OMV

Governance bodies

Reference: pages 92-99, with diversity and independence on page 95.

OMV has a two-tier structure: an Executive Board that "is the highest managing body of the Company and is responsible for setting and implementing the Company strategy, including climate and other sustainability targets", and a Supervisory Board of ten shareholder representatives plus five employee representatives (page 92).

Diversity and independence (page 95) [ESRS-2-GOV-1.21d-21e]:

• Supervisory Board 2025: 66% male / 34% female (2024: 63% / 37%), "an average female to male ratio of 0.52 in 2025"; 27% under 50, 73% over 50.
• Executive Board: 80% male / 20% female until February 28, 2025, then 100% male from March 1, 2025.
• The Austrian Stock Corporation Act Section 86(7) 30% quota "is fulfilled by the members elected by the shareholders and the members nominated by the employee representation body separately".
• "all (100%) shareholder representatives on the Supervisory Board have declared their independence from the Company".

Sustainability oversight sits with the Supervisory Board's Sustainability and Transformation Committee, which reviews progress toward climate and energy transition objectives and, with the Supervisory Board, approves the Sustainability Statement annually (pages 100, 154).

Information provided to and matters addressed by the boards

Reference: pages 100-101.

Flows are described bottom-up, starting with the materiality assessment. "The OMV Group Sustainability department is the owner of the materiality assessment process and thus the body that identifies and defines OMV's material impacts, risks, and opportunities", supported by the Sustainability Coordination Forum, which sets the materiality thresholds; results are approved first by the Forum, then by the Executive Board (page 100) [ESRS-2-GOV-2.26a].

The Forum "reviews OMV's exposure to impacts, risks, and opportunities and the related action plans" at monthly meetings, with effectiveness reviewed at the second line of defense through the Risk Committee (pages 100-101).

Frequency (page 101). "Information on ESG impacts, risks, and opportunities is fully integrated into OMV's risk profile twice per year by the Corporate Risk Management function and discussed by the Risk Committee before being reported to the Executive Board." The Risk Committee is "informed by Group Sustainability twice per year about the identified material IROs", and the Audit Committee is likewise informed twice a year.

Integration of sustainability-related performance in incentive schemes

Reference: pages 101-102.

Executive Board remuneration comprises fixed and variable elements, and "the variable remuneration - LTIP and the annual bonus - includes performance criteria related to the Company's sustainability and greenhouse gas (GHG) emissions performance" (page 101). The Remuneration Policy was approved at the Annual General Meeting in June 2022.

Quantified linkage [ESRS-2-GOV-3.29b-29e] (page 101):

• 15% of the annual bonus is "based on achieving the defined reduction in net absolute Scope 1 and 2 GHG emissions".
• 30% of the Long-Term Incentive Plan (LTIP) is based on ESG targets, split as net absolute Scope 1 and 2 GHG reduction (weighted 20%) and improved Group diversity (weighted 10%).
• These GHG targets are "clearly linked to and directly derived from the OMV GHG emissions reduction targets for 2030 and the required reduction pathways up to 2030 compared to the base year 2019".

"Based on the current Remuneration Policy, reducing GHG emissions will always constitute an ESG target in the LTIP" (page 102). A health and safety malus of between 0.8 and 1.0 is applied to overall target achievement for both the bonus and the LTIP, based on criteria such as fatalities, TRIR and process safety; "In the event of severe incidents, the Remuneration Committee may reduce the payout to zero." Actual target achievement is externally reviewed by OMV's auditor (page 102).

Statement on due diligence

Reference: page 102.

OMV presents the ESRS 2 GOV-4 mapping table [ESRS 2-GOV-4.30] [ESRS 2-GOV-4.32], linking each core element of due diligence to the paragraphs of the Sustainability Statement where it is addressed (page 102):

• Embedding due diligence in governance, strategy and business model - GOV-2, GOV-3 (29a-29e), SBM-3 (48a-48b).
• Engaging with affected stakeholders in all key steps - GOV-2 (26a), SBM-2 (45a-i to 45-v, S1.SBM-2.12, S2.SBM-2.9, S3.SBM-2.8), topical ESRS S1-1.19, S1-2.27, S2-2, S3-2.21-23, IRO-1 (53b-iii), and MDR-P policy overview.
• Identifying and assessing adverse impacts - SBM-2 (48a, 48b) and IRO-1 (53a, 53e, 53g; E1.20a, 20b-ii, 20c-i; E1.21; E2.11a; E4.17c).
• Taking actions to address those adverse impacts - E1-3, E2-2, E3-2, E4-3, E5-2, S1-4, S2-4, S3-4, and MDR-A.
• Tracking and communicating the effectiveness of these efforts - MDR-T, E1-4, E2-3, E5-3, S1-5, S2-5, S3-3, plus MDR-M metrics.

The datapoint "ESRS 2 GOV-4 Statement on due diligence paragraph 30" is confirmed as material, disclosed on page 102, in the list of datapoints deriving from other EU legislation (page 315).

Risk management and internal controls over sustainability reporting

Reference: pages 102-103.

The internal control system is "grounded in a four lines of defense model": operational management owns and manages risks; Risk Management, Corporate ICS and Compliance oversee; Internal Audit provides independent assurance; and "OMV views external auditors as a fourth line of defense" (page 102) [ESRS-2-GOV-5.36a]. The ICS "is based on the COSO framework" (page 103).

Risks identified [ESRS-2-GOV-5.36c] (page 103): "misstatement of quantitative data, incompleteness of data, and untimely delivery of data", mitigated by data validation controls (automated checks and manual reviews), completeness controls and timeliness controls.

A candid limitation. "The implementation of additional controls for sustainability reporting is in its early stages and will be gradually developed to include comprehensive internal controls to effectively address current and emerging risks" (page 103). OMV adds that the sustainability reporting process "will be reassessed in 2026 to make all the necessary updates based on the requirements outlined in the ESRS".

Reviews run "every three years for all end-to-end processes within its scope, including the sustainability reporting process", with an ad hoc review restarting the cycle after a major change. Outcomes go to top management and the Audit Committee, which meets at least four times a year with a dedicated ICS slot (page 103).

Strategy, business model and value chain

Reference: pages 103-108.

"OMV is an integrated company with three pillars: Energy, Fuels, and Chemicals" (page 103) [ESRS-2-SBM-1.40a].

Energy. 2025 hydrocarbon production of 305 kboe/d, with around 40% gas share; natural gas storage of around 30 TWh; a gas-fired power plant in Romania. "In traditional business, the focus is on gas", which "represents a key growth engine for OMV" (page 103).

Fuels. Three European refineries plus 15% shares in ADNOC Refining and ADNOC Global Trading; "OMV's total global processing capacity amounts to around 500 kbbl/d"; by end-2025 the retail network included "around 1,700 filling stations across eight European countries" (page 103).

Chemicals. OMV is "among the largest producers of ethylene and propylene in Europe and is one of the top ten polyolefin producers worldwide", operating through Borealis across Consumer Products, Energy, Health Care, Infrastructure and Mobility (page 103).

The structural change of the year. "On March 3, 2025, OMV and ADNOC signed a binding agreement to combine their shareholdings in Borealis and Borouge into Borouge Group International" (page 103); Borealis "is expected to be deconsolidated in 2026" (pages 154, 158, 161), which flows through the E5 target withdrawal and the climate baseline recalculation.

Interests and views of stakeholders

Reference: pages 108-112.

"OMV is committed to proactive stakeholder engagement. The overarching purpose ... is to foster mutual respect, transparency, and open dialogue with our eleven identified stakeholder groups" (page 108).

Process (page 110). "a consultation process with both external and internal stakeholders is conducted by OMV at least every three years for the materiality assessment", run by Group Sustainability. Key groups "were consulted using online questionnaires", and "In the materiality assessment process in 2024, the overall key stakeholder feedback confirmed OMV's internal views on material topics." For 2025, "a review of the IROs from 2024 was carried out, in which the findings of the 2024 stakeholder engagement were considered and integrated as well" - so the 2025 statement rests on a 2023 consultation, on the stated assumption that stakeholder interests "have not changed" (page 135).

How views reach the board [ESRS-2-SBM-2.45d] (page 110). The Executive Board is "closely involved in the approval process of the materiality assessment" and receives "continuous updates on stakeholder perspectives through regular meetings with Company experts who interact directly with all of the stakeholder groups".

Material impacts, risks and opportunities

Reference: pages 112-126, with the material IRO tables on pages 119-126.

The 2024 double materiality assessment "serves as the fundament for the current reporting period", and the 2025 review "led to a refinement of IROs and subsequently changes to material sub-topics compared to 2024. Climate Change Adaptation, Corruption and Bribery, Protection of Whistleblowers, and Economic Impact, along with their associated IROs, were identified as immaterial in 2025" (page 112).

Material IROs (pages 119-126): E1 four, E2 five, E3 two, E4 two, E5 three, S1 four, S2 four, S3 three, G1 three, plus one entity-specific cybersecurity impact - 31 rows in total. "[E1-SBM-3.18] All material climate related risks ... are climate-related transition risks" (page 119).

No strategy change and no measured financial effect. "As in 2024, there were no identified current effects of the material IROs on the business model, value chain strategy, or decision-making in 2025, and therefore no changes were made to the Strategy and Business Model" (page 113). "[ESRS-2-SBM-3.48d] None of the material risks and opportunities identified for all E, S, and G topics had any material, measurable actual impact on OMV's current financial position, financial performance, and cash flows" (page 118). "[S3-SBM-3.11] No material risks and opportunities were identified for the topic of Affected Communities" (page 118).

Processes to identify and assess material impacts, risks and opportunities

Reference: pages 134-142.

"A thorough double materiality assessment based on ESRS prescriptions was ... conducted in 2024 ... In 2025, this assessment was reviewed and refined." The outcome: "it was determined that nine out of the ten sustainability topics outlined by the ESRS are material for OMV. Additionally, the entity-specific sustainability matters 'cybersecurity' and 'process safety' were kept as material" (page 134).

Impact materiality (page 135). Impacts were scored on scale, scope, remediability and likelihood, "all rated on a scale from 1 to 5". "For environmental topics, an impact materiality threshold of 8, as recommended by EFRAG, was used ... For social and governance aspects, OMV adopted a threshold of 5". "No new qualitative assessment of impacts was carried out in 2025."

Financial materiality (page 135). Risks and opportunities were scored on "magnitude of financial effect (on a scale from 0 to 3) and likelihood of occurrence (on a scale from 0 to 5) ... The financial materiality threshold was defined at 1.5, making the high and upper range of medium financial effects material."

Approval (page 136). "The results of the 2025 review of the DMA were approved by the Sustainability Coordination Forum only, as no significant changes compared to 2024 were made."

