OMV has established the following policies in order to manage our material impacts and risks related to E2 Pollution (including Process Safety).
Code of Conduct
Our license to operate relies on compliance with environmental protection regulations, which is of critical importance to governmental authorities, shareholders, and stakeholders, including the public, local communities near our operations, and environmental NGOs and NPOs. OMV’s Code of Conduct formalizes our public commitments to safeguarding the environment. For the Code of Conduct, unless otherwise specified, the key contents of the policy that are relevant for E2 Pollution and the entity-specific sub-topic Process safety, the process for monitoring, the scope of the policy, involvement of senior-level management, reference to third-party standards (where relevant), interests of key stakeholders in setting the policy (where relevant), and how the policy is made available to potentially affected stakeholders are covered under ESRS 2 Overarching Policies. Additionally, as part of our commitment outlined in the Code of Conduct, we are dedicated to substituting hazardous substances with less hazardous alternatives where reasonably practicable. To support this effort, processes should be designed, modified, and applied to minimize the production and use of hazardous substances, including the reduction of hazardous by-products or waste, as well as minimizing quantities or concentrations for handling and storage.
HSSE Directive
For the HSSE Directive, unless otherwise specified, the key contents of the policy that are relevant for E2 Pollution and the entity-specific sub-topic Process safety, the process for monitoring, the scope of the policy, involvement of senior-level management, reference to third-party standards (where relevant), interests of key stakeholders in setting the policy (where relevant), and how the policy is made available to potentially affected stakeholders are covered under ESRS 2 Overarching Policies.
HSSE Risk Management Standard
The OMV Group HSSE Risk Management Standard establishes a framework for identifying, assessing, controlling, documenting, and communicating health, safety, security, and environmental risks, with a particular focus on process safety. Its general objectives are to ensure the protection of people, the environment, and company assets, while supporting business integrity and sustainable operations. This policy directly addresses the negative material impact related to soil, air, and water pollution stemming from incidents and process safety events, as well as the resulting material financial risk of costly remediation payments and reputational damage. To achieve its objectives, the policy includes a process for ongoing monitoring and review through risk registers, audits, and stakeholder engagement. The effectiveness of all our HSSE policies is monitored by the respective functions through audits, HSSE assessments, site walks, and by tracking year-on-year progress of the targets set. The scope of the policy covers OMV, Borealis, and OMV Petrom, along with their respective subsidiaries, and applies to all employees; affected stakeholders include internal teams, contractors, and external parties as relevant. Minor exclusions apply, for instance within Borealis, where separate guidelines covering entity-specific operational incidents are provided. Members of the EB represent the most senior level accountable for approving and implementing this standard. The policy aligns with third-party standards such as ISO 31000 and IEC. Stakeholder interests are considered through structured communication, consultation, and participation in risk management processes. The policy is made available to all relevant stakeholders via internal platforms and policy updates are communicated to all OMV employees on a monthly basis.
Enterprise-Wide Risk Management Standard
For the Enterprise-Wide Risk Management (EWRM) Standard, unless otherwise specified, the key contents of the policy that are relevant for E2 Pollution, the process for monitoring, the scope of the policy, involvement of senior-level management, reference to third-party standards (where relevant), interests of key stakeholders in setting the policy (where relevant), and how the policy is made available to potentially affected stakeholders are covered under ESRS 2 Overarching Policies.
Environmental Management Standard
For the Environmental Management (EM) Standard, unless otherwise specified, the key contents of the policy that are relevant for E2 Pollution, the process for monitoring, the scope of the policy, involvement of senior-level management, reference to third-party standards (where relevant), interests of key stakeholders in setting the policy (where relevant), and how the policy is made available to potentially affected stakeholders are covered under ESRS 2 Overarching Policies. Within OMV’s EM Standard, processes and mechanisms have been defined to prevent, mitigate, and remediate potential negative impacts and risks. The EM Standard specifically outlines the following processes for managing pollution:
Risk Management
OMV is committed to proactively identifying, analyzing, and evaluating the environmental aspects, impacts, risks, and opportunities associated with all our business activities. The evaluation of environmental aspects, impacts, and risks under normal, abnormal, and accident conditions is conducted in accordance with the approaches and processes outlined in the HSSE Risk Management Standard and are fully aligned with the Environmental Risk Assessment methodology specified in ISO 14001. Appropriate measures are implemented according to the level of risk. This approach reflects our dedication to responsible environmental stewardship and continuous improvement.
