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ESG policies and regulations

Environmental regulations

Code of Ethics of the ENEA Group	Code of Code of Ethics of the Lubelski Węgiel Bogdanka Capital Group Group and ENEA Group Compliance Policy	ENEA Group Procurement Policy
developing new services and products in consideration of the environment, investing in solutions that satisfy stringent environmental standards, working on technologies to increase production of energy from renewable sources, making rational use of energy and natural resources, striving to reduce the volumes of generated waste and pollution, initiating and actively participating in educational campaigns for environmental protection and building environmental awareness, preventing breakdowns that can be harmful to the environment.	minimising emissions, reasonable management of natural resources, seeking to maintain balance between the Group’s activities and the natural environment, investing in environmentally-friendly technologies, supporting renewable energy sources, working with organisations that care for the natural environment.	accounting for environmental considerations when selecting suppliers of products and services¹ such as the energy efficiency of the object of the contract.

1) If considered relevant to the object of the contract.

All suppliers must also abide by the ENEA Group Code of Conduct for Contractors, which among others sets outs the Group’s expectations with regard to environmental protection. Selected rules, e.g. those that specify how to manage generated waste, must be complied with by third parties carrying out work on the premises or for the benefit of the Group’s companies.

Furthermore, in line with ENEA Group Communication Policy, in its communications the Group promotes environmentally friendly values and supports environmental protection projects.

The Group’s companies monitor and document environmental factors and the effects of the environmental measures they take. They apply their own policies, procedures, instructions and regulations that are adjusted to their operations and that oblige them to protect the environment and use it in a sustainable way.

Selected environmental regulations in Enea Group’s companies

Company	Environmental management – due care policies, standards and procedures
Enea SA	ENEA Capital Group Climate Policy, ENEA S.A. Environmental Policy.
Enea Bioenergia	Procedure for accounting for the use of combustion by-products based on a contract with Elektrownia Połaniec S.A., Procedure for accounting for combustion by-products with third-party buyers, Operating instruction for waste registration in the BDO (Waste Database) system, Instruction for average volume density and humidity of ash and slag mixture, Instruction for operating the warehouse at ENEA Bioenergia, In addition, the company is bound by the following Połaniec Power Plant’s instructions: Instruction for operating “Pióry” combustion waste storage facility, Instruction on accounting for and use of gypsum produced at the Power Plant.
Enea Połaniec Power Plant	Procedure for identification and evaluation of environmental aspects, Environmental monitoring procedure, Environmental Management Programme.
Enea Nowa Energia	Waste management policy for ENEA Nowa Energia sp. z o.o., Procedure on the use of fluorinated greenhouse gases, Procedure on handling the removal of trees or shrubs from land owned or held in perpetual usufruct by ENEA Nowa Energia sp. z o.o., Instruction on managing dangerous and hazardous substances and mixtures, Emergency preparedness and response procedure, Instruction on water management for the cascade hydropower plant on the Brda River (Koronowo, Tryszczyn, Smukała), Instruction on water management for the hydropower plants on the Wda River (Żur and Gródek), Instruction on water management for all hydropower plants on the Rega River, Instruction on water management for the Hydropower Plant Oborniki, Instruction on water management for the cascade hydropower plant on the Gwda River.
Enea Operator	Procedure for registering power devices containing at least 6 kg of SF6 gas and operations performed on them, Procedure for management of dismantling materials and waste in ENEA Operator sp. z o.o.
Enea Oświetlenie	Waste management at ENEA Oświetlenie sp. z o.o.
Enea Ciepło Oddział Elektrociepłownia Białystok	Environmental Management System Policy and the procedures based on this policy, Procedure "Identification of threats and determining how to respond to environmental emergencies at ENEA Ciepło sp. z o.o. – Białystok CHP Plant Division”, Procedure "Prevention and reduction of the impact of emergencies on the environment at ENEA Ciepło sp. z o.o. – Białystok CHP Plant Division”, Procedure “Conduct in the event of environmental emergencies at the Białystok CHP Plant”, Sustainable Development Criteria System Book (SDC).
Enea Ciepło Centrala	Environmental Management System Policy and the following procedures based on this policy: Internal procedures: Identification of environmental aspects, Responding to danger and failure, Waste management, System of monitoring and measuring parameters affecting the environment, Programme for prevention of severe industrial accidents relating to the storage and use of hazardous substances and materials at the Zachód Heat Plant, a quality instruction, Instruction on the disposal of combustion by-products from the Zachód Heat Plant, Internal inspections and training of Employees on the proper handling of waste in the Zachód Heat Plant and in heat distribution networks and hubs, an instruction, Instruction on handling spills of petroleum substances or chemical substances, Instruction on the use of excavated soil, Internal instructions on monitoring and reporting CO₂ emissions.
EkoTRANS Bogdanka	Quality and Environmental Policy, Management of waste generated at Łęczyńska Energetyka in Bogdanka, a procedure, Identification of environmental aspects, a procedure, Identification and evaluation of environmental aspects and impacts, a procedure.
Łęczyńska Energetyka	Quality and Environmental Policy, Management of waste generated at Łęczyńska Energetyka in Bogdanka, a procedure, Identification of environmental aspects, a procedure, Identification and evaluation of environmental aspects and impacts, a procedure.
Miejska Energetyka Cieplna Piła	Instruction “Waste management”, Procedures referred to in the CO2 emissions monitoring plan, Procedures referred to in the CO2 monitoring methodology plan.
LW Bogdanka	Policy of the Integrated Quality, Environmental and OHS Management System with related environmental procedures.

