ESRS S4 Consumers and end-users

The Enea Group has adopted policies for managing key sustainability issues with regard to all consumers and end users. The key regulations pertaining to the Customer Relations topics are:

1. Best Practices of Electricity and Gaseous Fuel Suppliers – a code of best practices within the meaning of the Act of 23 August 2007 on Combating Unfair Market Practices (Journal of Laws No. 171, item 1206). The Code also commits the Enea Group to complying with the principles of the Energy Trading Association and, in this regard, is subject to an annual audit conducted by an independent certification body. The document contains both provisions based on mandatory legal requirements and additional practices adopted by sellers to protect the interests of customers. In accordance with the Code of Best Practice for Sellers, the content and form of contracts with consumers should be clear and unambiguous and the marketing materials used by sellers must contain only accurate information that does not mislead consumers. The document also addresses issues related to contract termination, changes to contract terms and the protection of personal data. It is not specified whether the document was developed with the participation of stakeholders.
2. Enea Group Communication Policy – the purpose of this document is to ensure credible and responsible communication, including communication with end users. The Policy requires communication that is appropriate to the situation and the audience, proactive, consistent, accessible and two-way.
3. Complaint Handling Policy – the purpose of this document is to ensure that complaints are handled in accordance with applicable laws and internal policies.

With the exception of Enea Operator¹, the Group’s companies do not make their Code of Best Practice publicly available. The Seller Policies are available on the website² and Enea Group employees can access them through the internal IT system. In 2025, the content of the documents remained unchanged.

The documents were prepared without consulting end users. Policies regarding the management of material sustainability issues related to consumers, like other policies, are approved by the Enea S.A. Management Board or the management boards of companies within the Enea Group, as well as by directors reporting to management board members.

In 2025, the Enea Group did not have a uniform human rights policy in place for consumers and end-users. Nevertheless, in accordance with the Enea Group Code of Ethics, the Enea Group adheres to the principle of equal treatment and non-discrimination, which it applies not only to its employees but also to its customers. In addition, the documents listed above address human rights issues in the context of customers and consumers, including the rights to information, safety, privacy and the right to file complaints.

Although the Enea Group Code of Ethics was not drafted based on the UN Guiding Principles on Business and Human Rights, the organization believes that its provisions reflect the values set forth in those principles. Throughout the entire value chain, the companies of the Enea Group have not recorded any instances of non-compliance with the UN Guiding Principles on Business and Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises with regard to consumers or end users.

Some of the companies within the Enea Group whose operations involve consumers comply with the provisions of the Compendium of Electricity Consumer Rights. The Compendium, which was developed by the Energy Regulatory Office in cooperation with the Office of Competition and Consumer Protection, defines in detail the rights of electricity consumers and the obligations of energy companies. The individual chapters of the Compendium address, among other things, issues related to grid connections, the right to choose a supplier, rates, payments, complaints, social initiatives for energy consumers and the prevention of unfair market practices.

¹ At Enea Operator, the Code of Good Practice is available on the website: O Enei Operator | Enea Operator
² https://www.enea.pl/dla-domu/dobre-praktyki-sprzedawcow

For the Product Development and Management Division of Enea S.A., consumer opinions and expectations are among the key elements of the management process that influence decisions regarding environmental, social and economic impacts. In this process, the organization takes into account available satisfaction surveys (NPS, Customer Experience, CSI), analyses of complaints and inquiries submitted to Enea S.A. through available contact channels, findings from consultations conducted during the rollout of new products – such as dynamic rates, energy storage solutions, and loyalty programs – as well as analyses of the impact of regulatory changes on customers. These opinions, which also come from people who work directly with customers, have a significant impact on service design – including efforts to simplify documents, implement e-invoicing and introduce self-service solutions. Feedback from consumers also informs initiatives aimed at improving accessibility, such as appointment scheduling systems, new in-person and mobile Customer Service Offices, e-Contracts, e-Forms, the development of the Electronic Customer Service Offices (eBOK), and the Moja Enea app.

