Note
The Annual Report has been prepared in the Czech language and in English. In all matters of interpretation of information,
views or opinions, the Czech version of the Annual Report takes precedence over the English version.
MND a.s.
Annual Report
2024
MND
MND
a.s., Uprkova 807/6,
695
01 Hodonfn, Czech Republic,
Company
No
.: 28483006, VAT No.: CZ699003312
Customer
Toll-Free Line Line:
800
400 500, e-mail:mnd@mnd.cz,www.mnd.eu
Company
registered
in
the
Commercial Register with
the
Regional Court
in
Brno, Reg.
Page 2 (total 219)
Content:
I. Report on the company's business activities and the state of its assets (consolidated) .......................... 3
1. Company ....................................................................................................................................................................... 3
2. Consolidated group ....................................................................................................................................................... 3
3. Jointly controlled and associated entities..................................................................................................................... 4
4. Business activities the MND Group .............................................................................................................................. 4
5. Sale of gas and electricity to households and small businesses ................................................................................... 4
6. Trading in energy commodities .................................................................................................................................... 5
7. Underground gas storage ............................................................................................................................................. 5
8. Exploration and production of hydrocarbons ............................................................................................................... 5
9. Drilling and workover activities .................................................................................................................................... 5
10. Investments in renewable energy sources and new development projects ................................................................ 6
11. Human resources .......................................................................................................................................................... 6
12. Education and social affairs .......................................................................................................................................... 6
13. Corporate social responsibility and sponsorship .......................................................................................................... 6
14. MND Group's financial results and state of assets in 2024 .......................................................................................... 7
15. Information on risk management ................................................................................................................................. 7
16. Outlook for the upcoming period ................................................................................................................................. 7
17. Subsequent events ....................................................................................................................................................... 7
II. Report on relations between the controlling entity and the controlled entity, and
between the controlled entity and entities controlled by the same controlling entity ............................ 8
1. The structure of relations between the Company and other Related Entities ............................................................. 8
2. Role of the Company .................................................................................................................................................... 8
3. Methods and means of control .................................................................................................................................... 8
4. Overview of significant acts .......................................................................................................................................... 8
5. Overview of contracts ................................................................................................................................................... 9
6. Loss evaluation and settlement .................................................................................................................................... 9
7. Advantages and disadvantages of the relations between Related Entities .................................................................. 9
Annex 1 - List of Related Entities ............................................................................................................................................ 10
Annex 2 - List of contracts between Related Entities concluded during the Accounting Period ........................................... 18
Annex 3 - List of contracts between Related Entities concluded prior to the Accounting Period .......................................... 23
III. Consolidated Sustainability Statement ............................................................................................... 28
1 ESRS 2 - General information ...................................................................................................................................... 28
1.1 Basis for preparation .............................................................................................................................................. 28
1.2 Governance ............................................................................................................................................................ 31
1.3 Strategy .................................................................................................................................................................. 35
1.4 [IRO-1] Description of the processes to identify and assess material impacts, risks and opportunities................ 46
1.5 ESRS Index .............................................................................................................................................................. 53
1.6 Data points resulting from other EU legislation ..................................................................................................... 55
2 Environmental information ........................................................................................................................................ 66
2.1 EU Taxonomy for the 2024 reporting period ......................................................................................................... 66
2.2 E1 - Climate change ................................................................................................................................................ 83
2.3 E2 - Pollution .......................................................................................................................................................... 92
2.4 E3 - Water and marine resources ........................................................................................................................... 95
2.5 E5 - Resource use and circular economy ................................................................................................................ 97
3 Social information ..................................................................................................................................................... 100
3.1 S1 - Own workforce .............................................................................................................................................. 100
3.2 S4 - Consumers and end-users ............................................................................................................................. 110
4 Governance information ........................................................................................................................................... 115
4.1 G1 - Business conduct .......................................................................................................................................... 115
IV. Consolidated financial statements of MND a.s. as at 31 December 2024 .......................................... 118
V. Separate financial statements of MND a.s. as at 31 December 2024 .................................................. 174
VI. Independent auditor's report ........................................................................................................... 219
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.
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I. Report on the company's business activities and the state of its
assets (consolidated)
1. Company
MND a.s. (hereinafter referred to as the "Company") was established by its sole founder on 30 September 2008
under the original business name ORTOKLAS a.s.. The Company was incorporated on 3 November 2008 and is
entered in the Commercial Register at the Regional Court in Brno under file number B 6209.
2. Consolidated group
As at 31 December 2024, the Company formed a consolidated group with the following entities that are controlled
entities vis-à-vis the Company pursuant to Section 74 et seq. of Act No. 90/2012 Coll., on Business Corporations, as
amended:
1. IGNIS HOLDING a.s., with its registered office at Prague 10, Strašnice, Vinohradská 1511/230, 100 00, ID No.:
07435304;
2. FVE Mušov I s.r.o., with its registered office at Hodonín, Úprkova 807/6, 695 01, ID No.: 19174098;
3. FVE Mušov II s.r.o., with its registered office at Hodonín, Úprkova 807/6, 695 01, ID No.: 17873517;
4. FVE Orlová I s.r.o., with its registered office at Hodonín, Úprkova 807/6, 695 01, ID No.: 06763731;
5. FVE Orlová II s.r.o., with its registered office at Hodonín, Úprkova 807/6, 695 01, ID No.: 19254504;
6. FVE Tichá s.r.o., with its registered office at Hodonín, Úprkova 807/6, 695 01, ID No.: 28605233;
7. G2P Borkovany s.r.o., with its registered office at Hodonín, Úprkova 807/6, 695 01, ID No.: 17873592;
8. "Geologichne bureau "Lviv" LLC, with its registered office at Lviv Oblast, Lviv, 79011, ul. Kubiyovicha 18,
Office 6, Ukraine, reg. no. 31978102;
9. "Horyzonty" LLC, with its registered office at Lvivska Oblast, Lviv, 79011, ul. Chubaia Hrytska 6C, Office 7,
Ukraine, reg. no. 36828617;
10. KBOC Director s.r.o., with its registered office at Hodonín, Úprkova 807/6, 695 01, ID No.: 19666144;
11. MND Austria a.s., with its registered office at Hodonín, Úprkova 807/6, 695 01, ID No.: 19407904;
12. MND BESS a.s., with its registered office at Hodonín, Úprkova 807/6, 695 01, ID No.: 21140839;
13. MND BESS GmbH, with registered office at 29227 Celle, Maschweg 1, Federal Republic of Germany, Reg. No
HRB212002;
14. MND Drilling & Services a.s., with registered office at Lužice, Velkomoravská 900/405, 696 18, ID No.:
25547631;
15. MND Energy Storage a.s., with its registered office at Hodonín, Úprkova 807/6, 695 01, ID No.: 27732894;
16. MND Energie a.s., with registered office at Prague 6, Vokovice, Evropská 866/71, 160 00, ID No.: 29137624;
17. MND GasInvestUA s.r.o., with its registered office at Hodonín, Úprkova 807/6, 695 01, ID No.: 19237375;
18. MND Gas Storage a.s., with its registered office at Hodonín, Úprkova 807/6, 695 01, ID No: 285 06 065
19. MND UK NORTH SEA LTD, with its registered office is 4th Floor 3 Dering Street, London W1S 1AA, United
Kingdom of Great Britain and Northern Ireland, reg. no. 15921060;
20. MND Ukraine a.s., with its registered office at Hodonín, Úprkova 807/6, 695 01, ID No.: 08957517;
21. MND Wind s.r.o., with its registered office at Hodonín, Úprkova 807/6, 695 01, ID No.: 17873568;
22. Oriv Holding a.s., with its registered office at Hodonín, Úprkova 807/6, 695 01, ID No.: 11735376;
23. "Precarpathian energy company" LLC, with registered office at Ivano-Frankivska Oblast, Bohorodchany,
77701, ul. Shevchenka, Ukraine, reg. no. 36042045;
24. SG Storage 2 s.r.o., with its registered office at Hodonín, Úprkova 807/6, 695 01, ID No.: 05781779;
25. "Tynivske" LLC, with registered office at Chubaya Gritska Street, building 6C, room 7, Lviv, 79005, Ukraine,
reg. no. 45716076;
(the Company and its controlled entities together the “MND Group” or “Group”).
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.
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Page 4 (total 219)
3. Jointly controlled and associated entities
As at 31 December 2024, the following entities were jointly controlled or associated entities vis-à-vis the Company
(pursuant to Section 22, par. 3, point (b) and (c) of Act No. 563/1991 Coll., on Accounting, as amended):
1. Biosférická rezervace Dolní Morava o.p.s., with its registered office at 691 44 Lednice, Zámecké náměstí 69,
ID No.: 285 06 065;
2. NANO Advanced s.r.o., with its registered office at Jakubské náměstí 580/4, Brno-město, 602 00 Brno, ID:
26949211;
3. NANO Advanced Electrolysis s.r.o., with its registered office at Jakubské náměstí 580/4, Brno-město, 602 00
Brno, ID: 19283768;
4. Silent partnership Anshof with ADX VIE GmbH, with its registered office at Ölzeltgasse 3/8, 1030, Vienna,
Austria, reg. no. FN515926s
5. Silent partnership AT-I with ADX VIE GmbH, with its registered office at Ölzeltgasse 3/8, 1030, Vienna,
Austria, reg. no. FN515926s
6. Oriv Windpark LLC, with its registered office Oriv Windpark LLC, with registered office at Sichovykh Striltsiv,
12 ap. 9, Lviv, 79007, Ukraine, reg. no. 38057121
4. Business activities the MND Group
The principal business activities of the MND Group are:
• Sale of gas and electricity to households and small businesses;
• Trading in energy commodities;
• Operation of underground gas storage facilities and provision of gas storage services;
• Exploration and production of oil and natural gas;
• Drilling contractor services, focusing on drilling of oil and gas exploration and production wells, hydro and
geothermal wells, and well workover and abandonment;
• Investment in renewable energy sources and the development of new technologies.
These activities were carried out both in the Czech Republic and abroad. The MND Group does not engage in
research and development activities. Neither MND a.s. nor other MND Group companies have branches abroad.
5. Sale of gas and electricity to households and small businesses
As at 31 December 2024, the MND Group supplied energy to 269,722 supply points. For gas, it was more than
119,000 and for electricity, more than 150,000 supply points. As part of its offer, MND reflected the development
of the market and continuously adjusted the prices of its products so that customers were satisfied with the energy
supply from MND. The MND Group has long prided itself on and invested in a pro-customer, transparent and fair
approach to energy supply.
MND Group has launched its first projects using artificial intelligence to speed up the processing of customer
requests and refine data analysis. These innovations improve communication with customers, leading to an
increase in the quality of service provided.
Another significant step was the takeover of call centre and back-office services into internal management, which
resulted in greater operational efficiency, better customer service and measurable improvements in business
results.
The extension of our range of services also includes a new solar account functionality that allows customers to
share the funds received from the purchase of electricity. The move underlines MND's focus on innovation and, like
the company's other services, is built on fairness, simplicity, and transparency.
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6. Trading in energy commodities
MND Group continued its business activities on the European continent. MND operated as a licensed electricity and
gas trader, including trading with and above gas storage facilities, primarily in the markets of the Czech Republic,
Germany, the Netherlands, Austria, and Hungary. In 2024, we increased the volumes traded in the financial markets
for emission allowances, oil, and started trading selected oil products on a global level. As part of our long-term
strategy, the MND Group has continued to develop and refine automated and autonomous trading models for
various market segments, countries and commodities. MND further expanded its geographic reach to include
electricity trading in Italy.
Increased volatility in the markets persisted throughout the year, mainly due to the emergence of external non-
market risks - especially risks associated with the ongoing war in Ukraine and the threat to gas flows through its
territory. Trading strategies reflected the increased risk. The aim was, as last year, to keep the risk parameters of
trades at low level, to focus on short-term holding of trading positions and to eliminate market risks by cross
hedging between commodities.
7. Underground gas storage
MND Group is the operator of the Uhřice and Dambořice underground gas storage facilities (UGS). The Uhřice gas
storage facility consists of two storage structures and has a total storage capacity of 335 million m
3
, with the
potential for further development to 350 million m
3
. The Dambořice gas storage facility was commissioned during
2016 and has a total storage capacity of 448 million m
3
. In addition to natural gas storage, both storages are also
suitable for electricity storage via hydrogen gas and are ready to receive energy in the form of hydrogen up to 5% H
2
concentrations mixed with natural gas at the entry point of MS Brumovice from 1 January 2022.
8. Exploration and production of hydrocarbons
MND Group is the largest Czech group engaged in the production of oil and natural gas. The Group holds five
exploration permits covering a total area of 1,784 km
2
in the region of south-eastern Moravia. Subsidiaries hold
nine exploration and production licenses with a total area of 400 km
2
in Ukraine. These exploration areas are
covered by a network of 2D seismic surveys and, to a large extent, a network of 3D seismic surveys. In 2024, the
MND Group carried out 3D seismic survey in the Zhukivska license area in eastern Ukraine. Based on the results and
interpretation of the seismic measurements and other geological information, the MND Group designs and drills
exploration wells to discover new oil and gas fields. In 2024, the MND Group drilled two appraisal wells and two
exploration wells in southern Moravia and six wells in western Ukraine.
The MND Group produces oil and/or natural gas from 36 fields in the region of south-eastern Moravia. Oil
production in 2024 amounted to 75 thousand m
3
, natural gas production amounted to 79 million m
3
and natural
gas supplies from own production amounted to 71 million m
3
. Subsidiaries in Ukraine produced 67 million m
3
of
natural gas.
9. Drilling and workover activities
In 2024, the MND Group drilled 4 wells for its own operations (MND a.s.) and 19 wells for external customers. The
MND Group carried out drilling or underground workover operations in Hungary, France, Germany, Croatia, Spain,
and the Czech Republic. The Group has completed drilling projects for HHE Sarkad Limited, several projects for the
Vermilion Energy Group, completed a project in France for KEM-ONE S.A.S and has also completed several projects
in the German market for Neptune Energy Deutschland GmbH, Rhein Petroleum GmbH and started a long-term
cooperation with the operator Wintershall Dea Deutschland GmbH.
In the Czech Republic, the MND Group started its drilling activities in 2024 by drilling 2 deeper wells - Borkovany 8
and Krumvíř 3 - with the Bentec 350 rig for the parent company MND a.s. In addition, the MD150 rig was used to
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Page 6 (total 219)
drill the Břeclav 46 and Břeclav 45 wells for LAMA Gas & Oil a.s. from August to September, followed by the
Koryčany 21 and Mikulov 3 wells for MND a.s.
10. Investments in renewable energy sources and new development projects
During 2024, the construction of a 54.6 MW wind power plant in the Lviv region of western Ukraine, in which MND
Group is participating with its partner company Ivena Limited, was completed.
In 2024, the MND Group continued to invest in projects for the construction of rooftop photovoltaic power plants
in the locations of MND's operating centres - Ždánice, Poddvorov, Hodonín, and Lužice.
MND Group is engaged in the development of modern energy projects and invests in their implementation and
preparation. The Borkovany Grid Support Services (GSS) project has been completed. In parallel, project
preparation and the start of construction of a similar GSS project at the Hrušky 5 site, and project preparation for
the implementation of large capacity battery storage facilities in the Czech Republic and Germany were carried out.
The implementation and operation of the CHP unit in Lužice was completed and the implementation of the CHP
unit in Ždánice was started.
In cooperation with universities and business partners, MND Group has participated in projects related to hydrogen
technology, transportation and underground storage of hydrogen.
The MND Group has joined NANO Advanced s.r.o. as a majority shareholder, which is developing an advanced water
electrolyser for hydrogen production that will use artificial intelligence elements to control it.
The MND Group is a partner in the COREu project, whose main objective is to develop CO
2
transport routes in the
regions of Southern and Central Europe.
11. Human resources
As at 31 December 2024, MND Group companies employed a total of 1 156 employees, of which 1 079 were in the
Czech Republic and 77 in Ukraine.
12. Education and social affairs
The MND Group encourages employee education and provides an environment that is conducive to the personal
development of every employee. The educational system focuses on professional, managerial, and language
training. The MND Group also promotes cooperation with selected secondary schools and universities in the Czech
Republic and abroad, with a focus on both increasing the qualifications of its employees, and on acquiring new
talents, further developing their skills by giving them the opportunity to work with teams of experts. With respect
to employee care, the MND Group focuses on creating a professional working environment with a broad selection
of employee benefit options.
13. Corporate social responsibility and sponsorship
The MND Group has an active social responsibility program to support a wide range of beneficial and charitable
events and civic associations in the Czech Republic. Consistent with the scope and location of its business and
respect for the environment, MND directs its activities to improve the quality of the environment in the
communities where it operates.
MND has been cooperating on joint projects with the Dolní Morava Biosphere Reserve, o.p.s. concerning the
protection of natural and cultural diversity and sustainable economic development.
MND financially supports a wide range of other projects focusing mainly on sports, culture and education, especially
supporting children in sports.
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Page 7 (total 219)
14. MND Group's financial results and state of assets in 2024
The MND Group reported a consolidated profit of CZK 572 million for 2024 CZK after tax. Revenues amounted to
CZK 28,578 million in the period concerned. The consolidated profit from operating activities for the period under
review amounted to CZK 811 million. The consolidated result from financial operations amounted to a loss of
CZK 189 million.
The MND Group's assets as at 31 December 2024 were as follows:
• property, plant and equipment worth CZK 9 571 million CZK, intangible assets in the amount of
CZK 289 million, and non-current financial assets of CZK 1 547 million;
• current assets of CZK 9 676 million CZK, comprising current financial assets of CZK 3 240 million and cash of
CZK 1 139 million.
The MND Group's equity as at 31 December 2024 totalled CZK 10 657 million, of which equity attributable to the
shareholders amounted to CZK 10 421 million. The total liabilities amounted to CZK 10 541 million.
In 2024, the MND Group companies did not hold any own shares or interim certificates.
15. Information on risk management
The principal role of the MND Group’s risk management is to identify risks, determine a risk measurement method,
quantify and analyse risk exposure, define a hedging strategy and the hedging implementation as such. The overall
responsibility for setting up the MND Group’s risk management system and supervising its operation lies on the
level of the board of directors. With regard to the diversity of operations and the corresponding risks, the
management of each group company is responsible for setting up and monitoring risk management policies.
Information on the MND Group’s risk management is disclosed in note 30 of the notes to the consolidated financial
statements, which includes a description of investment instruments used by the MND Group and price, credit and
liquidity risks as well as the risks connected with cash flows that the MND Group is exposed to.
16. Outlook for the upcoming period
In 2024, the MND Group has recorded an increase in natural gas production. In 2024, compared to 2023 levels, it
expects a decline in hydrocarbon production in the Czechia and a significant increase in gas production in Ukraine.
In sales of gas and electricity to end customers, MND Group expects a further increase in the number of customers.
MND Group's financial results will depend to a large extent on oil, gas, and electricity price developments in
European markets.
17. Subsequent events
Significant subsequent events are disclosed in Note 33 of the notes to the consolidated financial statements.
Prague, 16 May 2025
Ing. Miroslav Jestřabík
Ing. Jiří Ječmen
Member of the Board of Directors
Member of the Board of Directors
Member
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Group
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.
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Page 8 (total 219)
II. Report on relations between the controlling entity and the
controlled entity, and between the controlled entity and entities
controlled by the same controlling entity
The company MND a.s., with its registered office in Hodonín, Úprkova 807/6, postal code 695 01, Czech Republic,
ID No. 28483006, incorporated in the Commercial Register kept with the Regional Court in Brno, registration
no. B 6209 (hereinafter the “Company”) acted in the accounting period from 1st January, 2024 to 31st December,
2024 (hereinafter the “Accounting Period”) as a controlled entity in accordance with the provision of Section 74 et
seq. of Act No. 90/2012 Coll., on business corporations and cooperatives, as amended (hereinafter the “BCA”).
In compliance with Section 82 of the BCA, the Board of directors of the Company, as the controlled entity, has
issued for the Accounting Period this report on relations between the controlling and controlled entities, and
between the controlled entity and other entities controlled by the same controlling entity (hereinafter the “Report
on Relations” and “Related Entities"). This Report on Relations has been structured in accordance with Section 82,
par. 2 and 4 of the BCA.
1. The structure of relations between the Company and other Related Entities
The Company is a member of the KKCG Group comprised of companies directly or indirectly controlled by
KKCG Group AG, with its registered office at Kapellgasse 21, 6004 Lucerne, the Swiss Confederation, registration
number CHE-326.367.231 (hereinafter the “KKCG Group AG”).
The Company is controlled by KKCG Group AG indirectly via its parent company, MND Group AG, with its registered
office at Kapellgasse 21, 6004 Lucerne, the Swiss Confederation, registration number CHE-448.401.517.
The list of all the entities of KKCG Group that are, either directly or indirectly controlled by KKCG AG, including the
Company, constitutes Annex 1 to this Report on Relations. Data on KKCG Group companies are stated as at
31 December 2024.
2. Role of the Company
The role of the Company, as the controlled entity, is to conduct oil and gas exploration and production operations,
natural gas storage, drilling contractor services, trade in gas and electricity, energy supply to residential and small
business customers and investment in renewable energy sources and development of new technologies.
3. Methods and means of control
The control of the Company is exercised via its 100% share in voting rights at the general meeting of the Company.
4. Overview of significant acts
In the Accounting Period the Company did not perform any acts upon the initiative or in the interest of KKCG Group
AG, or of entities under KKCG Group AG control, concerning assets whose value exceeds 10% of the Company’s
equity as specified in its most recent financial statement, except for those listed below:
(in millions of Czech crowns)
2024
Costs / purchases
Purchase of services
5 132
Revenues / sales
Total sales
8 685
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5. Overview of contracts
During the Accounting Period, the Company and KKCG Group AG, or any other entities controlled by KKCG
Group AG, entered into the contracts attached as Annex 2 to this Report on Relations.
The contracts concluded between the Company and KKCG Group AG, or any other entities controlled by KKCG
Group AG, prior to the commencement of the Accounting Period were still in force during the Accounting Period
and are listed in Annex 3 to this Report on Relations.
6. Loss evaluation and settlement
The Company did not suffer any loss as a result of the contracts entered into during the Accounting Period between
the Company and other KKCG Group entities or other actions taken by the Company in the interest of or at the
instigation of such entities during the Accounting Period.
7. Advantages and disadvantages of the relations between Related Entities
The Company derives numerous benefits from its membership in the KKCG Group, with KKCG Group AG as the
controlling entity. These benefits include, in particular, the opportunity to share know-how and information (in
compliance with the laws and third-party contractual obligations), to draw on the strong reputation associated with
the KKCG brand, and to access both intragroup and external bank financing (e.g. the possibility of having its financial
obligations secured by other entities within the group).
The Company is not aware of any disadvantages arising from its relations with the Related Entities.
Annexes:
Annex 1 - List of Related Entities
Annex 2 - List of contracts between Related Entities concluded during the Accounting Period
Annex 3 - List of contracts between Related Entities concluded prior to the Accounting Period
Prague, 31 March 2025
Miroslav Jestřabík
Jiří Ječmen
Member of the Board of Directors
Member of the Board of Directors
MND a.s.
MND a.s.
Member
of
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Group
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.
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Page 10 (total 219)
Annex 1 - List of Related Entities
List of entities controlled as at 31 December 2024 by KKCG Group AG, Kapellgasse 21, 6004 Lucerne,
Swiss Confederation, reg. no. CHE-326.367.231
COMPANY
Registered office, Identification number / Registration number
"CCB" Congress Center Baden
Betriebsgesellschaft m.b.H.
"Geologichne byreau "Lviv” LLC
"Horyzonty" LLC
"Precarpathian energy company" LLC
"Tynivske" LLC
Allwyn AG
Allwyn Asia Holding a.s.
Allwyn Austria Holding 1 GmbH
(formerly SAZKA Austrian Gaming
Holding a.s.)
Allwyn Austria Holding 2 GmbH
Allwyn Austria Holding 3 GmbH
Allwyn Czech Republic Holding a.s.
Allwyn Entertainment Financing (UK)
Plc
Allwyn Entertainment Financing (US)
LLC (formerly Allwyn Services US LLC)
Allwyn Entertainment Ltd.
Allwyn Financing Czech Republic 2 a.s. v
likvidaci / in liquidation
Allwyn Greece & Cyprus Holding 2 Ltd
Allwyn Greece & Cyprus Holding Ltd
Allwyn Illinois LLC
Allwyn Information Technology Systems
Single Member S.A.
Allwyn International AG (formerly
Allwyn International a.s.)
Allwyn Investments Cyprus Ltd
Allwyn Italy Holding AG (formerly
Italian Gaming Holding a.s.)
Allwyn Lottery Solutions Limited
Allwyn North America Inc.
Allwyn Services Czech Republic a.s.
Allwyn Services UK Ltd
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COMPANY
Registered office, Identification number / Registration number
Allwyn Slovensko a.s. (formerly Allwyn
Slovakia a.s.)
Allwyn Technology Services Limited
Allwyn UK Holding B Ltd
Allwyn UK Holding C Ltd
Allwyn UK Holding Ltd
Allwyn US Holding Inc.
ALOE spol. s r. o.
Aricoma a.s.
Aricoma Capital a.s.
Aricoma Digital s.r.o.
Aricoma Enterprise Applications s.r.o.
(formerly Internet Projekt, s.r.o.)
Aricoma Enterprise Cybersecurity a.s.
Aricoma Enterprise Cybersecurity s.r.o.
Aricoma Group Finance a.s.
Aricoma Group Holding a.s.
Aricoma Shared Services s.r.o.
(formerly Aricoma Brand s.r.o.)
Aricoma Systems a.s.
(formerly AUTOCONT a.s.)
Aricoma Systems s.r.o.
(formerly AUTOCONT s.r.o.)
Aricoma Systems SRL
Avenga AG
Avenga Germany GmbH
Avenga Holding S. á r. l.
Avenga Holding s.r.o.
(formerly Avengiro s.r.o.)
Avenga International GmbH
Avenga International Holding GmbH
Avenga IT Professionals Sp. z o.o.
AVENGA LIMITED
(formerly Next Peak Limited)
Avenga Malaysia Sdn. Bhd.
Avenga Platinum Holding I GmbH
Avenga Platinum Holding II GmbH
Avenga Poland sp. z o.o.
Avenga Portugal, Lda.
Avenga s. r. o.
Avenga Services sp.z.o.o.
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COMPANY
Registered office, Identification number / Registration number
Avenga US Holding Corp.
Avenga US LLC
Azúr a.s.
Blue Rosemarine Development s.r.o.
Cachi Valle Aventuras S.A.
(in liquidation)
CAI Hungary Kft.
Camelot UK Lotteries Limited
Casino Odense K/S
Casino Sopron Kft.
Casino St. Moritz AG
Casinoland IT-Systeme GmbH
Casinos Austria (Liechtenstein) AG
Casinos Austria (Swiss) AG
Casinos Austria AG
Liegenschaftsverwaltungs und Leasing
GmbH
Casinos Austria Aktiengesellschaft
Casinos Austria International
(Mazedonien) Holding GmbH
Casinos Austria International Belgium
S.A.
Casinos Austria International GmbH
Casinos Austria International Holding
GmbH
Casinos Austria International Ltd.
Casinos Austria Management GmbH
Casinos Event Immobilien GmbH
CAST Casinos Austria
Sicherheitstechnologie GmbH
CIPHER SOLUTIONS, a.s.
Clarystone s.r.o.
Clearcode Services Sp. z o.o.
CLS Beteiligungs GmbH
Collington II Limited
Complejo Monumento Güemes S.A.
(in liquidation)
Consulting 4U s.r.o.
Coopera Development s.r.o.
Core Value Global Holding LLC
CoreEmpl Company Inc.
Cuisino Ges. m.b.H.
Deutsche Sportwetten GmbH
Member
of
KKCG
Group
www
.
mnd.eu
Page 13 (total 219)
COMPANY
Registered office, Identification number / Registration number
Entretenimientos y Jegos de Azar
(EN.J.A.S.A.) S.A. (in liquidation)
Finance-Gate Software GmbH
FM&S Czech a.s.
Fortuna 1 ApS
FVE Mušov I s.r.o.
FVE Mušov II s.r.o.
FVE Orlová I s.r.o.
FVE Orlová II s.r.o.
FVE Tichá s.r.o.
G2P Borkovany s.r.o.
GIST, s.r.o.
G-JET s.r.o.
Glücks- und Unterhaltungsspiel
Betriebsgesellschaft m.b.H.
Harriague y Asociados SRL
HELLENIC LOTTERIES S.A. (HELLENIC
LOTTERIES – SOCIÉTÉ ANONYME FOR
THE PRODUCTION, OPERATION,
CIRCULATION, PROMOTION AND
MANAGEMENT OF LOTTERIES)
HORSE RACES SINGLE MEMBER S.A.
IGNIS HOLDING a.s.
Incluit LLC
Inmobiliara Ovale S.A.
INSTANT WIN GAMING North America
Inc.
INSTANT WIN GAMING (Gibraltar)
Limited
INSTANT WIN GAMING LIMITED
IPM – Industrial Portfolio Management
a.s.
IT Service sp. z o.o.
ITK Inwestycje sp. z o.o.
JiBa Hold s.r.o.
JNR Alfa, s.r.o.
JNR Beta s.r.o.
(formerly SC Czech ACI, s.r.o.)
JNR Sigma, s.r.o
JTU Czech, s.r.o.
KBOC Director s.r.o.
KBOC Investering B.V.
KCT Data, s.r.o.
KKCG a.s.
Member
of
KKCG
Group
www
.
mnd.eu
Page 14 (total 219)
COMPANY
Registered office, Identification number / Registration number
KKCG Advisory a.s.
KKCG Development a.s.
KKCG Financing 2 a.s.
KKCG Financing a.s.
KKCG Industry B.V.
KKCG Methanol Holdings LLC
KKCG Real Estate Group a.s.
KKCG Structured Finance AG
KKCG TechLabs s.r.o.
KKCG Technologies Finance s.r.o.
KKCG Technologies s.r.o.
KKCG UK Advisory Ltd
KKCG US Advisory LLC
Krč Alfa a.s.
Krč Beta a.s.
Krč Development, s.r.o.
KrP stav. s.r.o.
Kynero Consulting a.s.
Leisure & Enterteinment S.A.
(in liquidation)
Liberty One Methanol LLC
Liberty One O&M LLC
Liberty Two Methanol LLC
LLC Avenga Ukraine
LLC ITK Services Ukraine
LLC ITK Ukraine
LTB Beteiligungs GmbH
MARTKOPI OIL COMPANY LIMITED
MEDICEM Group a.s.
Medicem Inc.
MEDICEM Technology s.r.o
Metanol d.o.o.
Mindsquared a.s.
MND a.s.
MND Austria a.s.
MND BESS GmbH
MND BESS a.s.
MND Drilling & Services a.s.
MND Drilling Germany GmbH
MND Energie a.s.
Member
of
KKCG
Group
www
.
mnd.eu
Page 15 (total 219)
COMPANY
Registered office, Identification number / Registration number
MND Energy Storage a.s.
MND Energy Storage Germany GmbH
MND Gas Storage a.s.
(formerly Moravia Gas Storage a.s.)
MND GasInvestUA s.r.o.
MND Germany GmbH
MND Group AG
MND Prodej a.s.
MND UK NORTH SEA LTD
MND Ukraine a.s.
MND Wind s.r.o.
Musala Services EOOD
Musala Soft DOOEL
Musala Soft EAD
Musala Soft Kosovo LLC
Musala Soft LLC
NANO Advanced Electrolysis s.r.o.
NANO Advanced s.r.o.
NEOFACTO Luxembourg S.A.
NetOp CLD Ltd.
Neurosoft Cyprus Ltd
Neurosoft Romania Software and
Services Srl
NEUROSOFT S.A. (NEUROSOFT SOCIÉTÉ
ANONYME SOFTWARE PRODUCTION)
Nikolajka Development s.r.o.
NOVECON a.s.
ÖLG Holding GmbH
OPAP CYPRUS LTD
OPAP ECO SINGLE MEMBER S.A.
OPAP INTERNATIONAL LTD
OPAP INVESTMENT LTD
OPAP S.A. (Organization of Football
Prognostics S.A.)
OPAP SPORTS LTD
Oriv Holding a.s.
Österreichische Klassenlotterie
Vertriebsgesellschaft m.b.H.
Österreichische Lotterien Gesellschaft
m.b.H.
Österreichische Sportwetten
Gesellschaft m.b.H.
Perfectial Holding Limited
Member
of
KKCG
Group
www
.
mnd.eu
Page 16 (total 219)
COMPANY
Registered office, Identification number / Registration number
Perfectial LLC
Perfectial Solutions Limited
Pernerova Development s.r.o.
Qinshift Espaňa S.L.
(formerly Aricoma Espaňa S.L.)
QINSHIFT a.s.
Qinshift AB (formerly Seavus AB)
Qinshift Academy DOO (formerly
Seavus Educational and Development
Center DOO)
Qinshift Academy DOOEL
QINSHIFT CAPITAL a.s.
Qinshift Czechia s.r.o. (formerly
Cleverlance Enterprise Solutions s.r.o.)
Qinshift d.o.o. Banja Luka
Qinshift DOO
Qinshift DOOEL
Qinshift Germany GmbH (formerly
Cleverlance Deutschland GmbH)
Qinshift H2B s.r.o.
(formerly Cleverlance H2B s.r.o.)
Qinshift LLC (formerly Seavus FLLC)
Qinshift S.R.L.
Qinshift Slovakia s.r.o. (formerly
Cleverlance Slovakia s.r.o.)
Qinshift Software Technologies J.S.C.
(formerly SEAVUS SOFTWARE
TECHNOLOGIES J.S.C.)
Qinshift Sweden AB (formerly Aricoma
Group International AB)
Qinshift Switzerland GmbH
(formerly Seavus GmbH)
Qinshift USA Inc.
