Human Rights

Human rights are universal values that guide our conduct in every aspect of our activities. The OMV Group strives to be a fair and responsible employer and recognizes its responsibility to respect, fulfill, and support human rights in all operations. We are committed to addressing any adverse human rights impacts we are involved in and to implementing adequate measures for their prevention, mitigation, and, where appropriate, remediation.

The OMV Group holds itself responsible for respecting the human rights of our employees, as well as those of people directly impacted by or involved with our business, for example our suppliers and contractors, communities, indigenous peoples, and the society in which we live and operate our business. Our responsibilities in the area of human rights include, and are not limited to, equality and non-discrimination, decent living wages, working hours, employee representation, security, primary health care, labor rights in the supply chain, education, poverty reduction, land rights, and free, prior, and informed consent (FPIC). We specifically concentrate on the impact of our activities on the human rights of individuals and groups that are more likely to be in vulnerable situations, such as indigenous peoples, women, and children.

Specific Policies and Commitments

Our Code of Conduct and the OMV Group Human Rights Policy Statement, which are both approved by the Executive Board, set out our understanding of and responsibility for respecting and realizing human rights in our business environment. Our Human Rights Policy Statement includes detailed descriptions of our specific human rights commitments, e.g., related to workers’ rights, vulnerable groups, and security, as well as our commitment to contributing to a Just Transition.¹ “Just Transition” refers to addressing the social and economic effects of the transition to an environmentally sustainable economy as stated in the Guidelines of the International Labour Organization (ILO) for a just transition. Borealis and OMV Petrom have developed their Human Rights Policy Statements based on the OMV Group’s statement, and both have been approved by the CEO and Executive Board respectively.

The OMV Group respects and supports human rights as described in the Universal Declaration of Human Rights and in internationally recognized treaties, including those of the International Labour Organization (ILO). OMV, OMV Petrom, and Borealis have signed the UN Global Compact and are fully committed to the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. This includes a commitment to upholding labor rights, such as decent living wages, working hours, employee representation, and provisions against forced labor, child labor, and human trafficking. We therefore fully support the aims of the UK Modern Slavery Act 2015 and are committed to operating our business and supply chain free from forced labor, slavery, and human trafficking. The OMV Statement on Modern Slavery and Human Trafficking explains in detail the countermeasures taken in all parts of the business and supply chain.

In addition to these commitments to international norms, we have further mapped out our human rights responsibilities in a comprehensive Human Rights Matrix, which is designed to serve as the foundation for our activities in this area. The OMV Group Human Rights Matrix covers responsibilities in the areas detailed below. The management of these commitments is further defined in a number of internal directives and regulations, such as the Community Relations and Community Development handbook available for all CSR focal points within the OMV Group, the Human Rights Management System, and our Community Grievance Procedure.

In 2023, we initiated a thorough revision of our OMV Group Human Rights Management in line with the UN Guiding Principles on Business and Human Rights, as well as any new or upcoming legal requirements, such as the EU Corporate Sustainability Due Diligence Directive (CSDDD), and other regulations related to mandatory human rights due diligence. With the revision of the human rights due diligence steps and the reformulation of roles and responsibilities, we aim to improve the integration of human rights into our overall risk management processes and across all functions.

We have also reviewed in detail our Human Rights Matrix, which forms the heart of the OMV Group Human Rights Management System and describes our concrete human rights responsibilities (for more details, see Human Rights Matrix).

Equality and Non-Discrimination

This includes the implementation of appropriate guidelines and awareness raising. Read more about our approach to this topic in Diversity, Equity, and Inclusion.

Security

This includes preventive, defensive, and community-oriented approaches to security, clear guidelines, supervision, and training, all in line with the Voluntary Principles on Security and Human Rights. Read more about our approach to this topic in Corporate Security.

Health and Safety

This includes the OMV Group’s health and safety management as well as community arrangements. Read more about our approach to this topic in Health, Safety, and Well-Being.

