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  • Consumers and End-users [ESRS S4]

Consumers and End-users [ESRS S4]

Interests and views of stakeholders [S4.SBM-2]

The focus of our activities is on identifying and responding to the needs of consumers and end-users. This approach ensures that all key areas of the Group’s activities – from the design and development of products and services, through communication and marketing, to customer service processes – are consistently informed by considerations relating to consumer safety and satisfaction. Across our operations, we implement solutions aimed at ensuring product and service quality, as well as compliance with the requirements related to energy efficiency and lifecycle safety.

Evolving consumer needs, including a shift towards a prosumer model – characterised by active and informed users of products and services – are a key driver of the parallel evolution of the ORLEN Group’s business model. The model is realigned at the level of individual Group companies, where due account is taken of the specific characteristics of the retail customer segments they serve. In response to these developments, in 2025 we continued to enhance our product and service offerings for retail customers. Our initiatives were focused on improving their accessibility and usability, advancing self-service solutions, and further enhancing the overall customer experience. Details of selected adjustments we made in 2025 to our offerings and operational solutions in response to retail customer expectations are provided in disclosure S4-4.

The strategic direction for our activities targeting end-users is defined at the ORLEN Group level within the Consumers & Products segment, with due consideration given to applicable legal requirements, in particular the consumer protection regulations. These strategic priorities are implemented at the country level, ensuring alignment with Group-level decisions as well as compliance with local regulatory frameworks and market conditions. The implementation process is underpinned by systematic integration of feedback from consumers and end-users, and further informed by ongoing analysis of their evolving needs and expectations. Customer views obtained through available touchpoints, satisfaction surveys, and behavioural analysis constitute a key source of insights we rely on to enhance our product and service offerings and to design new convenience-enhancing solutions within our retail infrastructure.

Material impacts, risks and opportunities and their interaction with strategy and business model [S4.SBM-3]

Our operations generate material impacts on the natural environment, society and the economy, as reflected in the outcomes of the double materiality assessment for consumers and end-users. The material impacts, risks and opportunities we identified through the materiality assessment relate in particular to data privacy of consumers and end-users, access to quality information, health and safety aspects of product use, accessibility of products and services, energy security, as well as responsible sales and marketing practices. These areas are intrinsically linked to the ORLEN Group’s strategy and business model, which is rooted in large-scale industrial operations and the provision of essential products and services to a broad customer base across domestic and international markets. As a result of these dependencies, the Group’s influence on consumers is extensive and embedded in the wide product availability, long-term customer relationships, and a sustained focus on quality and safety.

The rapid pace of technological advancement, increasing pressure for digitalisation, the adoption of new business models associated with the energy transition, the rising importance of ESG factors, intensified efforts to improve energy efficiency, the signing of the Effective Transformation Charter, as well as the diversification of energy sources, and the decarbonisation process continue to reshape the Group’s strategic direction and business model. These dynamics give rise to both risks and opportunities. Key risks include those related to personal data protection, product safety, and the continuity of access to fuels and energy amid geopolitical volatility. Conversely, significant opportunities arise from our efforts to strengthen energy security, advance the energy transition, ensure wide availability of our products and services, and reinforce customer trust and loyalty.

Potential negative impacts on consumers and end-users have not been assessed by the ORLEN Group as widespread or systemic. Where they occur, they are incidental in nature and effectively mitigated through our established internal standards, procedures and management systems.

An essential component of the ORLEN Group’s strategy is to develop digital solutions in response to evolving customer expectations and the growing uptake of digital channels to access products and services. 2025 Marked a significant step forward in the deployment of cloud technologies and artificial intelligence, both within our internal operations and in customer-facing applications. This direction creates material opportunities to enhance customer experience, broaden the product offering, and improve operational efficiency. At the same time, it introduces risks related to data security, business continuity, and customer trust.

In response, we systematically integrate digital development into our business model, partnering with established and reputable technology providers while implementing robust internal procedures to manage operational and cybersecurity risks. This approach allows us to harness the benefits of advanced technologies – such as improved service quality, personalised offerings sought after by customers, and optimised processes – while maintaining high standards of security and service reliability. Recognising the risk of digital exclusion of some customers, we additionally develop alternative solutions to ensure accessibility. In particular, dedicated processes within our Contact Centre support customers who, having no access to digital tools, are unable to benefit from digitalonly promotional offers or services.

