Regulation Class Document Class

Directive Main Document

Regulation Title

Environmental Management

Topic
Environmental Management

Objective
To define responsibilities and requirements for Environmental Management throughout OMV Group.

Target Group
Line managers, HSSE managers, environmental experts, all employees

Scope of Effectiveness
OMV Aktiengesellschaft and all companies which are fully consolidated. In companies not fully consolidated,
where OMV Aktiengesellschaft has a controlling interest. All stock corporations are excluded with the result that
these regulations have to be separately enforced in these entities.

Responsible for Content: GTR-V Barbara Oberhauser 09.01.2012

Org. Unit First- Last Name Signature Date

Regulation Approver 1: GT-R Rod D. Ritchie 20.01.2012

Org. Unit First- Last Name Signature Date

Regulation Approver 2: G-T Gerald Kappes 20.01.2012

Org. Unit First- Last Name Signature Date

As approved by the Executive Board of: 02.02.2012

Date

Effective as of: 08.02.2012

Date

In the interests of simplicity and readability, the language of this statement is gender neutral to the extent possible. Where
applicable, the masculine includes the feminine. Print-out is only valid on the date printed. Check for the latest version in the
Regulations Platform. In case of conflict, the document in its Master Language must be applied.

HSSE-D-006 Master Language: English

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 Index of content
1. Introduction & Intended Purpose of Regulation ...............................................................3
2. Content of Regulation..........................................................................................................3
2.1. Leadership and Commitment.........................................................................................3
2.2. Organizational set up of Environmental Management ................................................4
2.2.1. Organization.....................................................................................................................4
2.2.2. Responsibilities................................................................................................................4
2.3. People, Competency and Behavior................................................................................5
2.4. General requirements for Environmental Management activities ..............................5
2.5. Links to other Business Processes .................................................................................7
2.6. General requirements for Environmental aspects........................................................8
3. Internal Reference Links ......................................................................................................9
4. External Reference Links ...................................................................................................10
5. Obsolete Regulations ........................................................................................................10
6. Certification Standards......................................................................................................10
7. Terms & Abbreviations......................................................................................................10
8. Keywords / Search Criteria................................................................................................10
9. Annexes ..............................................................................................................................10
10. Amendments from Previous Versions .............................................................................10

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1. Introduction & Intended Purpose of Regulation

This Environmental Management Directive defines the responsibilities and requirements for the
process of environmental management of OMV Group's operations, including acquisitions,
divestment and investment programs. This process will ensure cost effective management of
risks and liabilities related to environmental issues through the identification of potential
environmental impacts and control measures, setting key performance indicators, and
measuring and reporting against targets.

The objectives of this directive are to:

Provide a harmonized framework for integrated environmental management throughout

OMV Group operations;

Ensure appropriate management of environmental risks, potential liabilities and
environmental investments;

Support a precautionary approach to environmental challenges, undertake initiatives to
promote greater environmental responsibility and encourage the development as well as
the application of environmentally friendly technologies;

Ensure sustainable development in all business operations;

Define an auditable framework for environmental management across OMV Group;

Improve environmental performance across OMV Group.

This Environmental Management Directive provides the link between the high level principles
set out in the Corporate Sustainability:HSSE Policy, other Directives and in the commitment to
the UN Global Compact and the implementation of environmental management at the
operational level. For further details see also Corporate HSSE Standard Environmental
Management*.

Subsidiaries as well as Group functions are responsible for ensuring that systems and
procedures are in place to enable the requirements of this Environmental Management
Directive.

2. Content of Regulation

2.1. Leadership and Commitment

Environment is a key pillar of OMV Group’s sustainability approach and, thus, balanced with the
economic and social challenges in the sustainability strategy and related activities.
Environmental Management is an integrated part of OMV Group’s HSSE Management System,
as laid down in the HSSE Management System Directive. The environmental management is
following the Plan-Do-Check-Act approach as defined there. It covers the whole life-cycle of an
OMV Group activity, operation or product (e.g. due diligence/acquisition/investment,
planning/design, construction, operation/production, maintenance, transport, marketing,
abandonment/divestment, remediation, disposal).

