S3 Affected Communities

We have identified the following communities that may be subject to impacts listed below from most direct impact to indirect:

  • The communities living around our operated sites.
  • The communities living near the sites of our unoperated joint ventures.
  • Communities impacted by the extraction of oil, gas, metals and minerals, especially indigenous people in our supply chain.
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Policies

Relevant policies to manage material impacts for affected communities:

  • Code of Conduct and Ethics
  • Code of Conduct for Suppliers
  • Health, Safety, Environment, Human Rights and Communities Policy (“HSEC Policy”)

Currently, our HSEC policy does not refer to indigenous people’s rights. Over the next year, we are updating our HSEC framework to include dedicated guidelines that respect Indigenous rights and ensure that Indigenous peoples are recognised and supported.

For more information, and full text of the policies, please refer to the following link:

www.gunvorgroup.com/ethics/policies

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Engagement, Channels &
Remediation

Gunvor seeks to maintain open channels of communication with affected communities and to ensure that concerns can be raised, addressed, and remedied in a timely and transparent manner. Our approach to community engagement and access to remedy varies depending on the nature of the activity and our level of operational control, including across operated assets, joint ventures, and trading activities.

Assets

In our assets, communities have several channels of communication with the sites. Local residents have a direct line to the refineries to raise complaints if they observe an issue. The refinery reacts immediately to understand the root of the issue, severity and ensure remediation. The complaints are almost exclusively related to smell and noise, with peaks at certain times of the year. All complaints are monitored and followed-up on until resolution.

Effectiveness of engagement and remedy is regularly reviewed with monthly KPIs indicating nature of complaints, solutions brought and follow-up.

JVs

Through human rights assessments of joint ventures, we ensure that communities can engage directly with the Company.

Trading

Understanding the perspectives of communities in our trading supply chain requires a more indirect approach. In 2024, we have engaged suppliers of Palm Oil Mill Effluent and metals to understand how they are managing human rights due diligence. This assessment includes community focus. Communities’ perspectives are also gathered through desktop research at KYC step, including recurring controversies. We pay specific attention to potential impacts on indigenous people and how our counterparties are managing potential impacts.

Speak-up

Gunvor maintains “Speak Up,” an anonymous whistleblowing channel accessible to all internal and external stakeholders. While designed primarily for internal use, this publicly available platform guarantees strict confidentiality and protection against retaliation. For further details, please refer to G1.

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Actions & Resources

The nature and severity of Gunvor’s impacts on affected communities can vary significantly depending on the type and location of our operations.

Assets

In the context of our refining assets (GRI & GER), some of the most direct and commonly experienced impacts involve odour (smell) emissions and noise pollution. These disturbances may fluctuate in frequency and intensity based on the type of industrial activities taking place at any given time—such as maintenance shutdowns and flaring events.

To ensure these impacts are identified and managed appropriately, we operate robust monitoring systems at both the asset level and Group level. Each refinery is equipped with environmental monitoring equipment that tracks noise levels, volatile organic compound (VOC) emissions, and other relevant indicators in real time or through regular sampling. In parallel, site-specific community feedback mechanisms, such as complaint hotlines and liaison, help us identify unreported or emerging concerns directly from local residents.

All refining sites are subject to regular audits, both internal (led by the HSEQ and sustainability teams) and external (by local authorities, certification bodies, or independent auditors). These reviews assess compliance with regulatory thresholds, the effectiveness of mitigation measures (e.g., sound barriers, enclosed systems, flare gas recovery), and the adequacy of community communication protocols.

While impacts such as odour and noise are typically non-hazardous, we recognize that repeated or unmanaged exposure can lead to a decline in community well-being, perceived quality of life, and trust in industrial operators. As such, we are committed to ongoing efforts to minimize nuisance factors and strengthen community dialogue at the local level, in line with our broader HSEC objectives.

The most severe and numerous impacts arise further up the supply chain, with impacts at the extraction level. Our 2023 human rights risk mapping highlighted higher risks and impacts in the metals and minerals and oil and gas upstream value chains.

JVs

We conduct human rights assessments of all our assets, including our joint ventures, as part of our commitments to the banks. These assessments are audited.

In the human rights assessment, PGL recognized local communities as an important rightsholder group and gave due consideration to the safety and well-being of communities surrounding its operations. The actions planned in collaboration with Gunvor reflect PGL’s commitment to addressing identified impacts, fostering a culture of continuous improvement, and embedding respect for human rights across its operations, business relationships and affected communities.

As of 8 Dec 2025, Gunvor has divested its stake in PTP and is no longer involved in its operations or governance. In 2023, potential impact on communities were identified regarding the initial compensation process at the construction of the PTP pipeline. These concerns were raised at PTP’s board, who had been working with local authorities to review compensation processes, which was granted early 2024. For more information, please refer to our 2023 Sustainability Report.

Trading

Controls are embedded within the KYC processes. This allows us to allocate a certain level of risks to the counterparties we trade with. All counterparties go through a KYC process, which includes human rights screenings. When a specific risk or impact is identified, the case is escalated to the sustainability team to advise on further steps. This may mean further engagement with the counterparty, insertion of specific clauses in the contracts and in some cases, where the risk or impact is too high and is not adequately mitigated, refraining from engaging in commercial activity with the counterparty.

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Targets

Gunvor has not yet formalised specific targets related to affected communities. We are currently working with our joint venture partners and value chain participants to define appropriate targets and associated metrics to strengthen our approach to managing impacts on affected communities.