Neste

Information about the role of administrative, management and supervisory bodies can be found in the Corporate Governance Statement on pages 64-78. Board committees and their roles are described, including the Audit Committee, People & Remuneration Committee, and Project Committee. The Board of Directors is responsible for the company's strategic direction and overseeing management. In October 2024, the company restructured its organization and appointed a new leadership team to expedite decision-making to navigate the complexities of the current business environment.

Sustainability matters are integrated into Board oversight and decision-making processes. The Board receives regular updates on sustainability performance and climate-related matters. In 2024, sustainability was a key focus area with the company's carbon handprint and footprint targets being integrated into strategic planning. Information on sustainability matters addressed by the Board can be found in the governance sections.

Our climate commitments remain connected to the remuneration of Neste's key personnel, as a performance measure in Neste's long-term incentives (LTIs) to further drive the commitment and implementation of actions across the organization. In 2024, Neste's renewed short-term incentive plan (STI) was implemented to support business performance. Details of the remuneration structure including sustainability-related performance measures are provided in the Remuneration report on pages 84-89.

We implement an ongoing process of human rights due diligence to identify, assess and address adverse human rights impacts across our business operations and value chains. Stakeholder engagement is a key component of Neste's human rights due diligence, extending across our operations, supply chains, and communities. When assessing human rights risks, we pay special attention to vulnerable groups such as women, children, migrant workers and Indigenous Peoples.

Neste has put in place ongoing management processes to identify, prevent, mitigate and remedy adverse human rights impacts. We continuously monitor and track the effectiveness of our response, with transparent reporting and communication on how impacts are addressed.

All Neste´s renewable raw material suppliers are subject to rigorous sustainability due diligence, as stated in Neste's Supplier Sustainability Approval Principle. It sets the minimum sustainability requirements for approving suppliers through a multi-step process, including raw material evaluation, risk assessments, counterparty screening, a sustainability review and audits.

Our compliance program includes risk management and internal controls over sustainability reporting. We carry out annual compliance risk assessments to support us in our risk-based approach and to guide us in our compliance efforts and risk prevention and mitigation actions in the organization. Risk management processes are described in detail on pages 79-83, including specific sustainability-related risks and their management. The company has established processes for ensuring the accuracy and completeness of sustainability data through our Sustainability data package and internal verification procedures.

At Neste, we are leading the way towards a sustainable future. We are committed to further strengthening our position as the world's leading producer of sustainable aviation fuel and renewable diesel.

We at Neste have a successful history with strong value creation over the past 20 years. Our investments in renewable fuels have made us the market leader in sustainable aviation fuel (SAF) and renewable diesel. As the world needs to mitigate climate change and shift away from fossil fuels, there will be a growing market for lower-emission fuels in the long term.

Neste is able to utilize low-quality renewable raw materials to produce high-quality renewable fuels at scale. Our key sources of competitive advantage stem from global raw material sourcing and unique pretreatment capabilities. We also have refining capacity on three continents, enabling global value-chain optimization.

Neste continues to seek growth in renewable fuels targeting market leadership, cost competitiveness and technology advantage. Our renewables production capacity will be increased to 6.8 million tons in 2027. With world-class operations on three continents, Neste will be well positioned to create value in the future.

Neste provides renewable, lower-emission fuels for transportation, aviation, marine and other industrial uses, as well as renewable and circular solutions for the chemical and plastics industries. We produce renewable products at our refineries in Finland, the Netherlands and Singapore, as well as through our joint operation with Marathon Petroleum in Martinez, California.

We actively listen to employee feedback by conducting global employee engagement surveys regularly. The survey results are discussed systematically across the organization and translated into actionable plans at all levels of the organization. In addition, we conduct employee surveys targeted at specific groups – for example, new joiners and summer trainees, as well as employees leaving the company.

At a local level, a key element of employee cooperation is that it is driven by local requirements in each country of operation. Neste is committed to following applicable local collective agreements and has local cooperation bodies or works councils in Finland, Rotterdam and Singapore. In 2024, a works council was also established in Amsterdam.

As a result of requests from Neste employees, Neste started negotiations with employee representatives aiming to establish a European Works Council (EWC) that is based on EU legislation.

Stakeholder engagement is a key component of Neste's human rights due diligence, extending across our operations, supply chains, and communities. We actively seek opportunities to collaborate with our stakeholders to advance positive systemic change and enhance our leverage to address the root causes of adverse human rights impacts.

The company conducts regular materiality assessments to identify and prioritize the most significant sustainability impacts, risks and opportunities. Based on our materiality assessment, we have identified key focus areas including climate change, biodiversity, human rights, supply chain & raw materials, compliance, people, and safety.

Our work is guided by our sustainability vision covering climate, biodiversity, human rights, and supply chain and raw materials. With our partners, we are aiming for a carbon neutral and nature positive value chain by 2040.

The year 2024 was marked by geopolitical, economic and regulatory uncertainty. For Neste, the year was particularly challenging. New players and increased capacity have entered the renewables industry, resulting in a decline in product prices and intensified demand for waste and residue raw materials. In October 2024, we initiated a full potential analysis to identify all necessary measures to ensure solid performance in all market conditions.

Despite recent headwinds in the green transition, the challenge of climate change continues to be urgent. The coming decades necessitate a significant reduction in the use of fossil energy sources. Neste is well-positioned to address this challenge, offering solutions that enable decarbonization even in hard-to-abate sectors like aviation.

Every year we analyze the saliency of our human rights impacts based on severity and likelihood. The assessments evaluate our actual and potential impacts on people throughout the value chain at a practical and granular level. This enables us to monitor our progress, account for any new risks resulting from changes in our business and accurately focus and prioritize our work.

In 2024, we held internal workshops to expand the depth and scope of our saliency assessment across our business areas. We also evaluate the effectiveness of our current measures and assess whether existing practices are sufficient in scale and complexity to address our salient issues.

We carry out annual compliance risk assessments to support us in our risk-based approach and to guide us in our compliance efforts and risk prevention and mitigation actions in the organization.

In 2024, we continued our internal pilot to assess scope 3 hotspots and to identify our critical suppliers and partners with a significant role in supporting us in our efforts to decarbonize our value chain.

We completed our materiality analysis of biodiversity impacts according to SBTN guidance for upstream and direct operations, and concluded that freshwater and land use aspects are material for biodiversity and nature in Neste´s value chain.

This Annual Report includes a Sustainability statement prepared in accordance with the Corporate Sustainability Reporting Directive (CSRD) and European Sustainability Reporting Standards (ESRS). The Review by the Board of Directors contains the complete Sustainability statement on pages 100-149.

Based on our materiality assessment, we report on the following material topics: ESRS 2 (General Disclosures), E1 (Climate Change), E2 (Pollution), E3 (Water and Marine Resources), E4 (Biodiversity and Ecosystems), E5 (Resource Use and Circular Economy), S1 (Own Workforce), S2 (Workers in the Value Chain), S3 (Affected Communities), and G1 (Business Conduct).

All sustainability indicators and metrics are collected under Neste's Sustainability data package on pages 37-62.

Our roadmap toward a carbon neutral value chain: We closely monitor the development of the latest climate science, sectoral guidance, best practises and the leading climate frameworks such as the Science Based Targets initiative (SBTi), Transition Pathway Initiative (TPI) and Exponential Roadmap Initiative (ERI) to develop our climate commitments. As a result, achieving significant emissions reductions within our own operations and across the value chain remains the central approach to meeting our climate targets.

