DELA Group recognises its responsibility to contribute to a sustainable future. This is the first sustainability statement that we have released under the Corporate Sustainability Reporting Directive (CSRD). This is a regulatory framework introduced by the EU for the 2024 financial year to enhance and standardise corporate sustainability reporting. The implementation of CSRD in Dutch legislation had not been completed at the time of preparing the annual report. Since DELA places great value on transparency and has wide-ranging ambitions related to sustainability, we have chosen to showcase our efforts and report our progress by means of this sustainability statement.

One of the European Sustainability Reporting Standards (ESRS’s) key components is the double materiality analysis, which identifies material sustainability issues across three areas – environmental, social and governance (ESG) – that are relevant to our business, value chain and stakeholders. This process involves assessing the potential impact of our activities on the environment and people, the risks that sustainability-related matters pose to our company, and the opportunities that sustainability initiatives can create. This sustainability statement incorporates the CSRD framework and the specific requirements of the ESRS's. In alignment with the materiality analysis, we report – in addition to the EU taxonomy – on the following topics:

• General disclosures
• Climate change
• Sustainable use of resources
• Personal services
• Privacy
• Good employer practices
• Business conduct 

Although this is our first time reporting under this new standard, we aim to ensure that sustainability is always an integral part of DELA’s strategy. This statement therefore aims to both provide transparency and demonstrate our commitment to contributing to sustainability. The reporting process is also an opportunity for us to emphasise our ambitions, which are part of a firm conviction that sustainability is not a final goal but an ongoing process.

Structure of sustainability statement
DELA has determined which thematic ESRS standards apply based on the identified material impacts, risks and opportunities. These include E1 Climate Change, E5 Material Use and Circular Economy, S1 Own Workforce, S4 Consumers and End-Users, and G1 Business Conduct alongside ESRS 2 General Disclosures. There are no entity-specific topics identified. The flowchart from ESRS 1 Appendix E was used to determine which disclosures should be reported for the identified material impacts, risks and opportunities.

The sustainability statement appendices contain a reference table, indicating where each ESRS section can be found in the report.

Value chain vs. own organisation
We have determined the material impacts, risks and opportunities based on the entire value chain of both funeral services and insurance. While the policies, actions and targets reported mainly relate to our own company, they also apply to the broader value chain for climate change and sustainable resource use. We report on metrics that only concern the performance of our own organisation, with the exception of Scope 3 CO₂ emissions.

Reported metrics
The metrics on which we report come from our information systems and suppliers and other external sources. Sectoral averages are used if no direct data is available. The collection, review and consolidation of data are managed by our reporting & control department. Line managers review the results before final reporting.

The methodology appendix on principles provides a complete overview of the definitions of our sustainability metrics, including details on the data sources and estimates used.

We expect our reported metrics to improve over time as new sustainability regulations lead to more standardised data. We aim for transparency in case of data changes or assumptions to ensure that readers can understand the context of any modifications.

Time horizons
We assess material impacts, risks and opportunities over the short, medium and long term. Since sustainability matters often become material over longer periods, a forward-looking approach is required. In this sustainability statement we apply the following definitions in line with the ESRS for forward-looking reporting:

• Short term: 1 year;
• Medium term: 1 to 5 years;
• Long term: More than 5 years.

Financial effects of sustainability impacts
The financial effects of managing material impacts have been identified and are reported under actions if they involve significant amounts. This only concerns the expected costs for the climate change transition plan. These financial effects are limited and not expected to pose a risk to our continuity so do not require adjustments to the strategy or business model.

Reliability of sustainability statement
This is DELA’s first sustainability statement based on the CSRD/ESRS's and it has not yet been integrated into the existing control systems. We have undertaken various initiatives in recent years to ensure its completeness and accuracy. First and foremost, we have built up knowledge and expertise regarding the legislation and its implications. For the non-financial quantitative data points, we have documented how DELA collects, aggregates and reports such data. And we have drafted a preliminary sustainability statement in which provide an initial elaboration on each reporting requirement.

The responsible parties internally provided all the necessary input, which our CSRD project team then transformed into a report. The internal responsible parties then reviewed the information for accuracy and completeness. The Executive Board then approved the sustainability statement as part of the overall annual report.

The sustainability statement will be integrated into the existing control systems in 2025 and therefore be integrated into our policy, processes, work instructions and internal controls. 

The financial and sustainability statements both follow the same governance framework. The audit committee oversees the financial and sustainability reporting process. The risks, internal controls and their operational effectiveness are also assessed in the risk committee. These responsibilities are clearly outlined in the regulations of both committees, which have been approved by the Supervisory Board.

We are committed to ensuring the accuracy of our sustainability statements. The independent accounting firm, selected by the Supervisory Board in collaboration with the internal audit function and Executive Board, audits our financial statements. Our sustainability data is subject to an assurance report with a limited level of assurance by the same independent auditor. We will follow up on findings from the independent auditor’s report and the management letter with action plans in which we define responsibilities and deadlines, and monitor implementation. 

We provide services that include ‘natura’ (in-kind) funeral insurance and a savings plan in the Netherlands, capital insurance in all three countries, and life insurance policies in the Netherlands and Germany. These policies ensure a diverse offering that meets various cultural and financial preferences. The premiums collected are invested in an attempt to minimise inflationary price rises for our policyholders. We work with service providers of products and services in the upstream insurance value chain such as IT and facility services, and with asset managers.

We also provide comprehensive funeral services in the Netherlands and Belgium. We assist bereaved families in organising a funeral, regardless of whether the deceased was insured with DELA or another provider, or not insured at all. In the Netherlands, our focus is on organising funerals for customers with in-kind insurance policies. In the upstream funeral value chain, we collaborate with service providers such as funeral transportation companies and facility services, as well as suppliers of coffins, company clothing and cremation furnaces.

There have been no significant changes in the products and/or services offered in the reporting period. More details about our business model can be found in the corresponding section of our Executive Board Report.

Our overall goal in terms of sustainability is to enhance our positive impacts, reduce any negative impacts, make the most of sustainability-related opportunities and manage sustainability-related risks. Our current strategy for the 2021-2025 policy period explicitly considers DELA's impact on customers and employees. In all that we do, we strive for high customer and employee satisfaction and to act with integrity. We are committed to the Paris Climate Agreement and aim to reduce resource use while opting for more sustainable alternatives. These sustainability-related targets align with our core activities in insurance and funeral services. The desired growth of our core activities may increase our positive impact but could also lead to negative effects such as higher resource consumption and increased CO₂ emissions due to a greater number of funerals. We will formulate a new multi-year strategy for 2026-2030 over the coming year, further integrating our strategy and targets in relation to sustainability.

The table below presents the components of DELA's current strategy related to sustainability themes, with a focus on key (future) challenges and the main solutions or projects initiated within the framework of sustainability reporting.

While DELA has a broad range of stakeholders, as a cooperative it primarily serves the interests of its members. These interests are financial as well as focused on the well-being of customers in both the short and long term. In addition, policyholders, bereaved families and employees are among our key affected stakeholders. Others include suppliers, funeral directors at funeral homes/crematoria, visitors to and guests at our locations, and the natural environment.

DELA attaches great value to listening to the views of our stakeholders as we strive to understand their needs and expectations. We actively engage with affected stakeholders to build support for our policies. Management and Executive Board take the outcomes of stakeholder research and consultations seriously, incorporating feedback into strategy, policy, targets and measures wherever necessary and possible.

The following overview outlines how we engage in dialogue with stakeholders.

The ownership with regards to various stakeholders is evolving. We are continuously working on optimising our processes to consistently engage stakeholders and disseminate the received views across the entire group. Strengthening this approach is crucial for DELA as it will ensure that valuable stakeholder input is more consistently embedded in our decision-making processes.

We have incorporated the interests of key stakeholders such as suppliers, employees, policyholders, visitors and the environment within the materiality analysis. DELA carries out an integrated assessment of the interests of all these stakeholders. As part of the double materiality analysis, various bodies have been informed about the identified stakeholders and sustainability-related impacts. The views of employees (via works councils) and members (via the general meeting and confidential committee) are shared with the Executive Board. In addition, the Management Board receives regular monthly updates on key insights from customers and employees via reports on NPS, eNPS and absenteeism.

The new multi-year strategy for 2026-2030 will incorporate the impacts identified for both the environment and our stakeholders. This strategy will be reviewed in 2025, including in the works councils, the general meeting and cooperative panel. These steps will further contribute to maintaining strong relationships with our stakeholders.

By means of a materiality analysis, we identify the impacts, risks and opportunities related to sustainability that are relevant (material) to our company. The CSRD requires a double materiality analysis, which combines impact materiality (how a company affects people and the environment) and financial materiality (how sustainability-related topics impact our business).

The materiality analysis has identified the following material topics.

Below follows a brief explanation of the impacts, risks and opportunities of these topics:

Climate change: DELA has a negative impact on the environment due to its CO₂ emissions and those of our chain partners. The significant amount of energy we consume in carrying out our core activities also has a negative impact. CO₂ emissions contribute to global warming. In addition, we have a negative impact via investments that have an environmental impact related to CO₂ emissions. The only material sustainability-related risk is a decline in the value of our investment portfolio due to climate change. A number of scenarios have been added to the existing resilience analysis (ORSA) to estimate the financial impact of sustainability-related risks on our investment portfolio in the medium and long term. The assessment indicates that there is a material but acceptable risk to the value reduction of the investment portfolio due to climate change. This risk is expressed as a market risk. Both the likelihood and magnitude of this risk are considered average, meaning DELA’s financial position can withstand any potential impact. In the event that this risk materialises, reduced investment returns will be partially offset by premium increases for our policyholders. The Risk Management section provides further insights into how this risk, as part of market risk, relates to DELA’s other risk categories.

Sustainable use of resources: Although DELA does not produce its own products, we do consume resources in providing our services. The use of raw materials and waste generation have a negative impact on the environment. Key resources in our services include coffins, paper, flowers and company clothing.

Personal services: We have a positive impact on the well-being of our customers, especially policyholders and bereaved families, by providing comprehensive support (emotional, financial and practical) in relation to funerals and farewells.

Privacy: Any failure to properly protect our customers' personal data could have a negative impact on their well-being.

Good employment practices: We have a positive impact on the well-being of our employees by offering good working conditions and benefits. That said, working in the funeral services sector can have potential negative impacts such as disrupting the work-life balance, performing mentally and physically demanding work and being confronted with aggressive behaviour. In addition, we have a potential negative impact on the wellbeing of (potential) permanent employees due to a lack of focus on diversity and inclusion.

Business conduct: We have a positive impact on our stakeholders via our corporate culture. There is, however, a potential negative impact for whistleblowers if they are not adequately protected.

DELA is involved in material impacts through our own activities, the procurement of services and products from suppliers (upstream), via intermediaries (downstream) and the other funeral service providers who use our locations and services (downstream).

The impacts and risks are concentrated in the value chain as follows, including the stakeholders affected:

Our business model aligns with the interests of members, policyholders and bereaved families. We can increase our positive impact and reduce the negative without having to adjust our business model. Since we are not making significant changes to our strategy or business model, we expect all material effects to occur in the short, medium and long term.

We will annually assess whether significant changes have arisen from internal or external developments that would require a full revision of the double materiality analysis. This may also be influenced by the yet-to-be-determined sector-specific ESRS standards. In the event that a revision is not needed we will enrich the analysis with input from internal experts and external stakeholders. In 2025, we will further develop our structured dialogue with stakeholder groups and incorporate the outcomes of the materiality analysis into the formulation of our new multi-year strategy for 2026-2030.

Step 1: Identification of stakeholders
Our internal project team of experts analysed the current stakeholders. We expanded the group to include the environment as a ‘silent’ stakeholder in addition to the stakeholders identified in the 2022 materiality analysis. The conclusion was that members, customers, employees, suppliers and the environment are the most affected stakeholders.

Step 2: Value creation and supply chain insights: insurance & funeral services
DELA has two core activities: insurance (including investments) and funeral services. The value chains have been mapped out for both activities, with key actors identified upstream and downstream.

Step 3: Longlist and shortlist
We began the 2022 materiality analysis with a traditional longlist of topics, compiled from literature and interviews. DELA's impact on various stakeholders was considered and an internal panel of employees with expertise in finance, control, strategy and corporate social responsibility narrowed the longlist down to a shortlist. The materiality of the shortlisted topics was then assessed by a broader group of internal experts and subsequently validated by three external experts, resulting in the final materiality analysis.

