MOL Hungarian Oil and Gas Plc.

Reference: page 142

MOL Group's governance structure is described in the Corporate Governance Declaration. The Financial Risk Committee (FRC) and the Sustainable Development Committee (SDC) oversee impacts, risks and opportunities. The SDC approves the Double Materiality Assessment and ensures management systems and rules of procedure are in place to achieve sustainability goals, while the FRC monitors financial and operational risks including the Enterprise Risk Management system. Members of the Supervisory Body attend FRC and SDC meetings to provide oversight. Roles and responsibilities are set out in the Charter of the Committees operated by the Board of Directors of MOL Plc. Executive management assesses and manages climate related risks across roles including Group Strategy, Chief Economist, Public and EU Regulatory Affairs, the SE department and Investor Relations. The Board of Directors defines business objectives and reviews strategy, integrating climate related risks, and receives regular updates. The Board typically meets six times per year and the SDC four times per year. Reported diversity data show the Supervisory Board and Board of Directors were 95.5 percent male and 4.5 percent female in 2024, with 81.8 percent over 50 years of age.

Reference: page 142

The Board of Directors communicates through the Chairman CEO, who implements resolutions and reports on company affairs. The Board receives updates on strategic issues and capital market developments and evaluates business unit performance. The Board, its committees and individual Board members may request information or opinions from any unit or employee, provided they inform the Chairman CEO at the same time. The Board regularly reports to the Supervisory Board on management, financial situation and business policy. The Supervisory Board receives briefings from Internal Audit and detailed information on major business areas including Strategy and Business Development, Investor Relations, Corporate Relations and Regulatory Affairs, Human Resources, Group Compliance and Ethics, Group Security and Cybersecurity. Governance is carried out through the Chief Executives' Committee (CEC) and the Management Committee (MC); the CEC adopts strategic decisions and the MC links the CEC with the work organisation. The SDC monitors progress against sustainability goals with regular reports from the Group Vice President of Health, Safety and Environment and the Head of Investor Relations and ESG Coordination. The Board of Directors and SDC receive a wide range of sustainability related topics as reports or proposals at each meeting.

Reference: page 152

MOL Group addresses the integration of sustainability related performance in incentive schemes under ESRS 2 GOV-3. In the List of Disclosure Requirements complied with in preparing the sustainability statement, this disclosure requirement is incorporated by reference to the Corporate Governance Declaration, section 8. The reader is directed to that section of the management report for the description of how sustainability related performance is reflected in the company's incentive arrangements.

Reference: page 152

MOL Group provides its statement on sustainability due diligence under ESRS 2 GOV-4. In the List of Disclosure Requirements complied with in preparing the sustainability statement, this disclosure requirement is mapped to the G1 chapter, Sub chapter B on supply chain management. The list of datapoints deriving from other EU legislation confirms that the statement on due diligence is a datapoint under the Sustainable Finance Disclosure Regulation and is located in the supply chain management section, which sets out the company's due diligence approach across its business relationships and value chain.

Reference: page 152

MOL Group discloses risk management and internal controls over sustainability reporting under ESRS 2 GOV-5. In the List of Disclosure Requirements complied with in preparing the sustainability statement, this disclosure requirement is mapped to the Oversight on sustainability related issues section and to the Integrated Risk Management section. Risks related to sustainability matters are identified through the Group's Enterprise Risk Management process, which follows the Group Risk Management Policy and takes a bottom up approach where Risk Owners and Risk Sponsors list relevant risks in their domain. The Financial Risk Committee monitors financial and operational risks including the ERM system, providing the basis for controls over the information reported in the sustainability statement.

Reference: page 152

MOL Group discloses its strategy, business model and value chain under ESRS 2 SBM-1. In the List of Disclosure Requirements complied with in preparing the sustainability statement, this disclosure requirement is incorporated by reference to the Management Discussion and Analysis section of the report. The Group's double materiality assessment, and therefore its sustainability statement, covers the upstream and downstream value chain, with relevant policies, actions, targets and metrics reported accordingly. The views and expectations of key stakeholders informed MOL Group's Shape Tomorrow Strategy, which includes sustainability related targets disclosed in the respective topical chapters. The list of datapoints from other EU legislation notes that involvement in fossil fuel activities and in chemical production are reported in the Management Discussion and Analysis, while involvement in controversial weapons and in tobacco cultivation and production is marked as not relevant.

Reference: page 144

The groups of stakeholders MOL Group regularly engages with are described in the Stakeholder Engagement section of its website and include, but are not limited to, shareholders, employees, customers, suppliers, professional associations, local communities and authorities. Beyond regular engagement by specialised functional departments and business owners, the ESG Coordination department conducted a broad internal and external stakeholder engagement exercise in autumn to gather information supporting the materiality assessment. Internal stakeholders were selected to represent the corporate structure (Downstream, Upstream, Consumer Services and Corporate Functions) and the geographic structure (Group level divisions, MOL Hungary, Slovnaft and INA). External stakeholders shortlisted to assess the Group's impact included investors and financial analysts, creditors and banks, affected communities, regulators and non governmental organisations. Tailored questionnaires were sent and in depth interviews conducted with high priority stakeholders. Results were consolidated by weighting each stakeholder type equally. These findings formed the foundation for the Double Materiality Assessment and ensured continuity with the previous GRI based materiality methodology. Stakeholder views also informed the Shape Tomorrow Strategy.

Reference: page 149

MOL Group's double materiality assessment produced a list of 23 impacts (IM-01 to IM-23), 12 risks (RK-01 to RK-12) and 11 opportunities (OP-01 to OP-11). All ten topical standards were assessed as material: E1, E2, E3, E4, E5, S1, S2, S3, S4 and G1. Material impacts include contribution to the transition to a low carbon economy, effect on climate, effect on air quality, spills, water discharges, waste generation, work related injuries and road accidents, human rights and labour practices in the value chain, and risk of data exposure. Material risks include increased cost of greenhouse gas emissions, risks related to new energy efficiency and renewable energy regulations, exposure to security threats, risk of fraud and risk of information and cyber security incidents; three risks were assessed as currently non material. Material opportunities span green hydrogen production, waste management services, sustainable chemicals, renewable energy production, e-charging network, sustainable aviation fuel and biogas production. The Materiality Matrix maps ESRS 1 AR 16 topics tailored to MOL Group and adds entity specific topics: Disturbance of local communities, Shared wealth and economic impact, and Cyber security. Detailed IRO descriptions appear at the start of each topical standard.

