Climate Change [ESRS E1]

Climate change is a key strategic challenge, material to the long-term resilience of our business model, competitiveness and value creation.

In 2020, we committed to achieving climate neutrality by 2050, as reaffirmed in the ORLEN 2035 Strategy, thereby setting a clear long-term direction for our transformation.

This ambition is delivered through coordinated climate mitigation actions across our own operations and our value chain, including Scopes 1, 2 and 3 greenhouse gas emissions.

Our goal of achieving climate neutrality by 2050 is aligned with the Paris Agreement objective to limit global temperature increase to below 2°C above pre-industrial levels, while pursuing efforts to limit it to 1.5°C, as well as with EU climate policy, including the European Green Deal, which targets climate neutrality by 2050.

Climate governance

Decarbonisation and the energy transition are key strategic priorities within our corporate governance framework, underpinning the long-term resilience of our business model, value creation and alignment with EU climate policy. These matters are taken into account in decision-making at both management and supervisory levels, and form a core of our ORLEN 2035 Strategy⁴, the Climate Policy⁵, ORLEN Transition Plan6, and the Climate pillar of our Sustainable Development Strategy⁷.

Oversight of climate and sustainability matters rests with the Company’s highest governing bodies, including the Management Board and the Supervisory Board, which ensures their integration into strategic planning, risk and opportunity management, and capital allocation decisions. We view decarbonisation and the energy transition not only as regulatory requirements, but also as drivers of our long-term growth, new business lines, low- and zero-carbon technologies and enhanced competitiveness. Emission reduction targets are an integral part of our ORLEN 2035 Strategy, approved by the Management Board and the Supervisory Board. Progress in its implementation is reported regularly to the governing bodies.

Decarbonisation and energy transition objectives are also reflected in the variable remuneration framework for senior management. A portion of the remuneration of the Management Board and key management personnel is linked to the achievement of sustainability and energy transition objectives, including emission reduction targets and the implementation of the ORLEN Transition Plan. This directly aligns management accountability with the Group’s long-term climate ambition and stakeholder expectations.

For further details on the integration of sustainability-related performance targets into our remuneration system and on greenhouse gas emission reduction targets, see disclosure GOV-3.

⁴ ORLEN 2035 Strategy

⁵ ORLEN Group Climate Policy

⁶ ORLEN Transition Plan

⁷ ORLEN Group Sustainable Development Strategy

Transition plan for climate change mitigation [E1-1]

ORLEN Transition Plan

As part of our pathway to climate neutrality, we have developed and published the ORLEN Transition Plan, setting out our priorities, actions and investments supporting the energy transition and progress towards the climate neutrality goal⁸.

The Plan complements the ORLEN 2035 Strategy, published in early 2025, which defines our development path to 2035. Sustainability underpins our long-term business growth and is anchored in the energy transition.

⁸ The ORLEN Transition Plan was adopted by the ORLEN S.A. Management Board on 8 April 2025, as recorded in Minutes No. 1469/25 of the Management Board meeting, and by the Sustainability Committee of the Company’s Supervisory Board on 15 April 2025.

Strategic rationale for the transition

As natural plays a key role in the process of phasing out coal in Central Europe, we intend to further diversify our supply sources and increase own oil and gas production and supply volumes to support broader use of natural gas in the Energy segment and strengthen regional energy security.

With regard to crude oil, and petroleum-based fuels in particular, which continue to play an important role in transport, we intend to keep refining throughput at a level consistent with regional demand for conventional fuels, in line with the scenarios adopted for our strategic planning, as described in disclosure ESRS 2 SBM-3. At the same time, those scenarios assume a gradual increase in the share of renewable energy in transport, both in the form of electricity and other alternative fuels. In parallel, we are developing new business areas, including CCUS, alternative fuels, mechanical and chemical recycling, renewable energy, nuclear power based on SMR technology, and energy storage. By 2035, we plan to fully phase out coal-based energy generation, with coal exiting the power generation mix by the end of 2030, in line with the Net Zero Emissions scenario⁹.

⁹ Based on the Net Zero Emissions scenario developed by the International Energy Agency and published in World Energy Outlook 2025.

Key assumptions of the ORLEN Transition Plan for the energy transition process

Decarbonisation targets

Our emission reduction targets, described in detail in disclosure E1-4, are a central component of the ORLEN Transition Plan and set out a measurable pathway for transforming our business towards a low- and zero-carbon economy. The short-, medium- and long-term targets support a phased reduction of greenhouse gas emissions across our key business segments, while preserving our energy security and financial stability. Their delivery helps align our operational, investment and technology initiatives with the ambition of achieving climate neutrality by 2050.

