General Disclosures [ESRS 2]

General basis for preparation of sustainability statement [BP-1]

This Sustainability Statement (“Statement”) has been prepared on the basis of:

• the requirements of Chapter 6c of the Accounting Act of 29 September 1994 (consolidated text: Dz. U. of 2023, item 120, as amended);
• the sustainability reporting standards as defined in Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023 supplementing Directive 2013/34/EU of the European Parliament and of the Council as regards sustainability reporting standards;
• the reporting requirements under Article 8 of 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, and amending Regulation (EU) 2019/2088 (“Regulation (UE) 2020/852”).

This Sustainability Statement covers ORLEN S.A. as the parent and the ORLEN Group. The consolidation scope is the same as in the ORLEN Group’s consolidated financial statements for the previous financial year.

In the case of ongoing upstream projects in Canada and Norway, our activities are to a large extent conducted through joint operations. Depending on the role of ORLEN Group companies in individual projects, as the project’s operator or a non-operator partner, greenhouse gas emissions were reflected accordingly in the disclosures prepared in line with the requirements of ESRS E1.

Rafineria Gdańska, as a joint operation conducted through a separate vehicle, is consolidated at 70% of its assets and liabilities. This proportionate share has been included in disclosures E1, E2, E3, E4, E5, S1-6 and S1-9.

In the ORLEN Unipetrol Group, the joint operation carried out through Butadien Kralupy, in which ORLEN Unipetrol holds a 51% interest, has been reflected in disclosures E1, E2, E3, E4, E5 and S1 in proportion to that interest.

This Sustainability Statement covers relevant information from across the value chain, including suppliers (upstream) and consumers (downstream).

For detailed information on entities covered by this Sustainability Statement for 2025 by segment, see Notes 7.1 and 12.6 to the consolidated financial statements for 2025.

The ORLEN Group prepares sustainability reporting annually. We have used the option provided for in the ESRS not to disclose classified, and in particular legally protected information, including information relating to intellectual property and know-how with respect to cybersecurity.

We have used the exception from disclosing impending developments or matters in the course of negotiation, available under Article 63r(7) of the Accounting Act (in accordance with Articles 19a(3) and 29a(3) of Directive 2013/34/EU).

Disclosures in relation to specific circumstances [BP-2]

The role of the administrative, management and supervisory bodies [GOV-1]

Disclosure on the composition and diversity of the Management Board and Supervisory Board is incorporated by reference to Section 7 of the Management Board’s Report. There is no employee representative on the Management Board.

Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies [GOV-2]

Responsibility for oversight of sustainability matters has been assigned to the Company’s top governing bodies, including the Management Board and the Supervisory Board, ensuring ongoing integration of sustainability topics into strategic planning, risk and opportunity management and capital allocation processes.

The responsibilities of the Supervisory Board, including the Sustainability Committee, are set out in the Rules of Procedure for the Supervisory Board.

The responsibilities of the Management Board are governed by the generally applicable laws, the Company’s Articles of Association and the Rules of Procedure for the Management Board. Furthermore, based on the Management Objectives framework established by the ORLEN S.A. General Meeting, the Supervisory Board determines bonus targets for the Management Board members, which are documented in their MBO Sheets. The Management Objectives, as well as the weights and criteria for their delivery, are specified in detail in a Supervisory Board resolution. For 2025, the Supervisory Board set quantitative and qualitative objectives for the Management Board members, reflecting their respective scopes of responsibility, assigned relevant bonus thresholds to these objectives, and defined separate targets for variable remuneration.

The Supervisory Board and the Management Board are presented with biannual reports on the delivery of the Sustainable Development Strategy and the Climate Policy, biannual reports on activities related to the monitoring of the Company management for compliance with the ORLEN Group Code of Ethics and the Human Rights Policy, biannual reports on the delivery of the ORLEN Group Charitable Policy, and a business strategy progress report prepared at least twice a year.

In 2025, the management of economic, environmental and climate impacts was discussed at about 13 meetings of the ORLEN S.A. Management Board and at about 13 meetings of the Supervisory Board and its Committees.