The ORLEN Group identifies positive impacts in relation to the accessibility of communication and feedback channels for consumers and end-users, supported by the provision of multiple channels through which they can raise concerns and structured processes for handling and responding to such submissions, as described in disclosures S4-2 and S4-3. Additional positive impacts include safety education initiatives for children, most notably the Energa-Operator Safe Land programme delivered by the ENERGA Group, broad access to products and services through the continuous alignment of our offerings with customer needs, as well as contributions to strengthening energy security and supporting a just transition. The actions taken in relation to these positive impacts are detailed in disclosure S4-4. The identified positive impacts apply across all consumer and end-user groups recognised by the ORLEN Group.

In our interactions with consumers and end-users, we consistently apply responsible marketing practices and ensure access to reliable and clear information. Potential risks associated with inadequate communication are mitigated through transparent disclosure standards, oversight of marketing content, and strict adherence to applicable regulations. This approach not only reduces reputational risk we could otherwise face, but also strengthens customer trust. Consistent, responsible communication remains a cornerstone of building the ORLEN brand credibility and fostering longterm customer loyalty.

Characteristics of customers and end-users

Disclosures under ESRS S4 cover all consumers and end-users in direct relationships with companies of the ORLEN Group, including those using the Group’s fuel or non-fuel products and services, postsales customer support, or available communication and contact channels.

Within the scope of these disclosures, the following main categories of consumers and end-users were identified:

  • customers of service stations, who use our fuel products and services and non-fuel offerings, including food and beverages, convenience goods, and additional services such as car washes,
  • customers of electric vehicle charging stations,
  • household end-users purchasing electricity and/or gas, who also qualify as end customers as defined in the Energy Law,
  • users of courier services,
  • customers using e-commerce platforms and mobile applications, and
  • recipients of communications disseminated via channels such as press, television, radio, and outdoor advertising.

Groups of consumers and end-users included in the scope of the ORLEN Group’s reporting who are particularly vulnerable in the context of negative impacts

ImpactDescription of the group of consumers and end-users
Use of products that are inherently harmful to people and/or may increase risks for adverse health impacts. Customers using our fuel products, due to potential exposure to vapours and explosion risks, as well as customers purchasing certain non-fuel goods available at our service stations, such as tobacco products, alcoholic beverages, and energy drinks. Use of fuels and gas, especially without due caution, may involve a risk of burns or poisoning. We place a strong emphasis on compliance with applicable health and safety standards and on ensuring that consumers are provided with all relevant information.
Potential negative impact on rights to privacy and protection of personal data. This group includes, in particular, participants of the VITAY loyalty programme, users of the vitay.pl ecommerce platform, and users of mobile applications. Potential impacts on consumer privacy may also arise from the operation of video surveillance systems at ORLEN service stations, where personal data such as images or vehicle registration numbers may be processed. Terms and conditions of service and privacy policies are in place for our websites and mobile applications, while promotional campaigns are governed by dedicated rules.
Availability of accurate product or service information in order to avoid potentially harmful ways of using it. Customers using our petroleum-based products, electricity and gas, electric vehicle charging services, non-fuel services, courier services, or ancillary services such as car washes. Consumers are properly informed about the characteristics of our products and services, as well as any hazards associated with their use. Products available at service stations are labelled in accordance with applicable regulations, including fuel marking requirements and allergen information for food products. The communication includes prominently displayed instructions on how to use car washes, refuelling stations and electric vehicle charging stations (also in the application). In the case of courier services, instructions are provided via email, SMS and notifications in the mobile application.
Marketing and sales strategies and health or privacy impacts. Consumers particularly vulnerable to communication practices and marketing strategies, including purchasers of tobacco products, alcoholic beverages, and energy drinks. Such products are sold exclusively to adults who are not under the influence of intoxicating substances. We provide dedicated training for service station staff on responsible sales practices. In addition, point-of-sale systems include mechanisms supporting compliance with these practices.