Alignment with 1.5°C pathway

We have set a long-term ambition for the ORLEN Group to achieve climate neutrality by 2050. At the same time, our emissions reduction pathway for Scope 1 and 2 emissions to 2030 and 2035 is aligned with a warming scenario above 2°C, while our near-term Scope 3 targets are aligned with a scenario above 2.5°C10. This reflects the continued material role of fossil fuels in our business model, including the development of natural gas production and the ongoing operation of our refining assets. As a result, emissions across our value chain, particularly Scope 3 (Category 11 – Use of sold products), which dominates our emissions profile, remain relatively high.

The pace at which we reduce our emissions is closely tied to the pace of the energy transition in Central Europe. The region remains highly dependent on fossil fuels, with a strong need to ensure energy security and limited availability of stable low-carbon alternatives in the short to medium term. In this context, natural gas serves as a transition fuel, while existing refining assets remain essential for maintaining energy and fuel supply. At the same time, economic convergence, relatively high energy intensity of GDP, and the need to sustain growth continue to drive demand for reliable and accessible energy in the region.

Our transition plan assumes continued use of natural gas as a transition fuel and the development of gas-fired generation, including CCGT units, to support energy security and system stability in Central Europe. While these measures contribute to lowering emissions intensity of the domestic energy mix, from the perspective of the ORLEN Group as the reporting entity, they limit our ability to achieve emissions reductions in line with the pace of decarbonisation assumed under a 1.5°C scenario, which requires faster and deeper reductions in fossil fuel use.

By 2035, based on reductions measured using the Net Carbon Intensity indicator – which in the 2019 base year covered 75% of the ORLEN Group’s Scope 1 and 2 emissions and 75% of Scope 3 Category 11 emissions – we expect to decarbonise at a pace broadly consistent with the IEA Stated Policies Scenario. The ORLEN 2035 Strategy and the ORLEN Transition Plan do not preclude achieving climate neutrality by 2050. Rather, they focus on enabling key investment decisions while maintaining flexibility for further transformation activities in the period 2036–2050. This reflects a phased approach to decarbonisation, with full alignment with a 1.5°C pathway expected beyond 2035.

Net Carbon Intensity reduction vs World Energy Outlook 2025 scenarios

The primary benchmarks for assessing the ORLEN Group’s climate targets are provided by the International Energy Agency’s (IEA) scenarios set out in the World Energy Outlook, widely recognised as a credible source of long-term outlooks for the energy sector, in which we operate as an integrated energy group.

The analysis is based on a comparison of the ORLEN Group’s Net Carbon Intensity (NCI) against three IEA scenarios: the Current Policies Scenario (CPS) and the Stated Policies Scenario (STEPS), which reflect current and planned climate policies, respectively, as well as the Net Zero Emissions (NZE) scenario, which is aligned with a pathway limiting the increase in average global temperature to 1.5°C. For the purpose of presenting our emission reduction pathway, historical values were averaged for years where complete data was not available, making it possible to establish 2019 as the base year.

As shown in the chart, our NCI trajectory to 2030 and 2035 is broadly aligned with the STEPS scenario. Over the longer term, assuming climate neutrality is achieved by 2050, it converges with the more ambitious NZE pathway.

Our long-term climate ambition remains aligned with the Paris Agreement objective of limiting global temperature increase to well below 2°C above pre-industrial levels, while pursuing efforts to limit it to 1.5°C. Its delivery, however, will depend on further technological progress, the regulatory environment and demand-side developments shaping the pace of the energy transition, particularly in relation to value chain emissions. At the same time, the targets and actions planned to 2035 represent a transitional phase in our energy transition and will support the development of the operational and technological capabilities required for further emissions reductions beyond 2035. This includes the growing role of zero-carbon energy sources, the development of CCUS technologies, and initiatives to reduce emissions in hard-to-abate sectors, including transport.

ORLEN’s emission reduction pathway against IEA’s Net Zero Emissions (NZE) scenario

Selected decarbonisation levers in own operations¹¹

¹¹ In-house analysis based on the ORLEN 2035 Strategy.

Key decarbonisation actions of the ORLEN Group to 2035

Selected transition levers in own operations¹²

¹² In-house analysis based on the ORLEN 2035 Strategy.

