ENVIRONMENTAL IMPACT AND CLIMATE ACTIONSEU Taxonomy

The EU Taxonomy, i.e. a regulatory framework introduced by Regulation 2020/852/EU of the European Parliament and of the Council, is a classification system that establishes a list of environmentally sustainable economic activities. Under the Taxonomy Regulation, the European Commission has developed an actual list of environmentally sustainable activities, defining the technical screening criteria for each environmental objective through delegated acts. The EU Taxonomy is a system that allows a uniform classification of sustainable development activities. It is a system designed to support investors in making investment decisions.

Polskie Sieci Elektroenergetyczne is not subject to mandatory disclosure under EU Regulation 2020/852. The disclosures have been prepared and made voluntarily.

In accordance with Article 8 of Regulation 2020/852 (Taxonomy), information has been provided on how and to what extent PSE’s activities are associated with economic activities that qualify as environmentally sustainable (Taxonomy-aligned activity). The direct basis for methods of calculating indicators and data presentation is the above-mentioned Regulation together with Commission Delegated Regulation (EU) 2021/2139 of 4 June 2021. (Delegated Act defining technical screening criteria, which was updated by Commission Delegated Regulation (EU) 2023/2485 of 27 June 2023), Commission Delegated Regulation (EU) 2021/2178 of 6 July 2021 (Delegated Act to Article 8 of the Taxonomy Regulation), Commission Delegated Regulation (EU) 2022/1214 of 9 July 2022 (Delegated Act on nuclear and fossil gas related activities) and Commission Delegated Regulation (EU) 2023/2486 of 27 June 2023 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council and amending Commission Delegated Regulation (EU) 2021/2178.

The key performance indicators have been prepared in accordance with the requirements outlined in EU Delegated Regulation 2021/2178, to the best of our knowledge and with due diligence.

The assessment of Taxonomy-alignment of economic activities with the classification system under individual key performance indicators was carried out on the basis of the technical criteria set forth in EU Delegated Acts 2021/2139, 2022/1214 and 2023/2485. Regulation 2023/2486 was also considered as part of the Taxonomy eligibility assessment process.

Minimum safeguards

PSE complies with the minimum safeguards referred to in Article 18 of EU Regulation 2020/852.

The assessment of compliance with the minimum safeguards at PSE included a review of the organisation’s existing documents, processes, and actions taken with respect to two reference documents:

1. OECD Guidelines for Multinational Enterprises on Responsible Business Conduct

With regard to the requirements of the Guidelines, the project team reviewed the organisation’s existing documents and processes based on the following questions reflecting the due diligence requirements:

Are responsible business conduct issues incorporated into management policies and systems?
Does the organisation have a process in place to identify and assess actual and potential negative impacts (including on people and the environment) associated with the activities, products or services of the enterprise?
Does the organisation have procedures and tools in place to stop, prevent or mitigate the negative effects of activities on people and the environment?
Does the organisation have a process in place to monitor the implementation and outcomes of sustainability due diligence mechanisms?
Does the organisation have a procedure in place to communicate on how to deal with negative impacts?
Does the organisation have a procedure in place which, where applicable, supports taking relevant remedial actions or in cooperation with remedial actions?

2. Final Report on Minimum Safeguards

The second reference document included in the assessment is the Final Report on Minimum Safeguards by Platform on Sustainable Finance published in October 2022, which identifies the occurrence of at least one of two prerequisites within the four core topics as non-compliance with the minimum safeguards:

Human rights
Corruption
Taxation
Fair competition

The analysis reviewed internal documents and external sources, including the OECD National Contact Points reporting database, and found that none of the prerequisites were present.

1.1. TURNOVER KPI

Based on an analysis of each business segment, PSE analysed the revenue generated in 2023 and assigned its corresponding portion to the activities that ate Taxonomy-eligible. The sales revenue figures are derived from financial and accounting records and are consistent with the figures in the Financial Statements.

