[S4-4] Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions

The PGE Group takes action to minimise negative impacts and maximise positive influence on consumers and end-users. The Group focuses on ensuring privacy, access to high-quality information, and health and safety. The PGE CG works to effectively manage risks and leverage opportunities in this area by implementing the principles outlined in the regulations referenced in section S4-1.

In 2024, no reports were recorded concerning serious human rights issues or incidents related to consumers or end-users.

Privacy

In the area of privacy, the PGE CG carries out ongoing activities related to the implementation of its personal data protection policy. This includes data retention, data protection incident management, and breach notification procedures. Key actions taken in 2024 include:

Involvement of Data Protection Officers in privacy-by-design processes, and regular data protection training for employees conducted by PGE CG companies (both for new hires and as refresher tranining during employment),
Implementation of IT solutions,
Periodic personal data protection risk assessments in line with internal procedures,
Assignment of personal data protection KPIs for 2024 to the management boards of the different companies, aimed, inter alia, at raising awareness of data protection issues among employees.

Among the remedial measures taken for affected individuals, the PGE CG informed data subjects about incidents and outlined possible actions to minimise any potential negative consequences.

As part of data protection, companies have been assigned tasks to be completed in 2024:

Initiate a project to effectively regulate data retention in the company.
Undertake awareness-raising activities for managers on personal data protection in the company.
Conducting an information campaign aimed at directors and managers on the implementation of the privacy by design obligation.

The expected result of these activities is to minimise (eliminate) the number of incidents occurring in the area of personal data protection in the PGE Capital Group by implementing corrective measures, informing whether an incident constituted a personal data protection breach and whether it required notification to the supervisory authority after its occurrence, and issuing recommendations and their implementation in order to avoid similar incidents in the future. In the related area of information systems protection and cyber security, the goal is to achieve the highest possible level of security, including zero data leakage, as well as zero critical incidents in accordance with the National Cyber Security System Act.

Health and safety / Security of a person

The PGE CG implements measures to safeguard the health and safety of both its clients and employees, thereby increasing positive impact and opportunities while mitigating risks or negative influence. These efforts include investment in modern technologies, renewable energy sources, and infrastructure upgrades to reduce harmful emissions, directly benefiting health of consumers and end-users. These initiatives are long-term in nature. A key element of PGE CG’s commitment to health and safety are its awareness-raising and educational campaigns, which help inform the public about safe use of electricity and energy equipment.

Due to the long-term nature and distributed implementation of these actions, it is difficult to continuously assess their impact or attribute outcomes to specific initiatives.

Notable health and safety activities carried out in 2024 include:

Information and education campaigns to increase awareness among consumers about energy safety and efficient energy use (described in S3-4),
Cooperation with local communities, including local authorities, associations, public services such as: (e.g. fire services, territorial defence forces, police), Such activities include the exchange of experiences and opinions, joint exercises in the field of energy infrastructure protection and crisis response exercises (PGE Dystrybucja S.A.).
Ongoing implementation of the Security Management Policy, which includes physical protection and technical security of PGE CG assets. This helps ensure employee safety, property protection, and continuity of production and distribution operations. Their uninterrupted operation of the latter ensures the energy security for consumers and end-users. No incidents means less expenditure on troubleshooting. Under this policy, PGE CG companies are required to take corrective actions.

Examples of ongoing initiatives by specific companies:

Adjusts its product portfolio to new legal frameworks, promoting energy self-consumption and security through the sales of energy storage solutions. For consumers and end-users, replacing old heating systems with RES technologies reduces the risk of carbon monoxide poisoning and improves air quality, which has a positive effect on their health.

Offer 24/7 failure reporting services. Rapid response reduces accident risks and ensures safety for workers and residents. The companies provide ongoing updates about planned works and outages and respond to public enquiries.

To ensure well-targeted responses to actual or potential negative impacts of the Group, the security unit at PGE S.A. may, based on investigations into incidents related to the business activities of PGE CG companies (including those involving security of a person), may recommend specific corrective measures to PGE CG entities where incidents have occurred. In addition, physical security risks are assessed quarterly through the ERM system, with mitigation actions defined accordingly. The PGE CG has reporting channels in place for irregularities. In the event of negative feedback from consumers or end-users submitted through these channels, the Group identifies appropriate corrective actions and works toward their effective implementation. Details of reporting procedures and channels are provided in section G1-1.

Access to (quality) information / Responsible marketing practices / Access to products and services

In the areas of access to (high-quality) information, access to products and services, and responsible marketing practices, the PGE Group undertakes activities aimed at addressing its significant impact on consumers and end-users. The key ongoing initiatives implemented in this scope in 2024 include:

Oversight by the Corporate Centre over the retail sales of products and services provided by PGE CG companies, management of customer relationship strategies, and coordination of related activities across the Group. One of the supervisory activities carried out in 2024 was the implementation of consumer rights protection reporting by PGE Group companies. Special attention was also given to complaints and claims. The operational management of significant risks and the utilisation of significant opportunities related to these consumers and end-users, as well as evaluation of the effectiveness of these activities, are carried out at the level of PGE CG companies that offer their products and services to consumers.
Implementation of a reporting and supervisory system in PGE CG companies involved in sales and customer service processes. The system includes risk mitigation and corrective actions, and the resulting reports are used to recommend risk reassessment, procedural improvements, and employee training to ensure consumer rights protection. The system operates under continuous operational oversight and covers areas such as complaints and claims.
Provision of high-quality information via websites, mobile apps, communication and education campaigns, and printed materials. These communication and education initiatives aim to raise consumer awareness about the use of electricity and heat, enabling informed decision-making.
The PGE CG provides and promotes digital customer service solutions such as eInvoice, Moje PGE, eBOK, and the 991 Assistant app, ensuring 24/7 access to products and services, and equal availability for all customers.
- PGE Obrót S.A. is actively promoting digital solutions such as eInvoice and Moje PGE. In 2024, more than 2.3 million customers used the eInvoice service.
Marketing and promotion campaigns are tailored to business objectives and include risk minimisation measures such as legal advice. This approach ensures PGE CG’s compliance with responsible marketing principles and mitigates the risk of penalties from authorities such as the Office of Competition and Consumer Protection (UOKiK).
Ensuring a high level of customer service and reliable information through employee training, the adoption of plain language principles, and the simplification of documentation to make it more understandable for customers.
- In the area of contract and product documentation, PGE Obrót S.A. fulfils its obligations under the Consumer Rights Act and reflects statutory information requirements in its contractual and product-related documents. Consumers are informed about their rights concerning contracts concluded remotely or outside business premises. The company continuously monitors legal developments and updates its contract templates for electricity and other products and services accordingly. Insights gathered from the sales network and contractors are used to identify opportunities and risks, enabling the company to adjust sales and service processes to the new market landscape and implement the related documentation changes based on a thorough analysis.
- Within the framework of access to information, the PGE Group aims to simplify the language of client documentation.

Among the ways of implementing activities in this regard, efforts to simplify the language of client documentation stand out. For PGE Obrót S.A., the aim in 2024 was to simplify the language in formal documents addressed to the mass customer, while for PGE Dystrybucja S.A. – Inventorying documentation and modifying a specific range of documents.

An important way of monitoring the results of actions taken in the customer area is the customer satisfaction index (CSI – Consumer Satisfaction Index). According to the methodology used to calculate the CSI index value for PGE Obrót S.A. and PGE Dystrybucja S.A. in 2024, both companies achieved indices above 80%, which is considered expected.