Workers in the value chain

We take our responsibility of making sure that our operations and services do not have a negative impact on employees throughout our value chain seriously. Health and safety are at the heart of our approach. We recognise that there is a risk of accidents and unsafe working conditions, which can in turn harm employees' health and well-being. That is why we actively work to prevent and mitigate such risks by working with value chain partners, making clear agreements and carrying out continuous monitoring.

Impacts, risks and opportunities

As described in the section ' ' , we carried out a DMA This reassessment led to the identification of a new impact: the focus has shifted from other labour rights to the health and safety of workers in the value chain. This adjustment was made because the recent analysis showed that the most significant negative impacts primarily arise from exposure to accidents and unsafe working conditions.

Geographical dimensions

Heijmans is exclusively active in the construction sector in the Netherlands. Our largest suppliers for the main material flows – steel, concrete, asphalt and plastics – 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, we took steps to gain greater insight into material-oriented quality marks and researched software that can support us in increasing the understanding of risks within our value chain.

In accordance with the DMA 2025, we are focusing on deepening our insight into the value chain through due diligence, audits and reporting channels, and embedding basic standards in our Code of Conduct and contracts. Although no concrete, measurable targets have yet been set, the priority lies in strengthening monitoring and collaboration. Based on further analysis, we will then determine which SMART targets are required.

Policy

Within Heijmans’ own operations, strict supervision of working conditions is maintained. Heijmans is committed to preventing negative impacts on workers in the value chain, paying particular attention to health and safety. The policy focuses on employees working for subcontractors, suppliers, ancillary parties and contract partners, and is in addition to the policy for our own workforce.

Subcontractors, suppliers, ancillary parties and contract partners are actively involved in our procurement and value chain responsibility. They sign a framework or project contract that includes the General Terms and Conditions of Purchase and Subcontracting (GTCPS). For framework contracts, the updated Sustainability Declaration for 2025, which incorporates our Code of Conduct, also applies. The sustainability aspects from the GTCPS, the Code of Conduct and the Sustainability Statement form an integral part of our collaboration with suppliers, subcontractors and consultants. These documents set out clear requirements in the areas of working conditions, human rights, social safety, the environment and integrity.

In control of the value chain

In 2025, Heijmans' 'In control of the value chain' policy underlines our ongoing commitment to respecting human and labour rights, including the right to a safe working environment, across the entire value chain. We make an active contribution to sustainable and inclusive growth for all parties involved. Our 'In control of the value chain' policy is primarily monitored and safeguarded by the Procurement department, which is responsible for its implementation and compliance within the organisation.

The Safety department plays a key role here by making an active contribution to ensuring safe working conditions on our projects.

In 2025, the focus will lie on Tier 1 (direct suppliers or partners who supply products or services directly to us; they have a direct contractual relationship with Heijmans), with the aim to expand this to Tier 2 and Tier 3 in the coming years. This allows us to broaden our perspective and increase our influence further down the value chain, and work towards a transparent value chain in which employees can work in safety and are treated fairly and with respect. This approach ensures we are gradually working towards having more control of the value chain.

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

We further strengthened our commitment to stakeholder dialogue in 2025, engaging in existing meetings with employees at subcontractors, suppliers, ancillary parties and contract partners to gain valuable insights on working conditions, health and safety. By actively involving our contractors in this process, we contribute to improving social aspects, working conditions, health, safety and the environment within our company, at our partners and throughout the wider value chain. This also allows us to make sure the voices of employees throughout the value chain are increasingly heard, and that they are included in decisions that affect their well-being and working environment.

The dialogue takes place between Heijmans and the responsible contact persons at the subcontractor or supplier, such as the account manager, director or health and safety coordinator. These interactions are valuable to us because they contribute to a more transparent value chain and provide greater insight into the impact on the health and safety of employees at subcontractors, suppliers, affiliated parties and contract partners. The next page sets out the type of dialogue conducted, its frequency and the topics discussed.