Reference: page 145

In the reporting year MOL Group introduced a new Double Materiality Assessment (DMA) methodology to comply with CSRD requirements, following EFRAG's Materiality Assessment Implementation Guidance. The focus shifted toward identifying material impacts on people and the environment and the financial risks and opportunities related to sustainability matters. Impacts were identified first, building on survey based stakeholder engagement, due diligence findings, peer and sector studies and deep dive workshops with internal subject matter experts, and were rated by severity (scale, scope and irremediable character), likelihood and time horizon. Risks were identified through the Enterprise Risk Management process under the Group Risk Management Policy, using a bottom up approach with Risk Owners and Risk Sponsors, with likelihood and financial effect determined for each ESG risk. Opportunities were drawn from the Shape Tomorrow Strategy and management insights, classified by maturity and expected financial effect. Materiality of each IRO was determined using scale, likelihood and scope against defined thresholds. The assessment was validated by internal subject matter experts and key external stakeholders, the results were validated by the Board of Directors, and the methodology was approved by an external auditor. The matrix adds entity specific topics: Disturbance of local communities, Shared wealth and economic impact, and Cyber security.

Reference: page 152

The primary aim of the DMA is to determine which Disclosure Requirements are elaborated in the Sustainability Report. MOL Group assigned the relevant disclosure requirement to each IRO on its final list, consulting EFRAG's document Links between AR16 and Disclosure Requirements (ID 177). Generally, where at least one material IRO was matched to a disclosure requirement, that requirement was considered material and included; the Materiality Matrix and relevant IROs were also used to judge materiality at the sub paragraph level. The chapter provides a List of Disclosure Requirements complied with in preparing the sustainability statement, mapping each ESRS 2, E1 to E5, S1 to S4 and G1 disclosure requirement to its location in the report or noting where it is omitted as not material or under phase in provisions. A further list sets out datapoints in cross-cutting and topical standards that derive from other EU legislation such as SFDR, the EBA Pillar disclosure requirements, the Climate Benchmark Standards Regulation and the EU Climate Law. Deloitte provided limited assurance over the sustainability statement and reasonable assurance over two selected KPIs: Scope 1 CO2 emissions under ETS and TRIR.

Reference: page 160

MOL Group disclosed its transition plan for the first time in the 2024 sustainability statement, expanding on its updated Shape Tomorrow Strategy. The plan was approved by the Sustainable Development Committee and the Board of Directors and adopted by the Annual General Meeting. The targets are to decrease absolute gross Scope 1 and Scope 2 (location based) emissions against a 2019 baseline, decrease absolute Scope 3 use phase emissions of sold energy products (Category 11) against a 2022 baseline, reach net zero greenhouse gas emissions on all scopes by 2050, and allocate 50 percent of total CAPEX to low carbon and sustainable business projects. The 2019 baseline was 6.9 mn tonnes CO2eq for Scope 1 and a separate value for location based Scope 2. Key decarbonization levers are energy efficiency, electrification and renewable energy, sustainable feedstocks and products, and carbon capture solutions, with carbon removals scaled up after 2030 to reach net zero. The plan is built mainly on the Steady Transition scenario.

Reference: page 171

MOL Group manages climate related impacts, risks and opportunities through policies at three layers. At the strategic level, the Shape Tomorrow Strategy Review approved by the Board in 2024 sets the climate neutrality commitment of net climate neutrality by 2050, sustainable transformation of Downstream operations, advancing biogas and hydrogen value chains, renewable energy and circular economy, green mobility, and decarbonizing exploration and production. At the business unit level, each unit defines its approach in Area Books, including the Downstream Production Area Book, the Renewables and Energy Efficiency Management Area Book aligned with ISO 50001, and the Circular Economy Services Area Book. At the environmental regulation level, the Group HSE and Social Impact Policy and the HSE Management System govern greenhouse gas matters under Element 7 Environmental Stewardship. Commitments include eliminating routine flaring, a Leak Detection and Repair program, greenhouse gas reduction plans in high intensity businesses, and compliance with EU ETS I and II, the Methane Regulation and CBAM.

Reference: page 163

MOL Group reduced Scope 1 and Scope 2 emissions by 9 percent between 2019 and 2024, driven mainly by energy efficiency projects. In 2024 it invested around USD 80 million in CAPEX on energy efficiency and emission reduction projects. Completed actions include hydrogen management improvements at Rijeka Refinery cutting emissions by 11 ktpa, heat integration at the Danube Refinery crude distillation unit, new pressure swing absorption units at MOL Petrochemicals, and inauguration of a green hydrogen facility at the Danube Refinery with a 10 MW electrolysis unit producing about 1,600 tonnes of green hydrogen annually. Recent acquisitions included Aurora Kunststoffe, ReMat plastics recycling, a biogas plant near Szarvas, and a 66 MWp photovoltaic plant in Balloszog. Planned actions over the next five years require around USD 80 million in CAPEX out of a total planned low carbon investment, including fuel switching at the Slovnaft powerplant, electromotor replacement cutting emissions by 101 ktpa, a CO2 compressor station in Croatia, a new 48 MWp solar plant in Tiszaujvaros, and further green hydrogen and biomethane projects. EU Taxonomy eligible turnover is reported as a single digit percentage with lower alignment.

Reference: page 160

MOL Group set climate targets aligned with its Shape Tomorrow Strategy and transition plan. It commits to reduce absolute emissions against a 2019 base value, with the updated strategy accelerating the transition. The transition plan targets are to decrease absolute gross Scope 1 and Scope 2 (location based) greenhouse gas emissions against the 2019 baseline, decrease absolute Scope 3 use phase emissions of sold energy products (Category 11, covering natural gas and fossil based refinery products) against a 2022 baseline, reach net zero greenhouse gas emissions on all scopes by 2050, and allocate 50 percent of total CAPEX to low carbon and sustainable business projects. The 2019 baseline was 6.9 mn tonnes CO2eq for Scope 1 plus a location based Scope 2 value, and the Scope 3 use phase 2022 baseline was 56.7 mn tonnes CO2eq. Gases covered are carbon dioxide and methane. MOL notes its 2030 targets are below the SBTi cross sector pathway and that an oil and gas industry specific 1.5 degree benchmark is not yet available. FGSZ Scope 1 and 2 emissions are excluded from the targets.

Reference: page 174

MOL Group reported total energy consumption of 27,183,633 MWh in 2024, down from 27,924,988 MWh in 2023, a reduction of 2.64 percent. Direct energy consumption was 24,217,712 MWh, of which 16,408,214 MWh came from crude oil and petroleum products and 8,040,921 MWh from natural gas. Indirect energy consumption was 2,734,498 MWh, of which renewable energy was 102,181 MWh (down from 140,109 MWh in 2023). Energy intensity from activities in high climate impact sectors was 2.96 MWh per million HUF. All of MOL Group energy consumption is accounted as activities in high climate impact sectors. About 67.7 percent of direct energy consumption came from crude oil and petroleum products, with the remainder mainly from natural gas. The share of renewable energy in both consumption and production remained below 0.5 percent, based on estimation, even after new solar panels were acquired in 2024.

