Borealis GmbH

Governance roles

Reference: pages 27-31.

Borealis GmbH has a dual board structure: a five-member Executive Board (CEO, CFO, EVP Polyolefins/Circular Economy Solutions/Base Chemicals, EVP Operations, EVP Joint Ventures) and an eight-member Supervisory Board (SVB), five of whom represent shareholders OMV and ADNOC and three of whom are Works Council employee representatives. "Based on this, there are no independent Board members." The SVB has a Remuneration Committee and an Audit Committee.

The Sustainability and Responsible Care Committee (SRCC), sponsored by the CEO and chaired by the VP Sustainability & Public Affairs, oversees target setting on material IROs; its permanent members include the whole Executive Board and the VP HSE&Q. The DMA and IROs are updated annually under the VP Sustainability & Public Affairs and brought to the SRCC for endorsement; the SVB is informed in combination with Annual Report approval.

Borealis states plainly that "the responsibilities of the SVB and Executive Board for material IROs are currently not stipulated in Borealis GmbH's governing documents" and that it "does not currently have dedicated controls and procedures to manage IROs" beyond its general internal-control system.

Information and sustainability matters addressed by governance bodies

Reference: pages 31-32.

Executive and Senior Management discuss strategic and operational topics with the Executive Board through committees integrated into standing monthly/bi-weekly Executive Board meetings. The SRCC oversees implementation of the Responsible Care Policy, which "currently does not include trade-offs."

The VP Internal Audit & Compliance reports compliance updates to both the SVB and the Executive Board, and the Audit Committee receives a thorough annual compliance report covering whistleblower trends, case categorization, disciplinary measures and estimated damages. The Compliance department also presents annually to the Executive Board and Audit Committee on the Compliance Management System, required to maintain ISO 37001 and ISO 37301 certification.

Integration of sustainability performance in incentive schemes

Reference: pages 31-32.

Borealis runs two incentive plans: the short-term Borealis Incentive Plan (BIP) (grade 12+) and the Long Term Incentive Plan (LTIP) (grade 15+). Both include ESG-linked KPIs – HSSE performance, diversity, employee engagement, Circular Economy Solutions sales volumes, Scope 1 and 2 GHG emissions and renewable energy – plus an HSSE malus/clawback mechanism.

For the Executive Board, 5% of the BIP payout and 7.5% of the LTIP payout depend on sustainability-related targets, approved by the SVB via the Remuneration Committee. Climate-related considerations enter through the Circular Economy Solutions sales, Scope 1/2 emissions and renewable energy metrics, aligned with the targets reported under E1-4.

Statement on due diligence

Reference: page 32.

Borealis maps the core elements of due diligence to the relevant sections of its sustainability statement: (a) embedding due diligence in governance, strategy and business model – ESRS 2 GOV-2, GOV-3, SBM-3; (b) engaging with affected stakeholders – ESRS 2 GOV-2, SBM-2; (c) identifying and assessing adverse impacts – ESRS 2 IRO-1, MDR-P; (d) taking action to address adverse impacts – ESRS 2 IRO-1, SBM-3, MDR-A; and (e) tracking effectiveness and communicating – ESRS 2 MDR-A, MDR-M, MDR-T. No dedicated page-by-page index is given; the mapping is by disclosure section.

Risk management and internal controls over sustainability reporting

Reference: pages 32-34.

Borealis' process for the Annual Report is set out in two documents established in 2025: one covering DMA/IRO analysis, the other the development of the sustainability statement. Each chapter has a Content Owner, Content Provider and second-line Content Provider; the Head of Group Accounting owns the statement's development process, and a CSRD Steering Committee handles strategic decisions on timeframe, responsibilities and the audit process.

Main risks identified: non-compliance with CSRD/EU Taxonomy, reputational/fine exposure from incorrect data, missed legal deadlines, and a qualified assurance opinion. Mitigations include a centralized reporting tool with approval loops, aligned departmental timelines, and regular meetings with the auditor. The Group Risk Officer leads Enterprise Risk Management & Internal Control and reports to the VP Treasury and Funding; the cross-functional Risk Coaches Network (RCN), chaired by the CFO, reported to the Executive Board and Audit Committee twice in 2025.

Strategy, business model and value chain

Reference: pages 34-38.

Borealis produces Polyolefins and Base Chemicals (ethylene, propylene and other base chemical products) at sites in Austria, Belgium, Finland, Sweden, Germany and elsewhere. In 2025 the Supervisory Board approved the "We4C" strategy – re-invented around "Enabling Sustainability," "Delivering Innovative Solutions," "Assuring Peace of Mind" and "Driving Efficiency," with safety, compliance and sustainability as non-negotiable guardrails.

Headcount by country (2025 / 2024): Austria 1,469/1,470, Belgium 1,250/1,265, Finland 940/943, Sweden 1,023/986, Other Europe 875/884, Non-Europe 627/625. The Group had fossil-related revenues of EUR 270 million in 2025 as non-core business, mainly from temporary mitigation of the delayed Kallo PDH2 start-up. Sustainability goal: increase circular product sales to 1.2 million metric tons globally by 2030. Value chain runs from fossil/renewable/waste feedstock, raw materials, energy/utilities and packaging upstream, through own Polyolefins/Base Chemicals operations, to transport, customers, converters, brand owners, retailers, recycling/incineration/landfill and contractors downstream.

Interests and views of stakeholders

Reference: pages 38-41.

Key internal stakeholders are employees, the Works Council and owners (OMV, ADNOC); external stakeholders include customers, suppliers/contractors, capital market participants, NGOs, authorities, communities, industry associations, media and academia, each with mapped interests (e.g. communities: plastic waste, climate change, recycling).

The new We4C Strategy was developed in H2 2024 and received final SVB approval in Q1 2025, driven by a changed market environment: rising European energy/feedstock costs and supply disruption since 2022, a 25%+ cost-base increase 2020-2025, slowing PO demand (an "L-shaped" rather than "V-shaped" recovery), and delayed circularity regulation such as mass-balancing rules. Employee views flow through the yearly Pulse/Temperature Check survey and Works Council dialogue; "the interests, views and rights of value chain workers do not directly flow into Borealis' strategy and business model."

Material impacts, risks and opportunities and their interaction with strategy and business model

Reference: pages 42-57.

