[SBM-2] Interests and views of stakeholders

The PGE Group makes every effort to ensure that its ongoing activities in the area of energy transition are fair, transparent, and carried out in line with arrangements developed through dialogue with its stakeholders.

This dialogue takes place at various levels and is tailored to the type and communication needs of each stakeholder group. There are also mechanisms in place – such as regular dialogue sessions – that provide all key stakeholder groups with a platform to exchange views collectively and to express their expectations towards the company. As part of the PGE CG’s efforts to gain insight into stakeholder perspectives, the following activities can be highlighted:

Review and revision of the stakeholder mapa

With the participation of representatives from various departments within PGE S.A. and key companies of the PGE Capital Group, a review and verification of the stakeholder map was conducted. As part of this process, the influence and level of interest of individual stakeholder groups in the PGE Capital Group were assessed. The data collected was then consolidated and standardised during dedicated workshops.

Regular stakeholder dialogue sessions

In line with the AA1000 standard (open to all stakeholder groups). Based on the information and suggestions gathered during the meetings, the PGE Group assesses the feasibility of implementing the proposals and incorporating them into strategic planning processes. Following each session, all participants receive a formal response from the organisation regarding the matters raised during the discussion. The most recent session was held in 2022, with the next planned for 2025. This three-year cycle allows time for the fulfilment or planning of previous commitments and the identification of new issues of particular importance to stakeholders.

Double materiality assessment process

As part of the double materiality analysis, stakeholder opinion surveys were conducted alongside a series of in-depth interviews with representatives from various areas of the PGE Capital Group. These interviews took the form of structured discussions, giving participants the opportunity to express their views on the materiality of ESG topics for the PGE Group and to identify opportunities, challenges, and ambitions related to environmental, social, and governance aspects. Based on these interviews, the reported topics were analysed for their materiality to PGE in accordance with ESRS.

The in-depth interviews with PGE Group employees led to the identification of initially material topics across environmental, social, and corporate governance dimensions. The outcomes of the materiality impact assessment — of which the stakeholder opinion research formed a key component — were presented to the PGE Capital Group’s Sustainable Development Committee and subsequently approved by the Management Board of PGE S.A.

The PGE Capital Group has dedicated units responsible for maintaining ongoing cooperation with stakeholders and conducting dialogue with selected stakeholder groups

These include, among others, the Department of Dialogue and Social Relations, the Department of International Relations, the Regulatory Affairs Department, and the Investor Relations Division.

Scope and objectives of cooperation with key stakeholders of the PGE Capital Group.

