Annual Report 2021

Taxonomy

The EU Taxonomy refers to several regulations related to economically sustainable economic activities. This includes: Article 8 of the Regulation of the EU 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (Regulation 2020/852) and the EU Commission Delegated Regulation of 4 June 2021 establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation or climate change adaptation and for determining whether that economic activity causes no significant harm to any of the other environmental objectives (Technical screening criteria); as well as Commission Delegated Regulation (EU) 2021/2178 of 6 July 2021 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by specifying the content and presentation of information to be disclosed by undertakings subject to Articles 19a or 29a of Directive 2013/34/EU concerning environmentally sustainable economic activities, and specifying the methodology to comply with that disclosure obligation (Disclosure Regulation). These regulations are hereinafter also referred to as the Taxonomy. Orange Polska disclosed the proportion of Taxonomy-eligible and Taxonomy non-eligible economic activities in their total turnover, capital and operational expenditures and the qualitative information (key performance indicators, key indicators).

The Taxonomy aims to define an activity classification system that provides clarity as to which activities qualify as sustainable and which do not. Establishing the criteria for environmentally sustainable economic activities is important for the European Union’s goal of sustainable development and the transition to a safe, climate-neutral, climate-changeresilient and more resource-efficient circular economy.

According to the Regulation 2020/852, an environmentally sustainable activity is an activity that makes a significant contribution to the achievement of at least one of the environmental objectives set out in the Regulation, does not harm the environmental objectives, meets certain minimum safeguards set out in the Regulation, including in the field of human rights, and meets the technical screening criteria.

Pursuant to the Taxonomy, in 2021 some enterprises, including Orange Polska, should for the first time report key performance indicators related to eligible activities implementing two out of six environmental goals, i.e. climate change mitigation and adaptation to the climate changes. Activities that pursue successive environmental goals will be reported by enterprises in later periods, after completing the Taxonomy with the remaining goals. The Management Board of Orange Polska analysed our activities in terms of qualifying the activities conducted by the Group in accordance with the Taxonomy and presented the key performance indicators of the proportion of turnover (revenue), capital expenditures and operating expenditures related to these activities.

Orange Polska commented on the qualifications and indicators related to the Group’s eligible activities, as the system for identifying and classifying eligible activities regulated in the Taxonomy requires interpretation and does not reflect all activities undertaken by companies in the environmental area.

The European Commission examined 13 business sectors, which are described in Annexes 1 and 2 to the Technical Screening Criteria regulation. The European Commission’s approach is progressive – the priority has been given to the business sectors responsible for higher greenhouse gas emissions, and the eligibility analysis of other sectors will be the subject of further work by the Commission. Therefore, not all sectors of the economy have been reviewed, including the telecommunications sector, and only a few areas of this sector’s activity have been included in the Taxonomy, which results in the low level of the key indicators disclosed by Orange Polska.

Most of Orange Polska’s activities in the field of telecommunications services to residential, business and telecommunications operators are currently outside the scope of Annexes 1 and 2 to the Taxonomy Screening Criteria, although Orange Polska believes that its activities may contribute positively to climate change adaptation and mitigation in terms of reducing its environmental footprint.

In the future, regulatory changes may result in other activities in the field of information and communication services being classified as eligible by the Taxonomy, in addition to the currently classified activities such as data processing through processing centres and solutions for reducing greenhouse gas emissions. This could include services constituting the main activities of Orange Polska, which is important from the point of view of ensuring balanced and sustainable development of the European Union. Another example of an activity important from the point of view of Orange Polska, but which cannot be classified as eligible according to our interpretation of the Taxonomy, is the purchase of renewable energy for own needs (i.e. from wind farms) under long-term contracts with suppliers.

Activities carried out by Orange Polska in the area of the environment, along with climate goals, climate risks, and initiatives to improve energy efficiency and the circular economy in order to reduce the negative impact on the climate, are presented in section 10.

The above explanations are important for an understanding of the key performance indicators of eligible activities presented below, which show a low level of such activities in Orange Polska in accordance with our interpretation of the Taxonomy, due to the limited scope of activities classified by the Taxonomy as eligible.

