E3 Water and marine resources

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Policies related to water and marine resources:

Gunvor’s approach to water is governed within its Group HSEC Policy (Health, Safety, Environment, Human Rights and Communities), which sets out the company’s overarching environmental expectations applicable to all operational sites. Under the policy’s Environmental Expectations, Gunvor’s sites are required to establish and implement environmental management systems focused on continual improvement, set targets and objectives for environmental performance, specifically including resource efficiency in relation to energy and water, and ensure compliance with all applicable permits, laws and regulations.

Water governance at the operational level is therefore embedded within Gunvor’s broader environmental management framework.

Gunvor commits to reporting its environmental performance on an annual basis, of which water consumption forms a part. We refer to this policy for further information.

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Actions and resources in relation to water:

Gunvor monitors water stress exposure across its operational footprint and takes steps to ensure that abstraction practices do not materially impact water availability in the regions where it operates. Site-level water management is conducted in accordance with applicable environmental permits and local regulations, with each site required to operate within its permitted discharge limits and volumes.

Gunvor’s refinery operations are inherently water-intensive, with freshwater playing an essential role across multiple process stages, including feedstock pretreatment, steam generation, heat exchange, and the cooling of processed products. Recognising this dependency, Gunvor’s sites implement operational measures to manage water use efficiently, including closed-loop cooling systems where technically feasible and ongoing monitoring of water intake and discharge volumes.

Based on current assessments, the company ensures that water abstraction practices at each site remain within the bounds of applicable regulatory permits and do not materially compromise local water availability.

The site of Bilbao power plant (BBE), acquired in 2024, which uses saline port water for cooling purposes, has finalised the integration into Gunvor’s Group environmental reporting framework. Water and wastewater data for this facility are incorporated into monthly reporting cycles where quality assurance processes are established.

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Targets related to water and marine resources:

Following its materiality assessment, Gunvor has concluded that water consumption does not currently represent a material negative impact of a magnitude that would necessitate the setting of formal quantitative reduction targets at Group level. This conclusion is grounded in three factors: the nature of water sources utilised across Gunvor’s operations (principally non-potable and saline water for cooling purposes alongside freshwater for process use); demonstrated compliance with site-level abstraction and discharge permits at all reporting locations; and the absence of significant operational presence in areas classified as highly water-stressed under established risk assessment frameworks. Gunvor acknowledges that this position will be kept under active review.

Regarding marine resources, Gunvor’s operations do not involve the extraction, exploitation, or material disturbance of marine biological resources. The use of saline port water for cooling at BBE does not constitute use of marine resources beyond abstraction and return within permitted parameters, and this activity is not considered a material impact on marine ecosystems.

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Water consumption:

In 2025, Gunvor’s total water consumption across its consolidated operations was 2.8 million cubic metres (m³), compared to 2.5 million m³ in 2024 (restated). The year-on-year increase of approximately 14% is not indicative of a deterioration in water efficiency but rather reflects a normalisation of the full operating capacity at the Ingolstadt refinery (GRI), which had temporarily suppressed consumption below typical run-rate levels. On a like-for-like, normalised basis, water use across the portfolio has remained broadly stable.

In 2025, Gunvor’s total water discharge across its operations was 1.4 million m³, consistent with the volume discharged previous years. Water is primarily discharged to surface water bodies and municipal treatment systems in accordance with site-specific environmental permits.

Scope and boundary of reported data:

The figures above cover all Gunvor’s sites, including primary refinery, biofuel operations within its consolidated reporting boundary and the Bilbao power plant (BBE), acquired in 2024, which abstracts saline port water for once-through cooling purposes. As saline water abstraction presents a materially different environmental risk profile compared to freshwater withdrawal, BBE’s water data will be analysed separately.

Gunvor is working towards disclosing water withdrawals disaggregated by source type freshwater, brackish, and saline and by water-stress area classification in future reports, in line with the requirements of ESRS E3 and GRI 303.

All Gunvor sites – Wastewater consumption

0
200,000
400,000
600,000
800,000
1,000,000
1,200,000
1,400,000
1,600,000
1,800,000
2022
2023
2024
2025
GRI 700,121 713,788 795,107 706,015
GER 595,596 749,971 795,349 604,373
BBE N/A N/A N/A 12,732
GBH 90,431 74,916 73,184 62,843
GBB 28,300 28,828 24,764 32,659

All Gunvor sites – Freshwater consumption

0
500,000
1,000,000
1,500,000
2,000,000
2,500,000
3,000,000
2022
2023
2024
2025
GRI 1,508,587 1,357,991 1,702,855 1,963,806
GER 634,836 600,693 553,415 548,295
BBE N/A N/A N/A 36,754
GBH 114,484 101,653 118,688 161,580
GBB 104,364 112,697 96,704 101,795