ESRS S3 Affected communities

The aims of the Policy are monitored by appropriate organizational units responsible at the Enea Group for maintaining relations with stakeholders.

• The Enea Group Social Engagement Policy, which defines the mission, aims, principles and priority areas of social activities performed in the Enea Group, in accordance with the Enea Group Development Strategy to 2035 until 2035 and the assumptions of the ESG Strategy. The document is a primary strategic act in force in all the Enea Group companies with regard to planning, performing and reporting activities connected with social involvement The Policy aims to, among others:
  • strengthen relations with local communities,
  • support education about ecology and energy,
  • promote health and social well-being,
  • develop partnerships with local governments and social organizations,
  • promote diversity, integration and social inclusion.
• Rules for social engagement activities¹, which outline the procedures for collaborating with local social partners, the local government and organizations working on behalf of local communities, as well as the process for evaluating initiatives, planning activities and reporting on their results.

Impacts and actions connected with socially responsible transformation of regions follow directly from the Development Strategy, so it is not planned to prepare a policy in this area.

The first two documents were adopted by the Management Board of the parent company in the Enea Group and are applicable to all  the companies making up the organization. It is the Enea S.A. Management Board that is responsible for adopting regulations, whereas the managing unit is the ESG Department. The documents do not refer directly to standards adopted internationally, and while they were being prepared, no consultations were held with affected communities.

In the reporting period, there was no separate policy in force at the Enea Group concerning human rights with reference to affected communities. The organization has not implemented such a regulation because issues of human rights are covered  by other corporate documents, including the Stakeholder Engagement Policy, the Enea Group Social Engagement Policy, Rules  for social engagement  activities, Rules and Regulations  of the ESG Management Division (defining the overarching framework of ESG responsibility and oversight) and the Code of Ethics of the Enea Group. The above regulations specify activities in which  the Enea Group is not involved. These are activities of political or religious nature, discriminating activities or those violating the law or generally accepted social norms. The further sections of the chapter describe specific paths of proceeding in the event  of violations.

Regulations about affected communities are consistent  with values and guidelines for human rights established at the international level.

In 2025, the Enea Group did not record any cases of breaching international guidelines  for human rights relating to affected communities neither in its operating activity nor in the value chain.

¹ Adopted by all the Enea Group companies, except for Lubelski Węgiel Bogdanka S.A

The type and intensity of cooperation with local communities are adjusted each time to the nature of a project, its scale and potential impact. The Office acquires opinions directly from local communities – social partners, organizations, schools, local governments and residents as well as stakeholders who are party to social consultations. The Company also closely cooperates with local government units and public institutions representing social interests.

The Company takes into consideration opinions of local communities, among others while preparing annual plans of social activities, assessing and selecting social partners and performing social projects. Remarks communicated by the communities may result in adjustments to the performed activities. One of the initiatives which takes into consideration opinions of a local community is the cooperation of Enea Wytwarzanie with Bogusław Klimczuk Cultural Center in Kozienice during the organization of Children’s University of Science and Culture. The project responded to the needs reported by the local community so as to increase access of children aged 6–11 to attractive educational forms of intellectual and cultural development.

The unit managing social engagement at the Company is the Head of the Social Engagement Office. The Head fulfills a substantive, operational and coordinating role, being responsible for contacts with partners, assessment of projects, planning activities and reporting.

Also, Enea Operator holds a structured dialog with key groups of stakeholders – local communities and local government units – which translates directly into the company’s planning and operating processes. Opinions are given by participants of village meetings and housing estate councils are taken into account at the stage of planning an investment project. It occurred, for example, while selecting the placement of a high-voltage power line, defining the location of the Main Power Supply Point (GPZ) in Słubice and in the Złotów municipality. Since 2024, the company has intensified dialog with energy producers, organizing regular meetings and webinars, and provides access to a special portal to provide knowledge about connecting RES and grid balancing as well as market requirements. The cooperation model also includes technical dialog with suppliers and contractors during procurement procedures and formalized cooperation with uniformed services to work out procedures of reacting in crises. These measures contribute to a socially responsible transformation of the regions.

