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Disclosure requirements in ESRS compiled with in preparing the sustainability statement following the materiality assessment [IRO-2]

Disclosure requirements covered [IRO-2]

ESRSDisclosure requirementLocation in the report
ESRS 2BP-1 General basis for preparation of the sustainability statementSection 6.1.1
BP-2 Disclosures in relation to specific circumstancesSection 6.1.2
GOV-1 The role of the administrative, management and supervisory bodiesSection 6.1.3
GOV-2 Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodiesSection 6.1.4
GOV-3 Integration of sustainability-related performance in incentive schemesSection 6.1.5
GOV-4 Statement on due diligenceSection 6.1.6
GOV-5 Risk management and internal controls over sustainability reportingSection 6.1.7
SBM-1 Strategy, business model and value chainSection 6.1.8
SBM-2 Interests and views of stakeholdersSection 6.1.10
SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business modelSection 6.1.11
IRO-1 Description of the process to identify and assess material impacts, risks and opportunitiesSection 6.1.12
IRO-2 Appendices – Disclosure Requirements in ESRS covered by the undertaking's sustainability statementSection 6.13.1
ESRS E1
Climate change
E1-1 Transition plan for climate change mitigationSection 6.3.1
E1-2 Policies related to climate change mitigation and adaptationSection 6.3.2
E1-3 Actions and resources in relation to climate change policiesSection 6.3.3
E1-4 Targets related to climate change mitigation and adaptationSection 6.3.4
E1-5 Energy consumption and mixSection 6.3.5
E1-6 Gross Scopes 1, 2, 3 and Total GHG emissionsSection 6.3.6
E1-7 GHG removals and GHG mitigation projects financed through carbon creditsSection 6.3.7
E1-8 Internal carbon pricingSection 6.3.8
ESRS E2
Pollution
E2-1 Policies related to pollution Section 6.4.1
E2-2 Actions and resources related to pollutionSection 6.4.2
E2-3 Targets related to pollutionSection 6.4.3
E2-4 Pollution of air, water and soilSection 6.4.4
E2-5 Substances of concernSection 6.4.5
E2-5 Substances of very high concernSection 6.4.6
ESRS E3
Water and marine resources
E3-1 Policies related to water and marine resources Section 6.5.1
E3-2 Actions and resources related to water and marine resourcesSection 6.5.2
E3-3 Targets related to water and marine resourcesSection 6.5.3
E3-4 Water consumptionSection 6.5.4
ESRS E4
Biodiversity and ecosystems
E4-1 Transition plan and consideration of biodiversity and ecosystems in strategy and business model Section 6.6.1
E4-2 Policies related to biodiversity and ecosystemsSection 6.6.2
E4-3 Actions and resources related to biodiversity and ecosystemsSection 6.6.3
E4-4 Targets related to biodiversity and ecosystemsSection 6.6.4
E4-5 Impact metrics related to biodiversity and ecosystems changeSection 6.6.5
ESRS E5
Resource use and circular economy
E5-1 Policies related to resource use and circular economySection 6.7.1
E5-2 Actions and resources related to resource use and circular economySection 6.7.2
E5-3 Targets related to resource use and circular economySection 6.7.3
E5-4 Resource inflowsSection 6.7.4
E5-5 Resource outflowsSection 6.7.5
ESRS S1
ORLEN Group own workforce
S1-1 Policies related to own workforce Section 6.8.1
S1-2 Processes for engaging with own workforce and workers' representatives about impactsSection 6.8.2
S1-3 Processes to remediate negative impacts and channels for own workforce to raise concernsSection 6.8.3
S1-4 Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions Section 6.8.4
S1-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesSection 6.8.5
S1-6 Characteristics of the undertaking's employeesSection 6.8.6
S1-8 Collective bargaining coverage and social dialogueSection 6.8.7
S1-9 Diversity metricsSection 6.8.9
S1-10 Adequate wagesSection 6.8.7
S1-11 Social protectionSection 6.8.7
S1-12 Persons with disabilitiesSection 6.8.8
S1-13 Training and skills development metricsSection 6.8.11
S1-14 Health and safety metricsSection 6.8.7
S1-15 Work-life balance metricsSection 6.8.7
S1-16 Remuneration metrics (pay gap and total remuneration)Section 6.8.10
S1-17 Incidents, complaints and severe human rights impactsSection 6.8.12
ESRS S2
Workers in the value chain
S2-1 Policies related to value chain workers Section 6.9.1
S2-2 Processes for engaging with value chain workers about impactsSection 6.9.2
S2-3 Processes to remediate negative impacts and channels for value chain workers to raise concernsSection 6.9.3
S2-4 Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions Section 6.9.4
S2-5 - Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesSection 6.9.5
ESRS S3
Affected communities
S3-1 Policies related to affected communities Section 6.10.1
S3-2 Processes for engaging with affected communities about impactsSection 6.10.2
S3-3 Processes to remediate negative impacts and channels for affected communities to raise concernsSection 6.10.3
S3-4 Taking action on material impacts on affected communities, and approaches to managing material risks and pursuing material opportunities related to affected communities, and effectiveness of those actions Section 6.10.4
S3-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesSection 6.10.5
ESRS S4
Consumers and end-users
S4-1 Policies related to consumers and end-usersSection 6.11.1
S4-2 Processes for engaging with consumers and end-users about impactsSection 6.11.2
S4-3 Processes to remediate negative impacts and channels for consumers and end-users to raise concernsSection 6.11.3
S4-4 Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions Section 6.11.4
S4-5 - Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesSection 6.11.5
ESRS G1
Business conduct
G1-1 Business conduct policies and corporate cultureSection 6.12.1
G1-2 Management of relationships with suppliersSection 6.12.2
G1-3 Prevention and detection of corruption and briberySection 6.12.4
G1-4 Incidents of corruption or briberySection 6.12.5
G1-5 Political influence and lobbying activitiesSection 6.12.6
G1-6 Payment practicesSection 6.12.3