For the 2024 materiality analysis, we added the ten thematic ESRS topics, including sub-topics, to the 17 material topics from 2022. The Risk Management department assessed whether financial and non-financial risks – classified as ‘high’ or ‘medium’ in our risk management system – needed to be included and whether material impacts led to additional sustainability-related risks. This did not result in any additional sustainability topics. To create a shortlist of material impacts, risks and opportunities, we first removed economic (non-ESG-related) topics from the 2022 list. We then evaluated whether the ESG-related topics aligned with standard ESG (sub)topics. A separate analysis was conducted to assess the potential material impacts of our investment portfolio.

The refined list of 87 topics was evaluated by internal experts, supplemented by additional research and data analysis of the potential material positive/negative impacts, risks and/or opportunities. This process reduced the longlist to eight key topics with 48 possible impacts, risks and opportunities.

Step 4: Defining impacts, risks and opportunities
We described in concrete terms the potential material impacts, risks and opportunities for the topics identified as material during Step 3. Internal expertise and input from stakeholder dialogues were used for this purpose.

Step 5: Prioritisation of material topics
We assessed the materiality of each impact, risk and opportunity using internal expertise and input from stakeholder dialogues (see ‘explanation of prioritisation’ table below for the methodology). The results of the periodic ORSA were used to determine the likelihood and magnitude of sustainability-related risks in the investment portfolio. The ORSA evaluates whether our strategy can withstand the effects of sustainability-related risks in the investment portfolio.

Ultimately, we identified 15 material impacts, risks and opportunities, which were grouped into six material topics.

Step 6: Stakeholder consultation
We also discussed the identified material topics and their associated impacts, risks and opportunities with two key stakeholder groups. The first was our customers, represented by the confidential committee and members of the general meeting. The second group consisted of our employees, represented by the works councils in the Netherlands and Belgium. We validated the materiality analysis and material topics in dialogue sessions and asked them to complete a survey to confirm DELA’s material sustainability topics and suggest any missing ones. In addition, we compared our material topics with eight other providers of funeral insurance and/or life insurance in dialogue sessions held in mid-2024

The information gathered was incorporated into Steps 3, 4 and 5 of the double materiality analysis. As a result of the dialogues with members and employees, the potential negative impact on employee well-being of insufficient whistleblower protection and the positive impact of our corporate culture were added to the list of material impacts. 

Finalisation
We discussed the double materiality analysis on a number of occasions with the Management, Executive and Supervisory Board. The double materiality analysis and identified impacts, risks and opportunities were approved by the Executive Board at the end of 2024.

The sustainability statement may not include every impact, risk or opportunity that each individual stakeholder (group) considers important based on their own specific estimates. 

Various policy documents support the management of sustainability-related impacts, risks and opportunities. Unless otherwise stated, these policies are not aligned with internationally recognised frameworks such as the UN Guiding Principles on Business and Human Rights (UNGPs), the International Labour Organization Declaration on Fundamental Principles and Rights at Work or the OECD Guidelines for Multinational Enterprises.

The Management Board defines objectives for their respective business units, including those related to sustainability themes. The Executive Board approves these objectives at the group level, with support from internal experts. Targets have been set for 2030 for the topics climate change and sustainable resource use, while objectives are reviewed annually for the topics personal services and good employment practices as part of the business planning cycle.

Each year, the Executive Board prepares a letter specifying the proposed frameworks for the upcoming year. The Management Board then develops annual plans that detail the targets and activities they will undertake. These plans are based on input from upper levels of management, which can indicate the resources and support needed to meet the targets. This results in a cohesive and goal-oriented plan that provides direction for the entire company.

The finalised annual plans, including the goals and projects for the upcoming year, are reviewed annually with a representative body of employees known in the Netherlands and Belgium as works councils. Since Germany does not have a works council, the annual plans are shared and discussed with all employees. Additionally, DELA Group’s annual plan is shared with members of the general meeting.

The monitoring and management of the various sustainability topics is conducted via regular periodic reports at the business unit and group level. Key results in areas such as good employment practices and the provision of personal services, including issues like absence due to illness, turnover and NPS, are reported monthly. These reports are intended for Management, Executive and Supervisory Board. Sectors report monthly and quarterly to the Management Board. Our Management Board submits monthly and quarterly reports to the Executive Board, which then reports to the Supervisory Board. The objectives for climate change and sustainable resource use were set in the report year and internal periodic reporting began in 2025.

Furthermore, the periodic ORSA evaluates whether the current strategy can withstand the impact of sustainability-related risks in the investment portfolio. An ad-hoc ORSA is conducted to reassess these risks in the case of trigger events such as major acquisitions.

A member of the Management or Executive Board has been assigned responsibility for all material topics and their associated impacts, risks and opportunities:

The Executive Board responds to diverse customer needs and ensures a consistent level of quality. It also guarantees proper safeguards in the areas of business conduct and ethical business operations. The Management Board is tasked with implementing this as a delegated responsibility, using additional programmes if required. The Supervisory Board ensures that customer-centric values and interests are central to the business strategy and oversees the effectiveness of internal risk management and control systems, including those related to business conduct.

As a member of the Supervisory Board, Willemien Caderius van Veen is responsible for DELA’s ESG themes. She also chairs the audit committee, where sustainability reporting is discussed periodically. The audit committee within the Supervisory Board is responsible for preparing an oversight of internal risk management and control systems, ensuring compliance with recommendations and following up on findings from the internal audit function and external auditor. A remuneration and nomination committee specifically addresses good employment practices and business conduct.

When appointing members to the Supervisory Board, Executive Board and Management Board, we ensure a balanced mix of knowledge, experience, education and perspectives. This in turn enables decisions to be made that take into account a range of viewpoints. Our Executive Board consists of two statutory group directors and three non-statutory group directors (with one positions still vacant). DELA does not have independent directors. The Executive Board is 50% female and 50% male. Employees are represented in the Management Board by the HR director. The Supervisory Board includes two board members who represent the members. The general meeting also includes regional representation to ensure that local insights and interests are incorporated in our decision-making.

The Executive Board has broad experience in the financial sector and in-depth knowledge of relevant laws and regulations, including business conduct policies. Our competence and suitability procedures are based on the Policy Rule set by the Dutch central bank (DNB) in 2012. We also assess the suitability of individuals in key leadership positions under Solvency II regulations, including risk management roles, actuarial functions, and internal audit functions.

In general, the Management, Executive and Supervisory Board maintain their expertise levels through continuous education, covering topics such as cybersecurity, GDPR, ethics and risk management. Annual evaluations assess the performance of the Executive Board and Supervisory Board. The retirement and possible reappointment of Supervisory Board members is reviewed annually. Recruitment and selection policies for new appointments are strictly followed. Knowledge and expertise in the area of sustainability, particularly environmental topics, is strengthened via training and knowledge-sharing from external and internal experts. The CSRD progress report is also periodically discussed within Management, Executive and Supervisory Board, increasing their familiarity with its contents.

The Management, Executive and Supervisory Board and its committees took additional actions on various sustainability topics in 2024. Attention was paid to the double materiality analysis and sustainability reporting in the annual report. Targets and a transition plan for climate change were developed and objectives for sustainable resource use established. The Remuneration Policy and employee satisfaction survey results were carefully reviewed, while customer satisfaction survey results were analysed. Sustainability risks were addressed, and sustainable investment strategies and objectives refined. Psychological security within the organisation was the subject of focused attention in order to ensure a safe and supportive working environment for employees.

Performances in relation to sustainability (including CO₂ reductions) are not linked to variable remuneration at DELA except at DELA Belgium, where a variable remuneration system is in place. Up to 10.5% of the fixed salary may be awarded as variable remuneration based on specific targets such as the minimum customer satisfaction scores (NPS), which are considered a sustainability metric. DELA Belgium’s works council is involved in setting the annual variable compensation objectives (CAO 90). Members of the Executive and Supervisory Board do not receive variable remuneration.

See the corresponding section in the Executive Board Report for more details on governance.

We expect that DELA will need to comply with the Corporate Sustainability Due Diligence Directive (CSDDD) by 2028. This European regulation came into effect in 2024 and requires companies to manage and mitigate negative impacts on human rights and the environment within their supply chain. This directive complements the CSRD by enhancing accountability and transparency through mandatory sustainability due diligence. We will begin implementation in 2025 to ensure timely compliance.

Our procurement and outsourcing policies currently govern our relationships with and selection of suppliers. Due diligence checks are carried out for all new partnerships to identify potential issues such as misconduct, corruption or non-payment of suppliers further down the supply chain. Existing contracts are continuously monitored, primarily focusing on payment behaviour and compliance with sanction regulations.

Our Corporate Social Responsibility (CSR) procurement code, has a broad scope and requires suppliers – including subcontractors – to adhere to its principles. Suppliers must commit to socially responsible business practices, specifically regarding labour and human rights, as outlined in the Universal Declaration of Human Rights of the United Nations. They are also expected to respect the environment and comply with all applicable (supra)national environmental laws and regulations. In addition, suppliers must adhere to all applicable (supra)national competition laws and regulations. While acknowledging that some existing (local) contracts signed in the past may deviate from these current standards, new suppliers are told about our CSR Procurement Code during the selection process. This code is publicly available on our website.

The EU Taxonomy defines a set of environmentally sustainable economic activities. The taxonomy includes six environmental objectives: two climate objectives – mitigation of and adaptation to climate change – and four other environmental objectives, namely the sustainable use and protection of water and marine resources, the transition to a circular economy, pollution prevention and control, and the protection and restoration of biodiversity and ecosystems.

The taxonomy provides a classification system that identifies environmentally economic activities which can be considered sustainable. This helps companies and investors determine which activities substantially contribute to the six environmental objectives without causing significant damage to any of them. The result is greater transparency and easier comparability of sustainability information.

The EU taxonomy regulations are still evolving and considerable uncertainty remains about how to apply certain additional guidelines. The additional tools, including FAQ9, were only published at the end of November 2024. DELA has chosen to apply only the mandatory tables for insurers, rather than using multiple tables for each activity of a mixed group. Within the framework of the EU taxonomy, we consider the insurer to be the predominant nature of DELA Cooperative. This choice will be reviewed again in the coming year. 

Financial institutions, including insurers, must explain what proportion of their investments relate to the financing of taxonomy-eligible and taxonomy-aligned activities. See the financial statements for the value of the investments as of the end of 2024. In the prescribed tables, below and in the sustainability statement appendices, we show which part of the investment portfolio qualifies for the taxonomy (eligible) and is aligned with it. This concerns the tables from Annex IX, X (with the exception of the first table, which only applies to non-life insurers and reinsurers), and XII of the delegated regulation. We have calculated the amounts and percentages with the assistance of external parties.

The investments are accounted for at fair value. The data is based on the investments that were in the portfolio on 31 December 2024.

We have made every effort to collect the required data on eligible and aligned activities in accordance with the EU taxonomy. Limitations in the availability of data meant we had to make several interpretations and assumptions in order to arrive at the reported information. The reported data also represents a snapshot in time.

The coverage (84.77%) is determined by dividing DELA's investments, excluding exposures to central governments, central banks, supranational entities, and derivatives, by the total investments, including the company's real estate (headquarters, crematoria and funeral homes).

For the listed companies in our portfolio, we have used data from an external ESG data service provider to verify what percentage of revenue and investments (capex) is ‘aligned’ with the six objectives. We also calculate what percentage of revenue and investments (capex) is ‘eligible’. This does not take into account the type of bond, such as grey, green, social and sustainable. The external supplier linked the data from its data providers to our portfolio and we received this input in at the end of February. DELA follows the methodology, calculations and estimates of the external data provider and does not make any adjustments to the received data.

The classification of listed companies into financial and non-financial enterprises was made based on data from this external data provider. In addition, a lack of information led to the assumption being made that companies from non-EU countries are not subject to Articles 19a and 28a of Directive 2013/34/EU. As a result, the percentages under ‘The proportion of exposures to financial and non-financial undertakings not subject to Articles 19a and 29a of Directive 2013/34/EU over total assets covered by the KPI’ and ‘The proportion of exposures to financial and non-financial undertakings from non-EU countries not subject to Articles 19a and 29a  of Directive 2013/34/EU over total assets covered by the KPI’ are the same. It was also assumed that companies from EU countries are subject to Articles 19a and 28a of Directive 2013/34/EU.