The operational implementation of sustainability and climate activities is carried out by the relevant business areas of the ORLEN Group, which are responsible for strategy operationalisation, progress monitoring and reporting to administrative and management bodies. Monitoring mechanisms include regular reporting to the Management Board and Supervisory Board, including updates on the execution of the business strategy that incorporate information on progress against the ORLEN Transition Plan, including emission reduction targets.

Management of climate- and sustainability-related issues

Management bodies

The Management Board is responsible for the oversight over sustainability and approves the outcomes of the double materiality assessment process, including any identified material impacts, risks and opportunities, based on information provided at least annually.

The Management Board is responsible for defining and implementing the ORLEN Group’s strategy, including sustainability and climate objectives. It oversees sustainability matters and approves key strategic decisions. Quarterly monitoring of strategy progress constitutes a key element of the Management Board’s oversight over sustainability across the ORLEN Group.

At the operational level, sustainability objectives are implemented by relevant ORLEN Group business areas and corporate functions, which are responsible for strategy operationalisation, execution of activities within their respective remits, and progress monitoring. This ensures that sustainability objectives are integrated into day-to-day operations, decision-making processes, and the Group-wide system for managing risks and opportunities. These functions cooperate with specialised units responsible for sustainability and energy transition, ensuring alignment across the organisation and the integration of sustainability goals into daily operations and decision-making processes.

Areas of responsibility of ORLEN Management Board Members

Climate risks and opportunities are managed under the oversight of the President of the Management Board and the Member of the Management Board for Transition, who also serves as the Climate Officer and chairs the Climate and Sustainability Council. In addition, in accordance with the division of responsibilities set out in the relevant Management Board resolution, the Member of the Management Board for Transition oversees the Sustainable Development and Energy Transition area, the scope of which is defined in the ORLEN S.A. Organisational Rules.

The President of the Management Board, whose remit is Strategy and Innovation, oversees the implementation of the ORLEN Group Strategy and the ORLEN Transition Plan, ensuring the integration of climate and sustainability considerations into strategic processes at the Group level.

The sustainability reporting processes are overseen by Vice-President of the ORLEN S.A Management Board for Finance.

Supervisory bodies

The ORLEN S.A. Supervisory Board exercises ongoing oversight over the Company’s operations across all areas, including sustainability and climate matters.

The Supervisory Board includes a Sustainability Committee, which supports it in monitoring and assessing the implementation of the Sustainable Development Strategy and sustainability reporting.

Integration of sustainability-related performance in incentive schemes [GOV-3]

Sustainability-related initiatives and actions have been operationalised and incorporated into our Management by Objectives (MBO) scheme. Their successful implementation has a direct effect on annual bonuses awarded to the Management Board and executive management staff, ensuring alignment of the Group’s operations with sustainable development goals. The applicable framework is set out in the Rules of the Incentive Scheme for the Management Board of ORLEN S.A. and rules that govern setting and assessing the delivery of individual bonus-triggering objectives for Management Board members for each year. The documents are adopted by way of a Management Board resolution.

Statement on due diligence [GOV-4]

Adherence to the responsible business conduct standards is a fundamental aspect of our operations. We follow practices aligned with the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, which are designed to prevent negative impacts and to ensure appropriate action is taken when adverse effects occur in connection with our activities, particularly in relation to employees, human rights, natural environment, anti-corruption, consumer protection and business conduct. We also expect that these practices will be complied with by our business partners and companies in our value chain, and in other business relationships.

The principles of responsible business conduct are reflected in numerous internal procedures and processes. The key policies governing these topics include: The ORLEN Group Code of Ethics, ORLEN Group Supplier Code of Conduct, Human Rights Policy, policies on employee matters (including non-discrimination and equal opportunities), Competition Law Compliance Policy, ORLEN Group Anti-Corruption and Fraud Prevention Policy, and policies on reporting irregularities and cases of misconduct.

Importantly, we continue to strengthen and develop our due diligence framework. Ongoing initiatives include the development of a methodology for evaluating supplier sustainability performance and efforts taken to integrate due diligence processes and policies across the entire ORLEN Group. The table below presents selected key elements of our due diligence.

Elements of due diligence

Risk management and internal controls over sustainability reporting [GOV-5]

The Enterprise Risk Management System (ERM) is one of the management tools supporting the effective delivery of strategic and operational objectives, and providing information on the risks at ORLEN S.A. and on their effective management. Its purpose is to identify risks that may affect the achievement of ORLEN S.A.’s business objectives.

