Pollution (Air, Water, and Soil)
Code of Conduct
The OMV Code of Conduct underscores our commitment to applying responsible natural resources management by conducting all activities in an environmentally responsible manner and with the aspiration to cause no damage to the environment. This includes a commitment to implement prevention and control measures to prevent losses to water and soil, by following the best recognized industry practices, beyond those provided by authoritative standards and guidance, in the operation of our activities. Where spills have occurred, they shall be assessed and cleaned up promptly after their occurrence to limit their impact on the environment and/or society. This policy highlights our overarching commitments to mitigate the negative impact identified in relation to water and soil pollution, as well as non-GHG emissions.
For the Code of Conduct, unless otherwise specified, the process for monitoring, the scope of the policy, involvement of senior-level management, reference to third-party standards (where relevant), interests of key stakeholders in setting the policy (where relevant), and how the policy is made available to potentially affected stakeholders are covered in E1 Climate Change.
Additionally, 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 byproducts or waste, as well as minimizing quantities or concentrations for handling and storage.
Environmental Management Standard
The Environmental Management (EM) Standard provides guidelines for the effective management of the negative impacts related to non-GHG emissions from our own operations and the use of OMV’s products, as well as water and soil pollution resulting from asset integrity failure at our onshore or offshore operations. The OMV EM Standard stipulates that all OMV businesses and activities must understand the impacts of their air emissions on local and regional ambient air quality. Air emissions are required to be monitored, controlled, and minimized in order to mitigate the potential effects on human health and harm to the environment. All our refineries and major chemical plants are located in the EU, where stringent legal requirements, such as the National Emissions Ceiling (NEC) Directive and the Ambient Air Quality Directive, govern air emissions. Air emissions must be systematically monitored or estimated, and appropriate monitoring systems or estimation models must be in place. Any new developments or significant changes to existing operations must consider emissions reduction at all decisional phases through value improvement practices and engineering. Our commitment to improving air quality around operational sites to ensure the right of communities to a clean, healthy, and sustainable environment, as well as work with our suppliers and customers to reduce emissions throughout the value chain, is also reaffirmed in our Code of Conduct. To monitor this process, an internal Environmental Management System (EMS) audit should be conducted annually, and a full environmental management audit carried out by an external auditor or OMV Environmental Advisor/Expert every three years for sites without ISO 14001 certification.
For the EM Standard, unless otherwise specified, the scope of the policy, involvement of senior-level management, reference to third-party standards (where relevant), interests of key stakeholders in setting the policy (where relevant), and how the policy is made available to potentially affected stakeholders are covered in E1 Climate Change. Within OMV’s EM Standard, processes and mechanisms have been defined to prevent, mitigate, and remediate potential negative impacts and risks. These include:
Risk Management
The management of safety and environmental impacts and risks allows OMV to pursue opportunities while assuring the protection of people, the environment, and Company assets, giving priority to all Company activities to ensure business integrity. Pollution-related risks are an integral part of our corporate and HSSE risk management framework. As part of the biannual EWRM process, water/pollution-related risks and mitigation measures are assessed in a larger strategic context, while local environmental impacts, risks, and opportunities are identified, analyzed, and evaluated by all OMV businesses, as prescribed in our Environmental Management Standard. Asset integrity risks that can lead to the pollution of air, water, and soil are managed via our Integrated Risk Register (IGRR).
Asset integrity risks related to a potential loss of primary containment exist for both our offshore and onshore operations. Due to the several layers of protection implemented, major offshore oil spills are very unlikely but have the potential to significantly impact the marine environment. The mitigation strategy aims to minimize the probability of such risks occurring and maximize preparedness so that we can provide timely remediation measures in the unlikely event of an oil spill. OMV allocates significant resources to prevention and mitigation measures. Any new or existing offshore drilling activity is accompanied by third-party analysis evaluating the magnitude of a potential major event and its possible consequences. In OMV, onshore integrity events have a higher probability of occurrence, but the impact magnitude is lower. Asset integrity programs are in place to identify and remediate the associated impacts and risks.
