FINANCIAL STATEMENTS  
on the date and for the financial year ended  
December 31st, 2024  
prepared in accordance with the accounting regulations complying with  
the International Financial Reporting Standards  
approved by the Ministry of Finance Order no.2844/2016  
1
I.  
STATEMENT OF THE FINANCIAL STANDING ON DECEMBER 31, 2024  
- RON-  
December 31st,  
2023  
December 31,  
2024  
Name  
Note:  
ASSETS  
Intangible assets  
Tangible assets  
Intangible assets  
Financial Assets  
5
6
664,780,731  
670,831,075  
5,559,573  
2,522,803  
(862,397)  
3,037,998  
535,374  
7
Deferred corporate tax -related receivables  
Total non-current assets  
Current assets  
14  
2,876,342  
671,230,445  
678,913,451  
Inventories  
8
9
6,015,541  
39,442,129  
136,176,830  
687,107  
6,519,564  
52,981,332  
107,742,173  
697,600  
Trade receivables and other receivables  
Cash and cash equivalents  
Prepaid expenses  
10  
Total current assets  
TOTAL ASSETS  
182,321,607  
853,552,052  
167,940,669  
846,854,120  
EQUITY AND LIABILITIES  
Equities  
Subscribed and paid-up share capital  
Legal reserves  
11  
11  
11  
11  
11  
11  
28,569,842  
5,713,968  
28,569,842  
5,713,968  
Revaluation reserves  
Other reserves  
43,539,329  
558,422,603  
45,124,461  
49,323,047  
730,693,250  
49,838,300  
547,585,477  
36,970,805  
61,616,539  
730,294,931  
Retained earnings  
Result of the year  
Total equity  
Long-term liabilities  
Long-term liabilities to employees  
Other long-term liabilities  
Deferred Tax Liabilities  
Total long-term liabilities  
Current liabilities  
12  
12  
14  
30,236,672  
2,423,254  
(862,397)  
32,659,926  
25,764,827  
2,792,606  
901,503  
29,458,936  
Trade liabilities  
12  
12  
12  
12  
13  
26,574,075  
(862,397)  
33,091,805  
1,807,695  
Current Corporate Tax  
Other liabilities  
33,027,370  
14,276,429  
16,321,002  
90,198,876  
122,858,802  
853,552,052  
28,764,158  
14,143,449  
9,293,146  
Liabilities to employees  
Short-term provisions  
Total current liabilities  
Total liabilities  
87,100,253  
116,559,189  
846,854,120  
TOTAL EQUITIES AND LIABILITIES  
These financial statements, from page 2 to page 64, have been authorized for release by the  
company’s management on March 25th, 2025.  
Director General,  
Eng. Dorin Tudora  
Economic Director,  
Econ. Sanda Toader  
The attached notes, from 1 to 25, are an integral part of these financial statements.  
3
 
II.  
STATEMENT OF PROFIT OR LOSS AND OTHER ELEMENTS OF THE GLOBAL  
RESULT FOR THE FINANCIAL YEAR ENDED DECEMBER 31st, 2024  
- RON-  
December 31st,  
2023  
485,113,609  
December 31,  
2024  
Name  
Note:  
Revenues from contracts  
533,618,409  
Earnings from disposal of assets  
Other revenues  
-
72,663,354  
606,281,763  
6,144,917  
612,108  
55,208,434  
540,934,151  
6,543,246  
Total Operating revenues  
Expenditure on inventories  
16  
Expenses with energy and water  
Personnel expenses  
20,915,838  
210,186,200  
18,596,747  
194,394,992  
Value adjustments on fixed assets, less  
adjustments related to rights of use resulted from  
leasing contracts  
79,156,049  
61,484,586  
Value adjustments for rights of use resulted from  
leasing contracts  
2,140,874  
2,051,485  
Value adjustments on current assets  
Expenses with external services  
Loss from disposal of assets  
Provisions adjustments  
7,640,692  
144,041,293  
91,590  
(239,459)  
126,935,543  
-
12,192,689  
2,446,008  
Other expenses  
Total Operating Expenses  
Operating Profit  
74,286,024  
556,796,166  
49,485,597  
6,384,256  
62,357,840  
474,570,988  
66,363,163  
6,689,934  
17  
Financial Revenues  
Interests’ expenses related to leasing contracts  
237,637  
175,242  
Other financial expenses  
Financial Expenses  
93,964  
331,601  
83,799  
259,041  
Financial profit  
Profit before corporate tax  
Expenses with current corporate tax  
18  
14  
6,052,655  
55,538,252  
10,227,235  
6,430,893  
72,794,056  
10,586,561  
Expenses with (revenues coming from) deferred  
corporate tax  
(4,012,030)  
49,323,047  
1,229,473  
590,956  
61,616,539  
531,142  
PROFIT OF THE YEAR  
Actuarial earnings (Loss) from discounted benefits  
granted upon retirement  
Surplus from revaluation of the tangible assets  
Other elements of the equities - retained earnings  
-
35,055,317  
-
755,268  
Total other global result elements that will not  
be subsequently reclassified as profit or loss  
1,984,741  
35,586,459  
Net increase of the modernization quota reserve  
Total other global result elements that will not  
be subsequently reclassified as profit or loss  
TOTAL OTHER ELEMENTS OF THE GLOBAL  
RESULT  
7,844,065  
6,869,587  
7,844,065  
6,869,587  
9,828,806  
42,456,046  
TOTAL GLOBAL RESULT  
Result per share  
59,151,853  
5.70  
104,072,585  
7.12  
These financial statements, from page 2 to page 65, have been authorized for release by the  
company’s management on March 25th, 2025.  
Director General,  
Eng. Dorin Tudora  
Economic Director,  
Econ. Sanda Toader  
The attached notes, from 1 to 25, are an integral part of these financial statements.  
4
 
III.  
STATEMENT OF CHANGES IN SHAREHOLDERS EQUITY ON DECEMBER 31st,  
2024  
- RON-  
Year’s  
profit or  
loss  
Share  
capital  
Legal  
reserves  
Revaluation  
reserves  
Other  
reserves  
Retained  
earnings  
Name  
Total Equities  
Balance on January  
1st, 2024  
28,569,842 5,713,968  
49,838,300 547,585,477 36,970,805  
61,616,539  
49,323,047  
730,294,931  
49,323,047  
1,229,473  
-
Net result for the year  
-
-
-
-
-
1,229,473  
6,298,971  
Actuarial gain of the  
period  
Surplus from  
revaluation  
-
-
(6,298,971)  
-
-
-
-
Other elements of the  
equities - retained  
earnings  
Allocation of profit  
provided by law -  
exemption of  
reinvested profits  
Net increase of the  
modernization quota  
reserve  
-
-
-
-
-
2,993,062  
7,844,065  
755,268  
732,340  
-
755,268  
-
-
-
(3,725,402)  
-
-
-
7,844,065  
Total other global  
result elements  
-
-
(6,298,971)  
(6,298,971)  
10,837,127  
10,837,127  
9,016,052  
9,016,052  
(3,725,402)  
45,597,645  
9,828,806  
59,151,853  
(58,753,534)  
Total global revenues  
related to the period  
Dividends due to  
shareholders  
-
-
(862,397) (57,891,137)  
Total transactions  
with the owners  
directly recognized in  
equities  
(862,397) (57,891,137)  
(58,753,534)  
730,693,250  
Balance on December  
31st, 2024  
28,569,842 5,713,968  
43,539,329 558,422,603 45,124,461  
49,323,047  
5
 
STATEMENT OF THE CHANGES IN EQUITIES ON DECEMBER 31st, 2023  
- RON-  
Total  
Equities  
Share  
capital  
Legal  
reserves  
Revaluation  
reserves  
Other  
reserves  
Retained  
earnings  
Year’s profit  
Name  
or loss  
Balance on January  
1st, 2023  
Net result for the  
year  
28,569,842  
5,713,968  
17,101,648  
533,897,764  
37,149,214  
61,663,616  
61,616,539  
684,096,052  
-
-
-
-
-
61,616,539  
Actuarial gain of the  
period  
531,142  
531,142  
Surplus from  
revaluation of the  
tangible assets  
Surplus from  
33,599,049  
(862,397)  
1,456,268  
-
35,055,317  
-
-
-
-
-
862,397  
-
revaluation  
Allocation of profit  
provided by law -  
exemption of  
-
3,725,402  
(572,707)  
(3,152,695)  
-
reinvested profit  
Net increase of the  
modernization quota  
reserve  
Total other global  
result elements  
Total global  
revenues related to  
the period  
Dividends due to  
shareholders  
-
-
-
-
-
-
-
32,736,652  
32,736,652  
6,869,587  
12,051,257  
12,051,257  
-
820,832  
820,832  
(999,241)  
-
(3,152,695)  
58,463,844  
6,869,587  
42,456,046  
104,072,585  
(58,510,921) (59,510,162)  
Prescribed  
distributions  
1,636,456  
1,636,456  
Total transactions  
with the owners  
directly recognized  
in equities  
1,636,456  
(999,241)  
(58,510,921) (57,873,706)  
Balance on  
December 31st,  
2023  
28,569,842  
5,713,968  
49,838,300  
547,585,477  
36,970,805  
61,616,539  
730,294,931  
The position „Other reserves” includes also the reserve representing the modernization quota in amount of 504,511,205  
RON on 31.12.2024, namely 496,667,140 RON on 01.01.2024. This reserve is constituted as per GD no.168/1998.  
The modernization quota is destined exclusively for the financing of the modernization works and development of the  
goods in public domain. The modernization quota is being collected at the extent of capitalization and proceeds of the  
production and is reflected in the reserves on account of the expenses. On a monthly basis is being written back to the  
modernization quota at the level of depreciation of the fixed assets financed out of this source. On 31.12.2024, the  
value of the reserve represents the modernization quota that is to be resumed to revenues at the level of the  
depreciation of fixed assets financed out of this source, of 467.574.762 RON, and the difference of 36,936,443 RON  
represents the reserve available destined to the modernization and development works related to the goods from public  
domain.  