The overlying minimum principles for environmental management within OMV Group are:

Selection of measures to prevent pollution will be based on the best available technology,
balancing the improvements in environmental performance over the life-cycle of the activity
or operation with the cost of implementation;

A precautionary approach will be taken; where there are threats of serious or irreversible
damage, lack of full scientific certainty shall not be used as a reason for postponing
measures to prevent environmental damage;

Control of impacts due to OMV Group's activities is the Group's responsibility;

Environmental damage shall as a priority be prevented at source;

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Impacts and risks are managed according to the Corporate HSSE Standard Risk
Management.

2.2. Organizational set up of Environmental Management

2.2.1. Organization
Line Management is responsible to provide sufficient organizational set up and resources at
Corporate and Operational level (e.g. Business Segment, sites/ventures) to ensure fulfillment of
the requirements laid down in this Directive. Roles and responsibilities have to be clearly
defined and documented.

The Environmental Management Department, as part of the Group’s Corporate HSSE

Department, assists in identifying and effectively managing environmental risks in all OMV
Group’s operations, it monitors international environmental trends and best practices, it
develops solutions for environmental challenges, it supports management of environmental
legal obligations and liabilities and it assists in reporting and investigating environmental
incidents.

At the Operational level, environmental functions are mainly part of the local HSSE
organization. In cases where no separate HSSE organization exists or for specific functions (e.g.
technical qualification in the field of hazardous goods or waste management, or appointed
officers for pollution or water protection, as might be requested by law) operational staff can be
entrusted as well.

To facilitate senior management involvement and strategic steering of environmental topics,

appropriate Committees can be established on Group, Business Segment or site/venture level,
like the Corporate Carbon Steering Committee and Divisional Carbon Management Teams.

Environmental expert networks should be established to enhance communication, knowledge

transfer and experience exchange between Corporate, Business Segments and sites/ventures,
under coordination of the respective Corporate function.

2.2.2. Responsibilities
The responsibilities in Environmental Management within OMV Group are summarized in the
table below.

Process steps EB LM HSSE Operat. GTS-V

BP HSSE1)

Establish environmental statement in OMV Group A C C C R

Sustainability:HSSE Policy
Establish OMV Group environmental strategy A C C C R
Establish subsidiaries/site/venture environmental A C R C
strategy
Identify legal and contractual requirements 2) A C R C
Identify environmental baseline, impacts, risks and A C R C
liabilities 3) and define measures/investments
Provide risk summary for incorporation into Due A C C R
Diligence reports
Define KPIs on Group level C C C A/R
Define KPIs on Operational level A C R C
Establish the Group's environmental objectives and A C C C R
targets
Establish subsidiary/site/venture environmental C A C R C
objectives and targets

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 Establish Environmental Management Plan A C R C
Develop Group environmental management A C C C R
directives and standards
Implement environmental management directives, A C R C
standards and develop specific procedures
Keep records and report on environmental issues I A C R C
Check the plausibility of the environmental reports C C C A/R
on Group level
Monitor and evaluate environmental performance, I C C C A/R
environmental target achievement and
environmental costs on Group level
Monitor and evaluate environmental performance I A C R C
as well as environmental costs and target
achievement on subsidiary/site/venture level
Monitor environmental legal compliance of A C R C
2)
operations/activities
Perform environmental audits and reviews A C R R

Legend:
EB = Executive Board; LM = Line Management; BP = Business Partner; GTS-V = Environmental
Management Department in Corporate HSSE
R = Responsible (for the doing); A = Accountable (ultimately answerable), C = Consult; I = Inform
1) depending on local organizational set up
2) strongly supported by Legal Departments
3) strongly supported by Controlling Departments

2.3. People, Competency and Behavior

High environmental awareness and competency beyond the HSSE function is crucial for the
appropriate implementation of the present environmental directive. For details see Corporate
HSSE Standard Awareness and Competency.

2.4. General requirements for Environmental Management activities

Establish environmental statement in Sustainability:HSSE Policy and Strategy

The Environmental Policy and Strategy are integrated part of the Sustainability:HSSE Policy and
Strategy (see also HSSE Management System Directive)

Identify Legal and Contractual Requirements

Line Management shall ensure the monitoring of existing and upcoming environmental
legislation. For each activity the correspondent legal requirements and environmental permit
conditions as well as contractual requirements (especially in case of
acquisitions/investments/divestments) must be identified and followed. Subsidiaries and
sites/ventures shall maintain an appropriate legal compliance register.

