ESRS E2 Pollution
E2-1 Policies adopted to manage significant impacts, risks or opportunities related to pollution
In 2025, by resolution of the parent company’s Management Board, the Enea Group adopted a uniform environmental regulation entitled the Enea Group Environmental Policy. The purpose of the Policy is to minimize the impact of the Enea Group’s business on the natural environment and to promote sustainability and environmental responsibility.
The document is of a general nature and covers the Group’s own operations as well as various specific issues, including: natural resources, emission and noise reduction, ecosystem protection, environmental education and the pursuit of innovative solutions and low-emission technologies. The Policy directly addresses the mitigation of negative impacts related to air and water pollution. Its effectiveness is intended to be monitored through internal and external audits. The Policy has been uploaded to the Group’s intranet.
Some Enea Group companies have adopted detailed regulations regarding pollution, hazardous substances and mixtures as well as water and wastewater management. These have been tailored to the scale and specific nature of their operations. The topic of water pollution is described in greater detail in section E3 “Water and marine resources.”
All procedures and instructions adopted by each company have been shared with employees on the intranet.
At LW Bogdanka, the issue of pollution is governed by the Integrated Management System Policy, which constitutes a clear commitment by the company to prevent pollution by minimizing negative impacts on the natural environment.
In accordance with the implemented instruction IZS-PZ/S/05/06-01, LW Bogdanka uses chemical products in accordance with their intended purpose and refrains from using products classified as Category 1 carcinogenic or mutagenic.
At Enea Wytwarzanie, the organization’s standards of conduct applicable to the broadly defined use of natural resources and care for the natural environment, also in the context of pollution, are set out primarily by the Integrated Quality, Environmental and OHS Management System Policy approved by the Company’s Management Board. The Policy defines the framework for setting environmental objectives and includes a commitment to fulfill environmental protection requirements, including those related to pollution prevention. It covers all of the company’s activities, products and services that fall within the realm of the Integrated Management System and have been formally incorporated into the environmental management system. This means that all operational, maintenance and support processes are carried out in accordance with specific environmental requirements and that employees and collaborators are required to observe them. All individuals employed by the company as well as those working under its supervision, at every organizational level, are responsible for implementing and complying with the provisions of the Policy. In its implementation of the Policy, the company has committed to comply with the following standards: PN-EN ISO 9001:2015, PN-EN ISO 14001:2015 and PN-EN ISO 45001:2024.
When regulations were developed at Enea Wytwarzanie, consideration was given, among other aspects, to environmental conditions that affect the company’s business or are affected by them, as well as the needs and expectations of stakeholders relevant to the operation of the system. The Policy is available on the company’s website.
The primary document governing incident prevention and emergency response within the company is the Procedure for Identifying Potential Emergencies and Responding to Their Occurrence. The document lays down the principles for identifying potential hazards in order to protect the natural environment and safeguard human life and health. The Procedure also establishes methods for appropriate response in emergency situations, ensures the readiness of necessary personnel and resources, and describes preventive measures to mitigate the risk of events with a negative impact on the environment.
Additional pollution-related regulations implemented by Enea Wytwarzanie include:
- Identification and Assessment of Environmental Aspects procedure, which defines the rules for identifying environmental aspects and assessing their impact on the environment,
- Environmental Monitoring Manual, which specifies the scope and methodologies for conducting environmental monitoring,
- Environmental Monitoring Procedure, which defines the rules for monitoring and conducting measurements related to environmental aspects,
- Identification of Potential Emergency Situations and Response procedure, which governs the prevention of emergency situations and describes the response to mitigate environmental impacts,
- Rules for the Use of Fluorinated Greenhouse Gases, which ensures oversight of F-gas obligations,
- Instructions for the Management of Hazardous Substances and Mixtures, which describes the safe handling of hazardous substances,
Enea Wytwarzanie has also adopted an Emergency Response Plan for Threats to Human Life, Health, Property or the Environment, which defines procedures for environmental emergencies, methods of analyzing the causes of accidents and ways to implement preventive measures.