These financial statements, from page 2 to page 65, have been authorized for release by the  
company’s management on March 25, 2025.  
Director General,  
Eng. Dorin Tudora  
Economic Director,  
Econ. Sanda Toader  
The attached notes, from 1 to 25, are an integral part of these financial statements.  
6
IV.  
CASH-FLOW STATEMENT OF THE YEAR ENDED DECEMBER 31, 2024  
(DIRECT METHOD)  
- RON-  
12 months, 2023  
(audited)  
12 months, 2024  
(audited)  
Name of the Item  
Cash flows from operating activities:  
Proceeds from services supply  
Proceeds from interests related to banking  
placements  
+
+
582,922,244  
520,121,301  
6,575,548  
6,330,776  
+
-
-
-
-
Other proceeds  
8,277,472  
153,460,415  
206,738,812  
64,996,587  
12,216,120  
54,102,021  
106,016,537  
4,251,235  
140,225,977  
192,207,154  
54,308,422  
10,776,280  
46,814,796  
86,615,455  
Payments to the suppliers of goods and services  
Payments to and on behalf of the employees  
VAT payments  
Corporate tax payments  
-
A
Other payments regarding the operating activities  
Net cash from operating activity  
Cash flows from investment activities:  
Proceeds from sale of tangible assets  
Proceeds from modernization quota  
Payments for tangible/intangible assets  
Net cash from investment activity  
Cash-flows from financing activities  
Paid dividends  
+
+
-
11,087  
67,444,545  
85,402,577  
(17,946,945)  
620,592  
58,084,160  
104,205,104  
(45,500,352)  
B
-
-
-
56,893,975  
2,497,018  
243,943  
57,664,500  
3,195,528  
185,354  
Payments on leasing debt account  
Interest payments  
C
(59,634,936)  
(61,045,382)  
Net cash from financing activities  
Net increase of the cash and cash  
equivalents=A+B+C=D2-D1  
28,434,656  
(19,930,279)  
Cash and cash equivalents at the beginning  
of the period  
D1  
D2  
107,742,173  
136,176,829  
127,672,452  
107,742,173  
Cash and cash equivalents at the end of the  
period  
The cash balance and cash equivalents on 31.12.2024 is 26.4% higher compared to December  
31st, 2023 (136,176,829 RON compared to 107,742,173 RON), following the increase by 4.9  
mRON of the existing cash in bank accounts on 31.12.2024 and also the collection, before  
maturity, of the equivalent value of several transport services delivered in the month of December  
2024.  
Of the total cash in balance on 31.12.2024, the party related to the modernization quota amounts  
to 36.936.443 RON.  
The effects of the three activity areas (operation, investment and financing) over the cash in the  
12-month period of 2024 reveal the following:  
- the operating activity has triggered a cash-flow in the amount of 106,016,537 RON;  
- the investment activity ended with a negative cash-flow in the amount of 17,946,945 RON;  
- the financing activity has diminished the total cash flow by 59,634,936 RON  
The value of net the cash-flow from the operating activity has increased by 19.4% YoY, due to an  
increase in the proceeds from transport services.  
7
 
As compared to the previous year, the net cash from the investment activity (cash-flow deficit)  
increased by 27.6 mRON. The deficit decrease has been determined by a volume of payments  
of assets less than that registered in the same period of the year 2023.  
The net cash from the financing activity in both periods 2024 and 2023 registers negative amounts  
determined by the payment of dividends to the shareholders and the amounts related to leasing.  
These financial statements, from page 2 to page 64, have been authorized for release by the  
company’s management on March 25, 2025.  
Director General,  
Eng. Dorin Tudora  
Economic Director,  
Econ. Sanda Toader  
The attached notes, from 1 to 25, are an integral part of these financial statements.  
8
V.  
EXPLANATORY NOTES TO THE FINANCIAL STATEMENTS ON DECEMBER 31, 2024  
1. Business Description and General Information  
The company “CONPET” S.A. (“The Company”) is a joint-stock company, with a unitary system  
administration, as per Law no. 31/1990 on the companies, republished, subsequent amendments,  
registered at the Prahova Trade Registry under no. J199100006291 and the Financial  
Supervisory Authority by the registration certificate no. 7227/1997.  
The registered offices is in Ploiesti Municipality, no. 1-3, Anul 1848 Street, Prahova County.  
CONPET S.A. is the concessionaire of the operating activity of the National Transport System of  
crude oil, rich gas, condensate and ethane quality acquired in 2002, by conclusion with the  
National Agency for Mineral Resources (NAMR), the competent authority representing the State  
interests in the oil resources domain, of the Oil Concession Agreement, agreement approved by  
GD no.793/25.07.2002.  
The company’s shares are being traded on the Bucharest Stock Exchange (BVB) market, under  
“COTE” issuing symbol, having as unique identifier at global level for entities (Legal Entity  
Identifier - RON) 254900P00DXXOYGGAQ77.  
Currently, CONPET S.A. is included in 6 indices of the total of 10 of the Bucharest Stock  
Exchange, namely BET-TR, BET-XT, BET-XT-TR, BET-BK, BET- BET-XT and BET PLUS.  
Concurrently, CONPET(COTE) is included in the indices MSCI Frontier IMI and MSCI Romania  
IMI (Investable Market Indices).  
On December 31st, 2024, CONPET S.A. has a market capitalization of 652.7 mRON (131  
mEURO), ranking 34 in the “Top Issuers according to capitalization”.  
Company’s Set-up  
CONPET is set up based on GD no. 1213/20.11.1990 regarding the set-up of the joint stock  
commercial companies in the industry, pursuant to Law no.15/1990 regarding the reorganization  
of the public economic units as autonomous administrations and joint stock companies, by taking  
over all assets and liabilities of the former Crude Oil Pipeline Transport Enterprise (Rom.I.T.T.C.).  
The shareholder structure and number of voting rights at 31.12.2024, are:  
a) The Romanian State by the Ministry of Energy, holding 5,083,372 shares with voting  
rights, representing 58.72% of the share capital,  
b) legal persons, with 2,083,424 shares with voting rights representing 24.06% of the share  
capital, and  
c) natural persons, with 1,490,732 shares with voting rights representing 17.22% of the share  
capital.  
9
 
Company’s Mission  
CONPET mission is the operation of the National Transport System via Pipelines under safe and  
secure conditions, free access to the system’s available capacity to all the inquirers, authorized  
legal persons, under equal conditions, on a non-discriminatory and transparent basis.  
Other Information on the Company’s Business  
As per the Articles of Incorporation, the company’s core business is the transport of crude oil, rich  
gas, ethane and condensate via pipelines aiming at supplying the refineries with crude oil and  
derivatives out of domestic production, as well as with imported crude oil (NACE code 4950-  
“transports via pipelines”).  
CONPET supplies transport services for its clients both via the National Transport System  
concessioned based on the Oil Concession Agreement of the National Transport System of Crude  
Oil, Rich Gas, Condensate and Ethane via pipelines, as well as by rail, from the loading ramps to  
the refineries, for the oil areas not connected to the major transport pipelines.  
The crude oil National Transport System represents the ensemble of the major interconnected  
pipelines ensuring the collection of the oil extracted from the exploitation areas or of the imported,  
from the delivery sites to the processing units.  
CONPET, as Concessionaire of the crude oil National Transport System, entitles as a common  
carrier and the obligation to provide, as per the legal provisions, free access to the system’s  
available capacity to all the inquirers, authorized legal persons, under equal conditions, on a non-  
discriminatory and transparent basis.  
The National Transport System of crude oil is part of the public domain of the Romanian State  
and is under the administration of the National Regulatory Authority in the Mining, Petroleum and  
Geological Storage of Carbon Dioxide (as per the provisions of the Oil Law). It comprises a  
pipeline system of approximately 3,800 km, with an overall nominal transport capacity of  
approximately 27.5 million tons annually, operationally reduced capacity to approximately 18.7  
million tons/year.  
The Legal Environment  
The activities in the oil sector, where the crude oil transport activity is included, are regulated by  
the Oil Law no.238/2004.  
The National Regulatory Authority in the Mining, Petroleum and Geological Storage of Carbon  
Dioxide (Ro. ANRMPSG) represents the interests of the State in oil resources domain and is the  
competent authority authorized to apply the dispositions of Law 238/2004. As per the Oil Law,  
ANRMPSG entitles as Concession Provider of the goods belonging to the public domain,  
concessioned to the operators acting in the oil industry.  
The main responsibilities of ANRMPSG are the following:  
- negotiates and concludes, on State’s behalf, oil agreements;  
- awards mining concession licenses and exploitation permits;  
- issues regulatory acts, norms, instructions, orders and regulations;  
- controls the compliance of the holders of the concession agreements with the concession  
licenses and exploitation permits conditions;  
- manages the Crude Oil and Natural Gas National Pipeline Transport Systems and regulates  
the exploitation activities thereof by system’s concession agreements concluded;  
-annuls the concession acts/administration acts;  
10  
- approves the tariffs and the frame-contract for the transport of crude oil, rich gas,  
condensate and ethane.  
The tariff for the supply of the transport service via the National Transport System of crude oil,  
rich gas, condensate and ethane  
The transport tariff stands for the exchange value of the transport service supplied by the holder  
of the oil concession, as common carrier for the transport, via the crude oil National Transport  
System, of an oil tone along the oil takeover sites from the domestic producers or import and the  
delivery sites to the refineries.  
The company practices different transport tariffs for the two subsystems belonging to the National  
Transport System, namely the subsystem for the transport of crude oil, rich gas, condensate and  
ethane from the domestic production and the subsystem for the transport of the imported crude  
oil. For the transport on the import subsystem are being settled tariffs per refineries and per  
transported quantities installments, being applied the bracket tariff model.  