All datapoints that derive from other EU legislation [IRO-2] – Appendix B

Disclosure Requirement and related datapointSFDR referencePillar 3 referenceBenchmark Regulation referenceEU Climate Law referenceComment
ESRS 2 GOV-1 Board’s gender diversity, paragraph 21(d)Indicator No. 13 in Table 1 of Annex ICommission Delegated Regulation (EU) 2020/1816, Annex II
ESRS 2 GOV-1 Percentage of board members who are independent, paragraph 21(e)Delegated Regulation (EU) 2020/1816, Annex II
ESRS 2 GOV-4 Statement on due diligence, paragraph 30Indicator No. 10 in Table 3 of Annex I
ESRS 2 SBM-1 Involvement in activities related to fossil fuel activities, paragraph 40(d)iIndicator No. 4 in Table 1 of Annex I Regulation (EU) 575/2013, Article 449a; Commission Implementing Regulation (EU) 2022/2453 (6) Table 1: Qualitative information on Environmental risk and Table 2: Qualitative information on Social risk Delegated Regulation (EU) 2020/1816, Annex II
ESRS 2 SBM-1 Involvement in activities related to chemical production, paragraph 40(d)iiIndicator No. 9 in Table 2 of Annex IDelegated Regulation (EU) 2020/1816, Annex II
ESRS 2 SBM-1 Involvement in activities related to controversial weapons, paragraph 40(d)iiiIndicator No. 14 Table 1 of Annex IDelegated Regulation (EU) 2020/1818, Article 12(1); Delegated Regulation (EU) 2020/1816, Annex II
ESRS 2 SBM-1 Involvement in activities related to cultivation and production of tobacco, paragraph 40(d)ivDelegated Regulation (EU) 2020/1818, Article 12(1); Delegated Regulation (EU) 2020/1816, Annex II
ESRS E1-1 Transition plan to reach climate neutrality by 2050, paragraph 14Regulation (EU) 2021/1119, Article 2(1)
ESRS E1-1 Undertakings excluded from Paris-aligned Benchmarks, paragraph 16(g) Regulation (EU) 575/2013, Article 449a; Commission Implementing Regulation (EU) 2022/2453 Template 1: Banking book – Climate Change transition risk: Credit quality of exposures by sector, emissions and residual maturity Delegated Regulation (EU) 2020/1818, Article 12.1(d) to (g) and Article 12.2
ESRS E1-4 GHG emission reduction targets, paragraph 34Indicator No. 4 in Table 2 of Annex I Regulation (EU) 575/2013, Article 449a; Commission Implementing Regulation (EU) 2022/2453, Template 3: Banking book – Climate change transition risk: alignment metrics Delegated Regulation (EU) 2020/1818, Article 6
ESRS E1-5 Energy consumption from fossil sources disaggregated by sources (only high climate impact sectors), paragraph 38Indicator No. 5 in Table 1 and Indicator No. 5 in Table 2 of Annex I
ESRS E1-5 Energy consumption and mix, paragraph 37Indicator No. 5 in Table 1 of Annex I
ESRS E1-5 Energy intensity associated with activities in high climate impact sectors, paragraphs 40 to 43Indicator No. 6 in Table 1 of Annex I
ESRS E1-6 Gross Scope 1, 2, 3 and Total GHG emissions, paragraph 44Indicators Nos, 1 and 2 in Table 1 of Annex I Regulation (EU) 575/2013, Article 449a; Commission Implementing Regulation (EU) 2022/2453 Template 1: Banking book – Climate change transition risk: Credit quality of exposures by sector, emissions and residual maturity Delegated Regulation (EU) 2020/1818, Article 5(1), Article 6 and Article 8(1)
ESRS E1-6 Gross GHG emissions intensity, paragraphs 53 to 55Indicator No. 3 Table 1 of Annex I Regulation (EU) 575/2013, Article 449a; Commission Implementing Regulation (EU) 2022/2453, Template 3: Banking book – Climate change transition risk: alignment metrics Delegated Regulation (UE) 2020/1818, Article 8(1)
ESRS E1-7 GHG removals and carbon credits, paragraph 56Regulation (EU) 2021/1119, Article 2(1)