Enterprise risk management is an ongoing process subject to adjustments necessitated by changes in the economic environment and ORLEN S.A.’s operations, as well as shifts in the materiality of risks affecting the achievement of ORLEN S.A.’s business objectives. Enterprise risk management encompasses activities both at the level of ORLEN S.A. and within individual business processes. Selected key companies of the Group operate risk management systems that are based on the risk management system in place at ORLEN S.A. ORLEN S.A. has adopted an Enterprise Risk Management Policy and Procedure, which is mandatory for all ORLEN S.A. employees. Provisions applicable to ORLEN S.A. employees also apply to individuals providing services to ORLEN S.A. under civil law contracts.

Risks related to the scopes of sustainability disclosures are reported within the enterprise risk management framework, which is overseen by the Head of the Audit and Enterprise Risk Management Office. A risk report is prepared annually at ORLEN S.A. based on the outcomes of the risk self-assessment and control testing. The report is submitted to the Management Board. For information on enterprise risks related to the scope of sustainability disclosures, see here. The risk prioritisation methodology is described in disclosure IRO-1.

Strategy, business model and value chain [SBM-1]

ORLEN Group business model

ORLEN Group companies are engaged in the following types of activity:

• exploration, appraisal, import and production of hydrocarbons;
• energy generation (power and heat), refining and petrochemical activities including crude oil processing and manufacturing of refining, petrochemical and chemical products and intermediates, biofuels and oils;
• trading: distribution and trading of electricity and heat, wholesale and retail sale of fuel products, petrochemicals, chemicals and other products, sale and distribution of gaseous and liquid fuels;
• service activities, including crude oil and fuel storage, transport, maintenance and overhaul services, laboratory services, security, design, administrative and courier services, insurance and financial services, press distribution, and media activities (newspapers and websites).

In early 2025, we presented our updated business strategy ORLEN 2035, which establishes strategic priorities across four key operating segments: Upstream & Supply, Downstream, Energy, Consumers & Products. Consequently, we made a corresponding change to the presentation of the ORLEN Group operating segments in reporting. The new segments reflect the current management model, which is aligned with key trends and with the decision-making structure that has been in place at the Group since 2025. The changes will result in providing more relevant and reliable information, giving a clearer reflection of our performance and business outcomes. Their main purpose was to enhance the usefulness, transparency, clarity and comparability of the Group’s financial statements. The changes address investor needs, and are consistent with market practice observed among other global multi-energy groups.

For management purposes, the Group’s operations have been divided into four operating segments since 2025:

• Upstream & Supply: domestic and international production, involving exploration for and production of mineral resources such as natural gas and crude oil, drilling and oilfield services (upstream), wholesale of crude oil and wholesale of gas;
• Downstream: refining production, petrochemical production, wholesale of refined products, wholesale of petrochemical products, maintenance services (in refining and petrochemical production assets), hydrogen;
• Energy: conventional power, new energy, heat, distribution of electricity and gas, trading in electricity, energy services;
• Consumers & Products: retail sale of fuels, retail sale of electricity and gas, retail services, emobility.

The Corporate Functions segment includes management, administrative and other activities not allocated to any of the identified operating segments. The Corporate Functions area provides support to other business segments.

Value chain by segment

Upstream & Supply – Upstream

Upstream & Supply – Gas

Downstream – Refining

Downstream – Petrochemicals

Energy

Consumers and Products

For a detailed description of each segment, see here.

Significant groups of products and/or services offered

The ORLEN Group is Central Europe’s leading manufacturer of petrochemicals, supplying products to customers in nearly 100 countries across six continents. Our portfolio includes both basic and specialty products.

Number of employees by contract type and region

Headcount by geographical area

Significant markets and/or customer groups served

For detailed information on the ORLEN Group’s key markets in 2025, see Note 1 to the consolidated financial statements for 2025.

Statement on the conduct of activities in specific sectors and the related revenues

For detailed information on revenue earned by the ORLEN Group in high climate impact sectors in 2025, see Note 11.1 to the consolidated financial statements for 2025. We have assumed that all ORLEN Group companies operate in high climate impact sectors.

