ORLEN Group Workforce [ESRS S1]

Developed by ORLEN S.A., our Code of Ethics sets out clear, practical and up-to-date guidelines defining standards of conduct applicable to all employees, in alignment with the Group’s core values: Responsibility, Progress, People, Energy and Dependability. The Code also articulates our position on the ethical principles and standards governing the Group’s activities, as well as their current scale and strategic direction, expectations towards our business partners, and best practices in business ethics. Overall responsibility for its implementation rests with the ORLEN S.A. Management Board, while operational oversight is exercised by the relevant Directors. The ORLEN Group Code of Ethics is publicly available on the corporate intranet and on our website at: www.orlen.pl.

The Human Rights Policy details the standards for conduct, behaviour, and regulations applicable across the Group that directly or indirectly pertain to the protection of human rights, both within the organisation and in our interactions with external stakeholders. The Policy actions are grounded in internal regulations, national legislation, and internationally recognised standards and guidelines, including: the Universal Declaration of Human Rights, the ILO Declaration, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines, the IFC Performance Standards, and the 10 Principles of the United Nations Global Compact. In matters relating to human rights, forced labour and child labour, our Human Rights Policy clearly affirms the ORLEN Group’s zero-tolerance approach to any form of abuse or violation of human rights and children’s rights. Any potential case of human rights abuse or breach of the highest standards of ethical business conduct, as outlined in the Policy, would be met with our firm response and immediately reported to the competent law enforcement authorities. The provisions of the Policy apply across all Group companies, our entire value chain, and all geographies in which the ORLEN Group operates. Overall responsibility for its implementation rests with the ORLEN S.A. Management Board, while operational oversight is exercised by the relevant Directors. The document is available on the corporate intranet and on our website at: www.orlen.pl.

The principles set out in our Diversity Policy are aimed primarily at enhancing awareness and understanding of the role of diversity, while creating an open and inclusive workplace culture. The Policy actions are also grounded in our internal regulations. Areas covered by the Policy include recruitment, hiring, promotions, protection against unjustified dismissal, prevention of workplace bullying and discrimination, access to training opportunities, and work-life balance. Responsibility for its implementation rests with the Executive Director for HR. The Diversity Policy includes no provisions that would govern the process for monitoring or evaluating its application. The document is available on our corporate intranet.

The Collective Bargaining Agreement is a labour law contract negotiated through bargaining between the employer and trade unions present at the respective company. Serving as an ‘HR constitution’, the document establishes a coherent and incentive-based remuneration and bonus system, sets standards for employer-employee relations, and defines norms fostering an equitable partnership between the employer and trade unions. Individual employers within our Group conclude separate Collective Bargaining Agreements, the provisions of which apply to all employees of the respective company.

The Collective Bargaining Agreement in place at ORLEN S.A. governs a number of areas, including:

• employment, promotions and termination of employment contracts,
• remuneration, bonus schemes and other employment or work-related benefits,
• professional development and training,
• working conditions and mutual obligations of the parties to the employment relationship,
• working time and leave entitlements,
• trade union activity and social dialogue at ORLEN S.A.

At companies that have not concluded Collective Bargaining Agreements, Remuneration Rules are in place, which apply to all workforce members with employment contracts and define remuneration and bonus systems, including the level of pay and its components. The Collective Bargaining Agreements and Remuneration Rules are generally accessible to all employees and trade unions, with responsibility for their implementation resting with the Management Boards of the respective Group companies.

The Work Rules constitute the primary internal framework governing employment conditions and the organisation of work at the ORLEN Group. Alongside principles derived from generally applicable labour laws, in particular the Polish Labour Code, they also contain provisions tailored to the specific nature of our Group’s operations.

The Work Rules cover the following key areas:

• organisation and orderly conduct of work processes,
• working time and its recording for payroll purposes,
• occupational health and safety, including the protection of workers’ health,
• rights and obligations of employees and the employer,
• disciplinary liability and procedures in the event of breaches of employee duties.

The Work Rules apply to all employees of the Group companies covered by their scope. They are implemented by the Management Board of each company working closely with workers’ representatives and trade unions, in accordance with the applicable legal provisions. The document is made available to employees via our corporate intranet or other internal communication channels.

