Pollution [ESRS E2]

Double materiality assessment summary for pollution [E2.IRO-1]

Policies related to pollution [E2-1]

We have completed work on the development of a draft policy dedicated to the management of material impacts, risks and opportunities relating to pollution prevention and control, including air, water and soil pollution, the substitution of substances of concern and minimisation of their use, and the gradual phase-out of substances of very high concern. The policy will also address the prevention of incidents and emergency situations, as well as the effective management of their impacts on people and the environment. The policy development process was initiated in the second quarter of 2025, and the formal adoption of the document is planned for 2026.

Pending the development and implementation of a dedicated policy, pollution prevention and abatement matters are addressed in the ORLEN Group Environmental Policy, introduced by an order of the President of the ORLEN S.A. Management Board of 20 January 2025. It was developed as an internal Group-wide regulation and, prior to its adoption, was subject to broad consultation across multiple areas of our organisation. The ORLEN Group companies were also required to make sure it is effectively communicated to their employees.

The ORLEN Group Environmental Policy constitutes the overarching framework for environmental management within the ORLEN Group and comprehensively covers key aspects of our impacts on the environment. It sets out our commitments to minimising the environmental adverse impacts of our operations and defines the principles that guide our activities.

Our commitments under the ORLEN Group Environmental Protection Policy include:

• establishing environmental protection objectives for the Group’s operations;
• considering environmental impacts in the process of capital project planning;
• focusing on innovation and the advancement of new technologies that may drive improvements in environmental protection;
• improving on an ongoing basis operational processes and environmental management systems; implementing sustainable practices;
• implementing planned measures to achieve the environmental protection objectives for the Group’s operations and monitor progress;
• conducting environmental studies, surveys and programmes, and advancing the digitalisation of processes across the Group’s operations to improve environmental impact monitoring and mitigation;
• requiring contractors to comply with specified environmental standards and supporting them in their efforts to reduce negative environmental and climate impacts;
• raising awareness and effectively implementing the principles of the ORLEN Group Environmental Protection Policy, including through educational initiatives and employee training, fostering proenvironmental attitudes and actions, and promoting the concept of sustainable development within local communities.

The Environmental Protection Policy primarily applies to our own operations and, where relevant, extends across our value chain, in particular by requiring contractors and suppliers to comply with specified environmental standards.

The Policy provides a robust foundation for further, more detailed sectoral policies, including the planned pollution prevention and abatement policy, as well as the Circular Economy Policy, which was developed and subsequently approved by the President of the ORLEN S.A. Management Board in 2025.

Pollution-related matters form a pillar of our Sustainable Development Strategy for 2025–2035, reflected in Stream 6 – Circular economy and pollution abatement. One of the objectives of this stream for 2030 is the optimisation of the ORLEN Group’s emission indicators for SO₂, NOx, particulate matter and other pollutants.

In addition, we have environmental management systems in place at the ORLEN Group that address pollutant emissions control and abatement. The relevant documents are designed to ensure the safe conduct of operations in full compliance with applicable legal regulations. They serve as key instruments supporting responsible management, with a particular emphasis on maintaining the highest standards in occupational health and safety and environmental protection, as well as strengthening employee awareness in this area among our workforce engaged in activities that may impact the environment.

Actions and resources related to pollution [E2-2]

The ORLEN Group’s operations, encompassing oil and gas production, crude oil refining, production of organic and inorganic chemicals, combustion, product packaging, as well as service activities, are associated with environmental impacts, in particular pollutant emissions. The scale and nature of these impacts vary depending on the type of each company’s operations, as well as its size and geographical area of activity.

We are actively working to reduce the adverse environmental impacts of our operations and to mitigate pollution-related risks through such measures as investing in equipment and technologies that reduce pollutant emissions, implementing BAT/BREF guidelines on emission reduction techniques and measures, progressively substituting hazardous substances with biodegradable alternatives, and maintaining rigorous incident and spill response procedures.

The directions of our initiatives addressing material pollution-related issues are set out in the ORLEN Group Sustainable Development Strategy for 2025–2035 and in the ORLEN Group Environmental Protection Policy aligned with the Strategy.

