Taxonomy Disclosures

Commission Delegated Regulation (EU) 2026/73, which entered into force on 28 January 2026, implemented changes to the quantitative disclosure templates. Under the aforementioned regulation, companies may choose which disclosure templates to use for 2025 – they may use the templates used last year or those introduced by Regulation 2026/73. The Enea Group has decided to adopt new disclosure templates. Nevertheless, it should be noted that the comparability of the KPIs for 2024 and 2025 has been preserved almost entirely, as the calculation methodology has not changed. In addition, the changes to the “do no significant harm” principle, implemented by the same regulation, did not have a clear impact on the assessment of the Group’s eligibility and alignment with the Taxonomy. When preparing the disclosures for the Enea Group, particularly for the purpose of assessing the eligibility and alignment of its activities with the technical screening criteria, materiality thresholds were not applied either. The Enea Group therefore does not classify any activities as exempt from assessment or deemed immaterial.

Enea Group companies keep their accounts in accordance with International Accounting Standards and International Financial Reporting Standards (IAS/IFRS), as endorsed by the European Union. On this basis, it was possible to identify the amounts (expressed in monetary units) associated with the identified activities in individual companies, in accordance with the definitions set out in the EU Taxonomy. These amounts, broken down into three categories, namely:

• turnover (net sales revenue from products or services),
• capital expenditures, and
• operating expenses,

served as the denominator for each of the three key performance indicators.

Next, the amounts were allocated to the following groups, separately for each indicator:

• non-Taxonomy-eligible,
• Taxonomy-eligible but not Taxonomy-aligned, and
• Taxonomy-aligned (serving as the numerator for each of the three indicators).

“Turnover” in the Taxonomy refers to net sales revenue recognized in accordance with IAS 1, paragraph 82(a) a) as defined in Article 2(5) of Directive 2013/34/EU of the European Parliament and of the Council of 26 June 2013, which provides that these are amounts derived from the sale of products and the provision of services after deducting discounts and value-added tax and other taxes directly related to turnover. Accordingly, this included consolidated net turnover (for the most part, recognized in accordance with IFRS 15), including revenue recognized under IFRS 16 (the Enea Group is also a lessor).

In the Taxonomy, capital expenditures are defined as increases in certain fixed assets, such as property, plant and equipment or intangible assets, as specified in the relevant IAS/IFRS: (1) IAS 16 Property, Plant and Equipment, (2) IAS 38 Intangible Assets, (3) IFRS 16 Leases, and (4) IAS 40 Investment Property.

In the Taxonomy, operating expenses are defined as the five categories of direct, non-capitalized costs listed in one of the regulations (research and development, short-term leases, building renovation activities, maintenance and repairs, and the broad category of other).

The Enea Group performed an analysis of the various categories included in the definition of operating expenses, observing the disclosure requirements set forth in the EU Taxonomy, on the basis of which, within the category of other expenditures relating to the day-to-day servicing of assets of property, plant and equipment, it included in the denominator costs from the following categories: fire protection services and other fire prevention measures, cleaning services (in particular, cleaning in buildings as an element necessary to ensure effective performance of their roles) mandatory specialized training for employees whose professional duties include solely the maintenance of power poles.

The most significant operating expenses at the Enea Group primarily include repair and maintenance costs (both the consumption of repair and maintenance materials and third-party services related to repairs and maintenance) due to the extensive portfolio of property, plant and equipment held by the Enea Group.

Summary of the criteria assessment for key activities of the Enea Group are presented in the table above. The description is narrowed down to the activities that have a material impact on key performance indicators. The evaluation methodology varied across projects, reflecting the specific nature of particular activities and the diverse technical screening criteria. For activities deemed aligned with the EU Taxonomy, compliance with individual criteria was evidenced by relevant supporting documentation. These criteria were verified, for instance, based on corporate records or internal company analyses. The description is narrowed down to the activities that have a material impact on key performance indicators. An analysis of physical climate-related risks was conducted for all activities, as described further on in this disclosure. Based on the analysis conducted by the Enea Group, the technical screening criteria for the above EU Taxonomy-aligned activities were deemed to have been met.

