Resource Use and Circular Economy [ESRS E5]

Summary of the double materiality assessment [E5.IRO-1]

Policies related to resource use and circular economy [E5-1]

Actions and resources in relation to resource use and circular economy [E5-2]

Our actions in relation to circular economy are designed to enhance the resilience and long-term competitiveness of the ORLEN Group. These efforts include the development and implementation of projects enabling the gradual introduction of lower-carbon products (based on renewable or wastederived materials), the integration of eco-design principles, cost optimisation through a more efficient use of resources, and the expansion into new business areas.

In 2025, we continued projects initiated in previous years and launched new initiatives supporting the circular economy. The examples below illustrate how these initiatives contribute to the implementation of the Circular Economy Policy.

Implementation of circular economy principles

We seek to maximise the potential of raw materials embedded in products by extending the economic circulation of resources, recovering value from waste streams and progressively substituting fossilbased raw materials with renewable, circular and secondary inputs as part of the delivery of ORLEN Group’s strategic objectives to 2035, including:

• the phase-out of coal-based heat generation by the end of 2035:
  • Climate Neutrality Plans (CNP) for our heat generation assets. An example of circular economy-related initiatives implemented under the CNP are four projects to build heat pumps utilising heat recovered from wastewater in heat generation assets within the Warsaw agglomeration. In 2025, preparatory work was carried out for pumps with a total planned capacity of approximately 250 MWt, with further implementation scheduled for subsequent years;
• steady increase in the share of renewable energy in our fuel mix by 2030, including our investments in:
  • Hydrotreated vegetable oil (HVO) unit in Płock. The unit, located on the site of our production plant in Płock, will produce biodiesel and sustainable aviation fuels (SAF) from vegetable oils, used cooking oils, animal fats, etc. Once this facility is in operation, our annual HVO production is expected to reach 300 thousand tonnes. Its commissioning is planned for 2026;
  • Oil pressing plant in Kętrzyn. A facility for the production of vegetable oil in Kętrzyn, with an annual capacity of 200,000 tonnes of rapeseed oil. The output will be primarily supplied to the refinery in Trzebinia, owned by ORLEN Południe, where it will be further processed into biocomponents and biofuels. In 2025, construction works on buildings and oil storage infrastructure progressed, with completion scheduled for 2027;
  • 2G bioethanol plant in Jedlicze. The complex of units for the production of secondgeneration bioethanol, primarily from straw, with an annual processing capacity of approximately 150,000–180,000 tonnes, will be located at ORLEN Południe’s refinery in Jedlicze. In addition to bioethanol, it will produce lignin, to be used as fuel for a biomass-fired boiler in a new on-site CHP plant, as well as liquid organic fertilisers. Construction works continued in 2025, with subsequent project phases planned for the coming years.

Implementation of effective resource management

We implement resource management mechanisms to optimise operational processes and minimise our environmental impacts. Our efforts focus on reducing the consumption of raw materials, water and energy, while advancing reuse, recovery and recycling practices, in line with circular economy principles, across the Group’s operations. Our key projects in this area include:

• A comprehensive energy efficiency programme deployed in our Downstream assets, designed to bring down energy and resource intensity of production. The programme plays a key role in managing resources effectively and optimising processes to reduce raw material and energy consumption. Currently, more than 100 projects are planned or underway across the ORLEN Group under this programme. All of these initiatives are aligned with the strategic horizon of the ORLEN 2035 Strategy. In the coming years, investment projects are planned at the production plants of ORLEN S.A., Rafineria Gdańska, ORLEN Południe, ORLEN Lietuva, ANWIL S.A., and ORLEN Unipetrol:
  • Waste heat recovery at ORLEN Unipetrol. Completed in 2025 as part of the energy efficiency programme, this project enables the recovery of waste heat from flue gases and its use for the generation of process steam required for refinery operations in Kralupy;
  • Heat utilisation at ORLEN S.A. In the coming years, a project will be developed to utilise lowtemperature heat from one of the units of the production plant in Płock for cooling, enabling the replacement of the existing freon-based cooling system.
• The Hummingbird programme: an employee-driven initiative supporting continual improvement and standardisation of efficiency-enhancing solutions. It provides a simple and intuitive platform for employees to submit their ideas via a dedicated application. Circular economy initiatives implemented as part of the programme in 2025 included:
  • Refurbishment of certain components of renewable energy units. At Energa Wytwarzanie S.A., wind turbine gearboxes were refurbished using in-house capabilities, which reduced the need for new components, lowered costs and shortened turbine downtime;
  • Process optimisation and waste reduction. At IKS Solino S.A., we optimised the salt tablet production process, enabling the utilisation of approximately 80% of salt waste that had previously remained unused.

