• ESRS E4 Biodiversity and ecosystems

ESRS E4 Biodiversity and ecosystems

E4-1 Transition plan and consideration of biodiversity and ecosystems in the strategy and business model

The Enea Group has not conducted an assessment of the resilience of its current business model or adopted strategy to physical risks and transition risks related to biodiversity and ecosystems, as no material risks have been identified in this area and thus no need has been identified for further work to enhance resilience.

The Enea Group affects biodiversity and ecosystems in various ways, including:

  • energy generation from conventional sources and the significant CO₂ emissions associated with it contribute to climate change, which exerts an adverse impact on biodiversity,
  • dams on rivers, e.g. the weirs used in hydroelectric power plants, which are a serious obstacle for aquatic organisms,
  • tree clearing in areas where power lines are located and in other areas where investments or renovations are carried out,
  • changes in river mineralization associated with coal mining by LW Bogdanka S.A.,
  • potential land subsidence as a result of underground coal mining and related damage to ecosystems.

E4-2 Policies related to biodiversity and ecosystems

The Enea Group Environmental Policy described in disclosure E2-1 aims to minimize the impact of the Enea Group’s operations on the natural environment, including biodiversity and ecosystems.

It also addresses the reclamation of former mining sites and the protection of habitats and species. The document does not address in detail any issues related to specific locations, land, seas or deforestation. Enea Ciepło and Enea Elektrownia Połaniec have Biomass Procurement Policies in place, which define the rules for managing and controlling the biomass supply chain and for documenting the origin of raw materials to mitigate the risk of supplies that do not comply with the applicable laws.

The basis for implementing the objectives of the Policies is the Due Diligence System (SNS) and certification for compliance with the Sustainability Criteria (KZR).

The Policies require the companies to avoid unreliable or unsustainable sources of biomass, to procure only biomass fuels that have been sourced, produced, processed and sold with respect for human rights and to promote responsible management that takes into account the protection of the environment and its natural resources.

Company management is responsible for their pursuit and the documents are publicly available and communicated to stakeholders.

E4-3 Actions and resources related to biodiversity and ecosystems

In 2025, the Enea Group took actions related to biodiversity and ecosystems that resulted from the pursuit of the Environmental Policy. The Group companies’ cooperation with local communities or their representatives is described in the context of specific activities.

LW Bogdanka’s approach to biodiversity management involves ongoing monitoring of the outcomes of ongoing reclamation, natural inventories of mining areas and taking measures for active habitat protection. A key element of environmental oversight is the monitoring of rivers and lakes located within the boundaries of mining operations. In this regard, the company collaborates with scientists and managers of protected areas, including the Poleski National Park.

The company has implemented procedures for the operation of machinery and equipment to prevent uncontrolled seepage into the ground. The management of hazardous substances and waste storage is carried out in a formalized manner, in accordance with environmental guidelines. In parallel, LW Bogdanka analyzes the potential impact on biodiversity during the planning stage of new investments and operational projects, enabling environmental considerations to be incorporated across the asset lifecycle.

External activities are based on building partnerships with environmental organizations and institutions and on cooperation under the umbrella of a grant fund that supports scientific research in the field of ecosystem protection. The company intends to continue the reclamation of areas affected by mining damage and the site of the Mining Waste Disposal Facility in Bogdanka.

In the company’s assessment, its activities constitute sustainable systemic solutions and thus do not exert any negative impact on sustainability goals. During the reporting period, activities related to biodiversity did not generate any significant capital expenditures or operating expenses. For the most part, the resources involved included financial funds for ongoing project activities and human resources tasked with preparing specialized analyses and substantive studies.

During the reporting period, Enea Operator minimized its impact on the environment and animal and plant habitats. When executing investment projects, the Company strictly adheres to the requirements set forth in environmental decisions and environmental impact assessments, and its actions are in compliance with legal regulations, local government decisions and decisions of Regional Directors for Environmental Protection. Enea Operator has also implemented the Procedure for Managing the Removal of Trees and Shrubs under Power Lines,

As regards activities related to biodiversity and ecosystems, Enea Operator secures overhead power lines and supports bird populations. Initiatives pursued in this area include:

  • maintaining a safe distance between live components and trees (grid reliability and environmental safety),
  • installation of nesting platforms – locations for new nests are selected based on grid inspections, reports from residents or government agencies and local authorities. Among other initiatives, Enea Operator supports the osprey population. The outcomes of its endeavors are monitored by the Regional Directorate for Environmental Protection (RDOŚ) in Gorzów Wielkopolski,
  • securing 110 kV lines using specialized bird warning devices. The type and placement of these devices result from environmental decisions preceded by observations of flight paths and nesting attempts,
  • participation in the International White Stork Census.

The company has introduced fieldwork standards under which work is planned in consideration of protection regimes to avoid interference during breeding seasons. Moreover, staff regularly obtain information via the intranet and e-mail regarding species protection guidelines and the obligation to report threats to protected habitats. The company also holds training sessions and environmental contests for employees and their families.

