ESRS Content index

ESRS 2: General disclosures (July 2023)

BP-1

General basis for preparation of the sustainability statements

Annex 2, Introduction (p. 90)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

Our strategy contains both financial and non-financial provisions. We don't disclose some of our financial strategic targets for reasons of confidentiality

BP-2

Disclosures in relation to specific circumstances

Annex 2, Introduction (p. 90)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 2.1 Results (p. 111)
Annex 3, ESRS Content index (p. 156-166)
Annex 3, Basis of reporting (p. 152-155)

There are no other specific circumstances than referenced
ESRS-2 13, 14, 15 and 17 are not applicable

GOV-1

The role of the administrative, management and supervisory bodies

Roles and responsibilities (p. 19-20)
Our leadership in 2025/2026 (p. 13)
Report of the Supervisory Board (p. 21-26)
Annex 2, 3.2, Results (p. 122)

Representatives from employees and other workers are not represented in the Board

Profile Supervisory Board Deloitte Netherlands

https://www2.deloitte.com/content/dam/Deloitte/nl/Documents/about-deloitte/deloitte-nl-profile-supervisory-board.pdf

GOV-2

Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies

Report of the Supervisory Board (p. 21-26)
Annex 2, Introduction (p. 90)

GOV-3

Integration of sustainability-related performance in incentive schemes

Deloitte has not yet systematically included sustainability-related performance in incentive schemes

GOV-4

Statement on sustainability due diligence

Annex 2, 1.1 Sustainability due diligence (p. 92-93)
Annex 2, 1.3 Reporting boundaries (p. 93)
Annex 2, 1.5 Materiality (p. 93-98)

GOV-5

Risk management and internal controls over sustainability reporting

Risk management (p. 27-30)
Annex 2, 1.4 Reliability and completeness (p. 93)
Annex 2, 1.6 Reporting process (p. 99)
Annex 3, Basis of reporting (p. 152-155)

SBM-1

Market position, strategy, business model(s) and value chain

Our purpose and strategy (p. 6-9)
About Deloitte (p. 12-15)
Value creation (p. 16-18)

ESRS-2 40c-d: Deloitte operates across all sectors, but always in audit or advisory roles. Clients can operate in sectors mentioned in these requirements

SBM-2

Interests and views of stakeholders

Our purpose and strategy (p. 6-9)
Annex 2, 1.5 Materiality (p. 93-98)

ESRS-2 45c not applicable as we have not changed our strategy

SBM-3

Material impacts, risks and opportunities and their interaction with strategy and business model(s)

Our Purpose and Strategy (p. 6-9)
Value creation (p. 16-18)
Financial statements (p. 31-87)
Annex 2, 1.5 Materiality (p. 93-98)
Throughout Annex 2 (p. 88-148)

Impacts, risks and opportunities are disclosed at the beginning of every paragraph dealing with a material sustainability matter Initiatives taken to reduce current negative impacts. Risks and opportunities are described in the sections where we disclose information on our material sustainability impacts thoughout the report;
Where applicable, the source of the impacts, risks and opportunities is disclosed;
Current financial effects for material risks and opportunities are deemed not material. Liabilities, including those regarding material sustainability matters, are disclosed in Notes 8.2 to the Financial Statement;
We do not believe investments or disposals will be necessary as a result of managing material sustainability matters;
Our strategy is sourced through our normal planning cycle: costs are absorbed in the current year P&L.

