Business risks
Operational risks
Key: Risk materiality level: low ; medium ; high
Probability that the risk will materialise: low ; medium ; high
Yoy change in the risk level: increase ; decrease ; no change ; new risk – no arrow
Changes in and impact of material operational risks on the PGNiG Group
| Risk | Description |
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Resource discoveries and estimates
Poland:
Norway:
Libya:
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The main risk inherent in exploration activities is the risk of failure to discover hydrocarbons, i.e. exploration risk. This means that not all identified leads and prospects actually have deposits of hydrocarbons which can qualify as an accumulation. In addition, the actual quantity and quality of accumulated hydrocarbons may differ from estimates. If the results of successful exploration in the form of new reserves do not balance production from existing fields, the recoverable reserves in the PGNiG Group’s fields will gradually decrease as the production continues. Reserves estimates and production projections may be erroneous due to imperfections inherent in the applied equipment and technology, which affect the quality of the acquired geological information. Irrespective of the methods applied, data on the volume and quality of commercial reserves of crude oil and natural gas is always an estimate. Actual production, income and expenses relating to a given deposit may significantly differ from estimates. The weight of this risk is further increased by the fact that in the full business cycle the period from start of exploration to the launch of production from a developed field takes six to eight years, while the production lasts from 10 to 40 years. Formation characteristics determined at the stage of preparing the relevant documentation are reviewed after production launch. Any downward adjustment of the reserves or production volumes may lead to lower revenue and adversely affect the PGNiG Group’s financial performance. |
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Cost of exploration
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Capital intensity of an exploration project depends on prices of energy, materials and cost of services, including transport. Cost of exploratory work is especially sensitive to steel prices, which are passed onto prices of casing pipes and production tubing used in drilling. An increase in prices of energy and materials translates into higher costs of exploratory work. Profitability of foreign exploration projects also depends to a significant extent on prices of oil derivative products and on exchange rates. To reduce costs, the Company seeks new sources of supply, plans supply chains in advance and negotiates contracts. |
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Project delays
In Poland and abroad:
Norway:
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Under the applicable Polish laws and regulations, the process of obtaining a licence for exploration and appraisal of crude oil and natural gas reserves lasts from one to one and a half years. In foreign markets such procedures may even take up to two years from the time the winning bid is awarded until the actual contract is ratified. All these factors create the risk of delays in the start of exploration work. The formal and legal obstacles, beyond PGNiG’s control, include those related to:
These factors materially delay investment activities and entering the area to commence construction work. Further, PGNiG’s obligation to comply with the Public Procurement Law frequently protracts tender procedures. A protracting project exacerbates the risk related to estimation of capital expenditure. |
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Limitations on the contractors market
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The risk is largely attributable to a limited number of qualified suppliers often providing specialist services and supplies, and to deteriorated competitiveness on the contractor market, an increase in labour costs, prices of materials and services. Another risk factor is the reduced ability to meet customers’ needs in a timely manner due to economic developments and forced organisational changes resulting from the COVID-19 pandemic. The risk materialisation may result in delays in the execution of key projects, in particular those related to the purchase of specialist tools and equipment from entities whose plants are located in countries that have suffered significantly from the global pandemic. Another symptom of the risk materialisation may be reduced competitiveness among contractors and suppliers in the market due to reduced capacities or closures of their operations (as they implement the necessary cost cutting measures).
This risk may result from an insufficient number of qualified contractors, deteriorated competitiveness in the contractors market, and increase in the cost of labour, materials and services. |
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Safety, environmental protection and health regulations
In the Exploration and Production segment:: Poland:
Norway:
In the Trade and Storage segment
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The need to ensure compliance with environmental laws in Poland and abroad may significantly increase the PGNiG Group’s operating expenses. Currently, the Group incurs significant capital expenditure and costs to ensure compliance of its operations with the ever more complex and stringent regulations concerning safety and health at work, as well as environmental protection. Offshore upstream operations carry a significant risk of environmental pollution resulting from oil spills. The risk is monitored on an ongoing basis, and field operators have implemented a number of barriers and technical solutions to mitigate the risk. |
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Unforeseen events and emergencies
In the Exploration and Production segment Poland:
Norway:
Generation
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Hydrocarbon deposits developed by the PGNiG Group are usually located at great depths, which involves extremely high pressures and, in many cases, the presence of hydrogen sulfide. Consequently, the risk of hydrocarbon blowout or leakage is very high, which in turn may pose a threat to people (employees and local population), the natural environment and production equipment.