Reference: page 175

In 2024 MOL Group reported gross Scope 1 emissions of 6.38 mn tonnes CO2eq (6.64 in 2023), of which 89.85 percent came from regulated emission trading schemes. Gross location based Scope 2 was 0.65 mn tonnes CO2eq and gross market based Scope 2 was 0.92 mn tonnes CO2eq. Total Scope 1 plus 2 emissions were 7.03 mn tonnes CO2eq (7.25 in 2023), with Upstream and Downstream as the main segments. Total Scope 3 emissions were 56,538,921 tonnes CO2eq (55,767,391 in 2023), dominated by Category 11 Use of sold products at 52,430,648 tonnes CO2eq, with Category 1 Purchased goods and services at 1,854,922 tonnes and other categories including processing of sold products and investments. Total greenhouse gas emissions (Scope 1 plus location based Scope 2 plus Scope 3) were 63.57 mn tonnes CO2eq, and on a market based basis 63.84 mn tonnes CO2eq. Scope 1 and 2 emissions fell about 3 percent year on year, while Scope 3 rose about 1.4 percent driven by higher crude oil purchases and use of sold refinery products.

Reference: page 180

MOL Group applies internal carbon pricing as a shadow price to factor the financial impact of carbon emissions into capital expenditure and investment decisions, risk management and opportunity assessment, project development, operations and value chain engagement, and product development and R&D. The scheme currently applies to Scope 1 emissions under EU ETS, covering 89.8 percent of Scope 1 in 2024. Carbon price premises are reviewed annually, incorporating EU ETS forecasts. MOL Group projects a continuous price increase until the 2040s, driven by free allocation phase out and stricter benchmarks, with prices expected to gradually decline afterwards as emissions decrease. The company discloses an ETS carbon price forecast of EUR 140 per tonne by 2030 in its scenario analysis and capital market releases. CO2 related costs from EU ETS and the Hungarian CO2 tax are embedded in financial planning, capital allocation, asset valuation, impairment calculations and fair value assessment of acquired assets, and the company recognizes provisions for excess CO2 emissions.

Reference: page 195

MOL Group's pollution policies sit within the Group HSE and Social Impact Policy and the HSE Area Book, with process-based regulations in the Environmental Stewardship element of the HSE MS. All operated technologies must comply with BAT associated emission limits (BAT-AEL) and performance levels (BAT-AEPL), and the lowest-emission techniques are considered when designing new technology or buying equipment. The Air Protection section requires measuring or calculating technology-related pollutants and preparing action plans to reduce air emissions. The Soil and Groundwater section sets prevention as first priority, with desktop risk assessments, remediation programs for high-risk findings, a risk-based mechanical integrity program, independent reviews of long-term remediation, and contamination assessment when selling or acquiring assets. Substances of concern are managed under Element 8 of the HSE MS through hazardous material documentation, product stewardship, new product assessments, REACH-relevant contract clauses, Safety Data Sheets, and exposure scenario controls.

Reference: page 196

To maintain air quality, MOL Group runs regulatory-compliant emission and air-quality measurements including discontinuous, continuous, and Leak Detection and Repair (LDAR) programs; the total cost of these regular processes was USD 1.6 million in 2024. Regular soil and groundwater management measures (remediation planning, licensing, monitoring, soil excavation and replacement, plus geological and hydrogeological studies) cost USD 5.3 million, 26.8% more than the prior year (USD 4.1 million). Actions for REACH and hazardous material safety cost USD 3.34 million, 6.9% lower than the previous year. Major projects include a 360,000-tonne-per-year mixed waste utilization facility at Szazhalombatta (operational expected by mid-2028) with five-stage flue gas cleaning, wastewater treatment upgrades at Szazhalombatta and Tiszaujvaros, and historical pollution remediation at the Urinj Peninsula (around EUR 4 million budget, new wells and submersible pumps installed). In 2024, 4 incidents spilling more than 1 bbl of hydrocarbon were registered group-wide, totaling about 508 m3 spilled; the largest was a product pipeline leak near Gardony on 16 October where up to 487 m3 of diesel leaked into the soil.

Reference: page 197

MOL Group has set two voluntary, time-bound pollution targets focused on air emissions. First, it commits to maintaining SOx (sulfur oxides) emissions in 2040 at the same level as the 2021 to 2022 average, with the baseline calculated at 4,026 tonnes (2021: 3,409 tonnes; 2022: 4,643 tonnes). Second, it aims to keep NOx (nitrogen oxides) emissions in 2040 consistent with the 2021 to 2022 average, with the baseline calculated at 5,433 tonnes (2021: 5,324 tonnes; 2022: 5,541 tonnes). These voluntary targets reflect MOL Group's commitment to minimizing the environmental impact of its operations, particularly in areas prone to air quality challenges, by focusing on operational efficiency and maintaining stringent control over emission sources across all operated companies.

Reference: page 198

In 2024, air emissions in tonnes were: Sulphur Dioxide (SO2) 3,678 (down from 4,647 in 2023), Nitrogen Oxides (NOx) 5,370 (2023: 5,413), Volatile Organic Compounds (VOC) 7,560 (2023: 7,851), Carbon Monoxide (CO) 1,114 (up from 1,026), and Particulate Matter (PM) 160 (down from 212). Other 2024 air pollutants included Nickel and compounds 0.4 tonnes and Benzene 17 tonnes, with HFCs, Ammonia, and dioxins plus furans reported at 0. Water contaminants discharged in 2024 (tonnes) included Total Petroleum Hydrocarbons (TPH) 19, Chemical Oxygen Demand (COD) 1,943 (2023: 1,791), Biological Oxygen Demand (BOD) 329 (2023: 281), Suspended Solids 821 (2023: 766), plus smaller amounts of Zinc 6.3, Phenols 2, Total nitrogen 1.2, Copper 0.7, and Nickel 0.2. Emissions cover routine, abnormal, maintenance, emergency, combustion, and fugitive sources. Air emissions are calculated by direct measurement, site-specific data, published emission factors, or estimation; water emissions by regular laboratory analysis reported in tonnes.

Reference: page 200

MOL Group produces, transports, and commercializes fossil fuels and refined products, some of which fall within the ESRS categories of Substances of Concern (SOC) and Substances of Very High Concern (SVHC). Spill and accidental release risks are addressed under Impact Metric IM-04 (Spills) and managed via REACH and other regulations. The disclosure takes an output-focused approach listing material product groups with SOC or SVHC content and their hazard classes. Crude oils (Carcinogenicity 1A, Germ Cell Mutagenicity 1B, SVHC) had refinery processing of about 1,256 kt. Naphtha products had refinery production of 91 kt and sales of 48 kt. Motor gasolines (SVHC) had refinery production of 104 kt. Diesel and heating oils had refinery production of 6,720 kt and sales of 1,100 kt. Kerosenes had refinery production of 7 kt and sales of 71 kt. Fuel oils (SVHC) had production of 79 kt. Butadiene (SVHC) had petrochemical production of 74 kt and sales of 76 kt. Raffinate had petrochemical production of 114 kt. A comprehensive group-level list is not yet available as compliance is managed locally.