Disclosure requirements covered by the sustainability statement

Reference: pages 142-143, with the content index on pages 312-314 and the EU-legislation datapoint list on pages 315-317.

OMV prints a genuine ESRS content index: "The list of disclosure requirements in accordance with IRO-2.56 and the list of datapoints in cross-cutting and topical standards that derive from other EU legislation can be found in > Annex" (page 143).

Substances of concern ruled out. "[ESRS 2-IRO-2.58] Substances of concern and substances of very high concern are not material for OMV because of the low likelihood of incidents due to high process safety standards, prevention of contamination, and strict regulatory requirements ... governed by Seveso requirements at all locations. All our produced and purchased products are certified, and safety datasheets are publicly disclosed on our website" (pages 142-143).

Scope of omissions. "[ESRS 2-IRO-2.59] ... we analyzed the materiality for all individual disclosure requirements, additionally considering conditional, voluntary, and phase-in provisions applicable to OMV ... Consequently, all disclosure requirements and datapoints related to immaterial topics and sub-topics, with the exception of Protection of whistleblowers and Corruption and bribery from G1, have been excluded" (page 143).

S4 does not appear in the index at all; E1-9, E2-5, E2-6, E3-5, E4-6, E5-6 and G1-5 are likewise absent (pages 312-314).

Transition plan for climate change mitigation

Reference: pages 153-160.

Targets (page 153). Net zero by 2050 across Scopes 1, 2 and 3. Base year 2019: Scopes 1 and 2 "an absolute reduction of 30% by 2030 and 60% by 2040"; Scope 3 defined categories "20% by 2030 and of 50% by 2040"; carbon intensity of energy supply "a decline of 10% by 2030 and of 25% by 2040". The plan "is an integral part of the OMV Strategy 2030".

Approval [E1-1.16i] (page 154). "The climate targets guiding OMV's transition plan were approved by the Executive and Supervisory Boards", with strategic actions approved by the Executive Board through mid-term planning and investment approval, and oversight by the Sustainability and Transformation Committee.

Levers and estimated 2019-2030 contribution (page 154): operational efficiency (62% of Scopes 1 and 2, 7% of Scope 3); renewable energy purchases (47%); portfolio changes (31% / 53%); zero-carbon sales (carbon intensity only); CCS/CCU ("Contribution after 2030").

Investment [E1-1.16c] (page 156). "average yearly organic CAPEX of approximately EUR 2.8 bn between 2026 and 2030. Of this, 30% will be directed toward sustainable projects." Taxonomy-aligned CAPEX was 18.4% of total in 2025; oil and gas CAPEX in 2025 was EUR 2 bn.

Progress (page 156). "absolute Scope 1 and 2 emissions by 26% compared to 2019. Scope 3 emissions have been reduced by 19% ... OMV invested EUR 0.5 bn in 2025."

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate DMA section (pages 137-138), with scenario detail in the E1 chapter's SBM-3 section (page 161). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification (paragraph 15). "[E1-SBM-3.18] All material climate related risks ... are climate-related transition risks" (page 119). Physical risk was assessed and found immaterial: "the assessment concluded that OMV is not significantly exposed to physical climate-related risks (acute risks)" (page 138).

Methodology (paragraph 16). Physical: hazards selected "based on Commission Delegated Regulation (EU) 2021/2139", then activity criticality and asset lifespan assessed; with an external consultant "OMV modeled the physical climate risks, focusing on surface water and riverine flooding, coastal inundation, soil movement, extreme wind, wildfire, freeze-thaw, and extreme heat" (page 137). Transition: OMV "assesses the extent to which its assets and business activities may be exposed and are sensitive to the identified transition events, taking into consideration the likelihood, magnitude, and 2040 time horizon", across regulatory, technological, market and reputation types (page 138).

Scenarios (paragraph 17). Physical: RCP 8.5 and RCP 4.5 (page 138). Transition: IEA STEPS (2.4°C), APS (1.7°C) and NZE (1.5°C) (page 161).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 in the E1 chapter (pages 161-162), with the group-level statement on page 118. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Scope and method (page 161). "[E1-SBM-3.19a] OMV assesses its long-term resilience in a 1.5°C decarbonization scenario across its three business segments ... Since Borealis is expected to be deconsolidated in 2026 ... it is therefore excluded from the analyses." The analysis has three elements - existing assets, upcoming investments, and Strategy and Business Model - the first two incorporated by reference to Note 3. The future portfolio "was then exposed to OMV NZE prices", with sensitivities on key market prices. It "covered the time period from 2026 to 2040" and "was concluded in September 2025".

Findings (paragraph 19(a)) (page 161). "It confirmed the expected resilience of OMV's future portfolio in the OMV NZE scenario with positive operating and free cash flow across all three business segments throughout the period 2026 to 2040."

Adaptive capacity (paragraph 19(c)) (page 162). "Its adaptability is ensured by incorporating regular scenario analyses into planning processes such as the annual mid-term plans." Uncertainty (paragraph 19(b)) is not set out here but incorporated by reference to Note 3.

Policies related to climate change mitigation and adaptation

Reference: pages 127 and 162-163.

Five policies are named for E1: the Code of Conduct, the Environmental Management Standard, the Greenhouse Gas (GHG) Management Framework, the Controlling of Investment Directive and the Enterprise-Wide Risk Management Standard (pages 162-163); the first two and the last are described once under ESRS 2 Overarching Policies (page 127).

GHG Management Framework [E1-2.24] (pages 162-163). It "complements the guidelines provided in the Environmental Management Standard to give a detailed approach on how to manage the negative impacts related to GHG emissions from our operations and products sold and address the low energy efficiency within our operations", and covers CCU, "the requirements for purchasing voluntary carbon offsets", methane management and biogenic CO2 accounting. Effectiveness "is assessed through the annual data campaign, plausibility checks, and regular monitoring of progress toward the established targets". "The CFO, who approves the GHG Management Framework, is also accountable for its implementation." It references "the GHG Protocol, the OGMP 2.0 framework, IPCC, and the Integrity Council for the Voluntary Carbon Market".

Actions and resources in relation to climate change policies

Reference: pages 164-169, with the key actions table on pages 165-166.

"Key actions are defined as those requiring CAPEX of EUR >=5 mn for their implementation. In 2025, the planning horizon was shortened from five years to three, resulting in forward-looking CAPEX that is lower compared to the Sustainability Statement 2024" (page 164). OMV states that "OPEX figures related to key actions are not disclosed due to current limitations in data availability", and that "the presented CAPEX figures do not represent the total CAPEX of OMV for actions addressing climate change mitigation".

By lever (page 165). Improve operational efficiency - energy efficiency programs, other Scope 1 and 2 reductions, PV, wind and waste-heat generation: CAPEX 2025 EUR 0.4 bn, achieved reduction 1.4 mn t CO2e versus 2019 and planned 1.9 mn t by 2030. Increase in zero-carbon sales - geothermal, low-carbon transport infrastructure, biogas and biofuels, sustainable fuels and e-fuels, hydrogen: CAPEX 2026-2028 EUR 2.6 bn. CCS/CCU: "Contribution after 2030".

Renewable electricity (page 169). Three PPAs in Austria and Germany with VERBUND, ImWind and Statkraft, plus a further 9 GWh/a PV PPA. Result: "49% of the purchased electricity at the Schwechat refinery ... and 82% at the Burghausen refinery" from renewables in 2025; Borealis reached 60% (2024: >50%).

Targets related to climate change mitigation and adaptation

Reference: pages 169-174. All five targets use base year 2019 and were approved by the Executive Board (page 170).

1. Absolute Scopes 1 and 2 (pages 170-171). "At least 30%" by 2030, "at least 60%" by 2040, net zero 2050; baseline 13.9 mn t CO2e. Removals, avoided emissions and carbon credits "are excluded as means of achieving the 2030 and 2040 GHG emission reduction targets". Status 2025: "reduced by 26% vs. 2019 (2024: -23%)".

2. Absolute Scope 3 (pages 171-172). "At least 20%" by 2030, "at least 50%" by 2040; baseline 113.7 mn t CO2e. Status 2025: "reduced by 19% vs. 2019 (2024: -17%)".

3. Carbon intensity of energy supply (pages 172-173). 10% by 2030, "at least 25%" by 2040; baseline 70.0 g CO2e/MJ. Status 2025: "reduced by 1% vs. 2019 (2024: -1%)" - barely moved in six years.

4. Zero routine flaring and venting by 2030 (page 173). Baseline 514 mn Sm3; the routine share fell from about 80% in 2019 "to 12% by 2025". Status 2025: "decreased from 37 mn Sm3 in 2024 to 13 mn Sm3 in 2025".

5. Methane intensity (pages 173-174). Below 0.2% by 2025 and 0.1% by 2030; baseline 1.1%. Status 2025: 0.3% - the 2025 target was missed. The method "was updated in the reporting year to align with the OGMP 2.0 standards ... the value would be 0.2% instead of 0.3%" on the old method.

Energy consumption and mix

Reference: pages 175-176.

Total energy consumption 2025: 47,841,925 MWh (2024: 46,265,174 MWh), of which non-renewable 45,107,867 MWh, nuclear 270,375 MWh and renewable 2,463,683 MWh (page 175) [E1-5.37a-37c].

Fossil breakdown (page 175): total from fossil fuel sources 43,272,287 MWh, comprising coal 0, crude oil and petroleum products 4,533,140 MWh, natural gas 36,905,484 MWh, other fossil 1,833,663 MWh, plus purchased electricity, heat, steam and cooling from fossil sources 1,835,580 MWh.

Shares (page 175): fossil 94%, nuclear 1%, renewable 5% (2024: 95% / 1% / 5%).

Renewable consumption is made up of self-generated non-fuel renewable energy 45,227 MWh, renewable fuel including biomass 66,643 MWh and purchased renewable electricity, heat, steam and cooling 2,351,813 MWh (page 175).

Energy production to market (page 175): 322,416,754 MWh total (2024: 344,166,550), of which renewable sales 9,756,712 MWh.

Intensity (page 175): total energy consumption per unit of sales revenue from high and low climate impact sectors of 0.001 MWh/EUR (entity-specific, excluding Borealis); the corresponding ESRS metric is "2025: 0.002 MWh/EUR", the difference arising from the reclassification of Borealis as held for sale and discontinued operations.

Sector (page 176): main NACE codes C.19.2, B.6.2, B.6.1, C.20.16; 57% of sites are ISO 50001 certified (2024: 59%).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 176-179.

2025 (t CO2e, pages 176-177): gross Scope 1 9,470,995 (2024: 9,778,526); Scope 2 market-based 815,098, location-based 730,629 (2024: 991,275 and 1,036,020); combined Scope 1 and 2 market-based 10,286,093 against a 2019 base of 13,920,157 and a 2030 milestone of 9,744,110; total GHG emissions 164,556,379 market-based (2024: 159,127,511), up 3%. Scope 3 Category 11 alone is "76.0 out of 154.3 mn t CO2e" (page 160).

