ESG Report of the
ENEA Capital Group for
2022

Non-financial risks

Based on the information acquired in the ERM process, the Group Risk Management Department analyzed the enterprise risks1) in consultation with the relevant companies in terms of an adverse impact on the labor, social, environmental, human rights or anti-corruption areas. It was decided that such enterprise risks would be regarded as non-financial risks of material importance to the ENEA Group’s operations that were assessed as key or critical risks for any of the companies, and assessed as low or medium risks within a company but which might refer to more than one company. As a result of the analysis, material non-financial risks were identified in the labor, social and environmental areas. However, the enterprise risk registers of the ENEA Group companies do not include any risks at present that could be assigned to the human rights or anti-corruption areas.

1) According to the definition adopted in the regulations concerning the ERM process, such risks whose likelihood of materialization was assessed by the organizational units as greater than 10% are regarded as enterprise risks.

Risk Risk management methods
Risk of a generation gap − ensuring a motivational remuneration system,
− activities in the area of employer branding aiming to win the best candidates for work, including actions addressed to students and graduates,
− patronage programs in technical and industry schools.
Risk of a loss of competence − recruitment processes,
− training and other forms of employee education,
− ongoing monitoring of turnover rate,
− ensuring a motivational remuneration system.
Risk of accidents at work or occupational diseases − comprehensive and ongoing OHS inspections,
− raising employees’ awareness during initial and periodic training and competitions,
− taking technical and organizational preventive measures and equipping employees with personal and collective protective equipment in order to reduce exposure to work environment factors that are harmful for health,
− monitoring the work environment through measurements of harmful factors at workplaces.
Risk of unavailability of employees as a result of an epidemic − complying with the recommendations of the Ministry of Health and the Chief Sanitary Inspectorate.
Risk of information leaks by unauthorized employees − cooperating closely with the unit responsible for the investor relations at the ENEA Group,
− training in the field of obligations of the issuer and persons having access to confidential information,
− actions in the PR and CSR areas performed only by authorized persons.

Risk Risk management methods
Risk of improper management of information in a crisis situation (failure to adapt the content of the message and communication channels to stakeholders, provision of false information) − applying such communication procedures in crises that mitigate the risk of provision of incomplete or delayed information,
− maintaining efficient communication channels with key business units.
Reputational risk − maintaining proper communication with stakeholders,
− taking pro-environment initiatives.
Risk of social turmoil, deterioration of relations with social partners associated with the pursuit of significant organizational or business changes − active and open dialog with the social stakeholder in respect to information about the company’s activity.
Risk of imposition of penalties as a consequence of establishing or maintaining cooperation with a sanctioned entity − verifying customers on a sanction list in sales processes,
− verifying the concluded contracts / amending annexes in terms of the sanction list,
− updating the sanction list on an ongoing basis.

Risk Risk management methods
Risk of malfunction of FGD, SCR and/or electrostatic precipitators due to a failure of these units, which may cause an increase in atmospheric emissions − monitoring the emissions level as regards environmental pollution on a continuous basis,
− inspecting the installations on an ongoing basis,
− maintaining strategic stocks of spare parts on a continuous basis,
− carrying out tests.
Risk of reducing or ceasing the activity due to a failure to obtain valid environmental decisions and permits − monitoring the laws on an ongoing basis and participating in training in the field of environmental protection laws periodically,
− monitoring decision validity on an ongoing basis,
− ongoing supervision over the manner of implementation and compliance with the conditions specified in the decisions held.
Risk of failure to conform to the terms and conditions of the applicable permissions with respect to:
– water and sewage management (including the instream flow requirements and the permitted temperature of spent cooling water),
– waste management, including sludge from flue-gas desulfurization installations (hereinafter referred to as “FGD”),
– atmospheric emissions, including NOx, SO2 and particles
− controlling the level and temperature of the Vistula River water on an ongoing basis and taking relevant measures in the case of, among others, very low or very high water levels or an increase in water temperature,
− monitoring the emissions level as regards environmental pollution on a continuous basis and performing tests.
Risk of causing damage to elements of natural environment in connection with the operation of or execution of investment projects in the electricity distribution area − monitoring the power grid on a continuous basis and inspecting the transformers periodically,
− equipping new/upgraded facilities with tight oil sumps.
Risk of improper management of hazardous waste − inspecting and updating storage spaces and monitoring waste storage times,
− verifying potential waste consignees and as a consequence concluding contracts on hazardous waste management with entities that hold competencies necessary for the final waste treatment,
− including such provisions in contracts on waste collection that guarantee the provision of such information to the company that is necessary for complying with the obligation to monitor the path of the waste until the moment of their final recovery or neutralization.
Risk of biomass fire − ensuring biomass transport equipment has automatic dust removal devices, which prevent excessive dust concentrations at locations with excessive dust production (dump stations),
− performing periodic inspections of ventilation systems in areas with biomass dust explosion hazard,
− supervising the biomass unloading, storage and transport facilities in the CHP plant on an ongoing basis,
− inspecting the protective systems on a regular basis, upgrading and replacing fire detectors in biomass systems,
− complying strictly with the approved operating procedures and instructions, ensuring the operability of devices and systems that protect people and installations, performing ongoing inspections, training the employees periodically, raising awareness of potential risk, organizing joint exercises with the State Fire Service, and performing periodic interdisciplinary OHS inspections.
Risk of the spontaneous combustion of coal due to oxidation − measuring coal temperature on storage yards,
− replacing coal which was stored longer on yards,
− compacting the rolled coal layers on storage yards and the lateral slopes on yards.
Risk of limitation of electricity generation from bituminous coal due the radical reduction of atmospheric emissions of pollution planned by the European Commission − incorporating combined cycle power units to replace the currently operating 8×200 MW units in ENEA Wytwarzanie,
− developing and implementing a CO₂ emissions reduction concept by incorporating CCS (Carbon Capture Storage) and/or CCU (Carbon Capture and Utlilisation) installations.

Risk Risk management methods
Risk of breaching personal data protection laws and internal regulations − delivering initial and periodic training to employees and associates,
− regular periodic reviews and assessment of personal data processing systems with regard to their security,
− securing personal data processing systems through system security measures (forcing changes of passwords, firewall, antivirus software),
− streamlining processes based on identified incidents,
− ensuring the availability of a Data Protection Officer.
Risk related to violation of competition and consumer protection regulations − introducing measures to improve communication with the consumer (at the stage of sale and offer presentation),
− giving legal and accounting opinions on templates of contracts and terms of contracts as well as marketing materials,
− periodic monitoring and reporting as regards cases of unfair competition and taking corrective measures.

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