Affected Communities [ESRS S3]

The Policy governs the management of impacts, risks and opportunities arising from operation of our assets and their effect on local communities. It sets out the following objectives:

• to minimise operational nuisance,
• to build long-term relationships based on dialogue,
• to ensure alignment between business, social.

The Policy addresses impacts and risks such as noise, odours, restrictions on property access, the risk of claims and social tensions, as well as opportunities related to improved relationships, increased trust and the facilitation of project implementation.

The Policy applies to all ORLEN Group locations in Poland and abroad where its production, logistics, project and upstream operations are carried out. Its scope also covers indirect impacts across the value chain, including those arising from field works, transport and upgrades carried out by contractors.

Responsibility for the implementation and application of the Policy rests with the ORLEN S.A. Management Board, while operational oversight is exercised by the relevant directors and the Local Community Relations Officer.

The Policy has been developed taking into account the expectations of local communities, identified through consultations, reporting channels and ongoing dialogue led by the Local Community Relations Officer.

The document is publicly available on orlen.pl, and information on its implementation is communicated to communities through meetings, consultations and reporting channels.

The ORLEN Group Code of Ethics and the Human Rights Policy set out our commitment to preventing negative impacts on human rights, including those affecting local communities. They address impacts such as access to information, the ability to raise concerns, safety in the vicinity of assets, respect for property rights, and risks related to potential infringements of the rights of local communities and landowners.

The document applies across all Group companies, our entire value chain (including contractors involved in fieldwork, transport and operational activities), and all geographical locations in which we operate.

The policies are aligned with:

• The International Bill of Human Rights,
• The United Nations Declaration on the Rights of Indigenous Peoples,
• ILO Convention No. 169,
• The OECD Guidelines for Multinational Enterprises,
• The United Nations Guiding Principles on Business and Human Rights.

Overall responsibility for its implementation rests with the ORLEN S.A. Management Board, while operational oversight is exercised by the relevant directors.

In updating and applying the policies, material needs of local communities, as expressed through grievances, reports and ongoing local dialogue, are taken into account.

The documents are publicly available, and information on grievance channels is communicated to affected communities via the website and dedicated contact channels.

The Policy governs donations and community support, addressing impacts and opportunities related to social engagement, including:

• social contribution and sponsorship activities,
• projects delivered by corporate foundations,
• building trust and strengthening relationships with communities affected by the Group’s operations.

Considering the impacts of our operations, the Policy defines the following areas of community engagement:

• Sustainable development:
  • projects focused on environmental protection,
  • projects addressing the needs and rights of communities affected by exclusion or deficits in key areas of life, aimed at mitigating negative impacts or generating positive impacts,
  • projects related to the protection and respect of human rights,
  • projects addressing just transition.
• Education and science: initiatives supporting the advancement of education and science, including scholarship programmes, vocational training, basic and applied research, science outreach, and support for educational and research institutions.
• Culture and the arts: initiatives promoting culture and the arts, including funding for exhibitions, concerts, festivals and cultural institutions; improving access to culture.
• Health and social care: support for healthcare institutions, preventive health programmes, and initiatives aimed at improving the quality of life of people in need,
• Sport, recreation and tourism: promoting physical activity and healthy lifestyles, supporting the development of amateur and professional sport and recreational activities, as well as advancing and promoting tourism,
• Public safety and civil protection: initiatives supporting public safety services and the maintenance of public order, rescue and civil protection services, including support for volunteer fire brigades and entities authorised to carry out mountain, water and maritime search and rescue. The Policy is directly linked to identified impacts, risks and opportunities, including strengthening social acceptance of projects and reducing the risk of conflicts. It applies across the ORLEN Group and, through the Organisational Standard, extends to subsidiaries implementing charitable activities, and it covers all locations where social projects are carried out. Responsibility for implementation rests with the Management Board of ORLEN S.A., while operational delivery is ensured by the Group’s corporate foundations and relevant organisational units. The Policy has been developed to address local needs, and its priorities reflect the areas most frequently identified as material, including safety, education, health and local development. Information on the Policy and support programmes is published on orlen.pl and on the websites of the Group’s foundations.

The ORLEN Group Climate Policy, Environmental Protection Policy, Biodiversity Policy, Energy Policy and the ORLEN Transition Plan address impacts and risks related to environmental nuisance, emissions, land use, climate risks, and the effects of infrastructure on local living conditions. Together, these documents shape the Group’s relationships with local communities by reducing environmental nuisance, preventing incidents and supporting the deployment of more efficient technologies.

