Workers in the value chain (S2)

SBM-2 - Interests and views of stakeholders

Vesteda recognises the critical role that value chain workers play as key stakeholders in its operations. We define workers in the value chain as those who are not directly employed by the company but are part of the broader supply chain. These workers might be employed by suppliers, contractors, or other third parties that provide goods or services to the company and are thus in the upstream of our value chain. Examples relating to this section include workers providing maintenance services to Vesteda, or contractors for new construction projects and large-scale renovations.

We take into account that our business model may play a role in creating material impacts related to working conditions of value chain workers. Vesteda takes into account the views and interests of stakeholders through various means. This included conducting a salience assessment, which addresses the potential impacts on a stakeholder’s human rights. The Management Board is informed about the outcomes of this assessment, which is then translated into the company's strategy and business model.

SBM-3 - Material impacts, risks and opportunities and their interaction with strategy and business model

The impacts, risks and opportunities that Vesteda's operations have on or create for workers in the value chain are documented in the DMA, which you can find in the section Materiality analysis and results according to the concept of double materiality. Vesteda has in place a SpeakUp mechanism, which enables the employees of (sub)contractors to safely and transparently file complaints about incidents, events, or grievances at (or about) the workplace.

Vesteda impacts the rights of value chain workers through its activities as a business partner and as an investor. Firstly, Vesteda acts as a business partner when engaging in procurement and outsourcing activities, impacting suppliers and employees of (sub)contractors. Secondly, Vesteda has an investor role as our investment decisions can have significant impacts on the built environment, impacting employees of (sub)contractors. The salient topics identified for Vesteda for both these roles are the following: non-discrimination, health and safety, freedom of expression, prohibition of child labour and forced labour and adequate wages.

We identified migrant workers in the construction sector as especially vulnerable to negative impacts, including discrimination, exploitation and forced labour due to their precarious legal and economic status. Impacts with regards to health and safety and freedom of expression are relevant for all construction workers, regardless of their background. Additionally, within the supply chain, we identified certain materials used in Vesteda's portfolio, such as solar panels and electric vehicles, as at a heightened risk of being produced under conditions involving child and forced labour.

Vesteda has a zero-tolerance policy for any form of child or forced labour, as outlined in our Human Rights Policy and Supplier Code of Conduct. The risks are widespread and systemic due to the complexity of global supply chains, making it crucial for Vesteda to continuously monitor and improve transparency to mitigate these risks effectively. In the following sections, we describe in more detail our policies, processes, actions and targets aimed at helping to mitigate potential negative impacts on workers in the value chain.

S2-1 - Policies

Vesteda has several policies aimed at mitigating the risks of negative impacts in its supply chain, namely the Human Rights Policy, the Supplier Code of Conduct and the SpeakUp mechanism. The most senior level of the organisation accountable for all policies mentioned in this section is the Management Board, which ensures the implementation and compliance with the highlighted policies. In this section, we outline these policies in greater detail.

The key contents of the Human Rights Policy in relation to workers in the value chain are requirements to ensure respect for human rights in line with international standards, and of specific rights linked to the salient issues identified in Vesteda’s role as a business partner and investor. The policy includes our requirements with respect to ongoing due diligence, engagement and our expectation that suppliers adhere to similar standards and ensures transparency and accountability through public reporting and effective grievance mechanisms. The human rights commitment as expressed in this policy applies to Vesteda’s relationship with suppliers and this should therefore be read in conjunction with our Human Rights Policy and our Supplier Code of Conduct.

Vesteda’s Supplier Code of Conduct outlines what we expect from suppliers with regards to their respect for human rights. It was updated in 2025 to emphasise actions on the salient topics, including those related to value chain workers. Vesteda monitors its suppliers for potential and actual human rights impacts and takes appropriate action, varying from engagement and support to full disengagement with the supplier. The Supplier Code of Conduct outlines expectations for business partners with regards to salient issues, including health and safety, non-discrimination, zero-tolerance policy for child and forced labour and awareness of its various forms. Vesteda’s Supplier Code of Conduct is based on, among other things, the IVBN Code of Ethics and has been approved by the Vesteda Management Board and Management Team[1]. The Supplier Code of Conduct is updated in line with the salient topics.

To date, no cases of severe human rights incidents or cases of failure to respect the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work or the OECD Guidelines for Multinational Enterprises involving our suppliers have been brought to Vesteda’s attention[2].

1 IVBN is the Dutch trade association of institutional and professional real estate investors in the Netherlands.

2 In line with the UN Guiding Principles on Business and Human Rights, a severe human rights incident is defined by the substantial impact it may cause. This impact is assessed based on three key factors: scale, scope and irremediability. An incident may be considered severe if it meets one or more of these criteria.

The SpeakUp mechanism provides a mechanism for employees, business partners, and the general public to confidentially report concerns related to breaches of Vesteda's (Supplier) Code of Conduct, including human rights violations. The Supplier Code of Conduct outlines the expectations that all suppliers must act in line with the relevant and applicable laws and regulations. This mechanism ensures that any improper behaviour or breaches of conduct can be reported anonymously. Additionally, Vesteda continuously reviews and updates its SpeakUp mechanism.

S2-2 - Identifying and addressing impact

Vesteda has several ways of engaging with value chain workers about potential impacts. These include the external stakeholder validation as part of the DMA and salience assessment and by raising awareness through the Supplier Code of Conduct. The Management Team is the most senior body responsible for the engagement with workers in the value chain.

