ESRS
[ESRS 2 SBM-3] Material impacts, risks and opportunities and their interaction with strategy and business model

In 2024, the following aspects of biodiversity and ecosystems were identified as significant for the PGE Capital Group:

  • Climate change as a factor directly contributing to biodiversity loss.
  • Changes in land use and in the use of fresh water and seas as a factor directly contributing to biodiversity loss
  • Direct exploitation as a factor directly contributing to biodiversity loss.
  • Impact on the extent and condition of ecosystems caused by land degradation.
  • Impact on and dependence on ecosystem services.

The significant impacts (both positive and negative) of the PGE Capital Group on biodiversity and ecosystems in the context of climate change, resulting from its emission-intensive activities and the scope of partnerships entered into and proprietary programmes implemented, are present throughout the value chain.

Location Segment
The distribution network is located in the following areas and their vicinity:

  • National Parks: Wigry, Biebrza, and Narew, Białowieża, Kampinos
  • Landscape Parks: Warta-Widawka, Łódź Uplands, Bug, Mazowiecki, Chojnów, Spała, Sulejów and Bolimów, Knyszyn Forest
  • Natura 2000 sites: ‘Pradolina Warszawko-Berlińska’, ‘Doliny Przysowy i Słudwi’ and ‘Zbiornik Jeziorsko’
  • Forests: Pisz, Augustów, as well as protected areas of the Bieszczady and Roztocze.
Distribution
PGE Energetyka Kolejowa manages sites across Poland with a total area of almost 4,500 hectares. PGE Energetyka Kolejowa manages sites across Poland with a total area of almost 4,500 hectares. A special place is a small plot of land located in the Biebrza National Park. Its area has been formally excluded from protected status. On the plot, there is a power substation, which is essential for infrastructure. Railway Energy Services
There are protected areas in the vicinity of PGE Energia Odnawialna S.A. facilities, for example:

  • Natura 2000 special areas of conservation (SAC) and landscape protection areas (LPA): The Low Beskids landscape protection area and the East Beskids landscape protection area.
  • Landscape parks (LP) – in the Lesko poviat: The Słonne Mountains Landscape Park, Ciśniańsko-Wetliński Landscape Park, San Valley Landscape Park.
Renewables
In the immediate and broader vicinity of installations in the Conventional Energy segment, the following protected areas are present:

Opole power plant

The nearest protected areas are within 12.5 km of the highest ELO emitter. These are: Stobrawski Landscape Park – 6.9 km; Stobrawsko-Turawskie Forests LPA – 7.63 km and Niemodlin Forests LPA – 11.3 km; ‘Bory Niemodlińskie’ Natura 2000 site – 11.4 km, ‘Łąki w okolicach Chrząstowic’ Natura 200 site – 12.25 km; ‘Grądy Odrzańskie’ Natura 2000 site – 1.62 km.) – in the Lesko poviat:

Dolna Odra Power Plant

In the immediate vicinity of the Dolna Odra Power Plant, there are two partially overlapping conservation sites within the Natura 2000 network. These are:

  • ‘Dolna Odra’ Habitats Special Area of Conservation (under Habitats Directive) – approx. 0.8 km from the Power Plant
  • ‘Dolina Dolnej Odry’ Birds Special Area of Conservation (under Birds Directive) – approx. 0.3 km from the from the Dolna Odra Power Plant
  • ‘Dolina Tywy’ Habitats Special Area of Conservation
  • ‘Jeziora Wełtyńskie’ Birds Special Area of Conservation

Landscape Parks: Lower Odra Valley Landscape Park

Rybnik Power Plant

On the northern side of the Rybnik Power Plant site and around the Rybnik reservoir, there are nature conservation areas in the form of the Rudy Landscape Park. To the south, there is an ecological area of Okrzeszyniec Valley.