We have identified and taken several measures to reduce GHG emissions in our production (scopes 1 & 2). We met our short-term target of 100% renewable electricity procurement globally in 2023 with electricity supplier contracts and additional market measures. In 2024, solar power supply started from the Lakari solar plant in Rauma, Finland. In the medium-term, we will focus on improving energy efficiency and electrification, and in the long-term, our decarbonization actions include scaling new technologies.

In October 2024, we announced a decision to re-evaluate our renewable hydrogen plans and withdraw from investing into a 120 MW electrolyzer at the Porvoo refinery. We still plan to utilize renewable hydrogen at the Porvoo refinery and are actively evaluating alternative pathways for securing renewable hydrogen.

Progress of Porvoo refinery transformation: In 2023, Neste completed the strategic study on gradually transforming its crude oil refinery in Porvoo, Finland, into a leading renewable and circular solutions refining hub. The planned transformation will proceed in phases, and requires multiple separate investment decisions during the next decade before targeted completion. The transformation will complete Neste's journey to a 100% renewable and circular solutions producer when finalized.

Our climate work is divided into three priority areas: carbon handprint, carbon footprint and use phase emission intensity. We enable our customers to reduce their greenhouse gas (GHG) emissions by offering renewable and circular solutions to replace fossil products.

Since 2020, evaluating the production carbon footprint (scope 1 & 2) emission impact of investment decisions has been mandatory at Neste. To increase the transparency of the different GHG emission impacts of our investments, we have introduced new criteria and guidelines to enable our project teams to evaluate all the potential climate impacts of the possible investments. To align our investment decisions to support our climate commitments, Neste applies an internal carbon price for our scope 1 & 2 GHG emissions in investment calculations, business case evaluations and strategic planning.

We aim to achieve our carbon handprint target by growing our renewable and circular solutions capacity. Through our strategic investment project in Rotterdam, our total production capacity of renewable products will expand to 6.8 million tons annually in the coming years. Moreover, we diversify our raw materials portfolio, increasing the use of raw materials with lower GHG impact throughout product life cycle.

Naantali bio-steam boiler: In 2024, a new steam boiler was completed at the Neste Naantali terminal. The new energy facility produces steam for the Naantali terminal heating tanks with a bio-steam boiler using domestic wood chips and recycled wood as an energy source and an electric boiler using renewable energy. The supply of steam produced with renewable fuels and energy supports Neste's aim of reducing emissions in our own production.

In 2024, our R&D expenditure was EUR 86 million. In 2024, we increased our focus on supporting existing businesses and enhancing their competitiveness. We prioritized research investments, among others, to advance chemical recycling and develop innovative pretreatment technologies.

Carbon handprint: We help our customers to reduce their GHG emissions by at least 20 MtCO2e annually by 2030 with our renewable and circular solutions.

Carbon footprint (scopes 1 & 2): We reduce emissions in our own production by 50% by 2030 and reach carbon neutral production by 2035.

Use phase emission intensity: We reduce the use phase emission intensity of sold products (scope 3) by 50% by 2040 compared to 2020 levels, and work with our suppliers and partners to reduce emissions across our value chain (scope 3).

After the first target of halving our scopes 1 & 2 emissions by 2030, we are committed to reaching carbon neutrality in our own production by 2035. To achieve this, on top of the identified short-, medium- and long-term decarbonization measures, credible additional actions are needed within or beyond our value chain to neutralize or mitigate the residual emissions.

Energy consumption and mix

Neste reported energy consumption and mix in accordance with ESRS E1-5 for the first time in 2024. The scope of reporting is aligned with the European Sustainability Reporting Standards (ESRS), and 2024 data is not directly comparable with 2022 and 2023 disclosures due to changes in methodology and scope.

Energy consumption by source (MWh)

Energy intensity

Energy production

Methodology and scope: Energy consumption and production data is collected from Neste's own measurement devices or via energy invoices. Estimates were used for minor energy consumption sources like small rented offices and own logistics. Data coverage is estimated to be >99%. Market-based scope 2 accounting covers contractually purchased electricity bundled with instruments, such as Guarantees of Origin (GoOs). In 2024, 86.2% of Neste's total electricity usage was covered by GoOs. Unbundled renewable energy certificates are not utilized for scope 2 market-based accounting. Energy intensity covers all Neste operations in operational control. Relevant high climate impact sectors (based on NACE) include activities related to Neste's refining operations, sale and trading of fuels and raw materials, retail sale of fuels, shipping operations and other supporting activities.

Comparability note: The scope of reporting for 2024 is aligned with ESRS requirements. 2024 data is not comparable with 2022 and 2023 disclosures due to changes in methodology and reporting boundaries. Historical years did not include the full disaggregation by source category required under ESRS E1-5.

Gross Scopes 1, 2, 3 and Total GHG emissions

Overview

Neste reports greenhouse gas (GHG) emissions following the GHG Protocol Corporate Standard and its supplement Corporate Value Chain (Scope 3) Accounting and Reporting Standard. The reporting includes emissions of the GHGs covered by the GHG Protocol. Emissions have been converted into carbon dioxide equivalents.

Scope 1: Direct GHG emissions

Scope 1 emissions from refining and Neste owned fleet (tCO₂e):

Breakdown by source: Not disclosed at sub-category level (stationary combustion, mobile combustion, process emissions, fugitive emissions).

Scope 2: Indirect GHG emissions from purchased energy

Scope 2 emissions (tCO₂e):

Scope 3: Other indirect GHG emissions from value chain

Scope 3 emissions by GHG Protocol category (tCO₂e):

Notes:

• ⁴Part of upstream transportation emissions are accounted in other categories.
• ⁵Part of downstream transportation emissions are accounted in category 4.
• Categories 2 (Capital goods), 6 (Business travel), 7 (Employee commuting), 8 (Upstream leased assets), 10 (Processing of sold products), 13 (Downstream leased assets), and 14 (Franchises) are not disclosed separately.

Upstream value chain emissions (scope 3): 8.6 MtCO₂e (2024) Downstream value chain emissions (scope 3): 47.9 MtCO₂e (2024)

Total GHG emissions (Scopes 1 + 2 + 3)

GHG intensity

Note:

• ³Use phase emission intensity is calculated by dividing the emissions from the use of fuel products sold by Neste (part of scope 3) with the total amount of sold energy (gCO₂e/MJ).

Biogenic CO₂ emissions

Not disclosed separately.

Methodology notes

Scope of reporting: Aligned with the European Sustainability Reporting Standards (ESRS). 2024 data is not comparable with 2022 and 2023 disclosures due to scope changes.

Consolidation approach: The scope of consolidation of sustainability reporting is in principle the same as for the financial statements. Entities that are subsidiaries or controlled similarly to subsidiaries are fully included in the reporting scope. Joint operations, joint ventures and associates, including Martinez Renewables, are excluded from sustainability reporting.

GHG Protocol alignment: Neste follows GHG Protocol Corporate Standard and its supplement Corporate Value Chain (Scope 3) Accounting and Reporting Standard. The reporting includes emissions of the GHGs covered by the GHG Protocol. Emissions have been converted into carbon dioxide equivalents.

EU ETS coverage: In 2024, 94% of Scope 1 emissions were from regulated emission trading schemes (2023: 90%, 2022: 98%).

Carbon handprint

Customer GHG emissions reduction (MtCO₂e):

Note: Carbon handprint describes the difference of carbon footprint of a product or service and a baseline product or service. Neste's customer GHG emissions reduction is calculated by aggregating the customer's GHG emission reduction for each batch of renewable products delivered to Neste's customers. The GHG emission related to each batch is compared with the GHG emission that the same quantity of a fossil fuel reference (baseline) would emit.

To align our investment decisions to support our climate commitments, Neste applies an internal carbon price for our scope 1 & 2 GHG emissions in investment calculations, business case evaluations and strategic planning.