Reference: page 202

MOL Group's water policies are part of its environmental stewardship commitments, aimed at reducing negative impacts on surface and subsurface water bodies, with general commitments in the Group HSE and Social Impact Policy and the HSE Area Book and process-based regulations in the Environmental Stewardship element of the HSE MS. Risk-based quantity measurement is in place for water withdrawal and discharge, with measurements highly recommended above medium risk (around 10% of MOL Group water withdrawal). Fresh water usage is assessed and a risk-based reduction plan is implemented. Risk assessments cover water scarcity, particularly related to climate change. Minimization of water consumption and freshwater intake is prioritized, especially in high and extremely high water-stressed areas. Efficient practices include closed cooling circuits, tank cooling, and preferred grey water usage at offices. Quality standards are maintained for industrial wastewater, internal limits and operational discipline apply to wastewater treatment plants, best available techniques are ensured, separated sewage systems are established for new technologies, water emergency drills are conducted, and water quality risks are addressed through pollutant reduction plans.

Reference: page 202

The oil and gas industry both consumes large amounts of water for production and produces large amounts of water from oil and gas extraction, and MOL Group continuously works to improve handling of these quantities. Regular measures to safeguard water resources include projects to reduce water intake and discharges, water pollution prevention plans, surface water studies, water permitting, and monitoring and laboratory analyses of water and sewage releases through self-monitoring, plus emergency response initiatives to protect surface water from pollution incidents. Allocated resources (annual HSE-supervised operational expenses) for these actions were USD 5.9 million in 2024, 4.8% down from USD 6.2 million in the prior year, excluding soil and groundwater protection reported under pollution. On top of these regular activities, in 2024 MOL Petrochemical initiated a project to enhance water circularity by reusing purified wastewater from its Wastewater Treatment Units that would otherwise be discharged into the River Tisza, reducing water extraction and discharge load, saving energy through optimized pumps, and automating the firefighting system. The project is financed through MOL Group's internal Green Fund.

Reference: page 202

In line with its policy objectives, MOL Group is targeting a 10% reduction in freshwater withdrawal by 2040 compared to the average withdrawal recorded in 2021 and 2022. The baseline for this target is the average of 76.4 million cubic meters. The target is voluntarily set and is intended to help preserve water resources near MOL Group's operations and prevent potential negative impacts on communities and water ecosystems.

Reference: page 203

Total water withdrawal increased to 104,094 thousand m3 in 2024 from 99,912 thousand m3 in 2023, with freshwater withdrawals reaching 81.9 million m3. Withdrawal by segment in 2024 (thousand m3) was Upstream 4,494, Refining 76,475 (of which freshwater 57,432), Petrochemicals 13,459, and Other 9,666. Total water consumption was 21,544 thousand m3 (2023: 20,167), split into Upstream 855, Downstream Production (Refining and Petrochemicals) 17,230, Midstream 3, and Other 3,459. The share of water consumption in regions with high or extremely high baseline water stress was 0% across all segments. Total water discharge rose to 115,634 thousand m3 (2023: 112,478), comprising discharge after primary treatment 59,306, secondary treatment 7,507, tertiary treatment 18,103, no treatment 28,219, and water transferred to third parties for treatment 2,506. Fresh water consumption is calculated by subtracting fresh water returned to a fresh water body from total fresh water withdrawn.

Reference: page 205

MOL Group manages biodiversity impacts through its HSE Management System. Element 7 of the HSE MS requires regular biodiversity impact assessments and Biodiversity Action Plans for all sites in protected areas and next to water sources, and requires minimising biodiversity impacts of greenfield developments during design. The company commits to restoring affected areas to their natural state where possible, guided by regulatory requirements and best practice such as the IPIECA Management and Remediation of Sites in the Petroleum Industry. Appendix A of the HSE MS sets rules for remediation and liability management of abandoned sites. The remediation process covers site assessment, hazard mapping and ranking, remediation action plan development (with a register of liabilities and financial demands), risk-based corrective action during project implementation, and aftercare monitoring. Corrective measures include traditional remediation, exposure pathway elimination, land use restrictions and monitoring of natural attenuation.

Reference: page 206

Continuous monitoring is conducted for HSE-relevant activities in protected areas and areas of high biodiversity value outside protected areas. Where applicable, Biodiversity Impact Assessments are carried out and Biodiversity Action Plans are developed if a negative impact is identified. In 2024, five Biodiversity Impact Assessments and 49 Biodiversity Action Plans were prepared for Exploration and Production activities. Measures addressed impacts on air, water and soil, including monitoring of air emissions from point sources every one and five years, disposal of produced water under water-law permits, groundwater monitoring at collection stations, immediate rehabilitation of soil contamination, and corrosion protection of underground pipelines. MOL Group operates more than 200 companies and 2,000 sites, so biodiversity actions are managed locally and cannot be consolidated at Group level. There is no standardized methodology to quantify or allocate financial resources for biodiversity actions across the Group, so MOL reports at an aggregate level without a consolidated financial breakdown.

Reference: page 206

MOL Group has currently not adopted any targets on measurable biodiversity indicators. Instead, the company seeks to minimise its impacts on biodiversity and ecosystems through stringent processes and through targets related to the drivers of biodiversity and ecosystem degradation, such as climate change, pollution and water use. MOL refers readers to the targets sections in other environmental standards for further information.

Reference: page 207

MOL Group reports sites located in or near protected areas. In total there were 247 sites covering 223 km2: Upstream had 55 sites covering 204.8 km2, Downstream had 4 sites covering 16.6 km2, and Retail & Logistics had 188 sites covering 1.6 km2 (excluding 108 MOL Polska Retail & Logistics sites covering 0.9 km2 not yet under the HSE MS scope). Upstream activities cover the largest area in protected and biodiversity-rich areas and negatively affect biodiversity through temporary land use change. In 2024 the protected areas affected by MOL upstream activities included seven national parks in Hungary (Hortobagy, Koros-Maros, Orseg, Balaton Uplands, Duna-Drava, Kiskunsag and Bukk), four areas in Croatia (Regional Park Mura-Drava, Special Reserve Durdevacki Pesci and Crni Jarki, Nature Park Lonjsko Polje, and Zutica Forest), and three game reserves in Pakistan (Kohat Darwazai Banda, Kohat Marchungi and Kohat Dhoda Paya).

