ESRS
[E1- 2] Policies related to climate change mitigation and adaptation

When managing significant impacts, opportunities and risks related to climate change mitigation and adaptation, the PGE Group complies with legal provisions and internal regulations, such as:

Environmental Policy, including the Declaration
on environmental policy
Environmental Management System Model
in PGE CG
PGE Group Strategy until 2030
Strategic Management Regulations
Environmental Context and Planning in PGE CG

Environmental policy (including declaration on environmental policy) – general information

Within the PGE Capital Group, the highest authority responsible for implementing policies related to climate change adaptation, mitigation and energy is the Management Board of PGE S.A. The Management Board plays a key role in decision-making concerning the development and implementation of strategy, sustainable development actions, and environmental regulations aimed at climate change mitigation and adaptation.

The main objectives of the Environmental Policy focus on:

  • defining the general principles, powers and responsibilities in the area of environmental protection at PGE CG,
  • identifying processes and activities carried out within PGE CG that are of key importance for environmental protection, assigning key roles defined in the environmental management process to the appropriate levels of the organisational structure within PGE CG,
  • identifying environmental processes in the individual segments, taking into account the specificity of each segment covered by this Policy,
  • continuously raising employee awareness within PGE CG regarding environmental protection.

All organisational units within PGE CG involved in the environmental protection process implemented in PGE CG are obliged to apply the principles defined in the Environmental Policy. The Management Boards of the companies are responsible for compliance with the requirements of this Policy.

In accordance with the Environmental Policy, the Management Board of PGE Polska Grupa Energetyczna S.A. has also adopted a Declaration by the Management Board of PGE Polska Grupa Energetyczna S.A. on the environmental policy. On the basis of this Declaration, the Presidents of the Management Boards of the PGE CG companies are required to familiarise their subordinate employees with the Declaration, and all employees of the PGE Capital Group are obliged to apply it in practice. Directors of organisational units, in cooperation with the heads of the environmental protection units, are responsible for performing their tasks in compliance with the Policy. The Management Board of PGE S.A. is responsible for the implementation of the Environmental Policy and for ensuring the resources necessary to carry out the objectives and tasks resulting from it. Additionally, Environmental Policy Declarations have been adopted in PGE CG companies that are key to the Group’s operations, including:

  • PGE GiEK S.A.
  • PGE Energia Ciepła S.A.
  • KOGENERACJA S.A.
  • PGE Toruń S.A.
  • Elektrociepłownia Zielona Góra S.A.
  • PGE Energia Odnawialna S.A.
  • PGE Dystrybucja S.A.
  • PGE Ekoserwis S.A.
  • ZOWER sp. z o.o
  • PGE Energetyka Kolejowa S.A.
  • PGE Energetyka Kolejowa Holding sp. z o.o.
  • PGE Energetyka Kolejowa Obsługa sp. z o.o.
  • PGE Energetyka Kolejowa Centrum Usług Wspólnych sp. z o. o.

ENESTA sp. z o.o. (in restructuring) has adopted an individual declaration on environmental policy.

The remaining companies, i.e.  PGE Obrót S.A., PGE Systemy S.A., Energoserwis Kleszczów sp. z o.o., MegaSerwis sp. z o.o., ELMEN sp. z o.o., ELTUR-SERWIS sp. z o.o., BETRANS sp. z o.o., BESTGUM POLSKA sp. z o.o., RAMB sp. z o.o., MEGAZEC sp. z o.o., PGE Gryfino Dolna Odra sp. z o.o., Energetyczne Systemy Pomiarowe sp. z o.o. are not covered by this regulation and have not adopted relevant policies or declarations.

Climate change mitigation and adaptation in internal regulations

The Environmental Policy and the Declaration by the Management Board of PGE Polska Grupa Energetyczna S.A. also address the issue of mitigating the impact of PGE CG’s core operations on the environment, including climate, as well as mitigating the related risks. They describe the approach to pollution, emissions, other impacts, the monitoring systems control, ongoing analysis of environmental parameters, emission reporting, and initiating actions to reduce environmental impact. With regard to reducing greenhouse gas emissions, the provisions of the Declaration on environmental policy set out the following key commitments of PGE CG:

  • commitment to the continuous improvement of actions to protect and improve the state of the environment and to prevent pollution – by implementing high, economically justified technological standards;
  • planning the Group’s development based on modern and environmentally friendly technologies that meet the criteria of the best available techniques (BAT);
  • responsibly fulfilling the requirements related to environmental aspects, including those established by law as well as those resulting from the nature of a given investment;
  • rational and efficient use of raw materials, fuels, electricity and heat;
  • systematic development of energy production from renewable sources;
  • minimising negative environmental impacts through appropriate management of water and wastewater systems and air emissions, reducing the volume of waste generated and using it as efficiently as possible.