Companies of the ORLEN Group operate structured occupational health and safety (OHS) management systems, developed in accordance with internal policy documents and operational instructions, and fully compliant with the requirements of national legislation. A majority of ORLEN Group companies adhere to the ISO 45001 compliant occupational health and safety management system or, alternatively, they are subject to internal and external audits. These companies have established their own OHS policies covering all operational areas and applying to both employees in their own workforce and to contractor staff.

At the Group level, we have implemented a coherent and comprehensive policy-based approach to occupational safety management. In 2025, updated Organisational Standard No. SO/11/2025 Ed. 2 was introduced covering the ORLEN Group Policy for the Management of Occupational Health and Safety, Fire Safety, Process Safety, and Safety of Storage and Transport of Dangerous Goods. The Standard was approved by the ORLEN Group Council (Resolution No. 13/2025 of 10 December 2025), and entered into force on the same date. The Policy aims to ensure consistent standards of occupational health and safety and process safety across the ORLEN Group, and to enhance intragroup collaboration and effective information sharing related to safety matters. The system tools defined in the Policy include a set of Safety Standards and Technical Standards of the ORLEN Group, as well as the functional strategy for process safety, fire safety and occupational health and safety until 2035. These Standards represent our uniform requirements for work safety, fire safety, process safety, and safety of operations involving the handling of dangerous goods, including best practices identified within the Group companies and standards adopted by leading industry peers. Responsibility for the implementation and application of the Policy rests with the Management Boards of ORLEN Group companies. The document has been made available to workers via our corporate intranet.

Our Well-Being Policy offers key solutions designed to improve the quality of our employees’ lives and their overall well-being across multiple dimensions. Its objective is to define initiatives intended to support employees’ physical and mental health, and to mitigate the adverse effects of stress and discomfort in both professional and personal contexts. Initiatives implemented under the Well-Being Policy are structured across specific dimensions, including wellness, workplace comfort, job satisfaction, work-life balance, and the external environment. Oversight of the implementation and application of the Policy, and of related HR activities, is exercised by the Executive Director for HR. Its provisions apply to employees of ORLEN S.A., with the implementation of solutions developed within ORLEN S.A. extended also to other Group companies. The Policy is available to employees via our corporate intranet.

The programme defines solutions designed to help our employees balance their professional and private lives by offering a range of family-related benefits and support measures (in addition to parental rights provided under the Labour Code and the ORLEN S.A. Work Rules). The programme includes dedicated arrangements for parents of the youngest children (up to three years of age), employees with disabilities, and those providing care to family members. It also addresses matters related to long service jubilees, retirement and birthdays of former employees. Oversight of compliance with the document, which is applicable to all ORLEN S.A. employees, is exercised by the Executive Director for HR. Many of the programme’s components have also been implemented by other Group companies as part of best practice sharing. Information about the document is available on the corporate intranet and on our website at www.orlen.pl. Updates on what has been going on at the Company are also sent to the home addresses of employees on maternity, paternity, parental or childcare leave.

The Rules, based on the Polish Act on Company Social Benefits Funds and the relevant regulation of the Minister of Labour and Social Policy, define eligibility, the purposes for which funds may be allocated, and the criteria for granting benefits. The document applies to employees, former employees and their family members, covering both ORLEN S.A. and other partner entities that are parties to our joint social benefits programme. The provisions of the Rules are agreed with trade unions present at ORLEN S.A. Oversight of compliance is exercised by the Executive Director for HR, while Directors reporting to this role are responsible for supervision within their respective areas. The Rules are available on our intranet and have also been distributed to partner entities participating in the joint social benefits programme with ORLEN S.A.

This programme defines the standards of conduct, daily behaviours and attitudes expected of all employees, to be practised both within and outside the organisation. Its purpose is to establish the rules and procedures for awarding the ‘Distinguished ORLEN Employee’ title in alignment with our core values:

• Responsibility,
• Progress,
• People,
• Energy, and
• Dependability.

‘Distinguished ORLEN Employee’ is a long-established honorary title conferred by the President of the Management Board in recognition of outstanding professional, social, and ethical contributions aligned with the ORLEN Group’s values. It is the highest and most prestigious distinction at the Company, awarded every year to employees within three categories: for lifetime outstanding service, exceptional professional achievements and socially responsible attitudes. The programme applies to all ORLEN S.A. employees, with oversight of compliance exercised by the Executive Director for HR. The document has been consulted with the relevant functions and trade unions active at ORLEN S.A. It is available on our corporate intranet.