Utilisation of waste

We are increasing the share of circular economy solutions within our value chain by using selected waste streams and converting them into valuable products, in line with the waste hierarchy. Examples of our actions in this area include:

• Fertilisers from ashes. ORLEN Termika S.A. expanded its portfolio of by-products from combustion processes, which previously included TERMKRUSZ, TERMASZ and ProAsh (building products and synthetic gypsum), by adding mineral plant growth enhancers produced from biomass ash, marketed as FloraTerm and AgroTerm. In 2025, ORLEN Termika S.A., as the first large-scale producer, obtained approval from the Minister of Agriculture and Rural Development to market mineral plant growth products consisting entirely of bottom and fly ash fractions generated from the combustion of forest or agricultural biomass at the Siekierki CHP plant. As a result, farmers will gain access to a valuable input material, which is produced in the energy generation process. Such projects are also an example of our efforts to explore new circular business opportunities.

• Development of biomethane production. The construction of our biomethane production facility in Głąbowo is currently nearing completion. Being the first biomethane plant in the ORLEN Group and the first facility of this type in Poland equipped with a liquefaction unit for the production of bioLNG, it is scheduled to commence operations in 2026 and is expected to produce approximately 7 mcm of biomethane annually. Concurrently, three agricultural biogas plants are operational within the ORLEN Group: in Konopnica (Province of Łódz), Wojny-Wawrzyńce (Province of Białystok) and Buczek (Province of Bydgoszcz and Toruń), with capacities ranging from 1.2 to 2.0 MW. At all these locations, processes have been launched to convert these plants into biomethane production facilities.

Identification of circular solutions across the life cycle of products and assets

We take steps to identify circular solutions across the life cycle of our products and assets, including in new projects, existing processes and resources generated as a result of the modification or decommissioning of our operations, with due regard to our environmental management framework. Our initiatives in this area include:

• reducing the use of raw materials in ORLEN own-brand packaging:
  • Reduction in packaging weight. From September 2025, the weight of 3.1-litre canisters for ORLEN-branded windscreen washer fluids, produced by ORLEN Oil, was reduced from 160 g to 150 g;
  • Optimisation of water bottles. The weight of plastic bottles used for VERVA own-brand water was also gradually reduced. In 2025, in connection with the introduction of packaging containing recycled rPET, the weight of bottles in three size formats was reduced by between 1.8% and as much as 7.5%. In line with eco-design principles, bottles for ORLEN own-brand water and juices are made from rPET, are fitted with tethered caps, and use labels that are easy to separate from the bottle, which facilitates the preparation of bottles for further recycling.

Fostering partnerships and industrial symbiosis

As an integrated multi-energy group, we look for opportunities to establish partnerships and industrial symbiosis through cooperation within the ORLEN Group and by engaging with third-party supplies, public administration, local authorities and local communities. An example of such activities within the ORLEN Group is:

• HyFly project. production of RFNBO synthetic fuels. The project involves the construction of a synthetic aviation fuels (e-Jet) production unit with a capacity of approximately 70 kt per year, using hydrogen produced through water electrolysis powered by renewable energy and captured carbon dioxide of biogenic origin from biomass combustion and municipal waste processing. The participation of ORLEN Group companies in this initiative creates new opportunities for the use of our resources. For example, the captured CO2 will originate from the biomass boiler forming part of one of the ORLEN Group companies’ assets, as well as from the waste-to-hydrogen project being developed by ORLEN S.A. In addition to the e-Jet RFNBO aviation fuel, we are also assessing the possibility of producing e-naphtha, a feedstock for the petrochemical industry. In 2025, a feasibility study was carried out taking into account synergies between the assets and units participating in the project. In 2025, the HyFly project received a high score in the final evaluation of its application for EU funding under the Innovation Fund, and was nominated for Project Development Assistance (PDA). It was also awarded the STEP Seal by the European Commission, granted to projects distinguished by high quality, innovation and strategic importance for achieving the objectives of the Strategic Technologies for Europe Platform (STEP).

