About the report

GRI indicators

The Integrated Report of PGE Polska Grupa Energetyczna SA and the PGE Capital Group for 2022 is prepared in accordance with the guidelines of the International Integrated Reporting Council (IIRC).

The purpose of integrated reporting is to present the process of financial and non-financial value creation. An integrated report is information about how the company’s strategy, management, performance and the organization’s environment lead to value creation in the short, medium and long term.

Other reporting standards and requirements

  • 2-3

The financial data presented in PGE Group’s 2022 report on non-financial information is consistent with the information contained in PGE Group’s consolidated financial statements for the year ended December 31, 2022, which have been prepared in accordance with the requirements of International Financial Reporting Standards („IFRS”) as adopted by the European Union. The information on the application of corporate governance principles is based on the recommendations and principles contained in the „Best Practices for WSE Listed Companies 2021″.

The integrated report in the ESG section is prepared according to the structure:

E – environment,

S – social

G – governance

The 2022 Non-Financial Information Report has been prepared in accordance with current Global Reporting Initiative standards, including:

  • GRI 1: Foundation (2021)
  • GRI 2: General Disclosures (2021)
  • GRI 3: Material Topics (2021)

In addition, the report includes our own indicators, references to the 10 Global Compact Principles, as well as to the Sustainable Development Goals (SDGs).

The PGE Group is also required to disclose the extent to which its business activities can be considered environmentally sustainable. This requirement stems from Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investments, amending Regulation (EU) 2019/2088 and the Delegated Regulations on the establishment of a framework to facilitate sustainable investments (hereinafter: EU Environmental Taxonomy, Taxonomy). According to Commission Delegated Regulation (EU) 2021/2178, the first annual reporting period covered 2021, for which eligibility indicators were reported. In the second reporting year, 2022, indicators for both eligibility and compliance with the Taxonomy are reported.

Disclosures for 2022 on the extent to which PGE’s operations can be considered environmentally sustainable are available here.

Entities included in the reporting

  • 2-2

The report is prepared on an annual basis and covers non-financial information for the period from January 1 to December 31, 2022 and includes consolidated data for PGE Group and the parent company, PGE Polska Grupa Energetyczna SA. As at December 31, 2022, PGE Group comprised 79 companies in which PGE Polska Grupa Energetyczna SA directly or indirectly held more than 50% of the share capital. In addition, in three companies, PGE Polska Grupa Energetyczna SA’s (indirect) shareholding is 50%. They are under joint control with the other shareholder (PGE Polska Grupa Energetyczna SA and the other shareholder each hold 50% shares), which are in the case of:

  • Elektrownia Wiatrowa Baltica 2 sp. z o.o. – ORSTED Baltica 2 Holding sp. z o.o.,
  • Elektrownia Wiatrowa Baltica 3 sp. z o.o. – ORSTED Baltica 3 Holding sp. z o.o.,
  • PGE Soleo Kleszczów sp. z o.o. – Kleszczów Municipality

In the case of employee issues, 31 companies were included in the non-financial report, which showed employment in 2022.

These are:



3. PGE Energia Odnawialna

4. PGE Dystrybucja

5. PGE Obrót

6. GOZ (Gospodarka Obiegu Zamkniętego)


8. PGE Paliwa sp. z o.o.

9. PGE Toruń SA

10. EC Zielona Góra


12. PGE Synergia

13. PGE Systemy

14. PGE Dom Maklerski

15. PGE Nowa Energia sp. z o.o.

16. PGE Baltica sp. z o.o.

17. PGE Ventures sp. z o.o.

18. PTS BETRANS sp. z o.o.

19. BESTGUM sp. z o.o.

20. Elbis sp. z o.o.

21. ELTUR-SERWIS sp. z o.o.

22. MegaSerwis sp. z o.o.

23. RAMB sp. z o.o.

24. ENESTA sp. z o.o.

25. ELMEN sp. z o.o.

26. Energoserwis – Kleszczów sp. z o.o.

27. MEGAZEC sp. z o.o.

28. ELBEST Security sp. z o.o.

29. Energetyczne Systemy Pomiarowe sp. z o.o.

30. PGE Gryfino 2050 sp. z o.o.

31. PGE Asekuracja

In the case of environmental issues, an annotation indicating the scope of data is included next to each GRI indicator from this area. The list of companies included in the calculation of the carbon footprint for PGE Group is given in the chapter „Carbon footprint of PGE Group”.

