• ESRS E5 Resource use and circular economy

ESRS E5 Resource use and circular economy

E5-1 Policies adopted to manage significant impacts, risks or opportunities related to resource use and circular economy

The issues related to the use and sourcing of raw materials are the topic of the Enea Group Climate Policy and the Enea Group Environmental Policy described in sections E1-1 and E2-1. These documents include objectives related to the shift away from primary raw materials and a transition to RES and improving the efficiency of electricity generation, resources use and circular economy. In its Environmental Policy, the Enea Group commits, among other things, to using resources efficiently, moving away from the use of primary resources, and increasing the use of secondary resources. The Group points to:

  • reduction in the use of water and natural resources,
  • implementation of practices for sustainable sourcing and use of raw materials,
  • increase in the share of recycled materials.

Additionally, some of the companies belonging to the Group adopted their own regulations in this regard, adjusted to the nature of business and scale of operations. Their scope aligns with the adopted Environmental Policy and enables the day-to-day organization of work in the areas of the circular economy and waste management.

In LW Bogdanka, the management of incoming resources is governed by the Operations Plan, under which the company’s various divisions order the necessary inventory and make appropriate use of their resources. With regard to waste management, the company bases its operations on the Integrated Management System Policy, under which it minimizes its negative impact on the environment. The provisions of this regulation were prepared according to ISO 9001:2015, ISO 14001:2015 and ISO 45001:2024

Enea Operator manages waste in accordance with the Procedure for management of dismantling materials and waste, under which every material resulting from dismantling is evaluated by a specialized committee to assess its potential for further use within the company. Materials classified as waste (in accordance with the Waste Act) are transferred to authorized recipients engaged in recycling or recovery. If recycling or recovery is not possible, the waste is sent for other treatment processes in accordance with the waste management hierarchy.

The Department of OHS and Environmental Protection is responsible for implementing and updating the Procedure. The document is an internal act of the company and is not made available publicly.

In Enea Elektrownia Połaniec the issues related to resource use and the circular economy are part of the Integrated Management System for electricity and heat production. One of its elements is the environmental management system which covers all organizational units within the company. The procedures and instructions relating to the environmental management system are updated continuously to ensure compliance with applicable laws and permits. Elektrownia Połaniec has a Waste management program in a power plant in place, which is linked to the Environmental monitoring procedure. The document is updated whenever new types of waste emerge and addresses all issues related to waste generated during the electricity production process. In accordance with the provisions of the Program, the company reduces the amount of waste it generates in order to eliminate the need for their landfilling. Provisions regarding waste management are also included in the Warehouse management manual, the Manual for the management of steel scrap and non-ferrous metals, and the Manual for the handling of waste generated at Enea Elektrownia Połaniec S.A. by external entities.

The Integrated Management System Policy of Elektrownia Połaniec covers in its scope the observance of the ISO 14001 standard.

The President of the Management Board of Enea Elektrownia Połaniec is responsible for implementation of the IMS Policy.

At Enea Wytwarzanie the Integrated Quality, Environmental and OHS Management System Policy approved by the Company’s Management Board sets forth the organization’s standards of conduct regarding the broad use of natural resources and care for the natural environment, including the management of by-products and waste. The Waste Management Rules at Enea Wytwarzanie sp. z o.o. were implemented in the Kozienice Power Plant. Their aim is to minimize the quantity of waste and their negative impact on people’s life and health and on the environment.

Additionally, Enea Wytwarzanie implemented regulations related to waste i.e. Waste Management Rules at Enea Wytwarzanie sp. z o.o. and the Integrated Management System which regulate the manner of handling waste and introduce rules to minimize the quantity of waste generated.

At Enea Nowa Energia and its subsidiaries the Waste management manual applies. It governs the issues related, among others, to waste management, handling waste management by contractors and hierarchy for handling waste contributing to the reduction of the use of primary resources. The Generation Division of Enea Nowa Energia is responsible for implementing the Manual. The document has been made available to the employees in the electronic form in the intranet and in hard copy in the company’s office.