The transport tariffs are established in accordance with the NAMR Order no.53/2008 for the  
approval of the Instructions on criteria, the methodology and procedure for establishing regulated  
tariffs for transport through the National Transportation System and are approved by the National  
Regulatory Authority for Mining, as follows, Oil tanker and Geological Storage of Carbon Dioxide  
as competent authority.  
The transport tariffs are determined by allocation of the transport service value to the crude oil  
quantities transported to the beneficiaries, by using a methodology based on the determination of  
the cost of service, defined as all the revenues required to cover the transport system operations,  
here included:  
- the operating cost, which contains material expenses, personnel expenses, pipeline  
maintenance expenses, expenses with energy, gas and water, costs related to the amortization  
of the fixed assets, royalties and other fees applicable to the carried, the expenses related to the  
provision of the pipeline guard, the amounts due to landowners, other expenses etc;  
- the modernization, development quota;  
- reasonable profit margin.  
2. Preparation Grounds  
(a) Declaration of Conformity  
These financial statements of the Company were drawn up based on accounting regulations in  
accordance with the International Financial Reporting Standards (“IFRS”) approved by the Order  
of  
the  
Ministry  
of  
Public  
Finances no.2844/2016.  
The IFRS standards represent the standards adopted according to the procedure provided by the  
Regulation (EU) no.1.803/2023 of the Commission from August 13, 2023 and include standards  
and interpretations approved by the Committee for Accounting International Standards (“IASB”),  
Accounting International Standards (“IAS”) and interpretations issued by the Committee for the  
Interpretation of the International Financial Reporting Standards (“IFRIC”).  
The financial statements prepared on the date and for the financial year ended December  
31, 2024, have been audited.  
11  
(b) Overview of the Financial Statements  
The financial statements are being presented in compliance with IAS,1 the Overview of the  
Financial Statements. The company has adopted an overview based on liquidity within the  
financial standing statement and an overview of the revenues and expenses according to the  
nature thereof within the statement of profit and loss and other elements of the global result,  
considering that these methods of presentation offer credible information and more relevant than  
the information presented based on other methods permitted by IAS 1.  
(c) Functional and Presentation Currency  
The financial statements are being presented in Romanian Lei (RON), as per the applicable  
accounting regulations, all amounts being rounded at the closest RON. The Romanian Leu (RON)  
is also the functional currency of the Company, as it is being defined by IAS,21, The effects of the  
variation of the currency.  
(d) Evaluation Grounds  
The financial statements are being prepared at historical cost, except for the tangible assets, other  
than the tangible assets in progress, which are being assessed at re-evaluated value, while the  
stocks are being assessed at the smallest value between the cost and the net achievable value.  
The accounting policies defined here-below have been consistently applied for all periods  
presented in these financial statements.  
(e) Business Continuity  
Financial statements have been prepared considering the business ongoing concern.  
(f) Accounting Estimates and Professional Reasoning  
The preparation of the financial statements pursuant to the International Financial Reporting  
Standards (“IFRS”) implies the use, by the Company, of estimates, professional reasoning and  
hypotheses affecting the reported value related to assets, liabilities, revenues and expenses.  
Estimates and assumptions are continuously evaluated and are based on historical experience  
and other factors, including predictions of future events that are believed to be reasonable under  
certain circumstances. The results of these estimates set the grounds for the professional  
reasonings regarding the accounting value of the assets and liabilities that cannot be obtained  
from other information sources. The actual results may be different from the estimates values.  
The significant reasoning used by the management for the application of the Company’s  
accounting policies and the main sources of uncertainty regarding the estimates have been the  
same with those applied to the financial statements related to 2023.  
(g) The Use of Estimates and Reasonings  
CONPET concluded, in 2002, a concession contract with NAMR according to which the Company  
is entitled to use public patrimony assets including the goods part of the crude oil National  
Transport System.  
The company CONPET operates as a joint stock company, as per the Law no.31/1990 on the  
companies, republished, with subsequent amendments, where most of the shares are being held  
by the State, being a public enterprise as per GEO. 109/2011 on the corporate governance of  
public enterprises. The services supplied by the company are not public services, as they are  
being supplied for the benefit of the clients’ legal persons, therefore they do not fall under the  
provisions of IFRIC 12, Services Concession Agreements.  
12  
3. Accounting Policies  
Hereinafter, there are described the significant accounting policies applied consistently by the  
company on preparation of its financial statements.  
(a) Transactions in Foreign Currency  
The transactions in foreign currency are being expressed in RON by application of the currency  
from the transaction date. The monetary assets and the debts expressed in foreign currency at  
the end of the period are being converted into RON at the currency valid on that date.  
The gains and losses generated by the differences in currency, realized or not realized, are being  
included in the profit and loss statement and other global result elements of the respective  
financial year.  
The foreign exchange of the main foreign currencies was:  
December 31,  
2024  
31.12.2023  
4.9746  
RON/EURO  
RON/USD  
RON/GBP  
4.9741  
4.7768  
5.9951  
4.4958  
5.7225  
(b) Accounting for the Effect of Hyperinflation  
In accordance with IAS 29 Financial reporting in hyperinflationary economies, the financial  
statements of an entity whose functional currency is the currency of a hyperinflationary economy  
shall be presented in the current unit balance-sheet date, i.e. non-monetary items are restated  
using a general price index from date of acquisition or contribution.  
Therefore, the values reported in terms of purchasing power on December 31, 2003, are treated  
as the basis for the carrying amounts of these financial statements.  
As the characteristics of the economic environment in Romania indicate the cessation of  
hyperinflation, starting January 1,2004, the Company no longer applies IAS 29.  
(c) Financial Instruments  
(i) Non-derivative financial assets  
The company initially recognizes the financial assets (receivables and deposits) on the date they  
have been initiated. All other financial assets here included the assets designated at fair value  
through profit or loss, are recognized initially on the trading date, when the Company becomes  
part of the contractual terms of the instrument.  
Any interest in the financial assets transferred that is created or retained by the Company is  
recognized separately, as asset or liability.  
The financial assets and liabilities are compensated and in the statement of financial standing the  
net value is presented exclusively when the Company has the legal right to offset the amounts  
and intends either to settle them on a net basis, or to realize the assets and settle the obligation  
simultaneously. On 31.12.2024, the company holds the following non-derivative financial assets:  
cash, cash equivalents and receivables.  
13  
Receivables  
Receivables are financial assets with fix payments or determinable that are not listed on an active  
market. The receivables contain trade receivables and other receivables.  
Cash and cash equivalents  
Cash and cash equivalents comprise the amounts recorded in cash accounts, current accounts,  
deposits redeemable at maturity and other cash equivalents. The liquid assets in foreign currency  
are reassessed at the exchange rate from the end of the period.  
(ii) Non-derivative financial Liabilities  
The Company recognizes in accountability the non-derivative financial liabilities on the trade date  
when the Company becomes party to the contractual terms of the instrument. The Company has  
the following non-derivative financial liabilities: guarantees retained within contractual  
transactions, trade liabilities and other liabilities.  
Trade Liabilities and Other Liabilities  
Liabilities to the suppliers and other liabilities include the exchange value of the products  
suppliers’ deliveries, works executed and the services supplied.  
Leasing-related liabilities  
As per IFRS 16, a contract is or contains a leasing contract in case that leasing contract confers the  
right to control the use of an asset identified for a certain period of time in exchange for a counter  
value.  
For such contracts, on the date of initiation of performance, a lessee must recognize an asset related  
to the right of use and a debt deriving from the leasing contract, debt generating interest.  
The company includes in the item “Other debts” also the debts deriving from the leasing contracts at  
the present value of the payments of leasing that are not paid at that date.  
(iii) Share capital - Common stocks  
The share capital consisting of common stocks (ordinary) is recorded at the value established  
based on the articles of association and addenda.  
The company recognizes the amendments to the share capital only after the accomplishment of  
the legal procedures provided by Law no.31/1990.  
(d) Tangible assets  
(i) Recognition and Assessment  
The tangible assets in the company’s patrimony are classified in the following category of assets  
of same kind and similar use:  
lands;  
constructions;  
operating oil product;  
technological equipment, measuring installations and devices, control and adjustment and  
means of transport;  
other tangible assets;  
14  
tangible assets in progress.  
The tangible assets are initially evaluated at cost by the Company. After initial recognition, the  
tangible assets are being revealed in the statement of the financial standing at the re-evaluated  
value, established based on an assessment report drafted by an authorized independent expert.  
The re-evaluations are made with fair regularity to make sure that the accounting value does not  
significantly differ from what would have been determined by using the fair value on the date of  
the reporting period.  
The tangible assets are being presented in the statement of the financial standing at the re-  
evaluated value, diminished by the cumulated depreciation and the loss from cumulated  
depreciation, except for advance payments and ongoing tangible assets appear at cost.  
The cost of an element of tangible assets is made up of the procurement price, here included the  
import fees or non-recoverable procurement fees, the transport expenses, manipulation,  
commissions, notary fees, expenses with permits acquirement and other non-recoverable  
expenses directly related to tangible assets and any other direct costs attributable to bringing the  
asset to the place and in operating conditions.  
The tangible assets in progress stand for the unfinished investments made in-house or under  
contract. They are being evaluated at the production or procurement cost, as the case may be.  
Tangible assets in progress pass to the category of tangible assets completed after the reception,  
putting into operation or commissioning thereof, as the case may be.  
The cost of a tangible asset built in-house is being determined by using the same principles as  
for a purchased asset.  
The Company does not recognize in the carrying amount of an element of tangible assets, the  
current repairs and usual maintenance, these costs are recognized as an expense when incurred.  