Borealis' IRO table (pages 42-52) sets out material impacts, risks and opportunities across E1, E2, E3, E4, E5, S1, S2, S3 and G1; S4 (consumers/end-users) carries no material IROs. In 2025 the Group conducted an IRO update: IROs were "grouped and condensed, resulting in fewer IROs," while new IROs were identified for E3 Water and Marine Resources and E4 Biodiversity and Ecosystems – both newly material for the first time in 2025.

A 2025 climate resilience analysis to 2100 found limited physical risk: under both a realistic intermediate (2.5C) and pessimistic high-emission (4C) scenario, "only 0.4% of the asset portfolio value is at risk in 2030, rising to just 0.5% in 2050, and 0.6/0.8% in 2100." Borealis has not assessed resilience for other material IROs beyond the DMA itself. "No entity-specific topics have been identified." Impacts connected to strategy include E1, E2, E3, E4, E5, G1 and S3 directly; S2 only indirectly (via suppliers); within S1 only health & safety, adequate wages and training/skills link directly to strategy.

Description of the processes to identify and assess material impacts, risks and opportunities

Reference: pages 58-63.

Borealis ran its first ESRS-aligned DMA in 2024 (long-list/short-list, expert interviews, stakeholder engagement, workshop scoring, topic finalization, signed off via the Danish-style structure: reviewed by relevant SVPs, approved by the Executive Board and SVB). In 2025 it conducted an IRO review updating the 2024 assessment rather than a full fresh DMA; the next full revision is planned for 2026. Impact scales run 1-5 (scale/scope/likelihood/remediability plus a human-rights factor); financial materiality uses magnitude (1-3) x probability (1-5), with a financial materiality threshold of 1.5.

Borealis commissioned a site-level climate risk study in 2025 covering 17 production sites against RCP 8.5, 6.0, 4.5 and 2.6 scenarios over 10/30/50-year horizons (decades 2030/2050/2070); most-affected sites include Burghausen (surface water flooding), Renasci (coastal inundation) and Linz (surface/riverine flooding). "No material physical risks were identified" and the study "did not reveal any material transition events." Borealis does not intend to fully integrate the IRO process into its Enterprise Risk Management process, instead cross-informing the two.

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: pages 64-72 (content index); page 72 (materiality note).

Borealis' ESRS content index lists, for ESRS 2: BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2, MDR-A, MDR-M, MDR-T; for the topical standards it lists E1-1 to E1-8 (not E1-9), E2-1 to E2-4 (not E2-5/E2-6) plus an entity-specific microplastics line, E3-1 to E3-4 (not E3-5), E5-1 to E5-5 plus an entity-specific circular-feedstock line (not E5-6), S1-1 to S1-6, S1-8 to S1-14, S1-16, S1-17 (not S1-7 or S1-15) plus an entity-specific S1.14 line, S2-1 to S2-5 plus an entity-specific line, and G1-1 to G1-4, G1-6 (not G1-5) plus an entity-specific line. E4 and S3 carry no DR-level entries in the index because both are reported only at the minimum newly-material-topic level (see E4/S3 disclosures).

On materiality: "Substances of concern and substances of very high concern, as well as pollution of air... and pollution of water, soil, living organisms and food resources... are not material for Borealis because of the low likelihood of incidents, due to high process safety standards... and strict regulatory requirements."

Transition plan for climate change mitigation

Reference: pages 88-96.

Borealis runs two roadmaps: Scope 1+2 (market-based) to 2050, and a newly developed (2025) combined Scope 1+2 (market-based)+Scope 3 (excluding 3.15) roadmap with only a mid-term (2030) target. The combined Scope 1+2 target implies an 18% emissions cut by 2030 versus the 2019 base year despite growth from the new Kallo dehydrogenation plant. Levers: Scope 1 – energy efficiency, electrification, CCUS (post-2030 enabler), hydrogen/biofuels, resource efficiency (flaring reduction); Scope 2 – 100% renewable power by 2030, less CO2-intensive purchased steam/heat; Scope 3 – supplier/customer decarbonization, circular end-of-life treatment.

"The transition plan is not in line with the Paris Agreement" (E1-1.17), because Borealis estimates "a significant amount of residual emissions by 2050" given supply, financial, regulatory and innovation constraints; the combined Scope 1+2+3 roadmap also "lacks a long-term target." As OMV's majority-owned subsidiary, Borealis' emissions are included in OMV Group's own reporting and roadmap, "where increases in Borealis' emissions are expected to be compensated for by decreases in OMV Group's emissions." The Executive Board and SVB approved the Scope 1+2 roadmap to 2030; the 2025 Scope 3 roadmap has Executive Board but not yet Supervisory Board alignment. In 2025 Borealis realized 9,488 t CO2e/year of Scope 1+2 savings (excluding grid power).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (pages 61-62) and ESRS 2 SBM-3 (page 52), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Borealis commissioned a site-level climate risk study in 2025 for its own operations, assessing hazards, vulnerability and risk for 17 production sites against physical hazards (extreme temperature, drought, wildfire, coastal/fluvial flooding, water stress, tropical cyclones) using RCP 8.5, RCP 6.0, RCP 4.5 and RCP 2.6 scenarios over 10/30/50-year horizons (decades 2030/2050/2070) – a high-emissions scenario among those used. Most-affected sites: Burghausen (surface water flooding), Renasci (coastal inundation), Linz (surface/riverine flooding), Stenungsund and Porvoo (soil movement). "No material physical risks were identified."

Transitional risks and opportunities were not assessed within that site-level study but are addressed through the DMA/IRO review (captured in the SBM-3 IRO table's "IRO Type" column); "no scenario analysis has been used to identify transition risks." Capital allocation plans were out of scope for the climate vulnerability study, and Borealis states its "climate scenarios used in the assessment... are not fully aligned with the critical climate-related assumptions made in the consolidated financial statements."

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (page 52), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"In 2025, Borealis conducted a resilience analysis to understand the vulnerability of its assets to climate change until 2100." Under both a realistic intermediate-emission (2.5C) and a pessimistic high-emission (4C) scenario, physical damage risk is limited: "only 0.4% of the asset portfolio value is at risk in 2030, rising to just 0.5% in 2050, and 0.6/0.8% in 2100." Consistent with this, SBM-3's E1 section states that "physical climate-related risks are no longer considered material compared with the previous reporting year," though Borealis "has not yet conducted a resilience analysis for the identified material transition risks" and plans a more in-depth analysis of physical risks, including financial impacts, "over the coming years."