Monitoring
Emissions to air and water are systematically monitored or estimated and controlled and appropriate monitoring systems or estimation models are in place. In all our refineries, we monitor emissions of pollutants such as sulfur oxides (SOx), nitrogen oxides (NOx), carbon monoxide (CO), particulate matter/dust, and non-methane volatile organic compounds (NMVOCs) as required by European and national legislation and the respective permits. If emissions are found to be in excess of nationally prescribed limits and/or limits defined in a permit, additional monitoring stations are installed and measures are implemented. OMV has a Well Integrity Management System (WIMS) in place covering all active wells operated by OMV. The WIMS enables a uniform and structured approach to describing, documenting, and reporting the status of well integrity throughout the production phase of a well in a predefined operating envelope. The WIMS therefore ensures that we operate our wells safely for people and the environment.
Prevention and Treatment
OMV has long implemented technologies to reduce emissions, such as installing end-of-pipe abatement technologies and floating roofs to reduce emissions. Over the past few years, we have focused on upgrading such technologies to ensure that they are still effective and reducing emissions. For instance, a SNOX flue gas cleaning plant was installed at the Schwechat refinery. With the SNOx Refurbishment of Wet Sulfuric Acid (WSA) program, in which a solution patented by OMV (two-layer PFA film structure with monitoring system) was implemented, both the reliability and the availability of the flue gas cleaning system could be increased. The flue gas cleaning plant at the Schwechat refinery is used for the removal of dust, and for denitrification and desulfurization of flue gases from the two power plants before they are emitted via the stack. This enables the separation of 95% of dust, the recovery of over 96% of sulfur, and the prevention more than 90% of NOx emissions. Identified leaks are addressed immediately or within defined time frames in accordance with the site’s maintenance processes and based on the risk assessment outcome and other factors, such as feasibility of repair during operation. To strengthen our response to and reduce the environmental impact of oil spills, we continue to perform emergency drills, including pollution scenarios. At our Petrobrazi, Schwechat, and Burghausen refineries, we have implemented Leak Detection and Repair (LDAR) programs. These programs involve both external partners and internal staff who continually monitor installations for leaking equipment. Whenever leaks are identified, they are repaired as quickly as possible, and the effectiveness of these repairs is thoroughly verified by the monitoring personnel.
Audits
At OMV, internal and external audits are a core requirement of our Environmental Management System (EMS), which is aligned with ISO 14001. Internal EMS audits are conducted at least annually to review compliance, assess performance, and identify improvement opportunities. These audits can cover the whole Environmental Management System or focus on a particular environmental topic. Additionally, every three years, sites without ISO 14001 certification undergo a full audit by an external expert or OMV Corporate Advisor. For certified sites, the ISO 14001 audit fulfills this requirement. These audits are essential for maintaining high environmental standards and driving continuous improvement across all OMV operations.
Spills Preparedness and Response Planning
Oil spills are a critical environmental issue for our industry. Spill management is defined as the prevention of spills in operations and those caused by incidents such as sabotage or natural hazards, and the management and remediation of spills resulting from an incident. Our key commitment is to prevent spills from happening in the first place. However, if spills to soil or water do occur, the Spills Preparedness and Response Planning Annex to our EM Standard provides clear guidelines on how to handle and clean them up to ensure the lowest possible impact from the incident. The EM Standard and its Annexes apply to all OMV sites globally, Borealis GmbH, and OMV Petrom S.A. The process for monitoring the effectiveness of all our HSSE policies is carried out by the respective functions through audits, HSSE assessments, site walks, and by tracking progress against targets.
