Reporting principles

In our report, we discuss the topics that we believe are of material importance and which have been indicated as relevant by our stakeholders. In 2017, we once again decided which themes were of material importance with reference to an online survey completed by internal and external stakeholders.

The process of determining materiality consisted of the following steps:

Step 1: Updating relevant topics
In 2017, our material topics were updated. The first step involved putting together a longlist of 169 topics consisting of various themes that could be relevant for Gasunie. In order to come up with a shortlist, the longlist was scanned against relevant external frameworks such as the GRI Standards, SASB and ISO 26000, internal documents and strategy papers and the annual reports of peers. After this review, a manageable shortlist was put together with the most prominent topics.

Step 2: Defining reporting priorities
We determined the priorities in the shortlist with reference to an online survey in which 34 external stakeholders from different stakeholder groups participated. Internally, the survey was completed by the full Executive Board and three additional key officers from the organisation. In the analysis, the internal and external scores carried equal weight.

Step 3: Drawing up the materiality matrix
Based on this prioritisation, we created the materiality matrix and included it in the chapter ‘Our key themes’. The 6 topics with the highest scores have been included in this annual report as material topics. Together, these topics form the basis of this integrated annual report. The new materiality matrix was submitted to and approved by the CFO and member of the Executive Board.

Reporting policy

In drawing up this report, we followed the Transparency Benchmark Criteria of the Dutch Ministry of Economic Affairs and Climate as much as possible. In addition, the report has been prepared in compliance with the GRI Standards (Core application level) and we apply the Integrated Reporting principles of the International Integrated Reporting Council. Our ambition is to remain among the front-runners in the Transparency Benchmark.

In order to encourage further non-financial reporting, the EU published the EU Non-financial Reporting Directive in 2014 (EU NFRD – 2014/95/EU) This directive was anchored in Dutch legislation in two separate regulations: disclosure of non-financial information and disclosure of diversity policy. The first disclosure requires public-interest organisations with more than 500 employees to provide insight into how they address environmental, social and HR matters, the respecting of human rights and the fight against corruption and bribery in their operations and value chain. This should include policy, results, main risks and control measures, and non-financial KPIs with regard to these areas. The second disclosure requires an explanation regarding the diversity policy for the Executive Board and the Supervisory Board.

The table below shows how we comply with both these disclosure regulations.


Material topic for Gasunie



Energy transition
Footprint reduction

  • The policy pursued: Strategy: CSR focus areas and multi-year plan
  • The results of the policy pursued: Energy transition results; Environmental results
  • The main risks and controlling these risks: Our risk profile; Connectivity matrix
  • Essential non-financial performance indicators: Connectivity matrix

Social and HR matters


  • The policy pursued: Strategy: CSR focal points and multi-year plan; Employees, Safety results
  • The results of the policy pursued: Employees, Safety results, Annexes
  • The main risks and controlling these risks: Our risk profile; Connectivity matrix
  • Essential non-financial performance indicators; Connectivity matrix

Respecting human rights

Socially responsible procurement

  • The policy pursued: Annex 3 – Product and supplier information
  • The results of the policy pursued: Annex 3 – Product and supplier information
  • The main risks and controlling these risks: Gasunie currently has no insight into the specific risks relating to human rights.
  • Essential non-financial performance indicators: Gasunie currently does not apply any specific KPI in the field of human rights.

Fighting corruption and bribery

Corporate governance

  • The policy pursued: Employees (Code of Conduct paragraph); Annex 3 Product and supplier information
  • The results of the policy pursued: Energy transition results; Environmental results
  • The main risks and controlling these risks: Our risk profile
  • Essential non-financial performance indicators: Employees (Code of conduct paragraph and Reporting misconduct paragraph), KPI: No. of incidents of bribery and corruption, reports of ‘suspected misconduct’

Diversity of Executive Board and Supervisory Board

Corporate governance

  • The policy pursued: Annex 5 – Diversity
  • Objectives and results: Annex 5 – Diversity

We report on the most relevant performance indicators (KPIs) that ensure from our strategy. These include indicators in the fields of finance, health, safety and the environment, as shown in the Connectivity matrix and in the ‘Management approach to our material themes’ chapter.