Within the ORLEN Group, the Whistleblower Protection Policy is grounded in applicable legislation, in particular the Polish Act on the Protection of Whistleblowers of 14 June 2024 (Dz.U. of 2024, item 928), which constitutes the transposition of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law (OJ L 305, 26.11.2019). The purpose of the Policy is to ensure consistent standards across our Group companies for the protection of individuals reporting breaches of law, internal regulations, or ethical standards. It defines the requirements, responsibilities, and procedures for the receipt and handling of whistleblower reports in a manner that guarantees security, confidentiality, and impartiality.

Topics addressed by the Policy include:

• prevention of legal and regulatory breaches,
• protection of individuals reporting violations of law or internal regulations,
• compliance with applicable whistleblower protection legislation,
• assurance that all reports are handled with due diligence and that whistleblowers are protected against any form of retaliation.

The Whistleblower Protection Policy has been implemented at ORLEN Group companies required to establish such internal frameworks under the applicable legislation. It applies to all workforce members and extends across our entire value chain. Its implementation within individual Group companies reflects local legal requirements in their home jurisdictions, as well as the specific nature of their operations, branches or representative offices. 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.

The Policy is aligned with:

• the United Nations Guiding Principles on Business and Human Rights,
• the OECD Guidelines for Multinational Enterprises,
• the International Bill of Human Rights.

The scope of reportable breaches defined in the Whistleblower Protection Policy includes constitutional freedoms as well as human and civil rights. The Policy is made available to all employees via our corporate intranet and communicated to workforce members without intranet access by their respective line managers. The Group’s trade partners are introduced to the Policy prior to entering into business relationships, while other external stakeholders can access it via www.orlen.pl. The ORLEN S.A. Economic Security Office maintains a register and archive of reported cases, with access restricted to authorised personnel only, reflecting the confidentiality of these records.

The Policy establishes a framework for identifying, developing and effectively deploying the potential and skills of people in our workforce, supporting the Group’s long-term capacity to deliver on its business and sustainability strategies. The Policy applies to the Group’s own workforce, forming an integral part of its human capital management system. Its objectives are to foster the professional development of employees, ensure equal access to development opportunities, and build a succession pipeline for key competencies across the Group. The ORLEN Group Human Resources Management Policy is grounded in the principles of respect for human rights, equal treatment, nondiscrimination, and social dialogue, in line with our core values and applicable requirements of the labour law. It applies at the Group level, with due account taken of local legal and organisational conditions relevant to individual companies. Responsibility for its implementation at ORLEN S.A. rests with the Executive Director for HR. The document can be accessed via our corporate intranet.

This framework is designed to ensure the protection of individuals, including people in our workforce, in connection with the processing of their personal data, in compliance with applicable legal requirements, in particular the General Data Protection Regulation (GDPR) and national legislation governing that area. It defines the principles of lawful, secure, and accountable personal data processing, the roles and responsibilities of personnel involved in the processing activities, as well as mechanisms for risk management, incident response, and the exercise of data subjects’ rights. These provisions apply to all employees of ORLEN S.A., irrespective of the geographical location where they are based, as well as individual contractors rendering their services to the Company. Companies of the ORLEN Group may adopt a harmonised personal data protection standard, aligned with the framework implemented at ORLEN S.A. The framework covers all personal data processing activities carried out by ORLEN S.A., both in its capacity as data controller and data processor. It also extends to our relationships with external parties, including contractors and suppliers, by governing data processing agreements, data sharing, and audits of processors. Accordingly, the framework addresses relevant elements of our value chain wherever personal data processing occurs. Ultimate responsibility for the implementation of the personal data protection framework at ORLEN S.A. rests with the Management Board.

While the framework does not explicitly reference the UN Guiding Principles on Business and Human Rights, the ILO Declaration, or the OECD Guidelines for Multinational Enterprises, its underlying principles of privacy protection, respect for individual rights, accountability, data minimisation, and risk management are consistent with internationally recognised standards on human rights and responsible business conduct. The framework does not contain explicit provisions addressing human trafficking, forced or compulsory labour, and child labour. The documentation is made available to employees and other authorised persons via our corporate intranet and at www.orlen.pl. It provides for mechanisms to monitor and evaluate compliance with personal data protection rules. Compliance with the data processing requirements, as well as the effectiveness of technical and organisational measures we have put in place, are monitored on a day-to-day basis by process owners, and through periodic audits and inspections conducted by the Data Protection Officer or the Data Protection Team.