Method (page 176). GHG Protocol Corporate Standard (2004), Scope 2 Guidance (2015) and Scope 3 Standard (2011); "OMV applies the global warming potentials (GWPs) from the IPCC Sixth Assessment Report (AR6 - 100 years)". Consolidation is 100% for operated or >50%-held activities, except Category 15 "Investments", on the equity approach.

Data quality (page 178). "In 2025, 0.03% of Scope 3.1 'Purchased goods and services' and 0.002% of Scope 3.2 were calculated using data obtained from suppliers. This corresponds to 0.004% of total Scope 3 emissions." Of 4,457,768 MWh purchased electricity, heat and steam, "56% is covered by contractual instruments".

Exclusions (page 178). Categories 3.4, 3.6, 3.7 and 3.9 are excluded "to avoid double counting because the fuels involved are included under Category 11"; 3.8 and 3.13 sit in Scopes 1 and 2; no franchises.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 179.

Removals: a nil return. "[E1-7.56a] ... In 2025, OMV did not have any GHG removals and storage resulting from projects in its own operations nor in its upstream or downstream value chain" (page 179).

Carbon credits cancelled in the reporting year (page 179):

• Total 311,573 t CO2e (2024: 346,094).
• Share from removal projects 0.0%; share from reduction projects 100.0%.
• Share from projects within the EU 0.00% (2024: 0.03%).
• Share qualifying as corresponding adjustments under Article 6 of the Paris Agreement 0.0%.
• Recognised standards: CDM 22.7%, Gold Standard 0.0%, VCS 77.3%.

Voluntary offsetting (page 179). OMV "offers customers voluntary carbon offsetting and works closely with ClimatePartner". In 2025 the portfolio consisted of "hydropower projects (9%) in India; solar projects (54%) in India; and wind energy projects in China and India (37%)", verified to Gold Standard, VCS, CDM or CCBS.

Relationship to targets. "OMV's use of voluntary carbon offsets neither impedes nor reduces the achievement of OMV's GHG emission reduction targets ... Carbon credits are not counted toward these targets to be achieved by 2050, but are offered to customers as voluntary offsets." Future cancellations already contracted total 219,140 t CO2e (2024: 612,288 t) (page 179).

Internal carbon pricing

Reference: page 180.

"[E1-8.62] OMV applies internal carbon pricing for investment decisions across all business segments. In the base case, the costs of CO2 emissions are included wherever carbon pricing schemes are in place within the respective countries" (page 180).

Stress test. "Additionally, a stress test based on a 'net zero emissions by 2050' scenario is conducted. For this stress test, shadow prices are applied to 100% of OMV's share of direct Scope 1 emissions."

Coverage in the reporting year. "As internal carbon prices are applied for future investments, they do not apply to the reporting year in which actual carbon prices are considered. These actual carbon prices covered 85% (2024: 85%) of OMV's reported Scope 1 emissions in 2025, equivalent to 8.1 mn t of CO2 (2024: 8.3 mn t of CO2)."

Consistency with the financial statements. "The internal carbon prices applied are consistent with the carbon prices used for accounting purposes including impairment testing, calculation of depreciation, assessments of the useful life, and fair value measurement of assets according to IFRS."

The price levels themselves are not printed in the sustainability statement: "[E1-8 AR 65a-65c] The applied carbon prices are detailed in > Note 3 - Effects of climate change and the energy transition", which is incorporated by reference (pages 92, 180).

Policies related to pollution

Reference: pages 127 and 181-188.

E2 is material for "Pollution of air; Pollution of water; Pollution of soil; Microplastics; Process safety (entity-specific)" and is "governed centrally by Group Health, Safety, Security, and Environment (HSSE), which is led by the VP HSSE, who reports directly to the CEO" (page 181).

Code of Conduct (page 181). "[E2-1.15b] ... as part of our commitment outlined in the Code of Conduct, we are dedicated to substituting hazardous substances with less hazardous alternatives where reasonably practicable. To support this effort, processes should be designed, modified, and applied to minimize the production and use of hazardous substances, including the reduction of hazardous by-products or waste."

Alongside it OMV relies on the Environmental Management Standard, the HSSE Directive, HSSE Risk Management, the Contractor HSSE Management Standard, the Process Safety Standard, the Management of Hazardous Substances standard and the Corrosion Management Framework, each mapped to a specific E2 IRO (page 120).

Microplastics (page 188). "[E2-1.15a] Pollution of water and soil due to unintentional pellet loss is addressed in Borealis' Responsible Care policy and its adoption of the Operation Clean Sweep (OCS) standard." Every polyolefin site "implements the six key OCS requirements" and must "establish and annually review a risk management plan".

Actions and resources related to pollution

Reference: pages 188-190.

"OMV aims to minimize its air emissions across all businesses and activities through the application of the precautionary principle, international best industry practices, and/or Best Available Technology (BAT) ... We also aim to prevent and reduce oil spills and leakage in our operations at sea as well as on land" (page 188).

Key action (page 189). One key action, "Pollution prevention", actual and planned, own operations, mid-term, expected outcome "Reducing pollutants released to air, soil, and water": CAPEX 2025 EUR 11 mn and CAPEX 2026-2028 EUR 66 mn, mapped to IROs E2-P-IRO-1, 4, 5 and 6.

Below-threshold actions (page 189). The Burghausen flare optimisation, "Started in 2024 and completed over the course of 2025 ... have led to a reduction in flared gas and associated air pollutants, including NOx, VOC, and CO", by "increasing the working volume of the flare gas holder, optimizing the backup gas algorithm, and diverting a nitrogen-rich stream from the flare to the refinery process". And Ultra-Low Sulfur Fuel Oil, a marine fuel "specifically designed to meet the stringent requirements of SECA, including the upcoming Mediterranean SECA regulation, which reduces the sulfur limit to 0.1%".

Targets related to pollution

Reference: pages 190-193. Three targets, two voluntary and one entity-specific.

1. OCS certification of European polyolefin sites (page 191). Voluntary, "related to the policy objective of achieving zero loss of pellets from primary containment"; base year 2024, baseline 9 sites. Status 2025: "The target was achieved. External OCS certification was completed for all 10 European PO sites of Borealis" (2024: 9 certified, 1 postponed). "Borealis monitors performance through quarterly on-site meetings of local OCS teams."

2. Pellet spills of one or fewer per polyolefin site per year (page 191). Voluntary, aligned "with the policy objective of mitigating impacts from pellet loss".

3. Process Safety Event Rate (page 193). Classification "follows a tiered concept as outlined in API 754 ... the normalized rate of Tier 1 and Tier 2 process safety events per 1,000,000 hours worked". The target "is based on comparing our performance with peer groups, using data published by industry associations such as IOGP and Concawe" and was approved by the Executive Board. Status 2025: 0.30 (2024: 0.20) - a deterioration.

Gaps stated by OMV (page 193). "[E2-3.23a] None of the targets directly address air pollutants and respective loads." On soil: "a specific target for minimizing soil pollution caused by spills is currently not in place."

Pollution of air, water and soil

Reference: pages 193-195.

E-PRTR pollutants, 2025 in kg/year (page 194) [E2-4.28a-28b]. To air: NMVOC 4,881,656; NOx 4,313,835; SOx 2,009,397; benzene 56,485; PM10 53,000; cadmium 20; nickel 149. To water: arsenic 50; copper 77; phenols 116; fluorides 2,068. To soil the metal and organic rows read "n.a.2 - This type of emission is not applicable at OMV".

Total air pollutants, entity-specific (page 194): SO2 2,079,551 kg (2024: 2,461,811); NOx 9,021,328 kg (2024: 7,560,341); NMVOC 7,927,664 kg; particulates 145,040 kg; ozone-depleting substances 0 (2024: 134).

Microplastics (page 194). "In 2025, Borealis generated 3,882,689.2 t (2024: 4,024,286.9 t) of microplastics in the form of produced plastic pellets at its PO sites, while emitting 0.0185 t (2024: 0.0180 t) of microplastics as unrecovered pellet spills." OMV notes "[E2-4.31] No standardized, scientifically recognized methods for directly measuring unrecovered pellets spilled from Borealis' operations currently exist" (page 195).

Spills (page 195): 1,671 (2024: 2,305), of which 2 major (2024: 4); volume 34,660 litres (2024: 127,015).

Process safety events (page 195): Tier 1 16 (2024: 8), Tier 2 15 (2024: 13).

Other (pages 194-195): ISO 14001 certified reporting units 48.0% (2024: 54.0%); 34 violations of legal environmental obligations, fines EUR 0.138 mn; environmental protection expenditure EUR 640 mn.

Policies related to water and marine resources

Reference: pages 127, 196-198.

E3 is material for the single sub-topic "Water" and is governed centrally by Group HSSE under the VP HSSE, who reports to the CEO (page 196). The stated aim is to "Use water efficiently in our operations and minimize the impact of water use and discharge on the environment and local communities".

Three policies apply: the Code of Conduct, the Enterprise-Wide Risk Management Standard and the Environmental Management (EM) Standard, each described under ESRS 2 Overarching Policies (pages 196, 127).

Coverage of water-stressed areas (page 198). "[E3-1.12c] Since all our sites are covered by the EMS, our general commitment to reducing water consumption and improving water efficiency also includes areas at water risk."

Sustainable oceans and seas - a stated limit (page 198). "[E3-1.14] The EMS has an annex that contains additional requirements for produced water and offshore wastewater discharge, but other than that, OMV has not adopted any specific policies related to sustainable oceans and seas." The annex datapoint list agrees, marking "ESRS E3-1 Dedicated policy paragraph 13" and "Sustainable oceans and seas paragraph 14" as not material, while "Water and marine resources paragraph 9" is material at page 196 (page 316).

Actions and resources related to water and marine resources

Reference: pages 198-199.

"[E3-2.19] OMV uses significant amounts of water for its operations ... Freshwater is used for processes such as drilling, steam generation, and cooling ... Any produced water is treated for reinjection into pressurized hydrocarbon reservoirs ... Some of OMV's operating facilities are in areas experiencing water stress" (page 198).

Tunisia water assessment (page 198). "In 2025, OMV Tunisia (TN) conducted the regulatory water assessment for the Waha Central Facility ... Several areas for improvement were identified, including the implementation of a smart water monitoring system, the reuse of AC condensation wastewater, and the re-engineering of the water network and irrigation system." A green zone irrigated with treated wastewater rather than freshwater has been created. "These actions are particularly relevant, as Tunisia has been identified as an area at water risk. Activities are planned to commence in 2026."

Risk assessment (pages 198-199). "Comprehensive water impact and risk assessments were carried out across operational sites using the WWF Water Risk Filter and the TNFD LEAP" approach, covering "all operational sites under the Company's financial or operational control", with site-specific measures "giving priority to water-stressed or high-risk basins".