Since 2020, evaluating the production carbon footprint (scope 1 & 2) emission impact of investment decisions has been mandatory at Neste. To increase the transparency of the different GHG emission impacts of our investments, we have introduced new criteria and guidelines to enable our project teams to evaluate all the potential climate impacts of the possible investments.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Time horizons

The time horizons used in the scenario assessment are defined as:

• Short-term: 1–2 years
• Medium-term: 3–5 years
• Long-term: over 6 years

These align with and cover strategic planning, capital allocation as well as expected lifetime of assets. Neste's strategic planning focuses on the next 10 years, with the scenario analysis extending to 2050 to account for the increasing impact of climate change.

Climate scenarios used

Neste bases the scenario analysis on internationally acknowledged climate pathways published by the International Energy Agency (IEA). In 2024, the implications for Neste were analyzed in three climate scenarios:

• Net Zero World 2050: in line with the 1.5°C pathways
• Net Zero EU and North America by 2050: consistent with a 2°C trajectory
• Compromised Climate Targets: reflecting global warming of 2.5°C or more by the end of the century

Identified transition risks

Neste has identified two material climate-related transition risks related to climate policy developments:

1. Development in legislation could lead to a competition disadvantage or to the loss of existing or potential markets for Neste
2. Policy developments which could lead to the undermined competitiveness of Neste's key raw materials

No material physical climate risks were identified in the double materiality assessment.

Specific assets at transition risk

Neste has identified its Porvoo refinery and oil refining business as assets and activities at risk due to climate policy developments and the transition to a lower-carbon economy.

Neste's ambition is to gradually transform the oil refinery in Porvoo, Finland into a leading renewable and circular solutions refining hub in the mid-2030's. Neste ended refinery operations at its Naantali oil refinery in 2021, and the refinery has been fully decommissioned. When finalized, the transformation of Porvoo refinery will complete Neste's journey to a 100% renewable and circular solutions producer.

Potential implications of climate change to Neste

Methodology

Neste calculates the impacts and tests its strategy resilience against the scenarios by estimating the impact on Neste's profitability compared to a base case. The results are used to support Neste's strategy development and financial planning, and the identified climate risks are included in Neste's Enterprise Risk Management (ERM) process.

The scope of the annual scenario analysis covers Neste's entire value chain at a high level. Analysis includes assessment of scenario drivers, implications on the business environment and on Neste's businesses and strategy. The analysis focuses on transition risks such as the anticipated financial effects related to e.g., climate policy developments.

Uncertainties

Uncertainties related to scenario analysis include:

• The pace and scope of regulatory changes
• Technological advancements
• Market dynamics
• The varying impacts of climate change across geographies and industries
• The use of national or regional data

These factors affect the considered projections for energy demand, the adoption of lower-carbon technologies and the global transition to renewable solutions. The impact potential of these drivers on Neste are evaluated in short-, medium- and long term time horizons with varying degrees of certainty.

Alignment with financial statements

Neste incorporates application requirement 15 in the E1 Climate change standard by reference to its Financial statements. Key climate-related assumptions made in the financial statements are described in Note 2 Accounting Policies in Neste's Consolidated Financial Statements, under the heading 'Climate related topics'. The assumptions are based on the same scenario analysis and identified risks and opportunities as described in this section.

Resilience analysis

Impacts, risks and opportunities identified and assessed as material in the double materiality assessment are central to Neste's strategy and included e.g., in decision-making considering major investments and capital allocation. Neste believes to be well positioned to adjust its strategy and business models to climate change. Neste's strategy aims at growing in more sustainable solutions, which supports business resilience, and for instance raw material and business model choices can be adjusted depending on the conditions in the business environment.

We follow strict criteria to mitigate pollution related environmental impacts and risks. Our focus areas for biodiversity management include pollution: We mitigate environmental impacts from pollution as required under the applicable environmental regulations.

Identifying chemical substances included in the various regulatory reporting schemes is becoming increasingly important. In 2024, we developed tools and data to manage the new EU Corporate Sustainability Reporting Directive (CSRD) requirements for reporting Substances of Concern. We also continued the work to ensure safe handling of chemicals at Neste to prevent hazardous exposure for workers.

In 2024, we developed tools and data to manage the new EU Corporate Sustainability Reporting Directive (CSRD) requirements for reporting Substances of Concern. We also continued the work to ensure safe handling of chemicals at Neste to prevent hazardous exposure for workers.

New wastewater treatment units have been recently installed in Porvoo and Singapore. A new wastewater treatment unit is being completed at the Rotterdam refinery and will start operation with the expansion of the production unit.

In 2024, we had 15 environmental permit violation cases at refineries (12), pre-treatment plants (1) and terminals (2) with limited local environmental impact. No serious environmental incidents occurred at Neste's refineries or terminals in 2024.

New wastewater treatment units have been recently installed in Porvoo and Singapore. A new wastewater treatment unit is being completed at the Rotterdam refinery and will start operation with the expansion of the production unit.

Detailed pollution data including air emissions, water discharges, and waste generation is provided in the Sustainability data package.

Substances of concern and substances of very high concern

Metrics

Reporting principles

Chemical substances

The substance is a substance of concern (SoC) if it:

• Is a Substance of Very High Concern (SVHC) as identified in accordance with the EU REACH Regulation and added by ECHA to the candidate list for authorization (subsection i. in the definition of SoC in EC 2023/2772);
• Has harmonized classification in Part 3 of Annex VI to CLP Regulation with one of the hazard classes or hazard categories declared in the subsection ii. in the definition of SoC in EC 2023/2772;
• Has negative effects on reuse and recycling according to the EU product-specific ecodesign requirements. Ecodesign for Sustainable Products Regulation (ESPR) entered into force in July 2024, and it establishes a framework for setting ecodesign requirements on specific product groups.

Chemical substances are identified by the CAS/EC number that is declared in the SVHC list and in Annex VI to CLP. Neste has introduced CAS/EC numbers of the chemicals in the ERP systems so that substances of concern can be screened and amounts calculated.

None of the chemicals Neste supplies as feedstock or manufacturers is listed in the SVHC list by ECHA. However, many of the petroleum products are included in the Annex VI to CLP due to harmonized classification of health effects such as carcinogenicity. Majority of the reported amounts are from substances that are hazardous to health because there is no harmonized environmental classification in CLP Annex VI e.g., for petroleum products. However, petroleum products have properties that are hazardous to the environment and thus self-classified to indicate the environmental hazards. The self-classification is declared e.g., in the safety data sheets.

Emissions

Production sites shall evaluate SoC emissions that are identified as significant in accordance with their environmental permits or other authority or legal requirements. The main reference for the identification is the Annex II of the Industrial Emission Portal Regulation (EC) No. 2024/1244, which also covers the most significant SoC/SVHC polluting substances.

In 2024, Neste reports the total amount of substances of concern that leave its refineries as emissions to the environment and that can be identified with certainty, for example based on the CAS number. The reporting refers to the Annex II of the EU's Industrial Emissions Portal Regulation (2024/1244) and focuses on those substances that exceed the threshold values of the aforementioned Regulation for air, water and soil. In terms of air emissions, reported pollutants are carbon monoxide (over 95% of total reported SoC emissions) and benzene. Carbon monoxide is formed in the combustion processes, but upon entering the atmosphere, it oxidizes further into carbon dioxide, which is not classified as a SoC. Less than 0.1% of total SoC emissions (such as phenol, nickel and zinc) end up in water courses. These emissions have not been found to have a significant impact on, for example, the state of receiving water bodies.

