EU Taxonomy

The EU Taxonomy was part of the EU Green Deal, Europe's strategy to become the first climate-neutral continent in 2050. The EU Taxonomy serves as a classification system summarising what activities are and are not considered ecologically sustainable. We report in accordance with the Delegated Regulations (EU) 2021/2178, (EU) 2021/2139 and (EU) 2023/2486, as amended by Delegated Regulation (EU) 2026/73 of 4 July 2025. In previous years, the figures were prepared on the basis of the reporting requirements of the Disclosures Delegated Act that applied prior to the amendments introduced by the Omnibus Delegated Act.

Heijmans falls within the scope of the EU Taxonomy. The EU Taxonomy requires the company to conduct research into which part of the company's turnover, capital expenditure (CapEx) and operating expenditure (OpEx) is eligible for the Taxonomy for all six environmental goals stated in the EU Taxonomy. Furthermore, the EU Taxonomy requires the company to assess which part is actually aligned with the criteria listed in the directive for all six environmental goals.

Eligibility

As part of the eligibility assessment based on the company's primary business operations, Heijmans used the currently available EU documents that contain the definitions and clarifications for non-financial companies:

• The Climate Delegated Act (new window) (2021/2139)

• The Disclosures Delegated Act (2021/2178)

• The Complementary Climate Delegated Act (2022/1214)

• The Environmental Delegated Act (new window) (2023/2486)

• The amendments to the Climate Delegated Act (2023/2485)

• The Commission notice documents with EU Taxonomy Frequently Asked Questions

• The Omnibus simplification package

Based on the ISO 9001 and ISO 14001 certificates, Heijmans has made the most granular breakdown possible regarding its business operations and compared them with the Taxonomy activities. In general, Heijmans focuses on the following:

• The design, construction and maintenance of infrastructure for the transport of people, goods and energy.

• The development, renovation and management of construction projects.

• The realisation and maintenance of energy systems in buildings, including the sale and invoicing of energy.

Hegeman was acquired on 17 December 2025. Hegeman’s revenue, CapEx and OpEx that may be relevant under the EU Taxonomy are not included in the EU Taxonomy due to their limited impact, in line with the financial statements.

Eligibility of turnover

The total turnover to be assessed under the Taxonomy consists of revenue from projects for third parties within the Group’s business areas Living, Working and Connecting, including revenue obtained from joint operations (see also Chapter 1, ‘Consolidated statement of profit or loss’, in the financial statements). Consolidated statement of profit or loss in the financial statements).

At project level, revenue is allocated to one of the defined economic activities based on the description and substance of the project concerned (eligibility). Intercompany turnover has been excluded to prevent the double counting of turnover.

The main economic activities in which Heijmans generates eligible turnover are included in the economic activities 4.9 CCM Transmission and distribution of electricity, 7.1 CCM Construction of new buildings and 7.2 CCM Renovation of existing buildings. The economic activity 7.1 CCM also includes the turnover from the sale of land intended for residential purposes.

In addition to the aforementioned main activities, Heijmans carries out several activities of limited scope, which in previous years were linked to economic activities. These activities range from the distribution of district heating and cooling to the renewal of wastewater collection and treatment systems, as well as the installation, maintenance and repair of energy-efficient equipment. Together, these unassessed activities, which are considered non-material, account for 4.2%.

As certain economic activities occur in multiple environmental goals, the eligible turnover of these activities can be allocated to multiple environmental goals.

See Table TAXO1 for an overview of the allocations.

Table TAXO1 Eligibility and alignment share per environmental target

Eligibility of Capital Expenditure

Capital Expenditure (CapEx) consists of investments in accordance with Chapter 6.10 Property, plant and equipment and lease additions in accordance with Chapter 6.11 Leases. The CapEx to be assessed for the Taxonomy consists of €45 million in investments in property, plant and equipment and €46 million in lease additions in the 2025 financial year.

In the eligibility analysis of the CapEx KPI, a distinction is made between leases and investments that are directly attributable to economic activities and those that are not. All leases and investments within Heijmans arise from a plan to make business operations more sustainable. Investments under this plan have been designated as eligible by Heijmans.

Directly attributable items, and therefore eligible as referred to in point 1.1.2.2(c) of Annex I to Regulation (EU) 2021/2178, include, among other things, investments and leases relating to passenger cars and light commercial vehicles (economic activity 6.5 CCM), investments and leases forming part of road freight transport (economic activity 6.6 CCM), investments in the timber-frame housing factory in Heerenveen (economic activity 7.1 CMM) and investments in accommodation and business premises (economic activity 7.7 CMM).

Indirectly attributable leases and investments are allocated in proportion to eligible turnover within the Living, Working and Connecting business areas. For economic activities for which aligned revenue has been achieved, investments are also allocated as aligned, in proportion to revenue.