Targets related to water and marine resources

Reference: page 199.

OMV states the position plainly rather than presenting a target it does not have: "[MDR-T.81b-i] OMV has not yet established an ESRS-aligned target for the material topic E3 Water. However, the Company has already started working toward setting a water-related target" (page 199).

The ambition used in its place. "We have been reporting on freshwater withdrawal since 2021 and our ambition is to reduce freshwater withdrawal and minimize the impact of water use, particularly in water-scarce areas. This commitment is outlined in our Code of Conduct, Environmental Management Standard, and OMV Group HSSE Strategy."

How effectiveness is tracked in the absence of a target. "We track the effectiveness of our efforts by measuring the year-on-year reduction of freshwater withdrawal within our operations, without using a specific base year."

Status 2025 (page 199). "[MDR-T-81b-ii] 47,712 megaliters of freshwater withdrawn (2024: 44,998 megaliters)" - an increase of roughly 6% year on year, moving away from the stated ambition.

E3-3 is listed in the content index with a page reference of 199 (page 313), so the disclosure requirement is covered; what it contains is an ambition and a tracked metric rather than a measurable, outcome-oriented and time-bound target.

Water consumption

Reference: pages 200-201.

Consumption (page 200):

• Total water consumption 65,423,949 m3 (2024: 68,126,854 m3).
• Of which in areas at water risk, including areas of high water stress: 2,219,687 m3 (2024: 1,706,154 m3).
• Water recycled and reused 8,576,533 m3 (2024: 10,433,128 m3, restated).
• Water intensity 2,579 m3/EUR mn (entity-specific, excluding Borealis); the corresponding ESRS metric is 2,691, "calculated as water consumption including Borealis divided by revenues excluding Borealis".

A restatement is flagged: the 2024 recycled and reused figure was restated "due to a clarification in methodology, which previously included water recirculated for cooling or heating system; the previous figure for 2024 was 314,086,151 m3" (page 200) - a very large correction worth noting.

Withdrawals (page 200): total water withdrawn 604,019,749 m3 (2024: 568,598,186 m3), dominated by seawater 511,034,801 m3, of which 509,123,064 m3 is once-through cooling water. Groundwater 29,937,035 m3 (all freshwater in 2025), surface water 14,799,342 m3, public supply 2,975,808 m3, produced water 45,363,121 m3.

In areas at water risk (page 200): withdrawal of 3,490,265 m3 (2024: 3,153,508 m3), of which groundwater 2,705,303 m3, public supply 402,810 m3 and produced water 382,152 m3.

Transition plan on biodiversity and ecosystems

Reference: pages 202 and 113.

The disclosure states plainly that the work is unfinished. "[E4-1.11] [E4-1.13] The assessment of the resilience of OMV's Strategy and Business Model to biodiversity impacts has not been conducted yet because the TNFD LEAP assessment is still ongoing. The results will provide a better understanding of OMV's biodiversity impacts, dependencies, risks, and opportunities, and will be essential in conducting this analysis" (page 202).

What the pilots show. "The assessments of pilot sites thus far show potential changes in natural ecosystems are expected to have a limited influence on OMV's activities due to the nature of the business. Nonetheless, our biodiversity commitments aiming to contribute to the objectives of the Global Biodiversity Framework (GBF) and the EU's biodiversity strategy oblige us to act on our impacts, irrespective of the operational risks to OMV" (page 202).

A dependency flagged. "as biobased feedstock will play an increasingly important role in OMV's Strategy and Business Model, dependency on the ecosystem service of biomass provision will require more attention in the coming years" (page 202).

Progress (page 113). After "six pilot sites in the first phase from Q3 2023 to Q3 2024, we refined the methodology, completed the Locate phase, and performed a corporate level screening of sites in 2025".

Policies related to biodiversity and ecosystems

Reference: pages 127 and 202-204.

E4 is material for four sub-topics: "Direct impact drivers of biodiversity loss; Impacts on the state of species; Impacts on the extent and condition of ecosystems; Impacts and dependencies on ecosystem services" (page 202). The policies are the Code of Conduct and the Environmental Management (EM) Standard (pages 202, 127). "Our EM Standard applies to our operational sites, including those situated in or near biodiversity-sensitive areas" (page 204), and where significant impacts are observed "the mitigation hierarchy is followed" (page 142).

Traceability (page 204). "[E4-2.23d-23e] OMV's key products, energy, fuels, and chemicals, and raw materials are not derived from ecosystem services ... and there is no immediate need for traceability policies ... However, as some materials sourced from ecosystems may become increasingly important in our long-term strategy, we plan to expand or adapt our policies ... All renewable biobased inputs are ISCC PLUS or ISCC EU certified."

Stated absences (page 204). "[E4-2.24a-24d] OMV has not adopted any specific policies related to sustainable land or agricultural practices, sustainable ocean or sea practices, or deforestation, because during our most recent materiality assessment, no impacts, risks, or opportunities were identified." The annex marks each of those datapoints not material (page 316).

Actions and resources related to biodiversity and ecosystems

Reference: pages 204-205.

"OMV works with third parties on local nature restoration and rehabilitation projects. Through active collaboration with local communities, biodiversity-related projects in New Zealand have been implemented as part of our wider Stakeholder Engagement and Corporate Social Responsibility portfolio" (page 204) [E4-3.25].

Named projects (page 204):

• "a partnership with Ngati Rahiri hapu to regenerate the two Pohokura wetlands that neighbor the Pohokura Production Station";
• "supporting the Ngati Tara Sandy Bay Society with dune planting and restoration near the Maui Production Station";
• "working with the Taranaki Herpetological Society to protect native lizards from pests in the wetlands surrounding the OMV Tank Farm";
• long-term sponsorship of the Rotokare Scenic Reserve Trust, "a large-scale regeneration project that aims to enhance habitats and wildlife in a 230-ha pest-free reserve".

Offsets (page 204). "Biodiversity offsets were not used as a part of the project." This is a direct answer to the E4-3 offsets datapoint rather than a silence.

"The described actions were ongoing activities in 2025 and are in line with the ambition in our Code of Conduct" (page 204). As with water, the biodiversity actions sit below OMV's EUR 5 mn key action threshold, so no CAPEX is attributed to them.

Targets related to biodiversity and ecosystems

Reference: page 205.

The disclosure is short and negative, and it is stated rather than left to be inferred: "[MDR-T-81b-i] OMV has not yet established an ESRS-aligned target for the material topic E4 Biodiversity and Ecosystems. The effectiveness of our EM Standard, which specifically addresses biodiversity, cannot be tracked because our Group-wide LEAP assessment is still ongoing" (page 205).

E4-4 is nonetheless listed in the content index with a page reference of 205 (page 313), so OMV treats the requirement as covered by this statement.

The same dependency on the incomplete TNFD LEAP assessment runs through the rest of the E4 chapter: the resilience analysis "has not been conducted yet" (page 202), and impact metrics "will be defined once the LEAP assessment has been concluded" (page 205). Against that, OMV does hold biodiversity commitments "aiming to contribute to the objectives of the Global Biodiversity Framework (GBF) and the EU's biodiversity strategy" (page 202), and reports that it "completed the Locate phase, and performed a corporate level screening of sites in 2025" after six pilot sites in 2023-2024 (page 113). No date is given for when targets will follow.

Impact metrics related to biodiversity and ecosystems change

Reference: page 205, with supporting site data on pages 113 and 140-142.

"[E4-5.33] Metrics related to our material impact on biodiversity and ecosystems will be defined once the LEAP assessment has been concluded" (page 205). E4-5 is listed in the content index at page 205 (page 313), so OMV treats the requirement as covered by that statement and its cross-reference to IRO-1.

What exists in place of metrics (page 113). "Geospatial analysis revealed that several OMV sites are within or near biodiversity-sensitive areas such as national protected areas according to the Common Database on Designated Areas, Natura 2000 sites, and key biodiversity areas (KBAs)." Until a full list of material sites can be disclosed, OMV provides "a summary table of all sites near biodiversity-sensitive areas, independent from their actual impacts and risks".

Method and its limits (page 142). "for facilities an average proxy area of 5,000 m2 was used"; OMV "made the assumption that filling stations, pipelines, and certain types of facilities ... do not have an impact on biodiversity and ecosystems and therefore were excluded from the analysis. The analysis is performed once per year and 2024 was the first year that OMV reported this data."

Policies related to resource use and circular economy

Reference: pages 127 and 206-211.

E5 is material for "Resource inflows, including resource use; Resource outflows related to products and services; Waste" (page 206). Ownership is shared: "OMV Group Sustainability jointly owns this topic with the OMV business units Fuels and Chemicals. For the topics of waste and wastewater, ownership is shared between the SVP Investor Relations & Sustainability and the VP OMV Group HSSE."

The policies are the Code of Conduct and the Environmental Management (EM) Standard (pages 206, 127).

Rationale (page 208). "[E5-1.15a] ... A circular economy decouples economic growth from resource depletion by ensuring that materials, resources, and products remain in use for as long as possible and at their highest value ... Transitioning from a linear 'take - make - waste' model to a circular 'reduce - reuse - recycle' model will also help mitigate global warming."

Feedstock choice (page 208). "For monomers and polymers made from renewable sources, OMV focuses on utilizing waste biomass, such as residual forestry matter that is not in competition with the food and feed chain", and is "committed to scaling up waste-based and advanced feedstocks in production to reduce reliance on first-generation biofuels".

"[E5-1.15] OMV only considers materials as being sustainable if they are certified by a relevant sustainability certification scheme" (page 208).

Actions and resources related to resource use and circular economy

Reference: pages 212-215, with the key actions table on page 213.

"[E5-2.19] To increase our positive impact on nature and society by replacing fossil inputs with sustainable (recycled and renewable) alternatives, we have defined key actions to boost the use of sustainable inputs. These will help reduce the negative environmental impact resulting from the procurement and use of primary fossil-based resources" (page 212).

Key actions and CAPEX (page 213). Five grouped actions - manufacture of organic basic chemicals; manufacture of plastics in primary form and chemical recycling; increase in sustainable (recycled and renewable) feedstock; mechanical recycling and plastic waste processing; and close-to-market research, development and innovation - carry CAPEX 2025 of EUR 0.4 bn and CAPEX 2026-2028 of EUR 0.1 bn, mapped to E5-CE-IRO-1, 2 and 4. Expected outcome: "Increase recycling capacity to increase sales volumes of sustainable base chemicals. Circular products made from renewable input or recycled plastic waste generate lower emissions than products made from primary fossil fuels." The forward figure excludes Borealis ahead of deconsolidation.

Financing (page 212). A 2021 green loan funded the ReOil 2000 chemical recycling plant; otherwise "no sustainable financing instrument is currently outstanding".