The ORLEN Group does not conduct any activities related to chemical production, i.e. its activities do not fall under division 20.2 of Annex I to Regulation (EC) No 1893/2006. Furthermore, the Group does not engage in any activities related to controversial weapons or the cultivation and production of tobacco.

Sustainable Development Strategy

ORLEN Group Sustainable Development Strategy for 2025–2035

In 2025, following an update to our business strategy and the extension of its time horizon to 2035, we also revised the ORLEN Group Sustainable Development Strategy.

The ORLEN Group Sustainable Development Strategy is a comprehensive framework guiding our development and operations in line with sustainability principles. It is structured around five core pillars: Climate, Environment, Employees, Communities, and Governance. The pillars are further broken down into 18 streams, each with targets set across three time horizons: a short-term horizon to 2026, a medium-term horizon to 2030, and a long-term horizon beyond 2035. The updated ORLEN Group Sustainable Development Strategy for 2025–2035, published in March 2025, builds on and replaces the earlier 2024–2030 version.

The Sustainable Development Strategy addresses the most pressing market and regulatory challenges of today, focusing on climate change, environmental protection, biodiversity protection, social relations, and the geopolitical and economic landscape. Its objectives align directly with the UN Sustainable Development Goals (SDG), the European Sustainability Reporting Standards (ESRS), and the Ten Principles of the UN Global Compact (UNGC), which the ORLEN Group formally endorsed by joining the initiative in 2024. This approach to strategy development and implementation not only supports a broader commitment to responsible business practices but also ensures detailed and transparent sustainability reporting in line with the CSRD and other regulatory requirements. Reporting on the implementation of the Sustainable Development Strategy – for information on the status of key activities under the Strategy, see sections corresponding to individual ESRSs.

Structure of the ORLEN Group Sustainable Development Strategy for 2025–2035

Objectives of the Sustainable Development Strategy

Within the Climate pillar, the key focus areas include decarbonisation and energy transition. We have set targets for investments in renewable energy sources, such as the Baltic Power offshore wind farm, and in bio-gas and bio-fuels production, as well as greenhouse gas emission reduction targets for 2030 and 2035 (2019 baseline), as part of the pathway to achieving net zero by 2050:

• a 13% reduction in absolute emissions in Oil & Gas (Scopes 1 and 2) by 2030, rising to 25% by 2035;
• a 40% reduction in Scope 1 GHG emissions intensity in the Energy segment by 2030, rising to 55% by 2035;
• a 10% reduction in Net Carbon Intensity (NCI) of the Group’s energy products by 2030, rising to 15% by 2035.

One of our most significant commitments is the complete phase-out of coal-fired power generation by 2030, followed by the phase-out of coal from heat generation by 2035. By 2030, we also intend to achieve two dedicated targets in the upstream operations – Near-Zero Upstream Methane Emissions and Zero Routine Flaring. For more details on the decarbonisation objectives, see the ORLEN Transition Plan.

Under the Environment pillar, we focus on minimising the adverse environmental impacts of our operations and preventing biodiversity loss. The core ambitions under the biodiversity protection stream are to develop and implement a Group-wide Biodiversity Action Plan (BAP). Another important element is sustainable water and wastewater management, where we intend to develop a water and wastewater policy and calculate the Group’s water footprint. We also plan to implement closed-loop water systems, e.g. by upgrading car washes at service stations, not only to reduce the volumes of water used, but also to cut down on the consumption of chemical agents. A separate stream within the Environment pillar is focused on advancing the circular economy and abating pollution. Its key targets include drawing up a circular economy policy and developing recycling operations.

Under the Employees pillar, targets have been established to further minimise workplace accidents within the ORLEN Group (the 2030 target is Total Recordable Incident Rate < 0.2), alongside the implementation of uniform Group-wide occupational health, safety, and process safety standards. Another major focus area is employee well-being. We intend to continue and expand our portfolio of professional advancement programmes to support skills development, as well as initiatives promoting both physical and mental health. Our efforts were recognised in the prestigious Top Employer 2026 ranking, published annually by the Top Employers Institute. ORLEN has consistently ranked among Poland’s best employers for the past 15 years, and one of our core ambitions for the years ahead is to maintain our position among the region’s leading employers.