The target group includes all employees and external experts involved in providing subject matter advice to OMV companies and all contractor employees. Multiple stakeholder groups are affected by our spill management activities. Government authorities are involved through potential breaches of environmental regulations, while employees and contractors are impacted by potential health and safety issues arising from accidents and damage to the environment and society. NGOs/NPOs are interested in potential damage to the environment and society, society may suffer from damages to the surrounding environment, and shareholders may have to deal with direct financial losses due to the costs of remediation measures and reputational damage. Furthermore, as OMV is diversifying, oil spills are no longer the only spills we need to deal with. For our subsidiary Borealis, preventing pellet spills is also a key issue. Unless otherwise specified, the involvement of senior-level management, reference to third-party standards (where relevant), interests of key stakeholders in setting the policy (where relevant), and how the policy is made available to potentially affected stakeholders are covered under ESRS 2 Overarching Policies. To prevent, mitigate, and remediate potential negative impacts and risks related to the pollution of air, water, and soil, specific processes and mechanisms have been defined. These include:
Emergency Response and Contingency Plans
We conduct spill responses according to a plan that identifies appropriate resources (persons in charge and intervention materials) and expertise. This plan assists on-site personnel with dealing with spills by clearly setting out the responsibilities for the actions necessary to stop and contain the spill and to mitigate its effects. This includes techniques for preventing the spill from moving beyond the immediate site and collecting the spilled substance and contaminated material. Clear communication and coordination protocols are set out in the local plans, particularly where national or international response resources may be required. We carry out regular oil spill response drills and training.
Clean-Up and Remediation
All oil spills occurring on land or in water are assessed and cleaned up immediately after their occurrence in accordance with the Spills Preparedness and Response Planning Annex of our EM Standard. In particularly difficult cases, we rely on third-party support for capping and containment, surface clean-up, and emergency management. Leaks are repaired immediately or within defined time frames in accordance with the site’s maintenance processes and based on the risk assessment outcome and other factors, such as feasibility of repair during operation. We approach remediation measures in line with the relevant legal requirements, which include clean-up, restoration, rehabilitation, and/or replacement of damaged environmental receptors. Remediation measures are implemented to make the affected land suitable for its intended use. These include actions such as cleaning up spills (e.g., by excavation and clean earth filling), or relying on natural attenuation (recovery) based on the respective decision of the environmental authorities. Provisions are included in our accounts for the liabilities related to spills and cover cleaning and remediation costs.
Process Safety Management Standard
OMV’s Process Safety Management Standard serves as a framework and reference for the implementation and maintenance of the process safety regulations in place by defining the minimum requirements and providing guidance on how process safety is integrated into the management of health, safety, security, and environment. The Process Safety Management Standard directly addresses the negative material impacts related to soil, air, and water pollution stemming from incidents and process safety events by minimizing the threats associated with handling hazardous substances in oil, gas, energy, and chemical activities. By doing this, we aim to prevent accidents that could harm humans, the environment, assets, and OMV’s reputation. The framework involves proactive risk identification and management through the analysis and evaluation of hazards to control risks within acceptable limits. It promotes a strong safety culture through leadership commitment, employee participation, and continuous learning. By integrating the Standard into the HSSE management system, OMV ensures compliance with legal and industry standards. The framework provides clear guidelines on the mitigation of and emergency response mechanisms to handle accidents. The effectiveness of all our HSSE policies is monitored by the respective functions through audits, HSSE assessments, site walks, and by tracking progress against targets. The Process Safety Management Standard and the Additional Relevant Standards addressing process safety apply to OMV globally, with specific provisions for local legal compliance taken into consideration. This includes OMV and all its subsidiaries, Borealis, and OMV Petrom, along with their respective subsidiaries. Minor exclusions apply, for instance within Borealis, where separate guidelines that cover entity-specific operational incidents are provided.
All the policies that govern process safety management (the Process Safety Management Standard and the Additional Relevant Standards) within OMV are approved by the Executive Board. Responsibility for implementing these policies lies with the respective business units or the respective members of the board of directors. The corporate functions are responsible for supporting the implementation and, to a certain degree, overseeing their governance and monitoring. OMV’s Process Safety Management Standard is guided by internationally accepted best practice requirements and standards, including those developed by major oil industry associations and organizations such as API, IOGP, Ipieca, Concawe, and ISO. In the development of the Process Safety Management Standard, subject matter experts and relevant departments were either directly involved or their feedback on the first draft was sought during an internal consultation process. The HSSE-related corporate policies are made available to all OMV employees via the Regulations Alignment Platform on the OMV Intranet. The process for monitoring is covered under ESRS 2 Overarching Policies.