1. Analysis of activities qualified by the Taxonomy as eligible

Orange Polska has reviewed all its activities related to the first two environmental goals to determine which of them can significantly contribute to climate change mitigation or climate change adaptation according to the Taxonomy. During the review, the description of eligible activities included in the Screening Criteriag criteria was taken into account. Orange Polska’s activities generating eligible revenue as defined by the Taxonomy are as follows:

Environmental objective European Taxonomy activity Orange Polska activity
Climate change mitigation 6.4 Transport
Operation of personal mobility devices, cycle logistics.
4th generation bike rentals
(without docking stations)
7.6 Construction and real estate
Installation, maintenance and repair of renewable energy
technologies.
Professional services in the field of photovoltaics offer for customers*

* revenue including installation of photovoltaic
installations and revenue related to sale of equipment

8.1 Data processing, hosting and related activities
Storage, manipulation, management, movement, control, display, switching, interchange, transmission or processing of data through data centres, including edge computing.
Hosting and data processing services in data centres*

* revenue calculated on the basis of information
from reporting systems

8.2 Data-driven solutions for GHG emissions reductions
Development or use of ICT solutions that are aimed at collecting, transmitting, storing data and at its modelling and use where those activities are predominantly aimed at the provision of data and analytics enabling GHG emission reductions
Services based on the Internet of Things

Orange Polska’s activities in the field of capital expenditures and operating expenditures related to business activities that can be considered as eligible are as follows:

Environmental objective European Taxonomy activity Orange Polska activity
Climate change mitigation 6.4 Transport
Operation of personal mobility devices, cycle logistics.
4th generation bike rentals
(without docking stations)
7.6 Construction and real estate
Installation, maintenance and repair of renewable energy
technologies
Professional services in the field of photovoltaics offer for customers*

* revenue including installation of photovoltaic
installations and revenue related to sale of equipment

8.1 Data processing, hosting and related activities
Storage, manipulation, management, movement, control, display, switching, interchange, transmission or processing of data through data centres, including edge computing
Hosting and data processing services in data centres*,**

* operating expenditures include IT infrastructure monitoring, maintenance of the technical environment in the centres, excluding energy costs
** capital expenditures are related to expenditures in data centres

8.2 Data-driven solutions for GHG emissions reductions
Development or use of ICT solutions that are aimed at collecting, transmitting, storing data and at its modelling and use where those activities are predominantly aimed at the provision of data and analytics enabling GHG emission reductions.
Services based on the Internet of Things

The list of activities qualifying for Taxonomy was defined as a result of a comprehensive review of Orange Polska’s operations with the participation of managers and experts from business, finance, CSR division and external experts.

2. Calculation of key performance indicators

Orange Polska calculated the key indicators in accordance with the Disclosure Regulation based on its processes, existing reporting systems and made assumptions.

Orange Polska used the methodology described in Annexes 1 and 2 of the Disclosure Regulation to calculate the eligible portion of revenue, capital expenditures and operating expenditures. In case of activities classified under the Taxonomy as eligible, but insignificant in 2021 in terms of the amount of revenue, capital or operating expenditures, Orange Polska did not include this part of its activity in the indicators.

The proportion of revenue related to eligible activities was calculated by dividing the sum of revenue from eligible activities described in section 1 above by revenue specified in the consolidated income statements in the consolidated financial statements of the Orange Polska Group for the year ended December 31, 2021 (consolidated revenue).

31 December 2021
Revenue from eligible activities PLN 33 million
Consolidated revenue PLN 11,928 million
Percentage of revenue related to eligible activities 0.28%
Percentage of revenue from non-eligible activities 99.72%

The proportion of revenue related to eligible activities is 0.28%, which reflects the small proportion of telecommunications services falling within the current scope of the Taxonomy.

It should be noted that the revenue taken into consideration under the activity „Data-driven solutions for GHG emissions reductions” concerns the entire revenue related to the Internet of Things (IoT, line of business excluding revenue related to the sale of equipment), considering that this activity enables other economic sectors to reduce their greenhouse gas emissions.