The following manuals apply at Enea Ciepło: the Manual for handling waste at Elektrociepłownia Białystok and the Manual for handling waste at Enea Ciepło sp. z o.o. – CENTRALA which set forth among others the rules for handling generated waste, form and circulation of documents regarding the activities during which waste is generated, requirements for handling generated waste and requirements for contractors of works and sites lessees. This Manual governs the rules of cooperation between operations, maintenance, and supervisory departments whose activities are related to waste management.

E5-2 Actions and resources related to resource use and circular economy

In 2025 the majority of companies of Enea Group undertook actions related to the resource use and circulation economy. Management of this area is based on the waste hierarchy and focuses on waste prevention and reuse.

At the same time, Enea Group did not identify any situations in this area that would require remedial measures to be taken on behalf of the affected parties.

In 2025, LW Bogdanka:

  • continued to recover mining waste generated during the rinsing andpurification of minerals. The shale, which constitutes the company’s mining waste, is used, among other things, for land reclamation. LW Bogdanka conducts these actions among others in cooperation with partner research institutions. The company has also begun work on a new business area – the thermal disposal of medical waste, where design documentation has already been completed and a building permit has been obtained; a cooperation agreement is currently being drafted, and construction is scheduled to begin in the middle of 2026,
  • reduced the amount of waste generated by RG Bogdanka while increasing the rate of waste recovery. In accordance with the Materials andinventory management manual, the company classifies materials generated by its own operations. Timely maintenance and maximizing the reuse of serviceable materials and tools, including through regeneration, are standard practice at the company. RG Bogdanka stores waste and regularly transfers it to the authorized entities.

The key actions of Enea Wytwarzanie that align with the circular economy concept include:

  • maintaining the status of ash and gypsum as by-products and their use primarily inthe cement and construction industries. This enables to reduce the amount of combustion waste generated and provide by-products to the market,
  • maximizing sales of the ash and slag mixture extracted from the landfill, which is used in civil engineering projects and cement plants. Such actionsallow reducing the amount of natural aggregates extracted and replacing them with ash and slag mixture of anthropogenic origin.

Key actions undertaken by Enea Elektrownia Połaniec included:

  • the management of combustion by-products, such as ash and slag generatedby the combustion of coal and biomass, and synthetic gypsum produced during the flue gas desulfurization process, at a level no lower than the amount generated during the reporting year. Fly ash and gypsum from flue gas desulfurization are mainly processed at cement plants and used in the production of building materials,
  • increasing the proportion of biomass co-fired in units 2–7 to reduce emissions of sulfur oxides and carbon dioxide, while simultaneously reducing the amount of combustion waste generated. The company is carrying out modernization works on its existing biomass fuel supply system, which will result in the creation of appropriate conditions for unloading and storing (a high-storage shelter along withthe accompanying infrastructure) an increased volume of biomass fuel. Completion of the works will make it possible to increase the energy contribution of co-fired biomass relative to coal from the current 30% to approximately 45% in 2026.

Since August 2025 Elektrownia Połaniec has taken over from Enea Bioenergia the rights and obligation arising out of integrated permit to operate the Pióry combustion waste storage facility and sector-specific decisions.

Enea Nowa Energia started concept works on modernization to maximize the use of waste as a feedstock for biogas production. Currently, biogas power plants can use, among other things: corn silage, energy beet pulp, distillers’ grains, vegetable waste, and other plant-based waste. A by-product of biogas production is digestate, which qualifies as a fertilizer or soil conditioner. It offers an economical alternative to mineral fertilizers, supports sustainable agriculture, contributes to environmental protection, and helps farmers reduce production costs.

In power plants belonging to Enea Nowa Energia new materials are used only occasionally, specifically in the event of a breakdown or when damaged or worn-out components of the system need to be replaced. The company strives to purchase sufficiently durable materials and raw materials – in its procurement procedures, it specifies detailed requirements regarding the specifications of equipment and materials to ensure the selection of durable components with high recyclability.

In addition, all employees participate in regular training sessions on topics such as proper waste management.

In 2025 ENEA Operator joined the Competent Entrepreneurs in the Circular Economy program which aim is to comprehensively verify and identify opportunities to implement the circular economy principles at the company. In accordance with the program’s objectives, the support includes, among other things, the introduction of green procurement, expanding employees’ knowledge of the circular economy, analyzing opportunities for greater use of primary materials, and increasing the share of recycled materials. The aim of the program is to reduce emissions in the operations of Enea Operator.