To mitigate the negative impact of unplanned releases from process safety incidents, which can lead to property damage and pollution in the vicinity of our operations, OMV adheres to the Process Safety Management Standard. This standard provides comprehensive guidelines and procedures for preventing and managing process safety incidents and spills, ensuring controls are in place to minimize their likelihood and impact, thereby safeguarding the environment and property surrounding our operations. Within OMV’s Process Safety Management Standard, processes and mechanisms have been defined to prevent, mitigate, and remediate the actual negative impact. These include:
Risk Management
Process safety threats are systematically evaluated through a variety of process hazard assessments such as HAZOP studies, QRAs (Quantitative Risk Assessments), and risk assessments according to the Seveso Directive, which is the main EU regulation covering the control of major onshore accident hazards involving dangerous substances. Recommendations from process hazard analyses (PHAs), audits, reviews, and incident investigations addressing process safety risks are centrally recorded and prioritized systematically in the OMV Integrated Risk Register. This is linked to the mid-term planning process to ensure there is budget available to implement the recommendations. Prior to the start-up of a new facility, after major modifications, or following a turnaround, we conduct an independent pre-start-up safety review to ensure that the facility is safe for start-up and operations. In 2025, to identify and manage risks, a register containing risk reduction measures identified as a result of various process hazard analyses (PHAs), assessments, and safety studies was put in practice in each operated production unit and populated with data, including from Borealis sites. This provides a consolidated overview to support the prioritization and further development of risk reduction plans. A software tool to manage the results of process hazard analyses, recommendation tracking, and workflows was refined at OMV.
Emergency Management Plans
Process safety incidents can at times affect communities in the vicinity of our operations. For this reason, we have emergency management plans in place that are coordinated with the surrounding communities. Different levels of emergency management plan outline roles and responsibilities, structures, communications, and the interfaces required for emergency and incident management teams. Emergency response plans include specific emergency procedures and alerting and notification requirements to ensure that an emergency response is managed in a coordinated manner.
Inspection and Maintenance
Comprehensive inspection and maintenance programs are carried out by dedicated departments for inspection, maintenance, and plant integrity. They conduct regular inspections of process equipment, pipelines, tanks, and more, and manage the testing of safety equipment plus plant maintenance and turnarounds.
Investigations and Audits
Regular audits, reviews, and updates to our safety systems and procedures are mandated in the policies. OMV’s commitment to enhancing our safety protocols not only ensures a secure working environment but also prevents damage to our assets and mitigates negative impacts on our personnel, surrounding communities, and the environment. All incidents are identified and reported in an appropriate and timely manner. Work-related incidents with potential consequences for people, the environment, assets, or our reputation are investigated in a suitable manner to determine direct causes, root causes, and systemic causes so we can learn from them and prevent the recurrence of similar incidents. Tier 1 and Tier 2 process safety events are measured, tracked, and investigated continuously for a consistent overview of OMV’s process safety performance. In addition to Tier 1 and 2 process safety incidents, we monitor Tier 3 process safety events for a better assessment of the critical barriers. The monitoring and reporting of process safety events provides an overview of the challenges to safety systems so that weaknesses within the barriers can be identified and corrected at facility level.
Additional Relevant Standards
Other corporate regulations governing process safety at OMV include Contractor HSSE Management, Management of Hazardous Substances, and Reporting, Investigation, and Classification of Incidents. Collectively, these provide the framework for safety management and mandate regular reviews and updates of risk registers and action plans to ensure compliance and continuous improvement of our safety culture. These standards aim to address our actual and potential negative impact related to soil, air, and water pollution stemming from incidents and process safety events. Our Major Accident Prevention Policy sets out the overall aims and guidelines for preventing and controlling major accidents as part of OMV’s operations. Acknowledging that the hazard of major accidents in onshore or offshore operations related to oil and gas extraction, transportation, refining, and distribution activities is significant, and recognizing that such major accidents can have severe consequences for the environment and affected persons, OMV firmly believes that if a strong awareness of HSSE is embedded in the company culture, this will lay the foundation for all its operations and relationships with contractors.