Additionally, for the categories ‘The proportion of DELA's investments other than investments held in respect of life insurance contracts where the investment risk is borne by the policyholders that are directed at funding or are associated with Taxonomy-aligned economic activities’ and ‘The proportion of DELA's investments other than investments held in respect of life insurance contracts where the investment risk is borne by the policyholders that are directed at funding or are associated with Taxonomy-aligned economic activities’, no data is available for the total, only divided into revenue and capital expenditures. For this reason, these categories are reported based on revenue and capital expenditures rather than the total.

For the non-listed investment portfolios in ‘real estate’, ‘infrastructure’, ‘agriculture and forestry’, 'mortgages' and 'private loans', we have used information from the SFDR reports provided by asset managers. Seven of the 25 asset managers we work with were unable to provide this reporting for 2023, which accounts for 21.8 per cent of the invested capital in these non-listed funds. As a result, we have assumed 0 per cent ‘eligible’ and 0 per cent ‘aligned’ for these portfolios. Of the reports that have been received, the ‘alignment’ is 4.1% based on revenue and 5.0% based on capital expenditures. Additionally, we report our own real estate as 0% 'eligible' and 0% 'aligned' as DELA has so far chosen not to fully carry out the alignment assessment. We will evaluate this decision in the coming year based on developments related to the EU taxonomy regulations.

The classification of non-listed investments into financial and non-financial undertakings, as well as whether they fall under EU or non-EU countries and thus need to comply with the EU taxonomy, is not available with the current information. All non-listed investments are therefore reported under 'The proportion of exposures to other counterparties in over total assets covered by the KPI.'

Compared to 2023, the revenue-based proportion of taxonomy-aligned exposures has increased from 6.5% in 2023 to 6.9% in 2024. The same proportion based on capital expenditures has increased from 1.2% in 2023 to 6.3% in 2024.

Our operational CO₂ emissions stem from the likes of crematoriums, offices, funeral service locations and transportation. In addition, the upstream value chain – such as the supply of products and services or business travel – also contributes to CO₂ emissions. The majority of our CO₂ emissions are concentrated within the funeral services chain. This is due to the energy-intensive cremation process and the products and services associated with funerals. Our CO₂ emissions are a direct consequence of our core activities.

2. High energy consumption from own operations
Energy consumption has a significant impact on the environment as it places pressure on the total availability of finite energy resources, both fossil and renewable. Moreover, the use of fossil energy results in CO₂ emissions.

DELA currently has a negative environmental impact due to energy consumption within its own operations. This includes crematoriums, office and funeral service locations, and company-owned transport. According to the European Energy Efficiency Directive, we are classified as a major energy consumer. The majority of this impact is linked to the funeral services chain. Cremation is an energy-intensive process, and the energy consumption of our funeral service locations, where we organise ceremonies, also plays a role.

3. CO₂ emissions investments
If we assess the total impact of CO₂ emissions from our current investment portfolio, we observe that it is, on balance, negative. Investing the premiums of our policyholders is essential to our business model, as it helps keep premiums low while ensuring guaranteed pay-outs in the event of death.

4. Risk of investment portfolio depreciation
The value of our investment portfolio may grow at a slower rate or even decline due to climate change, which represents a transition risk. This sustainability-related risk is part of the existing market risk and systemic risk that we already manage within our investment portfolio. This risk has been assessed in the resilience analysis.

In 2023, a comprehensive resilience analysis was conducted on this risk using the climate scenario dataset from ORTEC Finance. No material risks were excluded from this analysis. This climate scenario dataset uses various inputs to model the impact of climate change on financial markets, making the dataset suitable for determining the risk of value depreciation in the investment portfolio. The key drivers and pressure factors included as inputs in the scenarios are climate data, macroeconomic data, policy information and financial data. The scenarios account for both transition risks and physical risks. Within this, both acute physical risks (e.g., hurricanes and floods) and chronic physical risks (e.g., warmer average temperatures and rising sea levels) are included. The key limitations and exclusions of the scenarios are as follows. Transition risks from behavioural changes, such as changes in lifestyle (e.g., low-meat diets) or economic systems (e.g., circular economy) are not currently included in these scenarios. The econometric approach of the dataset assumes that historical interactions between economic and financial variables will continue to exist in the future. The dataset includes four climate scenarios, ranging from ambitious climate policies (<1.5°C) to limited or no action against climate change (>4°C):

• Net-Zero (NZ): Ambitious policies result in a carbon-neutral economy by 2050, limiting global warming to below 1.5°C. The high climate ambition results in a path of high growth and low emissions, achieving the targets of the Paris Agreement and limiting global warming to less than 1.5°C by the end of the century.
• Net-Zero Financial Crisis (NZFC): This is a potential vulnerability to the Net-Zero scenario, where the transition to a low-emission economy is challenging. The new reality of a shock to the financial markets is priced in.
• Limited Action (LA): This scenario sees policymakers taking moderate steps to limit climate change. The commitments made in the national agreements of the climate accord (NDCs) are not fully met because policy actions are too weak and insufficiently urgent. The scenario results in a temperature increase of nearly 3°C by the end of the century.
• High Warming (HW): In this scenario, policymakers take no steps to fulfil the commitments made in the NDCs. This is the most extreme scenario, where the temperature rises to 4.2°C, well above the set targets. The largest losses occur on the financial markets in this scenario. 

The Net-Zero scenario aligns with the policy direction followed by DELA, with a time horizon of 40 years used for the calculations. This means that the targets set by DELA fall within this time horizon.

The resilience analysis demonstrates that DELA’s investment portfolio is resilient to most climate scenarios. Only in the most extreme scenario – where no global climate change mitigation measures are implemented – does solvency fall below the regulatory threshold. Given the current global efforts to limit temperature increases, however, this scenario is considered unlikely. Risks do not occur simultaneously and everywhere. By diversifying investments across industries and countries/continents, the risk of a single event affecting the entire portfolio is mitigated. Diversification therefore helps to reduce the impact of risks. Underperforming investment returns have an impact on the premium development for our policyholders. According to the calculations, our strategy and business model provide sufficient resilience against the risks of climate change.

In 2024, we conducted a sensitivity analysis, calculating the impact of a 20% investment loss due to climate change. The investment loss has an impact on the premium development for our policyholders. The results confirm that our solvency remains just above the regulatory threshold, aligning with previous analyses. An early full recalculation is therefore unnecessary.

Based on the findings of the 2023 analysis and previous years, we have decided to conduct a comprehensive analysis of the impact of climate scenarios on investment returns once every three years, unless significant changes occur in regulatory guidelines or data availability. Meanwhile, DELA continues to annually perform a sensitivity analysis as part of the ORSA, assessing the impact of any adverse investment returns that may be triggered by climate risks.

Below is a further explanation of how this topic is being addressed, initially in our own operations and then for our investment activities.

The climate change transition plan focuses on the reduction of greenhouse gas emissions within Scope 1, Scope 2 and Scope 3, as defined by the GHG Protocol. In 2024, the plan was developed with concrete targets, actions and resources for CO₂ emissions in Scope 1, Scope 2 and the ‘business travel’ category of Scope 3. In 2025, the plan will be expanded to include targets, actions and resources for the remaining Scope 3 categories. The climate change transition plan applies to DELA’s value chains for both funeral services and insurance in the Netherlands and Belgium. As DELA Germany only operates within the insurance sector, where energy consumption and CO₂ emissions are minimal, no specific actions are planned at this time.

The most significant locked-in greenhouse gas emissions stem from buildings and cremation furnaces. These emissions can be reduced by transitioning buildings to be gas-free and replacing gas-fired cremation furnaces with electric furnaces. All these assets have been incorporated into the climate change transition plan. DELA does not offer products with potential locked-in greenhouse gas emissions. Three essential decarbonisation levers have been identified to help ensure the success of our climate change transition plan:

1. Making buildings and cremation furnaces gas-free 
Buildings and cremation furnaces consume significant amounts of energy, with a typical gas cremation furnace using approximately 50m³ of natural gas per cremation. Replacing gas-fired cremation furnaces with electric versions reduces energy consumption by 80%. And our CO₂ emissions decrease by 100% as we source electricity from renewable energy. Our goal is to make all buildings gas-free by 2050 via improved insulation and minimising energy demand. Key challenges in achieving this goal include the limited availability of electric cremation furnaces and grid congestion when upgrading to higher-capacity electrical connections. While exploring mitigating actions to reduce the risk of grid congestion, we do remain dependent on the expansion of the electricity network’s capacity.

2. Divesting or clustering locations
As an efficient property portfolio is a critical precondition for gas-free renovations, it is essential to ensure we have the right buildings in the right locations. Several locations in the Netherlands were divested over the past two years and a further clustering of locations may lead to additional divestments. In addition, we are implementing a zonal location strategy for our funeral homes in Belgium. The remaining buildings are renovated after clustering. A strategy has now been determined for the first zone, which includes five locations.

3. Fossil-free transport
Our current approach involves replacing fossil-fuel vehicles with electric vehicles. Thanks to a sufficient driving range and charging infrastructure, EVs are a viable solution. This transition applies to lease cars (both personal and pool vehicles), transport for the deceased, and ceremonial vehicles in both the Netherlands and Belgium. 

The climate change transition plan does not currently account for emerging technologies. However, alkaline hydrolysis (resomation) could become an additional option if legislation in the Netherlands or Belgium permits it. Moreover, when renovating buildings we assess the latest best practices in technology such as refrigerants used in heat pumps. There are no nature-based solutions included in the current climate change transition plan.

The progress of actions outlined in the climate change transition plan is monitored quarterly. As part of the annual planning cycle, the planned actions for the upcoming calendar year are reassessed and supplemented at least once a year with additional actions for the following year. This ensures an up-to-date plan is always in place detailing the intended actions over a rolling five-year horizon.

We estimate that the current target, along with the planned actions, will also ensure sufficient progress in energy efficiency and renewable energy. This is why specific targets for reducing energy consumption or expanding renewable energy have not been set at this time.

In 2024, we set CO₂ reduction targets for our own operations, covering Scope 1, Scope 2 and business travel within Scope 3 across all countries where DELA operates in both the funeral and insurance sectors. This target relates to 100% of the emissions in Scope 1 and 2, and 33% of the Scope 3 emissions from the company's own operations. It concerns emissions in CO₂eq, originating from CO₂ and HFCs (refrigerants). These targets will be expanded in 2025 to include upstream and downstream CO₂ emissions in the value chain, aligning with the GHG Protocol’s broader Scope 3 emissions. The 2023 annual report does not include absolute CO₂ reduction targets. 

To define our climate change mitigation targets, DELA has followed the guidelines of the internationally recognised Science Based Targets initiative (SBTi). Since no sector-specific benchmark is available, we have used the SBTi economy-wide scenario as our reference. SBTi prescribes a linear annual reduction of 4.2% in Scope 1 and Scope 2 CO₂ emissions over the short term (5-10 years). This target is considered ‘scientifically grounded’ as it aligns with the goal of limiting global warming to 1.5°C, in accordance with the Paris Climate Agreement. Our set targets mean DELA complies with this guideline as our goal reflects a linear annual reduction of 4.4%. However, we have not submitted our targets for validation by SBTi as our stakeholders have not requested this and submission would require additional investments.

We have selected 2021 as the baseline year for our targets. This decision is based on the availability of group-level measurement data from 2021 onwards. The CO₂ emissions in 2021 provide a realistic reflection of our organisational size following the acquisition of Yarden. Furthermore, business operations were less affected by the COVID pandemic compared to 2020. Our targets are based on market-based CO₂ emissions.

The table below shows the quantitative targets.

The climate change transition plan outlines the decarbonisation levers and specific actions required to achieve our targets. The actions in the plan should lead to an estimated reduction of 3,677 tonnes of CO₂ emissions between 2025 and 2029. Of this, approximately 2,748 tonnes of savings come from actions in the Netherlands, while 929 tonnes are attributed to actions in Belgium. The chart below illustrates the contribution to the targets per country.

With the planned actions, DELA is well on track at the group level to exceed the target of a 40% reduction in CO₂ emissions by 2030 compared to the 2021 baseline.

The plan distinguishes between short, medium and long-term actions. Each year, we prepare a detailed schedule for the key actions over the next five years, covering the short and medium term. These actions are worked out in detail, while long-term actions are described at a higher level of abstraction. The plan is updated annually and extended by one additional year, ensuring that we always maintain a five-year horizon of detailed planning.

The actions implemented in 2024 fall within the decarbonisation levers outlined in the climate change transition plan and were carried out in both the Netherlands and Belgium. All actions have been successfully completed in 2024. 