Safety and environmental risk management focuses on managing risks to make them as low as reasonably practicable, assessing hazards, with a preference for elimination over management, and preventing hazardous events rather than merely mitigating them. Once a pollution-related risk is identified, the business implements response measures in accordance with the Group framework, while also taking into account local legal requirements and the complexity of the facility or asset.
Monitoring
In all our refineries, we monitor emissions of pollutants such as sulfur oxides (SOx), nitrogen oxides (NOx), carbon monoxide (CO), particulate matter/dust, and non-methane volatile organic compounds (NMVOCs) as required by European and national legislation and the respective permits. If emissions are found to be in excess of nationally prescribed limits and/or limits defined in a permit, additional monitoring stations are installed, and measures are implemented.
OMV has a Well Integrity Management System (WIMS) in place covering all active wells operated by OMV. The WIMS enables a uniform and structured approach to describing, documenting, and reporting the status of well integrity throughout the production phase of a well in a predefined operating envelope. The WIMS therefore ensures that we operate our wells safely for people and the environment.
Prevention and Treatment
Air emissions must be systematically monitored or estimated and controlled. Appropriate monitoring systems or estimation models should be established. OMV has long implemented technologies to reduce emissions, such as installing end-of-pipe abatement technologies and floating roofs to reduce emissions. Over the past few years, we have focused on upgrading such technologies to ensure that they are still effective and reducing emissions. For instance, a SNOx flue gas cleaning plant was installed at the Schwechat refinery. With the SNOx Refurbishment of Wet Sulfuric Acid (WSA) program, in which a solution patented by OMV (two-layer PFA film structure with monitoring system) was implemented, both the reliability and the availability of the flue gas cleaning system could be increased. The flue gas cleaning plant at the Schwechat refinery is used for the removal of dust, and for denitrification and desulfurization of flue gases from the two power plants before they are emitted via the stack. This enables the separation of 98% of dust, the recovery of over 96% of sulfur, and the prevention of approximately 95% of NOx emissions.
Identified leaks are addressed immediately or within defined time frames in accordance with the site’s maintenance processes and based on the risk assessment outcome and other factors, such as feasibility of repair during operation. To strengthen our response to and reduce the environmental impact of oil spills, we continue to perform emergency drills, including pollution scenarios. At our Petrobrazi, Schwechat, and Burghausen refineries, we have implemented Leak Detection and Repair ( LDAR) programs. These programs involve both external partners and internal staff who continually monitor installations for leaking equipment. Whenever leaks are identified, they are repaired as quickly as possible, and the effectiveness of these repairs is thoroughly verified.
Corrosion Management Framework
The Corrosion Management Framework provides guidelines for the effective management of our assets and facilities to prevent negative impacts, such as water and soil pollution, resulting from asset integrity failure at our onshore or offshore operations. To complement the EM Standard, OMV’s Energy division has developed a Corrosion Management Framework ( CMF) to provide a proactive and consistent approach to corrosion monitoring and management across the entire division. Covering the full life cycle of the equipment exposed to the risk of corrosion in both oil and gas facilities, from the well to the sales point, this framework encompasses the entire value chain of our business. This standard, endorsed by the Head of Development of OMV, applies to all employees and contractors involved in corrosion management during the design, engineering, construction, commissioning, and operation phases of oil and gas fields at OMV Energy and OMV Petrom Exploration & Production (including its affiliates) globally, but excludes SapuraOMV. The CMF stipulates that all protective coatings and claddings shall comply with international standards such as ISO 14879, ISO 16961, and/or ISO 12944.