At Enea Operator, the key persons who work with affected communities are the director of the local distribution branch (for investment projects) and the director or manager responsible for the relevant area (for other projects). The basis for operational cooperation is the formation of teams for each project, comprising representatives from the relevant departments, such as the technical, communication and security departments, as well as the contractor’s representatives. The company’s Management Board is the most important body responsible for managing the company and is often directly involved in cooperation with county and voivodship authorities.

.] At the Enea Group, assessment of the effectiveness of cooperation with affected communities is a formal and cyclical process, supervised by the Social Engagement Unit and based on Principles of social engagement activities. The effectiveness verification system includes, among other things:

• internal and external reports submitted by the Enea Group companies on a quarterly and annual basis,
• verification of compliance of the activities with approved annual plans and strategic social objectives,
• dialog with stakeholders whose quality is assessed on the basis consultations, investigations and opinions as well as meetings with representatives of local communities.

The Social Engagement Office of Enea S.A. obtains opinions from representatives of particularly vulnerable local communities, including local government units, schools, children’s homes, childcare institutions and non-governmental organizations. In addition, the Unit takes into consideration the information received during social consultations and dialog with local stakeholders. Another mechanisms supporting dialog are quarterly and annual reports on social activities which record reported needs and the scale of support provided to each group.

The Social Engagement Office plays the role of an operating and coordinating unit and operates within the ESG Department, which is responsible for integrating results of social activities with the Group’s strategic objectives. The Office closely cooperates with coordinators of social activities in the Group companies – cyclical, working and workshop meetings are organized to work out uniform directions, criteria and performance indicators.

Each identified need or proposal to act is assigned to one of the four strategic pillars of social engagement which are the key mechanism for streamlining and selecting activities at Enea S.A.

• Environmental protection and ecology
  measures to mitigate or compensate for the environmental impact of energy-related activities (e.g. land restoration, green infrastructure, environmental education)
  
• Science and education
  strengthening competences, awareness of energy transition and human capital (children, youth, adults)
• Health protection and promotion
  activities meeting the health needs of communities and employees
  
• Development and activation of social
  initiatives strengthening social resilience, local bonds and grass-roots initiatives.

This assessment serves as the basis for recommending compensatory, educational or relational interventions. For initiatives addressed to specific communities or regions, the Office conducts consultations with relevant stakeholders (e.g. local government bodies, nongovernmental organizations, local partners) and then prepares a proposal for formal approval within ESG procedures. Only after having been approved is the activity included in the annual plan of social activities or implemented as a supplementary initiative.

LW Bogdanka identifies needs of affected communities in cooperation with stakeholders and institutions. The Company carries out mitigation measures related to the remediation of mining damage, as described in greater detail in the environmental chapter.

At Enea Operator, a group particularly vulnerable to a potential adverse impact resulting from the Enea Group’s activity are natural persons on whose land infrastructure elements have been or will be located. The Company pays damages to such individuals, enters into land easement agreements with them and minimizes adverse consequences of investment projects by, e.g. plantings or putting up screens.

The general communication channels which operate in the Group serve dialog with stakeholders rather than reporting concerns by communities affected by the impacts of the Group’s activity. More information about channels for reporting can be found in chapter G1.

The Enea Group believes that affected communities are aware of the existence of the channels because they take part in social consultations and report mining damage.

The Enea Group did not find the presence of indigenous peoples in the territory of its activities, as a result of which there are no procedures which would take into account their customs or legal systems.

In the reporting period, the majority of the Enea Group companies took actions associated with material impacts on affected communities as presented in a table at the beginning of the chapter.

The Enea Group makes efforts to ensure that practice in the area social investments and cooperation with the neighborhood does not generate any adverse consequences for local residents. The process of mitigating adverse impacts (described in disclosure S3-3) involves, among other things, reviewing projects for social neutrality or positive social impact, also with respect to identified impacts. The Group does not perform projects which could cause conflicts or such that cause the risk of occurrence of conflicting interests between the Enea Group and the local community and lead to social tensions, protests, complaints or deterioration of relations with stakeholders. In practice, this means projects interfering with everyday life of residents, reducing resources in the public space or causing environmental and social nuisance.

