things. For this, we use the list of occupational sicknesses of the International Labour Organization (ILO). In 2024, we had 28 registered cases of our own employees with work-related ill health treated by our company doctor, which was 0.48% of the number of employees.

Incidents and complaints

Currently, the number of reports is reported quarterly to the Executive Board and every six months to the Supervisory Board, divided into the following categories:

• Fully work-related conflict

• Mixed case: inappropriate behaviour in relation to work conflict/disturbed relationship

• Private problems

• Bullying/intimidating behaviour

• Sexual intimidation, unacceptable behaviour

• Verbal aggression

• Physical aggression

• Violence

• Discrimination

• 1Here we adhere to Article 1, section a of the Working Conditions Act.
• 2We cannot calculate the accident rate for self-employed workers for 2024, as the accidents for these groups are divided among both temporary employment agencies and subcontractors. In addition, we cannot make an accurate estimate because there is not enough information available for ‘self-employed workers’. 

The compliance officer and our confidential counsellors received a total of 54 reports of integrity issues and inappropriate behaviour in 2024. For each case, the Executive Board first considered the seriousness of the matter and then conducted a fact-finding investigation. The reports let to, among other things, written warnings, including final warnings. All reports were also discussed (anonymised where necessary) in Executive Board meetings and evaluated afterwards with the managers involved. In 2024, the reports did not result in fines, penalties or damages for Heijmans.

Of the 54 reports, three were related to discrimination. In 2024, we did not break down the reports of discrimination by gender, race or ethnic origin, nationality, religion or belief, disability, age or sexual orientation, or other relevant forms of discrimination involving internal and/or external stakeholders in all activities during the reporting period. It is therefore not possible to report on this for 2024. For 2025, the compliance officer will work with our confidential counsellors to keep track of this breakdown. After that, it will also be possible to report on this aspect.

• 1Heijmans received three reports and 0.12 reports were added for Van Wanrooij.
• 2Van Wanrooij does not currently have a system for reporting complaints or incidents and has not yet been integrated into the Heijmans system. We have added extra reports based on the number of employees. The number of reports in 2024 was 52, with 2.14 reports added for Van Wanrooij.

Workers in the value chain

We feel responsible for ensuring that our services and activities have no adverse impact on employees throughout our chain. This includes the impact on employees of subcontractors and partners who have poor working conditions and terms of employment. This has a particular impact on 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.

Impacts, risks and opportunities

As described in the ‘General Information’ section, we performed a double materiality analysis, as required by the ESRS. The double materiality analysis defined an impact on Employees in the value chain:

Policy

Heijmans strives to mitigate the impact on employees of subcontractors and partners who use poor working conditions and terms of employment by drawing up policies aimed at the employees in the value chain. Partners are stakeholders with whom Heijmans works directly or indirectly, including suppliers, for the realisation of its products and services. In addition to the aforementioned policy regarding its own workforce, Heijmans also has a policy that specifically focuses on the value chain. This policy takes into account employees in vulnerable positions, which includes migrants, vulnerable minorities and part-time employees.

Suppliers, subcontractors, ancillary and contract partners are involved in our procurement and chain responsibility. They sign a framework or project contract containing the Sustainability Statement and the General Purchasing and Subcontracting Conditions (Dutch acronym: AIOV), which include our code of conduct. Both the sustainability aspects that are guaranteed in our AIOV, as well as the code of conduct and the Sustainability Statement are part of our negotiations and discussions with suppliers, subcontractors, consultants, etc. The Sustainability Statement recognises that truly sustainable business operations can only be achieved when the three aspects of sustainability – People, Planet and Profit – are respected and a proper balance is struck between them. It includes rules for improving social aspects, working conditions and health, safety and the environment. These include refraining from the direct or indirect employment of children and any form of forced labour.

In addition to the Sustainability Statement, the AIOV and our code of conduct, the reporting procedure for undesirable behaviour and integrity and abuses, our human rights policy and the Heijmans GO! policy also apply to employees of subcontractors and partners. You can find these in the ‘Our own employees’ section.

For the full Sustainability Statement, please see our corporate website.