Key transition actions of the ORLEN Group to 2035

Energy transition financing

Planned capital expenditure under the ORLEN 2035 Strategy will support delivery of the ORLEN Transition Plan. We anticipate cumulative CAPEX and merger and acquisition spending of PLN 350– 380 billion in 2025–2035, covering both growth projects and maintenance of existing assets¹³.

Approximately 40% of the expenditure will be allocated to low-carbon projects, leading to the creation of a sustainable product portfolio and supporting the implementation of our transition plan.

¹³ The ORLEN Group is excluded under Article 12 of Commission Delegated Regulation (EU) 2020/1818 of 17 July 2020 supplementing Regulation (EU) 2016/1011 of the European Parliament and of the Council as regards minimum standards for EU Climate Transition Benchmarks and EU Parisaligned Benchmarks.

Breakdown of capital expenditure to 2035¹⁴

¹⁴ Source: ORLEN Transition Plan

Breakdown of capital expenditures by ORLEN’s key activities, in accordance with the Taxonomy classification and NACE codes for oil-, gas- and coal-related activities.

The remaining 60% of capital expenditure relates primarily to the continued development of our natural gas operations, including gas production, import and its use as a fuel in the energy sector, as well as to the maintenance and modernisation of our petrochemical and refining production assets, including the New Chemistry project. It also includes maintenance CAPEX across existing assets in all business segments.

The development of gas-fired power generation (high-efficiency CCGT units) was not classified as low-carbon in the cumulative CAPEX breakdown for 2025–2035 presented in Figure 17. However, these projects contribute to lowering the emissions intensity in energy generation (kg CO₂e/MWh) and the Net Carbon Intensity (NCI, g CO₂e/MJ). They are also eligible under the EU Taxonomy as CCM 4.29 – Electricity generation from fossil gaseous fuels.

At the same time, some investments classified as low-carbon in the cumulative CAPEX breakdown for 2025–2035 in Figure 18 are not included in the CAPEX KPI under the EU Taxonomy. This applies in particular to investments in joint ventures, especially in offshore wind, as well as other transitionenabling activities such as CCUS and initiatives to reduce direct emissions from Upstream & Supply and Downstream assets, including energy efficiency improvements and methane emissions reduction.

To minimise risks associated with inefficient capital allocation, including the risk of locked-in emissions, we have adopted differentiated minimum return thresholds (hurdle rates), calibrated to specific project types.

Minimum return thresholds

The differentiation in capital return expectations reflects the anticipated impact of each project category on the emissions profile. Investments that demonstrably support emissions reduction benefit from more favourable economic evaluation criteria, while projects with a potential to increase the Group’s carbon footprint are subject to more stringent return requirements.

Qualitative analysis of carbon lock-in

Estimates of potential carbon lock-in associated with our key assets and products are based on projections of future greenhouse gas emissions. Over the long term, petroleum products and natural gas may face declining demand, which may affect the value of assets involved in their extraction, processing and sale, and in extreme cases lead to early asset retirement and carbon lock-in.

We identify carbon lock-in risk as material in our transition risk analysis and climate strategy resilience assessment. This risk is addressed as part of our asset portfolio management, including the assessment of assets related to the production, processing and sale of crude oil and natural gas. The analysis covers both Scope 1 and Scope 2 emissions from assets operated by the Group, and Scope 3 emissions from the use of sold products. Carbon lock-in risk is systematically integrated into our strategic planning and investment decision-making.

Scope 1, Scope 2 and Scope 3 emissions are subject to a reduction pathway aligned with our decarbonisation targets, as set out in the ORLEN Transition Plan, and climate mitigation targets reported in disclosure ESRS E1-4. The pathway includes decarbonisation actions across all business segments that are considered material to emissions intensity of our operations: Upstream & Supply, Downstream and Energy.

As part of the carbon lock-in analysis, for Scope 1 we identified the highest-risk areas of our operations, in line with the CSRD framework and the provisions applicable to activities related to crude oil production and refining, as well as the use of gas and coal in electricity generation.

Key areas the ORLEN Group’s operations in terms of Scope 1 emissions; emissions from the highest-risk areas [million tonnes of CO₂e].

Material impacts, risks and opportunities and their interaction with strategy and

business model [E1.SBM-3]

The ORLEN 2035 Strategy and the related ORLEN Transition Plan have been developed in response to the key challenges of the energy transition, including regulatory pressures, shifts in demand patterns, and the need to reduce greenhouse gas emissions across the value chain. Together, these documents define our development priorities and capital allocation directions, enabling us to gradually strengthen the resilience of our business model while maintaining energy security and competitive edge in a changing market environment.

