Workers in the Value Chain [ESRS S2]

Interests and views of stakeholders [S2.SBM-2]

The interests and views of stakeholders significantly influence the ORLEN Group’s strategy and business model. Our activities reflect a strong commitment to sustainable development and respect for human rights throughout our supply chain.

Based on the double materiality assessment, we identified material impacts on workers in our value chain. One of the key areas addressed in our Sustainability Strategy is ensuring contractor safety, in line with the safety standards applied to our own workforce. For details, see disclosure S1.

Consideration for the interests, views and rights of value chain workers is reflected in our Procurement Policy and the ORLEN Group Supplier Code of Conduct, with the latter serving as a key instrument in our collaboration with suppliers. The Code provides that suppliers are required to manage their workers and workplaces responsibly, which includes supporting skills development, ensuring workplace safety, and providing employees and contractors with a safe and fair working environment.

The ORLEN Group Supplier Code of Conduct also includes commitments relating to human rights, labour rights, environmental matters, and occupational health and safety. Our Anti-Corruption Policy, which suppliers are also required to accept when entering a procurement procedure, provides a mechanism for reporting any actions contrary to applicable laws. Matters concerning value chain workers are also governed by the terms of business relationships with suppliers, as set out in the contracts.

Material impacts, risks and opportunities and their interaction with strategy and business model [S2.SBM-3]

Our business model is based on integrated operations across the entire value chain, including in particular:

• production and sourcing of raw materials,
• processing and production (refining, petrochemicals and power generation),
• logistics and distribution,
• wholesale and retail sales,
• extensive cooperation with contractors, suppliers and third parties.

This structure means that a significant part of our activities are carried out by individuals who are not part of our own workforce but work within the upstream and downstream segments of our value chain, often in environments involving increased operational risk.

Workers in our value chain are mainly individuals employed by our contractors and subcontractors, who perform work for the ORLEN Group but are not its own employees. They include in particular:

• employees of third-party companies carrying out technical, maintenance, construction and service work,
• individuals performing operational and logistics tasks at the ORLEN Group’s process units and facilities,
• employees of companies providing transport, storage, support, and plant maintenance services,
• employees of third-party operated service stations,
• workers working in the operations of a joint venture or special purpose vehicles.

All workers in our value chain may potentially be exposed to negative impacts, which may be systemic (arising from the geographical location in which operations are conducted) or one-off in nature (resulting from specific incidents, such as loss of reputation by a supplier). Systemic impacts may occur in countries with the highest social risk where we identify value chain workers: Algeria, Saudi Arabia, Azerbaijan, Guyana, Kazakhstan, Nigeria, Norway, Poland, Russia, the United States and the United Kingdom. Supplies from Russia, exclusively via pipelines and not subject to international sanctions, continued in the first quarter of 2025.

We operate in an extensive multinational value chain. As part of a Group-level assessment of social impacts and risks relating to workers in the value chain, we identified no distinct groups of people with particular characteristics or facing greater risk of harm. No additional analyses have been undertaken in this area.

As a general principle, all workers in the value chain are subject to the same rules as the ORLEN Group’s own workforce. Under the Supplier Code, all suppliers are required to ensure that value chain workers are treated in accordance with the guidance on working conditions, occupational health and safety, and human rights.

This disclosure does not cover all workers in our value chain who were engaged in active cooperation with the ORLEN Group during the reporting period. Given the scale of our operations, it is not currently possible to verify the entire value chain, which encompasses a wide range of occupations, including service station staff, tanker and LNG carrier crews, gas and electricity meter readers, cleaning personnel, IT professionals, lawyers, advisers. Some workers in our value chain are based in countries with elevated risk, which creates potential exposure related to non-compliance with labour or environmental requirements.

Our value chain is global in nature, and our suppliers are based in various regions of the world, including Europe, the Middle East, Asia, North America and South America. There is a risk that in some of these regions workers’ rights may not be respected. In the current reporting period, we did not identify any material impacts in our value chain associated with a significant risk of child labour or forced or compulsory labour.

Suppliers, subcontractors and business partners are one of our key stakeholder groups and the most relevant group in the context of value chain worker considerations. As part of the double materiality assessment, the interests of this stakeholder group are taken into account in the assessment of impacts, risks and opportunities. The results of the double materiality assessment are reflected in our sustainability strategy.

