ESG Report of the
ENEA Capital Group for 2021

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Approach to environmental and climate management

At the ENEA Group, we are fully aware how energy production and distribution affects the state of the environment, including the climate, and therefore also the quality of life.

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Therefore, in a well-thought-out manner, we implement further solutions allowing for monitoring and minimizing our greenhouse gas emissions and other pollutants and we rationally manage our natural resources. We also make sure that our mining and generation activities do not endanger biodiversity and continuity of environmental processes.

The Group has in place a number of policies and procedures referring to environmental matters. The ENEA Group Code of Ethics states, among other things, that the company:

takes environmental factors into account when developing new services and products

invests in solutions satisfying stringent environmental standards

works on technological solutions to increase production of energy from renewable sources

makes rational use of energy and natural resources and strives to reduce generated waste and pollution

nitiates and actively participates in educational campaigns for environmental protection and building environmental awareness

prevents any breakdowns that may be dangerous for the environment

Our commitment to sustainable development and natural environment is also embedded in the Code of Ethics for the LW “Bogdanka” S.A. Group and the ENEA Group Compliance Policy, which, among others, requires us to:

  • take actions to minimize pollution emissions and to ensure reasonable management of natural resources,
  • undertake initiatives to retain the balance between the Group’s operations and the natural environment,
  • carry out capital expenditures using environmentally friendly technologies,
  • support renewable energy sources,
  • cooperate with environmental organizations.
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The ENEA Group Procurement Policy contains a rule that, when selecting suppliers of products and services, non-price criteria should be taken into account, including environmental factors such as energy efficiency of the subject of contract. However, bid evaluation criteria are defined individually for each tender procedure and selected environmental aspects are included only when deemed suitable for the subject of contract. At the same time, contracts with all our suppliers contain an undertaking to observe the provisions of the ENEA Group’s Code of Conduct for Contractors, which contains our expectations, among others in respect to environmental protection.

In proceedings conducted by ENEA Operator for the supply of means of transport, CO₂ emission is one of the evaluation criteria. The Company has also adopted a rule that it rules out from proceedings any suppliers who are natural persons legally convicted for crimes against the environment under Article 181-188 of the Criminal Code.

The ENEA Group Communication Policy contains provisions stating that the Group’s communication is conducted in a manner that promotes environmentally friendly values and that the Group’s sponsorship activities will focus, without limitation, on the domain of environmental protection.

The individual companies have and update on an ongoing basis their own policies, procedures, instructions and regulations, which are suitable to their unique character, obligating them to protect the environment and use it in a sustainable way. In addition, some of the principles, e.g. the ones setting out the requirements for handling the waste produced, must be observed by external entities performing work on the sites of and for Group companies. They also apply methodologies for monitoring and documenting specific environmental impacts and effects of their pro-environmental activities.

Selected due diligence policies, standards and procedures in the area of environmental management in ENEA Group companies