Our Contractor HSSE Management Standard defines the minimum requirements for integrating HSSE issues into all phases of the contract life cycle and into the contractor management process. This standard aims to define a structured process for the HSSE management of contractors, from selection through to contract close-out. Together, these policies offer comprehensive guidelines and measures to mitigate the negative impact of unplanned releases from process safety incidents, which can result in property damage and pollution in the vicinity of our operations. The effectiveness of all our HSSE policies is monitored by the respective functions through audits, HSSE assessments, site walks, and by tracking progress against targets. For the scope of the Contractor HSSE Management Standard and further information, please refer to S2 Contractor HSSE Management Standard. The most senior level responsible for the implementation of these additional relevant standards is the OMV Executive Board. The Reporting, Investigation, and Classification of Incidents standard refers to the third-party standard API 754.
For the Management of Hazardous Substances and the Reporting, Investigation, and Classification of Incidents standards, unless otherwise specified, the scope of the policy and description of the interests of key stakeholders in setting the policy (where relevant) are the same as in the Process Safety Management Standard.
OMV’s HSSE management engages with employees and their representatives, such as works councils and trade unions, to address critical issues and identify areas for improvement. For example, Borealis conducts HSE Forums at each location, where employee representatives are consulted and informed about the HSE management system. The HSSE department organizes HSSE Days for various OMV units to educate employees on HSSE topics, including process safety. Additionally, OMV collaborates with local authorities and regulators to ensure that policies comply with legal requirements. Furthermore, the Safety Training Centers established at the sites provide a platform for interaction and exchange.
Corrosion Management Framework
To complement the EM Standard, OMV’s Energy division has developed a Corrosion Management Framework (CMF) that establishes a proactive and consistent approach to corrosion monitoring and management across all operations. The CMF provides clear guidelines for maintaining the integrity of our assets and facilities, helping to prevent the negative material impact related to soil, air, and water pollution stemming from incidents (e.g., resulting from asset integrity failures at both onshore and offshore sites), as well as the potential negative impact specifically related to water pollution. This framework supports our commitment to environmental protection and responsible resource management. The scope of the CMF is the OMV Energy division, covering the full life cycle of the equipment exposed to the risk of corrosion in both oil and gas facilities, from the well to the sales point. This standard, endorsed by the Head of Development of OMV, applies to all employees and contractors involved in corrosion management during the design, engineering, construction, commissioning, and operation phases of oil and gas fields at OMV Energy and OMV Petrom Exploration & Production (including its affiliates) globally. The most senior level accountable for implementation is the EB, specifically the member responsible for the Energy business segment. The CMF stipulates that all protective coatings and claddings shall comply with international standards such as ISO 14879, ISO 16961, and/or ISO 12944. Furthermore, the CMF requires adherence to various industry standards, such as ISO 15156, NACE SP0499, NACE SP0407, NACE SP0169, NACE TM0497, and API TR17 TR6.
For the Corrosion Management Framework, unless otherwise specified, the interests of key stakeholders in setting the policy (where relevant) and how the policy is made available to potentially affected stakeholders are the same as the HSSE Directive. The EM Standard, which includes the annex on Spills Preparedness and Response Planning, and the Corrosion Management Framework are key policies providing guidelines to mitigate the negative impacts related to the pollution of air, water, and soil. These policies cover prevention and control measures identified in our materiality assessment and are listed in the IRO table in SBM-3 Material Impacts, Risks, and Opportunities and Their Interaction with Strategy and Business Model. Currently they apply exclusively to OMV operations. Additionally, our Code of Conduct, an overarching policy, underscores our commitment to implementing prevention and control measures to protect water and soil. We aim to follow the best-recognized industry practices beyond those provided by authoritative standards and guidance in our operations. Any spills are to be promptly assessed and cleaned up to minimize their impact on the environment and society.