In regions particularly vulnerable to tensions related to energy transition, Enea S.A. performs compensatory, educational and relation-building programs. Some of the activities are repair measures to minimize adverse impacts connected, for example, with the production activity, but most of them aim to develop the local community and the region and support the whole process of energy transition.

Key measures performed at the level of the Enea Group and selected companies can be divided into several categories:

The key actions included:

• the Enea Academy of Talent program (6th edition in 2024 and preparation of the 7th edition for 2025) providing equal educational opportunities for children and youth from the region of operation of the Enea Group and awarding grants for educational projects for schools and organizations
• the Exempt from Theory program (2024/2025 edition and planned 2025/2026) supporting practical education, raising competences of young people and strengthening social capital in the regions,
• the Running–Collecting–Helping strengthening social integration and promoting physical culture, which motivates employees and local communities to take up physical activity, whereas collected kilometers are converted into measurable support for local organizations,
• the CukierAsy (SugarAces) program, whose aim is to disseminate knowledge on type 1 diabetes, especially in the context of physical efforts, and due to this improve social well-being of children and families in particularly vulnerable locations (the Company financed educational and developmental actions),
• Political Leadership School (2025 edition) aiming to build competences or future social and civic leaders and strengthen the potential of young candidates for leaders in the region of the Enea Group’s operation, which is not only to raise qualifications of the participants but also develop attitudes conducive to openness to civic dialog,
• intensifying protection of active flora and fauna of the Lublin Polesie region and the Lublin area due to protective and educational initiatives performed in cooperation with local and regional environmental and social organizations and institutions, especially the Polesie National Park,
• local initiatives in Łęczna and mining regions, or areas particularly affected by energy transition, supporting their social and cultural development and measures mitigating consequences of the transition.

• Short-term perspective (up to one year) includes cyclical educational and social projects and current measures responding to identified needs of local communities and authorities. The residents gain direct access to educational, social and health promoting actions, taken in response to current local needs, which translates into a fast improvement of accessibility of the social offer and reducing the risk of exclusion.
• The medium-term perspective (one to three years) focuses on building stable partnerships and long-term cooperation with our stakeholders. In this horizon, it is essential to strengthen the educational potential of regions and support areas undergoing energy transition through initiatives that extend beyond the annual budget cycle. The residents benefit from a sustained improvement in educational and social skills, ongoing support stemming from long-standing partnerships and greater social resilience in the regions, including those undergoing energy transition.
• The long-term perspective (more than three years) encompasses strategic initiatives aimed at systematically building social capital in local communities, in particular by strengthening local cultural institutions and community organizations, creating spaces for dialog and cooperation and developing skills of local leaders and community activists.

In 2025, the financial resources allocated by the parent company to affected communities consisted exclusively of operating expenditure (Opex) related to social programs and initiatives implemented under the Social Engagement Principles, the Stakeholder Engagement Policy, and the ESG Department Regulations. The measures were financed only from the own resources of the Enea Group, without the need to use sustainable financing instruments, such as social bonds. In 2025, Enea S.A. devoted PLN 1.4 million for the above. In financial statements of Enea S.A., operational expenses are not presented as a separate item but as a significant category of costs of operating activity. The Group makes use of available non-financial resources, in particular the work of its team and collaboration with local partners. These activities are carried out in accordance with established procedures, and in regions undergoing transition, they take into account results of dialog with stakeholders.

Example projects:

• Future after departure from using coal social dialog and dialog meetings for the community of the Łęczna municipality – social diagnosis of the Łęczna municipality and organization of three dialog meetings with the residents with preparation of the final report and information materials summing up the activities (contract value – PLN 306 thousand),

• Exempt from Theory – Enea Program cooperation on the organization of the Polish nationwide Exempt from Theory contest covering support of at least 60 social projects performed by youth, communication and promotional actions of the Enea Program, coordination of project teams and participation of Enea representatives in summary activities, including the Grand Final of the Contest (contract value – PLN 270 thousand).

In 2026, the Enea Group plans to increase operating expenses on affected communities.

The parent company in the Enea Group implemented processes due to which, if needed, it is possible to introduce repair measures (more information in disclosure S3-3). These include procedures and compliance, monitoring of social partners and project progress, as well as channels for submitting feedback.

