ESG Report of the
ENEA Capital Group for
2022

Environmental impact management

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Generation and supply of electricity and heat to customers in a way that is safe for the environment and compliant with the law is one of the main priorities for the ENEA Group. It also strives to rationally manage natural resources and to ensure biodiversity and sustainability of environmental processes in its surroundings.

The Group has in place a number of policies and procedures referring to environmental matters. The  ENEA Group Code of Ethics states, among other things, that the company:

takes environmental factors into account when developing new services and products,
invests in solutions satisfying stringent environmental standards,
works on technological solutions to increase production of energy from renewable sources,
makes rational use of energy and natural resources and strives to reduce generated waste and pollution,
initiates and actively participates in educational campaigns for environmental protection and building environmental awareness,
prevents any breakdowns that may be dangerous for the environment.

The commitment to sustainable development and natural environment is also embedded in the Code of Ethics for LW Bogdanka Group and ENEA Group Compliance Policy, which among others requires the Group to:

  • take actions to minimize emissions of pollutants and to ensure reasonable management of natural resources,
  • undertake initiatives to retain the balance between the Group’s operations and the natural environment,
  • carry out capital expenditures using environmentally friendly technologies,
  • support renewable energy sources,
  • cooperate with environmental organizations.
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The ENEA Group Procurement Policy contains a rule that, when selecting suppliers of products and services, non-price criteria should be taken into account, including environmental factors such as energy efficiency of the subject of contract. However, bid evaluation criteria are defined individually for each tender procedure and selected environmental aspects are included only when deemed suitable for the subject of contract.

At the same time, contracts with all suppliers contain an undertaking to observe the provisions of the ENEA Group’s Code of Conduct for Contractors, which contains the Group’s expectations, among others in respect to environmental protection.

The ENEA Group Communication Policy contains provisions stating that the Group’s communication is conducted in a manner that promotes environmentally friendly values and that the Group’s sponsorship activities will focus, without limitation, on the domain of environmental protection.

The individual companies have and update on an ongoing basis their own policies, procedures, instructions and regulations, which are suitable to their unique character, obligating them to protect the environment and use it in a sustainable way. In addition, some of the principles, e.g. the ones setting out the requirements for handling the waste produced, must be observed by external entities performing work on the sites of and for Group companies.

Additionally, the Group companies apply methodologies for monitoring and documenting specific environmental impacts and effects of their pro-environmental activities.

Selected due diligence policies, standards and procedures in the area of environmental management in selected ENEA Group companies

  • ENEA S.A. Environmental Policy
  • Policy of Integrated Quality, Environmental and OHS Management System at ENEA Wytwarzanie Sp. z o.o.
  • Book of the Integrated Quality, Environmental and OHS Management System consistent with the requirements of the standards PN-EN ISO 9001:2015, PN-EN ISO 14001:2015 and PN-ISO 45001:2018
  • Procedure “Supervision over legal and other requirements”
  • Procedure “Periodic evaluation of compliance with legal and other requirements”
  • Procedure “Identification and evaluation of environmental aspects”
  • Procedure “Monitoring of environmental effects of the activity”
  • Procedure “Identification of potential emergencies and responding to their occurrence at ENEA Wytwarzanie sp. z o.o.”
  • Rescue plan in case of a threat to life and human health and property or the environment at ENEA Wytwarzanie sp. z o.o. in Świerże Górne (Kozienice Power Plant)
  • Procedure “Goal management”
  • Procedure „Management review, analysis and improvement” and Other detailed procedures and instructions governing conduct setting out the principles of performing operations that impact the environment, monitoring, performing measurements and exercising metrological oversight over devices used to monitor the effects of environmental activity
  • Environmental Management System Policy and the following procedures based on this policy:
    • Supervision over documentation (SZŚ)
    • Supervision over records (SZŚ)
    • Process monitoring (SZŚ)
    • Goal management (SZŚ)
    • Internal audits (SZŚ)
    • Handling non-compliance – corrective actions (SZŚ)
    • Periodic evaluation of compliance with legal and other requirements (SZŚ)
    • Management review (SZŚ)
  • Procedure PŚ-4.3-01 “Identification of environmental aspects”
  • Procedure PŚ-4.4-01 “Responding to danger and failure”
  • Procedure PŚ-4.4-02 “Waste management”
  • Procedure PŚ-4.5-01 “System of monitoring and measuring parameters affecting the environment”
  • Quality instruction QI-7.5-11 “Program for prevention of severe industrial accidents relating to the storage and use of hazardous substances and materials at the Zachód Heat Plant”
  • Internal instructions on monitoring and reporting CO₂ emissions:
    • Instruction I-OŚ-01 “Management of records and documentation”
    • Instruction I-OŚ-02 “Determination of changes affecting the allocation of emission allowances for installations”
    • Instruction I-OŚ-03 “Calculation of CO₂ emissions”
    • Instruction I-OŚ-04 “Quality of the information system used for data flow activities”
    • Instruction I-OŚ-05 “Estimation of fuel consumption during a belt weigher and gas flow meter breakdown”
    • Instruction I-OŚ-06 “Monitoring of outsourced processes”
    • Instruction I-OŚ-07 “Identification of installed devices used to determine data values”
    • Instruction I-OŚ-08 “Staff management for ETS purposes”
    • Instruction I-OŚ-09 “Evaluation of the adequacy of the monitoring methodology plan/Evaluation of the adequacy of the monitoring plan”
    • Instruction I-OŚ-10 “Management of data flow activities”
    • Instruction I-OŚ-11 “Implementing corrections and rectifying measures”
    • Instruction I-OŚ-12 “Supervision over metering equipment for monitoring CO₂ emissions”
    • Instruction I-OŚ-13 “Internal reviews and validation of data”
    • Instruction I-OŚ-14 “Uncertainty assessment”
    • Instruction I-OŚ-15 “Analysis of CO₂ emission monitoring risk”
    • Instruction I-OŚ-16 “Analysis of the risk of the PMM monitoring methodology plan”
    • Instruction I-OŚ-17 “Monitoring of basic data and audit activities related to the application for free allocation of CO₂ emission allowances”
  • Biomass purchasing policy
  • sustainable development Criteria System Book (SDC)
  • Environmental Management System Policy and the following procedures based on this policy:
    • Supervision over documentation (SZŚ)
    • Supervision over records (SZŚ)
    • Process monitoring (SZŚ)
    • Goal management (SZŚ)
    • Internal audits (SZŚ)
    • Handling non-compliance – corrective actions (SZŚ)
    • Periodic evaluation of compliance with legal and other requirements (SZŚ)
    • Management review (SZŚ)
  • Procedure „Identification of threats and determining how to respond to environmental emergencies at ENEA Ciepło sp. z o.o. – Białystok CHP Plant Division”
  • Procedure „Prevention and reduction of the impact of emergencies on the environment at ENEA Ciepło sp. z o.o. – Białystok CHP Plant Division”
  • Procedure “Conduct in the event of environmental emergencies at the Białystok CHP Plant”
  • Procedure “Monitoring CO₂ emissions in the Białystok CHP Plant”
  • Instruction on the organization of rescue operations at the site of ENEA Ciepło sp. z o.o. – Białystok CHP Plant Division
  • Instruction on managing dangerous and hazardous substances and mixtures
  • Instruction on handling waste at the Białystok CHP Plant
  • Instruction “Waste management”
  • Procedures referred to in the CO₂ emissions monitoring plan
  • Procedures referred to in the CO₂ monitoring methodology plan
  • Environmental Policy
  • Company Environmental Pollution Bank Program SOZAT
  • Procedure for registering power devices containing at least 6 kg of SF6 gas and operations performed on them
  • Procedure for management of dismantling materials and waste in ENEA Operator sp. z o.o.
  • Waste management at ENEA Oświetlenie sp. z o.o.
  • Procedure for identification and evaluation of environmental aspects 
  • Environmental monitoring procedure
  • Environmental Management Program 
  • Policy of the Integrated Quality, Environmental and OHS Management System with related environmental procedures
Environmental impact of the ENEA Group