Labor Rights

This includes decent living wages, working hours, employee representation, collective bargaining, and provisions against forced labor, child labor, and human trafficking. We support the “five fundamental principles and rights at work” outlined in the ILO Declaration. We are committed to respecting workers’ rights, in line with ILO’s fundamental Conventions on rights at work, and we expect our contractors, suppliers, and the joint ventures we participate in to do the same. Where local labor rights standards fall short of the OMV Group’s standards, based on international human rights law, the OMV Group is guided by its higher standards unless this is forbidden by law.

The OMV Group strives to be a fair and responsible employer. Upholding and promoting labor rights is essential to achieving legal compliance in a local and international environment. It is also essential to ensuring that our global workforce can develop professionally and fulfill their personal aspirations in line with our business needs.

Working Hours and Flexibility

We are committed to complying with applicable local working time and overtime payment provisions, which is essential for a professional working environment. Part-time work is offered. In general, our part-time employees are entitled to the same benefits as full-time employees, except where benefits are linked to the amount of time worked (e.g., number of home office days per month, with full-time employees being entitled to more home office days than part-time employees). In line with local legal provisions, we offer further flexible work options such as special part-time work for certain age groups and work-from-home options that provide greater time flexibility for our staff. We offer various forms of long- and short-term breaks from work such as sabbaticals and parental and other care leave.

Operational Changes and Minimum Notice Periods

Our personnel policy is based on long-term employment. Both staff and the organization should benefit from long-term working relationships. We are also aware that job security represents a major concern not only for the individual employee, but also for society and the region concerned, and we therefore make every effort to live up to these responsibilities by means of contingency planning. Where business, organizational, or security changes require adaptations in the workplace, or even a termination of employment, we evaluate all the options, engage in constructive dialogue, and respond with the maximum possible care and sensitivity. Almost all of our employees are covered by mandatory notice periods under employment law or collective bargaining agreements in the event of restructuring. In situations where, despite training, transfer, or development programs, staff release becomes unavoidable, we make every effort to consider the economic and social consequences of those affected. We are committed to complying with local legislation regarding minimum notice periods in each country where we operate.

Wages

We are committed to locally applicable decent living wage standards. For almost all of our employees, minimum wages or salaries are fixed by law or agreed by way of collective bargaining.

Right to Education

This includes employee training and support for basic education in the surrounding communities. Read more about our approach to this topic in Skills Development and Training and Community Investments.

Property and Standard of Living, Including Land Rights and Poverty Reduction

We adhere to international best practices, which require avoiding involuntary resettlement, or at least keeping it to a minimum. Where resettlement is unavoidable, all people affected should be compensated fully and fairly. We are committed to a fair and transparent procedure for land use and compensation to local communities or authorities. If exploration, development, or production activities have the potential to impact communities, and/or their land, we consult with all relevant stakeholders ahead of time and obtain permission to use the land either temporarily or permanently.

Local Communities and Indigenous Peoples

We are committed to community consultation based on free, prior, and informed consent (FPIC) in accordance with IFC Performance Standard 7 and ILO Convention 169. We are aware of indigenous communities in the proximity of our operations in Māui, Pohokura, and Maari in New Zealand, as well as in the Arma district in Yemen. Read more about our approach to engaging with our communities in Community Impacts and Grievances.

Privacy and Family Life

This includes personal data protection and appropriate living and working conditions. An internal data protection directive is in effect for our employees, and we adhere to a public data protection policy regarding the processing of personal data. The OMV Group is aware that specific circumstances of operations in the field (remote locations away from family, residence in camps, etc.) potentially impact rights to privacy and to family life. Therefore, we apply the principles of necessity and proportionality regarding our employees’ living and working conditions.

Environment and Climate Change

The OMV Group recognizes the right to a clean, healthy, and sustainable environment as a human right that is intrinsically linked to a wide range of other human rights. With our OMV Strategy 2030, we are fully committed to supporting and accelerating the energy transition, acting on responsible resources management, and minimizing the environmental impacts of our operations.

Cognizant of the social impacts that the energy transition entails, the OMV Group is committed to contributing to a Just Transition for our employees and communities, and to addressing the social and economic effects of the transition to an environmentally sustainable economy.

