Governance & ethics

At HeadFirst Group, responsible governance and ethical behaviour are the foundation of our strategy and our long-term success. We maintain a clear governance structure in which our organisational chart, strategic goals, and the OGSM (Objectives, Goals, Strategies, Measures) methodology ensure alignment and accountability across all departments. Progress is monitored via our OGSM process, allowing for data-driven insights and timely decision-making.

Our governance model integrates essential policies on business continuity, data protection, quality and information security, and risk management. Two of our most material topics within this ESG pillar are data protection, privacy and cybersecurity, and political engagement. In addition, we consider corporate citizenship, ethics, anti-bribery, and responsible supply chain behaviour as critical foundations of good governance.

Ethical Conduct and Integrity

We believe that ethical conduct must be embedded in every aspect of our operations. This is reflected in our Code of Conduct and Ethics, Anti-Bribery & Corruption Policy, which apply to all employees, management, and third-party partners. These documents outline our expectations in areas such as integrity, fraud prevention, fair competition, conflict of interest, and anti-corruption.

We maintain a zero-tolerance policy for corruption and bribery. Facilitation payments, kickbacks, and other unethical business practices are strictly prohibited. All employees receive ethics training during onboarding and participate in annual refresher sessions. Breaches of ethical policies are addressed promptly and may result in disciplinary measures.

We also extend these expectations to our supply chain through our Code of Conduct for Partners. All suppliers must agree to and sign this Code as part of our procurement process. It outlines standards for human rights, labour practices, environmental sustainability, anti-bribery, and safe working conditions. If violations are detected, HeadFirst Group will provide support to help the partner improve, but continued noncompliance may result in termination of the partnership.

We also commit to fair competition and do not tolerate anti-competitive behaviour, such as collusion or abuse of market position. These principles are embedded in our Ethics and Anti-Bribery Policy, which applies to all staff and management.

Political engagement

We believe in fair labour laws that support inclusive and balanced participation in the labour market. Therefore, HeadFirst Group actively engages with policymakers, parliamentarians, ministries, and stakeholders to shape effective labour legislation, especially regarding the self-employed.

In 2024, we co-authored the report “An international perspective on self-employment legislation: What the Netherlands can learn from other countries” with ONL voor Ondernemers and ZiPconomy. Following the publication, we organised a roundtable discussion for Members of Parliament and policy advisors. At the time of writing, four political parties (VVD, D66, CDA, and SGP) have published a legislative proposal inspired by laws and regulations from Belgium.

We also contributed to parliamentary debates with position papers and shared insights from our survey of over 1,200 self-employed professionals on the end of the enforcement moratorium (per January 2025).

Additionally, we hosted webinars and roundtable sessions for clients, suppliers, and professionals to translate these complex developments into practical implications. We also closely monitor and engage with developments related to the upcoming VBAR legislation, which aims to clarify employment classifications in the Netherlands. We see it as our responsibility to inform our stakeholders and help them prepare.

Data protection, privacy, and cybersecurity

We remain committed to protecting the personal data of our employees, customers, and suppliers. Data minimisation continues to be a key principle in our approach — by only collecting the data we truly need, we reduce our exposure and enhance privacy by design. For example, when someone registers in Striive, we still only request the most essential information. Additional details are only collected if and when an assignment proceeds.

Raising and maintaining awareness of the General Data Protection Regulation (GDPR) and broader data protection principles remains a focus. Over the past year, we continued to provide targeted training and practical guidance to embed privacy and security awareness throughout the organisation.

Our goal is to prevent security and privacy incidents as much as possible. When an incident occurs, we conduct a thorough root cause analysis (RCA) and implement improvements to prevent recurrence. In the past year, we experienced a small number of minor information security incidents. These were resolved quickly and had no impact on business operations. 

HeadFirst Group defines an information security incident as any event that compromises the confidentiality, integrity, or availability of information, systems, or services — including data breaches involving personal data. We operate under a certified ISO/IEC 27001:2022 framework, and all incidents are recorded, reviewed, and analysed as part of our ISMS. This report only includes incidents with external impact or relevance. No such incidents were recorded in the past year. 