The following actions are planned for the period 2026 to 2029:

For the period 2025–2029, the total additional investments are estimated at €39.2 million, divided into four main categories:

1. (Dis)investments in locations in the Netherlands
   A budget of €34.2 million is allocated for measures focusing on crematoriums and funeral centres. These investments cover cremation furnaces, buildings and installations
2. (Dis)investments in locations in Belgium
   A net budget of €1.8 million is allocated for building and installation investments in funeral centres.
3. Investments in vehicle fleet in the Netherlands
   €1.9 million is budgeted for the electrification of the transport vehicle fleet.
4. Investments in vehicle fleet in Belgium
   A €1.3 million additional investment is planned for sustainable upgrades to the Belgian transport fleet.

Our own real estate (head offices, crematoriums and funeral homes) is considered an investment asset. As of the end of 2023, the total own real estate value in the Netherlands represented around 4% of DELA’s total investment portfolio. Over the next five years, €34.2 million is expected to be invested in renovations in the Netherlands. These costs are listed under the investment costs item in the financial statements. Operational expenses for locations are expected to decrease due to lower energy consumption. This reduction will allow rental values charged to the funeral services business to increase, providing financial coverage for the investments. The same approach is applied to real estate and renovations in Belgium. 

The investments are fully financed from DELA’s own cash flow. Approximately €36 million of this amount is covered by the entities DCG BV and DELA Vastgoed BE, which are responsible for locations and cremation furnaces in the Netherlands and Belgium. The necessary funds are sourced from rental income paid by the funeral service entities to these entities or through internal financing. For the electrification of the vehicle fleet, leasing structures are utilised that eliminate the need for direct investments in this area. This targeted and financially sound approach enables DELA to continue investing in a CO₂-neutral future and contributes to sustainable operations within the framework of our climate change transition plan.

The use of fossil energy decreased by 5,535 MWh in 2024 compared to 2023, representing a 11% reduction. The total energy consumption fell by 1,559 MWh, which corresponds to a 2% reduction. At the same time, electricity consumption increased by 14%, aligning with our ongoing transition away from fossil fuels and commitment to electrification. This shift reflects DELA’s strategic focus on reducing our reliance on fossil energy while increasing renewable and electric energy use.

Scope 1, 2 and 3 CO₂ emissions
We calculate our CO₂ footprint according to the internationally recognised standard, the GHG Protocol (Greenhouse Gas Protocol), following the operational control approach. For Scope 1 and Scope 2, the basis for determining emissions is measured consumption data, supplemented by estimates when necessary. For the market-based emission factor of purchased electricity (Scope 2), we rely on our procurement contracts with suppliers. If no registered Guarantee of Origin (GvO) is available for electricity consumption, we apply the average electricity mix of the respective country (location-based emission factor). This primarily applies to electricity used for charging vehicles. A detailed overview of the assumptions and methodology used for the CO₂ emissions calculation is included in the methodology appendix on accounting principles in this statement.

In 2024, we revised the calculation of CO₂ emissions in Scope 3 (indirect emissions from activities of other parties in the value chain) to ensure a clear delineation and greater reliability. As a result of this revision, the following elements are excluded from the calculation:

• Visitor transport (excluded due to operational boundaries, effect -13.000 tonnes);
• Funeral catering in Belgium (excluded due to operational boundaries, effect -3.900 tonnes);
• Gravestones (excluded due to operational boundaries, effect -700 tonnes).

The revision resulted in the addition of the following elements:

• IT equipment (materiality based on magnitude, effect +200 tonnes)
• Workwear (materiality based on magnitude, effect +300 tonnes)
• Waste (materiality based on magnitude, effect +900 tonnes)
• Commuting (materiality based on magnitude, effect +1.900 tonnes)
• Cremations at external locations (materiality based on magnitude, effect + 1,800 tonnes)

The results from previous years have been adjusted to reflect the revised boundaries, ensuring a consistent year-by-year comparison. As a result, the Scope 3 CO₂emissions over 2023 have been changed from 24,332 tonnes to 14,040 tonnes in the new calculation. In 2023, an adjustment was made to the emission factor for forest-compensated natural gas purchased in the Netherlands. Until 2023, DELA modelled forest-compensated gas as CO₂ neutral. However, based on regulatory developments and public consensus, DELA assigned an emission factor to this gas from 2023. To maintain comparability of results over the years, the baseline year 2021 has now also been adjusted to reflect this updated emission factor. 

The table below shows the development of our CO₂ emissions.

Our total emissions for the own operations were 5% lower than last year, contributing to a total emissions reduction of 25% compared to the baseline year. Our Scope 1 and Scope 2 emissions were 9% lower than last year and 35% lower compared to the baseline year. This demonstrates that we are making strong progress toward achieving our medium-term reduction targets.

The CO₂ emissions within Scope 1 decreased by 667 tonnes in 2024 compared to 2023. Emissions within Scope 2 fell by 341 tonnes. While all the planned actions were implemented in Belgium regarding the measures related to buildings and cremation ovens, the savings fell short of the forecast: a reduction of 799 tonnes was achieved instead of the expected 1,092 tonnes. In the Netherlands, savings of 633 tonnes were realised in the same category due to the reduced use of fossil fuels. At the same time, an increase in the use of refrigerants led to a rise of 274 tonnes. In the area of transportation, we observe an increase in the use of electricity in both the Netherlands and Belgium due to a higher proportion of electric vehicles. At the same time, the total number of kilometres driven has increased, resulting in higher consumption of fossil fuels. As a result, the achieved savings differ from the forecast: instead of the expected reduction of 99 tonnes, there was a net increase of 208 tonnes. Further steps will be taken in 2025 to establish interim control over CO₂ emissions so that we can monitor emissions on an ongoing basis and adjust where needed.

A further explanation of the results for Scope 3.15 investments is included in the results under climate change investments.

CO₂ intensity
The CO₂ intensity, i.e. the CO₂ emissions divided by the net revenue, is indicated in the table below.

The CO₂ intensity has decreased by 7% compared to 2023. For calculating total CO₂ intensity, we use the total consolidated revenue as reported in the annual financial statements.

Our socially responsible investment policy primarily focuses on minimising negative impacts. Where possible, we also invest in projects with a positive impact, such as healthcare real estate and forestry. Public opinion on what constitutes acceptable investments also evolves over time. Take, for example, the ongoing debate around investing in fossil fuels and defence/weapons. We closely monitor these developments and adjust our policy when necessary.

Legislation and regulations form the foundation for socially responsible investing. Since 2015, we have endorsed the Principles for Responsible Investment (PRI). As DELA can have a greater impact by collaborating with other major investors we maintain an ongoing dialogue with the likes of the Dutch Association of Insurers. In implementing our investment policy, we also take into account UN standards such as the Global Compact Principles and Guiding Principles, as well as the OECD Guidelines for Multinational Enterprises and the Sustainable Development Targets (SDGs). By endorsing these standards, we expect the companies in which we invest to align their activities and strategies with ten universally accepted principles covering human rights, labour, the environment and anti-corruption.

The DELA website communicates with policyholders and other interested parties about our responsible investment policy. We provide both a summary and the full policy, supplemented by various links and background documents on the codes and principles DELA supports. Our UN PRI reports, the latest exclusion list, our Voting Policy and our periodic voting and engagement reports are also available on the website. Newsletters and publications keep members regularly informed on a variety of topics, including responsible investing. 

We also communicate any policy changes with the relevant asset managers. Discussions are held with new asset managers about DELA’s investment beliefs and how these are reflected in the asset manager’s processes. An asset manager is only selected if they align with our expectations.

We therefore aim for a 50% reduction in CO₂ emissions per million invested capital by 2030 compared to 2019, and net-zero emissions by 2050. This target applies to Scope 1 and 2 CO₂ emissions of the governments and companies in which we invest. The CO₂ emissions of our investments in 2019 were 127,8. The target is based on intensity to allow for better comparability, as it accounts for portfolio growth. The units used are CO₂e emissions and CO₂e/€million invested. An expected portfolio growth to approximately €14 billion by 2030 means the forecast for absolute CO₂ emissions is 888,014 tonnes. Stakeholders were not involved in setting these targets.

Several decarbonisation levers to reduce CO₂ emissions in our investments have been identified. We carefully select and monitor managers, actively use our voting rights and engagement, exclude certain companies, and make investments with a positive impact. There is no forecast of the contribution to the target for individual levers. In addition, we monitor our results annually against our targets. No significant investments are foreseen for the implementation of the CO₂ reduction plan within our investments.

Selection and monitoring of managers
We primarily invest through external asset managers. For our liquid portfolio, we mainly work with mandates. External asset managers operate within our policy framework but often add their own supplementary principles. This approach ensures a balanced strategy that combines returns with responsibility. Our illiquid investments are made through funds. When selecting new funds, we conduct screenings to ensure they align with our investment beliefs and meet our sustainability criteria. In the event of significant adjustments being made to our policy we assess whether the existing agreements are still aligned.

We have agreed on additional specific targets with some managers, for example a 50% lower emissions target than the benchmark for passive equity mandates. 

Exclusions
We adhere to EU, UN and Dutch sanctions legislation and supplement these exclusions with our own principles. Sanctions legislation applies to our entire investment portfolio. We exclude companies and countries that violate international laws, sanctions and sustainability-related regulations. We do not invest in companies involved in the development, production or maintenance of any type of controversial weapons. 

We also exclude companies that derive a substantial part of their revenue from the following sectors, as we believe investing in these industries has a net negative impact on the environment, society and/or good corporate governance. Companies are excluded if more than 25% of their revenue comes from the following sectors:

• Tar sands
• Coal
• Shale energy
• Oil and gas extraction in the Arctic
• Tobacco, fur & specialty leather
• Predatory loans
• Assault weapons for civilian use
• Recreational cannabis
• Gambling

Our service provider screens our investments based on the sectors and countries we have identified and reports which companies should be excluded. We then engage in discussions with external asset managers to assess whether the list is complete and accurate before finalising the exclusion list.

By the end of 2024 we had excluded 734 companies and 35 governments/countries. Of these, 437 companies are excluded due to sector involvement, 95 companies due to involvement in controversial weapons, and 202 companies due to violations of the UN Global Compact Principles. Some 69 of the excluded companies are on the list for violating the climate-related principles 7 to 9 in the UN Global Compact Principles.

Engagement
We engage in dialogue with the companies in which we invest to influence how they address sustainability, implement sustainability-related improvements and mitigate sustainability risks. This goes beyond CO₂ reduction and includes other ESG topics, like environmental management, human rights, employment conditions and business ethics. 

For the implementation of our engagement and voting policy, we collaborate with a professional service provider that was selected for an approach and objectives that align with ours. This company establishes new engagement priorities annually, determines voting strategies for annual general meetings of shareholders and examines how collaboration with other investors or stakeholders will take place. These priorities are set in close consultation with us and other clients.

By outsourcing engagement and proxy voting to a professional party, the invested capital of multiple (institutional) investors is pooled together. This larger collective investment is leveraged on in engagement initiatives; joining forces allows us to have a greater impact. Such an impact is essential to encourage companies to manage their operations responsibly in relation to society and the environment.

For our fund investments, we engage in dialogue with asset managers on various sustainability aspects within the portfolio. It is crucial that we can make our voice heard when selecting a fund. Within our fund investments, our own portfolio managers ensure presence at key meetings, the inclusion of relevant topics on the agenda and active participation in discussions.

Furthermore, the Global Real Estate Sustainability Benchmark (GRESB) is used for real estate funds. This independent benchmark assesses and compares real estate funds and portfolios worldwide based on their sustainability performance. These performance results are published annually and serve as a basis for identifying key areas of focus in our dialogue with real estate funds.

The outcomes of the dialogues we conduct with companies are factored into our decisions on whether to invest in a company or maintain an existing investment. Aspects considered in this process include the expected returns, public opinion, the topics discussed in the dialogue and the progress companies make on those topics.

Exercising voting rights
We cast our votes at shareholder meetings where possible for the companies in our investment portfolio. An active voting policy is an integral part of the dialogue we maintain with these companies. For voting on climate change-related matters, we follow the policy of the specialised party that also conducts engagement on our behalf. For certain other ESG-related topics, such as executive remuneration and corporate governance, we apply a different voting policy. These deviations are taken into account by the specialised party when executing the policy. We also exercise our voting rights at fund-related general meetings whenever possible.

Investments with a positive impact
When opportunities are identified we invest in specific sustainable investments or funds that have a positive impact on people, society or the environment. Although this has been very limited to date, we will conduct research in 2025 on how DELA can increase its investments with a positive impact.