The costs of current maintenance are mainly the workmanship and expandable costs and may  
include the cost of small components. The purpose of these expenses is often described as being  
meant for the “repairs and maintenance “of the tangible assets’ element.  
(ii) Ulterior costs  
Replacements of several components of tangible assets  
The components of several elements of tangible assets may need the replacements at time  
regulated intervals. The company recognizes in the carrying amount of a tangible asset of an  
element of tangible assets, the cost of the replaced part of such an element, when that cost is  
borne by the entity, if the validation criteria are being met, for tangible assets.  
General Regular Inspections  
One condition for the continuation of the exploitation of an element of tangible asset is the  
performance of a general major regular inspection for detecting defects, notwithstanding whether  
they are being replaced or not, component parts of the respective assets. When a general regular  
inspection is being performed, the related cost is recognized in the accounting value of the  
tangible asset as a replacement, if the recognition criteria are satisfied.  
An element of tangible assets and any significant part initially recognized are derecognized in the  
moment of disposal or when are not being expected future economic benefits from its use or sale.  
If an element of tangible asset is re-assessed, all other assets in the class are part of, except for  
the situation when there is no active market for that asset. A class of intangible assets contains  
assets of the same nature and similar use, being operated by the entity. If the fair value of a  
tangible asset cannot be determined by reference to an active market, the asset value presented  
15  
in the balance sheet is its reassessed value on the date of the last reassessment, wherefrom are  
being decreased the cumulated value adjustments.  
When certain components of a tangible asset have a different useful life, they are being counted  
as distinct accounting elements (major components) of tangible assets.  
The statement related to the evolution of tangible assets of the Company during 2023 and 2022  
is detailed in note 5.  
Operating Oil Product  
The company recognizes in tangible assets the operating oil product evaluated in the balance  
sheet at determined cost from the re-evaluation performed as per GD no.26 from January  
22,1992, updated with inflation rate up to 31.12.2003, when the Romanian economy was  
inflationary. Since oil operating product of the Company physically renews at every pumping and  
that the component elements of this product do not bear, therefore, moral or qualitative  
depreciation, the operation oil product has not useful life, thus is not being depreciated. The  
company presents the operating oil product at the cost value, here included the effects of  
restatements registered in the previous years as per application of “IAS29”, Financial reporting in  
the hyper inflationary economies”.  
The Goods belonging to State Public Domain  
The company administers goods belonging to the State public domain, as grantor of the oil  
concession Agreement concluded with the National Agency for Mineral Resources, approved by  
GD no.793/2002 for a period of 30 years.  
Pursuant to the concession agreement, the objectives assumed by CONPET S.A. in relation to  
its activity are to ensure the operation of the national transport system via pipelines under  
maximum safety and economic efficiency conditions, to continuously improve the quality of  
services and to protect the environment.  
The goods resulting in following the investments provided by the rehabilitation, modernization and  
development programs performed out of own company’s financing sources are being capitalized  
and depreciate on the minimum duration related to the remaining lifespan of the respective asset  
or the remaining term of the concession agreement. The goods are to be included in the State’s  
public domain on the date of amortization of the investment by the company, namely on the expiry  
of the normal operation term or cease of the oil agreement, if applicable, as per the legal  
provisions.  
(iii) Reclassification as Investment Property  
When an asset is being held more for obtaining revenues out of rentals or for the increase of the  
capital value or both, rather than for being used in the production or supply of goods and services,  
for administrative purposes or to be sold during the normal carryout of the business, the asset is  
being transferred into investment property. Our company transfers an asset into the category of  
investment property if the latter generates cash flows that are independent of other assets largely  
held.  
The company does not hold investment property in balance on the date of preparation of these  
financial statements.  
16  
(iv) Intangible Assets held in view of Sale  
When there is an amendment brought to the use of an intangible asset, meaning that its  
accounting value is to be recovered mainly by a sale transaction and not by its continuous use,  
the company records the asset transfer from the tangible assets category to non-current assets  
held in view of sale.  
The non-current assets are classified as assets held for sale when:  
They are available for immediate sale;  
The company’s management is engaged in a sales plan;  
There are minimum chances that the sales plan incur significant changes or be withdrawn;  
An active program to find buyers is initiated;  
The assets group is being traded at a reasonable price as compared to the fair value;  
It is expected the sale be concluded within 12 months as of the date of assets classification  
as held for sale.  
Certain events or circumstances may extend the period for the completion of sales by more than  
one year. An extension of the period does not prevent an asset (or an asset group to be disposed)  
classified as being held in view of sale in case the delay is caused by events or circumstances  
outside the management control and there is enough proof that the company remains committed  
to the plan regarding the asset’s sale (or the group destined to disposal).  
The intangible assets (or asset group to be disposed) that are classified as being held in view of  
sale are being assessed by the company at the minimum between the accounting value and the  
fair value, less the sale costs.  
The intangible assets are not being depreciated whilst they are being classified in view of sale.  
The company does not have fixed assets in terms of selling, in balance on the date of preparation  
of these financial statements.  
(v) Assets related to the right of use of the assets taken by leasing  
On initiation of a contract, the company evaluates if that contract is or includes a leasing. A  
contract is or contains a leasing whether that contract confers the right to control the use of an  
asset identified for a certain period in exchange for a counter value.  
As per IFRS 16, Leasing Contracts, at the date of starting the performance, the company, as a  
lessee, recognizes an asset related to the right of use. The cost of the asset related to the right  
of use includes the value of the initial value of the debt deriving from the leasing contract, any  
leasing payment being performed at the date of initiation of performance or prior to third date,  
minus any leasing stimulants received or any direct initial cost borne by the company as lessee.  
The company re-evaluates whether a contract is or includes a leasing only provided that the terms  
and conditions of the contract are amended. The company determines the duration of a leasing  
contract as being the irrevocable period of a leasing contract, along with:  
(a) the periods covered by an option of extension of a leasing contract if the lessee has the  
reasonable confidence that it will exercise that option; and  
(b) the periods covered by an option of termination of the leasing contract if the lessee has  
reasonable confidence that it will exercise that option.  
In terms of financial standing, the assets related to the right of use are being included in the same  
element-item as the one where the assets support of the company are being presented.  
17  
(vi) Amortization  
The amortization is being calculated by using the straight-line method.  
The useful lifespans of the tangible assets are settled by a reception commission of the company,  
named by the decision of the Director General, made up of specialists in the economic and  
technical domains.  
The goods resulting from the investments related to the National Transport System via pipelines  
are depreciated along the minimum duration between the remaining lifespan of the respective  
assets or the remaining duration from the concession agreement.  
The assets related to the rights of use of the leased assets shall be depreciated on a straight-line  
basis over the term of the contract.  
The lifespans of the tangible assets are being periodically revised and, if applicable, on the date  
of value increase thereof, due to some expenses subsequently performed.  
(vii) Sale/ cessation of Intangible Assets  
The tangible assets that are scrapped or sold are being derecognized from the balance sheet  
together with the corresponding accumulated depreciation. Any profit or loss resulting from such  
an operation is included in current profit or loss.  
The gain or loss resulting from the derecognition of an element of tangible assets is being  
determined as the difference between the net proceeds out the net accounting value of the assets.  
(e) Intangible assets  
(i) Recognition and Assessment  
Intangible assets are initially recognized at cost. The cost of intangible assets includes expenses  
that are not directly attributable to the purchase of the respective elements. The expenditure  
related to the acquisition of software licenses is capitalized based on the costs of purchase and  
commissioning of the respective programs. The costs associated with the maintenance of the  
software programs are recognized as expenses upon occurrence.  
(ii) Subsequent Expenditure  
The subsequent expenses are capitalized only when they increase the future economic benefits  
embodied in the value of the assets to which they are intended. All other expenditure, including  
expenditure on the goodwill and the internally generated brands, are recognized in profit or loss  
when incurred.  
(iii) Depreciation  
Depreciation is recognized in profit or loss using the linear method for the useful life estimated for  
intangible assets other than goodwill, from the date they are available for use.  
(f) Depreciation of Assets  
The Non-Financial Assets  
The carrying value of the Company's assets that are not of a financial nature, other than deferred  
tax assets, are reviewed at each reporting date to identify the existence of depreciation indices.  
If such indices exist, it is being estimated the recoverable amount of the said assets.  
The recoverable amount of an asset or of a cash-generating unit is the maximum between its  
value and its fair value, less the costs to sell that asset or units. A cash-generating unit is the  
smallest identifiable group that generates cash and that independently of the other assets and  
18  
other groups of assets could generate cash flows. To determine the use value, the expected future  
cash flows are discounted using a discount rate before taxation, which reflects the current market  
conditions and the risks specific to the said asset.  
A depreciation loss is recognized when the carrying amount of the asset or cash-generating unit  
exceeds its estimated recoverable amount of the asset or the cash-generating unit.  
The depreciation losses recognized during the previous periods are being assessed at each  
reporting date to determine whether they have diminished or no longer exist. The depreciation  
loss is reversed if there has been a change in the estimates used to determine the recoverable  
amount.  
Given some internal and external factors, the Company assessed the netbook value registered  
at the balance sheet date for depreciable tangible assets, to evaluate the possibility of existence  
of a depreciation thereof, which could attract the record of an adjustment for depreciation.  
The Financial Assets  
The short-term receivables are not discounted. The recoverable amount of other assets is  
deemed the highest value between the fair value (less sale costs) and the use value. Estimating  
the value of use of an asset involves updating the estimated future cash flows using a pre-tax  
discount rate that reflects current market assessments regarding the time value of money and the  
risks specific to the asset.  
Depreciation losses on financial assets or a receivable recorded at the amortized cost is carried  
forward if there has been a change in the estimates used to determine the recoverable amount.  
(g) Stocks  
The main categories of stocks are consumables, spare parts, ongoing services and materials like  
inventory objects.  