With regard to climate change mitigation, adaptation and energy, the Declaration covers the full scope of key operational and geographical activities of the companies that have adopted it. The Declaration takes into account the interests of key stakeholders by including provisions on:

  • raising the skills, awareness and commitment of employees to environmental protection.
  • supporting and participating in the promotion of environmental protection in local and national social initiatives.

The Declaration on the Environmental Policy of PGE S.A. is published on the PGE Group website. Internal stakeholders are informed of the Policy through internal communication channels such as the intranet and newsletters. The policy is also available in the internal document repository.

The organisation is required to comply with the requirements of government administration bodies and other relevant authorities, as well as statutory and regulatory provisions, requirements specified in permits, concessions, licences, orders, rules or guidelines issued by public authorities and court rulings. It also takes into account the requirements and interests of social groups, NGOs, public authorities, customers, and business partners.

PGE Group strategy until 2030

The PGE Group Strategy, which is the overarching document setting out the organisation’s directions and goals, directly addresses climate-related issues by presenting assumptions regarding the Group’s achievement of climate neutrality by 2050. According to the Strategy, investments in low- and zero-emission energy sources and network infrastructure are to serve as the main levers for implementing the plan. By 2030, the share of renewable energy in the Group’s portfolio is to increase and CO₂ emissions are to be reduced, while by 2050, the Group aims to achieve climate neutrality, i.e. net zero CO₂ emissions, and provide 100% green energy to its customers.

  • achieving climate neutrality by 2050, which is a central element of the Strategy and the transformation of the business model;
  • actions for sustainable development – the PGE Group implements ESG elements focused on environmental and social aspects as well as corporate governance. The Group has adopted, among others, an Environmental Policy, a Diversity Policy and other regulations enabling the management of sustainability matters within the Group;
  • defining in the Strategy directions for actions and initiatives related to energy efficiency and the development of renewable energy sources.
  • Infrastructure modernisation – the PGE Group invests in the modernisation and expansion of its distribution network to improve energy efficiency (reduce network losses) and reduce indicators of supply interruptions (SAIDI and SAIFI);
  • Technological innovations – implementation of modern technologies such as smart grids and energy management systems allows for more efficient use of energy resources (minimising the time during which renewable energy sources are curtailed and maximising the available connection capacity);
  • Energy efficiency programmes – the PGE Group implements programmes aimed at improving energy efficiency both in its facilities and for end customers by promoting energy-saving solutions and technologies, such as heat pumps and waste heat recovery.
  • The PGE Group has planned significant investments in renewable energy sources, including offshore wind farms, photovoltaics, and onshore wind farms. By 2030, PGE intends to construct 2.5 GW of new capacity in offshore wind farms, 3 GW in photovoltaics, and expand the portfolio of onshore wind farms by at least 1 GW;
  • Energy storage – as part of the Strategy, PGE plans to develop energy storage systems with a capacity of at least 0.8 GW, which will enable better management of the production and distribution of energy from RES;
  • Decarbonisation – the Group is pursuing the decarbonisation of its generation portfolio through a gradual withdrawal from coal and an increased share of low- and zero-emission energy sources.

The PGE Group Risk Committee, whose purpose is to monitor exposure to risks and to limit the scope of risk to an acceptable level in relation to the implementation of the PGE Group’s strategy and business objectives, oversees the climate risk management process. These risks are analysed both in terms of the impact of climate change on PGE’s operations and the impact of the Group’s activities on the climate.

Strategic management regulations in the PGE Capital Group

The objective of the Regulations is to implement and systematise the strategic management process within the PGE Capital Group in such a way as to:

  • streamline the development and implementation of the PGE CG Strategy;
  • set strategic objectives for key companies within the PGE CG;
  • enable the monitoring of the implementation of the PGE CG Strategy.

The Regulations apply to organisational units within PGE S.A. and key companies of the PGE CG that participate in the strategic management process.

The development and update of the document includes a number of key activities such as defining the scope and timeframe of the strategy, setting the mission and vision, as well as establishing strategic objectives and initiatives. The Strategy is submitted for approval by the Management Board of PGE S.A. and, upon approval by the Supervisory Board, is published, communicated for implementation, and further disseminated both internally and externally.

References to standards or third-party initiatives that the company commits to observe are presented below, including international and EU environmental management systems:

supports environmental protection and the reduction of emissions, taking into account socio-economic needs and the principles of sustainable development. The Environmental Management System, compliant with PN-EN ISO 14001:2015, identifies and monitors the PGE Group’s impact on the environment, ensuring compliance with legal requirements and emissions control. Audits confirm compliance with standards and good management practices, and improvements are implemented where necessary. Considering the key companies of the PGE Capital Group (PGE S.A., PGE GiEK S.A., PGE Energia Ciepła S.A., PGE Energia Odnawialna S.A., PGE Dystrybucja S.A., PGE Ekoserwis S.A., PGE Energetyka Kolejowa S.A.), the ISO 14001:2015 standard has been implemented in 100% of the companies and is certified in most of them, including: PGE GiEK S.A., the District Heating segment (PGE Energia Ciepła S.A. and its companies: KOGENERACJA S.A., Elektrociepłownia Zielona Góra S.A., PGE Toruń S.A.), PGE Ekoserwis S.A., and PGE Energetyka Kolejowa S.A.