PGE Group stakeholders	Purpose of cooperation	The extent of collaboration, including how PGE CG understands the interests and views of key parties in relation to the strategy and business model
STATE PUBLIC ADMINISTRATION	Implementing tasks related to the country’s energy security and responding to regulatory requirements. Cooperation in achieving climate goals and contributing to national energy policy directions, as well as supporting the development of a favourable and growth-oriented regulatory environment.	PGE’s important role in the Polish economy makes it a natural dialogue partner for a wide range of government institutions. Cooperation with public administration includes, among other things, active participation in the regulatory process by providing feedback and presenting positions during public consultations on draft legislation. The aim of this cooperation is to support the development of the energy sector in Poland and to undertake actions in the interest of electricity and heat consumers. Furthermore, the PGE Capital Group carries out projects within public–private partnerships, for example in the expansion and modernisation of energy infrastructure. PGE Group maintains continuous cooperation with the Energy Regulatory Office, aimed at ensuring the PGE Group’s compliance with applicable regulations, contributing to market development through administrative decisions, and protecting consumer rights. The PGE Group’s operations are also subject to oversight by other regulators, such as the Office of Competition and Consumer Protection, the Office of Technical Inspection, and the Polish Financial Supervision Authority.
SHAREHOLDERS	Providing access to information necessary for assessing the company’s market position.	Creating shareholder value is the primary objective of the company as a commercial entity and a listed company on the Warsaw Stock Exchange. The Group undertakes investment projects following a thorough analytical process aimed at estimating the expected rate of return in relation to the weighted average cost of capital, adjusted for premiums or discounts stemming from the nature and risk profile of the given investment project. Annual bonus targets for the management team include financial indicators such as EBITDA or fixed cost levels. The Investor Relations and ESG Department ensures the coordination of all activities necessary to initiate and maintain good relations with current and potential shareholders and investors. This involves comprehensive and timely communication with the market and adherence to the highest reporting standards. Communication is carried out through the publication of periodic and current reports, as well as meetings and conferences where shareholders are regularly updated on PGE Group’s activities. Cooperation with shareholders also takes place through other communication channels, allowing for the exchange of views and submission of expectations.
FINANCIAL INSTITUTIONS AND RATING AGENCIES	Providing access to information to enable company assessments and secure investment financing.	The PGE Group maintains active and open dialogue with financial institutions and rating agencies. It cooperates with banks and other financial institutions by providing key information on its operations, development plans, and financial performance. Additionally, the PGE Capital Group collaborates with rating agencies that assess, among other things, the Group’s creditworthiness. Interactions are conducted as needed, for example through responses to enquiries or questionnaires. The results of these assessments are communicated to investors, shareholders, and business partners.
SUPRANATIONAL INSTITUTIONS	Influencing the development of regulations at the EU level, cooperation within international organisations.	The PGE Group works with international institutions by submitting opinions on draft regulations at the international level, helping to shape legislation in a way that supports the energy sector. The Group actively engages in cooperation with organisations through a dedicated unit within PGE S.A. At the same time, Members of the Management Board of PGE S.A. are members of international industry associations, which play an active role in providing input and submitting proposals to supranational institutions.
CURRENT EMPLOYEES (AS OWN WORKFORCE)	Ensuring safe and stable working conditions, offering competitive remuneration and development opportunities, while promoting well-being and work-life balance.	Creating safe working conditions and stable employment for its internal workforce is a priority for the PGE Group. Cooperation with employees is carried out through regular contact with the employer – using dedicated communication channels, through HR Business Partners, employee surveys, satisfaction studies, and other forms of evaluation.
EMPLOYEE REPRESENTATIVE ORGANISATIONS AND TRADE UNIONS	Collaboration and dialogue aimed at ensuring safe and stable working conditions for employees, and implementing social support measures.	The PGE Group cooperates with employee organisations and trade unions through discussions and consultations on key matters affecting employees, including working conditions, health and safety, and other important aspects of employment. Their opinions and arguments are analysed by the organisation and contribute to informed business decision-making.
STRATEGIC CUSTOMERS	The aim of the cooperation is to provide the best possible offer and a stable and secure supply of energy and heat.	The Group conducts customer satisfaction surveys and gathers information on customer expectations and needs regarding its product offering and customer service processes. It uses available communication channels for this purpose. The findings from these surveys are implemented in day-to-day operations by optimising sales and service processes. From a financial perspective, the Group pursues a selective investment approach, taking into account the potential impact on the cost of electricity or district heating supply for end users. In addition to tailored energy solutions, the PGE Capital Group offers its clients energy advisory services to help optimise energy consumption. Through its investments in RES, the Group supports strategic clients in their energy transition by offering opportunities to switch to more sustainable energy sources.