The allocation of revenues and costs according to the Taxonomy was made possible by the new controlling model implemented in 2019, facilitating a multi-faceted analysis of financial performance. The main product was a revised layout of the controlling objects, including cost centres. The new controlling objects reflect the functioning of our organisation in a better and more precise way and therefore enable more precise analyses of the activities of each area of the company. The analysis showed that 99.85 percent of the company’s consolidated revenues is derived from business activities that are Taxonomy-eligible.

Financial year N

Year

Substantial contribution criteria

DNSH (“do no significant harm”) criteria (h)

Economic activity (1)

Code or codes (a)
(2)

Turnover (3)

Proportion of Turnover, Year N
(4)

Climate change mitigation (5)

Climate change adaptation (6)

Water and marine resources
(7)

Pollution
(8)

Circular economy
(9)

Biodiversity
(10)

Climate change mitigation (11)

Climate change adaptation (12)

Water and marine resources (13)

Pollution (14)

Circular economy (15)

Biodiversity (16)

Minimum safeguards (17)

Proportion of Taxonomy-aligned (A.1.) or Taxonomy-eligible (A.2.) activity
Turnover,
year N-1 (18)

Category
Enabling activity
(19)

Category
Transitional activity (20)

Text

[TPLN]

%

T; N;
N/EL (b)
(c)

T/N

%

E

T

Transmission and distribution of electricity

CCM 4.9.

154,917.42

96.7

T

N/ EL

N/EL

T

0

Turnover from
environmentally sustainable activities (Taxonomy-aligned) (A.1)

154,917.42

96.7

100

0

T

0

Of which enabling activities

154,917.42

96.7

0

T

0

E

Of which transitional activities

0

T

0

T

EL; N/EL
(f)

Turnover from Taxonomy-eligible but not environmentally sustainable activities (non-Taxonomy-aligned activities) (A.2)

0

97.9

A. Turnover of
Taxonomy-eligible activities (A.1+A.2)

154,917.42

96.7

100

0

97.9

B. TAXONOMY-NON-ELIGIBLE ACTIVITIES

Turnover from Taxonomy-non-eligible activities

5,281.10

3.3

TOTAL

160,198.53

100.0

Nuclear and fossil gas related activities

Row	Nuclear energy related activities

1	The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce energy from nuclear processes with minimal waste from the fuel cycle.	NO
2	The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies.	NO
3	The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades.	NO

	Fossil gas related activities

1	The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels.	NO
2	The undertaking carries out, funds or has exposures to construction, modernisation, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels.	NO
3	The undertaking carries out, funds or has exposures to construction, modernisation and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels.	NO

Taxonomy-aligned economic activities (denominator)

Row	Economic activities	Amount and proportion (the information is to be presented in monetary amounts and as percentages)
Row	Economic activities	CCM + CCA		Climate change mitigation (CCM)		Climate change adaptation (CCA)
		Amount	%	Amount	%	Amount	%

1	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
2	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
3	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
4	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
5	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
6	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
7	Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI	26,213,324.63	99.85	26,213,324.63	100	0	0
8	Total applicable KPI	26,213,324.63	99.85	26,213,324.63	100	0	0

Taxonomy-aligned economic activities (numerator)

Row	Economic activities	Amount and proportion (the information is to be presented in monetary amounts and as percentages)
Row	Economic activities	CCM + CCA		Climate change mitigation (CCM)		Climate change adaptation (CCA)
		Amount	%	Amount	%	Amount	%

1	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI	0	0	0	0	0	0
2	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI	0	0	0	0	0	0
3	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI	0	0	0	0	0	0
4	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI	0	0	0	0	0	0
5	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI	0	0	0	0	0	0
6	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI	0	0	0	0	0	0
7	Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the numerator of the applicable KPI	26,213,324.63	99.85	26,213,324.63	100	0	0
8	Total amount and proportion of taxonomy-aligned economic activities in the numerator of the applicable KPI	26,213,324.63	99.85	26,213,324.63	100	0	0

