Section:

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Report structure

Information on this

Business model

EU Taxonomy

Society

Report

Employees and human

Environment and climate

Occupational health

Process safety

rights area

and safety

Anti-corruption and

GRI content

bribery

index

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Contents

Information on this Report � � � � � � � � � � � � � � � � � � � � � � � 4

Reporting principles, structure and methodology . . . . . . . . . . 5 Material reporting aspects . . . . . . . . . . . . . . . . . . . . . . . 8 Reporting period, frequency and contact point . . . . . . . . . . . 10 ORLEN Group's transition towards CSRD. . . . . . . . . . . . . . . 11

Business model � � � � � � � � � � � � � � � � � � � � � � � � � � � � � 12

ORLEN Group and ORLEN S.A

. 15

Organisation and development policy

20

Brands and products

22

ORLEN Group's 2030 Strategy

23

Sustainable Development Strategy

. 31

ORLEN Group stakeholders

35

Tax transparency

37

Anti-competitive behaviour

39

EU Taxonomy � � � � � � � � � � � � � � � � � � � � � � � � � � � � �

40

Regulatory framework

. 41

Consolidated disclosures of the ORLEN Group

42

Key performance indicators and relevant

accounting principles

46

Society � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �

63

Management of the social area

65

Key performance indicators

69

Due diligence procedures

. 71

Material risks and management approaches

107

Employees and human rights area � � � � � � � � � � � � � � � � � 109

Management of the employees and human rights area

. 111

Key policies

113

Key performance indicators

119

Due diligence procedures

133

Respect for human rights at the ORLEN Group

145

Material risks and risk management approaches

in the employees and human rights area

152

Environment and climate � � � � � � � � � � � � � � � � � � � � � �

155

Environment and climate management

159

Key policies

165

Key performance indicators

168

Due diligence procedures

190

Management of climate risks

207

Material risks and management approaches

211

Occupational health and safety � � � � � � � � � � � � � � � � � �

219

Occupational health and safety management

220

Key performance indicators

224

Due diligence procedures

234

Material risks and management approaches

245

Process safety � � � � � � � � � � � � � � � � � � � � � � � � � � � � �

247

Process safety management and policies in place

248

Due diligence procedures

256

Key performance indicators

260

Material risks and management approaches

265

Anti-corruption and bribery � � � � � � � � � � � � � � � � � � � �

266

Anti-corruption and bribery management

267

Key performance indicators

276

Due diligence procedures

279

Material risks and management approaches

284

GRI content index � � � � � � � � � � � � � � � � � � � � � � � � �

286

Authorisation of the Non-Financial Report

of the ORLEN Group and ORLEN S.A. for 2023 � � � � � � � �

295

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01 Information on this Report

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The GRI Standards disclosures discussed in this section

Number of GRI Universal

Standards 2021 indicator Disclosure title disclosure

2.4

Restatements of information

3-1

Process of determining material topics

3-2

List of material topics

1. Reporting principles, structure and methodology

This Non-Financial Report (the "Report") includes data pertaining to the ORLEN Group (the "ORLEN Group") and ORLEN S.A. ("ORLEN", the "company") for 2023.

2023

This Report has been prepared in accordance with:

Art. 49b.1 and Art. 55.2b-e of the Polish Accounting Act of 29 September 1994, as amended, which implements the guidelines of Directive 2014/95/EU of the European Parliament and of the Council of 22 October 2014 on disclosure of non-financialand diversity information.

EU Taxonomy regulations:

Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment and amending Regulation (EU) 2019/2088, which has introduced the obligation to include in the Non-Financial Report of the ORLEN Group and ORLEN S.A. for 2023 information on how and to what extent their activities qualify as environmentally sustainable.

The disclosure obligations have been further specified in Commission Delegated Regulation (EU) 2021/2178 of 6 July 2021 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by specifying the content and presentation of information to be disclosed by undertakings subject to Articles 19a or 29a of Directive 2013/34/EU concerning environmentally sustainable economic activities, and specifying the methodology to comply with that disclosure obligation.