"Borealis has not assessed the resilience of its business model with regard to other material impacts, risks, and opportunities, except insofar as these were addressed within the scope of the DMA."

Policies related to climate change mitigation and adaptation

Reference: pages 96-100.

Five policies bear on climate mitigation: the Responsible Care Policy (CEO-owned, aligned to the Responsible Care Global Charter signed in 2006/2014); the HSE Management System Policy (VP HSE&Q-owned, incorporating ISO 14001/50001/45001); the Energy Management System Policy (VP HSE&Q-owned, ISO 50001); the Commercial Operations for Energy, Utilities and CO2 Emission Allowances Policy (SVP Base Chemicals-owned, covers PPA sourcing and emission-allowance trading, "not aligned to any third-party standards"); and the Mergers and Acquisitions Policy (VP Strategy & Group Development-owned), which requires every M&A due-diligence phase to assess impact on Borealis' corporate carbon footprint, transition plan and climate risk.

These policies collectively address energy efficiency (Responsible Care, HSE Management, Energy Management policies) and renewable energy deployment (the Commercial Operations policy's PPA-sourcing process). "No other areas were identified."

Actions and resources in relation to climate change policies

Reference: pages 100-105.

2025 Scope 1 actions: product compressor improvements (17 GWh/yr, 3.8 kt CO2e), furnace leak reduction (13 GWh/yr, 3 kt CO2e), boiler-stack heat recovery (26 GWh/yr, 5.9 kt CO2e), heat-exchanger replacement (20 GWh/yr, 4 kt CO2e); flaring-avoidance roadmap (25 kt CO2e/yr full potential), with 2025 realizations at Schwechat (steam, 3,500 t CO2e), Stenungsund (reactor pre-heating, 1,100 t CO2e) and Antwerp (chemical heat pump, 930 t CO2e). Investigated: electrification of a gas compressor (73 kt CO2e/yr potential), electrical boilers (114 kt), electric cracker furnaces (96 kt); CCS across multiple plants (1,300 kt/yr potential).

Scope 2: a Belgium PPA for 120 GWh signed in 2025, part of a roadmap to ~600 kt CO2e/yr savings by 2030. Scope 3: supplier engagement, circular-content products and customer/transport decarbonization targeted at 3.3 Mt, 4 Mt, 2.5 Mt and 0.7 Mt CO2e/yr respectively by 2050. CAPEX allocated to Scope 1 decarbonization levers to 2030: EUR 60.3 million; "no significant CAPEX has been allocated specifically for decarbonization levers in Scope 2" or "for the Scope 3 actions." Total realized 2025 Scope 1+2 saving: 9,488 t CO2e/yr.

Targets related to climate change mitigation and adaptation

Reference: pages 106-113.

Mid-term (2030): cut net absolute Scope 1+2 emissions to 2.0 Mt CO2e (2019 baseline: 2.43 Mt). 2025 performance: 2.094 Mt CO2e (68% Scope 1/32% Scope 2); the yearly sub-target of 2.056 kt was not achieved, "primarily because Borealis is not surrendering Guarantees of Origin of renewable power in the regions where it has the highest CO2 intensity/MWh impact." A new 2025 target keeps Scope 1+2 (market-based)+Scope 3 (ex-3.15) "at the same level (+/-5%) in 2030 as 2019" (base 25.6 Mt CO2e).

Long-term (2050): net-zero for Scope 1+2 (90% gross reduction plus 10% neutralization). Yearly targets: ETS emissions capped at 1.510 Mt CO2e in 2025 (achieved 1.404 Mt); CO2 intensity 0.7282 t/t HVC (achieved 0.7472, missed); renewable power 40% (achieved 60%); 115 GWh energy savings (achieved 53 GWh).

"Borealis' Scope 1 and 2 reduction target for 2030 is currently not in line with limiting global warming to 1.5C" per SBTi's Absolute Contraction Approach or OECM; "Scope 3 reduction targets are not in line with the Paris Agreement." The 2050 net-zero target is Paris-aligned. Targets are gross, excluding offsets, though Borealis "will allow for 10% external GHG compensation" if needed. Base year 2019 predates COVID-19 and aligns with majority shareholder OMV. Targets are not externally assured.

Energy consumption and mix

Reference: pages 113-114.

Coal and other fossil fuel consumption are 0 in both years. Energy intensity for the high climate-impact sector (NACE C.20.16, manufacture of plastics in primary forms) was 1,589 MWh/mn EUR in 2025 (2024: 1,619), against total net revenue of EUR 7,591,833 thousand.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 114-119.

2025 gross emissions (t CO2e), vs 2024 / 2019 base: Scope 1: 1,536,798 (2024: 1,599,059; base 1,569,016), 91% EU-ETS covered. Scope 2 location-based: 548,267 (2024: 870,919); market-based: 674,038 (2024: 858,264). Combined Scope 1 + market-based Scope 2: 2,210,835 (90.0% of base). Scope 3 total: 63,679,632 (base 47,681,047); largest categories are Investments (cat. 15): 33,064,319, End-of-life treatment (cat. 12): 12,128,671, Purchased goods/services (cat. 1): 10,314,309, and Use of sold products (cat. 11): 2,052,050. Total market-based GHG: 65,890,467 t CO2e (2024: 54,587,314 – a 21% year-on-year rise, driven largely by investments and end-of-life categories).

GHG intensity: Scope 1 0.202 kgCO2e/EUR; Scope 1+2 (market-based)+Scope 3: 8.679 kgCO2e/EUR (2024: 6.952, a correction for underreported investments). Material Scope 3 categories per the GHG Protocol: 1, 2, 3, 4, 5, 8, 10, 11, 12 and 15; categories 6, 7, 9, 13, 14 excluded as immaterial. Share of Scope 3 emissions from primary (supplier/customer) data: 0% – all mass- or spend-based. Scope 3 category 15 includes Borealis' 36%-owned Borouge and 50%-owned Baystar joint ventures.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 120.