In the 2025 financial year, Heijmans reported 78% of its CapEx as eligible (2024: 73%).

Eligibility of Operating Expenditure

Operating expenditures (OpEx) consist of “short-term leases” in accordance with note 6.11 “Leases” in the financial statements, “Research, development and innovation costs” in accordance with note 6.5d “Research and development costs” in the financial statements, and “Management and maintenance costs” (including measures for the renovation of buildings and all other direct expenditure relating to the day-to-day maintenance of tangible fixed assets).

In the 2025 financial year, the OpEx to be assessed for the Taxonomy consists of €128 million in short-term leases, €17 million in “Research and development costs” and €4 million in “Management and maintenance costs”.

In the eligibility analysis of OpEx, a distinction is made between leases and costs that are directly and indirectly attributable to economic activities. All leases and costs are included in a plan to make business operations more sustainable.  The costs under this plan have been designated as eligible by Heijmans.

Directly attributable items, and therefore eligible as referred to in point 1.1.3.2(c) of Annex I to Regulation (EU) 2021/2178, include, among other things, rental and lease costs relating to passenger cars and light commercial vehicles (economic activity 6.5 CCM), office rental costs (economic activity 7.7 CCM) and research, development and innovation costs (economic activity 9.1 CCM).

Leases and costs that are not directly attributable are allocated in proportion to eligible turnover within the Living, Working and Connecting business areas. For economic activities for which aligned revenue has been achieved, leases and costs are also allocated as aligned, in proportion to revenue.

In the 2025 financial year, Heijmans reported 58% of its OpEx as eligible (2024: 57%).

Alignment

Where economic activities may be eligible under multiple environmental objectives, Heijmans chooses to link them primarily to the environmental objective of climate change mitigation (CCM), in line with its strategy aimed at limiting CO₂e emissions. The strategy also ensures that Heijmans' economic activities best correspond to the descriptions and criteria within the environmental goal of Climate Mitigation.

For individual projects, the opportunities to meet the taxonomy criteria for environmental objectives other than climate change mitigation are also explored. In 2025, this exploration resulted in a major project under activity KM 4.9 achieving alignment for both climate change mitigation and climate change adaptation.

Alignment has been determined for activities 4.9 CCM “Transmission and distribution of electricity”, 7.1 CCM “Construction of new buildings” and 7.2 CCM “Renovation of existing buildings”. Together, these three activities represent 68% of Heijmans' total turnover.

Turnover, investments and operational costs of activities for which there is as yet no proof and/or this proof is not available centrally are included as eligible non-aligned. This applies, among other things, to both Whoon, acquired in 2023, and Van Gisbergen, acquired in 2024.

Alignment of turnover

Individual projects have been assessed for alignment in the economic activities 4.9 CCM Transmission and distribution of electricity and 7.2 CCM Renovation of existing buildings. The projects within these economic activities differ to such an extent that they were assessed separately for alignment.

In the case of the economic activity 7.1 CCM Construction of new buildings, the projects developed and carried out in the Living business area are homogeneous in nature. This is due to the frequent use of similar housing products. Alignment of these economic activities was examined based on sample projects. The percentage aligned with the assessed sample projects was then applied to all comparable projects.

As much project information as possible is used for alignment. Evidence for economic activities 7.1 CCM and 7.2 CCM consists of BENG calculations; 7.1 CCM is a legal calculation, 7.2 CCM is a Taxonomy-specific adjusted BENG calculation that does not include the renewable energy generated on the building. For climate adaptation, Heijmans prepares a report for each project that defines climate-related risks and control measures. Heijmans uses a waste dashboard with waste partners to demonstrate that more than 70% of construction and demolition waste is reused. Furthermore, each home has a detachability analysis pursuant to ISO 20887. The construction of new buildings and renovation of existing buildings have DNSH criteria (Do No Significant Harm criteria) with respect to pollution. Heijmans has assessed these criteria to the best of its ability, but points to the complexity of the requirements of Annex C to the Climate Delegated Regulation and the limitations of collecting data on all substances in all materials, products and equipment used by the company. Turnover from 7.1 CCM economic activities meeting the criteria increased from €365 million in 2024 to €436 million in 2025.

For economic activity 7.2 CCM, alignment was achieved in 2025 for three projects. Together, these projects account for a 1% contribution to Heijmans' total alignment score. Alignment is achieved because the renovation reduces the primary energy demand of these projects by more than 30%.

Alignment was demonstrated for the first time in 2025 for economic activity 4.9 Transmission and distribution of electricity. The alignment percentage is 2% (2024: 0%). Alignment has been demonstrated on one major project for both the environmental goal of Climate Change Mitigation (CCM) and the environmental goal of Climate Change Adaptation (CCA).