ESRS E1-9 Exposure of the benchmark portfolio to climaterelated physical risks, paragraph 66Delegated Regulation (EU) 2020/1818, Annex II; Delegated Regulation (EU) 2020/1816, Annex IIThis disclosure is not provided due to transitional provisions
ESRS E1-9 Disaggregation of monetary amounts by acute and chronic physical risk, paragraph 66(a) ESRS E1-9 Location of significant assets at material physical risk, paragraph 66(c) Regulation (EU) 575/2013, Article 449a; Commission Implementing Regulation (EU) 2022/2453, points 46 and 47; Template 5: Banking book – Climate change physical risk: Exposures subject to physical risk. This disclosure is not provided due to transitional provisions
ESRS E1-9 Breakdown of the carrying amount of real estate assets by energy-efficiency classes, paragraph 67(c) Regulation (EU) 575/2013, Article 449a; Commission Implementing Regulation (EU) 2022/2453, point 34 Template 2: Banking book – Climate change transition risk: Loans collateralised by immovable property – Energy efficiency of the collateral This disclosure is not provided due to transitional provisions
ESRS E1-9 Degree of exposure of the portfolio to climaterelated opportunities, paragraph 69Delegated Regulation (EU) 2020/1818, Annex IIThis disclosure is not provided due to transitional provisions
ESRS E2-4 Amount of each pollutant listed in Annex II of the EPRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water and soil, paragraph 28 Indicator No. 8 in Table 1 of Annex I, indicator No. 2 in Table 2 of Annex I, indicator No. 1 in Table 2 of Annex I, and indicator No. 3 in Table of 2 of Annex I
ESRS E3-1 Water and marine resources, paragraph 9Indicator No. 7 in Table 2 of Annex I
ESRS E3-1 Dedicated policy, paragraph 13Indicator No. 8 in Table 2 of Annex 1
ESRS E3-1 Sustainable oceans and seas, paragraph 14Indicator No. 12 in Table 2 of Annex INot applicable
ESRS E3-4 Total water recycled and reused, paragraph 28(c)Indicator No. 6.2 in Table 2 of Annex I
ESRS E3-4 Total water consumption in m3 net revenue on own operations, paragraph 29 Indicator No. 6.1 in Table 2 of Annex I
ESRS 2 SBM 3-E4, paragraph 16(a)(i)Indicator No. 7 in Table 1 of Annex I
ESRS 2 SBM-3 E4, paragraph 16(b)Indicator No. 10 in Table 2 of Annex I
ESRS 2 SBM-3 E4, paragraph 16(c)Indicator No. 14 Table 2 of Annex I
ESRS E4-2 Sustainable land/ agriculture practices or policies, paragraph 24(b)Indicator No. 11 in Table 2 of Annex I
ESRS E4-2 Sustainable oceans / seas practices or policies, paragraph 24(c)Indicator No. 12 in Table 2 of Annex INot applicable
ESRS E4-2 Policies to address deforestation, paragraph 24(d)Indicator No. 15 in Table 2 of Annex I
ESRS E5-5 Non-recycled waste, paragraph 37(d)Indicator No. 13 in Table 2 of Annex I
ESRS E5-5 Hazardous waste and radioactive waste, paragraph 39Indicator No. 9 in Table 1 of Annex I
ESRS 2 SBM-3-S1 Risk of incidents of forced labour, paragraph 14(f)Indicator No. 13 in Table 3 of Annex I
ESRS 2 SBM-3-S1 Risk of incidents of child labour, paragraph 14(g)Indicator No. 12 in Table 3 of Annex I
ESRS S1-1 Human rights policy commitments, paragraph 20Indicator No. 9 in Table 3 and indicator No. 11 in Table 1 of Annex I
ESRS S1-1 Due diligence policies on issues addressed by the fundamental International Labor Organisation Conventions 1 to 8, paragraph 21Delegated Regulation (EU) 2020/1816, Annex II
ESRS S1-1 Processes and measures for preventing trafficking in human beings, paragraph 22Indicator No. 11 in Table 3 of Annex INot applicable
ESRS S1-1 Workplace accident prevention policy or management system, paragraph 23Indicator No. 1 in Table 3 of Annex I