The stocks are valued at the lower cost and net achievable value.  
The cost of stocks is based on the first in - first out (FIFO) principle and includes costs incurred  
for the purchase of inventories, production or processing costs and other costs incurred for  
bringing the inventories in the form and present location.  
The net achievable value is the estimated selling price to be obtained in the ordinary course of  
business, the less estimated costs of completion, when appropriate, and the estimated costs  
necessary to the sale.  
If applicable, there will be value adjustments applied for the obsolete stocks, with slow movement  
or damaged.  
(h) Dividends  
The dividends are recognized as a liability in the period in which their distribution is approved.  
The distribution of dividends is being performed subsequently to the approval of the annual  
financial statements.  
(i) Revaluation reserves  
The re-evaluations are performed with sufficient regularity so that the carrying amount does not  
differ substantially from that which would be determined by using the fair value at the balance  
sheet date.  
The difference between the value resulting after revaluation and the net accounting value of  
tangible assets is presented either according to its nature (appreciation/depreciation), either at  
the revaluation reserve as a distinct sub-element in “Equities” or in the "Profit and Loss" account.  
19  
If the revaluation result is an increase over the net accounting value, then, it is treated as follows:  
as an increase of the revaluation reserve presented within the total equity, if there was no previous  
decrease recognized as an expense related to that asset or as an income to compensate the  
expense with the decrease previously recognized at that asset.  
If the revaluation result is a decrease of the net accounting value, it is treated as an expense with  
the entire value of the depreciation when in the revaluation reserve is not recorded an amount on  
the asset (revaluation surplus) or as a decrease of the reserve from the revaluation by the  
minimum between the value of that reserve and the amount of the decrease and the possible  
difference remaining uncovered is recorded as an expense.  
The revaluation surplus included in the revaluation reserve is transferred to the retained result  
when this surplus represents an achieved gain. The gain is deemed realized as monthly  
amortization is being registered and when deleting from the records of the asset for which was  
established the revaluation reserve. No part of the revaluation reserve can be distributed, directly  
or indirectly, except for the case when it represents achieved earnings.  
A particularity occurs in case of the assets financed out of the modernization quota.  
Thus, in case the revaluation result shows an increase compared to the net accounting value,  
then it is being treated as follows:  
as an increase of the revaluation reserve, if there was no previous decrease written-back as  
an expense related to that asset,  
as an increase of the reserve established out of the modernization quota, up to the set-off of  
the decrease previously recognized and for which, simultaneously with the depreciation  
expense was also diminished the quota reserve by writing back to revenues.  
In case the result of revaluation is a decrease of the net accounting value, the latter will be treated  
as an expense when in the revaluation reserve is not registered an amount related to that asset  
(revaluation surplus) and the reserve formed out of the modernization quota is diminished  
simultaneously by writing back as revenues.  
Starting May 1, 2009, the statutory reserves from the revaluation of fixed assets, including the  
lands, performed after January 1, 2004, which are deducted from calculation of taxable profit  
through tax depreciation or from expenditure regarding the assigned and / or squashed assets,  
shall be taxed concurrently with the deduction of the fiscal depreciation, respectively when  
deducting from the administration of these fixed assets, as appropriate.  
The reserves made are taxable in the future, in case of change of reserve destination, reserve  
distribution towards the participants in any form, liquidation, division, merger of the taxpayer or of  
any other reason except for transfer, after May 1, 2009, of the reserves mentioned in the previous  
paragraph.  
(j) Legal reserves  
The legal reserves are constituted at a rate of 5% of gross statutory profit, as of the end of the  
year until the total legal reserves reach 20% of the nominal share capital (statutory) paid-up in  
compliance with the legal provisions. These reserves are deductible at the calculation of the  
corporate tax and are distributable exclusively upon liquidation of the Company. During 2024,  
there have not been distributed amounts to the legal reserves as they are currently constituted  
within the limit of the quota of 20% of the share capital, as per the provisions of Art.183, Para (1)  
and (2) of Companies Law no. 31/1990, subsequent amendments and completions.  
20  
(k) Other reserves  
The company constitutes profit reserves also at the expense of the modernization quota, based  
on the GD no.168/1998 on setting the quota for the expenses necessary for the development and  
modernization of crude oil and natural gas production, refining, transport and petroleum  
distribution, subsequent amendments, presented in GD’s no.768 of 7 September 2000 and 1116  
of 10th of October 2002 and according to the provisions of Law no.227/2015 on the Fiscal Code.  
The modernization quota is included in the transport tariffs and the level of the quota is approved  
by ANRMPSG once with the approval of the transport tariffs.  
In other reserves - the modernization quota, as sub-element of the accounts of equities are being  
included the amounts representing the plus resulting from the revaluation of the tangible assets  
financed out of modernization quota, until the clearing of the decrease previously acknowledged.  
(I) Affiliated parties  
The Parties are deemed related in case they are subject to control (or joint control) by the same  
entity or when an entity can directly or indirectly control or significantly influence the other party,  
either through ownership, contractual rights, family relationship or otherwise, as defined in IAS 24  
Presentation of Affiliated Party Disclosures.  
(m) The Benefits of the Employees  
(i) Benefits granted upon Retirement  
In the normal course of business, the Company makes payments to the Romanian State in the  
account of his employees, at the statutory rates.  
All employees of the company are included in the Romanian State pension plan. These costs are  
recognized in the statement of global results once with salaries recognition.  
The Company recognizes a provision for retirement benefits granted upon retirement and death.  
The discounted value of the liabilities related to the benefits granted on retirement death is  
annually determined by an independent actuary. The Company operates no other pensions or  
post-retirement benefits plan and, consequently, has no other pension-related liabilities.  
(ii) Short-term Employees Benefits  
The short-term employees’ benefits are the ones to be settled in no more than 12 months as of  
the end of the reporting period when the employees have supplied the said services. These  
benefits are mainly represented by salaries and contributions of the employer to social insurance,  
rest and medical leaves, the employees’ share of profit. The liabilities related to these benefits  
are recognized as expense while the services are supplied and are assessed on a non-discounted  
basis.  
The company establishes a fund for the employees’ share of profit, as per the provisions of  
Government Ordinance no.64/August 30, 2001.  
(n) Provisions  
The provisions are recognized when the Company has a current obligation (legal or implicit)  
generated by a past event, when it is probable that an outflow of resources be required to settle  
the obligation, and duty can be estimated reliably.  
The amount recognized as a provision is the best estimate at the balance sheet date of the costs  
required to settle this obligation.  
21  
The best estimate of the costs required to settle current debt is the amount that the Company  
would pay, reasonably, to settle the obligation on the balance sheet date or for the transfer thereof  
to a third party at that time.  
Where the effect of the time value of money is material, the amount of the provision is the present  
value of the expenditure expected to be required to settle the obligation. The discount rate used  
reflects current market assessments of the time-value of money and the risks specific to the  
liability.  
Gains from the expected disposal of assets should not be considered in measuring a provision.  
If estimated that one or all expenses related to a provision will be reimbursed by a third party, the  
reimbursement is recognized only when it is certain that it will be received. The reimbursement is  
considered as a separate asset.  
Provisions are reviewed at each balance sheet date and adjusted to reflect the current best  
estimate. If an outflow of resources is no longer likely to settle an obligation, the provision shall  
be canceled by reversal of revenues.  
(o) Subsidies  
The subsidies for assets, here included the non-monetary subsidies to fair value, are registered  
in the accountancy as subsidies for investments and are recognized by the method of approach  
based on capital, in compliance with the subsidies for investments are recognized outside the  
profit and loss, by deduction of the value of the subsidy from the assets cost.  
(p) Revenues  
Revenues related to Services Supply  
The revenues from the services supply are recognized in the period in which they were provided  
in correspondence with the stage of execution.  
As per IFRS 15 Revenues from clients’ contracts, the value of the trade price allocated to an  
obligation of execution is recognized in revenues when (or gradually) an execution measure in  
being fulfilled.  
To determine the trade price the terms of the contract and the usual business practices are being  
considered. The price of the transaction represents the value of the consideration to which the  
company expects to have the right in exchange of the transfer of goods or services promised to  
a client, not including the collected amounts on behalf of some third parties.  
Revenues from royalties, rentals and interests  
Recognition rules:  
-
- interests are recognized periodically, proportionally, upon generation of the said income,  
on an accrual-based accounting;  
- royalties and rentals on short-term are recognized based on an accrual accounting basis,  
-
under the contract.  
(q) Financial Revenues and Expenses  
The financial revenues comprise interest revenues related to the funds invested and other  
financial revenues. The interest revenues are recognized in profit or loss on the accrual-based  
accounting, using the effective interest method.  
The financial expenses mainly contain expenses with interests related to leasing contracts and  
the expenses related to currency differences.  
22  
The interest expenses generated by the debts coming from the leasing contracts are being  
registered in the loss and profit account along the leasing contract period, calculated at the  
outstanding balance of the debt related to the leasing, for each stage. This will determine higher  
expenses at the beginning of the leasing contract.  
(r) Corporate Tax  
The corporate tax expenses comprise the current corporate tax and the deferred tax.  
The corporate tax is recognized either in the profit and loss of the period, or outside the profit and  
loss, in other elements of the global result or straight in the equities.  
(i) Current Tax  
The current tax is the tax payable on the profit realized in the current period, determined using  
tax rates enacted on the reporting date and any adjustment for prior periods.  
For the financial year ended December 31, 2024, the corporate tax rate, under the Fiscal Code,  
was 16%.  
(ii) Deferred Tax  
The deferred tax is determined by the Company using the balance sheet method for those  
temporary differences arising between the tax calculation base on assets and liabilities and their  
book value, used for the individual financial statements reporting.  
The deferred tax is calculated using the tax rates that are expected to apply to the temporary  
differences upon the write-back thereof, under the legislation in force on the reporting date.  