IRO-1

Description of the processes to identify and assess material impacts, risks and opportunities

Annex 2, 1.5 Materiality (p. 93-98)
Risk management (p. 27-30)
Annex 2, 2.1 Climate and CO2 (p. 101-105)

IRO-2

Disclosure Requirements in ESRS covered by the undertaking’s sustainability statements

Annex 3, ESRS Content index (p. 156-166)
Annex 2, 1 General information (p. 91)
Annex 2, 2 Environmental information (p. 101-114)
Annex 2, 3 Social information (p. 115-140)
Annex 2, 4 Governance information (p. 141-148)

ESRS-2 58: Brief explanation concerning non-materiality for E2, E3, E4 and E5 is provided
ESRS-2 59: Our reporting meets the requirements of ESRS 1 section 3.2
ESRS-2 60-81: All material topics are disclosed taking the MDR into account. Possible deviations are disclosed in the ESRS Content Index

MDR-P

Policies adopted to manage material sustainability matters

All material topics are disclosed taking the MDR into account. Possible deviations are disclosed in the ESRS Content Index

MDR-A

Actions and resources in relation to material sustainability matters

All material topics are disclosed taking the MDR into account. Possible deviations are disclosed in the ESRS Content Index

MDR-M

Metrics in relation to material sustainability matters

All material topics are disclosed taking the MDR into account. Possible deviations are disclosed in the ESRS Content Index

MDR-T

Tracking effectiveness of policies and actions through targets

All material topics are disclosed taking the MDR into account. Possible deviations are disclosed in the ESRS Content Index

ESRS E1: Climate change (July 2023)

MDR-P

Policies adopted to manage material sustainability matters

Annex 2, 2.1 Climate and CO2 (p. 102, 109-111)
Annex 2, 1.3 Reporting boundaries (p. 93)
Annex 2, 1.1 Sustainability due diligence (p. 92-93)

MDR-A

Actions and resources in relation to material sustainability matters

Annex 2, 2.1 Climate and CO2 (p. 109-111)
Annex 2, 1.3 Reporting boundaries (p. 93)

ESRS 2-69: There are no plans that require significant operational or capital expenditures. All costs of climate programmes are absorbed in our normal planning cycle

MDR-M

Metrics in relation to material sustainability matters

Annex 2, 2.1 Climate and CO2 (p. 112-114)
Annex 3, Basis of reporting (p. 152-155)

Both ESRS defined and entity specific metrics have been included in the report
Metrics are consolidated on level of DTTL which then submits them to CDP for validation

MDR-T

Tracking effectiveness of policies and actions through targets

Annex 2, 2.1 Climate and CO2 (p. 106, 112-114)
Annex 2, 1.3 Reporting boundaries (p. 93)

WorldClimate is a top-down programme where we consult with stakeholder how we approach the actions prescribed
ESRS-2 81 Not applicable as Deloitte has set outcome-oriented targets

ESRS-2

Disclosure requirement related to ESRS 2 GOV-3 Integration of sustainability-related performance in incentive schemes

Annex 2, 2.1 Climate and CO2 (p. 91)

The realisation of climate targets is not part of our Executive Board's remuneration

E1-1

Transition plan for climate change mitigation

Annex 2, 2.1 Climate and CO2 (p. 107-108)

ESRS-E1 16c: As Deloitte is asset-light, we don't foresee funding that requires capital investments
ESRS-E1 a6d: There are no potentially locked-in GHG emissions from key assets and products. Deloitte does not own energy-intensive key assets and our products consist of audits and advisory services and are therefore also not energy-intensive
ESRS-E1 16e: Not applicable as our economic activities are not covered by delegated regulation on climate adaptation or mitigation under the Taxonomy Regulation
ESRS-E1 16g: Deloitte is not excluded on the basis of Article 12

ESRS-2

Disclosure Requirement related to ESRS 2 SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model

Annex 2, 2.1 Climate and CO2 (p. 101-105)

ESRS-2

Disclosure requirement related to ESRS 2 IRO-1 – Description of the processes to identify and assess material climate-related impacts, risks and opportunities

Annex 2, 1.5 Materiality (p. 93-98)
Annex 2, 2.1 Climate and CO2 (p. 101-105)

E1-2

Policies related to climate change mitigation and adaptation

Annex 2, 2.1 Climate and CO2 (p. 108-109)

E1-3

Actions and resources in relation to climate change policies

Annex 2, 2.1 Climate and CO2 (p. 108-110)

