EU Taxonomy

Regulatory framework

Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment requires that we disclose in the nonfinancial statement of the ORLEN Group for 2025 information on how and to what extent our activities fall within the scope of the EU Taxonomy for environmentally sustainable economic activities.

The criteria for determining which economic activities qualify as environmentally sustainable (i.e. are aligned with the EU Taxonomy) have been established under:

• Commission Delegated Regulation (EU) 2021/2139 of 4 June 2021 establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation or climate change adaptation and for determining whether that economic activity causes no significant harm to any of the other environmental objectives;
• Commission Delegated Regulation (EU) 2022/1214 of 9 March 2022 as regards economic activities in certain energy sectors, establishing the technical screening criteria for nuclear and fossil gas related activities;
• Commission Delegated Regulation (EU) 2023/2485 of 27 June 2023 establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation or climate change adaptation and for determining whether that economic activity causes no significant harm to any of the other environmental objectives;
• Commission Delegated Regulation (EU) 2023/2486 of 27 June 2023 establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to the sustainable use and protection of water and marine resources, to the transition to a circular economy, to pollution prevention and control, or to the protection and restoration of biodiversity and ecosystems, and for determining whether that economic activity causes no significant harm to any of the other environmental objectives;
• Commission Delegated Regulation (EU) 2026/73 of 4 July 2025 amending Delegated Regulation (EU) 2021/2178 as regards the simplification of the content and presentation of information to be disclosed concerning environmentally sustainable activities and Delegated Regulations (EU) 2021/2139 and (EU) 2023/2486 as regards simplification of certain technical screening criteria for determining whether economic activities cause no significant harm to environmental objectives¹.

The disclosure obligations have been further clarified in Commission Delegated Regulation (EU) 2021/2178 of 6 July 2021 specifying the content and presentation of information to be disclosed by undertakings subject to Articles 19a or 29a of Directive 2013/34/EU concerning environmentally sustainable economic activities, and specifying the methodology to comply with that disclosure obligation. These obligations have been modified by the abovementioned Commission Delegated Regulation (EU) 2026/73².

¹ Regulation (EU) 2021/2139, Regulation (EU) 2023/2485, Regulation (EU) 2022/1214, Regulation (EU) 2023/2486 and Regulation (EU) 2026/73 are jointly referred to as the “Technical Screening Criteria” or “TSC”.

² Regulation (EU) 2020/852, Regulation (EU) 2021/2139, Regulation (EU) 2021/2178, Regulation (EU) 2022/1214, Regulation (EU) 2023/2485, Regulation (EU) 2023/2486 and Regulation (EU) 2026/73 are jointly referred to as the “EU Taxonomy” or “Taxonomy”.

Consolidated disclosures of the ORLEN Group

As part of our 2025 disclosures, we are required to provide descriptive information and disclose the proportion of the ORLEN Group’s economic activities classified as Taxonomy-eligible and Taxonomy-aligned along six environmental objectives, i.e. climate change mitigation, climate change adaptation, sustainable use and protection of water and marine resources, transition to a circular economy, pollution prevention and control, and protection and restoration of biodiversity and ecosystems (jointly: “environmental objectives”). Moreover, with respect to those environmental objectives, we disclose the proportion of the ORLEN Group’s Turnover from the sale of products or services, capital expenditures (CAPEX) and operating expenditures (OPEX) related to environmentally sustainable economic activities³.

The number of Taxonomy-eligible and Taxonomy-aligned activities may vary from year to year, which is due to the size of the ORLEN Group. As part of our operations, we acquire or establish new companies and launch new projects that, once specific criteria have been met, may be recognised as environmentally sustainable.

³ The key performance indicators are referred to as “key indicators” “indicators” or “KPIs”.

Determination of Taxonomy-eligible economic activities

In accordance with the EU Taxonomy, an economic activity qualifies as Taxonomy-eligible irrespective of whether that economic activity meets any or all of the Technical Screening Criteria. We have determined which of the ORLEN Group’s activities qualify as Taxonomy-eligible and Taxonomy-non-eligible based on the description of activities contained in the EU Taxonomy, and using the NACE codes provided there as ancillary information. Our economic activities that qualify as Taxonomyeligible are associated primarily with the climate-related objective of climate change mitigation. The activities listed at the end of this section are associated with operations that generate revenue or involve capital expenditures or operating expenditures. Activities which do not involve such revenue and expenditures are not subject to the disclosure obligations.

Early-stage research and development projects are not Taxonomy-eligible activities. We have not recognised as Taxonomy-eligible our activities related directly to refining processes and based on fossil fuels, as the Taxonomy does not cover activities related to the manufacture and sale of fuels.

It should be noted that the EU Taxonomy requires interpretation, so in our assessment of Taxonomyeligibility we took into account the FAQs documents published by the European Commission. If the European Commission issues any new interpretations, this may affect both the future eligibility of specific activities and their assessment as Taxonomy-aligned.