Double materiality assessment summary for consumers and end-users [S4.IRO-1]

SegmentAreaGeographical regionS4
Risk, opportunity, impact
Impact (I)
Risk (R)
Opportunity (O)
Positive (+)
Negative (-)
Actual (A)
Potential (P)
Value chain
Organisation (O)
Downstream (D)
Upstream (U)
Upstream & Supply,
Downstream,
Consumer & Products
Refining;
Petrochemicals;
Gas;
Retail
Europe + North America + Libya + Pakistan + Middle EastPrivacy of consumers and end-users GDPR-related incidents I-PD
Costs of non-compliance with the General Data Protection Regulation (GDPR) RD
Reputational damage and customer loss resulting from personal data breaches RD
PolandFreedom of expression for consumers and end-users Availability of communication channels and concern-raising mechanisms for consumers and end-users I+AO,D
EuropeAccess to (quality) information Inadequate communication about products and services offered I-PO,D
Penalties for misleading consumers, greenwashing or other actions contrary to applicable lawsRO,D
Security of a person Failure to adequately secure energy requirements I-PO,D
Risk of disruption to continuity of energy supplyRO,D
Protection of children Safety education for children I+AO,D
Access to products and services Broad availability of offered products I+AO,D
Disruptions in access to products and servicesI-PO,D
Building customer loyalty and trust by ensuring access to products and services, including those produced in a sustainable manner OO,D
Loss of revenue due to geopolitical instabilityRO,D
Improving energy security and ensuring just transitionI+P,AO,D
Health and safety of consumers and end-users Penalties for non-compliance with product safety standards RO,D
GlobalResponsible marketing practices Strengthening brand credibility, translating into higher sales and customer loyalty OO,D
short-termmedium-termlong-term
Privacy of consumers and end-usersR
R



Access to (quality) informationR
Access to products and servicesO
R



Health and safety of consumers and end-usersR
Security of a personR

The policies in force at the ORLEN Group in relation to consumers and end-users address material impacts, risks and opportunities identified within this area, including matters related to consumer rights, personal data protection, access to reliable information, product/service safety and quality, responsible marketing practices, as well as the protection of human rights and vulnerable groups, including children. These policies reflect the nature of our interactions with consumers and end-users, serving as a source of consistent standards of conduct applicable across the organisation.

Their applicability extends to all companies forming part of the ORLEN Group and to the Group’s operational activities in its interactions with consumers and end-users, both in Poland and on international markets. These policies apply broadly to all consumers and end-users, though specific solutions may be tailored to particular groups, such as service station customers, customers using electric vehicle charging services, mobile app users, retail customers in e-commerce channels, or electricity end-users. The scope of these policies, standards and procedures covers the Group’s entire operations, from production and distribution to retail sales at service stations and e-commerce platforms, and extends to both upstream and downstream value chain segments. Relevant activities are carried out across various geographic regions, with consideration for the specifics of local markets and impacts on the interests of key stakeholder groups, including suppliers, contractors and local communities.

Responsibility for the establishment and implementation of policies relating to consumers and endusers rests with the Management Boards of the respective Group companies, under the operational oversight of Directors in charge of relevant functional areas. As part of this remit, they must ensure compliance with applicable laws, internal regulations and international standards and guidelines, while maintaining the consistency of approaches across the Group.

The policies have been developed taking into account stakeholder expectations, including those of consumers and end-users, industry organisations and supervisory authorities. Stakeholder interests are incorporated through ongoing dialogue with customers, analysis of customer complaints and issues, consultations, and monitoring of regulatory and market developments.

All consumer- and end-user-related policies are available on the websites of ORLEN S.A. and other Group companies, and through our mobile applications. Instructions for using services offered at our service stations are also readily accessible. For employees and key contractors, the policies are communicated through training, workshops, information sessions, and internal communication channels. Business partners and suppliers are contractually bound to follow specific ethical and operational standards.

The application of the policies is subject to systematic monitoring, which includes analysis of customer complaints and issues, legal compliance assessments, oversight of personal data protection, monitoring of marketing activities, and evaluation of the implemented measures. The monitoring process also involves identification of areas requiring corrective or improvement actions.