They apply to all of the Group’s production, energy, logistics and infrastructure assets, as well as to impacts across the value chain, including indirect emissions, water management and land use during project implementation. Oversight is exercised by directors responsible for environmental, climate and energy areas. The Policies are aligned with relevant UN climate frameworks, EU environmental standards and sustainability reporting requirements. The policy documents and information on their implementation are available on orlen.pl and in ESG and sustainability publications.

The monitoring process includes:

• ongoing analysis of submissions and grievances from affected communities,
• assessment of response timeliness,
• monitoring of corrective actions,
• oversight by the Local Community Relations Officer,
• evaluation of compliance with international guidelines,
• at subsidiary level, monitoring compliance with local safety procedures and incident response.

During the reporting period, we did not identify any instances of non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises, in relation to affected communities.

We did not record any significant incidents or human rights violations affecting local communities during the reporting period.

In 2025, we launched the Just Transition programme area, a key instrument for delivering our Sustainable Development Strategy under the Communities and Environment pillars. It addresses challenges related to economic transformation, including the energy transition and its implications for local communities, and includes actions to preserve and protect biodiversity, particularly in areas adjacent to ORLEN infrastructure.

In collaboration with Polityka Insight, in 2025 we published the report “Cities Transition Index”, assessing the readiness and progress of the 37 largest cities in Poland across heat, electricity, circular economy, environment and transport. The analysis was complemented by examples of well-designed policies implemented by smaller cities. We also partnered in the Local Government Climate Congress in Łódź.

As part of our engagement with local communities, the ORLEN Group Sustainable Development Strategy identifies the ORLEN as a Good Neighbour initiative, whose objectives were implemented in 2025 through activities supporting just transition, including the ORLEN Community Energy programme. Its first edition targeted communities near fuel terminals and is designed as a long-term initiative to build partnership-based relationships with local communities.

The ORLEN Think Energy grant programme was also launched to fund research and analytical projects in energy transition, decarbonisation, sustainable development and socio-economic resilience. We supported initiatives strengthening the resilience of cities and communities to energy, climate and information-related challenges, including by co-funding the Energy Transition Cities Forum and the Resilient and Strong Poland project.

The ORLEN Foundation for Pomerania plays a particularly important role in this area, given the scale and nature of its initiatives. In 2025, the Foundation’s support for the Just Transition programme focused primarily on implementing initiatives in selected locations of ongoing renewable energy projects, particularly offshore wind projects operated by the ORLEN Group. In the municipality of Łeba, where the Baltic Power project is being developed, outreach activities included supporting local communities and building relationships with local authorities. In 2025, the second edition of the Baltic Power grant programme was delivered, providing financial and expert support to initiatives submitted by residents and community organisations in Łeba, including funding for the full or partial implementation of selected projects. The primary objective of the programme is to stimulate social engagement among local organisations and informal groups. It also aims to foster integration among residents of Łeba, which is located near the Baltic Power offshore wind project.

Projects related to environmental protection and biodiversity are described in disclosures E1 and E4.

The ORLEN Group engages in dialogue with affected communities, including through the Local Community Relations Officer. A detailed description of the Officer’s role, the actions undertaken, the communication channels used and the mechanisms for monitoring their effectiveness is provided in disclosures S3-2 and S3-3. As part of our double materiality assessment, we identified an additional area (organisation-specific disclosure): community support, including support for local communities, through which we exert material actual positive impacts on affected communities. The inclusion of this topic reflects the central role that community engagement plays in the ORLEN Group’s operations. Supporting communities is a core component of our Sustainable Development Strategy and embodies our fundamental values. We foster social engagement and reinforce our position as a responsible community partner through our own initiatives, including charitable and sponsorship programmes, and the projects run by our corporate foundations, which play a vital role in building social capital and in strengthening and integrating local communities. Projects delivered through the foundations, such as health, education, sports, and culture, help address pressing social challenges and respond to the needs of the wider environment. Volunteer efforts by our employees, carried out with the support of the corporate foundations, are also an important aspect of this work.

We actively support the development of local talent through a variety of educational programmes targeting students at different stages of learning, as well as through partnerships with universities. Listed below are some of the initiatives implemented in this area 2025.