Conducting an assessment of climate risks and exposure to those risks is one of the requirements for complying with the DNSH principle in the case of economic activities assessed for their substantial contribution to climate change mitigation. An assessment of physical climate-related risks was conducted only after an initial analysis determined that the activity in question met all other TSC. All activities considered to be Taxonomy-aligned have demonstrated a substantial contribution to the climate change mitigation. In their case, the assessment of climate risk and exposure to this risk was limited to do no significant harm requirements.

The evaluation process: Each of the economic activities reviewed in terms of Taxonomy alignment was assessed in the context of the twenty-eight physical climate-related hazards listed in the classification in Appendix A to Commission Delegated Regulation (EU) 2021/2139. At the first stage of climate risk assessment, for each activity verified for Taxonomy alignment, the representatives of individual companies identified the existence of key infrastructure and process elements enabling the conduct of the respective activity: product/service manufacturing sites, transportation lines, administrative buildings, critical suppliers, key customers, necessary utilities, employees and others. A list of key infrastructure and process components was compiled based on their locations in order to analyze their exposure to climate-related hazards and to document the occurrence of physical climate risks for each component in the past. Based on this information, climate-related hazards that have no effect on the activity subject to the review due to their absence in the locations where the activity is conducted or the absence of a causal link between the harmful effects and the reviewed activity.

After the initial analysis of the exposure to climate-related hazards, we produced a list of hazards identified as relevant to the reviewed activities for each company and each key element of infrastructure and processes. In the second stage of the risk and exposure assessment, representatives of the companies evaluated the magnitude of the anticipated financial impacts and the likelihood of risks affecting key elements necessary for conducting the assessed economic activities. The companies applied risk assessment criteria in accordance with the Enea Group’s Enterprise Risk Management Methodology.

Assessment results: The analysis identified one significant risk – drought – at an inherent level of 4.8. Electricity generation from bioenergy at Enea Elektrownia Połaniec. However, the risk is mitigated by the already implemented and fully functional physical and non-physical adaptation solutions which reduce the risk to a below material level. No material physical climate risks were identified for the other economic activities subject to assessment.

We have also carried out an analysis of compliance of economic activities carried out in 2025 with the minimum safeguards as defined in Article 18 of Regulation (EU) 2020/852. The assessment was overseen by the Enea Group’s ESG Department, with participation from internal units responsible for specific areas relevant to the minimum safeguards, including Human Resources and Compliance. The analysis used Article 18 of the aforementioned Regulation as a starting point and was additionally based on:

• the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct,
• the UN Guiding Principles on Business and Human Rights,
• the Guidelines of the European Platform for Sustainable Finance contained in the Final Report on Minimum Safeguards,
• A guide for businesses on the application of the EU Taxonomy’s minimum safeguards, prepared by the Working Group on Minimum Safeguards coordinated by the Ministry of Economic Development and Technology

The analysis of compliance with minimum safeguards was conducted based on a checklist covering six thematic areas, namely (i) human, labor and consumer rights, (ii) corruption, (iii) fair competition, (iv) taxation, (v) the environment, and (vi) science, technology and innovation. The checklist was completed based on applicable documents and extensive internal consultations within the Enea Group.

The assessment concluded that the Enea Group operated in accordance with the minimum safeguards in 2025. Although the Group does not have a single document systematizing the due diligence process, elements of this process, as defined in the aforementioned guidelines, have been integrated into the Group’s operations through the adoption and implementation of a number of documents, in particular: the Enea Group Code of Ethics, the Enea Group Compliance Policy (establishing the compliance system within the Enea Group), the Policy Against Workplace Harassment, Discrimination and other Unacceptable Conduct, the Procedure for Reporting Breaches and Protecting Whistleblowers in the Enea Group, the Enea Group’s Code of Conduct for Contractors, the Rules for Offering and Receiving Gifts in the Enea Group, the Third-Party Risk Management Procedure and analogous procedures in subsidiaries, and the Diversity, Equity, Inclusion and Belonging Policy (DEiB Policy), which define the values and principles of conduct adopted by the Group. The Group also has a tax strategy in place.