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  • The criteria for determining whether a given economic activity qualifies as environmentally sustainable are set out in:
    • Commission Delegated Regulation (EU) 2021/2139 of 4 June 2021 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation or climate change adaptation and for determining whether that economic activity causes no significant harm to any of the other environmental objectives.
    • Commission Delegated Regulation (EU) 2023/2485 of 27 June 2023 amending Delegated Regulation (EU) 2021/2139 establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation or climate change adaptation and for determining whether that economic activity causes no significant harm to any of the other environmental objectives.
    • Commission Delegated Regulation (EU) 2022/1214 of 9 March 2022 amending Delegated Regulation (EU) 2021/2139 as regards economic activities in certain energy sectors and Delegated Regulation (EU) 2021/2178 as regards specific public disclosures for those economic activities.
    • Commission Delegated Regulation (EU) 2023/2486 of 27 June 2023 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing

substantially to the sustainable use and protection of water and marine resources, to the transition to a circular economy, to pollution prevention and control, or to the protection and restoration of biodiversity and ecosystems, and for determining whether that economic activity causes no significant harm to any of the other environmental objectives, and amending Commission Delegated Regulation (EU) 2021/2178 as regards specific public disclosures for those economic activities.

  • This Report references the GRI Standards and GRI 11 sector-specific disclosures: Oil and Gas Sector 2021. The reporting process covers the ORLEN Group companies, including those not directly classified as Oil and Gas. It is the latest version of the standard for ESG and sustainability reporting, effective for reports or other materials published on or after 1 January 2023. The disclosures addressed in this Report are listed at the beginning of each section and in the summary table at the end of this Report.
  • The scope of information contained in this Report takes into account the expectations resulting from international

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This Report presents: the business model, non-financial key performance indicators, policies and procedures as well as potential risks and risk management methods for the entire ORLEN Group and for ORLEN S.A. It covers activities carried out by the ORLEN Group and ORLEN S.A. in 2023.

In 2023, a survey was conducted among the ORLEN

Group's internal and external stakeholders to probe their opinions on sustainable development and corporate social responsibility. The project involved, among other things, a revision of the reported aspects. Stakeholder consultations consisted in conducting a survey (online questionnaire) and individual interviews with representatives of the ORLEN Group's key and important stakeholders.

The purpose was to probe stakeholders' opinions on

and governance topics that the company should consider when planning its sustainable development agenda.

The stakeholder survey fulfils the obligation of engaging stakeholders in the materiality assessment process according to the GRI Standards of reporting.

The survey was carried out in accordance with the international AccountAbility Stakeholder Engagement Standard - AA1000SES, providing the rules for stakeholder relations management.

Additionally, representatives from various departments and offices within ORLEN S.A., along with key representatives of selected ORLEN Group companies, undertook a comprehensive review of the Group's stakeholder map.

Preparation of this Report included the following stages:

  • Confirmation of significant business and sustainability topics relevant to the ORLEN Group and ORLEN S.A. and their materiality, through consultations and a survey held in the course of internal and external consultations in 2023.
  • Review of the ORLEN Group's stakeholder map.
  • Collection of data reflecting implementation of the sustainable development policies, strategies and objectives, as well as the due diligence procedures and risk management policies and how they are put into effect at the ORLEN Group and ORLEN S.A.
  • Compilation of this Report of the ORLEN Group and ORLEN S.A. for 2023 based on data collected in accordance with Art. 49b and Art. 55.2b-e of the Polish Accounting Act of 29 September 1994 (Dz.U. of 2021, item 217), the EU Taxonomy regulations and GRI Standards, with the incorporation of conclusions and expectations resulting from international ESG ratings, and reference to the recommendations of the Task Force on Climate-related Financial Disclosures.

A detailed description of all aspects of the ORLEN Group's financial and non-financial activities will be published in 2024 in the online ORLEN Group Integrated Report for 2023. External assurance of this Report will be based on the ISAE 3000 standard.