Scenario analysis

To strengthen our organisation’s resilience to a changing external environment, we have embedded scenario analysis as an integral part of our medium- and long-term strategic planning. It serves as a tool supporting strategic decision-making, optimisation of the project portfolio under conditions of uncertainty, and regular updates to macroeconomic assumptions. The analysis covers three differentiated macroeconomic scenarios: a base case, an accelerated transition case and a delayed transition case, which capture alternative decarbonisation pathways, differing, among other things, in the pace of carbon price growth and the associated energy demand trajectory.

In addition, for assessing climate-related risks described in disclosure ESRS2 IRO-1, we considered a scenario aligned with the Paris Agreement, i.e. the low-emission SSP1-1.9 scenario, corresponding to a pathway which assumes keeping global temperature increase to 1.5°, and the high-emission SSP5-8.5 scenario, used for assessing physical risks.

The scenario analysis is based on sector-specific scenarios, enabling assessment of the exposure of our assets and operations to transition risks under different and realistic rates of economic decarbonisation across the region and in the countries where we operate. We use a base-case scenario reflecting current policies corresponding to publicly available reference scenarios: NECM WEM (National Energy and Climate Plan with existing measures) and IEA STEPS (Stated Policies Scenario), which serves as a reference in our strategy definition process¹⁶ and in calculating and recognising costs in financial reporting. Furthermore, we apply scenario analysis to assess how climate-related risks and opportunities may affect our operations, strategy, and the long-term resilience of our business model.

The analysis also takes into account elements of an accelerated energy transition, arising from regulations and instruments currently at the implementation stage, as well as the possibility of a delayed energy transition, assuming a slower pace of climate policy implementation and limited effectiveness of regulatory mechanisms.

The findings from the long-term development analyses of our key assets indicate that, in the mediumterm horizon to 2035, the pace of the energy transition in Central Europe will enable the ORLEN Group to strengthen its competitive position through the execution of the ORLEN 2035 Strategy and objectives embedded in the ORLEN Transition Plan. We also used insights from the Climate Neutrality Plans¹⁷ developed for selected assets and integrated them into the ORLEN 2035 Strategy and ORLEN Transition Plan.

For the period to 2050, uncertainty remains around the future viability of certain decarbonisation technologies, whose cost-effectiveness will depend on both their scalability and, even more critically, the availability and stability of regulatory support. Based on current long-term analyses, in the period 2036–2050, the macroeconomic environment will be characterised by a high degree of uncertainty in projected supply and demand, commodity prices, regulatory frameworks and support instruments, depending on scenario assumptions.

¹⁶ For details of the assumptions used in our strategic planning, see ORLEN 2035 Strategy and ORLEN Transition Plan.

¹⁷ Plans prepared in connection with Directive (EU) 2023/959 of the European Parliament and of the Council of 10 May 2023 amending Directive 2003/87/EC establishing a system for greenhouse gas emission allowance trading within the Union and Decision (EU) 2015/1814 concerning the establishment and operation of a market stability reserve for the Union greenhouse gas emission trading system.

The analyses highlight the need for regular updates to strategic assumptions, reflecting developments in technology, regulatory incentives and investment opportunities. Decisions on the ORLEN Group’s future development and the pace of our progress towards climate neutrality will depend on evolving market conditions and regulatory developments.

Key scenarios used by ORLEN in the assessment of climate-related risks and opportunities and in strategic and financial planning

Description of the processes to identify and assess material climate-related risks and opportunities [E1.IRO-1]

Double materiality assessment summary for climate change [E1.IRO-1]

The identification and assessment of material climate-related impacts, risks and opportunities form an integral part of our strategic planning. The process includes analyses of potential risks and opportunities arising from the implementation of policies, regulations and mechanisms supporting the transition to a low- and zero-carbon economy, in line with the European Green Deal and the Paris Agreement.

Severity

Given the energy-intensive nature of its business, the ORLEN Group has a significant impact on the climate. This impact stems both from the substantial greenhouse gas emissions generated by our own operations and from emissions arising across the value chain, as reported in disclosure E1-6.

Due to the structure of our business model, the vast majority of our emissions arise outside our direct operations and are classified as Scope 3. Accordingly, we focus not only on reducing Scope 1 and Scope 2 emissions, but also on addressing value chain emissions by reshaping our business portfolio and expanding low- and zero-carbon energy sources. These measures are intended to gradually strengthen our business model’s resilience while ensuring energy security, a just transition, and our competitiveness, in line with the framework described in disclosure E1-1.