As part of this project, eight thematic stages were completed, covering the scope and specific nature of Enea Operator, i.e.:

  1. Stage I – assessment and identification of the practical potential of the circular economy,
  2. Stage II – regulatory knowledge and practical application,
  3. Stage III – identification areas of improvement,
  4. Stage IV – industrial symbiosis and advanced circular economy models,
  5. Stage V – development of circular economy policy elements in accordance with the ESRS E5-1 standard,
  6. Stage VI – the workwear cycle in the circular economy model,
  7. Stage VII – green public procurement,
  8. Stage VIII – rules for green procurement in EU programs.

In 2025 one of the actions related to the resources undertaken by Enea Operator was an all-year campaign dedicated to waste management, covering the preparation of advice regarding handling waste and organization of competitions for employees and their families.

The infrastructure belonging to Enea Operator is regularly maintained, and damaged materials are repaired. It is standard practice in the company’s projects to assess which materials from dismantling are suitable for reuse or repair and continued use.

The service life of power infrastructure is at least several decades. After a long period of use, many of the existing systems must be replaced with new ones. In the power facilities operated by Enea Operator, durable materials have been used that are designed to be repairable and recyclable, in order to reduce waste and make efficient use of materials. The use of modular solutions allows for the replacement of individual infrastructure components.

Enea S.A.:

  • monitoring of EU and national regulations regarding circular economy to adapt tofuture market and technological changes.

Enea Oświetlenie:

  • the use of LED light fixtures with a longer service life,
  • regular maintenance of light poles extending their service life.

Enea Logistyka:

  • waste sorting and sending it for recycling,
  • reducing the use of disposable materials,
  • using packaging from purchased goods for secondary packaging,
  • conducting an awareness campaign on reducing the use of paper towels,
  • the introduction of mandatory double-sided printing,
  • replacing bottled water with water dispensers.

The Group has not allocated financial resources to support activities in E5 area. Measures are financed and allocated as part of current operations, depending on their scale and needs.

E5-3 Targets related to resource use and circular economy

Targets related to resource use are set forth in the Enea Group Sustainability Strategy. The document mentions the increase in the role of the circular economy in the Group’s operations as a voluntary strategic goal. In the Strategy Enea Group adopted the percentage of waste designated for reuse, recycling or recovery vs. all waste generated during the year. It helps prevent waste generation, prepare materials for reuse, and increase recycling rates in accordance with the waste management hierarchy, thereby minimizing the use of virgin materials. In the base year 2024 it was 58.7%. The target for 2030 is the value of the indicator above the level of 2024–2029, and for 2035 – above the level of 2024–2034. No reference was made to environmental thresholds when determining the indicator.

Percentage of waste designated for reuse, recycling or recovery vs. all waste generated during the year [%]