Governance

In 2023, we took major steps to entrench accountability for human rights in our Company leadership. The Corporate Human Rights Experts team has been integrated into the Group Sustainability Team, which reports to the CFO. Our CEO continues to be the key owner of the topic of human rights, with the CFO being a co-owner. We continued our biannual human rights briefings with the CEO and CFO. They are both personally briefed about our main achievements and challenges related to our human rights impact at least twice a year (and whenever critical concerns arise). The main topics of discussion during the 2023 briefing sessions included principal achievements, major gaps and next steps of our human rights management approach, human rights compliance in contractor management, human rights grievances, the annual human rights risk ranking, the Human Rights Self-Assessment (HRSA) at Pak-Arab Refinery Limited (PARCO), the Community Grievance Mechanism (CGM) Assessment at OMV Tunisia, and our results of the Corporate Human Rights Benchmark. At the end of 2022, the OMV Group renewed its commitment to human rights with the formal approval of our revised OMV Group Human Rights Policy Statement by the OMV Executive Board.

Below Board level, accountability for our compliance with human rights lies with the respective countries’ business heads. Locally based human rights focal persons conduct due diligence at the operating facilities with the support of five human rights experts at Group level (at OMV, SapuraOMV, OMV Petrom, and Borealis) plus a team of four Social Compliance Experts at Borealis. Action plans and mitigation measures are implemented and reported by the respective functions, depending on which aspect of human rights is in question. Thus, the People & Culture (P&C) department deals with human rights issues related to labor rights, the Procurement department steers the management of human rights issues in supplier relationships, the HSSE department is responsible for health, safety, and security-related human rights issues, and the corporate Community Relations and Development function oversees OMV responsibilities related to the human rights impact on communities and indigenous peoples.

Management and Due Diligence Processes

The human rights due diligence process involves assessing the human rights risk associated with our current and future business activities and taking risk management actions. This ongoing process uses external resources and expertise, which includes external stakeholders, particularly those from impacted groups.

Human Rights Matrix

Since 2008, we have mapped out our human rights responsibilities in a comprehensive Human Rights Matrix designed to serve as the foundation for our activities in this area. We use this tool to assess our human rights challenges and activities, and prioritize our actions as essential, expected, or desirable in defense of human rights. In 2023, we initiated a review of the Human Rights Matrix as a follow-up to our review of the OMV Group Human Rights Policy Statement in the previous year. Keeping the overall structure of our Human Rights Matrix, we aim to improve the alignment of its content and language with international human rights due diligence standards and legislation. The updates will reflect the increasing responsibility of companies and better incorporate the most salient issues.

At all stages of the human rights due diligence process, we use the OMV Group Human Rights Matrix as a common standard, mapping out reality on the ground against the specific responsibilities as defined in the matrix, and identifying any gaps we need to focus on. This approach helps us identify any potential human rights impact of our business activities, whether it relates to non-discrimination and diversity, labor-related issues (e.g., decent living wage standards and adequate break times), indigenous peoples’ rights, or human rights in the supply chain.

Risk Assessments

The OMV Group has developed due diligence tools and techniques to assess the risk of human rights violations² A human rights violation happens when OMV fails to respect, fulfill, and support the realization of human rights in relation to our business activities, or becomes complicit in human rights abuse as understood under current international law, and as committed to in our OMV Group Human Rights Policy Statement and mapped out in our OMV Human Rights Matrix. related to our business, even before we launch or acquire business in a new country. Human rights are one of the components considered when making the decision to engage in a new country. The relevant human rights risks are presented to the respective Executive Board member to factor into the decision on whether or not to enter a country. We use these assessments to derive concrete measures to reduce the risk of direct and indirect involvement in potential human rights violations. We also conduct regular assessments of our current operations to determine their exposure to the risk of human rights and labor rights violations.