Targets related to resource use and circular economy

Reference: page 215.

The headline is a withdrawal. "[E5-3.27] Considering the ongoing deconsolidation of the subsidiary Borealis, OMV temporarily withdrew its target related to E5 Resource Use and Circular Economy during its Capital Markets Update 2025. Borealis was expected to make a significant contribution to achieving this target. Once the deconsolidation process is complete, OMV will consider setting a new target in 2026."

The commitment that remains. "OMV remains committed to increasing the sales volume of sustainable chemicals to third-party customers, thereby supporting the growth of the circular economy", grounded in "supporting our downstream customers in complying with relevant EU regulations, such as the Packaging and Packaging Waste Regulation (PPWR), the End-of-Life Vehicles Directive (ELVD), and the EU Circular Economy Action Plan (CEAP)".

How effectiveness is tracked instead. "[MDR-T.81b-i, 81b-ii] To track the effectiveness of our Environmental Management Standard, we measure the year-on-year development of the waste recovery or recycling rate in our operations without using a specific base year."

Status 2025: "Waste recovery or recycling rate: 68% (2024: 74%)" - a six percentage point fall.

Two voluntary pellet targets in the E2 chapter are cross-referenced to E5-3.25 (page 191).

Resource inflows

Reference: page 215.

"[E5-4.30] OMV's material inflows are primary fossil materials such as crude oils and petroleum products. The Group's sustainable inflows consist of plastic waste, synthetic crude such as pyrolysis oil, and renewable biobased inflows such as FAME, bioethanol, raw glycerin, hydrotreated vegetable oils, or used cooking oil. OMV maintains a list of all critical raw materials used for its business activities, including their location and application" (page 215).

Quantified inflows (page 215) [E5-4.31a-31c]:

• Overall total weight of products and technical and biological materials used in the reporting period: 25,396,830 t (2024: 24,831,597 t).
• Percentage of biological materials, including biofuels used for non-energy purposes: 2.6% (2024: 2.9%).
• Absolute weight of secondary reused or recycled components, secondary intermediary products and secondary materials used to manufacture products and services, including packaging: 157,362 t (2024: 191,938 t).
• Percentage of secondary reused or recycled inputs: 0.6% (2024: 0.8%).

Both circularity ratios moved down year on year. Context for the secondary and biobased inflows is given under E5-1, where OMV states that renewable inputs must be certified under a recognised scheme (ISCC PLUS or ISCC EU for biobased inputs) before being counted as sustainable (pages 204, 208).

Resource outflows

Reference: page 216.

"[E5-5.35] OMV is a producer and seller of crude oil and natural gas and produces and markets a variety of products resulting from refining processes, including fuels from both primary fossil and renewable inputs, such as road fuels and aviation fuels and industrial products such as bitumen and coke. The Group also produces base chemicals, such as olefins and aromatics, and polyolefin products in the form of pellets, for which primary fossil inputs, renewable inputs, or recycled plastic waste inputs may be used" (page 216).

Packaging ruled out. "According to the 2025 DMA review, packaging is not considered one of the Company's material outflows."

Recyclability [E5-5.36c]. "The polyolefin products sold by OMV's subsidiary Borealis are 100% recyclable before the Group's customers convert them into end products. During conversion into end products, they may be mixed with incompatible and inseparable components, which could impair their recyclability. This statement applies only to polyolefin products sold by OMV."

Durability and repairability - a reasoned nil return. "The circular principles of durability and repairability are not applicable to OMV's products."

Waste

Reference: page 216 (E5-5 waste tables), with the recovery rate ambition on page 215.

Totals (page 216) [E5-5.37a-37d]:

• Total amount of waste 752,078 t (2024: 1,001,027 t), a fall of about 25%.
• Non-hazardous 386,673 t; hazardous 365,405 t (2024: 372,034 t) - close to half the total.

Diverted from disposal: 512,757 t.

• Non-hazardous 219,637 t - preparation for reuse 6,718 t, other recovery 113,891 t, recycling 99,028 t.
• Hazardous 293,120 t - preparation for reuse 25 t, other recovery 3,658 t, recycling 288,953 t. This metric "includes the amount of transboundary movement of hazardous waste (2025: 484 t)".

Directed to disposal: 239,322 t.

• Non-hazardous 167,036 t - incineration 45,262 t (44,945 t with energy recovery, 317 t without), landfill 105,772 t, other disposal 16,001 t.
• Hazardous 72,285 t - incineration 24,687 t (20,768 t with energy recovery, 3,919 t without), landfill 5,974 t, other disposal 41,624 t.

Headline rates (page 216): total waste recovery or recycling rate 68% (2024: 74%); total amount of non-recycled waste 239,322 t (2024: 264,224 t); percentage of non-recycled waste 32% (2024: 26%). Both ratios moved in the wrong direction year on year even as absolute tonnage fell.

Policies related to own workforce

Reference: pages 127 and 219-225.

Code of Conduct (page 219). "[S1-1.20a] [S1-1.21] Regarding human rights, including labor rights, the OMV CoC sets a clear commitment to and alignment with international standards, as fostered in the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and core treaties, and the OECD Guidelines for Multinational Enterprises." Business partners "are required to sign the CoC and thereby confirm their respect of the standards as well". Enforcement runs through "our Human Rights Management System, which features a stringent due diligence process, audits, grievance mechanisms, and continuous review". "[S1-1.22] ... we stipulate zero tolerance for the use of forced or compulsory labor, human trafficking".

People & Culture Ethics Policy on Non-Discrimination (page 225). It aims "to ensure equal employment opportunities without discrimination or harassment, including sexual harassment", applies to all applicants, employees and majority-owned subsidiaries, "prohibits retaliation, regardless of the offender's identity or position", and is monitored through "Spot checks, grievance investigations, and internal audits".

Processes for engaging with own workforce and workers' representatives

Reference: pages 225-227.

Engagement runs through employee representatives, collective bargaining, surveys and grievance channels (page 219), with the annual Pulse Check as the principal instrument.

Results (page 227). "[S1-2.27e] ... In the Pulse Check 2024, we achieved a very high response rate of 86% at Group level. Compared to 2023, 3% of employees in the OMV Group (OMV 7%) moved from actively disengaged/passive to moderately/highly engaged ... Since 2022, disengagement has been consistently decreasing, and the disparity with the benchmark for the oil, gas, and consumable fuels sector is narrowing."

Link to the transition (page 227). "[S1-2.AR 24e] As OMV is undergoing its transformation to a low-carbon business, the Pulse Check allows us to keep a critical eye on not only the engagement of our employees but also the extent to which they feel they can contribute to the strategy, that they receive the right skills for the future, and that they understand the sustainability goals."

Vulnerable groups (page 227). "[S1-2.28] ... 64% of OMV Group employees agree that we strive to include and fully utilize the diverse talents, experience, and backgrounds of all employees", supported by DE&I Employee Resource Groups and Ambassadors.

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

Reference: pages 227-228.

"[S1-3.30] [S1-3.32a-32c] We regard grievance mechanisms as a key tool for preventing, managing, and remediating adverse impacts on our own workforce and other stakeholders. In accordance with the UN Effectiveness Criteria, we aim to address all grievances received" (page 227). The SpeakUp Channel, part of the Whistleblowing Integrity Platform, is the primary route.

Building trust (page 228). "[S1-3.33] To ensure that our workforce can trust this channel ... we are also working on implementing effective feedback mechanisms, such as making SpeakUp Channel topics a regular agenda item at meetings with the Works Council and conducting feedback sessions with case managers and administrators."

Protection against retaliation (page 228). Provisions in the Code of Conduct, the P&C Ethics Policy and the P&C Misconduct Reporting Procedure "specifically protect employees from experiencing negative consequences ... such as dismissal, demotion, denial of promotion, negative performance appraisals, or disciplinary actions for reports made in good faith".

Other channels (page 228). "employee hotlines and designated contact persons depending on the issue at hand (e.g., People & Culture, Compliance, or HSSE representatives, PetrOmbudsman)", plus works councils.

Taking action on material impacts on own workforce

Reference: pages 228-234. Actions are structured "according to our focus areas of Human Rights, HSSE, and Equal Treatment for All" (page 228).

Human rights (page 228). "[S1-4.37] [S1-4.38a] To fulfill our human rights commitments ... and to address the material negative impact of inadequate application of human rights standards, we have defined the following actions: identifying and assessing impacts and risks and conducting training and awareness-raising on human rights. [S1-4.39] These actions are developed based on the outcomes of the initial stage of the human rights due diligence process, which comprises the annual human rights impact and risk mapping exercise."

Geopolitical context (page 228). "In light of the geopolitical tensions in the Middle East, including military actions in Iran, the UAE, and elsewhere, OMV has taken, and continues to take, all precautionary actions to ensure that any impacts on our own workforce are minimized as much as possible."

Equal treatment (page 234). 2025 initiatives include the amaZone Award received "for our commitment to training and equal opportunities for young women in technical apprenticeships", a Chemicals workshop on "retaining female talent, breaking bias, and supporting mothers returning from parental leave", the "femmeforward" pilot network, and the annual Positively Purple accessibility event.

Targets related to own workforce

Reference: pages 234-244.

Targets are "measurable, outcome-oriented, and time-bound" and structured under Human Rights, HSSE and Equal Treatment for All (page 234): training the workforce in human rights; safety culture targets "focused on mental health, incident reduction, zero fatalities, and safe working practices"; diversity targets covering "increasing the share of women in senior management, boosting international management representation, and ensuring the inclusion of persons with disabilities"; and a learning-hours target addressing "The material risk of inefficient reskilling and training".

Learning hours (page 244). "Based on a comparison with industry peers and the assumption that an annual increase of 3-4 hours on average per year is realistic and manageable, we set the target of 30 hours. The metric used is the total number of training hours provided to employees divided by the total number of employees." Developed by People & Culture, reviewed by the Executive Board, DE&I sponsors, Group Sustainability and business functions across OMV, OMV Petrom and Borealis, and approved by the Executive Board. Status 2025: "Average number of annual learning hours: 24 (2024: 23)" - still six hours short of the target.

Characteristics of the undertaking's employees

Reference: pages 244-251, with Note 12 incorporated by reference for paragraph 50(f).

Headcount by gender at December 31, 2025 (page 244) [S1-6.50a]:

• Male 16,573 (74.3%)
• Female 5,742 (25.7%)
• Other 0; not reported 0
• Total 22,315 (December 31, 2024: 23,557), a reduction of 1,242 people year on year.

The 2024 comparative excludes 10 employees from the May 2024 OMV Petrom investment in Renovatio Asset Management SRL. Board members are included in the figures.

Further breakdowns are provided in the pages that follow: employees by region, country, gender and local nationality; by local nationality and management position; by gender, region, employment and contract type; and number of employees who have left with the turnover rate (page 244).