During the reporting year under review, changes to our offerings and analytical activities were also driven by customer feedback, which was primarily relayed through the Customer Service Offices. In particular, the review examined whether customers were required to provide an email address (a potential barrier for the digitally excluded), whether offers promoting environmental themes posed a risk of greenwashing, and whether information regarding the source of energy was transparent.

At Enea Ciepło, our collaboration with customers is aimed at ensuring the stability and security of supply, effective communication, education and dialog. It pertains to the rights and obligations of the parties and is strictly regulated by law (in the Energy Law, decisions of the Energy Regulatory Office and regulations). The heat consumer has limited ability to negotiate the price, but has the right to full information. The collaboration covers both commercial support under existing sales agreements and technical support (hubs, parameters and breakdowns). Well-maintained heating systems mean fewer breakdowns and fewer complaints. The key is supply continuity, quick response and clear communication. The Customer Service Office plays a significant role in this area; in addition to its core responsibilities, it handles customer reports of outages and complaints regarding heat supply, and provides advisory and educational services – for example, explaining what contracted capacity is, how to use heat efficiently, and how to reduce costs.

At Enea Operator, the Director of the Distribution Services Sales Department and the Director of the Planning and Development Department are primarily responsible for operational cooperation with consumers and end users. The directors of the Development and Investment Departments in the individual Distribution Branches and the directors of the Distribution Regions are also involved in the process.

Enea Centrum collects feedback from consumers and end users to monitor the proper execution of processes and, in particular, to identify and eliminate the so-called pain points. The information collected is used to analyze the effort customers put into interacting with the company and to implement measures aimed at reducing that effort. The primary goal of these activities, as identified through feedback analysis, is to improve customer satisfaction and increase the likelihood that customers will recommend Enea’s services to others.

The highest-ranking position in the company responsible for overseeing customer relations is the Management Board Member for Commercial Matters, who reports directly to the President of the Management Board.

The effectiveness of cooperation with consumers is assessed, among other things, by analyzing the reasons why consumers have approached the Negotiation Coordinator attached to the President of the Energy Regulatory Office to seek an amicable resolution of disputes. Enea Centrum also analyzes CSAT satisfaction levels and NPS recommendation scores, as described above.

The Enea Group has established channels through which all end users can directly report their concerns or needs. Information about them is published on the websites of Enea Group companies, in correspondence and on invoices, as well as in notifications in the mobile app. The company responsible for customer service – including handling incoming inquiries – is Enea Centrum.

Enea Operator has also implemented its own channels that allow end users to report issues. These include a hotline, an online form and the Energy Emergency Service. End users can also turn to the Energy Regulatory Office, the Office of Competition and Consumer Protection and the Consumer Federation.

Some of the other companies within the Enea Group offer various ways to submit comments, requests and complaints, tailored to the specific nature of their business operations. These are typically multi-channel solutions that include both traditional methods (in-person contact at brick-and-mortar and mobile Customer Service Offices, hotlines and written correspondence) and digital tools (dedicated email addresses, chat services, online forms, eBOK, mobile apps and the ePUAP and e-Delivery platforms).

The letters that the Enea Group sends to its customers state that customers may appeal the decision to the Negotiation Coordinator reporting to the President of the Energy Regulatory Office. Every consumer of services and products provided by the Enea Group has this right. Most of the information provided on behalf of end users by government agencies (ERO, UOKiK and county/municipal consumer ombudsmen) is handled by Enea S.A. The exception is Enea Operator, which handles such matters independently.

³ https://www.enea.pl/strona-korporacyjna/zglaszanie-naruszen

The companies of the Enea Group monitor the effectiveness of their reporting channels. According to Enea Centrum, the channels made available to end users are designed to ensure high effectiveness. In addition, the company ensures adequate access to expertise and consultation, and in its dealings with complainants, it focuses on dialog as a means of reaching mutually agreed-upon solutions.