The Procurement department is responsible for communicating with the various stakeholder groups and making sure that their perspectives are incorporated into our approach. We strive to ensure this is embedded within the value chain through our sustainable procurement policy. Nevertheless, Heijmans has limited insight into compliance with this policy by employees at subcontractors and partners, which means that this group runs an increased risk of suffering adverse impacts. In addition, we are still lacking an overall picture of the direct views of stakeholder groups belonging to marginalised groups. Deepening this understanding therefore remains a focal point for the years ahead to ensure their perspectives are structurally embedded in our policies and processes.

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. Heijmans ensures the respect of labour and human rights through its own (tightened) policy frameworks, supplier code, contractual chain clauses and due diligence processes pursuant to the UN Guiding Principles, OECD and ILO.

Actions

In 2025, Heijmans took a range of actions to identify, remedy and prevent negative impacts for employees in the value chain. We have rolled out a practical, structured approach: a risk analysis of our main material flows, value chain mapping and human rights due diligence; integration of policies (Code of Conduct, reporting procedures, anti-discrimination); periodic audits and supplier assessments; toolbox meetings; mandatory training; SpeakUp channels; and targeted stakeholder dialogue.

The inclusion of reporting channels in the Code of Conduct and supplier terms and conditions has been refined, and we are keen to emphasise that suppliers and subcontractors must inform their employees of SpeakUp, confidential counsellors and the compliance officer. This allows us to increase awareness of employees' health, safety and working conditions at subcontractors, suppliers, ancillary parties and contract partners.

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

Negative impacts on employees of subcontractors, suppliers, ancillary parties and contract partners are identified and addressed in various ways. Audits and the use of the GO! app and the website geenongevallen.nl allow safety risks to be identified and mitigated at an early stage. We monitor the effectiveness of reporting procedures through periodic assessments, satisfaction measurements and analyses of recurring incidents. Processes are refined and stakeholders are involved in improvement actions where necessary.

To this end, the reporting and complaints channels are a crucial part of our approach. Alongside internal confidential counsellors, employees of suppliers and subcontractors can also report their concerns (anonymously) through SpeakUp, confidential counsellors or directly to the compliance officer. Furthermore, the supplier terms and conditions stipulate that contractors must actively inform their employees of the reporting options available. Confidential counsellors provide anonymised reports on a quarterly basis; these are analysed and discussed in the Integrity Committee and reported to the Executive Board, the Supervisory Board and the external auditor.

Our actions focus on employees of subcontractors, suppliers, ancillary parties and contract partners found in the upstream value chain. We use the various actions described above to address and then mitigate any negative impacts of our own practices. All actions have a rolling time horizon.

Remedial actions for negative impacts

Several incidents occurred in 2025 that affected employees' health and safety. Each incident is investigated carefully, with appropriate actions taken to remedy unsafe situations and prevent such accidents from reoccurring. Such actions may include discussions with the employees and suppliers involved or rendering an unsafe situation safe. The company's own operations are subject to both supervision and monitoring, and this is embedded in the value chain through the sustainable procurement policy.

By combining reporting channels, audits, due diligence and remedial actions, we facilitate safe reporting and transparent, efficient follow-up for employees in the value chain. We encourage an open reporting culture and provide whistleblowers with strong protection from retaliation to make sure everyone can report misconduct in a risk-free environment.

Targets

In 2025, Heijmans did not set any specific targets for employees in the value chain. Our priority this year was to deepen our insight into the value chain and complete the risk analysis. Until that point, we will monitor the situation using the knowledge and insights available to us. Once we have sufficient insights, we will draw up appropriate targets and include them in our reporting.

In our 2024 sustainability statement, we announced our intention to develop in 2025 an approach for the identification of geographical areas, raw materials and services in our value chain that pose a significant risk of child labour or forced labour. This specific approach has not yet been implemented in 2025. We intend to explore this topic further during 2026, including on the basis of existing risk assessment tools and insights from the Procurement department. Doing so will allow us to investigate how we can integrate geographical risks into our broader value chain analysis from a structural perspective, partly within the framework of the Corporate Sustainability Due Diligence Directive (CSDDD).

In 2025, Heijmans does not yet have a complete picture of the views of employees who may be particularly vulnerable or belong to marginalised groups. Deepening this understanding remains an important point of attention for the years ahead to ensure their perspectives are structurally embedded in the policies and processes.