IoT-based services include solutions for managing public bikes, lighting control, air quality control, reading water meters, and supporting the development of smart cities. Smart solutions make it possible to optimise the use of manufactured goods or support their use and better manage natural resources and, consequently, reduce CO₂ emissions to the benefit of the climate.

Orange Polska’s capital expenditures ratio related to eligible activities was calculated by dividing the sum of capital expenditures related to eligible activities (described in section 1 above) by the sum of capital expenditures specified in the consolidated financial statements of the Orange Polska Group for 2021, calculated according to the definition of the Taxonomy, according to which the sum of investments includes:

  • acquisition of intangible assets (acquisitions of intangible assets in the Note 11 ‘Other intangible assets’ in the consolidated financial statements of the Orange Polska Group for 2021);
  • acquisition of fixed assets (acquisitions of property, plant and equipment in the Note 12 ‘Property, plant and equipment’ in the consolidated financial statements of the Orange Polska Group for 2021);
  • increase in right-of-use assets (additions in right-ofuse assets in the Note 14.1 ‘Group as a lessee’ in the consolidated financial statements of the Orange Polska Group for 2021).

The sum of capital expenditures defined as above differs from the eCapex ratio presented in the consolidated financial statements of the Orange Polska Group for the year ended December 31, 2021, mainly because eCapex does not include an increase in right-of-use assets and is decreased by the proceeds accrued on the disposal of assets.

The capital expenditures ratio related to the eligible activities is 6%, which corresponds to a small fraction of the capital expenditures related to the telecommunication activities of Orange Polska.

This is because the current Taxonomy does not take into account all activities of the telecommunications sector, including activities carried out by Orange Polska for the benefit of the climate and the environment.

The increase in demand for digital services, necessary to ensure sustainable development, must be accompanied by an improvement in the energy efficiency of the telecommunications sector. By investing in the expansion of the infrastructure of its networks, Orange Polska takes care to increase their energy efficiency. Capital expenditures on activities classified as eligible include expenditures on data centres.

31 December 2021
Capital expenditures related to eligible activities PLN 140 million
Sum of capital expenditures PLN 2,356 million
Capital expenditures ratio related to eligible activities 6%
Percentage of capital expenditures related to non-eligible activities 94%

As defined in the Disclosure Regulation, the operating expenditures included in the calculation of Orange Polska’s operating expenditures ratio related to eligible activities, eligible operating expenditures in the indicator numerator and the sum of Orange Polska operating expenditures included in the indicator denominator include operating expenditures for:

  • non-capitalised costs related to research and development;
  • renovation work on buildings;
  • short-term rental;
  • maintenance and repair;
  • any other direct expenses related to the day-to-day servicing of fixed assets by the entrepreneur or a third party commissioned with the activities necessary to ensure the continuity and efficiency of the functioning of these assets.

As defined in the Delegated Regulation, Orange Polska did not take into account the expenditures related to energy, as they are not considered as direct expenses related to the day-to-day servicing of property, plant and equipment.

Orange Polska’s operating expenditures ratio related to eligible activities has been calculated by dividing the operating expenditures related to eligible activities described in section 1 by the sum of operating expenditures in the consolidated financial statements of the Orange Polska Group for the year ended December 31, 2021 corresponding to the definition above (total operating expenditures).

31 December 2021
Operating expenditures related to
eligible activities
PLN 7 million
Total operating expenditures PLN 956 million
Operating expenditures ratio related to eligible activities 0.7%
Percentage of operating expenditures related to non-eligible activities 99.3%

The operating expenditures included in the ratio are included in the consolidated financial statements of the Orange Polska Group for the year ended December 31, 2021 under external purchases, other operating income and expenses, and labour expense and, according to the definition of the Disclosure Regulation, they do not cover a significant portion of operating expenses included in the consolidated operating income of the Orange Polska Group.

The low value of the ratio is due to the fact that the current Taxonomy does not take into account all activities of the telecommunications sector undertaken to mitigate or adapt to climate change, including activities carried out by Orange Polska for the benefit of the climate and the environment.

Due to the low values, Orange Polska decided not to include in the operating expenditures ratio the activities subject to the Taxonomy related to the installation and use of solar installations generating energy for Orange Polska’s own use, expenses related to the use of leased photovoltaic panels and electric cars.

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