Enea S.A., Enea Operator, Enea Centrum and Enea Ciepło analyze, among other things, the number and type of complaints received, the timeliness of responses, the accuracy of billing, the timeliness of email support for inquiries and the average waiting time at the Customer Service Office.

The companies of the Enea Group do not have the necessary information to accurately assess the effectiveness of the channels made available to end users by third parties. However, in the organization’s assessment, the number of cases referred through the Compliance Committee, the Energy Regulatory Office and the Negotiation Coordinator attached to the President of the Energy Regulatory Office indicates that these channels are available to consumers and are being used by them. During the reporting period, Enea Operator was involved in 761 cases in investigative and administrative proceedings conducted by the Office and the Negotiation Coordinator attached to the President of the Energy Regulatory Office.

The Enea Group has implemented a range of corrective measures, which, in the case of key energy companies, are strictly regulated by law.

At Enea Centrum, the primary corrective measures include revising contract terms, correcting billing and providing compensation in the event of documented damage. The list of corrective actions also includes issuing an apology to the affected customer. In situations where damage has been caused directly by the negative actions of the entity’s employees, the redress mechanism provides for the payment of compensation to consumers or end users under the liability insurance policy.

At Enea Operator and Enea Centrum, the corrective measures are strictly based on the provisions of the Energy Law and its implementing regulations, which require the company to grant discounts in the event of failure to meet customer service quality standards. This system provides for financial compensation calculated as a fraction of the average wage in the national economy. Customers are entitled to discounts in specific situations, such as unreasonable delays in resolving power supply disruptions, failure to provide advance notice of planned outages or failure to provide information on the expected time of service restoration. These regulations also cover situations where there is a lack of information regarding changes to network parameters or the need to modify the customer’s installation.

At Enea S.A., in the event of any personal data breach, the Personal Data Protection Office implements corrective measures to address the consequences of the breach and secure the data. This is carried out in accordance with the Procedure for Handling Personal Data Breaches. The process also includes an analysis of the causes of incidents, which enables the implementation of measures to mitigate the risk of similar incidents occurring in the future. The most common mitigation measure is to send employees to training sessions on personal data protection.

At heating companies, such as Enea Ciepło and MEC Piła, corrective measures are based on strict legal regulations and business continuity management systems. Enea Ciepło offers consumers discounts for failing to meet the quality standards for the heat it supplies. The company also charges fees for the inconvenience caused by the installation of heating infrastructure on third-party land. At MEC Piła, the key mechanism for mitigating negative impacts on customers is the Business Continuity Management System, which defines the parameters for acceptable downtime and the required time to restore service functionality. Another component of the corrective and preventive measures is a comprehensive information policy – the company provides detailed technical data on the status of the network, any outages that have occurred and planned modernization work.

During the reporting year, our activities focused on educational and product-related issues and were designed to support customers in the face of changes in the energy market and the energy transition. No specific results of the activities have been defined.

In addition, Enea Operator conducts a range of information campaigns aimed at educating consumers about the safe use of energy and encouraging them to consume as much electricity as possible that is generated from renewable energy sources. The company has introduced eco-friendly rate plans as well as special products and services designed to encourage consumers to use energy and draw power at specific times. In 2025, Enea Operator and Enea S.A. also launched a new website – one that is transparent and user-friendly. The website’s structure reflects customers’ interests and its various features make it easier to find information and communicate with the company.

At Enea Centrum, key efforts focused on improving service efficiency⁴. These included the digitization and automation of customer interactions, such as the implementation of AI-powered bots in the Contact Center, the development of self-service tools in the eBOK and the Moja Enea mobile app and the introduction of online contract signing and the delivery of electronic documents via email. In addition, the company has implemented a division of responsibilities in the areas of debt collection and customer service, as well as the Simple Service initiative, designed to streamline the processes that account for 80% of the workload in these areas. Enea Centrum is also implementing solutions designed to simplify invoices, improve their readability and streamline billing processes, including the Simple Invoice initiative and efforts to promote e-invoicing.

