Code of Conduct
For the Code of Conduct, unless otherwise specified, the key contents of the policy that are relevant for Management of relationships with suppliers including payment practices, 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.
Corporate Procurement Directive and Purchase to Pay Standard
OMV’s Corporate Procurement Directive describes the overall process of supplier engagement and supplier management, including how human rights aspects are embedded in supplier prequalification, audits, and meetings. Through the guidelines that it provides, it addresses the potential positive impact of active engagement with suppliers and business partners to develop a good corporate culture and promote sustainability awareness across our network, and the potential negative impact regarding the financial vulnerability of business partners deriving from their significant dependence on OMV as their primary source of revenue. The Purchase to Pay Standard defines the minimum requirements for the Group-wide Purchase to Pay process, encompassing all existing regulations within the process scope. This standard pertains to activities such as requesting, purchasing from external suppliers (excluding inter-company purchases), receiving, accounting, and paying for goods and services. Together with the Corporate Procurement Directive, it outlines the procedures and payment terms that guide the time frame within which invoices from our suppliers and contractors should be paid, so as to mitigate our potential negative impact on business partners caused by late payments. Biannual checks and progress tracking against targets are carried out by the Governance & Analytics and Strategy & Digitalization procurement units to monitor the effectiveness of the Corporate Procurement Directive’s implementation.
Both the Corporate Procurement Directive and the Purchase to Pay Standard apply to OMV (OMV Aktiengesellschaft and all its fully consolidated subsidiaries), including BorealisExcluding mtm plastics GmbH, mtm compact GmbH, Ecoplast Kunststoffrecycling GmbH, DYM Solution Co Ltd., Integra Plastics AD, Renasci Oostende Recycling N.V., Rialti S.p.A. and OMV Petrom and their subsidiaries. The principles and minimum standards stipulated in the directive apply to all purchasing activities within OMV that are managed by OMV Group Procurement, while some goods and services, such as renewable fuels and feedstock and trading activities, are purchased through other departments. OMV’s Corporate Procurement Directive and Purchase to Pay Standard are signed and approved by the Executive Board. The most senior level with accountability for the Corporate Procurement Directive is the Chief Procurement Officer, while for the Purchase to Pay Standard it is the Chief Information Officer, who reports directly to the CFO. The Corporate Procurement Directive and the Purchase to Pay Standard have been developed through extensive alignment with internal stakeholders, including accounts payable and business representatives, and are also based on information acquired during our collaboration with the external partners CDP and EcoVadis. The provisions are made available to all OMV employees via the Regulations Alignment Platform on the OMV intranet. Relevant aspects for suppliers are incorporated into contractual agreements.
To ensure we have a standardized approach to payment conditions for all our suppliers and contractors, including those from small and medium-sized enterprises (SMEs), we stipulate 60-day standard payment terms in the Corporate Procurement Directive and Purchase to Pay Standard. We continuously monitor payment terms to ensure they are in line with the contractual agreements conducted with our suppliers. To safeguard this, one day prior to expiry of the payment term, the SAP system proposes for payment all invoices that are due, and they are paid automatically the next day without the need for manual intervention. Where invoices are blocked for payment (e.g., for tax reasons), the reasons are analyzed, and remediation measures are initiated.
The Corporate Procurement Directive outlines specific processes related to supplier engagement and management. These include:
Supplier Relationship Management (SRM)
OMV’s SRM framework not only focuses on managing strategic relationships with our suppliers and contractors but also incorporates sustainability into supplier segmentation, performance, meetings, and innovation. To support OMV on its transformation journey to becoming a leader in innovative sustainable fuels, chemicals, materials, and the circular economy, it is crucial to ensure that suppliers are encouraged to innovate. This helps unlock their potential, and the innovative solutions they develop provide an opportunity to enhance and strengthen partnerships. Furthermore, active and fair engagement with suppliers regarding sustainability matters has the potential to foster positive change in the supply chain and addresses the potential negative impact of the financial vulnerability of suppliers due to delayed payment from OMV.
Prequalification
Supplier prequalification is part of precontractual activities, during which OMV collects information from a potential supplier with the purpose of evaluating compliance with our HSSE and sustainability requirements. The goal of the prequalification process is to screen potential suppliers before bringing them on board to ensure that only those suppliers that meet our HSSE and sustainability standards are considered for future collaboration. Prequalification is based on a standardized list of elements and objectives that align with the OMV Group’s HSSE Management System (e.g., HSSE Policy, ISO 9001, 14001, 45001) and our Sustainability Framework (e.g., Sustainability Policy, Human Rights Policy Statement, and grievance mechanisms).