Risks and opportunities

In our operations we identified climate-related physical risks that may affect our operational continuity, financial performance and service quality. These risks, described in detail in the section below, are addressed by our climate change adaptation activities.

The identification of transition risks and opportunities related to climate change mitigation and energy is based on a set of key indicators that assess our exposure to risks related to the energy transition, while also enabling the identification of opportunities arising from the shift to a low- and zero-carbon economy. These factors form the basis for further analysis of material impacts, risks and opportunities (IRO) and are used in decision-making processes, including the definition of strategic directions and decarbonisation actions.

The analysis of climate-related risks and opportunities was carried out in line with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD), and covered the identification, classification and assessment of physical and transition risks and opportunities over the short, medium and long term.

Material climate-related physical risks

Material transition risks related to climate change mitigation and energy

In parallel, we identify a range of opportunities related to our efforts to mitigate climate change, including opportunities that may arise from enhanced energy efficiency, expanded use of lowercarbon energy sources, newly developed product and service offerings, entry into new markets, and organisational resilience built through business diversification.

Material opportunities related to climate change mitigation and energy

Policies related to climate change mitigation and adaptation [E1-2]

Actions and resources in relation to climate change policies [E1-3]

Set out below are the actions we implemented through 2025 to mitigate climate change and limit its impacts, together with projections for the period to 2030 and 2035.

The scope of these disclosures covers a range of measures, encompassing both ongoing investments and planned initiatives arising from our strategies and the ORLEN Transition Plan. They span, among other things, decarbonisation projects within our own operations, as well as initiatives aimed at reducing emissions across our value chain, including Scope 3 emissions.

The delivery of these actions is supported by dedicated capital expenditures described in the ‘Energy transition financing’ section of disclosure E1-1, which are a key factor underpinning the credibility and feasibility of our decarbonisation targets.

Targets related to climate change mitigation and adaptation [E1-4]

Under the ORLEN 2035 Strategy, we have adopted greenhouse gas emissions reduction targets for 2030 and 2035. They reflect our strategic growth priorities and planned transformation pathway, including the allocation of capital expenditure to the energy transition, and form an integral part of the ORLEN Transition Plan.

Delivery of the targets is supported by dedicated investment programmes and operational measures across our key business segments. Given the strategic importance of the energy transition, the decarbonisation targets are regularly monitored and reviewed within our corporate governance framework. Progress against the targets is reported to the management and supervisory bodies and taken into account in decision-making processes.

The ORLEN Group aims to achieve the following emission reduction targets (calculated relative to the 2019 baseline):

GHG emission reduction targets¹⁸

Emissions reduction targets

Oil & Gas – reduction of absolute Scope 1 and Scope 2 emissions [million tonnes of CO₂e]

The Oil & Gas target covers Scope 1 and Scope 2 emissions from hydrocarbon production and oil processing operations under our operational and financial control.

We aim to reduce these emissions by 13% by 2030 and 25% by 2035 relative to the base year, when they totalled 17.5 million tonnes of CO₂e. In 2025, Scope 1 and Scope 2 emissions amounted to 16.2 million tonnes of CO2e, representing a 7% reduction relative to the base year.

The reduction achieved between 2019 and 2025 was driven by:

• Energy efficiency projects implemented at refining and petrochemical production plants (emissions reduction by approximately 0.5 million tonnes of CO₂e),
• Lower emissions from upstream operations (emissions reduction by approximately 0.1 million tonnes of CO₂e),
• Reduction in Scope 2 emissions (by approximately 0.2 million tonnes of CO₂e),
• The remaining reduction was attributable mainly to production optimisation.

Key identified levers for achieving the emission reduction target in our Oil & Gas operations, i.e. the Upstream & Supply and Downstream segments, include:

• Reduction of emissions from upstream operations, to be achieved primarily by cutting methane emissions and eliminating routine gas flaring. In this context, we have adopted two targets for 2030 – Zero Routine Flaring and Near Zero Upstream Methane Emissions – covering all upstream operations under control of ORLEN Group companies acting as the operators;
• Expansion of the use of low-carbon energy by decommissioning integrated generation assets relying on carbon-intensive energy sources and shifting generation towards lower-carbon sources;
• Implementation of energy-efficiency solutions such as heat recovery systems and electrification of production facilities;
• Production and use of renewable and low-carbon hydrogen and its derivatives as a key energy carrier supporting the decarbonisation of our own operations;
• Development of the carbon capture, utilisation and storage (CCUS) technology to reduce emissions from our refining and petrochemical plants;
• Reduction of Scope 2 emissions, i.e. indirect greenhouse gas emissions from the generation of purchased electricity and heat.