We do not foresee there to be significant CapEx or OpEx consequences to our Climate strategy on the short to medium term

E1-4

Targets related to climate change mitigation and adaptation

Annex 2, 2.1 Climate and CO2 (p. 106)

E1-5

Energy consumption and mix

Not material

E1-6

Gross Scopes 1, 2, 3 and Total GHG emissions

Annex 2, 2.1 Climate and CO2 (p. 111-112)

E1-7

GHG removals and GHG mitigation projects financed through carbon credits

Annex 2, 2.1 Climate and CO2 (p. 113)

Programme is operated by Deloitte NSE on behalf of its geographies and reported on in their Impact report. It is therefore not in scope for Deloitte NL reporting
ESRS-E1 61: No claims on carbon neutrality have been made

E1-8

Internal carbon pricing

Not applicable as Deloitte does not (yet) use internal carbon pricing

E1-9

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Annex 2, Introduction (p. 90)
Annex 2, 2.1 Climate and CO2 (p. 103-105)

ESRS-E1 66c: There are no assets at material physical risk
ESRS-E1 66d: Monetary amount for short-, medium- and long-term is negligible
ESRS-E1 67b: As we do not regard transition risks to our own assets or those owned by others to be material, we cannot provide a figure other than < 5%.
ESRS-E1 67c: We don't own real estate assets
ESRS-E1 67d: There are no such liabilities
ESRS-E1 68-70: Not applicable to Deloitte

Relevant Application requirements

AR 4

Taxonomy-aligned revenue is not yet mandatory for Deloitte to report on

AR 5

Not applicable as Deloitte is not included in the EU Paris-aligned Benchmarks

AR 6-8

Annex 2, 2.1 Climate and CO2 (p. 101-105)

AR 9

Annex 2, 1.5 Materiality (p. 93-98)
Annex 2, 1.3 Reporting Boundaries (p. 93)
Annex 2, 2.1 Climate and CO2 (p. 101-105)

AR 11-18

Annex 2, 2.1 Climate and CO2 (p. 101-105, 108-110)

ESRS-E1 AR18: Climate change physical and transition risks are negligible

AR 19-22

Annex 2, 2.1 Climate and CO2 (p. 108-110)

ESRS-E1 AR 19b: Although we address many of these types of mitigation actions, we have not aggregated them
ESRS-E1 AR 19d: We have not disclosed the climate change adaptation actions by type of adaptation solution
We do not foresee there to be significant CapEx or OpEx consequences of our Climate strategy on the short to medium term

AR 24-30

Annex 2, 2.1 Climate and CO2 (p. 107-110, 112-113)
Annex 3, Basis of reporting (p. 152-155)

Baseline year is consistent with prior years' reporting
ESRS-E1 AR 26: No sector specific or cross sector pathway available
ESRS-E1 AR 29 Not applicable as we have not adjusted our base year

AR 32-35

Not material

AR 39-44

Annex 3, Basis of reporting (p. 152-155)

ESRS-E1 AR 39a: Our definitions are based on GHG Protocol to facilitate CDP submission of DTTL
ESRS-E1 AR 40: Not applicable to Deloitte as we do not have such associates, joint ventures, unconsolidated subsidiaries (investment entities) and contractual arrangements
ESRS-E1 AR 41: Disaggregation of emission related information does not add insights and is - in practice - not feasible without assumptions that would not improve the quality of the information presented. Our policies, targets, activities and results are uniformly applicable within Deloitte Netherlands
ESRS-E1 AR 42: For our own operations we report on our results in our own financial year (June 1 - May 31). For suppliers that participate in CDP, we use the data from their financial years
ESRS-E1 AR 43a: Our Scope 1 emissions include fuel used for heating our offices and power the ICE cars in our fleet
ESRS-E1 AR 43c: Deloitte does not have such emissions
ESRS-E1 AR 43d: We do not include any removals, or any purchased, sold or transferred carbon credits or GHG allowances in the calculation of Scope 1 GHG emissions
ESRS-E1 AR 44: Not applicable to Deloitte