Due diligence starts with an initial risk ranking at country level: every country we operate in (or plan to operate in) is assessed based on comprehensive human-rights-related data and in consultation with internal experts. The countries are rated as low, medium, and high risk, countries with the greatest manageable risk, and “no-go” countries with unmanageable risk. Based on this rating, we develop our yearly work plan, defining further due diligence actions and human rights training. Internationally recognized third-party experts support the OMV Group in conducting due diligence on the Company’s exposure to human rights risks in countries with high human rights risks. In 2023, for example, external human rights experts supported our Human Rights Self-Assessment in Libya. We also conducted a country entry check that included assessments of human rights risks related to OMV’s potential business activities in the country and proposals on concrete mitigation measures in case of positive entry. Compliance checks of about ten potential suppliers in renewable supply (renewable feedstock, GHG tickets, and renewable products such as SAF (Sustainable Aviation Fuel) were also carried out. The purpose of these compliance checks is to find out if these suppliers have commitments, systems, and processes in place to comply with OMV’s human rights commitments.

We additionally conduct dedicated country risk assessments regarding labor rights to determine and monitor the legal situation and future development. As well as monitoring relevant labor rights risks, we work closely with employee representatives depending on the type of risk and potential impacts. With our annual initial risk rating, we also identify countries with elevated risks³ Elevated risk countries are those identified with a risk level of “high,” “greatest manageable,” or “no-go” (out of five levels: low risk, medium risk, high risk, greatest manageable risk, no-go) in our initial risk rating. of severe human rights abuse such as forced labor, child labor, or restrictions on the freedom of association. Within our country portfolio, 12 out of 48⁴In 2023, Russia was not included in the human rights risk ranking for the OMV Group. (25%) countries (e.g., Yemen, Libya, and Brazil) show an elevated risk of child labor. Some 18 out of 48 (38%) countries (e.g., Yemen, Libya, and China) have an elevated risk of forced labor. The freedom of association is generally limited in 14 out of 48 (29%) countries (e.g., UAE, China, and Malaysia). We inform the respective General Managers and Human Rights Focal Persons about the elevated risk levels in their countries and recommend specific mitigation measures, for example human rights training for employees and the integration of the mentioned human rights issues in contractor meetings.

Self-Assessments

The Human Rights Self-Assessment is one of the tools we use to evaluate the effectiveness of our human rights due diligence approach. Such assessments create internal awareness, capture our self-perception of our human rights performance, and facilitate the identification of gaps and further actions. Based on the outcomes of these assessments, we offer, support such as further capacity building to local experts or encourage peer and business partner initiatives to tackle local challenges. In 2023, we followed up on our Human Rights Self-Assessment at Pak-Arab Refinery Limited (PARCO)⁵ Pak-Arab Refinery Limited (PARCO) is a joint venture between the government of Pakistan (60%) and the Emirate of Abu Dhabi (40%), through its Mubadala Investment Company (MIC). OMV holds a 10% stake via MIC in PARCO., which we conducted in 2022 with the support of external human rights experts. A detailed report produced by the experts was shared with the PARCO management along with key recommendations, which included:

• Establishing a human rights management system that supports the identification, integration, tracking, and mitigation of human rights risks.
• Building the capacity of PARCO’s team and establishing functions dedicated to implementing human rights due diligence at PARCO.
• Developing an operational level grievance mechanism that applies to external stakeholders.
• Reviewing PARCO’s policies and clearly committing to promoting equality in all aspects of the company.
• Applying a human rights lens across processes and practices that focuses on right holders, including vulnerable groups.
• Including a human rights clause in policies e.g., Code of Conduct & Ethics, Guiding Principles of PARCO. Developing and implementing procedures to address human rights risks in security, land acquisition, community health and safety, and the supply chain.
• Leveraging CSR initiatives to engage stakeholders on the human rights impacts of operations.
• Establishing policies that protect employees from reprisals.

We also conducted a Human Rights Self-Assessment exercise at OMV Libya and a detailed report was provided by the experts, which outlined the following recommendations:

• Increase understanding of human rights risks related to assets, particularly taking into account workers and local communities.
• Build the capacity of the in-country team and establish functions dedicated to implementing Human Rights Due Diligence and monitoring progress at OMV Libya and associated assets.
• Explore ways to gain and exercise leverage with operators and the national oil company (NOC) in mitigating identified human rights impacts to the greatest extent possible.
• Engage with key local stakeholders, including civil society, on human rights impacts and how best to manage them going forward.
• Explore ways to engage with communities likely to be impacted by activities linked to assets.
• Ensure follow-up and proper documentation of all OMV efforts for the above.