Spills
Spills Preparedness and Response Planning Standard
Oil spillsOil spills are defined as hydrocarbon liquid spills that reach the environment. are a critical environmental issue for our industry. Spill management is defined as the prevention of spills in operations and those caused by incidents such as sabotage or natural hazards, and the management and remediation of spills resulting from an incident. Our key commitment is to prevent spills from happening in the first place. However, if spills to soil or water do occur, the Spills Preparedness and Response Planning Standard provides clear guidelines on how to handle and clean them up to ensure the lowest possible impact from the incident. The Spills Preparedness and Response Planning Standard, which is an annex to the Environmental Management Standard, applies to all OMV sites globally, Borealis AG, and OMV Petrom S.A., but excludes SapuraOMV Upstream Sdn. Bhd. and all its fully consolidated subsidiaries (entity regulation existing). The target group includes all employees and external experts involved in providing subject matter advice to OMV companies and all contractor employees. Multiple stakeholder groups are affected by our spill management activities. Government authorities are involved through potential breaches of environmental regulations, while employees and contractors are impacted by potential health and safety issues arising from accidents and damage to the environment and society. NGOs/NPOs are interested in potential damage to the environment and society, society may suffer as a result of damage to the surrounding environment, and shareholders may have to deal with direct financial losses due to the costs of remediation measures and reputational damage. Furthermore, as OMV is diversifying, oil spills are no longer the only spills we need to deal with. For our subsidiary Borealis, preventing pellet spills is also a key issue.
Unless otherwise specified, the involvement of senior-level management, reference to third-party standards (where relevant), interests of key stakeholders in setting the policy (where relevant), and how the policy is made available to potentially affected stakeholders are covered in E1 Climate Change.
The EM Standard, Corrosion Management Framework, and Spills Preparedness and Response Planning Standard are key policies providing guidelines to mitigate the negative impacts related to pollution of air, water, and soil. These policies cover prevention and control measures identified in our materiality assessment and are listed in the IRO table, and currently apply exclusively to OMV operations. Additionally, our Code of Conduct, an overarching policy, underscores our commitment to implementing prevention and control measures to protect water and soil. We aim to follow the best-recognized industry practices beyond those provided by authoritative standards and guidance in our operations. Any spills are to be promptly assessed and cleaned up to minimize their impact on the environment and society.
To avoid incidents and emergency situations, and, if they occur, control and limit their impact on people and the environment, OMV adheres to the Environmental Management Standard. This mandates that spill prevention and control plans be tailored to the specific characteristics of each business. All onshore and offshore operations must identify and analyze activities that pose a risk of liquid spills with adverse environmental effects. When such risks are identified, operations must develop written spill prevention, control, and response procedures for all hazardous substances on site, particularly oil and hydrocarbons. These procedures can be annexed to the overall Response Procedure or form a standalone Spill Prevention, Control, and Response Plan, depending on legal requirements, facility complexity, and spill response needs. Any spill response system must include hazard identification, risk assessment, prevention, control, and response plans, command and control arrangements, and training and testing. Contingency planning is central to spill preparedness and involves gathering information, conducting risk assessments, identifying threatened environmental and socio-economic receptors, and developing response strategies. Additionally, procedures are established to ensure adequate response capabilities are mobilized according to the identified risks and to manage the responsible disposal of recovered materials. By following these guidelines, OMV is committed to preventing incidents and effectively controlling and mitigating their impact when they do occur.
Within OMV’s policies, processes and mechanisms have been defined to prevent, mitigate, and remediate potential negative impacts and risks related to the pollution of air, water, and soil. These include:
Emergency Response and Contingency Plans
We conduct spill responses according to a plan that identifies appropriate resources (persons in charge and intervention materials) and expertise. This plan assists on-site personnel with dealing with spills by clearly setting out the responsibilities for the actions necessary to stop and contain the spill and to mitigate its effects. This includes techniques for preventing the spill from moving beyond the immediate site and collecting the spilled substance and contaminated material. Clear communication and coordination protocols are set out in the local plans, particularly where national or international response resources may be required. We carry out regular oil spill response drills and training.
Clean-Up and Remediation
All oil spills occurring on land or in water are assessed and cleaned up immediately after their occurrence in accordance with the Spill Preparedness and Response Planning annex of our EM Standard. In particularly difficult cases, we rely on third-party support for capping and containment, surface clean-up, and emergency management. Leaks are repaired immediately or within defined time frames in accordance with the site’s maintenance processes and based on the risk assessment outcome and other factors, such as feasibility of repair during operation. We approach remediation measures in line with the relevant legal requirements, which include clean-up, restoration, rehabilitation, and/or replacement of damaged environmental receptors.
