As there is a high degree of overlap between the material topics Climate Change, Environment (including all its material sub-topics, waste management, and process safety), and Health, Safety & Well-Being, covered in the Social chapter, the overarching policies that govern these topics are also the same. This section details all the general policies relevant to the material topics and sub-topics that fall under our Net Zero Transformation focus area, while specific policies pertaining to individual material topics and sub-topics are located within their respective chapters. In support of OMV’s transition into a net-zero business in line with the Paris Agreement and EU climate strategies and targets, OMV has developed the following policies and frameworks to guide its actions.
Code of Conduct
Our Code of Conduct outlines our commitments to reducing GHG emissions and supporting society’s shift from a linear to a circular economy. We aim to achieve this by offering diversified products with a reduced carbon footprint, gradually moving away from fossil fuels, and reaching net zero emissions by 2050.
Our process management systems and our corporate regulations and directives constitute the mandatory detailed implementation of OMV’s policies. They represent the conscientious translation of the Code of Conduct into practice and form the basis of our monitoring systems. OMV has implemented appropriate due diligence systems, measures, and ongoing checks to ensure that the spirit and the terms of our Code of Conduct are also applied in practice, including in our operations and value chain. Our Code of Conduct outlines our commitments to reducing operational emissions by improving both operational and energy efficiency. It includes transitioning to cleaner energy sources within our operations and sourcing renewable energy in accordance with the OMV Strategy 2030. By increasing the deployment of established renewable energy technologies and developing innovative solutions in the fields of low- and zero-carbon technologies for energy supply, mobility, and industry, OMV aims to enhance the production and sales of low- and zero-carbon energy. By working collaboratively with our suppliers and customers, we aim to reduce emissions across the entire value chain. Additionally, we ensure that our products and their emissions reduction potential are marketed accurately and transparently, avoiding any misleading statements. OMV is also aware of the social impacts associated with the energy transition and is committed to facilitating a Just Transition for our employees and communities, addressing the social and economic effects of the shift toward an environmentally sustainable economy.
Our process for monitoring the effectiveness of our Code of Conduct is an ongoing exercise. It includes performing human rights impact assessments, evaluating the effectiveness of our Community Grievance Mechanisms (CGMs), and conducting internal audits, compliance checks, spot checks, and supplier assessments. These efforts ensure transparency, accountability, and ethical behavior across our Company, reinforcing our dedication to responsible business practices.
The OMV Code of Conduct, which is approved by OMV’s Executive Board, applies worldwide in all our business segments and consolidated subsidiaries. Adjustments specific to companies and/or certain segments and countries are welcomed, provided they harmonize with the OMV Code of Conduct. The document is an annex to the OMV Group Sustainability Directive. The CoC is applicable globally across all business segments and fully consolidated subsidiaries. Adherence to the Code of Conduct is mandatory for everyone working for OMV or acting on behalf of, with, and for OMV. All business partners and other individuals acting on behalf of OMV must comply with all relevant laws and regulations and follow our Code of Conduct or equivalent standards if they have their own adequate regulations in place. This includes all workers in the value chain, such as those of extractive business partners, JV partners, suppliers, agents, consultants, sales representatives, dealers, contractors, sub-contractors, contract workers, and affiliates.
Our Code of Conduct is guided by various international standards for sustainable development and OMV is a signatory to the United Nations Global Compact (UNGC). We are committed to upholding the values of the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises, and fully support the goals of the Paris Agreement, the Kunming-Montreal Global Biodiversity Framework’s 2050 vision and 2030 mission, and the UN Sustainable Development Goals (SDGs). The Code of Conduct was revised in 2024, during which certain key stakeholders including OMV subject matter experts and employees, among others, were consulted either directly (e.g., through meetings) or indirectly (e.g., Community Grievance Mechanism). Feedback received from key stakeholders was considered to ensure that, wherever possible, their interests were not undermined. The Code of Conduct is publicly available on the OMV website and is also embedded within our General Purchase Conditions. It is supplemented with further documents and training to ensure that employees and business partners understand our commitments and know how to apply them in practice.