ESRS S1-3 Grievance/complaints handling mechanisms, paragraph 32(c)Indicator No. 5 in Table 3 of Annex I
ESRS S1-14 Number of fatalities and number and rate of workrelated accidents, paragraph 88(b) and (c)Indicator No. 2 in Table 3 of Annex IDelegated Regulation (EU) 2020/1816, Annex II
ESRS S1-14 Number of days lost to injuries, accidents, fatalities or illness, paragraph 88(e)Indicator No. 3 in Table 3 of Annex I
ESRS S1-16 Unadjusted gender pay gap, paragraph 97(a)Indicator No. 12 in Table 1 of Annex IDelegated Regulation (EU) 2020/1816, Annex II
ESRS S1-16 Excessive CEO pay ratio, paragraph 97(b)Indicator No. 8 in Table 3 of Annex I
ESRS S1-17 Incidents of discrimination, paragraph 103(a)Indicator No. 7 in Table 3 of Annex I
ESRS S1-17 Non-respect of UNGPs on Business and Human Rights and OECD guidelines, paragraph 104(a)Indicator No. 10 in Table 1 and indicator No. 14 in Table 3 of Annex IDelegated Regulation (EU) 2020/1816, Annex II; Delegated Regulation (EU) 2020/1818, Article 12(1)
ESRS 2 SBM-3 S2 Significant risk of child labour or forced labour in the value chain, paragraph 11(b)Indicators Nos. 12 and 13 in Table 3 of Annex I
ESRS S2-1 Human rights policy commitments, paragraph 17Indicator No. 9 in Table 3 and indicator No. 11 in Table 1 of Annex I
ESRS S2-1 Policies related to value chain workers, paragraph 18Indicators Nos. 11 and 4 in Table 3 of Annex I
ESRS S2-1 Non-respect of UNGPs on Business and Human Rights principles and OECD guidelines, paragraph 19Indicator No. 10 in Table 1 of Annex IDelegated Regulation (EU) 2020/1816, Annex II; Delegated Regulation (EU) 2020/1818, Article 12(1)
ESRS S2-1 Due diligence policies on issues addressed by the fundamental International Labor Organisation Conventions 1 to 8, paragraph 19Delegated Regulation (EU) 2020/1816, Annex II
ESRS S2-4 Human rights issues and incidents connected to the undertaking’s upstream and downstream value chain, paragraph 36Indicator No. 14 in Table 3 of Annex I
ESRS S3-1 Human rights policy commitments, paragraph 16Indicator No. 9 in Table 3 of Annex I and indicator No. 11 in Table 1 of Annex I
ESRS S3-1 Non-respect of UNGPs on Business and Human Rights, ILO principles or/and OECD guidelines, paragraph 17Indicator No. 10 in Table 1 of Annex IDelegated Regulation (EU) 2020/1816, Annex II; Delegated Regulation (EU) 2020/1818, Article 12(1)
ESRS S3-4 Human rights issues and incidents, paragraph 36Indicator No. 14 in Table 3 of Annex I
ESRS S4-1 Policies related to consumers and end-users, paragraph 16Indicator No. 9 in Table 3 and indicator No. 11 in Table 1 of Annex I
ESRS S4-1 Non-respect of UNGPs on Business and Human Rights and OECD guidelines, paragraph 17Indicator No. 10 in Table 1 of Annex IDelegated Regulation (EU) 2020/1816, Annex II; Delegated Regulation (EU) 2020/1818, Article 12(1)
ESRS S4-4 Human rights issues and incidents, paragraph 35Indicator No. 14 in Table 3 of Annex I
ESRS G1-1 United Nations Convention against Corruption, paragraph 10(b)Indicator No. 15 in Table 3 of Annex I
ESRS G1-1 Protection of whistle-blowers, paragraph 10(d)Indicator No. 6 in Table 3 of Annex I
ESRS G1-4 Fines for violation of anti-corruption and antibribery laws, paragraph 24(a)Indicator No. 17 in Table 3 of Annex IDelegated Regulation (EU) 2020/1816, Annex II
ESRS G1-4 Standards of anti-corruption and anti-bribery, paragraph 24(b)Indicator No. 16 in Table 3 of Annex I

Management Report

on the activities of the ORLEN Group and ORLEN S.A. for 2025.

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