Natural and epidemiological risks: In the countries where PGNiG conducts exploration and production work, natural hazards – such as climate risk, natural catastrophe risk, the occurrence of strong wind, floods, landslides, high temperatures, earthquakes, venomous animals and poisonous plants – may be expected. Such threats may result in delays in or suspension of works, which lifts the costs of remedial measures, posing a huge financial risk to the Company. The possibility of a crisis situation, e.g. a pandemic related to a contagious disease, should also be considered. The actual or possible incidence of a disease, e.g. COVID-19, in employees may lead to limited availability of qualified personnel, elimination of personnel performing works, and subsequent delay in or suspension of the works. The epidemic situation caused by the occurrence of the SARS-CoV-2 virus poses a risk to the health of employees and achievement of the objectives set by PGNiG TERMIKA S.A. Operational business continuity plans have been prepared to prevent, counter and combat COVID-19. A team was appointed to coordinate the Company’s operations during the pandemic. A number of preventive measures have been put in place, in particular as regards the organisation of work and implementation of sanitary restrictions. |
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Risk of termination of EPSA
Libya
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The EPSA stipulates commitments to carry out specific exploration works during a defined period. The occurence of force majeure suspends the lapse of time for the fulfilment of exploration commitments. Referring to political stabilisation, the management of NOC may order the resumption of exploration works and, in the absence of any action taken by the company, may deem it a failure to perform its obligations under the EPSA and terminate the agreement by taking over the rights to the licence and all results of the works and analyses already performed, and call on the guarantee issued by PGNiG S.A. to NOC to secure the performance of works by PGNiG UNA. |
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Changes in legal regulation
In Poland and abroad::
Norway:
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In some countries, exploration and production activities may be hindered by frequent and unexpected changes in legislation, which may give rise to particularly serious risks in countries with authoritarian regimes. |
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Political and economic situation
Poland:
Norway:
Libya:
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Some countries where the PGNiG Group is conducting exploration and production activities are threatened by military conflicts and terrorist attacks, which may lead to limitation, suspension or even discontinuation of such activities. Some major risks related to acts of war include the possible imposition of embargoes and humanitarian crises. They may affect the continuity of the Company’s business, preventing or hindering the achievement of its strategic objectives. Armed conflicts may lead to deficits of natural gas and crude oil on the European market, triggering price shocks.
The PGNiG Group’s operations are also exposed to the risk of social or political unrest in some regions. Changes of governments may result in withholding issuance of petroleum licences. Those countries are also at risk of internal conflicts and civil unrest due to poverty and demographic issues. If these risks materialise, the Company’s activities may be limited, suspended or discontinued. In certain countries, operations of exploration companies may be hindered by the absence of adequate infrastructure, which may be an obstacle in transporting equipment, personnel and materials to the sites. Problems may also arise in providing supplies and ensuring appropriate health care. These risks may lead to limitation or suspension of the Company’s exploration activities. Cultural considerations. In countries where religious extremism plays a prominent role, it is easier to disrupt exploration and production processes due to religious and cultural differences, which may result in:
In August 2014, the low level of security in Libya brought about the notification of force majeure in the project and suspension of operations, which is currently a key factor preventing the resumption of performance of the exploration commitments. The stabilising political situation in Libya since mid-2020 and the expected parliamentary and presidential elections give hope for the resumption of exploratory works. |
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Opposition from local communities
Exploration & Production segment Poland and other countries:
In the Trade and Storage segment
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The protests of residents of areas where drilling operations were carried out focus, among other things, on noise emitted by the drilling equipment working around the clock, increased vehicle traffic and the destruction of roads, as well as concerns about environmental pollution (water, soil). Protests result in delays or suspension of drilling work, prolongation of administrative procedures and damage to the Company’s image. In order to minimise the risk, the locations of wells are reviewed in terms of potential conflicts and dedicated information campaigns are conducted. It is increasingly more common that local communities expect to receive direct benefits.