Key stakeholders affected by tree felling, the routing of power lines through protected areas and the adverse impact of such lines on birds are the owners of land on which high-, low- and medium-voltage poles and accompanying infrastructure are located. The company considers the following to be such stakeholders:

  • private individuals,
  • state administrative authorities, in particular the State Forests and the Regional Directorate for Environmental Protection (RDOŚ),
  • local government bodies, in particular municipalities.

Every report of a hazard posed by infrastructure (such as a crumbling stork’s nest on a pole, trees growing into power lines) is reviewed in terms of infrastructure safety, flora and fauna, and the surrounding environment. Where necessary, prompt action is taken to improve safety. These are unscheduled activities carried out in compliance with applicable environmental laws.

In 2025, Enea Wytwarzanie took actions related to the impact on biodiversity and ecosystems. Some of them were based on environmental impact decisions, while others were carried out by the company at its own initiative. The most important ones included:

  • environmental monitoring of power plants, ash-slag disposal sites and the company’s surroundings, including supervision of sites inhabited by protected species (including the peregrine falcon, the spotted eagle owl, the herring gull, terns, the European beaver, orchids and other rare plants) within the power plant site, adjacent areas and Natura 2000 sites (Middle Vistula Valley, Kozienicka Refuge, Kozienicka Primeval Forest),
  • ichthyological monitoring of the Vistula River in the power plant area and monitoring the effectiveness of the fish ladder at the check dam to protect aquatic resources,
  • conducting the project under strict environmental supervision, including the modernization of the wastewater treatment plant, work within the track areas and European beaver habitats and the construction of two battery energy storage facilities (in accordance with the obtained environmental decisions), and the operation/demolition of the dam,
  • preparation of nature inventories for new projects covering the growing, breeding and wintering seasons (in accordance with the environmental decisions),
  • online live feed from a white stork nest in the village of Molendy,
  • introduction of protected freshwater crayfish, the protected bitterling (fish species) and mussels into the Traszka reservoir – an initiative carried out jointly with the State Forests, the Faculty of Animal Sciences at the Warsaw University of Life Sciences (SGGW) and the Institute of Forest Sciences at SGGW, in cooperation with the local community and the media,
  • promotion of the exhibition entitled “The Green Face of the Kozienice Power Plant” and raising awareness of local communities about the high natural value of the areas surrounding the plant,
  • publication of a brochure describing the lichens present at the Kozienice Power Plant as indicators of air quality,
  • enhancing habitats at sites inhabited by the spotted rat snake – a protected and rare snake species – through the planting of vegetation that supports its food sources,
  • maintaining insect feeding plots on the power plant grounds and planting selected nectar-producing species,
  • publication of the book “The Natural Environment of the Kozienice Power Plant. Energy in Harmony with Nature,” describing natural values and summarizing educational and conservation activities,
  • press releases on the natural values of the Kozienice Power Plant,
  • conducting nature-themed educational activities during events and in schools within Kozienice County.

In 2025, Enea Elektrownia Połaniec carried out activities to offset biodiversity loss resulting from the operation of the facility. These mainly involved stocking the Vistula River with fish and are described in greater detail in disclosure E3-2. Other company activities included:

  • planting native tree species as part of the “Planting the Next Generation of Forests” campaign,
  • and taking action to build a fish ladder on the Vistula River near the flexible weir. This action will result in the restoration of the river’s ecological continuity by enabling the free movement of aquatic organisms, especially fish, despite the presence of weirs or other obstacles,
  • conducting research entitled Assessment of the Impact of the Połaniec Power Plant’s Cooling Waters on the Ichthyofauna of the Vistula River,” taking into account the impact of conditions in the cooling water channel on selected ecological groups – including, in particular, the reproduction and survival of the ichthyofauna. As a result of the research, a plan of compensatory measures will be developed, to be carried out in the coming years.

In addition to the activities related to river ecosystem conservation, as described in disclosure E3-2, Enea Nowa Energia has also been pursuing other biodiversity-related initiatives. The company’s Procedure on the Rules for the Removal of Trees and Shrubs provides for felling in only necessary situations, in consideration of the safety of humans and property. All activities that may affect protected animal or plant species, such as the demolition of European beaver dams, are coordinated with the Regional Directorate for Environmental Protection. The company also monitors the impact of nine wind farms on birds and bats, and reports the outcomes to the Regional Directorate for Environmental Protection. The monitoring of eight power plants is required by the environmental permit decision.

Despite the measures taken by the Enea Group to protect biodiversity, in December 2025, an incident occurred at Enea Nowa Energia that affected natural resources. In accordance with the requirements of Water Law permit, the company carried out the flushing of the Old Brda Riverbed, having previously notified the relevant parties of the planned water discharge. As a result, approximately 1 ton of fish died. The company immediately reported the incident to the competent authorities; currently, no proceedings are pending in this matter. The fish were removed and disposed of at the company’s expense.

