This is a Category B project according to IFC's Policy on Environmental and Social Sustainability considering that it is expected to have limited adverse E&S risks and impacts that are few in number and site-specific and readily addressed through existing mitigation measures and good international industry practices (GIIP) as described in the following sections.

Key E&S issues associated with the project are: (i) E&S capacity & ability to assess and manage the E&S risk and impacts of its investments in line with IFC PS, particularly in relation to biodiversity; (ii) corporate ESMS/capacity and review of E&S performance of subsidiaries; (iii) labor and working conditions; and (iv) supply chain & contractor management.

 The issuer has formal Human Resources (HR) policies and procedures in line with local and EU labor requirements, which are generally aligned with IFC PS2, and cover aspects such as hiring, rights, obligations (including non-discrimination and equal opportunities), retrenchment, and working conditions. The primary documents regulating labor-related issues include a group-level HR Policy and a Policy of Diversity and Respect for Human Rights. The basic principles of the Diversity Policy include respect for human rights and prohibition of any discrimination.

The issuer provides written employment contracts to all employees, which specify the terms of the employment, including the salary, working hours, overtime arrangements, holidays, rights in terms of freedom of association, and rights related to submitting internal complaints, if applicable. The working conditions are the same for migrant, ex-pat, and local workers. National legislation provides employees with the right to form and join workers' organizations.

The issuer will require PAK PCE to develop and implement a worker's grievance mechanism (WGM), in accordance with national requirements and IFC's PS2. The WGM will be made available to all sub-project workers, irrespective of their employer. PAK PCE will disseminate information about its use to the workforce (ESAP#6).

The issuer has developed an occupational health and safety (OHS) management system that complies with all national legal requirements, which are generally aligned with IFC PS. The issuer requires its subsidiaries, including PAK PCE, to implement management systems that include OHS procedures regularly updated to reflect changes in changing regulations, conditions, and factors influencing the work environment. All workers, including contractors, are required to be adequately trained and equipped with personal protective equipment in accordance with the type of performed works. PAK PCE will develop and implement a contractor management procedure to be applied to all IFC-financed sub-projects and include provisions on OHS, and environmental protection in the legal agreements with contractors to ensure ESMS requirements are adequately respected by the contracted workforce (ESAP #1, ESAP #4).

Pollution generated during the construction and operation of renewable energy projects is generally minor and readily mitigated through standard pollution prevention and control measures. PAK PCE will require its contractors/subcontractors to comply with environmental license conditions and the requirements of project-specific ESMPs (ESAP#1 and 4), covering such aspects as fugitive dust from earth-moving activities; noise and exhaust from construction machinery; sanitary effluents from worker facilities (typically disposed of via septic systems), and non-hazardous and hazardous solids wastes (typically disposed of through registered contractors or at the local waste disposal facilities in the case of non-hazardous wastes), as applicable. Noise from construction activities is not expected to be a significant issue for the sub-projects, as there will likely be limited nearby sensitive receptors, and construction activities will be restricted to daylight hours.

Volumes of liquid, solid, and hazardous waste generated by the project during operations are expected to be low. For solar sub-projects, small quantities of water will be required to clean solar panels during the operational phase. Water will only be sourced from appropriately permitted sources. For wind sub-projects under consideration for IFC financing, an assessment of potential operational impacts (shadow flicker, noise elevations etc.) will be undertaken prior to PAK PCE’s acquisition of the project. For sub-projects to be developed utilizing IFC’s use of proceeds, PAK PCE will ensure that operational impacts comply with national standards and IFC PS.

 Risks and impacts to host communities of sub-projects and the public will be individually assessed during the ESIA process (as per ESAP#2). Based on the findings, appropriate mitigation measures will be defined and implemented during the construction and operation of each sub-project.

The wind sub-projects to be developed by PAK PCE and its subsidiaries are generally located away from local settlements to minimize noise impacts and safety risks (i.e., blade and ice throw). Sub-project ESIAs will establish safety buffer zones around each turbine, and appropriate mitigation measures will be defined within the sub-project ESMPs, including installing warning signs and active engagement to inform local people of the dangers posed by the project. The solar assets to be developed are expected to be located on rehabilitated industrial lands, with minimal potential for adverse impacts on local communities. Electrical equipment will be fenced, and cables insulated to avoid any electrical hazards. Access to agricultural fields, villages, communities, and their networks will not be disrupted /hindered.

The main road traffic risk associated with the sub-projects is related to transporting solar and wind components (PV panels, turbines, blades, and wind tower components – abnormal loads) to the various project sites from vendor facilities. Additional risks relate to the transport of other construction materials and the project personnel. Risks associated with this transport will be assessed within the sub-project ESIAs. As per ESAP#2, applicable control measures to protect local community members from road traffic accidents, in line with GIIP will be defined in each sub-projects ESMP and implemented by PAK PCE and their contractors/sub-contractors.

The issuer publishes an annual sustainability report, which includes E&S-related KPIs and other information to its stakeholders (https://grupapolsatplus.pl/pl/odpowiedzialny-biznes/raporty-niefinansowe-grupy-polsat). Additionally, any comments and queries about the E&S/sustainability issues through a dedicated email address komunikacja@cyfrowypolsat.pl.

At the IFC-financed sub-project level, as detailed under ESAP#2, the issuer will require PAK PCE to complete an ESIA aligned with IFC PSs for any sub-project to be developed utilizing IFC proceeds, which will include adequate engagement with stakeholders. If a national-level ESIA was completed prior to PAK PCE acquiring the sub-project, a gap analysis will be conducted to determine whether there are material differences between the national-level ESIA and IFC PSs (including the adequacy of stakeholder engagement). If material differences are identified in this regard, these will be addressed to ensure the assessment complies with IFC PS requirements on stakeholder engagement. As per ESAP#1, the issuer will ensure PAK PCE develops and implements a stakeholder engagement procedure and grievance redress mechanism in line with IFC PS1 as part of its ESMS.

The issuer’s corporate sustainability report is prepared per the requirements of Global Reporting Initiative GRI-G4 standards, and performance data for every year (including details on energy use, water use, waste quantity, and GHG emissions) is disclosed on the issuer’s website (https://grupapolsatplus.pl/en/investor-relations/results-centre/results-centre/financial-reports). From 2023 the issuers corporate sustainability report will include information relating to PAK PCE.

    komunikacja@cyfrowypolsat.pl