Company activities

Risks and Threats

Risk management system

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KOGENERACJA Group has implemented solutions in the scope of integrated risk management architecture – defined by a uniform standard for PGE Energia Ciepła Group. The primary goals of the process in the currently used model are to:

  • protect the Company’s current economic value;
  • strengthen the Company's capability to achieve its business goals while maintaining a balanced risk exposure;
  • support the decision-making processes in the Company.

Risks to ordinary business are measured once a year in the perspective of year n+1. In this way, in a reasonably downside scenario, it is possible to identify and prepare an appropriate response to risks in the context of significant changes taking place in the Company’s key business functions. The entities which conduct business in the heat and electricity generation sector have an obligation to cater to the basic needs of citizens and ensure energy security of the country as well as energy transition leading to the achievement of climate protection goals. Mindful of the trust that clients have placed in the Company and the importance of energy and heat supply to ensure the proper functioning of local communities, all risks that could lead to disruption of planned production are taken into account in a conscious and responsible manner. Risk measurement is not only focused on the possible damage to assets or a failure to achieve profit, but also on threats associated with the possible loss of trust of the Company's customers and damage to its reputation as a reliable energy supplier.

Like other entities in the heating sector, KOGENERACJA Group is also exposed to risks resulting from the specific nature of its operational activities, functioning in a specific market and regulatory and legal environment, as well as risks resulting from the current macroeconomic and geopolitical situation.

At KOGENERACJA S.A., risk management is implemented based on the GRC (Governance – Risk – Compliance) model, i.e. the concept of 3 lines of defence (Business – Risk – Audit). It allows the process to be aligned and integrated at all levels of management, in individual areas of activity. Definition of functions, as part of corporate risk management, ensures independent assessment of individual risks and their impact on the Company, with significant risks mitigated and controlled. As a separate compliance function has been set up within the Group, this ensures that the business activity of KOGENERACJA S.A. is conducted in accordance with applicable legal requirements and internal standards.

Key risks along with their assessment until the end of 2025

  high risk; intolerable risk, requiring immediate and active response aimed at the simultaneous reduction of impact and likelihood

  medium risk; an appropriate response should be prepared, based on cost-benefit analysis

  low risk; does not pose a threat and can be tolerated

↗   increase 

↔   stable trend 

↙   decrease

Risk areaRisk name Risk level/ trendMitigating actions and risk management tools

MARKET AND PRODUCT RISKS 

related to the prices and volumes of products and services offered


Production of electricity and heat – related to production planning and the negative impact of factors shaping production possibilities

Key actions:

  • Selection of optimal production scenarios adapted to the current market situation and current investment implementation schedule. Fulfillment of obligations specified in trade agreements regarding the supply of fuels, production raw materials and components, as well as ongoing cooperation with fuel and raw material procurement managers.
  • Preparation and implementation of plans for: crisis management, overhauls, ongoing infrastructure/ production maintenance;
  • Implementing preventive measures and recommendations from the lessons-learned process;
  • Ensuring effective and uninterrupted cooperation with the heating network operator;
  • Active participation in tasks related to the development of the heating network and cooperation with stakeholders in order to enable effective planning of the city’s heat and electricity supply.
  • Ensuring effective transaction monitoring and the quality of services.
  •  Applying for guaranteed and cogeneration bonuses, acting in accordance with procedures for managing the high-efficiency cogeneration support system and striving to achieve an ecological effect for the installation.
  • Monitoring and optimisation of variable costs of energy production and the impact on the implementation of obligations arising from the EU ETS system.
  • Monitoring of the actual carbon emissions, dynamic balancing and monitoring of the correct operation of measuring devices;
  • Ensuring the highest possible operational readiness of the Capacity Market Units and the operational capacity of measurement systems related to the requirements of the Capacity Market.
  • Constant monitoring of regulations and fulfillment of capacity obligations in accordance with the law;
  • Analysing the legal and regulatory requirements;
  • Ensuring compliance of the tariff process with relevant laws;


Heat sales volume - related to the implementation of the heat sales plan, resulting from unfavourable external and internal conditions affecting the demand for energy goods