We aim to be transparent about our objectives and how we aim to achieve them. In our annual report, we therefore elaborate on our activities and results, explaining not only what went well, but also what did not go so well and what we are doing to improve matters. We measure our transparency on the basis of our score in the Transparency Benchmark. In 2016, we set our goals for the coming years, placing more emphasis on our position with respect to state-owned companies. We aim to achieve approximately 185 points and to finish at least in the top 30 of all participants.

Transparency benchmark ambition

Total score

Energy, oil & gas subcategory

State-owned companies (33)

2015 financial year

Top 30 (approx. 185 points)

Top 3

Top 10

2016 financial year

Top 30 (approx. 185 points)

Top 3

Top 8

2017 financial year

Top 30 (approx. 185 points)

Top 3

Top 8

2018 financial year

Top 30 (approx. 185 points)

Top 3

Top 8

Our total score for the 2016 annual report was 194 points, which meant we achieved our target of 185 points.

It was announced in December 2017 that the structure of the Transparency Benchmark would be changing from 2018. The frequency of the benchmark will be changing from yearly to every two years. The next edition is in 2019 and relates to the reports from 2018. The approach and implementation will remain the same. Updated criteria will be introduced in 2018, however, with more attention to chain transparency and the Sustainable Development Goals. For the 2017 annual report, due to the lack of official benchmark results, it is not possible to make a comparison with other participating companies.

This report is an annual publication. The current edition relates to the 2017 financial year, which runs from 1 January 2017 to 31 December 2017. The report also includes an account of relevant developments that took place in 2018 before the publication of the report.

For the materiality analysis, we select topics that are relevant to our stakeholders and on which we have an impact as a company. This also helps determine the scope of this report. This report covers Gasunie in the Netherlands, Gasunie in Germany, GTS, GGS and participations such as BBL Company, in which, in terms of capital provision, Gasunie has a majority shareholding of 60%. Figures relating to these business units have been included in the overall figures and results in so far as they are available.

With regard to matters relating to safety, health and the environment, the data recorded in the Netherlands and Germany differs somewhat, which is sometimes due to differences in legislation. Whenever possible, data from the Netherlands and Germany has been combined. Where this was not possible, the data is presented separately. Participations in which we have a minority shareholding in terms of capital provision have not been included in the report. Our subsidiaries GTS and GGS issue their own annual reports, in which their specific results are reported in more detail.

We report on our role as a transporter of natural gas, a supplier of related services, and as owner and operator of the Dutch national gas transport network, but also address relevant internal and external developments that have an impact on our organisation. We have also included in this report topics that are relevant in our value chain, but which we cannot influence directly, such as earthquakes and the changing composition of gas. Safety is one of our top priorities, which is why we have also included a summary of the safety performance of our contractors in this report.

Other performance data, such as that of suppliers, has not been taken into account. Details about acquisitions and disposals are included in line with legal obligations in the report covering the year in which they took place.

Data collection process

In collecting the data for this report, both internal and external sources (such as manuals, management information systems and third-party data) are consulted. The departments bearing final responsibility for executing our key policy themes are involved in collecting the non-financial data for this report. For the most part, these departments were Safety, Finance, HR, Communications and Public Affairs, both in the Netherlands and Germany. The data they provided was verified by our internal audit department as part of their internal auditing activities.

Measuring and registration systems

The environmental data of Gasunie in the Netherlands is generally measured and recorded as follows:

  • Data relating to the use of energy and water is derived from the overviews provided by the suppliers of energy and water at our principal locations. Data relating to the other locations is estimated, based on normal usage and/or third-party invoices.
  • Emissions are mainly registered by the Olympus computer system, developed for registering compressor data. Emissions of CO2, CH4 and NOx are calculated on the basis of the fuel consumption of the machines, which is measured continuously. Each machine has its own emission characteristics, which have been registered in Olympus. The registration is corrected manually before and after operation of the compressors.
  • Data on fugitive emissions is obtained from recent measurements, in accordance with the EPA21 method, and from historical research on emissions at specific types of location.
  • HFC emissions are calculated on the basis of amounts (in kg) recorded in the logbooks at the various locations.
  • All environmental irregularities are registered according to their cause in the Accident database system, from which the reported data is derived.
  • Specifications of raw materials are based on purchasing data, with the exception of the usage of odorant, which is calculated.
  • Specifications of nitrogen are based on purchasing data and on the data recorded at the Ommen and Kootstertille locations.
  • Data in relation to our safety KPIs is registered in our Accident reporting system.
  • General HR data (such as FTE numbers) is taken from SAP.