AR 45

Annex 2, 2.1 Climate and CO2 (p. 112, 114)

Our Scope 2 emissions include bought electricity (for offices and fleet) and heat. Steam and cooling are not applicable to Deloitte
We only include scope 2 emissions that are the result of our own procurement
Deloitte does not have biogenic emissions
We do not include any removals, or any purchased, sold or transferred carbon credits or GHG allowances in the calculation of Scope 2 GHG emissions

AR 46

Annex 2, 2.1 Climate and CO2 (p. 111-112)
Annex 3, Basis of reporting (p. 152-155)

ESRS-E1 AR 46c: Screening is done on the level of DTTL and NSE
Scope 3 emissions are updated on an annual basis
We do not include any removals, or any purchased, sold or transferred carbon credits or GHG allowances in the calculation of Scope 3 GHG emissions

AR 47-52

Annex 2, 2.1 Climate and CO2 (p. 112-113)

ESRS-E1 AR 49: Not aplicable to Deloitte
ESRS-E1 AR 51: Not material at present

AR 53-55

Annex 2, 2.1 Climate and CO2 (p. 113)

AR 56-60

Not applicable as we do not engage in these activities

AR 61-64

We don't report on carbon credits as this activity is NSE-led

AR 65-66

Not applicable as Deloitte does not (yet) have an internal carbon price mechanism

AR 67-71

Annex 2, 2.1 Climate and CO2 (p. 103-105)

AR 70: No assets at material physical risks hence not disclosed
AR 71: As there are no assets at material risk due to climate change and there are no associated liabilities, this requirement is not applicable
AR 71b: We have not assessed these effects yet

AR 72

We do not believe our revenue to be at risk due to physical climate risks in the short or medium term as our business is volatile and climate opportunities exceed climate risks. For the longer term, together with our NSE partners, we will further investigate what our clients’ exposure is to physical climate risks and we will assess what the potential impact is on their business continuity.

AR 73

ESRS-E1 AR 73a: Not applicable as there are no assets at material transition risk
ESRS-E1 AR 73b: This information is included on page 9 of our CO2 Performance Ladder report FY24 that is published online (https://www2.deloitte.com/nl/nl/pages/over-deloitte/articles/sustainability-impact-deloitte-netherlands.html)
ESRS-E1 AR 73c: Not applicable as there are no assets at material transition risk

AR 74

Deloitte does not operate installations regulated under an emission trading scheme

AR 76

We do not believe our revenue to be at risk due to physical climate risks in the short or medium term as our business is volatile and climate opportunities exceed climate risks. For the longer term, together with our NSE partners, we will further investigate what our clients’ exposure is to physical climate risks and we will assess what the potential impact is on their business continuity.

AR 77-78

Not applicable to Deloitte as these risks are negligible and Deloitte's asset base is relatively small

AR 79

Not applicable to Deloitte as we are not part of emission trading schemes

Ar 80-81

Not applicable to Deloitte

Entity specific metrics

Reducing of business travel emissions per FTE from 2019 levels

Annex 2, 2.1 Climate and CO2 (p. 101)

Sourcing renewable energy for our buildings

Annex 2, 2.1 Climate and CO2 (p. 114)

Conversion of fleet to electric vehicles

Annex 2, 2.1 Climate and CO2 (p. 101)

ESRS S1: Own workforce (July 2023)

ESRS-2

Disclosure Requirement related to ESRS 2 SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model

Value creation (p. 16-18)
Our Purpose and Strategy (p. 6-9) Annex 2, 3 Social information (p. 115-116)
Annex 2, 3.1 Employee value position (p. 117)
Annex 2, 3.2 Diversity, equity and inclusion (p. 120)
Annex 2, 3.3 Learning adn development (p. 123)
Annex 2, 3.4 Wellbeing (p. 128)
Annex 2, 1.1 Sustainability due diligence (p. 92-93)