ORLEN Group companies pursue certifications to confirm compliance with recognised international standards, which directly contributes to the safety and protection of consumers and end-users. Certifications held by the Group include:

  • ISO 9001 Quality Management System,
  • AQAP 2110 Quality Management System,
  • ISO 45001 OHS Management System,
  • ISO/IEC 27001 Information Security Management System,
  • HACCP Food Safety Management System.

Group companies implement organisational and technical measures to ensure the security of personal data and to enable consumers to exercise their rights. This is supported by the Group Information Protection Policy, governing access to various categories of information, and the Personal Data Security Policy, defining principles for the processing and safeguarding of personal data. In addition, Group companies both contribute to and apply codes of best practice developed by thirdparty organisations such as industry associations, alliances, foundations and other industry or sector bodies, for example the Responsible Business Forum. Our approach to human rights is grounded in internal regulations, national legislation, and internationally recognised standards and guidelines.

These include:

  • Universal Declaration of Human Rights,
  • International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work, based on core ILO conventions,
  • UN Guiding Principles on Business and Human Rights – the ‘Protect, Respect, Remedy’ framework,
  • OECD Guidelines for Multinational Enterprises,
  • International Finance Corporation (IFC) Performance Standards,
  • Ten Principles of the United Nations Global Compact.

We exercise due diligence to ensure that human rights are respected both within our own operations and in our business relationships. The relevant guidance is provided in the ORLEN Group Human Rights Policy, which highlights our commitment to avoiding any actions that could infringe on human rights, whether internally among employees or externally across our value chain. Mechanisms such as contractor and supplier screening systems and whistleblowing procedures have been established to identify and address potential human rights risks. During the reporting period, there were no severe human rights issues or incidents involving consumers or end-users at the ORLEN Group that would constitute breaches of the UN Guiding Principles, ILO standards or OECD Guidelines. The policies described above are linked to impacts on the security of a person and protection of children.

At the ORLEN Group, we allow for remedial measures to be applied and implemented in the event of actual or potential human rights breaches.

Existing policies and procedures related to consumers’ and end-users’ freedom of expression include: the Human Rights Policy, Personal Data Protection Policy, Procedure for Handling Grievances and Complaints, as well as a set of regulations governing our marketing practices and access to services, which define the framework for remedial action and responses to reported concerns. Consumers, end-users and other stakeholders are provided with multiple channels through which they can raise concerns, as described in disclosures S4-2 and S4-3. All submissions are reviewed and verified, with applicable procedures in place to ensure that individuals submitting reports in good faith are protected against retaliation. Where irregularities are identified, we implement appropriate corrective and remedial measures, commensurate with the breach, ranging from operational improvements and adjustments to customer service standards, to measures addressing root causes and preventing recurrence, as described in more detail in disclosure S4-3.

Policies governing the Group’s impact on access to products and services include: the Integrated Management System Policy, covering quality, safety, legal compliance and continuous improvement of processes involved in the provision of products and services, the Energy Policy, defining the framework for ensuring the continuity and security of energy supply and for efficient management of energy resources, the Food Safety Policy, establishing standards for the quality and safety of food products offered to customers, and the ORLEN Group Environmental Protection Policy, addressing environmental impact mitigation and responsible production and distribution.

The ORLEN Group is committed to ensuring that products and services meet all requirements, seeking to continually improve workplace safety, and fulfilling all requirements related to the security of information processed at the ORLEN Group. Responsibility for developing and implementing policies in key areas, such as privacy, freedom of expression, access to information, health and safety, security of a person, protection of children, non-discrimination, access to products and services, responsible marketing practices, and food safety, rests with the respective Management Boards of the Group companies.

As regards responsible marketing practices, we have implemented an anti-greenwashing procedure to mitigate the risk of misleading ESG-related communications. This framework comprises the Responsible Communication Code and the ORLEN Group Environmental Communication Policy, referenced by workforce members for relevant guidelines and best practices. These processes are overseen by a dedicated greenwashing prevention team.

Additionally, at the Group level, the following documents apply:

  • ORLEN Group Code of Ethics (which covers access to products and services by underlining the obligation to ensure high quality and minimise negative impacts),
  • Competition Law Compliance Policy,
  • Organisational Standards for ORLEN Group companies,
  • Hazard Analysis and Critical Control Points (HACCP) Manual (at service stations),
  • Good Hygiene Practice and Good Manufacturing Practice Guidelines (at service stations),
  • Systems and procedures governing product safety and access to food information,
  • Advertising Code of Ethics issued by the Advertising Council.