Identification of key impact areas

  • 3-1

The identification of key impact areas was the basis for determining the material topics to be presented in PGE Group’s non-financial information report. This was done through internal and external consultations conducted in the form of workshops and panel discussions.

The information needs and expectations, resulting from the identification of actual and potential, negative and positive economic, environmental and human impacts necessary to be included in the non-financial report, were gathered from almost 80 key PGE stakeholder representatives during Polish- and English-language dialogue sessions held in mid-June 2022. They were conducted in accordance with the AA1000 SES standard, with the support of an independent external facilitator. The meetings were workshop-based.

Representatives of all PGE Group’s key stakeholders were invited to the dialogue sessions, i.e.: central and local government administration, regulators and market supervision, shareholders, investors, customers, employees, banks and financing institutions, insurers, suppliers and subcontractors, industry, pro-social and environmental organisations, the media, CSR/ESG analysts, academia, local communities and the competition.  Of the invited key stakeholders, only representatives of competitors did not attend the session.

The dialogue sessions were conducted using general forum discussions, subgroup discussions and individual work using an online questionnaire, which fostered the involvement of the participants and provided an opportunity to propose issues and exchange ideas. The PGE stakeholders present at the meetings were asked to review 39 aspects of the company’s economic, environmental and human impact, allocated to 4 areas: business, environmental, employee and social. In addition to the aspects suggested as a result of the earlier analysis, stakeholders were also asked to indicate those areas of the company’s impact that they consider to be key and were not included in the list.

As a result of the dialogue, PGE Group’s key stakeholders identified among the most relevant topics for them to be discussed in the company’s non-financial reporting:

1. Strategy and implementation

2. Preventing the emergence of non-compliance with laws and regulations (including those relating to the supply and use of products and services), as well as ensuring compliance with environmental regulations, preventing abuses, violations of environmental laws and regulations

3. Company’s impact on the climate, including greenhouse gas emissions and ways to reduce them

4. Company’s impact on the environment and preventive measures

5. Management of energy consumption at the organisation

6. Water management at the organisation

7. Management of waste

The results of the external sessions were presented to the Board of Directors of PGE SA and the members of management who are part of the Sustainability Committee, as well as those who work directly with them, more than 30 people in total. Discussions at the Board meeting and the Sustainability Committee meetings discussed the key themes of the company’s economic, environmental and human impacts and agreed to prioritise these themes as issues of importance to be included in the report. The key themes were defined in relation to two dimensions:

  • impact – what influence PGE Group’s activities have on the issue in question
  • materiality – the extent to which the topic is relevant to PGE Group’s activities

As key external stakeholders identified environmental impact as the most significant influence of PGE Group on the environment, the members of PGE Group Sustainability Committee also raised the need to describe in the report on non-financial information the social impact, particularly related to the fair transformation process, as well as to present full transparency of business activities undertaken, in line with the principles of corporate governance applicable in PGE Group.

The key topics have been included in the report on non-financial information, in accordance with the principles of the GRI standards. With regard to the management of material topics, in accordance with GRI 3-3, PGE Group addresses the following aspects to which the indicated GRI indicators are assigned.

  • 3-2

Important topics GRI aspects Indicator
1. Strategy and its implementation Economic performance
  • Own indicator – strategy implementation
  • GRI 201-1
  • GRI 201-2
2. Legal and regulatory compliance, including compliance with environmental regulations n/a
  • GRI 2-47
  • Own indicator – environmental penalties
3. Company impact on climate – emission of greenhouse gases and ways of reducing them Emissions
  • GRI 305-1
  • GRI 305-2
  • GRI 305-3
  • GRI 305-4
  • GRI 305-5
  • GRI 305-6
  • GRI 305-7
  • GRI 201-2
4. Company’s impact on the environment and preventive measures Resources


  • GRI 301-1
  • GRI 301-2
  • GRI 301-3
  • GRI 304-1
  • GRI 304-2
  • GRI 304-3
  • GRI 304-4
5. Management of energy consumption at the organisation Energy
  • GRI 302-1
  • GRI 302-2
  • GRI 302-3
  • GRI 302-4
  • GRI 302-5
6. Water management at the organisation Water and wastewater
  • GRI 303-1
  • GRI 303-2
  • GRI 303-3
  • GRI 303-4
  • GRI 303-5
7. Management of waste Waste
  • GRI 306-1
  • GRI 306-2
  • GRI 306-3
  • GRI 306-4
  • GRI 306-5
8. Labour issues with a particular focus on the energy transition process Employment