• As part of our nationwide educational initiatives, we supported a communication campaign on offshore wind energy delivered by the Polish Wind Energy Association. The campaign aims to build public understanding of offshore wind development in Poland, counter misinformation, and highlight the opportunities it creates, including career prospects.

Corporate foundations play a particularly important role in this area, given the scale and nature of their initiatives.

Selected initiatives implemented by the Ignacy Łukasiewicz ORLEN Foundation:

• Science on the Move – Science Bus programme delivered on a continuous basis – features a double-decker bus equipped with chemistry and physics laboratories and a demonstration tent, enabling interactive lessons and shows. It aims to spark interest in science among primary and secondary school students and to deepen their knowledge through engaging, non-conventional approaches. In 2025, the Science Bus visited 49 schools.
• Nationwide FunLab grant programme – supports schools, particularly in smaller towns, in establishing modern, fully equipped science laboratories for chemistry, physics, biology and vocational subjects.
• Museum Destination grant programme – launched in a pilot edition in 2025 for primary and secondary schools. Selected beneficiaries received grants of up to PLN 10 thousand to organise school trips to the Warsaw Gasworks Museum, the Gas Industry Museum in Paczków and the Oil Industry Museum in Bóbrka.

Selected initiatives implemented by the ORLEN Foundation: The ORLEN Foundation delivers a wide range of grant and scholarship programmes, including Bona Fide, My Above-Average Interests, From Molecules to Galaxies, I Can Do More, Holidays with the ORLEN Foundation, Power of Responsibility, Model United Nations, and climate education initiatives, as well as the Safe Teenager in the Digital World project; for details, see the foundation’s website at www.fundacja.orlen.pl. In addition to supporting talented pupils and students, the programmes help develop the skills of future engineers and researchers who may join the ORLEN Group, while also promoting equal access to education.

A key role in mitigating negative impacts on the safety of local communities is played by ORLEN’s Company Fire Brigade, a firefighting unit integrated into Poland’s National Firefighting and Rescue System (KSRG). It primarily operates at the production plant in Płock and operates at other sites under service agreements to provide firefighting and emergency response. The Company Fire Brigade also participates in emergency response exercises organised by ORLEN Group companies, both in Poland and abroad. A dedicated Emergency Plan has been developed for the Płock site and agreed upon with the Commander-in-Chief of the State Fire Service in the Province of Warsaw. This plan is reviewed and updated in line with national regulations. Pre-plans, or site-specific operational documents, are developed for each production and storage facility. These serve as operational tools to support decision-making by the Emergency Operations Leader. The Company Fire Brigade is also engaged in preventive fire safety measures, starting from the design phase of new or modernised facilities through to final inspections and commissioning. These specialists are also responsible for fire safety inspections, which are essential in maintaining the safety of both industrial assets and the surrounding communities.

Selected initiatives implemented by the ORLEN Foundation:

• In 2024, the ORLEN Foundation partnered with the Mountain Volunteer Search and Rescue Service (GOPR). A donation of nearly PLN 1.5 million supported rescue operations in 2025 and improved safety in the Polish mountains. ORLEN has been a longstanding supporter of national rescue organisations, including the Masurian Volunteer Search and Rescue.
• In 2025, specialised protective suits with a total value of nearly PLN 140 thousand were donated to the Maritime Search and Rescue Service (SAR).
• The ORLEN on Watch programme provides grants for specialist training, psychological support, and the purchase and insurance of equipment, with the aim of enhancing safety and emergency preparedness. Donations were provided to 368 volunteer and state fire service units.
• The ORLEN for Rescue Dogs programme supports rescue teams working with search and rescue dogs. A total of 42 grants were awarded, supporting 127 teams across Poland.
• The Together for Safety programme focuses on strengthening the resilience and operational capacity of volunteer fire brigades, with grants awarded to 129 units.
• The Safe Eaglets initiative promotes safety education for children by equipping existing State Fire Service training rooms and co-financing new ones. Support was provided to 24 units, with eight new training rooms established.