The ORLEN Group companies monitor pollution levels on an annual basis through, inter alia, air emission measurements and tests of soil, water and wastewater conducted by accredited laboratories. The scope and methods of pollution monitoring are aligned with applicable legal requirements and administrative decisions held by the Group, and are carried out in accordance with reference methodologies. The results obtained form the basis for assessing ongoing processes and, where necessary, for undertaking corrective actions. We also duly perform the obligation to report annually on pollutant emissions to the relevant administrative authorities. Selected Group companies disclose this information in publicly available reports.

We have a range of environmental procedures, orders and instructions in place at the ORLEN Group that address the management and reduction of pollutant emissions, including the mitigation of negative impacts of air, water and soil pollution, the prevention of incidents and emergency situations, and the limitation of their impacts on people and the environment. These documents serve to support responsible management, with particular emphasis on maintaining the highest standards of occupational health and safety and environmental protection. They undergo reviews and updates as required. ORLEN Group companies have also established and follow internal procedures for conducting monitoring and performing measurements related to environmental protection.

The ORLEN Group companies allocate financial resources to the implementation of pollution prevention action plans, recognising them as a key element of our sustainable development strategy and efforts to maintain technological leadership. The funding required to deliver our operational and investment plans is budgeted on a case by case basis as part of operational, maintenance and investment plans.

The following resources have been allocated by ORLEN Group companies to pollution-related activities:

• financial resources: including expenditures on measurements and laboratory services, and implementation of budgeted projects related to environmental surveys, monitoring and supervision, as well as capital expenditure;
• technical resources: in particular measurement systems;
• organisational and human resources: including employees responsible for environmental protection, monitoring, reporting, supervision, inspections, plant maintenance, as well as support from external contractors (environmental surveys, advisory services).

Individual pollution-related measures are funded through both operating expenditure (OPEX) and capital expenditure (CAPEX). The capital expenditure spent on these measures in 2025 was approximately PLN 210 million, while the amount planned for 2026 is PLN 235 million.

The majority of expenditures are financed from our own resources and, to a lesser extent, through intra-group loans and external funding, including funding under the European Funds for Infrastructure, Climate and Environment Programme 2021–2027 (FEnIKS), the European Funds for a Modern Economy 2021–2027 instrument, as well as funding for projects involving process innovations in the area of gas infrastructure implemented under the Innovations for the Environment priority programme.

Our key activities are concentrated in the European Union and relate primarily to our own operations. In our operations and across the value chain, we oversee external service providers and suppliers through the ORLEN Group Supplier Code of Conduct. In addition, Group companies may use internal organisational regulations to require counterparties to remedy the effects of any damage caused directly or indirectly by emissions, leaks, discharges or any other forms of release of hazardous substances into the air, water or soil. ORLEN S.A. has also adopted Environmental Protection Rules that provide for periodic inspections of cooperating entities, including checks on their compliance with environmental protection requirements.

Our key projects currently under way or planned, including ongoing pollution-related measures

Targets related to pollution [E2-3]

We plan to define measurable, time-bound and outcome-oriented targets within five years. Meanwhile, for the reporting year 2025 we have adopted pollution-related goals resulting from the ORLEN 2035 Strategy and the ORLEN Group Sustainable Development Strategy for 2025–2035. In line with the objectives of the ORLEN Group Sustainable Development Strategy for 2025–2035, one of the goals to be achieved by 2030 is the optimisation of our emission indicators for SO₂, NOx, particulate matter and other pollutants. Selected ORLEN Group companies adopted a zero-incident principle in relation to potential leakages that may give rise to pollutant emissions, as well as an objective of minimising the use of hazardous chemical substances.

Progress towards the abovementioned goals is monitored using our environmental management systems, including ISO 14001 and EMAS, through emission measurements and analysis, internal audits, periodic reviews of indicators at the level of particular sites and organisational units, and systems such as the Leak Detection and Repair system. The monitoring results are used to assess compliance with emission levels specified in integrated and sectoral permits.