"Borealis will limit GHG neutralization to 10% of its current base-year emissions; however, in the current GHG roadmap carbon offsetting and carbon credits are not planned and are seen as a last resort in case direct emission reduction actions would be delayed." The present Scope 1+2 roadmap foresees no additional GHG neutralization. If neutralization of residual or hard-to-abate emissions is needed, Borealis would use purchased high-quality GHG removal credits from recognized providers, or generate removals within its own operations via BECCS (bioenergy with carbon capture and storage). This is a complete, if currently nil, disclosure: no removals or carbon-credit-financed projects were undertaken in 2025.

Internal carbon pricing

Reference: pages 120-121.

Borealis operates an internal CAPEX shadow-price scheme for ETS-covered emissions, using CO2 forecast prices informed by the IEA's Announced Pledges and Stated Policies (STEPS) scenarios for its base case, and the IEA's Net Zero Emissions by 2050 scenario for its net-zero case. Applied prices: EUR 129-162 per tonne CO2e, on a volume of 1.403 Mt CO2e (EU-ETS perimeter). This covers 91% of Scope 1 GHG emissions; Borealis "has no internal pricing for Scope 2 emissions (0%)." The scheme has not been validated by a third party. Expected additional emission-certificate purchases from 2028 onward are incorporated into the Mid-Term Plan 2025-2030 and allocated to cash-generating units for impairment testing.

Policies related to pollution

Reference: pages 121-123.

Borealis' sole material E2 sub-topic is microplastics: "every Borealis polyolefin (PO) production site produces microplastics in the form of plastic pellets," managed under the CEO-owned Responsible Care Policy, which embeds the Operation Clean Sweep (OCS) Standard – a voluntary industry initiative on plastic pellet/flake/powder loss, administered by a steering committee of the European Commission, EU member states and NGOs.

Key objectives: deploy OCS at all PO sites; obtain external OCS certification for all European PO sites (recycling plants excluded); follow a pellet-loss hierarchy (zero loss from primary containment, mitigate spills, clean up to prevent unrecoverable loss); implement six OCS requirements (worksite setup, internal procedures, training, regular auditing, regulatory compliance, partner encouragement). Each location maintains an annually reviewed risk-management plan covering preventive, containment and cleaning measures, with internal audits and annual external certification audits.

Actions and resources related to pollution

Reference: pages 123-124.

All 10 European polyolefin sites achieved/maintained external OCS certification in 2025 through successful audits (e.g. Borealis Antwerpen N.V. 13.10.2025, Borealis Polymers Oy Porvoo 19.09.2025, Borealis AB 07.05.2025). "Compliance achieved. However, zero pellet loss has not been achieved so far, and all OCS activities therefore fall into the 'reduce pollution' category."

Borealis judges upstream pollution risk negligible: its only plastic-material input is post-consumer waste for recycling, received in pieces "substantially larger than the maximum of 5 mm" for microplastic classification, so "Borealis has therefore not taken action related to pollution occurring in the upstream value chain" beyond supplier ratings. No downstream action is taken. All 2025 OCS actions were either small investments or cost-free, none individually or cumulatively exceeding the EUR 2.5 million threshold.

Targets related to pollution

Reference: pages 124-126.

Target 1: obtain/maintain external OCS certification at all 10 European PO sites for 2025 (baseline 2024: 9) – achieved, all 10 sites certified. Target 2: no more than 1 pellet spill per PO site per year globally (baseline 2024: 7) – not achieved, 5 total spills recorded in 2025 but "one site had two spills" (Borealis Polyolefine GmbH Schwechat).

Both targets were set in 2024 via internal benchmarking against industry best practice, "not based on conclusive scientific evidence," approved by a senior-manager steering committee; "no stakeholders were directly involved in the target-setting process." Target 2 relates to both water and soil pollution given microplastics' non-biodegradability; Target 1 does not. "Substances of concern and substances of very high concern are not material for Borealis" [ESRS 2-IRO-2.58]. All E2 targets are voluntary.

Pollution of air, water and soil

Reference: pages 126-127.

Metrics relate to the material impact of unintentional pellet loss. Microplastics generated as produced plastic pellets: 3,882,689.2 metric tons in 2025 (2024: 4,024,286.9 metric tons). Microplastics emitted as unrecovered pellet spills: 0.01850 metric tons in 2025 (2024: 0.01800 metric tons) – an entity-specific datapoint, with spills tracked in the Synergi Life incident tool and weights mostly estimated during on-site investigation.

Data collection on pellet-spill incidents began in 2024 with OCS rollout. Borealis notes "there are currently no standardized, scientifically recognized methods or tools available for directly measuring and quantifying the amounts of unrecovered pellets," pending a proposed EU Regulation (2023/073 (COD)) and REACH Annex XVII amendment it will adopt once finalized. For European PO sites the metric is externally validated during OCS certification.

Policies related to water and marine resources

Reference: pages 128-131.

Water use (cooling, steam generation, product handling) is managed under the Responsible Care Policy and the Environmental Management Process, requiring every operational site to develop a water management plan covering resource identification, monitoring, target-setting/KPIs ("reduce-reuse-recycle") and risk assessment; a high-level external water-risk screening runs every three years. The plan templates were established only in 2025.

"To date, Borealis has not made a consolidated effort to address environmental topics such as water in its product and service design." Current policy carries no specific commitment to reduce consumption in water-risk areas, pending completion of a priority-location evaluation expected by end-2026. On oceans: "Borealis has no sites offshore," though some sites discharge wastewater to the sea under strict permits; OCS (see E2) addresses marine plastic-pollution prevention directly.

Actions and resources related to water and marine resources

Reference: pages 130-131.

Four workstreams: (1) all sites will complete water management plans in 2026 as part of the HSSE Plan 2026; (2) an ongoing analysis of water-risk/high-water-stress areas, with priority-location targets to be set by end-2026; (3) a new environmental and energy data management tool rolled out in 2025 covering all water data from withdrawal to discharge, full implementation expected by end-2026; (4) a dedicated Water Network Team of cross-disciplinary experts managing water integrity, reuse/recycling and risk.

All actions focus on polyolefin production sites including recycling facilities; "all actions related to water in 2025 were either small investments or without cost", none exceeding the EUR 2.5 million threshold individually or cumulatively.