Annex 2, Impacts, risks and opportunities in sub-sections 3.1, 3.2, 3.3 and 3.4 describes positive and negative impacts
ESRS-S1 14e: Not applicable due to the nature of our business
ESRS-S1 14f and 14g: We have no operations at risk and no operations in countries or geographic areas considered at risk
ESRS-S1 16: Not applicable to Deloitte

S1-1

Policies related to own workforce

Annex 2, 3 Social information (p. 116-119, 120-121, 123-125, 127)
Annex 2, 1.1 Sustainability due diligence (p. 92-93)

All policies pertaining to material impacts on our own workforce, as well as associated risks and opportunities are described in paragraphs 3.1, 3.2, 3.3 and 3.4

S1-2

Processes for engaging with own workforce and workers’ representatives about impacts

Annex 2, 3 Social information (p. 116)
Annex 2, 1.2 Materiality (p. 95)
Annex 2, 3.2 Diversity, equity and inclusion (p. 120-121)

ESRS-S1 27d and 27e: Not applicable to Deloitte
ESRS-S1 29: Not applicable

S1-3

Processes to remediate negative impacts and channels for own workforce to raise concerns

Annex 2, Social information (p. 116)
Annex 2 4.2 Ethics and integrity (p. 143-146)

ESRS-S1 34: Not applicable

S1-4

Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions

Annex 2, 3 Social Information (p. 119, 121-123, 126-129)

MDRs are incorpporated in the disclosures of our material sustainability matters
ESRS-S1 34: Practices are diclosed in sections on Data security and sustainable procurement. We don't see how these activties could negatively impact our own workforce

S1-5

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Annex 2, 3 Social Information (p. 119, 122, 126-127, 129)

MDRs are incorpporated in the disclosures of our material sustainability matters

S1-6

Characteristics of the undertaking’s employees

Annex 2, Social information: Introduction (p. 115-116)
Annex 3, Basis of reporting (p. 152-155)
Annex 1, Workforce (p. 50)

ESRS-S1 50e: Where applicable, contextual infromation is provided
ESRS-S1 51 and 52: NL is one single region. DDC does not meet materiality criteria from ESRS (>50 employees representing more than 10% of workforce)

S1-7

Characteristics of non-employees in the undertaking’s own workforce

Annex 2, Social information: Introduction (p. 115-116)

ESRS-S1 57: Data is available and reported

S1-8

Collective bargaining coverage and social dialogue

Annex 2, Social information: Introduction (p. 116)

ESRS-S1 60-62: Not applicable as there are no collective bargaining agreements within Deloitte
ESRS-S1 63b: The Netherlands is the only geography within the EEA in which Deloitte NL employs people

S1-9

Diversity metrics

Annex 2, 3.2 Diversity, equity and inclusion (p. 120-122)

S1-13

Training and skills development metrics

Annex 2, 3.1 Employee value proposition (p. 117)
Annex 2, 3.3 Learning and development (p. 126-127)

Each employee has one formal performance review per year, hence we report the % of employees that have had a performance review

S1-15

Work-life balance metrics

Annex 2, 2.4 Wellbeing (p. 129)

S1-16

Remuneration metrics (pay gap and total remuneration)

Annex 2, 3.2 Diversity, equity and inclusion (p. 121-122)

Relevant Application requirements

AR 10

There were no significant changes in policies in the reporting year with the exception the adoption of the Human Rights Policy that is included in section 1.1 and that has not (yet) led to significant changes in our approach to our own workforce.