The Group has not allocated financial resources to support activities in E4 area. Measures are financed and allocated as part of current operations, depending on their scale and needs.

E4-4 Targets related to biodiversity and ecosystems

The strategic goal of Enea Group, specified in the Enea Group Sustainability Strategy, is the protection of ecosystems and support for biodiversity. To achieve it, in every key investment the Group will implement at least one measure resulting from voluntary programs for ecosystems and  biodiversity. These measures will be developed for Enea Group and will take into account the specific nature of each company’s operations. The goal is qualitative, it does not have a target level or base year set, but it relates to the term of the ESG Strategy which is the period until 2035. Depending on the nature of investment, this target may relate to the different levels of mitigation hierarchy.

The target was not set on the basis of international agreements or frameworks1, and does not take environmental thresholds into account. It is linked to the significant impacts that the Enea Group has on biodiversity and  ecosystems, and it implements measures to offset biodiversity loss. This target covers all business activities of the Group.

E4-5 – Impact metrics related to biodiversity and ecosystems change

The Enea Group has identified locations in or near biodiversity-sensitive areas that are negatively impacted by the company. These are areas where the infrastructure of LW Bogdanka S.A. is located (the area of meadows located in Natura 2000 areas and the Nadrybie field located in their vicinity is 16.39 ha in total), Enea Nowa Energia (the area of land used is 899.3 ha), Enea Wytwarzanie (the area of land near protected areas is 559.5 ha), PEC Oborniki (the area of land near protected areas is 0.5 ha) and Enea Operator (the area of land which occupy distribution lines in protected areas is 2,313 for high voltage and 8,274 ha for medium voltage lines)2.

Enea Nowa Energia conducts monitoring activities focused on assessing impacts on ecosystems, which include in particular: the monitoring of the effectiveness of existing fish ladders, including quantitative and species-based measurements of ichthyofauna and other aquatic organisms, as well as the monitoring of the activity and mortality of birds and bats in the areas where wind farms are located. These are administrative and informational activities and do not impact the value of the E4-5 indicator.

Area of biodiversity sensitive areas in [ha] 2024 2025
LW Bogdanka S.A. 16.39 16.39
Enea Nowa Energia 265.00 899.30
Enea Wytwarzanie 558.70 559.50
PEC Oborniki – 0.50
Enea Operator 10,785.00 10,587.00
Area of biodiversity sensitive areas in [ha] 2024 2025
LW Bogdanka S.A. 16.39 16.39
Enea Nowa Energia 265.00 899.30
Enea Wytwarzanie 558.70 559.50
PEC Oborniki – 0.50
Enea Operator 10,785.00 10,587.00

The Report for the previous reporting period for LW Bogdanka S.A. showed the value of 161,410 ha referring to the total surface of mining areas. The correct surface of mining areas is 16,141 ha, but this value does not apply to biodiversity-sensitive areas. The area of sensitive areas is 16.39 ha and is the only value captured in the E4-5 indicator, which is in line with the methodology adopted for the entire Group.

1 This includes the Kunming–Montreal Biodiversity Framework, key aspects of the EU Biodiversity Strategy for 2030, and other national policies and legislation on biodiversity and ecosystems
2 Enea Operator is not in possession of actual data on the length of lines in protected areas. The company intends to collect information and publish actual data. The data presented were estimated based on information about the length of high and medium voltage lines, the average width of the easement strip, which is generally equal to the felling strip, assuming that 32.6% of the lines are located in protected areas. The assumption is in line with the information on the area of Poland under protection (Statistics Poland data from 2018). Low-voltage lines were not taken into account in the estimation of the line area, because they run through built-up areas.

The table below presents material topics with the impacts, risks and opportunities identified and corresponding policies, actions or targets.

Material topic IRO Name Policies (P), Actions (A),
Targets (T)
Biodiversity Climate change impact on biodiversity P, A
Environmental disturbances associated with the operation of hydrotechnical barriers P, A
Tree clearing for power lines, investments and modernizations P, A
River pollution with salts and heavy metals P, A
Risk of bird and bat collisions with wind turbines P, A
Bird mortality caused by power lines P, A
Negative impact of open cooling systems on aquatic ecosystems P, A
Impact of mines on the degradation and destabilization of ecosystems P, A
Material topic IRO Name Policies (P), Actions (A),
Targets (T)
Biodiversity Climate change impact on biodiversity P, A
Environmental disturbances associated with the operation of hydrotechnical barriers P, A
Tree clearing for power lines, investments and modernizations P, A
River pollution with salts and heavy metals P, A
Risk of bird and bat collisions with wind turbines P, A
Bird mortality caused by power lines P, A
Negative impact of open cooling systems on aquatic ecosystems P, A
Impact of mines on the degradation and destabilization of ecosystems P, A
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