ESRS E3 Water and marine resources
E3-1 Policies related to water and marine resources
Across the Enea Group, issues related to water and marine resources are generally governed by the Enea Group Environmental Policy. In the Policy, the Group has included commitments to reduce water consumption and water pollution, comply with legal regulations, protect biodiversity, prevent pollution and ensure the efficient use of resources. Some companies have adopt additional specific regulations regarding water.
At LW Bogdanka and Łęczyńska Energetyka, issues related to water management are addressed in the Integrated Management System Policy (ZSZ), which governs water consumption and discharge. It complements the Enea Group Environmental Policy, ensuring consistency and a uniform framework for environmental management. The Policy focuses on the reasonable use of water resources, monitoring water quantity and quality and limiting the negative impact of the companies’ business on the environment. The Integrated Management System Policy serves as the basis for undertaking operational, investment and modernization activities tailored to the Group’s needs. LW Bogdanka and Łęczyńska Energetyka are located in areas that are not subject to a high risk of drought.
At Enea Wytwarzanie and Enea Elektrownia Połaniec, water-related issues constitute part of the implemented Integrated Management System for electricity and heat generation. More information on related regulations is provided in disclosure E2-1.
The areas where Enea Wytwarzanie conducts its business are located in a zone of a high risk of drought and a low risk of water resource depletion. The company has not adopted any additional regulations in this regard due to the mitigation measures taken and the construction of a water retention weir on the Vistula River. Adopted documents:
- Instructions entitled Principles of Water and Wastewater Management at Enea Wytwarzanie sp. z o.o., Kozienice Power Plant – Fulfillment of Formal and Legal Obligations – the document ensures compliance with the requirements contained in the applicable water law permits, integrated permits and current legal provisions under water law and implementing regulations,
- Instructions on Environmental Monitoring in an Open Water Cooling System – the document defines the rules for monitoring cooling water and the operation of draft cooling towers.
Enea Ciepło manages issues related to water resources in accordance with the Environmental Management System. The company operates its facilities in accordance with the applicable legal regulations, obtained integrated permits and water-law decisions. The company does not operate any facilities located in areas with a significant water deficit.
Enea Nowa Energia conducts its business based on, among other documents, the Water Management Instructions developed for hydroelectric power plants located on the Rega, Brda, Wda, Gwda, Obra and Myśla rivers. The company has obtained all required water-law permits issued for hydroelectric power plants, including permits for the use of water for power generation, the discharge of rainwater into rivers and the abstraction of groundwater. Enea Nowa Energia runs its business in accordance with, among other regulations, water law, the Water and Flood Framework Directive and the Flood Risk Management Plan. All of the company’s internal regulations have been shared with employees on the intranet and at the company’s head office.
Some of the facilities are located in areas with significant water shortages. The company has not adopted and does not intend to adopt any additional policies regarding water consumption in these areas, as its business does not involve excessive water consumption.
The Enea Group has not adopted any policies related to the sustainability of seas and oceans.
E3-2 Actions and resources related to water and marine resources
In 2025, the Enea Group took certain actions related to water resources.
LW Bogdanka uses mine water1 in an integrated manner, primarily for its own operations, for technological purposes at the Mechanical Coal Processing Plant, to supply fire protection systems and for technological purposes underground. Mine water is directed to a water treatment plant where it is processed into potable and industrial water used in the company’s own operations. To properly manage water discharges and prevent uncontrolled outflows, the company monitors the impact of mining activities on the Świnka river. The scope of specific studies includes, without limitation:
- physicochemical measurements,
- sampling and determination of pH, total suspended solids, total dissolved solids, heavy metals and trace elements,
- biological tests.
Studies conducted by LW Bogdanka and scientists indicate that mine water discharged from the mining facility directly into the Świnka River affects the river’s physicochemical parameters. Owing to favorable hydrogeological conditions and the management of water discharge volumes, the adverse impact on the aquatic environment is controlled. At the same time, the company takes action aimed at restoring and regenerating the aquatic ecosystem and the water body. The most significant work in this regard includes hydrotechnical tasks, the construction of water reservoirs, the maintenance of drainage ditches and land reclamation endeavors. Historical data indicate that the quality of water in the Świnka River returns to its pre-discharge state approximately 500-1000 meters downstream from the discharge point.
These measures are undertaken as part of the company’s own operations on an annual basis. In the future, LW Bogdanka intends to continue using water obtained from drainage processes to increase the utilization rate of mine water.