Environmental data relating to Gasunie in Germany is collected in various ways. These include direct measurements (electricity, water consumption and emissions), indirect measurements (e.g. calculations of CO2 and NOx emissions from fuel gas) and registration (waste collection reported by external suppliers). All data is entered in our environment database. This database is the source of all forms of environmental reporting, including our emissions trading, which is audited and certified each year by an independent third party (the auditing and certification only applies to the emissions trading part). Although we treat our measuring and registration systems with care, we acknowledge that the information provided is, in part, subject to a degree of uncertainty, which is inherent to limitations at the measuring location and with regard to calculation periods.

Changes in definitions and measuring methods

Over the past financial year, no changes took place in the definitions we use for the KPIs. With respect to emissions measurements of fugitive leaks, we are working on making these measurements more accurate. To this end, we compare the emissions measured in accordance with the current (legally prescribed) method (EPA21) with more accurate measuring methods. By doing this, we may be able to make certain proposals in the future for adjusting the legal requirements in order to obtain a more accurate result.


As required by law, our financial statements have been audited by an external auditor. An external auditor furthermore reviewed the sustainability information in our annual report. We have this sustainability information reviewed because we consider it important that reasonable certainty is added to this information for the user of this information. The auditor assesses whether the reported sustainability information has been drawn up in compliance with the GRI Standards (Core application level). The external auditor reports its findings to the Executive Board in an audit report and an assurance report. Where necessary, the Executive Board takes measures to improve the reporting processes regarding non-financial information and sustainability reporting.

The annual report is prepared by the Executive Board and the annual financial statements included therein are audited by the external auditor. The annual report is then submitted for review to the Supervisory Board. Following a positive opinion, they advise the Annual General Meeting to adopt the financial statements as prepared. The annual report including the financial statements is published within a few days after presentation at the AGM.

Management systems

We comply with all national and international legislation in so far as it applies to our company. We also have our own strict requirements: our technical standards are specified in the ‘Gasunie Technical Standards’, and our safety, health and environment standards are specified in our ‘Commitment to Safety, Health and Environment Policy’. In our ‘Code of Conduct’, we explain how we expect our employees to behave with respect to integrity, safety and accountability.

We have a whistle-blower policy (for reporting suspected misconduct) and a counsellor has been appointed to deal with any reports. We have also set up a Complaints Committee to which employees can turn with any complaints. In addition, counsellors are available for various areas, including with regard to undesirable behaviour. Finally, we always make sure we handle with care any complaints that arise from the local communities in which we work.

Our policy with regard to safety and the environment is ISO 14001 certified.
We promote standards within our chain by participating in national and international working groups, such as in the fields of green grids and methane emissions. In these groups, we carry out research and exchange knowledge, with the aim of learning from each other. Since 2016, we have been chairing a Marcogaz working group that studies methane emissions within the gas transport chain.

Embedding CSR policy and accountability

Our CSR policy and activities are fully aligned with our strategic objectives. The head of the Organisation & Strategy department is responsible for the CSR policy.

Business units and departments are themselves responsible for the content and implementation of CSR policy in their focal area. The CSR Task Force has been discontinued because of the establishment of the Coordination Teams under the Executive Board. The Asset Coordination Team bears responsibility for two CSR focal points: footprint reduction and Socially Responsible Procurement. The other two focal points, the energy transition and sustainable mobility, are the responsibility of the Organisation & Strategy department. In 2017, a CSR coordinator was appointed as the point of contact for parties inside and outside the organisation, as the person responsible for monitoring the process and progress in the day-to-day implementation of CSR and as a driver for this topic in various working groups.

The Executive Board is responsible for formulating our CSR policy and objectives, and for CSR policy and performance in practice. The policy is aligned with the Supervisory Board. The Executive Board monitors and evaluates progress and results by means of reports and targets and makes adjustments with regard to material social aspects where necessary. The Supervisory Board supervises all of this, and also monitors the external reporting.