The receivables and debts related to deferred tax are offset only if there is a legally enforceable  
right to offset liabilities and current tax receivables and whether they are related to the tax  
collected by the same tax authority on the same entity subject to taxation or different tax  
authorities but willing to achieve settlement of current receivables and payables by the tax, using  
a net basis or the related assets and liabilities will be realized simultaneously.  
The deferred tax receivable is recognized by the Company only to the extent where the  
achievement of future profits is likely to happen, which can be used to cover the tax loss. The  
deferred tax related receivable is reviewed at the end of each financial year and is reduced to the  
extent that the corresponding tax benefit is unlikely to be realized. The additional taxes that arise  
from the distribution of dividends are recognized, at the same date, with the obligation of  
dividends’ payment.  
(iii) Tax Exposures  
For the determination of current and deferred tax, the Company considers the impact of uncertain  
fiscal positions and the possibility of the occurrence of additional taxes and interests. This  
assessment is based on estimates and assumptions and may involve a series of judgments about  
future events. New information may become available, thus determining the Company to change  
its judgment regarding the accuracy in estimating the existing fiscal liabilities; such changes of  
fiscal obligations bear effect over the tax expenditure in the period when such determination is  
made.  
(s) Earnings per share  
The earnings per share are determined by dividing the profit or loss attributable to the Company’s  
ordinary shareholders to the weighted average number of ordinary shares related to the period  
under review.  
23  
(t) Business Segments Reporting  
A segment is a distinct component of the Company that provides certain products or services  
(business segment) or provides products and services in a particular geographical environment  
(geographical segment), which is subject to risks and rewards that are different from those of  
other segments.  
The company CONPET has a single reportable segment, namely transport services supply for its  
clients both via the National Transport System and by railway.  
(u) Contingent Assets and Liabilities  
The contingent liabilities are not recognized in the statement of the financial standing and in the  
profit and loss account. They are disclosed in the notes to the financial statements, except for the  
possibility of an outflow of resources representing economic benefits being removed.  
A contingent asset is not recognized in the financial statements and in the profit and loss account  
but disclosed when an inflow of economic benefits is likely to happen.  
(v) Ulterior Events  
The financial statements reflect subsequent events after the year-end events that provide  
additional information on the Company's standing on the reporting date or those that indicate a  
possible violation of the going-concern principle (events causing adjustments). Events following  
the end of the year that are not adjusting events are disclosed in notes when they are considered  
significant.  
(w) Comparative Figures  
The statement of the financial standing for the year ended December 31, 2024 shows  
comparability with the statement of the financial standing for the financial year ended December  
31, 2023.  
(x) New Standards and Interpretations  
The implications of the new Financial Reporting International Standards (IFRS EU)  
The following new standards and amendments of the existing standards issued by the  
International Accounting Standards Committee (IASB) and adopted by the EU are in force for the  
current reporting period:  
Norm/Interpretation  
[IAS 8.31 (a), 8.31(c)]  
Nature of imminent amendment of the  
accounting policy  
The possible impact on the  
financial statements  
[IAS 8.31 (e)]  
[IAS 8.31 (b)]  
Amendments to IAS 1 Presentation of The amendments issued in January 2020 offer a The adoption of the  
amendments did not have a  
significant impact on the  
financial statements.  
financial statements - Classification more general approach to the classification of  
of liabilities in short-term and long- liabilities provided by IAS 1, starting from the  
term liabilities, issued by IASB on 23 contractual agreements existing on the reporting  
January 2020, and Amendments to date. The amendments issued in October 2022  
IAS  
1
„Presentation of financial clarify the way an entity must respect, within twelve  
statements” - Long-term liabilities months from the reporting period affect the  
with financial indicators issued by IASB classification of a liability and set the effective date  
on October 31, 2022  
of both amendments to the annual periods starting  
with or after January 1, 2024.  
24  
Norm/Interpretation  
[IAS 8.31 (a), 8.31(c)]  
Nature of imminent amendment of the  
accounting policy  
The possible impact on the  
financial statements  
[IAS 8.31 (e)]  
[IAS 8.31 (b)]  
Amendments to IAS 7 Cash flow According to the amendments, it adds requirements The adoption of the  
amendments did not have a  
significant impact on the  
financial statements.  
statements and IFRS  
7
Financial on the information needed to be presented, as well  
instruments: information to be as indications within the existing requirements on  
provided Financing agreements in the information to be provided for providing  
relation to suppliers issued by IASB on qualitative and quantitative information on financing  
25 May 2023.  
agreements in relation to suppliers.  
Amendments to IFRS 16 leasing The amendments provide that the seller-lessee The amendments did not  
have a significant impact on  
the financial statements.  
Contracts in a sale and leaseback subsequently assesses the lease liabilities arising  
transaction issued by IASB on 22 from a leaseback transaction so as not to recognize  
September 2022  
any gains or losses related to the right of use  
retained. The new requirements do not prevent the  
seller-tenant from recognizing in the profit or loss  
account gains or losses from the partial or total  
termination of a leasing contract.  
The following new standards and amendments to existing standards issued by the International  
Accounting Standards Board (IASB) and adopted by the European Union (EU) that have not yet  
entered into force for the annual financial reporting period ending 31 December 2024 and have  
not impacted or been applied to the preparation of these financial statements: [IAS 8.31 (a)]  
Norm/Interpretation  
[IAS 8.31 (a), 8.31(c)]  
Natura of imminent amendment of the accounting  
The possible impact on  
the financial statements  
[IAS 8.31 (e)]  
policy  
[IAS 8.31 (b)]  
Amendments to IAS 21 Effects of Amendments provide guidance for entities to mention The adoption of these  
amendments will not have  
a significant impact on the  
financial statements in the  
future.  
exchange rate variation Lack of when a currency is convertible and how to determine  
convertibility issued by IASB on 15 the exchange rate when it is not convertible  
August 2023, effective from January 1,  
2025  
On the time of approval of these financial statements, the following existing standards were issued  
by the IASB but have not yet been adopted by the EU:  
Norm/Interpretation  
[IAS 8.31 (a), 8.31(c)]  
Natura of imminent amendment of the accounting  
The possible impact on  
the financial statements  
[IAS 8.31 (e)]  
policy  
[IAS 8.31 (b)]  
Amendments to IFRS 9 and IFRS 7 - The amendments clarify the classification of financial The Company anticipates  
that the adoption of these  
amendments to existing  
accounting standards will  
not have a significant  
impact on the performance  
of the Company in the  
future  
Amendments to the classification and assets that have environmental, social, corporate  
evaluation of financial instruments governance (ESG) and similar characteristics. The  
issued by IASB on May 30, 2024  
amendments also clarify the date on which an asset or  
financial liability is derecognized and introduce  
additional disclosure requirements for investments in  
equity instruments designated at fair value through  
other  
instruments that have contingent characteristics  
Amendments to IFRS 10 Consolidated The amendments resolve the contradiction between The Company anticipates  
comprehensive  
income  
and  
financial  
that the adoption of these  
amendments to existing  
accounting standards will  
not have a significant  
impact on the performance  
of the Company in the  
future  
financial statements and IAS 28 the requirements of IAS 28 and IFRS 10 and clarify  
Investments in associated entities that in a transaction involving an associate or joint  
and joint ventures  
-
Sale of or venture, gains or losses are recognized when assets  
contribution of assets between an sold or contributed are an undertaking. This change  
investor and associated entities or its could only be applied if the entity had not developed  
joint ventures issued by IASB on 11 an accounting policy for this purpose  
September 2014  
IFRS 19 Branches without public The standard allows subsidiaries to provide limited The Company anticipates  
that the adoption of these  
amendments to existing  
accounting standards will  
not have a significant  
liability: information to be provided information when applying IFRS Accounting  
issued by IASB on 9 May 2024  
Standards to financial statements. IFRS 19 is optional  
for eligible subsidiaries and sets out information  
25  
Norm/Interpretation  
[IAS 8.31 (a), 8.31(c)]  
Natura of imminent amendment of the accounting  
The possible impact on  
the financial statements  
[IAS 8.31 (e)]  
policy  
[IAS 8.31 (b)]  
requirements for subsidiaries that choose to apply for impact on the performance  
of the Company in the  
future  
it.  
IFRS 14 Deferral accounts related to This standard aims to enable entities that first adopt The Company anticipates  
that the adoption of these  
amendments to existing  
accounting standards will  
not have a significant  
impact on the performance  
of the Company in the  
future  
regulated activities issued by IASB on IFRS, and currently recognize deferral accounts for  
January 30, 2014  
regulated activities under generally accepted previous  
accounting policies, to continue to do so when  
switching to IFRS  
Amendments to IFRS 1, IFRS 7, IFRS These  
amendments  
include  
clarifications, The Company anticipates  
that the adoption of these  
amendments to existing  
accounting standards will  
not have a significant  
impact on the performance  
of the Company in the  
future  
9, IFRS 10 and IAS 7 - Annual simplifications, corrections and modifications in the  
Improvements to IFRS Accounting following areas: (a) hedge accounting adopted by an  
Standards Volume 11 issued by IASB entity adopting the standards for the first time (IFRS  
on July 18, 2024  
1); (b) gain or loss on discharge (IFRS 7); (c)  
presentation of the deferred difference between fair  
value and trading price (IFRS 7); (d) introduction and  
disclosures of credit risk information (IFRS 7); (e)  
removal of lease liabilities by the lessee (IFRS 9); (f)  
transaction price (IFRS 9); (g) determination of a „de  
facto” representative (IFRS 10); (h) cost-based  
method (IAS 7).  