  • ENEA S.A. Environmental Policy
  • Policy of the Integrated Quality, Environmental and OHS Management System
  • Book of the Integrated Quality, Environmental and OHS Management System based on the requirements of the standards PN-EN ISO 9001:2015, PN-EN ISO 14001:2015 and PN-N-18001:2004/OHSAS 18001:2007
  • Procedure “Supervision over legal and other requirements”
  • Procedure “Identification and evaluation of environmental aspects”
  • Procedure “Environmental monitoring”
  • Procedure “Identification of potential accidents and emergencies and responding to their occurrence at ENEA Wytwarzanie sp. z o.o. at the Świerże Górne site”
  • Rescue plan in case of a threat to life and human health and property or the environment at ENEA Wytwarzanie sp. z o.o. in Świerże Górne (Kozienice Power Plant)
  • Emergency preparedness and response procedure at the Koronowo site
  • Procedure “Goal management”
  • Procedure „Management review, analysis and improvement”
  • Other detailed procedures and instructions governing conduct setting out the principles of performing operations that impact the environment, monitoring, performing measurements and exercising metrological oversight over devices used to monitor the effects of environmental activity
  • Environmental Management System Policy and the following procedures based on this policy:
    • Supervision over documentation (SZŚ)
    • Supervision over records (SZŚ)
    • Process monitoring (SZŚ)
    • Goal management (SZŚ)
    • Internal audits (SZŚ)
    • Handling non-compliance – corrective actions (SZŚ)
    • Periodic evaluation of compliance with legal and other requirements (SZŚ)
    • Management review (SZŚ)
  • Procedure PŚ-4.3-01 “Identification of environmental aspects”
  • Procedure PŚ-4.4-01 “Responding to danger and failure”
  • Procedure PŚ-4.4-02 “Waste management”
  • Procedure PŚ-4.5-01 “System of monitoring and measuring parameters affecting the environment”
  • Quality instruction QI-7.5-11 “Program for prevention of severe industrial accidents relating to the storage and use of hazardous substances and materials at the Zachód Heat Plant”
  • Internal instructions on monitoring and reporting CO2 emissions:
    • Instruction I-OŚ-01 “Management of records and documentation”
    • Instruction I-OŚ-02 “Determination of changes affecting the allocation of emission allowances for installations”
    • Instruction I-OŚ-03 “Calculation of CO2 emissions”
    • Instruction I-OŚ-04 “Quality of the information system used for data flow activities”
    • Instruction I-OŚ-05 “Estimation of fuel consumption during a belt weigher and gas flow meter breakdown”
    • Instruction I-OŚ-06 “Monitoring of outsourced processes”
    • Instruction I-OŚ-07 “Identification of installed devices used to determine data values”
    • Instruction I-OŚ-08 “Staff management for ETS purposes”
    • Instruction I-OŚ-09 “Evaluation of the adequacy of the monitoring methodology plan/Evaluation of the adequacy of the monitoring plan”
    • Instruction I-OŚ-10 “Management of data flow activities”
    • Instruction I-OŚ-11 “Implementing corrections and rectifying measures”
    • Instruction I-OŚ-12 “Supervision over metering equipment for monitoring CO2
    • Instruction I-OŚ-13 “Internal reviews and validation of data”
    • Instruction I-OŚ-14 “Uncertainty assessment”
    • Instruction I-OŚ-15 “Analysis of CO2 emission monitoring risk”
    • Instruction I-OŚ-16 “Analysis of the risk of the PMM monitoring methodology plan”
    • Instruction I-OŚ-17 “Monitoring of basic data and audit activities related to the application for free allocation of CO2 emission allowances”
  • Biomass purchasing policy
  • Sustainable Development Criteria System Book (SDC)
  • Environmental Management System Policy and the following procedures based on this policy:
    • Supervision over documentation (SZŚ)
    • Supervision over records (SZŚ)
    • Process monitoring (SZŚ)
    • Goal management (SZŚ)
    • Internal audits (SZŚ)
    • Handling non-compliance – corrective actions (SZŚ)
    • Periodic evaluation of compliance with legal and other requirements (SZŚ)
    • Management review (SZŚ)
  • Procedure “Identification of threats and responses to environmental emergencies at the Białystok CHP Plant”
  • Procedure “Prevention and mitigation of emergencies on the environment at the Białystok CHP Plant”
  • Procedure “Conduct in the event of environmental emergencies at the Białystok CHP Plant”
  • Procedure “Monitoring CO2 emissions in the Białystok CHP Plant”
  • Instruction on the organization of rescue operations at the site of ENEA Ciepło sp. z o.o. – Białystok CHP Plant Division
  • Procedure „Identification of threats and determining how to respond to environmental emergencies at ENEA Ciepło sp. z o.o. – Białystok CHP Plant Division”
  • Procedure „Prevention and reduction of the impact of emergencies on the environment at ENEA Ciepło sp. z o.o. – Białystok CHP Plant Division”
  • Procedure “Conduct in the event of environmental emergencies at the Białystok CHP Plant” 
  • Instruction on managing dangerous and hazardous substances and mixtures
  • Instruction on handling waste at the Białystok CHP Plant
  • Instruction “Waste management”
  • Procedures referred to in the CO2 emissions monitoring plan
  • Environmental Policy
  • Company Environmental Pollution Bank Program SOZAT
  • Procedure for fulfillment of obligations towards entities financing the investments of ENEA Operator sp. z o.o.
  • Procedure for registering power devices containing at least 6 kg of SF6 gas and operations performed on them
  • Procedure for management of dismantling materials and waste in ENEA Operator sp. z o.o.
  • Waste management at ENEA Oświetlenie sp. z o.o.
  • Procedure for identification and evaluation of environmental aspects
  • Environmental monitoring procedure 
  • Environmental management program  
  • Policy of the Integrated Quality, Environmental and OHS Management System with related environmental procedures
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The activities of Group companies are conducted in strict compliance with the accepted internal regulations, general provisions of law as well as the content of the necessary permits and administrative decisions, such as the right to release emissions into air, decisions on environmental conditions of a permit to carry out a project, or water permits.

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significant non-financial penalties or sanctions imposed on ENEA Group companies for non-compliance with environmental protection laws or regulations in 2021

Climate policy and oversight of climate-related issues

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At the time of publication of the Report (25 May 2022) works were underway on the preparation of a comprehensive climate policy common for the entire ENEA Group. The document will identify key risks and opportunities associated with climate change, define ways and principles for managing them, and set the company climate goals and indicators for attaining them.

As of 16 February 2021 the person responsible in the ENEA Group for managing its climate impact is the Vice-President of the Management Board for Operational Affairs, Mr. Marcin Pawlicki and as of March 2022 also the Vice-President of the Management Board for Strategy and Development, Mr. Lech Adam Żak. Since 20 April 2021, the unit responsible for this area in ENEA S.A. is the Innovation and Climate Transition Office, which has been established on the basis of the earlier Innovation Department and is part of the Strategy Division at the Group Strategy and Development Management Department.

By the publication date of the Report, the method of oversight of the Supervisory Board over climate matters has not been agreed upon. Also, no committees have been established to monitor and supervise over the progress in the implementation of climate-related goals and tasks. Both of these issues are to be addressed during the work on the Group’s climate policy.

The method of managing climate-related risks and opportunities is presented in the section entitled Management of non-financial risks. By 25 May 2022, no measures have been defined that are used to manage risks and opportunities. Their list and target levels will be recorded in the ENEA Group Climate Policy, which is currently being developed.

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