Identify Environmental Baseline, Impacts, Risks and Liabilities

A key element within environmental management is the identification of historical, existing and
potential environmental impacts associated with the current or planned operation. The
environmental aspects and impacts shall be managed during the whole lifecycle of operations.
Subsidiaries and sites/ventures shall maintain appropriate environmental aspect and impact
registers according to the Corporate HSSE Standard Environmental Management*.
Environmental performance shall be monitored by keeping records on emissions, discharges
and resource consumption according to legal and internal requirements. Environmental risk
management has to be performed according to the Enterprise-Wide Risk Management
Directive, Corporate HSSE Standard Risk Management, and the Corporate HSSE Standard
HSSE in Projects*. This shall include identification of potential environmental liability and their
monetary significance.

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 Where a project or new activity can significantly impact OMV Group performance (variation of
10% of a Group KPI) or targets, a copy of the risk assessment or Environmental Impact
Assessment (EIA) shall be provided to the Corporate Environmental Management Department
for review. Aspects to be considered when screening the significance of the projects / activities
include:

Energy and/or natural resources consumption;

Level of pollutant emissions and/or discharges;

Quantities of dangerous substances;

Sensitive environmental areas;

Changes in environmental performance.

Identified risks have to be managed effectively and mitigation and control measures have to be
defined adequately to the risk level. Based on the outcome of the environmental assessment,
measures to manage identified risks shall be integrated into operation and maintenance
instructions, project plans, Due Diligence reports or Environmental Management Plans.

Define Key Performance Indicators

Key performance indicators (KPIs) shall be identified based on the results of the environmental
assessment to reflect:

Actual and potential impacts associated with the activity (short and long term);

External and internal monitoring and reporting requirements;

Business strategy;

Stakeholder expectations;

Existing or historical site contamination.

Establish Environmental Objectives, Targets and Programs

Relevant objectives and targets shall be set on different levels of the organization (e.g. BSC,
MbO). The objectives and targets shall take account of:

Business strategy and functional HSSE strategy and targets;

Relevance to environmental KPIs;

Commitment to continuous improvement and other expectations set out in the
Sustainability:HSSE Policy;

Business planning process.
Actions, responsibilities and schedules shall be laid down in Environmental Management
Programs and tracked accordingly.

Develop Environmental Directive, Standards and Procedures

Internal regulations shall be in place to define processes, criteria and minimum standards for
environmental relevant business activities, to measure, monitor and evaluate environmental
performance, to enhance continuous improvement and to ensure legal compliance.

Keep records, report, monitor and benchmark environmental performance

As a basis for the tracking of strategic environmental targets and evaluation of legal compliance
the monitoring includes a periodic review of environmental KPIs, including current values as
well as forecast data for certain KPIs, based on current operations, mid-term planning of
operations/production as well as new projects and their impact on these KPIs.
Appropriate records shall be kept by subsidiaries/sites/ventures, results reported within the
respective organization and data consolidated and communicated according to external or
internal requirements. These records shall include

Emissions and discharges;

Environmental incidents;

Environmental baseline assessment of new/acquired sites;

Environment aspect and impact register;

Environmental complaints and external requests;

Performance against objectives and targets;

Status and validity of environmental permits and/or conformity programs.

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 Environmental performance shall be benchmarked internally and against specific industry peer
groups as well, taking into account OMV Group strategy and targets. Results from external
audits and rating companies shall be evaluated.

Perform Environmental Audits and Reviews

Environmental audits and reviews shall be done as defined in the HSSE Management System
Directive and respective internal regulations (see also Corporate HSSE Standard HSSE MS
Audit*).

They shall include aspects regarding management system, environmental performance and
compliance and shall cover all life-cycle steps of an operation/activity including due diligence
and abandonment/remediation. Based on the results, environmental strategic plans, programs,
KPIs will be established.