Taxonomy-eligible but not taxonomy-aligned economic activities

Row	Economic activities	Amount and proportion (the information is to be presented in monetary amounts and as percentages)
Row	Economic activities	CCM + CCA		Climate change mitigation (CCM)		Climate change adaptation (CCA)
		Amount	%	Amount	%	Amount	%

1	Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
2	Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
3	Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
4	Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
5	Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
6	Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
7	Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI	0	0
8	Total amount and proportion of taxonomy eligible but not taxonomy-aligned economic activities in the denominator of the applicable KPI	0	0

Taxonomy non-eligible economic activities

Row	Economic activities	Amount	Percentage

1	Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0
2	Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0
3	Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0
4	Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0
5	Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0
6	Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0
7	Amount and proportion of other taxonomy-non-eligible economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI	38,524.77	0.15
8	Total amount and proportion of taxonomy-non-eligible economic activities in the denominator of the applicable KPI	38,524.77	0.15

Accounting principles

The key performance indicator for Turnover (KPI Turnover) was based on PSE’s financial statements for 2023 prepared in accordance with International Reporting Standards (IFRS). Net sales revenue from the above-mentioned statements was used as the denominator of the indicator.

Then, based on the provisions of Commission Delegated Regulation (EU) No. 2021/2139 of 4 June 2021, PSE analysed individual business segments, which were assigned to two categories:

category I – bringing together the company’s areas of operation that are Taxonomy-eligible,
category II – bringing together the company’s areas of operation that are Taxonomy non-eligible,

Due to the fact that PSE is a transmission system operator (TSO) – defined in the Energy Law – as an energy company engaged in the transmission of electricity, the Taxonomy-eligible areas include revenue as defined in the Electricity Tariff for 2023 for:

electricity transmission services through the transmission grid (fixed and variable network fee),
using the national power system (quality fee)
settlements for electricity exchange between the national power system and the power systems of non-EU-member states (market fee),
providing access to the national power system (transitional fee),
ensuring the availability of electricity from renewable sources in the national power system (RES fee),
ensuring the availability of electricity from high-efficiency cogeneration (cogeneration fee),
remaining on standby to provide power to the power system and supplying such power to the system during periods of emergency (capacity fee),
connection to the transmission grid (connection fee),
revenues from the sale of electricity from the sale of electricity in the Balancing Market through physical delivery under power purchase agreements (PPAs) concluded by participants and real-time balancing of electricity demand with its output in the national power system (NPS),
obtained under the inter-TSO compensation (ITC) mechanism,
revenues derived from cross-border redispatching,
allocating transmission capacity on synchronous interconnections (with Germany, the Czech Republic and Slovakia) and non-synchronous interconnections (with Sweden and Lithuania) and the interconnection with Ukraine.

PSE, as a transmission system operator, also conducts other activities, which are a marginal part of its business. It has adopted the materiality principle, according to which events occurring in the enterprise that do not significantly affect the asset and financial position of the entity will not be included in the Taxonomy. A percentage indicator was used to determine the materiality threshold. The determination of the materiality threshold percentage is based on the volume of total sales revenue. The materiality threshold was set at over 1 percent of the company’s total revenue. Revenue from other activities amounted to 0.15 percent of total revenue, so it was included in Category II, which comprises the company’s areas of operation that are Taxonomy non-eligible.

Based on the assessment of compliance with EU Regulation 2020/852 described below, revenue from taxonomy-eligible activities were identified.

Information on the assessment of compliance with Regulation (EU) 2020/852

The various revenue categories of PSE were analysed for Taxonomy eligibility. The process included an analysis of Taxonomy-eligible activities as defined in EU Regulation 2021/2139 and EU Regulation 2022/1214. Based on the analysis, one Taxonomy-eligible activity was identified:

CCM 4.9.