Rabcat Computer Graphics GmbH
Relax Rezidence Cihlářka, s.r.o.
Rezervoarji d.o.o
Sabris Consulting s.r.o.
Sabris Consulting SK s.r.o.
SALEZA, a.s. (in bankruptcy, insolvency
proceedings initiated)
SAZKA a.s.
SAZKA DELTA AIF VARIABLE CAPITAL
INVESTMENT COMPANY LTD
Member
of
KKCG
Group
www
.
mnd.eu
Page 17 (total 219)
COMPANY
Registered office, Identification number / Registration number
SAZKA DELTA MANAGEMENT LTD (in
liquidation)
SAZKA FTS a.s.
SAZKA Services s.r.o.
SC Czech ACJ, s.r.o.
SC Czech ADC, s.r.o.
SC Czech ADE, s.r.o.
SC Czech ADK, s.r.o.
SDL ALFA, s.r.o.
SC Czech ADZ, s.r.o.
SC Czech AER, s.r.o.
SC Czech AGM, s.r.o.
SDL Beta, s.r.o.
(formerly SC Czech AES, s.r.o.)
SG Storage 2 s.r.o.
Spielbanken Niedersachsen GmbH
SPORTLEASE a.s.
Springtide Ventures s.r.o.
Stoiximan Limited (Office/Branch in
Cyprus)
Stoiximan Ltd
Stoiximan Ltd Greek Branch
STR Czech s.r.o.
STZ Gama s.r.o.
SUPERMARINE, s.r.o.
Sweetspot CZ s.r.o.
SYSCOM SOFTWARE spol. s r.o.
TaxLabs s.r.o.
Theta Real s.r.o.
TORA DIRECT SINGLE MEMBER S.A.
(TORA DIRECT SINGLE-MEMBER
SOCIETE ANONYME FOR THE
PROVISION OF SERVICES)
TORA WALLET SINGLE MEMBER S.A.
(TORA WALLET SINGLE-MEMBER
SOCIETE ANONYME FOR ELECTRONIC
MONEY SERVICES)
US Methanol LLC
US Methanol Midco LLC
VESTINLOG, s.r.o.
Viage Production S.A.
Vinohradská 230 a.s.
Member
of
KKCG
Group
www
.
mnd.eu
Page 18 (total 219)
Annex 2 - List of contracts between Related Entities concluded during the Accounting Period
Contracting party
Contract No.
Subject of the contract
Date of contract
Aricoma Enterprise Applications s.r.o.
NS/2024/0123
Work contract No 88-240029
07.06.2024
Aricoma Enterprise Cybersecurity a.s.
NSO/2024/0001
Agreement on the protection of confidential information and data
06.02.2024
Aricoma Enterprise Cybersecurity a.s.
MND Energy Storage a.s.
NS/2024/0017
Agreement on accession to the Contract for work - execution of the Information
Security Risk Analysis
20.12.2024
FVE Mušov II s.r.o.
NSO/2024/0012
Contract for the provision of a contribution to other capital funds
26.09.2024
FVE Orlová I s.r.o.
PS/2024/0015
Premium recharging agreement
09.02.2024
FVE Orlová II s.r.o.
PS/2024/0016
Premium recharging agreement
09.02.2024
FVE Tichá s.r.o.
PS/2024/0017
Premium recharging agreement
09.02.2024
KBOC Investering B.V.
NSO/2024/0020
Agreement on consideration for novation and assignment of the Agreement for sale
and purchase of shares
13.06.2024
KKCG a.s.
NS/2024/0252
Agreement on cooperation to prevent damage in Ukraine
02.12.2024
Kynero Consulting a.s.
RO/2240064
Printing ID cards
31.12.2024
LLC Geologichne bureau "Lviv"
PS/2024/0037
Contract for Services
01.04.2024
LLC Horyzonty
PS/2024/0038
Contract for Services
01.04.2024
LLC Precarpathian energy company
PS/2024/0036
Contract for Services
01.04.2024
MND BESS a.s.
NSO/2024/0039
Contract for the provision of a contribution to other capital funds
26.09.2024
MND BESS a.s.
PS/2024/0018
Contract for the provision of services
07.02.2024
MND BESS GmbH
NSO/2024/0018
Contract for the provision of a contribution to other capital funds
16.05.2024
MND Drilling & Services a.s.
NP/2024/0025
Exchange contract
25.06.2024
MND Drilling & Services a.s.
NS/2023/0261
Contract for work - drilling of Borkovany 8 well
15.01.2024
MND Drilling & Services a.s.
NS/2024/0011
Contract for work - workover of the Bošovice 7 well
06.02.2024
MND Drilling & Services a.s.
NS/2024/0015
Contract for work - workover of the Lubná 18 well
15.02.2024
MND Drilling & Services a.s.
NS/2024/0050
Contract for work - repair of the well-heads Uhřice 86, 87, 88, 104a, 102, 76a, 57, 61a
31.07.2024
MND Drilling & Services a.s.
NS/2024/0051
Contract for work - drilling of the Krumvíř 3 well
08.03.2024
MND Drilling & Services a.s.
NS/2024/0062
Contract for work - workover of the Uhřice 78a well
14.03.2024
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Page 19 (total 219)
Contracting party
Contract No.
Subject of the contract
Date of contract
MND Drilling & Services a.s.
NS/2024/0064
Contract for work - abandonment of a set of 11 wells
25.03.2024
MND Drilling & Services a.s.
NS/2024/0065
Contract for work - workover of the Uhřice 90a well
02.04.2025
MND Drilling & Services a.s.
NS/2024/0074
Contract for work - workover of the Uhřice 77a well
04.04.2024
MND Drilling & Services a.s.
NS/2024/0077
Contract for work - workover of the Ždánice 11 well
04.04.2024
MND Drilling & Services a.s.
NS/2024/0078
Contract for work - workover of the Ždánice 101 well
04.04.2024
MND Drilling & Services a.s.
NS/2024/0079
Contract for work - workover of the Ždánice 102 well
04.04.2024
MND Drilling & Services a.s.
NS/2024/0085
Contract for work - workover of the Uhřice 35 well
15.04.2024
MND Drilling & Services a.s.
NS/2024/0098
Contract for work - workover of the Ždánice 27 well
02.05.2024
MND Drilling & Services a.s.
NS/2024/0099
Contract for work - workover of the Ždánice 124 well
26.04.2024
MND Drilling & Services a.s.
NS/2024/0100
Contract for work - workover of the Ždánice 88 well
02.05.2024
MND Drilling & Services a.s.
NS/2024/0104
Contract for work - workover of the Uhřice 63bH well
06.05.2024
MND Drilling & Services a.s.
NS/2024/0108
Contract for work - workover of the Ždánice 92 well
13.05.2024
MND Drilling & Services a.s.
NS/2024/0112
Contract for work - workover of the Ždánice 95 well
17.05.2024
MND Drilling & Services a.s.
NS/2024/0126
Contract for work - workover of the Ždánice 28 well
07.06.2024
MND Drilling & Services a.s.
NS/2024/0131
Contract for work - workover of the Ždánice 19 well
31.05.2024
MND Drilling & Services a.s.
NS/2024/0133
Contract for work - workover of the Ždánice 13 well
20.06.2024
MND Drilling & Services a.s.
NS/2024/0141
Contract for work - workover of the Uhřice 76a well
26.06.2024
MND Drilling & Services a.s.
NS/2024/0145
Contract for work - workover of the Ždánice 190H well
28.06.2024
MND Drilling & Services a.s.
NS/2024/0146
Contract for work - workover of the Ždánice 192H well
05.07.2024
MND Drilling & Services a.s.
NS/2024/0147
Contract for work - workover of the Mutěnice 14 well
02.07.2024
MND Drilling & Services a.s.
NS/2024/0158
Contract for work - workover of the Ždánice 45 well
18.07.2024
MND Drilling & Services a.s.
NS/2024/0159
Contract for work - workover of the Ždánice 60 well
11.07.2024
MND Drilling & Services a.s.
NS/2024/0160
Contract for work - workover of the Mutěnice 8 well
29.07.2024
MND Drilling & Services a.s.
NS/2024/0161
Contract for work - workover of the Koryčany 1 well
26.07.2024
MND Drilling & Services a.s.
NS/2024/0163
Contract for work - workover of the Ždánice 29 well
23.07.2024
MND Drilling & Services a.s.
NS/2024/0165
Contract for work - workover of the Poddvorov 24 well
22.07.2024
MND Drilling & Services a.s.
NS/2024/0171
Contract for work - production test at the Krumvíř 3 well
25.07.2024
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Page 20 (total 219)
Contracting party
Contract No.
Subject of the contract
Date of contract
MND Drilling & Services a.s.
NS/2024/0173
Contract for work - workover of the Ždánice 53 well
29.07.2024
MND Drilling & Services a.s.
NS/2024/0175
Contract for work - workover of the Ždánice 48 well
05.08.2024
MND Drilling & Services a.s.
NS/2024/0176
Contract for work - workover of the Poddvorov 109 well
09.08.2024
MND Drilling & Services a.s.
NS/2024/0186
Contract for work - workover of the Ždánice 184 well
15.08.2024
MND Drilling & Services a.s.
NS/2024/0187
Contract for work - workover of well 37
04.09.2024
MND Drilling & Services a.s.
NS/2024/0190
Contract for work - workover of the Ždánice 155 well
14.06.2024
MND Drilling & Services a.s.
NS/2024/0191
Contract for work - workover of the Ždánice 119 well
08.08.2024
MND Drilling & Services a.s.
NS/2024/0192
Contract for work - workover of the Poddvorov 36 well
16.09.2024
MND Drilling & Services a.s.
NS/2024/0198
Contract for work - workover of the Klobouky 5 well
16.09.2024
MND Drilling & Services a.s.
NS/2024/0208
Contract for work - drilling of the Koryčany 21 well
01.10.2024
MND Drilling & Services a.s.
NS/2024/0225
Contract for work - drilling of the Mikulov 3 well
12.11.2024
MND Drilling & Services a.s.
NS/2024/0230
Contract for work - workover of the Hrušky 42 well
08.11.2024
MND Drilling & Services a.s.
NS/2024/0234
Contract for work - workover of the Hrušky 58 well
19.11.2024
MND Drilling & Services a.s.
NS/2024/0247
Contract for work - workover of the Bošovice 4 well
09.12.2024
MND Drilling & Services a.s.
NS/2024/0266
Contract for work - workover of the Bošovice 7 well
30.12.2024
MND Drilling & Services a.s.
PS/2024/0096
Lease agreement on business lease of movable property
17.10.2024
MND Drilling & Services a.s.
PS/2024/0104
Cost recharging agreement
11.11.2024
MND Drilling & Services a.s.
RO/2240017
Recharging of water consumption in 2024
31.12.2024
MND Drilling & Services a.s.
RO/2240018
Purchase of material from stock 2024
31.12.2024
MND Drilling & Services a.s.
RO/2240019
Defectoscopic works 2024
30.04.2024
MND Drilling & Services a.s.
RO/2240020
Participation in weighing of pipe material
31.12.2024
MND Drilling & Services a.s.
RO/2240022
Technical gases purchase 2024
31.12.2024
MND Drilling & Services a.s.
RO/2240029
Cleaning of leased premises 2024
31.12.2024
MND Drilling & Services a.s.
RO/2240075
Fuel tank rental
31.12.2024
MND Drilling & Services a.s.
RS/2240003
First aid training
05.12.2024
MND Drilling & Services a.s.
RS/2240004
Assembly and testing of the rescue trolley
03.01.2025
MND Drilling & Services a.s.
RS/2240007
Reprographic work
02.12.2024
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Page 21 (total 219)
Contracting party
Contract No.
Subject of the contract
Date of contract
MND Drilling & Services a.s.
RS/2240010
Sale of goods warehouse
11.11.2024
MND Drilling & Services a.s.
RS/2240017
Laboratory services 2024
02.12.2024
MND Drilling & Services a.s.
RS/2240021
Evaluation of the logging measurement
17.12.2024
MND Energie a.s.
NS/2024/0001
Contract for electricity supply services
02.01.2024
MND Energie a.s.
NS/2024/0203
Contract for electricity supply services
21.10.2024
MND Energie a.s.
NS/2024/0214
Contract for electricity supply services
22.10.2024
MND Energie a.s.
NS/2024/0264
Contract for electricity supply services
30.12.2024
MND Energie a.s.
PS/2024/0007
Purchase contract
25.01.2024
MND Energie a.s.
PS/2024/0035
Contract for the purchase of electricity from renewable sources
04.04.2024
MND Energie a.s.
PS/2024/0079
Purchase contract
21.08.2024
MND Energie a.s.
PS/2024/0107
Purchase contract
19.12.2024
MND Energie a.s.
PS/2024/0112
Settlement Agreement
09.12.2024
MND Energie a.s.
PSO/2024/0031
Agreement on withdrawal of shares from circulation
04.09.2024
MND Energy Storage a.s.
NS/2024/0060
Purchase contract
09.04.2024
MND Energy Storage a.s.
OP/2024/0036
Gas storage contract for reservation of monthly storage capacity with fixed capacity
07.10.2024
MND Energy Storage a.s.
PS/2024/0020
Contract for the lease of a vehicle
10.02.2024
MND Energy Storage a.s.
PS/2024/0027
Framework contract for the provision of services
26.06.2024
MND Energy Storage a.s.
PS/2024/0045
Framework agreement for the provision of services in the field of "Human resources"
01.02.2024
MND Energy Storage a.s.
PS/2024/0078
Contract for the acquisition and use of Aveva Historian FLEX software
31.07.2024
MND Energy Storage a.s.
RS/2240027
Professional and promotional activities
09.01.2025
MND G2P s.r.o.
NS/2024/0205
Lease agreement
04.11.2024
MND G2P s.r.o.
NS/2024/0249
Electricity supply and cost recharging contract
30.10.2024
MND G2P s.r.o.
NSO/2024/0038
Contract for the provision of a contribution to other capital funds
26.09.2024
MND G2P s.r.o.
PS/2024/0033
Connection and Operating Agreement between gas market participants
15.03.2024
MND G2P s.r.o.
PS/2024/0059
Contract for the establishment of an easement
16.05.2024
MND G2P s.r.o.
PS/2024/0106
Premium recharging agreement - liability
29.11.2024
MND Gas Storage a.s.
OP/2024/0039
Gas storage contract for reservation of annual storage capacity with fixed capacity
18.11.2024
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Page 22 (total 219)
Contracting party
Contract No.
Subject of the contract
Date of contract
MND Gas Storage a.s.
OP/2024/0040
Gas storage contract for reservation of annual storage capacity with fixed capacity
18.11.2024
MND Gas Storage a.s.
PS/2024/0028
Framework contract for the provision of services
26.06.2024
MND Gas Storage a.s.
PS/2024/0044
Framework agreement for the provision of services in the field of "Human resources"
01.02.2024
MND Gas Storage a.s.
PS/2024/0077
Purchase contract Sale of the well Uhřice 48
23.07.2024
MND Gas Storage a.s.
PS/2024/0083
Purchase contract Sale of the well Uhřice 89
09.09.2024
MND Group AG
NSO/2024/0030
Share Purchase Agreement
01.07.2024
NANO Advanced s.r.o.
NSO/2024/0025
Contract for the provision of contributions
03.06.2024
Oriv Holding a.s.
NSO/2024/0026
Contract for the provision of a contribution to other capital funds
18.06.2024
Oriv Holding a.s.
NSO/2024/0041
Contract for the provision of a contribution to other capital funds
05.11.2024
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Page 23 (total 219)
Annex 3 - List of contracts between Related Entities concluded prior to the Accounting Period
Contracting party
Contract No.
Subject of the contract
Date of contract
Aricoma Digital s.r.o.
NS/2023/0196
Technical maintenance and development contract
14.09.2023
Aricoma Enterprise Applications s.r.o.
724.42-735/03
Navision Service
18.12.2003
Aricoma Enterprise Applications s.r.o.
724.42-736/03
Navision licence
18.12.2003
Aricoma Enterprise Applications s.r.o.
NS/2022/0188
Work contract No. PAS-220048
22.12.2022
Aricoma Systems a.s.
NS/2015/0141
Subcontract for the provision of services
28.08.2015
Aricoma Systems a.s.
NS/2016/0045
Contract for the provision of services
03.05.2016
Aricoma Systems a.s.
NS/2016/0094
Subcontract for the provision of services
29.07.2024
Aricoma Systems a.s.
NS/2017/0008
Subcontract for the provision of services
06.02.2017
Aricoma Systems a.s.
NS/2019/0242
Contract for the provision of services
13.12.2019
Aricoma Systems a.s.
NS/2021/0111
Contract for the provision of services
26.10.2021
Aricoma Systems a.s.
NS/2023/0030
Framework Licensing Agreement
24.02.2023
Aricoma Systems a.s.
OP/2022/0039
Agreement for the provision of datacentre, cloud and other services
27.12.2022
FM&S Czech a.s.
NS/2021/0052
Contract for the provision of fitness services
12.05.2021
FM&S Czech a.s.
NS/2021/0053
Contract for the provision of services - factory catering
12.05.2021
FM&S Czech a.s.
NS/2021/0054
Rental and service contract
12.05.2021
FM&S Czech a.s.
NS/2021/0151
Contract for the provision of property management and maintenance services
01.07.2021
FVE Mušov I s.r.o.
PS/2023/0042
Contract for the provision of services
19.05.2023
FVE Mušov II s.r.o.
PS/2023/0043
Contract for the provision of services
19.05.2023
FVE Orlová I s.r.o.
PS/2023/0067
Contract for the provision of services
16.10.2023
FVE Orlová II s.r.o.
PS/2023/0068
Contract for the provision of services
16.10.2023
FVE Tichá s.r.o.
PS/2023/0066
Contract for the provision of services
16.10.2023
KKCG a.s.
NS/2016/0079
Contract for the provision of services
30.05.2016
KKCG a.s.
PS/2022/0023
Sublease agreement Bořislavka centre
01.05.2022
KKCG AG
NS/2016/0107
Trademark Licensing Agreement
23.08.2016
KKCG Services a.s.
NS/2020/0070
ICT Service Contract
08.06.2020
Kynero Consulting a.s.
RO/2230051
Card ID
28.01.2022
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Page 24 (total 219)
Contracting party
Contract No.
Subject of the contract
Date of contract
Horyzonty LLC
PS/2023/0028
Contract for Services
01.04.2023
Horyzonty LLC
PS/2024/0021
Contract for Information Technology Services
31.12.2023
MND Austria a.s.
PS/2023/0048
Contract for the provision of services
09.06.2023
MND Drilling & Services a.s.
724.42-007/01
Economic and payroll services
12.02.2024
MND Drilling & Services a.s.
724.42-146/01
Contract for work
19.01.2001
MND Drilling & Services a.s.
NS/2005/0266
Contract for work
01.09.2005
MND Drilling & Services a.s.
NS/2006/0209
Agreement on the joint use of the canteen and technological equipment
31.07.2006
MND Drilling & Services a.s.
NS/2011/0012
Framework contract for the execution of small-scale perforation works
21.01.2011
MND Drilling & Services a.s.
NS/2012/0108
Framework contract for the provision of services - repairs, preventive inspections,
maintenance, emergency service
01.05.2012
MND Drilling & Services a.s.
NS/2012/0168
Lease agreement for non-residential premises and land
01.05.2012
MND Drilling & Services a.s.
NS/2013/0346
Framework contract for the supply of diesel fuel
31.10.2013
MND Drilling & Services a.s.
NS/2014/0462
Framework contract for the supply of machine parts
31.12.2014
MND Drilling & Services a.s.
NS/2015/0038
Contract for re-invoicing of costs - water and sewerage charges Lužice
30.01.2015
MND Drilling & Services a.s.
NS/2016/0130
Framework contract for the provision of services - transport and crane services
18.10.2016
MND Drilling & Services a.s.
NS/2017/0039
Contract for storage and storage-related activities
29.03.2017
MND Drilling & Services a.s.
NS/2018/0257
Framework Contract - cleaning, renovation and storage of footrests and rods
31.12.2018
MND Drilling & Services a.s.
NS/2019/0001
Framework contract Well research
16.01.2019
MND Drilling & Services a.s.
NS/2019/0119
Contract for the provision of steam generator services
31.12.2020
MND Drilling & Services a.s.
NS/2020/0090
Framework contract for the provision of services - cementing and pressure units work
27.07.2020
MND Drilling & Services a.s.
NS/2020/0128
Framework contract for the provision of environmental services
02.12.2020
MND Drilling & Services a.s.
NS/2022/0105
MWCD lease agreement
31.03.2022
MND Drilling & Services a.s.
NS/2022/0135
Lease agreement Object S Lužice
31.08.2022
MND Drilling & Services a.s.
NS/2022/0202
Contract for work - abandonment of a set of 25 wells
07.12.2022
MND Drilling & Services a.s.
NS/2022/0221
Lease agreement
15.09.2022
MND Drilling & Services a.s.
NS/2023/0053
Contract for the re-invoicing of gas supply costs
01.01.2023
MND Drilling & Services a.s.
NS/2023/0238
Contract for work - abandonment of the Krumvíř 1Ra well
01.11.2023
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Contracting party
Contract No.
Subject of the contract
Date of contract
MND Drilling & Services a.s.
NS/2023/0264
Contract for work - workover of the Ladná 7 well
29.12.2023
MND Drilling & Services a.s.
NS/2023/0269
Contract for work - workover of the Žižkov 20 well
29.12.2023
MND Drilling & Services a.s.
PS/2004/0003
Contract for cost re-invoicing - electricity Lužice
10.02.2004
MND Drilling & Services a.s.
PS/2007/0062
Contract for the provision of well control services
20.12.2007
MND Drilling & Services a.s.
PS/2012/0012
Framework contract for the provision of services - repairs, preventive inspections,
maintenance, emergency service
01.05.2012
MND Drilling & Services a.s.
PS/2013/0043
Lease agreement
30.07.2013
MND Drilling & Services a.s.
PS/2014/0003
Agreement on the use of mine water use and reimbursement of costs
02.01.2014
MND Drilling & Services a.s.
PS/2014/0028
Framework contract for services - dismantling and assembly of drilling rigs
23.07.2014
MND Drilling & Services a.s.
PS/2014/0039
Lease agreement for the lease of business premises and the provision of services
related to the lease
03.11.2014
MND Drilling & Services a.s.
PS/2015/0082
Insurance premium rebilling agreement
26.11.2015
MND Drilling & Services a.s.
PS/2020/0058
Agreement on rebilling of operating and maintenance costs for the HV 64 line
02.11.2020
MND Drilling & Services a.s.
PS/2020/0059
Framework agreement for the provision of HR services
30.10.2020
MND Drilling & Services a.s.
PS/2022/0004
Contract for the provision of well control services
03.02.2022
MND Drilling & Services a.s.
PS/2023/0016
Contract for the lease of a vehicle
02.01.2023
MND Drilling & Services a.s.
MND Energy Storage a.s.
PSO/2022/0002
Agreement on the reimbursement of the costs of the release of a member of a trade
union body
01.02.2022
MND Energie a.s.
NS/2021/0124
Contract for the provision of services
27.10.2021
MND Energie a.s.
NS/2021/0125
Contract for the provision of services
27.10.2021
MND Energie a.s.
NS/2022/0213
Contract for electricity supply services
09.12.2022
MND Energie a.s.
NS/2022/0219
Contract for electricity supply services
22.12.2022
MND Energie a.s.
NS/2022/0220
Contract for associated services for the supply of natural gas
22.12.2022
MND Energie a.s.
NS/2023/0013
Contract for gas supply services
19.08.2022
MND Energie a.s.
NS/2023/0014
Contract for gas supply services
19.08.2022
MND Energie a.s.
NS/2023/0077
Contract for electricity supply services
14.04.2023
MND Energie a.s.
OE/2021/0013
EFET electricity
01.11.2021
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Contracting party
Contract No.
Subject of the contract
Date of contract
MND Energie a.s.
OP/2021/0079
EFET gas
01.11.2021
MND Energie a.s.
PS/2021/0062
Contract for the provision of services
04.04.2025
MND Energie a.s.
PS/2021/0063
Lease agreement
04.04.2025
MND Energie a.s.
PS/2021/0064
Sublease agreement Bořislavka centre
27.10.2021
MND Energie a.s.
PS/2021/0065
Contract for the provision of services
27.10.2021
MND Energie a.s.
PS/2021/0066
Contract for the provision of services
27.10.2021
MND Energie a.s.
PS/2021/0075
Sublease agreement Bořislavka centre
27.10.2021
MND Energie a.s.
PS/2021/0077
Contract for the provision of services
30.11.2021
MND Energie a.s.
PS/2021/0080
Contract for the lease of movable property
31.12.2021
MND Energie a.s.
PS/2021/0081
Sublease and service contract
01.11.2021
MND Energie a.s.
PS/2023/0004
Insurance premium recharging agreement
16.01.2023
MND Energy Storage a.s.
NS/2012/0120
Contract for gas supply to the Dambořice field
30.04.2012
MND Energy Storage a.s.
NS/2015/0248
Purchase contract - low temperature condensate
28.12.2015
MND Energy Storage a.s.
OP/2019/0035
Contract for the provision of commercial dispatching services
02.01.2019
MND Energy Storage a.s.
OP/2022/0009
Gas storage contract for reservation of monthly storage capacity and gas loan
28.02.2022
MND Energy Storage a.s.
OP/2023/0023
Gas storage contract for reservation of monthly storage capacity and gas loan
14.04.2023
MND Energy Storage a.s.
OP/2023/0040
Gas storage contract for reservation of annual storage capacity with fixed capacity
24.07.2023
MND Energy Storage a.s.
PS/2008/0101
Drill Core Storage Contract
28.02.2008
MND Energy Storage a.s.
PS/2008/0113
Lease agreement for the lease of non-residential premises
30.05.2008
MND Energy Storage a.s.
PS/2009/0012
Contract for the provision of electronic communications services
30.01.2009
MND Energy Storage a.s.
PS/2009/0019
Contract for the provision of well control services
30.04.2009
MND Energy Storage a.s.
PS/2009/0025
Contract for the maintenance of mining measurement documentation
30.04.2009
MND Energy Storage a.s.
PS/2010/0057
Contract for the provision of economic and other services
30.07.2010
MND Energy Storage a.s.
PS/2015/0006
Insurance premium recharging agreement
02.01.2015
MND Energy Storage a.s.
PS/2016/0002
Contract for the provision of maintenance services for technical equipment
13.01.2016
MND Energy Storage a.s.
PS/2016/0021
Contract for the provision of reservoir engineering and geology services
30.04.2016
MND Energy Storage a.s.
PS/2022/0005
Contract for well control services and reimbursement of the costs of the MWCD
30.12.2021
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Contracting party
Contract No.
Subject of the contract
Date of contract
MND Energy Storage a.s.
PS/2023/0005
Framework contract for the provision of services
02.01.2023
MND Energy Storage a.s.
PS/2023/0006
Framework contract for the provision of services
02.01.2023
MND Energy Storage a.s.
PS/2023/0007
Framework contract for the provision of services
02.01.2023
MND Energy Storage a.s.
PS/2023/0012
Framework contract for the provision of services
02.01.2023
MND Energy Storage Germany GmbH
PS/2015/0067
Contract for Services
30.09.2015
MND G2P s.r.o.
PS/2023/0040
Contract for the provision of services
19.05.2023
MND Gas Storage a.s.
NP/2012/0003
Land Use Agreement
02.01.2012
MND Gas Storage a.s.
NS/2016/0012
Purchase contract
09.02.2016
MND Gas Storage a.s.
NS/2023/0127
Lease agreement
15.06.2023
MND Gas Storage a.s.
PS/2011/0039
Contract for the maintenance of mining measurement documentation
01.08.2011
MND Gas Storage a.s.
PS/2011/0040
Contract for well control services and reimbursement of the costs of the MWCD
01.08.2011
MND Gas Storage a.s.
PS/2011/0076
Contract for the provision of services
01.08.2011
MND Gas Storage a.s.
PS/2016/0003
Framework agreement for the provision of technical equipment and reservoir
engineering services
13.01.2016
MND Gas Storage a.s.
PS/2021/0048
Agreement to allow off-take and reimbursement of costs for electricity
21.09.2021
MND Gas Storage a.s.
PS/2022/0006
Contract for well control services and reimbursement of the costs of the MWCD
30.12.2021
MND Gas Storage a.s.
PS/2023/0020
Framework contract for the provision of services
13.06.2023
MND Gas Storage a.s.
PS/2023/0023
Framework contract for the supply of goods
05.04.2023
MND Gas Storage a.s.
PS/2023/0024
Framework contract for the provision of services
05.04.2023
MND GasInvestUA s.r.o.
PS/2023/0044
Contract for the provision of services
19.05.2023
MND Prodej a.s.
PS/2020/0062
Contract for the provision of services
30.10.2020
MND Prodej a.s.
PS/2023/0003
Insurance premium recharging agreement
09.02.2023
MND Ukraine a.s.
PS/2020/0064
Contract for the provision of services
05.11.2020
MND Wind s.r.o.
PS/2023/0039
Contract for the provision of services
19.05.2023
Oriv Holding a.s.
PS/2021/0061
Contract for the provision of services
01.11.2021
SAZKA a.s.
NSO/2014/0123
Agreement on the regulation of relationship within the VAT group
29.10.2014
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III. Consolidated Sustainability Statement
1 ESRS 2 - General information
1.1 Basis for preparation
[BP-1] General basis for the preparation of the Consolidated Sustainability Statement
This Consolidated Sustainability Statement (hereinafter the "Statement") of MND a.s. (hereinafter "MND") has
been prepared in accordance with Act No. 563/1991 Coll., on Accounting, as amended (hereinafter the "Act on
Accounting"), which transposes the Accounting Directive (2013/34/EU)
1
as amended by the Corporate
Sustainability Reporting Directive (2022/2464)
2
, including the European Sustainability Reporting Standards
3
(hereinafter the "ESRS" or "Standards"). The Statement also contains disclosures pursuant to Article 8 of Regulation
(EU) 2020/852
4
of the European Parliament and of the Council and the Commission Delegated Regulation
(hereinafter "EU Taxonomy").
The Statement was prepared for the period from 1 January 2024 to 31 December 2024, in the same scope as the
consolidated financial statements, and includes MND, the parent company, and the companies with which MND
forms a consolidated group
5
(the "Group").
The Statement covers the Group's own operations, upstream (suppliers) and downstream (customers) parts of the
value chain, including companies that were under joint control or affiliated (within the meaning of section 22(3)(b)
and (c) of the Act on Accounting) in relation to MND, where relevant, depending on the identified impacts, risks
and opportunities. The information and data disclosed about specific impacts, risks and opportunities may be
limited to the specific Group companies, groups of employees, activities and products, based on the results of the
double materiality assessment.
The Group has not exercised the option to omit specific disclosures relating to intellectual property, know-how or
the results of innovation, nor has it applied exemptions for disclosure of information on impending developments
or matters in the course of negotiations.
Selected financial information presented in the Statement is derived from the Group's consolidated financial
statements, which are prepared in accordance with IFRS standards. Monetary amounts are expressed in Czech
crowns. Other figures are presented in the units specified in the relevant section of the Statement. Rounding of
these figures may cause minor discrepancies.
In accordance with ESRS 1, the Group does not disclose comparative information in respect of year 2023. Where
permitted by ESRS, the Group has applied the phase-in requirements and transitional provisions and therefore the
Statement does not include information that is not required for this reporting period.
1
Directive 2013/34/EU of the European Parliament and of the Council of 26 June 2013 on the annual accounts, consolidated accounts and
related reports of certain types of undertakings, amending Directive 2006/43/EC of the European Parliament and of the Council and repealing
Directives 78/660/EEC and 83/349/EEC
2
Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022 amending Regulation (EU) No 537/2014,
Directive 2004/109/EC, Directive 2006/43/EC and Directive 2013/34/EU as regards corporate sustainability reporting.
3
Commission Delegated Regulation (EU) 2023/2772 supplementing Directive 2013/34/EU of the European Parliament and of the Council as
regards sustainability reporting standards.
4
Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 establishing a framework to facilitate sustainable
investments and amending Regulation (EU) 2019/2088
5
For detailed information on the consolidating entity, see Part I. Business Report, point 2.
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List of phased-in disclosure requirements
ESRS
Disclosure
requirement
Full name of the disclosure
request
Phased-in or effective date (including first year)
ESRS 2
SBM-3
Material impacts, risks and
opportunities and their
interaction with strategy
and business model.
The undertaking may omit the information prescribed by ESRS 2
SBM-3 paragraph 48(e) (anticipated financial effects) for the first
year of preparation of its sustainability statement. The undertaking
may comply with ESRS 2 SBM-3 paragraph 48(e) by reporting only
qualitative disclosures for the first 3 years of preparation of its
sustainability statement, if it is impracticable to prepare
quantitative disclosures.
ESRS E1
E1-9
Anticipated financial effects
from material physical and
transition risks and
potential climate-related
opportunities
The undertaking may omit the information prescribed by ESRS E1-9
for the first year of preparation of its sustainability statement. The
undertaking may comply with ESRS E1-9 by reporting only
qualitative disclosures for the first 3 years of preparation of its
sustainability statement, if it is impracticable to prepare
quantitative disclosures.
ESRS E2
E2-6
Anticipated financial effects
from pollution-related risks
and opportunities
The undertaking may omit the information prescribed by ESRS E2-6
for the first year of preparation of its sustainability statement.
Except for the information prescribed by paragraph 40 (b) on the
operating and capital expenditures occurred in the reporting period
in conjunction with major incidents and deposits, the undertaking
may comply with ESRS E2-6 by reporting only qualitative
disclosures, for the first 3 years of preparation of its sustainability
statement.
ESRS E3
E3-5
Anticipated financial effects
from water and marine
resources-related risks and
opportunities
The undertaking may omit the information prescribed by ESRS E3-5
for the first year of preparation of its sustainability statement.