Benzene has been identified and reported as the most significant SoC substance of NMVOC emissions at the Porvoo refinery. Neste is aware that other SoC substances can potentially also be present in NMVOC emissions. The total NMVOC of oil refineries is calculated as total carbon and the exact composition has not been reported. As the reporting definitions become more precise and the general knowledge base accumulates, the reporting of SoC emissions will be re-evaluated.

Validation by an external body other than the assurance provider

Neste is subject to annual environmental authority inspections and conducts emission reporting to competent authorities in the EU. Neste shall annually report to its competent authority data on the releases to air, water and land of any pollutant listed in IEPR Annex II for which the applicable threshold specified in that Annex is exceeded. The authorities assess the quality of the data, in particular the accuracy, completeness, consistency and credibility. This process is based on the requirements of the Industrial Emissions Portal Regulation (IEPR).

In Singapore the national water agency (PUB) regulates the sewerage system, as well as the treatment and discharge of industrial wastewater into public sewers. The industrial wastewater from the Singapore refinery is discharged to these sewers. If necessary, they must be treated to specified standards before being discharged into a sewer.

Management approach

Substances of concern are recognised and tracked in Neste's internal IT systems. There are a variety of existing regulatory requirements in place for notifying manufactured and imported chemicals and their yearly volumes to the national authorities. By managing these and many other EU and national requirements Neste has gathered depositories of data on hazardous chemicals. Reporting substances of concern as defined in the ESRS are managed together with the work related to these regulatory requirements. Neste continues to develop accounting of substances of concern for CSRD reporting.

Through the implementation of the Neste OEMS, the company aims to ensure that product compliance and chemical safety hazards are effectively managed in its operations. The OEMS includes the Neste Product & Chemical Safety Principle, which outlines mandatory chemical legislation requirements and their handling across its operations. It covers the mitigation of material risks related to Neste's use and processing of substances of concern. Neste is dedicated to product and chemical safety, ensuring compliance with regulations, minimizing risks, and fostering a sustainable approach to chemical management.

The Product & Chemical Safety Principle mandates the identification of substances of concern. Neste is actively working towards substituting chemicals with less harmful alternatives where possible and increasing the use of renewable raw materials and products. This shift towards renewable resources is key in gradually reducing the presence of substances of concern in Neste operations.

Neste carefully follows and takes due care in implementing various chemical compliance and safety regulations, like the EU REACH and CLP Regulations, that aim to ensure a high level of protection of human health and the environment. Part of Neste's revenue is based on manufacturing and selling products that contain substances of concern – chemicals like transportation and marine fuels.

We believe that by implementing water stewardship, we can also build more resilient operations. We are therefore working to update our approach to water and related targets to achieve a nature positive value chain by 2040. In 2024, we continued to develop our water stewardship approach at our sites as part of the update of our environmental management principle.

Our focus areas for biodiversity management include Water: We promote sustainable water use.

Currently, we are focusing on strengthening the water balance management. A new wastewater treatment unit is being completed at the Rotterdam refinery and will start operation with the expansion of the production unit. New wastewater treatment units have been recently installed in Porvoo and Singapore.

According to our company-wide Environmental Management Principle, major investment projects include an Environmental Compliance Analysis and a compliance review when building new production capacity or increasing current capacity.

The most recent water risk evaluation of Neste sites was undertaken in 2024, based on the WWF water risk filter tool's 2024 update and new Water Availability data layer that is in line with SBTN criteria. All our refineries are located in low-risk areas, but the updated evaluation indicates that Neste has six small-scale collection and recycling sites for waste and residue raw material in high and two sites in moderate water availability risk areas.

Elevated water risks can cause potential pressure in the pricing of water resources. Both water intake and wastewater treatment have been considered in long-term operational financial planning.

Detailed water consumption data is provided in the Sustainability data package.

Nature positive value chain by 2040

Neste aims to drive a positive impact on biodiversity and achieve a nature positive value chain by 2024. A nature positive value chain means that throughout our value chain, we create more positive impacts on nature than causing adverse ones.

Our phased approach:

• 2025: Net positive impacts - Aim to create net positive impacts (NPI) for biodiversity from new activities from 2025 onward.
• 2035: No net loss - Target no net loss (NNL) of biodiversity from all ongoing activities by 2035.
• 2040: Nature positive impact throughout our value chain.

To achieve these goals, we apply the mitigation hierarchy to manage our biodiversity impacts: Avoid and minimize all negative impacts, restore affected areas and finally compensate for the residual impacts from our own operations.

Our focus areas for biodiversity management include: • Land: We avoid the conversion of habitats with valuable biodiversity and aim to prevent deforestation. • Water: We promote sustainable water use. • Pollution: We mitigate environmental impacts from pollution as required under the applicable environmental regulations.

Neste has identified some vulnerable species and habitats to protect on our land, and within the Naantali terminal three hectares of forest have been protected. We follow strict criteria to mitigate pollution related environmental impacts and risks.

In 2024, we reinforced our commitment to a nature-positive value chain. Building on insights from the SBTN pilot, we continued to map material impacts on our supply chain by identifying, assessing and prioritizing raw materials and regions critical for biodiversity.

Building on the development of our No Net Loss (NNL) and Net Positive Impact (NPI) methodology pilots in 2023, we continued to refine our NPI approach in future investment projects.

In 2024, we defined criteria for application of the mitigation hierarchy within Neste's new investments. This included development of new internal guidance for investment projects to follow. The first investment projects have started to implement the criteria in their development.

Implementing this approach is a key step toward creating net positive impacts on biodiversity from new activities starting in 2025.

Biodiversity approach development with Fauna & Flora: Our collaboration with Fauna & Flora, initiated in 2022, has been instrumental in developing Neste's biodiversity work. As an international, world´s oldest wildlife conservation charity, they have supported us in creating an approach to net positive impacts and nature positive value chain.

Our biodiversity targets:

• 2025: Create net positive impacts (NPI) for biodiversity from new activities in our own operations from 2025 onward.
• 2035: Target No Net Loss (NNL) of biodiversity from all ongoing activities in our own operations by 2035.
• 2040: Aim to create nature positive impact throughout our value chain by 2040.

We are also exploring the introduction of time-bound targets to support our efforts in achieving a nature-positive value chain.

The scope of "Net positive impact" (NPI) and "No net loss" (NNL) approach is set for Neste's own operations. No net loss means net zero impact on biodiversity. NPI and NNL aim to address impacts through a mitigation hierarchy: avoiding and minimizing losses, restoring affected areas, and finally compensating the residual impacts, so that no biodiversity loss remains, and a positive impact is created.

Impact metrics related to biodiversity and ecosystems change

Neste follows key frameworks and engages in collaborations in developing impact metrics related to biodiversity. For example, Neste has been collaborating with Fauna & Flora and SBTN to develop a methodology for Neste.

Land use and habitat protection

Protected forest areas:

• Naantali terminal: 3 hectares of forest have been protected (out of total 300 hectares in Naantali)
• Status: The company has voluntarily protected forest areas in accordance with national legislation at the former refinery site in Naantali

Operations near protected areas

• No material biodiversity-related negative impacts or negative effects on biodiversity-sensitive areas have been identified for Neste sites
• Biodiversity baseline inventories were undertaken at Porvoo and Naantali sites in Finland between 2022 and 2023
• Certain areas with moderate biodiversity values with potential for biodiversity impact mitigation were defined
• The land is for the most part not considered areas of high biodiversity value
• Some vulnerable species and habitats have been identified to protect on land in Porvoo and Naantali

Methodology development

• Neste completed materiality analysis of biodiversity impacts according to SBTN guidance for upstream and direct operations
• Key development areas for Neste's renewable supply chain were identified through the SBTN validation pilot
• The company is developing action plans on land, water and pollution across the value chain
• Collaboration with Fauna & Flora has supported gaining local knowledge of material supply chains

Note: The company states it is developing impact metrics and methodology in collaboration with Fauna & Flora and SBTN but has not yet disclosed quantified metrics for land use footprint, deforestation footprint, species impact metrics, ecosystem condition metrics, or restoration metrics beyond the 3 hectares of protected forest.