Reference: page 210

MOL Group's E5 chapter is split into three sub-chapters: own waste generation and treatment (A), circular economy and resource use in the downstream segment (B), and the circular economy services segment in Hungary (C). For own waste (sub-chapter A), waste handling is governed by the Group HSE and Social Impact Policy and the Environmental Stewardship element of the HSE MS, applying R principles (refuse, reduce, reuse, repurpose, recycle), the waste pyramid, selective collection, waste minimization plans and transportation protocols. For the downstream segment (sub-chapter B), the Shape Tomorrow Strategy and three area books (Downstream Development, Optimisation Sales and New Businesses, and Downstream Production) drive a shift away from virgin resources toward secondary materials, petrochemicals, biofuels and biomethane. For circular economy services (sub-chapter C), the main policies are the Circular Economy Services Area Book, the MOHU Concession Contract, and MOHU's ISO 9001 and ISO 14001 certified Integrated Management System, applying the 4 Rs concept (Reduce, Reuse, Recycle, Recover).

Reference: page 217

For own waste (A), MOL carries out excavation, transport and treatment of hazardous and non-hazardous waste; general operative actions cost USD 16.3 million in 2024, up about 15% from USD 14.1 million in 2023. For the downstream segment (B), a crude diversification program launched in 2022 involves USD 500 million of investment to reach 100% capability to process alternative crude by 2026 at the Szazhalombatta and Bratislava refineries. The Polyol complex was inaugurated in May 2024, and a chemical recycling facility at Tiszaujvaros is planned to process 40,000 tonnes of mixed waste plastics annually using Lummus Green Circle pyrolysis. MOL blended over 600 kilotons of biofuels across 8 countries and co-processed over 100 kilotons of renewable feedstocks at the Danube Refinery in 2024. For circular economy services (C), MOHU was awarded the Hungarian waste management concession in 2023, introduced the Extended Producer Responsibility and Deposit Refund systems (more than 2,700 reverse vending machines installed, 6 million packagings returned per day in Q4), and plans up to USD 2.9 billion of investment over five years.

Reference: page 224

For own waste (sub-chapter A), MOL Group does not plan public targets beyond ensuring compliance with all Best Available Technology requirements. The main targets sit in the circular economy services segment (sub-chapter C) and originate from the Concession Contract and EU Waste Framework Directive, applying primarily to MOHU. Declared targets are: build a minimum 100 kt capacity waste-to-energy plant; meet the EU landfilling target of a maximum 10% of municipal solid waste by 2035 (with possible derogation to 2040), against a 2023 baseline; meet the EU reuse or recycling target of a minimum 65% of municipal solid waste by 2035, against a 2023 baseline of approximately 34%; and an investment commitment of 185 billion HUF by 2033 over the firm concession period (2023 to 2033), of which 53 billion HUF had been reached by the end of 2024.

Reference: page 219

MOL Group reports the main resource inflows for its Downstream segment in 2024. The principal input materials processed at refineries were crude oil: own-produced crude oil and imported crude oil (imported crude reported at 1,448 kt). These crude oil inflows are the primary feedstock for the refining and petrochemical production described in the downstream segment. The circular economy services segment (MOHU) is described as non-waste-generating with no resource inflow for its own processes, its only resource outflow being clean secondary raw materials.

Reference: page 219

MOL Group reports the main resource outflows of its Downstream segment in 2024, covering both refinery production and external sales (in kilotons). Refining outputs include LPG, naphtha, motor gasoline, diesel and heating oil, kerosene, fuel oil and bitumen, plus an internal transfer for petrochemical feedstock. Petrochemicals outputs are reported by product type and by product group, including olefin products, polymer products (864 kt produced, 848 kt sold), butadiene products (74 kt produced, 76 kt sold) and raffinate (114 kt). For the circular economy services segment, the only resource outflow is clean secondary raw materials produced by MOHU.

Reference: page 211

Total waste generated at MOL Group level was 176,779 tonnes in 2024 (175,744 tonnes in 2023), an increase driven mainly by higher waste from well drilling and maintenance. Total hazardous waste was 76,258 tonnes (87,468 tonnes in 2023). Non-recycled waste was 78,511 tonnes, representing 44% of the total (61% in 2023). Total waste diverted from disposal by recovery operations was 114,458 tonnes (83,487 tonnes in 2023), comprising 33,446 tonnes of hazardous waste (preparation for reuse 9,201; recycling 22,471; other recovery 1,775) and 81,012 tonnes of non-hazardous waste (preparation for reuse 17,181; recycling 59,411; other recovery 4,419). Total waste directed to disposal was 78,511 tonnes, split into 42,812 tonnes hazardous (incineration with energy recovery 7,070; without energy recovery 3,921; landfilling 2,696; other disposal 29,124) and 35,700 tonnes non-hazardous (incineration with energy recovery 3,497; without energy recovery 30; landfilling 23,095; other disposal 9,078). The largest waste stream by composition was construction and demolition waste (EWC 17) at 74,847 tonnes.

Reference: page 231

MOL Group manages workforce impacts and risks through several Group-level policies. The Human Resources Area Book is the highest-level process-based HR policy, defining main HR processes, rules and strategic goals across the Group, and is binding for affected employees. It covers six core processes: Employee Attraction, Recruitment and Selection; Reward and Benefits; Learning and Development; Workforce and Employment Management; HR Advisory; and HR Process Design and Control. The updated Group People Strategy was presented to top management and the Supervisory Board in June 2024 around five pillars (Refine, Attract, Engage, Develop, Build). Reward is based on the Hay job-evaluation methodology with pay scales benchmarked against international market standards. Further commitments are set in the HSE and Social Impact Policy, the Code of Ethics and Business Conduct, and the Diversity and Inclusion Process Description.

Reference: page 232

MOL Group engages its workforce directly and through representatives. Identification of impacts and risks on employees is supported by continuous feedback collection and regular engagement surveys. The Employee Engagement Survey is launched every two years using an external vendor, complemented by pulse checks. On Group level all employees are represented by the European Works Council, re-elected for a five-year mandate, which held two ordinary meetings in 2024 with senior management and organises a Senior Management Forum twice a year. Trade unions are present in Hungary, Croatia, Slovakia, Bosnia and Herzegovina, Poland, Romania, Montenegro and Russia, and works councils and occupational safety committees operate at local level with regular joint management-worker meetings. MOL also supports individual workers through mechanisms such as the Social Fund in MOL Hungary, allocated by the trade union. Townhall events provide a forum to raise concerns and propose ideas.

Reference: page 255

MOL Group operates the SpeakUp! whistleblower mechanism, a secure platform for raising concerns, reporting violations and seeking advice. Reports are treated confidentially, can be submitted anonymously, and are protected from reprisal. The channel is open to employees, individuals in contractual relationships with MOL Group companies, and any external stakeholder with a legitimate interest. Established in 2006, it operates under Hungary's whistleblower protection legislation. The investigation process follows the Ethics Council Rules of Procedure across ten steps from receiving reports to monitoring implementation and publishing anonymised case studies. The Ethics Council, chaired by an independent party, oversees the mechanism, reviews investigations and reports regularly to the Board of Directors, Chairman-CEO and Supervisory Board. Workers can also raise concerns through works councils, occupational safety committees, grievance mechanisms and hotlines, and are protected against reprisals when reporting safety issues in good faith.