The undertaking may comply with ESRS E3-5 by reporting only
qualitative disclosures, for the first 3 years of preparation of its
sustainability statement.
ESES E5
E5-6
Anticipated financial effects
from resource use and
circular economy-related
risks and opportunities
The undertaking may omit the information prescribed by ESRS E5-6
for the first year of preparation of its sustainability statement.
The undertaking may comply with ESRS E5-6 by reporting only
qualitative disclosures, for the first 3 years of preparation of its
sustainability statement.
ESRS S1
S1-7
Characteristics of non-
employee workers in the
undertaking’s own
workforce
The undertaking may omit reporting for all datapoints in this
Disclosure Requirement for the first year of preparation of its
sustainability statement.
ESRS S1
S1-8
Collective bargaining
coverage and social
dialogue
The undertaking may omit this Disclosure Requirement with regard
to its own employees in non-EEA countries for the first year of
preparation of its sustainability statement.
ESRS S1
S1-11
Social protection
The undertaking may omit the information prescribed by ESRS S1-
11 for the first year of preparation of its sustainability statement.
ESRS S1
S1-12
Percentage of employees
with disabilities
The undertaking may omit the information prescribed by ESRS S1-
12 for the first year of preparation of its sustainability statement.
ESRS S1
S1-13
Training and skills
development
The undertaking may omit the information prescribed by ESRS S1-
13 for the first year of preparation of its sustainability statement.
ESRS S1
S1-14
Health and safety
The undertaking may omit the data points on cases of work-related
ill-health and on number of days lost to injuries, accidents, fatalities
and work-related ill health for the first year of preparation of its
sustainability statement.
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Page 30 (total 219)
ESRS
Disclosure
requirement
Full name of the disclosure
request
Phased-in or effective date (including first year)
ESRS S1
S1-14
Health and safety
The undertaking may omit reporting on non-employees for the first
year of preparation of its sustainability statement.
ESRS S1
S1-15
Work-life balance
The undertaking may omit the information prescribed by ESRS S1-
15 for the first year of preparation of its sustainability statement.
1.1.1 [BP-2] Disclosures in relation to specific circumstances
Time horizons
The time horizons for the purposes of this Statement are as follows:
• short-term horizon: up to 1 calendar year (corresponding to the accounting period);
• medium-term horizon: 1 to 5 years;
• long-term horizon: more than 5 years.
The Group has not deviated from the medium- or long-term time horizons as defined under the ESRS in the
Statement.
Value chain estimation and sources of estimation and outcome uncertainty
Where permitted by the ESRS, the Group has applied the phased-in requirements and transitional provisions and
therefore the Statement does not include disclosures that are not required for this reporting period.
The Statement does not include any indicators covering upstream and downstream value chain data estimated
using indirect sources such as sectoral averages or other proxies, except for greenhouse gas emissions.
For the presentation of quantitative metrics, estimates and assumptions have been used in cases where direct
measurable data were not available and thus these may be subject to a higher degree of measurement uncertainty.
The table below provides an overview of the metrics that are subject to a certain degree of measurement
uncertainty. The Group will make every effort in future reporting periods to establish reliable methods for obtaining
such information.
Description of the
metric
Source of uncertainty
Approximations and judgements
GHG emissions
Inaccurate measurement
technique, poor quality data,
missing data
Using emission factors, natural gas is considered to be a mixture
consisting of 100% methane, extrapolation of operational data for
which data exist (see section Environmental information, article
2.2.7[E1-6] Gross Scope 1, 2, 3 and total GHG emissions).
Energy consumption-
related metrics
Insufficient data granularity
for Horyzonty LLC and
Precarpathian energy
company LLC, Geologichne
Bureau "Lviv" LLC
The Group has data on the total value of electricity consumption for
Horyzonty LLC, Precarpathian energy company LLC, Geologichne
Bureau "Lviv" LLC.
The data source used to estimate the energy mix was Ukraine:
Energy Country Profile - Our World in Data
Recycled and reused
water
The volume is calculated for
drilling purposes (exact
measurements are not
available)
The resulting value is calculated as the difference between the
projected and actual water consumption.
A degree of uncertainty may also apply to statements about the future that are based on current expectations and
assumptions. Actual results could subsequently differ significantly due to a number of factors, including
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unpredictable market developments, regulatory or technological changes, operational risks or geopolitical events
and natural disasters. Given these uncertainties, the projections presented should be interpreted with caution.
Changes in the preparation or presentation of sustainability information and reporting errors in prior
periods
In 2023, the Group disclosed information according to the EU Taxonomy, which was neither part of the
sustainability statement nor subject to verification by the auditor. This information in respect of year 2023 has been
restated in this Statement – see section Environmental information, article 2.1 EU Taxonomy for the 2024 reporting
period
Disclosures stemming from other legislations
No additional disclosures were identified.
1.2 Governance
1.2.1 [GOV-1, GOV-2, GOV-3] The role of administrative, management and supervisory bodies
The structure of MND is hierarchical with clearly defined roles and responsibilities across the different levels and
within the respective bodies. The roles and responsibilities of each body are regulated by the Articles of Association
of MND.
The statutory body of MND is the Board of Directors, which is responsible for the business management of MND.
The supervisory body of MND is the Supervisory Board. Membership in the Supervisory Board is incompatible with
the membership in the Board of Directors. Further information on the position and competence of the Board of
Directors of MND and the Supervisory Board of MND is regulated by the Articles of Association of MND and Act No.
90/2012 Coll., on Commercial Companies and Cooperatives, as amended.
As of 31 December 2024, the Board of Directors of MND was composed of 3 men, and the Supervisory Board of
MND was also composed of 3 men, i.e. 100% male representation (0% female). The members of the Supervisory
Board of MND are independent of the members of the Board of Directors of MND (100% share of independent
board members). All members of the Board of Directors of MND have the status of executive member and all
members of the Supervisory Board of MND have the status of non-executive member. MND employees are not
directly represented on the administrative, management and supervisory bodies of MND.
Composition of the Board of Directors of MND
as of 31 December 2024
Experience relevant to the industry, products and geographic
locations of the undertaking (including sustainability) and the
Group's culture
Chairman of the Board of
Directors
Karel Komarek
Founder of KKCG Group
30 years of experience in the Oil & Gas industry
Member of the Board of
Directors
Ing. Jiří Ječmen
Long-standing member of the Group's statutory and
supervisory bodies
Member of the Board of
Directors
Ing. Miroslav Jestřabík
Long-standing member of the Group's statutory and
supervisory bodies
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Composition of the MND Supervisory Board as of 31
December 2024
Experience relevant to the industry, products and geographic
locations of the undertaking (including sustainability) and the
Group's culture
Chairman of the
Supervisory Board
Ing. Robert Kolář
Long-standing member of the supervisory boards of Group
companies
Member of the
Supervisory Board
Ing. Pavel Šaroch
Long-standing Investment Director at KKCG Group
Member of the
Supervisory Board
JUDr. Josef Novotný
Attorney-at-law, long-standing member of the supervisory
boards of Group companies
Responsibility for overseeing the impacts, risks and opportunities identified within this Statement, similar to the
Group's overall strategy, is the responsibility of the Board of Directors of MND and the statutory bodies of individual
companies within the Group. This includes areas related to corporate governance, including the approval and
oversight of compliance with the Code of Ethics of MND Group and the Compliance System (for more information,
see Governance information, article 4.1.1 [G1-1] Business conduct policies and corporate culture).
As part of the approval of the Group's double materiality assessment, the Board of Directors was informed of all
identified material impacts, risks and opportunities. The process of formalising the impacts, risks and opportunities
according to ESRS was only been undertaken for 2024 and the Board of Directors approved the identified material
impacts, risks and opportunities for this reporting period as set out in article 1.3.4 [IRO-1] Description of the
processes to identify and assess material impacts, risks and opportunities. In addition to overseeing the
identification of material impact risks and opportunities in the context of compliance with reporting requirements,
the Board of Directors also oversees the implementation of the management of material impacts, risks and
opportunities where these impact the Group’s strategy or relate to risk and compliance matters, including
processes associated with the decision-making on significant transactions. This role is not delegated to a specific
management level position or committee.
The Group does not currently have specific targets for material impacts, risks and opportunities, including those
related to climate change. If such targets are set in the future, a process will be formalised for the Board of Directors
to monitor progress towards achieving them, including alignment with the Group's business conduct and culture.
The Group has also not yet implemented a system of incentives or remuneration policies related to sustainability
matters for members of the administrative, management or supervisory bodies.
To ensure effective management of impacts, risks and opportunities in the interim period before specific roles and
responsibilities are formalised, the preliminary structures and processes have been established. These already
oversee the sustainability agenda although they are still in the process of development and validation to ensure
proper functionality. An ESG Committee has been established to provide recommendations, advice and information
(at least quarterly) to the designated member of the Board of Directors - Ing. Jiří Ječmen. The ESG Committee (as a
sui generis establishment) operates at a management level and provides a platform for planning and monitoring
initiatives related to significant impacts, risks and opportunities in the Group. The Group ESG Coordinator leads the
Group ESG Team, which acts in an advisory, consultative and informative capacity to the ESG Committee and the
management of each Group company. He collaborates with selected personnel of the Group companies, the so-
called ESG Points of Contact, on the management of activities at an operational level. If a specific part of the risk
and opportunity impact management does not require a separate project or programme oversight, the relevant
decisions are made within the existing management and decision-making bodies. This reflects the fact that where
possible, impact, risk and opportunity management is integrated into existing business processes rather than being
treated as a separate topic. The Group does not apply specialised controls and procedures in managing impacts,
risks and opportunities.
Composition of the ESG Committee:
Group ESG Coordinator
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Director of Energy Division of MND a.s.
Chairman of the Board of Directors of MND Drilling & Services a.s.
Director of Trading Division of MND a.s.
Member of the Boards of Directors of MND Energy Storage a.s. and MND Gas Storage a.s.
Executive Director of MND Energie a.s.
HR Director of Energy Division of MND a.s.
The Group is working to finalize and formalize these structures and processes to reflect the results of the analysis
of material topics and lessons and experiences from their operation.
The Group has also established a CSR Sub-Committee which serves as an advisory body to the ESG Committee. Its
main function is to coordinate the Group's voluntary donor activities aimed at incorporating social and
environmental considerations into corporate operations and community projects in the regions where the Group
operates.
In preparation for ESRS reporting obligations, including ensuring access to expertise and skills, the Board of
Directors approved the engagement of external consultants, and support for training of employees responsible for
the sustainability agenda.
Persons responsible for managing sustainability-related impacts, risks and opportunities were appointed to their
roles based on their expertise and understanding of the subject matter. The Group ESG Coordinator and the Group
ESG team receive ongoing training and update their knowledge through specialised training sessions, seminars and
conferences.
ESG Committee
Experience relevant to the industry, products and geographic locations
(including sustainability) of the undertaking
Group ESG Coordinator
Josef Novotný
Accredited degree in atmospheric sciences, sustainability and ESG
courses of PwC Academy, 3 years of experience in ESG and Oil & Gas.
Director of Energy Division
of MND a.s.
Jana Hamršmídová
30 years of experience in executive positions in companies operating in
hydrocarbon exploration and production, underground gas storage,
renewable energy construction and operation, electricity generation
from gas, and carbon capture and storage (CCS) projects
.
Chairman of the Board of
MND Drilling & Services a.s.
René Kachyňa
17 years of experience in executive positions in companies engaged in
deep drilling, including drilling of geothermal wells.
Director of Trading Division
of MND a.s.
Martin Pich
20 years of experience in executive positions in companies involved in
international trade with energy commodities, 25 years of experience in
the industry.
Member of the Boards of
Directors of MND Energy
Storage a.s. and MND Gas
Storage a.s.
Pavel Marek
28 years of experience in executive positions in companies involved in
hydrocarbon exploration and production in the Czech Republic, Ukraine,
Yemen, Georgia, Germany and Morocco, and underground gas storage
companies.
Executive Director of MND
Energie a.s.
Milan Duba
7 years of experience in executive positions in companies selling energy
to end customers, focusing on strategy, business development and
improving customer satisfaction.
HR Director of Energy
Division of MND a.s.
Petra Kulčárová
25 years of experience in human resource management, accredited
degree in social security.
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1.2.2 [GOV-4] Statement on due diligence
Some elements of due diligence are already embedded in the Group's principles and activities.
The Group upholds its commitment to respecting human rights, sustainable business practices, and socially
responsible conduct throughout its operations. The Group is working to ensure that these commitments are
reflected across its value chain.
The Group is also currently preparing for the transposition of Directive (EU) 2024/1760 of the European Parliament
and of the Council on corporate sustainability due diligence into the Czech law.
The individual elements of the due diligence process are described in the sub-sections of this Statement, and their
location is indicated in the following table.
Basic elements of due diligence
Location in the Statement
Embedding due diligence in governance, strategy
and business model
ESRS 2 - General information - Article 1.2.1 [GOV-1, GOV-2, GOV-3] The
role of administrative, management and supervisory bodies
Involving affected stakeholders in all key steps of
the due diligence process
ESRS 2 - General information – Article 1.3.3 [SBM-2] Interests and views
of stakeholders
Identifying and assessing adverse impacts
ESRS 2 - General information - Article 1.4 [IRO-1] Description of the
processes to identify and assess material impacts, risks and opportunities
Social information:
Article 3.1.3 [S1-2] Processes for engaging with own workforce and
workers’ representatives about impacts
Article 3.2.3 [S4-2] - Processes for engaging with consumers and end-
users about impacts
Taking actions to address those adverse impacts
Environmental information
Article 2.2.4 [E1-3] Actions and resources in relation to climate change
policies
Article 2.3.2 [E2-2] Actions and resources related to pollution ,
Article 2.4.2 [E3-2] Actions and resources related to water resources
Article 2.5.2 [E5-2] Actions and resources related to resource use and
circular economy
Social information:
Article 3.1.5 [S1-4] Taking action on material impacts on own workforce,
and approaches to managing material risks and pursuing material
opportunities related to own workforce, and effectiveness of those
actions,
Article 3.2.5 [S4-4] - Taking action on material impacts on consumers and
end-users, and approaches to managing material risks and pursuing
material opportunities related to consumers and end-users, and
effectiveness of those actions
Governance information - Article 4.1.1 [G1-1] Business conduct policies
and corporate culture
Tracking the effectiveness of these efforts and
communicating about them
Environmental information:
Article 2.2.6 [E1-5] Energy consumption and mix,
Article 2.2.7 [E1-6] Gross Scope 1, 2, 3 and total GHG emissions,
Article 2.3.4 [E2-5] Substances of concern and substances of very high
concern,
Article 2.4.4 [E3-4] Water consumption,
Article 2.5.3 [E5-4] Inflow of resources,
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Basic elements of due diligence
Location in the Statement
Article 2.5.5 [E5-5] Resource outflows,
Social information:
Article 3.1.7 [S1-6] Characteristics of the undertaking’s employees,
Article 3.1.8 [S1-8] Collective bargaining coverage and social dialogue,
Article 3.1.9 [S1-9] Diversity ,
Article 3.1.10 [S1-14] Health and safety ,
Article 3.2.6 [S4-5] - Targets related to managing material negative
impacts, advancing positive impacts, and managing material risks and
opportunities
1.2.3 [GOV-5] Risk management and internal controls over sustainability reporting
As year 2024 is the Group's first year of reporting under the ESRS, the control environment is still emerging and is
thus less mature than for financial reporting. The Group is therefore introducing enhanced internal controls and
external auditor assurance over the preparation of the Statement, including integration into the Group's annual
reporting process, which is already well established, and includes internal approvals, checks and external assurance.
The Group ESG team is responsible for monitoring and assessing the risks in the process of preparing the Statement
for the year 2024 and reporting significant findings to the ESG Committee. The Group ESG Team is informed of the
resolutions or outcomes of the ESG committee meetings through the Group ESG Coordinator. The ESG committee
reports at least quarterly to the designated member of the Board of Directors - Ing. Jiří Ječmen. The Group's ESG
team has applied its internal risk assessment methodology, taking into account the likelihood and impact of risks,
and has identified that the main risks associated with the Statement relate to the accuracy and completeness of
the data, particularly with regards to data collection. The prioritisation of risks was based on the potential impact
on the quality of the information, reputation and the financial impact on the Group. The risks identified for 2024
primarily relate to data reported for the value chain as the Group has no operational control over this, for
operations in Ukraine due to the ongoing war conflict, and the manual process of data collection and consolidation.
Where estimates are used by the Group, these are based on widely used third party data such as DEFRA (UK
Department for Environment, Food & Rural Affairs) to determine emission factors under the GHG Protocol or in the
case of metrics, the best estimates of personnel responsible for data collection. The risk of deliberate
misrepresentation of the reported information was assessed as low as the Group does not link the financial
evaluation or remuneration of employees or board members to sustainability indicators.
The Audit Committee of MND a.s. also monitors the assurance process of the Statement in accordance with the
legal regulations.
The Group is in the process of preparing the implementation of software that will allow greater control over the
data collection and reporting process, which will involve the integration of the control mechanisms for the
preparation of the Statement.
1.3 Strategy
1.3.1 [SBM-1] Business model
As part of its sustainable and responsible approach, the Group applies the principles of protecting the environment,
protecting the health of its employees and protecting the rights of its customers, but the Group has not yet adopted
a specific strategy or set specific targets in the area of sustainability.
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As of 31 December 2024, the Group employed a total of 1 156 employees, of which 1 079 were in the Czech Republic
and 77 in Ukraine.
The Group's principal activities are:
• energy supply to households and small businesses:
As of 31 December 2024, the Group supplied natural gas to more than 119 000 and electricity to more than
150 000 supply points in the Czech Republic.
• trading with energy commodities:
The Group operated as electricity and natural gas licensed trader, including trading over gas storage
facilities and storage capacity, in the European Union markets, mainly in the Czech Republic, Germany, the
Netherlands, Austria and Hungary. Since 2023, the Group has traded on the financial markets with emission
allowances and crude oil.
• operation of underground gas storage facilities and provision of gas storage services:
The Group is the operator of underground gas storage facility Uhřice (PZP Uhřice). PZP Uhřice consists of
two storage structures. The total actual storage capacity of PZP Uhřice is 335 million m
3
, with the potential
for further development up to 350 million m
3
.
The Group is also the operator of the underground gas storage facility Dambořice (PZP Dambořice). The
Dambořice gas storage facility was commissioned on 1 July 2016 and has a total storage capacity of 448
million m
3
as of 31 December 2024.
In addition to storing natural gas, both underground storage facilities are also suitable for storing electricity
via gaseous hydrogen and are ready to receive energy in the form of hydrogen up to 5% H
2
concentrations
mixed with natural gas at the entry point of MS Brumovice from 1 January 2022.
• exploration and production of crude oil and natural gas:
The Group holds licences for five exploration areas with a total area of 1 784 km
2
in the Czech Republic, in
the South-East Moravia region and holds (through subsidiaries) nine exploration and production licenses
with a total area of 400 km
2
in Ukraine.
The Group produces oil and/or natural gas from 36 fields in the South-East Moravia region. Oil production
in 2024 amounted to approximately 75 thousand m
3
and natural gas production to approximately 79 million
m
3
. Subsidiaries in Ukraine produced approximately 67 million m
3
of natural gas.
• provision of services in the field of drilling of exploration and production wells for oil and gas and hydro and
geothermal wells, underground repairs and abandonment of wells:
In 2024, the Group carried out drilling or subsurface repairs, abandonment and re-abandonment of wells
for internal and external customers' needs within the European Union countries.
investing in renewable energy and in the development of new technologies:
The Group is engaged in the construction and operation of renewable energy sources, specifically
photovoltaic and wind power plants, in the Czech Republic and Ukraine. The installed capacity is currently
10.8 MWp in the Czech Republic and 59 MW in Ukraine.
The Group is also currently in the phase of pre-project preparation and preparation of documentation for
the subsidy for the Carbon capture and storage ("CCS") project, with an investment requirement of
approximately CZK 4.6 billion, with an estimated implementation period of 7-8 years. Implementation of
the project plan would enable the storage of approximately 800 thousand tonnes of CO
2
e per year.
In 2024, the Group worked on project preparation for the construction of a large-scale battery storage
facility ("BESS") in the Czech Republic, with completion scheduled for late 2025/early 2026. Pre-project
preparation for projects of the same nature and larger scale was also underway in Germany, with the first
project currently scheduled for completion in 2026.
In the Czech Republic, the Group operates one Gas-to-Power ("G2P") grid support services resource,
consisting of six gas-fired engine-generators enabling the generation of electricity from natural gas. The
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current installed capacity is 3 MW. Another similar project is under construction with completion scheduled
for mid-2025.
In year 2024, the Group generated CZK 22 537 million in revenue from fossil fuels, as defined in Article 2, point 62
of Regulation (EU) 2018/1999 of the European Parliament and of the Council, and did not generate any revenue
from economic activities in accordance with the taxonomy related to fossil gas as required by the EU Taxonomy.
No products or services offered by the Group are prohibited in the markets in which the Group operates.
Number of employees by geographic locations
Country
Number of employees
Czech Republic
1 079
Ukraine
77
The breakdown of total revenues under IFRS 8 Operating Segments ((i) Exploration and Production, (ii) Gas and
Electricity Trading, Storage, (iii) Drilling services, (iv) Other Unclassified Activities) is disclosed in note 4 of the
consolidated financial statements.
1.3.2 [SBM-1] Value chain
The Group is an oil and gas enterprise. The Group focuses on the efficient operation of its extraction facilities and
technologies. The material resources and services used by the Group are essential for maintaining and upgrading
its operations.
The upstream part of the value chain comprises the supply of energy required for its own operations, the supply of
technology and components for its own operations, the purchase of water and materials to support mining and
related activities, and the purchase of electricity and natural gas for supplies to end customers. In addition, the
upstream part of the value chain also includes IT, economic, administrative and other services (in particular,
transportation services for produced oil/natural gas, rental of the distribution network and distribution services for
natural gas and electricity to end customers, as well as technical, operational, recycling and environmental
services). The Group actively assesses the risks associated with its supply chain and monitors key suppliers
6
, to
minimise any potential impact on its business. Ensuring sufficient diversification is a key strategy in this process.
The Group's own activities include oil and natural gas exploration and production, drilling services, as well as storage
and transportation to processing plants. The Group also trades energy domestically and internationally as a licensed
electricity and natural gas trader, trading involving natural gas storage and capacity. In the area of renewable energy
investments and climate change mitigation, the Group is involved in the construction and operation of photovoltaic
and wind power plants, the analysis of technologies to store CO
2
in rock structures and hydrogen infrastructure.
The Group emphasises the safety and health of its employees and promotes fair pay and equal treatment.
In the downstream part of the value chain, the Group focuses on the sale of oil and natural gas and the supply of
natural gas and electricity to end customers through distribution networks (mainly households, for whom the Group
saturates their energy needs). The Group also provides drilling contractor services and natural gas storage services.
1.3.3 [SBM-2] Interests and views of stakeholders
The stakeholders form an important part of the Group's business. They include individuals, groups and institutions
that have direct or indirect relationship with and interest in the Group's business activities. Engaging with
6
A key supplier is defined as a supplier that the Group (i) cannot replace or (ii) can only replace at an unreasonable cost or (iii) whose
elimination would have a significant impact on the Group's business model.
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stakeholders and understanding their views and expectations is not only key to the Group's ability to deliver its
business strategy, grow its business and create long-term value, but also to identify impacts, risks or opportunities.
The table below presents the key stakeholder groups. Internal departments, such as HR regularly communicate
with stakeholder groups such as their own employees through various channels, gaining valuable insights on topics
of importance to them and related to employment issues.
Key stakeholders
Form of engagement
Purpose of engagement
(topics)
Consideration of stakeholder engagement
outcomes
Employees
Questionnaire surveys
on selected topics
among selected groups
of employees - 1-2 times
a year
Intranet - daily
MND report magazine -
4 times a year
Improving corporate culture -
succession and substitutability
Evaluation of employee
satisfaction and employee
motivation - management
development, remuneration
(including benefits)
Internal communication -
communication across the
organization
Improvement of internal and inter-
departmental communication – continuation
of exit meetings, maintaining open
communication channels across all
companies.
Introduction of management skills training,
feedback required towards employees.
Initiation of steps towards greater
optimisation and efficiency of incentive
systems.
Business
partners
(suppliers of
materials,
resources and
services and
customers)
Cooperation / contract
negotiation - ongoing,
informal communication
KYC questionnaires -
when establishing
cooperation
Screening of suppliers in the
area of corporate culture -
topics of governance,
corruption, sanctions, etc.
Long-term business
relationships - individual
initiatives of business partners
towards the Group
Initiation of steps for the consistent
implementation of the Code of Ethics of
MND Group / Compliance System (e.g.
thorough screening against sanctions lists).
Continued use of specialised software aimed
at screening business partners.
Planned supplier questionnaires not only at
the start of cooperation, but also on an
ongoing basis.
7
Individual suggestions considered by the
persons responsible.
Consumers /
End-users
Questionnaire surveys
(during contracting,
customer portal,
website) - on an ongoing
basis
Satisfaction survey after
phone call - ongoing
Communication clarity -
customer satisfaction with the
contracting process
Measure the touch points that
most impact customer
satisfaction (changes, service
requests, contract
anniversaries, calls)
Identifying the potential for
new products/services/
predicting churn
Increasing the clarity and intelligibility of
communication
Continue to collect feedback (including on
changes made).
Improving customer processes and
improving the quality of service based on
customer feedback.
7
relevant for MND a.s. - Trading Division.
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Key stakeholders
Form of engagement
Purpose of engagement
(topics)
Consideration of stakeholder engagement
outcomes
Trade Unions
Negotiations with trade
unions - regular
quarterly meetings and
information sharing,
once a year negotiation
of amendments to the
collective agreement,
once a year addressing
safety issues within ISO
45001
Adjustment of the
remuneration system
Ensuring safe working
conditions
Employee training
The results of negotiations with unions are
reflected in written amendments to
collective agreements.
Implementing preventive measures to
reduce accidents and improve workplace
safety.
Local actors
(municipalities,
landowners)
Involvement before and
during project
permitting (e.g.
exploratory drilling) - as
required
Authorisation of the plan
Resolution of property rights to
the land concerned
In 2024, no material topics emerged from
the interactions.
Banks and
investors
KYC questionnaires - 1x
per year
Meetings - as required
Information on corporate
culture, carbon footprint and
financial reporting
Implementation of corporate culture
measures and training
Preparation of an internal Carbon Report for
the purpose of completing the banks'
questionnaires.
The Group has leveraged insights from its existing stakeholder dialogue set up as part of its due diligence in
assessing material impacts of risks and opportunities (see article 1.4 [IRO-1] Description of the processes to identify
and assess material impacts, risks and opportunities.
The Group does not currently expect to change its strategy or business model based on the results of stakeholder
engagement. Next steps include greater formalisation of the stakeholder engagement process over the next few
years, but this step is unlikely to significantly affect stakeholder relations.
The Board of Directors is informed of the views and interests of the stakeholders concerned within the framework
of the internal process set up by the persons responsible for the relevant agenda, e.g. the results of negotiations
with the trade unions as employee representatives regarding wage increases, especially in cases where specific
measures would be necessary.
Employees
Employees are one of the most important stakeholders within the Group. The Group makes efforts to ensure that
their views and comments are heard and respected in the context of the Group's day-to-day operations, including
decision-making processes, adjustments and changes to business strategy. These efforts include consulting and
gathering feedback from employees, which is then used to develop policies and procedures. The Group focuses on
maintaining long-term, stable and strong relationships with employees based on trust, recognition of commitments
and legitimate interests and open communication. The Group also emphasises compliance with applicable laws and
regulations as part of its strategy to ensure respect for the human rights of its employees.
The Group believes that open and constructive dialogue is the key to lasting and stable employee relations. Regular
and effective communication with them is the ground of the Group's approach to transparency, accountability and
building trust. Employees are a key part of the Group's business and their involvement in consultation processes is
therefore essential.
The Group acts responsibly and is committed to building relationships based on ethics, integrity and respect for
human rights. It provides truthful, complete and relevant information in all forms of communication and
encourages employee involvement in consultation processes.
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Consumers and end-users
Consumers and end-users, which the Group defines as its customers, play a key role in its activities, especially in
MND Energie a.s., which, as an electricity and gas trader, is the only company within the Group that handles the
personal data of its customers (hereinafter the "customer data").
The customers of MND Energie a.s. (hereinafter the "customers") are consumers (households) and entrepreneurs,
i.e. natural persons engaged in the business and legal entities with gas consumption up to 630 MWh/year and
customers connected at the low voltage level of electricity (retail customers). The consumers make up the majority
of MND Energie a.s.'s customer portfolio.
The interests, views and rights of consumers and end-users are an integral part of the Group's business strategy
and are taken into account in its development, changes or adjustments, as the Group can achieve its economic
objectives by making efforts to contribute to their satisfaction.
1.3.4 [SBM-3] Material impacts, risks and opportunities and their interaction with strategy and
business model
Based on the double materiality assessment, material topics (at the granularity of sub-topics and sub-sub-topics),
that originate from material impacts, risks and opportunities, were identified. An overview of the material topics is
provided in the table below.
The Group already managed majority of material impacts, risks and opportunities based on its capabilities and
priorities prior to the double materiality assessment. As part of the double materiality assessment, the Group
performed a qualitative analysis of the resilience of its current business strategy.
Based on the inputs used to analyse natural and social resource dependence, resilience to climate risks (see more
detail in 1.4 [IRO-1] Description of the processes to identify and assess material impacts, risks and opportunities
below and the section Environmental information, article 2.2.1 [SBM-3] Material impacts, risks and opportunities
and their interaction with strategy and business model), the current geopolitical situation and already ongoing
actions, the Group has concluded that it is able to address material impacts, risks and opportunities in the short
and medium term through current strategic and operational initiatives and it has not identified the need to develop
specific processes to manage them. As the Group assessed some of these areas for the first time in 2024, both in
terms of financial impact and dependency, the Group recognises that it will need to obtain more information and
strengthen this analysis related to material impacts, risks and opportunities by improving the methodology,
including medium- and long-term time horizons.
With respect to year 2024, the Group has not identified any actual financial impact of material risks and
opportunities on its financial position, financial performance and cash flows, nor has it identified any material risks
and opportunities where there would be a material risk of material adjustment to the accounting values of assets
and liabilities to be reported in the relevant financial statements in the next reporting period.
The Group does not currently anticipate any changes to its business strategy or business model (including its value
chain), but will monitor, for example, the regulatory environment and adjust its plans.
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Topical
standard
Topic and sub-topic
Actual and
potential
impacts, risks
and
opportunities
Description of activities or business
relationships leading to impact, risk or
opportunity
Consequences for the business model,
value chain, strategy and decision-
making, including the Group's
response
Value chain
Time horizon
Upstream
Own operation
Downstream
Short-term
Medium-term
Long-term
E1
Climate change
mitigation
Actual negative
impact
The production of greenhouse gas emissions
associated with oil and gas exploration and
production, including unexploited reserves,
contributes to climate change with negative
impact on the environment and people.
The Group is investing in emission
reduction measures using available
technologies within the current
business model.
X
X
X
X
X
E1
Climate change
mitigation
Actual negative
impact
The production of greenhouse gas emissions
associated with the purchase of goods and
services, including energy commodities,
contributes to climate change with negative
impact on the environment and people.
The Group monitors the current market
situation and its needs within its
current business model.
X
X
X
X
E1
Climate change
mitigation
Potential positive
impact
Reducing greenhouse gas emissions through
carbon capture and storage (CCS) projects
and the development of battery energy
systems (BESS) contributes to climate
stability, with a positive impact on the
environment and people.
The Group monitors the current market
situation and develops projects that
can have a positive impact on the
environment.
X
X
X
X
X
E1
Climate change
mitigation
Opportunity
Reducing greenhouse gas emissions through
carbon capture and storage (CCS) projects
and the development of battery energy
systems (BESS).
The Group monitors current
developments, including grant
opportunities, and pursues the
opportunity as a potential additional
source of income for the Group.
X
X
X
E1
Climate change
mitigation
Opportunity
Reducing greenhouse gas emissions through
projects focused on electricity production
from renewable energy sources.
The Group generates income within its
current business model and
continuously evaluates opportunities
for further future investments.
X
X
X
X
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Topical
standard
Topic and sub-topic
Actual and
potential
impacts, risks
and
opportunities
Description of activities or business
relationships leading to impact, risk or
opportunity
Consequences for the business model,
value chain, strategy and decision-
making, including the Group's
response
Value chain
Time horizon
Upstream
Own operation
Downstream
Short-term
Medium-term
Long-term
E1
Climate change
mitigation
Actual positive
impact /
Opportunity
(transition to
renewables)
Reducing greenhouse gas emissions through
projects focused on the generation of
electricity from renewable energy sources
contributes to climate stability, with
positive impacts on the environment and
people.
The Group generates income within its
current business model and expects to
do so in the future.
X
X
X
X
E1
Climate change
mitigation
Risk
The risks associated with the transition to a
low-carbon economy, including a possible
shift away from fossil fuels, additional
taxation and other regulatory measures, can
lead to revenue losses or additional costs.
The Group monitors the current market
situation and develops projects that
may be an opportunity to compensate
for revenue shortfalls.
X
X
E1
Climate change
mitigation
Actual negative
impact
The production of greenhouse gas emissions
associated with the sale and consumption of
oil, gas and electricity (purchased on the
market) to customers contributes to climate
change with negative impact on the
environment and people.
The Group monitors the current
situation within the current business
model.
X
X
X
X
E1
Energy
Actual negative
impact
The production of greenhouse gas emissions
associated with the consumption of energy
for their own operation contributes to
climate change with negative impact on the
environment and people.
The Group is investing in emission
reduction measures using available
technologies within the current
business model.