We create solutions for mitigating climate change and shifting toward the circular economy by refining waste, residues, and innovative raw materials into renewable fuels and sustainable feedstock for polymers and chemicals.

Neste has been advancing chemical recycling to accelerate the transition to a circular economy for plastics. We are using raw materials like liquefied waste plastic and liquefied discarded rubber tires and refine them into high-quality drop-in feedstock for the production of new plastics.

Neste provides the polymers and chemicals industries with renewable and circular solutions that help mitigate climate change, combat plastic waste pollution and reduce dependence on fossil resources.

To scale up chemical recycling, we are building upgrading capacities for 150,000 tons of recycled raw materials, such as liquefied waste plastic, per year. The new unit is planned to be finalized in 2025. In 2024, we continued our processing runs at our Porvoo refinery.

In 2024, we continued to build chemical recycling capacities at the Porvoo refinery in Finland. The new upgrading facility will be completed in 2025, increasing our processing capacity for recycled raw materials, such as liquefied waste plastics, to 150,000 tons annually.

Collaborations:

• Successful first processing trial run with a challenging new raw material, liquefied discarded tires.
• Strengthening chemical recycling logistics infrastructure in Europe in cooperation with Tepsa Netherlands and at the Porvoo refinery.
• Cooperating with Alterra and Technip Energies to accelerate scale up of liquefaction capabilities.
• Project agreement with Borealis and Covestro to enable the recycling of discarded tires into high-quality plastics for automotive applications.

ESRS E5-4: Resource Inflows

Renewable and Recycled Raw Material Inputs

Neste reports its renewable raw material inputs globally, with a breakdown between waste and residues versus vegetable oils:

Renewable feedstock composition:

• Used cooking oil (UCO): oils and fats of vegetable or animal origin used by the food industry or restaurants to cook food for human consumption
• Animal fat from food industry waste: derived from the food industry's meat processing waste
• Vegetable oil processing waste and residues: including palm fatty acid distillate (PFAD), spent bleaching earth oil (SBEO), empty fruit bunch oil (EFBO), and palm oil mill effluent (POME)
• Other waste and residues: fish fat from fish processing waste, tall oil based raw materials, food waste, technical corn oil and acid oils
• Vegetable oils: in 2024, the share of vegetable oils such as rapeseed oil, soybean oil and sunflower oil was approximately 10% of global renewable raw material inputs

Traceability: For palm fatty acid distillate (PFAD), Neste reports that 100% of supply was mapped to palm oil mills and 90% was traceable to plantations in 2024.

Fossil Raw Material Inputs

Recycled Raw Materials

Neste has been advancing chemical recycling using:

• Liquefied waste plastic
• Liquefied discarded rubber tires

These are refined into high-quality drop-in feedstock for the production of new plastics. Neste is building upgrading capacities for 150,000 tons of recycled raw materials per year, with the new unit planned to be finalized in 2025.

Non-Renewable Resource Replacement

In 2024, Neste's renewable and circular solutions helped replace 4.0 million tonnes (3.0 Mt in 2023) of non-renewable resources in transport, aviation and polymers and chemicals sectors. This calculation is based on energy-based comparison with relevant fossil references, with the difference expressed as the energy content of crude oil.

Total Resource Inflows Summary

Resource outflows

Neste's renewable and circular solutions helped replace 4.0 Mt of non-renewable resources in transport, aviation and polymers and chemicals sectors in 2024 (compared to 3.0 Mt in 2023 and 3.1 Mt in 2022).

Renewable Products

Neste provides renewable diesel, sustainable aviation fuel (SAF), and renewable feedstock for polymers and chemicals:

• Renewable diesel: In 2024, greenhouse gas (GHG) emission reduction customers could achieve by switching fossil diesel to Neste MY Renewable Diesel™ was up to 75% or up to 95% over the life cycle of the fuel compared to fossil diesel. Neste MY Renewable Diesel is a drop-in solution, which means it can be used in existing diesel vehicles and fuel infrastructures as such.

• Sustainable aviation fuel: Neste MY Sustainable Aviation Fuel™ (SAF) is made from 100% renewable waste and residue raw materials. In its neat form, Neste MY SAF can reduce greenhouse gas emissions by up to 80% over the fuel's life cycle compared to using fossil jet fuels. The fuel can be used as a drop-in solution, as it is compatible with existing aircraft engines and airport fuel infrastructure, requiring no extra investment in them.

• Renewable and recycled feedstock for polymers and chemicals: Renewable Neste RE is produced with renewable raw materials, primarily waste and residue oils and fats. Life cycle assessment (LCA) shows renewable Neste RE produced via renewable refineries has a more than 85% smaller carbon footprint over its entire life cycle compared with fossil feedstock. Recycled Neste RE is a product from the chemical recycling of hard-to-recycle plastic waste or discarded rubber tires. LCA on recycled Neste RE shows a reduction of more than 35% of GHG emissions when plastic waste is chemically recycled instead of incinerated and then used to replace fossil feedstock in plastics manufacturing.

Circular Economy Approach

Neste has been advancing chemical recycling to accelerate the transition to a circular economy for plastics. Raw materials like liquefied waste plastic and liquefied discarded rubber tires are refined into high-quality drop-in feedstock for the production of new plastics. To scale up chemical recycling, Neste is building upgrading capacities for 150,000 tons of recycled raw materials, such as liquefied waste plastic, per year. The new unit is planned to be finalized in 2025.

No specific product durability, warranty periods, repairability scores, or design-for-circularity targets are disclosed for products.

Waste

Total Waste Generated

Waste Management Approach

Waste volumes are based on invoicing data. 25% of total waste generated in 2024 was recovered or recycled.

The waste volumes are reported from Neste's own operations. Calculation principles are detailed separately under "Principles for calculating the key indicators".

Neste follows applicable local discharge permits and requirements. Waste waters are treated to meet requirements before safe discharge.

Our Human Rights Principle outlines seven priority areas for human rights at Neste: fair employment; health & safety; equity, diversity & non-discrimination; children & young workers; modern slavery; fair treatment and economic, social & cultural rights.

Neste's Code of Conduct provides the framework for our global business operations and is a key element of our compliance program. We follow the Neste Occupational Health Principle throughout the organization, subject to local legislation and requirements.

Our Safety Leadership Principle outlines our ambitions, expectations and accountabilities for all employees and anyone working for the company. Safety management and its continual improvement is defined by the Neste Operational Excellence Management System (OEMS).

We actively listen to employee feedback by conducting global employee engagement surveys regularly. The survey results are discussed systematically across the organization and translated into actionable plans at all levels of the organization. In addition, we conduct employee surveys targeted at specific groups – for example, new joiners and summer trainees, as well as employees leaving the company.

At a local level, a key element of employee cooperation is that it is driven by local requirements in each country of operation. Neste is committed to following applicable local collective agreements and has local cooperation bodies or works councils in Finland, Rotterdam and Singapore. In 2024, a works council was also established in Amsterdam.

As a result of requests from Neste employees, Neste started negotiations with employee representatives aiming to establish a European Works Council (EWC) that is based on EU legislation.

We believe in open communication and continuous learning from one another, and encourage dialogue to build engagement.