Levers for reducing greenhouse gas emissions

Power & Heat – reduction of emissions intensity in electricity and heat generation [kg CO₂/MWh]

The Power & Heat target covers Scope 1 greenhouse gas emissions from operations contributing to electricity and heat generation that are under the Group’s operational and financial control, as well as emissions and energy generation volumes from joint ventures accounted for using the equity method. This approach ensures alignment with the objectives of the ORLEN 2035 Strategy and the ORLEN Transition Plan, under which the delivery of strategic KPIs in conventional gas-fired generation and renewable energy is supported, among other things, by the development of activities carried out through joint ventures.

We aim to reduce emissions intensity in energy generation by 40% by 2030 and 55% by 2035 relative to the 2019 base year, when it stood at 377 kg CO₂e/MWh.

In 2025, the metric was 309 kg CO₂e/MWh, down 18% pp versus the base year. The reduction achieved between 2019 and 2025 was attributable to the growth of renewable and gas-fired energy generation, as well as lower utilisation of coal-fired power plants and CHP plants. In particular:

• Emissions from energy generation were down by approximately 0.8 million tonnes of CO₂e, mainly as a result of a reduced use of coal;
• Energy output increased by 3.5 TWh, primarily due to the development of renewable energy sources.

The identified decarbonisation levers for reducing emissions intensity in the Energy segment (kg CO₂e/MWh) include:

• Expansion of renewable energy sources, primarily by increasing the installed capacity in offshore and onshore wind projects and solar PV assets;
• Expansion of gas-based power generation, including the construction of highly efficient combinedcycle gas turbine (CCGT) plants to replace the most carbon intensive and least efficient coal-fired units in Poland and strengthen the stability to the national power system amid rapid development of renewable energy generation;
• Coal phase-out in power generation, that is the discontinuation of coal use for electricity generation through the decommissioning of the coal-fired Ostrołęka B power plant by 2030;
• Transformation of the heat generation segment by gradually moving away from coal in cogeneration and transitioning towards natural gas, renewable energy sources such as biomass and biogas, and increased electrification of generation processes;
• Development of small modular reactors (SMRs) – an innovative zero-carbon technology supporting the decarbonisation of power generation, heat generation and industry.

Levers for reducing greenhouse gas emissions

Net Carbon Intensity – reduction of Net Carbon Intensity (NCI) of the ORLEN Group’s energy products [g CO₂e/MJ]

The Net Carbon Intensity target covers Scope 1 and Scope 2 emissions from operations related to the production of hydrocarbons and fuels and generation of electricity and heat, as well as Scope 3 Category 11 emissions from the use of our energy products and volumes of energy generated by the ORLEN Group.

We aim to reduce the NCI by 10% by 2030 and 15% by 2035 relative to the 2019 base year, when it stood at 78.6 g CO₂e/MJ.

In 2025, the metric was 77.2 g CO₂e/MJ, down 2% from the base year. resulting from increased generation of power and heat from low- and zero-carbon sources, as well as the reduction of Scope 1, Scope 2 and Scope 3 emissions.

Identified levers enabling achievement of the Net Carbon Intensity (g CO₂e/MJ) target:

• Increased production of low- and zero-carbon energy, driven by investments in the Energy segment and ramp-up of our own natural gas production;
• Development of the production of alternative fuels, including biofuels, synthetic fuels, and automotive-grade hydrogen, capable of effectively replacing conventional petroleum-derived fuels in the transport sector;
• Decarbonisation and optimisation of our own operations, through measures such as energy efficiency improvements, methane emission reductions, capture and storage (CCS) of carbon from our installations, switching to lower-carbon energy sources, and the phase-out of coal in power and heat generation;
• Development of carbon management services, supporting the capture and storage of emissions generated by third parties. The capture and storage of these third-party emissions constitutes a technological offset, making it possible to reduce CO₂ emissions beyond our own operations.

Levers for reducing greenhouse gas emissions

NCI calculation methodology

We have developed a dedicated Net Carbon Intensity (NCI) calculation methodology to measure carbon intensity per unit of energy generated. The largest source of emissions in our value chain is the use of sold products, which is accounted for under Scope 3, Category 11.

Our NCI methodology focuses on key decarbonisation levers deployed within our own operations, as well as on enabling measures that facilitate the energy transition beyond our own operations by reshaping the energy mix and supporting the decarbonisation of industrial sectors.