Ownership matters. In agricultural countries, and in particular those poorly developed, an important factor limiting access to exploration sites is the strong attachment to land property owned for many generations. |
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Financial risk in the Exploration and Production segment:
Libya
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Lack of sufficient resources to complete exploration works and prepare for the launch of production. PGNiG UNA’s operations in Libya are financed entirely by the sole Shareholder (PGNiG S.A.). Failure to provide sufficient funds may result in the risk of termination of the EPSA and NOC calling on the guarantee issued by PGNiG S.A. |
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DIGITAL FIELDS
PGNiG Group
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The process of digitisation of field data and optimisation of production involves a risk related to the dispersion of E&P data, due mainly to the lack of proper continuity in the collection of such data. This results in the varying quality and format of data, and therefore the need to verify many sources, as well as time- and labour-consuming process of data unification and centralisation. In addition, there is a risk of discontinuation of support for standard E&P licences due to technological developments towards cloud solutions, which may result in a lack of technical support and inability to update the domain programmes for the E&P segment. Another threat is the limited computing capacity required for building models. The limitation is due, among other things, to frequent technology changes, requiring the use of hardware with higher parameters, which may reduce the analytical capacity, extend the time of generating management information and, consequently, halt or delay PGNiG’s works. |
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Competition
In the Exploration and Production segment: Norway:
In the Trade and Storage segment Wholesale trade:
PGNiG OD:
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In the Exploration and Production segment: Both in Poland and abroad there is a risk of competition from other companies seeking licences for exploration and appraisal of hydrocarbon deposits, although it should be noted that this risk has significantly diminished in the Polish market over the past year. Certain competitors of PGNiG, especially those active globally, enjoy strong market positions and have greater financial resources than those available to the Group. Thus, it is probable that such companies would submit their bids in tender procedures and be able to acquire promising licences, offering better terms than PGNiG could offer given its financial and human resources. This competitive advantage of oil majors is particularly important on the international market.
As in previous years, competitors seek to increase gas fuel sales by offering competitive prices of the fuel or dual fuel (gas and electricity) bundles. A noteworthy development is also the growing activity of large energy companies on the Polish natural gas market. Given the prevailing trend in supplier switch numbers (according to URE data), the number of people switching energy supplier should increase in the coming years. The situation on the domestic market has led to changes in the competitive environment, as a number of smaller sellers have ceased to operate in Poland. On the other hand, the price dynamics may soon create new risks and the possibility of new players entering the Polish market. Particular attention should be paid to the continuing activity of the largest Polish energy companies on the domestic natural gas market. |
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Administrative regulation of natural gas prices and deregulation of the Polish gas market
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Gas trading on the exchange market has been excluded from the tariff regime. Prices of gas paid by end users have also been gradually liberalised as the process of deregulation advances. The first customer groups in respect of which the tariff requirement has been disapplied are wholesale and business customers. Currently, sales in Poland to the largest customers are done on market terms, either through POLPX or on the basis of market price indices. Due to the fact that the structure of sales is not perfectly matched by the structure of purchases (e.g. as a result of production from own sources) and that prices in individual markets may vary, there is a risk of inaccurate estimation of income and expenses, which may adversely affect financial performance.
Dependence of PGNiG OD’s revenue on tariffs approved by the President of URE is the key factor affecting the company’s regulated business. Tariffs are crucial to the company’s ability to generate revenue that would cover its reasonable costs and deliver a return on the capital employed. Currently, a significant portion of that revenue depends on the selling prices of gas fuel and is regulated in accordance with rules which have been modified in 2021 and 2022. In order to protect households against a surge in natural gas prices, in December 2021 a mechanism was introduced into the Energy Law to spread the rise in gas tariff prices over time (Art. 62f). Further legislative amendments imposing additional obligations and requirements on PGNiG aim at protecting natural gas customers who are particularly exposed to the impact of price rises, extending tariff prices to cover additional customer groups. The new regulations envisage achieving the objective of protecting households and customers providing public services, while introducing compensation for gas sellers to tariff customers. |
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Take-or-pay gas supply contracts
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PGNiG is a party to long-term take-or-pay contracts for gas supply to Poland, and committed to duly discharging its obligations under those contracts. Assuming that PGNiG’s customer portfolio remains unchanged, the volume of gas imports specified in the take-or-pay contracts will allow the Company to optimise its gas purchases under long-term and spot contracts, including for LNG. If PGNiG loses its market share, there is a risk that the Company would be forced to look for new ways to utilise the surplus volumes of gas in its portfolio. |
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Market price of natural gas
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Growing costs of gas procurement on the Polish Power Exchange (POLPX). Since the beginning of 2021, natural gas prices have been growing unprecedentedly across Europe. The soaring prices of gas fuel are driven by a combination of macroeconomic and geopolitical factors; therefore, the global market situation has a direct effect on gas prices in Poland. Gas prices on the Polish Power Exchange in Warsaw are correlated with gas prices on West European markets, especially Germany and the Netherlands. The unprecedented surge in gas fuel prices is a global and extremely complex phenomenon. In 2021, the economies of individual countries started to grow dynamically on a rebound after pandemic-related lockdowns, which became a key driver behind the global price growth. This coincided with a very low level of gas storage after the cold winter in late 2020 and early 2021, as well as with insufficient supply of natural gas, mainly due to Russian Gazprom’s behaviour. Gazprom, the main gas supplier to Europe, failed to fully utilise the existing technical capacities for gas transit in the western direction and to inject sufficient volumes of gas into its storage facilities in Western Europe ahead of the winter. Cumulation of all these adverse factors has contributed to a record-high price increase in the last 12 months. For PGNiG OD, which sells gas on the retail market, this has translated into higher gas procurement costs.