In 2024, we established site-level complaint channels for third-party workers during the Porvoo refinery turnaround to address their concerns. We use a range of practices to inform workers about their rights and address their concerns, e.g. informative posters and leaflets, induction sessions, contractor social audits, social toolbox meetings, and site-level complaints channels.

Neste has established various channels for employees to report concerns and potential violations of our Code of Conduct and other policies. These include management reporting lines, HR channels, and anonymous reporting mechanisms.

Due to the organizational changes implemented in 2024, a significant part of employees were impacted by line manager change, lateral move, demotion, promotion or reclassification of the job. The number of line managers was reduced as the average size of teams increased. The organizational changes led to a reduction of approximately 390 roles globally. Neste offered change support for all employees globally. Career coaching was provided for those who were made redundant.

To improve cost effectiveness and strengthen long-term competitiveness, Neste simplified its organizational structure and operational model and streamlined business and function-level operations during 2024.

We provide versatile learning opportunities to support the growth of our people. To support the growing demand for continuous learning, we launched a new learning platform, WeLearn, in October 2024. The average time spent in learning programs for Neste employees in 2024 was 18.5 hours.

We are committed to training our employees on human rights and labor standards. Human rights training is integrated into our global induction for new employees and all Neste employees are required to complete a mandatory Code of Conduct e-learning course, which includes topics on advancing respect for human and labor rights.

In 2024, we supported the wellbeing of our employees by providing various services globally and additional support like webinars on change adaptation and resilience.

We encourage everyone to be the leader of their own development by driving clarity, supporting growth and empowering renewal. This includes regular Forward discussions with line managers to discuss development plans and set learning goals.

By the end of 2024 Neste employed an average of 5,876 employees with approximately 629 new employees globally, of whom approximately 64% were permanent positions.

The organizational changes led to a reduction of approximately 390 roles globally. There was also an increase in both the geographical dispersion and share of multinational teams.

Detailed workforce characteristics including employee numbers by region, employment type, age, and gender are provided in the Sustainability data package on pages 37-62.

During the Porvoo Turnaround 2024, some 7,600 people took part in the turnaround works and completed over 1.4 million working hours. We pay special attention to safeguarding the rights of migrant workers and third-party employees working for contractors and subcontractors on Neste sites, especially during peak times such as our expansion projects, shutdowns and turnarounds.

We use a range of practices to inform these workers about their rights and address their concerns, e.g. informative posters and leaflets, induction sessions, contractor social audits, social toolbox meetings, and site-level complaints channels.

Detailed information on non-employee workers is provided in the Sustainability data package.

At a local level, a key element of employee cooperation is that it is driven by local requirements in each country of operation. Neste is committed to following applicable local collective agreements and has local cooperation bodies or works councils in Finland, Rotterdam and Singapore. In 2024, a works council was also established in Amsterdam.

As a result of requests from Neste employees, Neste started negotiations with employee representatives aiming to establish a European Works Council (EWC) that is based on EU legislation.

Detailed collective bargaining coverage data is provided in the Sustainability data package.

We embrace diversity, equity and inclusion. Our Human Rights Principle outlines equity, diversity & non-discrimination as one of our seven priority areas for human rights at Neste.

Our Human Rights ambition for 2030 includes reducing inequality: By 2030, we will reduce inequalities across the value chain and address the root causes of systemic human rights issues. Advance diversity, equity and inclusion in our own businesses and supply chains.

Detailed diversity metrics including gender distribution across management levels and age demographics are provided in the Sustainability data package.

Adequate wages

Benchmark used

Neste uses Fair Wage Network (FWN) as its living wage benchmark.

Coverage and assessment

• Own workforce: In 2024, Neste completed its annual internal living wage gap assessment covering all countries in its global operations, using data provided by the Fair Wage Network. The analysis of assessment results is described as ongoing.

• Supply chain: Neste assesses living wage practices in its upstream supply chains. In 2024, the company assessed the living wage practices of 11 renewable raw material suppliers. Living wage data is used in the onboarding process and sustainability audits for renewable raw material suppliers.

• Worker voice surveys: In 2024, Neste conducted 501 anonymous worker surveys in supply chains across Asia and North America, covering topics including living wages.

Targets and commitments

Neste commits to:

• Pay all of our employees a living wage (stated as part of 2030 sustainability vision)
• Require strategic contractors and suppliers to pay their employees a living wage by 2030
• Take action to promote living wages in Neste's supply chains

The company states: "We pay all of our employees a living wage, take action to promote living wages in Neste's supply chains, and require strategic contractors and suppliers to pay their employees a living wage by 2030."

Methodology

• Data source: Fair Wage Network provides the living wage data
• Assessment frequency: Annual internal living wage gap assessment
• Scope: Covers all countries in Neste's global operations
• Analysis: The company analyzes diverse remuneration elements in all locations
• Supplier engagement: Living wage data is used to gain understanding of supplier wage practices and raise awareness among suppliers
• No specific gap percentages or findings disclosed: The company states "analysis of assessment results is ongoing" but does not report the percentage of employees earning below living wage or specific gap amounts

Geographic scope

Global - covers all countries where Neste operates. No geographic exclusions mentioned.

Value chain extension

Neste extends living wage requirements to strategic contractors and suppliers, with a 2030 deadline. The company uses living wage assessments in sustainability audits and capacity building for renewable raw material suppliers.

We offer versatile global services to ensure efficient ways of working and to support wellbeing at work as well as work-life balance. In 2024, we supported the wellbeing of our employees by providing various services globally and additional support like webinars on change adaptation and resilience.

We follow the Neste Occupational Health Principle throughout the organization, subject to local legislation and requirements.

Detailed information on social protection and benefits is provided in the Sustainability data package.

We embrace diversity, equity and inclusion. Our approach to diversity includes supporting persons with disabilities as part of our commitment to creating an inclusive workplace.

Information on persons with disabilities in our workforce is provided in the Sustainability data package where available and in compliance with local privacy regulations.

We provide versatile learning opportunities to support the growth of our people. To support the growing demand for continuous learning, we launched a new learning platform, WeLearn, in October 2024. The platform offers personalized learning experiences to help employees discover new learning opportunities based both on role requirements and personal skills and interests.

In 2024, we organized several strategic development programs for different target groups with the help of our partners. The programs are built on strategy and leadership and are delivered by top-of-the-field professors to ensure an inspiring learning experience.

Training metrics:

• Average time spent in learning programs for Neste employees in 2024 was 18.5 hours
• Company-wide development programs had more than 640 participants

We encourage everyone to be the leader of their own development by driving clarity, supporting growth and empowering renewal. This includes regular Forward discussions with line managers to discuss development plans and set learning goals.

Health and safety metrics

Coverage of health and safety management system

Neste reports that 100% of its own workforce is covered by the company's occupational health and safety management system, as stated in the Sustainability statement under S1-4.

Fatalities

Recordable work-related accidents and injury rates

Note on scope: Excludes green-field expansion projects where Neste is not responsible for the construction site. TRIF and LWIF rates are calculated per million hours worked. In 2024, there were 49 injuries in total, of which 20 involved contractors. Total working hours were approximately 10,290,000 for employees and 11,614,000 for contractors.

Days lost to work-related injuries

Neste has not disclosed the number of days lost to work-related injuries, fatalities, or work-related ill health for the reporting period. This metric is marked as 'Not disclosed' in the ESRS S1-14 disclosure table.

High-consequence injuries and work-related ill health

Neste reports that in 2024 there were no injuries resulting in permanent effects on health, and 6 cases resulted in long absences from work. Main injury types were cuts, punctures or scrapes, slips, trips and falls, or caught in, under or between incidents.