Regulations on employee issues

Employee issues in the Enea Group are primarily regulated by the following documents:

work rules and regulations of the Enea Group’s companies,
internal collective bargaining agreements,
Code of Ethics of the ENEA Group and Code of Ethics of Lubelski Węgiel Bogdanka Capital Group,
ENEA Group Compliance Policy and Compliance Policy of Lubelski Węgiel “Bogdanka” S.A., which describe, among others, the desired Employee conduct and attitudes,
procedures for implementing Employee development activities in Group companies,
Estimate Budget of Common Social Activities in the ENEA Group which sets out the scope and the principles for awarding social benefits to Employees for the year,
policies against mobbing, discrimination and other unacceptable behaviour in Enea Group’s companies,
Procedure of the ENEA Group Management Committee on the personnel policy as regards appointing Management and Supervisory Boards in the Group’s companies.

We have also adopted policies and procedures tailored to the specifics of our individual companies. They define, among others, the recruitment and onboarding processes, rules of awarding bonuses, rules of Employee development activities, work time recording, registration and settlement of business travel as well as the rules applied when Employees leave our company. The adopted internal regulations ensure compliance with the law.

Important internal regulations concerning Employee issues adopted in Enea Group’s companies that are of key importance from the viewpoint of labour matters
Enea SA	Code of Ethics of the ENEA Group, Multi-Company Collective Bargaining Agreement for Employees of the Utilities Sector, Internal Collective Bargaining Agreement for Employees of ENEA S.A. and its Subsidiaries listed in appendix no. 10 to the Agreement, Work Rules and Regulations of ENEA S.A., Policy against mobbing, discrimination and other unacceptable conduct in ENEA S.A., Rules of Bonuses for the Employees of ENEA S.A. Rules and Regulations for Awarding Bonuses to ENEA S.A. Employees based on the Management by Objectives System, ENEA S.A. Competence Model, ENEA S.A. Recruitment Procedure, ENEA S.A. Employee Development Procedure, ENEA S.A. Employee Onboarding Rules, Rules of procedure in connection with termination of employment relationship with Employees of ENEA S.A., Estimate Budget of Common Social Activities in the ENEA Group, ENEA Group Compliance Policy.
Enea Operator	Code of Ethics of the ENEA Group, Multi-Company Collective Bargaining Agreement for Employees of the Utilities Sector, Internal Collective Bargaining Agreement for Employees of ENEA S.A. and its Subsidiaries listed in appendix no. 10 to the Agreement, Work Rules and Regulations for Employees of ENEA Operator sp. z o.o., Policy against mobbing, discrimination and other unacceptable conduct at ENEA Operator sp. z o.o., Recruitment Procedure, Employee Onboarding Procedure in ENEA Operator sp. z o.o., Rules and Regulations of the Management-by-Objectives System in ENEA Operator sp. z o.o., Rules and Regulations for Organising Business Trips in ENEA Operator sp. z o.o, Employee Development Procedure in ENEA Operator sp. z o.o., Estimate Budget of Common Social Activities in the ENEA Group, ENEA Group Compliance Policy.
LW Bogdanka	Internal Collective Bargaining Agreement, Work Rules and Regulations, Rules and Regulations of the Company Social Benefit Fund, Code of Ethics of the Lubelski Węgiel Bogdanka Capital Group, HR Policy of Lubelski Węgiel „Bogdanka” S.A., Policy of Employee recruitment and selection for production positions, Policy of Employee recruitment and selection for managerial and specialist positions, Compliance Policy of Lubelski Węgiel „Bogdanka” S.A., Procedure for Reporting Breaches in Lubelski Węgiel “Bogdanka” S.A., Policy of Employee Qualifications Raising and Development in Lubelski Węgiel “Bogdanka” S.A., LWB Group’s subsidiaries have adopted documents equivalent to those listed above.