Transmission and distribution of electricity

The activity mentioned above has been analysed with reference to the technical criteria set for this activity in EU Regulation 2021/2139. The analysis was carried out by a project team that included representatives from each unit. The requirements of the individual technical criteria were consulted and confirmed with staff in the respective units with the appropriate knowledge to confirm whether the technical criterion concerned was met.

PSE is part of the European energy system and therefore it meets criterion 1.a) “ the system is the interconnected European system, i.e. the interconnected control areas of Member States, Norway, Switzerland and the United Kingdom, and its subordinated systems”;

According to the technical screening criteria, “Infrastructure dedicated to creating a direct connection or expanding an existing direct connection between a substation or network and a power production plant that is more greenhouse gas intensive than 100 g CO₂e/kWh measured on a life cycle basis is not compliant”. As part of compliance assessment, it was assumed that the Polish and European energy systems are on a decarbonisation path, so no new connections with power plants generating energy from carbon-intensive sources are being created or expanded. At the same time, due to the fact that the existing connection infrastructure was not created separately for high-carbon and low- or zero-carbon sources, it is not possible to separately determine within the existing infrastructure to what extent it meets the cited exemption criterion. Therefore, based on the direction of energy development towards zero-carbon energy indicated above, it was assumed that 100% of the infrastructure intended for the creation of a direct connection is compliant.

Consequently, 100% of the revenue associated with CCM 4.9 Transmission and distribution of electricity was assessed as Taxonomy-aligned.

Contribution to multiple objectives, disaggregation of KPIs

Not applicable. Turnover from activities contributing to more than one environmental objective was not identified. The key performance indicator was not disaggregated.

1.2. Capex KPI

Financial year N

Year

Substantial contribution criteria

DNSH (“do no significant harm”) criteria (h)

Economic activity (1)

Code or codes (a)
(2)

Capital expenditure (3)

Percentage of capital expenditure, year N
(4)

Climate change mitigation
(5)

Climate change adaptation
(6)

Water and marine resources
(7)

Pollution
(8)

Circular economy
(9)

Biodiversity
(10)

Climate change mitigation
(11)

Climate change adaptation
(12)

Water and marine resources (13)

Pollution (14)

Circular economy (15)

Biodiversity (16)

Minimum safeguards (17)

Proportion of Taxonomy-aligned (A.1.) or Taxonomy-eligible (A.2.) activity
Turnover,
year N-1
(18)

Category
Enabling activity
(19)

Category
Transitional activity (20)

ext

[TPLN]

%

T; N;
N/EL (b)
(c)

T/N

%

E

T

A. TAXONOMY-ELIGIBLE ACTIVITIES

A.1 Types of environmentally sustainable activities (Taxonomy-aligned)

Transmission and distribution of electricity

CCM 4.9

1,849,563.66

100

T

N/EL

T

0

CapEx from environmentally sustainable activities (Taxonomy-aligned) (A.1)

1,849,563.66

100

0

T

0

Of which enabling activities

1849563,66

100

0

T

0

E

Of which transitional activities

0

T

0

T

A.2 Taxonomy-eligible but not environmentally sustainable activities (non-Taxonomy aligned activities) (g)

EL; N/EL
(f)

CapEx from Taxonomy-eligible but not environmentally sustainable activities (non-Taxonomy-aligned activities) (A.2)

0

100

A. CapEx from Taxonomy-non-eligible activities (A.1+A.2)

1,849,563.66

100

0

100

B. TAXONOMY-NON-ELIGIBLE ACTIVITIES

CapEx from Taxonomy-non-eligible activities

0

TOTAL

1,849,563.66

100

Nuclear and fossil gas related activities

Row	Nuclear energy related activities

1	The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce energy from nuclear processes with minimal waste from the fuel cycle.	NO
2	The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies.	NO
3	The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades.	NO