At Enea Elektrownia Połaniec, pollution-related issues constitute part of the Integrated Management System for electricity and heat generation, which has been designed in consideration of a variety of aspects, including the stakeholders’ significant requirements. Among its elements is an environmental management system covering all organizational units within the company. Pollution-related procedures and instructions that have been implemented within the system include:
- Procedure for the Identification and Assessment of Environmental Aspects, which defines the rules for identifying environmental aspects and assessing their impact on the environment,
- Procedure for Environmental Monitoring, which defines the extent and methodology of environmental monitoring,
- Procedure for Prevention, Preparedness and Response to Accidents and Emergencies, which defines the rules of conduct in emergency situations to mitigate the consequences of potential accidents.
- Environmental Management Program, which describes measures aimed at minimizing adverse impacts on the natural environment,
- Program for prevention of severe industrial accidents relating to the storage and use of hazardous substances and materials.
- Waste Management Program, which describes the principles of waste management and specifies methods for preventing waste generation, reducing its volume and minimizing its environmental impact.
The Integrated Management System Policy and the environmental management system comply with ISO 14001 and apply to all organizational units within the company. Procedures and instructions regarding the system are updated on an ongoing basis to ensure their continuous compliance with the law and integrated permits. The responsibility for implementing the IMS Policy rests with the President of the Enea Elektrownia Połaniec Management Board. The environmental management system is overseen by the Director of the Environmental Engineering Division.
Enea Ciepło manages pollution-related aspects through procedures and policies that form the environmental management system. These include:
- Preventing and Reducing the Environmental Impact of Emergencies procedure, the purpose of which is to minimize the risk of environmental emergencies through preventive measures and to ensure and maintain the proper technical condition of equipment and emergency response installations,
- Actions for Environmental Emergencies procedure, which defines the rules and procedures for responding to environmental emergencies, as well as for analyzing the causes of accidents and taking corrective actions,
- Instructions for the Management of Hazardous and Potentially Hazardous Substances and Mixtures, which emphasizes the obligation for employees to review safety data sheets and establishes the rules for properly labeling areas designated for the storage of substances.
Enea Nowa Energia manages pollution-related issues in a variety of ways, including through the Waste Management Manual, the Manual for the Management of Hazardous and Potentially Hazardous Substances and Mixtures, the Procedure for the Use of Fluorinated Greenhouse Gases and the Emergency Preparedness and Response Procedure. These documents contain environmental guidelines for personnel and counterparties providing services to the company. They refer, among other topics, to: environmental protection law, water law, the Act on the Prevention and Remediation of Environmental Damage, the Waste Act and the Act on Ozone-Depleting Substances.
With regard to its own operations (personnel) and the upstream value chain (counterparties providing services to the company, that is suppliers and contractors), Enea Nowa Energia’s policies focus on preventing air, water and soil pollution resulting from the operation of assets and controlling such pollution. At the company, air emissions may originate solely from the firing of biogas in the power generators of biogas-fired power plants, although in 2025 emissions were zero due to the technological phasing-out of the biogas-fired plant. Other facilities – hydro, wind and photovoltaic – do not generate process emissions. Marginal indirect emissions are associated with boiler houses, transportation, welding processes and system leaks. They are calculated annually based on KOBiZE indicators and safety data sheets.
Substances of concern are used solely for maintenance and operational purposes. Enea Nowa Energia maintains a registry of fluorinated greenhouse gases present in its equipment. For equipment subject to this requirement, it has established files in the central operator registry. The company monitors the use of substances of concern and, where possible, replaces them with environmentally friendly products.
In accordance with the Emergency Preparedness and Response Procedure, in order to prevent failures, emergencies and incidents, Enea Nowa Energia conducts regular technical inspections, maintenance and overhauls of its generating units as well as inspections and repairs of transportation vehicles and machinery, and employee training. The company maintains proper storage management of waste and hazardous substances and has put in place fire safety measures.
E2-2 Actions and resources related to pollution
In 2025, within the Enea Group, actions related to pollution were taken predominantly by companies operating in the Mining and Generation areas. This is due to the specific nature of their business. During the reporting period, Enea Group companies did not encounter any situations that would require providing remedial measures to persons harmed as a result of actual significant impacts related to pollution.
In the Mining Area, LW Bogdanka managed its significant impact on air pollution primarily through taking mitigation measures within its own operations. Among the initiatives pursued were the following:
- emission monitoring – ongoing control of key physicochemical characteristics of released substances,
- technical reduction measures – operation of emission-limiting equipment, including filtration systems installed directly on emission sources.