1 Mine water is saline groundwater which accumulates in the workings of deep mines as a result of displacement from the overburden and seepage from porous coal-bearing rocks.
Owing to the technological systems used, primarily closed-loop systems, Enea Wytwarzanie reduces water consumption and minimizes water losses in technological processes. The extent of these activities covers the Kozienice Power Plant site, including the area where the ash-slag mixture waste landfill is located. The power plant uses surface water resources from the Middle Vistula River basin for technological purposes and groundwater from the Oligocene aquifer for domestic purposes.
Key activities related to water resources in water-stressed areas include:
- reuse of wastewater and other process water in technological systems, including the replenishment of losses in the water-ash removal cycle and the steam-water cycle. This reduces surface water consumption and decreases the volume of wastewater discharged,
- directing water to seal equipment and capture heat, then returning it to the system for use in a closed-loop cooling system,
- introducing the recirculation of washwater and water from pretreatment and filter rinsing processes – this measure increases the efficiency of water use in the preparation of process water,
- returning water to the storage area via drainage pumping, which reduces the need to draw from external sources.
The outcomes of these measures, as expected by Enea Wytwarzanie, include reducing primary water consumption in production processes, reducing the volume of wastewater that requires treatment, increasing the degree of closed-loop water circulation and reducing potential environmental risks resulting from water abstraction. These measures significantly support the achievement of objectives called for by the Enea Group Environmental Policy – they reduce pressure on water resources, minimize water losses and enhance process efficiency.
The company cooperates closely with scientific institutions on long-term monitoring of water quality and temperature, including by measuring the impact of cooling water on the ichthyofauna of the Vistula River.
Enea Wytwarzanie continuously monitors water conditions in the Vistula River to ensure an undisturbed flow. Water for plant operations is drawn only to a level that ensures the maintenance of an undisturbed flow.
To reduce the risk of drought2, in previous years the company built a weir to dam water in the Vistula River.
Enea Elektrownia Połaniec also closes the water cycle in the hydro-ash removal system. This is supplemented by industrial wastewater, rainwater and treated domestic wastewater. Excess wastewater from the hydro-ash removal system is used as process water in the flue gas desulfurization plant. The use of a closed-loop hydro-transport system contributes to reducing the amount of wastewater discharged into the Vistula River and reducing water withdrawal for process needs. The stakeholders identified by the company in the case of water resources are mainly water users: the State Water Management Authority “Wody Polskie,” the Polish Angling Association and environmental non-governmental organizations (NGOs).
Moreover, Elektrownia Połaniec regularly conducts activities related to the restoration of the aquatic ecosystem, which are intended to offset the loss of biodiversity. In cooperation with local organizations, the company conducts annual fish stocking campaigns in the Vistula River. In 2025, in collaboration with representatives of the Tarnobrzeg Region of the Polish Angling Association (PZW), employees of a fish farm, members of Angling Club No. 32 at Elektrownia Połaniec, students from nearby schools and participants in the Occupational Therapy Workshops in Połaniec, in consultation with the State Water Management Authority “Wody Polskie,” thousands of young fish were released into the river. The selection of fry species was based on an analysis of the mix of species naturally occurring in the respective section of the Vistula and the fry themselves come from the same genetic pool as the populations living in the Vistula. This helps strengthen and replenish the native fish fauna.
Enea Elektrownia Połaniec continuously monitors water levels in the Vistula to ensure that the minimum flow is maintained. Water withdrawal for plant operations is limited exclusively to a level corresponding to the minimum flow. In the event of a threat of exceeding the minimum flow level, electricity generation is reduced, which automatically decreases the demand for water.
