Organisational culture, integrity and compliance

NS aspires to be an organisation characterised by an open and safe corporate culture where professional integrity is a matter of course. We attach great importance to results-oriented working practices that are consistent with the norms and values to which we have committed ourselves. To this end, we approach the risks and issues surrounding integrity and compliance in a controlled and balanced manner.

Code of Conduct

The conduct of NS’s employees and the choices they make in their work are crucial to the integrity of the company. Our Code of Conduct forms the basis for the professional conduct of all NS employees, helping them to make the right decisions and deliberate choices in a variety of sometimes difficult situations. A more detailed description of our code of conduct can be found in the Sustainability Report in the chapter on Good Governance.

Integrity Desk and Integrity Issues Reporting Scheme

Employees have several options for reporting integrity issues or abuses (anonymously or otherwise): via the Integrity Desk, via a special app, by email, by telephone or in a one-on-one conversation. The NS Integrity Issues Reporting Scheme (including whistleblower reporting) guarantees that employees can safely report actual or suspected irregularities and that NS will deal with these reports carefully and confidentially. Employees may seek support from one of NS’s confidential advisers if they want to report an integrity violation or for other reasons. External stakeholders can report issues to NS via a special desk. The Integrity Desk and Integrity Issues Reporting Scheme are also described in the Good Governance chapter of the Sustainability Report.

Compliance

NS is committed to conducting its business with integrity and transparency. As a state-owned company, we must also set a good example. That is why we make sure we are 'compliant', in other words that we carefully observe laws and regulations. Primary responsibility for compliant working practices rests with the NS business units themselves. In this context, they are able to draw on the knowledge and advice of teams and departments that have extensive knowledge of compliance, such as NS Legal and QHSE. The Integrity, Risk & Compliance department supervises compliance at NS and reports on its findings to the Executive Board and the Supervisory Board. For further information, please refer to the Good Governance chapter in the Sustainability Report.

Privacy

For NS, the need to handle our passengers’ and employees’ personal data carefully is self-evident. To remain compliant with privacy legislation, NS has set up a privacy structure and governance arrangement. We also constantly seek to train our employees in and raise their awareness of the importance of privacy. We do this through channels such as e-learning modules, training courses and newsletters. Last year we once again appointed ‘privacy champions’: employees who, in addition to their regular work, answer questions and serve as the eyes and ears of the Privacy Office within their business units. At year-end 2025, there were 98 active privacy champions within NS (2024: 101). Together with the Data Protection Officer and Privacy Officers, these privacy champions make up the privacy function within NS.

Privacy by design

Effective and careful data processing starts with privacy by design. This means that we recognise the need to protect the privacy of data subjects right from the initial design phase of a product or service. We also carry out assessments in which we check the impact of data protection. This allows us to identify risks to data subjects and take measures to manage those risks at an early stage.

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