2022 Communication on Progress

OMV PETROM S.A.

Published date

June 29, 2022

No. of questions

61

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

    1. Does the Board / highest governance body or most senior executive of the company:

    2. Does the company have a publicly stated commitment regarding the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

    No formal structure

    Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)

    Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)

    Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)

    Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Prevention

    6. Does the company have a process or processes to assess risk?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    6.1. During the assessment of risk, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    7.1. During the due diligence process, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Concerns and grievance mechanisms

    8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

    Optional comment
    The internal Whistleblowing Directive lays out how employees and externals can confidentially and anonymously make a whistleblower report regarding all relevant topics pursuing the EU Whistleblowing Directive, including (but not only) corruption and bribes, conflicts of interest, competition law, and capital markets law.

    8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    Is the process confidential (e.g., whistleblowing process)?

    Are there processes in place to avoid retaliation?

    Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)

    Other (Please provide additional information)

    Optional comment
    The internal Whistleblowing Directive lays out how employees and externals can confidentially and anonymously make a whistleblower report regarding all relevant topics pursuing the EU Whistleblowing Directive, including (but not only) corruption and bribes, conflicts of interest, competition law, and capital markets law.

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Lessons

    10. How does the company capture lessons regarding each of the following sustainability topics?

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Executive Pay

    11. Is executive pay linked to performance on one or more of the following sustainability topics?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Board Composition

    12. Percentage of individuals within the company’s Board / highest governance body by:

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    5

    Male (%)

    60

    Female (%)

    40

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    40

    Above 50 years old (%)

    60

    From minority or vulnerable groups (%)

    0

    Executive (%)

    100

    Independent (%)

    0
    Optional comment
    page 100 Sustainability Report 2021

    13. Do you produce sustainability reporting according to:

    IPIECA

    Data Assurance

    14. Is the information disclosed in this questionnaire assured by a third-party?

    Assurance statement page 143 in the 2021 Sustainability Report

  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    Response

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    In 2021, we worked specifically on: ► Risk assessment for security forces ► Human rights awareness campaign ► Human rights e-learning preparation for all employees starting 2022 Separately, we have drafted an implementation plan to address security risk assessment.

  • Labour

    Commitment

    1. Does the company have a policy commitment in relation to the following labour rights principles?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    2021

    Forced labour

    Not an area of concern given where the business is located/does business

    Child labour

    Not an area of concern given where the business is located/does business

    Non-discrimination in respect of employment and occupation

    2021

    Occupational safety and health

    2021

    Working conditions (wages, working hours)

    2021

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving labour rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks /impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    4. Who receives training for the following labour rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Performance

    6. What is the percentage of employees covered under collective bargaining agreements?

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    100

    7. What is the percentage of employees in a trade union or other workers' organization?

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

    Employees in a trade union or on a worker committee (%)

    87.4

    8. In the course of the reporting period, what was the percentage of women in:

    Percent of women (%)

    Unknown

    Senior leadership level position

    0.56

    Non-executive board

    Optional comment
    The percentage is calculated by reference to the total number of women / men and is available in the 2021 Sustainability Report on page 101.

    9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    100
    Optional comment
    The correct percentage in Romania is 120% (unable to fill in the form) details on page 103 of the 2021 Sustainability Report. The company has more men in the blue-collar category (51%), where average remunerations are lower, while 87% of women are white-collar employees with higher average remunerations. Ratio of the basic salary and remuneration of women to men for each employee category is calculated as ratio of average base gross salary or remuneration of defined category between woman and men (where average base gross salary or remuneration = sum of total base gross salary or remuneration divided by w/m headcount).

    10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    0.41
    Optional comment
    per mn hours worked

    11. In the course of the reporting period, what was the company’s incident rate?

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    Optional comment
    We do not track this exact KPI, however all Occupational Safety KPIs can be consulted in the 2021 Sustainability Report on page 103.

    Response and Reporting

    12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    OMV Petrom strives to be a fair and responsible employer. Upholding and promoting labor rights is essential to achieving legal compliance in a local and international environment. It is also essential to ensuring that our global workforce can develop professionally and fulfil their personal aspirations in line with business needs. To mitigate supply chain risks including forced labor, slavery, human trafficking, and corruption, OMV Petrom imposes the legal requirements and internal rules and standards applicable to OMV Petrom on its suppliers. Our suppliers are obligated to fully comply with the content of the Code of Conduct, and our supply chain partners are required to sign 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.