2.5. Links to other Business Processes

Environmental management is strongly linked to a number of business processes, especially:

Planning and Budgeting – environmental related projects and activities, e.g. based on
Environmental Targets or Environmental Management Plans, are part of Mid-Term-
Planning;

Engineering and Project Management – environmental requirements are identified and
complied with during the whole life-cycle of a project from the early design phase to
construction/implementation and start-up/roll-out;

Investment – environmental performance, impacts and risks are considered as part of
requirements for the acquisition, sale and restructuring of assets within OMV Group as
established in the corresponding internal regulations;

Product Development – technical assessment of all new products shall include an
assessment of the environmental impacts associated with the product’s life-cycle
(development, manufacture, transport, retail, use, disposal), giving equal priority to
technical and economic considerations;

Procurement-– environmental relevant supplies and services are selected upon technical
criteria, which shall be balanced with environmental and economic considerations. Supplier
audits shall include a review of the environmental impacts associated with product
manufacture;

Contractor Management - Contractors are required to work in accordance with all
environmental requirements. Contractor selection shall include an assessment of the
contractor’s environmental management systems and environmental performance.
Appropriate measures shall be agreed on as part of the contract to ensure application of
appropriate environmental standards;

Operation and Maintenance activities – sufficient procedures are in place to monitor
environmental performance and to reduce environmental impact and avoid environmental
damage;

Abandonment, decommissioning and remediation – environmental aspects are monitored
and impacts mitigated after operations have ended and the site is left;

Controlling –environmental costs are assessed in order to provide sound data basis for
management decisions and to meet internal and external reporting requirements;

Joint Venture Management – in Joint Ventures where OMV Group holds a minority share
Line Managers and Environmental Managers should work within Joint Venture
organizations and other partners to move towards achieving OMV Group’s environmental
standards through appropriate input in setting up of the work programs and budget
planning.

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2.6. General requirements for Environmental aspects

Energy use and energy efficiency

For all energy-producing and -consuming systems a systematic analysis of energy efficiency
improvements and cost reduction opportunities shall include a hierarchical examination of
opportunities to:

Monitor consumption and improve monitoring equipment;

Reduce loads on the energy system;

Reduce losses in energy distribution and energy consumption;

Improve energy conversion efficiency;

Use lower-carbon fuels (fuel switch) and alternative energy sources.

Such analyses have to consider cost benefit relations.

Climate change and carbon management

Improvements of energy efficiency and reduction of greenhouse gas emissions (GHG), e.g.
from flaring and venting, are a key consideration in current business operations at all
organizational levels as well as in new projects, operations and acquisitions as well as in the
development of products and services.
The following elements shall be in place for an effective carbon management:

Systematic monitoring of direct and indirect GHG emissions;

Monitoring of energy consumption by appropriate inventories;

Systematic screening of GHG reduction opportunities;

Systematic assessment of climate change related risks.

Emissions to the atmosphere

Emissions to the atmosphere both from point sources as well as fugitive emissions shall be
prevented or minimized. Therefore, air emissions shall be monitored or estimated and
controlled systematically. Appropriate monitoring systems or estimation models have to be in
place.

Water management and discharges

Water conservation shall be considered in environmental management plans, with the objective
to reduce water consumption and thereby reduce water treatment before and after use, and
wastewater discharges. It shall be avoided to consume drinking water for industrial purposes,
and impact on water supply for local community needs to be assessed.
The generation and discharge of wastewater of any type should be reduced and managed
through a combination of:

Efficient use of water;

Recurrent analysis of process/treatment techniques and offering of alternatives to reduce
wastewater volume and load of pollutants;

Conservation of fresh water in fresh water constraint areas, by reusing, reducing and/or
recycling water.

Waste Management
All sites/ventures shall develop and implement a Waste Management Plan (onshore) and / or
Discharge Management Plan (offshore) which addresses all waste categories.
The following hierarchy shall be applied for waste control:

Avoid;

Reduce;

Re-use;

Recycle;

Dispose in controlled legitimate manner.
Waste streams shall be reviewed regularly to identify measures for improvement and cost
effectiveness (‘move up the waste hierarchy’). All waste shall be processed and disposed off via
licensed facilities or reputable licensed contractors.