Work in production environments involves exposure to factors that may affect the health and safety of workers. Key workplace conditions include exposure to noise, vibration, chemical and electrical hazards, dust, extremely high or low temperatures, shift work, and the operation of machinery and equipment. This calls for continuous monitoring of the working environment and identification of specific workplace hazards as an essential precaution. To mitigate negative impacts associated with working conditions in production areas, we have implemented a comprehensive set of preventive and organisational measures, including in particular:

• provision and use of appropriate personal protective equipment (PPE), such as protective clothing and footwear, as well as hearing, respiratory and eye protection devices, in accordance with the defined allocation standards,
• organisation and delivery of occupational health and safety training (at induction and periodically thereafter), supplemented by specialised training in first aid, safe work practices and similar topics,
• implementation of technical and organisational controls to reduce workers’ exposure to hazardous factors, including the modernisation of technical facilities, process automation, and improvements in workplace ergonomics,
• provision of prophylactic meals and beverages in conditions involving increased physical exertion, strain or adverse microclimate,
• operation of OHS Committees and the Social Labour Inspectorate, which support oversight of working conditions and initiate safety improvement measures,
• ongoing consultation with workers’ representatives and trade unions on occupational risk assessments, the organisation of work, and proposed changes affecting workplace safety.

Where an occupational accident occurs, the accident investigation report sets out conclusions and preventive recommendations to be implemented by the employer’s representative (typically the injured employee’s direct supervisor), to help prevent similar incidents in the future. This helps improve safety both for the injured employee and for others working in the area. Depending on the circumstances of the case, employees who have suffered a workplace accident, an accident while commuting to or from work, or an occupational disease, may also apply for additional financial assistance in the form of a hardship grant. In justified cases, further support may be provided by the ORLEN Group’s foundations under their programmes, in line with their constitutive documents and internal rules. We also give employees the option to join additional medical care schemes, providing access to a broad range of healthcare services, including specialist consultations.

Given the specific characteristics of our industry, marked by a high proportion of technical roles and elevated operational risk, it is particularly important to ensure equal treatment of workers, including gender equality and equal pay for work of equal value. At the ORLEN Group, we conduct regular analyses of remuneration structures by gender, job position, organisational unit, and grading level. These analyses are intended to identify potential pay gaps, eliminate unjustified disparities, and enhance the transparency of remuneration policies. In 2024, the gender pay gap was calculated exclusively for ORLEN S.A., and stood at -0.62%. In 2025, the gap calculated based on 78% of the Group’s employees was -3%.

We apply a systematic, multi-level approach to preventing violence and harassment in the workplace, including policies, procedures, training, safe reporting channels and ethical oversight. In 2025, ORLEN S.A. introduced mandatory training for all employees on preventing workplace bullying, discrimination and all forms of harassment, and all Group companies have six months to implement this requirement. At the same time, specialised training is being provided for managers on identifying and preventing workplace bullying, discrimination and harassment, alongside webinars on inclusive language. Ethics Officers are appointed each year in further Group companies. In 2025, the ORLEN Group provided remedies to affected employees in the form of professional psychological support (including consultations and psychologist on-call hours at the Psychological Assessment and Support Unit), with full confidentiality and anonymity ensured. Employees also had access to additional medical care, under which they could receive mental health support. A total of 350 psychological support sessions, amounting to 696 hours, were delivered for ORLEN S.A. employees, their immediate family members and employees of Group companies.

We provide employees with a broad range of social protection arrangements, encompassing solutions implemented in line with applicable laws or based on rules adopted at company level, e.g. under collective labour agreements or company social benefit funds. These include medical care, such as subscription-based healthcare, social benefits such as co-financing of holidays for employees and their family members, hardship assistance for employees facing difficult personal, family or financial circumstances, housing loans, and benefits for retirees and pensioners, such as subsidies for holidays or health resort stays.

Flexible working arrangements have been implemented across the Group, including home office (on a fully remote or hybrid basis), in line with the Labour Code and as agreed with trade unions. Thanks to these flexible work models, our employees are better able to balance their working time around private and family life. These arrangements support work-life integration, enhancing employee satisfaction, engagement, and overall productivity.