All environmental impacts of the Group are monitored and minimized by the units responsible for environmental protection within companies. They are mitigated also through Circular economy activities promoting optimization of resource consumption. However, even though all legal requirements are met and due diligence exercised, it is still impossible to completely eliminate the impacts of mining and generation activities on the environment; therefore, corrective measures are taken and/or compensation is paid as necessary. The firm also runs a number of diverse social projects targeted at local communities.

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ENEA Group’s operations may expose local communities to e.g.:

  • restrictions in access to water,
  • destruction of biodiversity in places where mining and generating units are located,
  • production of combustion waste (ash, slag),
  • production of large quantities of mining waste,
  • withdrawal and discharge of considerable quantities of water from the Vistula river for cooling purposes,
  • subsidence of land caused by coal mining using the top coal caving method, which may lead to degradation of arable land,
  • impact of the mining operations on water management (among others discharge of mineralized mine water to the Świnka river),
  • impact of linear construction projects on the landscape of the neighboring agricultural and forest areas,
  • disruption of the morphological continuity of rivers through the use of damming of water for hydroelectric purposes,
  • emission of dust and gas pollution from fuel combustion installations (Kozienice Power Plant, Połaniec Power Plant, Białystok CHP Plant),
  • impact related to the transportation (exhaust fumes, noise, dust).

We are taking all the necessary measures to reduce the likelihood of a serious failure of the Połaniec or Kozienice power plants, mainly by maintaining the technical infrastructure in good condition and by adhering to the proper procedures. The special care exercised in this respect is due to the fact that hazardous substances are used in these plants.

The company does not exert environmental impact entailing above-average use of resources shared with local communities, or influence on shared resources.

Compliance with environmental regulations

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The activities of Group companies are conducted in strict compliance with the accepted internal regulations, general provisions of law as well as the content of the necessary permits and administrative decisions, such as the right to release emissions into air, decisions on environmental conditions of a permit to carry out a project, or water permits.

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significant non-financial penalties or sanctions imposed on ENEA Group companies for non-compliance with environmental protection laws or regulations in 2022
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Climate policy and oversight of climate-related issues

The individuals responsible in the ENEA Group for managing its climate impact is the Vice-President of the Management Board for Operational Affairs, Mr. Marcin Pawlicki and the Vice-President of the Management Board for Strategy and Development, Mr. Lech Adam Żak. By the publication date of the Statement, the method of oversight of the Supervisory Board over climate matters has not been agreed upon. Also, no committees have been established to monitor and supervise over the progress in the implementation of climate-related goals and tasks. The unit monitoring the Group’s climate-related activities is the Climate Transition Office at the Group Strategy and Development Management Department.

Work is currently underway to prepare a comprehensive climate policy to be pursued by all ENEA Group companies. The document will identify the directions, in which the Group will develop in order to minimize climate change as much as possible. The work on the policy is slated for completion in 2023.

The ENEA Group Climate Policy will clarify the goals to minimize climate change (along with indicators for their fulfillment) and systematize the measures to achieve them. It will detail the roles and responsibilities of individual organizational units and Group employees in the area of climate impact management and adaptation to climate change. It will be used as a tool to build and consolidate awareness of climate responsibility within the Group.

Lech Żak, Vice-President of the ENEA S.A. Management Board for Strategy and Development

We discuss our approach to managing climate risks and opportunities in the section entitled Management of non-financial risks.

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