Reference: page 233

MOL Group implemented actions across talent management, health and safety, and diversity. Within talent management, 1,871 colleagues were identified as talents, of which 81 hold senior expert or managerial roles. Fresh graduates from eight countries were hired within the Growww framework, reaching a 48% female ratio. The MOL Group Academy organised trainings for participants, and leadership programs including LEAD and First Time Leader continued across core countries. On occupational health and safety, MOL continued the six Group-level Life Saving Rules, expanded the LEON adaptive mobile training tool, ran Consequences training for managers, and strengthened its Contractor HSE program. In 2024 the company allocated USD 19.9 million to Occupational Health and Safety activities, a 3.5% increase on USD 19.2 million in 2023. Diversity and inclusion actions covered four pillars: multi-generational collaboration, female empowerment, working capacity and wellbeing.

Reference: page 235

MOL Group's primary HR target is to keep sustainable employee engagement at a minimum of 70% at all times, measured biennially through the Employee Engagement Survey against international industry benchmarks. On occupational health and safety, the objective is to be comparable with top first- and second-quartile oil and gas companies. The Group-level tolerable Total Recordable Incident Rate (TRIR) limit was set at 1.3 for 2024, with actual performance of 1.04, and the TRIR target was tightened to 1.25 for the following year. The fatality target is zero, the only acceptable level. On diversity, MOL Group has a publicly communicated target to reach a minimum percentage of women in management at the AY 18 grade and above, and a target for all employees to complete annual ethics training. The share of female managers reached 28.2% in 2024, up from 27.9% in 2023.

Reference: page 257

At year-end 2024 MOL Group employed 25,528 people (headcount), up from 24,912 in 2023. The overall gender split was 73.1% male and 26.9% female. Of the total, 24,957 were full-time employees (73.8% male, 26.2% female) and 571 part-time (45.7% male, 54.3% female). Permanent (indefinite-term) employees numbered 22,347 and temporary (fixed-term) employees 1,934. During 2024, 2,852 employees left the undertaking, giving a turnover rate of 12.8%, down from 14.1% in 2023. By country, the workforce comprised 10,130 employees in Hungary, 8,453 in Croatia, 3,058 in Slovakia, 1,618 in other European Union countries and 377 in non-European Union countries. Employee data is based on annual sustainability data collection and reflects year-end closing headcount.

Reference: page 235

In 2024, 90.3% of MOL Group employees had potential coverage of collective bargaining agreements, down from 92.8% in 2023. Coverage by country was 100.0% in Croatia, 100.0% in Slovakia, 85.2% in Hungary, 74.0% in other EEA countries and 0.0% in non-EEA countries. In the EEA, collective bargaining agreements are per company and coverage applies to all employees in the company. Separately, 96.7% of employees were covered by workers' representatives, based on trade union coverage (100.0% in Croatia and Slovakia, 98.9% in Hungary). On Group level all employees are also represented by the European Works Council. Negotiations during the year focused on securing higher income for operational and expert employees through base salary increases or improvements to material rights.

Reference: page 258

In top management (positions graded AY 4 or above), MOL Group had 50 male employees and 4 female employees in 2024, equating to 92.6% male and 7.4% female, compared with 91.5% male and 8.5% female in 2023. Across the broader workforce, the share of female managers was 28.2% in 2024 (27.9% in 2023). By age, 14.5% of employees were below 30 years old, 54.6% were between 30 and 50 years old, and 30.8% were over 50 years old. During 2024, 31.8% of all hires were female, a higher share than overall female representation in the Group, supporting progress towards better gender balance.

Reference: page 236

MOL Group reports that it pays an adequate wage to all its employees. Employees are paid above the minimum wage in all jurisdictions where minimum wage legislation applies, and where there is no minimum wage requirement, employees are paid above the wage level needed for a decent standard of living. This commitment is supported by the Group's remuneration structure, which is based on transparent principles of internal equity and external competitiveness, with job positions evaluated using the Hay methodology and pay scales benchmarked against international market standards.

Reference: page 254

Persons with disabilities are addressed within MOL Group's diversity and inclusion framework and human rights commitments rather than through a dedicated quantitative metric. The Code of Ethics names persons with disabilities among the vulnerable groups requiring particular attention, and occupational health services examine the conditions of employment of workers with disabilities. Disability is one of the focus areas of the Diversity and Inclusion framework, and related actions in 2024 included INA's White Cane Awareness Day event and its participation in a project providing internship opportunities for students with disabilities, alongside Group-level awareness initiatives on the benefits of employing colleagues with disabilities. The report does not disclose a specific number or percentage of employees with disabilities.

Reference: page 234

MOL Group placed significant emphasis on training and development in 2024. Over 759 thousand hours of training were recorded, with funds allocated for training and skills development. The accelerated focus on upskilling and reskilling under the Shape Tomorrow strategy drove an increase in average training hours per employee, accompanied by a roughly 9% increase in average training costs. Within the MOL Group Academy framework, 369 trainings were organised covering multiple topics for 1,894 participants. Around 3,600 white-collar colleagues were enrolled in the TCCD/GPS technical competence and career development programs across multiple countries. Digital learning tools including LinkedIn Learning, the LEO microlearning platform for blue-collar workers, and leadership programs such as LEAD were also deployed. Note: some training figures in the source carry OCR corruption on numerals and only unambiguously legible values are stated here.

Reference: page 249

In 2024, 95% of MOL Group employees were covered by a Group-level health and safety management system. There were zero fatalities from work-related injuries among own workforce (own staff plus contractors), an improvement on nine contractor fatalities in 2023, and zero fatalities from work-related ill health. Recordable work-related accidents (TRI) for own staff and contractors fell to 96 from 117 in 2023, an 18.8% decrease. The Total Recordable Incident Rate (TRIR) for own staff and contractors was 1.04 (excluding Midstream), down from 1.31 in 2023 and well below the 1.3 tolerable limit. Lost Time Injuries fell about 17% to 84, with the Lost Time Injury Frequency (LTIF) declining to 0.9 from 1.1. One occupational illness (caused by a tick bite) was registered for own staff. Worked hours rose from about 89 million to 91 million.

Reference: page 259

In 2024, the rate of average base salary of women to average base salary of men was 93.3%, reflecting the difference between the average total monthly base salary of female and male employees. The annual total remuneration ratio of the highest paid individual to the median annual total remuneration for all employees was 96.3. This indicator uses the median annual total remuneration of employees at MOL Group's Hungary-based companies, INA d.d. and Slovnaft a.s., compared with the highest paid individual in MOL Group whose remuneration is taken from the MOL Group Remuneration Report. A fully Group-wide median figure for all employees was not available due to limitations in the data collection process.