E5-4 – Resource inflows

Resource inflows [t] 2024 corrected data 2025
Total weight of products and technical and biological materials used in the reporting period 21,586,289.99 22,794,397.88
Total weight of products used in the reporting period 239,013.05 517,779.35
Total weight of technical materials used in the reporting period 19,533,349.27 20,205,768.61
Total weight of biological materials used in the reporting period 1,813,927.66 2,070,849.92
Percentage of sustainably sourced biological materials (and biofuels used for non-energy purposes) used to manufacture the products and provide services (including packaging) 84.38% 99.79%
Weight of sustainably sourced biological materials (and biofuels used for non-energy purposes) used to manufacture the products by the entity (including packaging) 1,530,580.85 2,066,453,53
Weight of sustainably sourced biological materials (and biofuels used for non-energy purposes) used to provide the services by the entity (including packaging) 0.00 0.00
Percentage of sustainably sourced biological materials (and biofuels used for non-energy purposes) used to manufacture the products by the entity (including packaging) 84.38% 99.79%
Percentage of sustainably sourced biological materials (and biofuels used for non-energy purposes) used to provide the services by the entity (including packaging) 0.00% 0.00%
Total weight of reused or recycled components, products and secondary materials used to manufacture the products and provide the services by the entity (including packaging) 11,367.21 12,948.99
Weight in absolute terms of reused or recycled components used to manufacture products by the entity (including packaging) 10,439.89 12,943.12
Absolute weight of reused or recycled components used to provide services by the entity (including packaging) 0.00 5.87
Absolute weight of reused or recycled products used to manufacture products by the entity (including packaging) 0.00 0.00
Absolute weight of reused or recycled products used to provide services by the entity (including packaging). 0.00 0.00
Absolute weight of secondary materials used to manufacture products by the entity (including packaging). 927.32 0.00
Absolute weight of secondary materials used to provide services by the entity (including packaging). 0.00 0.00
Percentage of reused or recycled components, products and secondary materials used to manufacture the products and provide the services by the entity (including packaging) 0.05% 0.06%
Resource inflows [t] 2024 corrected data 2025
Total weight of products and technical and biological materials used in the reporting period 21,586,289.99 22,794,397.88
Total weight of products used in the reporting period 239,013.05 517,779.35
Total weight of technical materials used in the reporting period 19,533,349.27 20,205,768.61
Total weight of biological materials used in the reporting period 1,813,927.66 2,070,849.92
Percentage of sustainably sourced biological materials (and biofuels used for non-energy purposes) used to manufacture the products and provide services (including packaging) 84.38% 99.79%
Weight of sustainably sourced biological materials (and biofuels used for non-energy purposes) used to manufacture the products by the entity (including packaging) 1,530,580.85 2,066,453,53
Weight of sustainably sourced biological materials (and biofuels used for non-energy purposes) used to provide the services by the entity (including packaging) 0.00 0.00
Percentage of sustainably sourced biological materials (and biofuels used for non-energy purposes) used to manufacture the products by the entity (including packaging) 84.38% 99.79%
Percentage of sustainably sourced biological materials (and biofuels used for non-energy purposes) used to provide the services by the entity (including packaging) 0.00% 0.00%
Total weight of reused or recycled components, products and secondary materials used to manufacture the products and provide the services by the entity (including packaging) 11,367.21 12,948.99
Weight in absolute terms of reused or recycled components used to manufacture products by the entity (including packaging) 10,439.89 12,943.12
Absolute weight of reused or recycled components used to provide services by the entity (including packaging) 0.00 5.87
Absolute weight of reused or recycled products used to manufacture products by the entity (including packaging) 0.00 0.00
Absolute weight of reused or recycled products used to provide services by the entity (including packaging). 0.00 0.00
Absolute weight of secondary materials used to manufacture products by the entity (including packaging). 927.32 0.00
Absolute weight of secondary materials used to provide services by the entity (including packaging). 0.00 0.00
Percentage of reused or recycled components, products and secondary materials used to manufacture the products and provide the services by the entity (including packaging) 0.05% 0.06%

Enea Elektrownia Połaniec and Enea Ciepło obtained all of their biological materials in a sustainable manner. The companies used biomass with an SDC (sustainable development criterion) certificate in the combustion plant. Moreover, the companies use the INiG SDC biomass origin certification system.  No Group companies apply the principle of cascading use when sourcing biological materials.

The stated weights are mostly derived from direct measurements taken by truck scales, company scales, conveyor belt scales and measuring meters. In the remaining companies, estimates were used in the absence of actual data. Data available on purchase documents were also used to determine the weights. Some of the equipment used to weigh products and materials has been certified. In the case of reused or recycled components, products and secondary materials used to manufacture products and provide services by the Group, the reuse and recycling categories do not overlap with each other. Accordingly, double counting has been avoided in the presented data. As regards the weight of reused or recycled components used to manufacture products, the total weight comes from LWB and pertains to paving, shackles and struts. The weight refers to all these components and has been accounted for once without additionally counting the recycled parts of these components. As for the weight of secondary materials used to manufacture products, the entire weight comes from Enea Nowa Energia. As in the case of LWB, the total weight of these materials is provided without additionally accounting for the proportion of these materials that come from recycling. The measurement of this metric has not been validated by an external body other than the assurance provider.