We ensure that the affected land is fit for the intended use by implementing remediation measures, including cleaning up spills (e.g., by excavation and clean earth filling), as well as relying on natural attenuation (recovery) based on the respective decision of the environmental authorities. Provisions are included in our accounts for the liabilities related to spills and cover cleaning and remediation costs.
Microplastics
Responsible Care Policy
Borealis has identified microplastic pollution through unintentional pellet loss from its operations as a material impact. Borealis manages this impact through its Responsible Care policy. The impacts of unintentional pellet loss from the subsidiary Borealis’ operations are specifically managed through the polyolefin (PO) production sites’ compliance with the Operation Clean Sweep (OCS) standard. OCS is a voluntary industry initiative, specifically designed to reduce and prevent plastic pellet, flake, or powder loss throughout the entire plastics supply chain, from production to handling and transport. It does this by committing its participants to best practices when handling plastic pellets and requiring external certification of compliance with the standard. The requirements of the OCS standard are integral to Borealis’ EMS and therefore its Responsible Care policy, which applies to all Borealis entities and affiliates globally involved in the processing, handling, or management of polyolefins (PO sites). Newly acquired entities are required to follow a comprehensive implementation plan that includes adherence to Responsible Care principles and the implementation of the OCS standard.
The policy aims to reduce the emission of plastic particles into the environment as far as possible. The key content and objectives of the policy include deploying the OCS standard at all of Borealis’ PO sites, obtaining external OCS certification of all PO sites in Europe (recycling plants are currently excluded from the certification process), and implementing the following pellet loss hierarchy as a guiding principle for avoiding pellet spills to the environment: zero loss of pellets from primary containment, mitigation of impacts in case of pellet spills, and cleaning up spillages to prevent unrecoverable pellet loss to the environment. Additionally, the policy involves implementing the six key OCS requirements at every PO site, which improve the worksite setup to prevent and address pellet spills, creating and publishing internal procedures to achieve zero pellet loss, providing employee training and accountability for spill prevention, containment, clean-up, and disposal, auditing performance regularly, complying with all applicable local and national regulations governing pellet containment, and encouraging partners to pursue the same objectives. The Responsible Care policy is owned by the Borealis CEO, who is also accountable for its implementation and the OCS standard at all PO sites.
It is aligned with the Operation Clean Sweep standard and ISO 14001 for environmental management systems. When establishing this policy, Borealis accounted for the interests of key stakeholders, including its owners through consultation with the Supervisory Board, and its employees through consultation with the works council. The OCS standard is managed by a steering committee comprising representatives from the European Commission, EU member states, and NGOs, thus ensuring their interests and perspectives are considered. This policy is not available to external stakeholders. However, the OCS standard, which underpins the policy, is publicly available through the OCS website. Within Borealis, the OCS standard is integrated into their Group-wide management system and is translated into local languages and contexts to ensure it is accessible and understandable for every Borealis employee. All Borealis employees are regularly trained on complying with the requirements and working toward preventing pellet loss. For more information, see the Borealis Group Annual Report 2024 – Group Management Report – Non-financial Statement.
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. Additionally, all environmental topics related to Borealis’ operations are managed through their environmental management system, which aligns with the Responsible Care policy. Borealis’ management system is structured into five levels. The first level, “policy,” establishes the framework for areas such as Environment, Health & Safety, and Product Stewardship, as outlined in the Responsible Care policy. The second level includes management handbooks, the third level describes processes, the fourth level provides detailed instructions, and the fifth level covers meeting charters. To avoid incidents and emergency situations involving the unintentional loss of plastic pellets, every PO site implements the six key requirements of the Operation Clean Sweep (OCS) standard, as detailed in the Group’s operational instruction on OCS implementation. Each Borealis site must also establish and annually review a risk management plan. This plan includes protocols and procedures to prevent and address spills, incorporating preventive measures such as preventive maintenance and double sealings, containment measures like catch trays and housings, and cleaning or reaction measures, including vacuum cleaners and street sweepers. The plan outlines responsibilities, actions, timeframes, and documentation procedures for instances where pellets are found outside the designated primary containment. It clarifies who is responsible, who handles the cleanup and how, and who reports and follows up both within Borealis and externally, such as with the authorities.