We actively monitor pay trends prevailing on the market and benchmark them against internal compensation practices. Where justified, we optimise our practices, e.g. by amending the Collective Bargaining Agreements or internal Remuneration Rules, or propose targeted salary increases for critical talent. There are a number of trade unions at the Group, ensuring that appropriate compensation standards are maintained. Furthermore, annual pay consultations are held with employee representatives under the framework of Collective Bargaining Agreements.

At the ORLEN Group, social dialogue with our employees is an ongoing process, maintained through trade unions and other communication channels. The Collective Bargaining Agreements formally define the circumstances, frequency, and forms of mandatory engagement with employees. The positive impact of social dialogue within our Group is reinforced through systematic engagement mechanisms that allow workforce members to meaningfully participate in shaping the working conditions and organisational decisions.

The ORLEN Group hosts a number of trade unions actively involved in its operations and governance processes.

A key factor reinforcing the positive impact of collective bargaining within the ORLEN Group is its grounding in a clear and well-established legal framework, encompassing the Constitution of the Republic of Poland, the Labour Code and the Act on Trade Unions. This ensures the predictability, transparency, and partnership-based approach to negotiations between the employer and trade unions. As a result, it fosters trust between the parties, reduces the risk of labour disputes, and supports stable employer–employee relations.

At the Group, we offer a robust package of non-pay benefits, including social assistance in the form of subsidies towards holidays or health resort treatments, leisure activities for children and young people, rehabilitation stays for children with disabilities, or in-patient rehabilitation for employees. The Group’s employees are also provided with access to medical care and life insurance.

ORLEN Group employees are offered regular, mandatory training programmes, covering areas such as personal data protection, information security, occupational health and safety and the Code of Ethics, which supports a safe and responsible working environment. In addition, we offer a broad portfolio of development training opportunities, covering technical capabilities, systems, and language skills, aimed at enhancing our employees’ professional competencies. Tailored training programmes are also delivered to selected groups of workers, depending on identified needs.

We actively promote diversity and inclusion across the ORLEN Group’s operations. Dedicated policies are in place, alongside initiatives such as the Diversity Charter and Diversity IN Check. As part of our commitment to diversity management, at ORLEN S.A. we carry out initiatives dedicated to the empowerment and inclusion of neurodivergent individuals and persons with disabilities. Our longstanding Accessible ORLEN programme is designed to foster a diverse, bias-free working environment. Within this initiative, an in-house support desk has been established, offering free advice on disability-related matters to our workforce members. The programme also features communication and education initiatives to raise awareness and understanding of disability inclusion. A dedicated email channel has been made available to workers, providing space to submit suggestions, raise questions, or propose initiatives related to disability issues.

In response to this risk, the ORLEN Group has implemented a range of concrete and systemic mitigation measures. These include:

• Group-wide personal and process safety management system – a comprehensive framework covering occupational health and safety, fire safety, process safety, and the safe storage and transport of dangerous goods. Its purpose is to ensure consistent OHS and process safety standards across all Group companies, thereby reducing the risk of costs associated with regulatory breaches;
• introduction and application of the Group-wide safety framework, comprising the ORLEN Group Safety Standards and ORLEN Group Technical Standards. These standards harmonise OHS requirements across the Group, drawing on best practices identified within our companies as well as solutions adopted by leading industry peers. Their application reduces our exposure to financial penalties, claims, and operational disruptions resulting from regulatory non-compliance;
• regular OHS training supported by ongoing awareness-raising, information campaigns, and educational initiatives promoting safe behaviours among workers. These measures form an integral part of our risk management approach;
• monitoring of safety performance metrics and KPIs – the ORLEN Group keeps track of key performance indicators related to workplace incidents involving both our employees and contractors, with the data used to assess the effectiveness of OHS initiatives and to identify emerging risk areas at an early stage, before they translate into adverse financial or legal consequences;
• root cause analysis of accidents and near-miss events – ORLEN Group companies conduct detailed investigations into all workplace incidents, supported by a standardised Group-wide methodology, which informs the implementation of targeted preventive measures;
• long-term OHS planning at the Group level – overall strategic priorities are defined across the ORLEN Group, aligned with the ORLEN Group Sustainable Development Strategy for 2025–2035.

Through this strategic approach, the risk of costs that could arise from non-compliance with OHS regulations is systematically managed rather than addressed on an ad hoc basis.