Following a detailed review of all of the ORLEN Group’s economic activities, it was determined that thirty-five of them qualify as contributing to the first environmental objective, i.e. climate change mitigation, whereas one qualifies as contributing to climate change adaptation. One activity qualifies as contributing to the objective related to the sustainable use and protection of water and marine resources, three activities qualify as contributing to the transition to a circular economy, and three – to pollution prevention and control.

List of eligible activities

Determination of Taxonomy alignment of Taxonomy-eligible economic activities (environmental objectives)

The process of determining Taxonomy alignment of economic activities in accordance with the requirements for reporting year 2025 was performed for all six environmental objectives, and consisted in analysing compliance with the criteria of making a ‘substantial contribution’ to one primary objective and the criteria of ‘doing no significant harm’ (“DNSH”) to the other environmental objectives.

Out of the list of the abovementioned eligible activities, sixteen were identified as being aligned with the Taxonomy (these activities are described below). We reviewed the material contribution criteria for individual activities eligible under all six environmental objectives. Where the substantial contribution criteria were not met or compliance with the criteria could not be confirmed, the activities were not reported as Taxonomy-aligned. The scope of work undertaken to verify the above criteria was the same for both Taxonomy-aligned and non-aligned activities.

Alignment with the TSC was identified only for activities related to the objectives of climate change mitigation and climate change adaptation. For the remaining objectives, no activities aligned with the EU Taxonomy were identified.

Substantial contribution

The EU Taxonomy has established various substantial contribution criteria for eligible activities. In our analysis, we have assessed compliance with the criteria established for each activity. Below is an explanation of how this assessment was performed.

Compliance with the DNSH criteria

The DNSH criteria are designed to ensure that economic activities do no significant harm to the other environmental objectives. The combination of the substantial contribution and DNSH criteria is aimed at ensuring that contribution to one of the environmental objectives of the Taxonomy is not made at the expense of other environmental objectives. The DNSH criteria vary from activity to activity (except for those DNSH criteria that apply to climate change adaptation, where the assessment approach is substantially the same for all activities). We have analysed compliance with the DNSH criteria for all economic activities meeting the substantial contribution criteria. The analysis included an assessment of the location where a given economic activity is carried out, the specific nature of the economic activity concerned and the applicable DNSH criteria. For some activities that meet the substantial contribution criteria, it was not possible to fully confirm compliance with the DNSH criteria, for instance due to the limited potential of the installation infrastructure or lack of complete documentation demonstrating satisfaction of the Technical Screening Criteria. Where this was the case, we did not report the activity as Taxonomy-aligned.

Compliance with minimum safeguards

The assessment of the ORLEN Group’s compliance with the minimum safeguards as defined in the EU Taxonomy was carried out with due consideration of the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (the “OECD Guidelines”), the UN Guiding Principles on Business and Human Rights (the “UN Guiding Principles”), the Platform on Sustainable Finance report on minimum safeguards, as well as other guidance and instructions, such as the Guidebook for Enterprises on the Application of the Minimum Safeguards of the EU Taxonomy prepared by the Working Group on Minimum Safeguards operating at the Polish Ministry of Development Funds and Regional Policy.

Minimum safeguards serve as a protective mechanism. They consist of appropriate procedures, in particular those relating to due diligence, designed to ensure that the company’s activities are aligned with the OECD Guidelines and the UN Guiding Principles while minimising negative impacts. However, due diligence procedures cannot guarantee that breaches of human rights, labour rights or standards relating to other thematic areas covered by the OECD Guidelines will never occur. Instead, their purpose is to verify whether we are actively making every effort to prevent actual adverse impacts.

Our assessment covered six areas:

• human rights, labour rights and consumer rights,
• the environment,
• combating bribery and other forms of corruption,
• science, technology and innovation,
• fair competition,
• taxation.

Standards of responsible business conduct are embedded in the ORLEN Group’s organisational culture and reflected in a wide range of internal policies, procedures and processes. We have incorporated elements of the due diligence process set out in the OECD Guidelines and the UN Guiding Principles into our operations through a number of adopted and implemented documents. Our key policies addressing this area include: the ORLEN Group Code of Ethics, ORLEN Group Supplier Code of Conduct, ORLEN Group Human Rights Policy (Human Rights Policy), policies governing employee matters (including non-discrimination and equal opportunities), Competition Law Compliance Policy, ORLEN Group Anti-Corruption and Fraud Prevention Policy, and whistleblowing policies.

We apply preventive and mitigating measures to reduce the risk of adverse impacts and ensure an appropriate response to identified irregularities, including, in particular, onboarding training and dedicated employee training in areas such as anti-corruption, human rights, fair competition, data security, environmental protection, and occupational health and safety. These measures also extend to the value chain: suppliers participating in our procurement procedures are required to familiarise themselves with and accept our key standards, including the ORLEN Group Supplier Code of Conduct, the Code of Ethics, the Human Rights Policy, the Anti-Corruption Policy, the Policy for Accepting and Offering Gifts, and the Conflict of Interest Management Policy. In addition, we incorporate appropriate clauses in our contracts and agreements with trading partners, covering environmental protection, occupational health and safety, sanctions, anti-corruption, and beneficial ownership statements. Where irregularities are identified or supplier assessments produce unsatisfactory results, we take remedial actions and their implementation is subject to further monitoring.