The company also provides remedial measures to individuals affected by actual significant water-related impacts. In accordance with a decision issued in 2000 by the Mayor of the Town and Municipality of Połaniec, Enea Elektrownia Połaniec covers the costs of supplying potable water to the residents of Tursko Małe and Tursko Małe-Kolonia as compensation for disrupting water relations through its operations. Additionally, in accordance with the water-law permit for the abstraction of groundwater for domestic purposes from wells located in Tursko Małe-Kolonia, the company is required to cover the costs of purchasing potable water from the water supply network for the residents of six developed plots located within the depression cone of this intake. To reduce the risk of flooding caused by the inflow of rainwater and meltwater from the catchment area (location of the Pióry Landfill), the facility has been fitted with a buffer tank. The tank, built in 2005, protects residents of nearby towns from flooding caused by heavy rainfall. The risk of flooding is directly associated with the existence of the landfill and the excess of leachate occurring during rainy periods. In 2025, in accordance with the Water Management Plan, Enea Nowa Energia carried out work to restore morphological continuity to sections of the Brda, Martwa Brda, Wda and Gwda rivers where the company operates hydroelectric barrages. The company has a team dedicated to mitigating risks associated with the construction of fish passages at the barrages. In cooperation with external experts (including in biology and hydrobiology), variant analyses for restoring passability at the barrages in the Brda, Wda and Gwda river basins have been completed. The scheduled completion date for the construction of the fish passage is 2027. Concurrently, the effectiveness of existing fish migration facilities is being monitored. The outcomes of the study will determine further investment activities. Moreover, the company is cooperating with state authorities on the construction of fish passages, the result of which in the investment project on the Rega and Drawa rivers.
Other companies are focusing on standard operations, in accordance with the applicable laws, integrated permits and water-law decisions. For instance, Enea Ciepło conducted inspections of water and wastewater management tanks and verified the technical condition of chemical storage tanks as well as the sump pits beneath tanks and transformers. Inspections of sanitary, industrial and stormwater sewer networks were also conducted, along with an analysis of the quantity and quality of wastewater discharged into water bodies and the municipal sewer system.
The Group has not allocated financial resources to support activities in E3 area. Measures are financed and allocated as part of current operations, depending on their scale and needs.
2 Enea Wytwarzanie runs its business in an area with a high risk of drought and a low risk of water resource depletion.
E3-3 Targets related to water and marine resources
A voluntary target regarding water and marine resources has been defined in the Enea Group Sustainability Strategy. The target consists of the optimization of water and wastewater management, which indirectly relates to reducing water consumption. The Strategy defines the Enea Group’s target based on the unit water withdrawal rate per MWh of energy generated. The indicator is the ratio of the amount of water withdrawn for technological purposes (excluding water withdrawal for social and domestic purposes) and the amount of gross electricity and heat generated in the respective reporting year. Calculations are performed for the whole organization, excluding LW Bogdanka (due to the specific nature of its operations, LW Bogdanka has its own water management target). The adopted targets are uniform across all operations of the Group. No separate targets have been set for water-stressed areas and with significant water scarcity, as no significant water consumption has been identified in such areas.
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. To achieve this, the Group will, among other actions, make changes to its energy mix and develop and implement action plans to improve the efficiency of its water and wastewater management. These plans will be developed gradually over the coming years and will take into account the specific characteristics of each relevant company.
The target is based on internal analyses and technological capabilities identified by the Group. The target does not take environmental thresholds into account, either. It has been set by the Group’s employees and is linked to the significant impacts that the Enea Group exerts on water resources, particularly in the context of water consumption.
E3-4 Water consumption
Information on water consumption is based on invoices for water purchases and data from measuring devices for water withdrawal from deep or surface water intakes. 99.99% of the data on the amount of stored water are derived from water permits for the storage of water in water reservoirs issued for hydroelectric power plants (maximum amount of water that may be stored). The water quality in these reservoirs is not monitored. Information on water volumes was obtained from measuring instruments such as electromagnetic flow meters, flow sensors, ultrasonic flow meters, etc. In most cases, these devices were legally certified. Some of the locations of Enea Operator and Enea Elektrownia Połaniec are in areas which, according to the Drought Mitigation Plan and data from the Aqueduct Water Risk Atlas, should be classified as water-stressed areas.
The reported data have been derived from measurements. The measurement of this metric has not been validated by an external body other than the assurance provider. Revenue and other income from the Consolidated Financial Statements for 2025 (that is, PLN 28,136,652 thousand) has been used to calculate water consumption.
The water consumption figure for 2024 has been corrected due to the erroneous allocation of returned abstraction of water to water consumed by Enea Wytwarzanie. Consequently, water consumption has changed. The values changed from 1,537,844,118.73 to 23,734,723.73 m³, and from 46,637.26 to 719.79 m³, respectively. Water consumption in water-stressed areas also changed, since the areas of Enea Wytwarzanie were not taken into account. The figure changed from 904,825.87 to 19,479,251.87 m³.
The table below presents material topics with the impacts, risks and opportunities identified and corresponding policies, actions or targets.