As part of our commitment to promoting preventive healthcare and improving access to medical screenings, we implemented the following initiatives in 2025 together with our medical partners, in response to local community needs:

• The free preventive screening programme Get Tested Today for a Healthier Tomorrow for residents of Płock and the Płock district, run from July to December 2025, was an opportunity to take part in monthly screenings and medical consultations. In total, 1,412 people participated in the programme. As part of the programme, a Health Festival offered cardiology consultations with ECG tests, pulmonology consultations with spirometry, and dietetic consultations with body composition analysis. Over two days, 328 people were examined. In response to strong interest, the programme was extended from January to March 2026, and work began on a new health programme scheduled to run from April to the end of 2026.
• The Health Festival organised by the ORLEN for Pomerania Foundation held its pilot edition in Przejazdowo near Gdańsk on 30–31 August 2025. Residents had access to free screenings and consultations with various specialists. The event also included an educational zone (beekeeping and environmental workshops) and a children’s zone (educational activities and a cycling safety training area). It attracted over 1,200 participants, who completed more than 2,400 screenings.
• In addition, the ORLEN Foundation supported key medical institutions and research projects. More than PLN 600 thousand was provided to the Children’s Memorial Health Institute to modernise the Small Steps Academy rehabilitation centre. The Foundation also funded training for staff of the Obstetrics and Gynaecology Clinic at the Institute of Mother and Child (PLN 100 thousand), delivered at Medway Maritime Hospital in the United Kingdom. Further support for rare disease research included a grant of PLN 200 thousand to the Rett Syndrome Research Trust for gene therapy research for people with Rett syndrome.

Selected sports initiatives:

• The Sporting ORLEN programme forms part of our social engagement, addressing declining physical activity among children and young people while supporting amateur sport in Poland over the long term. The first edition in 2025 demonstrated the importance of supporting local sports initiatives. A total of 183 clubs from across the country received funding, including multi-sport clubs (45), volleyball clubs (28), and athletics and swimming clubs (15 each). The funding enabled clubs to organise training sessions and camps, as well as psychological and nutrition workshops. In total, more than 23,000 young athletes participated, supported by 951 coaches and instructors.
• In 2025, ORLEN continued as Strategic Partner of the Sports Eagles Foundation, whose programme encourages children and young people to engage in regular physical activity. Under the Active School programme, activities delivered at municipal sports facilities included From Orlik to the Stadium football tournaments, with 72,000 participants; Handball at Orlik, with over 14,000 participants; Athletics at Orlik, with more than 42,000 participants. In total, the programme reached over 628,000 participants across more than 7,600 schools.
• As Main Sponsor of the Football Plus project, run by the Amp Football Association, ORLEN supports the development of football for children and young people with disabilities. In 2025, 19 events were held as part of the programme. The tournament cycle concluded with a national event in Warsaw, held at the football arena on the campus of the Warsaw University of Life Sciences (SGGW). Over 300 players with disabilities from across Poland took part.
• The Football Future with ORLEN project promotes sport among children by enabling their development within Poland’s longest-running youth football programme. It supports equal opportunities for physical development and the pursuit of sporting interests. Summary of Football Future with ORLEN initiatives in 2025:
  • 1,626 matches and tournaments,
  • 10,985 training sessions (nearly 16,500 hours),
  • approximately 3,800 participants,
  • approximately 30,000 items of sports equipment procured,
  • nearly 250 participants in the annual ORLEN Junior Cup,
  • 76 training camps organised by participating clubs.

Selected initiatives in culture:

• In 2025, ORLEN launched the first call for applications under its original Cultural ORLEN programme, aimed at children and young people across Poland. The programme seeks to strengthen local initiatives that, through collaborative artistic projects, foster social connections and support the personal development of young people. The call was accompanied by a nationwide social campaign under the slogan ‘Culture energises’, highlighting culture as a source of inspiration, community and development, particularly for younger audiences. Nearly 2,800 applications were submitted by cultural institutions, foundations and associations nationwide.
• In 2025, we continued our partnership with the Fryderyk Chopin National Institute, extending our ongoing support for the organisation. The collaboration included major cultural events that attracted large audiences and played a significant role in promoting Polish culture both at home and abroad, most notably the Chopin Competition. The preliminary rounds alone were attended by over 145,000 people, while online broadcasts generated more than 3.6 million views.
• ORLEN also continued its partnership with the National Museum in Warsaw, supporting its exhibition, educational and promotional activities at the main building and its branches: The Xawery Dunikowski Museum of Sculpture at Królikarnia, the Poster Museum in Wilanów, the Museum of Interiors in Otwock Wielki, and the Museum in Nieborów and Arkadia. The partnership covered permanent and temporary exhibitions, special projects and a broad educational offer for diverse audiences.
• We continued our patronage of the Grand Theatre - National Opera, supporting various artistic events across Poland. These included six premieres and the season’s flagship event – the world premiere of the opera “The Best City in the World: An Opera About Warsaw”.
• In 2025, we extended our collaboration with the Royal Castle in Warsaw, becoming one of its key sponsors.
• We also continued our cooperation with the POLIN Museum, which delivered an extensive programme of educational, cultural and exhibition activities. In March 2025, the temporary exhibition “1945. Not the End, Not the Beginning” opened and attracted over 95,000 visitors. In April, the 13th edition of the Daffodils social and educational campaign took place, involving nearly 700 volunteers, over 6,000 schools, libraries and institutions, and reaching more than 800,000 students across Poland.
• We continued our cooperation with Zachęta – National Gallery of Art as a patron of the institution, supporting its exhibition, educational and international projects. A total of 16 exhibitions were presented, featuring both established artists and premiere works created specifically for the gallery.
• In January 2025, we launched a partnership with the Łazienki Królewskie Museum, supporting key cultural and educational initiatives within this historic palace and park complex.
• From 1 January 2025, we also partnered with the Polish Royal Opera through the “Opera on Tour” series and the We Show the Opera project. “Opera on Tour” aims to broaden access to high culture across Poland, particularly in areas with limited access to professional theatre.