Training and Awareness Raising

We pay special attention to training and raising awareness to bring our human rights commitment to life. We provide training on human rights, which helps equip our employees with an understanding of our human rights management process and gives them a space to work on concrete operational issues and local challenges. Even though the key concepts of the OMV Group Human Rights Management are the same across all countries in which we operate, the training focal points and discussions vary significantly, ranging from human rights in armed conflict environments and the risk of the OMV Group’s complicity to the OMV Group’s human rights responsibilities in joint ventures, personal legal liability, and employees’ human rights and grievances. In 2023, we launched a Human Rights Learning Path within our OMV Group Sustainability Academy. A total of 170 participants in six instructor-led sessions learned about human rights in general and within the business context, human rights at OMV, human rights of employees (our own as well as those of contractors and suppliers), human rights of external stakeholders, and human rights and security. The provision of additional resources (e.g., links to online webinars and reading materials from renowned external providers, such as ILO, UN, Ipieca, ICRC) allowed colleagues to delve further into specific topics, e.g., diversity and non-discrimination, labor conditions, forced labor, child labor, human trafficking, and other human rights issues.

All employees are strongly encouraged to complete our interactive e-learning course on human rights, which is part of the training curriculum for all our employees worldwide. In 2023, we promoted our newly launched human rights e-learning course, which guides employees through human rights norms and situations. The course provides a basic understanding of human rights in the business context and provides insight into our specific responsibilities, for example related to diversity and non-discrimination, labor rights of our own and contractors’ employees, human rights in security setups, and the rights of our communities, as well as severe human rights violations such as child labor, forced labor, and human trafficking. It also provides an insight into our due diligence tools and what to do in the event of observed or alleged human rights abuse. In 2023, Borealis launched a mandatory human rights e-learning course for the entire Borealis workforce in nine languages, covering all relevant human rights aspects and including transparent information and lessons learned related to the PDH Kallo incident in 2022. In addition, the Borealis ethics code of conduct e-learning covers human rights topics including discrimination, harassment, diversity, inclusion, bribery, and corruption. In 2023, 13% of the Borealis workforce⁶ Based on Borealis Group head count on December 31, 2023 completed the human rights e-learning and 88% completed the ethics code of conduct e-learning. In addition, 100% of the Borealis Executive and Supervisory Boards received in-person ethics training covering human rights.

SapuraOMV has continued raising awareness of human rights among its staff. To ensure everyone who works for SapuraOMV is kept up to date, all new staff, including interns, are briefed during their induction and are required to complete an online e-learning module on human rights within the first month of their employment. In this module, they are taught the basics and the main principles of human rights, as well as the implications for their own work. A total of 326 employees have completed the one-hour human rights e-learning since its launch in 2022.

We also implement internal awareness-raising campaigns throughout the Group. On the occasion of the UN World Day Against Trafficking in Persons on July 30, 2023, we informed our staff about our policies and activities against human trafficking. During an internal communication initiative, we also explained how everyone can contribute to this in their daily lives by paying attention to the well-being of our own and our contractors’ and suppliers’ workers, and being alert to any complaints or allegations regarding working conditions. A human rights awareness campaign was also conducted on the occasion of the international Human Rights Day in December. All employees Group-wide were informed about our commitment and the Human Rights Learning Path, and were invited to complete the human rights training modules.

In 2023, we also focused on developing the skills and awareness of our business partners in the context of human rights. Within the Libyan NOC onboarding exchange program, representatives from the NOC and the operating companies participated in a 1.5-hour human rights awareness session. In addition, we developed and implemented an exchange program to further strengthen the human rights skills of PARCO’s CSR manager. During a two-week training program, she gained knowledge of corporate responsibilities and reporting concerning human rights and its integration and fulfillment in various corporate functions. The objective was to implement the findings in coordination with the implementation of the recommended actions resulting from the Human Rights Self-Assessment (HRSA) exercise at PARCO. She had individual training sessions with various OMV corporate functions that deal with human rights-related topics, including security, procurement, people and culture, community relations, and development. Additionally, she worked on an assignment to better understand the process behind the development of a human rights policy document for an organization.