The company takes these actions on an ongoing basis, without any strictly confined timeframe. LW Bogdanka treats them as a permanent operational element of environmental management. During the reporting period, the company’s priority issue was to ensure full operational compliance with the environmental permits obtained. The expected outcomes of these actions include ensuring continuous compliance with administrative decisions and effectively reducing pollutants released into the atmosphere.
In 2025, Enea Wytwarzanie focused its own operations on monitoring and reducing emissions of pollutants into the air and water. A key activity in this context was to ensure operational continuity and high technical efficiency of the protective infrastructure. The company carried out ongoing modernizations, repairs, inspections and specialized maintenance of flue gas desulfurization and denitrification systems, electrostatic precipitators, wastewater treatment plants and related infrastructure. In the area of air protection at the Kozienice Power Plant, the priority remained the maintenance of consistently high efficiency and availability of emission control equipment, while simultaneously and continuously monitoring emissions to document full compliance with the laws in force.
As regards water and wastewater management, Enea Wytwarzanie focused on maintaining permissible quality standards for domestic wastewater, stormwater, industrial wastewater and wastewater from flue gas desulfurization systems. This process is supported by a system for monitoring the volume of discharged wastewater and periodic testing of its condition and composition carried out by a laboratory accredited by the Polish Center for Accreditation. Moreover, in 2025, the modernization of the stormwater and industrial wastewater treatment plant serving the 200 MW units was launched with a view to optimizing existing process systems and maintaining an effective, legally compliant level of treatment for stormwater and industrial wastewater. The modernization is scheduled for completion in 2026.
Enea Elektrownia Połaniec focused its actions, in particular, on maintaining the high efficiency and effectiveness of protective equipment with a view to ensuring emission levels consistent with BAT conclusions. As regards air protection, a key measure was the replacement of the layers of SCR catalytic modules in units 2, 4 and 7, enabling the maintenance of a significant nitrogen oxide (NOx) emission reduction in accordance with applicable regulations.
In the area of water and wastewater management, Enea Elektrownia Połaniec focused on stabilizing the quality parameters of wastewater from the flue gas desulfurization system at the mechanical and chemical wastewater treatment plant in order to fulfill the requirements provided for in the BAT conclusions and national regulations. Moreover, the closed-loop hydro-ash removal system operates using rainwater, snowmelt and wastewater. These actions are complemented by the continuous monitoring of particulate and gaseous emissions and discharges into waters coupled with waste management measures. Moreover, as at 1 August 2025, due to the acquisition of the business of Enea Bioenergia (the Pióry combustion waste storage facility, for which an integrated permit had been issued, along with facilities for the storage of biomass fuels and fly ash, for which sectoral decisions had been issued), the company expanded its operational and environmental oversight.
In 2025, Enea Ciepło completed investment projects related to the rearrangement of its energy mix and the shift from coal-fired sources to low-emission technologies. The company completed the preparatory stages for photovoltaic farms at the Białystok CHP Plant and in Sowlany, which are scheduled to be commissioned in 2026. The modernization of generation infrastructure was completed, including the replacement of auxiliary equipment for boiler B-5, the refurbishment of the pressure section of boiler B-6 and the deployment of new oil-gas units B-4 and B-5. The company also built an electric vehicle charging station, used for its own needs, and obtained permits to erect a similar commercial facility. Furthermore, as part of ongoing activities, an annual analysis is carried out to assess the possibility of replacing specific hazardous substances with less harmful alternatives or eliminating them completely through technological changes.
In the medium term, covering the period 2025-2032, Enea Ciepło intends to extend the service life of its turbine set TZ1 and biomass boilers, and increase their efficiency. Of key significance to emissions efficiency are investments, intended for the period 2025-2028, in heat recovery and energy storage, including the construction of heat pumps in cooling water and flue gas systems, heat recovery systems, electrode boilers and a heat accumulator, which will enable the gradual lessening in pollutant emissions into the environment.