In control of the value chain

With its ‘In control of the value chain’ (Grip op de Keten) policy, Heijmans confirms its dedication to promoting respect for human and labour rights throughout the value chain and we contribute to sustainable and inclusive growth for all parties involved. We have formulated three principles to this end: [1] gain insight, [2] increase involvement and [3] refine policy. ‘In control of the value chain’ refers to the impact Heijmans has on the employees of subcontractors and partners who have poor working conditions and terms of employment.

To make improvements in the value chain, it is important to first gain a clear picture of the current situation (gaining insight). Gaining insight is related to involving employees throughout the value chain. By actively involving employees in the value chain, we can better embed human and labour rights in our business operations (increasing involvement). This enables Heijmans to act in accordance with human rights. Finally, having clear and effective policies is crucial to ensuring a sustainable and fair value chain. We want to ensure that policies do not just exist on paper, but are actually integrated into our organisation. This strengthens internal compliance and helps us to achieve a genuinely lasting positive impact (refining policy).

This policy complements the Heijmans human rights document, which describes Heijmans‘ human rights policy and human rights due diligence. The UNGPs emphasise companies’ responsibility to respect human rights and prevent negative impacts in their value chain. This includes improving working conditions and guaranteeing job security, with special attention for employees in vulnerable positions. Guiding Principle 13 requires that companies contribute to both the prevention of violations through their own activities and address impacts that arise from the activities of their partners, even if they have not directly contributed to them. Heijmans used the above principles and legislation to formulate its policies in this respect. We are not aware of any incidents involving non-compliance with human rights in the value chain.

In addition, Heijmans has not yet entered into any other agreements with Global Union Federations (GUFs) regarding respect for the human rights of employees in the value chain.

The ‘In Control of the Chain’ policy is monitored and safeguarded by the procurement and safety department. In the coming years, it will become clearer how responsibilities are allocated within the departments. It will also become clear which stakeholders are needed to help implement the policy. To this end, the policy will be made available to potentially affected stakeholders.

Involving employees in the value chain in the process and decision making

Heijmans is committed to listening to the voices of employees throughout the value chain and to including them in decisions that affect their well-being and working environment. By involving our contractors in taking on this responsibility, we want to help improve social aspects, working conditions and health, safety and the environment, both within our own company and among our contractors and in our contractors' chains. We do this by facilitating open communications and encouraging cooperation. Contact takes place between Heijmans and authorised representatives (account managers or directors) at the party of the client/contractor with whom Heijmans works or with the H&S contact person (H&S coordinator). They are seen as the representatives of subcontractors' employees. Taking these perspectives into account contributes to a strong, transparent value chain. This enables Heijmans to gain insight into the impact on employees of subcontractors and partners with poor working conditions and terms of employment.

The type of dialogue conducted, how often it occurred and the topics discussed for each stakeholder group within the scope last year are listed below.

The Chief Procurement Officer is responsible for ensuring that stakeholder groups are included in Heijmans' approach.

Currently, it is not clear what the positions of subcontractors‘ and partners’ employees are, as they may be particularly vulnerable to impacts and/or marginalised. We also have no direct contact with these employees regarding the development of policy documents. In the coming years, Heijmans will focus on trying to gain insight into this aspect.

Actions

Heijmans has taken various actions to mitigate the identified impact. These involve ensuring good working conditions for subcontractors‘ and partners’ employees. Because parts of the value chain have been under-examined in previous years, we are still in the initial phase of this process. In 2024, we looked at the majority of the employees present at Heijmans business locations. This included: [1] contract parties at fixed Heijmans locations, [2] suppliers who carry out work on projects and [3] subcontractors.

Heijmans is responsible for the coordination of health and safety for employees and workers at its own business locations, with the exception of subcontractors and direct contractors of clients and those present at the building sites of subcontractors. It is possible that we play a coordinating role with regard to subcontractors at our own building sites. Heijmans appoints a dedicated H&S coordinator who is present at a building site for a pre-determined period and who is responsible for all health and safety aspects. This role is limited to our own building sites.

Working conditions and compliance with employment conditions are strictly monitored in Heijmans' own operations. In the chain, this is guaranteed by the sustainable procurement policy. Nevertheless, Heijmans has limited insight into compliance with this policy in the case of the employees of subcontractors and partners, which means that this group runs an increased risk of suffering adverse impacts.

For the actions listed below, the focus is on employees of subcontractors and partners who are part of the upstream value chain. We use the various actions to address any negative impact of our own practices and then mitigate them. Both actions have a rolling time horizon.

