GOV-5 Risk management and internal controls over sustainability reporting

During the reporting period, the Enea Group maintained a risk management process and internal controls related to sustainability reporting. Responsibility for reporting has been assigned to the ESG Department, which collaborates with the Controlling Department and the Risk Management Department in this regard.

The organization has in place procedures for addressing issues related to sustainable development. The ESG Department Director holds regular meetings with the Management Board Member for Corporate Matters, who is responsible for overseeing ESG issues across the Enea Group. The matters of risk management and internal control for the purposes of sustainability reporting are also addressed during these meetings.

In order to minimize the risk of errors in the data collection process, the Enea Group applies internal control principles to the data collection process, such as a two-stage review of information provided.

In 2025, the management of risks and opportunities identified in the double materiality analysis was incorporated into the Enea Group’s risk management system. The ESG risk assessment method is described in section IRO-1.w podrozdziale IRO-1.

The ESG risk assessment at the Enea Group was conducted in accordance with the Enea Group’s Methodology for Managing ESG Risks and Opportunities, under which risks were assessed in terms of likelihood and financial impact on a four-point scale. They are assigned a rating based on the product of the probability assessment and the maximum financial impact of the risk. Risks rated between 8 and 12 are key, while risks rated 16 are critical. Key and critical risks are reported for disclosure purposes in the sustainability report. In addition, as part of the risk assessment, time horizons are defined for the short term (up to 1 year), the medium term (more than 1 year up to 5 years), and the long term (up to 15 years). The results of the ESG risk assessment are used in the Enea Group’s risk management process to analyze and identify operational and strategic risks.

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