The Natura 2000 sites closest to the power plant are:

  • ‘Stawy Wielikąt’ Birds Special Protection Area and ‘Ligota Tworkowska’ – approx. 17 km.
  • ‘Stawy Łężczok (Nędza)’ Habitats Special Area of Conservation – approx. 17 km
  • ‘Graniczny Meander Odry’ Habitats Special Area of Conservation – approx. 26 km
  • ‘Dolina Górnej Wisły’ Birds Special Protection Area – approx. 38 km.
  • ‘Podziemia Tarnogórsko-Bytomskie’ Habitats Special Area of Conservation – approx. 40 km

Bełchatów Power Plant and Bełchatów Lignite Mine

  • The Widawka Valley Landscape Protection Area,
  • Łuszczanowice Nature Reserve,
  • Murowaniec Nature Reserve

Turów Power Plant and Turów Lignite Mine

  • Natura 2000 Special Area of Conservation: Przełomowa Dolina Nysy Łużyckiej – the area is located in the Dolnośląskie Voivodeship, in the Jelenia Góra region, and covers a part of the Nysa Łużycka valley from Trzciniec to Zgorzelec.
Conventional Generation
There are protected areas in the immediate and broader vicinity of the District Heating installations, including, for example: PGE Energia Ciepła Oddział w Szczecinie

In the vicinity of the Pomorzany and Szczecin CHP plants, there are the following Natura 2000 sties:

  • ‘Dolna Odra’ Habitats Special Area of Conservation,
  • ‘Dolina Dolnej Odry’ Birds Special Area of Conservation

Other areas important for the condition of the urban environment and biodiversity conservation include allotment gardens, Bukowa River valley, residential and street greenery, biologically active surfaces accompanying buildings and developed areas, public green areas (squares, parks) and the Odra River with its wetlands.

District Heating
Location Segment
The distribution network is located in the following areas and their vicinity:

  • National Parks: Wigry, Biebrza, and Narew, Białowieża, Kampinos
  • Landscape Parks: Warta-Widawka, Łódź Uplands, Bug, Mazowiecki, Chojnów, Spała, Sulejów and Bolimów, Knyszyn Forest
  • Natura 2000 sites: ‘Pradolina Warszawko-Berlińska’, ‘Doliny Przysowy i Słudwi’ and ‘Zbiornik Jeziorsko’
  • Forests: Pisz, Augustów, as well as protected areas of the Bieszczady and Roztocze.
Distribution
PGE Energetyka Kolejowa manages sites across Poland with a total area of almost 4,500 hectares. PGE Energetyka Kolejowa manages sites across Poland with a total area of almost 4,500 hectares. A special place is a small plot of land located in the Biebrza National Park. Its area has been formally excluded from protected status. On the plot, there is a power substation, which is essential for infrastructure. Railway Energy Services
There are protected areas in the vicinity of PGE Energia Odnawialna S.A. facilities, for example:

  • Natura 2000 special areas of conservation (SAC) and landscape protection areas (LPA): The Low Beskids landscape protection area and the East Beskids landscape protection area.
  • Landscape parks (LP) – in the Lesko poviat: The Słonne Mountains Landscape Park, Ciśniańsko-Wetliński Landscape Park, San Valley Landscape Park.
Renewables
In the immediate and broader vicinity of installations in the Conventional Energy segment, the following protected areas are present:

Opole power plant

The nearest protected areas are within 12.5 km of the highest ELO emitter. These are: Stobrawski Landscape Park – 6.9 km; Stobrawsko-Turawskie Forests LPA – 7.63 km and Niemodlin Forests LPA – 11.3 km; ‘Bory Niemodlińskie’ Natura 2000 site – 11.4 km, ‘Łąki w okolicach Chrząstowic’ Natura 200 site – 12.25 km; ‘Grądy Odrzańskie’ Natura 2000 site – 1.62 km.) – in the Lesko poviat:

Dolna Odra Power Plant

In the immediate vicinity of the Dolna Odra Power Plant, there are two partially overlapping conservation sites within the Natura 2000 network. These are:

  • ‘Dolna Odra’ Habitats Special Area of Conservation (under Habitats Directive) – approx. 0.8 km from the Power Plant
  • ‘Dolina Dolnej Odry’ Birds Special Area of Conservation (under Birds Directive) – approx. 0.3 km from the from the Dolna Odra Power Plant
  • ‘Dolina Tywy’ Habitats Special Area of Conservation
  • ‘Jeziora Wełtyńskie’ Birds Special Area of Conservation

Landscape Parks: Lower Odra Valley Landscape Park

Rybnik Power Plant

On the northern side of the Rybnik Power Plant site and around the Rybnik reservoir, there are nature conservation areas in the form of the Rudy Landscape Park. To the south, there is an ecological area of Okrzeszyniec Valley.