Environmental Management Standard
The Environmental Management (EM) Standard provides detailed guidelines on managing the negative impacts of GHG emissions from our operations and products sold, as well as addressing the low energy efficiency of our operations. This includes mitigating the high emissions and significant energy consumption in continued operations and business activities under the current business model. It stipulates an assessment of environmental impacts and risks, and adherence to environmental performance requirements in terms of emissions into the atmosphere, water use and discharge, pollution resulting from spills, the use of raw materials, waste management, hazardous substance handling, and biodiversity and ecosystem protection. Specifically, it covers substances and pollutants that include, but are not limited to: GHG and non-GHG air emissions, spills, plastic particles, hazardous substances, naturally occurring radioactive material, noise and vibrations, and non-hazardous waste. Over the past few years, the EM Standard has been enhanced to include minimum requirements on odor emissions and H2S in vented gas, and two new annexes on the Water Management Plan Framework and Water Management Plan Template. The OMV EM Standard also defines the process of carrying out Environmental and Social Impact Assessments (ESIAs), mainly for projects. The OMV Environmental Management Standard requires that all OMV businesses and activities use energy responsibly, conserve primary energy resources, and implement energy management plans in accordance with ISO 50001. It also provides requirements for flaring and venting in existing and future operations.
The EM Standard is approved by OMV’s CEO, who has overall accountability for its implementation, and is applicable globally across all OMV business segments and fully consolidated subsidiaries, with the exception of SapuraOMV. It also applies to all external consultants that provide environmental services to OMV companies. The general principles for environmental management at OMV include complying with all applicable environmental laws and regulations, and observing internationally accepted best practice industry guidelines, for instance the International Standards Organization (ISO), the International Association of Oil & Gas Producers (IOGP) and the global oil and gas association for advancing environmental and social performance across the energy transition (Ipieca) best practices, among others. The EM Standard requires that all relevant OMV businesses and activities (including investment, acquisitions, and divestment) implement an Environmental Management System (EMS) consistent with ISO 14001 and adhering to the minimum requirements listed. OMV subject matter experts and relevant employees were either directly involved in the development of the Standard or their feedback on the draft Standard was sought during the internal consultation process. The EM standard is available on OMV’s Regulations Alignment Platform and is supplemented with training to ensure that all affected employees and contractor employees understand our general guidelines and know how to apply them in practice. Please also refer to E2 Pollution, E3 Water, E4 Biodiversity and Ecosystems, and E5 Resource Use and Circular Economy.
Greenhouse Gas Management Framework Standard
The Greenhouse Gas Management Framework Standard complements the guidelines provided in the EM Standard to give a detailed approach to 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. This includes mitigating the high emissions and significant energy consumption of continued operations and business activities under the current business model.
The GHG Management Framework is an OMV standard that defines how to measure, report, and manage greenhouse gas emissions. It contains the definitions, boundaries, and rules for OMV’s strategic GHG reduction targets and “net zero by 2050” ambition. The Standard defines reduction measures such as Carbon Capture and Storage (CCS) and Carbon Capture and Utilization (CCU), as well as the requirements for purchasing voluntary carbon offsets and their contribution to achieving the Group’s GHG targets. It also provides guidance on the management of methane emissions, and the accounting and reporting of biogenic CO2 emissions. It applies to OMV including Borealis and OMV Petrom, but excludes SapuraOMV Upstream Sdn. Bhd. The CFO as the person who approves the GHG Management Framework is accountable for its implementation, while responsibility for implementation lies with the SVP Investor Relations & Sustainability. The GHG Management Framework references the GHG Protocol, the OGMP 2.0 framework, IPCC, and the Integrity Council for the Voluntary Carbon Market. OMV subject matter experts and relevant employees were either directly involved in the development of the Standard or their feedback on the draft Standard was sought during the internal consultation process. The Standard is made available to all OMV employees via OMV’s Regulations Alignment Platform on the OMV Intranet.
