E-Fiber Exploitatie B.V.
Environmental, Social and Governance (ESG) Policy
The Board of E-Fiber Exploitatie B.V. recognizes that environmental, social and governance (“ESG”) issues have a material effect on the performance of the company and its subsidiaries (the “Group” or “E-Fiber”). Our aim is to ensure that such issues are considered at all levels of the Group’s business activities, and in accordance with International and National Codes and Principles.
Specifically, the E-Fiber Board aims to achieve this by:
- Ensuring that our vision and ESG objectives are relevant, understood and communicated and that our employees demonstrate alignment to them.
- Identifying all material ESG risks in the business activities undertaken by E-Fiber and its subsidiaries and ensuring that the risks are fully considered and managed in a responsible and ethical way.
- Ensuring that key decisions are only taken after full consideration of all material ESG issues and risks.
- Setting targets for environmental, social and governance matters which will be reported, monitored, reviewed and disclosed to our employees and shareholders.
- Adopting high standards of governance and ethics in our business conduct.
- Providing appropriate information, instruction and training and ensuring that this policy is communicated to all persons working for E-Fiber and its subsidiaries.
- Working together with our customers, suppliers and business partners to encourage them to adopt the principles or similar policies resulting in the same outcomes.
- Aspiring to achieve benchmark levels in environmental, social and governance performance and making these themes core to what we do
ESG Specific Commitments
- Committing to the protection of the environment through continuously reducing the environmental footprint of our business and developing a sustainable supply chain.
- Encouraging all staff to consider the environmental consequences of their actions and to seek to minimize the impact where reasonably practicable.
- Continuously monitoring how the evolution of the Group’s business practices could impact the environment and how the environmental impact of new business practices can be mitigated.
Consideration and monitoring of key environmental metrics material to the Group, including energy consumption, % of energy sourced from renewable sources, greenhouse gas emissions, physical risks, water consumption and waste production.
- Seeking where possible to use contractors who hold certifications for ISO9001 (Quality Management System) and ISO14001 (Environmental Management System).
- Designing and developing where possible E-Fiber’s networks to be more resilient to climate change risks, in particular in the context of the Netherlands increased risk of flooding or other extreme weather events.
- Contributing to the United Nations Sustainable Development Goals:
o SDG 9 “Industry, Innovation and Infrastructure” through roll-out of fiber networks in areas of very low connection speeds to increase speeds and bandwidths available to consumers, to provide more resilient, energy efficient connectivity.
o SDG 12 “Responsible Production and Consumption” as the Group’s roll-out focuses on less densely populated areas to help bridge the gap in connectivity discrepancies between rural and dense urban municipalities in the Netherlands.
o SDG 13 “Climate Action” by minimizing the climate impact of data transmission through less energy consumption and reduction in greenhouse gas emissions by transitioning from copper and cable networks to fiber optic.
- Recognizing that open access fiber optic networks contribute positively to reducing the overall digital divide and thus increase social cohesion over a territory.
- Encouraging a culture of diversity with the highest ethical standards, respect human rights, promote gender equality and act against incidents and grievances in a systematic manner.
- Supporting a culture in which all employees are valued and respected.
- Promoting the Group’s commitment to the wider society and community development. Seek to engage proactively with key stakeholders (particularly the communities where E-Fiber operates. Ensure to the extent possible (for example through the choice of contractors) that supply chain which supplies E-Fiber adheres to values consistent with E-Fiber’s own.
- Adhering to the Group’s policy on Health and Safety to ensure adequate control of health and safety risks in order to prevent any incidents occurring in the workplace or through any of the Group’s operations for our employees and supply chain.
- Reporting on H&S incidents regularly through monthly board reporting.
- Ensuring compliance with regulations and guiding principles governing the protection of human rights, operational and occupational health and safety, environmental and business practices in the jurisdictions in which we operate.
- Identifying the relevant legislative and regulatory requirements and ensuring that fibre optic networks are compliant with these requirements, and where practicable meeting them in an environmentally responsible manner.
Other ESG Matters
Reporting, Disclosure and Communications
Environmental, Social and Governance risks and opportunities are addressed monthly at board meetings. E-Fiber monitors and reports key ESG metrics on a monthly, quarterly or annual basis as appropriate. These metrics include energy consumption, the % of energy sourced from renewable sources, injuries and fatalities, water and waste consumption, greenhouse gas emissions grievances from stakeholders, fraud attempts, and any other board-level or operational issues. Serious
incidents, injuries and fatalities are reported to board members as soon as they occur and become known.
The E-Fiber board devise an annual stakeholder engagement strategy for the year ahead which identifies key opportunities and methods of communication with stakeholders.
ESG Reporting Matrix
The below matrix provides guidance on the approach to classification of ESG incidents. Serious incidents, injuries and fatalities (i.e. level 3 or above) are reported to board members as soon as they occur and become known.
Personal Injury Reporting
At each Board meeting, a designated person shall present a report on any incidence and severity of employee or sub-contractor injury occurring on company property or at the fault of the company. The report should include statistics on the number of injury incidents, the severity of those incidents (as per the guidelines above) and the number of lost work days as a result of the incidents. Statistics shall be presented for the year to date of the current year and compared with the equivalent period in the prior reporting year.
The personal injury statistics should be presented to the Board in a standardised format across the E-Fiber Group companies in line with the below example.
In addition, at each Board meeting, the company shall present its “Accident Frequency Rate” for the current financial year. The Accident Frequency Rate shall be calculated by dividing the number of injury incidents with lost time by the total estimated number of worked hours and multiplying the resultant figure by 1,000,000.
Operational, Compliance, Reputational Incident Reporting
At each Board meeting, a designated person shall present a report on any incidence and if so the severity of operational, compliance and reputational incidents at the company and the financial impact of such incidents. Statistics shall be presented for the current financial period and compared with the equivalent period in the prior reporting year.
The operational, compliance and reputational incident report should be presented in a standardised format across the Group companies in line with the below example.
At each Board meeting, a designated person shall present a report containing statistics on a number of measures to indicate the company’s impact on, or positive contribution to, its local environment.
To the extent that these statistics are not readily available, the company shall attempt to implement the necessary processes and procedures for this information to be obtained as soon as reasonably practicable.
The environmental report should be presented in a standardised format in line with the below example.
Annual ESG training should be completed by those within the organisation who are responsible and have oversight of ESG matters as part of their role.
Scope and Application
Direction and oversight of the Environmental, Social and Governance Policy is the responsibility of the Board, which has delegated day-to-day management responsibility to the Chief Executive Officer of E-Fiber.
This Policy applies to all the companies that sit within the E-Fiber group (E-Fiber Exploitatie B.V. and its subsidiaries).
This Policy will be reviewed annually.