X
X
X
X
E2
Substances of (very
high) concern
Potential
negative impact
If substances of (very high) concern are
handled incorrectly, environmental
pollution and damage to health might
occur.
The Group invests in substance
management measures using available
technologies within the current
business model.
X
X
X
X
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Topical
standard
Topic and sub-topic
Actual and
potential
impacts, risks
and
opportunities
Description of activities or business
relationships leading to impact, risk or
opportunity
Consequences for the business model,
value chain, strategy and decision-
making, including the Group's
response
Value chain
Time horizon
Upstream
Own operation
Downstream
Short-term
Medium-term
Long-term
E3
Water - Water
withdrawal
Potential
negative impact
The withdrawal (purchase) of water for
mining and exploration activities that may
be carried out in areas of water risk and
thus affect the hydrological conditions in
those areas.
The Group minimises water
consumption, including reusing it in the
process using available technologies
within the current business model.
X
X
X
X
E3
Water - Water
consumption
Actual negative
impact
Water consumption during mining and
exploration activities can affect hydrological
conditions and society.
The Group minimises water
consumption, including water reuse in
the process, using available
technologies within the current
business model.
X
X
X
X
X
E5
Resource inflows,
including resource use
Actual negative
impact / Risk
(resource
dependency)
Oil and gas extraction, and the associated
depletion of non-renewable resources.
The Group is investing in the
identification and exploration of new
oil and gas discoveries, as well as
opportunities to diversify revenue
streams, for example from, within its
current business model.
X
X
X
X
E5
Waste
Actual negative
impact
Drilling and mining operations produce
wastes (sludge, reagents, etc.) that, if not
handled properly, can contribute to
environmental pollution.
The Group minimises waste production
using available technologies and
complies with the prescribed waste
management obligations within current
business model.
X
X
X
X
S1
Working conditions -
Working hours
Potential
negative impact
Continuous operation in mining and
exploration activities can lead to excessive
workload for employees.
The Group minimises the impact on
employees by monitoring attendance
and financial or non-financial
compensation in accordance with legal
requirements
X
X
X
X
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Topical
standard
Topic and sub-topic
Actual and
potential
impacts, risks
and
opportunities
Description of activities or business
relationships leading to impact, risk or
opportunity
Consequences for the business model,
value chain, strategy and decision-
making, including the Group's
response
Value chain
Time horizon
Upstream
Own operation
Downstream
Short-term
Medium-term
Long-term
S1
Working conditions -
Work-life balance
Actual negative
impact
The continuous operation in extraction and
exploration activities, especially in remote
locations, leads to employee isolation and
disruption of work-life balance.
The Group minimises the impact on
employees by monitoring attendance
and compensating them with rotations,
compensatory time off and allowances
within set processes
X
X
X
X
S1
Working conditions -
Collective bargaining
coverage and social
dialogue
Actual positive
impact
Active dialogue with employees and
functioning labour unions contribute to
improving working conditions, including
remuneration and transparency.
The Group promotes social dialogue
with employees and their
representatives, including labour
unions, within the framework of set
processes.
X
X
X
X
S1
Working conditions -
Work-life balance
Actual positive
impact
Benefits above and beyond those required
by law or negotiated by the labour union
contribute to the quality of life and
employee satisfaction.
The approach to employees, including
the provision of benefits, is part of the
Group's strategic management and is
subject to continuous, ongoing
updating in response to current needs
and trends
X
X
X
X
S1
Working conditions -
Health and safety
Actual negative
impact
Health impacts in hazardous work positions,
e.g. mining and exploration.
The Group minimises the impact on
employees by applying OHS and PPE
policies within set processes.
X
X
X
X
S1
Equal treatment and
opportunities for all -
Gender equality
Actual negative
impact
Gender imbalance in favour of men in top
management, and in specific technical
positions.
The gender disparity is not based on
the Group's strategy or decisions and is
mainly due to the nature of the
business.
X
X
X
X
S1
Equal treatment and
opportunities for all -
Potential
negative impact
Unequal remuneration of men and women
in the same position performing equivalent
work could lead to gender inequality.
The Group minimises the impact on
employees by monitoring salaries and
X
X
X
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Topical
standard
Topic and sub-topic
Actual and
potential
impacts, risks
and
opportunities
Description of activities or business
relationships leading to impact, risk or
opportunity
Consequences for the business model,
value chain, strategy and decision-
making, including the Group's
response
Value chain
Time horizon
Upstream
Own operation
Downstream
Short-term
Medium-term
Long-term
Equal pay for equal
work
remuneration, including preparing for
the legislation on pay transparency.
S4
Information-related
impacts on consumers
and/or end-users -
Privacy
Potential
negative impact
Violation of consumer privacy through
improper handling or processing of user
data or leakage of sensitive data.
The Group minimises the impact on
customers through established data
protection and cybersecurity systems.
X
X
X
X
X
G1
Corporate culture
Potential
negative impact
Insufficient implementation and compliance
with the Group's policies, including the
Code of Ethics, can have a negative impact
on the corporate culture and indirectly on
society.
The Group minimises the likelihood of
impacts by emphasising compliance
with legislation, internal policies and
employee training.
X
X
X
X
X
X
G1
Whistleblower
protection
Potential
negative impact
Potential violations of whistleblower
protection may lead to violations of rights
and damage trust in whistleblowing
channels.
The Group minimises the likelihood of
impacts by emphasising compliance
with legislation, internal policies and
employee training.
X
X
X
X
X
X
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1.4 [IRO-1] Description of the processes to identify and assess material impacts, risks
and opportunities
The Group carried out a double materiality assessment, which includes the identification of material impacts, risks
and opportunities, considering materiality from both an impact and financial perspective.
Identifying, assessing and managing impacts, risks and opportunities requires a complex set of input parameters.
The Group uses data from internal sources such as performance metrics and employee and customer surveys, and
external sources such as sector statistics or regulatory requirements. The scope of the materiality assessment
covers all major activities and geographic regions in which the Group operates, as well as significant parts of the
value chain.
Phase I: Understanding the business model and value chain
The first step to identify and assess material impacts, risks and opportunities was to map and understand the
Group's business model and value chain. Resources and relationships across the main activities were mapped to
provide a clearly defined scope for the double materiality assessment.
The mapping process included information on upstream and downstream value chains obtained from the
description of the business model and from the discussions with internal stakeholders at the levels of MND and its
subsidiaries.
Phase II: Identification of impacts, risks and opportunities
In the second phase, the impacts, risks and opportunities were identified within the defined topics, sub-topics and
sub-sub-topics according to ESRS 1 Appendix A/AR 16. GRI 11: Oil and Gas Sector 2021, SASB for Oil and Gas,
Sustainability reporting guidance 2023 from IPIEC and the draft Oil and Gas Sector ESRS, publicly available databases
such as ENCORE and benchmarking with companies in similar industry that already report sustainability
information. The identification process also included insights from existing due diligence systems such as supplier
screenings, surveys and feedback from internal and external stakeholders such as employees or documentation for
reporting to regulatory bodies, mainly in the environmental sector. This information was evaluated through
interviews with internal experts within the Group and external consultants.
The Group focused on its key activities and business relationships that could lead to an increased risk of negative
impacts. These areas mainly include oil and gas exploration and production, management of relationships with
suppliers who are significant contributors to revenue, customer relationship management and the Group
governance. In doing so, the Group has considered the impacts that it contributes to through its own activities or
as a result of its business relationships. This process led to the compilation of a long list of impacts, risks and
opportunities and subsequent validation of its completeness.
Stakeholders involved in the process of identifying impacts, risks and opportunities primarily included experts in
specific areas such as HR, procurement, legal, environmental protection who have a comprehensive understanding
and overview of the Group's activities and business model. In addition, suggestions from other stakeholders were
considered in identifying impacts, risks and opportunities. The topics and stakeholder engagement are further
described in ESRS 2 - General information, article 1.3.3 [SBM-2] Interests and views of stakeholders.
Phase III: Assessment of impacts, risks and opportunities
The assessment of impacts, risks and opportunities was carried out through the engagement of the above key
internal stakeholders in workshops and subsequently it was validated.
Identified actual and potential, positive or negative impacts were rated on a scale from 1 to 5 in terms of their scale,
scope and irremediable character to determine their relative severity and likelihood. The assessment was based on
available quantitative in-house and third-party data, qualitative input from meetings with internal and external
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stakeholders. Where relevant, local specific aspects (territorial and legislative) were also taken into account. The
information collected in the previous phases was used during the assessment process. The evaluation also included
a silent stakeholder, namely the nature, through the results of third-party research. Impacts with a rating "2.5 -
Important" or higher were considered material and were identified and described as material to the Group.
The financial risks and opportunities are based not only on the identified actual and potential impacts, but also on
the climate risk analysis. The assessment includes the potential impact of future events on assets, performance and
value creation, as well as data on the impact of past events. The past events are analysed using available financial
data, while estimates of future events are based on best practices and available information, including information
from financial institutions. The combination of the magnitude of the financial effect and the probability of its
occurrence defines financial materiality. Risks or opportunities with a rating "2.5 - Significant" or higher have been
considered material and have been identified and described as having a material impact on the Group.
As part of the process of identifying, assessing and managing sustainability impacts and risks, the Group has built
on its existing established internal system for managing traditional risks, including monitoring regulatory,
commercial and financial risks associated with environmental, social and governance issues. A similar approach is
taken to the process of identifying, assessing and managing opportunities, which is integrated into the overall
management process.
The Group will continue to monitor risks as part of the existing operational and financial risk monitoring process
and as part the double materiality process.
Phase IV: Final validation and approval at higher levels
The consolidated summary of material impacts, risks and opportunities was reviewed and validated by the Group
ESG team, the ESG Committee and finally presented to the MND Board of Directors for final approval. Following
the validation of the 2024 double materiality assessment results, the Group ESG Team concluded that the set
threshold of 2.5 was sufficient to capture all significant impacts, risks and opportunities.
The assessment of double materiality according to ESRS requirements was first carried out for year 2024 and will
be reviewed every 5 years. An earlier review will only occur if there is a change in the Group's business model or a
significant acquisition.
In preparing the first ESRS-required disclosures, the Group assessed the requirements for individual data points
with respect the identified IROs and mapping.
The approach described above was applied cross-sectionally, i.e. regardless of the topical standard. A possible topic-
specific approach to identifying and assessing impact, risks and opportunities is presented below:
E1 (Climate change)
The carbon footprint was calculated by internal experts within the Group according to the GHG Protocol
methodology covering Scopes 1, 2, 3. At the time of the double materiality assessment, the final version of the
calculation for year 2024 was not available, therefore the calculation for year 2023 was used. Due to the nature of
the Group's business, the majority of emissions (86%) are associated with Scope 3, specifically the use of the sold
product. Potential climate change impacts with respect to changes in the Company's business strategy have not yet
been assessed. The Group has also reviewed its activities and plans to identify actual and potential future sources
of GHG emissions. This process included (1) an analysis of operational activities identifying emissions from the
extraction, processing and transportation of oil and gas; (2) an assessment of future projects and their potential
GHG emissions; and (3) identification of other climate-related impacts. In addition, the actual and potential climate
change impacts of the identified emission sources were assessed. The calculation of total GHG emissions includes:
(1) quantification of emissions from operational activities and planned projects; (2) an assessment of how identified
emissions contribute to climate change and potential long-term impacts; (3) an assessment of GHG emissions along
the entire value chain, including suppliers and customers.
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A climate risk analysis was conducted and included physical (chronic, acute) and transition-related risks and
opportunities. The analysis involved the collection, processing and evaluation of data from these databases and
was undertaken for two scenarios of possible climate developments: RCP4.5-SSP245 and RCP8.5-SSP585, which are
based on the latest IPCC AR6 report to comprehensive compliance with the required climate and socio-economic
attributes. Specifically, IPCC RCP4.5-SSP245 describes a medium scenario with no strong climate policies and
regulations in place. RCP8.5-SSP585 represents the worst-case scenario and is the most used for climate risk
analysis. These scenarios were chosen because of their high probability of occurrence (the optimistic scenario
RCP2.6 is most likely to be exceeded). The analysis was carried out in the short-term time horizon for the analysis
of the current situation, in the medium-term horizon until 2030 and in the long-term horizon until 2050.
Furthermore, this analysis was carried out in alignment with the European Union's long-term plan for 2050, known
as Net Zero 2050, which is part of the Green Deal for Europe. This plan is legally anchored in Regulation (EU)
2021/1119 on achieving climate neutrality, which means achieving net zero emissions by 2050. The Group does not
currently have GHG emission reduction targets.
In assessing the impacts, risks and opportunities, the business model, all assets and technologies owned, as well as
the Group's entire value chain were considered. Considered assets included drilling technology, infrastructure,
storage tanks, compressor stations, pressure caps and office buildings. The analysis considered the expected
technical and functional obsolescence of all assets, strategic planning horizons and (future) capital allocation plans
over all defined time horizons.
The climate risk analysis included assets aggregated to the required ESRS geolocation granularity, specifically at
NUTS 3 level, into five aggregated groups - CR: South Moravian Region, Moravian-Silesian Region, UA: Lviv Region,
Ivano-Frankivsk Region, Poltava Region, covering all assets owned by the Group. As part of the transition risk
analysis, not only the assets owned by the Group but also the assets related to the main infrastructure in connection
with the value chain (supply and demand) were examined. At the same time, the context relating to regulatory,
legislative, social developments and changes in the business were taken into account. During the analysis, there
were limits to data availability for selected chronic and acute physical risks. These sites and assets are shown in
Figure 1.
Figure 1- Locations and assets included in the Group's climate risk analysis
The following physical risks were assessed as part of the analysis:
• Chronic: changing temperature, heat stress, temperature variability, changing wind conditions, changing
precipitation patterns and types, precipitation or hydrological variability, soil erosion, solifluction.
• Acute: heat wave, cold wave/freeze, forest fire, storm, tornado, heavy rainfall, flood, river spill.
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Due to the nature of the risks, type of assets, location or nature of the Group's business, the following risks were
assessed as not relevant:
• Chronic: melting permafrost, ocean acidification, salinization, coastal erosion, land degradation,
• Acute: cyclone, glacial lake outburst, avalanche, landslide, landslide.
The analysis of physical climate risks is based on external publicly available climate sources that assess the
significance of these risks. The tools and sources used include Climate Analytics - Climate Impact Explorer,
Copernicus, Aqueduct - Water Risk Atlas, the study "Projections of soil loss by water erosion in Europe by 2050"
from ScienceDirect and the study "Land use and climate change impacts on global soil erosion by water (2015-
2070)" from the PNAS (Proceedings of the National Academy of Sciences) database. Based on these tools and
sources, physical climate risk thresholds and areas affected by each risk were identified.
The results of the physical climate risk analysis are broken down into individual climate scenarios, time horizons
and locations. In both scenarios examined, for all locations in which the Group is acting as a risk (1) changing
temperature; (2) heat stress; (3) temperature variability; (4) precipitation or hydrological variability. For the RSP 8.5
scenario and 2050 horizon, (5) tornadoes also came out as a risk. For some locations, (6) changing precipitation
patterns; (7) soil erosion; (8) storm; (9) drought; and (10) flood also came out at risk. These risks could potentially
adversely affect the Group's business. The identified physical risks included in the assessment of double materiality
are shown in the table below.
Temperature-related
Wind-related
Water-related
Solid mass-related
Chronic
Changing temperature
(air, freshwater, marine
water)
Changing wind patterns
Changing precipitation
conditions and types
(rain, hail, snow/ice) -
JMK, MSK
Coastal erosion
Heat stress
Precipitation or
hydrological variability
Soil degradation
Temperature variability
Ocean acidification
Soil erosion - JMK
Permafrost thawing
Saline intrusion
Solifluction
Sea level rise
Water stress
Acute
Heat wave
Cyclones, hurricanes,
typhoons
Drought - PO
Avalanche
Cold wave, frost
Storms (including
blizzards, dust and
sandstorms) - JMK, MSK,
LO, IFO
Heavy precipitation (rain,
hail, snow/ice)
Landslide
Wildfire
Tornado
Flood (coastal, fluvial,
pluvial, ground water)
Subsidence
Glacial lake outburst
LEGEND
AREAS
Relevant for all areas
JMK
South Moravian Region
Refers to the area covering part of the assets
MSK
Moravian-Silesian Region
It does not apply in any horizon
LVO
Lviv region
IFO
Ivano-Frankivsk region
PO
Poltava region
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Based on the identification of physical climate-related risks, the following chronic and acute climate-related risks
were evaluated in the double materiality assessment: changing temperature, heat stress, temperature variability,
changing precipitation patterns and types, precipitation or hydrologic variability, soil erosion, storm, tornado,
drought. None of the topics were found significant.
The analysis of the risks and opportunities associated with the transition considered factors of the changing energy
sector. The key factor in this case is the regulatory changes that are very relevant to the Group. Given the ongoing
transformation of the energy sector and the compelled changes in consumer behaviour, legislative adjustments are
necessary in response to the ongoing climate change, which has led to tightening of environmental regulations.
This subsequently requires the Group to invest in technologies or other measures to meet the requirements, which
impacts the Group's financial performance. In the case of carbon pricing, the impacts on the Group are beyond its
control and may result in a potential profit losses due to decreased demand for its products.
To mitigate this existing risks for the Group, the Group is ready to adapt to new legislative changes and diversify its
portfolio with low-emission fuels such as hydrogen or biogas. In the event of a transition to hydrogen fuels, the
Group has decided to adapt its infrastructure to allow the blending of hydrogen into natural gas. For existing
operations in the oil and gas extraction segment, it is essential to increase the efficiency of the extraction process
to remain competitive.
The analysis of risks and opportunities related to the transition was developed through a qualitative analysis, based
on the TCFD framework and covering the risk groups Policy and Law, Technology, Market and Reputation, and
included the following steps: (1) a list of potential risks and opportunities covering all relevant sectors of the Group's
business was developed; (2) the list was shortened after an initial review, leaving only 11 risks (R5 was also assessed
as not relevant in the next stage) and 4 opportunities relevant to the geographical areas of the business; (3)
individual risks and opportunities were assessed in a workshop involving Group experts.
The list of analysed risks and opportunities is based on the nature of the industry in which the Group is involved
and possible short, medium and long-term regulatory, legislative and societal developments and includes the
following items: (1) EU ETS expansion/increase, (2) charging methane emissions from gas leaks, (3) tightening
legislation, (4) tightening reporting, (5) lack of a national regulatory framework, (6) diversion of more restrictive
regulation, (7) exposure to litigation, (8) lack of enforcement of climate requirements on suppliers, (9) failure to
invest in decarbonisation/transformation technologies, (10) unavailability of key commodities, (11) negative
perception of the Group due to fossil fuels, (12) obtaining subsidies to support decarbonization, (13) obtaining
sufficient capital to support decarbonization, (14) transition to renewables, and (15) increased support for natural
gas as a transitional energy source as part of decarbonization of the Czech Republic.
The analysis took into account all assets directly owned by the Group and parts of the supply chain, however, due
to their nature, the assessment of risks and opportunities associated with the transition was performed only at the
Group level. The risks and opportunities affect the entire Group and are common to all assets and activities.
Individual risks and opportunities were assessed based on the frequency of occurrence and the level of impact of
the risk/opportunity on the Group. The scale of assessment for both variables ranges from 1-4, where the variables
are multiplied by each other, resulting in the values shown in the tables below. For transition risks, significant
outcome values are coloured red, moderately significant orange and least significant green. For opportunities, this
is an inverted colour scale (green values are significant, medium and low significance are described in light green).
The risks and opportunities assessed as "high" under the SSP2-RCP4.5 scenario were then reflected in the double
materiality assessment and evaluated. All conclusions from the carbon footprint calculation, climate risk analysis
(both physical and transition-related) were used as inputs for the Group-wide double materiality assessment.
Significant transition-related risks are assessed in the Environmental information section, article 2.2.1 [SBM-3]
Material impacts, risks and opportunities and their interaction with strategy and business model.
Subsequently, a double materiality assessment was conducted in which all physical climate-related risks were
assessed as non-material. However, their occurrence in the future together with negative financial impacts on the
Group's assets is not excluded.
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Any uncertainties in the above analyses may be based on the following factors:
• the available models do not provide sufficiently detailed data for individual areas within the quadrants
covering the relevant territory; and
• in the case of solifluction, soil moisture saturation data were used, where the trend showed a decrease in
this parameter, which implies a reduced risk for solifluction. Similarly, landslides were not assessed as a
relevant risk to the Group's assets.
The uncertainties mentioned above relate to areas and assets associated with mineral extraction where they can
potentially negatively affect estimates related to the resilience. It can be assumed that as climate models become
more accurate, this uncertainty will naturally decrease. At the same time, the Group's assets are not located in any
areas exposed or at risk of solifluction. Both uncertainties can therefore be considered low and, for the time being,
the Group has not defined strategies to mitigate them. The Group will monitor and assess these uncertainties on a
regular basis.
E2 (Pollution)
To identify material topics, the Group applied a double materiality assessment during which significant sites and
business activities, including the value chain, were assessed. Specialised tools were not used to identify impacts,
risks and opportunities.
During the double materiality assessment, dialogues were held within the Group with internal experts (ecologists).
Based on these consultations, the assumption was made that the volume of used substances of (very high) concern
is equal to the purchased volume of such substances.
During the double materiality assessment, the topic E2 - Substances of (very high) Concern was assessed as relevant
for the following Group companies: MND a.s., MND Drilling & Services a.s., MND Energy Storage a.s., MND Gas
Storage a.s. and Horyzonty LLC (collectively referred to as the "E2 Relevant Companies"). For the E2 Relevant
Companies, the potential negative impact related to environmental pollution and health damage from the
mishandling of substances of (very high) concern or their release due to a malfunction or accident was assessed.
E2 Relevant Companies are in contact with the relevant regulatory and supervisory authorities to the extent
required by law. Representatives of local stakeholders, in particular municipalities and landowners, are involved in
the project permitting process prior to entering the site. The impact of commercial activities on pollution is also
discussed during the permitting process. However, no conclusions or issues have arisen from the communications
regarding the impact of the Companies' activities on pollution.
In addition, the Group carries out regular environmental assessments which include emissions to air, land and
water. Potential pollution from these substances is mainly related to the extraction, storage, transport and sale of
petroleum products. During the extraction process, screening for harmful chemicals is also regularly carried out,
including a protocol assessment of the safety data sheet prior to the purchase of a chemical, including those
regulated by relevant regulations such as CLP 1 (Classification, Labelling, Packaging) and REACH 2 (Registration,
Evaluation and Authorisation of Chemicals).
E3 (Water and marine resources)
To identify material topics, the Group applied a double materiality assessment, during which all material sites and
assets used by the Group in its own operations were assessed. The assessment took into account the entire value
chain. The Group identified two significant negative impacts: a reduction in water availability and quality, and
potential deterioration of hydrological conditions due to water withdrawal and consumption. The Group identified
impacts, risks and opportunities through a double materiality assessment. The presence of water stress at the sites
was investigated using the Aqueduct Water Risk Atlas tool.
Reductions in water availability and quality and potential deterioration of hydrological conditions are significant
due to drilling and exploration and production activities, particularly due to injection of water into wells. For this
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reason, the topic is relevant to the following Group companies: MND Drilling & Services a.s. (CR) and MND a.s. (CR)
(collectively, the "E3 Relevant Companies").
The E3 Relevant Companies are in contact with the water authority and the municipalities in the affected areas to
the extent required by law. Representatives of local stakeholders, in particular municipalities and landowners, are
also involved in the project permitting process before entering the site. The impact of activities on water abstraction
and consumption is also discussed during the permitting process. However, no conclusions or issues have arisen
from the communications regarding the impact of the E3 Relevant Companies' activities on water availability in the
landscape. The E3 Relevant Companies are not subject to additional monitoring due to the volume of consumption.
E4 (Biodiversity and ecosystems)
The Group assessed impacts across the value chain. The Group assessed impacts on biodiversity and ecosystems
across all the sustainability issues covered by ESRS under E4 topic. No other sustainability matters were identified.
The assessment took into account the scale, scope, irreversibility and likelihood of impact.
By the nature of its business model, the Group is dependent on the availability of mineral resources (oil, natural
gas), which is one of its ecosystem services. The Group has carried out a climate risk analysis, but these risks (and
any other systemic risks) have not been considered in the context of biodiversity and ecosystems.
The Group ensures that all activities are carried out in accordance with the relevant legislation. The Group is also in
contact with local stakeholders (municipalities, landowners).
No conclusions have emerged from the interactions to date that would indicate the significance of the impacts that
the Group would have on biodiversity and ecosystems. The Group does not operate in locations that are in areas
that are sensitive in terms of biodiversity. Thus, the Group has not identified the need to implement biodiversity
mitigation measures.
Based on the double materiality assessment, no significant impacts, risks and opportunities were identified for the
Group in the E4 – Biodiversity and Ecosystems topic.
E5 (Resource use and circular economy)
To identify material topics, the Group applied a double materiality assessment in which all material locations in
which the Group operates as well as the entire value chain were assessed. The Group did not use any specialised
tool in the assessment. The double materiality assessment process included consultation with internal
environmental specialists.
As a result, two material impacts relevant to the following Group companies were identified: MND Drilling &
Services a.s., MND a.s. and Horyzonty LLC (collectively, the "E5 Relevant Companies").
E5 Relevant Companies carry out drilling, exploration and production activities that deplete non-renewable
resources and produce waste. In addition, drilling and extraction activities produce waste (sludge, reagents, etc.)
that contribute to environmental pollution.
The E5 Relevant Companies are in contact with relevant mining authority and the Ministry of the Environment to
the extent required by the legislation of the Czech Republic. In Ukraine, the E5 Relevant Companies are in contact
with (i) the State Service of Geology and Mineral Resources of Ukraine of the Ministry of Environmental Protection
and Natural Resources of Ukraine and (ii) the State Environmental Inspectorate of the Lviv Region of the Ministry
of Environmental Protection and Natural Resources of Ukraine. Prior to entering the site, representatives of local
stakeholders, in particular municipalities and landowners, are involved in the project permitting process. During
the permitting process, the scope of activities, including the management of the waste generated, is discussed.
However, no conclusions or issues have arisen from the communications regarding the impact of the Company's
activities on resource use and waste management.
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G1 (Business conduct)
The Group prioritises the compliance with legal regulations, which sets the framework for the development of
corporate culture and business conduct. The double materiality assessment was made based on internal
professional judgment and other sources such as relevant legislation or information from the Group's relevant
compliance and legal departments.
1.5 ESRS Index
The following table provides an overview of the identified significant topics and disclosure requirements that are
part of this Statement, along with a reference to a specific page of this Statement. The Group has omitted all
disclosure requirements in Topic Standards S2 and S3 as they are below its materiality thresholds.
Standard
Disclosure
requirement
identifier
Requirement for disclosure
Page
ESRS2 - General
information
BP-1
General basis for the preparation of the sustainability statements
28
BP-2
Disclosures in relation to specific circumstances
30
GOV-1
The role of the administrative, management and supervisory bodies
31
GOV-2
Information provided to and sustainability matters addressed by the
undertaking’s administrative, management and supervisory bodies
31
GOV-3
Integration of sustainability-related performance in incentive
schemes
31
GOV-4
Statement on due diligence
34
GOV-5
Risk management and internal controls over sustainability reporting
35
SBM-1
Strategy, business model and value chain
35, 37
SBM-2
Interests and views of stakeholders
37
SBM-3
Material impacts, risks and opportunities and their interaction with
strategy and business model
40
IRO-1
Description of the process to identify and assess material impacts,
risks and opportunities
46
IRO-2
Disclosure requirements in ESRS covered by the undertaking’s
sustainability statement
53
ESRS E1 - Climate
change
E1.SBM-3
Material impacts, risks and opportunities and their interaction with
strategy and business model
83
E1-1
Transition plan for climate change mitigation
85
E1-2
Policies related to climate change mitigation and adaptation
85
E1-3
Actions and resources in relation to climate change policies
86
E1-4
Targets related to climate change mitigation and adaptation
87
E1-5
Energy consumption and mix
87
E1-6
Gross Scopes 1, 2, 3 and Total GHG emissions
89
E1-7
GHG removals and GHG mitigation projects financed through carbon
credits
91
E1-8
Internal carbon pricing
91
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Standard
Disclosure
requirement
identifier
Requirement for disclosure
Page
E1-9
Anticipated financial effects from material physical and transition
risks and potential climate-related opportunities
91
ESRS E2 - Pollution
E2-1
Policies related to pollution
92
E2-2
Actions and resources related to pollution
93
E2-3
Targets related to pollution
93
E2-5
Substances of concern and substances of very high concern
93
ESRS E3 - Water and
marine resources
E3-1
Policies related to water and marine resources
95
E3-2
Actions and resources related to water and marine resources
96
E3-3
Targets related to water and marine resources
96
E3-4
Water consumption
96
ESRS E5 - Resource
use and circular
economy
E5-1
Policies related to resource use and circular economy
97
E5-2
Actions and resources related to resource use and circular economy
98
E5-3
Targets related to resource use and circular economy
98
E5-4
Resource inflows
98
E5-5
Resource outflows
98
ESRS S1 - Own
workforce
S1.SBM-3
Material impacts, risks and opportunities and their interaction with
strategy and business model
100
S1-1
Policies related to own workforce
101
S1-2
Processes for engaging with own workforce and workers’
representatives about impacts
103
S1-3
Processes to remediate negative impacts and channels for own
workforce to raise concerns
104
S1-4
Taking action on material impacts on own workforce, and
approaches to managing material risks and pursuing material
opportunities related to own workforce, and effectiveness of those
actions
105
S1-5
Targets related to managing material negative impacts, advancing
positive impacts, and managing material risks and opportunities
107
S1-6
Characteristics of the undertaking’s employees
107
S1-8
Collective bargaining coverage and social dialogue
108
S1-9
Diversity metrics
108
S1-14
Health and safety metrics
109
S1-16
Remuneration metrics (pay gap and total remuneration)
109
S1-17
Incidents, complaints and severe human rights impacts
110
ESRS S4 - Consumers
and end-users
S4.SBM-3
Material impacts, risks and opportunities and their interaction with
strategy and business model
110
S4-1
Policies related to consumers and end-users
111
S4-2
Processes for engaging with consumers and end-users about
impacts
112
S4-3
Processes to remediate negative impacts and channels for
consumers and end-users to raise concerns
112
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Standard
Disclosure
requirement
identifier
Requirement for disclosure
Page
S4-4
Acting on material impacts on consumers and end-users, and
approaches to managing material risks and pursuing material
opportunities related to consumers and end-users, and
effectiveness of those actions
113
S4-5
Targets related to managing material negative impacts, advancing
positive impacts, and managing material risks and opportunities
114
ESRS G1 - Business
conduct
G1-1
Business conduct policies and corporate culture
115
1.6 Data points resulting from other EU legislation
The table below includes all data that is based on other EU legislation as set out in Annex B of ESRS 2 and indicates
where this data can be found in this Statement. Data points that were not relevant to this Statement are marked
as 'not relevant' or 'phasing in'.