The Communities pillar is particularly important due to our significant impacts on the populations in the areas where we operate. The portfolio of initiatives that support and engage local communities will be further developed. A key objective is to draft and implement a just transition programme designed to protect communities in regions affected by the energy transition. Another objective is to establish a more structured approach to local community engagement. To this end, a Local Community Ombudsman has been appointed as a dedicated contact for submitting suggestions, feedback, or complaints.

The last pillar, which integrates all other pillars, is Governance. Our initiatives in this area included the development of due diligence objectives for human rights and environmental protection, spanning the whole ORLEN Group value chain. Other Governance goals include harmonising standards on ethics, anti-corruption, and human rights across the ORLEN Group, and putting in place a centralised cybersecurity governance model. We will continue and expand our array of training programmes dedicated to fostering diversity and equal opportunities throughout the organisation. A key initiative is Orlen Women Forward – The Power of Diversity, aimed at promoting diversity and empowering women at all career levels.

Key elements of the ORLEN Group strategy that relate to sustainability matters

The key strategic priorities defined in the ORLEN 2035 Strategy are presented below.

Upstream and Supply

Downstream: Transformation of the Refining business

Downstream: Petrochemicals

Energy: Renewables

Energy: Low-carbon generation technologies

Consumers & Products

Interests and views of stakeholders [SBM-2]

We define a stakeholder as any identifiable group or entity (including an institution or the natural environment) that may influence or be influenced by our operations through our strategies, products, manufacturing processes, management systems and procedures.

Responsibility and dialogue are fundamental to our approach to stakeholder relations. Our commitment to fostering strong relationships is reflected in tailored communication strategies: we select the optimal frequency and suitable channels for particular stakeholder groups, addressing their unique characteristics and current expectations.

We engage in various forms of dialogue, which include:

• recurring, dedicated in-person dialogue sessions conducted as part of the double materiality assessment process (as described in disclosure IRO-1),
• the Local Community Relations Officer inbox,
• dedicated dialogue sessions with local communities around new capital projects,
• meetings with investors,
• B2B customer surveys and enquiries,
• press conferences and meetings with journalists, the Press Office inbox,
• regular employee satisfaction surveys,
• feedback forms for individual customers, for example regarding their experience with service stations,
• social media channels.

Information on stakeholder views and interests gathered as part of engagement with the ORLEN Group stakeholders is taken into account in the development of our strategic directions or business model.

Analysis of interests and views of key stakeholders in the context of ORLEN’s strategy and business model

We consider stakeholder input in shaping our strategy and in our ongoing business activities. The updated ORLEN Group Sustainable Development Strategy incorporates the outcomes of stakeholder dialogue and the double materiality assessment process. The document is structured around five pillars and 18 streams, and has been intentionally designed to reflect key expectations of stakeholders, including investors, employees and rating agencies, customers, business partners, local communities and other groups relevant to the Company’s operations. Matrix analyses, consultations and reported needs have triggered a revision of our sustainability priorities, strengthening elements relating to environmental responsibility and local engagement.

ORLEN Group Stakeholder impact map

The dependency matrix illustrates the level of mutual influence between ORLEN and key stakeholder groups, and forms part of the double materiality assessment process in line with ESRS requirements. Analysis of the matrix enables a systematic and comparative assessment of relationships with stakeholders and supports the identification of those requiring priority management, as well as those requiring ongoing monitoring or periodic dialogue. It confirms that the ORLEN Group operates within a complex ecosystem of relationships in which stakeholders with a high degree of mutual impact are of particular importance. Their identification facilitates structured dialogue and integration of their perspectives into the double materiality assessment process in accordance with the requirements of the CSRD Directive.

Key stakeholders include entities whose decisions, needs and views are directly relevant to the Group’s growth directions, investments, operational security and financial performance, while the Group’s operations have a material impact on their economic, social and environmental circumstances. In 2025, local communities were also classified within this group, reflecting the growing importance of their expectations in the context of the energy transition and the Group’s new investments. This change entails the need for in-depth consultations, dialogue and education, as well as initiatives supporting local development and building community trust in investment processes.