Supplier Selection
Following prequalification, Procurement and business representatives select the best suppliers based on a predefined set of commercial and technical criteria during a tender process. Social and environmental criteria are part of the commercial evaluation, so as to give sustainability added value in sourcing. To support the overall OMV Group Sustainability Targets 2030 and the Sustainable Procurement ambition to give sustainability a “value” in sourcing, the Procurement department has included two criteria to assess the sustainability performance of the bidders in their commercial evaluation: the EcoVadis score and completion of our climate change questionnaire.
In 2025, OMV invited more than 1,000 suppliers to respond to a simplified version of the climate change questionnaire, which was developed internally based on the CDP structure. In addition to reporting their emissions, we asked suppliers whether they have carbon reduction targets in place and invited them to share with us any initiatives or projects to reduce carbon emissions in which they would like us to participate. Suppliers were selected based on spend so as to focus on our largest business partners and thus maximize impact. In addition, individual meetings and webinars were offered to our suppliers to help them better understand the requirements of the climate change questionnaire and why this information is important to OMV.
Risk Assessments
Understanding a supplier’s risk is an important factor in deciding whether and how we conduct business with them. The risk profile set up by OMV Procurement in our internal IT systems for Tier 1 suppliers aims to enhance supply chain resilience and compliance with the requirements of the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD). It is based on three major risk areas: Sustainability, Procurement, and HSSE. Furthermore, OMV has a screening process in place to ensure that parties sanctioned by the EU or international organizations, such as the United Nations, are not accepted as procurement partners.
Audits
OMV conducts two types of audits of its suppliers and contractors: on-site Together for Sustainability (TfS) audits that focus on the sustainability performance of a company, and audits performed by an external auditor. The audits are carried out as part of the prequalification process and/or during contract execution. The aim of the audits is to measure the performance of our suppliers and define actions that will enable them to optimize their performance and meet OMV requirements. During the external audits, we pay special attention to the financial stability of our suppliers, their strategy and organization, supply chain, sustainability (e.g., social and environmental issues), and their cybersecurity performance. Each audit finding classified with a red flag is followed up and analyzed by the Procurement team in collaboration with business representatives and any other relevant function (e.g., HSSE, Legal, Internal Audit, and Compliance). Information on the outcome of the audit is made available to the supplier, and the supplier is requested to submit a proposed corrective plan with concrete measures and an implementation timeline. In 2025, 16 audits (2024: 13) resulted in follow-up measures.
Supply Chain Carbon Transparency
We aim to continuously manage and decrease the carbon volume of our purchased goods and services. Only by working together with our suppliers will we be able to define joint low-carbon initiatives to continuously decrease the carbon emissions in the supply chain and meet our Paris Agreement commitments. Our climate change questionnaire is our central instrument for creating transparency related to carbon emissions in our supply chain, and it is closely linked to our target Engage with Suppliers to Assess Their Carbon Footprint.
Supplier Capacity Building
OMV works with its suppliers to improve overall sustainability performance by inviting them to individual meetings or webinars to increase awareness of the importance of participating in TfS assessments or completing our climate change questionnaire. We also include topics related to sustainability and low-carbon procurement in our annual strategic supplier meetings and invite key suppliers to deep dive workshops on innovation. In 2025, 17 meetings were organized with our strategic suppliers, during which commercial, technical, HSSE, and sustainability topics were discussed. In total, 6 deep dive workshops on innovation were also held with key suppliers.
Local Content
We aim to support the local communities in the locations where we operate by fostering economic development. Local procurement strengthens the local economy and meets the local procurement expectations of neighboring communities. Increased local procurement has had the added benefit of reducing business disruption in recent years, as well as the potential for a smaller carbon footprint due to the reduced transportation distance of the goods purchased. In 2025, the spend with local suppliers at Group level was 70.9% (2024: 71.1%).
Supplier ESG Programs
Minimum ESG requirements, like presenting proof of a CSR/Human Rights Policy or accepting our Code of Conduct, are part of our supplier prequalification practices. Furthermore, to ensure effective implementation of supplier ESG programs, we award additional points in the commercial evaluation to bidders who have completed/agree to complete the EcoVadis assessment and climate change questionnaire. Suppliers that do not meet the minimum EcoVadis score of 45 are requested to improve and retake the assessment in the following year.Not meeting this requirement does not lead to exclusion from contracting. Through these supplier ESG programs, we aim to increase our potential positive impact on the corporate culture of our suppliers, as that in turn might lead to improvement in working conditions and quality of life for workers in the supply chain. We actively engage not only with our suppliers, but also with buyers on sustainable procurement and supplier innovation practices. Our buyers receive regular training on how to assist the Procurement department in achieving its sustainable sourcing goals. To this end, they engage with suppliers and encourage participation in ESG evaluations, such as the EcoVadis assessments or our climate change questionnaire. In 2025, sustainable procurement training for buyers focused on applying OMV’s new Code of Conduct in supplier sourcing and contracting. Two training sessions were conducted, attended by 190 buyers from OMV, OMV Petrom, and Borealis (compared to 155 buyers in 2024).