After certain resources were reclassified from the products category to technical materials category in Enea Wytwarzanie, data for the previous reporting period were corrected. The Total weight of products item was changed from 17,146,756.30 t to 239,013.05 t, while the Total weight of technical materials item from 2,625,606.02 to 19,533,349.27 t. The total mass of products, technical materials and biological materials remained the same. In 2024, due to a mathematical error in calculating the mass of reused or recycled components used in product manufacturing, a value of 12,029.19 t was incorrectly reported; the correct value was 10,439.89 t. This correction also affected the total aggregate mass of reused or recycled products, which changed from 12,956.51 t to 11,367.21 t, as well as the corresponding ratio, which moved from 0.06% to 0.05%.

E5-5 – Resource outflows

Waste generated [t] 2024 2025
Total amount of waste generated 5,839,662.47 5,766,104.86
Total amount of waste generated – hazardous waste 821.65 1,861.05
Total amount of waste generated – radioactive waste 0.00 0.00
Total amount of waste produced – non-hazardous waste 5,838,840.81 5,764,243.80
Total amount of waste for which disposal was avoided 3,427,623.37 3,307,759.01
Total amount of waste for which disposal was avoided – hazardous waste 580.99 911.66
Amount of hazardous waste for which disposal was avoided – preparation for reuse 9.16 65.08
Amount of hazardous waste for which disposal was avoided – recycling 224.00 52.70
Quantity of hazardous waste for which disposal was avoided – other recovery processes 347.83 793.44
Total quantity of waste for which disposal was avoided – non-hazardous waste 3.427.042,38 3,306,847.34
Quantity of non-hazardous waste for which disposal was avoided – preparing for reuse 4,674.74 267,166.46
Quantity of non-hazardous waste for which disposal was avoided – recycling 0.00 5,896.16
Quantity of non-hazardous waste for which disposal was avoided – other recovery processes 3,422,367.64 3,033,784.72
Total amount of waste for which disposal was avoided 3,427,623.37 3,307,759.01
Amount of waste for which disposal was avoided – preparation for reuse 4,845.55 267,231.54
Amount of waste for which disposal was avoided 317,450.42 5,948.86
Quantity of waste for which disposal was avoided – other recovery processes 3,105,327.40 3,034,578.16
Total quantity of waste sent for disposal 2,412,039.10 2,458,345.60
Total quantity of waste sent for disposal – hazardous waste 240.66 905.56
Quantity of hazardous waste sent for disposal – incineration 0.00 0.72
Quantity of hazardous waste sent for disposal – landfill 239.19 839.16
Quantity of hazardous waste sent for disposal – other disposal processes 1.47 65.68
Total quantity of waste sent for disposal – non-hazardous waste 2,411,798.44 2,457,440.04
Non-hazardous waste sent for disposal – incineration 0.00 0.00
Non-hazardous waste sent for disposal – landfill 2,411,362.18 2,456,310.26
Non-hazardous waste sent for disposal – other disposal processes 436.25 1,129.78
Total quantity of waste sent for disposal 2,412,039.10 2,458,345.60
Quantity of waste sent for disposal – incineration 1.66 0.72
Quantity of waste sent for disposal – landfill 2,411,595.62 2,457,149.42
Quantity of waste sent for disposal – other disposal processes 441.82 1,195.46
Total quantity of non-recycled waste 5,839,438.47 5,760,156.00
Percentage of non-recycled waste 99.99% 99.90%
Waste generated [t] 2024 2025
Total amount of waste generated 5,839,662.47 5,766,104.86
Total amount of waste generated – hazardous waste 821.65 1,861.05
Total amount of waste generated – radioactive waste 0.00 0.00
Total amount of waste produced – non-hazardous waste 5,838,840.81 5,764,243.80
Total amount of waste for which disposal was avoided 3,427,623.37 3,307,759.01
Total amount of waste for which disposal was avoided – hazardous waste 580.99 911.66
Amount of hazardous waste for which disposal was avoided – preparation for reuse 9.16 65.08
Amount of hazardous waste for which disposal was avoided – recycling 224.00 52.70
Quantity of hazardous waste for which disposal was avoided – other recovery processes 347.83 793.44
Total quantity of waste for which disposal was avoided – non-hazardous waste 3.427.042,38 3,306,847.34
Quantity of non-hazardous waste for which disposal was avoided – preparing for reuse 4,674.74 267,166.46
Quantity of non-hazardous waste for which disposal was avoided – recycling 0.00 5,896.16
Quantity of non-hazardous waste for which disposal was avoided – other recovery processes 3,422,367.64 3,033,784.72
Total amount of waste for which disposal was avoided 3,427,623.37 3,307,759.01
Amount of waste for which disposal was avoided – preparation for reuse 4,845.55 267,231.54
Amount of waste for which disposal was avoided 317,450.42 5,948.86
Quantity of waste for which disposal was avoided – other recovery processes 3,105,327.40 3,034,578.16
Total quantity of waste sent for disposal 2,412,039.10 2,458,345.60
Total quantity of waste sent for disposal – hazardous waste 240.66 905.56
Quantity of hazardous waste sent for disposal – incineration 0.00 0.72
Quantity of hazardous waste sent for disposal – landfill 239.19 839.16
Quantity of hazardous waste sent for disposal – other disposal processes 1.47 65.68
Total quantity of waste sent for disposal – non-hazardous waste 2,411,798.44 2,457,440.04
Non-hazardous waste sent for disposal – incineration 0.00 0.00
Non-hazardous waste sent for disposal – landfill 2,411,362.18 2,456,310.26
Non-hazardous waste sent for disposal – other disposal processes 436.25 1,129.78
Total quantity of waste sent for disposal 2,412,039.10 2,458,345.60
Quantity of waste sent for disposal – incineration 1.66 0.72
Quantity of waste sent for disposal – landfill 2,411,595.62 2,457,149.42
Quantity of waste sent for disposal – other disposal processes 441.82 1,195.46
Total quantity of non-recycled waste 5,839,438.47 5,760,156.00
Percentage of non-recycled waste 99.99% 99.90%