The policies established by the ORLEN Group in relation to consumers and end-users constitute a coherent governance framework, supporting a consistent and responsible approach to customer relationships across all areas of our activities. Their practical implementation is based on continuous compliance monitoring, analysis of consumer feedback, and ongoing improvement of organisational and operational solutions. These policies allow us to effectively align our activities with the evolving regulatory and market conditions, while maintaining consistent standards for the protection of consumer and end-user rights. As a result, the Group maintains a robust, transparent and accountable framework governing its customer relationships, fully aligned with applicable legal requirements and internationally recognised standards.

Processes for engaging with consumers and end-users about impacts [S4-2]

The ORLEN Group regularly engages with consumers and end-users to obtain feedback and identify customer needs and expectations. This information is then used in our decision-making processes and to enhance our offering.

Customer feedback constitutes a key input to the ORLEN Group’s operations that is systematically incorporated both into our day-to-day service delivery and into longer-term planning across operational, product and marketing areas. Operational responsibility for managing our engagement with consumers and integrating outcomes into the Group’s approach rests with specialised organisational units whose remits are relevant to customer relations. These include, in particular, customer service functions, marketing units, the Retail Network Customer Standards and Relations Department at ORLEN S.A., as well as operational units responsible for product and service quality. Overall operational accountability for ensuring effective engagement with consumers and end-users – and for embedding its outcomes into decision-making – rests with the Executive Director in charge of retail sales and customer service within the Group’s management structure. Strategic oversight is exercised by the Management Board, which considers insights derived from customer dialogue in performance reviews, development plans and broader management processes.

The key tool for understanding customer expectations and perceptions consists in regular market and opinion research, conducted across all our retail markets. It results in a series of reports, such as ‘Consumer Attitudes and Behaviour’, ‘Brand Performance’ and ‘ORLEN Brand Reputation’, which provide both trend-based information on how customer attitudes change over time and assessment of customer perceptions of the Group’s offerings, pricing and communication activities. There is also a standardised consumer research framework (including Usage & Attitude and Brand Performance studies) covering all our retail markets, with findings in the form of reports used to inform key business and marketing decisions.

These insights are complemented by the ‘Voice of Customer’ satisfaction survey programme run within the ORLEN retail network, which measures customer experience using the Net Promoter Score (NPS), along with satisfaction ratings across specific aspects of service station performance. Areas assessed include staff courtesy, service speed, employee competence, and cleanliness of the forecourt, station facilities, and restrooms. The survey is run among participants of the VITAY loyalty programme, with several dozen thousand responses collected monthly, analysed and used to identify areas for improvement.

In parallel, customer feedback is continually analysed following telephone helpline interactions, through satisfaction surveys, and via reviews published online. Where appropriate, direct contact is established with customers to provide support or investigate reported issues. In addition, satisfaction surveys following visits to Customer Service Offices are conducted in cooperation with an external advisory firm. One example of in-depth customer insight analysis was the myORLEN Household Customer Satisfaction Survey carried out in May 2025 to comprehensively evaluate service quality and customer service processes across different touchpoints. The results indicated that 80% of household customers were satisfied with the company’s services, with an NPS of 40 (56% promoters and 16% detractors).

The ORLEN Group actively monitors customer feedback across digital channels, including Google, Google Play, the App Store and social media platforms. Both qualitative feedback (comments) and quantitative indicators (ratings and their distribution across Customer Service Offices) are analysed and reported. Our marketing activities are similarly informed by customer insights, including testing of advertising materials such as television campaigns. The insights gathered are used to optimise our product and service offerings, upgrade and improve the technical condition of service station infrastructure, and enhance customer service standards. Customer feedback also informs updates to our operational procedures and the provision of additional training for service station and customer service staff.

This engagement is conducted both directly and indirectly – through credible consumer representatives. We engage, in particular, with relevant consumer protection authorities, including the Polish Office of Competition and Consumer Protection (UOKiK) and Energy Regulatory Office (URE), which represent consumer interests and provide insight into their situation. Submissions received via these institutions are prioritised within our established customer service processes. In addition, myORLEN engages with organisations representing vulnerable consumer groups, including MIGAM, to ensure service accessibility for individuals with hearing impairments.

