Business Principles and Social Responsibility Performance

Business ethics and compliance

OMV is a signatory to the UN Global Compact and adheres to the OECD Guidelines for Multinational Enterprises. OMV’s Code of Conduct and Code of Business Ethics publicly lay out our commitments to responsible and ethical business conduct. The Code of Conduct applies to all employees. Although we are headquartered in Austria – a country with high business ethics standards – we operate in several countries in the Middle East, North Africa, Asia-Pacific, the Americas, and Europe that are defined as high risk by the Transparency International Corruption Perceptions Index. We strive to avoid the risks of bribery and corruption that are specific to our sector. We also highly value our reputation. Therefore, our highest priority is ensuring uniform compliance with our business ethics standards wherever we operate. Compliance with ethical standards is a non-negotiable value that supersedes any business interest. Absolute commitment to this objective is embedded at all levels of OMV from top management to every employee. Our business partners are also expected to share the same understanding of and commitment to ethical standards. Every Company activity, from planning business strategy to daily operations, is assessed for compliance with ethical standards, such as the Code of Conduct and Code of Business Ethics.

A dedicated cross-regional compliance organization ensures that OMV standards are consistently met across the Group. In 2023, 9,285 OMV Group employees were trained in business ethics. In addition, OMV introduced a new Ethics & Integrity Policy that defines the principles of what it means to act ethically and with integrity. This policy aims to guide the way that business is conducted within OMV, what is considered acceptable or desirable behavior, above and beyond compliance with laws and regulations. The Ethics & Integrity Policy is supported by a newly established Ethics & Integrity Committee, which shall provide reassurance that the organization is living up to its ethical values and commitments.

The Integrity Platform provides an anonymous whistleblower mechanism for OMV employees and external stakeholders, such as suppliers. They can use this platform to report issues relating to corruption, bribery, conflicts of interest, antitrust law, capital market law, public procurement, environmental protection, product and food safety and consumer protection, corporate tax regulations, and data protection.

Supplier compliance

Implementing sustainable procurement means caring about the environmental, social, and economic impacts of the goods and services the Company intends to purchase. At OMV, we aim to foster innovation, maximize value contribution, and enable supply chain growth. OMV has a Code of Conduct in place that ensures that suppliers support OMV’s principles. It is of paramount importance to our organization to be fully compliant with all applicable legal requirements, as well as with our internal safety, environmental protection, and human rights standards while managing our supply chain. OMV has a process in place to ensure that existing and potential business partners sanctioned by the EU or international organizations, such as the United Nations, are not accepted as procurement partners. In 2023, OMV’s Corporate Procurement Directive was revised. Two of the main changes were the introduction of sustainability criteria as part of the commercial evaluation and sustainability embedded in the Supplier Relationship Management process. To ensure we have a standardized approach to payment conditions for our suppliers and contractors, we have 60-day standard payment terms stipulated in the Corporate Procurement Directive.

To mitigate supply chain risks including forced labor, slavery, human trafficking, and corruption, OMV imposes the legal requirements and internal rules and standards applicable to OMV on its suppliers. Our suppliers and supply chain partners are obligated to sign and fully comply with the content of the Code of Conduct. In addition, our suppliers must accept the General Conditions of Purchase, which further detail our business standards (e.g., labor rights), as an integral part of our contractual agreements. OMV reserves the right to terminate relationships with suppliers if non-compliance is discovered or not addressed in a timely manner.

The Supplier Relationship Management Framework was rolled out in 2023. As a result, sustainability is now part of supplier segmentation, supplier performance, supplier meetings, and supplier innovation. Supplier prequalification is part of precontractual activities, during which OMV collects information from a potential supplier for the purpose of evaluating compliance with our HSSE and other sustainability requirements. The goal of the prequalification process is to screen potential suppliers before bringing them on board or during the tender stage to ensure that only those suppliers who meet our HSSE and sustainability standards can be considered for future collaboration. Following prequalification, the procurement colleagues and business representatives select the best suppliers based on a predefined set of commercial and technical criteria during a tender process. In 2023, we continued to embed sustainability elements into sourcing activities (e.g., technologically innovative elements, carbon emissions, energy efficiency KPIs, CDP and EcoVadis score) during several pilot projects.

OMV conducts supplier audits as part of the prequalification process and/or during contract execution. The aim of the audits is to measure the performance of our suppliers and define actions that will enable them to optimize their performance and meet OMV requirements. During the audits, we pay special attention to the financial stability of our suppliers, their strategy and organization, supply chain, sustainability (e.g., human rights, carbon footprint management, environmental management, certifications, and social responsibility), and their cybersecurity performance. We also carry out annual subject-specific audits on topics such as process safety, quality, and efficiency. During the supplier audits, we place great emphasis on understanding not only the management approach to the topics within the scope of the audits (e.g., HSSE aspects), but also how the topics are understood and applied by the employees on site (e.g., through discussions with workers and managers).

Since 2021, OMV has been a member of Together for Sustainability (TfS). As a joint initiative and global network of 50 companies, TfS sets the de facto global standard for the environmental, social, and governance performance of chemical supply chains. The TfS program is based on the principles of the UN Global Compact and Responsible Care^®. Being a TfS member helps OMV to further embed sustainability into its day-to-day business operations and further cascade sustainability requirements within our supply chain.