	Fossil gas related activities

1	The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels.	NO
2	The undertaking carries out, funds or has exposures to construction, modernisation, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels.	NO
3	The undertaking carries out, funds or has exposures to construction, modernisation and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels.	NO

Row	Economic activities	Amount and proportion (the information is to be presented in monetary amounts and as percentages)
Row	Economic activities	CCM + CCA		Climate change mitigation (CCM)		Climate change adaptation (CCA)
		Amount	%	Amount	%	Amount	%

1	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
2	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
3	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
4	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
5	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
6	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
7	Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI	1,849,563.66	100	1,849,563.66	100	0	0
8	Total applicable KPI	1,849,563.66	100	1,849,563.66	100	0	0

Taxonomy-eligible but not taxonomy-aligned economic activities

Row	Economic activities	Amount and proportion (the information is to be presented in monetary amounts and as percentages)
Row	Economic activities	CCM + CCA		Climate change mitigation (CCM)		Climate change adaptation (CCA)
		Amount	%	Amount	%	Amount	%

1	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI	0	0	0	0	0	0
2	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI	0	0	0	0	0	0
3	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI	0	0	0	0	0	0
4	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI	0	0	0	0	0	0
5	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI	0	0	0	0	0	0
6	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI	0	0	0	0	0	0
7	Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the numerator of the applicable KPI	0	0	0	0	0	0
8	Total amount and proportion of taxonomy-aligned economic activities in the numerator of the applicable KPI	0	0	0	0	0	0

Taxonomy non-eligible economic activities

Row	Economic activities	Amount	Percentage

1	Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0
2	Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0
3	Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0
4	Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0
5	Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0
6	Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0
7	Amount and proportion of other taxonomy-non-eligible economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI	0	0
8	Total amount and proportion of taxonomy-non-eligible economic activities in the denominator of the applicable KPI	0	0

Accounting principles

The calculation of the Capex KPI was based on the financial statements of PSE S. A. for the year ended 31 December 2023 – the denominator consisted of costs accounted for in accordance with:

a) IAS 16 Property, Plant and Equipment, paragraph 73(e)(i) and (iii);

b) IAS 38 Intangible Assets, paragraph 118(e)(i);

c) IAS 40 Investment Property, paragraphs 76(a) and (b) (for the fair value model);

d) IAS 40 Investment Property, paragraphs 79(d)(i) and (ii) (for the cost model);

e) IAS 41 Agriculture, paragraphs 50(b) and (e);

f) IFRS 16 Leases, paragraph 53(h).

Based on the assessment of compliance with EU Regulation 2020/852 described below, taxonomy-eligible activities capital expenditure was identified.

Information on the assessment of compliance with Regulation (EU) 2020/852

The individual categories of capital expenditure incurred by PSE S.A. were analysed in accordance with the provisions of EU Regulation 2021/2178, Annex I, Section 1.1.2.2. to determine whether they meet one of the following conditions:

are related to assets or processes that are associated with Taxonomy-aligned economic activities;
form part of a plan to expand Taxonomy-aligned economic activities or to allow Taxonomy-eligible economic activities to become Taxonomy-aligned (“CapEx plan”);
are related to the purchase of output from Taxonomy-aligned economic activities and individual measures enabling the target activities to become low-carbon or to lead to greenhouse gas reductions, notably activities listed in points 7.3 to 7.6 of Annex I to the Climate Delegated Act, as well as other economic activities listed in the delegated acts adopted pursuant to Article 10(3), Article 11(3), Article 12(2), Article 13(2), Article 14(2) and Article 15(2) of Regulation (EU) 2020/852 and provided that such measures are implemented and operational within 18 months.

Based on the analysis performed, the CapEx associated with CCM 4.9 Electricity Transmission and Distribution activity, which was shown as compliant in the Turnover KPI, was found to be Taxonomy-aligned, according to condition (a) indicated above. This is capital expenditure incurred for investment tasks included in the Investment Projects Plan for 2022-2026 adopted by the company and arising from the Transmission Grid Development Plan.