Pollution of air, water and soil [E2-4]

Pollution of soil

We do not carry out any treatment of waste in soil, i.e. in accordance with the E-PRTR definition, releases to soil are associated with waste disposal processes in soil (D2 – Land treatment and D3 – Deep injection (e.g., injection of pumpable discards into wells, salt domes or naturally occurring repositories, etc.)). Soil pollution may occur as a result of emergency situations or incidental leakages. In 2025, no pollutant emissions to soil were recorded during the normal operation of the ORLEN Group facilities.

When potential soil pollution is identified, tests are carried out to analyse whether permissible limits have been exceeded. Measurements are performed on the basis of accredited sampling and chemical analyses of soil samples conducted by accredited laboratories. Additionally, periodic tests are performed at selected ORLEN Group facilities in accordance with decisions issued by the relevant administrative authorities for specific areas, such as province marshals. Measurement and sampling of pollutants emitted to soil (for the companies operating in Poland) are conducted in accordance with the Regulation of the Minister of the Environment of 1 September 2016 on methods for assessing soil surface contamination (Dz.U. of 2016, item 1395), as well as regulations of other countries in which ORLEN Group companies operate.

Data collection for the purposes of accounting and reporting on pollution is governed by an internal order defining the principles for financing and the methods of implementing remediation works at ORLEN S.A. facilities.

For the pollutants listed in Annex II to Regulation (EC) No 166/2006 of the European Parliament and of the Council of 18 January 2006 concerning the establishment of a European Pollutant Release and Transfer Register and amending Council Directives 91/689/EEC and 96/61/EC (the “E-PRTR Regulation”), the volumes of air emissions related to the ORLEN Group’s operations in 2024–2025 that exceeded the thresholds set out in the E-PRTR Regulation are presented in Table 76. In addition, Table 77 presents consolidated emissions data for ORLEN Group companies broken down by business segment.

The tables do not include the six greenhouse gases reported under ESRS E1 Climate Change, namely carbon dioxide (CO₂), methane (CH₄), nitrous oxide (N₂O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulphur hexafluoride (SF₆) and nitrogen trifluoride (NF₃).

The 2024 emissions volumes were determined on the basis of emission factors and, in the 2025 reporting year, were restated to reflect actual data.

Pollution of air

For the pollutants listed in Annex II to Regulation (EC) No 166/2006 of the European Parliament and of the Council of 18 January 2006 concerning the establishment of a European Pollutant Release and Transfer Register and amending Council Directives 91/689/EEC and 96/61/EC (the “E-PRTR Regulation”), emissions from our installations in 2024–2025 that exceeded the thresholds set out in the E-PRTR Regulation are presented in Table 81. In addition, Table 82 presents consolidated data on emissions from the ORLEN Group companies’ installations broken down by business segment, which also take into account the thresholds set out in the E-PRTR Regulation.

The 2024 emissions originally reported in the 2024 Sustainability Statement were determined on the basis of emission factors. In the 2025 reporting year, they were restated to reflect actual data. The initial use of estimates was due to the lack of a complete set of measurement data at the time the 2024 Sustainability Statement was published. The originally published 2024 emissions of nonmethane volatile organic compounds (NMVOC) were overstated relative to the actual figures not only because they had been calculated using emission factors, but also because the unit of measure was incorrectly assigned to data from one of the companies.

No values were recorded for the Consumers & Products and Corporate Functions segments.

ORLEN Group facilities emit air pollutants as a result of their production processes. The substances representing the largest share of our total emissions are sulphur oxides, nitrogen oxides, nonmethane volatile organic compounds, carbon monoxide and particulate matter.

Pollution of water

For the pollutants listed in Annex II to the E-PRTR Regulation, air emissions from our installations in 2024–2025 that exceeded the thresholds set out in the E-PRTR Regulation are presented in Table 83. The 2024 emissions originally reported in the 2024 Sustainability Statement were determined on the basis of emission factors, and in the 2025 reporting year they were restated to reflect actual data. The initial use of estimates was due to the lack of a complete set of measurement data at the time the 2024 Sustainability Statement was published.