Reference: page 259

In 2024, MOL Group recorded one incident of discrimination. There were 104 complaints filed through channels for own workforce to raise concerns, compared with 106 in 2023, showing no significant change. No complaints were filed to National Contact Points for OECD Multinational Enterprises. Fines, penalties and compensation for damages as a result of discrimination incidents, including harassment, were zero HUF. There were zero severe human rights issues and incidents connected to own workforce, including zero cases of non-respect of the UN Guiding Principles and OECD Guidelines for Multinational Enterprises, and zero HUF in associated fines, penalties and compensation. Separately, the Ethics Council received whistleblower reports related to improper workplace behaviour and unfair labour practices. Complaints and incidents are managed through MOL Group's SpeakUp! whistleblower system.

Reference: page 261

MOL Group's principles on the economic, environmental and social development of local communities and respect for human rights are set out in its Code of Ethics and Business Conduct and its HSE Social Impact Policy, both published on its website. These commit the Group to making positive impacts while eliminating negative impacts on communities, to continuously measuring and openly communicating social performance, and to a culture in which employees support local development. Community engagement and grievance management follow an integrated framework defined by the internal Community Engagement Methodology, aligned with ISO 9001 and ISO 14001, the AA1000 Stakeholder Engagement Standard and IPIECA's community grievance mechanism standard. Engagement is based on inclusivity, transparency, responsiveness and accountability, using a four step process (identify and analyse, design and plan, implement, evaluate and update). For shared wealth, the Managing Corporate Giving Activities Process Description and the website principles govern sponsorship, donation and social investment, including a commitment to allocate 1% of the Group's average net business result over the past three years to such initiatives.

Reference: page 262

MOL Group engages directly with affected communities, their legitimate representatives or credible proxies such as local non profits, municipalities and associations. Community Relationship Officers maintain continuous communication and address concerns, and community perspectives are actively sought to inform decision making and manage potential and actual impacts. Special attention is given to marginalised and vulnerable groups, considering physical safety, environmental and health conditions, quality of life and social cohesion. For ongoing operations such as refineries and drilling sites, engagement occurs regularly; for site openings or closures it must occur as early as possible in the project lifecycle. Methods include public hearings, joint activities and ongoing communication with authorities and stakeholders, with frequency and method tailored to context. Effectiveness is assessed through monitoring and evaluation, and community feedback informs continuous improvement. To monitor performance, local communication teams send half yearly reports to Group Communications, which reports at least annually to the Sustainable Development Committee and prepares an Annual Report on Community Engagement. Engagement on shared wealth and economic impact also extends to trade organisations, industry associations and multi stakeholder partnerships.

Reference: page 263

The aim of MOL Group's 2024 actions was to ensure community engagement, including grievance mechanisms and trainings, is implemented in 100% of major operations and that complaints, especially on noise, odour, water and air quality, are minimised. At the Danube Refinery the Hello Dufi mobile application was launched in early 2024, allowing residents to submit comments; investments were made to reduce odour sources. At the Bratislava (Slovnaft) Refinery grievances rose against the prior year, linked to two major turnarounds affecting the Ethylene unit, with noise reduction projects in the testing phase. At the Rijeka Refinery six grievances were recorded (three sea related, three air quality) versus seven the prior year, with remediation drilling and equipment upgrades during the turnaround. In Upstream Croatia three grievances were recorded, down from prior years, after fewer workover activities near populated areas. At Site Sisak two grievances were recorded, both confirmed unrelated to the site. In Upstream Pakistan grievances included 14 HSE related and 8 community related, with awareness raising and a local committee at the Makori Deep location averting potential conflict. On shared wealth, MOL Group contributes to national budgets through taxes, mining royalties, rental expenses, wages, salaries and social security, detailed in its Payments to Governments report. With the Hungarian Food Bank Association the 2024 partnership saved more than 14 tonnes of surplus food. The Green Belt Program operates in several countries to create public green spaces, and the Talent Support and Child Healing Program supports young people in sports, classical music and sciences.

Reference: page 264

The most important key performance indicators for community engagement are the share of relevant operations with an implemented Community Engagement Plan and the share of closed grievances out of registered grievances by stakeholders. Because these are measured site by site, MOL Group has not implemented a formal Group level target for them, and relevant information is disclosed in the actions section above. For shared wealth and economic impact, MOL Group's published Shape Tomorrow Strategy includes a target that at least a defined share of social investments be spent on local communities, with social investments defined as voluntary contributions to communities near operations and to society at large through transfer of knowledge, skills or resources. Interim progress towards this target is not published. The report states that in 2024 MOL Group donated in cash, in kind giving or leverage in total, a figure that does not include sponsorships (the precise amount is affected by OCR corruption and is not clearly legible in the source text).

Reference: page 269

MOL Group's Consumer Services policies aim to meet changing consumer needs while minimising negative environmental effects, supporting the transition to sustainable mobility and transport, and ensuring profitability and business continuity. The highest level process based policies, supervised by the Group Consumer Services Vice President, are the Retail Area Book and the Mobility Area Book, which must be applied across all MOL Group companies through local Process Descriptions. In Retail, a key priority is ensuring continuous availability of critical products and services such as fuel and convenience goods (IM-20). In Mobility, policies focus on driving innovative and sustainable mobility solutions in line with the Shape Tomorrow strategy, including continuous investment in EV charging infrastructure and alternative fuels (IM-01, IM-22, OP-06, OP-07). HSE compliance is central, with strict operational standards, regular staff training and provision of life saving equipment such as defibrillators (IM-21). The Group Retail organisation has committed to conscious waste management, recycling and increased energy efficiency to support carbon reduction goals.

Reference: page 270

MOL Group integrates consumer perspectives into strategic and operational decisions through structured engagement combined with business data. The main Group level channels include Brand Tracking, a customer insight system monitoring customer behaviour monthly across seven countries, with 3,000 customers per country (a cumulative 21,000 participants) and monthly collection of 250 customers per month per country, covering brand awareness, usage patterns and 25 distinct KPIs related to fuel, gastronomy, store hygiene, loyalty programs and staff behaviour. Product quality is assessed through rigorous testing, including fuel quality assessments with DTC Austria and blind taste tests by third party agencies. An internal research system, including the Rate My Shopping initiative, gathers rapid feedback from loyalty program members. The MOL MOVE digital, gamified, tier based rewards program has been introduced in eight markets (Croatia, Slovenia, Hungary, Czech Republic, Slovakia, Romania, Serbia and Poland). For general consumer complaints MOL Group has no unified policy; retail stations operate their own complaint handling following local legal requirements, and unresolved concerns can be escalated to the Group level SpeakUp! mechanism, which accepts anonymous and confidential reports.