Cogeneration support system – related to obtaining support for high-efficiency cogeneration and the impact of unfavourable external and internal conditions on achieving the expected revenues from support

Emissions Trading System – related to the use of allowances and the fulfillment of obligations under the carbon emissions trading system

Tariffs (regulated prices) – resulting from the statutory obligation to approve rates for heat prices

Capacity Market – resulting from threats related to failure to meet the obligations resulting from the capacity obligation of Capacity Market Units

ASSET RISKS

related to the development and maintenance of assets


Tangible investments – related to the strategic directions of the Company’s development and limited possibilities of obtaining financing for these projects


Key actions:

  • Active implementation of the development strategy and transformation of own production capacities.
  • Conducting analyses of the market, legislative and technological environment and available financing sources.
  • Ensuring appropriate preparation of participants in the investment process.
  • Ensuring appropriate management of the investment process, including taking into account macroeconomic and geopolitical conditions.
  • Ensuring appropriate supervision of work in progress.
  • Applying appropriate safeguards to ensure proper performance of the contract.
  • Selection of units, production volumes and renovation plans taking into account the schedule for implementing development investments and decarbonisation plans.
  • Carrying out maintenance and reconstruction repairs in accordance with adopted standards and increasing supervision over the asset maintenance process.
  • Ensuring professional handling of the maintenance process and the availability of an appropriate level of external failure-response services.
Asset management and maintenance investments – related to the risks resulting from maintaining the proper technical condition of production assets

Failures - related to the operation and deterioration of energy equipment and facilities over time and unplanned unavailability of generating units caused by: disruptions, random events and failures

OPERATIONAL RISKS

related to the implementation of current business processes


Fuel management - related to uncertainty about the costs, quality, timeliness and quantity of delivered fuels, production raw materials and the efficiency of the inventory management process


Key actions:

  • Fuel management policy integrated at the PGE Group level.
  • Ensuring the continuity of contracts for the purchase and transport of fuels, production raw materials and components.
  • Applying a fuel strategy that takes into account the investment implementation schedule.
  • Predefining the quality requirements for fuels and production inputs.
  • Implementation of the principles of optimal management of fuel stock, taking into account the appropriate levels of contracted capacity and keeping fuel stocks at the required regulatory level;
  • Ensuring professional handling of the purchasing process and applying internal regulations regarding its implementation.
  • Ensuring the development of appropriate descriptions of contract subjects and the application of methods ensuring the correct estimation of contract values.
  • Appropriate shaping of the generational succession process, including preparation and implementation of the succession and retention plan for employees at the Company.
  • Shaping friendly working conditions, applying an adequate remuneration system, transparent principles of motivation and competence assessment, and ensuring professional development of employees.
  • Ensuring appropriate levels and professional handling of dialogue with trade unions and maintaining communication in key areas.
  • The employer’s initiative regarding changes aimed at improving the situation of employees, taking into account the business environment and regulations of the PGE Group.
  • Ensuring an appropriate identification process and response to cybersecurity threats.
  • Applying IT and OT security measures, including implementing recommendations and reconfiguration actions.
  • Carrying out activities related to the implementation of the requirements of the NIS-2 Directive.
  • Raising employee awareness of cybersecurity and exchanging good practices in the area of cybersecurity.
  • Applying appropriate procedures, including the Confidential Information Policy.
  • Providing Plant Protection Plans.
  • The use of communication in the area of physical protection aimed at maintaining an adequate level of security.
Purchasing – related to inefficiency and irregularities in the purchasing process

Human resources – related to difficulties in providing staff with appropriate experience, competences and abilities to carry out specific tasks

Industrial relations – related to the failure to reach an agreement between the Group's authorities and trade unions, which may lead to strikes/ collective disputes

Cybersecurity – the risk of deliberate disruption of the proper functioning of production assets and IT systems

Protection and security of facilities – related to maintaining a high level of protection of the Company's devices and facilities

LEGAL AND REGULATORY RISKS

related to meeting the requirements of the legal environment


Environmental protection – obligations resulting from the regulations specifying environmental requirements to be met by energy installations and the rules for using the natural environment, including uncertainty as to their final shape and level of limits and ESG reporting