Targets related to water and marine resources

Reference: page 131.

"Borealis acknowledges that specific targets for water and marine resources have not yet been established" – due to water's recent (2025) identification as a material topic. The Group is conducting a comprehensive impact evaluation, expected complete by end-2026, after which target-setting will begin. In the interim, effectiveness is tracked through: embedding water management plans in Group/site HSE scorecards linked to performance incentives from 2026; Water Network Team activities reviewed regularly with senior management; and internal/external ISO 14001 audits and management-system reviews. This is a nil-target disclosure with a stated timeline and interim monitoring mechanism, not a gap left unexplained.

Water consumption

Reference: pages 131-132.

2025 water indicators (Mm3 unless noted): Water consumption 2.7; Water consumption in areas at water risk/high water stress 1.9; Water recycled and reused 0.1; Water withdrawals 566.5; Water discharges 563.7; Water intensity ratio 0.0005 Mm3/kg; Water consumption per net revenue 0.3594 m3/mn EUR. Water storage is "not relevant for Borealis" and storage changes are nil. 2024 comparatives are unavailable – "water metrics were established in 2025."

Consumption is derived as withdrawal minus discharge, which Borealis flags may underestimate actual consumption because rainwater is discharged with effluent without a matching withdrawal figure, and steam-process condensate exits as effluent without being captured in withdrawal data. Reused/recycled volumes from sequential water use and semi-closed cooling loops "cannot be measured" due to system complexity. Withdrawal/discharge figures are externally validated via environmental permits.

Policies related to resource use and circular economy

Reference: pages 133-134.

Borealis' Overarching Circular Economy Policy aims to "gradually replace non-renewable, fossil-based resources with renewable or recycled ones," spanning own operations, upstream suppliers and downstream customers. Entity-specific circular-economy KPIs were derived from the strategy in 2022. Policy objectives: collaborate closely with customers on circular products; continue building a broad circular solutions portfolio; develop Borealis' sustainability-driven business as a global polyolefin leader. The Executive Board holds overall accountability; the VP Circular Economy Solutions has operational responsibility.

Borealis runs four mechanical recycling operations and one chemical-recycling company (producing pyrolysis oil, used at its German and Finnish sites), plus renewable feedstock use at sites in Finland, Sweden, Belgium, Germany, the Netherlands and Austria.

Actions and resources related to resource use and circular economy

Reference: pages 134-136.

2025 actions: full integration of mechanically-recycled-plastics acquisition Integra Plastics (Bulgaria), with a further capacity investment announced; divestment of mtm compact for lack of synergies; a new mechanical recycling plant in Austria put on hold due to unfavorable economics; a partnership with Infinium on carbon-capture-and-utilization (CCU) feedstock, launching a first CCU foam application with Fullstride Ventures; Borealis Compounds Inc. (USA) gained ISCC PLUS certification to offer Bornewables/Borcycle into North America; launch of the global mechanical-recycling brand Recleo (unifying Borealis and Borouge portfolios) in December 2025.

Collaborations: Alba, Neste, Tomra and Reclay (upstream); brand owners, converters and infrastructure firms (downstream); the Finnish SPIRIT circularity program (concluded end-2025); Bornewable PP pens with Gehr/Stabilo; Borcycle C yoghurt cups with Valio; a recycled-content Persil pouch with Korozo/Henkel. Borealis has opted to omit certain IP/know-how-sensitive detail on resources allocated to the circular economy.

Targets related to resource use and circular economy

Reference: pages 136-137.

Target: 1.2 million metric tons of circular product sales by 2030, covering upstream waste collection/sorting and biowaste processing across all global operations. The target is based on internal/external data and yield-extrapolation assumptions (not scientific evidence) because "methodological uncertainties make it difficult to set a precise and credible target for the share of circular feedstock"; stakeholders were not directly involved in setting it, though Borealis is a long-standing Ellen MacArthur Foundation partner. Borealis changed one target/metric/methodology during 2025.

Performance: waste volume processed fell 0.9%, which under "very tough recyclate market conditions due to the low price of fossil-based materials... can be considered a good result." The targets relate to increasing circular material use, minimizing primary raw-material use, sustainable sourcing of renewables, waste diversion, and GHG reduction – but not to circular product design.

Resource inflows

Reference: page 138.

Fossil inflows: natural gas, oil, monomers and naphtha. Circular inflows: sorted waste bales/flakes for mechanical recycling, and insourced recyclates (pyrolysis oil, circular naphtha, bio-propane, bio-diesel, bio-naphtha, e-naphtha). Total weight of products/materials used in 2025: 6,092,149 metric tons (2024: 5,742,250). Biological materials used: 12,700 t (2025), 0.21% of total (2024: 19,700 t, 0.34%), certified via ISCC PLUS. Secondary (recycled feedstock) materials: 175,012 t, 2.9% of total (2024: 191,800 t, 3.34%), certified via ISCC PLUS (chemical) and Recyclass (mechanical).

"No assumptions are used in these calculations. The weight figures are direct measurements, taken from suppliers' documentation, and are regularly checked." There is no external validation of Borealis' internal data-aggregation process beyond the certification schemes.

Resource outflows

Reference: page 139.

Borealis sells polyolefin pellets and base chemicals (monomers, phenol, aromatics), which may be fossil-, recycled- or renewable-based; products are classified as circular once more than 25% of content is renewable or recycled. "Borealis' products are 100% recyclable before the Group's customers convert them into end products," though post-conversion mixing with incompatible/inseparable components can impair recyclability.

The single reported metric is the Group's total circular-solutions capacity (circular sales volume of polymers and chemicals by recycled/renewable content), recorded in SAP (full integration scheduled 2026) and validated via a "multiple eyes" principle between financial controllers and content owners. Entity-specific: 219,240 metric tons of circular feedstock processed in 2025 (2024: 221,200; 2022: 117,000) – down 0.9% year-on-year but up 87% versus 2022.

Policies related to own workforce

Reference: pages 140-143, 158-161 (Health & Safety).

Governance documents are collated in the Borealis Management System (BMS): the Borealis P&C Standard, the Borealis People Policy (defining the employer-employee relationship framework), and a set of Group operative instructions (reward, talent acquisition, training, payroll, promotion, home-working). The SVP P&C, reporting to the CEO, is accountable for implementation; policies apply Group-wide unless local law requires variation.