Controlling of Investment Directive
The Controlling of Investment Directive regulates the process of investment decision-making and reporting within OMV, more specifically defining CAPEX for controlling purposes. The Directive also regulates the investment criteria for sustainability projects that are aimed at mitigating the negative impacts and risks identified, including projects to reduce GHG emissions from operations, products sold, and low energy efficiency in our operations. The goal is to promote and facilitate investments in projects aligned with our climate targets, including our long-term net zero target. OMV defines CAPEX for sustainability projects as investments that meet one of the following two criteria: either they are aligned with the EU Taxonomy, or they are investments that support the implementation of OMV’s 2030 Sustainability Framework. The latter includes investments related to methane leakage detection and repair, energy efficiency programs, chemical recycling, and community investments classified as strategic social investments, among others. For sustainability projects to pass the final investment decision, different financial hurdles apply compared to those applicable to the rest of the projects in the portfolio. “Sustainability CAPEX” projects use distinct “weighted average cost of capital (WACC)” rates that consider the specific risks of sustainability projects (usually lower compared to other projects) and a payback period of <20 years (longer than for other projects).
The scope of the Controlling of Investment Directive covers OMV including all its fully consolidated subsidiaries. The Directive is approved by the OMV Executive Board, which is accountable for its implementation. Responsibility for implementation lies with the SVP Group Controlling & Performance Management. OMV subject matter experts and relevant employees were either directly involved in the development of the Directive or their feedback on the draft Directive was sought during the internal consultation process. The Directive is made available to all OMV employees via OMV’s Regulations Alignment Platform on the OMV Intranet.
Borealis Policies for Climate Change Adaptation
Borealis, a part of the OMV Group, is actively taking steps to adapt to climate change, thereby enhancing its resilience across the value chain. It has several policies (Responsible Care Policy, HSE Management System Policy, Energy Management System Policy, Commercial Operations for Energy, Utilities, and CO2 Emission Allowances Policy) related to climate change mitigation and adaptation, which ensure the consistent delivery of essential feedstock from upstream operations to its own facilities, as well as the reliable delivery of products downstream. Borealis offers products and solutions that support climate adaptation, thereby increasing climate resilience for customers and society. These products include solutions for cooling, rainwater management, and more. However, it is anticipated that Borealis’ suppliers will pass on more of their climate change adaptation costs, leading to higher feedstock costs for Borealis. There is no policy addressing climate change adaptation at the OMV Group level.
Mergers and Acquisitions Policy
This policy enhances the framework for managing material IROs identified through the due diligence process required to assess the impacts and risks of M&A projects on the company’s carbon footprint, and to prevent reputational damage and loss of customers. The objective of this policy is to outline the minimum requirements for the planning, approval, and execution of M&A projects at Borealis. It also includes requirements regarding climate change mitigation and adaptation during an M&A project. According to the policy, the impact of the M&A project on Borealis’ corporate carbon footprint, transition plan, and climate change mitigation and adaptation risks needs to be assessed during the due diligence phase. The policy scope applies to the following M&A projects: acquisition of all or parts of the shares or assets of entities not under the control of Borealis; divestments of Borealis-controlled tangible and intangible assets or shares; and mergers involving the contribution of shares or existing assets. The Mergers and Acquisitions Policy requires the due diligence phase of an M&A project to assess its impact on Borealis’ corporate carbon footprint, transition plan, and risks related to both climate change mitigation and adaptation. The Vice President for Strategy & Group Development of Borealis is accountable for implementing the policy. Any material deviation from the procedure must be brought forward by the project owner and approved by the Executive Board of Borealis. This policy does not refer to third-party standards. No other areas were identified. The policy is made available internally to Borealis employees.