Health and safety

Training and education

Diversity and equal treatment

Total number of cases of discrimination

  • GRI 401-1
  • GRI 401-2
  • GRI 401-3
  • GRI 403-1
  • GRI 403-2
  • GRI 403-3
  • GRI 403-4
  • GRI 403-5
  • GRI 403-6
  • GRI 403-7
  • GRI 403-8
  • GRI 403-9
  • GRI 404-1
  • GRI 404-2
  • GRI 404-3
  • GRI 405-1
  • GRI 405-2
  • GRI 406-1
9. Transparency of operations in accordance with PGE Group’s corporate governance principles Anti-corruption

Child labour

Forced labour

Public policy

Customer privacy

  • GRI 205-1
  • GRI 205-2
  • GRI 205-3
  • GRI 408-1
  • GRI 409-1
  • GRI 415-1
  • GRI 418-1

Reference to oil and gas sector indicators

In 2022, PGE Group produced electricity from gas at 2.79 TWh (4.2 per cent) and heat at 7.26 PJ (13.8 per cent) of its total production.

Due to the GRI recommendations indicating that an entity is obliged to report sector indicators when a particular activity included in the sector standard is key for the company – after analysing the data, the authors of the report decided that due to the small percentage of gas-fired power generation activities in PGE Polska Grupa Energetyczna’s total activities – indicators for the 'Oil and Gas’ sector would not be included.

However, we would like to point out that despite the absence of a sectoral reporting obligation, most of the data included in the indicators for the Oil and Gas sector are presented in this report.

Correction of information

  • 2-4

No adjustments have been made to the PGE SA and PGE Group’s 2022 Non-Financial Report with respect to the 2021 report, in particular regarding the scope, coverage or measurement methods used in the report.

Report verification

  • 2-5

The PGE SA and PGE Group 2022 Non-Financial Report has not been externally verified in its entirety. The following data were externally verified:

  • financial data given behind the financial report and/or consistent with the 2022 Management Report. financial data given behind the financial report and/or consistent with the 2022 Management Report. The audit was conducted by PKF Consult spółka z ograniczoną odpowiedzialnością sp.k, in accordance with the National Standards on Auditing in the wording of the International Standards on Auditing adopted by the National Council of Statutory Auditors and in accordance with the Act of 11 May 2017 on Statutory Auditors, Audit Firms and Public Supervision („Act on Statutory Auditors” – Dz. U. of 2020, item 1415, as amended) and EU Regulation No. 537/2014 of 16 April 2014 on detailed requirements for statutory audits of public-interest entities („EU Regulation” – OJ EU L158, as amended).
  • data concerning CO2 emissions from installations of PGE Group participating in the EU ETS system – the volume of CO2 emissions was verified by an authorised and independent accredited verifier, from the list of accredited verifiers published on the KOBiZE website. The volume of CO2 emissions was calculated on the basis of and in accordance with the legal regulations of the ETS, in particular with the decisions granted by the competent authorities, authorising the emission of greenhouse gases from the installation. Operators are responsible for preparing and submitting reports on their annual GHG emissions in accordance with the rules and the approved monitoring plan.
  • Certification of the Sustainability Criterion for biomass combustion – applies to PGE Energia Ciepła SA for the locations: Szczecin Branch and Kielce Branch, the subsidiary Zespół Elektrociepłowni Wrocławskich KOGENERACJA SA Elektrociepłownia Czechnica and the Dolna Odra Branch of PGE Górnictwo i Energetyka Konwencjonalna SA. where the System for the Sustainability Criterion has been implemented and certified. Current certificates are available on the website of the Oil and Gas Institute (INiG). Participants in INiG’s sustainability criterion are required to certify the entire life cycle of biofuels, bioliquids and biomass fuels. Registration in the sustainability criterion system means that the organisation meets the requirements of the Sustainability Criteria (SCC), as required by the European Commission (RED II Directive).
  • EMAS verification – applies to the full range of environmental data in the case of two branches of PGE Górnictwo i Energetyka Konwencjonalna companies – Elektrownia Opole and Zespół Elektrowni Dolna Odra, and a branch of PGE Energia Ciepła company – Elektrociepłownia Wybrzeże. The Eco-Management and Audit Scheme (EMAS PI:2999), together with the prepared environmental declaration, is subject to annual verification by an independent accredited verifier. EMAS registration means compliance with the highest standards in environmental management and audit.

PGE Group’s previous integrated report, which was published in 2022 and covered 2021, is available here.

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