Identification of new business opportunities

We invest in identifying new business opportunities based on circular economy principles and in developing products and services aligned with the concept of circularity. One such business opportunity is the production and supply of sustainable aviation fuels (SAF) for the aviation sector:

• Sustainable aviation fuels. We are expanding our sustainable aviation fuel (SAF) offering. Following the launch of SAF sales at the domestic airports in Warsaw, Kraków and Katowice, as well as in Prague in the Czech Republic, in 2025 we commenced supplies to the Baltic markets. Investments in the refinery in Mažeikiai enabled ORLEN Lietuva to supply SAF at airports in Vilnius, Riga and Tallinn since mid-September 2025.

Expansion of the circular economy potential

We undertake initiatives aimed at expanding the knowledge of circular economy and the opportunities arising from implementing circularity, as well as an analysis of current challenges in such projects, including:

• Circular ORLEN. In 2025, we launched a series of dedicated workshops involving ORLEN Group business segments and companies and devoted to exploring the potential and identifying crosssegment circular economy synergies across the ORLEN Group’s operations. This project will be continued in 2026;
• Assessment of opportunities and impacts. We also regularly perform an assessment of impacts, risks and opportunities related to the circular economy. Its findings are presented in this Statement.

Promoting research and innovation

We prioritise research and innovation as key enablers for achieving our strategic objectives and strengthening our competitive position:

• Through our corporate venture capital fund, ORLEN VC, we established partnerships and invested in early-stage companies in 2025, with close cooperation set to continue in 2026:
  • Advanced recycling. One such company is ReVentas, which is working on the commercialisation of an innovative proprietary plastics (polypropylene and polyethylene) recycling technology based on dissolution processes.
  • Innovative SAF production. Another example is OXCCU, a company developing a technology for the production of synthetic sustainable aviation fuels supported by an innovative catalyst. The technology uses biogenic CO₂ and biohydrogen derived from biomass waste, biogas and/or other sustainable CO₂ sources to produce SAF.
• ORLEN Skylight Accelerator. Under this programme, we provide a platform for collaboration and pilot implementations of innovative technologies and startup solutions that address our current business needs. In November 2025, the 16th call for applications was completed, with further rounds planned for 2026. As part of the 16th call, in the area of the circular economy, we sought:
  • solutions using renewable non-biological feedstocks, such as CO₂ and water, in processes enabling energy- and environmentally efficient production of syngas for further synthesis into alternative fuels;
  • solutions for compact technological systems, designed for industrial applications and enabling the utilisation of available process gas streams and the efficient recovery and use of waste heat.
• NEXTLOOPP. ORLEN S.A. also participates in an international hybrid recycling project. Through mechanical processes, hybrid recycling delivers recyclate of a quality comparable to that achieved through chemical recycling, while being significantly simpler and more cost-efficient. PolyPrism, the technology behind the project, enables the identification and separation of food-grade polypropylene (PP) from other packaging waste. Feedstock purity achieved with this method reaches up to 95% polypropylene after the first sorting stage and up to 99% after the second. Another essential element of the polypropylene recyclate production is PPristine, a pioneering disinfection technology. In 2025, as part of industrial-scale tests of packaging production for the food and cosmetics industries, we successfully manufactured approximately 14,000 units of packaging with varying shares of recycled content – 35%, 65% and 100%. Work under this project will continue in 2026.