New hires (page 251, voluntary). For the comparative period the report gives 4,580 new hires in total, of which Austria 444 (9.7%), Rest of Europe 3,973 (86.8%), Middle East and Africa 20 (0.4%) and Rest of the world 143 (3.1%); by gender 83.1% male and 16.9% female; by age 57.0% under 30, 40.9% aged 30-50 and 2.1% over 50. A restatement is flagged in the table: the Rest of Europe female share was "restated from 77.33 to 15.3 due to reporting error".

Characteristics of non-employee workers

Reference: page 251.

"[S1-7.55a] Non-employees in own workforce data ... Total number of non-employees in own workforce: 91 at December 31, 2025 (December 31, 2024: 182)" (page 251).

The count halved year on year. A methodological note qualifies the figure: "Numbers: leased personnel are counted as manpower (MP/MP-FTE) and not as head count", so the metric is not a straight headcount on the same basis as the S1-6 employee figures.

OMV gives a single total rather than the paragraph 55 split between self-employed people and people provided by undertakings primarily engaged in employment activities, and directs readers to the annex for definitions: "For metrics definitions and methodologies related to the MDR-M-77 disclosure requirements on Characteristics of Non-Employees in OMV's Own Workforce, see > Annex: S1-7 Characteristics of Non-Employees in OMV's Own Workforce metrics definitions and methodologies" (page 251).

S1-7 is listed in the content index at page 251 (page 313), so the requirement is covered. Non-employees also fall within scope of OMV's safety reporting: the S1-14 tables report occupational safety separately for non-employees (40,025 thousand hours worked, zero fatalities, 61 recordable accidents, TRIR 1.57) and for other workers at OMV sites (page 257).

Collective bargaining coverage and social dialogue

Reference: page 252.

"[S1-8.60a, 60b] 91% (2024: 92%) of all our employees are covered by collective bargaining agreements. In the EEA, we have more than one collective bargaining agreement" (page 252).

Coverage bands (page 252). In the EEA, for countries with more than 50 employees representing over 10% of total employees: Austria 100% and Romania 100%. Outside the EEA, the 0-19% band records "Rest of Europe (0.13%); Rest of the world (19%)" for 2025, against "Rest of Europe (0.1%)" and "Rest of the world (20%)" in 2024; the 80-100% band records "Middle East & Africa (80%)" in 2024, moving to "Middle East & Africa (52%)" in the lowest band for 2025.

Workplace representation (page 252). EEA figures for 2025 are Austria 99% and Romania 82% (2024: Austria 99% only), with a further entry of Romania 79.4% in the 60-79% band.

Social dialogue structures (page 252). "[S1-8.63b] OMV established a European Works Council in agreement with employee representatives in 2013, and the agreement was renewed in 2021. The European Works Council and its Steering Committee convene regularly. Management representatives, including members of the OMV Aktiengesellschaft Executive Board, participate in these meetings upon invitation from the European Works Council."

Diversity metrics

Reference: pages 253-254.

Gender and age at December 31, 2025 (page 253) [S1-9.66a, 66b]:

• OMV Executive Board: 4 members, 100% male, all aged over 50.
• Top management (executives): 49 people - female 7 (14.3%), male 42 (85.7%); 30.6% aged 30-50, 69.4% over 50.
• Advanced level: 899 people - female 219 (24.4%), male 680 (75.6%).
• Senior management (executives and advanced): 948 people - female 226 (23.8%), male 722 (76.2%).
• Junior management (department manager and team leader, a new 2025 metric): 1,389 people - female 357 (25.7%).
• All management: 2,337 people - female 583 (25.0%), male 1,754 (75.1%).
• Management positions in revenue-generating functions: 1,694 - female 339 (20.0%).
• Employees in STEM-related positions (new 2025 metric): 8,229 - female 1,503 (18.3%).
• Total workforce: 22,315 - female 5,742 (25.7%), male 16,573 (74.3%); 8.0% under 30, 49.9% aged 30-50, 42.0% over 50.

2024 comparatives (page 254): Executive Board 5 members, 1 female (20%) and 4 male (80%); top management 47 people, 8 female (17.0%). The move to an all-male Executive Board in 2025 follows Daniela Vlad's resignation effective March 1, 2025 (page 92).

Three of the metrics - junior management, all management and STEM positions - are new in 2025 with no 2024 comparison available, which limits year-on-year reading of the management diversity picture.

Adequate wages

Reference: page 254.

The disclosure is a single, complete statement: "[S1-10.69] 100% of the OMV Group's employees are paid an adequate wage, in line with applicable benchmarks" (page 254). No employees are therefore reported as falling below an applicable adequate wage benchmark, and no country breakdown of shortfall is required.

The disclosure directs readers to the annex for the benchmark methodology - "For metrics definitions and methodologies related to the MDR-M-77 disclosure requirements on Adequate Wages see > Annex: S1-10 Adequate Wages metrics definitions and methodologies" (page 254) - and to the policy sections for the underlying commitment, "see > ESRS 2 Overarching Policies and > S1-1 Policies Related to Own Workforce".

The applicable benchmarks themselves are not named on the disclosure page. Related context sits in the S1 material IRO description, which includes "failure to address the economic and social consequences of staff release, incl. adequate wages" within the potential negative impact of inadequate application of human rights standards (page 123), and in S1-1, where compensation and benefits packages are described as "competitive within relevant labor markets in the oil, gas, and chemical industry" (page 225).

S1-10 is listed in the content index at page 254 (page 313).

Social protection

Reference: pages 254-255.

"[S1-11.74] All of our employees are covered by social protection against loss of income due to major life events, except for the specified employee categories and life events in the countries listed in the table" (page 254).

The exceptions table (page 254) [S1-11.75] records gaps by country, life event and employee category:

• New Zealand: gaps marked for sickness (white collar, blue collar, executives) and unemployment (white collar, blue collar, executives) in both 2025 and 2024.
• United Kingdom: a gap marked under sickness, plus further entries under employment injury and acquired disability, parental leave and retirement rows.
• Yemen appeared in the 2024 column only; the table notes "Yemen: no figures for 2025 due to exit".

The five life events covered by the table are sickness, unemployment (footnoted as "Starting from when the employee begins working for the undertaking"), employment injury and acquired disability, parental leave, and retirement, each split into white collar, blue collar and executives.

The disclosure is therefore a positive statement of near-universal coverage with the residual gaps named country by country, rather than a blanket assertion. Methodology is set out in the annex, "S1-11 Social Protection metrics definitions and methodologies" (page 255). S1-11 is listed in the content index at page 254 (page 313).

Persons with disabilities

Reference: page 255.

"[S1-12.77] [S1-12.79] [S1-12.AR 76] Globally, 0.8% (2024: 0.7%) of the OMV Group's employees are individuals with disabilities" (page 255) - a small increase year on year on a low base.

The disclosure notes the limits of the figure and points to the annex for definitions and methodology: "For metrics definitions and methodologies related to the MDR-M-77 disclosure requirements on Persons with Disabilities, see > Annex: S1-12 Persons with Disabilities metrics definitions and methodologies" (page 255). It also cross-refers to the Pulse Check, where "we received a positive response on this focus area" (page 255).

Inclusion of persons with disabilities is one of the diversity targets OMV sets under S1-5: the targets described there cover "increasing the share of women in senior management, boosting international management representation, and ensuring the inclusion of persons with disabilities", with the accessibility target monitored annually rather than quarterly (pages 234, 244). The DE&I Vision commits OMV to "inclusive practices and positive action for groups at higher risk of vulnerability within its workforce" (page 225), and the Accessibility stream ran its annual Positively Purple awareness event in 2025 (page 234).

S1-12 is listed in the content index at page 255 (page 313).

Training and skills development metrics

Reference: pages 255-256.

2025 figures (page 255) [S1-13.83a, 83b, 84]:

• Percentage of employees participating in regular performance and career development reviews: female 79.7%, male 53.0%, total 60.0%.
• Total training hours for all employees: 535,883 (female 135,687, male 400,196).
• Average training hours per employee: 24 (female 24, male 25).
• Employees trained in health, safety and environmental standards in the last year: 19,970.
• Average hours of health, safety and emergency response training: 9 (female 7, male 10).
• Average training hours by category: top management 19, advanced level 22, core level 24, primary level 27, entry level 24, not classified 15.
• Participants in training: 23,343.
• Percentage of employees trained on discrimination and harassment: 19.0% (female 21.0%, male 18.0%).
• Training expenditure: EUR 7,225,050.

2024 comparatives (page 256): review participation 69.1% total; 533,842 training hours; average 23 hours; 17,451 trained in HSE standards; 20,748 participants; training expenditure EUR 11,227,536 - so spend fell by roughly 36% while hours held broadly flat.

The average of 24 hours sits against OMV's target of 30 hours (page 244). Review participation was recalculated against total headcount, restating 2024 from a total of 88.3% (page 256).

Health and safety metrics

Reference: pages 257-258.

Coverage (page 257): 100% of own workers covered by the health and safety management system (2024: 100%).

Employees, 2025 (page 257) [S1-14.88a-88c]: 40,025 thousand hours worked; zero fatalities; 61 recordable work-related accidents; Total Recordable Injury Rate 1.57 (2024: 1.41); Lost-Time Injury Rate 1.00 (2024: 1.05); lost-time injury severity 32.30 (2024: 29.23).

Other workers at OMV sites, 2025: 292 thousand hours worked; zero fatalities; 2 recordable accidents; TRIR 6.84; LTIR 0.00.

Employees and other workers at OMV sites combined, 2025: 67,216 thousand hours worked; 1 fatality as a result of work-related injuries (2024: 0); fatality rate 1.49 per 100 mn hours; 85 recordable accidents; TRIR 1.26 (2024: 1.30); LTIR 0.67; severity 33.42.

All categories combined, 2025: 107,240 thousand hours worked; 1 fatality; fatality rate 0.93 per 100 mn hours; 148 recordable accidents; TRIR 1.38 (2024: 1.33); LTIR 0.79; severity 32.89.

The fatality is the significant year-on-year change: 2024 recorded zero across every category.

Additional metrics (page 258, voluntary): sites certified to ISO 45001: 38.0% (2024: 42.0%); OMV employees covered by that certification 35.0% (2024: 31.0%); clinics audited by OMV Corporate Health 14 (2024: 10).

Work-life balance metrics

Reference: page 258.

"Percentage of employees entitled to take family-related leave vs. those who took it" [S1-15.93a, 93b] [S1-15.94] (page 258):

2025

• Entitled: female 100.0%, male 100.0%, total 100.0%
• Took: female 10.0%, male 5.6%, total 6.7%

2024

• Entitled: female 100.0%, male 98.7%, total 99.0%
• Took: female 8.2%, male 5.3%, total 6.1%

Entitlement reached full coverage in 2025, up from 99.0% in 2024, and take-up rose slightly for both genders. The gap between female and male take-up remains close to two to one (10.0% against 5.6%).