Regarding specific labor rights issues, the rights and obligations of our employees are set out in employment contracts. We keep our employees up to date via our various internal channels of communication (e.g., employee intranet, emails, and news feed) in the event of legal changes or new available information. For questions and specific information, we provide local P&C contacts and employee support hotlines.

Employee Representation

Employee representation is a valued and long-standing feature in the Company’s strategic orientation. Employee representatives are offered information and consultation rights as legally foreseen. A good and constructive working relationship with employee representation is an overall priority and is seen as being in the best interest of the Group and our staff.

Given the internationality of our Group activities and the various locations where we operate, employee representation at the OMV Group is diverse and depends on the local legal situation and the setup and activities of the local workforce. We cooperate with all official employee repre­sentation bodies, and deal responsibly with our staff directly where no employee representation is available.

Grievance Management

According to the UN Guiding Principles, an effective grievance mechanism is a crucial instrument for ensuring compliance with our human rights commitment, and a source of continuous learning for improving Company human rights performance. Particular emphasis is placed on the prevention of human rights violations and the integration of human rights issues into our decision-making processes. This includes registering grievances to ensure a preventive approach.

Our approach to managing community grievances follows the precautionary principle of obtaining local approval of OMV Group operations. This involves identifying and resolving the issues of concern to the local community early on. OMV’s localized Community Grievance Mechanism (CGM) procedures stipulate a stringent approach to systematically receiving, documenting, addressing, and resolving grievances in all the countries where we operate. Human rights grievances from community members and suppliers are submitted through the CGM and then analyzed locally and at Group level. For more information about the CGM, see Community Impacts and Grievances.

We offer our employees various channels for bringing issues, concerns, and grievances to our attention. They include the PetrOmbudsman at OMV Petrom, where employees and management can have confidential, off-the-record, informal discussions and address issues related to the workplace. Moreover, employees can bring forward their concerns in direct dialogue with human rights managers, human resources business partners, and works council members. At Borealis, such concerns can also be raised through the Borealis Ethics Hotline, anonymously and confidentially, with Group Ethics & Compliance, Ethics Ambassadors, and other reporting channels. In the event of legal or other changes (e.g., restructuring and pension issues), we offer interactive communication sessions with employees regarding working conditions. In 2023, internal grievances concerning field rotations and annual leave were raised by seven site employees. All seven cases are closed. At the end of 2023, out of twelve, two grievances had not yet been solved and P&C was still in dialogue with the complainants – in an effort to find a solution acceptable for all stakeholders involved and in line with national law and international human rights standards. The OMV Group’s strong human rights management was put to the test in 2022 when we were faced with major human rights violations related to our business activities.

The OMV Group is always seeking ways to improve and is strongly committed to further strengthening its processes and mitigation measures to prevent any maltreatment and disrespect of workers’ human rights in the supply chain.

At corporate level, we analyzed the HSSE and Procurement directives for contractor management and prepared a detailed checklist for human rights compliance to be used at site level. The human rights e-learning refers specifically to human rights in business relations, and the new OMV Group Human Rights Policy Statement details our human rights commitment related to labor rights and business partners in line with business best practice and international standards. There was a dedicated instructor-led session within the Sustainability Academy on the Human Rights Learning Path, focused solely on human rights in contractor and supplier management – 25 participants from various functions at OMV Petrom, Borealis, and OMV learned about the most relevant human rights risks and how to identify and address them. Our Code of Conduct is currently under review. It defines our business partners’ human rights responsibilities in more detail, including commitments on conducting human rights due diligence. We use our collaboration with business partners to embed salient human rights in their business practices and increase their awareness of ethical and ecological standards. We expect business partners to also pass these requirements, as applicable, on to their respective business partners, thus ensuring the application of the values and principles of our Code of Conduct, including ethical behavior, throughout our full value chain.