In 2025, the Group continued to work on internal regulations relevant to compliance with minimum safeguards, expanding them and integrating them more closely. First and foremost, the Methodology for Managing ESG Risks and Opportunities and the DE&B Policy were adopted and implemented. In addition, he Procedure for Reporting Breaches and Protecting Whistleblowers was updated and the Enea Group’s Compliance Policy was adapted to the new reporting model, specifying the rules for cooperation among Group companies within the framework of a partially integrated system for reporting breaches and protecting whistleblowers. The Compliance Policy and the Procedure for Reporting Violations and Protecting Whistleblowers are described in Section G of the Enea Group’s Sustainability Report.

In the adopted regulations, the Group commits to respecting human rights. At Enea Group, child labor, forced labor and any forms of slavery or servitude are prohibited. Our business partners are also expected to adhere to these values. The documents also cover issues related to counteracting corruption, in own business and external relations and unfair competition. The Enea Group considers counteracting corruption to be one of the most important elements of its Compliance System. The sources of anti-corruption regulations in the Enea Group are the aforementioned documents, i.e.: Enea Group Compliance Policy, Enea Group Contractor Review Procedure and the Rules for Offering and Receiving Gifts.

The Group identifies potential negative impacts within the scope of the OECD and UN Guidelines, based, among other things, on its Methodology for Managing ESG Risks and Opportunities, as well as through a double materiality analysis process for the purposes of required disclosures. The double materiality analysis identified, for example, the lack of supplier audits regarding human rights compliance and the impact of the transition on employment. Within the framework of the broader processes of compliance management and enterprise risk analysis, the Enea Group also identifies and evaluates the risk of corruption and bribery, and tax risk.

With regard to the identified potential negative impacts, the Group takes a number of preventive measures, including information and education measures (various internal training courses), awareness-raising (campaigns) and control measures. The Group also takes mitigation and corrective measures, in particular on the basis of the policies for reporting breaches and protecting whistleblowers and counteracting workplace harassment.

The Group and its individual companies have introduced the internal whistleblowing system, while in the parent company, the whistleblowing system is accessible not only to the company’s own workforce and all other stakeholders. The applicable mechanisms offer various reporting channels, both anonymous and non-anonymous, using digital (application or email) and analogue solutions. As mentioned above, changes were made to the Procedure for Reporting Breaches and Protecting Whistleblowers document in 2025. A model of partial centralization of report handling has been implemented, under which the Enea Group Compliance Officer receives reports, conducts an initial review and registration and then forwards the reports to the appropriate Compliance Committee within the Company for further processing. This solution enables centralized filtering of information and uniform risk monitoring at the Enea Group level.

The Enea Group collects quantitative data relevant to the minimum safeguards in various areas, including data on complaints filed through whistleblowing mechanisms, occupational health and safety metrics (e.g. workplace accidents), training, data protection incidents, etc. The Group also reports on elements relevant to the due diligence process both internally and externally. These policies and reports are published on the Group’s websites.

Finally, the Group engages with stakeholders, which is one of the key elements of the due diligence process – as part of the update to the double materiality analysis in September 2025, a survey was conducted to incorporate stakeholder feedback. Two versions of the survey were prepared – one for Enea Group employees and one for external stakeholders. The surveys were distributed by the Enea Group. Stakeholders indicated the extent to which specific issues in the E, S and G areas should be material for the Enea Group. The selected areas covered several identified factors in order to avoid unnecessarily lengthening the survey. Respondents selected their answers on a five-point scale. We received 722 responses to the survey questions, including 531 from employees.  In the case of internal stakeholders, the dialog primarily involves employees and their representatives, particularly trade unions. In this case, it is the most structured and takes on various forms. The Enea Group allows their employees to express views and influence important matters concerning the organization and working conditions, governance or organizational culture. The Group companies also conduct a dialog with local communities as part of the ongoing activities. This dialog is adapted to the needs, circumstances and projects.

Further information is provided in the Social Disclosures section later in this Report.