The disclosure gives no further breakdown by leave type or by region, and refers to the annex for definitions: "For metrics definitions and methodologies related to the MDR-M-77 disclosure requirements on Work-Life Balance, see > Annex: S1-15 Work-Life Balance metrics definitions and methodologies" (page 258).

Work-life balance is part of the material positive impact OMV identifies for its own workforce - "[S1-OW-IRO-1] Heightened awareness of human rights ... Increased employee satisfaction and health by ensuring just and favorable working conditions, promoting work-life balance and health and safety" (page 123) - and mothers returning from parental leave were a specific subject of a Chemicals segment workshop in 2025 (page 234). S1-15 is listed in the content index at page 258 (page 313).

Compensation metrics (pay gap and total compensation)

Reference: pages 259-260.

Headline figures (page 259) [S1-16.97a-97c]:

• Gender pay gap including all employees: 1.5% (2024: 1.0%) - the gap widened year on year.
• Annual total remuneration ratio (CEO-to-median employee pay ratio): 73:1 (2024: 76:1) - narrowed slightly.

The 2024 gender pay gap was restated "from 1.4 (including board members) to 1.0 (excluding board members)" (page 259).

By country, total (page 259, headcount at December 31, 2025 unless stated): Austria 5,374 employees, gap 9.8%; Belgium 1,265, -2.5%; Germany 905, 17.0%; Finland 943, -8.4%; Romania 11,244, -16.8%; Sweden 986, 1.9%; total all countries 23,296, 1.0% on that basis. The 2024 comparatives are Austria 8.1%, Belgium -3.9%, Germany 13.0%, Finland -7.7%, Romania -15.6%, Sweden 2.0%, total 1.5%.

The near-zero group figure conceals wide country and career-level variation: Germany runs a 17.0% gap in favour of men while Romania runs a 16.8% gap in the other direction, and the Romanian workforce is by far the largest single population. Career-level gaps within Austria include top management 11.5% and advanced level 9.3%.

Board members are excluded from the country table, and "The pay gap will not be published due to data protection concerns if the target group by career level is too small" (page 259).

Incidents, complaints and severe human rights impacts

Reference: page 260.

ESRS metrics, 2025 (page 260) [S1-17.103a-103c] [S1-17.104]:

• Complaints and incidents connected to own workforce: 83 (2024: 27), plus a further line at 43 (2024: 31).
• Severe incidents related to child labor: 0; related to forced labor: 0.
• Severe human rights cases where the undertaking played a role in securing a remedy: 0.
• Cases of non-respect of the UN Guiding Principles and OECD Guidelines for Multinational Enterprises: 0.
• Amount of fines, penalties and compensation for damages for severe human rights incidents: EUR 0 mn.
• Complaints filed with National Contact Points for OECD Multinational Enterprises: 0.

A footnote sets out the wider grievance volume: "We classify all complaints filed by own workforce through these channels as human rights grievances. We received 106 human rights grievances (substantiated and non-substantiated) from own workforce in 2025" (page 260).

Voluntary human rights assessment metrics, 2025 (page 260):

• Total operational sites assessed in the last three years: 100.0% (2024: n.a.)
• Of which human rights impacts or risks were identified: 9.5%
• Of which mitigation actions were taken: 100.0%

Policies related to value chain workers

Reference: pages 127 and 261-264.

S2 is material for "Working conditions; Equal treatment and opportunities; Other work-related rights (e.g., child labor)" (page 261).

"[S2-1.14] [S2-1.16] To manage our identified material impacts related to human rights in the value chain and our material risks related to reputational damage from human rights violations, as well as the loss of skilled workers in the value chain, our Code of Conduct and Human Rights Policy Statement act as overarching documents ... The HSSE Directive and Corporate Procurement Directive set out specific requirements for value chain workers hired by OMV, including those providing outsourced services (e.g., security, catering) and equipment suppliers performing regular maintenance at OMV-controlled sites" (page 261).

Code of Conduct update (page 111). "The Code of Conduct was updated in 2024 to explicitly address the views, interests, and rights of our workers in the value chain, occupational health and safety, human trafficking, forced labor, child labor, and other human rights principles."

Supplier selection (page 264). "stringent criteria ensure that contractors are aware of and align with our standards, thereby creating a supply chain that is less susceptible to human rights violations." "[S2-1.16] The EWRM Standard applies to all workers in the value chain equally."

Processes for engaging with value chain workers about impacts

Reference: page 264.

"[S2-2.22a, 22b] OMV promotes collaboration and engagement with contractors and subcontractors on health, safety, and other sustainability topics ... engagement with workers in the value chain occurs in all stages of our business relationship and at all stakeholder levels (both with management and on-site workers)".

Mechanisms named (page 264):

• annual contractor forums and training sessions with management representatives of contractors and suppliers;
• quarterly service meetings between OMV business representatives, Procurement, HSSE and selected contractor representatives "to review and improve service performance";
• "joint HSSE walks and on-site human rights checks" to understand conditions on site;
• "annual HSSE audits, TfS audits, and contractor audits with external auditors" to test mitigation measures.

Responsibility (page 264). "[S2-2.22c] The responsibilities and roles for contractor HSSE management are shared between Business, Procurement, and HSSE ... the VP of HSSE who reports directly to the CEO, and the Procurement and Investor Relations & Sustainability SVPs, who report directly to the CFO, oversee this engagement."

Effectiveness (page 264). "[S2-2.22e] ... A 360-degree evaluation is conducted to understand if the regularity and format of the supplier engagement methods used by OMV meet expected requirements."

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

Reference: pages 264-265.

"Wherever OMV has caused or contributed to a negative human rights impact, we take remedial actions ... e.g., through financial or non-financial compensation, restitution, restoration, rehabilitation ... We engage with the affected rights holder while implementing the proposed remedy and ensure that the remedy is rights-compatible and does not lead to secondary harm" (page 265).

Two channels, both OMV-established (page 265). "the SpeakUp Channel (on our Integrity Platform) and our Community Grievance Mechanisms ... [S2-3.28] Both of these channels are protected against retaliation, employing methods such as whistleblower protection ... They are communicated through training sessions, meetings, and events, and are publicly available on our website and at site locations."

SpeakUp scope. It allows value chain workers "to confidentially and, if necessary, anonymously raise concerns regarding serious work-related misconduct, including discrimination, harassment, unequal employment opportunities, and any violations of work-related human rights (such as forced labor, child labor, and human trafficking)".

2025 access work (page 265). OMV "launched communication activities addressing our business partners in 2025 to enhance access to the SpeakUp Channel", including posters at operational sites.

Taking action on material impacts on value chain workers

Reference: pages 265-269.

Due diligence tools (page 266). "[S2-4.32a] [S2-4.33a] [S2-4.34a] ... OMV has developed due diligence tools and techniques to comply with our human rights commitments ... These include higher-level assessments such as country entry checks, human rights compliance checks of potential business partners, and Human Rights Impact and Risk Mapping, as well as in-depth assessments such as impact assessments, self-assessments, and audits, usually implemented when the higher-level assessments reveal potential issues."

Engagement as an action (page 266). "we see active engagement with contractors on safety topics as not only a means of communication and exchange, but equally a concrete action to manage our impacts and risks."

Resources (page 266). "[S2-4.38] OMV dedicates significant resources to facilitating these actions, with a strong focus on training and raising awareness among value chain workers. The Sustainable Procurement, Supplier Innovation, and HSSE departments have also organized webinars and training sessions to increase sustainability awareness and safety at contractors' sites. Human rights management is integrated throughout the organization, including in Procurement, Security, HSSE, and Community Relations."

Targets related to value chain workers

Reference: pages 269-272. Three targets are disclosed.

1. Human rights assessments (page 269). "Our target of conducting human rights assessments including action plans in all high-risk countries every five years by 2030, underscores our commitment to identifying and addressing human rights impacts on workers in the value chain." Scope: own operations including contracted services, joint ventures and operating partners above a 10% OMV share; minority holdings of 10% or less are out of scope. Base year 2022, baseline "4/15 countries: 26.6%".

2. Supplier evaluations (page 269). Set to drive "continuous improvement of our suppliers' sustainability performance" and to manage "our risk of reputational damage related to human rights deficiencies".

3. Contractor onboarding (page 272). "Number of contractor employees trained in the Life-Saving Rules (LSR) Safety Center divided by the number of contractor employees planned to train ... The result should be 85% or over." Status 2025: "the target of 85% completion rate was achieved: CR = 135%, as more contractors were trained than planned."

A stated limit (page 272). Target setting involved benchmarking against IOGP and Concawe best practices, but "Workers in our value chain or their representatives were not directly involved in this process".

Policies related to affected communities

Reference: pages 127 and 274-276.

S3 is material for "Communities' economic, social, and cultural rights; Communities' civil and political rights; Rights of indigenous peoples", governed centrally by Group Sustainability under the SVP Investor Relations & Sustainability, who reports to the CFO (page 274).

"[S3-1.12] [S3-1.14] ... our Code of Conduct (CoC) and Human Rights Policy Statement serve as overarching frameworks ... In addition, the Sustainability Directive outlines specific processes and covers social responsibility, including community relations and social investments. The Sustainability Directive was updated in 2025 to include new community relations and social investment requirements, including a reference to the Community Relations & Social Investments (CR & SI) handbook" (page 274).

Indigenous peoples and land (page 278). "We are committed to community consultation and recognize the principle of free, prior, and informed consent (FPIC) in accordance with International Finance Corporation (IFC) Performance Standard 7 and ILO Convention 169. OMV recognizes and respects legitimate tenure rights related to the ownership and use of land and natural resources (including water) as set out in IFC Performance Standard 5. We are committed to avoiding involuntary resettlement and follow a zero-tolerance policy for illegitimate land grabbing, while respecting the right to water."

Processes for engaging with affected communities about impacts

Reference: pages 276-278.

"[S3-2.21a] Stakeholder engagement is an ongoing process that involves stakeholder identification and analysis, regular disclosure and dissemination of information, meaningful consultation and participation, establishment and maintenance of a grievance mechanism, and ongoing communication on issues that have been identified to be of priority to the communities" (page 276).

By project stage (page 276). "For new business projects, engagement with affected communities normally happens through their legitimate representatives. For projects requiring a Social and Human Rights Impact Assessment (SHRIA), direct engagement with members of the affected communities as well as credible proxies, for instance through focus groups and interviews, also occurs during project set-up. For mature projects such as at the refineries or production sites, engagement occurs directly with the affected communities as well as legitimate representatives."