Enea Nowa Energia, owing to its relatively low emissions, focuses its attention on preventive measures: it counteracts water and soil contamination in accordance with applicable legal regulations governing water and wastewater management, uses water recirculation in hydroelectric power plants and safeguards against oil spills, and monitors domestic wastewater. As regards hazardous substances and mixtures, the company focuses on ensuring compliance with legal regulations, including ADR regulations.
Enea Elkogaz, Enea Połaniec Peak, Enea Kozienice Peak and EW Magazyn Energii do not have their own facilities and thus do not emit any pollutants.
The Group has not allocated financial resources to support activities in E2 area. Measures are financed and allocated as part of current operations, depending on their scale and needs.
E2-3 Targets related to pollution
Targets related to pollution are defined in the Enea Group Sustainability Strategy. Among its strategic objectives, the Group lists, without limitation, a reduction in the emission of pollutants into the air and water. The Enea Group has adopted a specific pollution indicator, which is the quotient of the sum of emissions of pollutants into water and air and the amount of gross electricity and heat generated in the respective reporting year.
In the baseline year of 2024, this indicator stood at 1.723 kg/MWh. The organization’s target for 2030 is to achieve a value of the indicator below the level of 2024-2029, and for 2035 – below the level of 2024-2034. The target will be monitored as the sum of emissions of pollutants into the air and water, with the Group collecting and monitoring data on emissions into the air and water separately, based on existing emission monitoring systems. It is linked to the Enea Group Environmental Policy’s guidelines on pollution prevention and is voluntary. The target has been set by the Group’s employees, without involving other stakeholders, and is based on internal analyses and technological capabilities identified by the Group.
Unit pollutant emission indicator for the Enea Group [kg/MWh]
E2-4 Pollution of air, water and soil
Pollution information has been compiled in accordance with KOBIZE reporting guidelines. The companies conduct continuous measurements of emissions of particulate matter, SO2, NOx, CO, NH3, HCl (Enea Wytwarzanie and Enea Elektrownia Połaniec also measure HF and Hg). The measurements are carried out by means of automatic measuring systems (AMSs) that fulfill the requirements of PN-EN 14181 and are connected to emission computers that collect and present data in the form of synoptic images and reports. Moreover, periodic monitoring of metals and metalloids and SO₃ is carried out once a year. For ash bunkers, transfer bunkers, limestone meal bunkers and hydrated lime bunkers, periodic monitoring of dust emissions is carried out every two years. Other substances are calculated based on indicators determined by unit measurements and the amount of fuel burned. Unit measurements are taken by companies holding the required accreditation obtained from the Polish Center for Accreditation. Data recorded by continuous monitoring are collected in the form of AMS system reports. At Enea Wytwarzanie, all emission data are collected in the Company’s Environmental Pollution Database. Moreover, employees keep spreadsheets, of which the primary one is the Environmental Charges Model (MOŚ), which is saved on a network drive.
E2-5 Substances of concern and substances of very high concern
Substances of concern and substances of very high concern emitted by Enea Group companies.
2 carcinogenicity, category 1, skin sensitization, category 1, specific target organ toxicity – repeated exposure, category 1
3 respiratory sensitization, category 1, Skin sensitization, category 1
4 specific target organ toxicity – repeated exposure, category 2, Hazardous to the aquatic environment – long-term hazard, category 2
5 hazardous to the aquatic environment – long-term hazard, category 2
6 skin sensitization, category 1, long-term aquatic hazard, category 2, specific target organ toxicity – repeated exposure, category 2
7 including: skin sensitization category 1, respiratory sensitization category 1, carcinogenicity category 2, reproductive toxicity category 2, long-term aquatic hazard category 2
8 carcinogenic category 1, toxic to specific target organs, repeated exposure category 1, skin sensitizer category 1, long-term aquatic hazard category 1 and 2
9 Skin sensitizer category 1,
10 Arsenic, chromium, copper, mercury, nickel, lead, phenols, zinc; long-term aquatic hazard category 1 and 3, skin sensitization, category 1.
After a calculation error was identified, the total mass of emitted substances of concern – which is the sum of emissions into air and water – was corrected. The component values did not change, since the correction applied to the incorrectly calculated sum only. As a result, the value for 2024 was updated from 34,064.02 t to 41,743.42 t.
2Carcinogenicity category 1
The table below presents material topics with the impacts, risks and opportunities identified and corresponding policies, actions or targets.