IFRS 18 Presentation and information The standard introduces three sets of new The Company anticipates  
that the adoption of these  
amendments to existing  
accounting standards will  
not have a significant  
impact on the performance  
of the Company in the  
future  
to be provided in the financial requirements for companies to improve their financial  
statements issued by IASB on April 9, performance reporting and give investors a better  
2024 will replace IAS 1 Presentation of basis for analyzing and comparing companies. The  
the financial statements  
main changes in the new standard to IAS 1 relate to:  
(a) the introduction of categories (operating,  
investment, financing, corporate tax related and  
discontinued) and defined sub-totals in the situation of  
profit or loss; (b) the introduction of requirements for  
improving aggregations and disaggregation; (c) the  
introduction of information on the performance  
measures established by management (MPCs) in the  
notes to the financial statements. Although IFRS 18  
does not affect the recognition or measurement of  
items in financial statements, its impact on the  
presentation is significant, especially in terms of the  
financial performance status and the inclusion of  
performance measures defined by management in  
financial statements  
4. Determination of Fair Value  
Certain Company's accounting policies and requests of information supply require the  
determination of the fair value for financial and non-financial assets and liabilities.  
Determination of Fair Value  
Fair values are multi-level classified in the fair value hierarchy based on the input data used in  
the assessment techniques, as follows:  
Level 1: Prices quoted on active markets for identical assets and liabilities.  
Level 2: Input data, other than the prices included at Level 1 containing observable values for  
assets or liabilities, directly or indirectly.  
Level 3: Inputs for assets or liabilities that are not grounded on the data observable on the market.  
26  
The fair values of the tangible assets have been determined in view of assessment and/or  
presentation of the information based on the methods described below.  
The reevaluated value of the lands, buildings and equipment was established beginning with the  
fair value based on the market method and on the cost using quoted market prices for similar  
items, when they are available, or the replacement cost when appropriate. The depreciated  
replacement cost reflects adjustments for physical deterioration, wear and tear, functional and  
economical obsolescence. The reevaluated value of lands, buildings and equipment was  
determined by authorized appraisers.  
Where applicable, additional information regarding the hypothesis used in the determination of  
fair value is presented in the notes specific to the named asset or liability.  
In the following chart the fair values are presented classified on the 3 level in the hierarchy of fair  
values, structured on a group of tangible assets:  
- RON-  
Fair value on December  
Level 1:  
Level 2:  
Level 3:  
32,143,553  
31, 2024  
Lands  
-
-
32,143,553  
Constructions;  
-
-
-
-
-
471,812,398  
75,125,494  
22,371,494  
26,772,094  
471,812,398  
75,125,494  
22,371,494  
26,772,094  
Machinery and equipment  
Measuring and control devices  
Means of transport  
-
-
-
Other assets  
-
-
1,204,907  
1,204,907  
TOTAL  
629,429,940  
629,429,940  
- RON-  
Fair value on December  
31, 2023  
Level 1:  
Level 2:  
Level 3:  
Lands  
Constructions  
Machinery and equipment  
Measuring and control devices  
Means of transport  
-
-
-
-
-
-
32,264,052  
469,508,287  
77,168,919  
19,425,309  
20,532,598  
32,264,052  
469,508,287  
77,168,919  
19,425,309  
-
-
-
-
20,532,598  
Other assets  
-
-
1,595,738  
1,595,738  
TOTAL  
620,494,903  
620,494,903  
27  
5. Tangible assets  
In 2024, compared to 2023, intangible assets have evolved as follows:  
Name  
Lands*  
Buildings  
and special oil products  
installation  
s*  
Operating  
Equipment Instrumentat  
ion and  
Means of  
transport  
Other  
tangible  
assets  
Tangible Total tangible  
assets in  
progress  
assets  
control  
equipment  
Gross accounting  
value on January 1,  
2024  
37,035,595 431,298,546  
39,541,805  
-
149,000,722  
(71,831,803)  
77,168,919  
72,076,378  
(52,651,069)  
19,425,309  
57,325,681  
9,747,338  
(8,151,600)  
1,595,738  
50,336,171  
-
846,362,236  
(175,531,161)  
670,831,075  
Cumulated  
(36,793,083  
)
amortization on  
January 1, 2024  
Net accounting  
value on January 1,  
2024  
(4,771,543)  
(1,332,063)  
32,264,052 429,966,483  
39,541,805  
20,532,598  
50,336,171  
Inputs of tangible  
assets  
Outputs of tangible  
assets at gross  
value  
Cumulative  
amortization of  
outputs  
1,157,096  
(8,404)  
56,685,732  
(86,580)  
-
-
10,225,945  
(517,346)  
8,840,133  
(573,753)  
10,706,770  
(894,562)  
119,800 (14,985,380)  
72,750,096  
(2,280,879)  
(200,234)  
195,982  
-
-
-
4,562  
23,767  
-
-
492,427  
563,060  
894,562  
2,174,360  
Amortization  
recorded during the  
period  
(1,273,753) (54,318,809)  
(12,244,451)  
(5,883,255)  
(4,467,274)  
(506,379)  
(78,693,921)  
Gross accounting  
value on December  
31, 2024  
38,184,287 487,897,698  
39,541,805  
-
158,709,321  
(83,583,827)  
75,125,494  
80,342,758  
(57,971,264)  
22,371,494  
67,137,889  
9,666,904  
(8,461,997)  
1,204,907  
35,350,791  
-
916,831,453  
(252,050,722)  
664,780,731  
Amortization  
cumulated  
December 31, 2024  
Net accounting  
value on December  
31, 2024  
(40,365,795  
)
(6,040,734) (55,627,105)  
32,143,553 432,270,593  
39,541,805  
26,772,094  
35,350,791  
Name  
Lands*  
Buildings  
and special  
installations*  
Operating  
oil  
products  
Equipment Instrumentation  
and control  
Means of  
transport  
Other  
tangible  
assets  
Tangible  
assets in  
progress  
Total tangible  
assets  
equipment  
Gross accounting value  
on January 1, 2023  
Cumulated amortization  
on January 1, 2023  
28,693,144 333,355,527 39,541,805  
(3,534,499) (56,497,335)  
25,158,645 276,858,192 39,541,805  
131,103,627  
(61,414,939)  
69,688,688  
67,450,565  
53,187,538  
9,551,894  
151,716,394  
-
814,600,494  
(207,575,033)  
607,025,461  
-
(45,825,088) (33,002,087) (7,301,085)  
Net accounting value  
on January 1, 2023  
Tangible assets inputs  
Inputs of tangible assets  
at gross value  
Cumulated amortization  
related to outputs  
Diminution of tangible  
assets up to the net  
value for the registration  
of the asstes re-  
21,625,477  
20,185,451  
2,250,809  
151,716,394  
1,206,066 154,381,431  
-
-
18,404,935  
(507,840)  
5,095,756  
(469,943)  
4,995,207  
(857,064)  
196,474 (101,380,223)  
82,899,646  
(3,955)  
3,041  
(121,048)  
81,201  
(1,030)  
1,030  
-
-
(1,960,880)  
-
505,947  
463,351  
857,064  
1,911,634  
-
-
(94,048,384)  
94,048,384  
-
-
-
-
-
-
-
-
(94,048,384)  
evaluation  
Amortization annuled  
from the accounting  
value as effect of net  
method application for  
the registration of assets  
re-evaluation.  
Amortization registered  
during the year  
Re-evaluation  
-
-
-
-
-
-
94,048,384  
(1,240,085) (38,964,313)  
(10,922,811)  
(7,289,332)  
(4,648,060)  
(851,545)  
-
-
-
(63,916,146)  
44,898,509  
(27,149)  
7,154,203  
(13,863)  
37,744,306  
(13,286)  
-
-
-
-
-
-
-
-
appreciations  
Re-evaluation  
depreciations  
Gross accounting value  
37,035,595 431,298,546 39,541,805  
(4,771,543) (1,332,063)  
32,264,052 429,966,483 39,541,805  
149,000,722  
(71,831,803)  
77,168,919  
72,076,378  
57,325,681  
9,747,338  
50,336,171  
-
846,362,236  
(175,531,161)  
670,831,075  
on December 31, 2023  
Amortization cumulated  
on December 31,2023  
Net accoutning value  
on December 31, 2023  
-
(52,651,069) (36,793,083) (8,151,600)  
19,425,309 20,532,598 1,595,738  
50,336,171  
* Note: Including rights of use resulting from rental and concession contracts  
28  
On 31.12.2024 the net value of the tangible assets decreased as compared to the end of 2023  
by the amount of 6,050,344 RON.  
During 2024 there were recorded inputs of tangible assets in the amount of 72,750,096 RON and  
outputs of tangible assets at a net value 106,519 RON.  
The depreciation of tangible assets registered in 2024 amounted to 78,693,921 RON.  
During 2024 tangible assets have been commissioned in the amount of 85,340,481 RON.  
In 2024 there have been registered also increases to the assets related to the rights of use  
resulting from leasing contracts, in amount of 246,470 RON.  
According to IFRS 16, the assets representing rights of use resulting from rental and concession  
contracts are recognized in tangible assets, as follows:  
At element-row “Lands” is included the value of the rights of use resulting from the lease  
and concession contracts concluded with various landowners.  
On the rented lands are located telecommunication equipment and cathodic protection  
stations in various locations in the country. On 31.12.2024, the gross value of these assets  
is 8,134,184 RON, the cumulated depreciation of 6,040,734 RON, resulting a net value of  
the rights of use related to the lands of 2,093,450 RON.  
In the position “Buildings and special installations” is recognized the value of the rights of  
use resulting from rental and concession contracts concluded with different owners for  
buildings that are rented for being made available to the gendarmes, according to GD  
no.1486/2005 on the insurance of security and objectives protection, the goods and values  
with gendarmes, and for the performance of administrative activities. On the date of  
31.12.2024, the gross value of these assets is 2,361,789 RON, the depreciation thereof  
on the same date being of 1,733,006 RON, resulting in a net value of the rights of use  
related to the buildings of 628,783 RON.  