To avoid incidents and emergency situations, and, if they occur, control and limit their impact on people and the environment, OMV adheres to the EM Standard, which mandates that spill prevention and control plans be tailored to the specific characteristics of each business. All onshore and offshore operations must identify and analyze activities that pose a risk of liquid spills with adverse environmental effects. When such risks are identified, operations must develop written spill prevention, control, and response procedures for all hazardous substances on-site, particularly oil and hydrocarbons. These procedures can be annexed to the overall Response Procedure or form a standalone Spill Prevention, Control, and Response Plan, depending on legal requirements, facility complexity, and spill response needs. Any spill response system must include hazard identification, risk assessment, prevention, control and response plans, command and control arrangements, and training and testing. Contingency planning is central to spill preparedness and involves gathering information, conducting risk assessments, identifying threatened environmental and socio-economic receptors, and developing response strategies. Additionally, procedures are established to ensure adequate response capabilities are mobilized according to the identified risks and to manage the responsible disposal of recovered materials. By following these guidelines, OMV is committed to preventing incidents and effectively controlling and mitigating their impact when they do occur.
Responsible Care Policy
Borealis has identified microplastics pollution through unintentional pellet loss from its operations as a material impact and manages it through its Responsible Care policy. The impacts of unintentional pellet loss from our subsidiary Borealis’ operations are specifically managed through the polyolefin (PO) production sites’ compliance with the Operation Clean Sweep (OCS) standard. OCS is a voluntary industry initiative, specifically designed to reduce and prevent plastic pellet, flake, or powder loss throughout the entire plastics supply chain, from production to handling and transport. It does this by committing its participants to best practices when handling plastic pellets and requiring external certification of compliance with the standard.
The key content and objectives of the policy include deploying the OCS standard at all of Borealis’ PO sites, obtaining external OCS certification of all PO sites in Europe (recycling plants are currently excluded from the certification process), implementing pellet loss hierarchy as a guiding principle for avoiding pellet spills to the environment based on zero loss of pellets from primary containment, mitigation of impacts in the event of pellet spills, and cleaning up spillages to prevent unrecoverable pellet loss to the environment. Additionally, the policy includes implementing the following six key OCS requirements at every PO site: improving the worksite setup to prevent and address pellet spills; creating and publishing internal procedures to achieve zero pellet loss; providing employee training and accountability for spill prevention, containment, clean-up, and disposal; auditing performance regularly; complying with all applicable local and national regulations governing pellet containment; and encouraging partners to pursue the same objectives.
The Responsible Care policy covers all Borealis entities and affiliates that process, handle, or manage polyolefins (PO sites). Newly acquired entities follow an integration plan, which includes the Responsible Care policy and implementing the OCS standard. The Responsible Care policy is owned by the Borealis CEO, who is also accountable for its implementation and the OCS standard at all PO sites. The Borealis Integrated Management System (IMS) is aligned with the Operation Clean Sweep and ISO 14001 standards. In setting its Responsible Care policy, Borealis considered the interests of key stakeholders – its owners through consultation with its Supervisory Board and its employees through consultation with the Works Council. The OCS standard is administered by a steering committee that consists of the European Commission, representatives of EU member states, and NGOs, and therefore takes account of their interests and views. Within Borealis, the OCS standard is integrated into its Group-wide management system and is translated into local languages and contexts to ensure it is accessible and understandable for every Borealis employee. All affected Borealis employees are trained on complying with the OCS Standard. The policy is not accessible for external stakeholders. For more information, see the Borealis Group Annual Report 2025 – Group Management Report – Sustainability Statement.
Pollution of water and soil due to unintentional pellet loss is addressed in Borealis’ Responsible Care policy and its adoption of the Operation Clean Sweep (OCS) standard. Additionally, all environmental topics related to Borealis’ operations are managed through their Environmental Management System, which aligns with the Responsible Care policy. Borealis’ management system is structured into five levels. The first level, “policy,” establishes the framework for areas such as Environment, Health & Safety, and Product Stewardship, as outlined in the Responsible Care policy. The second level includes management handbooks, the third level describes processes, the fourth level provides detailed instructions, and the fifth level covers meeting charters. To avoid incidents and emergency situations involving the unintentional loss of plastic pellets, every PO site implements the six key OCS requirements, as detailed in Borealis’ operational instruction on OCS implementation. Each Borealis site must also establish and annually review a risk management plan. This plan includes protocols and procedures to prevent and address spills, incorporating preventive measures such as preventive maintenance and double sealings, containment measures like catch trays and housings, and cleaning or reaction measures, including vacuum cleaners and street sweepers. The plan outlines responsibilities, actions, time frames, and documentation procedures for instances where pellets are found outside the designated primary containment.