We adopted a production-based approach, which mitigates the risk of double-counting while capturing all relevant areas and material emissions where future development is expected to most significantly contribute to reducing carbon intensity.

Energy consumption and mix [E1-5]

Methodology for calculating energy consumption and mix

Energy consumption data cover all companies referred to in disclosure BP-1. Data on electricity, heat and fuel consumption are obtained from measurement systems operating within production units, ERP systems, operator reports and invoices from energy suppliers. Where complete data are not available, we use estimates based on industry benchmarks and historical data. The collected primary data are converted into final energy using factors aligned with national guidelines and applicable reporting standards.

As part of the reporting process, we identify energy flows between Group companies and subsequently eliminate them in order to avoid double counting of consumption. Energy purchases are classified by supplier and origin, taking into account guarantees of origin and energy mix data published by energy suppliers. Energy generated within the Group is allocated to the appropriate categories based on the source and type of fuel. Own consumption of individual Group companies is determined based on the balance of energy purchased, generated and resold, and is subsequently consolidated at the Group level.

As part of ongoing improvements to the reporting methodology, we made adjustments to the 2024 data on generated electricity volumes and to the method used to determine consumption of energy purchased from outside the organisation for one of the trading companies. The adjustment reduced the generated energy volumes by 14,273 MWh.

In addition, following a refinement of the methodology and in the absence of reliable information confirming the origin of nuclear energy, all energy consumption from nuclear sources reported for 2024 was reclassified as energy purchased or energy from fossil sources. Adjustments were also made to the data on the consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources. The adjustments followed from a change in the methodology used in the calculations: we applied the market-based approach instead of the location-based approach, in line with the applicable sustainability reporting guidelines. Total energy consumption was revised to include a portion of fuels combusted in refining and petrochemical processes that had been omitted from the previous report, and the classification of gaseous fuel generated in crude oil processing was also changed.

Taken together, all changes made to the 2024 disclosure increased total energy consumption by 843,988 (1%).

Energy consumption and mix

Non-renewable and renewable energy generation

Energy intensity

Gross Scopes 1, 2, 3 and Total GHG emissions [E1-6]

The reporting boundary for the ORLEN Group’s greenhouse gas emissions is the same as that used in the ORLEN Group’s consolidated financial statements, and is described in disclosure BP-1. Compared with 2024, the organisational boundaries were adjusted in line with changes in the ORLEN Group organisation and structure. The allocation of the carbon footprint by business segment was also revised to reflect the new management structure of the ORLEN Group.

In 2025, the Scope 3 emissions data for 2024, originally reported as estimates based on 2023 data and revenue-based indicators (2023 vs 2024), were replaced with emissions calculated using actual operational data and literature-based emission factors, in accordance with the GHG Protocol. At the time of release of the 2024 Sustainability Statement, Scope 3 emissions were not compliant with the GHG Protocol due to data availability constraints. In this Sustainability Statement both the 2025 emissions and the restated 2024 data are compliant with the GHG Protocol and ESRS.

The year-on-year differences are mainly attributable to:

• a review and development of new questionnaires for collecting more comprehensive operational data from individual companies;
• disclosure of the full biogenic emissions for fuels containing biocomponents outside the scopes::
  • for Scope 1 purposes, biogenic emissions from the combustion of biogenic components in gasoline (10% bioethanol) and diesel oil (7% FAME) were calculated and reported outside Scope 1 for the Group as a whole, and biogenic emissions associated with purchased and used electricity, heat, steam and cooling were disclosed without excluding them from total Scope 1 emissions;
  • for Scope 3 purposes, biogenic emissions were excluded from Scope 3 Category 11 and presented separately;
• changes in the classification of purchased fuel depending on fuel use (own consumption: Scope 3 Category 3; resale: Scope 3 Category 1); fuels consumed by the Group, i.e. burned or used in the production process, were included in Category 3 in 2025 (in 2024 they were included in Category 1);
• allocation of transport of fuels used for own consumption to Scope 3 Category 3.

Differences between the 2024 and 2025 Scope 1 and Scope 2 carbon footprint results are mainly due to a change in the approach to collecting, processing and consolidating emissions data. In 2024, the calculations were performed using Excel spreadsheets, which involved a greater degree of manual data processing, more limited automation of quality controls, and a higher risk of inconsistencies in the way individual entities reported and aggregated data. In 2025, a new database tool was implemented, enabling more structured and consistent management of input data, automation of part of the validation process, standardisation of the calculation logic, and a more complete reflection of the reporting boundary. In effect, the results for 2025 and previous years are based on a more mature and systematic calculation process, which may have affected the reported emission amounts compared with the previous years.