Stakeholders that exert a strong impact on the ORLEN Group’s operations but are only moderately impacted by the Group are entities that shape the information, regulatory and market environment. Their influence on our reputation and operating conditions is significant; therefore, transparent communication, trend monitoring and active participation in industry and regulatory dialogue are essential.

Stakeholders significantly impacted by ORLEN (in the environmental, social or economic context), whose impact on ORLEN remains moderate, also constitute an important category. In relation to these groups, the Company undertakes consultative, social and environmental efforts, as well as extensive educational initiatives supporting the development of competencies, safety and environmental awareness. ORLEN’s educational programmes in the areas of energy and new technologies, as well as environmental protection and safety, significantly contribute to fostering long-term relationships and strengthening the social capital within its business environment.

In 2025, the natural environment was formally identified as a stakeholder for the first time. The ORLEN Group’s operations have a direct impact on ecosystem health, natural resources, and air, water and soil quality, while climate change, biodiversity loss and regulatory pressures influence the Group’s operating conditions, operating expenses and strategic risks. Incorporating the environment into the Group’s stakeholder map, in line with the ESRS approach, which recognises it as a non-human stakeholder, enables ORLEN to better identify areas that require impact mitigation, plan environmental actions, and develop investments supporting the energy transition and low-carbon economy.

The results of stakeholder engagement are used to identify material impacts, risks and opportunities (IROs), define strategic directions for sustainable development, design sustainability policies and actions, and plan communication, consultation and educational activities. The stakeholder dependency matrix will be regularly reviewed and refined in line with the development of the Group’s operations and evolution of the social, regulatory and environmental landscape. Further stakeholder engagement, including public consultations, industry partnerships, educational activities and ongoing monitoring of expectations, may result in future adjustments to the matrix, including changes in the materiality of individual stakeholder groups.

The Management Board and the Supervisory Board are regularly informed of stakeholder views through periodic reports on the double materiality assessment (including identified impacts, risks and opportunities), as well as through information provided in project documentation and sustainability reports.

Material impacts, risks and opportunities and their interaction with strategy and business model [SBM-3]

The double materiality assessment considers impacts, risks and opportunities related to sustainability matters, as required under ESRS 1 (AR 16), which are impacted by the ORLEN Group (impact materiality) or which have a material impact on the ORLEN Group (financial materiality).

The list of material topics for 2025 covers the same scope of ESRS standards as those identified in 2024, which formed the basis for analysis and assessment. Changes compared to 2024 relate solely to the aggregation of individual impacts, risks and opportunities due to their similar nature and management approach. The impact assessment was also linked to the financial assessment. Furthermore, positive impacts arising from legal requirements or constituting mitigating actions were removed, reducing the number of topics from 78 to 58 so that the report focuses on information that is genuinely material. The materiality threshold remained unchanged in 2025.

In addition to the impacts, risks and opportunities required to be disclosed under ESRS, in 2025 we also considered and presented two entity-specific disclosures.

Additional entity-specific topics

The thematic sections of this Sustainability Statement include tables containing descriptions of material impacts, risks and opportunities identified through the double materiality assessment, and specifying where in the value chain they are concentrated, considering the geographical areas, business segments and types of the ORLEN Group’s operations.

The double materiality assessment of impacts identified not only where they occur and their temporal dimension, but also whether they are positive or negative and actual or potential. The identified impacts are interrelated with the ORLEN 2035 strategy, the ORLEN Group Transition Plan and the ORLEN Group Sustainable Development Strategy, which set out objectives and actions in the areas of the energy transition and ESG.

Description of material impacts together with their point of origin and time horizon

Sustainability-related impacts, risks and opportunities are closely linked to our strategy and business model and constitute a key element of our management framework. They are material from the perspective of the long-term resilience of the business model, competitiveness and value creation. Sustainability matters are analysed not only in the context of regulatory requirements, but also as an important enabler for identifying and leveraging long-term growth opportunities for the ORLEN Group, in particular with respect to the development of new business lines, adoption of low- and zero-carbon technologies, and strengthening our competitive position.