The need to increase selling prices may adversely affect the Company’s image and growth prospects of the retail market. |
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Electricity prices
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The volatility of electricity prices is one of the key risks affecting the Company’s financial performance. This risk is mitigated by the use of diversified contracts: both SPOTs and forwards to hedge the company’s projected exposure at a specified rate and time horizon of the hedging arrangements. 2021 was a year of unprecedented price increases: the annual contract for the next calendar year quoted a price above PLN 900/MWh in December 2021. In the next year, the price of electricity will also be subject to significant changes, depending, among other things, on fluctuations in the prices of CO2 emission allowances, the share of renewable energy in Poland’s generation mix and changes in the balance of cross-border electricity exchange.
The volatility of electricity prices is also one of the key risks affecting the financial results of the Generation segment. Sales of electricity are governed by rules that limit exposure to the volatility. Any negative impact of lower prices on financial results is limited by matching the sales with purchases of CO2 emission allowances. |
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Prices of CO2 emission allowances
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The Group purchases CO2 emission allowances in quantities representing the difference between actual emissions and the emissions covered by free emission allowances it receives. CO2 emission allowances are purchased in accordance with the Company-set rules, defining the time horizon of purchases made and the rate of hedging the open position. In 2021, the prices of CO2 emission allowances increased (weighted average price on the ICE and EEX exchanges was EUR 59.41/tonne), to exceed EUR 80/tonne in December 2021. In the following year, the price of EUAs will mainly depend on the share of conventional sources in the staple of electricity generation, which is an effect of the efficiency of renewable energy sources and margins delivered by generation sources based on hard coal, lignite and natural gas. |
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Fuel prices
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In the Generation segment, the key fuels used for heat and electricity production are coal, gas and biomass. Matching the timing of sales of electricity and certificates of origin with the timing of fuel purchases makes it possible to partly to mitigate the adverse impact of rising fuel prices on the Company’s results. |
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Coal procurement and supply
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Coal is purchased by the Company mostly under contracts executed in advance and designed to ensure that strategic coal stocks are maintained above the level required by the Regulation of the Minister of Economy. Coal transport services are purchased in accordance with the Public Procurement Law. Contracts for the purchase and supply of coal may not be fully performed (as was the case in 2021). |
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Volume risk
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The volume of sales of cogenerated heat and electricity depends on weather conditions in the heating period. Above-average air temperatures result in lower sales and consequently lead to lower financial results of PGNiG TERMIKA S.A. Due to the volume risk, the Company adjusts its production plans to climate trends. |
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Adapting to BAT requirements
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With installations adapted to meet the requirements expressly stated in the Industrial Emissions Directive (IED), the next step will be to ensure compliance with emission limits imposed under the decision establishing the BAT Conclusions for large combustion plants. The deadline for compliance was August 17th 2021 or, where an IED derogation applied to an installation, the end date of the relevant derogation period. An investment plan has been developed for the PGNiG TERMIKA to ensure that the emission and technology requirements defined in the BAT Conclusions are duly met. The process of obtaining amendments to integrated permits in connection with the adaptation to the BAT requirements has been completed. Timely completion of investment projects plays a crucial role. Also, the implementation of the BAT Conclusions is monitored on an ongoing basis and any doubts as to their interpretation are clarified. |
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Limited market development in terms of supplying the distribution network
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Limitations at the entry points to the distribution system result from constraints of the supply network and insufficient capacity of gas stations. Consequently, the possibility of connecting new customers and gas network roll-out may be limited. In addition, end users may switch to direct or substitute competitors as it is no longer possible to finance connection projects other than those covered by existing contracts. |
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Risk of instability of the regulatory environment in Poland and EU