The types of initiatives designed to address consumer needs are the result of a process that involves monitoring the quality of customer service, as well as reporting on and analyzing key performance indicators (KPIs).

⁴ Completion of some of the described activities is scheduled for 2026.

Enea Ciepło strives to ensure the continuity, safety and stability of its supply on several levels. The first is securing backup heat sources (activated in the event of a failure or severe cold spells), fuel diversification (gas, coal, biomass, fuel oil), which reduces the risk of outages, and cogeneration (the simultaneous production of heat and electricity), which increases the system’s stability. The second level involves monitoring devices (networks and hubs), enabling continuous monitoring of parameters (pressure, temperature), rapid leak detection, and diagnostics (detecting failures before they occur). The third level involves inspections and repairs of equipment in heat distribution stations, the modernization of district heating networks (replacing old duct pipes with new pre-insulated pipes, which reduces heat loss) and close cooperation with customers regarding planned outages and the maintenance of customer-owned heat distribution stations and heating systems. The company also offers a 24-hour heating emergency service, which remains on standby at all times to respond to customer reports. Cybersecurity for control systems and physical security (critical infrastructure) are becoming increasingly important aspects of supply security.

Enea Operator provides consumers with remedies in the form of credits, including for power outages that exceed the standards set forth in the implementing regulations of the Energy Law. The company also offers discounts in areas where the distribution network does not meet the standards for rated voltage. In 2025, the company expanded its claims reporting procedures to include claims from prosumers resulting from irregularities in the distribution network – such irregularities can prevent energy generated by installations from being fed into the grid.

Discounts for heat consumers are not discretionary – they are strictly regulated by law, specifically in the Energy Law and its implementing regulations. The Law stipulates the obligation to grant discounts and refers to implementing regulations regarding the specific rules for granting them. These, in turn, define when the discount is due, specify its amount and outline how it is calculated. Enea Ciepło grants discounts for exceeding the permissible duration of heat supply interruptions, as well as for failing to meet quality standards (contractual heat supply parameters) and customer service standards.

At Enea Operator, several units manage key aspects of consumer engagement in accordance with organizational regulations. These are: the Distribution Services Sales Department, the Planning and Development Department, the Metering Information Management Department, the Traffic Management Department, the Operator Services and Tariffs Department, the Controlling and Risk Management Office, the Information Security and Defense Affairs Office and the Support Department.

At Enea Ciepło, numerous organizational units are involved in matters concerning consumers and end users, i.e. heat customers, in accordance with the company’s established regulations. These include: the Organization and Trade Department (including the Customer Service Office), the Controlling and Tariff Department and the Technical and Production Divisions, which carry out activities on behalf of consumers and end users in the areas of heat production, investments and equipment operation.

The effectiveness of measures related to energy supply security and reliability is monitored by calculating the SAIDI and SAIFI indicators.

Share of green energy in retail sales[%]

The strategic objective regarding customer satisfaction covers two areas: implementing measures to improve customer service quality, and developing and ensuring the security of the distribution network. The expected results regarding supply reliability are measured using the SAIDI and SAIFI indicators. The table below shows the progress toward achieving the goals in 2024 and 2025.

In addition, at Enea S.A., a permanent, long-term goal regarding personal data protection is to reduce incidents to a minimum relative to a baseline of 100 incidents (2023). The target is in line with the Enea Group Personal Data Protection Policy, which states that the Group must establish a personal data protection processing and management system that complies with the applicable legal requirements. The company set this target based on its monitoring of the number of incidents, without consulting stakeholders, consumers or end users, who also do not track the extent to which the target has been met or provide their feedback.