To mitigate this risk, ORLEN S.A. has implemented a comprehensive set of measures aimed at strengthening the security and governance of personal data processing. Key ones include the identification and assessment of risks involved in data processing activities, including the performance of risk assessments and data protection impact assessments (DPIAs). Appropriate technical and organisational safeguards are put in place to mitigate the identified risks, subject to regular monitoring, audits, and inspections. We also provide training on personal data protection and ensure continuous oversight by the Data Protection Officer and Data Protection Team. In addition, we have established procedures for managing data security incidents and breaches, defined data retention rules and put in place mechanisms ensuring the effective exercise of data subjects’ rights. Collectively, these measures are designed to reduce the risk of breaches affecting the confidentiality, integrity, and availability of personal data.

Since 2011, ORLEN S.A. has consistently held the Top Employer Poland title. The Top Employers certification programme is an annual, globally recognised assessment that rigorously evaluates companies and their human resources management practices. Employers are certified by the Top Employers Institute experts based on the HR Best Practices Survey scrutinising their people practices. The questionnaire covers 20 areas, including people strategy, work environment, talent acquisition, training and learning, well-being, diversity and inclusion. Based on a globally standardised methodology, the certification delivers an objective assessment that supports organisations in systematically raising the bar on their HR practices. Our HR activities are focused on employment stability and long-term career progression, which constitute key drivers of our competitive advantage in the labour market, particularly in a volatile economic environment. We also ensure high standards of occupational safety and run systematic surveys to gauge employee satisfaction levels. Our consistent employer branding efforts support the effective attraction and retention of talent, further reinforcing the Group’s competitive edge in the labour market.

We apply adequate, market-aligned remuneration processes and procedures, complemented by a competitive portfolio of non-pay benefits. These measures are designed to drive workforce motivation while reinforcing the Group’s positioning as a stable and attractive employer.

At the ORLEN Group, we systematically pursue initiatives aimed at fostering a workplace environment characterised by trust, psychological comfort and transparent employer–employee relations, which represents a material opportunity to enhance productivity and operational efficiency. These include the monitoring of employee engagement and satisfaction levels, provision of flexible working arrangements, and deployment of policies supporting employee well-being, further reinforced by transparent and formalised employment frameworks, including the Collective Bargaining Agreements, structured social dialogue, and initiatives revolving around ethical conduct, anti-discrimination, and diversity management. In parallel, continuous improvements to our HR and operational processes help strengthen the sense of security, partnership and employment stability in our workforce, translating into enhanced organisational effectiveness and overall Group performance.

We offer training opportunities and deploy a range of learning mechanisms and tools to continually raise employee competencies. The focus areas are upskilling, fostering professional specialisation, and aligning workforce capabilities with technological advances and evolving market requirements. The initiatives we implement include continuous expansion of our development training and mentoring programmes, combined with the application of mechanisms intended to support career progression, including transparent professional development and promotion criteria. These are designed to strengthen specialist skills, enhance individual and organisational performance, and optimise the utilisation of human capital in delivering the Group’s strategic objectives.

The effectiveness of these actions during the reporting period was assessed through:

• 15 preventive visits carried out at various ORLEN Group companies in the fourth quarter of 2025, following the launch of the new M1T2 Preventive Visits standard. The visits resulted in 207 recommendations, with progress on their implementation tracked in the recommendations register;
• Safety Culture Indicator, introduced as an additional performance metric to help identify improvement opportunities in safety management;
• safety incident classification procedure developed to further enhance safety performance metrics;
• regular preventive meetings – four meetings were held in 2025 with 54 participants;
• training on preventing workplace bullying, discrimination and harassment, the Code of Ethics and human rights protection, delivered in 43 Group companies;
• employee satisfaction surveys carried out at 20 Group companies.

The effectiveness of these actions, including efforts to advance positive impacts, is reflected in the Top Employer title, which ORLEN has received continuously for the past 15 years.

When reporting positive outcomes of initiatives addressed to our own workforce, we focus primarily on the scope and scale of the measures undertaken. At this stage, no distinction is made between evidence that specific actions have been implemented from evidence of actual outcomes for the people concerned, as measuring direct, long-term outcomes for employees, such as changes in behaviour, skills or financial situation, requires separate research tools, time and methods based on self-assessment, which have not yet been implemented across the Group.