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This risk is associated with the ongoing process of developing long-term sectoral regulations. As regards changes, there have been changes in technical guidelines for buildings (e.g., lowering of the primary energy (PE) limit), dependence on the energy efficiency of equipment and preferences for using renewables. The use of natural gas as a bridge fuel in the process of energy transition and towards climate neutrality is justified. As regards energy generation, changes are already seen in energy savings from energy efficiency improvement projects (e.g. thermo-modernisation of buildings, higher energy class equipment) and synergies with renewables (e.g. solar thermal systems, PV panels, heat pumps). These measures reduce unit demand for energy from end users. If the risk materialises, tariffs may be set at levels that do not secure the expected return on capital invested in the distribution of gas fuels. A measure to prevent the risk from materialising is to seek implementation of legislative changes and a relevant agreement with the URE. |
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Claims raised by property owners
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The risk arises from failure to secure a permanent legal title to property at the stage of project execution and property owners’ higher awareness of the related legal aspects. The consequences of materialisation of this risk include substantial claims raised by property owners regarding fees for occupying their property or limiting their right to use the property, an increase in litigation volume and costs, claims for removal or alteration of infrastructure, as well as provisions and claims related to extra-contractual use of property. |
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Substitution
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The substitution risk is associated with a potential lower cost of using alternative fuels and with unavailability or insufficient capacity of the gas network. The risk may arise from inability to use a wide range of marketing tools due to the nature of the business (separation of distribution and sales operations), from the direction of changes in the national energy policy, and from fuel price development on commodity exchanges. Materialisation of the substitution risk may suppress revenue and volume growth, while reducing efficiency of the networks built. |
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Lower amount of EU funds allocated for financing gas distribution projects
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This risk results from fund allocation priorities set by institutions responsible for distribution of EU funding. Unfavourable fund allocation may result in unavailability of financing for submitted projects or in low efficiency of such projects. One preventive mechanism is to promote the Company’s needs in institutions responsible for distribution of EU funding and the implemented RTE Rules to assess projects potentially eligible for co-financing. |
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Limitations on the contractors market
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This risk results from an insufficient number of qualified contractors, deteriorated competitiveness in the contractors market, increase in the cost of labour, and limited access to materials and services due to the COVID 19 pandemic. Should this risk materialise, implementation of planned investment processes may be slower than expected. |
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Lack of long-term regulatory policy
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The risk is related to the absence of long-term rules for determining the level of prices and charges in the distribution tariff. If the risk materialises, tariffs may be set at levels that do not secure the expected return on capital invested in the distribution of gas fuels and it may be difficult to obtain approval for each subsequent tariff. A measure to prevent the risk from materialising is to seek implementation of legal changes obliging the President of URE to establish a multi-year tariff regulation model, development of a regulatory-tariff model and a relevant agreement with the URE. |
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Regulated activities, administrative decisions in the Trade and Storage segment
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The validity of a decision dated May 16th 2012 (as amended) to grant the Company a licence for storing gas fuels in gas storage facilities for the period from June 1st 2012 until May 31st 2022 (the “Licence”) and a decision dated May 22nd 2012 (as amended) to designate the Company as the gas fuel storage system operator (the “Operator Decision”) expires on May 31st 2022.
On October 29th 2020, the Company filed a request with the URE to extend the Licence term from June 1st 2022 to May 31st 2042. The administrative proceedings are pending. The request to extend the term of the Operator Decision was also filed by PGNiG S.A., the owner of the storage facilities, in 2020, and the administrative proceedings have not yet been closed. |
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Risks related to equity investments (ventures)
Risk related to investing in growth companies
Risk related to industry exposure
Risk related to market environment
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The risk stems from the fact that investees’ ability to deliver performance is highly unpredictable. It should be noted that venture capital investments inherently carry a high degree of risk. This feature of such projects manifests itself throughout the investment period. The risk is managed by inclusion in the investment agreements of risk mitigation mechanisms. However, it is not possible to eliminate the risk completely.