Enea Centrum	Code of Ethics of the ENEA Group, Multi-Company Collective Bargaining Agreement for Employees of the Utilities Sector, Agreement on Application of Internal Collective Bargaining Agreement at ENEA Centrum sp. z o.o., Additional Protocol no. 1, Additional Protocol no. 2, Agreement - Appendix 1: Rules of stabilisation of employment and of disbursement of additional severance payments, Work Rules and Regulations in ENEA Centrum sp. z o.o. Rules and Regulations of Remote Work in ENEA Centrum sp. z o.o., Rules and Regulations of Awarding Bonuses to ENEA Centrum sp. z o.o. Employees based on the Management by Objectives System, Rules and Regulations of Awarding Bonuses to Employees of Direct Customer Service Department of ENEA Centrum sp. z o.o., Rules for parting with Employees of ENEA Centrum sp. z o.o. Rules and Regulations of “Employee with Energy” Competition, Policy against mobbing, discrimination and other unacceptable conduct at ENEA Centrum sp. z o.o., ENEA Centrum sp. z o.o. Employee Development Procedure, Rules of Employee Adaptation at ENEA Centrum sp. z o.o., Recruitment Procedure, Estimate Budget of Common Social Activities in the ENEA Group, ENEA Group Compliance Policy.
Enea Elektrownia Połaniec	Code of Ethics of the ENEA Group, Work Rules and Regulations for ENEA Połaniec Power Plant Employees, Internal Collective Bargaining Agreement for ENEA Połaniec Power Plant Employees, Rules and Regulations for Compensating Management Staff , Health Protection Programme and agreement on its performance, Policy against mobbing, discrimination and other unacceptable conduct in ENEA Połaniec Power Plant, Agreement with Trade Unions of 30 December 1999 on principles of cooperation, Agreement on the participation in costs of trade union activities signed with Companies spun-off in the restructuring process, Agreement on the participation in costs related to the conduct of PKZP signed with Companies spun off in the restructuring process, Rules and Regulations of the Company Social Benefit Fund and the Agreement on Common Social Activities, Instruction for Employee evaluation, Company agreement regarding the Employee Pension Plan, Rules and Regulations for giving awards and distinctions in ENEA Połaniec Power Plant, Recruitment Procedure, HR Instruction, Instruction on medical examinations, ENEA Group Compliance Policy.
Enea Wytwarzanie	Code of Ethics of the ENEA Group, Multi-Company Collective Bargaining Agreement for Employees of the Utilities Sector, Internal Collective Bargaining Agreement for Employees of ENEA Wytwarzanie sp. z o.o., Social Contract on the Transition of the Power Sector and the Lignite Mining Industry, including on the spin-off of Generating and Mining Coal Assets from Companies with State Treasury Shareholding, concluded on 22 December 2022 in Warsaw, Work Rules and Regulations for Employees of ENEA Wytwarzanie sp. z o.o., Rules and Regulations of the Company Social Benefit Fund at ENEA Wytwarzanie sp. z o.o., Policy against mobbing, discrimination and other unacceptable conduct in ENEA Wytwarzanie sp. z o.o., ENEA Wytwarzanie sp. z o.o. Personnel Management Procedure, Rules and Regulations for Granting Bonuses to Employees of ENEA Wytwarzanie sp. z o.o., Rules and Regulations for Granting Annual Bonuses to Employees of ENEA Wytwarzanie sp. z o.o., Recruitment Procedure, Remuneration System for Managers and persons indicated by the Management Board as Employees holding special competencies, ENEA Group Compliance Policy, Rules of Employee Induction at ENEA Wytwarzanie sp. z o.o.