The coverage percentage reflects the portion of invested assets for which measured emission data is available. To calculate emission intensity, an estimate of the total CO₂ emissions was made to arrive at an accurate value. The data reliability is based on the PCAF data quality assessment method. This provides an indication of the reliability and accuracy of the reported CO₂ emissions, where one represents the highest quality and five the lowest.

Since 2019, the availability and reliability of data on CO₂ emissions from companies and governments in which we invest has increased. Additional efforts were made in 2024 to gain a clear understanding of the CO₂ emissions of our portfolio, as well as the portfolios from 2019 (the base year) and 2023. However, historical data, particularly for non-listed categories such as mortgages and infrastructure, remains limited or difficult to trace.

The increase in emission intensity compared to the base year 2019 is almost entirely explained by changes to the investment portfolio: by the end of 2024, we were investing significantly more in the investment categories of private loans, forestry, agriculture, real estate and infrastructure. The infrastructure category has a particularly high emission intensity, which is accepted as the recent ALM study showed that, based on risk/return objectives for DELA, this is a suitable investment category. Naturally, we are making efforts to achieve a CO₂ reduction within this investment category through the aforementioned instruments. We also have the option to sell investments if this does not succeed in the future.

Our engagement efforts in 2024 led to 214 companies within our equity and corporate bond portfolio being addressed on climate-related topics such as net-zero strategies, emissions management and lobbying on climate change. The engagement in 2024 continued with a focus on the practical implementation of the energy transition and decarbonisation. This led to results in 31 instances. One example of engagement on climate change was with a multinational car manufacturer that took steps regarding climate lobbying.

At shareholder meetings, 82 proposals related to climate were on the agenda where we were able to exercise our voting rights. We voted against 62 times and in favour 20 times. For example, we supported a shareholder resolution at a large American sportswear company that called for a clear strategy to address climate change and more transparency from the company regarding reporting the impact of their business activities on the climate. In total, we exercised our voting rights at 1,572 shareholder meetings, voting on 18,419 items.

In 2025, we will take further steps to improve the monitoring of CO₂ emissions, obtain a more accurate picture of emissions within our current portfolio and that of 2019 (the base year), and set up emission intensity controls. In addition, the goals, interim milestones and measures for sustainable investing will be recalibrated as part of the climate change transition plan for Scope 3.

The environmental impacts have been assessed from three aspects. Firstly, we looked at the types of products we use, consume or offer in our services and whether these products could cause significant negative environmental impact. We then mapped the volume of resource flows as an important indicator of negative environmental impact. Finally, we considered the interests of our stakeholders. In this analysis, we consulted internal experts and an external party with specific knowledge of the wood and paper industry, the clothing industry and flower cultivation outside the EU. We did not organise consultations with affected communities.

Our material resource flows include coffins, paper, funeral bouquets/arrangements, workwear and waste. Based on our expenditures and an estimate of the resource inflows, we concluded that coffins and paper are substantial and, from this perspective, have the greatest negative impact on the environment. Funeral bouquets/arrangements are also of importance to our stakeholders. According to the national survey on death in May 2024, 55% of respondents expect sustainable options for their farewell ceremony. In addition to wishing to make sustainable choices regarding what happens to their body after death, coffin choices and the location of the farewell ceremony, 10% of respondents would also like to make sustainable choices regarding flowers. By responding to this expectation, we can encourage customers to make more sustainable choices and influence consumer behaviour on a broader scale. In addition, we aim to make the workwear worn by our funeral service employees more sustainable. For waste material outflows, we assessed the total volume of waste generated and the extent to which waste is separated.

We also assessed financial materiality by looking at the substitutability of the products we use and consume. Our conclusion is that there are sufficient alternatives to mitigate the risk of reduced supply or higher prices. We also see no material opportunities regarding sustainable resource use. 

We are involved in these material impacts through our suppliers who manufacture the products used in our services and handle our waste processing.

For coffins, we aim to use wood that is FSC or equivalently certified. At the same time, we are exploring innovative solutions to offer bereaved families a more sustainable alternative. Our target is thus based on these two pillars. Our goal is calculated based on the number of coffins that meet either of the following criteria: the wood used in the coffin is FSC or equivalently certified, where we currently recognise PEFC certification as an equivalent standard, or the coffin is made from a more sustainable alternative material, which we currently define as coffins made from ecoboard (produced with a sustainable type of glue) or mycelium. In addition, we have set a target to achieve a significant share of 30% sustainable alternatives, the availability of which will increase in the coming years due to product innovations. This target reinforces the importance of such developments. The challenge lies in developing sustainable alternatives together with our suppliers and their subcontractors, ensuring these meet the expectations of bereaved families. It is also essential that price and availability remain reasonably comparable to our existing range of coffins.

No goals have been set to date for funeral bouquets/arrangements as we first wish to investigate whether suitable alternatives are available within our memorial rituals.

For paper, the absolute target to reduce paper use to 150,000 kilograms focuses on reducing print usage, digitalising funeral print materials, and digitalising customer and member communications specifically in the Netherlands.

For workwear we are aiming for a 100% sustainable purchase of textiles. We calculate the percentage of sustainably sourced textiles based on the weight of sustainably purchased textiles relative to the total weight of purchased textiles. We define the sustainable procurement of textiles as those for which a valid sustainability certificate is demonstrably available. We do not distinguish between organic and non-organic resources. For example, we consider recycled polyamide that meets the Global Recycled Standard as sustainably sourced textile. We have not yet established criteria for developing a robust end-of-life programme for workwear

In general, we exclude packaging materials from our targets. For Belgium, we have not yet set targets for waste and for paper required for customer communication due to a lack of aggregated data. The underlying reason is that the procurement function for these categories is decentralised within Belgian funeral homes. We will set the target in Belgium for paper in 2025 and for residual waste in 2026. When setting targets, we exclude the activities in Germany where resource usage is very limited. We also exclude packaging materials when setting goals for material resource flows.

Our goal to reduce residual waste in the Netherlands is focused on increasing waste separation to promote recycling. We calculate the percentage based on the total amount of non-hazardous waste that is not collected separately. The aim is to achieve a maximum of 50% of residual waste. We collect hazardous waste (such as medical waste from the final care of the deceased and fly ash from crematorium filtration systems) that is separated in accordance with applicable laws and regulations. These waste streams are therefore excluded from the target to separate more waste. The non-hazardous waste target applies to Level C of the waste hierarchy. We have not set a target for hazardous waste.

We can only apply circular economy principles within the funeral services chain to a limited extent. For this reason, we have not set targets aimed at increasing circular product design, the share of circular resource use (CMUR), the sustainable use of renewable resources (in line with the cascading principle), or other topics related to resource use or the circular economy. 

We primarily focus on the procurement of sustainable resources. The principles of the circular economy reflected in our set targets are as follows:

• For coffins, we prefer secondary resources such as ecoboard (provided it is produced with sustainable glue) over primary resources (such as FSC or equivalently certified wood).
• For non-digital funeral cards, we prioritise secondary resources (FSC-recycled paper).
• For workwear, we are developing a robust end-of-life programme to be in place by 2030.
• Waste management is aimed at increasing waste separation to promote recycling.

None of the set targets are mandatory, meaning they are not legally required. We have not used scientific methodologies or significant assumptions in setting the targets. There is no link between the set targets and policy objectives, as we have not yet established a policy on sustainable resource use.

In 2025, we will discuss the importance of sustainable resource use and the associated targets with our stakeholders. We aim for a collaborative approach to achieving these targets and expect to further refine them as the transition plan for sustainable resource use is developed.

Several initiatives have already been launched in recent years to make our resource use more sustainable. For example, in 2018 we introduced the Spar Massief coffin, made from 100% FSC-certified wood and with a lower absolute weight. We also introduced the flower band – a band with loops that is placed around the coffin, allowing loose flowers to be inserted. This innovation can save an average of around 200 flowers per funeral. In addition, we are increasingly separating waste at our office and funeral locations as part of our waste management in the Netherlands. Our initiatives to date have not been focused on more efficient material use, increased use of secondary resources (recyclates), the application of circular design/circular business practices or waste prevention.

In 2024, we consulted internal and external experts about which additional actions could be taken to achieve the targets set for 2030. This process revealed that while aiming for sustainable resource use we must first carefully weigh the various interests of our stakeholders.

Bereaved families value having a wide range of choices during the funeral process, including the selection of the coffin, flowers and funeral cards, all of which directly influence resource use. We can encourage them to opt for more sustainable choices, for example, through our product range and pricing strategies. The Spar Massief coffin is the default option under our funeral insurance, meaning many members choose it, and we are responding to the demand for digital funeral cards. Creating sustainable alternatives for funeral wreaths is more challenging so we are also exploring suitable alternatives within our memorial rituals. Within our own operations, and particularly in our customer communications, we can reduce paper use by adopting more digital solutions. It is important to ensure accessibility for those who are less digitally proficient. When it comes to workwear, sustainability is important, but so is the comfort of our employees. Economic considerations also play a role in all of these choices, which is in the interest of our members. In short, there are various interests that are sometimes difficult to reconcile, and finding solutions to these dilemmas deserves our time and attention. The transition plan for sustainable material use that we will develop in 2025 will further elaborate on these solutions.

Coffins
We procure coffins for funerals organised by DELA with bereaved families selecting the product that best meets their personal wishes. In the Netherlands, we offer a standard product range, while in Belgium we provide a free choice. Most coffins are made of wood, but we also offer coffins made from resources such as willow, rattan or mycelium. Our coffins are supplied with interior lining and handles, which can also be made from various resources. Different types of packaging materials are used: protective material for the corners, standard LDPE wrap and (in the Netherlands) 100% recyclable LDPE wrap. In Belgium, we also use bubble wrap, cardboard and a reusable plastic cover as packaging material.

Paper
The paper we use includes customer communication (such as policies or annual statements), funeral print materials, office and funeral location printing paper, and products printed by suppliers on our behalf, including the members' magazine De Kroniek and commercial printing. This paper is delivered either unpackaged or packaged in cardboard boxes. FSC is the most common sustainability certification for wood and paper. Every link in the value chain must hold a 'chain of custody' (chain) certification. 

Workwear
Our workwear consists of garments for on-site staff and funeral directors. We fully replace this clothing every three years, purchasing individual clothing items as needed in the intervening years. We consider cotton, wool and leather to be organic materials. Sustainability certificates are linked to the type of fabric (textile) used to produce the garments rather than to the garment as a whole. Clothing is often delivered on a hanger, individually wrapped in plastic film and packaged in a cardboard box.

Funeral wreaths and floral arrangements
We procure funeral wreaths and floral arrangements for the funerals organised by DELA. As bereaved families and guests purchase the vast majority of flowers for a funeral themselves without DELA's involvement, these are not included in our reported resource flows. The funeral wreaths and floral arrangements we purchase from local florists vary widely as bereaved families select the product that best meets their personal wishes. In the Netherlands, we offer a standard product range, while in Belgium we provide a free choice. These arrangements vary in size, flower type and composition, and may include elements such as floral foam, wreaths, ribbons or small vases. The weight of the flowers compared to the weight of these other materials in a funeral arrangement/wreath is relatively low. Funeral wreaths and floral arrangements are typically delivered unpackaged to crematoria and funeral centres and do not carry sustainability certification.

The results for 2024 are:

The percentage of sustainably sourced organic resources provides insight into sustainable resource use as well as the traceability of sustainable resource procurement. The purchase of sustainable non-organic resources is not included in this percentage. The overall total weight of workwear is relatively low because the clothing was not fully replaced in 2024. Full replacement occurs once every three years.

A part of these resource inflows consists of secondary resources. This includes coffins made from mycelium or ecoboard, as well as packaging materials and textiles made from recycled resources. With no data currently available to substantiate this share, however, we are reporting 0 kilograms (0%) for secondary products as a precaution. 

One of the principles of the circular economy is to use resources as efficiently as possible (cascading use of renewable resources). While this principle does not apply to coffins and funeral wreaths/floral arrangements, it is relevant for paper and workwear. We separate paper at a limited number of locations to support recycling and have yet to implement measures aimed at the reuse or recycling of workwear. 

The results compared to the 2030 targets: 

In addition to sustainable resource use, the traceability of sustainable resource procurement also affects the results for coffins and workwear. We observe that while many of our suppliers are not yet certified, their subcontractors often are. The proportion of 100% FSC or equivalently certified wooden coffins (69%) is higher than the percentage of sustainably sourced organic resources (58%) for coffins. This is because certified coffins such as the Spar Massief are on average lighter in weight than coffins made from other types of wood. This aligns with our aim to use fewer resources. The results regarding paper show that our target of a maximum use of 150,000 kilograms a year is focused on reducing resource use.