The Company invests in entities offering solutions for the energy and for the exploration and production sectors. The absence of sectoral diversification is one of the major risk factors for the fund. The Company seeks to diversify its investment portfolio through inclusion of diverse companies from different and uncorrelated sectors. The purpose of such diversification is to reduce the impact of economic fluctuations in different sectors and trends on the value of the portfolio. Given the current situation on the gas market, the Company has identified the risk that its investment activity may be constrained by the availability of funds to be used for such investments. The Company assesses this risk as a temporary one until gas prices stabilise. |
Regulatory risks
| Risk | Description |
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Obligation to diversify gas imports
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The Council of Ministers’ Regulation of April 24th 2017 on the minimum level of diversification of foreign sources of gas supplies prescribes the maximum share of gas imported from a single country in total gas imports in a given year. In 2017–2022, the share may not exceed 70%. In view of the solutions adopted in the Regulation, the regulatory risk of its breach is low, as is the probability of its materialisation. |
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European Green Deal
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In 2021, the European Commission unveiled its draft legislation implementing the European Green Deal. The European Commission proposes to significantly cut the financing of fossil fuel infrastructure and to reduce the use of fossil fuels in the long term, in line with the climate neutrality objective. |
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New EU legislative package for the natural gas market
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On December 15th 2021, the European Commission presented legislative proposals to amend the provisions of the Gas Directive 2009/73, the Gas Regulation 715/2009 and the Security of Gas Supply Regulation (Regulation 2017/1938).
Proposals concerning tariff discount mechanisms to secure LNG supply and storage facilities, the stockholding obligation and mutual recognition of suppliers in the EU/EEA should be considered as factors of particular risk. |
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Regulation on methane emissions reduction in the energy sector.
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The proposal for a regulation of the European Parliament and of the Council on methane emissions reduction in the energy sector [COM(2021) 805], published by the European Commission on December 15th 2021, introduces a number of obligations related to leak detection, quantification and repair (LDAR) and to venting and combustion in flares. Being very stringent, those obligations would require significant financial outlays, reducing the competitiveness of companies, and could be difficult to comply with. Moreover, there are no corresponding gas import requirements because EU regulations do not apply to third country companies. Instead, information obligations have been imposed on gas importers. |
Non-compliance risk
Changes in and impact of material regulatory risks on the PGNiG Group
| Risk | Description |
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Non-compliance risk
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PGNiG has an organisationally and functionally separated compliance unit. In line with the compliance risk management model, each area at risk of non-compliance was assigned a dedicated compliance risk area manager (leader), who is in charge of ensuring that compliance standards are met. Since 2020, the Company has applied the ‘PGNiG Compliance Risk Management Procedure (the Compliance Programme)’, which formalises the Company’s compliance management model. Compliance risks (risks of breaching compliance standards) may arise in various areas and may materialise:
As part of anti-corruption measures, the PGNiG Group has put in place the ‘PGNiG Group Anti-Corruption and Misconduct Prevention Policy’, and additionally – the ‘PGNiG S.A. Anti-Corruption and Gift Procedure’, implementing the above policy at PGNiG. The internal regulations referred to in the preceding sentence were adopted in 2021, replacing the internal regulation which had previously governed that area. In addition, the Ethics and Compliance Management System is in place at the PGNiG Group, as a result of which the ethics and compliance areas were integrated into the Compliance Department. In addition, the ‘Transparency Policy for Managers’ is applied, with the principal objective of eliminating the risk of conflicts of interest and lack of transparency in decision-making processes within the PGNiG Group. The PGNiG Group also follows the PGNiG Group Code of Ethics, which is based on four values: quality, reliability, responsibility and partnership. The ‘Procedure for Reporting Cases of Misconduct and Handling the Reports at PGNiG S.A.’, as amended in 2021, is also in place, setting out the rules for reporting violations of laws, procedures and ethical standards, as well as the procedure for handling such reports. Pursuant to the above procedure, the Company has both internal and external reporting channels. The external whistleblowing channel has been available from the Company’s website since 2020. |
Financial risks
PGNiG and the PGNiG Group are exposed to financial risks, including in particular:
- Credit risk For more information, see Note 7.3.1 to the consolidated financial statements of the PGNiG Group,
- Market risk For more information, see Note 7.3.2 to the consolidated financial statements of the PGNiG Group,
- Liquidity risk For more information, see Note 7.3.3 to the consolidated financial statements of the PGNiG Group.