Supporting a responsible supply chain

We seek to strengthen our supply chain by responsibly managing relationships with our business partners and by identifying and mitigating risks based on environmental, social and governance (ESG) standards. In accordance with the ORLEN Group Sustainable Development Strategy for 2025–2035 one of the key initiatives is the implementation of a sustainable value chain (Stream 14). We intend to progressively integrate environmental, social and ethical considerations into our procurement processes:

• Supplier Code of Conduct. We require our suppliers to make a number of declarations, including that “to the greatest extent possible, the Supplier shall act in accordance with the principles of the circular economy” and that “the Supplier shall seek to source raw materials responsibly and with due respect for the natural environment, and/or to take environmental criteria into account in its purchasing decisions.” For detailed information on the Supplier Code of Conduct, see disclosure ESRS S2.

Promotion of knowledge and awareness of the circular economy

In 2025, we advanced awareness and understanding of the circular economy through the following initiatives::

• Circular economy pillars. Four circular economy pillars were defined for the ORLEN Group: ecodesign and circular decommissioning, circular processes, circular resources, and new business streams. These pillars provide a structured framework for implementing circularity principles and circular solutions across processes, products and services in all segments of our operations. The pillars were published in the ORLEN Transition Plan in 2025;
• Circular Economy Policy. We developed the ORLEN Group Circular Economy Policy, which was approved by the President of the ORLEN S.A. Management Board and published on our internal corporate platforms. The Policy defines our approach to circularity and sets out development priorities, operating principles and key enablers supporting the gradual implementation of the circular economy in the ORLEN Group;
• Circular ORLEN. We launched a series of dedicated workshops involving ORLEN Group business segments and companies, aimed at sharing knowledge and best practices in the area of the circular economy. The project is being continued in 2026;
• Promotion of the circular economy. We participated in conferences and published expert articles in the press on circular economy topics.

Capital expenditure on the circular economy in the ORLEN Group

The implementation of circular economy initiatives, including those presented as examples above and a wide range of energy efficiency measures, required significant capital expenditure. In 2025, our circular economy-related investments totalled PLN 1,035 million, with PLN 1,058 million earmarked for such projects in 2026.

Targets related to resource use and circular economy [E5-3]

The ORLEN Group implements its strategy with full consideration of targets related to resource use and circular economy. The development directions, operating principles and key enablers defined in the Circular Economy Policy have been designed to support the effective delivery of strategic objectives while strengthening the Group’s capacity to embed circularity across its operations. The current geopolitical landscape, ongoing supply chain disruptions, increasing consumer expectations, and evolving EU and national regulatory frameworks continue to shape our activities, guiding them towards more efficient resource use, enhanced operational resilience and the development of robust, localised supply chains. Our energy transition is underpinned by maximising value across our traditional business areas while adopting a methodical approach to decarbonising our assets and scaling renewable energy solutions. The implementation of the strategic objectives set out in the ORLEN 2035 Strategy indirectly addresses material impacts, risks and opportunities by aligning with the broader direction of the energy transition, reducing dependence on fossil-based resources, advancing innovative technological solutions and accelerating the decarbonisation of operations. Some of the objectives set out in the ORLEN 2035 Strategy are cross-cutting, meaning they may simultaneously relate to resource inflows and outflows as well as waste management. The ORLEN 2035 Strategy establishes a framework of strategic objectives for the ORLEN Group’s entire operations across two time horizons: 2030 and 2035.

Selected objectives of the ORLEN 2035 Strategy are closely aligned with circular economy principles:

• Renewable energy forms the cornerstone of the transition towards a circular economy. In this context, a notable achievement is our progress in the development of the Baltic Power offshore wind farm, implemented as a joint project of the ORLEN Group and Northland Power. This is the first project globally to be constructed using low-carbon steel produced almost entirely from recycled materials in furnaces powered by renewable energy. Moreover, the wind turbines will be recyclable at the end of their operational life at a rate of up to 82%. In 2025, we installed the first Vestas wind turbines with a capacity of 15 MW, along with two offshore substations, while installation work is continuing on additional monopiles, i.e. the structural foundations for offshore wind turbines. For more information on the development of renewable generation capacities, see disclosure ESRS E1;
• The ORLEN 2035 Strategy for the Energy segment includes plans to phase out coal-based power generation by 2030, and coal-based heat generation by 2035. As a result, we expect to reduce emissions of particulate matter and CO₂, as well as the volumes of waste generated as combustion by-products. These objectives and their implementation are described in detail in disclosure E1;
• As part of the objective to increase the share of renewable energy in our fuel mix, we are implementing investment projects to expand biofuel production, including the HVO unit in Płock, the rapeseed oil pressing plant in Kętrzyn, the 2G bioethanol complex in Jedlicze and the biomethane production plant in Głąbowo. In parallel, we produce renewable and low-carbon hydrogen for transport applications. In 2025, 155 tonnes of automotive-grade hydrogen, qualifying as low-carbon hydrogen in accordance with the EU Taxonomy, were produced at our plants in Włocławek and Trzebinia;
• We also aim to increase our installed recycling capacity. In 2025, we expanded our mechanical recycling capacity to 50,000 tonnes per year at the REMAQ facility and invested in ReVentas, a company developing hybrid recycling technology based on the dissolution of plastic waste.

The above objectives are embedded in our long-term strategy, the execution of which is subject to regular oversight. They reflect our business ambitions. Our strategic objectives were announced in 2025. Our strategy is regularly updated to reflect evolving market, regulatory and technological dynamics and ensure that our current objectives are effectively delivered and our competitive advantage is maintained.

Resource inflows [E5-4]

Our operations rely mainly on technical resources, including primary hydrocarbons (principally crude oil and natural gas) and process additives. At the same time, in line with the ORLEN 2035 Strategy, we aim to gradually increase the share of biological and circular feedstocks within our products.

In our own operations, we utilise property, plant and equipment concentrated across four core business segments:

• Upstream & Supply;
• Downstream;
• Energy;
• Consumers & Products.

Among these assets are seven refineries located in Poland, Lithuania, and the Czech Republic, power and CHP plants, renewable energy generation facilities, and a network of over 3,500 service stations in Poland, Germany, the Czech Republic, Austria, Hungary, Slovakia, and Lithuania.

The Upstream & Supply segment is responsible for producing natural gas and crude oil and preparing products for sale. This involves the end-to-end exploration and production process, from geological surveys and geophysical research, through to drilling and field development, to hydrocarbon production. The segment’s activities are conducted in:

• Poland (including the PGNiG Branch Complex, LOTOS Petrobaltic and LOTOS Upstream),
• Norway (ORLEN Upstream Norway AS),
• Canada (ORLEN Upstream Canada Ltd.), and
• Pakistan.

In 2024–2025, we continued oil and gas production activities, delivering essential resource streams that form the foundation of technical inputs for our production systems. The production structure in the reporting period comprised four principal categories:

• Natural gas and crude oil: the core of the upstream portfolio, produced in both onshore and offshore operations;
• Condensate and NGLs: complementing the stream of liquid raw materials and playing an essential role in optimising production inputs.

ORLEN Group production volumes

In 2024–2025, our material mix continued to be dominated by technical materials, with a progressively growing share of biological components:

• Product inflows: their share rose to 3.8% in 2025 from 2.6% in 2024, reflecting increased use of goods and components required to support the expanding scale of our service and production processes.
• Technical materials: continued to represent the core input component, but their share declined to 92.7% in 2025 from 96.1% in 2024. As a result of the ongoing diversification of our material mix towards alternative solutions.
• Biological materials: in line with our strategic decarbonisation pathway, the share of this category rose to 3.5% in 2025 from 2.7% in 2024, confirming the growing role of biocomponents within our portfolio.
• In addition to these main categories, our resource inflows include inputs procured from certified sources and secondary materials. These contribute to the advancement of circular economy objectives, the reduction of our environmental footprint and the increased share of alternative resources within our material mix.
• Sustainably sourced biological materials – the share of sustainably sourced biological materials and biofuels was 1.9% in 2025 vs 1.4% in the previous year.
• Recycled raw materials and components – the share of reused components, products, and secondary raw materials amounted to 0.2% in 2025 (compared to 0.1% in the previous year).