AR 12

Annex 2, 1.1 Sustainability due diligence (p. 92-93)

This is the case for the Deloitte and the Deloitte NL Human Rights Policy Statements and is disclosed in section 1.1

AR13

Annex 2, 1.1 Sustainability due diligence (p. 92-93)

AR 57

Annex 3, Basis of reporting (p. 152-155)

We report average employees in the reporting year

AR 59

Annex 3, Basis of reporting (p. 152-155)

Employee Value Proposition

MDR-P

Policies adopted to manage material sustainability matters

Annex 2, 3.1 Employee value proposition (p. 117-119)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

ESRS-2 65d: Third party standards are not referenced

MDR-A

Actions and resources in relation to material sustainability matters

Annex 2, 3.1 Employee value proposition (p. 117-119)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

ESRS-2 68d: Implementation and upholding of our EVP is a continuous process hence no time horizons are set
ESRS-2 69: Costs of EVP are part of our normal planning cycle and are paid out of revenues

MDR-M

Metrics in relation to material sustainability matters

Annex 2, 3.1 Employee value proposition (p. 117-119)
Annex 3, Basis of reporting (p. 152-155)

MDR-T

Tracking effectiveness of policies and actions through targets

Annex 2, 3.1 Employee value proposition (p. 117-119)

Diversity, equity and inclusion

MDR-P

Policies adopted to manage material sustainability matters

Annex 2, 3.2 Diversity, equity and inclusion (p. 120-122)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

MDR-A

Actions and resources in relation to material sustainability matters

Annex 2, 3.2 Diversity, equity and inclusion (p. 120-122)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

ESRS-2 69: DE&I activities are part of normal operational planning meaning that costs are planned for and allocated in the current financial year

MDR-M

Metrics in relation to material sustainability matters

Annex 2, 3.2 Diversity, equity and inclusion (p. 120-122)
Annex 3, Basis of reporting (p. 152-155)

MDR-T

Tracking effectiveness of policies and actions through targets

Annex 2, 3.2 Diversity, equity and inclusion (p. 120-122)

Entity specific metrics

Female partners as % of total partners

Annex 2, 3.2 Diversity, equity and inclusion (p. 120)

Women in leadership positions

Annex 2, 3.2 Diversity, equity and inclusion (p. 120)

Learning and development

MDR-P

Policies adopted to manage material sustainability matters

Annex 2, 3.3 Learning and development (p. 124-125)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

MDR-A

Actions and resources in relation to material sustainability matters

Annex 2, 3.3 Learning and development (p. 126)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

ESRS-2 69: Learning and development activities are part of normal operational planning meaning that costs are planned for and allocated on the current financial year

MDR-M

Metrics in relation to material sustainability matters

Annex 2, 3.3 Learning and development (p. 127)
Annex 3, Basis of reporting (p. 152-155)

MDR-T

Tracking effectiveness of policies and actions through targets

Annex 2, 3.3 Learning and development (p. 127)

Wellbeing

MDR-P

Policies adopted to manage material sustainability matters

Annex 2, 3.4 Wellbeing (p. 128-129)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

MDR-A

Actions and resources in relation to material sustainability matters

Annex 2, 3.4 Wellbeing (p. 128-129)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

ESRS-2 69: Wellbeing activities are part of normal operational planning meaning that costs are planned for and allocated on the current financial year

MDR-M

Metrics in relation to material sustainability matters

Annex 2, 3.4 Wellbeing (p. 128-129)
Annex 3, Basis of reporting (p. 152-155)

MDR-T

Tracking effectiveness of policies and actions through targets

Annex 2, 3.4 Wellbeing (p. 129)

ESRS-2 80: The metrics used are not suited to setting quantitative targets that are relevant for the activities in scope

Entity specific metric

Sickness leave

Annex 2, 3.4 Wellbeing (p. 129)

Social impact and social return

MDR-P

Policies adopted to manage material sustainability matters

Annex 2, 3.5 Social impact / Social return (p. 130-132, 136)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

MDR-A

Actions and resources in relation to material sustainability matters

Annex 2, 3.5 Social impact / social return (p. 132-135, 136)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

ESRS-2 68: The policies of Deloitte Impact Foundation do not require specific actions other than what is mentioned in the Governance and Policies sections
ESRS-2 69: Social impact / social return activities are part of normal operational planning meaning that costs are planned for and allocated on the current financial year