  • Environment

    Commitment

    1. Does the company have a formal policy on the following environmental topics?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    2021

    Water

    2021

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    2021

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    2021

    Energy & Resource Use

    2021

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks/ impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Climate Action

    6. What were the company’s gross global greenhouse gas emissions for the reporting period?

    Scope 1 Emissions

    Emissions (tCO2e)

    4040000

    Scope 2 Emissions

    Emissions (tCO2e)

    94000

    Scope 3 Emissions

    Emissions (tCO2e)

    23330000
    Optional comment
    The figures are available in the Sustainability Report 2021 on page 115

    7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

    Percent of revenue (%)

    8. Has the organization acted to support climate change adaptation and resilience?

    Energy / Resource Use

    9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

    % of total energy consumption

    Technology

    10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

    Percent of total revenue (%)

    Sector-specific Questions

    11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.

    Sector-specific: Water

    12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

    Water withdrawal (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    56347

    Groundwater:

    5348

    Surface water:

    10568

    Rainwater:

    0

    Wastewater:

    0

    Percentage of water withdrawn in regions with high or extremely high water stress (%)

    0.3

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    46332

    Groundwater:

    Surface water:

    Rainwater:

    Wastewater:

    Percentage of water consumed in regions with high or extremely high water stress (%)

    0.4
    Optional comment
    Figures available in the 2021 Sustainability report on page 117.

    13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

    Water intensity of products (cubic meter/$):

    Optional comment
    This KPI is not tracked currently, due to our very limited activity in regions with high or extremely high water stress.

    Sector-specific: Forest, biodiversity, and land use

    14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).

    Number

    Unknown

    Not applicable (Please provide additional information)

    Sites

    Hectares

    15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

    Conversion of natural resources (hectares)

    16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

    No

    No, but we plan to in the next 2 years

    Yes

    Forest ecosystem restoration

    Romania plants for tomorrow - Two new projects were part of “Romania plants for tomorrow” program in 2021. Urban forests were created in Moinești, Urziceni and Buftea to improve the air quality, reduce noise and support biodiversity. The second project is the Educational Forest, in which pupils from several schools in Prahova County took field trips to Tinosu to learn about the forest ecosystem. In this second year of our “Romania plants for tomorrow” program, approx. 600,000 seedlings were planted on 125 hectares, in 41 locations from 18 counties. The afforestation was performed in two seasons, spring and autumn.

    Other ecosystem restoration

    Reforestation

    Romania plants for tomorrow - Two new projects were part of “Romania plants for tomorrow” program in 2021. Urban forests were created in Moinești, Urziceni and Buftea to improve the air quality, reduce noise and support biodiversity. The second project is the Educational Forest, in which pupils from several schools in Prahova County took field trips to Tinosu to learn about the forest ecosystem. In this second year of our “Romania plants for tomorrow” program, approx. 600,000 seedlings were planted on 125 hectares, in 41 locations from 18 counties. The afforestation was performed in two seasons, spring and autumn.

    Natural regeneration

    Agroforestry

    Set-aside land

    Biodiversity offsetting

    Other (please specify in text box)

    Sector-specific: Air pollution

    17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

    Emissions (tCO2e)

    Unknown

    Not applicable (Please provide additional information)

    NOx

    2915

    SOx

    589

    Volatile Organic Compounds (VOC)

    Hazardous air pollutants (HAP)

    Particulate matter (PM10)

    Persistent organic pollutants (POP)

    Other (please specify in text box)

    3114
    Optional comment
    NM - VOC reported in the "other" category. The entire list of emissions related KPIs is available in the 201 Sustainability Report on page 117.