In 2025, we supported the Great Orchestra of Christmas Charity (WOŚP) for the first time, raising PLN 5,245,485.39 with the involvement of our customers. We contributed in two ways: collection boxes were placed at 1,737 service stations across Poland, and we donated PLN 1 for every coffee sold in January 2025. The Every Coffee Makes a Difference campaign was promoted through a specially designed WOŚP-themed cup, as well as television and billboard campaigns featuring ORLEN Team ambassador Anita Włodarczyk.

• In early May 2025, we established cooperation with the Institute of Biochemistry and Biophysics of the Polish Academy of Sciences, becoming a partner in the Antarctica under ORLEN’s Wing project. The initiative aims to designate a new Antarctic Specially Protected Area (ASPA) in one of the most remote regions of the world. It is intended to lead to the designation of an additional protected area, increasing the extent of protected zones and strengthening Poland’s international position in Antarctic research.
• Last year, once again we acted as a patron of the Explory 2025 – STEAM with Explory competition, the largest event in Poland promoting young talent in science and innovation. We have been a partner of the programme since 2013. The Explory programme, launched in 2012, is the largest initiative in Poland identifying and supporting young talent. Since its launch, the programme has built a community of over 4,000 young talents and supported more than 2,000 innovative research projects and inventions. Nearly 900 students (301 original STEAM projects) applied to the 14th edition in 2025.
• In 2025, the ORLEN Ignacy Łukasiewicz Foundation launched the pilot edition of the TURBOgrant programme aimed at student scientific societies at public universities implementing scientific, educational, development and research projects in the fields of earth sciences and energy, in particular geology, geophysics, environmental engineering, petroleum and gas engineering (including drilling and gas engineering), as well as robotics, automation, mechatronics and related disciplines. The programme aims to support talented young researchers at the early stages of their careers and contribute to the development of future engineering talent.
• In 2025, the Foundation concluded the second edition and launched the third edition of the Engineers of the Future programme, a nationwide grant programme for secondary school students. Participants develop their own research projects in energy-related fields, covering at least one scientific discipline such as physics, chemistry, energy, ecology or environmental protection. The programme culminates in the Nationwide Scientific Conference for Secondary Schools and is delivered in close cooperation with technical universities.

In 2025, we actively supported the following foundations for which ORLEN serves as the sole founder or one of the founding members:

• ORLEN Foundation, with ORLEN as its exclusive founder,
• ORLEN Foundation for Pomerania, also exclusively founded by ORLEN,
• PGNiG Ignacy Łukasiewicz Foundation, with ORLEN as the sole founder,
• Foundation of the Ignacy Łukasiewicz Oil and Gas Industry Museum in Bóbrka, with ORLEN as a co-founder,
• Grant Fund for Płock Foundation, with ORLEN as a co-founder alongside other partners, including the City of Płock,
• Grow Up With Us Foundation, with ORLEN as a co-founder,
• Polish National Foundation, with ORLEN as a co-founder.

In addition, ORLEN Group companies are the only founders of the following foundations:

• Energa Foundation, with ENERGA as the sole founder,
• Anwil Foundation, with ANWIL as the sole founder,
• ORLEN Unipetrol Foundation, with ORLEN UNIPETROL as the only founder.