Medical waste and fly ash are considered hazardous waste and processed in accordance with applicable laws and regulations. Medical waste is incinerated. Fly ash is removed in drums and stored at designated locations, which is necessary as it can potentially be contaminated with mercury and lead.

The results for 2024 regarding waste (separation) are:

The table below shows the scope and composition of our waste flows (in kilograms):

Waste directed to disposal is waste that we can no longer use or recycle, such as medical waste and fly ash from filtration systems. Waste diverted from disposal is waste that is given a new purpose such as plastic that is melted down to create new products and paper that is recycled. This also includes waste used to generate energy through incineration.

Waste separation is still limited in Belgium and Germany. In the Netherlands, we separate the following waste streams with a view to recycling:

• (Precious) metals left in cremation ashes (e.g., prosthetics) are offered to Stichting Orthometals foundation, which handles metal recycling for crematoriums.
• Other waste separated at various office and funeral locations is collected and processed by our suppliers. This includes confidential documents, plastic, drink cartons, glass, swill, organic waste (GFT) and batteries.

The results compared to the 2030 targets: 

The percentage of residual waste in the Netherlands is the benchmark for our set target of maximum 50% residual waste. 

This approach enables us to have a positive impact on the wellbeing of our customers, particularly policyholders and bereaved families. Our support goes beyond financial assistance. We focus our personal services specifically on the emotional and personal needs of policyholders, bereaved families, visitors and guests. We offer practical support and financial guidance. Our funeral insurance, savings insurance and life insurance policies ensure that members and policyholders can rest assured that their loved ones are financially secure in the event of death.

Our own funeral companies in the Netherlands and Belgium provide respectful and personalised support during the farewell process. We offer a range of services surrounding the funeral, including organising the ceremony, preparing and laying out the deceased, managing the cremation or burial, and providing aftercare for bereaved families. Families can rely on professional support and care.

We continuously develop new services related to 'passing on and remembrance', based on the indications and needs of our customers. This group includes our members, policyholders, bereaved families, and visitors to and guests of our funeral homes, funeral centres and crematoriums. Through these services, we aim to make a meaningful contribution during different phases of life and have a positive impact.

All customers who are impacted by our activities are included within the scope of our reporting.

In addition to everyday interactions, we also hold more formal discussions, for example, through our general meeting. The members of the general meeting contribute ideas on DELA’s overall policy and (future) services. This approach ensures that changes to our business model, strategy, policy or services do not have significant negative impacts on our customers. The board secretary organises the general meeting on behalf of the Executive Board and Supervisory Board, communicates the outcomes and initiates follow-up actions within the organisation.

We also conduct research as part of our dialogue with customers. The online cooperative panel regularly seeks our members' views on current topics and periodically conducts research on industry-related topics.

These stakeholder dialogues provide valuable insights, and we use the results to further optimise our operations, products and services.

For insurance products, we apply the Product Approval and Review procedure to both the development of new products and minor adjustments to existing products. Clear acceptance criteria are set such as customer interests and financial contribution. We also conduct periodic evaluations of the products. The KNVB criteria of the Authority for the Financial Markets (AFM) serves as a guiding principle for our insurance products in the Netherlands and Germany. Our funeral insurance in Belgium complies with the guidelines of the work programmes of the Financial Services and Markets Authority (FSMA).

Our funeral locations operate in a clear and consistent manner while considering local customs and preferences. We use protocols and manuals to ensure compliance with applicable laws and regulations such as the Dutch Burial and Cremation Act. These protocols and manuals are periodically reviewed, and compliance is regularly monitored.

We conduct our funerals in the Netherlands according to the Keurmerk Uitvaartzorg (Funeral Care Quality Mark), which stands for a high standard of service within the funeral industry. In addition, we apply the Greenleave principles for customers who wish to incorporate more sustainable elements into their funeral arrangements.

Our employees implement our personal service policy on a daily basis. Our integrity policy for employees explicitly outlines how to address issues such as discrimination, safety and health. This policy focuses on our staff and how they interact with each other as well as with our customers, bereaved families and guests.

Visitors to our website can find information about our services, specific quality standards and our complaints procedure.

The Executive Board holds the highest level of responsibility within the organisation for the policy on personal service. The Management Board and upper-level management of sectors are responsible for developing and implementing the policy within their specific areas of focus.

The Net Promoter Score (NPS) is seen as an important indicator of our customers' wellbeing and the extent to which impacts are experienced. It is a widely used metric that reflects how likely customers are to recommend our products and services to others. We measure customer satisfaction among both policyholders and bereaved families.

Like any organisation, we strive for the highest possible customer satisfaction levels and review our targets annually within the business planning cycle. The Management Board proposes these targets in their annual plans. The Executive Board then sets the targets and the Supervisory Board approves them. We inform the general meeting about this annually via the presentation of the business plan.

The group-level target for 2024 was 62 and two targets were set for 2025, namely 51 for insurance and 76 for funerals. 

The Executive Board and the Supervisory Board are informed about the NPS results on a monthly and quarterly basis through internal reports. The Management Board and the Executive Board review these results monthly and compare them with the set annual targets. During these discussions, they critically assess progress and, if necessary, implement corrective measures to ensure the organisation remains on track to achieve its targets.

We continuously improve our services for customers in all sectors and countries where we operate. We incorporate input received throughout the year from customers, the general meeting and the cooperative panel. This involves discussing achieved results, received feedback and potential improvement measures in team and departmental meetings.

The initiative was taken last year in Belgium took to develop a funeral quality manual to enhance the customer experience. In the Netherlands, we launched an optimisation programme with a clear focus on providing a better and more consistent customer experience during the funerals we organise. In addition, we introduced a programme for entrepreneurship at our locations, enabling us to respond even better and faster to local needs. These programmes will become an integral part of how we bring personal services to life in practice in 2025.

A new insurance proposition has been developed in Belgium and we expect to be able to sell the first policies by the end of 2025.

In addition, DELA is affiliated with various industry organisations for both its insurance and funeral services businesses. We follow the legislation and regulations of these industry organisations in our complaints policy. The Dutch Association of Insurers promotes a customer-oriented service among insurers, emphasising the importance of this approach in complaint handling too. To encourage a customer-focused approach to complaint handling, the association has established a framework for complaint handling which incorporates the regulations from the code of conduct. The Dutch Association of Insurers expects us to comply with these regulations and periodically assesses our compliance.

We actively offer a listening ear when things go wrong and look for solutions. In the Netherlands, customers can find the complaints procedure for complaints and feedback on our website and in the policy terms and conditions. Special customer feedback coordinators ensure that complaints, compliments and signals are reported and addressed. In Belgium, complaints are handled according to the guidelines set by Assuralia (the professional association of insurance companies). Customers can submit complaints by email or website. In Germany, the complaints procedure was updated in 2024 and documented in the 'Operations Manual', ensuring compliance with the Insurance Supervision Act and European Insurance Distribution Directive. Customers can submit complaints via the website or phone.

Complaint handlers aim to resolve complaints to the satisfaction of the complainant. Customers dissatisfied with the solution can contact our own disputes committee in the Netherlands. This committee consists of four engaged members of the cooperative and provides binding advice to the Executive Board. Another disputes committee is currently being established for our Belgian customers. The process and operation are described on our website. Bereaved families can also contact the Funeral Industry Ombudsman. Dissatisfied policyholders can approach the Financial Services Complaints Institute in the Netherlands or the Ombudsman in Belgium. We have not explicitly evaluated whether customers are aware of the complaints procedures. 

In addition, our business relations have a dedicated contact person within DELA (for example, a location or procurement manager). We discuss feedback from these business relations aimed at optimising our services in our regular meetings, after which we provide feedback to the relevant relation.

Our Whistleblower Policy states that we must not disadvantage whistleblowers and employees who support them during and after reporting a wrongdoing or disclosing a suspected wrongdoing.

Our complaint handling is not only focused on resolving specific issues for the customer in question on an ad hoc basis. We also strive to translate these signals into structural adjustments to our working methods to proactively prevent problems. We therefore define actions with clear ownership to address recurring issues, and report complaints internally on a quarterly basis through customer feedback reports. 

Our commitment to privacy protection is not only a legal requirement but a fundamental value for maintaining strong relationships with customers. We understand that their trust depends, in part, on the careful and secure handling of personal information. Digital threats such as phishing, ransomware, attacks via third parties and insider threats, is high and constant. Ransomware attacks are often accompanied by data theft, which can harm both us and our customers.

The identified negative impact concerns members, policyholders and bereaved families, as their personal data is stored in our systems. For customers within the insurance chain, we particularly manage certain sensitive data such as Citizen Service Numbers (BSN)/National Register Numbers (RN) for reporting purposes, and behavioural and medical data for insurance purposes. We also handle the personal data of (potential and former) employees, as well as those of suppliers and partners. While the potential impact on these groups has not been deemed material, we manage this impact with the stated policies and measures.

We are committed to maintaining adequate standards of privacy protection, following such guidelines as issued by the Dutch Data Protection Authority, De Nederlandsche Bank (DNB), EIOPA, the General Data Protection Regulation (GDPR) and the ISO/IEC 27001 standard, which also applies to our IT suppliers. Our data protection policy is primarily aligned with the GDPR, the leading European legislation. Laws and regulations serve the interests of all stakeholders. Although there has been no specific dialogue with stakeholders regarding privacy policies, policy changes resulting from evolving laws and regulations may be discussed with members at a general meeting.

The Executive Board is responsible for implementing these policies. We provide a comprehensive general privacy statement and a specific privacy statement for employees and suppliers. 

Six data breaches were reported to the authorities in 2024. Customers were informed about three of them. These affected customers received information from us about the nature of the incident, potential consequences, control measures implemented by DELA to prevent recurrence and actions they could take to avoid harm. There were no severe human rights violations involved in these incidents.

Our data protection officer (DPO) can be contacted regarding the processing and protection of personal data. The data protection officer is available to assist customers in the event of suspected privacy violations or incidents. Contact details are published on our website.

Any complaints about how we process personal data generally reach us via the complaints department. Specific complaints about the processing of personal data are forwarded to the data protection officer. It is then possible to submit a complaint to the authorities, as prescribed by the GDPR.

In the case of incidents and data breaches at (sub)processors, the processor reports the incident to the relevant DELA contact person and the data protection officer. This process is contractually established in the processing agreement. DELA then decides whether to notify the authorities and/or the individuals involved.

The data protection officer is responsible for analysing and reporting data breaches to the DELA Management Board. The report is prepared at the end of each quarter. Whether customers are aware of and/or have confidence in our policy is not part of this analysis and report.

Minimising data collection
We only process personal data for which we have a legal basis, namely:

• Contractual necessity: This involves the process of entering into and executing an agreement, which is the legal basis we use most frequently.
• Legitimate interest: This basis is permitted if our interests outweigh the interests or fundamental rights and freedoms of the data subject. The Dutch Data Protection Authority provides guidance against which we assess this processing.
• Legal obligation: We use this basis when we have to process personal data due to a legal requirement, such as compliance with tax legislation.
• Consent: Consent must meet many requirements to serve as a legal basis. All consents obtained are documented in the consent register.

Through instruments such as a Data Protection Impact Assessment and the Data Protection Control Framework, we assess the lawfulness of the legal basis for data processing. The substantive assessment involves input from a privacy officer and no processing will take place without a legitimate basis.

Addressing material negative impacts requires an integrated approach. We align product design, marketing and sales with principles of safety, privacy and transparency. ‘Privacy by Design’ is a crucial principle in this approach, supported by cross-departmental controls. A standard method for this approach will be developed in 2025.

Raising employee awareness
We also believe that a strong awareness of data protection is essential for a safe and reliable working environment. Specific investments are made in training, tools and structured guidance to strengthen our collective learning curve and responsibility in this area. In addition to mandatory and periodically repeated e-learning modules for all employees, we have implemented the following initiatives:

1. Data Academy: This initiative offers employees the opportunity to enhance their knowledge of data, data protection and privacy, combining theory and practice.
2. External training with the International Association of Privacy Professionals (IAPP) to strengthen expertise within our organisation. These programmes ensure employees stay up to date with the latest developments in privacy legislation and best practices.
3. Internal training by the data protection officer in sessions specifically tailored to our organisation that provide insights into the GDPR and translate legal frameworks into practical applications.