MEDIA	The aim of the cooperation is to ensure the transparency of the PGE Group’s activities, to educate, as well as to build the image of the PGE CG and to ensure constant access to information.	For PGE, the media represent one of the key communication channels with stakeholders, used to inform the public about its plans, results, and achievements. PGE places strong emphasis on a careful and proactive approach to media relations, recognising the importance of timely and comprehensive communication. Cooperation with the media is carried out through press releases, interviews, articles, and information campaigns.
LOCAL AUTHORITIES	The aim is to work together for the development and stable operation of the municipalities in which the PGE Group operates, leading to the development of the municipalities and the improvement of the quality of life of its inhabitants.	Given the scale and scope of its operations, the PGE Group engages in direct and regular dialogue with local authorities. It cooperates with local governments on various levels to support the development of local communities and implement joint projects. This cooperation takes the form of regular meetings, dialogue, and the exchange of positions, views, and information. The PGE Group actively supports the municipalities in which it operates through infrastructure investments, educational programmes, and social initiatives that contribute to improving the quality of life of local residents.
INDUSTRY ORGANISATIONS	The aim of being present in industry organisations is to increase the influence of energy companies and to communicate the industry coherently, e.g. when giving opinions on new regulations.	The PGE Group is a member of the Polish Electricity Association (PKEE) and EURELECTRIC. As a member of EURELECTRIC, the PGE Group also plays an important role in the Polish Committee of the World Energy Council. Through its participation in industry organisations, PGE builds valuable strategic partnerships. Meetings are held both in person and online.
CLIMATE AND ENVIRONMENT	The PGE Group’s aim is to strive to reduce its environmental and climate impact and increase its positive impact in this area.	Since 2020, the PGE Capital Group has cooperated with national parks. In 2024, the Bieszczady, Ojców, and Wolin National Parks joined the programme. PGE’s cooperation with national parks focuses primarily on endangered species protection, including monitoring the status and population of animals and plants in ecosystems, conducting scientific research (the results of which help guide conservation efforts), and undertaking initiatives to preserve biodiversity — including plant and animal species, wetlands, and landscape diversity in individual parks. The PGE Group is also actively involved in land reclamation projects. It restores the utility and natural value of post-mining areas to recreate or establish new environmental features. These activities are carried out, among others, at the Bełchatów and Turów lignite mines. The PGE Group also maintains open communication with environmental organisations regarding its impact on the climate and the natural environment.
SUPPLIERS AND BUSINESS PARTNERS (INCLUDING PERSONS WORKING IN THE VALUE CHAIN)	The aim of the collaboration is to ensure a reliable, stable energy supply and to build long-term relationships by working with responsible business partners who adhere to certain ethical, legal and social standards.	The PGE Group cooperates with suppliers and business partners on various levels to ensure operational efficiency and transparency. PGE’s procurement policy and the Code of Conduct for Business Partners of the PGE Capital Group emphasise the importance of compliance with high ethical, social, and environmental standards by both current and prospective suppliers. Purchasing and procurement activities are conducted on transparent and objective terms, in accordance with applicable law and internal procedures. When selecting business partners, the Group bases its decisions on substantive criteria. Cooperation is governed by internal regulations. The Group has developed a standard set of clauses used in contracts with business partners, covering requirements related to anti-corruption, respect for human and labour rights, occupational health and safety, fire protection, waste management, property protection, and the protection of the climate and natural environment.
SUPPLIERS AND BUSINESS PARTNERS OPERATING IN THE RES MARKET	The aim of the cooperation is to ensure a reliable, stable energy supply through the development of RES.	As part of building stable, long-term relationships with suppliers and business partners, the PGE Group develops cooperation standards, which are shared with suppliers during direct meetings. These sessions present the available opportunities for collaboration and the standards and rules that apply within PGE Group’s procurement processes.
LOCAL COMMUNITIES (INCLUDING AFFECTED COMMUNITIES)	The aim is to provide access to information about PGE’s activities in selected areas of the community, build trust and create new areas for collaboration. Taking care to ensure the security of local energy and heat supplies, transparency and inclusiveness of investment processes, through consultation, dialogue and support of residents and local authorities.	PGE Group’s investment processes are preceded by communication with the local community to provide full information about planned and ongoing activities. Communication takes place in the form of meetings with residents and local authorities, as well as information shared via municipal websites and local media. The company supports, on transparent and objective terms, the activities of legal entities and individuals – including employees of the PGE Capital Group and their families – as well as local communities in areas such as culture, science and education, medical care and healthcare, social assistance, environmental action, climate and nature protection, and sport (including sport for children, young people, and people with disabilities). PGE Group employees contribute to local communities, for example through employee volunteering. Cooperation with local communities takes many forms and is ongoing. Activities include dialogue sessions, direct meetings, and collaboration with local community representatives.
COMPETITORS	The aim is to share knowledge and experience, and to communicate consistently with the industry, e.g. when giving opinions and implementing new regulations.	PGE Group engages in dialogue with competitors through industry organisations in which it participates. Cooperation is based on the principles of fair competition, in accordance with the Code of Ethics of the PGE Capital Group.