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2.Material reporting aspects

GRI 3-1

Process of determining material topics

GRI 3-2

List of material topics

Both external and internal stakeholders were involved in the process of selecting material aspects to be reported by the ORLEN Group. The process of defining material reporting aspects at the ORLEN Group included the following activities:

Identification

Representatives of the ORLEN Group and its stakeholders took part in an opinion survey carried out in 2023 through an online questionnaire and a series of in-depth expert interviews with selected stakeholders.

The dialogue was conducted based on the GRI Standards and the AA1000SES international stakeholder engagement standard. The consultations concerned priority directions for sustainable and responsible business, as well as expectations as to disclosures relating to the Company's operations and their social and economic impacts, including determination of their materiality. The survey involved employees of the ORLEN Group and representatives of industry organisations, the investor community, academics, as well as social and business partners. The stakeholder survey was preceded by an internal review of material reporting aspects, which referred, among other things, to the GRI sector-specific guidelines.

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Prioritisation

FIGURE 1

The stakeholder survey confirmed the economic, social and environmental topics which should be reported. Stakeholders also voiced their opinions on the type of Green Deal- related information they considered most relevant and the Sustainable Development Goals 2030 which should be

Material ESG reporting topics for 2023

Development of renewable

energy and portfolio

of low-carbon products

Materiality for external

Water management and

stakeholders

water pollution prevention

R&D investments

Working conditions, including employee development opportunities

and benefits

pursued by ORLEN considering its business profile.

Validation

Stakeholders participating in the survey indicated the most relevant topics to report on, which were finally validated in the course of internal discussions at the ORLEN Group. The survey led to the determination of their materiality to the ORLEN Group and its stakeholders. As a result, the final list of the ORLEN Group's material reporting aspects was prepared, specifying their materiality for the ORLEN Group and its external stakeholders, as shown in the figure opposite. These material aspects have been included in this Report and will be discussed in detail in the ORLEN Group Integrated Report for 2023.

10.00

Social and

environmental criteria

Management of

in the supply chain management

Business ethics

sustainability aspects,

9.00

including ESG risks

Impact on local

Transparency

Service quality

and customer

communities

satisfaction

8.00

Social engagement

Climate change

Industrial process

7.00

safety

Emission

of

Anti-discrimination policy

air pollutants

Waste and

and equal opportunities

circular economy

6.00

Environmental education

Respecting

Impact on

of employees

human rights

the economy

5.00

and local communities

Biodiversity

Occupational health

and safety

4.00

4.00

5.00

6.00

7.00

8.00

9.00

10.00

Materiality for the ORLEN Group

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3.Reporting period, frequency and contact point

GRI 2-3

Reporting period, frequency and contact point

The previous report, for 2022, was published in April 2023. Non-financial reports are issued on an annual basis and are continually evolving, to reflect developments within the ORLEN Group and in its environment. The Report for 2023 will be the last one referencing the GRI Standards. Starting from 2025, our publications will align with the European Sustainability Reporting Standards (ESRS), in accordance with the Corporate Sustainability Reporting Directive.

We welcome all feedback, comments, and opinions on this Report, data presentation and our activities.

Please reach out to us via email to:

Katarzyna Krzywicka

Corporate Communication Area

Tel. (+48) 22 778 00 95 katarzyna.krzywicka@orlen.pl

GRI 2-4

Restatements of information

In 2022, the scope of the ORLEN Group's data in the section discussing the Energy segment was extended to cover the generation assets of former PGNiG S.A. (owned by ORLEN S.A. as per the relevant licence), ORLEN Upstream and the CHP plant operator EC Stalowa Wola. In addition, the operating data for CHP units at Rafineria Gdańska and EC Stalowa Wola was restated to reflect the ORLEN Group's interests in the companies.

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Attachments

Disclaimer

Orlen SA published this content on 25 April 2024 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 25 April 2024 17:46:02 UTC.