Contribution to multiple objectives, disaggregation of KPIs

Not applicable. No capital expenditure linked to activities contributing to more than one environmental objective was identified. The key performance indicator was not disaggregated.

1.3. OPEX KPI

Financial year N

Year

Substantial contribution criteria

DNSH (“do no significant harm”) criteria (h)

Economic activity
(1)

Code or codes (a)
(2)

Operating expenditure (OpEx)
(3)

Percentage of OpEx, year N
(4)

Climate change mitigation
(5)

Climate change adaptation
(6)

Water and marine resources
(7)

Pollution
(8)

Circular economy
(9)

Biodiversity
(10)

Climate change mitigation
(11)

Climate change adaptation
(12)

Water and marine resources
(13)

Pollution
(14)

Circular economy
(15)

Biodiversity
(16)

Minimum safeguards
(17)

Proportion of Taxonomy-aligned (A.1.) or Taxonomy-eligible (A.2.) activity
Turnover,
year N-1
(18)

Category
Enabling activity
(19)

Category
Transitional activity
(20)

Text

[TPLN]

%

T; N;
N/EL (b)
(c)

T/N

%

E

T

A. TAXONOMY-ELIGIBLE ACTIVITIES

A.1 Types of environmentally sustainable activities (Taxonomy-aligned)

Transmission and distribution of electricity

CCM 4.9.

154,917.42

96.7

T

N/ EL

N/EL

T

0

OpEx from environmentally sustainable activities (Taxonomy-aligned) (A.1)

154,917.42

96.7

100

0

T

0

Of which enabling activities

154,917.42

96.7

0

T

0

E

Of which transitional activities

0

T

0

T

A.2 Taxonomy-eligible but not environmentally sustainable activities (non-Taxonomy aligned activities) (g)

EL; N/EL
(f)

OpEx from Taxonomy-eligible but not environmentally sustainable activities (non-Taxonomy-aligned activities) (A.2)

0

97.9

A. OpEx from Taxonomy-non-eligible activities (A.1+A.2)

154,917.42

96.7

100

0

97.9

B. TAXONOMY-NON-ELIGIBLE ACTIVITIES

A. OpEx from Taxonomy-non-eligible activities

5,281.10

3.3

TOTAL

16,0198.53

100.0

Nuclear and fossil gas related activities

Row	Nuclear energy related activities

1	The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce energy from nuclear processes with minimal waste from the fuel cycle.	NO
2	The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies.	NO
3	The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades.	NO

	Fossil gas related activities

1	The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels.	NO
2	The undertaking carries out, funds or has exposures to construction, modernisation, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels.	NO
3	The undertaking carries out, funds or has exposures to construction, modernisation and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels.	NO

Taxonomy-aligned economic activities (denominator)

Row	Economic activities	Amount and proportion (the information is to be presented in monetary amounts and as percentages)
Row	Economic activities	CCM + CCA		Climate change mitigation (CCM)		Climate change adaptation (CCA)
		Amount	%	Amount	%	Amount	%

1	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
2	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
3	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
4	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
5	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
6	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
7	Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI	154,917.42	96.7	154,917.42	100	0	0
8	Total applicable KPI	154,917.42	96.7	154,917.42	100	0	0

Taxonomy-aligned economic activities (numerator)

Row	Economic activities	Amount and proportion (the information is to be presented in monetary amounts and as percentages)
Row	Economic activities	CCM + CCA		Climate change mitigation (CCM)		Climate change adaptation (CCA)
		Amount	%	Amount	%	Amount	%