In 2025, more than a dozen proceedings against various entities within the Enea Group, the subject matter of which falls within the scope of the minimum safeguards, were finally concluded. In assessing the Enea Group’s operations from this perspective, the recommendations of the European Platform for Sustainable Finance were followed. The platform noted that – in the event of certain categories of breaches – the status of non-compliance with minimum safeguards remains in effect until the company demonstrates that it has taken measures to make a recurrence of such violations unlikely.

In this context, it should be noted that the entities of the Enea Group have complied with the rulings and, where warranted by the nature of the case, have taken other measures aimed at improving the situation so that a recurrence of the breaches is unlikely. Final judgments handed down in 2025 concerned primarily labor rights. Out of 19 cases reported in this category in the entire Enea Group, 15 proceedings concerned a single issue in a single company. The factual circumstances underlying these cases, namely the system for calculating remuneration for employees in continuous operation, were amended in 2024 following changes to the Internal Collective Bargaining Agreement. The root cause of these cases has therefore been eliminated, and there is no risk of similar violations in the future, although legal proceedings may still be initiated against the company. The remaining four cases concerning labor rights are considered incidental. But even in these cases, Enea Group entities have taken additional measures, such as updating contracts and conducting training, to minimize the risk of similar breaches occurring in the future. Given the scale of employment, the complexity of labor relations, and the scope of the Enea Group’s operations, the risk of future adverse labor law rulings cannot be entirely excluded. However, Enea Group entities analyze every ruling and its factual basis, calibrating procedures, processes, and measures to mitigate risk.

In 2025, environmental decisions regarding water management were also issued against one Enea Group subsidiary. In response, the company implemented a series of actions to address the causes of the breaches and prevent future occurrences. Specifically, the formal and legal status of all water installations within the company was reviewed, and instructions regarding necessary remedial steps were issued to facility managers. Furthermore, training is being conducted for employees responsible for facilities utilizing water equipment.

Therefore, we concluded that the Enea Group conducted its activity in 2025 in accordance with the minimum safeguards.

• The most important activity, accounting for nearly 93% of the numerator of the key performance indicator related to turnover (and 19% of its denominator), is activity 4.9. Transmission and distribution of electricity (environmental objective: climate change mitigation). Enea Operator generates revenue from licensed activities, i.e. sales of distribution services to end users and revenue from grid connection fees. These are revenues originating from the grid assets held and are recognized for the most part under IFRS 15, where the main groups of contracts are contracts for distribution services. In these contracts, the service is provided on a continuous basis and the amount of turnover depends on the amount of distribution fees calculated in accordance with the DSO’s tariff. Compared to 2024, Taxonomy-aligned revenues increased slightly (approx. +4% y/y).
• The second most valuable Taxonomy-aligned activity of the Enea Group in terms of revenue generated is activity 4.8. Electricity generation from bioenergy (environmental objective: climate change mitigation). In 2025, revenue from this activity decreased compared to the previous year – the decline in turnover on the Green Unit (Enea Elektrownia Połaniec) was due to a drop in the selling price of electricity. The year-over-year decline in revenue from this activity was also influenced by the cessation of operations at the Liszkowo biomass power plant (Enea Nowa Energia) in September 2024.

The denominator of the turnover ratio is PLN 28,137 million. The noticeable increase in consolidated revenues generated by the Enea Group (leading to an increase in the denominator of the turnover KPI compared to 2024) is explained in the Management Board Report on the Activities of the Enea Group (in section 8.2. Consolidated statement of profit and loss).

• The most important Taxonomy-aligned activity is activity 4.9. Transmission and distribution of electricity (environmental objective: climate change mitigation), which accounts for more than 91% of the numerator of the CapEx KPI. The company carrying out the distribution activity is Enea Operator, whose grid investments include, among others: connection of new customers, new sources and the associated construction of new networks, the upgrading and rehabilitation of existing assets, meters and metering systems, and ICT infrastructure forming an integral part of the distribution grid operated by the company, as well as tools and devices for network maintenance services. The increase in capital expenditures compared to last year is due to higher capital expenditures actuals. The vast majority of CapEx incurred in this way have been accounted for in accordance with IAS 16 Property, Plant and Equipment.
• Another significant activity, accounting for 6% of the numerator of the CapEx KPI, were increased assets in the wind energy area – 4.3. Electricity generation from wind energy (environmental objective: climate change mitigation). These investments are attributable to Enea Nowa Energia’s subsidiaries: the Bejsce Wind Farm, acquired in 2023, and the Peplin, Skibno, Liskowo and Pomorze Wind Farms, acquired in 2025. Given the above, capital expenditures for the four wind farms in question were not identified until 2025, and these projects are currently at various stages of implementation. Similarly, most capital expenditures were recognized here in accordance with IAS 16 Property, plant and equipment.

