Provide a detailed account of any non-compliance incidents or enforcement actions that were necessary to ensure adherence to permit conditions, as required under Disclosure Requirement E2-4. This should include any material incidents where pollution had negative impacts on the environment or is anticipated to affect the company's financial cash flows, position, and performance across short-, medium-, and long-term horizons, as stipulated in Disclosure Requirement E2-6. Additionally, confirm if these activities fall under Directive 2010/75/EU on industrial emissions and relevant Best Available Techniques Reference Documents, regardless of whether they occur within the European Union.

Question

Accepted Answer

We have outlined all the disclosure requirements in the topical standards ESRS ‘E2 Pollution’, ESRS ‘E3 Water and marine resources’, and ESRS ‘S4 Consumers and end-users’, as these topics were deemed immaterial in our DMA. For ESRS E2 and ESRS E3, we identified and assessed impacts, risks, and opportunities following the same methodology and process steps as for the topics deemed material. This was informed by environmental impact assessments, risk registers, reported data, and other documentation, such as asset-specific conditions for management of pollution and water imposed by local authorities, which is particularly relevant for our CHP plants. However, none of the identified IROs were assessed as material for these two topics due to the high minimum environmental requirements imposed by authorities in the countries where we operate our assets.

Orsted

ESRS disclosure: E2-4_17

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