PGE Energetyka Kolejowa S.A. undertakes activities to optimise energy consumption and reduce losses, particularly in transformation and distribution. These efforts are formalised by the implementation and certification of an Energy Management System in accordance with ISO 50001.

In addition, two branches of PGE GiEK S.A. – the Opole Power Plant and the Dolna Odra Power Plant Complex – and two branches of PGE Energia Ciepła S.A. – the Wybrzeże and Szczecin CHP plants – have implemented the Eco-Management and Audit Scheme (EMAS). This EU environmental certification system is a tool supporting the implementation of a sustainability culture within the organisation, focusing on efficient resource and energy management. The system includes the publication of performance indicators related to the internal consumption of electricity and heat. According to the EMAS, units are required to annually prepare environmental statements which are verified by an authorised body. These statements serve as additional confirmation that the unit operates sustainably while maintaining high environmental standards, including those relating to climate issues.

Environmental context and planning in the PGE CG

The purpose of this Procedure is to support business management in the PGE CG companies by minimising threats and maximising opportunities that affect the ability to achieve intended results in environmental management, related to external and internal factors relevant to company objectives and stakeholders (in accordance with PN-EN ISO 14001: 2015 and the EMAS Regulation).

Environmental planning at PGE involves the identification and assessment of risks and opportunities related to external and internal factors, as well as stakeholder expectations and compliance obligations. This process also includes the identification and evaluation of environmental aspects and the establishment of environmental objectives, along with their monitoring and performance assessment.

Environmental issues are monitored and assessed as part of the Environmental Management System (EMS) review process. This process is key to ensuring that PGE’s activities are consistent with its environmental policy and for achieving its long-term environmental goals.

Additional policies in selected companies

At PGE GiEK S.A., PGE Energetyka Kolejowa S.A and key companies of the District Heating segment, additional policies consistent with the PGE Group Strategy until 2030 have been developed. These policies aim to facilitate the achievement of climate neutrality and a just transition.

In line with the requirements set out in the Renewable Energy Directive (RED II), PGE GiEK S.A. has implemented a Sustainability Criteria System (SCS) for biomass. To confirm the proper implementation of the SCS, the company has obtained relevant certificates entitling it to use SCS-certified biomass for electricity and heat generation. Current certificates are available on the website of the Oil and Gas Institute.

In 2024, Climate Neutrality Plans were developed and approved for most generation units, defining the path, budget, and timetable for achieving climate neutrality. Based on these plans, a Decarbonisation Plan for generation assets was prepared, aiming to phase out coal by 2030 and reach zero emissions by 2050, ensuring 100% green energy for customers.

The Decarbonisation Plan for generation companies in the District Heating segment (PGE Energia Ciepła S.A. and the companies: KOGENERACJA S.A., Elektrociepłownia Zielona Góra S.A., PGE Toruń S.A.) identifies the best available technologies that will enable the organisation to achieve its climate goals. The transformation is designed in stages, leading to zero-emission generation by 2050 in terms of emissions. The plan also includes estimated expenditures related to the transformation and the planned path and schedule for reaching the climate targets.

An important element of both the Climate Neutrality Plans and the Decarbonisation Plan is the assessment and mitigation of climate threats and environmental protection risks.

Additionally, in the locations of PGE Energia Ciepła S.A. (Szczecin, Kielce) and the location of KOGENERACJA S.A. (Czechnica), the Sustainability Criteria System for Biomass developed by the Oil and Gas Institute has been implemented and certified. This ensures that the biomass burned in these installations comes from sustainable sources and is legally considered zero-emission.

As part of the Declaration on the Environmental Policy for the Railway Energy Services segment, the following elements have been additionally specified:

  • systematic development of low-emission fuel and renewable energy distribution for the railway sector;
  • development of services related to sustainable railway and energy infrastructure.

Since 2020, PGE Railway Energy S.A. has implemented the 2030 Sustainable Development Strategy. The company’s strategy is based on four pillars: expansion of the distribution infrastructure network and maintaining a high standard of service; operational excellence through the introduction of innovations, digitalisation and customer-oriented approaches; Green Railway for Poland; and responsibility as a company – focusing on the needs of external stakeholders, employees, and associates, as well as environmental protection.

Within the 2030 Sustainable Development Strategy, the following are highlighted in the segment:

  • reduction of PGE Railway Energy S.A.’s carbon footprint (zero emissions);
  • reduction of the railway sector’s carbon footprint (zero-emission railway companies);
  • change in the railway’s energy mix, increasing the share of renewable energy;
  • investments in renewable energy sources;
  • improvement of railway energy efficiency – including the establishment of the Railway Energy Efficiency Centre (REEC).
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