In line with the ORLEN Group’s existing policies, procedures and practices, the measures taken and their outcomes are monitored on an ongoing basis, using internal reporting mechanisms, periodic assessments and reviews of the solutions in place. This monitoring is the responsibility of the organisational units competent for the matter concerned. Particular attention is paid to the results of periodic and ad hoc supplier assessments, the effectiveness of remedial actions, and the functioning of whistleblowing mechanisms. This approach strengthens our due diligence framework as it helps identify areas requiring improvement and progressively enhance the consistency, transparency and effectiveness of the process components.

Examples of the ongoing development of our due diligence procedures include the work continued in the reporting period on supplier evaluation methodology and further efforts to integrate processes and policies across the ORLEN Group. In 2025, workshops devoted to due diligence were held across the Group to build the companies’ capabilities in this area and ensure greater consistency in the measures taken. During those meetings, existing practices were reviewed and directions for change were identified in key processes to improve their effectiveness, transparency and alignment with applicable regulations and market standards.

As part of the Know Your Customer (KYC) process, which is being currently developed, we reviewed the Supplier Code of Conduct for compliance with requirements in the social area. A number of areas that need further improvement were also identified. In parallel, work is under way to implement a formal due diligence process across the Group, which will make it possible to integrate and harmonise the procedures and policies currently in place, ensuring consistent standards of conduct throughout the organisation.

In its recommendation on the assessment of compliance with minimum safeguards, the Platform on Sustainable Finance operating under the European Commision, refers to violations identified for individual topics.refers to violations identified for individual topics. We did not identify any final court judgments issued in 2025 that were relevant for this assessment. For more information on the respective topics associated with minimum safeguards, see the dedicated sections of this Sustainability Statement.

Key performance indicators and relevant accounting principles

The key performance indicators (KPIs) have been calculated in accordance with the guidelines set out in Regulation 2021/2178. We calculated the proportion of Turnover, capital expenditure (CAPEX) or operating expenditure (OPEX) that is associated with environmentally sustainable activities based on the same accounting principles as those used to prepare the ORLEN Group’s consolidated fullyear financial statements. The calculation of the KPIs for the Group took into account the relevant consolidation eliminations applied in the preparation of the financial statements. The KPIs presented in this Sustainability Statement do not include intra-group sales and Turnover resulting from captive consumption. No financial item was double counted: where appropriate, data was disaggregated as necessary to eliminate the risk of double counting. In cases where a single Taxonomy-eligible installation was used in both eligible and non-eligible activities, only the separated part of Turnover, capital expenditure and operating expenditure that was associated with the Taxonomy-aligned activity was used in calculating the KPIs. In the few cases where this did not have a significant effect on a KPI, a simplified approach was applied. With respect to the ORLEN Group’s operations outside of Poland, all activities were assessed in the same way as the activities carried out in Poland.

Significant changes relative to previous year’s disclosures

We monitor regulatory developments to ensure ongoing compliance with applicable requirements, including those relating to the Taxonomy. The disclosure tables in this Sustainability Statement differ from those presented last year (for 2024), as we decided to apply the updated reporting templates introduced by Commission Delegated Regulation (EU) 2026/73 effective from 1 January 2026. The Regulation introduced the option to apply materiality thresholds. In line with the principle of proportionality and with a view to reducing the reporting burden, it allows undertakings not to assess whether economic activities are aligned with the Technical Screening Criteria where those activities are not financially material to their business.

Additional disclosures

The ORLEN Group has joint ventures accounted for with the equity method, such as Basell ORLEN Polyolefins Sp. z o.o. and Baltic Power Sp. z o.o. The CAPEX KPI does not include capital expenditures of PLN 3.22 billion incurred by the ORLEN Group in 2025 on the development of a project to construct a wind farm of Baltic Power Sp. z o.o. Disclosures on additional KPIs related to investments accounted for with the equity method are not required.

Summary

Taxonomy-alignment of the ORLEN Group’s activities

Proportion of Turnover, capital expenditure, and operating expenditure from products or services associated with Taxonomy – eligible or Taxonomy-aligned economic activities – disclosure covering 2025 (summary KPIs)

Proportion of turnover from products or services associated with Taxonomy-eligible or Taxonomy-aligned economic activities – disclosure covering 2025 (activity breakdown)

Proportion of capital expenditure from products or services associated with Taxonomy-eligible or Taxonomy-aligned economic activities – disclosure covering 2025 (activity breakdown)

Proportion of operating expenditure from products or services associated with Taxonomy-eligible or Taxonomy-aligned economic activities – disclosure covering 2025 (activity breakdown)