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 Storage, handling and transport of hazardous substances/materials
In activities or projects involving hazardous substances/materials, prevention and control of
releases and of accidents shall be managed with appropriate procedures and management
plans. Hazardous substances/materials shall be transported by qualified and authorized services
using appropriate equipment.

Soil and groundwater protection

To prevent contamination of soil and groundwater, effective procedures shall be in place to
avoid the release of materials with adverse environmental effect. Irrespective of the cause, soil
and groundwater contamination shall be managed to reduce and minimize the risk to human
health and ecological receptors.

Any remediation of contaminated sites shall be approached individually considering the

situation at place, legal procedures, studies/investigation on the quality and quantity of
pollutants, land owner concerns, possible alternatives for remediation technologies as well as
remediation costs.

Spills
According to business specific characteristics, appropriate spill prevention and control plans
must be in place. Spill prevention and control measures shall include at least:

Identification and analysis of facilities and activities with major risk for loss of containment
(such as spill of liquids and/or solids and emissions of gases) with adverse effect on the
environment;

Preventive maintenance to avoid leakages;

Emergency response and contingency plans;

Clean-up and remediation procedures.

Naturally occurring radioactive material (NORM)

Where NORMs are an issue, a NORM management program shall be developed and
appropriate handling procedures have to be established.

Noise and vibration

Where noise or vibrations from e.g. projects, facilities/operations or transport activities have
relevant impact on the environment, prevention or mitigation measures (technical elimination,
engineering or administrative control, protective equipment at recipient) shall be established
(preferably by application of best available technology at the source).

Biodiversity and nature protection

OMV Group business activities may cause direct and indirect impacts on biodiversity, which
shall be described and analyzed within the environmental assessment in context and
interrelation with all environmental risks and impacts. Depending on the results of the
assessment, a Biodiversity Action Plan shall be considered.
Where operations take place in protected areas and/or areas of high biodiversity value outside
protected areas, appropriate inventories of location and size of these areas must be in place, as
well as systematic reporting about impacts, biodiversity monitoring and management.

3. Internal Reference Links

Sustainability:HSSE Policy
Directive HSSE Management System
Directive Enterprise-Wide Risk Management (FINANCE 015) including the Manual Enterprise-
Wide Risk Management (September 30, 2004 or updated version)
Directive Mergers and Acquisitions (DEVELOP 002)
Directive Controlling of Investment in the OMV Group (CONTROL 005) and respective sections
of the Controlling Manual (August 2006 or updated version)
Corporate HSSE Standard Environmental Management*
Corporate HSSE Standard Environmental Management Accounting*
Corporate HSSE Recommendation Estimation of emissions and discharges*

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 Corporate HSSE Recommendation Direct GHG emissions monitoring and forecasting*
Corporate HSSE Recommendation Indirect GHG Emissions: Scope 3 Inventory*
Corporate HSSE Recommendation for Environmental and Social Impact Assessment*
Corporate HSSE Recommendation Waste Management*
Corporate HSSE Recommendation Water Management*
Corporate HSSE Recommendation Biodiversity Management*
Corporate HSSE Standard Awareness and Competency
Corporate HSSE Standard Group-wide HSSE Reporting and Consolidation
Corporate HSSE Standard HSSE Risk Management
Corporate HSSE Standard HSSE in Projects*
Corporate HSSE Recommendation Environmental Practices in Projects*

Note: All regulations marked with * above shall be in place no later than December 31, 2012.

4. External Reference Links

None

5. Obsolete Regulations

None

6. Certification Standards

None

7. Terms & Abbreviations

BSC Balanced Score Card

EIA Environmental Impact Assessment
GHG Greenhouse gas
HSSE Health, Safety, Security, Environment
KPI Key Performance Indicator
MBO Management by Objectives

8. Keywords / Search Criteria

Environmental management, environmental strategy, environmental impact assessment (EIA),

environmental performance, environmental key performance indicators, environmental aspects

9. Annexes

None

10. Amendments from Previous Versions

Date of Regulation
Changes to previous versions:
effectiveness: code:
22.10.2007 HSSE 003 New Version
Revised after Re-shaping of the Corporate
08.02.2012 HSSE-D-006
organization (only major changes are marked)

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