We also successfully transitioned our ISO/IEC 27001:2013 certification to the updated 2022 version, demonstrating our continued commitment to international information security standards. As part of this transition, we expanded the scope of our certification to include ProUnity.

In addition, we have taken the proactive step to align with the requirements of the NIS2 Directive. Although not yet mandatory for us, this decision ensures that our cybersecurity posture is in line with the evolving regulatory landscape and the expectations for essential and important service providers in the EU.

We also closely monitor developments in artificial intelligence. While AI offers promising opportunities to improve processes and services, we are equally attentive to the potential risks it introduces — particularly regarding data protection, model transparency, and ethical use. We aim to adopt AI responsibly, balancing innovation with our commitment to security and privacy.

Focus areas and actions

HeadFirst Foundation

As part of our commitment to responsible business practices, we launched the HeadFirst Group Foundation in 2023. The Foundation coordinates our charitable donations, volunteering initiatives, and corporate sponsorships. Its mission is to foster a sustainable and inclusive society by supporting environmentally friendly initiatives and improving quality of life for all. Our work is guided by four pillars: Environmental, Social, Ethics, and Quality of Life. All employees receive dedicated volunteering days, which can be used for activities aligned with our ESG goals.

In 2024, we donated a total of €162,500 to different initiatives, including:

Teamwerk Participatiediensten (€15,000)
Teamwerk Participatiediensten supports people with poor job prospects through personalised coaching and employer partnerships. Our donation enabled them to offer additional guidance in 2024, including to a single mother who, with their support, found paid employment and regained stability.

JINC (€12,500)
Workshops and career inspiration for underprivileged youth through initiatives like 'Boss of Tomorrow' and job application coaching.

Koffiedroes (€135,000)
The “Coffee Grounds Project” is a unique collaboration between HeadFirst Group, the Municipality of Enschede, the University of Twente, and social enterprise DCW, offering eight people from a sheltered employment programme a sustainable job. In a newly created department at DCW, coffee grounds are collected, dried, and transformed into biodegradable flowerpots using a technique developed with the university — making the project both sustainable and circular.

Certifications and Continuous Improvement

HeadFirst Group maintains ISO 27001 (information security), ISO 9001 (quality management), and ISO 14001 (environmental management) certifications. These standards form the foundation of our integrated management system, supporting our ongoing commitment to compliance, continuous improvement, and operational excellence.

We are proud to report that no non-conformities were identified over the past two years during external audits for ISO 9001 and ISO 14001. In March 2025, we successfully completed both a scope extension and a transition audit for ISO 27001. The audit identified only three minor non-conformities —a strong outcome in such extensive assessments— and all have been promptly resolved. These results reflect the maturity of our processes and the strong alignment of our daily operations with internationally recognised best practices. 

Corporate Sustainability Reporting Directive (CSRD)

Over the past three years, HeadFirst Group has taken proactive steps to prepare for compliance with the CSRD. In 2024, we partnered with the ESG platform Master Sustainability Today to support the structured collection, validation, and governance of CSRD-relevant data. This initiative enables us to build a strong foundation for reporting both qualitative and quantitative disclosures under the ESRS.

Despite the introduction of transitional measures and timeline adjustments under the EU’s Omnibus Directive, we continue to move forward at full speed. Our ambition is to publish a report in 2026 (covering the financial year 2025) that is as aligned with CSRD and ESRS requirements as possible. While full compliance may not yet be achieved at that point, we aim to deliver a report that demonstrates transparency, accountability, and meaningful progress toward meeting all CSRD obligations.

Policies, Certifications and External Commitments

As part of our ambition to not just comply, but to lead in sustainable business practices, we underpin our ESG policy with formal certifications, adherence to international standards, and independent verification. Transparency and reliability are core principles of our sustainability reporting, and we continue to strengthen our foundations through alignment with globally recognised frameworks.