Human-rights commitments: Borealis has signed the UN Global Compact, commits to the UN Guiding Principles, and names eight specific ILO Conventions (freedom of association Nos. 87/98, forced labor Nos. 29/105, child labor Nos. 138/182, equal remuneration No. 100, non-discrimination No. 111). The Responsible Care Policy forms the Health & Safety policy framework, committing Borealis to be "a recognized leader in Responsible Care" with zero-harm ambitions, underpinned by ISO 45001 certification covering 84% of the workforce.

Processes for engaging with own workforce and workers' representatives about impacts

Reference: pages 143-144.

Engagement channels: regular local Works Council / local P&C Business Partner meetings; regular SVP P&C / European Works Council meetings (Borealis sits within OMV Group's European Works Council); an annual Executive Board location tour, with every site visited once a year; and the yearly Pulse/Temperature Check employee survey on retention, values, wellbeing and leadership. A P&C Business Circle, established 2024, gives the business a forum to test P&C concepts.

The SVP P&C oversees engagement effectiveness, assessed via the Pulse/Temperature Check's retention score and feedback clusters, analyzed at Group, location and (for managers with 10+ responses) individual level. DE&I engagement runs through interactive training, events (Positively Purple, International Women's Day, Pride), a DE&I playbook, LGBTQIA+ lunches and employee resource groups staffed by volunteer ambassadors and Works Council representatives.

Processes to remediate negative impacts and channels for own workforce to raise concerns

Reference: pages 144-145.

Borealis operates an independent Ethics Hotline (grievance mechanism) open to employees and external stakeholders; every new employee receives ethics training on it, and every white-collar employee completes an annual ethics certification confirming they have reported any witnessed or suspected policy violations. Effectiveness is assessed by monitoring feedback, resolution timelines and recurrence, triggering additional training where issues recur.

Alternative channels exist for employees who prefer a different route: line manager, engagement walks, P&C Business Partner, or the Works Council. Borealis extends whistleblower protection to all internal and external reporters, irrespective of local legal minimums, regardless of the criteria described under G1-1.

Taking action on material impacts on own workforce

Reference: pages 145-148, 164-167.

2024/2025 actions tracked through to completion: the Pulse Check 2024 follow-up (actions across Belief/Empowerment/Leadership/Values/Grow/Flexibility categories, e.g. a new organization live April 2025, a Cross-Border Working Policy, an internal-marketplace pilot launched Q4 2025); recurring GDPR/human-rights/ethics training; an Equal Pay and CSRD analysis process preparing for the EU Pay Transparency Directive; a new Flexible Working Policy (2025); a P&C internal-marketplace pilot for career opportunities.

Planned for 2026: harmonizing the BIP/LTIP incentive plans, a Global Mobility Policy, and rolling out the "Grow Together" people-development platform. "The actions listed above do not require significant operational or capital expenditures." P&C process owners sit in five Centers of Excellence (Growing Talent, New Ways of Working & Reward, Organizational Evolution, Strategy & Transformational Leadership, Employee Experience & Digital Transformation).

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: pages 149-150.

Target: increase the proportion of employees with a disability at the Vienna Head Office (2024 baseline: 0.6%; 2025 performance: 1.2%). A Network for Accessibility was established, centered on the Positively Purple event. The KPI was proposed by the DE&I Accessibility substream and signed off by the Executive Board; as a new 2025 target there is no multi-year trend yet. A planned +1% Pulse Check inclusion-score target for 2025 was not introduced, following a decision to exclude diversity questions from the 2025 Temperature Check. Performance is tracked monthly to flag whether the Group is above, below or on target.

Characteristics of the undertaking's employees

Reference: pages 150-152.

Total headcount: 6,184 in 2025 (2024: 6,173) – 4,751 male, 1,433 female. By type: 6,044 permanent / 140 temporary; 5,575 full-time / 609 part-time (2024: 6,032/141; 5,600/573). Borealis employs no non-guaranteed-hours workers. By country (2025/2024 headcount): Austria 1,469/1,470, Belgium 1,250/1,265, Finland 940/943, Sweden 1,023/986, Other Europe 875/884, Non-Europe 627/625.

Employee turnover: 11% – 698 employees left in 2025 (average headcount basis, excluding the divested mtm compact GmbH, 16 employees at divestment). Leaver categories include end of temporary contract, reorganization, resignation, termination and retirement; internal moves between Borealis legal entities are excluded from the count.

Collective bargaining coverage and social dialogue

Reference: pages 152-154.

87% of Borealis employees are covered by collective bargaining agreements. Coverage is 80-100% in Austria, Belgium, Finland, Sweden and "Other Europe" (Bulgaria, Croatia, Czech Republic, Poland, Romania, France, Germany, Italy, Netherlands, Spain); coverage is 0-19% in the Non-Europe region. Workplace representation (EEA) is 80-100% across Austria, Belgium, Finland, Sweden and Other Europe.

Borealis participates in OMV Group's European Works Council, with Borealis employee representatives proportionate to their share of total workforce, and maintains long-standing local employee-representative relationships in each country of operation.

Diversity metrics

Reference: pages 153-154.

Top management (Executive Board): 5 members, all male (100%) – unchanged from 2024. Career levels run Executive / Advanced (grade 14-21) / Core (grade 11-13) / Primary (grade 8-10) / Entry (grade 1-7), standardized across OMV Group for ESRS reporting purposes.

Age distribution (2025 / 2024): under 30: 719 (11.6%) / 709 (11.5%); 30-50: 3,458 (55.9%) / 3,421 (55.4%); over 50: 2,007 (32.5%) / 2,043 (33.1%).

Adequate wages

Reference: page 154.

"Borealis is committed to respecting local laws and does not pay salaries below the local legal minimum wage, as stated in collective labor agreements or similar regulations." This is a brief, single-paragraph disclosure with no quantified living-wage benchmarking or gap analysis, and no country-by-country breakdown beyond the general commitment.

Social protection

Reference: page 154.