ORLEN Group resource inflows [tonnes]

The management of biological materials within the Downstream segment is primarily carried out through the Integrated Management System at ORLEN Południe S.A., which ensures:

• compliance with the RED II requirements,
• certification under ISCC systems,
• certification under the KZR INiG system,
• oversight of raw material procurement, mass balance and GHG emissions,
• periodic confirmation of compliance by independent external auditors.

The process covers the entire value chain, from supplier qualification to reporting emissions and finished products.

In addition, we use biomass in accordance with the cascading use principle. Agricultural waste is processed into biogas, which is followed by the certification of digestate as an organic fertiliser, enabling the return of biogenic components to the ecosystem.

In our catalytic processes, we use platinum group metals (platinum and palladium) and silver as critical raw materials. We apply an advanced circular model by engaging specialised external operators to recover precious metals from spent catalysts at a very high efficiency level. In 2024, the volume of recovered metals amounted to approximately 152 tonnes, while in 2025 it was approximately 51 tonnes. The year-on-year variability in reported volumes follows from:

• maintenance cycles of our production assets – the transfer of catalysts for disposal and recovery is closely linked to the maintenance schedules and the lifecycle of the catalytic cores,
• the operational characteristics of the recovery process – time lags resulting from the technological complexity of recovery processes carried out by the external operators.

The efficiency of metal recovery from catalysts in 2024-2025 ranged from 98% to 99%, with the recovered materials reintroduced into the production cycle. This model reduces our dependence on primary raw materials and our environmental footprint in the supply area.

The data presented cover key raw material and material flows of the highest materiality to the ORLEN Group’s business profile. We are in the process of expanding the scope of monitoring of our resource inflows to include other categories, reflecting our ambition to continuously enhance our reporting system. The implementation of a more advanced calculation methodology and the progressive inclusion of additional raw material flows in our reporting may affect the direct comparability of data in the short term. However, this process is necessary to obtain complete and transparent information on our environmental impacts across the value chain. The calculations are based on data from management systems and calibrated measuring devices, and, in the case of estimates, on recognised industry benchmarks.

Resource outflows [E5-5]

Waste management is a material topic identified in the impact, risk and opportunity (IRO) assessment for the ORLEN Group conducted in accordance with ESRS requirements.

In line with the ORLEN 2035 Strategy, as of January 2025, our operations are carried out within the following operating segments: Upstream & Supply, Downstream, Energy, Consumers & Products and Corporate Functions.

As part of our operations we generate hazardous waste and non-hazardous waste, in particular from processes specific to the above segments, including refining, petrochemical, energy-related and hydrocarbon production processes, the production of organic and inorganic chemical products, as well as service activities.

These processes also determine the structure of our waste volumes, which, due to our diversified business profile, includes in particular:

• waste from refining and petrochemical processes (including residues, sludges, spent catalysts, oil waste),
• waste from the production of organic and inorganic chemicals (including nitrate melts, organochlorine waste, brine sludges),
• combustion waste from energy generation activities (including ash and slag),
• extraction and drilling waste (including drilling fluids, sludges),
• other waste, including that from service activities, packaging, construction and demolition.

The waste streams listed above are key categories specific to the operations of each operating segment. The materials present in waste are closely linked to the nature of production activities carried out at individual plants and units, as well as to the type of raw materials and auxiliary materials used. These include, in particular, plastics, metals, non-metallic minerals, biomass, organic and inorganic materials, textiles and various types of chemicals.

Calculation methodology

Given the diversity of our business activities, the types and characteristics of the waste they generate also vary considerably. Waste generated by the ORLEN Group includes waste from hydrocarbon extraction activities, crude oil refining, the production of organic and inorganic chemicals, combustion, product packaging, as well as service activities. We do not generate any radioactive waste.

The amount of waste generated by the ORLEN Group companies is documented and reported in accordance with the laws in force in each country, using locally implemented systems. The applicable system in Poland is the Database on Products and Packaging and on Waste Management (BDO), which maintains an ongoing quantitative and qualitative record of generated waste (based on supporting documentation such as waste transfer notes (KPO) and waste record sheets (KEO)) and waste management methods. The obligation to maintain waste records does not apply to the municipal waste stream. The quantities of waste reported in the BDO database are determined on the basis of direct measurements, i.e. weighing. The quantity of municipal waste may be determined using a permitted method other than weighing, i.e. based on the volume of generated waste and its average density. Where possible, for example in relation to ash and slag or flue gas desulphurisation processes, waste is reclassified as by-products. Such re-classified by-products are not included in the total amount of waste generated from our own operations.