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Disclosure
requirement
Data
point
Disclosure requirement
Link to the Sustainable
Finance Disclosures
Regulation
Link to Pillar 3
Reference to the
Benchmark Regulation
Reference to the
EU Climate Law
Page
ESRS 2
ESRS 2 GOV-1
21 (d)
Board's gender diversity
Indicator number 13 of
Table #1 of Annex 1
Commission Delegated
Regulation (EU)
2020/1816, Annex II
31
ESRS 2 GOV-1
21 (e)
Percentage of board
members who are
independent
Delegated Regulation
(EU) 2020/1816, Annex II
31
ESRS 2 GOV-4
30
Statement on due
diligence
Indicator number 10 Table
#3 of Annex 1
34
ESRS 2 SBM-1
40 (d) i
Involvement in activities
related to fossil fuel
activities
Indicators number 4 Table
#1 of Annex 1
Article 449a
Regulation (EU) No
575/2013;
Commission
Implementing
Regulation (EU)
2022/2453
Table 1: Qualitative
information on
Environmental risk
and
Table 2: Qualitative
information on
Social risk
Delegated Regulation
(EU) 2020/1816, Annex II
35, 37
ESRS 2 SBM-1
40 (d) ii
Involvement in activities
related to chemical
production
Indicator number 9 Table
#2 of Annex 1
Delegated Regulation
(EU) 2020/1816, Annex II
Non-material
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Disclosure
requirement
Data
point
Disclosure requirement
Link to the Sustainable
Finance Disclosures
Regulation
Link to Pillar 3
Reference to the
Benchmark Regulation
Reference to the
EU Climate Law
Page
ESRS 2 SBM-1
40 (d) iii
Involvement in activities
related to controversial
weapons
Indicator number 14 Table
#1 of Annex 1
Delegated Regulation
(EU) 2020/1818, Article
12(1) Delegated
Regulation (EU)
2020/1816, Annex II
Non-material
ESRS 2 SBM-1
40 (d) iv
Involvement in activities
related to cultivation and
production of tobacco
Delegated Regulation
(EU) 2020/1818, Article
12(1) Delegated
Regulation (EU)
2020/1816, Annex II
Non-material
ESRS E1
ESRS E1-1
14
Transition plan to reach
climate neutrality by
2050
Regulation (EU)
2021/1119,
Article 2(1)
85
ESRS E1-1
16 (g)
Undertakings excluded
from Paris-aligned
Benchmarks
Article 449a
Regulation (EU) No
575/2013;
Commission
Implementing
Regulation (EU)
2022/2453
Template 1:
Banking book-
Climate Change
transition risk:
Credit quality of
exposures by
sector, emissions
and residual
maturity
Delegated Regulation
(EU) 2020/1818,
Article12.1 (d) to (g), and
Article 12.2
85
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Disclosure
requirement
Data
point
Disclosure requirement
Link to the Sustainable
Finance Disclosures
Regulation
Link to Pillar 3
Reference to the
Benchmark Regulation
Reference to the
EU Climate Law
Page
ESRS E1-4
34
GHG emission reduction
targets
Indicator number 4 Table
#2 of Annex 1
Article 449a
Regulation (EU) No
575/2013;
Commission
Implementing
Regulation (EU)
2022/2453
Template 3:
Banking book –
Climate change
transition risk:
alignment metrics
Delegated Regulation
(EU) 2020/1818, Article 6
87
ESRS E1-5
38
Energy consumption
from fossil sources
disaggregated by sources
(only high climate impact
sectors)
Indicator number 5 Table
#1 and Indicator n. 5 Table
#2 of Annex 1
87
ESRS E1-5
37
Energy consumption and
mix
Indicator number 5 Table
#1 of Annex 1
87
ESRS E1-5
40-43
Energy intensity
associated with activities
in high climate impact
sectors
Indicator number 6 Table
#1 of Annex 1
87
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Disclosure
requirement
Data
point
Disclosure requirement
Link to the Sustainable
Finance Disclosures
Regulation
Link to Pillar 3
Reference to the
Benchmark Regulation
Reference to the
EU Climate Law
Page
ESRS E1-6
44
Gross Scope 1, 2, 3 and
Total GHG emissions
Indicators number 1 and 2
Table #1 of Annex 1
Article 449a;
Regulation (EU) No
575/2013;
Commission
Implementing
Regulation (EU)
2022/2453
Template 1:
Banking book –
Climate change
transition risk:
Credit quality of
exposures by
sector, emissions
and residual
maturity
Delegated Regulation
(EU) 2020/1818, Article
5(1), 6 and 8(1)
89
ESRS E1-6
53-55
Gross GHG emissions
intensity paragraphs
Indicators number 3 Table
#1 of Annex 1
Article 449a
Regulation (EU) No
575/2013;
Commission
Implementing
Regulation (EU)
2022/2453
Template 3:
Banking book –
Climate change
transition risk:
alignment metrics
Delegated Regulation
(EU) 2020/1818, Article
8(1)
89
ESRS E1-7
56
GHG removals and
carbon credits
Regulation (EU)
2021/1119,
Article 2(1)
Non-material
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Disclosure
requirement
Data
point
Disclosure requirement
Link to the Sustainable
Finance Disclosures
Regulation
Link to Pillar 3
Reference to the
Benchmark Regulation
Reference to the
EU Climate Law
Page
ESRS E1-9
66
Exposure of the
benchmark portfolio to
climate-related physical
risks
Delegated Regulation
(EU) 2020/1818, Annex II
Delegated Regulation
(EU) 2020/1816, Annex II
Phase-in
provision
ESRS E1-9
66 (a); 66
(c)
Disaggregation of
monetary amounts by
acute and chronic
physical risk paragraph
66 (a)
ESRS E1-9
Location of significant
assets at material
physical risk paragraph
66 (c)
Article 449a
Regulation (EU) No
575/2013;
Commission
Implementing
Regulation (EU)
2022/2453
paragraphs 46 and
47; Template 5:
Banking book -
Climate change
physical risk:
Exposures subject
to physical risk.
Phase-in
provision
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Disclosure
requirement
Data
point
Disclosure requirement
Link to the Sustainable
Finance Disclosures
Regulation
Link to Pillar 3
Reference to the
Benchmark Regulation
Reference to the
EU Climate Law
Page
ESRS E1-9
67 (c)
Breakdown of the
carrying value of its real
estate assets by energy-
efficiency classes
Article 449a
Regulation (EU) No
575/2013;
Commission
Implementing
Regulation (EU)
2022/2453
paragraph 34;
Template 2:
Banking book -
Climate change
transition risk:
Loans collateralised
by immovable
property - Energy
efficiency of the
collateral
Phase-in
provision
ESRS E1-9
69
Degree of exposure of
the portfolio to climate-
related opportunities
Delegated Regulation
(EU) 2020/1818, Annex II
Phase-in
provision
ESRS E2
ESRS E2-4
28
Amount of each
pollutant listed in Annex
II of the E-PRTR
Regulation (European
Pollutant Release and
Transfer Register)
emitted to air, water and
soil
Indicator number 8 Table
#1 of Annex 1 Indicator
number 2 Table #2 of
Annex 1 Indicator number
1 Table #2 of Annex 1
Indicator number 3 Table
#2 of Annex 1
Non-material
ESRS E3
ESRS E3-1
9
Water and marine
resources
Indicator number 7 Table
#2 of Annex 1
95
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Disclosure
requirement
Data
point
Disclosure requirement
Link to the Sustainable
Finance Disclosures
Regulation
Link to Pillar 3
Reference to the
Benchmark Regulation
Reference to the
EU Climate Law
Page
ESRS E3-1
13
Dedicated policy
Indicator number 8 Table
2 of Annex 1
95
ESRS E3-1
14
Sustainable oceans and
seas
Indicator number 12 Table
#2 of Annex 1
Non-material
ESRS E3-4
28 (c)
Total water recycled and
reused
Indicator number 6.2
Table #2 of Annex 1
96
ESRS E3-4
29
Total water consumption
in m 3 per net revenue
on own operations
Indicator number 6.1
Table #2 of Annex 1
96
ESRS E4
ESRS E4-2
24 (b)
Sustainable land /
agriculture practices or
policies
Indicator number 11 Table
#2 of Annex 1
Non-material
ESRS E4-2
24 (c)
Sustainable oceans /
seas practices or policies
Indicator number 12 Table
#2 of Annex 1
Non-material
ESRS E4-2
24 (d)
Policies to address
deforestation
Indicator number 15 Table
#2 of Annex 1
Non-material
ESRS E5
ESRS E5-5
37 (d)
Non-recycled waste
Indicator number 13 Table
#2 of Annex 1
98
ESRS E5-5
39
Hazardous waste and
radioactive waste
Indicator number 9 Table
#1 of Annex 1
98
ESRS S1
ESRS 2 - SBM 3 - S1
14 (f)
Risk of incidents of
forced labour
Indicator number 13 Table
#3 of Annex I
100
ESRS 2 - SBM 3 - S1
14 (g)
Risk of incidents of child
labour
Indicator number 12 Table
#3 of Annex I
100
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Disclosure
requirement
Data
point
Disclosure requirement
Link to the Sustainable
Finance Disclosures
Regulation
Link to Pillar 3
Reference to the
Benchmark Regulation
Reference to the
EU Climate Law
Page
ESRS S1-1
20
Human rights policy
commitments
Indicator number 9 Table
#3 and Indicator number
11 Table #1 of Annex I
101
ESRS S1-1
21
Due diligence policies on
issues addressed by the
fundamental
International Labor
Organisation
Conventions
Delegated Regulation
(EU) 2020/1816, Annex II
101
ESRS S1-1
22
Processes and measures
for preventing trafficking
in human beings
Indicator number 11 Table
#3 of Annex I
Non-material
ESRS S1-1
23
Workplace accident
prevention policy or
management system
Indicator number 1 Table
#3 of Annex I
101
ESRS S1-3
32 (c)
Grievance/complaints
handling mechanisms
Indicator number 5 Table
#3 of Annex I
104
ESRS S1-14
88 (b) and
(c)
Number of fatalities and
number and rate of
work-related accidents
Indicator number 2 Table
#3 of Annex I
Delegated Regulation
(EU) 2020/1816, Annex II
109
ESRS S1-14
88 (e)
Number of days lost to
injuries, accidents,
fatalities or illness
Indicator number 3 Table
#3 of Annex I
Phase-in
provision
ESRS S1-16
97 (a)
Unadjusted gender pay
gap
Indicator number 12 Table
#1 of Annex I
Delegated Regulation
(EU) 2020/1816, Annex II
109
ESRS S1-16
97 (b)
Excessive CEO pay ratio
Indicator number 8 Table
#3 of Annex I
Non-material
ESRS S2
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Disclosure
requirement
Data
point
Disclosure requirement
Link to the Sustainable
Finance Disclosures
Regulation
Link to Pillar 3
Reference to the
Benchmark Regulation
Reference to the
EU Climate Law
Page
ESRS 2 - SBM 3 - S2
11 (b)
Significant risk of child
labour or forced labour
in the value chain
Indicators number 12 and
n. 13 Table #3 of Annex I
Non-material
ESRS S2-1
17
Human rights policy
commitments
Indicator number 9 Table
#3 and Indicator n. 11
Table #1 of Annex 1
Non-material
ESRS S2-1
18
Policies related to value
chain workers
Indicator number 11 and
n. 4 Table #3 of Annex 1
Non-material
ESRS S2-1
19
Non-respect of UNGPs
on Business and Human
Rights principles and
OECD guidelines
Indicator number 10 Table
#1 of Annex 1
Delegated Regulation
(EU) 2020/1816, Annex II
Delegated Regulation
(EU) 2020/1818, Art 12
(1)
Non-material
ESRS S2-1
19
Due diligence policies on
issues addressed by the
fundamental
International Labor
Organisation
Conventions 1 to 8
Delegated Regulation
(EU) 2020/1816, Annex II
Non-material
ESRS S2-4
36
Human rights issues and
incidents connected to
its upstream and
downstream value chain
Indicator number 14 Table
#3 of Annex 1
Non-material
ESRS S3
ESRS S3-1
16
Human rights policy
commitments
Indicator number 9 Table
#3 of Annex 1 and
Indicator number 11 Table
#1 of Annex 1
Non-material
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Disclosure
requirement
Data
point
Disclosure requirement
Link to the Sustainable
Finance Disclosures
Regulation
Link to Pillar 3
Reference to the
Benchmark Regulation
Reference to the
EU Climate Law
Page
ESRS S3-1
17
Non-respect of UNGPs
on Business and Human
Rights, ILO principles or
OECD guidelines
Indicator number 10 Table
#1 Annex 1
Delegated Regulation
(EU) 2020/1816, Annex II
Delegated Regulation
(EU) 2020/1818, Art 12
(1)
Non-material
ESRS S3-4
36
Human rights issues and
incidents
Indicator number 14 Table
#3 of Annex 1
Non-material
ESRS S4
ESRS S4-1
16
Policies related to
consumers and end-
users
Indicator number 9 Table
#3 and Indicator number
11 Table #1 of Annex 1
111
ESRS S4-1
17
Non-respect of UNGPs
on Business and Human
Rights and OECD
guidelines
Indicator number 10 Table
#1 of Annex 1
Delegated Regulation
(EU) 2020/1816, Annex II
Delegated Regulation
(EU) 2020/1818, Art 12
(1)
111
ESRS S4-4
35
Human rights issues and
incidents
Indicator number 14 Table
#3 of Annex 1
113
ESRS G1
ESRS G1-1
§10 (b)
United Nations
Convention against
Corruption
Indicator number 15 Table
#3 of Annex 1
115
ESRS G1-1
§10 (d)
Protection of whistle-
blowers
Indicator number 6 Table
#3 of Annex 1
115
ESRS G1-4
§24 (a)
Fines for violation of
anti-corruption and anti-
bribery laws
Indicator number 17 Table
#3 of Annex 1
Delegated Regulation
(EU) 2020/1816, Annex II)
Non-material
ESRS G1-4
§24 (b)
Standards of anti-
corruption and anti-
bribery
Indicator number 16 Table
#3 of Annex 1
Non-material
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2 Environmental information
2.1 EU Taxonomy for the 2024 reporting period
Assessment of eligibility
We have assessed all existing economic activities carried out by the Group to determine which of these are eligible
for taxonomy under the Climate Delegated Act (Commission Regulation (EU) 2021/2139), the Supplementary
Climate Delegated Act (Commission Regulation (EU) 2022/1214), the Environmental Delegated Act (Commission
Regulation (EU) 2023/2486) and the amendments to the Climate Delegated Act (Commission Regulation (EU)
2023/2485). The process included the identification of economic activities related to turnover, capital expenditure
(CAPEX) and operating expenditure (OPEX).
In the following tables we list the different activities that primarily contribute to climate change mitigation.
In 2024, the analysis identified 9 relevant economic activities. A more detailed description of each activity is then
provided below (Results of the compliance assessment):
Economic activity number
Name of economic activity
4.1
Electricity generation using solar photovoltaic technology
4.6
Electricity generation from geothermal energy
4.10
Storage of electricity
4.29
Electricity generation from fossil gaseous fuels
6.5
Transport by motorbikes, passenger cars and light commercial vehicles
6.6
Freight transport services by road
7.3
Installation, maintenance and repair of energy efficiency equipment
7.4
Installation, maintenance and repair of charging stations for electric vehicles in buildings (and
parking spaces attached to buildings)
7.6
Installation, maintenance and repair of renewable energy technologies
The assessment was based on the Group's current knowledge of its business model and business activities and
expertise. The process took into account existing recommendations available at the time of the preparation of this
Statement.
The Group's non-eligible business activities not currently included in the EU taxonomy were identified as energy
sales to end customers, trading in electricity and gas, gas storage, oil and gas production, drilling and related
activities of the Group.
Compliance assessment process
In order to determine whether an identified economic activity is aligned with the taxonomy, it must meet the
requirements described in Article 3 of Regulation (EU) 2020/852. This sets out the obligation to assess compliance
with certain criteria for classifying an activity as environmentally sustainable. First, it was assessed whether the
selected activities of the Company make a significant contribution to one or more of the six environmental
objectives.
All the activities of the Group identified as eligible aim to make a significant contribution to climate change
mitigation. To make a significant contribution to the environmental objective, the activity shall comply with the
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specific technical screening criteria set out in the relevant Annex to the delegated act. We comment below on these
criteria and how they have been assessed by the Group.
Assessment of minimum safeguards
An important step in assessing economic activities in accordance with the taxonomy is compliance with minimum
safeguards (MS). The MSs include all procedures and processes put in place by the Group to ensure that economic
activities are conducted in accordance with the United Nations Guiding Principles on Business and Human Rights
(UNGPs) and the OECD Guidelines for Multinational Enterprises, and incorporate the principles of the International
Labour Organization Declaration on Fundamental Principles and Rights at Work, the International Bill of Human
Rights and Article 16 of the Taxonomy Regulation (EU) 2020/852, which defines minimum safeguards.
The Group has a corruption prevention programme in place, which includes risk assessments and training of its own
employees on anti-corruption rules. It also ensures that business partners are informed of these procedures. The
Group also complies with all relevant tax laws and has a transparent tax strategy. The Group also complies with
applicable competition laws. The Group rejects and does not tolerate human rights abuses. These attitudes and
principles are expressed in the Code of Ethics of MND Group.
During this reporting period, the Group did not record any violations of the UNGPs and OECD Guidelines for 2023
and 2024, did not receive any complaints and has no open case with the National Contact Point for the
Implementation of the OECD Guidelines for Multinational Enterprises (Ministry of Industry and Trade of the Czech
Republic), nor was it accused of human rights violations by the Business and Human Rights Resource Centre (BHRRC)
or received a request for comment on an open case with controversy.
Results of the compliance assessment
For the year 2024, the Group identified the following economic activities as taxonomy-aligned: electricity
generation using solar photovoltaic technology (4.1), storage of electricity (4.10), installation, maintenance and
repair of charging stations for electric vehicles in buildings (7.4) and installation, maintenance and repair of
renewable energy technologies (7.6).
4.1 CCM: Electricity generation using solar photovoltaic technology
The Group operates several photovoltaic power plants (PV plants) that sell the generated electricity to entities
outside the Group. These power plants include FVE Tichá, FVE Orlová I and II and FVE Mušov. By selling electricity
outside the Group, these projects support the wider energy market and contribute to the production of electricity
from renewable sources.
Technical screening criteria
These photovoltaic power plants use solar energy to generate electricity which they then sell on the market, thus
contributing to the expansion of renewable energy sources and the reduction of the carbon footprint and meeting
the established criterion that the activity consists of the generation of electricity using solar photovoltaic energy.
The "do no significant harm" principle
The Group has completed a climate risk assessment and has not identified any significant risks for the operation of
the facility that would require the development of an adaptation plan or measures. The climate risk analysis and
findings are discussed in more detail in section ESRS 2 - General information, article 1.4 [IRO-1] Description of the
processes to identify and assess material impacts, risks and opportunities.
In accordance with Czech legislation, environmental impact assessments were carried out in specific cases where
required. When selecting PV technologies, the Group places emphasis on long service life. Recyclability and
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dismantlability were similar across the assessed equipment and therefore could not be used as distinguishing
factors. None of the PVs are in areas sensitive in terms of biodiversity.
4.10 CCM: Storage of electricity
The MND BESS (Battery Energy Storage System) project focuses on electricity storage using a battery-based system.
This system enables the storage of surplus electricity generated from various sources, including renewable energy,
for later use during periods of high demand or supply outages. Through this project, the Group can enhance the
stability and reliability of electricity supply, optimize the use of energy resources, and contribute to the overall
efficiency of the energy system.
Technical screening criteria
The activity consists of the construction and operation of an electricity storage facility using lithium iron phosphate
batteries.
The "do no significant harm" principle
The Group has conducted a climate risk assessment and has not identified any significant risks related to the
operation of the facility that would require the development of an adaptation plan or measures. A more detailed
analysis of climate risks and findings is provided in section ESRS 2 - General information, article 1.4 [IRO-1]
Description of the processes to identify and assess material impacts, risks and opportunities.
The Group is certified under ISO 14001 and has established procedures for waste management, while also
complying with applicable requirements and regulations under Czech law.
In accordance with Czech legislation, a unified environmental statement was issued confirming that the project is
permissible. The MND BESS electricity storage facility is not located in areas sensitive in terms of biodiversity.
4.29 CCM: Electricity generation from fossil gaseous fuels
The Group's MND Gas to Power ("G2P") project, which commenced licensed operations in 2024, focuses on the
generation of electricity from produced gas using a cogeneration unit. The cogeneration unit will provide the
generated electricity primarily for balancing services, helping to stabilise the transmission system in the Czech
Republic.
Technical screening criteria
The life cycle GHG emissions criterion of less than 100 g CO
2
equivalent /kWh is not met for the Borkovany G2P
project and the facility does not replace an existing high emission electricity generation activity that uses solid or
liquid fossil fuels.
The "do no significant harm" principle
The Group has conducted a climate risk assessment and has not identified any significant risks related to the
operation of the facility that would require the development of an adaptation plan or measures. The climate risk
analysis and findings are discussed in more detail inESRS 2 - General information, article 1.4 [IRO-1] Description of
the processes to identify and assess material impacts, risks and opportunities.
The Group is certified under ISO 14001, including policies and processes for effective water management and
established procedures for waste handling, and complies with applicable requirements and regulations under the
Czech law.
G2P Borkovany has a total installed capacity of 3 180 MW and complies with national legislative requirements for
licensing by the Energy Regulatory Office. It also meets the emission limit requirements for designated stationary
sources, specifically for pollutants of dust, nitrogen oxides, in accordance with Decree No. 415/2012 Coll., on the
permissible level of pollution, its detection and the implementation of certain provisions of the Air Protection Act.
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G2P Borkovany is also not located in areas sensitive in terms of biodiversity.
6.5 CCM: Transportation by motorcycles, passenger cars and commercial vehicles
The Group's economic activity involves the purchase and operation of M1 vehicles, which includes partial
purchases, servicing and fleet replacement.
For the Group, this is a taxonomic activity that is exclusively related to capital and operating expenditure and does
not generate any revenue.
Technical screening criteria
The compliance requirements were carried out at the level of individual M2 and N1 vehicles and purchases. Given
the economics of vehicle purchases, the company does not have an established policy of purchasing only vehicles
that meet the emission footprint requirement of up to 50 g CO
2
/km. However, the Group owns and purchases
electric vehicles that meet this requirement. The Group has purchased 5 electric vehicles in 2024.
The "do no significant harm" principle
Since this is a taxonomy-eligible activity involving exclusively the purchase of outputs from external suppliers,
climate-related risks were not identified or further examined, in line with the principle of proportionality. A more
detailed analysis of climate risks and findings is provided in sectionESRS 2 - General information, article 1.4 [IRO-1]
Description of the processes to identify and assess material impacts, risks and opportunities
For specific vehicle purchases, no verification was carried out at the time of acquisition as to whether the vehicles
were at least 85% recyclable by mass and at least 95% reusable by mass, beyond the requirements imposed on
vehicle sellers under applicable legislation for placing such vehicles on the market.
The Group has not established a process for the procurement of tyres that meet the highest rolling noise
performance class, due to cost considerations and the current availability of such technology.
6.6 CCM: Freight transport services by road
Similarly, in the reporting year, the Group operated vehicles in categories N1, N2 or N3 falling within the scope of
the EURO VI standard, step E or its successor, for road freight transport services. In 2024, only partial purchases,
servicing and replacement of the existing fleet took place.
For the Group, this is a taxonomic activity that is exclusively related to capital and operating expenditure and does
not generate any revenue.
Technical screening criteria
The compliance requirements have been carried out at the level of individual vehicles of the specified categories
defined by the EU taxonomy. Given the economics of vehicle purchases, the company does not have a policy of
purchasing only vehicles that meet the requirement of zero direct (tailpipe) CO
2
emissions.
The Group also uses some of the vehicles to transport fossil fuels, thus failing to meet the criterion of substantial
contribution.
The "do no significant harm" principle
Since this is a taxonomy-eligible activity involving exclusively the purchase of outputs from external suppliers,
climate-related risks were not identified or further examined, in line with the principle of proportionality. A more
detailed analysis of climate risks and findings is provided in sectionESRS 2 - General information, article 1.4 [IRO-1]
Description of the processes to identify and assess material impacts, risks and opportunities.
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For specific vehicle purchases, no verification was carried out at the time of acquisition as to whether the vehicles
were at least 85% recyclable by mass and at least 95% reusable by mass, beyond the requirements imposed on
vehicle sellers under applicable legislation for placing such vehicles on the market.
Currently, the Group does not have a process in place for the procurement of tyres that meet the highest rolling
noise performance class, due to cost considerations and the current availability of such technology.
7.2 CCM: Renovation of existing buildings
In 2023, the Group invested in the reconstruction of buildings in the Lužice Industrial Park, which had been damaged
by a tornado in 2021. In 2024, the Group had no expenditures related to this activity.
For the Group, this is a taxonomic activity that is exclusively related to capital and operating expenditure and does
not generate any revenue.
Technical screening criteria
The requirements of the technical screening criteria were not met.
The "do no significant harm" principle
The Group has prepared a climate risk assessment and has not identified any significant risks related to the
renovation of existing buildings that would require an adaptation plan or specific measures; however ongoing
investments in energy efficiency are being made taking into account the lifetime of individual technologies. For a
more detailed discussion of the climate risk analysis and findings, seeESRS 2 - General information, article 1.4 [IRO-
1] Description of the processes to identify and assess material impacts, risks and opportunities
For specific projects, the Group purchases only construction components and materials that have been placed on
the European market in accordance with applicable legislation and therefore meet the basic requirements
regarding the admissibility or inadmissibility of substances and mixtures.
7.3 CCM: Installation, maintenance and repair of energy efficiency equipment
In 2024, the Group invested in building insulation, modernization of heating systems, and other partial repairs,
installations, and maintenance activities aimed at improving energy efficiency.
For the Group, this is a taxonomic activity that is exclusively related to capital and operating expenditure and does
not generate any revenue.
Technical screening criteria
Maintenance, repairs, and installations in the Group’s buildings follow the principle of prudent asset management.
Currently, there is no guarantee that investments consistently meet the requirement of purchasing equipment
within the top two energy efficiency classes or minimum energy performance standards.
The "do no significant harm" principle
The Group has conducted a climate risk assessment and has not identified any significant risks related to building
operations that would require the development of an adaptation plan or measures, apart from ongoing investments
in measures aimed at reducing energy intensity and considering the lifespan of individual technologies. A more
detailed analysis of climate risks and findings is provided in sectionESRS 2 - General information, article 1.4 [IRO-1]
Description of the processes to identify and assess material impacts, risks and opportunities
For specific projects, the Group purchases only construction components and materials that have been placed on
the European market in accordance with applicable legislation and therefore meet the basic requirements
regarding the admissibility or inadmissibility of substances and mixtures.
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7.4 CCM: Installation, maintenance and repair of charging stations for electric vehicles in buildings
(and parking spaces attached to buildings)
During the reporting period, the Group installed electric vehicle charging stations in its parking areas.
For the Group, this is a taxonomic activity that is exclusively related to capital and operating expenditure and does
not generate any revenue.
Technical screening criteria
In the 2024 financial year, electric vehicle charging stations were installed in parking areas adjacent to the Group's
buildings.
The "do no significant harm" principle
Since this is a taxonomy-eligible activity involving exclusively the purchase of outputs from external suppliers,
climate-related risks were not identified or further examined, in line with the principle of proportionality. A more
detailed analysis of climate risks and findings is provided in sectionESRS 2 - General information, article 1.4 [IRO-1]
Description of the processes to identify and assess material impacts, risks and opportunities.
7.6 CCM: Installation, maintenance and repair of renewable energy technologies
In the 2024 financial year, the Group installed photovoltaic power plants (PVs) at its facilities to reduce electricity
consumption. Unlike activity 4.1 – Electricity generation using solar photovoltaic technology – these PVs were
installed, maintained, or repaired exclusively for self-consumption, most commonly on the rooftops of the Group’s
building.
For the Group, this is a taxonomic activity that is exclusively related to capital and operating expenditure and does
not generate any revenue.
Technical screening criteria
During the reporting period, the activities consisted of the installation, maintenance and repair of solar photovoltaic
systems and ancillary technical equipment on the buildings and land of the Group companies.
The "do no significant harm" principle
The Group has conducted a climate risk assessment and has not identified any significant risks related to the
operation of the facilities that would require the development of an adaptation plan or measures. A more detailed
analysis of climate risks and findings is provided in sectionESRS 2 - General information, article 1.4 [IRO-1]
Description of the processes to identify and assess material impacts, risks and opportunities
The installation of solar photovoltaic power plants is one of the measures aimed at reducing the consumption of
non-renewable energy sources and optimising the energy efficiency management of buildings owned by Group
companies. When selecting PV technologies, the Group places emphasis on long service life and recyclability.
Accounting principles for EU taxonomy KPIs
The accounting principles for key performance indicators (KPIs) within the taxonomy are based on the
interpretation of the Delegated Act on Disclosure (Commission Regulation (EU) 2021/4987), Annex I, and the
available European Commission guidance as amended).
The revenue, CAPEX and OPEX associated with taxonomy-eligible and taxonomy-aligned activities were determined
on the basis of the interdependency principle. This principle states that all revenue, CAPEX, OPEX that can be
reasonably attributed to an identified taxonomy-aligned or eligible activity can be classified as aligned or eligible
and included in the numerator of the respective indicator.
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The Group performed an item-by-item analysis of its revenue model, which allowed it to identify the revenues that
are eligible under the EU taxonomy and then to distinguish between those that meet the technical screening criteria
(aligned with the EU taxonomy), those that are eligible (failing at least one of the technical screening criteria for
substantial contribution, do no significant harm, or minimum safeguards) and those that are not covered by the
taxonomy (the Group's other activities).
When processing data within the EU taxonomy, emphasis was placed on eliminating the risk of double counting.
This approach included reconciliation with accounting data to ensure proper consideration of eliminations and
adjustments, and the use of consistent data sources to avoid duplicate inclusion of items, along with thorough
verification of the completeness and accuracy of all data.
The Group does not have a defined plan to expand existing eligible economic activities or to gradually demonstrate
alignment with the technical and other criteria set out in the EU taxonomy.
Calculation of Turnover
The share of taxonomy-eligible/aligned economic activities in our total turnover was calculated as the portion of
net turnover derived from products and services associated with taxonomy-eligible/aligned economic activities
(numerator) divided by net turnover (denominator).
The denominator of the turnover KPI corresponds to the “Total Income” line item in the Group’s consolidated
statement of comprehensive income.
Calculation of capital expenditure (CAPEX)
The key performance indicator (KPI) CAPEX is defined as taxonomy-aligned CAPEX (numerator) divided by our total
CAPEX (denominator).
Total CAPEX includes additions to tangible and intangible assets during the financial year. It includes acquisitions of
property, plant and equipment, intangible assets, right-of-use assets and investment property (IAS 40). Additions
resulting from business combinations are also included.
The Group's total capital expenditure corresponds to the sum of the “Additions” and the “Effect of asset
acquisition” line items in the notes 15 and 16 to the consolidated financial statements.
Calculation of operating expenses (OPEX)
The key performance indicator Opex is defined as taxonomy-aligned Opex (numerator) divided by our total Opex
(denominator).
According to the taxonomy rules, total Opex includes only a very narrow part of the Group's operating expenses.
These are direct non-capitalised costs relating to research and development, building renovation measures, short-
term leases and maintenance and repair. This includes:
Research and development expenditure recognised as an expense in the profit and loss account during the
reporting period).
Other expenditure has been determined on the basis of expenses recorded in the Repairs and Maintenance account
and the Lease expenses account, which are disclosed in notes 8 and 11 to the financial statements.
The Group does not include personnel costs related to maintenance, service costs, energy and material costs for
day-to-day maintenance, or other overheads due to their immateriality and the impracticality or inefficiency of
allocating a relevant share of total costs.
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Individual CAPEX/OPEX eligible under taxonomy and corresponding economic activities
We have identified the following purchased outputs and individual measures that correspond to eligible economic
activities and therefore result in taxonomy-eligible CAPEX and OPEX.
Description of taxonomy-eligible output and individual
measures
Corresponding economic activity under the EU Taxonomy
Purchase, maintenance and servicing of passenger cars by
the Group companies
6.5 Transportation by motorcycles, passenger cars and
commercial vehicles
Purchase, maintenance and servicing of freight vehicles by
Group companies
6.6 Freight transport services by road
Reconstruction of buildings in the Lužice industrial area after
the tornado
7.2 Renovation of existing buildings
All maintenance and repair of energy efficiency equipment in
our existing buildings (e.g. lighting replacement, insulation,
replacement of windows, doors, etc.)
7.3 Installation, maintenance and repair of energy efficiency
equipment
Installation, maintenance and repair of charging stations in
buildings and parking areas of Group companies
7.4 Installation, maintenance and repair of charging stations
for electric vehicles in buildings (and parking spaces attached
to buildings)
Installation, maintenance and repair of solar photovoltaic
power plants installed for the consumption needs of the
Group companies
7.6 Installation, maintenance and repair of renewable energy
technologies
Key performance indicators and contextual information
For reporting purposes, the Group uses the templates specified by the currently applicable Commission Delegated
Regulation (EU) 2021/2178 of 6 July 2021 supplementing Regulation (EU) 2020/852 of the European Parliament
and of the Council which clarifies the content and presentation of information to be disclosed by undertakings
pursuant to Article 29a of Directive 2013/34/EU in relation to environmentally sustainable economic activities and
specifies the methodology for fulfilling this disclosure obligation.
The overview of sustainability, eligibility, and key performance indicators is presented in the following summary
table:
Sustainability and eligibility
2024
2023
under the EU taxonomy in CZK million
Turnover
Capex
Opex
Turnover
Capex
Opex
Sustainable
32
78
3
15
302
2
Eligible
38
189
13
71
437
35
Non-eligible
28 675
3 395
197
56 345
507
131
Total
28 713
3 584
210
56 416
944
167
Sustainable
0%
2%
1%
0%
32%
1%
Eligible
0%
5%
6%
0%
46%
22%
Non-eligible
100%
95%
94%
100%
54%
78%
The sustainable turnover in 2024 amounted to CZK 32 million (2023: CZK 15 million), representing revenue from
the sale of electricity generated by solar power plants.
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Sustainable CAPEX in 2024 consisted solely of additions to tangible assets. The largest item was the acquisition of a
battery storage system in the amount of CZK 68 million. In 2023, CAPEX included CZK 114 million in additions to
tangible assets and CZK 188 million from asset acquisitions, primarily related to the purchase of PV Orlová I and
Orlová II and the construction of PV Mušov, totalling CZK 287 million.
Sustainable OPEX amounted to CZK 3 million (2023: CZK 2 million), consisting of repair and maintenance costs for
solar power plants.
The year-on-year increase in turnover and OPEX, and the decrease in CAPEX, were driven by the acquisition of PVs
in 2023.
Changes from the previous reporting period and corrections
In the 2024 EU Taxonomy reporting, the Group made several corrections to the comparative figures for the prior
period:
• The Group did not used the prescribed templates in the 2023 Report on Non-Financial Information.
• The Group incorrectly reported the turnover amount for activity 4.1 Electricity generation using solar
photovoltaic technology.
• The Group corrected the amounts of eligible capital expenditures for 2023 for the following activities 4.1
Electricity generation using solar photovoltaic technology, 4.10 Storage of electricity and 4.29 Electricity
generation from fossil gaseous fuels.
• In addition, the Group made corrections in 2023 data for activities 4.22 Electricity generation from wind
power and 5.12 Permanent underground geological storage of CO
2
.
• In 2023, operating expenditure included costs that are non-eligible under the EU Taxonomy definition of
operating expenditure. The Group corrected the 2023 figure for operating expenditure in activity 4.1 –
Electricity generation using solar photovoltaic technology, where higher eligible expenses had been
reported.