The alignment achieved for both environmental goals has been made possible because the project assessed as critical energy infrastructure has been extensively prepared and substantiated with an Environmental Impact Assessment (EIA) and the associated Memorandum on Scope and Level of Detail (MSLD). For the Substantial Contribution Criteria for climate change adaptation and the DNSH criteria for climate change adaptation, pollution, biodiversity and ecosystems, the EIA and MSLD are the main sources of evidence.

The Substantial Contribution Criteria for climate change mitigation are demonstrated by the project-specific agreement with client TenneT, supplemented by its policy plans for grid reinforcements in the coming years. For DNSH criteria on climate change mitigation, the available project-specific information has been used. DNSH criteria for circularity and pollution are also demonstrated using information from Heijmans' quality management system and legal requirements such as the Dutch PCB and PCT Decree as well as the Dutch Environmental Activities Decree.

Table TAX02 shows the results of the eligibility and alignment analysis of Heijmans' turnover.

Table TAXO2 Turnover

Alignment of Capital Expenditure

The CapEx-KPI eligibility analysis shows that Heijmans' eligible CapEx is divided into two categories. The first category contains CapEx items that are directly attributable to an economic activity. The second category consists of indirectly attributable investments linked to a plan to carry out activities aligned with the Taxonomy.

Within the directly attributable CapEx, one economic activity is aligned. This relates to investments in the industrial building and housing production facility in Heerenveen (economic activity 7.1 CCM) which are aligned with the Substantial Contribution Criteria and the DNSH criteria.

Table TAX03 shows the results of the eligibility and alignment analysis of Heijmans' CapEx.

Table TAXO3 CapEx

Alignment of OpEx

The OpEx eligibility analysis shows that eligible OpEx is divided into two categories. The first category contains OpEx items that are directly attributable to an economic activity. The second category consists of indirectly attributable leases and costs linked to a plan to carry out activities aligned with the Taxonomy.

In the first category, rental and lease costs related to passenger cars and light commercial vehicles (economic activity 6.5 CCM), office rental costs (economic activity 7.7 CCM) and research, development and innovation costs (economic activity 9.1 CCM) are classified. The rental and lease costs in these three economic activities are not in line with the Substantial Contribution Criteria and DNSH criteria as included in the EU Taxonomy. There is insufficient evidence available to meet the Substantial Contribution Criteria and the DNSH criteria.

In the second category, the Asphalt Processing item, which covers the maintenance of machines for asphalt processing is classified as eligible. The costs concerned are allocated on a pro rata basis to the asphalt-related economic activities, which are non-eligible and material.

Table TAX04 includes the results of the eligibility and alignment analysis of Heijmans' OpEx.

Table TAXO4 OpEx

Minimum Social Safeguards

The EU Taxonomy requires Heijmans, as a minimum, to ensure that due diligence processes relating to human rights (including labour and consumer rights), taxation, fair competition, bribery and corruption are in place and complied with. Heijmans meets this criterion. For information supporting the Minimum Social Safeguards, see the section 'Social information'.

Reporting requirements

The Turnover, CapEx and OpEx KPIs have been calculated in line with the requirements of Article 8 of the EU Taxonomy legislation for the 2025 financial year (1 January 2025 – 31 December 2025). The tables are designed in line with the requirements in Delegated Regulation (EU) 2023/2486. The terms used in the table in this chapter, ‘Taxonomy-eligible activities’ and ‘Taxonomy-aligned activities’, refer to eligibility and alignment, respectively.

Turnover

The denominator comprises total turnover and the numerator comprises Taxonomy-eligible turnover. The total turnover is the turnover as shown in the consolidated statement of profit or loss (financial statements).

The Taxonomy-eligible turnover is the portion of the consolidated turnover from products or services, including intangible assets, that are related to economic activities aligned with the Taxonomy and as such have been allocated to an economic activity.

CapEx

The denominator includes additions to property, plant and equipment and intangible fixed assets in the course of the financial year, before depreciation, amortisation and any revaluations, including those arising from upward revaluations and impairments, for the relevant financial year and excluding changes in fair value. The denominator also includes additions to property, plant and equipment and intangible fixed assets resulting from business combinations.

The numerator includes the portion of the CapEx related to economic activities aligned with the Taxonomy and as such allocated to an economic activity, as well as that portion of the CapEx linked to a plan to make business operations more sustainable in alignment with the requirements of the Regulation.

OpEx

The denominator comprises direct non-capitalised research and development costs, building refurbishment measures, short-term leases, maintenance and repair, and all other direct expenses related to the day-to-day maintenance of property, plant and equipment. Excluded expenses are overheads, raw materials, employees operating machinery, management costs and project development required to operate property, plants and equipment.

The numerator comprises the portion of OpEx related to Taxonomy-aligned economic activities that has been allocated to an economic activity as such, as well as the portion of OpEx linked to a plan to make business operations more sustainable in line with the requirements of the Regulation.