Although the Code does not explicitly address the issue of human trafficking, its general provisions regarding, among other aspects, respect for the dignity and rights of every human being obviously rule out any approval of such practices.
ESRS S2 Workers in the value chain
Interests and views of stakeholders
The interests, views and rights of people working in the value chain, including respect for their human rights, do not affect the Enea Group’s strategy or business model.
Material impacts, risks and opportunities and their interaction with strategy and business model
The material risk impacts and opportunities related to workers in the value chain identified in the Double Materiality Analysis process are not reflected in the Enea Group’s strategy or business model. Workers in the value chain are people hired by upstream entities in the Enea Group’s value chain, that is by suppliers.
The Enea Group does not audit its suppliers for compliance with human rights regulations – the Group is unable to ascertain whether the risk is universal or incidental. There is a certain risk that forced or child labor may be used in plant and machinery manufacturing and/or metal mining companies in Asia and/or Africa.
The positive impact exerted by the Enea Group results from the adoption of the Enea Group Code of Conduct for Contractors, which contains compliance obligations on the part of contractors, market and ethical standards, including in the areas of human rights and working conditions, in particular labor rights, also in respect of working hours. A major risk is the reputational risk associated with non-compliance with the Code of Conduct for Contractors by the Group’s suppliers.
Material topic: Workers in the value chain
The issue of human rights and working conditions of workers in the value chain is regulated by the Enea Group Code of Conduct for Contractors. The Code explicitly requires all contractors of the Group to:
- respect the dignity and rights of every human being and ensure that their staff treat each other with respect,
- respect fundamental labor rights,
- ensure fair working conditions and pay,
- refrain from hiring persons under the minimum legally permitted age in the respective country and below international standards,
- refrain from using forced labor and refrain from cooperating with subcontractors ever found to have benefited from the use of labor performed by children below the minimum age accepted in the respective country and/or below international standards,
- refrain from discriminating against workers on the basis of gender, age, origin, nationality, race, skin color, marital status, number of children, religion, sexual orientation, political views, disability, union membership or other discretionary factors, either during the recruitment process or during the term of employment,
- ensure that all workers enjoy working conditions that are safe and comply with all applicable health and safety regulations, monitor, manage and address any breaches thereof,
- ensure freedom of association without fear of intimidation or pressure of any kind, engage in social dialogue.
Moreover, LW Bogdanka has adopted the LWB Code of Conduct for Suppliers. The Code requires counterparties to comply with basic requirements and standards in the field of respect for human rights. Since 2024, the LW Bogdanka Group has also had a Human Rights and Diversity Policy in place, enabling it to monitor suppliers for human rights violations and urge them to abandon any practices considered out of compliance with the Policy.
The Enea Group enables all workers in the value chain to report breaches of the Enea Group Code of Conduct for Contractors via the communication channels specified on the organization’s website. In the event a breach of the Code is discovered, the Enea Group may deploy appropriate measures to ensure remedying the breach by the counterparty. In such a situation, the Group expects its contractors to promptly take all necessary investigative and remedial actions. In the event of serious breaches, Group companies reserve the right to impose sanctions on the counterparty.
Although the Enea Group Code of Conduct for Contractors was prepared on a basis other than the UN Guiding Principles on Business and Human Rights, the Group is of the opinion that the provisions of the Code are not at odds with the values laid down in these international regulations (including respect for the dignity and rights of every human being, respect for fundamental employee rights, etc.). In 2024, there were no cases of non-compliance with the UN Guiding Principles on Business and Human Rights.
Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions
In 2024, the Enea Group did not take any steps regarding material impacts on workers in the value chain.
In 2024, no cases of human rights violations in relation to workers in the value chain were ascertained.
Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
In 2024, the Enea Group did not pursue any objectives related to workers in the value chain. To date, the Group has not identified a justification for adopting such objectives. The terms of cooperation with workers in the value chain are regulated to a sufficient degree in the Enea Group Code of Conduct for Contractors and in specific contracts entered into between Group companies and such workers.
Processes for engaging with value chain workers about impacts
In 2024, in the Enea Group, the opinions of workers in the Group’s value chain did not impact any decisions or actions related to the management of actual or potential impacts. No engagement was undertaken with any value chain workers.
Processes to remediate negative impacts and channels for value chain workers to raise concerns
Enea Group companies provide all value chain workers with special channels for directly reporting any concerns or needs they may have. The internal reporting procedures in place enable confidential or anonymous reporting of any breaches in the Enea Group’s operations. Whistleblowers may report such breaches to Enea Group companies orally or in writing, including in traditional hard-copy form by mail to the physical addresses specified by the companies or using the Whistleblower Software system provided by an external supplier. In accordance with statutory requirements, whistleblowers are afforded protection against retaliation – in the parent company, this area is governed by the “Procedure for Reporting Breaches and Protecting Whistleblowers at Enea S.A.”
At Enea S.A., following the completion of investigation by the Compliance Committee, in accordance with the “Procedure for Reporting Breaches and Protecting Whistleblowers at Enea S.A.”, the Committee prepares a final report on the whistleblower notification. The report provides detailed information on all facts described in the notification, observing the rule of anonymity of the source if so elected by the whistleblower, and on all necessary steps and recommendations, for instance those regarding disciplinary action.
The Enea Group did not implement any special processes to inform value chain workers about the availability of channels for reporting concerns, but detailed information on this topic was published on the organization’s website. In 2024, the Enea Group did not assess the extent to which value chain workers were aware of the existence of such channels or how effective they were. Information on the protection of whistleblowers is provided in disclosure requirement G1-1 in the “Business conduct” section.