Occupational diseases are recorded separately from work-related injuries. Neste records all work-related injuries and has defined practices in its Operations Excellence Management System (OEMS) to minimize hazards and mitigate risks relating to work-related ill health or injuries.

We offer versatile global services to ensure efficient ways of working and to support wellbeing at work as well as work-life balance. In 2024, we supported the wellbeing of our employees by providing various services globally and additional support like webinars on change adaptation and resilience.

Our wellbeing model defines the various aspects of wellbeing, in which we all play a part. We follow the Neste Occupational Health Principle throughout the organization, subject to local legislation and requirements.

Detailed work-life balance metrics are provided in the Sustainability data package where available.

Compensation metrics (ESRS S1-16)

Neste has applied the phase-in provision under ESRS 1 Appendix C for its first year of CSRD reporting (2024). As a result, certain S1-16 disclosures are omitted during this initial reporting period.

Pay gap

Not disclosed. The company has not reported unadjusted or adjusted gender pay gap figures for 2024.

Remuneration ratio

Not disclosed. While Neste reports average total compensation for employees and total compensation of the CEO in its GRI disclosures (see GRI 2-21 on page 48), no specific CEO-to-median employee remuneration ratio is provided for ESRS S1-16 purposes.

Methodology

The company has indicated in its ESRS disclosure table (page 148) that both the unadjusted gender pay gap (ESRS S1-16 paragraph 97(a)) and the excessive CEO pay ratio (ESRS S1-16 paragraph 97(b)) are assessed as "Not material" for disclosure purposes. The company has applied the ESRS phase-in provisions for its first year of reporting under CSRD.

In 2024, we established site-level complaint channels for third-party workers during the Porvoo refinery turnaround to address their concerns. We use a range of practices to inform workers about their rights and address their concerns.

Neste has established various channels for employees to report concerns and potential violations of our Code of Conduct and other policies. These include management reporting lines, HR channels, and anonymous reporting mechanisms.

In 2024, we conducted 501 anonymous worker surveys in our supply chains across Asia and North America using worker voice technology. The survey provides insights into various topics affecting workers employed by our suppliers and contractors – for example, inequality, living wages, recruitment fees and children's access to education.

Detailed information on incidents, complaints and human rights impacts is provided in the Sustainability data package.

We require all our suppliers and business partners to comply with applicable laws and expect them to follow equivalent ethical business standards, as outlined in our Supplier Code of Conduct.

Neste Supplier Code of Conduct outlines the basic requirements Neste expects its suppliers and their first tier suppliers, contractors and business partners to adhere to and implement throughout their businesses. The Code covers five key elements: Compliance with laws and regulations; Business conduct; Environmental impact and climate change; Human and labor rights; Occupational health, safety and security.

All Neste´s renewable raw material suppliers are subject to rigorous sustainability due diligence, as stated in Neste's Supplier Sustainability Approval Principle.

In 2024, we conducted capacity building training for our renewable raw material suppliers in Asia, Oceania, the Americas and EMEA. The focus last year was on health and safety, as the majority of the findings of the renewable raw material supplier audits in 2023 were related to safety practices. In addition, capacity building training was held on the topics of environmental management and human rights.

Neste invited all its active suppliers and encouraged its main suppliers to invite their suppliers to the training. More than 80 raw material suppliers joined these different capacity building training sessions with over 120 participants globally.

We use worker voice technology to enable direct and anonymous engagement with workers on mobile devices. In 2024, we conducted 501 anonymous worker surveys in our supply chains across Asia and North America.

We assess human rights risks when planning to enter new sourcing regions for our renewable raw materials. Our sustainability screening for raw material suppliers and our sustainability audits have a strong human rights focus and prioritize the assessment of impacts on people.

In 2024, we conducted a total of 141 sustainability audits: 66 on renewable and recycled raw materials; 38 on terminals; and 37 contractor audits. Of these, 66 audits were carried out for renewable raw material suppliers.

We have established site-level complaints channels for workers in our value chain and support various reporting mechanisms for addressing concerns.

In 2024, we continued to develop our sustainability due diligence practices by focusing our audits on suppliers with the highest risks and most significant strategic importance. In 2025, we plan to further strengthen our supplier due diligence in accordance with upcoming regulation such as the EU's Corporate Sustainability Due Diligence Directive (CSDDD).

We are committed to advancing responsible recruitment in our operations and value chains, including:

• Adding no-recruitment-fee clauses to contracts with recruitment agencies
• Strictly enforcing Neste Supplier Code of Conduct no-recruitment-fee policy in sustainability audits
• Monitoring implementation of corrective actions from audits of migrant worker recruitment agencies

Audit findings by category (renewable raw material suppliers, %):

• Health & Safety: 46%
• Environment: 37%
• Human and Labor Rights: 10%
• Ethical Business Practices: 8%

We are working toward specific targets related to workers in our value chain as part of our Human Rights ambition 2030:

• Responsible recruitment: We commit to and promote the Employer Pays Principle, with implementation in high risk areas by 2030, to ensure that no worker pays for a job and the costs of recruitment are paid for by the employer, not the worker.

• Living wages: Require strategic contractors and suppliers to pay their employees a living wage by 2030.

In 2024, we assessed the living wage practices of 11 renewable raw material suppliers to gain understanding of supplier wage practices and raise awareness on this topic.

We implement an ongoing process of human rights due diligence that extends across our operations, supply chains, and communities. Our Human Rights Principle outlines our approach to respecting the rights of affected communities.

We continue to use human rights criteria and assessments to inform decision-making on strategic business development, investments and innovation projects. For example, in 2024, we completed a human rights impact assessment for the potential construction and operation of a new unit at Neste's Porvoo refinery. The assessment identified and evaluated potential human rights risks to local communities.

Stakeholder engagement is a key component of Neste's human rights due diligence, extending across our operations, supply chains, and communities. We actively seek opportunities to collaborate with our stakeholders to advance positive systemic change.

In 2024, we completed a human rights impact assessment for the potential construction and operation of a new unit at Neste's Porvoo refinery, which included engagement with local communities to understand potential impacts and develop appropriate mitigation measures.

We have established various channels for communities to raise concerns about our operations. These include local engagement processes and grievance mechanisms appropriate to the communities where we operate.

Our human rights impact assessments include the identification of appropriate channels for affected communities to raise concerns about potential impacts from our operations and projects.

In 2024, we completed a human rights impact assessment for the potential construction and operation of a new unit at Neste's Porvoo refinery. The assessment identified and evaluated potential human rights risks to local communities, construction workers, and future employees at the facility, providing recommended mitigation measures to ensure human rights are respected throughout the project.

We continue to work proactively with local communities where we operate to understand and address potential impacts from our operations and projects.

We are committed to providing safe, high-quality products to our customers. Our approach to product safety and quality is governed by various policies and standards that ensure our products meet regulatory requirements and customer expectations.

We take a comprehensive approach to managing risks related to our own products throughout their lifecycle, including their use by consumers and end-users.

We actively engage with our customers through various channels to understand their needs and address any concerns about our products. This includes direct customer relationships, industry partnerships, and participation in sector initiatives.

We provide customers with comprehensive product information and support to ensure safe and appropriate use of our products.

We have established customer service channels and complaint handling procedures to address any concerns or issues raised by consumers and end-users regarding our products.

Our customer engagement processes include mechanisms for receiving and responding to feedback about product quality, safety, and performance.

We continuously work to improve our products and services based on customer feedback and changing market needs. Our innovation and R&D efforts focus on developing solutions that meet customer requirements while advancing sustainability goals.