All Borealis employees are covered by social protection for sickness, unemployment, employment injury/disability, parental leave and retirement – via public programs in all countries except where noted: sickness (organizational benefit in the Netherlands and US); injury/disability (organizational in South Africa and US); parental leave (no coverage in Brazil and US); retirement (organizational benefit in the UAE). Unemployment coverage is public in all countries and starts upon employment.

Persons with disabilities

Reference: page 154.

Percentage of employees with disabilities: 1.02% as of December 31, 2025, subject to legal restrictions on data collection. No gender split is available "due to the limitations imposed by GDPR." Methodology: an inventory across all legal entities and countries, applying each jurisdiction's own legal definition of disability.

Training and skills development metrics

Reference: pages 155-156.

Average training hours per employee: 24 in 2025 (female 19, male 26; unchanged from 2024's 24, though the gender split shifted from 20/25). By employee category (2025 hours): Entry 28, Primary 25, Core 19, Advanced 14, Executives 4, Not Classified 38.

Performance and career-development review participation (2024 data, most recent reported): 82% overall (female 87%, male 81%), down from 85% in 2023. By category: Entry 73%, Primary 90%, Core 91%, Advanced 92%, Executives 100%, Not Classified 43%. Certain recently acquired entities (Ecoplast, mtm plastics, DYM Solution, Integra Plastics, Rialti, Renasci) have no performance-management system in place.

Health and safety metrics

Reference: pages 171-172 (Health & Safety sub-chapter).

100% of own workforce and non-employees are covered by an HSE management system based on legal requirements or recognized standards. Zero work-related fatalities among own workforce in both 2025 and 2024; one fatality among other workers (value chain) on Borealis' sites in 2024, none in 2025. Recordable work-related accidents: 44 for employees (rate 4.10/1mn hrs) and 2 for non-employees (rate 10.20), versus 2024's 33 (3.31) and 4 (11.67).

Group KPIs: Total Recordable Incident Rate (TRIR) 3.80 against a 3.50 target (2024: 3.80 vs 2.50 target); Process Safety Event Rate (PSER) 0.71 against a 0.50 target (2024: 0.41). Lost Workday Injury Rate fell to 2.1 (2024: 2.6); First Aid Injuries 191 (2024: 220); Near Misses 7,872 (2024: 7,674). 84% of the workforce is covered by ISO 45001 certification; 100% by Borealis' internally certified HSE management system. The specific datapoints on work-related ill-health days lost [S1-14.88d,e] are deferred under the ESRS "quick-fix" phase-in election (page 24).

Compensation metrics (pay gap and total compensation)

Reference: pages 156-157.

Gender pay gap: -1.17% in 2025 (2024: 3%), calculated on contractual base salary plus short- and long-term incentive plans and contractual working hours, using the ESRS-required methodology. Annual total remuneration ratio (highest-paid individual to median, excluding the highest-paid individual): 1:14.66. All 6,184 employees were included in the calculation; shift allowance and overtime were considered, but benefits in kind (cars, private health insurance, wellness programs) were excluded. "Borealis is a privately held company and does not have stock options."

Incidents, complaints and severe human rights impacts

Reference: page 157.

2025 (vs 2024): Incidents of discrimination: 14 (24); complaints filed through own-workforce concern channels: 79 (90); complaints to OECD National Contact Points: 0 (0); material fines/penalties/compensation for social/human-rights violations: 0 (0). Zero severe human rights issues or incidents connected to own workforce in either year, and consequently zero related fines and zero cases requiring Borealis to secure remedy. Data is sourced from Ethics Hotline cases, each assessed for workplace-inequality, discrimination or other human-rights relevance.

Policies related to value chain workers

Reference: pages 173-176.

Three documents govern value-chain-worker rights: the Ethics & Integrity Policy, the Borealis Code of Conduct, and the Social Compliance Framework (covering Borealis GmbH and its consolidated subsidiaries). Contractors, suppliers and business partners must acknowledge these as part of their contracts; Borealis can terminate relationships over sustained non-compliance. Commitments (per the Code of Conduct) include freedom of association, no forced/child labor, non-discrimination, fair wages, indigenous rights, 14-week minimum maternity leave (ILO 183), conflict-free minerals, and alignment with the Voluntary Principles on Security and Human Rights.

The Executive Board is accountable; day-to-day implementation sits with the Group Compliance team, supported by a network of more than 80 Ethics Ambassadors globally. The Compliance Management System is certified to ISO 37301:2021 and ISO 37001:2025. The Social Compliance Framework is reviewed on a three-year cycle incorporating stakeholder feedback.

Processes for engaging with value chain workers about impacts

Reference: pages 176-177.

Engagement occurs through planned/structured checks (site access control) and event-driven checks (audits), plus site-access-training sessions where every value chain worker is made aware of Borealis' social compliance ambition and reporting channels. Workers can use the whistleblower hotline, or engage directly during field walks/spot checks, including social-compliance walks led by the Group Compliance team, with findings shared with site operations.

Operational responsibility is split between the business, Procurement and HSE&Q; overall oversight sits with the VP HSE&Q and VP Sustainability & Public Affairs (reporting to the CEO) and the Chief Procurement Officer / VP Treasury and Funding (reporting to the CFO), with the VP Internal Audit & Compliance providing risk-based oversight for workers on Borealis' premises.

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: pages 177-178.

Value chain workers can report (including anonymously) through the structured grievance mechanism described under G1-1, assessed against the UN Effectiveness Criteria by independent external professionals. Business partners are contractually expected to provide their own accessible grievance mechanisms and to cascade due-diligence requirements to their own suppliers. Borealis also runs Together for Sustainability (TfS) audits and regular HSE audits.

Workers are informed of the whistleblower hotline during site-access training and via printed Speak-Up Cards. "Borealis does not have any dedicated KPIs or metrics assessing value chain workers' awareness and trust of Borealis' grievance processes." In 2025, 75 reports concerning value chain workers were received, covering issues such as fair wages and safe working conditions.

Taking action on material impacts on value chain workers

Reference: pages 178-182.

Key actions: Ethics & Integrity Policy/Code of Conduct embedded in supplier prequalification since 2022; annual safety programs and audits with Deloitte, TfS auditors and EcoVadis; mandatory three-year-cycle human-rights e-learning; updated Ethics & Integrity Policy/Code of Conduct (2025); triennial Social Compliance Framework review; risk-based site-access checks; continuous third-party due diligence. At year-end, 24.61% of contractors were ISO 50001 certified and 68.88% ISO 14001 certified.