The period-to-period differences in pollutant emissions discharged to water by the ORLEN S.A. production plant in Płock are driven primarily by the composition of the raw water abstracted from the Vistula river, the characteristics of the media processed in the production units, and the intensity of precipitation in a given period.

In the ORLEN Południe Group, fluctuations in the quantities of individual pollutants in wastewater between periods result mainly from changes in the composition of spent oils delivered to the Jedlicze plant, seasonal variations in precipitation, which may lead to either concentration or dilution of pollutants, and differences in the production volumes of individual products across the production units.

In the ORLEN Lietuva Group, a slight reduction in the amount of pollutants was recorded in 2025 compared with 2024, despite a small increase in the total volume of wastewater over the same period.

Changes y/y

In 2025, our emissions to air, water and soil remained stable in comparison to 2024, with the observed differences attributable primarily to the natural variability inherent in the nature of our operations.

Changes in the reported indicator values were driven by fluctuations in the scale of our production or operational processes, technological changes such as unit upgrades, temporary shutdowns or modifications to process media, as well as varying levels of operational activity. Other material factors included atmospheric conditions affecting combustion emissions and the variable composition of raw materials and waste directed for treatment. In selected areas, emission levels were also influenced by differences in the volumes of biogas or energy generated.

Some Group companies recorded a decrease in emissions resulting from reduced operation of specific equipment, the discontinuation of selected production processes, implemented upgrades, or a natural decline in the scale of operations. On the other hand, certain increases in pollutant loads were associated with intensified production activity or changes in the mix of fuels and raw materials used.

In many companies, it was confirmed that no wastewater was discharged directly into water bodies or soil, there were no emissions from installations for which the mandatory thresholds defined in the E-PRTR Regulation were exceeded, and no new cases of soil contamination, apart from historical cases subject to ongoing remediation. Therefore those cases were not included in above comparisons.

Measurement methodologies

In 2025, emissions to air, water and soil were monitored at the ORLEN Group using a combination of measurement-based methods, calculation-based approaches and activities aimed at assessing environmental conditions. Direct measurements were conducted wherever required by applicable laws or the terms of permits, and included continuous monitoring of emission sources using CEMS or AMS systems, periodic measurement campaigns performed by accredited laboratories, wastewater sampling – including composite daily samples – as well as soil quality testing carried out in accordance with applicable regulations on assessing land surface contamination. The measurement methods applied at the Group were based on PN-EN and ISO standards, Best Available Techniques (BAT), and industry-specific methodologies relating, inter alia, to emissions of ammonia, particulate matter, heavy metals, polycyclic aromatic hydrocarbons and wastewater parameters.

Where direct measurements were not feasible, we used estimation methods based on various data, including KOBiZE emission factors and literature-based indicators from recognised sources such as CONCAWE or PRTR guidelines, as well as mass balance algorithms, process parameters relating to fuel consumption and equipment operating time, and values specified in integrated permits.

In parallel, we conducted environmental monitoring activities, including wastewater quality checks in accordance with water permit requirements, periodic testing of water and soil, including in areas undergoing remediation, and measurements of key process parameters at wastewater discharge installations, such as pH, temperature and flow rates.

We follow relevant national standards, applied on the basis of European standards, in calibrating our automated measurement systems and verifying periodic measurement results. These standards set out, among other things, the requirements governing the operation of automated measurement systems to ensure an appropriate quality of emissions monitoring. Compliance with those requirements is achieved through quality assurance procedures (QAL) for automated measurement systems (AMS) used at industrial sites. All data collected are transferred to a centralised database, where they are verified, aggregated, organised, checked, grouped and compiled before the final reported emissions figures are established.

Data collection

We use an extensive data collection system, including:

• reports from measurements conducted by accredited laboratories;
• automatic monitoring systems for emitters;
• operational and production documentation;
• records of fuel, material and utilities consumption;
• monthly/quarterly operational reports;
• system registers (e.g. KOBiZE, PRTR);
• environmental testing reports;
• data from fleet and field equipment management systems;
• data from water and wastewater systems, as well as readings from measurement devices.