The Natura 2000 sites closest to the power plant are:

  • ‘Stawy Wielikąt’ Birds Special Protection Area and ‘Ligota Tworkowska’ – approx. 17 km.
  • ‘Stawy Łężczok (Nędza)’ Habitats Special Area of Conservation – approx. 17 km
  • ‘Graniczny Meander Odry’ Habitats Special Area of Conservation – approx. 26 km
  • ‘Dolina Górnej Wisły’ Birds Special Protection Area – approx. 38 km.
  • ‘Podziemia Tarnogórsko-Bytomskie’ Habitats Special Area of Conservation – approx. 40 km

Bełchatów Power Plant and Bełchatów Lignite Mine

  • The Widawka Valley Landscape Protection Area,
  • Łuszczanowice Nature Reserve,
  • Murowaniec Nature Reserve

Turów Power Plant and Turów Lignite Mine

  • Natura 2000 Special Area of Conservation: Przełomowa Dolina Nysy Łużyckiej – the area is located in the Dolnośląskie Voivodeship, in the Jelenia Góra region, and covers a part of the Nysa Łużycka valley from Trzciniec to Zgorzelec.
Conventional Generation
There are protected areas in the immediate and broader vicinity of the District Heating installations, including, for example: PGE Energia Ciepła Oddział w Szczecinie

In the vicinity of the Pomorzany and Szczecin CHP plants, there are the following Natura 2000 sties:

  • ‘Dolna Odra’ Habitats Special Area of Conservation,
  • ‘Dolina Dolnej Odry’ Birds Special Area of Conservation

Other areas important for the condition of the urban environment and biodiversity conservation include allotment gardens, Bukowa River valley, residential and street greenery, biologically active surfaces accompanying buildings and developed areas, public green areas (squares, parks) and the Odra River with its wetlands.

District Heating

Until the publication of the Statement, the PGE CG had not conducted an analysis of significant biodiversity-sensitive locations that may be directly affected by the organisation’s activities. The table above identifies sensitive, protected areas, or SAC (special areas of protection) that companies have identified in the vicinity of their locations. In 2025, the PGE CG started preparations for a detailed analysis of the negative and positive impact on biodiversity. These preparations included, inter alia, an analysis of locations relevant in terms of their links to biodiversity and ecosystems, and planning possible new measures to mitigate biodiversity loss. There are also plans to assess the actual and/or possible impacts and dependencies on biodiversity and ecosystems, and to identify the associated risks and opportunities.

From the perspective of negative impacts in other thematic areas relevant to biodiversity and ecosystems (including in relation to land degradation), locations where the PGE Capital Group conducts the following activities should be identified as critical:

Extraction processes in open-pit mining lead to changes in the landscape and land use, resulting in the potential loss of natural habitats and ecosystem fragmentation, as well as a reduction in the capacity of ecosystems to provide ecosystem services such as water purification and oxygen production;

Supply of raw materials, construction of infrastructure, and distribution processes lead to changes in land use or habitat fragmentation (e.g. lines in forest areas), and also possibly affect the quality of ecosystem services (e.g. in the context of pipeline leaks)

Construction of wind farms, both onshore and offshore, and photovoltaic farms requires large areas of land and can lead to a change in their use, with a consequent reduction in the capacity of ecosystems to provide services.

Among the analysed topics, possible impacts were also identified in sensitive areas, i.e. protected areas, due to the proximity of the PGE Capital Group. However, these areas are not covered by the PGE Capital Group’s operational activities. This concerns matters such as:

  • climate change as a factor directly contributing to biodiversity loss,
  • change in land use,
  • change in the use of fresh water and seas as a factor directly contributing to biodiversity loss,
  • direct exploitation as a factor directly contributing to biodiversity loss.

The locations of the different areas are listed in the table above, while the activities undertaken so far for these areas can be found in ESRS E4-3.

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