Certifications and standards
HeadFirst Group holds several key certifications that demonstrate the maturity and robustness of our ESG management systems:

• EcoVadis Gold Rating – In 2024, we were awarded an EcoVadis Gold Medal, placing us among the top 5% of companies assessed worldwide for sustainability performance.

• B Corp Certification – Since 2025, HeadFirst Group is officially B Corp certified, confirming that we meet high standards on social and environmental performance, accountability, and transparency.

• ISO 14001 – Environmental Management System, audited annually by DNV.

• ISO 27001 – Information Security Management System, audited annually, by DNV.

• ISO 9001 – Quality Management System, ensuring our processes meet high standards for service delivery and continuous improvement, audited annually by DNV.

• ISO 14064 – We report our CO₂ footprint in accordance with this internationally recognised standard. Annual calculations are independently verified by DNV.

• VCU Certificate – Applies to our entity Source Flex Solutions, ensuring compliance with safety standards for temporary employment agencies, audited annually by DNV.

• SNA (NEN 4400-1) – Demonstrates compliance with Dutch labour legislation and good employment practices across five entities. Audited twice a year by Cicero.

• Bovib quality mark – applies to our entity FastFlex B.V., confirming its compliance with financial integrity, tax legislation, and legal requirements across the hiring chain. Audited on an annual basis by Normec.

• BREEAM-NL Nieuwbouw en Renovatie ‘Excellent’ – Certification for our head office in Hoofddorp, confirming its high sustainability performance during the construction phase.

International Frameworks and Endorsements

We are committed to aligning our sustainability efforts with international frameworks and initiatives. These include:

• Science Based Targets initiative (SBTi) – Since 2022, we have committed to reducing our emissions in line with the 1.5°C pathway. Our listing is published on the SBTi website.

• European Sustainability Reporting Standards (ESRS) – We are preparing for CSRD alignment using ESRS as a guiding framework.

• Carbon Disclosure Project (CDP) – We participate in CDP and submitted our second disclosure in 2024.

• SER Diversity Charter – We signed the Dutch Diversity Charter in 2022 and report annually on progress made in our D&I action plan.

• Responsible Business Alliance (RBA) – We are listed as a participant and support the shared responsibility for due diligence in global supply chains.

• FSQS-NL by Hellios – Registration on this supplier qualification platform supports transparent and responsible sourcing.

• HeadFirst Group supports the principles of the United Nations Global Compact on human rights, labour, environment and anti-corruption, and is currently exploring formal participation.

In addition, we conduct internal RI&E (risk inventory & evaluation) assessments and provide policies and training to ensure health, safety, and wellbeing across our organisation.

Commitment to Continuous Improvement

By embedding these standards and commitments into our operations, we strengthen our ability to deliver measurable ESG impact and long-term value. These frameworks not only guide our current actions but also shape the way we adapt to new regulatory requirements, stakeholder expectations, and sustainability risks.

Trends and analyses

In 2024, no whistleblower reports, bribery notifications, or critical data or security incidents were recorded. We recognize the importance of clear reporting lines and ongoing awareness, which we evaluate annually to ensure accessibility and trust.

The number of active certifications and quality marks rose to nine, reflecting our commitment to verified standards across ESG domains. While 45% of professional suppliers have signed our Supplier Code of Conduct, we aim to increase this percentage in 2025 through targeted engagement and onboarding efforts. 

Charitable donations more than doubled in 2024, from €70,000 to €162,500, demonstrating our growing contribution to social impact initiatives. Volunteer hours, however, declined. This was largely due to the absence of a large-scale event such as the one organised in 2023, which had enabled broad employee participation. We recognise the importance of accessible volunteering opportunities and intend to facilitate such initiatives again to ensure employees can make full use of their dedicated volunteering days. Despite the overall drop, hours devoted to JINC programmes increased significantly highlighting continued employee engagement with impactful causes. 

Ethics and sustainability training remains part of both onboarding and annual refreshers, embedding responsible conduct into the core of our operations.