As an integrated energy group, we have an impact on the climate and the environment, including through exploration and production, gas distribution, crude processing, petrochemical production, power and heat generation, and energy supply to end users, which involve emissions and the use of natural resources. At the same time, we consistently pursue sustainable development initiatives, investing in the energy transition, development of low- and zero-carbon business lines, and reduction of greenhouse gas emissions. The implementation of the ORLEN 2035 strategy and our commitment to achieving climate neutrality by 2050 are aimed at reducing negative environmental impacts, while strengthening our competitiveness and positive impacts on communities and our economic environment as part of a sustainable transition process.

The identified material impacts, risks and opportunities are directly linked to our ORLEN 2035 strategy, the ORLEN Transition Plan and the ORLEN Group Sustainable Development Strategy. These documents guide our efforts relating to the energy transition, sustainable development, engaging with local communities, and adjustment of our product and service offering to adapt to evolving customer needs, ensuring consistency of our strategic approach over the short-, mediumand long-term horizons. The key time horizon for the ORLEN Group is the period up to 2035, which defines our strategic outlook.

In order to assess the resilience of the ORLEN Group Strategy and the related ORLEN Transition Plan to climate change impacts, the Company regularly analyses the principal factors affecting the Group’s growth. As a result, it is able to identify material climate-related risks and opportunities, including transition risks and physical risks, and to evaluate their potential impact on its operations, strategy implementation and ability to create value over the long term. The conclusions of these analyses, covering various scenarios for the legal and regulatory, technological, market and reputational developments, inform the strategic planning process and form the basis for adapting the ORLEN Group’s growth directions, including transformation and investment activities, in order to maintain the resilience of the Group’s business model under changing external conditions.

Our climate risk analysis is based on a range of climate scenarios and projections for developments in our economic environment, which include both possible unrestricted emissions growth, which is relevant to the materialisation of physical climate risks, and an accelerated energy transition. We have assessed the severity and the likelihood of physical climate risks on the basis of the high-emissions SSP5-8.5 scenario, which assumes an average global air temperature increase of around 4.4°C. Transition risks, in turn, have been analysed based on the low-emission SSP1-1.9 scenario, consistent with the Paris Agreement, which assumes keeping warming below 1.5°C. For the period to 2035, this scenario has been supplemented with the sector-specific scenarios described in disclosure E1, facilitating assessment of the exposure of our assets and operations to transition risks under different rates of economic decarbonisation.

The climate change scenarios we used reflect different possible developments in the ORLEN Group’s regulatory, market and technological environment, in particular differing rates of economic decarbonisation resulting, among other things, from the gradual phase-out of fossil fuels and the deployment of low- and zero-carbon technologies.

For detailed information on the resilience analysis of the ORLEN Transition Plan, see disclosure E1.

The current measurement of assets covering all identified risks is presented in the following sections of the consolidated financial statements: Note 4.3 – Impact of sustainability matters on the financial statements, and Note 12.6 – Impairment of property, plant and equipment, intangible assets, goodwill and right-of-use assets.

Description of the process to identify and assess material impacts, risks and opportunities [IRO-1]

The primary process we use at the ORLEN Group to identify and assess material impacts, risks and opportunities (IROs) is the double materiality assessment carried out in accordance with the requirements of the CSRD Directive and the Delegated Regulation on European Sustainability Reporting Standards (ESRS).

In 2025, we once again conducted a thorough double materiality assessment, identifying material impacts, risks and opportunities reported on in this Statement. The principle of double materiality means that we have considered:

• the impact materiality perspective, i.e. the ORLEN Group’s impacts on the environment and society in relation to sustainability matters,
• the financial materiality perspective, i.e. the impact of sustainability matters on the ORLEN Group’s future financial performance.

The analysis covered impacts, risks and opportunities related to all sustainability matters, as required under ESRS 1 (AR 16), as well as topics identified through stakeholder dialogue and benchmarking analysis, including ESG ratings and industry reports for the oil and gas sector.