• The Group added the following eligible activities to the 2023 figures for both capital and operating
expenditure that had not been reported in the 2023 report:
6.5 Transport by motorcycles, passenger cars and light commercial vehicles
6.6 Freight transport services by road
7.2 Renovation of existing buildings
7.3 Installation, maintenance and repair of energy efficiency equipment
7.6 Installation, maintenance and repair of renewable energy technologies
The comparison of the amounts reported in the 2023 Non-Financial Information Report and the restated
comparative 2023 figures presented in the 2024 Consolidated Sustainability Statement:
Original 2023 data (in CZK million)
Eligible activities
Aligned Activities
Non-Eligible Activities
Total turnover
62.5
6.4
56 353.5
Capital expenditure
173.2
172.8
770.8
Operating expenditure
12.5
12.5
161.3
Restated 2023 data (in CZK million)
Eligible activities
Aligned Activities
Non-Eligible Activities
Total turnover
71
15
56 345
Capital expenditure
437
302
507
Operating expenditure
36
2
131
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Proportion of turnover from products or services associated with Taxonomy-aligned economic activities - disclosure for 2024
Financial year 2024
2024
Substantial contribution criteria
DNSH criteria
2023
Economic
activities (1)
Code (a) (2)
Turnove
r (3)
Proporti
on of
turnover
(4)
Climate
change
mitigation
(5)
Climate
change
adaptatio
n (6)
Water (7)
Pollution
(8)
Circular
economy
(9)
Biodiversi
ty (10)
Climate
change
mitigation
(11)
Climate
change
adaptatio
n (12)
Water
(13)
Polluti
on
(14)
Circular
economy
(15)
Biodiversi
ty (16)
Minimum
safeguard
s (17)
Proportion
of turnover,
year 2023
(18)
Category
(enabling
activity)
(19)
Category
(transitio
nal
activity)
(20)
Turnove
r (3)
Text
CZK
million
%
A; N; N/EL
A; N;
N/EL
A; N;
N/EL
A; N; N/EL
A; N;
N/EL
A; N;
N/EL
A/N
A/N
A/N
A/N
A/N
A/N
A/N
%
E
T
CZK
million
A. TAXONOMY-ELIGIBLE ACTIVITIES
A.1. Environmentally sustainable activities (Taxonomy aligned)
Electricity generation using solar photovoltaic
technology
CCM 4.1
32
0%
A
N
N/EL
N/EL
N/EL
N/EL
A
A
A
A
A
A
A
0%
15
Turnover of environmentally sustainable
activities (Taxonomy aligned) (A.1)
32
0%
0%
0%
15
A.2. Taxonomy-Eligible but not environmentally sustainable activities (not Taxonomy aligned activities)
EL; N/EL
EL; N/EL
EL; N/EL
EL; N/EL
EL; N/EL
EL; N/EL
Electricity generation from fossil gaseous fuels
CCM 4.29
6
0%
EL
N/EL
N/EL
N/EL
N/EL
N/EL
0%
T
0
Electricity generation from geothermal energy
CCM 4.6
0
0%
EL
EL
N/EL
N/EL
N/EL
N/EL
0%
56
Turnover of Taxonomy-eligible but not environmentally
sustainable activities (not Taxonomy aligned activities) (A.2)
6
0%
0%
0%
56
A. Turnover of Taxonomy-eligible activities (A.1+A.2)
38
0%
0%
0%
71
B. TAXONOMY NON-ELIGIBLE ACTIVITIES
Turnover of Taxonomy-non-eligible activities
28 675
100%
100%
56 345
TOTAL
28 713
100%
100%
56 416
(a) Climate Change Mitigation: CCM, Climate Change Adaptation: CCA, Water and Marine Resources: WTR, Circular Economy: CE, Pollution Prevention and Control: PPC, Biodiversity and Ecosystems: BIO
A - Yes, the activity is eligible for the taxonomy and is aligned with the relevant environmental objective of the taxonomy, N - no, the activity is eligible for the taxonomy but is not aligned with the relevant environmental objective of the taxonomy, N/EL - non-eligible, the activity is non-eligible for
the taxonomy for the relevant environmental objective
EL - Activity eligible for the taxonomy for the respective objective, N/EL - Activity non-eligible for the taxonomy for the respective objective
I
-
-
I I
111
1 1111
"11111
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I I I
11
1
1111
II
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Proportion of capital expenditure from products or services associated with Taxonomy-aligned economic activities - disclosure for 2024
Financial year 2024
2024
Substantial contribution criteria
DNSH criteria
2023
Economic
activities (1)
Code (a) (2)
Capital
expendit
ure (3)
Proportio
n of
capital
expendit
ure (4)
Climate
change
mitigatio
n (5)
Climate
change
adaptatio
n (6)
Water (7)
Pollution
(8)
Circular
economy
(9)
Biodiversi
ty (10)
Climate
change
mitigatio
n (11)
Climate
change
adaptatio
n (12)
Water
(13)
Pollution
(14)
Circular
economy
(15)
Biodiver
sity (16)
Minimum
safeguard
s (17)
Proportion
of capital
expenditure,
year 2023
(18)
Category
(enabling
activity)
(19)
Categor
y
(transiti
onal
activity
) (20)
Capital
expendit
ure (3)
Text
CZK
million
%
A; N;
N/EL
A; N;
N/EL
A; N;
N/EL
A; N; N/EL
A; N;
N/EL
A; N;
N/EL
A/N
A/N
A/N
A/N
A/N
A/N
A/N
%
E
T
CZK
million
A. TAXONOMY-ELIGIBLE ACTIVITIES
A.1. Environmentally sustainable activities (Taxonomy aligned)
Electricity generation using solar photovoltaic
technology
CCM 4.1
1
0%
A
N
N/EL
N/EL
N/EL
N/EL
A
A
A
A
A
A
A
30%
287
Storage of electricity
CCM 4.10
68
2%
A
N
N/EL
N/EL
N/EL
N/EL
A
A
A
A
A
A
A
0%
E
2
Installation, maintenance and repair of charging
stations for electric vehicles in buildings (and
parking spaces attached to buildings)
CCM 7.4
1
0%
EL
EL
N/EL
N/EL
N/EL
N/EL
0%
0
Installation, maintenance and repair of renewable
energy technologies
CCM 7.6
8
0%
A
N
N/EL
N/EL
N/EL
N/EL
A
A
A
A
A
A
A
1%
13
Capital expenditure on environmentally sustainable activities
(Taxonomy aligned) (A.1)
78
2%
2%
A
A
A
A
A
A
A
32%
302
A.2. Taxonomy-Eligible but not environmentally sustainable activities (not Taxonomy aligned activities)
EL; N/EL
EL; N/EL
EL; N/EL
EL; N/EL
EL; N/EL
EL; N/EL
Electricity generation from fossil gaseous fuels
CCM 4.29
41
1%
EL
EL
N/EL
N/EL
N/EL
N/EL
5%
51
Transport by motorbikes, passenger cars and light
commercial vehicles
CCM 6.5
38
1%
EL
EL
N/EL
N/EL
N/EL
N/EL
3%
32
Freight transport services by road
CCM 6.6
16
0%
EL
EL
N/EL
N/EL
N/EL
N/EL
0%
3
Renovation of existing buildings
CCM 7.2
0
0%
EL
EL
N/EL
N/EL
EL
N/EL
5%
45
Installation, maintenance and repair of energy
efficiency equipment
CCM 7.3
16
0%
EL
EL
N/EL
N/EL
N/EL
N/EL
0%
4
Capital expenditure of Taxonomy-eligible but not
environmentally sustainable activities (not Taxonomy aligned
activities) (A.2)
111
3%
3%
14%
135
A. Capital expenditure of Taxonomy-eligible activities (A.1+A.2)
189
5%
5%
46%
437
B. TAXONOMY NON-ELIGIBLE ACTIVITIES
Capital expenditure of Taxonomy-non-eligible activities
3 395
95%
54%
507
TOTAL
3 584
100%
100%
944
(a) Climate Change Mitigation: CCM, Climate Change Adaptation: CCA, Water and Marine Resources: WTR, Circular Economy: CE, Pollution Prevention and Control: PPC, Biodiversity and Ecosystems: BIO
A - Yes, the activity is eligible for the taxonomy and is aligned with the relevant environmental objective of the taxonomy, N - no, the activity is eligible for the taxonomy but is not aligned with the relevant environmental objective of the taxonomy, N/EL - non-eligible, the activity is non-eligible for
the taxonomy for the relevant environmental objective
EL - Activity eligible for the taxonomy for the respective objective, N/EL - Activity non-eligible for the taxonomy for the respective objective
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Proportion of operating expenditure from products or services associated with Taxonomy-aligned economic activities - disclosure for 2024
Financial year 2024
2024
Substantial contribution criteria
DNSH criteria
2023
Economic
activities (1)
Code (a) (2)
Operating
expenditu
re (3)
Proportio
n of
operating
expenditu
re (4)
Climate
change
mitigatio
n (5)
Climate
change
adaptatio
n (6)
Water (7)
Pollution
(8)
Circular
economy
(9)
Biodiversi
ty (10)
Climate
change
mitigation
(11)
Climate
change
adaptatio
n (12)
Water
(13)
Pollution
(14)
Circular
economy
(15)
Biodiversi
ty (16)
Minimum
safeguard
s (17)
Proportion
of operating
expenditure,
year 2023
(18)
Category
(enabling
activity)
(19)
Category
(transitio
nal
activity)
(20)
Operatin
g
expendit
ure (3)
Text
CZK
million
%
A; N;
N/EL
A; N;
N/EL
A; N;
N/EL
A; N;
N/EL
A; N;
N/EL
A; N;
N/EL
A/N
A/N
A/N
A/N
A/N
A/N
A/N
%
E
T
CZK
million
A. TAXONOMY-ELIGIBLE ACTIVITIES
A.1. Environmentally sustainable activities (Taxonomy aligned)
Electricity generation using solar photovoltaic
technology
CCM 4.1
3
1%
A
N
N/EL
N/EL
N/EL
N/EL
A
A
A
A
A
A
A
1%
2
Operating expenditure of environmentally sustainable
activities (Taxonomy aligned) (A.1)
3
1%
2%
A
A
A
A
A
A
A
1%
2
A.2. Taxonomy-Eligible but not environmentally sustainable activities (not Taxonomy aligned activities)
EL; N/EL
EL; N/EL
EL; N/EL
EL; N/EL
EL; N/EL
EL; N/EL
Electricity generation from geothermal
energy
CCM 4.6
0
0%
EL
EL
N/EL
N/EL
N/EL
N/EL
10%
16
Electricity generation from fossil gaseous
fuels
CCM 4.29
1
0%
EL
EL
N/EL
N/EL
N/EL
N/EL
0%
1
Transport by motorbikes, passenger cars and
light commercial vehicles
CCM 6.5
4
2%
EL
EL
N/EL
N/EL
N/EL
N/EL
2%
4
Freight transport services by road
CCM 6.6
1
1%
EL
EL
N/EL
N/EL
N/EL
N/EL
1%
1
Renovation of existing buildings
CCM 7.2
0
0%
EL
EL
N/EL
N/EL
EL
N/EL
0%
0
Installation, maintenance and repair of
energy efficiency equipment
CCM 7.3
4
2%
EL
EL
N/EL
N/EL
N/EL
N/EL
8%
13
Operating expenditure of Taxonomy-eligible but not
environmentally sustainable activities (not Taxonomy
aligned activities) (A.2)
10
5%
5%
21%
35
A. Operating expenditure of Taxonomy-eligible activities
(A.1+A.2)
13
6%
6%
22%
36
B. TAXONOMY NON-ELIGIBLE ACTIVITIES
Operating expenditure of Taxonomy-non-eligible activities
197
94%
78%
131
TOTAL
210
100%
100%
167
(a) Climate Change Mitigation: CCM, Climate Change Adaptation: CCA, Water and Marine Resources: WTR, Circular Economy: CE, Pollution Prevention and Control: PPC, Biodiversity and Ecosystems: BIO
A - Yes, the activity is eligible for the taxonomy and is aligned with the relevant environmental objective of the taxonomy, N - no, the activity is eligible for the taxonomy but is not aligned with the relevant environmental objective of the taxonomy, N/EL - non-eligible, the activity is non-eligible for the
taxonomy for the relevant environmental objective
EL - Activity eligible for the taxonomy for the respective objective, N/EL - Activity non-eligible for the taxonomy for the respective objective
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As we carry out natural gas activities (activities 4.26-4.31), we publish below the special templates introduced by the Supplementary Delegated Act concerning activities
in certain energy sectors:
Turnover Template 1 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 the 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 the production of hydrogen from nuclear energy, as well as
their safety upgrades.
NO
Fossil gas related activities
4.
The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels.
YES
5.
The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels.
NO
6.
The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels..
NO
Turnover Template 2 Taxonomy-aligned economic activities (denominator)
Row
Economic activities
Climate change mitigation +
Climate change adaptation
Climate change mitigation
Climate change
adaptation
CZK million
%
CZK million
%
CZK million
%
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
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
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
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
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
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
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
32
0
32
0
0
8.
Total applicable KPI
28 713
100
28 713
100
0
Turnover Template 3 Taxonomy-aligned economic activities (numerator)
Row
Economic activities
Climate change mitigation +
Climate change adaptation
Climate change mitigation
Climate change
adaptation
CZK million
%
CZK million
%
CZK
million
%
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
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
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
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
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
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
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
32
100
32
100
8.
Total amount and proportion of taxonomy-aligned economic activities in the numerator of the applicable KPI
32
100
32
100
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Turnover Template 4 Taxonomy-eligible but not taxonomy-aligned economic activities
Row
Economic activities
Climate change mitigation +
Climate change adaptation
Climate change mitigation
Climate change
adaptation
CZK million
%
CZK million
%
CZK million
%
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
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
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
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
6
0
6
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
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
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
0
0
8.
Total amount and proportion of taxonomy eligible but not taxonomy-aligned economic activities in the denominator of the applicable KPI
6
0
6
0
Turnover Template 5 Economic activities not eligible for taxonomy
Row
Economic activities
CZK million
%
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
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
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
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
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
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
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
28 675
100
8.
Total amount and proportion of taxonomy-non-eligible economic activities in the denominator of the applicable KPI
28 675
100
Capex Template 1 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 the 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 the production of hydrogen from nuclear energy, as well as
their safety upgrades.
NO
Fossil gas related activities
4.
The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels.
YES
5.
The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels.
NO
6.
The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels..
NO
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Capex Template 2 Taxonomy-aligned economic activities (denominator)
Row
Economic activities
Climate change mitigation +
Climate change adaptation
Climate change mitigation
Climate change
adaptation
CZK million
%
CZK million
%
CZK million
%
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
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
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
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
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
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
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
78
2
78
2
8.
Total applicable KPI
3 584
100
3 584
100
Capex Template 3 Taxonomy-aligned economic activities (numerator)
Row
Economic activities
Climate change mitigation +
Climate change adaptation
Climate change mitigation
Climate change
adaptation
CZK million
%
CZK million
%
CZK million
%
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
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
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
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
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
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
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
78
100
78
100
8.
Total amount and proportion of taxonomy-aligned economic activities in the numerator of the applicable KPI
78
100
78
100
Capex Template 4 Taxonomy-eligible but not taxonomy-aligned economic activities
Row
Economic activities
Climate change mitigation +
Climate change adaptation
Climate change mitigation
Climate change
adaptation
CZK million
%
CZK million
%
CZK million
%
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
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
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
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
41
1
41
1
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
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
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
70
2
70
2
8.
Total amount and proportion of taxonomy eligible but not taxonomy-aligned economic activities in the denominator of the applicable KPI
111
3
111
3
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Capex Template 5 Economic activities not eligible for taxonomy
Row
Economic activities
CZK million
%
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
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
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
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
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
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
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
3 395
95
8.
Total amount and proportion of taxonomy-non-eligible economic activities in the denominator of the applicable KPI
3 395
95
Opex Template 1 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 the 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 the production of hydrogen from nuclear energy, as well as
their safety upgrades.
NO
Fossil gas related activities
4.
The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels.
YES
5.
The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels.
NO
6.
The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels..
NO
Opex Template 2 Taxonomy-aligned economic activities (denominator)
Row
Economic activities
Climate change mitigation +
Climate change adaptation
Climate change mitigation
Climate change
adaptation
CZK million
%
CZK million
%
CZK million
%
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
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
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
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
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
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
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
3
1
3
1
8.
Total applicable KPI
210
100
210
100
Opex Template 3 Taxonomy-aligned economic activities (numerator)
Row
Economic activities
Climate change mitigation +
adaptation
Climate change mitigation
Climate change
adaptation
CZK million
%
CZK million
%
CZK million
%
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
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
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
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
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
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
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
3
100
3
100
8.
Total amount and proportion of taxonomy-aligned economic activities in the numerator of the applicable KPI
3
100
3
100
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Opex Template 4 Taxonomy-eligible but not taxonomy-aligned economic activities
Row
Economic activities
Climate change mitigation +
Climate change adaptation
Climate change mitigation
Climate change
adaptation
CZK million
%
CZK million
%
CZK million
%
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
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
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
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
1
0
1
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
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
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
9
5
9
5
8.
Total amount and proportion of taxonomy eligible but not taxonomy-aligned economic activities in the denominator of the applicable KPI
10
5
10
5
Opex Template 5 Economic activities not eligible for taxonomy
Row
Economic activities
CZK million
%
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
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
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
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
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
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
197
94
8.
Total amount and proportion of taxonomy-non-eligible economic activities in the denominator of the applicable KPI
197
94
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2.2 E1 - Climate change
2.2.1 [SBM-3] Material impacts, risks and opportunities and their interaction with strategy and
business model
The MND Group has conducted a climate risk and resilience analysis. Two climate scenarios (RCP4.5-SSP245 and
RCP8.5-SSP585) and three time-horizons were assessed: short-term (historical - current state), medium-term (2030)
and long-term (2050).
The following sites and assets were included in the value chain:
Czech Republic: Ždánice, Žarošice, Uhřice, Dambořice, Borkovany, Lužice, Measuring station Brumovice, Dolní
Bojanovice, Orlová, Tichá, Mušov, Poddvorov, Hodonín.
Ukraine: Černý Les, Girska, Tynivska, Beregivska, Grabivska, Vishnia, Oriv Windpark (Lviv region).
A climate risk and resilience analysis were conducted in relation to all key assets owned. Physical and transition
risks were analysed. Some minor operational activities (such as the operation of an accredited geochemical
laboratory and innovation) and parts of the value chain that were not considered material in terms of physical and
transition risks were excluded from the analysis. The objective of the analysis was to determine the level of
exposure of each of the Group's climate resilient assets and technologies to risks associated with climate change.
The topic is discussed in detail inESRS 2 - General information, article 1.4 [IRO-1] Description of the processes to
identify and assess material impacts, risks and opportunities.
The analysis evaluated financial impacts with respect to probability of an event occurring and the implementation
of mitigation measures. Although some physical climate risks emerged as potential risks. during subsequent
assessment under the double materiality assessment, no physical risk was identified as material. The Group's
operations can therefore be considered resilient in this area. The materiality of physical risks will continue to be
monitored, and their potential impacts reassessed. Should the materiality threshold be exceeded, appropriate
investment measures will be taken to restore or enhance the Group’s resilience.
The findings of both analyses also served as the basis for the double materiality assessment (Double Materiality
Assessment – DMA).
The following risks were assessed as significant (material):
R1: Transition to a low-carbon economy creates risks for future demand of oil and gas, due to more restrictive
regulation of existing products and services. This represents a regulatory risk related to the transition to renewable
energy sources.
R2: Introduction of a carbon tax on methane emissions leading to increased operating costs. Extension of the EU
emissions trading system to other sectors and/or increase in carbon credits prices. This represents a regulatory risk
related to the transition to renewable energy sources.
As part of strengthening resilience, the Group's long-term objective is to keep risk-related matters at a minimum
level, which also applies to climate risks. Risk management, starting with identification and quantification, is
followed by an analysis and quantification of the exposure to a given risk. For environmental impacts, the Group
seeks to minimise them (restoration of depleted areas and removal of environmental burdens), implementing
sustainable development principles in its activities, thus contributing to the resilience of its strategy to climate
change.
As part of strengthening the resilience of the strategy to identified impacts, the Group is actively working to reduce
its negative environmental impact and is also focusing on adapting its strategy and business model to climate
change in the short-, medium- and long-term through several key initiatives:
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• The Group is investing in upgrading its mining facilities to reduce greenhouse gas emissions and increase
energy efficiency. In some cases, the Group has decided to phase out older, inefficient mining equipment
and replace it with more modern and environmentally friendly alternatives. However, from a climate risk
perspective, no significant steps are required to adapt to changing climate conditions.
• The Group promotes responsible environmental management, which includes the restoration of depleted
areas and the removal of environmental burdens. Upon completion of its extraction activities, the Group
carries out thorough reclamation work, which involves restoring the original landscape and ensuring its
ecological stability. These activities include the removal of contaminated materials, soil revitalisation, and
the planting of vegetation that supports biodiversity and ecosystem restoration. The removal of
environmental burdens is a key aspect of sustainable environmental management, as it minimises the
negative impacts of extraction on the environment and the health of local communities.
Given the nature of the Group's business, which is heavily oriented towards commodities such as oil and gas, it
would be difficult to flexibly switch to an alternative business model in the short-term horizon. Given the current
geopolitical situation and the technological readiness of the existing economies, the Group has assessed the risk of
transitioning to a low carbon economy in the short to medium-term as not material. The gradual transition to a low
carbon and resilient economy may represent a major change and financial risk for the Group in the long-term. The
primary determinant will be the evolving geopolitical situation and regulatory environment. Closely related to this
are developments in energy markets and technological advances within the sector dependent on commodities
traded by the Group.
Opportunities associated with transition and transformation are defined with a view of mitigating the impact of
transition risks on the Group and form a part of the procedures to strengthen resilience. These opportunities
include, for example, portfolio diversification (hydrogen, biogas), investment in renewable energy, and the
implementation of new technologies to reduce greenhouse gas emissions, contributing to decarbonisation and
improving the Group's reputation. Another key fact is the active communication of sustainability topics with
stakeholders such as investors, communities or employees.
The Group also focuses on the development and operation of renewable energy infrastructure, which includes the
construction of photovoltaic and wind power plants. MND Energie a.s. has introduced an innovative product called
Solar Account, which allows households and businesses to sell surplus electricity generated from their photovoltaic
systems back to the grid. This product promotes decentralisation of the energy sector by allowing smaller energy
producers to contribute to the overall energy balance. The Solar Account provides financial benefits for
photovoltaic system owners and increases the overall efficiency of renewable energy utilisation. In this way, the
Group promotes wider adoption and integration of renewable energy sources into the energy mix.
The Group's investment decisions reflect the energy sector's shift towards low-carbon sources, which is reflected
in an increase in the allocation of funds to renewable energy and other projects. These projects include investments
in a wind park in Ukraine, carbon dioxide storage in decommissioned oil and gas reservoirs, operation of a
commercial underground storage facility for the permanent storage of carbon dioxide captured from industrial
production, construction and acquisition of photovoltaic power plants and project preparation for the
implementation of large-scale battery storage facilities. In the context of carbon neutrality, the Group is engaged
in cooperation with universities and business partners in projects related to hydrogen technology, transportation
and underground storage of carbon. Finally, the Group is investing in training and retraining its employees to
prepare them for new challenges and opportunities in renewable energy and low carbon technologies. The Group
also works with universities and professional institutions to develop training programmes and internships for young
talent.
In the area of material transition risks, the Group is actively cooperating with financial institutions and investors to
ensure continued access to funding at an acceptable cost of capital. An example is the financing of renewable
energy projects such as wind and solar farms. In this way, the Group secures the necessary financial resources to
support its environmental initiatives. However, EU Taxonomy aims to move the investments into sustainable
activities, which requires adapting the Group's business model to meet these requirements and ensure access to
finance from investors and financial institutions.
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With this comprehensive approach, the Group is demonstrating its ability to adapt to the climate change and
contribute to a more sustainable future, even as it faces the challenges of transitioning to a more sustainable
business model.
2.2.2 [E1-1] Transition plan for climate change mitigation
Currently, the Group does not have a Climate Change Mitigation Transition Plan. The Group plans to adopt the Plan,
but without a more specific timeframe. The Climate Risk Analysis conducted in January 2025 will be taken into
account in the preparation of the Plan (for the Climate Risk Analysis conclusions, see the section Environmental
information, article 2.2.1 [SBM-3] Material impacts, risks and opportunities and their interaction with strategy and
business model).
Most of the Group's revenue is derived from the exploration, production, distribution or refining of oil and gas fuels.
The Group is therefore excluded from the EU benchmark values linked to the Paris Agreement under Delegated
Regulation (EU) 2020/1818, Article 12(1)(d) to (g).
2.2.3 [E1-2] Policies related to climate change mitigation and adaptation
The Group has implemented the following directive in relation to the management of material impacts, risks and
opportunities relating to the production of greenhouse gases associated with exploration and production:
• Directive on Protection of Environment - The relevant Group companies
8
regulate, among other things, air
protection
9
, including climate change mitigation, through internal directives. The directive specifically
defines the obligations and responsibilities for the operation of facilities that handle controlled substances
and fluorinated greenhouse gases. The directive is applied at the level of the actual operation, specifically
the operational centres in the Czech Republic (it is not applicable to activities in Ukraine). The directive has
been approved at the director level, and the heads of the respective organizational units are responsible
for the implementation of the relevant sub-policies. The current version of the Directive is available to
employees via a shared internal drive. In addition, selected companies
10
have implemented an
Environmental Management System in accordance with the requirements of ISO 14001 certification.
For the remaining companies of the Group, no operational needs have been identified for the adoption of a specific
directive regulating the production of greenhouse gases associated with exploration and production, and for this
reason the companies have not adopted such a directive.
Neither the Group nor the relevant companies have policies that relate to the positive impacts or opportunities
associated with the production of renewable energy sources (RES) and the implementation of innovative
technologies. However, the Group implements measures that directly respond to these opportunities and have a
positive effect, see article 2.2.4 [E1-3] Actions and resources in relation to climate change policies. The Group
prioritises sustainability matters the impacts, risks, and opportunities of which it perceives as most material. Thus,
for the time being, the Group does not address the impacts associated with supplier relationships (emissions
generated as a result of the production of materials and machinery used). The policies also do not address the
negative impacts and risks associated with commodity consumption and associated emissions, as the Group plans
(following the Group's business model) to continue in its mining activities.
The Group does not have policies that explicitly address climate change adaptation, energy efficiency, renewable
energy deployment or other climate change related topics. The Group prioritises sustainability matters the impacts,
risks, and opportunities of which it perceives as most material. This attention may take the form of policy (see
above) or action (see article 2.2.4 [E1-3] Actions and resources in relation to climate change policies).
8
MND a.s., MND Drilling & Services a.s., MND Gas Storage a.s., MND Energy Storage a.s.
9
The Directive also addresses waste management and water management.
10
MND a.s., MND Drilling & Services a.s., MND Gas Storage a.s.
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2.2.4 [E1-3] Actions and resources in relation to climate change policies
Following the Directive on Protection of Environment, the Group continued to apply rules related to controlled
substances and fluorinated greenhouse gases in the past year. Based on the register of the environmental aspects,
the Group (specifically MND Energy Storage a.s.) has also identified measures to address climate change, specifically
the measures to prevent uncontrolled leakage of natural gas and methane into the air, specifically the measures to
prevent operational leakage of natural gas and methane into the air by replacing part of the technology using
natural gas for operation, which subsequently escapes through the exhaust pipe, with compressed air. Compressed
air replaces natural gas in the start-up sequence of gas engines that drive compressors for natural gas storage. The
technology was commissioned in 2024. The annual avoided natural gas emissions are expected to be approximately
4 300 m
3
in 2025, equivalent to approximately 87 tCO2eq. The Group will continue to apply the rules and identify
measures. The implementation of these activities does not require significant human resources but will entail
significant financial resources (approximately CZK 2 million), especially in view of the expected amount of avoided
emissions as a result of the implementation of this measure.
The Group does not have a policy focused on RES production or implementation of innovative technologies (as
mentioned above, see article 2.2.3 [E1-2] Policies related to climate change mitigation and adaptation), however,
in 2024 the Group implemented the following activities in this area that contribute to mitigating the climate change:
• Construction of renewable energy sources (RES) - Construction of photovoltaic (PV) and wind power plants
(WPP) on the territory of the Czech Republic and Ukraine. Installed capacity is currently 10.8 MWp in the
Czech Republic and 59 MWp in Ukraine. The development of wind power projects continues and is in the
early stages of preparation. The scale of investment plans in PV and WPP depends on the projected return
on investment and the availability of financial resources. Plans will also be further developed in conjunction
with the forthcoming Climate Change Mitigation Transition Plan.
• Carbon capture and storage (CCS) - Planned measure, currently in the pre-project preparation phase and
preparation of documentation for the subsidy title. The measure will thus contribute to the decarbonisation
of the supply chain. The implementation period is estimated at 7-8 years. The current investment
requirement is approximately CZK 4.6 billion. The implementation of the project plan would enable the
storage of approximately 800 thousand tonnes of CO2e per year. The investment plan is strongly dependent
on the success of obtaining subsidies. The plans will also be further developed in conjunction with the
forthcoming Climate Change Mitigation Transition Plan.
• Battery energy storage system (BESS) - In year 2024, project preparation was underway for the
construction of a large-scale battery storage system in the Czech Republic, with completion planned for late
2025/early 2026. In Germany, pre-project preparation was underway for projects of the same nature but
on a larger scale, with the first project to be completed in 2026. The battery storage system will allow
energy from RES to be stored and subsequently used in periods when conditions for energy generation are
less favourable. The measure thus contributes to the decarbonisation of the supply chain. The measure will
thus contribute to a more efficient use of RES and decarbonisation of business activities. Investments in
BESS amounted to CZK 68.02 million in 2024. In the medium-term (until 2029), investments in the range of
around CZK 2.5 billion are planned. Plans will be further developed in conjunction with the forthcoming
Climate Change Mitigation Transition Plan.
The Group did not implement any actions to address other identified impacts, risks or opportunities in 2024. In
implementing measures, the Group focuses on sustainability matters it considers most material, considering also
the cost of the measures.
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2.2.5 [E1-4] Targets related to climate change mitigation and adaptation
The Group does not have set climate change mitigation and adaptation targets.
11
The Group does not currently plan
to set targets as it is seeking to find an optimal balance in relation to economic costs.
The Group does not specifically monitor the effectiveness of its policies and measures, except for those related to
GHG production associated with exploration and production and commodity consumption. The monitoring of the
effectiveness of policies and measures (for more information see articles 2.2.3 [E1-2] Policies related to climate
change mitigation and adaptation and 2.2.4 [E1-3] Actions and resources in relation to climate change policies) is
carried out through the following processes:
• Environmental aspects assessment - the identified impacts are assigned a remediation or prevention
method (source: Management review
12
+ Environmental Risk Register
13
).
• Review of the relevance of the HSEQ Policy - monitoring the achievement of sub-objectives (conducting
inspections, updating management acts, etc.) (source: Management review).
• Control activities during the planning and execution of drilling operations - establishes processes from
project planning to completion of work. The aim of the processes is to ensure that the site is handed over
free from environmental defects (source: Directive on Protection of Environment).
• Environmental performance assessment - monitoring energy consumption, air pollution (source:
Environmental Performance Assessment).
• Assessment of opportunities for energy reduction (source: Energy Audit).
The purpose of the above processes is to progressively improve the HSEQ level and culture of the Company. For the
purposes of monitoring the effectiveness of the policies and measures, the Group has not set indicators or a
baseline year against which to compare progress.
2.2.6 [E1-5] Energy consumption and mix
The energy consumption and energy mix are presented in the table below. Although energy production is not the
Group's core business, the Group covers a significant part of its energy needs through its energy production. The
energy produced comes from photovoltaic and G2P technologies. The collated data is based on direct
measurements of individual companies
14
and energy suppliers, except for the energy consumption mix associated
with activities in Ukraine. The energy mix of Ukraine was used to determine the estimate of the energy consumption
mix, for more see sectionESRS 2 - General information, Value chain estimation and sources of estimation and
outcome uncertainty. The data was not externally validated.
Table 1: Energy consumption and mix
15
Energy consumption and mix
Unit
2024
1) Fuel consumption of coal and coal products
MWh
0
2) Fuel consumption of crude oil and petroleum products
MWh
15 251.5
3) Fuel consumption of natural gas
MWh
114 196.2
11
These are material impacts, risks and opportunities related to (i) GHG production associated with exploration and production, (ii) RES
production and implementation of innovative technologies, (iii) emissions generated from the production of materials and machinery used,
(iv) commodity consumption and tied emissions.
12
In some entities referred to as a Management Review Report.
13
Only for MND Drilling & Services a.s., MND Energy Storage a.s. and MND Gas Storage a.s.).
14
The same range of companies as in the case of the calculation of GHG emissions of Framework 1 and 2.
15
Totals may vary due to rounding.
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Energy consumption and mix
Unit
2024
4) Fuel consumption of other fossil sources (process, waste and other fuels used for
energy purposes)
MWh
0
5) Consumption of purchased or acquired electricity, heat, steam and cooling from
fossil sources
MWh
6 750.8
6) Total fossil energy consumption (calculated as the sum of items 1 to 5)
MWh
136 198.5
Share of fossil fuels in total energy consumption
%
94.9
7) Consumption from nuclear sources
MWh
4 806.8
Share of consumption from nuclear sources in total energy consumption
%
3.3
8) Consumption of fuels from renewable sources, including biomass (also comprising
industrial and municipal waste of biologic origin, biogas, renewable hydrogen, etc.)
MWh
0
9) Consumption of purchased or acquired electricity, heat, steam, and cooling from
renewable sources
MWh
2 542.0
10) The consumption of self-generated non-fuel renewable energy
MWh
8.5
11) Total renewable energy consumption (calculated as the sum of items 8 to 10)
MWh
2 550.5
Share of renewable sources in total energy consumption
%
1.8
Total energy consumption (MWh) (calculated as the sum of items 6, 7 and 11)
MWh
143 555.8
Energy production
Unit
2024
Energy production from non-renewable sources
MWh
3 624.0
Renewable energy production
MWh
8 066.6
The Group's activities fall within a section with a high impact on climate, NACE Section B - Mining and quarrying
and NACE Section D - Production and distribution of electricity, gas, heat and air conditioning. The total
consumption and energy intensity in these sectors is shown in the table below.