Audits

In the event of serious suspicions of behaviour that is in violation of the code of conduct and/or the Sustainability Statement, Heijmans is entitled to have an audit carried out by an independent party. This is laid down in article 2.2 of the General Purchasing and Subcontracting Conditions. We use this action to try to avoid non-compliance with working conditions and terms of employment for employees of subcontractors and partners. You will find a more detailed explanation in the ‘Dealing with suppliers and subcontractors’ section of the ‘Business Conduct and Integrity’ chapter.

GO! App | geenongevallen.nl

In addition, the GO! App and geenongevallen.nl offer employees an accessible option for filing a report; depending on where the colleague who makes a report is working at the time, their colleagues in the same workflow are informed about the report. We work with a dashboard (IRES), with an enforcement policy that is linked to the report. This action allows us to identify potential safety risks, which we can mitigate after. You will find a more detailed explanation in the ‘Safety’ chapter.

In 2025, we will make a start on the development of the three principles from the ‘In control of the Chain’ policy. We will first focus on tier 1, and then eventually look at tiers 2 and 3. The first step will be to focus on gaining insight into our value chain.

To ensure we can make an effective contribution to remediation in the event of an impact on employees of subcontractors and partners with poor working conditions and employment terms, we will assess each situation separately. Affected stakeholders can report abuses to the company under the existing Reporting Procedure for Inappropriate Behaviour and Misconduct, which includes a regulation for violations of EU rights. We use this reporting procedure to explicitly address human trafficking, forced labour, compulsory labour and child labour. Due to the diverse nature of these situations, an uniform approach is not possible. If reports are made, we will investigate them thoroughly and discuss them - on an anonymous basis - in the Executive Board. We will determine which actions are necessary to prevent or limit the negative impact. The compliance officer will keep a register of all reports. We will assess each individual case to determine whether the report has been handled to the employee's satisfaction.

Every quarter, confidential counsellors provide an anonymised overview of the number of reports received, classified by nature. This overview is reported to the Executive Board, the Supervisory Board and the auditor every six months. The Integrity Committee evaluates the effectiveness of the actions taken, taking into account any signals on this subject from the Works Council.

Geographical dimensions

Heijmans is only active in the construction sector in the Netherlands. Our largest suppliers of the largest material flows (concrete, metal and steel, asphalt and plastic) are based in the Netherlands. Our aim is to gain more insight into the entire supply chain, including sub-suppliers and the origin of materials. In 2025, Heijmans aims to develop an approach to the identification of geographical areas, raw materials and services in our value chain that pose a significant risk of child labour or forced labour. We are still working out the details of this approach. We are investigating whether these risks are widespread, systemic or incidental in nature.

Based on this information, we can determine which employees in the value chain are at a greater risk of harm (for example due to demographic or geographical circumstances), so we can then act to uphold human rights.

Remediation actions for any negative impact

There are no known or reported cases of actual negative impacts affecting Heijmans‘ employees in the value chain. This also means that there have been no reports of serious human rights issues or incidents relating to Heijmans’ value chain. The company's own operations are subject to both supervision and monitoring, and this has been incorporated in the sustainable procurement policy in the chain. When a report is made by an affected stakeholder, it will be handled as described in the ‘Reporting procedure inappropriate behaviour and misconduct' section.

Targets

Although we are devoting attention to this issue and it is reflected in various policy areas, Heijmans has not set any specific targets with respect to any identified material impacts. We have not yet set any concrete targets, as we first want to gain a more in-depth understanding of our value chain and the associated risks. This means that we are not (yet) actively monitoring the effectiveness and results of the policy and the actions to manage the impact.

Actively investing in and managing human and labour rights within the value chain represents a broadening of Heijmans‘ focus. Currently, our focus is on the employees of subcontractors and partners who work at Heijmans’ own locations. Looking to the future, our ambition is to expand this to the entire value chain.

The Chief Procurement Officer is responsible for ensuring that we communicate with stakeholder groups and that these are included in Heijmans' approach.

At present, it is not clear what the views are of employees of subcontractors and partners who may be marginalised and/or particularly vulnerable to impacts. In the coming years, Heijmans will focus on trying to gain more insight into this aspect.