Monitoring security risks
In the development and design of our products, processes and systems, we are actively committed to protecting personal data and privacy. By integrating 'Security by Design' and 'Privacy by Design' into our working methods from the outset, we ensure that security and privacy are not added as an afterthought but embedded from the start. This approach means we carefully analyse risks and implement measures that optimally protect the data of customers and partners.

In addition, we have implemented an Information Security Management System (ISMS) to monitor security risks. We also have a 'responsible disclosure' programme for reporting vulnerabilities, are connected to relevant central cybersecurity platforms such as i-CERT and CCB, and collaborate with a cybersecurity company that monitors our IT environment 24/7. This allows us to ensure data is not leaked, respond quickly to incidents and minimise potential damage.

Monitoring
No specific metrics or targets have been set for this impact. We do not intend to establish such metrics but instead focus on preventing and responding to data breaches, minimising data collection, raising employee awareness and monitoring security risks.

Our processes for identifying necessary and appropriate measures and assessing the effectiveness of measures already taken in response to potential negative impacts are integrated into our Data Protection Control Framework. This framework includes monitoring signals, investigating incidents, applying privacy control measures and conducting risk assessments. These activities are part of our regular risk management process, enabling us to actively address and manage privacy-related issues.

Since data breaches are often unique, we evaluate each incident individually to determine appropriate control measures. A consistent documentation process is, however, used to support the organisation’s learning capability. The data protection officer provides feedback to the governing body and data owners when patterns or recurring issues are identified to further refine processes.

The responsible department is accountable for implementing appropriate measures to prevent the recurrence of privacy violations.

Resources
The data protection officer is supported by 20 specialists (privacy officers, privacy managers, GDPR desk staff) in maintaining the highest standards of privacy protection within DELA. The data protection officer oversees compliance with regulations and policies and informs and advises management, line management and employees on the application of relevant laws and regulations.

Privacy officers play an operational role and act as the daily point of contact for employees regarding data protection. They respond to operational (GDPR) questions, investigate and handle data breach notifications, support Data Protection Impact Assessments (DPIAs), and provide guidance during risk assessments related to outsourcing. In advisory processes, privacy officers consult with the data protection officer, present dilemmas if necessary and are the key contacts within the relevant business units for the data protection officer.

Five material impacts were identified across three subthemes in our double materiality analysis: 

1. Working conditions and circumstances: Positive impact on employee well-being through our working conditions and circumstances.
2. Safety & health:
   • Potential negative impact on the well-being of funeral staff due to a disrupted work/life balance.
   • Potential negative impact on the well-being of employees due to mentally and physically demanding work caused by the nature of the business (funeral sector).
   • Potential negative impact on the well-being of employees with customer contact when they face aggression from policyholders, bereaved families, guests and visitors.
3. Diversity: Potential negative impact on the well-being of (potential) permanent employees due to insufficient attention to diversity and inclusion within our operations. This can lead to a less inclusive work environment and a less diverse workforce.

Additional figures regarding our employee demographics can be found in the sustainability statement appendices. See also section 7 of the annual accounts, Average Number of Employees.

Last year saw 581 employees leave DELA, resulting in a turnover rate of 16% relative to the average number of employees. We choose to manage employee turnover excluding non-guaranteed hours employees. Temporary staff often have a flexible and temporary employment relationship. Their turnover is less representative of the stability of our organisation as their contracts are by nature short-term and their departure more often driven by external factors. The turnover rate exluding non-guaranteed hours employees stands at 364 employees, which translates to a turnover rate of 12% relative to the average number of employees excluding non-guaranteed hours employees.

In 2024, the Belgian Management Board organised a 'management team on tour'. They visited various locations over seven afternoons to engage in dialogue with employees on topics such as corporate culture, cross-pollination between insurance and funeral services, and improving collaboration.

DELA also employs more structured forms of engagement with employees. In the Netherlands, the works council plays a central role in employee representation. It has the right to advise on major business decisions, must approve HR policies, can propose topics and has access to all necessary information. This approach ensures that changes to our business model, strategy, policies or services do not lead to significant negative impacts on employees. The works council regularly meets with the CEO and other board members, both formally and informally. It holds six formal meetings a year and engages in ten to twelve informal meetings annually between works council representatives and the Executive Board. There are also two meetings a year under Article 24 of the Dutch Works Councils Act that members of the Supervisory Board attend.

In Belgium, employee representation is divided across three bodies. The committee for prevention and protection at work (CPBW) focuses on employee wellbeing and the prevention of workplace accidents, with ten to twelve meetings per year. The works council addresses financial, economic and social issues, also meeting ten to twelve times annually. One of these meetings is specifically dedicated to reviewing the previous year's figures, known as the EFI meeting. In addition, the trade union delegation negotiates collective labour agreements (CAOs) and discusses individual cases. These bodies, comprising representatives of both employees and the employer, meet monthly, and elections are held every four years to elect employee representatives. 

There is currently no works council in Germany. Due to the current size of the workforce, employees are entitled to initiate the establishment of one.

The secretaries of the works councils (for the Netherlands and Belgium) are responsible for organising the meetings. In principle, Executive Board members and directors should consider the outcomes, while the works council has a supervisory role in this process. Since there is no works council in Germany, the responsibility for initiating dialogue lies with the employees themselves, with the Management Board facilitating this process.

While there was no proactive evaluation of the effectiveness of the employee dialogues mentioned in 2024, no indications that the effectiveness was in doubt were seen. During the assessment of material impacts on employees with the works councils, it became clear that the works council considers the collaboration with DELA on sustainability themes to be satisfactory, and they do not feel that additional activities are necessary. Professionalising stakeholder engagement is scheduled for 2025. 

For employees seeking protection against retaliation, DELA’s whistleblower policy includes clear guarantees that no employee will face negative consequences for reporting misconduct. The channels for handling complaints are systematically communicated to employees during their onboarding and through regular HR publications. These channels are an integral part of DELA's organisational culture and policy, ensuring that employees feel heard and supported. This approach ensures that all employees, regardless of their role or location, have the opportunity to raise issues in a safe and confidential manner.

1. DELA's employment conditions policy offers additional benefits beyond the collective labour agreements (CAOs) for the insurance and funeral sectors in the Netherlands and Belgium. The policy emphasises fair remuneration, transparency and attractive employment terms. In Germany, where no CAO is applied, DELA maintains a similar employment conditions policy in the Netherlands and Belgium.

2. DELA's remuneration policy is based on the strategy, risk appetite, objectives and long-term interests of the organisation. The remuneration policy also considers market competitiveness, ensuring that total compensation and growth opportunities align appropriately with the defined and regularly externally assessed market, job grade and performance.

3. DELA believes in the importance of continuous development for all, enabling employees to enjoy their work more, pursue personal development targets, contribute to team objectives and support DELA's strategy. Employees have opportunities for personal and professional growth through training, education and coaching, helping them enhance their competencies, skills, job satisfaction and motivation.

Intended employees receive (or are referred to) the key policy documents along with their employment contract. This also applies to employees with a service agreement. For other personnel who are not directly employed, the key policy topics are explained during the onboarding process. Managers are the primary stakeholders responsible for helping implement the policy, supported in this role by the HR departments.

The Executive Board is the highest organisational level responsible for the policy on good employment practices. The Supervisory Board ensures that DELA maintains a diligent, controlled and sustainable remuneration policy that aligns with the long-term strategy, risk appetite, objectives and core values. The Executive Board is responsible for implementing the remuneration policy as approved by the Supervisory Board and for making proposals regarding this policy. HR departments are responsible for developing the HR policy in line with the strategy, while managers are responsible for executing the policy.

Employee satisfaction is measured annually among permanent employees in the Netherlands, Belgium and Germany using the employee satisfaction survey conducted by Effectory.

• Follow-up on the employee satisfaction survey:
  While the survey reported a high degree of engagement and a positive work experience, various areas for improvement were identified. Based on the feedback from employees we decided to promote clear and timely communication, ensuring that all colleagues are more involved in strategic changes. A greater emphasis will be placed on providing feedback on suggestions and ideas shared by colleagues. This approach should lead to better insights into the choices made by the organisation and their impact on employees' work. The survey also highlighted that work processes are sometimes unclear or ineffective. DELA will therefore focus on improving these processes to make work genuinely easier. Addressing behaviour remains a key focus within most teams, even though this is part of our core values. We will integrate these core values into team plans and personal development plans.

• Job evaluation survey:
  Partly in response to the employee satisfaction survey, DELA conducted a job evaluation survey in the Netherlands in 2024. It assessed whether DELA adequately considers factors such as emotional and physical demands (also known as work-related burdens) when assigning job levels. The survey confirmed that the assigned job levels are appropriate, and work-related burdens are included in the relevant job profiles. In addition, our salary scales were compared with the general market in the Netherlands and adjustments made to our salary structure based on this analysis.

• Learning and development:
  We encourage employees to bring out the best in themselves every day through team plans and personal development plans. A targeted range of training sessions and workshops support this and we also link learning opportunities to organisational targets. We strive to at least have 75% of permanent employees have a personal development plan in place.

• Recruitment:
  To prioritise employee wellbeing from the outset we consider the various wishes and needs of diverse target groups in our recruitment campaigns. Our approach is based on data collected over the past two years, feedback from current and former employees, and current market trends such as the quarterly updates from Statistics Netherlands (CBS), the annual Employer Brand Survey by Randstad, the annual Employer Image Survey in collaboration with Motivaction, and other relevant information available to connect with different target groups in the labour market. In addition, we have developed an action plan to reduce unwanted staff turnover. This includes exit interviews that provide valuable insights which are translated into concrete actions.

Monitoring
DELA continuously monitors and evaluates the impact of its policies and actions in the workplace, with managers playing an active role in this process. In addition, absence and turnover rates are monitored and reported in monthly and quarterly reports. These results are discussed in management meetings and with HR business partners, who review the data with the management teams to implement targeted actions.

An annual employee satisfaction survey is conducted among all employees, evaluating performance against the eNPS target and the broader impact of our policies. Less positive impacts and negative impacts are actively addressed through improvement programmes at the team, location, sector, country or even group level. Personal development plans and team development plans monitor and evaluate actions and initiatives at the individual and team levels, respectively.

Based on this evaluation, we annually assess whether current actions should be continued or if additional actions are needed.

To ensure good employment practices, DELA employs 47 employees (41 FTEs) in the HR departments across the different countries. External occupational physicians, coaches, training institutes and other specialists are engaged when necessary. 

These factors can negatively impact employee wellbeing, potentially leading to health issues, absenteeism or even premature ending of employment. These impacts stem from our business strategy and model.

This is anchored in three policy documents within DELA on integrity, health and safety/prevention and employability/attendance:

1. Integrity policy
   This emphasises the importance of safe and pleasant working conditions, where everyone feels comfortable and enjoys their work. Respectful interaction is a core principle at DELA.
2. Health and safety/prevention policy
   Promotes employee health and safety and reduces workplace risks. Our approach embraces the concept of positive health and personal responsibility. The policy not only contributes to reducing work-related accidents and illnesses but also enhances employee satisfaction and motivation. Attention to safe and healthy working practices has a positive effect on motivation and productivity and reduces absenteeism
3. Employability/attendance policy
   The basis for this policy is our vision on employability, absenteeism and health. At DELA, we strive to create a work environment that is pleasant and enjoyable. The policy focuses on present employees, absent employees and employees returning to work.

We continuously ensure that employees are aware of the various factors that influence their health and employability. An employee's own behaviour also plays a significant role in this regard. We view health not only as the absence of illness but also as experiencing enjoying one’s work. Both have a positive impact on employee health.

The responsibility for setting up occupational health and prevention services rightly lies with us as the employer. We comply with the law, which requires us to be supported by a registered occupational physician and/or a certified occupational health service for absence management and reintegration processes. We apply the statutory customised approach, aligning with our vision on employment practices. This means we offer tailored support that suits the individual situation of each employee.

HR departments are responsible for developing the personnel policy in line with the strategy, with managers being responsible for its execution.

Nearly all salaried employees are covered by the occupational health and safety management system. Employees of certain subsidiaries, joint ventures and majority shareholdings where DELA does not have operational control fall under the management systems of the respective companies.

Ongoing investments in safety actions and health programmes ensure that employees feel valued and protected. This includes training sessions related to physical strain and handling inappropriate behaviour such as aggression.

To reduce absenteeism, we place a strong emphasis on the ‘self-directed treatment’ model and run various preventive programmes. We also continue to focus on reducing workload in the funeral services sector as employees directly involved in funerals often experience a high workload. Although we’ve seen some improvement, this remains a key focus area. 