We did not identify any instances where our own practices, including those related to procurement, sales and data use, had caused or contributed to material negative impacts on our own workforce. During the reporting period, we identified no material operating expenditures or capital expenditures related to own workforce.

The 2025 gender pay gap for the ORLEN Group stood at -3%, which means that women’s pay was higher than men’s pay. This disparity falls within the range defined in the Pay Transparency and Equal Pay Directive, namely ±5%. The ORLEN Group’s gender pay gap is calculated using a benchmarking tool, employed both for market pay analysis and for consolidating data from different companies in order to calculate the pay gap. The gender pay gap was calculated as the difference between the average remuneration of men and women, divided by the average remuneration of men, and expressed as a percentage. The same methodology was applied in 2024 and 2025. The pay gap calculated for 2024 covered only employees of ORLEN S.A., whereas in 2025 it was based on data covering approximately 78% of the ORLEN Group’s workforce.

The calculation of the annual total remuneration ratio, comparing the remuneration of the highest-paid individual to the median of total annual remuneration of all other employees (excluding the highestpaid individual), for the entire ORLEN Group presents significant data collection challenges, stemming from the size and complexity of the Group, the number of employees across multiple entities, and, most importantly, the absence of a unified HR and payroll system.

The calculation covers all ORLEN Group subsidiaries operating across diverse geographic and business markets.

Accordingly, the metric for 2025 has been calculated using the methodology described below.

Annual total remuneration was determined on the basis of cost categories reported in the uniform financial consolidation system used across all ORLEN Group companies. At each company, it was calculated as the total cash remuneration paid to an employee during the reporting year, taking into account base salary, including sick pay, annual MBO bonuses, quarterly and monthly bonuses, other bonuses together with Christmas/Easter benefits, retirement and disability severance payments, shift allowances, long-service awards, one-off and special-purpose awards, the annual award, overtime pay and other payroll-related costs.

The calculation included cash components of remuneration paid for the reporting year, including amounts paid in January of the following year but relating to December of the reporting year. The only exception was MBO bonuses and the annual award. For the 2025 calculation, the amounts paid in 2025 were included, corresponding to bonuses for 2024, due to the payment timetable for these benefits (payments in June and July of the following year).

Items related to employee departures, such as severance payments on termination of employment and compensation under non-compete clauses, were excluded, as they concerned individual cases and could distort the comparability of the data.

Annual remuneration was calculated only for employees employed under employment contracts, regardless of how long they had been employed during the reporting year. For those who did not work for the full year, remuneration was annualised by dividing remuneration for the period worked by the number of months worked and multiplying the result by 12. This annualised amount was increased, where applicable, by the amounts actually paid in the form of benefits such as payment in lieu of untaken holiday, retirement or disability severance payments, and long-service awards.

For part-time employees, remuneration was converted to a full-time equivalent, including Christmas/ Easter benefits.

Given the global scale of our operations and the diversity of HR and payroll systems across jurisdictions, a consolidated weighted median approach has been applied:

• all total remuneration values (both the highest pay and the median for individual companies/subgroups) have been converted into the ORLEN Group’s reporting currency (PLN),
• the highest pay at the ORLEN Group has been taken as the total remuneration of the highest-paid individual identified in section 8.3. Remuneration of management and supervisory staff,
• given no access to individual-level payroll data (per capita raw data), a weighted median methodology based on employment levels has been applied. Median remuneration values for individual companies or sub-groups have been ordered in ascending sequence and assigned weights corresponding to the number of employees at each entity. The ORLEN Group median has been determined as the value corresponding to the median employee within this aggregated and weighted dataset.

The adopted methodology, based on the weighted median of entity-level medians, is recognised as the most reliable estimation approach for large corporate groups in the absence of a centralised payroll system. It eliminates statistical distortion that would otherwise arise from assigning equal weights to smaller advisory entities and large operational units. We note that the calculated median represents an estimate. The actual median, calculated on the basis of individual data for all employees, could differ marginally in the presence of extreme distributional asymmetries within subsidiaries. Nevertheless, the adopted methodology provides a high degree of confidence as to the order of magnitude of the reported metric. Based on the methodology described above, the annual total remuneration ratio of the highest-paid individual to the median annual total remuneration for all employees (excluding the highest-paid individual) is 20.90.

The measurement of these metrics has not been validated by an external body.