Stakeholder dialogue within the ORLEN Group was conducted using a variety of tools to engage key stakeholder groups. At the end of 2023 and in early 2024, we conducted a survey covering all sustainability areas among internal and external stakeholders. A total of 138 correctly completed questionnaires were collected, and the results were qualitatively incorporated into the assessment of impact materiality. In 2025, we held dedicated dialogue sessions focusing on social matters. The dialogue process was based on the AA1000 Stakeholder Engagement Standard (AA1000SES), which ensured its reliability and transparency. The sessions were addressed to stakeholders with close links to specific thematic areas, enabling the collection of in-depth expert opinions and expectations and thus facilitating the identification of sustainability topics to be potentially included in the ORLEN Group’s sustainability reporting. In identifying material topics, we considered the nature of our operations, business models and the geographical areas in which the ORLEN Group operates. This Sustainability Statement forms part of the ORLEN Group’s consolidated reporting and includes material topics identified by subsidiaries which are covered by the reporting obligation. The scales and materiality thresholds applied are derived from ORLEN’s management system: Enterprise Risk Management Policy, which is described in disclosure GOV-5.

The double materiality assessment relied on a wide range of internal and external sources of information.

External sources included:

• benchmarking analysis,
• ESG rating analysis,
• analysis of industry reports,
• external tools such as IPBES, GBS@, ENCORE, WWF, Biodiversity Filter,
• stakeholder consultations,
• the LEAP methodology following from a Taskforce on Nature-related Financial Disclosures (TNFD) recommendation.

Internal sources included:

• the risk management process,
• financial statements and Management Board’s Report,
• EU Taxonomy-aligned reporting,
• previous sustainability statements,
• customer satisfaction surveys and employee feedback,
• as well as the ORLEN Group Sustainable Development Strategy.

The impact materiality and financial materiality assessments drew on input from numerous experts across various departments and business areas of ORLEN S.A. and other ORLEN Group companies, who are responsible for the management of ESG topics within the Group’s segment-based approach. The detailed parameters of impact materiality and financial materiality were also consulted with experts from a third-party consultancy firm. As part of the double materiality assessment, we identified impacts, risks and opportunities based on the above sources and analysed them from both perspectives.

Description of the methods and assumptions used in topic areas

Impact materiality perspective

The assessment considered impacts occurring:

Assessment dimensions aligned with the assessment criteria

A weighted average was used to assess impacts, with more weight assigned to impact severity (understood as the scale, scope and irremediable character of the impact) than to its likelihood. Resulting scores ranged from 0 to 5, with the materiality threshold set at 3. Impacts scoring above 3 were considered material. For actual impacts, likelihood was always assigned the maximum score of 5, reflecting that the event has already occurred or its effects are ongoing. The impact score is calculated as a weighted average of the scores assigned to individual criteria. This approach ensures that actual impacts, being documented and characterised by the highest likelihood, can have higher materiality ratings than potential impacts, preventing the underestimation of impacts that have actually occurred and resulted in documented consequences.

Financial materiality perspective

Risks and opportunities were assessed according to the likelihood of occurrence and financial impact of the event. The materiality and financial thresholds applied are consistent with the ORLEN S.A. Enterprise Risk Management Policy.

Risk mapping methodology

The matrix and thresholds used in the assessment of financial materiality are derived from ORLEN’s management system: Enterorise Risk Management Policy.

In assessing financial materiality, risk is defined as a combination of severity and likelihood, both measured on a scale from 1 to 5, resulting in 25 possible risk combinations for the ORLEN Group, ranked by materiality from 1 to 25. From the perspective of the double materiality assessment, topics are considered material if their associated risks are assessed as moderate (10–15>, high (15–20> or critical (20–25>, i.e. the materiality threshold is set at 10.

Validation of results

The final list of material topics was discussed during a meeting of the Climate and Sustainability Council and Sustainability Committee. In February 2026, it was formally approved by the Management Board and the Supervisory Board. For a description of changes in the double materiality assessment, see disclosure SBM-3.

Material topics identified in the double materiality assessment process

As a result of the double materiality assessment, we analysed 76 material topics in accordance with the ESRS, including 22 environmental topics, 48 social topics, and 6 topics related to governance, as well as 2 additional entity-specific topics (not covered under the ESRS) that are considered significant in the context of the ORLEN Group’s operations.

List of material sustainability matters (by sub-topics and sub-sub-topics)

The identified impacts, risks and opportunities are presented in the disclosures on the respective areas.

The information disclosed under IRO-2 is available in appendices at the end of this Sustainability Statement.