The data on the waste generated have been obtained mainly from direct measurements taken by the companies and from data entered into the Database on Products and Packaging and Waste Management (BDO) based on these measurements. The devices used by the largest companies in terms of waste generation to measure the weight of the waste generated are certified.

The largest part of waste generated by the Enea Group is waste generated by the rinsing and purification of minerals. This is waste from the mining of hard coal deposits by Lubelski Węgiel Bogdanka S.A. Another significant stream is waste from the generation of electricity and heat by Enea Wytwarzanie, Enea Elektrownia Połaniec and Enea Ciepło (Białystok CHP Plant Division). These are mainly ashes, ash-slag mixtures and gypsum.

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)
Energy resources and materials Use of energy resources P, A, T
Use of biomass P, A, T
By-product generation through resource use P, A, T
Management of by-products of the combustion and flue gas desulfurization process (ashes, slag, ash and slag mixture, gypsum) P, A, T
Regulatory and market risks associated with limited availability or unavailability of (wood, agricultural) biomass, resulting in failure to meet emission parameters and loss of revenue from the capacity market P, A
Risk of conflicts with NGOs due to the use of biomass P, A
Possibility to recycle by-products of the combustion and flue gas desulfurization process, resulting in the reduction of their disposal costs P, A, T
Possibility to increase the value of and to sell by-products of the combustion and flue gas desulfurization process which may generate additional revenues P, A, T
Waste Generation of waste, including hazardous waste P, A
Material topic IRO Name Policies (P), Actions (A),
Targets (T)
Energy resources and materials Use of energy resources P, A, T
Use of biomass P, A, T
By-product generation through resource use P, A, T
Management of by-products of the combustion and flue gas desulfurization process (ashes, slag, ash and slag mixture, gypsum) P, A, T
Regulatory and market risks associated with limited availability or unavailability of (wood, agricultural) biomass, resulting in failure to meet emission parameters and loss of revenue from the capacity market P, A
Risk of conflicts with NGOs due to the use of biomass P, A
Possibility to recycle by-products of the combustion and flue gas desulfurization process, resulting in the reduction of their disposal costs P, A, T
Possibility to increase the value of and to sell by-products of the combustion and flue gas desulfurization process which may generate additional revenues P, A, T
Waste Generation of waste, including hazardous waste P, A
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