Reference: page 271

In 2024 the retail segment invested in delivering critical products of superior quality and maintaining a service station network across ten Central Eastern European countries, continuing to offer EVO Plus fuels and developing the e charging network. The mobility segment invested in advancing a cleaner mobility ecosystem. Under the MOL Plugee EV charging brand, launched in 2018, chargers were installed across the Group's service station network in the CEE region, with ultra fast and DC charger solutions added at existing and new locations in Hungary, and European roaming introduced enabling charging across six countries. MOL Limo is described as the largest car sharing service in Budapest, with about one third of its fleet electric, and each shared car expected to replace multiple private cars, supporting SDG 12. Bike sharing services MOL Bubi (Budapest) and Slovnaft Bajk (Bratislava) promote emission free mobility, and the managed fleet's average age remained under three years versus the Hungarian national average of 16 years. In 2024 MOL Group signed agreements with Hungary's three largest public transport and freight companies (Volanbusz, MAV and Waberer's) on hydrogen based mobility, and agreed with Mercarius Flottakezelo to form the joint holding MOL Mercarius. The Group identified no significant systematic negative impact on consumers; customer satisfaction is monitored continuously through the Rate My Shopping initiative integrated with MOL Move, flagging critical complaints such as financial discrepancies, ethical violations, cleanliness, HACCP issues and product unavailability. The eSMILE digital microlearning platform trains over 19,000 service station employees on product knowledge, consumer care, compliance and safety. Over a large number of service stations are equipped with defibrillators, with personnel trained in first aid at most stations (over 90% in Hungary, Slovakia, Czech Republic, Croatia and Slovenia).

Reference: page 275

MOL Group's ethics management system is anchored in its Code of Ethics and Business Conduct, available online in 13 languages and accessible across the Group. Its key principles cover free and fair trade and competition, anti-corruption and anti-fraud, corporate loyalty, and trustful business relations. The Code prohibits corruption, bribery, facilitation payments, kickbacks, money laundering and insider dealing, applying a zero-tolerance policy across the value chain. All employees must complete annual compulsory ethics training, and in 2024 98% of MOL Group employees successfully completed their Annual Ethics training. Ethics is integrated into the training curriculum for the Board of Directors and the Supervisory Board. Partners, including suppliers and sponsors, must align with the Business Partner Code of Ethics. The SpeakUp! whistleblower system, established in 2006, allows reporting of Code violations, assessed by the Ethics Council. Investigations are run by Group Anti-Fraud and Investigation organizations under principles of independence, confidentiality, GDPR-compliant data protection, and whistleblower protection from retaliation.

Reference: page 279

MOL Group Procurement manages a comprehensive worldwide supplier base and contracts with local suppliers where beneficial, supporting positive relationships with local communities (impact IM-09: key regional business partnerships). It aims for Group-level transparency, equal and fair treatment of suppliers, integrity, and prevention of conflicts of interest. MOL Group operates a Supplier Lifecycle Management framework with four pillars: supplier qualification, supplier evaluation and selection, supplier performance evaluation, and supplier relationship management. Sustainability is integrated into procurement under the Code of Responsible Procurement. Contracts are only concluded with suppliers pre-screened on financial, legal and sustainability grounds and pre-qualified on SE aspects, including ethical pre-screening where illicit employment, money laundering, terrorist financing, bribery and corruption are grounds for disqualification. The Business Partner Code of Ethics is a mandatory element of supplier contracts. A blacklisting process prevents business with parties committing corrupt, fraudulent or irregular practices, or who are sanctioned. In 2024, Group Procurement updated its supply chain sustainability risk assessment and identified high-risk suppliers based on environmental and social issues, with audits triggered for medium or high SE risk.

Reference: page 276

MOL Group maintains a zero-tolerance policy on corruption and bribery in any form, including facilitation payments, kickbacks, extortion and misuse of authority, across both private and public sectors and throughout its value chain. Detection and investigation are governed by the Security Area Book, the highest process-based policy for anti-fraud and internal investigation. The SpeakUp! whistleblower system routes reports relevant to bribery or corruption to the Group Anti-Fraud and Investigation organizations. Internal investigations follow an annual fraud risk assessment plan acknowledged by senior management; complex cases require approval of the Group Security Director. Investigations must be unbiased, proportionate, confidential and GDPR-compliant, with whistleblowers protected from retaliation. All country managing directors must report annually on corruption-related risks of their country and prepare mitigation plans. The Anti-Fraud Team issued quarterly Anti-Fraud newsletters as an awareness tool, and 98% of employees completed the annual ethics training, which includes dedicated anti-corruption content.

Reference: page 276

MOL Group reports that in 2024 there were no reported incidents of bribery, corruption, gifts or hospitality submitted through its whistleblower reporting system. No employees were dismissed or disciplined for corruption-related offenses, and no business partner contracts were terminated or not renewed due to corruption violations. No convictions were recorded for violations of anti-corruption or anti-bribery laws. The report notes two open competition-related proceedings: in Germany the Federal Antimonopoly Office initiated an ad hoc sectoral assessment requesting information from MOL Germany on the wholesale petroleum trading market, with no specific outcome as of the reporting date; and in Montenegro the Agency for the Protection of Competition continued an investigation into an alleged concerted practice, a decision MOL Group has challenged in court. No fines were paid for violation of anti-bribery laws or anti-competitive business practices, and MOL Group incurred no monetary losses from legal proceedings related to price fixing or price manipulation during the year.

Reference: page 277

Regulatory and public affairs activities are governed by the Corporate Affairs Area Book, with the Executive Vice President of Group Strategic Operations and Corporate Development as process owner. Oversight includes standing reports to management and supervisory bodies, such as two reports per year to the Board of Directors on the political and regulatory environment. MOL Group's Code of Ethics and Business Conduct prohibits engaging in political activities or pursuing political agendas, and it does not sponsor, donate to, or support political programs, parties or affiliated organizations. MOL Group made no direct or in-kind political contributions in 2024. The company is registered in the EU Transparency Register (REG number 08569166274-90) and addressed advocacy topics including climate action, energy, environment and taxation, supporting the EU Fit for 55 package and CCS/CCU initiatives. In 2024, total spending on membership fees for EU, international and national associations amounted to USD 1,691,294, broken down as national associations USD 626,669, EU and international associations USD 202,128, and EU policy associations USD 862,497 (including FuelsEurope, Concawe, CEFIC and IOGP). One Supervisory Board member, Norbert Izer, has held a position in public administration within the last two years.

Reference: page 280

There is no unified standard payment target across all MOL Group entities, but the most commonly used standard payment term is 60 days. MOL Group discloses the average time to pay an invoice from its reception against this 60-day benchmark for all supplier categories. In 2024, 84% of invoices were paid within this timeframe, and the average time to pay an invoice from its reception was 40 days. The figure was derived using a representative sampling methodology covering entities accounting for approximately 70% of total consolidated net revenue, selecting invoices where both the document date and payment date fell between January 1 and December 31, 2024. As of the reporting date, no legal proceedings related to late payments were outstanding. The company states that payments are made on or by the due date, aligning with contractual obligations and supporting predictable cash flow management for suppliers.