We aim to continuously manage and decrease the carbon volume of our purchased goods and services. Only by working together with our suppliers will we be able to define joint low-carbon initiatives to continuously decrease the carbon emissions in the supply chain and meet our Paris Agreement commitments. As part of its CDP Supply Chain membership, in 2023 OMV invited 394 suppliers to respond to the CDP climate change questionnaire. Suppliers were selected based on spend, estimated carbon emissions volume, and the carbon intensity of the goods and services purchased from them. In addition to reporting their emissions, we asked the suppliers whether they have carbon reduction targets in place, and invited them to share with us any initiatives or projects to reduce carbon emissions in which they would like us to participate. 71% of responding suppliers have a climate target in place (vs. 75% in 2022).

Human rights

Human rights are universal values that guide our conduct in every aspect of our activities. Our responsibilities in the area of human rights include, but are not limited to, equality and non-discrimination, decent living wages, working hours, employee representation, security, primary health care, labor rights in the supply chain, education, poverty reduction, land rights, and free, prior, and informed consent. OMV respects and supports human rights as described in the Universal Declaration of Human Rights and in internationally recognized treaties, including those of the International Labour Organization (ILO). We have been a signatory to the UN Global Compact since 2003 and are fully committed to the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. We fully support the aims of the UK Modern Slavery Act 2015 and are committed to operating our business and supply chain free of forced labor, slavery, and human trafficking. OMV considers human rights to be an important aspect of our risk management approach, which is integrated into our decision-making processes. OMV recognizes its responsibility to respect, fulfill, and support human rights in all business activities and to ensure that OMV does not become complicit in any human rights abuses as defined under current international law.

We conduct human rights risk assessments at country level to identify and assess ongoing and emerging human rights impacts and the resulting potential risks relevant to OMV business activities in the country in order to prevent and mitigate human rights risks and impacts. A total of 7,124 employees received training on human rights topics through the e-learning tool and in-person training sessions in 2023 (2022: 4,254). As professional training is essential to ensure compliance with our human rights commitment, we have set ourselves the goal of training all employees in human rights topics by 2025. In addition, internal awareness campaigns on human rights were implemented. In 2023, 19 incidents of human rights grievances were reported (2022: 35).

In late July 2022, OMV’s subsidiary Borealis was confronted with reports of alleged human trafficking practices conducted by the main contractor (IREM) and their subcontractor on a propane dehydrogenation (PDH) plant construction site in Kallo, Belgium. The practices were reported to involve exploitation, inadequate compensation, lack of social security, and poor housing conditions. Since the allegation, Borealis has taken many steps to increase oversight of the PDH construction site in Kallo, Belgium, and advance its organizational set-up both in terms of competence and governance. For instance, Borealis invested in additional capabilities and capacities to reduce the risk of social misconduct and malpractice, such as setting up and implementing a Global Social Compliance Team, with one social compliance manager across the company and three regional social compliance managers. Borealis also implemented regular alignment meetings with the social inspectorate and work authorities in Belgium and Austria. Borealis has a zero-tolerance policy for social malpractice and misconduct. A management document was implemented in the Borealis Management System (BMS), stating the company’s social compliance ambition, the framework for identifying regulatory and social compliance risks, advice on designing and implementing regulatory and legal compliance processes and controls to mitigate such risks, and how to monitor and report the effectiveness of these controls. Borealis has also implemented stricter access checks at the site gates of its production locations in Austria and Belgium, combined with more frequent and risk-based checks.

The OMV Group always seeks to improve, and is strongly committed to further strengthening its processes and mitigation measures to prevent any maltreatment and disrespect of workers’ human rights in the supply chain. At corporate level, we analyzed the HSSE and Procurement directives for contractor management and prepared a detailed checklist for human rights compliance to be used at site level. The revised human rights e-learning refers specifically to human rights in business relations, and the OMV Group Human Rights Policy Statement details our human rights commitment related to labor rights and business partners in line with business best practice and international standards. The OMV Group Human Rights Policy Statement was approved by the Executive Board of OMV Petrom in February 2023, while Borealis signed off its Human Rights Policy Statement in October 2023, with formal approval from its CEO. In addition, individual monitoring initiatives were implemented at a local level throughout the Group to ensure our suppliers’ compliance with human rights.

Community relations and development

OMV maintains an active partnership with local communities in all countries in which the Company does business and is committed to adding value to these societies. As part of OMV’s stakeholder dialogue, we have implemented Community Grievance Mechanisms (CGM) at all operating sites. In 2023, OMV registered 732 external grievances (2022: 776) from the Community Grievance Mechanisms. All of the grievances were handled in accordance with OMV’s localized community grievance management procedures, which stipulate a stringent approach to systematically receiving, documenting, addressing, and resolving grievances in all of the countries where we operate.

OMV has set the goal of aligning the CGM system at all sites with the effectiveness criteria of the United Nations Guiding Principles. We are striving to achieve this target by conducting assessments that include reviews of management processes and consultations with internal and external stakeholders. The assessments result in recommendations and tailored action plans to improve grievance management at site level. The action plans are implemented by local management and monitored by headquarters. The sites already assessed represent 93% of all registered grievances at OMV in 2023.