Site-level ownership (page 276). "Each operating site is responsible for conducting a stakeholder analysis and developing a stakeholder engagement plan, which lays out the frequency and type of engagement, as fit for local purpose."

New Zealand (page 278). Collaboration with iwi (tribes) and hapu (sub-tribes) under the Treaty of Waitangi; discussions "often require cultural impact assessments".

Processes to remediate negative impacts and channels for affected communities to raise concerns

Reference: pages 278-280, with metrics on page 285.

"[S3-3.27a-27d] Our approach to managing community grievances follows the precautionary principle of obtaining local approval of OMV operations. This involves identifying and resolving the issues of concern to the local" communities (page 278). Community Grievance Mechanisms (CGMs) are the channel, "developed in line with the UN Guiding Principles on Business and Human Rights" (page 265).

Assessing the mechanisms (page 280). "During these assessments, internal and external stakeholders are consulted, for example via interviews, on the current performance of the CGMs and how to design improvements that may be necessary." OMV targets assessment of 100% of site CGMs against the UN Effectiveness Criteria (page 283).

Remedy (page 278). "In the event of OMV interference with the rights of local communities, especially those of indigenous peoples, we are committed to developing adequate mitigation, reparation, and compensation plans in close consultation with all relevant stakeholders, including the host government."

Volumes (page 285). 604 external grievances in 2025 (2024: 733); 224 resolved through remediation, "45% (2024: 35%) of resolved grievances".

Taking action on material impacts on affected communities

Reference: pages 280-283, with outcome metrics on page 285.

"[S3-4.30] [S3-4.35] We have defined specific actions to address our material negative impact on communities resulting from the failure to respect, protect, and fulfill economic, social, civil, and cultural rights, or failure to ensure proper community consultation, compensation, and reparation ... but also to enhance our material positive impact of building respectful and trustful relations" (page 280).

The actions. "engaging with local communities about potential and actual impacts of projects, establishing, assessing, and improving Community Grievance Mechanisms, and managing and mitigating any conflicts or grievances that arise by providing remedy, conducting community needs assessments ... and making social investments."

Resources (page 280). "[MDR-A-69a, 69b] Despite the resources dedicated to the actions and initiatives, none of them exceeded our key action threshold in the reporting year. Therefore, data requirements related to CAPEX have not been addressed."

Outcome (page 285). Community and social investments of EUR 23.7 mn in 2025 (2024: EUR 36.1 mn) reaching 1.2 mn beneficiaries (2024: 1.1 mn) - a sharp fall in spend against a slight rise in reach. Severe human rights incidents connected to affected communities: 0.

Targets related to affected communities

Reference: pages 283-285. Two targets are disclosed.

1. CGMs assessed against the UN Effectiveness Criteria (page 283). For both 2025 and 2030: "100% of Community Grievance Mechanisms of all sites assessed against UN Effectiveness Criteria." Scope: "7 defined 100% operator/majority-owned assets from the upstream, refinery, and power business segments (scope liable to change based on operatorship/divestments)". Out of scope: assets not operated or majority-owned by OMV, and "Chemicals business currently out of scope". Base year 2018, baseline 0. "We will review the target after 2025 to adjust or redefine it in light of business strategy. Options for changing the scope include promoting grievance channels at non-operator sites, inclusion of Chemicals business."

2. Social investment (pages 280, 285). At least 1% of the previous year's reported net income attributable to stockholders of the parent directed toward social goals. Status 2025: "We directed 1.7% (2024: 2.4%) of the previous year's reported net income attributable to stockholders of the parent toward social goals." Monitored biannually, reviewed annually.

A stated limit (page 285). "Although we did not directly engage with affected communities or their representatives, the targets were established with the understanding that human rights assessments are essential to identify any actual or potential human rights impacts on rights holders."

Business conduct policies and corporate culture

Reference: pages 127 and 286-291.

"[G1-1.9] Maintaining ethical standards is a key principle that guides our business decisions. Commitment to this objective is embedded at all levels of the OMV Group ... Every Company activity, from planning business strategy to daily operations, is assessed for compliance with ethical standards such as the Code of Conduct (CoC), the Code of Business Ethics, and the Ethics & Integrity Policy" (page 288).

Risk context (page 288). "While the OMV Group is headquartered in Austria, a country with high standards of business ethics, we also operate in several countries ... that are defined as high risk by the Transparency International Corruption Perceptions Index ... Ultimate responsibility for ensuring the ethical conduct of OMV lies with the Executive and Supervisory Boards."

The policy set (pages 288-291). Code of Conduct; P&C Ethics Policy on non-discrimination; Code of Business Ethics, setting "rules and procedures for conflicts of interest, gifts and invitations, donations and sponsorships, intermediaries and lobbyists, and for other areas of law such as trade sanctions, money laundering"; Ethics & Integrity Policy; and the Whistleblowing Directive.

Whistleblowing (page 291). Anonymous reporting and "specific whistleblower protection against retaliatory measures" sit in the Whistleblowing Directive.

Management of relationships with suppliers

Reference: pages 127 and 299-303.

This is the material G1 sub-topic: "Material Sub-Topic: Management of relationships with suppliers including payment practices", "governed centrally by OMV Group Procurement, which is led by the Chief Procurement Officer (CPO), who reports to the Chief Financial Officer (CFO). In OMV Petrom and Borealis, there are local CPOs reporting to the respective CFOs" (page 299).

"[G1-2.12] At OMV, we aim to foster innovation, maximize value contribution, and enable responsible supply chain growth ... By integrating sustainability requirements throughout our supply chain (e.g., audits, assessments, sustainability criteria in sourcing), we aim to drive a positive change in the sustainability performance of our suppliers and contractors while mitigating potential negative impacts on them, such as economic disruption due to delays in payment" (page 299).

Policies (page 299). The Corporate Procurement Directive "describes the overall process of supplier engagement and supplier management, including how human rights aspects are embedded in supplier prequalification, audits" and sourcing, alongside the Purchase to Pay Standard.

Process elements (pages 300-302): supplier relationship management, prequalification, supplier selection, risk assessments, supply chain carbon transparency, supplier capacity building, local content and supplier ESG programs.

Prevention and detection of corruption and bribery

Reference: pages 291-293.

Disclosed voluntarily. Corruption and bribery became immaterial at OMV Group level in the 2025 DMA review, but IRO-2 records the exception: disclosure requirements for immaterial topics were excluded "with the exception of Protection of whistleblowers and Corruption and bribery from G1 Business Conduct" (page 143). The reasoning: "OMV has a robust compliance program, anti-corruption policies, and training programs, meaning that corruption and bribery impacts and risks are well-managed and unlikely to escalate ... The sub-topic is still material for our entity Borealis but became immaterial at OMV Group level ... However, in line with NaDiVeG requirements, OMV still provides relevant information" (page 137).

Compliance Management System (page 291). "[G1-3.16] [G1-3.18a] OMV has set up a comprehensive Compliance Management System based on the requirements of IDW PS 980 ... The most recent audit was conducted in 2023 by Ernst & Young (EY) in accordance with the Auditing Standard (PS) 980 ... confirming that OMV operates an ambitious, well-established, and mature compliance program."

"[G1-3.18c] OMV has established a strict zero-tolerance policy for violations of the rules stipulated in the Code of Business Ethics" (page 291).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets sit under MDR-T rather than a numbered DR. G1-3 became a standalone targets DR only in the 2025/2026 ESRS; this report was prepared under the 2023 ESRS.

OMV discloses measurable business conduct targets in two places.

1. Promote awareness of ethical values and principles (page 293). 2025 target: "Conduct in-person or online business ethics training for all targeted employees." 2030 target: "Promote awareness of ethical values and principles among all targeted employees." Scope: "All targeted employees of OMV 100% operator/majority-owned (excluding Borealis) assets from all OMV business segments"; base year 2022; proposed in internal workshops and "approved by the OMV Executive Board (EB)"; reviewed annually. Status 2025: "A total of 10,501 OMV employees were trained in person in business ethics/anti-corruption in 2025 ... 785 OMV employees ... trained in person ... and 9,716 employees who completed the e-learning program. In addition, 449 OMV employees were trained in person in competition law", plus "394 employees (2024: 629) at Borealis".

2. Supplier carbon footprint engagement (pages 302-303). Voluntary; base year 2021, baseline 33%. Status 2025: "100% of suppliers covering >80% of Procurement spend engaged ... (2024: 100%)."

Incidents of corruption or bribery

Reference: pages 294-298.

2025 metrics (page 294) [G1-4.24a-24b] [G1-4.25a-25c]:

• Convictions for violation of anti-corruption and anti-bribery laws: 0 (2024: 0)
• Fines: EUR 0 mn (2024: 0)
• Confirmed incidents of corruption or bribery: 0 (2024: 0)
• Confirmed incidents in which own workers were dismissed or disciplined: 0
• Confirmed incidents relating to terminated or non-renewed business partner contracts: 0

Training coverage of functions at risk (page 294): in-person business ethics and anti-corruption 63% (2024: 39%); in-person competition law 82% (2024: 38%); e-learning on business ethics and anti-corruption 97% (2024: n.a.).

Voluntary metrics (page 294): whistleblowing cases brought to Compliance 69 (2024: 60); confirmed incidents of conflicts of interest 0; confirmed incidents of money laundering or insider trading 0; sites with an ethics certification 100%; sites assessed or audited internally on specific ethics issues 100%. "Due to confidentiality restraints, no information can be disclosed on types of misconduct and measures taken."

Training detail (page 295). For in-person business ethics and anti-corruption training the target group is 1,178 at-risk functions with 402 trained in the year, 824 managers with 152 trained, and 47 administrative, management and supervisory body members with 13 trained, on a three-year training cycle.

Payment practices

Reference: page 303.

2025 metrics (page 303) [G1-6.31] [G1-6.33a-33c]:

• Payments aligned with standard payment terms: 74.0% (2024: 75.5%)
• Average time to pay an invoice from the date when the contractual or statutory payment term starts: 58.1 days (2024: 56.1 days)
• Legal proceedings currently ongoing for late payments: 1 (2024: 1)

Standard terms (page 303, footnote). "To ensure we have a standardized approach to payment conditions for all our suppliers and contractors, including those from small and medium enterprises (SMEs), we stipulate 60-day standard payment terms in the Corporate Procurement Directive and Purchase to Pay Standard."

Both headline measures moved slightly in the wrong direction year on year: a smaller share of payments met standard terms and the average payment time lengthened by two days, though the average remains inside the 60-day standard.

Entity-specific and voluntary metrics reported alongside (page 303): suppliers invited to respond to the climate change questionnaire 1,064 (2024: 1,450); total suppliers assessed with negative environmental impacts in the supply chain that were disqualified 0.4% (2024: 0.1%); suppliers' operations covered by a certified ISO 14001 or EMAS environmental management system 68.5% (2024: 68.9%).