PGE Group stakeholders	Purpose of cooperation	The extent of collaboration, including how PGE CG understands the interests and views of key parties in relation to the strategy and business model
STATE PUBLIC ADMINISTRATION	Implementing tasks related to the country’s energy security and responding to regulatory requirements. Cooperation in achieving climate goals and contributing to national energy policy directions, as well as supporting the development of a favourable and growth-oriented regulatory environment.	PGE’s important role in the Polish economy makes it a natural dialogue partner for a wide range of government institutions. Cooperation with public administration includes, among other things, active participation in the regulatory process by providing feedback and presenting positions during public consultations on draft legislation. The aim of this cooperation is to support the development of the energy sector in Poland and to undertake actions in the interest of electricity and heat consumers. Furthermore, the PGE Capital Group carries out projects within public–private partnerships, for example in the expansion and modernisation of energy infrastructure. PGE Group maintains continuous cooperation with the Energy Regulatory Office, aimed at ensuring the PGE Group’s compliance with applicable regulations, contributing to market development through administrative decisions, and protecting consumer rights. The PGE Group’s operations are also subject to oversight by other regulators, such as the Office of Competition and Consumer Protection, the Office of Technical Inspection, and the Polish Financial Supervision Authority.
SHAREHOLDERS	Providing access to information necessary for assessing the company’s market position.	Creating shareholder value is the primary objective of the company as a commercial entity and a listed company on the Warsaw Stock Exchange. The Group undertakes investment projects following a thorough analytical process aimed at estimating the expected rate of return in relation to the weighted average cost of capital, adjusted for premiums or discounts stemming from the nature and risk profile of the given investment project. Annual bonus targets for the management team include financial indicators such as EBITDA or fixed cost levels. The Investor Relations and ESG Department ensures the coordination of all activities necessary to initiate and maintain good relations with current and potential shareholders and investors. This involves comprehensive and timely communication with the market and adherence to the highest reporting standards. Communication is carried out through the publication of periodic and current reports, as well as meetings and conferences where shareholders are regularly updated on PGE Group’s activities. Cooperation with shareholders also takes place through other communication channels, allowing for the exchange of views and submission of expectations.
FINANCIAL INSTITUTIONS AND RATING AGENCIES	Providing access to information to enable company assessments and secure investment financing.	The PGE Group maintains active and open dialogue with financial institutions and rating agencies. It cooperates with banks and other financial institutions by providing key information on its operations, development plans, and financial performance. Additionally, the PGE Capital Group collaborates with rating agencies that assess, among other things, the Group’s creditworthiness. Interactions are conducted as needed, for example through responses to enquiries or questionnaires. The results of these assessments are communicated to investors, shareholders, and business partners.
SUPRANATIONAL INSTITUTIONS	Influencing the development of regulations at the EU level, cooperation within international organisations.	The PGE Group works with international institutions by submitting opinions on draft regulations at the international level, helping to shape legislation in a way that supports the energy sector. The Group actively engages in cooperation with organisations through a dedicated unit within PGE S.A. At the same time, Members of the Management Board of PGE S.A. are members of international industry associations, which play an active role in providing input and submitting proposals to supranational institutions.
CURRENT EMPLOYEES (AS OWN WORKFORCE)	Ensuring safe and stable working conditions, offering competitive remuneration and development opportunities, while promoting well-being and work-life balance.	Creating safe working conditions and stable employment for its internal workforce is a priority for the PGE Group. Cooperation with employees is carried out through regular contact with the employer – using dedicated communication channels, through HR Business Partners, employee surveys, satisfaction studies, and other forms of evaluation.