At local level, individual monitoring initiatives have been continued to ensure our business partners’ compliance with human rights. Among these were spot checks and HSSE walks, the inclusion of human rights in service quality meetings and evaluation criteria with our contractors, the confirmation of contractor employees’ employment registrations with local labor offices, detailed checks of framework contracts, and intensified promotion of our human rights training options. Furthermore, all business entities developed short- and mid-term plans to intensify human rights management in contractor relations.

SapuraOMV has followed up on its short- and long-term measures to improve our human rights performance in business relations, covering the topics of contractors’ agreements and work permits, wages, working and break times, working and housing conditions, access to grievance mechanisms, and training.

2023 Actions

In addition to reviewing our OMV Group Human Rights Management System and rolling out the expanded Human Rights Learning Path, our journey in 2023 focused on performing human rights assessments more consistently in existing high-risk assets and new projects.

In February 2023, the Human Rights Policy Statement was approved by the OMV Petrom Executive Board. It sets out OMV Petrom’s understanding of and responsibility for human rights in our business environment. It is OMV Petrom’s guiding principle for dealing with human rights issues in all aspects of daily business. It was published on www.omvpetrom.com and communicated to suppliers and dealers.

Throughout the year, OMV Petrom conducted three “cross-division” audits, which included human rights aspects, for some of its key contractors (i.e., those with contracts for at least two business divisions, whose activities are of high or medium HSSE risk, and who have long-term business activity with OMV Petrom). Topics like minimum age requirements, collective representation, training, and complaint systems were discussed and documentation provided.

In 2023, 13 human rights audits and assessments were conducted across the OMV Group. The findings of these, both positive and negative, are compiled in reports that are shared with the responsible managers. Our Group human rights experts support local management in developing action plans to address any identified issues or risks and further strengthen the integration of human rights into our business activities and relationships. In regular update meetings we monitor the activities and provide guidance and training to best overcome any challenges in implementing these action plans.

Borealis signed off its Human Rights Policy Statement in October 2023 with formal approval by the CEO. A new Social Compliance team, consisting of a Borealis Social Compliance Manager and three regional Social Compliance Managers, has been recruited and has established and implemented new social compliance processes and procedures to ensure compliant business conduct by Borealis’ business partners, particularly relating to the legal and ethical treatment of workers. Borealis has also conducted a human rights assessment at all Borealis locations in Belgium and the Netherlands. The assessment concludes that Borealis staff have a basic awareness of human rights requirements in accordance with applicable law and the Borealis Group’s policies related to human rights. Implementation of the human rights e-learning beginning in the fall of 2023 will continue to help raise awareness on human rights in Borealis locations.

In Malaysia, SapuraOMV continued to close any outstanding issues from the 2022 assessment at Jerun Fabrication Yard, e.g., regarding wages and benefits, to ensure everyone who works for the Jerun Offshore Development project is paid above minimum wage, their PPE is provided, and they know how to access the grievance mechanism. An on-site human rights assessment was conducted at the Asia Supply Base (ASB) in Labuan, covering its own staff and those employed under contract. It focused especially on the areas of wages and benefits, child labor, forced labor, working hours, and break times. SapuraOMV also initiated Human Rights Self-Assessments in Jerun, ASB, and B15. The respective managers were briefed about the questionnaire and the process and completed all questionnaires over the subsequent weeks. The analysis and final report including recommendations are expected in 2024.

Outlook

The OMV Group will take the following actions in the coming years to continue to improve our human rights approach:

• Continue our efforts in 2024, with our ongoing training and an awareness-raising campaign for employees.
• Finalize and roll out the reviewed Human Rights Management System across the Group and provide training to further enhance internal skills for its implementation and for the strengthened integration of human rights due diligence into existing business processes.
• We intend to focus on on-site human rights checks, to improve monitoring while at the same time raising awareness of human rights among our own and contractors’ staff.
• We aim to carry out assessments of high-risk non-operating assets to identify and address the human rights impacts of our business practices.
• Borealis is seeking certification for Social Compliance Standard SA8000 and will further enhance its social compliance procedures, based on experience gained in 2023.