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns [S4-3]

Our approach to remediation is guided by internal policies and procedures, such as the Personal Data Protection Policy, or the Procedure for Handling Grievances and Complaints of Retail Network Customers. These frameworks define how we respond to consumer issues and complaints, and how we implement corrective and remedial actions related to operational standards and to product and service quality. In the Call Centre environment, call activity is monitored online, recorded conversations are regularly reviewed, and cases logged in the CRM system are analysed. As part of the formal process we adopted for handling customer issues and requests in the distribution and emergency areas, we regularly assess the quality of responses to concerns raised. Each month, a random sample of submissions is reviewed, with conclusions from their analysis used to improve service quality and, to the extent possible, better align with customer expectations. Quality assurance is also an integral part of the operations at the Telephone Contact Centre, which includes an emergency line (991) and a general customer support line (801 404 404). Random call reviews and weekly operational meetings allow the team to promptly implement corrective measures where necessary.

The practical application of these mechanisms is reflected, for instance, in the customer service model implemented by myORLEN, where customer touchpoints include a network of 128 Customer Service Offices across Poland, a dedicated helpline available Monday to Friday between 7:00 a.m. and 7:00 p.m., as well as the eBOK online platform and mBOK mobile application. These channels are complemented by digital solutions, including BOT support outside helpline operating hours, a chatbot available on the company’s website, as well as traditional mail, email and social media channels.

In the event of potential consumer rights violations, including issues related to freedom of expression, access to information, personal safety, protection of children, non-discrimination, access to products and services, or responsible marketing practices, we ensure that customers have access to a variety of reporting channels, including:

  • online complaint and feedback forms on the websites of ORLEN Group companies,
  • telephone contact,
  • dedicated email addresses,
  • traditional mail sent to company addresses,
  • official social media profiles,
  • in-person reporting of issues and complaints at service stations or Customer Service Offices.

These channels are available to customers to share feedback, report issues, and raise concerns about products, services, or Group companies’ activities. All submissions are reviewed, enabling appropriate investigative or remedial actions to be taken, in line with our commitment to consumer rights and high service standards. Internal regulations applicable across the Group ensure that individuals submitting reports in good faith are protected against retaliation. We also promote the accessibility of relevant mechanisms for raising concerns within our business relationships by requiring partners to comply with the Human Rights Policy and other applicable policies, as described in detail in the S2-1 section.

Delivering high-quality products and services while upholding strong safety standards remains our top priority. In keeping with our focus on transparency, we take proactive steps to prevent industrial accidents, minimise environmental impacts, and protect human life and health. Should a risk arise, appropriate remedial measures are implemented immediately. We also work closely with law enforcement agencies to strengthen security at our service stations, particularly by addressing potential threats and monitoring higher-risk areas.

In cases involving personal data protection breaches reported to the Data Protection Authority, we specify the preventive and remedial measures that have or will be implemented to prevent recurrence. These measures are then evaluated for effectiveness by assessing whether similar issues or legitimate complaints have ceased, or if there has been a decrease in incident rates compared with previous years. Another form of tracking effectiveness is systematic monitoring and proactive ‘stress testing’ of risk areas.

Regular performance assessments help us adjust our activities to reflect the needs of consumers and end-users, respond to global challenges, and meet stakeholder expectations. By maintaining a strong focus on transparency and sustainability, we intend to foster long-term growth and strengthen our position as a responsible market leader.

The effectiveness of channels we have made available for raising concerns, grievances and complaints is assessed based on their actual use, including the volume and nature of submissions received across individual channels, response times, and customer satisfaction metrics. The availability of these channels is communicated to consumers and end-users via websites, mobile applications, Customer Service Offices and helplines.

The ORLEN Group regularly advances initiatives designed to enhance customer service processes with a continuous focus on improving the quality, overall performance and reliability of products and services. Actions taken in relation to consumers and end-users are closely aligned with the material impacts, risks and opportunities (IROs) identified through our double materiality assessment (DMA). These encompass, in particular, risks associated with product/service quality and safety, the availability and continuity of supply, the protection of personal data and privacy, access to transparent information and mechanisms for raising concerns, as well as the safeguarding of vulnerable groups, including children and people with disabilities. Concurrently, these actions allow us to pursue opportunities related to service excellence, digital innovation and the strengthening of long-term consumer trust.