The double materiality assessment identified negative impacts and risks relating to workers in our value chain. The risks are systemic in nature and relate primarily to safe working conditions. They arise from operating in high-risk countries and concern potential breaches of workers’ rights, as well as potential costs associated with non-compliance with occupational health and safety requirements. The negative impacts result from the fact that suppliers may only declare compliance with regulations with respect to workers in the value chain, without this being verified in practice, while we do not monitor their compliance in areas such as working time, adequate pay, social dialogue or occupational health and safety. At present, we do not conduct direct opinion surveys among workers in the value chain. We plan to implement engagement practices as part of the rollout of due diligence within five years.

The identified potential positive impacts include raising suppliers’ sustainability awareness through training and consultations, as well as improving occupational health and safety knowledge among workers in our value chain. We are preparing to launch a series of conferences for suppliers, including a sustainability information panel.

Double materiality assessment summary for workers in the value chain [S2.IRO-1]

Policies related to value chain workers [S2-1]

The policies related to value chain workers described below reflect our commitment to respecting human rights and adhering to the key international standards and agreements in this area.

Key ORLEN Group policies for managing material impacts on workers in the value chain

Processes for engaging with value chain workers about impacts [S2-2]

We do not have a policy specifically addressing the ORLEN Group’s engagement with workers in the value chain; however, we have defined rules for cooperating with suppliers. At present, this is the most relevant aspect of our engagement with workers in our value chain. Given the broad geographic spread of our sourcing activities and the wide range of goods and services we purchase, cooperation with suppliers is managed through a diversified framework involving different organisational units and different systems. Each company verifies its suppliers independently, in line with separate guidelines, and engages with value chain workers. Companies that have implemented our Organisational Standard for procurement manage these processes in accordance with central guidelines for supplier assessment and verification. In 2025, we launched a project to establish a centralised counterparty risk management function. The Counterparty Risk Management Office is currently being set up. It will be responsible for obtaining counterparty information required by the ORLEN Group, and keeping that information up to date in dedicated corporate systems. Plans also include the development of a dedicated IT system to manage a central counterparty database and to automate the verification process to the greatest extent possible. The Head of the Counterparty Risk Management Office will have operational responsibility for verifying cooperation and monitoring results.

Currently, we apply the following formal requirements in our cooperation with suppliers and business partners:

• acceptance of the Supplier Code of Conduct,
• acknowledgement of receipt and review of the Human Rights Policy,
• acknowledgment of receipt and review of the anti-corruption rules,
• inclusion of anti-corruption and sanction clauses in contracts,
• work rules for contractors / work safety requirements.

Processes to remediate negative impacts and channels for value chain workers to raise concerns [S2-3]

Our Human Rights Policy outlines the procedures for anonymous and voluntary reporting of violations and cases of misconduct. We guarantee the confidentiality and safety for individuals reporting concerns and are committed to ensuring effective remediation and appropriate corrective measures.

Channels to raise concerns

• Occupational safety hazard reporting systems operating in selected companies
• Ethics Officer
• Local Community Relations Officer
• A whistleblowing channel through which anyone acting in good faith may anonymously report violations of law by email at naruszenieprawa@orlen.pl or by telephone; Reports are handled by the Control and Security Office.

These channels are generally accessible, and information about them, together with guidance on how to submit reports, is published on the ORLEN website.

Since 2024, we have had in place a Whistleblower Protection Policy, covering reports of irregularities made in a work-related context, as well as the ORLEN S.A. Internal Whistleblowing Rules, which apply to the Group’s own workforce and to workers in our value chain and ensure a safe and secure environment for reporting concerns. For details, see disclosure G1.

Investigations in cases involving workers in the value chain are carried out using the same mechanisms as those applied in cases concerning the Group’s own employees; for details, see disclosure S1-3. The receipt and handling of reports concerning violations of law and internal regulations are governed by the ORLEN S.A. Internal Whistleblowing Rules, which ensure that cases are handled confidentially and with due respect for privacy and data protection rights. We are also developing a process for contractor verification and sustainability risk assessment covering environmental, social and governance matters. The aim of this process is to identify potential and actual indications of irregularities in the area of sustainability. Identifying such indications will help us define the appropriate course of further engagement with the contractor as part of the due diligence process, with a view to minimising risks and reinforcing good practices.

All supplier commitments relating to the rights of workers in the value chain are accepted by suppliers at the outset of the business relationship.

We are currently carrying out a project to introduce measures to manage material risks and pursue material opportunities related to workers in the value chain. The project is expected to be completed within five years. It is also intended to provide for remedy measures to be applied in the event of negative impacts on workers in the value chain, put in place channels for raising concerns, and establish ways of tracking and monitoring reported issues.

Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions [S2-4]

We seek to advance our positive impacts and currently we are taking steps to determine the optimal form of engagement with suppliers to improve working conditions for value chain workers. We have implemented a range of mechanisms to foster positive impacts on workers in our value chain, including:

• Appointment of the Ethics Officer;
• Register of Qualified Contractors: A tool used by the Energa Group to assess and select contractors meeting established standards;
• Anti-corruption clauses: Clauses included in business contracts to safeguard against corruption and conflicts of interest;
• Occupational health and safety: Requirement for contractors to comply with all relevant OHS regulations and procedures; Safety Points for ORLEN Service Stations, representing the fundamental rules required to be observed on the premises our of CODO service stations; contractual clauses Ensuring compliance with working time regulations, OHS standards, and the necessary training and certification requirements for workers.
• Training for personnel working at service stations and fuel terminals, training for road tanker drivers, and training provided through the ORLEN S.A. Training Centre, including detailed verification of both theoretical and practical knowledge in areas such as occupational health and safety, mechanics, electrical systems, and local hazards present at ORLEN production sites.
• Opportunity to participate in the ORLEN Group’s annual Occupational Safety and Health Protection Days.
• Mechanisms for reporting occupational safety hazards by employees of third-party companies.

We monitor the outcomes of these activities. For the results, see the table on the effectiveness of the occupational health and safety management system at the ORLEN Group in disclosure S1-14.

As part of our business model, we adhere to responsible sourcing practices, with our suppliers required to comply with the Supplier Code of Conduct and the ORLEN Group Code of Ethics. Suppliers are evaluated for compliance with these Codes and policies, including in the area of sustainability. In the coming years, we plan to carry out enhanced audits as part of the due diligence process, and to continually refine and adapt our operational and procurement procedures by identifying risks associated with workers in our value chain. This will lead to the implementation of more robust supplier selection and qualification procedures. The integration of ESG considerations into procurement processes will influence our operational strategy and support the achievement of the United Nations Sustainable Development Goals (SDGs).

The material impacts and risks relating to workers in the value chain identified through the double materiality assessment will be subject to further analysis, and we will make every effort to develop and implement an appropriate management approach. We are currently carrying out a long-term project to introduce measures to manage material risks and pursue material opportunities related to workers in the value chain. The project is expected to be completed within five years.

As part of our structured system for managing the safety of contractors performing work on premises owned or leased by ORLEN Group companies:

• we monitor accident rates for employees of third-party companies working on sites owned or leased by the ORLEN Group, and these statistics are included in the ORLEN Group’s occupational safety KPIs;
• we conduct inspections and audits to verify work safety and contractors’ preparation for the work to be performed, including inspections and audits required under our Technical Standard: Classification and Supervision of Safety of Third-Party Companies Operating on the ORLEN Group’s Sites or Providing Services to ORLEN Group Companies.
• we organise work safety workshops and webinars for employees of third-party companies;
• we hold inspections in the form of management Safety Walks on ORLEN Group sites, which also cover activities of third-party contractors; In addition, periodic inspections are performed by OHS services to verify work safety and third-party employees’ preparation for the work to be performed.

We monitor the outcomes of these activities. For the results, see the table on the effectiveness of the occupational health and safety management system at the ORLEN Group in disclosure S1-14.

We are currently implementing a supply chain due diligence system, in line with the requirements of the Corporate Sustainability Due Diligence Directive (CSDDD).

Furthermore, work is underway to introduce new procedures for centralised supplier verification, which will also address ways to minimise negative impacts on individuals associated with our value chain.

During the reporting period, we identified no material operating expenditures or capital expenditures related to value chain workers.

Internal functions involved in managing value chain worker-related matters

Effectively managing positive and negative impacts on workers in our value chain requires the active involvement of multiple organisational units across the ORLEN Group. Each unit plays a vital role in identifying, assessing, and managing risks, while also helping to drive initiatives that support sustainability goals. The Procurement area, responsible for implementing the ORLEN Group strategy for a sustainable value chain, oversees supplier relationships. It plays a critical role in contract negotiations and monitoring supplier standards. We plan to develop relevant standards, processes, and initiatives to be rolled out across ORLEN Group companies under the segment-based management model.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities [S2-5]

We have not set any measurable targets related to value chain workers. We plan to define measurable, outcome-oriented targets related to workers in the value chain within five years.

One of our goals under the Sustainable Development Strategy for 2025–2035 is to maintain the Total Recordable Incident Rate for the ORLEN Group (number of workplace accidents involving our employees and contractors) at below 0.2 from 2030 onwards. To achieve this goal, we inspect contractors’ workplaces, verify their qualifications, and provide training on safe working practices. As part of work on strategy operationalisation, ORLEN Group companies further enhance the area of contractor personal safety management.