We monitor product performance and customer satisfaction to identify opportunities for improvement and ensure our products continue to meet quality and safety standards.

Neste's Code of Conduct provides the framework for our global business operations and is a key element of our compliance program. We are committed to high ethical standards and conduct our business in compliance with applicable laws and regulations. This means acting transparently, responsibly, with integrity and in accordance with our values.

Our culture is based on our values – we care, we have courage, we cooperate. It fosters belonging and encourages conscious decision-making daily. We embrace diversity, equity and inclusion.

Neste's compliance policies, principles and standards are updated regularly and form the basis of our compliance program. They are implemented through communication and training.

We expect our suppliers and business partners to comply with applicable laws and adhere to equivalent ethical business standards, as outlined in our Supplier Code of Conduct.

Neste Supplier Code of Conduct outlines the basic requirements Neste expects its suppliers and their first tier suppliers, contractors and business partners to adhere to and implement throughout their businesses. Neste aims to include Supplier Code of Conduct in the contract terms for suppliers, contractors and other business partners.

All Neste´s renewable raw material suppliers are subject to rigorous sustainability due diligence, as stated in Neste's Supplier Sustainability Approval Principle. In 2024, we conducted a total of 141 sustainability audits.

In 2024, we internally identified gaps in sustainability due diligence within indirect procurement and prioritized key areas for improvement. This included increasing the use of standardized surveys and incorporating sustainability due diligence clauses in more contracts.

We constantly develop our compliance program with special efforts in the defined key focus areas: competition law compliance; anti-corruption; trade sanctions; privacy and anti-money laundering.

In 2024, we revised our Anti-Corruption Principle and Trade Sanctions Principle. As part of our continuous training efforts, we revised and issued an Anti-Corruption e-learning course for 3,700 office workers.

To enhance awareness, we issue regular compliance communication via various channels, including our Compliance Hub channel and global intranet. In 2024, this communication covered topics such as anti-corruption, competition law, trade sanctions and gifts and hospitality.

Incidents of corruption or bribery

Confirmed incidents

In 2024, Neste reported a total of 57 suspected misconducts through various reporting channels, including EthicsOnline. Of these, misconduct by Neste employees was confirmed in 9 cases (2023: 5 cases), related to conflict of interest, attempted fraud, misuse of sensitive information, breach of internal rules, leadership behaviour and/or inappropriate behavior. All confirmed cases led to further actions and/or process improvements.

The confirmed cases of misconduct were not related to corruption, bribery or facilitation payments.

The breakdown of the 57 reported suspected misconducts was as follows:

• Employment matters: 21 reports
• Health & safety: 7 reports
• Conflict of interest: 7 reports
• Inappropriate behavior: 5 reports
• Supplier/business partner misconduct/unethical behavior: 5 reports
• Discrimination and harassment: 3 reports
• Misuse of sensitive information: 3 reports
• Other: 2 reports
• Fraud: 1 report
• Unethical conduct towards clients/suppliers/business contacts: 1 report
• Theft, asset misuse, embezzlement: 1 report
• Bribery, corruption, facilitation payment: 1 report

One investigation was pending at the end of 2024.

Convictions and fines

Under the GRI 205-3 disclosure, Neste reported: "No confirmed incidents during the reporting period."

Under the SASB EM-RM-520a.1 disclosure (Total amount of monetary losses as a result of legal proceedings associated with price fixing or price manipulation), Neste reported: "No legal proceedings."

In the EU Taxonomy section, Neste reported no violations with anti-corruption safeguards.

Investigation and speak-up mechanisms

Neste maintains several reporting channels for suspected misconduct:

Ethics Online: An externally operated misconduct reporting system available 24/7 to all internal and external stakeholders, including supply chain actors. Reports can be made anonymously via phone or web service in multiple languages. The system serves as a grievance mechanism for alleged misconduct in Neste's operations.

Investigation Group: Responsible for evaluating and investigating reported cases in a professional, objective, confidential and prompt manner. The Investigation Group decides on the investigation lead and approach depending on the nature of the allegation. Investigations are impartial, unbiased and based on fact-finding. Where needed, Neste retains independent external forensic and/or legal expertise.

Non-retaliation policy: Neste maintains a strict non-retaliation policy for concerns reported in good faith, aligned with EU Directive 2019/1937 on the protection of whistle-blowers.

Reporting process: Misconduct investigations and outcomes are regularly reported to Neste's Ethics and Compliance Committee and at least annually to the Neste Board Audit Committee.

Anti-corruption programme

Neste has a zero-tolerance policy on corruption and bribery. The company's compliance program includes:

• Anti-Corruption Principle (revised in 2024)
• Anti-corruption e-learning course issued to approximately 3,700 office workers in Q4 2024
• Code of Conduct e-learning (94% completion rate including new joiners)
• Annual Compliance Acknowledgement for leadership members and targeted employees
• Regular compliance risk assessments
• Counterparty compliance screening for business partners covering trade sanctions, politically exposed persons, money laundering, and corruption/bribery risks

Political influence and lobbying activities

Political engagement approach

Neste actively engages with policy makers globally to drive and advance sustainability policies. The company shares its views on policies, laws and regulations with officials and legislators through public consultations, meetings, as well as part of a larger stakeholder dialogue with policymakers. Neste also participates in the work of industry associations.

The company engages with governmental organizations with the following purpose and key topics:

• Driving ambitious and technology neutral policies on climate and GHG emission reduction targets
• Advocating for renewable fuels in transportation and other industries
• Advancing market development for renewable and recycled materials, circular economy
• Advancing sustainable finance

Engagements are organized through:

• Sharing views on policies, laws and regulations with policymakers
• Supporting policymakers with industry insights and information on technological capabilities
• Responding to public consultations and meeting with officials on climate and energy topics
• Maintaining active membership in industry associations

Outcomes are taken into account by:

• Monitoring regulatory and legislative development that can affect e.g. the demand outlook of renewable and circular solutions to influence strategy planning
• Developing processes and operations to ensure compliance with relevant laws and regulations

Ethical standards and guidelines

Neste's compliance policies, principles and standards are updated regularly and form the basis of the company's compliance program. These are implemented through communication and training.

The company expects its suppliers and business partners to comply with applicable laws and adhere to equivalent ethical business standards, as outlined in the Supplier Code of Conduct.

Neste carries out annual compliance risk assessments to support a risk-based approach and to guide compliance efforts and risk prevention and mitigation actions in the organization.

Political contributions

Neste does not make political contributions.

Trade association memberships

Neste maintains active membership in industry associations. The company collaborates with industry associations on key topics including:

• Safety
• Climate change mitigation
• Transport emissions reductions
• Renewable and circular solutions
• Circular economy
• Plastics recycling
• Industry competitiveness

Engagement and cooperation includes:

• Memberships in key associations and certifications
• Participation in events, seminars and working groups

Relevant memberships include:

• FuelsEurope
• European Biodiesel Board
• Advanced Biofuels Association (US)
• The Chemical Industry Federation of Finland
• Cefic
• Renewable Carbon Initiative (RCI)

The company has been actively participating in the Chemical Industry Federation of Finland's biodiversity development work, including meetings with NGOs, arranging training, giving advice on several files, supporting advocacy, and contributing to the industry's overall biodiversity impact mapping.

Neste has participated in World Business Council for Sustainable Development (WBCSD) work on developing biodiversity and soil health metrics for regenerative agriculture.

No quantitative data on trade association membership fees or contributions is disclosed.

We are committed to fair payment practices with our suppliers and business partners. Our payment terms and practices are designed to support healthy business relationships and comply with applicable regulations.

Information on our payment practices is provided where required by local regulations and is included in our broader supplier relationship management approach.