Effectiveness monitoring applies only to activities for which the Office bears operational responsibility and for which verifiable data is available, in accordance with the procedures described.

The assessment of effectiveness includes, in particular:

• an annual review of social projects and initiatives, including verification of the achievement of quantitative and participation targets, an assessment of the quality of collaboration with local stakeholders, and confirmation that activities align with ESG goals and social engagement principles,
• monitoring of qualitative indicators derived from the ESG Strategy, including the number of projects targeting local communities, the number of recipients and beneficiaries of activities, and the number of social and institutional partnerships (these are not financial indicators nor do they measure the impact outcome; they merely reflect the scope of the Department’s actual impact),
• an analysis of feedback from stakeholders, including an assessment of the extent to which project objectives have been achieved and the alignment of activities with social expectations identified through dialog with stakeholders,

• an assessment of the quality and sustainability of the collaboration, with the continuity of the collaboration – including the continuation of projects by schools, organizations, and local partners – being considered a key indicator of effectiveness,
• participation in the identification of ESG risks and opportunities by reporting observations arising from ongoing activities and social signals that are significant from a relational and reputational perspective,
• verification of the alignment of projects with the priorities of the Enea Group, including education, the environment, health, culture and sports, as well as with the principles of transparency, neutrality and procedural compliance.

LW Bogdanka evaluates ongoing projects aimed at affected communities to ensure they align with the ESG Strategy.

Enea S.A. is taking steps to ensure the availability and effectiveness of corrective measures. The Company provides stakeholders with dedicated channels for reporting issues, takes into account feedback received during consultations as part of community programs, and responds to input from local governments, partner institutions and nongovernmental organizations. Thanks to this approach, affected communities can actually provide feedback on any potential negative impacts of Enea Group’s activities.

At the same time, the Company keeps track of reports and how they are handled, and analyzes them in terms of ESG risks and social impact.

With regard to material opportunities for the communities it serves, the Enea Group focuses on initiatives that support local communities, educational development, and youth engagement, thereby helping to build positive relationships between the company and local communities. Key initiatives include supporting education and future-oriented skills, promoting a healthy lifestyle, fostering neighborhood integration and building local community ties. In key locations for its operations, the Group also collaborates with cultural institutions, schools and local governments with whom it carries out joint projects of social significance.

In 2025, the companies of the Enea Group did not report any serious human rights issues or incidents in the affected communities.

In 2025, the Enea Group developed and implemented the Enea Group Sustainability Strategy to 2035. Under the Active Partner for the Community pillar, voluntary goals have been established, to which corresponding initiatives and indicators have been assigned. These refer to the impact that the Enea Group has on local communities; however, they were not consulted when the following goals were set:

• Developing local social programs and expanding the pool of beneficiaries – a goal measured by two indicators:
  • the number of beneficiaries/spectators, which is expected to rise to 2,100 in 2035, compared to 1,500 in 2024;
  • the number of beneficiaries of these initiatives (training participants, residents, employees), which is expected to reach 300,000 by 2035

• Development and implementation of standards for cooperation with local communities – an initiative aimed at improving cooperation, monitored and measured by the number of meetings held by the team comprising representatives from all companies responsible for engaging with local communities. The number of meetings is measured on an annual basis. The value of the index in 2035 should be 2.

For more information on the ESG Strategy, please refer to Disclosure SBM-1 in this Report. The issue of monitoring the effectiveness of policies and actions taken regarding significant impacts, risks and opportunities related to affected communities is described in this Report in Disclosure S3-4.

In terms of its impact on affected communities, the Group aims to manage social projects in a reliable and transparent manner and to mitigate risks to local communities. Progress is assessed based on qualitative indicators, including project compliance with applicable documents, an evaluation of social impacts, an analysis of reputational risks, the proper delivery of services and the completeness of documentation.

Enea S.A. also uses process metrics, such as the number of projects carried out in accordance with procedures, the number of projects subject to ESG assessment and the degree of fulfillment of obligations under signed contracts. These indicators allow us to monitor progress in a verifiable manner that is appropriate to the actual scope of the Company’s operations, without reporting data that is not measured or used in practice.