EMPLOYEE REPRESENTATIVE ORGANISATIONS AND TRADE UNIONS	Collaboration and dialogue aimed at ensuring safe and stable working conditions for employees, and implementing social support measures.	The PGE Group cooperates with employee organisations and trade unions through discussions and consultations on key matters affecting employees, including working conditions, health and safety, and other important aspects of employment. Their opinions and arguments are analysed by the organisation and contribute to informed business decision-making.
STRATEGIC CUSTOMERS	The aim of the cooperation is to provide the best possible offer and a stable and secure supply of energy and heat.	The Group conducts customer satisfaction surveys and gathers information on customer expectations and needs regarding its product offering and customer service processes. It uses available communication channels for this purpose. The findings from these surveys are implemented in day-to-day operations by optimising sales and service processes. From a financial perspective, the Group pursues a selective investment approach, taking into account the potential impact on the cost of electricity or district heating supply for end users. In addition to tailored energy solutions, the PGE Capital Group offers its clients energy advisory services to help optimise energy consumption. Through its investments in RES, the Group supports strategic clients in their energy transition by offering opportunities to switch to more sustainable energy sources.
MEDIA	The aim of the cooperation is to ensure the transparency of the PGE Group’s activities, to educate, as well as to build the image of the PGE CG and to ensure constant access to information.	For PGE, the media represent one of the key communication channels with stakeholders, used to inform the public about its plans, results, and achievements. PGE places strong emphasis on a careful and proactive approach to media relations, recognising the importance of timely and comprehensive communication. Cooperation with the media is carried out through press releases, interviews, articles, and information campaigns.
LOCAL AUTHORITIES	The aim is to work together for the development and stable operation of the municipalities in which the PGE Group operates, leading to the development of the municipalities and the improvement of the quality of life of its inhabitants.	Given the scale and scope of its operations, the PGE Group engages in direct and regular dialogue with local authorities. It cooperates with local governments on various levels to support the development of local communities and implement joint projects. This cooperation takes the form of regular meetings, dialogue, and the exchange of positions, views, and information. The PGE Group actively supports the municipalities in which it operates through infrastructure investments, educational programmes, and social initiatives that contribute to improving the quality of life of local residents.
INDUSTRY ORGANISATIONS	The aim of being present in industry organisations is to increase the influence of energy companies and to communicate the industry coherently, e.g. when giving opinions on new regulations.	The PGE Group is a member of the Polish Electricity Association (PKEE) and EURELECTRIC. As a member of EURELECTRIC, the PGE Group also plays an important role in the Polish Committee of the World Energy Council. Through its participation in industry organisations, PGE builds valuable strategic partnerships. Meetings are held both in person and online.
CLIMATE AND ENVIRONMENT	The PGE Group’s aim is to strive to reduce its environmental and climate impact and increase its positive impact in this area.	Since 2020, the PGE Capital Group has cooperated with national parks. In 2024, the Bieszczady, Ojców, and Wolin National Parks joined the programme. PGE’s cooperation with national parks focuses primarily on endangered species protection, including monitoring the status and population of animals and plants in ecosystems, conducting scientific research (the results of which help guide conservation efforts), and undertaking initiatives to preserve biodiversity — including plant and animal species, wetlands, and landscape diversity in individual parks. The PGE Group is also actively involved in land reclamation projects. It restores the utility and natural value of post-mining areas to recreate or establish new environmental features. These activities are carried out, among others, at the Bełchatów and Turów lignite mines. The PGE Group also maintains open communication with environmental organisations regarding its impact on the climate and the natural environment.