MDR-M

Metrics in relation to material sustainability matters

Annex 2, 3.5 Social impact / social return (p. 135-136)
Annex 3, Basis of reporting (p. 155)

MDR-T

Tracking effectiveness of policies and actions through targets

Annex 2, 3.5 Social impact / social return (p. 135-136)

Entity specific metrics

Hours spent on DIF Projects

Annex 2, 3.5 Social impact / social return (p. 135)

# DIF projects

Annex 2, 3.5 Social impact / social return (p. 135)

# employees involved in DIF projects

Annex 2, 3.5 Social impact / social return (p. 135)

ESRS S2: Workers in the value chain (July 2023)

Workers in the value chain

MDR-P

Policies adopted to manage material sustainability matters

Annex 2, 3.6 Global delivery centres (p. 138)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

MDR-A

Actions and resources in relation to material sustainability matters

Annex 2, 3.6 Global delivery centres (p. 138-139)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

ESRS-2 69: Workers in the value chain activities are part of normal operational plan meaning that costs are planned for and allocated on the current financial year

MDR-M

Metrics in relation to material sustainability matters

Annex 2, 3.6 Global delivery centres (p. 139)

MDR-T

Tracking effectiveness of policies and actions through targets

Annex 2, 3.6 Global delivery centres (p. 139)

ESRS 2 SBM-2

Interests and views of stakeholders

Annex 2, 3.6 Global delivery centres (p. 138-139)
Annex 2, 1.5 Materiality (p. 93-98)

ESRS 2 SBM-3

Material impacts, risks and opportunities and their interaction with strategy and business model

Our Purpose and Strategy (p. 6-9)
Value creation (p. 16-18)
Annex 2, 3.6 Global delivery centres (p. 138-139)

S2-1

Policies related to value chain workers

Annex 2, 3.6 Global delivery centres (p. 138-139)
Annex 2, 1.1 Sustainability due diligence (p. 92-93)

S2-2

Processes for engaging with value chain workers about impacts

This is outside our definition of material impacts

S2-3

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Annex 2, 3.6 Global delivery centres (p. 138-139)

S2-4

Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions

Annex 2, 3.6 Global delivery centres (p. 138-139)
Annex 2, 1.1 Sustainability due diligence (p. 92-93)

Activities are part of normal operational plan and staffing meaning that resources are planned for and allocated on the current financial year. No specific resources are allocated to the management of two positive material impacts

S2-5

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

No quantitative targets and KPIs are set at this moment

AR 27

As no reports were filed by value chain workers to date, we cannot (yet) assess the effectiveness of the channels for value chain workers to raise concerns

Responsible AI

MDR-P

Policies adopted to manage material sustainability matters

Annex 2, 3.7 Responsbile AI (p. 139-140)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

MDR-A

Actions and resources in relation to material sustainability matters

Annex 2, 3.7 Responsbile AI (p. 139-140)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

ESRS G1: Business conduct (July 2023)

ESRS-2 GOV-1

Disclosure Requirement related to ESRS 2 GOV-1 – The role of the administrative, management and supervisory bodies

Annex 2, 4. Governance information (p. 141)

ESRS-2 5b: Not specifically disclosed. See general sections in Roles and reponsibilities section and in Report of the Supervisory Board

ESRS-2

Disclosure Requirement related to ESRS 2 IRO-1 – Description of the processes to identify and assess material impacts, risks and opportunities

Anex 2, 4. Governance information (p. 141, 143, 147)

Per section in Chapter 4. Governance information, the relevant IROs have been disclosed

G1-1

Business conduct policies and corporate culture

Annex 2, 4.2 Ethics and integrity (p. 142, 143-144, 147-148)

ESRS-G1 10h: We believe all partners and employees are at a certain degree of risk and therefore have a training programme that is cross-functional

G1-3

Procedures to address corruption and bribery

Annex 2, 4.2 Ethics and integrity (p. 143-146)

ESRS-G1 18c: We regard any incident involving corruption as an ethical incident. All ethical incidents are reported to the Executive Board