Among the activities deemed Taxonomy-eligible but not Taxonomy-aligned, a wide variety of types have been identified; however, it is worth noting that over 76 million PLN of the total 198 million PLN in this group relates to the purchase, renovation, modernization and maintenance of real estate by Enea Operator – activity 7.1. Construction of new buildings, 7.2. Renovation of existing buildings, 7.3. Installation, maintenance and repair of energy efficiency equipment, 7.7. Acquisition and ownership of buildings.

The denominator of the CapEx indicator is PLN 6,237 million (up approx. 77% y/y). The increase in the denominator is mainly due to changes in property, plant and equipment – specifically, the acquisition of assets related to renewable energy sources, the construction of two CCGT units in Świerże Górne by Enea Elkogaz, the excavations at LWB and a pumping station on the Żelazny drainage ditch at LWB.

All significant values in the numerator of the CapEx key performance indicator resulted from increases recorded by the Enea Group’s existing companies. In other words, no significant amounts related to fixed asset increases resulting from business combinations within the meaning of IFRS 3 were included as Taxonomy-aligned or Taxonomy-eligible but non-Taxonomy-aligned.

Enea Group does not report Taxonomy alignment on the basis of capital expenditures (within the meaning of Delegated Regulation 2021/2178) and has not issued green bonds or debt securities to finance certain identified types of Taxonomy-aligned activities.

• The largest Taxonomy-aligned operating expenses are those incurred in connection with activity 4.9. Transmission and distribution of electricity (in the environmental objective: climate change mitigation; which accounts for more than 81% of the numerator of this KPI).This is largely attributable to Enea Operator, which incurs expenditures related to repair and maintenance work on its grid assets, costs of in-house work and related costs indispensable for the operation of the grid (without which the assets would be unable to perform their functions effectively). The most important category among these costs are without a doubt staff costs (payroll fund, social security contributions, charges for the Company Social Benefit Fund) linked to maintenance and repair workers. Compared to 2024, Taxonomy-aligned operating expenses increased slightly (approx. 7% y/y).
• The second-largest component, accounting for nearly 8% of the key performance indicator related to operating expenses, was the total cost associated with activity 4.8. Electricity generation from bioenergy (environmental objective: climate change mitigation). These costs increased only slightly in absolute terms compared to 2024 – Enea Elektrownia Połaniec reported higher expenses related to this activity (due to higher costs associated with the overhaul of the Green Unit), while Enea Nowa Energia’s expenses fell significantly, due to the decommissioning of the biomass power plant.
• Another significant activity, accounting for 6% of the numerator of the OpEx KPI, is performed by Enea Nowa Energia through expenses related to activity 4.3. Electricity generation from wind energy (environmental objective: climate change mitigation). These expenses were related to the maintenance of wind turbines at the farms owned by the company and its subsidiaries.

Among the activities considered as eligible but non-Taxonomy-aligned, a number of their different types have been recognized, however, it is worth clarifying that more than PLN 36 million out of PLN 47 million in total in this group are operating expenses made by Enea Operator – mostly activity 7.7. Acquisition and ownership of buildings, maintenance and renovation of buildings and structures other than those related to network operations (that is, for instance, head office buildings and local energy service stations) and, to a lesser extent, activity 6.5. Transport by motorbikes, passenger cars and commercial vehicles

The denominator of the OpEx KPI is PLN 919 million and it slightly increased compared to the denominator of the same ratio in 2024 (PLN 884 million). Most Enea Group companies report increases in their expenses, although one significant change is the decline Enea Nowa Energia’s operating expenses, as described above.