In addressing the identified negative impacts and risks, we apply a structured framework of preventive, mitigating and remedial measures, grounded in established internal policies and procedures, including those that govern the handling of customer complaints, issues and requests, personal data protection and user safety. These measures are intended to minimise the risk of consumer rights infringements, enhance service delivery and ensure full compliance with applicable regulatory requirements. An important focus area is the management of risks associated with customer experience and service quality. They are addressed through systematic monitoring of consumer feedback, analysis of customer satisfaction indicators, including the Net Promoter Score (NPS), evaluation of service performance across the Call Centre channels, and review of feedback sourced from digital platforms. This integrated approach allows us to identify areas for improvement and implement targeted corrective actions, by means of which we also capture the opportunity for reinforcing our positive impacts through enhanced service standards and accessibility.

With respect to risks associated with access to products and services and user safety, including the protection of children, we implement measures to ensure both the safe use of our infrastructure and the continuity of service delivery. These include the deployment of technical and organisational safeguards at service stations, ongoing incident monitoring, and close cooperation with competent authorities and institutions. As regards the protection of children and continuity of energy supply, initiatives undertaken across our Group – particularly within the energy segment – are based on solutions developed and advanced mainly by ENERGA, focused on preventing supply disruptions and mitigating potential adverse consequences for end-users.

Where actual negative impacts occur, remediation processes include the analysis of reported cases, the implementation of corrective actions, timely responses to customers and, where appropriate, the application of adequate remedies. These actions aim to both address the immediate consequences of identified issues and mitigate the risk of recurrence. The mechanisms in place support the achievement of objectives embedded in various policies applicable across the Group, in particular those relating to the protection of consumer rights (including human rights) and service quality. In 2025, there were no serious human rights issues or incidents involving consumers or end-users at the ORLEN Group, as described in more detail in disclosure S4-1.

The effectiveness of our actions, as well as progress in managing material risks and opportunities, are subject to ongoing evaluation based on both qualitative and quantitative data that are available, including trends in the volume and nature of customer submissions, customer satisfaction findings, service quality metrics, and incident recurrence information. Insights derived from this analysis inform continued process improvements and the refinement of our operational practices in subsequent reporting periods.

No significant separate capital or operating expenditure related to consumers and end-users was identified. As a rule, resources allocated to the actions described below are included in spending as part of operating or investing activities of the respective Group companies.

The ORLEN Group further ensures that their own practices, including those related to marketing, sales and personal data processing, do not cause or contribute to material negative impacts on consumers and end-users. This is achieved through the application of transparent data governance principles, oversight of marketing communications, and strict regulatory compliance. While we acknowledge the potential for inherent tensions between our business objectives and the prevention of negative impacts, the pursuit of business performance – including sales growth targets – is not undertaken at the expense of consumer safety or rights. This commitment is reflected in the ORLEN Group’s actions in relation to key areas, including responsible marketing, data privacy, sales practices, customer service and the protection of children, as described below.

Selected actions by area:

As at the reporting date, we had not established any formalised, measurable and time-bound targets relating to consumers and end-users in line with the ESRS MDR-T requirements. Our activities to date have focused on defining strategic directions, standards and operational initiatives in areas pertaining to customer relationships, including the mitigation of material negative impacts, the pursuit of opportunities and the management of consumer-related risks. In the next five years, we plan to set targets consistent with the MDR requirements.

The process of defining key actions in relation to consumers and end-users is informed by an assessment of the performance of customer-facing B2C sales and service channels, the Group’s transformation initiatives, and our new customer-centric Process Architecture. Customer perspectives are incorporated through a review of data from customer service channels, customer satisfaction surveys, as well as work to define the buyer personas and map the buyer journeys.

Our progress against these ambitions is monitored using process quality and efficiency indicators, customer satisfaction metrics (including NPS), the volume of complaints and customer issues submitted, as well as through regular management reviews.

Management Report

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

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