For on-site wastewater treatment plants, we adopted the formulas provided in the IPCC 2019 Refinement Guidelines. Scope 3 emissions based on primary data from suppliers and value chain partners accounted for less than 0.1% of total data in 2025; the remaining calculations were based on annually updated literature-based emission factors.

The calculation process was carried out in accordance with the following methodologies:

• GHG Protocol Corporate Standard (Scope 1),
• GHG Protocol Scope 2 Guidance (Scope 2),
• GHG Protocol Scope 3 Standard (Scope 3).

Sector-specific guidance issued by the American Petroleum Institute (API), International Petroleum Industry Environmental Conservation Association (IPIECA) and International Association of Oil & Gas Producers (IOGP) was also used to reflect the specific characteristics of emissions in the oil and gas sector. Data were collected using dedicated Excel templates, and calculations were performed in a database tool that automatically retrieved the source data.

Regulated Scope 1 greenhouse gas emissions [tonnes of CO₂e]

Scope 1 and Scope 2 GHG emissions (two reporting perspectives) [tonnes of CO₂e]

Scope 3 GHG emissions by category

Total GHG emissions by value chain level [tonnes of CO₂e]

Emissions intensity indicators

Emissions intensity calculated as gross GHG emissions to net revenue as disclosed in the ORLEN Group consolidated financial statements.

ORLEN Group carbon footprint by operating segment [tonnes of CO₂e]

Biogenic CO₂ emissions from the combustion or biodegradation of biomass (Scope 1, Scope 2 and Scope 3) [tonnes of CO₂e]

GHG removals and GHG mitigation projects financed through carbon credits [E1-7]

During the reporting period, we did not use any GHG removal and storage projects in our own operations, within the value chain or outside the value chain. In addition, we did not identify any carbon credits outside the value chain that had been cancelled or were planned to be cancelled.

In the short and medium term, we expect to use CCU and CCS technologies as measures to reduce greenhouse gas emissions.

As we continue to develop our decarbonisation strategy, we will assess the potential use of technological offsets, including CCU and CCS, as well as nature-based offsets, particularly in the context of the long-term target of achieving climate neutrality.

Any broader use of offset instruments, including carbon credits, by 2050 will be considered only to the extent provided for and on the terms set out under European Union regulations, taking into account the conditions formally established in applicable and future legislation and regulatory guidance.

Internal carbon pricing [E1-8]

We have mechanisms in place that support the allocation of capital towards low- and zero-carbon investments. One of the key instruments is the incorporation of the cost of CO₂ emissions into financial and strategic planning for activities covered by the EU ETS. As a result, the cost of emissions becomes a material factor in assessing the economic viability of new projects and influences both investment and strategic decision-making across the Group.

The carbon prices we use in strategic planning are consistent with those applied for the purpose of financial reporting, for instance to determine the useful lives of assets, perform impairment tests, and assess the economic viability of potential acquisitions in relation to assets covered by the EU ETS.

The internal carbon pricing mechanism is primarily used to assess the impact of new investments on Scope 1 emissions, particularly in areas covered by the EU ETS, which account for over 90% of the ORLEN Group’s direct emissions. With this approach, we can evaluate the project’s likely performance under future conditions, with tightening regulations and rising allowance prices, and select solutions aligned with our decarbonisation targets and long-term climate strategy.

For the purposes of strategic planning, we apply internally-developed assumptions regarding future CO₂ prices, reflecting the trajectory of the EU climate policy. They are based on three scenarios: base case, accelerated transition, and delayed transition, which differ primarily in the pace of allowance price growth and energy consumption pathways. The assumptions are intended to reduce the impact of short-term market volatility and provide a clearer view of the long-term trend.

We assume a continued increase in EUA prices under the EU ETS in the longer term, consistent with the EU’s objective of achieving climate neutrality by 2050. Under the base scenario, this implies:

• an increase in prices to approximately EUR 120/tonne of CO₂ by 2030;
• a further rise to over EUR 250/tonne of CO₂ around 2040;
• followed by growth towards approximately EUR 350/tonne of CO₂ by 2050.

At the same time, we are monitoring the development of the new EU ETS 2 system, which will cover part of Scope 3 emissions, particularly those related to road transport and buildings. Given the early implementation stage of ETS 2, we are currently assessing its potential impact and progressively incorporating it into our financial and strategic planning processes.