Customer data security regulations

Internal regulations that ensure appropriate protection of our Customers’ data are:

ENEA Group Security Policy,
Personal Data Protection Policy in the ENEA Group,
ICT Security Principles in the ENEA Group,
Information Processing Principles in the ENEA Group,
Personal Data Processing Principles in the ENEA Group,
Risk Management Methodology for Cybersecurity of Key Services in the ENEA Group,
Personal Data Processing Risk Methodology in the ENEA Group.

The companies in the Group can also adopt their own regulations, additional privacy and data recommendations. For example, LW Bogdanka adopted the Information Security Policy for ICT Systems.

Codes of Ethics

Our rules of procedure and ethical values are set out in the Code of Ethics of the ENEA Group. Our Code of Ethics is a collection of the fundamental values that guide Enea, as a modern and innovative energy group, in day-to-day business as well as in internal and external interactions. It also defines the rules of procedure in frequently encountered situations that are not regulated by law. Following the Code of Ethics in the daily performance of our professional duties not only helps us achieve the vision and carry out the mission of the Group, but also guarantees the safety of our Employees and gives them confidence that their behaviour and attitudes will be honourable and respectful.

Anti-corruption regulations

The methods of preventing corruption in the Enea Group have been detailed in more technical regulations, such as:

The Rules for Offering and Receiving Gifts in the ENEA Group which contain detailed guidelines and restrictions on offering and receiving gifts, including the nature of the gifts, value thresholds, relevant approvals and the extremely important idea of ’own judgment’ which covers a list of questions an Employee should answer before accepting or offering a gift, so as to determine whether or not it is appropriate (even if permitted by law).
The Policy for reporting breaches and protecting whistleblowers in the ENEA Group which comprehensively regulates the matters associated with reporting suspected violations, including corruption. The main purpose of the policy is to ensure that signals of possible violations are received, thoroughly analysed and properly managed, and that the person who reports them in good faith is protected from possible retaliation.
The Anti-corruption Policy of Lubelski Węgiel Bogdanka S.A. which sets out legal and ethical standards allowing for conducting business in a responsible and transparent manner. Counteracting corruption is also an important element of documents such as: the Code of Ethics of Lubelski Węgiel Bogdanka Capital Group, Procedure for Reporting Breaches in Lubelski Węgiel “Bogdanka” S.A., Guidelines on Offering and Receiving Gifts at Lubelski Węgiel “Bogdanka” S.A. and Compliance Policy of Lubelski Węgiel “Bogdanka” S.A.

Prevention of mobbing and discrimination

The diversity issues are addressed in various documents, such as:

the ENEA Group Code of Ethics, internal collective bargaining agreements

Policy against mobbing, discrimination and other unacceptable conduct
ENEA Group Compliance Policy
Compliance Policy of Lubelski Węgiel Bogdanka S.A. and Procedure for Reporting Breaches in Lubelski Węgiel Bogdanka S.A.

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