1	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI	0	0	0	0	0	0
2	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI	0	0	0	0	0	0
3	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI	0	0	0	0	0	0
4	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI	0	0	0	0	0	0
5	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI	0	0	0	0	0	0
6	Amount and proportion of taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the numerator of the applicable KPI	0	0	0	0	0	0
7	Amount and proportion of other taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the numerator of the applicable KPI	154,917.42	96.7	154,917.42	100	0	0
8	Total amount and proportion of taxonomy-aligned economic activities in the numerator of the applicable KPI	154,917.42	96.7	154,917.42	100	0	0

Taxonomy-eligible but not taxonomy-aligned economic activities

Row	Economic activities	Amount and proportion (the information is to be presented in monetary amounts and as percentages)
Row	Economic activities	CCM + CCA		Climate change mitigation (CCM)		Climate change adaptation (CCA)
		Amount	%	Amount	%	Amount	%

1	Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic activity referred to in Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
2	Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic activity referred to in Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
3	Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic activity referred to in Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
4	Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic activity referred to in Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
5	Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic activity referred to in Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
6	Amount and proportion of taxonomy-eligible but not taxonomy-aligned economic activity referred to in Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0	0	0	0	0
7	Amount and proportion of other taxonomy-eligible but not taxonomy-aligned economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI	0	0
8	Total amount and proportion of taxonomy eligible but not taxonomy-aligned economic activities in the denominator of the applicable KPI	0	0

Taxonomy non-eligible economic activities

Row	Economic activities	Amount	Percentage

1	Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0
2	Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0

3	Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0
4	Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0
5	Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0
6	Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-eligible in accordance with Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the applicable KPI	0	0
7	Amount and proportion of other taxonomy-non-eligible economic activities not referred to in rows 1 to 6 above in the denominator of the applicable KPI	5,281.10	3.3
8	Total amount and proportion of taxonomy-non-eligible economic activities in the denominator of the applicable KPI	5,281.10	3.3

Wskaźnik ustalono, dzieląc sumę wydatków operacyjnych związanych z działalnością kwalifikującą się do systematyki Taksonomii przez wydatki ogółem w zakresie ww. kategorii kosztowych.

Według przeprowadzonej kalkulacji w roku sprawozdawczym 97,9 proc. łącznych wydatków operacyjnych stanowiły wydatki kwalifikujące się do Taksonomii.

Odsetek kosztów operacyjnych związanych z działalnością niekwalifikującą się do systematyki Taksonomii wyniósł 2,1 proc.

Accounting principles

The basis for calculating the denominator of the Opex KPI in accordance with the provisions of Annex 1 to Regulation 2021/2178 was the separation of direct, non-capitalised expenses from PSE S.A.’s overhead costs, based on PSE S.A.’s financial statements for the year ended 31 December 2023, related to:

research and development,
building renovation activities,
short-term leases,
maintenance and repairs, and
any other direct expenses related to the day-to-day running of property, plant and equipment by the company or a third party outsourced to perform the activities necessary to ensure continuous and efficient operation of those assets

Operating expenses (OpEx) and operating costs are understood in the same way.

Due to the impossibility of assigning a single cost item within a cost type, the company included only those cost types in the denominator, which are attributable in their entirety or majority to the denominator.

The following cost categories were adopted in accordance with the guidelines described in the Regulation:

Technical materials	Technical materials consumed for the operation of buildings and structures and equipment installed in buildings and structures.
Consumables	Materials purchased for maintenance work or withdrawn from the reserve equipment warehouse, consumed in maintenance work.
Transmission grid repair services	Costs of repair/overhaul works carried out on transmission grid facilities (lines and substations).
Transmission grid O&M services	Costs of work related to the provision of maintenance of substation power equipment by external contractors.
Other O&M services	Costs of work related to the operation and maintenance of other assets used by the Company.
Other repairs	Overhaul costs of fixed assets not directly used for electricity generation and distribution (buildings and structures, machinery and equipment).
Research and development	Cost of research and development.
Cleaning services	Costs of cleaning services at transmission grid facilities (lines and substations) and at the Company’s offices.
Property protection	Costs of property protection services, supervision of transmission grid facilities (lines and substations) and Company offices.
Training	Specialised training necessary for employees to do their jobs.

