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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.

Environmental Reporting 

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.