For Belgium, a ‘Globaal Preventieplan 2025 - 2030’ is in place. Along with the associated actions, this plan has been communicated to employees and is accessible on the intranet. It addresses areas such as preventing workplace accidents, fire safety, ergonomics and managing psychosocial work stress. The plan includes regular training sessions and periodic inspections. Reports on these topics are regularly shared with the committee for prevention and protection at work (CPBW).

To improve the work-life balance, DELA has implemented a new rostering policy within the funeral services sector. The core principle is to ensure the right balance while maintaining the continuity and quality of services to customers.

To prevent workplace accidents, we use protocols and organise various training sessions focused on prevention and wellbeing. Examples include training on the proper way to carry coffins and on dealing with aggressive customers. The prevention advisor regularly visits locations to assess and advise on working conditions. An audit team also conducts periodic inspections to identify risky situations and ensure that all activities comply with the applicable safety regulations. Ergonomics is a priority among head office employees to prevent physical overload. We also strive to prevent workplace accidents by reporting all incidents, whether large or small, as well as hazardous situations. Employees can report via our HR system, prevention advisors, HR business partners, confidential advisors, managers or anonymously via whistleblower software to ensure appropriate actions are taken.

Recovery mechanisms
Employees and managers are involved in individual recovery processes and, in some cases, supported by an occupational physician and/or an (external) coach. The manager conducts regular check-ins with the employee to monitor recovery, evaluate reintegration and implement any necessary adjustments in the work process. More than half of the managers have completed the ‘self-directed treatment’ and/or 'sustainable conversations' training programmes to support this process. 

HR business partners also serve as a link between employees and management teams. They have the capability to evaluate whether individual recovery processes are progressing well based on feedback from employees. The Management Board is responsible for identifying trends and proposing recovery actions on a broader scale. They are also accountable for assessing the effectiveness of organisation-wide recovery actions. They receive data/input on the effectiveness of these recovery mechanisms from managers. 

Monitoring
The employee satisfaction survey assesses whether staff have a good work-life balance and how they perceive work pressure. We also monitor absenteeism monthly by sector and region to evaluate whether existing actions are effective and/or additional actions are needed. If the results of the employee satisfaction survey, the absence rate or the (unwanted) turnover rate indicate a need for action, additional actions are implemented at the team, location, sector, country or even group level.

Although this potential negative impact could particularly affect employees who belong to a minority group, there is no clear insight into whether individuals with specific characteristics are actually at greater risk of negative impact due to insufficient diversity, equity and inclusion within our organisation. 

A plan is currently in development and expected to be finalised in 2025. A dialogue session was organised in the Netherlands in 2024 to raise awareness about discrimination and inclusion among employees and managers. In 2025, a working group with interested employees will be established to build support for the diversity policy. 

DELA has also incorporated aspects of the policy into various business procedures, including a reporting system through confidential advisors, managers and whistleblower software, as well as dialogue sessions with employees and managers to raise awareness about discrimination and inclusion. There is also an integrity policy which specifies that discrimination and harassment are unacceptable. DELA has established channels to address and discuss such unwanted behaviour. In Belgium, the employment conditions explicitly refer to unwanted behaviour related to age, marital status, birth, wealth, religion or belief, political opinion, trade union convictions, language, current or future health status, disability, physical or genetic characteristic, social origin, nationality, race, skin colour, descent, national or ethnic origin, gender, sexual orientation, gender expression and gender identity. In addition, DELA complies with the legal obligation in Belgium concerning older employees, specifically the CAO104 employment plan for older employees.

Monitoring
An annual employee satisfaction survey is conducted, including questions about the perceived level of inclusion. If the results of this survey indicate a need for action, additional actions are taken at the team, location, sector, country or even group level.

In Belgium, we managed to maintain the high eNPS. As in previous years, DELA was recognised by Effectory as a ‘World-class Workplace’ in Belgium. Companies receive this label when they score above the benchmark average in eNPS and employment practices.

In Germany, the eNPS increased by 2 points, a strong result for a standalone business unit that is establishing its position in the German market.

Incidents/complaints
Employees did not report any complaints or incidents related to diversity, equity and inclusion through formal procedures in 2024. Sixteen employees contacted the confidential advisors with issues related to discrimination and intimidation. None of these reports led to formal complaints procedures.

While employees did not submit any formal complaints or incidents through formal procedures in 2024, approximately 50 employees did contact confidential advisors with various concerns. These reports included issues related to inappropriate behaviour and integrity, although some were simply about needing to talk. None of these reports led to formal complaints procedures.

Workplace accidents
In 2024, there were 55 workplace accidents reported. The accident rate per 1 million hours worked was 12%.

Absenteeism and leave 
The total absenteeism rate due to illness, personal circumstances and other causes in 2024 was 7.4 percent in the Netherlands (2023: 6.7 percent), 7.8 percent in Belgium (2023: 7.5 percent) and 6.9 percent in Germany (2023: 6.7 percent).

All (100 percent) salaried employees at DELA are entitled to family leave (maternity, paternity, parental and care) under social policy and/or collective labour agreements.

Gender distribution in upper-level management
The gender distribution at the upper-level management level (excluding interim employees) is as follows: 

At DELA, we understand that our services are often connected to significant moments in the lives of our customers. We ensure that integrity is always a priority in our corporate culture.

Two material impacts were identified under this topic in our double materiality analysis:

• We have a positive impact on stakeholders through our corporate culture by influencing their wellbeing.
• There is a risk of a negative impact for whistleblowers if we do not adequately protect them and they face negative consequences after reporting misconduct. 

When identifying and assessing our impacts in the area of business conduct, we considered our role in the insurance and funeral services value chains in all three countries where we operate. 

Although we do not accept any integrity-related incidents that could harm our reputation or financial position, they can sometimes occur despite all the precautionary measures. Our incidents policy clearly outlines the steps we take in the event of a (suspected) incident to minimise any negative impact as much as possible.

The integrity policy applies to the value chains and focuses on both our own employees and the parties we work for (customers) and with (suppliers, intermediaries and funeral directors). The works councils in the Netherlands and Belgium were consulted in developing the policy, while the interests of customers are represented by the general meeting, which is also consulted on major policy changes. The integrity policy has been approved by the responsible Management Board.

We place great value on aligning with existing initiatives and standards. Examples include:

• The Code of Conduct for Insurers 2018 (the Netherlands): This includes the core values of the Dutch insurance industry and demonstrates our commitment to balancing business growth with social progress while always keeping customer interests central.
• Competition compliance policy: We follow the policy of the Dutch Association of Insurers to ensure fair competition.

The integrity policy is made available to various target groups. New employees receive a copy along with their employment contract and significant attention is paid to this policy during introduction days and onboarding programmes. In addition, new Dutch policyholders receive a reference to the Code of Conduct of the Dutch Association of Insurers with their policy, which outlines our core values regarding integrity. For Belgian policyholders, a summary of our duty of care policy is included in the ‘General Duty of Care’ brochure, which is easily accessible via our website and the product webpages of the Uitvaartzorg funeral insurance. Our general website also highlights how integrity is a core value for policyholders and suppliers. The customer contact centre supports compliance with these standards, with employees well-informed about our policy and ready to answer questions and provide support. 

Management monitors compliance with the integrity policy via the SIRA process.

Promoting a culture of integrity begins with integrating our core values (engaged, acting with integrity and entrepreneurial spirit) into everyday work. By embedding these into personal and team development plans and discussing them in team and department meetings, we keep the topic front of mind and ensure it resonates within the organisation. Moreover, a culture of learning and performance encourages employees to take responsibility for their own actions and hold each other accountable for behaviour that deviates from our standards. All salaried employees take an oath to act with integrity upon joining the company. The annual employee satisfaction surveys provide insight into how integrity is perceived and practised within the organisation, offering pointers for improvement. These are ongoing actions.

In addition to these initiatives, we organised roundtable meetings for employees in the Netherlands in 2022 and 2023 to reassess our core values and corporate culture. A cultural enrichment initiative was started in Belgium in 2024, with managers and employees collaborating and culture ambassadors being involved. These efforts draw inspiration from the initiatives previously implemented in the Netherlands.

In 2024, we also established an ethics committee in the Netherlands which critically examines ethical issues and the conduct of our organisation. Meetings focus on deepening our norms and values through case studies. The ethics committee provides advice that contributes to sustainable decision-making by management.

In addition, in the Netherlands we initiated a study this year in response to the increased focus on personal safety in the workplace. The research aims to evaluate behaviours within our Dutch organisation. Various mechanisms have been identified as important for psychological security, such as leading by example, encouraging open discussions and expressing appreciation. A plan has been developed to optimise the effectiveness of these mechanisms using existing and new actions. This action plan aligns with ongoing programmes, supplemented with actions to ensure that managers at all levels safeguard psychological security and remain visible to all employees within their respective areas of responsibility.

We also believe in the continuous development and education of our employees, including in the area of business conduct. This is demonstrated by the various training programmes we offer, tailored to the needs of different roles and locations. For example, the Dutch account managers, product managers and quality managers who work for the insurer have all obtained certification related to the Financial Supervision Act. This certificate is essential for their work and enables them to advise customers competently. In the Netherlands, new colleagues at the customer contact centre and the external in-house call centre must obtain the basic certification within four months of employment to ensure they are well-prepared for their role. They also follow the 'permanent education' programme to keep their knowledge up to date. In Belgium, customer contact centre colleagues who interact with Belgian DELA intermediaries follow the FSMA 'basic knowledge' and 'general life insurance' modules. Customer care colleagues who also have direct contact with Belgian insurance customers complete these modules within two years of employment. This ensures they are well-informed and can optimally support customers. Our portfolio managers and analysts pursue the VBA or CFA qualifications for investment professionals, where acting with integrity is a central focus.

Within our funeral services business in the Netherlands, funeral directors undertake training to become registered and obtain the NaVU diploma. This diploma confirms their expertise and their ability to deliver high-quality services. New funeral directors must successfully complete this training within one year of joining. To keep their knowledge and skills up to date, they earn NaVU points annually as part of their permanent education programme. In Belgium, employees in the funeral sector follow a training programme at the in-house Funerals Academy. Specific training requirements and completion timelines have been established for all roles and participation is monitored.

The whistleblower policy states that whistleblowers and employees supporting them must not be disadvantaged during and after reporting misconduct or making a public disclosure of suspected misconduct. A condition for this protection is that employees have reasonable grounds (substantiated by facts) to believe the information accurate at the time of the report.

Reporting and following up on
The whistleblower policy explains how to safely report suspicions of irregularities, including in the area of business conduct, both internally and externally. Stakeholders can report concerns about non-compliant behaviour and business conduct through various channels. We distinguish between misconduct, integrity-sensitive incidents and other irregularities.

Stakeholders can report misconduct via an internal reporting point in the Netherlands and via whistleblower software in Belgium. Reports can come from employees, volunteers, board members, service providers, suppliers and subcontractors. External parties can report via our website. An impartial officer evaluates each report and responds within seven days. If misconduct is identified, we initiate an internal or external investigation and keep the whistleblower informed. Within eight to twelve weeks of the acknowledgement of receipt, we provide information on the substantive assessment and any follow-up steps. If the report concerns the Executive Board or Management Board, the Supervisory Board clarifies the approach to be taken.

Integrity-sensitive incidents which are not considered misconduct are reported by stakeholders to fraud coordinators and contact persons who assess and follow up. An initiative was launched in the Netherlands in 2024 to describe and formalise the process for handling reports of suspected fraud, and this process will be expanded for Belgium and Germany in 2025. The follow-up process varies depending on the nature of the incident. If necessary, we report to the relevant supervisory authority. 

Employees can always approach confidential advisors or their managers for advice and support in cases of (suspected) misconduct, integrity-sensitive incidents and other irregularities. Five confidential advisors are available in the Netherlands, including one external advisor. Three internal confidential advisors are available in Belgium. Before starting their role, all confidential advisors undergo external training from specialised professionals. This provides them with the knowledge, skills and sensitivity needed to optimally support employees in confidential matters.

In addition, employees in Belgium can contact the external service for prevention and protection at work. The follow-up on these reports depends on the situation.

Monitoring
The annual employee satisfaction survey assesses whether employees feel confident enough to speak up about mistakes they have made and the behaviour of colleagues and managers. The vast majority – more than 90% of respondents – expressed a neutral or positive opinion in 2024.

In Belgium, the Prevention and Protection at Work Committee (CPBW) monitors all employees at work, including whether they feel safe to speak up.