In 2024, the internal process for reporting non-financial data to support the preparation of the Sustainability Statement was updated in response to an expanded scope of work – both in terms of the volume of data to be reported and the number of Group companies involved in the process.
For the development of sustainability disclosures, the PGE Group decided to develop a new model for the preparation and reporting of non-financial data, building on past experience.
The role of coordinating non-financial reporting was assigned to the ESG Division within the Investor Relations and ESG Department at PGE S.A. In addition to coordinating the process, the ESG Division supported Group companies in data collection – through training sessions, the development of reporting tools, and the preparation of guidance materials.
As part of preparations for sustainability reporting for the year 2024, internal analyses were carried out to identify and mitigate potential risks associated with the reporting process.
At the same time, the Group undertook actions aimed at mitigating these risks.
At every stage of the process, the PGE Group identifies and analyses potential risks while simultaneously planning and implementing mitigating measures. During the cooperation with an external adviser to prepare the PGE CG for CSRD reporting, risks related to sustainability disclosures were identified. These risks were discussed during meetings with the adviser and among internal experts, followed by the development of proactive actions to prevent them.
The reporting process is subject to oversight and control mechanisms equivalent to those applied in periodic reporting.
Internal procedures include established rules for reporting, information policies, and related areas.
To address identified risks, the Group undertakes preventive measures, including training sessions for management and employees involved in the reporting process — both within PGE S.A. and across the Group’s companies. Data collection is supported by the use of structured templates containing built-in aggregation formulas, and the process is carried out with the involvement of experts who have participated in non-financial reporting in previous years. As part of the collaboration, the adviser assessed the feasibility of introducing IT solutions. Based on this assessment, a solution was selected that minimised risks associated with implementing entirely new systems across all Group companies – including risks related to working in an external cloud environment and vendor-related risks.
At the current stage of implementing the reporting process in accordance with the CSRD Directive (first year of reporting), the organisation is preparing the appropriate components necessary to build a system for managing the risk associated with the sustainability reporting of the year. The process is treated as long-term and is based both on existing expert knowledge in managing the reporting process and on knowledge of risk management. Preparing the appropriate foundation and materials necessary to build a reliable, complete, and experience-based method of measurement requires a multidimensional approach – work on this will commence within the PGE Capital Group under the newly established sustainable development management project.
The current risk assessments did not result from a developed methodology and were also not assigned a scale (from highest to lowest risk). In the first year of preparing the Statement, the PGE Group adopted the principle that all identified risks related to sustainability reporting are at the same high level – both in terms of the probability of occurrence and the significance of possible effects. Therefore, the PGE Group recognised the necessity to mitigate all identified risks and implemented actions to prevent their occurrence. All actions carried out aimed to ensure continuity of uninterrupted operation in the reporting process, i.e. maintaining process continuity without significant disruptions, by aligning the adequacy of solutions with the organisation’s capabilities.
The first year of reporting serves as a basis and pilot phase for creating a sustainability reporting risk management system in the coming years. Roles in the process and levels of data verification have been defined.
In the following years, it will be possible to compare the impact of disruptions and the classification of estimated risk using appropriate internal tools. This will enable not only the analysis and identification of risk but also ongoing monitoring and the implementation of necessary changes to reduce the probability of occurrence and minimise the significance of effects depending on the classification of a given risk.
Key identified risks for sustainability reporting
Mitigation: external and internal training, ongoing cooperation with an external adviser, early initiation of the process, workshops for teams responsible for specific components of the reporting process.
Mitigation: gradual implementation of the process from September 2023, starting with the development of a data collection structure and definition of roles within the organisation: subject area owners within PGE / ESRS / disclosure leaders / topic coordinators in segments / data providers in PGE Group companies; appointment of ESG Coordinators in each company; preparation of tools for collecting quantitative data.
Mitigation: development of a data collection structure, a five-step data checking/verification process involving the roles of individuals responsible for reporting at company level, thematic coordinators at company level, thematic area owners at PGE Group level, the ESG Division for completeness and data analysis in relation to previous years, where comparability is possible.
Mitigation: five-step data checking/verification process, development of data collection forms, use of long-standing experience from previous reporting processes.
Mitigation: thorough implementation of the double materiality assessment process.