Key actions:

  • Monitoring environmental protection laws and regulations.
  • Implementing and applying internal environmental protection standards;
  • Ensuring that required environmental permits and decisions are in place.
  • Ensuring regular checks and measurements of emissions and the technological process by competent bodies.
  • Applying technical and organisational protective measures to reduce emissions.
  • Applying standards for the management of waste and sewage generated in the production process.
  • Planning and implementation of investment and modernisation initiatives in order to meet environmental requirements.
  • Applying the Occupational Health and Safety Policy and the principles of organising safe work.
  • Training of employees and contractors in occupational health and safety.
  • Work environment control.
  • Applying personal data protection procedures.
  • Conducting training to shape awareness of employee and institutional responsibility in the field of personal data protection.
  • Ensuring compliance with legal and regulatory requirements.
Employee safety – related to failure to provide safe working conditions

Personal data protection – related to the breach of personal data security and the violation of the rights and freedoms of natural persons

Concessions – resulting from the statutory obligation to hold a license for the conducted activity

FINANCIAL RISKS

connected
with the Company’s financial management


Financial liquidity – connected
with the possibility of losing the ability to service current liabilities and obtaining sources of financing for business activities

Key actions:

  • The Group applies a central financing model, according to which external financing is obtained by PGE S.A.
  • Using various sources of intra-group financing, cooperation in the field of integrated liquidity management system and obtaining financing.
  • Various methods for verifying cash flow plans.
  • Planning current demand for financial resources and long-term financing needs within the scope of conducted operating and investment activities.
  • Application of financial liquidity management and debtor control procedures.
  • Implementation of the Credit Risk Management Policy and screening of contractors.
  • Ensuring professional service of the debt structure.

CO₂ Emissions Trading Scheme

On 7 July 2021. Within the so-called fourth settlement period covering the years 2021-2030, the Minister responsible for climate issues announced a list of installations with the final number of CO₂ emission allowances allocated for heat production for the years 2021-2025 (in accordance with the Act of 12 June 2015 on the greenhouse gas emission trading scheme). These allowances only apply to heat production, no allowances are allocated to electricity generators from 2020 onwards.

For 2024, the Company was granted a limit, including free CO2 emission allowances for heat production, in the amount of 105 422 Mg (109 630 Mg in 2023, 113 029 Mg in 2022, 114 744 Mg in 2021, 159 365 Mg in 2020, 374 649 Mg in 2019, 477 859 Mg in 2018).

CO2 allowance balance for the year ended 31 December 2024 – KOGENERACJA S.A.
Mg
For the year ended
31 December 2024
KOGENERACJA S.A.
Actual emissions in 2024*1 237 021
Annual allowance allocation105 422
Balance of 2024 after final settlement (shortfall)1 131 599
Transactions for 20241 176 678
Surplus45 079

For 2024, EC Zielona Góra was granted a limit, including free CO2 emission allowances for heat production, in the amount of 16 818 Mg (17 475 Mg in 2023, 17 948 Mg in 2022, 18 331 Mg in 2021, 32 538 Mg in 2020, 39 880 Mg in 2019, 47 491 Mg in 2018).

CO2 allowance balance for the year ended 31 December 2024 – EC Zielona Góra S.A.
Mg
For the year ended
31 December 2024
EC Zielona Góra S.A.
Actual emissions in 2024*554 376
Annual allowance allocation16 818
Balance of 2024 after final settlement (shortfall) 537 558
Transactions for 2024521 677
Shortfall-15 881

In accordance with the applicable accounting policy, the Group posted provisions for a shortage of COallowances in a total amount of PLN 170 872 thousand (in 2023: PLN 170 832 thousand); the value of provisions posted by the Parent Company is PLN 103 711 thousand (in 2023: PLN 135 794 thousand in 2023); and the subsidiary posted PLN 67 161 thousand (in 2023: PLN 35 038 thousand).

In December 2024, the Group redeemed COallowances for 2024 in the total amount of PLN 510,420 thousand, including the Parent Entity in the amount of PLN 380 308 thousand and the subsidiary in the amount of PLN 130 112 thousand.

Emission CO₂