    Overall Environment

    21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

    Strategic risks and opportunities (e.g., related to climate change or water stress) are assessed in a top-down process, while a bottomup process with a standardized methodology is used to assess environmental aspects, impacts, and risks, including legal compliance risks, in our operations. The framework and methodology for our coordinated Group-wide Environmental Risk Assessment are based on best practice, meet ISO 14001 requirements, and ensure the consistent qualitative assessment of operational risks related to the environment. The resulting environmental risk database includes information on existing controls for environmental risks and future actions required. We promote environmental communication including via events, awareness campaigns and round tables. Examples include the OMV Petrom Environmental Awards 2021 - webcast event with over 1,300 participants when the Executive Board awarded 70 winners with significant contribution to environmental performance in 2021, the awareness campaigns in Petrobrazi and PEC Turnu as well as the Environmental Round Table, knowledge exchange platform targeting the HSSE Managers and Environmental experts. In 2021, our total environmental costs (accounting for environmental protection expenditure, including depreciation and environmental investments for assets put into operation) amounted to EUR 174.49 mn (2020: EUR 148.82 mn). According to the EMA approach, the environmental investments for assets put into operation in 2021 totaled EUR 28.59 mn (2020 EUR 36.26 mn). In 2021, we paid EUR 0.076 mn (2020: EUR 0.047 mn) in fines and penalties. These sanctions resulted mainly from environmental incidents, related to spills. No paid fines were above EUR 10,000 in any of our operations in 2021.

  • Anti-corruption

    Commitment

    1. Does the company have an anti-corruption compliance programme?

    2019
    Optional comment
    Compliance with ethical standards is a non-negotiable value that takes precedence over all other considerations. At OMV Petrom, absolute devotion to this purpose reaches all levels, from top management to every employee. Additionally, our business partners are required to share our dedication to and knowledge of ethical standards. OMV Petrom Compliance department was founded in 2008 with the objective of managing corporate ethics-related risks throughout the OMV Petrom Group, including businesses located outside of Romania. The Compliance department examines and evaluates the company's exposure to business ethical concerns, provides guidance on how to avoid and handle such risks, and develops procedures to safeguard the organization against those risks. Continuous monitoring and evaluation of the efficacy of controls is critical to managing an organization's risk exposure. OMV Petrom has a strict zero-tolerance policy for bribery, fraud, theft, and other types of corruption. Corruption is defined broadly as any departure from morality and responsibility that is damaging to a person's or public interest in favor of another person's, public or private, benefit. Bribery is a form of corruption and is defined as the promise, offering, requesting, or receiving directly or indirectly, for oneself or another, of money or other undue benefits in exchange for the performance, nonperformance, haste, or delay of an act that involves service duties or for the performance of an act contrary to such duties. For our activities, community grievance mechanisms are in place, along with data protection management, public advocacy, and tax transparency

    2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

    Optional comment
    Code of Business ethics available for all employees, as a Corporate Directive

    Prevention

    3. Who receives training on anti-corruption and integrity?

    Optional comment
    E-learning Business ethics mandatory every 2 year for all whitecollar employees ► E-learning Competition law mandatory every 2 year for all employees in the most risk- exposed areas ► Direct Business ethics trainings (virtual or face-to-face) mandatory every 3 year for managers level 1-4 ► Direct Competition Law trainings (virtual or face-to-face) mandatory every 3 year for managers and employees in the most risk-exposed areas

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

    Optional comment
    Trainings in 2021: ► E-learning trainings on Business ethics: 4,100 participants ► E-learning trainings on Competition Law: 212 participants ► Virtual face-to-face trainings on Business ethics: 252 participants ► Virtual face-to-face trainings on Competition law: 84 participants

    4. Does the company monitor its anti-corruption compliance programme?

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    0
    n/a

    Confirmed during the current year, and related to this year

    0
    n/a
    Optional comment
    Public legal cases: zero public cases involving corruption brought against the organization or its employees during the reporting period. However, there are 2 legal actions pending with regard to competition law matters in subsidiaries in Moldova and Bulgaria

    6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

    7. Does your company engage in Collective Action against corruption?

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

    In 2021, we worked specifically on: ► enhancing the training and awareness activities in OMV Petrom and the subsidiaries outside Romania with a focus on whistleblowing ► starting the development of a new compliance tool accessible for OMV Petrom employees from their mobile phones ► enhancing third party risk mitigation by closer scrutiny of 1st tier subcontractors The Integrity Platform was expanded in view of new legal requirement and can be used to make reports of perceived violations. Maintaining a direct and permanent dialogue with the employees of OMV Petrom subsidiaries is an important objective of the awareness and training activity for the Compliance team. In this regard, meetings were held, both face to face and online with the management and employees of the three OMV Petrom subsidiaries