Based on the assumptions described, taxonomy-eligible expenses were identified.

Information on the assessment of compliance with Regulation (EU) 2020/852

The individual categories of capital expenditure incurred by PSE S.A., included in the denominator of the key KPI, were analysed in accordance with the provisions of EU Regulation 2021/2178 to determine whether they meet one of the following conditions:

a. are related to assets or processes associated with Taxonomy-aligned economic activities, including training and other human resources adaptation needs, and direct non-capitalised costs that represent research and development;

b. part of a plan to expand Taxonomy-aligned economic activities or to allow Taxonomy-eligible economic activities to become Taxonomy-aligned (‘CapEx plan’) under the conditions specified in the second subparagraph of this point 1.1.2.2;

c. are related to the purchase of output from Taxonomy-aligned economic activities and individual measures enabling the target activities to become low-carbon or to lead to greenhouse gas reductions, notably activities listed in points 7.3 to 7.6 of Annex I to the Climate Delegated Act, as well as other economic activities listed in the delegated acts adopted pursuant to Article 10(3), Article 11(3), Article 12(2), Article 13(2), Article 14(2) and Article 15(2) of Regulation (EU) 2020/852 and provided that such measures are implemented and operational within 18 months.

Based on the analysis performed, the expenditure related to activity 4.9 associated with a Taxonomy-aligned activity, which was shown as compliant in the Turnover KPI, was found to be Taxonomy-aligned, according to a) indicated above.

PSE does not have a capital expenditure plan that meets condition (b) indicated above. No operating expenses meeting condition (c) indicated above were identified, either.

Contribution to multiple objectives, disaggregation of KPIs

Not applicable. No operation expenditure linked to activities contributing to more than one environmental objective was identified. The key performance indicator was not disaggregated.

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ENVIRONMENTAL IMPACT AND CLIMATE ACTIONSEU Taxonomy

Minimum safeguards

1.1. TURNOVER KPI

Nuclear and fossil gas related activities

Taxonomy-aligned economic activities (denominator)

Taxonomy-aligned economic activities (numerator)

Taxonomy-eligible but not taxonomy-aligned economic activities

Taxonomy non-eligible economic activities

Accounting principles

1.2. Capex KPI

Nuclear and fossil gas related activities

Taxonomy-eligible but not taxonomy-aligned economic activities

Taxonomy non-eligible economic activities

Accounting principles

Information on the assessment of compliance with Regulation (EU) 2020/852

Contribution to multiple objectives, disaggregation of KPIs

1.3. OPEX KPI

Nuclear and fossil gas related activities

Taxonomy-aligned economic activities (denominator)

Taxonomy-aligned economic activities (numerator)

Taxonomy-eligible but not taxonomy-aligned economic activities

Taxonomy non-eligible economic activities

Accounting principles

Contribution to multiple objectives, disaggregation of KPIs

Carbon footprint

WPŁYW NA SPOŁECZEŃSTWO I PRACOWNIKÓW (S)

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	Proportion of Turnover/Total Turnover
	Taxonomy alignment by objective	Taxonomy eligibility by objective
CCM	99.85%	0%
CCA	0%	0%
WTR	0%	0%
CE	0%	0%
PPC	0%	0%
BIO	0%	0%

	Part of CapEx / Total CapEx
	Taxonomy alignment by objective	Taxonomy eligibility by objective

CCM	100%	0%
CCA	0%	0%
WTR	0%	0%
CE	0%	0%
PPC	0%	0%
BIO	0%	0%

	Part of OpEx/Total OpEx
	Taxonomy alignment by objective	Taxonomy eligibility by objective

CCM	96.7%	0%
CCA	0%	0%
WTR	0%	0%
CE	0%	0%
PPC	0%	0%
BIO	0%	0%