G1-4

Incidents of corruption or bribery

Annex 2, 4.2 Ethics and integrity (p. 146)

Quality

MDR-P

Policies adopted to manage material sustainability matters

Annex 2, 4.1 Quality of services (p. 142)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

MDR-A

Actions and resources in relation to material sustainability matters

Annex 2, 4.1 Quality of services (p. 142)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

ESRS-2 68c: Actions take place on an ongoing basis
ESRS-2 69: Quality related activities are part of normal operational planning meaning that costs are planned for and allocated on the current financial year

MDR-M

Metrics in relation to material sustainability matters

Annex 2, 4.1 Quality of services (p. 142-143)
Basis of reporting (p. 155)

MDR-T

Tracking effectiveness of policies and actions through targets

Annex 2, 4.1 Quality of services (p. 142)

ESRS-2 No new targets have been set yet

Entity specific metrics

Satisfactory regulatory reviews

Annex 2, 4.1 Quality of services (p. 142)

Client satisfaction score

Annex 2, 4.1 Quality of services (p. 142)

Likelihood to recommend score

Annex 2, 4.1 Quality of services (p. 142)

Ethics and integrity

MDR-P

Policies adopted to manage material sustainability matters

Annex 2, 4.2 Ethics and integrity (p. 143-144)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

MDR-A

Actions and resources in relation to material sustainability matters

Annex 2, 4.2 Ethics and integrity (p. 145)
Annex 2, 1.3 Reporting Boundaries (p. 93)

ESRS-2 68c: Actions take place on an ongoing basis (e.g. annual ethics survey, two-yearly refreshers, etc)
ESRS-2 68d: We do not report individual outcomes of cases due to privacy constraints
ESRS-2 69: Ethics and integrity related activities are part of normal operational planning meaning that costs are planned for and allocated on the current financial year

MDR-M

Metrics in relation to material sustainability matters

Annex 2, 4.2 Ethics and integrity (p. 145-146)
Basis of reporting (p. 155)

MDR-T

Tracking effectiveness of policies and actions through targets

Annex 2, 4.2 Ethics and integrity (p. 145-146)

ESRS-2 80: We feel that ethics metrics are not suited for outcome oriented target setting

Entity specific metrics

Incidents: number of reported occurance

Annex 2, 4.2 Ethics and integrity (p. 146)

Data security and privacy

MDR-P

Policies adopted to manage material sustainability matters

Annex 2, 4.3 Data security and privacy (p. 147-148)
Annex 2, 1.3 Reporting Boundaries (p. 93)

MDR-A

Actions and resources in relation to material sustainability matters

Annex 2, 4.3 Data security and privacy (p. 148)
Annex 2, 1.2 Scope (p. 93)
Annex 2, 1.3 Reporting Boundaries (p. 93)

ESRS-2 68c: Actions take place on an ongoing basis
ESRS-2 69: Data security activities are part of normal operational planning meaning that costs are planned for and allocated on the current financial year

MDR-M

Metrics in relation to material sustainability matters

Annex 2, 4.3 Data security and privacy (p. 148)
Basis of reporting (p. 155)

MDR-T

Tracking effectiveness of policies and actions through targets

Annex 2, 4.3 Data security and privacy (p. 148)

ESRS-2 80: No outcome oriented or time-bound targets have been set for data security and privacy
ESRS-2 81a: We believe no realistic outcome oriented target can be set for data security and privacy
ESRS-2 81bii: We use the number of breaches detected and reported as guiding KPIs

Entity specific metrics

Total internally reported incidents

Annex 2, 4.3 Data security and privacy (p. 148)

Total internally reported incidents involving personal data

Annex 2, 4.3 Data security and privacy (p. 148)

# Complaints regarding breaches of client privacy or loss of customer data

Annex 2, 4.3 Data security and privacy (p. 148)

# Instance that personal data breaches were reported to the supervisory authority

Annex 2, 4.3 Data security and privacy (p. 148)