2025 activity: 75 external reports received; 5 EcoVadis/climate-change training sessions; an Internal Audit on-site audit at Borouge (UAE); 23 TfS sustainability audits, of which 17 resulted in a corrective action plan. "There were no material impacts falling within Borealis' area of responsibility in 2025, so no actions were taken on the Group's behalf" – though Borealis did act as mediator on multiple ethics cases involving external companies. Zero severe human rights incidents in the upstream value chain in 2025.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 185.

Target (via OMV's TfS membership): cover 80% of Group-level procurement spend with EcoVadis sustainability evaluations by 2025 (2022 baseline: 36%) – achieved, reaching 80% in 2025 (2024: 65%). A parallel 80%-by-2030 target (2021 baseline: 33%) continues under an 80/20 supplier-spend approach, focused on suppliers from high-risk countries (e.g. South East Asia) for TfS audits.

The target was set via OMV Group/TfS consultation and approved by the OMV Executive Board; "the Group did not engage directly with workers in the value chain" in target-setting. 2025 entity-specific metrics: 900 suppliers with a valid EcoVadis score (2024: 368); 78% of reassessed suppliers improved their score (2024: 67%); 0.4% of assessed suppliers disqualified for negative environmental impacts; 154 whistleblower reports Group-wide (2024: 285).

Business conduct policies and corporate culture

Reference: pages 187-193.

Three documents cover ethical conduct: the Ethics & Integrity Policy (five objectives: act correctly, honestly, with respect, with fairness, and protect the company), the Code of Business Ethics (anti-bribery/fraud, conflicts of interest, gifts, transparency) and the Code of Conduct (climate, natural resources, health & safety, human rights, ethical practice). All three are available in ten languages across the global workforce and extend contractually to suppliers and business partners.

Corporate culture is monitored through ethical standards/training, leadership accountability, the confidential "Integrity" whistleblowing platform (hosted by EQS, 24/7, 24 languages), an Ethics & Integrity Committee, regular audits, and continuous improvement. Every white-collar employee completes an annual Ethics Certification. The Whistleblower Platform complies with the EU Whistleblower Directive (2019/1937); reports trigger a mandatory 7-day acknowledgment and a 90-day investigation timeline, reviewed quarterly by the Executive Board and annually by the Audit Committee.

Management of relationships with suppliers

Reference: pages 193-194.

Borealis has no formal late-payment-prevention policy but designs its purchase-to-pay process to pay "on the due date and not later," via automated daily payment runs with segregated invoice-recording and payment-approval duties. Suppliers seeking early payment can join the Dynamic Discounting Program; delayed or unpaid invoices can be raised through the standard complaints process.

Supplier prequalification was enhanced in 2025 with ethics, whistleblowing and human-rights questions. Procurement's commercial bid evaluation includes the bidder's EcoVadis Score; the Sourcing Council decides whether to add product-related sustainability criteria and sets their weighting. All suppliers undergo due diligence (sanctions/watchlist/adverse-media screening, due-diligence questionnaires) before the relationship begins.

Prevention and detection of corruption and bribery

Reference: pages 194-196.

Borealis rejects corruption and bribery "in all forms," enforced through the Ethics & Integrity Policy and a dedicated anti-bribery/anti-corruption instruction. Investigators sit within the Group Compliance team, separate from the management chain involved in any matter; the Committee provides quarterly updates to the Executive Board. All employees complete general ethics e-learning covering bribery/corruption; staff in at-risk functions (Procurement, Sales, Customer Service, Logistics, Legal, Treasury, Group Tax, Executive/Senior Management, etc.) complete dedicated anti-bribery e-learning.

2025 training coverage: 207 at-risk administrative/management staff trained (2024: 323; computer-based, 0.5 hours, annual). A new Approvals module for registering gifts, conflicts of interest, invitations and publications was implemented in the Integrity tool in 2025. "It should be noted that the implementation of [action] is partially delayed, as the CSDDD directive is postponed."

Targets related to business conduct (part of MDR-T/GDR-T disclosures)

Reference: pages 195-196.

Borealis has no single stated numeric "target" for business conduct, but tracks effectiveness through a dedicated "Metrics and Targets DR related to G1 Business Conduct" section with year-on-year monitoring: percentage of employees completing the Ethics e-learning rose to 93% in 2025 (2024: 85%); ethics reports filed through the whistleblower hotline by own workforce: 79 (2024: 62); ISO 37301/37001 non-compliances or recommendations: 2 (unchanged); average days to pay an invoice: 60.31 (2024: 56.70); late payments beyond the 60-day term: 7.18% (2024: 11.09%); legal proceedings for late payment: 1 (unchanged).

Effectiveness is further tracked via regular internal/external audits, Ethics & Integrity Committee review of substantiated investigations, and annual Audit Committee reporting on compliance and ethics outcomes (G1-1, pages 190-192). This is a 2023-ESRS report; the report provides the MDR-T "effectiveness tracked" limb rather than a single stated target.

Incidents of corruption or bribery

Reference: pages 196-197.

"Borealis has never been convicted for violating anti-corruption laws." As no breaches occurred, no remedial actions were necessary, though regular risk-based training continues for at-risk staff and a new Approvals module (gifts, conflicts of interest, invitations, publications) was implemented in the Integrity tool in 2025. No significant CAPEX or OPEX was incurred for these purposes; training used internally available resources. This is a nil/clean disclosure rather than an omission – the ESRS content index lists G1-4 with a page reference (196-197).

Payment practices

Reference: page 197.

Borealis "treats suppliers equally and does not differentiate between SMEs and other suppliers with regards to payments." Standard payment term for the procurement organization: 90 days end of month, second business day (changed from a shorter term in September 2025). Payment-term split by category (value-based %, 2025): Base Chemicals 53.53% (0-60 days), Procurement 33.94% (30-180 days), Non-Procurement 5.75% (0-60 days), Logistics 6.79% (30-60 days).

Average days to pay an invoice: 60.31 (2024: 56.70, restated for a calculation change); late payments (beyond the 60-day standard term): 7.18% (2024: 11.09%); legal proceedings for late payment: 1 in both years.