Table 2: Energy intensity
Energy intensity
2024
Total energy consumption of activities in high climate sectors per net revenue from activities in high
climate sectors (MWh/million CZK)
5
Total energy consumption of activities in high climate sectors (MWh)
143 555.9
Items and notes in the financial statements that refer to the values used in the calculation of energy performance
are identified below.
Table 3: Reconciliation of net income to items or information in the financial statements
Net revenue from activities in high climate impact sectors used to calculate energy intensity in
millions of CZK
28 713
Net revenue (other) in millions of CZK
0
Total net revenue (consolidated financial statements) in millions of CZK
28 713
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2.2.7 [E1-6] Gross Scope 1, 2, 3 and total GHG emissions
The Group's gross greenhouse gas emissions in the period under review amounted to 945.5 thousand tCO2eq
(location -based). The vast majority of these emissions are associated with the use of final products (Scope 3). For
a detailed breakdown of GHG emissions by framework and time horizon, see the table below.
Table 4: Group GHG emissions - Scope 1, 2 and 3
16
16
Totals may vary due to rounding.
17
The Group does not produce emissions of biogenic origin. The Group does not record biogenic CO
2
emissions from the combustion or
biodegradation of biomass.
18
The calculation includes GHG emissions (CO
2
, CH
4
, N
2
O, HFCs, PFCs, SF6, and NF3) from installations subject to the EU ETS. The period
covered is the same as the period for which the Sustainability Statement is drawn up.
19
The vast majority of Scope 3 greenhouse gas emissions come from the use of manufactured products - natural gas and oil. Primary data
and supplier data were not used in the calculation of Scope 3 emissions. In the calculation of Scope 3 emissions, only the following GHG
emission categories are reported in detail due to low reliability of external data or insignificance: 3.1 Purchased goods and services, 3.2
Capital goods, 3.4 Transport and distribution upstream of the value chain, 3.5 Waste generated from operational activities, 3.9 Transport
downstream of the value chain, 3.10 Use of products sold, 3.11 Use of products sold, 3.15 Investments.
Retrospective
Milestones and target years
2024
2025
2030
2050
Scope 1 GHG emissions
17
Gross Scope 1 GHG emissions (thousands tCO2eq)
73.7
The group has not yet set targets (see
information in E1-4)
Percentage of Scope 1 GHG emissions from regulated
emissions trading schemes (%)
18
12.8
The group has not yet set targets (see
information in E1-4)
Scope 2 GHG emissions
Gross location-based Scope 2 GHG emissions (thousands
tCO2eq)
6.4
The group has not yet set targets (see
information in E1-4)
Gross market-based Scope 2 GHG emissions (thousands
tCO2eq)
9.1
The group has not yet set targets (see
information in E1-4)
Gross market-based Scope 2 GHG emissions (including
Certificate of guaranteed origin) (thousands tCO2eq)
8.9
The group has not yet set targets (see
information in E1-4)
Significant scope 3 GHG emissions
19
Total Gross indirect (Scope 3) GHG emissions (thousands
tCO2eq)
865.2
The group has not yet set targets (see
information in E1-4)
1 Purchased goods and services
13.2
The group has not yet set targets (see
information in E1-4)
2 Capital goods
1.3
The group has not yet set targets (see
information in E1-4)
3 Fuels and energy-related activities
10.5
The group has not yet set targets (see
information in E1-4)
4 Upstream transportation and distribution
1.7
The group has not yet set targets (see
information in E1-4)
5 Waste generated in operations
15.0
The group has not yet set targets (see
information in E1-4)
9 Downstream transportation
0.6
The group has not yet set targets (see
information in E1-4)
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The reporting thresholds considered, the calculation methods for estimating GHG emissions and the tools used are
set out in the Group's GHG Report. The Group monitors emissions of CO
2
, CH
4
and N
2
O and emissions of other GHGs
are negligible. In calculating GHG emissions, the Group follows the GHG Protocol and ISO 14064-1 hierarchy of
inputs and emission factors. The following sources were used to determine the emission factors: the UK DEFRA,
EIB, UNFCC, the City of Prague Carbon Footprint Calculation and the Institute of Circular Economy, Orlen Unipetrol
The Group used the following contractual instruments in connection with the calculation of the scope 2 GHGs:
Table 5: Overview of contractual instruments
Name of the contractual instrument
Share of Scope 2
market-based (%)
Contractual instruments used for the sale and purchase of energy associated with attributes
regarding energy production
1.9
Certificate of guaranteed origin for the supply of ecologically produced electricity (EU EECS GO)
1.9
Contractual instruments used for the sale and purchase of energy associated without attributes
regarding energy production
0
Below are the total greenhouse gas emissions by country.
Table 6: Group GHG emissions by country
20
Total GHG emissions by country in 2024 (thousands tCO2eq)
Czech
Republic
Ukraine
Austria
Scope 1 gross GHG emissions
73.4
0.3
0
Scope 2 gross GHG emissions (location-based)
6.2
0.3
0
Scope 2 gross GHG emissions (market-based)
8.8
0.3
0
Scope 2 gross GHG emissions (market-based, including Certificate of
guaranteed origin)
8.6
0.3
0
Scope 3 gross GHG emissions
725.1
139.9
0.4
Total GHG emissions (location-based)
804.6
140.5
0.4
Total GHG emissions (market-based)
807.2
140.5
0.4
Total GHG emissions (market-based, incl. Certificate of guaranteed origin)
807.1
140.5
0.4
20
Totals may vary due to rounding.
Retrospective
Milestones and target years
2024
2025
2030
2050
10 Processing of sold products
38.2
The group has not yet set targets (see
information in E1-4)
11 Use of sold products
784.1
The group has not yet set targets (see
information in E1-4)
15 Investments
0.6
The group has not yet set targets (see
information in E1-4)
Total GHG emissions
Total GHG emissions (location-based) (thousands tCO2eq)
945.5
The group has not yet set targets (see
information in E1-4)
Total GHG emissions (market-based) (thousands tCO2eq)
948.1
The group has not yet set targets (see
information in E1-4)
Total GHG emissions (market-based) (including Certificate of
guaranteed origin) (thousands tCO2eq)
947.9
The group has not yet set targets (see
information in E1-4)
I I
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The Group follows the definition of a value chain given in the value chain description (see sectionESRS 2 - General
information, article 1.3.2[SBM-1] Value chain). The Group discloses sustainability information for the first year, and
in subsequent sustainability statements the Group will indicate whether the reported data is comparable. The
reporting of GHG emissions is identical to the date of the financial statements. Thus, there have been no significant
events and circumstances in the interim period that have had an impact on the reported GHG emissions for the
reporting period. The GHG intensity for the Group is presented below.
Table 7: GHG intensity per net revenue
GHG intensity per net revenue
2024
Total GHG emissions (location-based) per net revenue (tCO2eq / million CZK)
32.9
Total GHG emissions (market-based) per net revenue (tCO2eq / million CZK)
33.0
Total GHG emissions (market-based, including Certificate of guaranteed origin) per
net revenue (tCO2eq / million CZK)
33.0
Items and notes in the financial statements that refer to the values used in the calculation of GHG intensity are
identified below.
Table 8: Relationship between net income used and items/notes in the financial statements
Net revenue used to calculate GHG intensity
Item or note in the financial
statements
Net revenue used to calculate GHG intensity in millions of CZK
28 713
Net revenue (other) in millions of CZK
0
Total net revenue (in financial statements) in millions of CZK
28 713
2.2.8 [E1-7] GHG removals and GHG mitigation projects financed through carbon credits
The Group was not involved in any projects related to the removal or storage of greenhouse gases in 2024. There
were no activities of the Group's own or outside the value chain that were financed through the purchase of carbon
credits. The Group has not set a net zero emissions target.
In the future, the Group is considering the acquisition of carbon capture and storage (CCS) technologies, see more
in article 2.2.4 [E1-3] Actions and resources in relation to climate change policies.
2.2.9 [E1-8] Internal carbon pricing
The Group does not currently operate an internal carbon pricing system as defined in the ESRS. The introduction of
internal carbon pricing is under consideration, however with no specific timing.
2.2.10 [E1-9] Anticipated financial effects from material physical and transition risks and potential
climate-related opportunities
The Group has prepared the Climate Risk Analysis.
As the E1-9 disclosure requirement is a phase-in requirement under the ESRS, the Group took the option to omit
the prescribed disclosures when preparing the sustainability statement for the year 2024. The selected information
will be disclosed in the next sustainability statement, i.e. the sustainability statement for the year 2025.
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2.3 E2 - Pollution
The subtopic E2 - Substances of (very high) concern was identified as material for MND a.s., MND Drilling & Services
a.s., MND Energy Storage a.s., MND Gas Storage a.s. and Horyzonty LLC based on the double materiality assessment.
These companies will hereinafter be referred to as "E2 Relevant Companies" in accordance with the definition
established in ESRS 2 - General information, article 1.4 [IRO-1] Description of the processes to identify and assess
material impacts, risks and opportunities.
2.3.1 [E2-1] Pollution policies
E2 Relevant Companies handle substances of (very high) concern during their daily activities. Improper handling of
these substances could lead to environmental pollution and damage to health. Therefore, individual E2 Relevant
Companies regulate the management of chemicals (including substances of (very high) concern) through internal
directives. The directives include the definition of roles and responsibilities of users of chemicals -
storage/registration, transport and disposal. The directives also indicate procedures in the event of a spill or
accident. Senior staff or staff designated by them are responsible for ensuring compliance with the directives. The
adopted directives are in accordance with ISO 14001 Environmental Management System and ISO 45001
Occupational Health and Safety.
An overview of the directives in the E2 Relevant Companies is provided inTable 1. Employees of the E2 Relevant
Companies have access to the directives through a shared internal drive.
These directives are designed to comply with relevant legal regulations and minimise potential environmental and
health impacts. The environmental policy of the E2 Relevant Companies also emphasises the safe management of
chemicals. When working with chemical substances, employees must be familiar with the applicable health and
safety rules.
There is no common policy implemented at Group level focused on reducing the impact associated with the use of
substances of (very high) concern, including replacing and minimizing their use or phasing them out.
Table 1 : Overview of policies, registers and ISO standards in place by company
MND Drilling &
Services a.s.
MND Energy
Storage a.s.
MND Gas Storage
a.s.
MND a.s.
Horyzonty LLC
Management of
chemicals
SM 06-5021/04
Management of
chemical
substances and
chemical mixtures
Directive No. 405
/23
Management of
chemical
substances and
mixtures
Directive No
425/24
Management of
chemical
substances and
mixtures
Directive 020
Chemical
substances and
mixtures
No (only
compliance with
legal requirements
ensured)
ISO 14001
Yes
Yes
Yes
Yes
No (only
compliance with
legal requirements
ensured)
ISO 45001
Yes
Yes
Yes
Yes
No (only
compliance with
legal requirements
ensured)
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2.3.2 [E2-2] Actions and resources related to pollution
MND a.s. used a substance of very high concern - glutaraldehyde
21
- as a part of a pilot project carried out at a single
extraction site. For technical reasons, this project, including the use of glutaraldehyde, was suspended in mid-2024.
This led to a reduction in the potential negative impact associated with the use of substances of (very high) concern.
As part of the internal assessment of the restart of this pilot project, MND a.s. plans to assess the possibility of
replacing glutaraldehyde with another substance with lower risks. There are no significant financial or other
resources associated with the suspension of use of this substance. Reducing the use of other substances of concern
or substituting them would not be effective due to the low volumes, however, the E2 Relevant Companies monitor
the quantities of these substances in their operations.
As part of its established preventive measures, MND a.s. prepared a Register of Safety Objectives and Programmes
for 2024, which includes plans for specific pipeline replacements, repairs of containment sumps, and the
decommissioning of old wells and equipment. The main benefit of these replacements and modifications is to
reduce the risk of release of hazardous substances, including substances of concern. These precautionary measures
are and will be implemented on an ongoing basis throughout the extraction activities. Anticipated investments in
this area are planned within the standard capital and operating expenditures of E2 Relevant Companies. In relation
to the Register of Safety Objectives and Programmes, planned investments in year 2025 will amount to around CZK
99 million.
2.3.3 [E2-3] Targets related to pollution
E2 Relevant Companies have not set any specific risk reduction targets for the use of substances of (very high)
concern. The Group does not monitor the effectiveness of its measures and policies, except for monitoring the
quantity of substances used. For the purposes of monitoring the effectiveness of policies and measures, the Group
has not set indicators or a baseline year against which to compare progress.
2.3.4 [E2-5] Substances of concern and substances of very high concern
The Group decided to suspend the use of glutaraldehyde as of mid-2024 (see article 2.3.2 [E2-2] Actions and
resources related to pollution), so currently it does not use any substances of very high concern (SVHCs). Substances
of high concern (SHCs) continue to be used within the operations. These substances (e.g. cement, petroleum,
natural gas condensate, methanol, motor oil, diethylene glycol) are used in drilling, mining and other support
activities and, in case of their leaks into the environment, they could (depending on the type of substance leaked)
cause damage to health, soil, water and air pollution. The Group continuously strives to eliminate the risks of leaks.
Individual E2 Relevant Companies also keep records of substances used in accordance with the European Pollutant
Release and Transfer Register (E-PRTR).
22
The quantity of pollutants includes annual production or consumption in
tonnes. The scope of the register includes all E2 Relevant Companies. Any reporting of exceedances of limit values
is linked to the specific site at which the limit was exceeded.
21
The substance glutaraldehyde was used in the Group's operations at a single mining site as part of a pilot project and exclusively in a closed
process system. The closed system significantly reduces the risk of harm to the health of persons, with which the risk of this substance is
closely associated.
22
European Pollutant Release and Transfer Register (E-PRTR) | EUR-Lex
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Table 2: Overview of substances of concern at the Group's operations in 2024
23
Unit
Used
24
Sold
25
Emitted
26
In the form of
a product
Total quantity of substances of concern
kg
66 215 775
65 383 417
5 653
65 383 417
Carcinogenicity category 1 and 2
kg
65 367 312
65 363 647
2 065
65 363 647
Germ mutagenicity category 1 and 2
kg
920 647
920 647
0
920 647
Reproductive toxicity category 1 and 2
kg
0
0
1 053
0
Disruption of the endocrine system for human
health
kg
0
0
0
0
Disruption of the endocrine system for the
environment
kg
0
0
0
0
Persistent, mobile and toxic or highly persistent
and highly mobile properties
kg
0
0
0
0
Persistent, bioaccumulative and toxic or highly
persistent and highly bioaccumulative
properties
kg
0
0
0
0
Category 1 respiratory sensitisation
kg
0
0
0
0
Skin sensitisation category 1
kg
758 705
2 705
0
2 705
Chronic aquatic hazard category 1 to 4
kg
65 386 929
65 363 647
4 599
65 363 647
Danger to the ozone layer
kg
0
0
0
0
Specific target organ toxicity - repeated
exposure, category 1 and 2
kg
42 725
17 065
5 653
17 065
Specific target organ toxicity - single exposure,
categories 1 and 2
kg
29 480
0
0
0
Table 3: Overview of substances of very high concern at the Group's operations in 2024.
Unit
Total used
27
Total quantity of substances of very high concern
kg
125
Carcinogenicity category 1 and 2
kg
0
Germ cell mutagenicity category 1 and 2
kg
0
Reproductive toxicity category 1 and 2
kg
0
Disruption of the endocrine system for human health
kg
0
Disruption of the endocrine system for the environment
kg
0
Persistent, mobile and toxic or highly persistent and highly mobile properties
kg
0
Persistent, bioaccumulative and toxic or highly persistent and highly bioaccumulative
properties
kg
0
23
Any discrepancy between the quantities of substances listed in the “Used”, “Sold”, “Emitted”, “In the form of product” columns is due to
a change in the properties of the substances concerned during their use (i.e. the use of the substance of concern ceases to be in the group
of substances considered to be substances of concern as defined by the ESRS).
24
The total amount of substances of concern that are generated⁠ or used in production or that are procured.
25
The total amount of substances of concern that were sold as products, product ingredients or released into the environment in the past.
26
The total amount of substances of concern that leave the plant as emissions.
27
The total amount of substances of concern that are generated⁠ or used in production or that are procured.
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Unit
Total used
27
Category 1 respiratory sensitisation
kg
125
Skin sensitisation category 1
kg
125
Chronic aquatic hazard category 1 to 4
kg
125
Danger to the ozone layer
kg
0
Specific target organ toxicity - repeated exposure, category 1 and 2
kg
0
Specific target organ toxicity - single exposure, categories 1 and 2
kg
0
2.4 E3 - Water and marine resources
Reductions in water availability and quality and potential deterioration of hydrological conditions are significant
due to drilling and exploration and production activities, particularly due to injection of water into wells. These
impacts
28
were identified as relevant to MND a.s. (Czech Republic) and MND Drilling & Services a.s. (Czech Republic)
based on the double materiality assessment. These companies will be referred to hereafter as "E3 Relevant
Companies" in accordance with the definition established in ESRS 2 - General information, article 1.4 [IRO-1]
Description of the processes to identify and assess material impacts, risks and opportunities.
2.4.1 [E3-1] Policies related to water resources
E3 Relevant Companies set the following directive in relation to the identified material impacts (i.e. reduction in
water availability and quality and potential deterioration of hydrological conditions due to water withdrawal and
consumption):
• Directive on Protection of Environment - the directive regulates the processes associated with the
withdrawal of drinking water and the discharge of wastewater and describes the management of hazardous
substances to prevent leakage into surface water or groundwater. Finally, it defines the obligations and
activities related to flood protection. The directive was implemented by all E3 Relevant Companies. The
directive also describes the source and use of water, its treatment and pollution reduction. The directive
aims to reduce water consumption. As the Group does not operate in areas of high-water stress, the
directive does not provide a specific commitment for this topic. The implementation of the directive is
mainly the responsibility of the heads of the organizational units. The up-to-date version of the directive is
available on the shared internal drives of E3 Relevant Companies.
The wording of the Directive on Protection of Environment is not identical in all E3 Relevant Companies. Minor
differences are due to the specificities and activities of the company in question and are listed below:
• MND Drilling & Services a.s. (Czech Republic) - The directive regulates the withdrawal of drinking water and
discharge to wastewater and lists the required permits and consents of the water management authority.
It also describes the activities associated with the operation of a WWTP from a car wash.
• MND a.s. (Czech Republic) - similar to the MND Drilling & Services a.s. directive, it lists the permits and
consents of the water management authority and rules for handling hazardous substances. The monitoring
system tracks surface/groundwater samples and gas leaks from the subsurface through monitoring wells.
The directive also establishes the obligation to control water quality and regulates wastewater
management.
28
For a more detailed description, see ESRS Part 2 - General Information, Article 1.4 [IRO-1] Description of the procedures for identifying and
assessing significant impacts, risks and opportunities
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2.4.2 [E3-2] Actions and resources related to water resources
In the past year, the companies continued to take action to reduce water withdrawal and consumption and improve
water quality. Specifically, MND Drilling & Services a.s. reduces its water consumption by reusing some water for
its activities in the Czech Republic
29
. The water used to create the drilling fluid, which is necessary during drilling to
bring the rock to the surface, undergoes treatment so that it can be reused in the next drilling process. This is a
long-term measure and MND Drilling & Services a.s. will continue to recycle water in future years. The company
only monitors its total water consumption and does not have information on the water savings achieved solely due
to this measure. The costs associated with the saving measure are part of normal operating expenses; the measure
does not require significant operating or capital expenditures. The companies do not plan to reduce or increase
these operating expenses in the future.
Due to the unavailability of a suitable technological solution, MND currently does not implement specific measures
aimed at water availability and quality and the associated potential change in hydrological conditions.
2.4.3 [E3-3] Targets related to water resources
The E3 Relevant Companies did not set any targets in relation to the identified material impacts (i.e. reduction in
water availability and quality and potential deterioration of hydrological conditions due to water withdrawal and
consumption).
The effectiveness of the relevant directive and measures is monitored through water consumption trends, which is
tracked by the E3 Relevant Companies based on invoices provided by suppliers. The E3 Relevant Companies have a
long-term goal to reduce water consumption but have not set a baseline year or a value against which the progress
would be measured.
2.4.4 [E3-4] Water consumption
In 2024, the Group consumed a total of 19 572 m
3
of water from the water supply system. Water consumption is
within legal limits, so none of the Group companies are under increased regulatory scrutiny. The Group primarily
uses water in exploration and production processes, particularly to inject water into wells. Water injection into
wells is a practice associated with oil production; in Ukraine, water injection is not used as at these sites only natural
gas is being extracted. When establishing the data, the Group relies mainly on direct measurements and data
provided by water suppliers. Estimates are used to determine water consumption and withdrawal only in specific
cases - operations of MND (Trading Division) and MND Energie a.s. (indirect calculation - estimate based on data
from year 2023). The Group does not withdraw water from surface water or groundwater, for this reason the Group
does not monitor the water quality in the catchment areas. Should water discharge be restricted by a local
regulator, the Group has the ability to secure water withdrawals from other locations.
Table2 : Water consumption for the Group in 2024
Water consumption
Unit
2024
Total water consumption
m
3
19 572
Water consumption intensity ratio
m
3
/ million EUR
30
17.1
Total volume of reused and recycled water
m
3
1 018
Total volume of water stored at the beginning of the reporting period
m
3
0
Total volume of water stored at the end of the reporting period
m
3
0
29
South Moravian and Zlín regions, i.e. areas with water risk
30
Net income from own operating activities.
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Water consumption
Unit
2024
Changes in water supplies
m
3
0
Water withdrawals - total
m
3
30 013
Water withdrawal - from surface water
m
3
0
Water withdrawal - from groundwater
m
3
36
Water withdrawal - from third party water (refers to municipal water suppliers
and municipal wastewater treatment plants, public or private utilities and other
organisations involved in water and wastewater use)
m
3
29 977
The group does not consume water in areas of high-water stress.
31
2.5 E5 - Resource use and circular economy
Drilling activities, exploration and production activities lead to the depletion of non-renewable resources and the
production of waste. In addition, drilling and extraction activities produce waste (sludge, reagents, etc.) which
contributes to environmental pollution.
These impacts
32
were identified as relevant for the companies of the Group: MND Drilling & Services a.s., MND a.s.
and Horyzonty LLC. These companies will be referred to hereafter as "E5 Relevant Companies" in accordance with
the definition established in ESRS 2 - General information, article 1.4 [IRO-1] Description of the processes to identify
and assess material impacts, risks and opportunities).
2.5.1 [E5-1] Policies related to resource use and circular economy
The E5 Relevant Companies do not have policies that would specifically govern resource inflows. The main resource
inflow is from extraction itself, which is part of the business model of the Group. The level of extraction depends
on extraction plans.
The E5 Relevant Companies adopted general directives governing waste management (HSE Directive 508 on
Protection of Environment (MND a.s.), Directive on Protection of Environment in MND D&S (MND Drilling & Services
a.s.), Environmental Policy Directive (Horyzonty LLC)). The company’s environmental officer is responsible for the
preparation and updating of these directives, while the heads of individual sites are responsible for their
implementation.
In its directive, MND a.s. governs waste management, specifically waste prevention, collection, subsequent
transport and evidence. The text of the directive is available to all employees at the shared drive.
The MND Drilling & Services a.s. directive governs waste management, especially the obligations related to waste
disposal and take-back of products. The directive also specifically addresses the record-keeping of packaging waste
placed on the market. The text of the directive is available to all employees at the shared drive.
At MND Drilling & Services a.s., the Environmental Protection Directive is supplemented by the Waste Management
and Waste Registration Directive. Wastes generated in the Czech Republic such as drilling muds, waste from
underground well repairs or hazardous waste from the activities of MND Drilling & Services a.s. These are first
collected at the individual operations and then transported to the waste storage and treatment facility at the
Environmental Centre in Lužice. Records are kept for each operation and for each type of waste separately. The
31
A water stressed area is an area where there is a high demand for water due to human activities compared to the availability of water
resources. See https://www.wri.org/applications/aqueduct/water-risk-atlas for more information.
32
inESRS 2 - General information, article 1.4[IRO-1] Description of the processes to identify and assess material impacts, risks and
opportunities
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overall responsibility for keeping central records and reporting waste to the relevant administrative authorities lies
with the environmental officer and the head of HSEQ. Waste records and reporting are kept through the ENVITA
software. The text of the directive is accessible to all employees at the shared drive. MND a.s. and MND Drilling &
Services a.s. manage waste in accordance Act No. 541/2020 Coll., on Waste, as amended (the "Waste Act"),
ensuring efficient and responsible waste management in accordance with the legislative standards. The companies
ensure that all processes comply with current legislation, thereby eliminating the risk of penalties for non-
compliance. In addition to the Waste Act, the Companies also comply with other relevant legislation, in particular
with obligations under the water act, act on environment, the environmental damage act and other legal
regulations.
In the operations in Ukraine (Horyzonty LLC) the Ecological Policy Directive is applied. It, among other things,
addresses resource inflows and waste management. To ensure environmental safety, the directive stipulates that
the volume of waste reused - specifically fly ash, slag and rock - should be increased. Waste management should
be carried out in an environmentally safe manner. However, the directive does not specify what type of wastes
management is involved. The individual site managers are responsible for implementation of the directive.
2.5.2 [E5-2] Actions and resources related to resource use and circular economy
A significant type of waste generated by the activities of the E5 Relevant Companies is extraction waste, which may
be contaminated with hazardous substances. Further, there is also waste that can be used for technical stabilisation
of the landfill or reclamation. The structure and volume of waste generated also depends on the extracting activity
itself. Companies do not have measures in place to reduce the volume of extraction waste. The volume of extraction
waste depends on the extraction plans, the Group plans to continue in its extraction activities.
Neither the Group nor the E5 Relevant Companies have set measures related to resource inflows. The main
resource inflows are commodities, the extraction of which is part of the business model of the Group.
2.5.3 [E5-3] Resource use and circular economy targets
Neither the Group nor the E5 Relevant Companies have set any targets for resource inflows and extraction waste
production. The effectiveness of existing policies is currently only monitored through the maintenance of records
of the volume of waste extracted. The Group has not yet set qualitative and quantitative parameters associated
with assessing progress in these areas. Thus, the Group does not monitor progress compared to previous years.
2.5.4 [E5-4] Inflow of resources
Within the Group, the key inflow to operations is the extracted crude oil and natural gas that is being transported,
stored and sold. The quantities of crude oil and natural gas extracted are shown in the table below. The figures
presented are based on direct measurements taken by measuring instruments installed at the extraction facility.
Table 1: Quantities of extracted crude oil and natural gas
Inflow of resources
Unit
Value
Crude oil
m
3
74 935
Natural gas
m
3
146 072 725
2.5.5 [E5-5] Resource outflows
The raw materials that flow from the Group to the market are primarily crude oil and natural gas. A total of 74,935
m
3
of crude oil and 146 072 725 m
3
of natural gas passed through the Group. The vast majority (138 062 425 m
3
) of
the natural gas supplied to third parties for use, while the remaining portion was used for own consumption,
including the operation of technological equipment.
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See Table 2 below for greater detail on resource outflows.
Table 2: Waste
Waste
Unit
Value
Total amount of waste produced
t
10 734
Total HAZARDOUS waste diverted from disposal
t
3 870
Hazardous waste diverted from disposal as a result of preparation for re-use
t
3 829
Hazardous waste diverted from disposal due to recycling
t
0
Hazardous waste diverted from disposal due to other recovery operations
t
41
Total NON-HAZARDOUS waste diverted from disposal
t
1 502
Non-hazardous waste diverted from disposal as a result of preparation for re-use
t
22
Non-hazardous waste diverted from disposal due to recycling
t
1 434
Non-hazardous waste diverted from disposal due to other recovery operations
t
46
Total HAZARDOUS waste for waste treatment
t
1 754
Hazardous waste for incineration
t
0
Hazardous waste for landfill
t
19
Hazardous waste for other disposal operations
t
1 735
NON-HAZARDOUS waste for waste treatment
t
3 608
Non-hazardous waste for incineration
t
1
Non-hazardous waste for landfill
t
3 551
Non-hazardous waste destined for other disposal operations
t
56
NON-RECYCLED waste
t
9 300
NON-RECYCLED waste
%
86.6
Total amount of hazardous waste
t
5 624
Total amount of non-hazardous waste
t
5 110
The following waste streams are significant for the Group:
• Drilling waste - extraction residues generated during oil and gas exploration and production. The main types
of drilling waste include drilling fluids and interphase mixtures, particles of crushed rock sand, mud and clay
formed by the action of the rotary drill when penetrating the surface. If metal material stored in the
subsurface (e.g. metal supports from the repair or decommissioning of a well), is disposed of as metal
waste, it must be radiometrically tested for radioactivity (i.e. for radioactive residues) before it is sold. It is
the responsibility of the site manager to ensure that the waste is radiometrically tested, and the radiometric
test is carried out by a person authorised to do so. The site manager is also responsible for ensuring that
metal waste is sorted when it is handed over.
• Construction waste - waste is also generated during the construction process, and to a lesser extent during
operation, routine maintenance, filling changes or cleaning of machinery and equipment. Construction
waste, machine parts, transformers or other electrical equipment are also mainly generated at the end of
the life cycle of operational equipment.
• Hazardous Waste - The Group follows local legislative classifications for categorising hazardous waste. This
waste is directed for disposal through incineration, landfill and other disposal operations.
The calculations, criteria and methodology for proper waste record keeping are based on legislative requirements
arising from Act No. 541/2020 Coll., on waste, as amended. The Group obtains data on the quantity of waste from
entities that are authorised to manage waste. Estimates were used to calculate waste quantities only in specific
cases - for operations of MND (Trading Division) and MND Energie a.s. (indirect calculation - estimate based on data
from year 2023).
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3 Social information
3.1 S1 - Own workforce
3.1.1 [S1.SBM-3] Material impacts, risks and opportunities and their interaction with strategy and
business model
During the double materiality assessment, the Group identified five negative and two positive impacts in the areas
of working conditions and equal opportunities and treatment for all. These impacts relate exclusively to the Group's
own operations along the value chain. All employees in the Group were considered, regardless of geographical
location, type of employment or division. A detailed list of material impacts, including the time horizon and
information on their location in the value chain, is described in ESRS 2 - General information, article 1.3.4 [SBM-3]
Material impacts, risks and opportunities and their interaction with strategy and business model. The impacts
identified are based on the Group's business model, i.e. the sector in which the Group operates. Based on the
double materiality assessment, the Group will formalise working practices and processes to target the prevention
and mitigation of negative impacts.
In accordance with the Labour Code, a work-related risk analysis has been developed across the Czech companies
of the Group that identifies potential work-related health and safety risks for specific job categories. This
classification is described in detail in internal directives and was developed in accordance with legislative
requirements, including consultation with public health authorities.
Based on the Group's aforementioned work-related risk analysis, it was found that workers in the oil and gas
extraction, drilling and servicing sectors, as well as in the operation and construction of renewable energy plants,
are more susceptible to several identified negative impacts. The first is the reduced social protection due to
excessive working hours, which is caused by the continuous operation of some sites and by remote workplaces or
commuting abroad. Another negative impact assessed is the deterioration in the health and safety of the workforce
resulting from the nature of the sites. The last negative impact identified is gender inequality, which is caused by
the low percentage of women working in the oil and gas sector.
The majority of the Group's workforce are employees. These include operational and administrative staff. To a
limited extent (not systematically, only where such a form of contract is appropriate and mutually beneficial), the
Group companies use workers under agreement on performance of work and agreement on work activity. Agency
workers are not used by Group companies, which minimises the risk of human rights violations. Contractors (self-
employed persons), especially in the service operations, operate within the European Union, where the main
potential negative impact is work-related safety and injury rates, while other risks of human rights violations are
minimised by legislation. The security agencies do not show any risks of rights violations.
The Group operates mainly in the Czech Republic, where it is subject to a complex legal framework and the local
legislation enforces strict standards for the protection of human and employee rights. The Group's activities comply
with these national requirements and obligations, which minimise the risk of forced and child labour.
The double materiality assessment also identified positive impacts related to improving the well-being of the
workforce itself in two different areas: work-life balance (system and policy offering benefits) and social dialogue.
This overall impact, as well as the related activities, apply to the Group as a whole regardless of sector or country
of operation.
All employees are transferred to a permanent contract after the end of their fixed-term contract within the first
year, which provides high social protection. At the same time, the Group offers its employees a superior number of
benefits that exceed the legal requirements in the respective countries. However, these vary depending on the type
of company and the country in which it is located. There is also a regular social dialogue across the Group, which
takes place both formally and informally through various communication channels. Within these channels, the
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Group uses, for example, an intranet that is available to all employees
33
and also publishes an information magazine
and reports that are also available to all employees. There are also meetings with labour unions, employee surveys
and annual conferences. For companies like MND Drilling & Services a.s. communication is informal and takes place
directly between employees and employers during working hours. No risks or opportunities associated with own
workforce were identified as a result of the double materiality assessment.
In line with current and forthcoming sustainability legislation, the Group will strive to reduce its negative
environmental impact over the long-term. Currently, the Group does not perceive any material impacts on its own
workforce as a result of the transition to a low carbon economy.
3.1.2 [S1-1] Policies related to own workforce
The Czech Republic is a signatory to most of the major human rights treaties and reflects its commitments primarily
in the Charter of Fundamental Rights and Freedoms, which is the cornerstone of the Czech constitutional
framework and guarantees fundamental human rights and freedoms, including civil, political, economic, social and
cultural rights. The Group's policies are not directly based on the UN Guiding Principles on Business and Human
Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for
Multinational Enterprises. However, the Group complies with applicable laws and regulations and the protection
of human rights is an integral part of all its activities.
Similarly, the Group seeks to ensure that its activities in Ukraine meet human rights standards that are consistent
with Czech law. While there are some differences between the legislative frameworks of the two countries, the
Group actively seeks to compare and harmonise practices to bring Ukrainian conditions as close as possible to those
of the Czech Republic. In certain areas, such as leave and employee benefits, these differences are being equalised,
which contributes to ensuring fair and equal working conditions for all employees. In this way, the Group promotes
the protection of human rights and ensures that its activities in both countries are in line with international
standards and obligations.