Our classification of waste is based on the types of industrial processes in which it is generated (e.g. hydrocarbon extraction, crude oil refining, production of organic and inorganic chemicals, combustion, product packaging, service activities), and the morphology (composition) of the waste itself. The classification is aligned with the methods specified in integrated or sectoral permits. The composition of waste is closely linked to the nature of technological processes carried out at each plant and facility, as well as to the types of raw materials and auxiliary materials used in those processes. An analysis of the chemical composition of waste is carried out only in limited cases, and with respect to selected types of waste. Such analysis is necessary, for example, in the process of reclassification of waste as a by-product, e.g. in the case of combustion waste.

Waste management methods applied across the ORLEN Group are governed by applicable legal regulations, permits, adopted standards and policies (including the ORLEN Group Environmental Protection Policy, the ORLEN Group Circular Economy Policy, and Organisational Standard No. SO/4/2023 of 20 December 2023 on hazardous waste management), as well as procedures and regulations specific to individual ORLEN Group companies. Their purpose is to prevent waste generation and minimise the negative impact of activities related to waste generation and management. Waste generated within the ORLEN Group is transferred to specialised third-party operators holding relevant permits and authorisations for waste management, in compliance with legal requirements. In accordance with Organisational Standard No. SO/4/2023, following the final treatment of hazardous waste by qualified operators, such operators provide documentation confirming the treatment method applied.

Waste management activities within the ORLEN Group are carried out in strict compliance with applicable legal regulations and permits. In accordance with the Waste Act, where recovery (R) is not possible for technological reasons or cannot be carried out in a manner that ensures the safety of people and the environment, waste is subjected to disposal (D) operations. The decision to direct waste to disposal is made based on the classification of waste and its specific properties, in cases where recovery technologies are not available (e.g. spent oil-based drilling fluids on rock cuttings) or the safety of people and the environment is not guaranteed. Other reasons include a high level of contamination, composition and toxicity, which prevent the use of recovery and recycling operations, no possibility of further use, and economic considerations. Due to the chemical composition and toxicity of certain types of waste, the statutory priority is their complete neutralisation rather than recycling, which could lead to environmental contamination or contamination of end products.

Certain ORLEN Group companies hold the status of an entity placing packaged products on the market and are therefore subject to the extended producer responsibility (EPR) system under EU regulations. The ERP framework transfers the financial and organisational responsibility for the management of waste generated after the use of packaging to entities placing packaged products on the market, in accordance with the ‘polluter pays’ principle. These Group companies maintain quantitative and weight-based records of all types of packaging placed on the market, covering primary, secondary and transport packaging.

Obligations to ensure the required annual recycling rate for the mass of packaging placed on the market are fulfilled by ORLEN Group companies under agreements concluded with recovery organisations and business self-government organisations with regard to non-hazardous packaging, as well as with regard to multi-material packaging and packaging containing hazardous substances. ORLEN S.A. manages a network of service stations where it offers packaged products, ready-to-eat food services, as well as plastic shopping bags and single-use plastic products subject to the Single- Use Plastics (SUP) fee. It also places on the market deposit-return packaging of beverages, such as single-use plastic bottles with a capacity of up to 3 litres and metal cans of up to 1 litre. The Company pays the applicable fees. It also achieved the required recycling rate for packaging placed on the market and ensured the proper flow of funds related to the collection of deposits. In addition, ORLEN S.A. bears financial responsibility for the management of waste generated from these products under the EPR framework. This includes the costs of litter collection, emptying of public waste bins, as well as financing dedicated educational campaigns concerning SUP products. These costs are calculated separately for each kilogram of products placed on the market and are incurred independently of the standard Public Educational Campaigns (PKE), which are delivered on the Company’s behalf by a recovery organisation under a relevant agreement.