In the context of the DMA and salience assessment, Vesteda has gained insight into the perspectives of workers in the value chain by means of a stakeholder engagement survey. The survey aimed to assess Vesteda’s impacts on people and the environment, as well as sustainability related risks and opportunities. The respondents were asked to select which sustainability-related topics were the most relevant for Vesteda in terms of impact, risk and opportunity. Out of all the stakeholders contacted, the following parties took part in the survey: NGO representatives and suppliers or business partners.

S2-3 - Acting on material impacts and mitigating material risks

The SpeakUp grievance mechanism offers our business partners a confidential environment in which they can raise concerns relating to breaches of our (Supplier) Code of Conduct, including the corresponding human rights reflected therein. When they submit a complaint using the SpeakUp channel, the person who made the complaint can get updates by phone or email. Vesteda has an Internal Reporting Procedure (please see section G1-1 Policies), which protects stakeholders who report misconduct and file complaints from any form of retaliation. Following that procedure, Vesteda monitors and tracks issues raised by workers in the value chain. This enables Vesteda to identify and respond to issues promptly and ensures a clear and predictable process for workers in the value chain. Vesteda cannot guarantee that all workers in the value chain are aware of the SpeakUp Channel. As an alternative, there are different channels available for workers in the value chain to raise concerns through business partners, this is encouraged through the Supplier Code of Conduct.

S2-4 - Actions

Vesteda aims to identify and manage negative impacts on workers in the value chain through the outputs of the salience assessment, the DMA and the grievance mechanism analysis. For the details of the salience assessment process, please see the section Materiality analysis and results according to the concept of double materiality. As a result of the saliencies identified for the business partner/investor role, Vesteda has taken the following actions:

For non-discrimination, Vesteda actively requests its suppliers to sign the Supplier Code of Conduct as an annex to the framework agreement concluded with each party. The Code includes provisions on non-discrimination and is intended to promote ethical and inclusive working environments. As part of the agreement process, suppliers are expected to communicate the Code to their employees and business partners, ensuring that they are aware of its contents and can raise complaints anonymously if necessary. This requirement applies to all framework agreements and turnkey contracts related to new construction projects and large-scale renovation projects. Not all suppliers are currently covered by framework agreements; Vesteda is in the process of developing and expanding framework agreements with her key suppliers. In addition, suppliers and subcontractors are expected to conduct due diligence when entering into agreements with new business associates, in order to prevent human rights violations, environmental harm, and corruption. Through these measures, Vesteda aims to foster a responsible and transparent value chain that eliminates any form of discrimination. These measures also support the opportunity to attract and retain (sub)contractors more easily through positive experiences with their employees. By promoting fair, transparent and inclusive working conditions in our value chain, Vesteda strengthens its reputation as a reliable and responsible business partner. This enhances our ability to secure long-term collaborations with high‑quality suppliers and subcontractors;
With respect to the health and safety of workers, we directly monitor risks related to health and safety through the incident tracking system. In line with the Arbo health and safety regulations, companies we work with are required to ensure a safe workplace for employees at the construction site of our new-build and renovation projects. Regular assessments by Arbo health and safety inspectors at construction sites guarantee compliance. Vesteda frequently reviews these reports, addressing key areas in contractor meetings and takes appropriate follow-up action. At Vesteda, we recognise that the health and safety of workers in our supply chain is a fundamental aspect of responsible business conduct. Through our Supplier Code of Conduct, we actively promote safe and healthy working conditions throughout our value chain. This approach aligns with Dutch legislation, which emphasises the need to safeguard the health and safety of workers in the value chain. As such, we contribute to a responsible and compliant supply chain that prioritises workplace safety;
In terms of freedom of expression, we engage in dialogue with our business partners if considered necessary to help them gain insights into the factors that both inhibit and contribute to a psychologically safe working environment;
On the child and forced labour front, Vesteda is committed to upholding human rights and ethical labour practices in its supply chain. Our Supplier Code of Conduct explicitly prohibits child labour and forced labour in any form. We recognise that, while Vesteda does not directly influence the occurrence of such practices in the upstream production cycles of materials used in our projects, this does not absolve us of responsibility. We engage with our business partners to raise awareness of the various manifestations of forced and child labour, particularly in the Dutch construction sector. Through these efforts and the implementation of the Supplier Code of Conduct, we actively support the exclusion of child labour and forced labour in our value chain, reinforcing our commitment to ethical sourcing and social sustainability;
With respect to adequate wages, Vesteda has established framework agreements with a number of its direct suppliers as part of its commitment to promoting fair and transparent working conditions in its value chain. These agreements explicitly include the hourly wage rates agreed upon with each supplier, broken down by discipline, thereby contributing to greater transparency and accountability in labour cost provisions. For the remaining suppliers, we will implement similar framework agreements in due course. Through this structured approach, Vesteda aims to ensure that wage provisions for workers are adequately safeguarded, in line with our broader social responsibility objectives and supplier engagement strategy.

To date, no severe human rights issues and incidents connected to Vesteda’s upstream and downstream value chain have come to Vesteda’s attention.

S2-5 - Metrics and targets

We do not yet have specific targets for managing material negative impacts, advancing positive impacts or addressing material risks and opportunities for our role as investor and business partner. In accordance with the relevant phase-in provision, we have applied the phase-in option to omit the disclosure of targets for ESRS S2 in this Sustainability Statement.