The data is additionally verified through:

• internal audits;
• inspections by administrative authorities;
• reviews required under environmental management systems (ISO 14001);
• comparisons with previous reporting periods.

Measurement methods

Where calculation-based methods or other indirect approaches were applied, ORLEN Group companies reported that their use resulted primarily from technical constraints preventing direct measurement or from the disproportionately high cost of such measurements. At the same time, the emission factors and input data used were derived from reliable regulatory and industry sources, ensuring consistency and alignment with established standards. The level of uncertainty associated with these calculations remains low due to the stable nature of our technological processes, while methods based on fuel consumption and the corresponding emission factors ensure the repeatability of results. The approaches adopted in the calculations comply with the requirements of applicable environmental permits and reflect common market practice.

At certain Group locations, the very low level of emissions means that no measurement obligation applies, while the absence of installations subject to IED/BAT requirements eliminates the need for continuous monitoring systems such as AMS.

Microplastics

Due to the nature of our operations, the identified potential sources of microplastic emissions are mainly related to unintentional releases of primary and secondary synthetic polymer microparticles (SPM). A key measure applied to limit such emissions is the implementation of effective industry standards, such as the Operation Clean Sweep (OCS) programme, as well as continual education and awareness-raising among employees in the area of responsible management of polymer materials. As a producer of plastics, the ORLEN Group continuously monitors the evolving regulatory environment applicable to microplastics production and emissions, and complies with obligations arising from new regulations. Currently, there is no harmonised, widely recognised methodology for estimating microplastic emissions to the environment that would enable the presentation of comparable data across all reporting companies. Consequently, we do not have the technical capacity to present quantitative indicators of SPM emissions. We recognise the need for further development of monitoring and reporting systems for such emissions in order to enable a more comprehensive assessment of the impact of our operations.

In addition, we actively participate in initiatives of industry organisations addressing microplastics, such as the European Chemical Industry Council (CEFIC) and Plastics Europe Polska. One of their priorities is to develop reliable and consistent methodologies for estimating microplastic emissions, supporting both companies and regulators in effectively limiting their release into the environment.

Substances of concern [E2-5]

ORLEN Group companies produce, procure and use substances of concern in their operations. We continuously monitor substances of concern used in our processes in order to ensure safe working conditions and compliance with applicable legal requirements. The volumes presented in Table 76 are provided for individual hazard classes, meaning that if a given substance is classified in multiple hazard classes, its volume is reported under each of them. The quantities of substances of concern produced by the ORLEN Group have been calculated on the basis of internal reports from individual companies. The quantities of substances of concern that are procured have been determined based on safety data sheets. In the case of mixtures, we take into account substances listed in Section 3.2 of the safety data sheet that meet the definition of substances of concern; where concentration ranges are indicated, the upper bound of the concentration range is applied in accordance with the precautionary principle. To avoid double counting of the volumes transferred between ORLEN Group companies, each volume is reported only once. For substances purchased from outside the ORLEN Group, the volume is reported solely by the first acquiring company. For internally produced substances, the volume is reported only by the producing company. The restated 2024 data mainly reflect the inclusion of Rafineria Gdańska in the consolidated data and adjustments to data reported by Group companies.

The ORLEN Group does not produce substances of very high concern. However, such substances are used in our operations. We continuously monitor substances of very high concern used in our processes to ensure safe working conditions and compliance with applicable legal requirements. We also monitor on an ongoing basis the list of substances of very high concern published by the European Chemicals Agency. The quantities of substances of very high concern that are procured have been determined on the basis of safety data sheets. In the case of mixtures, we take into account substances listed in Section 3.2 of the safety data sheet that meet the definition of substances of very high concern; where concentration ranges are indicated, the upper bound of the concentration range is applied in accordance with the precautionary principle. The list of substances of very high concern is updated twice a year by the European Chemicals Agency, therefore the number of reported SVHCs is increasing. Year-on-year volume differences are also due to varying volumes of purchased additives and auxiliary chemicals, which depend on the production plans for a given year. The restated 2024 data mainly reflect the inclusion of Rafineria Gdańska in the consolidated data and adjustments to data reported by Group companies.