SUPPLIERS AND BUSINESS PARTNERS (INCLUDING PERSONS WORKING IN THE VALUE CHAIN)	The aim of the collaboration is to ensure a reliable, stable energy supply and to build long-term relationships by working with responsible business partners who adhere to certain ethical, legal and social standards.	The PGE Group cooperates with suppliers and business partners on various levels to ensure operational efficiency and transparency. PGE’s procurement policy and the Code of Conduct for Business Partners of the PGE Capital Group emphasise the importance of compliance with high ethical, social, and environmental standards by both current and prospective suppliers. Purchasing and procurement activities are conducted on transparent and objective terms, in accordance with applicable law and internal procedures. When selecting business partners, the Group bases its decisions on substantive criteria. Cooperation is governed by internal regulations. The Group has developed a standard set of clauses used in contracts with business partners, covering requirements related to anti-corruption, respect for human and labour rights, occupational health and safety, fire protection, waste management, property protection, and the protection of the climate and natural environment.
SUPPLIERS AND BUSINESS PARTNERS OPERATING IN THE RES MARKET	The aim of the cooperation is to ensure a reliable, stable energy supply through the development of RES.	As part of building stable, long-term relationships with suppliers and business partners, the PGE Group develops cooperation standards, which are shared with suppliers during direct meetings. These sessions present the available opportunities for collaboration and the standards and rules that apply within PGE Group’s procurement processes.
LOCAL COMMUNITIES (INCLUDING AFFECTED COMMUNITIES)	The aim is to provide access to information about PGE’s activities in selected areas of the community, build trust and create new areas for collaboration. Taking care to ensure the security of local energy and heat supplies, transparency and inclusiveness of investment processes, through consultation, dialogue and support of residents and local authorities.	PGE Group’s investment processes are preceded by communication with the local community to provide full information about planned and ongoing activities. Communication takes place in the form of meetings with residents and local authorities, as well as information shared via municipal websites and local media. The company supports, on transparent and objective terms, the activities of legal entities and individuals – including employees of the PGE Capital Group and their families – as well as local communities in areas such as culture, science and education, medical care and healthcare, social assistance, environmental action, climate and nature protection, and sport (including sport for children, young people, and people with disabilities). PGE Group employees contribute to local communities, for example through employee volunteering. Cooperation with local communities takes many forms and is ongoing. Activities include dialogue sessions, direct meetings, and collaboration with local community representatives.
COMPETITORS	The aim is to share knowledge and experience, and to communicate consistently with the industry, e.g. when giving opinions and implementing new regulations.	PGE Group engages in dialogue with competitors through industry organisations in which it participates. Cooperation is based on the principles of fair competition, in accordance with the Code of Ethics of the PGE Capital Group.

The PGE Group takes stakeholder relationships and feedback into account wherever possible during its day-to-day operations and considers them when making key decisions related to its strategy and business model. The PGE Group’s business model continues to evolve and adapt in response to technological progress, economic developments, social and regulatory trends, and stakeholder expectations. However, its core structure as a vertically integrated energy group remains stable – in 2024, there were no changes to the scope of the PGE Capital Group’s value chain, which continues to cover mining, generation, wholesale trading, distribution, retail sales, and other activities. In line with internal regulations, the Company conducts a strategic review at least once a year. As a result of this review, a decision may be taken to initiate an update of the strategy. As at the date of publication of this Statement, PGE S.A. has announced that an updated strategy will be published in mid-2025. The PGE Group continued to implement the strategic objectives and directions set out in the strategy adopted in October 2020. Key actions and decisions supporting the strategy and impacting the business model are taken on an ongoing basis by the Company’s governing bodies and internal collegial bodies (established by internal regulations), which perform management, supervisory, and advisory roles in specific business areas and key investment programmes.