There are also a number of policies across the Group that strongly reflect protection of human rights and general
attitudes towards their own workforce.
Code of Ethics of MND Group
The Code of Ethics of MND Group is described in detail in Governance information, article 4.1.1 [G1-1] Business
conduct policies and corporate culture and reflects the Group's general approach to respecting the human rights of
its own workforce.
The Code of Ethics of MND Group explicitly prohibits discrimination, in particular discrimination based on gender,
disability, family situation, sexual orientation, age, political opinion, race, religion or origin. It also explicitly prohibits
any form of harassment in the workplace, forced or illegal labour, child employment, etc. The Code of Ethics of
MND Group and other Group policies do not set out commitments related to, and are not explicitly aimed at,
reinforcing positive actions towards certain groups of employees who may be more affected by negative impacts.
This policy is implemented in the Group through employee training and its effectiveness is monitored through the
Compliance System.
Occupational Health and Safety ("OHS")
The Group places great emphasis on ensuring occupational health and safety to minimise the associated negative
impact on employees, which is embedded in its OHS system. Employees are required to behave in the manner that
does not endanger their own or others' safety and health, to comply with established work procedures, regulations
and employer's instructions, and to use designated work equipment and personal protective equipment. The OHS
33
Except for companies in Ukraine.
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policy also includes mandatory training of employees and subsequent verification of their knowledge, informing
supervisors of defects and hazards found in the workplace and reporting workplace accidents. The OHS system is
in accordance with ISO 45001 standards
34
and is part of an integrated HSE/HSEQ management system.
The statutory bodies of the relevant Group companies and the directors of the relevant divisions are the highest
level in the organisation responsible for the implementation of and compliance with the HSE policy. They work with
the management representative for HSE/HSEQ to formulate the relevant company's HSE policy and objectives,
approve internal regulatory documents, mandate the implementation of HSE inspections at all Group companies'
workplaces and provide resources to maintain and improve the HSE management system.
The Occupational Health and Safety Policy applies to all employees of the Group, as well as to all persons who are
present at the Group's workplaces with the knowledge of the employer. This ensures that occupational health and
safety is an integral part of all Group activities and that all employees are aware of their obligations and rights in
this area.
Work Regulation
The Group places great emphasis on compliance with the working regulations, which are binding on all employees
and employers. The Work Regulation is issued to improve work organisation, internal order and to strengthen work
discipline. This regulation covers a wide range of duties and responsibilities for both employees and managers of
the respective Group companies.
The Work Regulation and other related internal regulations cover various aspects of the employment relationship
and their related implications, including working hours, work-life balance, occupational health and safety, and rules
of conduct in the workplace.
The highest level in the organisation responsible for the implementation of the Work Regulation are the statutory
bodies or directors of the individual companies in the Group. The heads of the various departments are responsible
for issuing, implementing and updating the Work Regulations, as well as for familiarising employees with it.
The Work Regulation is not targeted at any particular group of employees but applies to all employees across all
companies. This ensures that occupational health and safety is an integral part of all company activities and that all
employees are aware of their obligations and rights in this area.
Privacy Policy
The data protection regulations set out the rules for the protection and processing of personal data, in particular
of employees, as well as other persons (including, for example, customers of MND Energie a.s., as described in more
detail in Social information, article 3.2 S4 - Consumers and end-users), in accordance with Regulation (EU) 2016/679
of the European Parliament and of the Council (GDPR) and applicable generally binding regulations of the Czech
Republic.
The regulation includes key principles relating to the processing of personal data that require personal data to be:
• processed in a fair, lawful and transparent manner;
• collected for specific, explicit and legitimate purposes;
• adequate, relevant and limited to the extent necessary;
• accurate and updated where necessary;
• stored for no longer than necessary;
• processed in a way that ensures appropriate security.
The Group shall organise training sessions at least once every 2 years and carry out regular reviews of these key
principles.
34
Applicable to MND a.s., MND Energy Storage a.s., MND Gas Storage a.s. and MND Drilling & Services a.s.
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The regulation is binding for all employees of the Group who, in the course of their work, handle or otherwise come
into contact with the personal data of other employees of the Group or other persons who provide their personal
data to the Group. Responsibility for the document rests with the director of the relevant company.
Remuneration policies
The Group's remuneration policies are closely linked to the collective agreements of the relevant companies, but
even where there is no collective agreement, these policies apply to all employees. These policies describe in detail
the remuneration systems of the companies and in this way the Group addresses the potential impact associated
with the pay gap between men and women in the same position and performing equivalent work.
Responsibility for the practical implementation of the remuneration policy lies with the HR departments of the
respective companies, which also ensure compliance with the rules and procedures set out in the relevant policy
or relevant collective agreement. The policies are approved by the statutory bodies or directors of the companies
concerned, who are also responsible by virtue of their position for compliance. The remuneration policies apply to
all employees across different job roles, which are categorised into several basic groups: worker positions, technical
and administrative positions - ADMIN, THP specialists, lower management, middle management and TOP
management. Each role has specific characteristics, responsibilities and requirements that affect their
remuneration. In this way, the Group ensures that remuneration is fair and meets both legislative requirements
and internal standards, contributing to overall employee satisfaction and motivation.
Collective agreements
The Group companies MND a.s., MND Drilling & Services a.s. and MND Energy Storage a.s. entered into collective
agreements with employee representatives (the Works Council of the PHGN Labour Union) that ensure that the
rights of their employees are respected. These agreements have a positive impact on employees in the area of the
social dialogue and include ensuring the fair working conditions including remuneration, benefits beyond those
required by law, occupational health and safety issues, promotion of labour union rights and social dialogue, and
guaranteeing equal opportunities without discrimination. They also lay down the conditions for the creation,
purpose and use of the Social Fund.
The Group does not have specific policies aimed at increasing gender balance considering the context of the oil and
gas sector, nor at increasing the proportion of women in top management.
3.1.3 [S1-2] Processes for engaging with own workforce and workers’ representatives about impacts
Cooperation with employees is one of the key aspects for the Group and is embedded in the Group's internal
regulations and other management documents. Although practices vary across the Group, there is always an
emphasis on open communication and active employee participation in decision-making processes. Within some
companies, a labour union is present to represent the interests of employees in co-decisions on the issuance of
work regulations, its amendments and related regulations, allowing employees to voice their opinions on their
working conditions.
The Group uses various channels of communication with its employees to ensure an effective and transparent
dialogue. The intranet is available to all employees.
35
At the same time, the Group publishes the MND Report
magazine, which is published quarterly in print and electronically (on the intranet) so that it is easily accessible to
all Group employees. In each of the Group's companies, face-to-face or online meetings with management on key
issues relating to the working environment, working conditions and economic performance (at once a year),
meetings with labour unions and employee surveys are held as required and in accordance with established
corporate processes. For most employees of Group companies, there is an opportunity to submit a suggestion or
35
except for companies in Ukraine.
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prevention card if they identify a near-miss, unsafe condition or behaviour, or if they have a suggestion for
improvement, the opportunity to communicate this via a feedback box or e-mail.
Employees are thus actively involved in decision-making and activities aimed at managing the impact on the
workforce through various channels of collaboration. Internal communication and cooperation with labour unions
is standard, as well as management visits to remote and external sites to obtain feedback, views and suggestions
from employees. Information first reaches HR departments, who then share it with company management
according to the severity and topic, while management take this information into account in their decisions.
At MND Drilling & Services a.s., communication with employees and satisfaction surveys are carried out more
informally and continuously through dialogue with supervisors, because due to the nature of work in the field and
at remote workplaces (with limited online capabilities), it is not possible to carry out the survey in any other way.
In the companies in Ukraine, given the limited number of employees, communication and engagement with
employees is done on an ad hoc basis as needed, focusing on issues related to human resources and the quality of
employees' work equipment.
Responsibility for communication with employees is not centralised within the Group. Moreover, in companies with
collective agreements in place, the labour unions also meet regularly with the management representatives of the
individual companies, at least on a quarterly basis (or more frequently as required), to discuss the relevant matters,
exchange opinions or obtain information driven in particular from the individual provisions of labour law. Other
topics addressed by the labour unions include the company's economic performance, working conditions,
occupational health and safety, wage developments and their individual components, labour movements,
personnel matters, incentives and benefits, employee development and training systems, organisational changes,
etc.
As part of monitoring the success of cooperation with its own workforce, Group companies organise (at least once
a year) management-employee meetings organised by the relevant HR department to discuss key issues relating to
the working environment and conditions. In addition, various employee surveys are conducted in Group companies
regarding benefits, satisfaction, engagement, development and training activities. These interactions, carried out
on an ad hoc basis, allow employees to express their views and provide feedback, which represents a valuable
source of information for management of each company. In this way, management can effectively monitor the
success of its communications and respond to employee needs.
In accordance with legislation, Group companies maintain proper records of persons with disabilities or reduced
working capacity and take their needs into account in both communication and work processes.
3.1.4 [S1-3] Processes to remediate negative impacts and channels for own workforce to raise
concerns
The Group identified a negative impact in health and safety due to the occurrence of work-related injuries during
the reporting period. When work-related injuries occur, the Group complies with applicable legislation and the rules
of the occupational health and safety system, which is implemented in accordance with ISO 45001 standards.
36
These procedures include, in particular, the recording of work-related injuries (accident logbook), their treatment
and the provision of appropriate medical care. At the same time, these procedures include clarification of the causes
and circumstances of the work-related injury and the adoption of corrective and preventive measures.
As some of the Group's activities require the Group's employees to work in remote locations or in continuous
operations, there may be an imbalance between personal and professional life. To prevent this, the Group ensures
that work schedules are set in accordance with the law, including breaks from work and that accurate and proper
records of hours worked are kept.
36
Applicable to MND a.s., MND Energy Storage a.s., MND Gas Storage a.s. and MND Drilling & Services a.s.
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Given the low number of women in management and technical positions, the Group classified gender imbalance as
an actual impact. The Group therefore strictly applies non-discrimination principles in its recruitment and
employment policies, based on the principles of equal access.
The Group is committed to transparency and collaboration with its workforce and employee representatives, which
is enshrined in the Code of Ethics of MND Group. The Group respects its employees and makes increased efforts to
care for them, including the opportunity to report any concerns about conduct that may violate values, legislation
or internal standards.
The Ethics Line is one of the channels through which employees can voice their concerns.
35
Internal whistleblower
channels are described in more detail in Governance information, article 4.1 G1 - Business conduct. Employees are
made aware of its availability. The Group has also in place the Compliance System and a procedure for investigating
complaints received, including whistleblower protection in accordance with Act No. 171/2023, on the protection of
whistleblowers, as amended, for companies to which it is relevant.
37
The Group familiarises its employees with the
related processes via its intranet but does not actively assess their confidence in them.
Although there is no official tool for collecting suggestions and comments, employees have the possibility to
contribute anonymously through the so-called Prevention Cards. These cards are available across the companies
(except for MND Energie a.s.) and are used to evaluate various suggestions and observations. In this way, employees
actively participate in identifying necessary and appropriate measures in response to specific negative impacts on
their workforce.
All channels described above are established by the Group companies themselves, except for the channel of MND
Energie a.s. established pursuant to Act No. 171/2023 Coll., on protection of whistleblowers, as amended, which is
provided through a third party.
3.1.5 [S1-4] Taking action on material impacts on own workforce, and approaches to managing
material risks and pursuing material opportunities related to own workforce, and effectiveness
of those actions
OHS
To continuously reduce the negative impact on the health of employees, the Group has implemented
comprehensive measures to ensure the health and safety of its employees in accordance with ISO 45001.
38
As part
of the job evaluation process, job positions are classified into four risk groups, which enables their targeted
management. Regular auditing of these standards ensures an appropriate level of health and safety in the
workplace. All employees are made aware of the risks associated with their job positions upon starting their
employment.
Annually, managers monitor these risks in individual occupations to ensure that established safety standards are
being met. The Group has also established a system to protect the health of employees, which includes regular
health and safety training and ensuring access to the necessary safety equipment.
In companies where there are several groups of employees at risk (within the meaning of Decree No. 423/2003
Coll.), regular risk assessment and monitoring of the health status of employees is carried out.
39
The effectiveness
of individual measures and initiatives is also monitored and evaluated within the framework and in accordance with
ISO 45001. Appropriate corrective and preventive measures are taken based on the procedures established to
clarify the causes and circumstances of any accidents at work.
37
These companies are MND a.s., MND Energie a.s., MND Drilling & Services a.s.
38
Applicable to MND a.s., MND Energy Storage a.s., MND Gas Storage a.s. and MND Drilling & Services a.s.
39
See further the article 3.1.1[S1.SBM-3]
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Work-life balance and social protection
The Group actively focuses on ensuring a work-life balance for its employees and on strengthening social protection,
particularly in the context of 12-hour work shifts and the potential impact on disrupting this balance among its
employees. All companies within the Group comply with applicable local laws, European law and standards, as well
as collective agreements, if any.
Measures implemented that have had a positive impact on the working and living conditions of employees include
flexible working hours, extension of holiday entitlement to 5 weeks and entitlement to 4 days off work for health
or family reasons. Excessive overtime work is restricted in office positions. Other benefits that promote a better
work-life balance include quality medical care and insurance, a reduction in the length of the fixed working week
to 37.5 hours (except companies in Ukraine), as well as support and allowances for leisure activities (sports,
cultural). The Group also organises team-building events, some of which are designed for employees' family
members. All employees in the Group are also provided with subsidised meals. The Group verifies the effectiveness
of these measures through employee feedback.
In the case of twelve-hour work shifts, breaks are organised in accordance with the legal requirements of the
countries in which the work is performed and the employees concerned enjoy the same above-standard benefits
over and above these legal requirements, except for those which, due to the nature of the shift operation at the
remote workplace, cannot realistically be used (e.g. employee events organised by the Group companies at their
administrative headquarters).
Gender inequality and remuneration policy
The Group is actively focused on ensuring fair remuneration for equivalent work to minimise the negative impact
relating to the pay gap for equivalent work. The unequal distribution of men and women in certain Group
companies and in aggregate across the Group is primarily due to the type of industry and nature of operations in
which certain Group companies operate. In general, there is a low representation of women in positions that are
technical and/or physically demanding (mainly mining, drilling and related activities). In Group companies that do
not engage in these activities, this trend is not prevalent. The Group does not have specific measures to increase
the proportion of women, as this impact arises from the sector and the nature of the work carried out.
The Group provides all employees with a salary - a cash remuneration for their work, according to its complexity,
responsibility and exertion, according to the difficulty of the working conditions, according to their performance
and the results achieved. The Group already complies with the terms of the forthcoming fair pay legislation and all
employees are entitled to the same wage or agreed remuneration for the same work or work of equal value. The
Group's remuneration policy complies with the Labour Code and collective agreements and includes market surveys
once a year to compare internal and external wages. In companies with continuous operations or in which working
hours are unevenly distributed, related allowances are granted (for night work, for working on public holidays),
some which are above the established legislative framework (for Saturday and Sunday work), and compliance with
legislative and hygiene standards is a clear standard.
The Group has not identified any material risks or opportunities arising from impacts and dependencies with respect
its own workforce. For this reason, no specific measures to mitigate risks or seize opportunities in this area are
currently planned or implemented. Despite the Group's best efforts to avoid negative actual impacts on its own
workforce, it cannot be guaranteed that none of these impacts will ever occur. The action steps mentioned above
are covered within the Group's budget, and their implementation falls within the agenda of several types of
employees (for example, managers who are responsible for HSE or HR staff who engage employees in discussions
on impacts). Currently, the Group is not actively mitigating the potential impacts from the transition to a climate
neutral economy.
The Group currently has no measures in place regarding the share of women in senior management. The other
impacts, i.e. the potential for insufficiently monitored working hours and listening to employees through social
dialogue, are mainly managed by the policies described above and no specific measures have been introduced in
relation to them.
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3.1.6 [S1-5] Targets related to managing material negative impacts, advancing positive impacts, and
managing material risks and opportunities
The Group did not set any specific targets for the year 2024 relating to managing material negative impacts,
promoting positive impacts and managing material risks and opportunities. These targets will be defined as part of
the development of the comprehensive workflows and structure that are currently being developed.
At the same time, active monitoring of negative impact management is ensured, especially in occupational health
and safety. The overall monitoring is in line with ISO 45001
40
and ISO 14001 standards, which the Group has
implemented in most of its companies. For this reason, the companies carry out monthly monitoring and provide
the necessary information to the management.
The Group does not have specific monitoring in place to track other impacts related to its own workforce.
3.1.7 [S1-6] Characteristics of the undertaking’s employees
As of 31 December 2024, the Group had a total of 1 156 employees
41
. For the total number of employees, the
"headcount" method was used, i.e. the number of employees regardless of their number of hours. For the other
indicators and employee distribution, the "full-time equivalent (FTE)" method was used. The figures in the following
tables represent actual figures as of 31 December 2024 and are not averages over the reporting period.
Table 1: Number of employees by gender in countries where the Group with at least 50 employees representing at least 10% of the total
number of employees
Total number of employees as of 31 December 2024 - gender
breakdown
Women
Men
Total
Czech Republic
312
767
1 079
Ukraine
16
61
77
Total
328
828
1 156
Table 2: Information on employees by type of contract, broken down by gender
Total number of employees in the country -
gender breakdown as of 31 December 2024
Czech Republic
Ukraine
Women
Men
Total
Women
Men
Total
Number of employees
312
767
1 079
16
61
77
Number of permanent employees
264
684
948
15
50
65
Number of temporary employees
44
69
113
1
11
12
Number of non-guaranteed hours employees
4
14
18
0
0
0
Table 3: Employee turnover
Employee turnover
2024
Number of employees who left the Group
72
Employee turnover rate
7.1%
The following method was used to calculate the employee turnover rate:
Number of terminated employment relationships * 100
Average number of employees
42
40
Applicable to MND a.s., MND Energy Storage a.s., MND Gas Storage a.s. and MND Drilling & Services a.s.
41
The number of employees includes all active and inactive employees whose employment contract has not been terminated as at 31
December of the reporting year.
42
Including persons with whom an agreement on performance of work or an agreement on work activity have been concluded.
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3.1.8 [S1-8] Collective bargaining coverage and social dialogue
The collective bargaining agreements detailed in section S1-1 covered 69.03% of the Group's employees as of 31
December 2024.
For information on non-EEA employees, the phase-in option was used for 2024.
Table 4: Coverage of collective bargaining and social dialogue
Coverage by collective agreements
Social dialogue
Coverage rate
Employees - EEA
(for countries with more 50
employees representing more
than 10% of the total number
of employees)
Employees - outside the EEA
(estimate for regions with more 50
employees representing more than
10% of all employees)
Workplace representation
(EEA only)
(for countries with more
than 50 workers
representing more than 10%
of the total workforce)
0-19%
-
-
20-39%
-
-
40-59%
-
-
60-79%
Czech Republic
Czech Republic
80-100%
-
-
3.1.9 [S1-9] Diversity metrics
For reporting purposes, top management has been defined in accordance with the ESRS definition, with top
management comprising one and two levels below the executive and supervisory bodies in the preparation of the
gender information.
Table 5: Number of employees by age group
Number of employees - age distribution
2024
Number of employees under 30 years old
162
% of employees under 30 years old
14%
Number of employees 30-50 years old
643
% of employees 30-50 years old
56%
Number of employees over 50 years old
351
% of employees over 50 years old
30%
Table 6: Number and proportion of men and women in top management
Number of employees in top management
2024
Women
5
Men
24
Total
29
Share of employees in top management
2024
Women
17%
Men
83%
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3.1.10 [S1-14] Health and safety metrics
Table 7: Occupational health and safety information, including management system coverage, number of fatalities and accidents at work
Employees
2024
% of own employees covered by OHS management system
100%
% of non-employees (contractors) covered by the OHS management system
0%
Number of fatalities as a result of work-related injuries and work-related ill health
0
Number of fatalities as a result of work-related injuries and work-related ill health of
other workers at the company's workplaces
0
Number of cases of recordable work-related injuries
15
Rate of cases of recordable work-related injuries
8
3.1.11 [S1-16] Remuneration metrics (pay gap)
The Group's companies operate in the oil and gas sector, which requires highly specialised technical training,
particularly in the fields of petroleum and chemical engineering, mechanical engineering, electrical engineering,
geology and geophysics, which have long been significantly male dominated. This is reflected in the generally lower
representation of women in positions requiring this type of qualification and consequently in their lower
representation in senior roles. At the same time, the nature of activities in certain Group companies—particularly
extraction and drilling operations—due to their physical demands and associated risks, results in open positions
attracting interest primarily from male applicants.
Both factors contribute significantly to the lower representation of women in this sector (women account for
approximately 28% of all Group employees) and affect the percentage difference in remuneration between male
and female employees.
The percentage pay gap between male and female employees is 26.8%.
Calculation of the pay gap
(Average gross hourly pay level of male employees – average gross hourly pay level of
female employees)
_________________________________________________________________________________ X 100
Average gross hourly pay level of male employees
All employees of the Group, including those with agreement on performance of work and agreement on work
activity, were included in the calculation. All remuneration
43
(fixed and variable components of gross salary) for the
reporting period was included in the calculation of average hourly wages.
43
See ESRS definition.
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3.1.12 [S1-17] Incidents, complaints and severe human rights impacts
Table 8: Incidents, complaints and serious human rights impacts
2024
Total number of cases of discrimination, including harassment, reported during the reporting
period
0
Number of complaints about social and human rights incidents
0
− Number of complaints submitted through channels for people in own workforce
(including complaint mechanisms)
0
− Number of complaints submitted to the OECD National Contact Points for
Multinational Companies
0
The total amount of fines, penalties and compensation for damages resulting from the incidents
and complaints listed above
0 CZK
Number of serious human rights incidents involving own employees during the reporting period
0
Number of severe human rights incidents related to own employees in the reporting period
(e.g. cases of non-compliance with the UN Guiding Principles on Business and Human Rights, the
ILO Declaration on Fundamental Principles and Rights at Work or the OECD Guidelines for
Multinational Enterprises)
0
Total amount of fines, penalties and compensation for the incidents described above
0 CZK
3.2 S4 - Consumers and end-users
3.2.1 [SBM-3] - Material impacts, risks and opportunities and their interaction with strategy and
business model
The double materiality assessment, which took into account all end-users and consumers, identified one material
negative impact related to the sub-topic of privacy under the sub-sub-topic "Impacts related to information for
consumers and/or end-users". This impact is related to the processing of personal data of customers
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MND Energie
a.s. and is mainly based on the need to process personal data when entering into contractual relationships with
customers (the link with the Group's strategy is described in ESRS 2 - General information, article 1.3.3 [SBM-2]
Interests and views of stakeholders). There are no risks or opportunities associated with consumers and end-users
arising from the Group's impacts.
MND Energie a.s.
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processes the personal data of its customers and potential customers for the purpose of
providing a specific product or service, identifying the customer in accordance with the Act on certain measures
against the legalization of proceeds of crime and terrorist financing, fulfilling the obligations set out in specific legal
regulations, sending commercial communications and other marketing communications, analysing behaviour and
preferences (profiling), storing them in case of a potential dispute in the future and securing information systems
and networks. Within MND Energie a.s., the risk of human error or cyber-attack, i.e. incidents that could lead to the
leakage of customer data, cannot be excluded. The possibility of this negative impact is reflected in the approach
to handling customer data through the processes described below.
The sub-sub-topic "Impacts related to information for consumers and/or end-users" applies to all customers of
MND Energie a.s. Affected consumers and end-users in the context of the described negative impact include
customers who provide MND Energie a.s. with their personal data. All consumer and business customers of natural
persons may therefore be affected by this impact.
44
For the definition of "customer" see sectionsESRS 2 - General information , Article 1.3.3 [SBM-2] Interests and views of stakeholders
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MND Energie a.s. is the only company in the Group that handles the personal data of end-users/consumers (i.e. its customers).
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3.2.2 [S4-1] - Policies related to consumers and end-users
The right to privacy is recognised under the UN Guiding Principles as a fundamental human right. The Group is fully
compliant with the applicable legislation regarding the processing of personal data, which is based on these
principles. Personal data is collected and processed in accordance with Act No. 110/2019 Coll. on the processing of
personal data, as amended, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April
2016 on the protection of natural persons with regard to the processing of personal data and on the free movement
of such data ("GDPR"), and Act No. 480/2004 Coll. on certain information society services, as amended. The Group
will also comply with any future regulations that may amend or replace these laws. Policies relating to consumers
and end-users are not directly linked to relevant internationally recognised instruments. The Group has not
assessed the consistency of its policies with these instruments. The Group is not aware of any cases of non-
compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental
Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises relating to consumers in its
downstream value chain.
The policies that address the only identified significant negative impact, namely the sub-sub-topic "Impacts related
to information for consumers and/or end-users" are listed below.
Group policies relating to consumers and end-users
The Privacy Policy and Code of Ethics, which also apply to all customers or business partners of Group companies,
are described in detail in Social information, article 3.1.2 [S1-1] Policies related to own workforce and in Governance
information, article 4.1.1 [G1-1] Business conduct policies and corporate culture. Privacy policies are developed at
the individual company level.
Policies of MND Energie a.s. concerning consumers and end-users
As MND Energie a.s. is the only company in the Group that processes customer data,
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it has additional internal
regulations dealing with handling of data. The key policies of MND Energie a.s. are:
• Principles for the Exercise of Data Subjects' Rights, which sets out the framework for ensuring the rights
of data subjects in accordance with the GDPR. The aim of this policy is to provide MND Energie a.s.
employees with clear guidelines for the correct handling of customer requests relating to their personal
data. The policy defines the rights of data subjects and describes the basic process for handling customer
requests in relation to the handling of their personal data. The policy also emphasises the importance of
staff training and regular monitoring of processes to ensure that personal data is protected, and that data
subjects' rights are respected. Responsibility for this policy rests with the company's Chief Executive Officer.
• Handling of Acquisition Data - This corporate governance document serves as a guide for company leaders
and executives who handle data of potential customers, including their personal data, i.e. acquisition data.
It specifies the approach to the granted consent of data subjects with the processing of personal data and
to the handling of personal data of persons/potential customers who have not given such consent.
Responsibility for this policy rests with the company's commercial director.
• Handling security incidents affecting personal data - despite the policies and procedures in place to
prevent security incidents involving personal data, an incident cannot be completely eliminated. The policy
aims to ensure a consistent process for handling such potential incidents across the company. This policy
contains a classification of incidents, impacts and risks and sets out the responsibilities and procedures for
handling and recording such incidents. This policy is the ultimate responsibility of the departmental
directors and has been approved by the company’s Chief Executive Officer.
● Code of Ethics "MND Ten Principles" - MND Ten Principles is a brief code of ethics of MND Energie a.s.,
which focuses on the relationship between the company and its customers. The code sets out the principles
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and rules that the company must follow in its relationship with its customers and the way it provides its
services. The main objective of the MND Ten Principles is to ensure that customers have access to clear and
transparent information on pricing structures and contract terms that are simple, understandable and free
from hidden costs and/or other ambiguities. Responsibility for this policy lies with the company’s Chief
Executive Officer. This policy follows the Code of Conduct for Gas and Electricity Traders issued by the
Energy Regulatory Authority in early 2017, which MND Energie a.s. has signed.
The implementation of the above policies is monitored through the monitoring of their breaches and their ad hoc
correction.
3.2.3 [S4-2] - Processes for engaging with consumers and end-users about impacts
From the Group companies, only MND Energie a.s. actively communicates with consumers and end-users.
Communication is direct, i.e. not through representatives or agents. The frequency of communication is further
described in ESRS 2 - General information, article 1.3.3 [SBM-2] Interests and views of stakeholders. This
communication occurs on an ongoing basis, both on a regular and ad hoc basis, throughout the duration of the
contractual relationship with the customer. The suggestions of consumers and end customers are consistently
analysed and implemented by MND Energie a.s., especially in the improvement of customer processes.
The company mainly uses its website for communication. Customers can find up-to-date information on the
services offered, pricing and contractual conditions there, as well as the aforementioned policies that could have a
direct impact on them. Direct contacts are available on the website, including special contacts such as the HR
department and the ethics line. MND Energie a.s. has also established a Data Protection Officer position. From the
perspective of MND Energie a.s., there are other communication channels that improve and strengthen
communication and facilitate interaction with customers. The main channels of communication with customers
include the customer hotline, e-mail, correspondence and customer centres in Prague and Hodonín.
The My MND portal is a key tool for existing customers of MND Energie a.s., facilitating communication with the
company and providing an overview of important information and services. In addition, the portal allows customers
to submit their requests and queries online, simplifying the entire communication process and ensuring that even
potentially disadvantaged customers have easy access to the information and services they need.
The Chief Executive Officer has the ultimate responsibility for communication. Communication and customer
satisfaction is closely monitored by the company in the framework of the so-called customer experience in two
systems. MND Energie a.s. uses a paid questionnaire tool to assess customer satisfaction and a comprehensive
customer support solution tool to service the call centre and assess customer satisfaction during telephone calls.
3.2.4 [S4-3] - Processes to remediate negative impacts and channels for consumers and end-users to
raise concerns
In addition to the above-mentioned forms of communication that MND Energie a.s. customers can use, contractual
partners of other Group companies can express their concerns via the Ethics Line,
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e-mail, telephone, intranet or
web interface. For more details, see the section Governance information, article 4.1 G1 - Business conduct. The
forms and methods of communication are evaluated as part of the customer satisfaction assessment of MND
Energie a.s.
In addition to the above, MND Energie a.s. provides the opportunity to report possible infringements in accordance
with the Act on Protection of Whistleblowers. The possibilities for consumers and end-users (i.e. external parties)
to submit a notification are described in more detail in Governance information, article 4.1 G1 - Business conduct.
MND Energie a.s. offers several forms to facilitate communication and requests from its customers. These forms
allow for the submission of complaints regarding services or products (online, by email or by post), ensuring that
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in addition to the company in Ukraine.
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concerns are properly evaluated and addressed. They also provide the opportunity to exercise rights related to
personal data, including the right of access, rectification, erasure and other rights under applicable law.
Customers can also lodge a complaint with the supervisory authority, which is the Office for Personal Data
Protection.
In the context of the above-mentioned customer satisfaction surveys, any negative feedback is investigated at the
level of the relevant company department depending on its content and incorporated in the context of customer
process improvement. The responsibility for investigating and incorporating feedback lies with the relevant
department.
3.2.5 [S4-4] - Taking action on material impacts on consumers and end-users, and approaches to
managing material risks and pursuing material opportunities related to consumers and end-
users, and effectiveness of those actions
In accordance with legal requirements, the Group investigates and evaluates to the fullest extent possible potential
and actual incidents that could lead to unauthorised disclosure or acquisition of personal data or a material breach
of the Policy or applicable data protection regulations. In the event of any incident involving the protection of
personal data, disciplinary action is taken against the employee who has violated the procedures contained in the
relevant internal data protection regulations. These procedures determine what action is subsequently taken in
response to a particular incident. By instructing the employee in question, the Group minimises the possibility of a
recurrence of the same behaviour.
Data protection is also part of the training programme that the Group organises for employees, which is described
in more detail in Social information, article 3.1.2 [S1-1] Policies related to own workforce.
Regarding the security of customer data,
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that is relevant for MND Energie a.s. The security is ensured in
accordance with best practice and current security standards. All data and key parts of the information system are
protected against unauthorised manipulation by multi-level physical security with controlled access by authorised
persons. All data is regularly backed up so that partial and full recovery can be performed at any time, if necessary.
The consistency and completeness of the backups are regularly checked. Backups are kept separate from
production systems. Access to them is controlled in a similar way to physical access to information systems. Data
and information systems with special sensitivity are preferably located in data centres with guaranteed operational
and security parameters. The Group does not have specific action plans and resources in place to manage the
impact on customers described above. Currently, the Group perceives that the management of this impact is
integrated into the Group's day-to-day management.
The Group has not identified any significant risks or opportunities arising from impacts and related to its customers.
For this reason, no specific measures to mitigate risks or seize opportunities in this area are currently planned or
implemented. The Group has also not received any reports of serious incidents involving its customers or issues
related to human rights.
The Group tracks the effectiveness of these measures through an indicator that it monitors on an ongoing basis.
This indicator is described below in article 3.2.6 [S4-5] - Targets related to managing material negative impacts,
advancing positive impacts, and managing material risks and opportunities. The Group manages this impact within
the standard agenda of the relevant budget for the period. Also, responsibilities are identified in the above
mentioned policies under this topic (article 3.2.2 [S4-1] - Policies related to consumers and end-users). In relation
to the identified impact, the Group has no further actions or measures planned at this time that would require
collaboration with other relevant parties or that would be required by the entire oil industry.
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3.2.6 [S4-5] - Targets related to managing material negative impacts, advancing positive impacts,
and managing material risks and opportunities
The Group did not set any specific targets for year 2024 in relation to managing significant negative impacts,
promoting positive impacts and managing significant risks and opportunities in conjunction with consumers and
end-users. These objectives will be defined as part of the development of the comprehensive workflows and
structure which are currently being developed.
Given the nature of this impact, the Group set an indicator which it monitors on an ongoing basis. This is the number
of security incidents reported to the Office for Personal Data Protection (or other similar supervisory authority). In
this way, the Group monitors whether policies and measures related to the protection of consumer and end-user
privacy are effective. If the number of incidents starts to increase, this would be a clear signal that the policies and
measures are not sufficiently effective.
Table 1: Number of incidents reported to the Authority
Number of incidents reported to the Office for Personal Data Protection (or other supervisory authority)
2024
Total
0
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4 Governance information
4.1 G1 - Business conduct
The role of the administrative, management and supervisory bodies, including the bodies' expertise on business
conduct