At the position “Means of transport” is included the value of the rights of use of 15 rail  
tanks necessary for the development of the activities specific to the company. On  
31.12.2024, the gross value of these assets is 949,290 RON, the cumulative amortization  
of 395,537 RON, resulting in a net value of the rights of use related to the means of  
transport of 553,753 RON.  
CONPET holds on December 31, 2024, lands with an area of 733,697 Sq.m, with an accounting  
value of 30,050,103 RON, which consists of:  
554,201Sq.m., lands with an accounting value of 16,293,210RON. The lands held based  
on 48 Land Ownership Certificates obtained during 2001-2005, appraised on the date of  
obtaining of the certificates, in compliance with GD no.834/1991 on the settlement and  
appraisal of various lands held by the state-owned commercial companies, at the value of  
26,708,233 RON. These lands have been obtained in the company patrimony at the expense  
of other equity reserves, without augmenting the share capital by the value thereof;  
155.401Sq.m lands with an accounting value of 4.168.765 RON, held based on 14  
Certificates of attestation of the property right obtained until 2001. The share capital of the  
company was augmented by the amount of these lands;  
29  
28.690 Sq.m land with an accounting value of 9.588.127 RON, purchased by the Company  
based on sale-purchase agreements. On one side of the purchased lands are located  
administrative buildings, and on the rest are telecommunication towers, which are intended  
for the transport activity. In 2024 it was acquired from OMV Petrom, through a sale-purchase  
contract, a built-in land having the categories of use courtyardsconstructions, with a  
measured area of 4,820 sq. m., on which is located an industrial railway line, with a built  
area on the ground of 630 sq. m. for the crude oil transport activities from the loading ramp  
located in the locality of Suplacul de Barcau.  
The lands held by the Company are in Ploiesti, at the company’s administrative offices, and in the  
24 counties covered by the transport pipelines or where the crude oil tanks loading ramps are  
being located.  
The tangible assets also include the oil operating product, evaluated in the statement of the  
financial standing at the cost determined from re-evaluation, retreated by the application of IAS  
29” The financial reporting in Hyper inflationary Economies”. On 31.12.2024, the accounting value  
of the operating oil product remained unchanged compared to the beginning of the year, being in  
amount of 39,541,805 RON.  
Tangible assets in progress  
On December 31, 2024, the value of the assets in progress is 35,350,791 RON and includes  
investment projects provided in “2024 Investment Program”, which are mainly composed of:  
replacement of pipeline portions on various lengths and routes, tanks modernizations, loading  
ramps modernizations, pumping stations modernizations, SCADA works, cathodic protection  
modernization systems etc.  
Re-evaluation of tangible assets  
After initial recognition, the tangible assets are being reappraised.  
The tangible assets for which the company has adopted the allowed alternative treatment, namely  
those submitted to re-evaluation, are being presented in the financial statements at the re-  
evaluated value (the fair value at the re-evaluation value), less the ulterior depreciation cumulated  
and the ulterior losses from depreciation. The re-evaluations have been performed with sufficient  
regularity, at least once at 3 years, the most recent being on 31.12.2023. On December 31st,  
2023 there were re-evaluated, by the ANEVAR authorized appraiser, the lands and goods from  
Group I represent “special buildings and constructions.”  
The tangible assets re-evaluated at fair value less depreciation, at 31.12.2024, compared to  
31.12.2023, reveal the following:  
- RON-  
Amendment during the  
year 2024  
Crt.  
No.  
1
Class  
Value on 31.12.2023  
Value at 31.12.2024  
Lands  
constructions;  
29,999,240  
429,276,229  
459,275,469  
30,050,103  
431,641,810  
461,691,913  
50,863  
2,365,581  
2,416,444  
2
TOTAL  
30  
6. Intangible assets  
In 2024, compared to 2023, the intangible assets evolved as follows:  
- RON-  
Other  
intangible  
assets  
Licenses and  
Total intangible  
assets  
Name  
software  
Gross accounting value on January 1, 2024  
Cumulated depreciation on January 1, 2024  
Net accounting value on January 1, 2024  
Inputs of intangible assets  
11,088,077  
(6,183,962)  
3,584,901  
14,672,978  
(9,113,405)  
(2,929,443)  
655,458  
51,008  
-
4,904,115  
34,229  
5,559,573  
85,237  
Outputs of tangible assets in gross value  
Outputs cumulated depreciation  
(1,860)  
(1,860)  
1,860  
-
1,860  
Depreciation registered during the period  
Gross accounting value on December 31, 2024  
(2,182,442)  
11,120,446  
(8,364,544)  
2,755,902  
(424,370)  
3,635,909  
(3,353,813)  
282,096  
(2,606,812)  
14,756,355  
(11,718,357)  
3,037,998  
Cumulated depreciation on December 31, 2024  
Net accounting value on December 31, 2024  
- RON-  
Other  
intangible  
assets  
Licenses and  
software  
Total intangible  
assets  
Name  
Gross accounting value on January 1, 2023  
Cumulated depreciation on January 1, 2023  
Net accounting value on January 1, 2023  
Inputs of intangible assets  
12,470,814  
(6,739,288)  
3,313,099  
(2,189,832)  
15,783,913  
(8,929,120)  
5,731,526  
1,512,200  
(2,894,937)  
2,894,937  
(2,339,611)  
11,088,077  
(6,183,962)  
4,904,115  
1,123,267  
271,802  
-
6,854,793  
1,784,002  
(2,894,937)  
2,894,937  
(3,079,222)  
14,672,978  
(9,113,405)  
5,559,573  
Outputs of intangible assets in gross value  
Outputs cumulated depreciation  
-
Depreciation registered during the period  
(739,611)  
3,584,901  
(2,929,443)  
655,458  
Gross accounting value on December 31, 2023  
Cumulated depreciation on December 31, 2023  
Net accounting value on December 31, 2023  
On 31.12.2024 the net value of the intangible assets has decreased as compared to the end of  
2023, by the amount of 2,521,575 RON.  
In 2024 there were registered intangible assets inputs of 85,237 RON and depreciation in amount  
of 2,606,812 RON.  
The depreciation method used is the linear one.  
The intangible assets include IT programs, soft licenses, electricity connection costs, water  
network and district heating network, borne by the company and recognized in intangible assets  
as the rights of use.  
Research and development-related expenses are not capitalized.  
7. Financial Assets  
Comparative statement of the financial assets for the two reporting periods reveals the following:  
- RON-  
Other non-  
current  
Fixed  
receivables  
Total financial  
assets  
Name  
securities  
Gross accounting value on January 1, 2024  
5,100  
2,837,892  
2,842,992  
31  
Impairment on January 1, 2024  
Net accounting value on January 1, 2024  
Inputs  
-
(320,189)  
2,517,703  
31,476  
(320,189)  
2,522,803  
31,476  
5,100  
-
Outputs  
-
5,100  
-
(2,100,794)  
768,574  
(2,100,794)  
773,674  
Gross accounting value on December 31, 2024  
Impairment on December 31, 2024  
Net accounting value on December 31, 2024  
(238,300)  
530,274  
(238,300)  
535,374  
5,100  
- RON-  
Total financial  
assets  
Other non-  
current  
Fixed  
receivables  
Name  
securities  
Gross accounting value on January 1, 2023  
Impairments for depreciation on January 1, 2023  
Net accounting value on January 1, 2023  
Inputs  
5,100  
2,852,134  
(320,189)  
2,531,945  
36,590  
2,857,234  
(320,189)  
2,537,045  
36,590  
-
5,100  
-
Outputs  
-
5,100  
-
(50,832)  
(50,832)  
Gross accounting value on December 31, 2023  
Impairments on December 31, 2023  
Net accounting value on December 31, 2023  
2,837,892  
(320,189)  
2,517,703  
2,842,992  
(320,189)  
2,522,803  
5,100  
On 31.12.2024, the net value of the financial assets decreased compared to the end of 2023, by  
1,987,429 RON, mainly due to the collection of guarantees granted to third parties.  
The company owns holdings to the share capital of the Independent Monitor Registry in amount  
of 5,000 RON and is associate member, along with other enterprises, in the Romanian National  
Committee of the World Petroleum Council (Ro. CNR-CMP), participating in the formation of the  
CNR-CMP patrimony with contribution in the amount of 100 RON.  
The long- term receivables, in net amount of 530.274 RON, represent guarantees granted to third  
parties and consist mainly of: returnable guarantees paid by the Company to the Ministry of  
Agriculture and Rural Development and the Ministry of Environment, Waters and Forests for the  
temporary removal of land from the agricultural circuit and the forest fund for the achievement of  
various investment objectives, including, as well as guarantees related to land and premises  
leases for the performance of production and administrative activities in different locations in the  
country and guarantees for the telecommunications equipment.  
8. Inventories  
- RON-  
Materials and Services in  
Waste  
products  
Total stocks  
Name  
Consumables  
progress  
Gross accounting value on January 1, 2024  
Impairments for depreciation of inventories  
Net accounting value on January 1, 2024  
6,467,315  
(853,307)  
5,614,008  
5,931,870  
872,224  
-
872,224  
33,332  
-
33,332  
350,525  
(306,334)  
7,372,871  
(853,307)  
6,519,564  
Stock input during the period  
Consumption/outputs of stocks during the period  
10,034,299  
16,316,694  
(16,849,863)  
(6,298,097) (10,245,432)  
Revenues from (Expense with) impairment for  
depreciation of stocks  
-
-
29,146  
29,146  
Gross accounting value on December 31, 2024  
Impairments of inventories  
Net accounting value on December 31, 2024  
6,101,088  
(824,161)  
5,276,927  
661,091  
-
661,091  
77,523  
-
77,523  
6,839,702  
(824,161)  
6,015,541  
32  
- RON-  
Materials and Services in  
Waste  
products  
Total stocks  
Name  
Consumables  
progress  
Gross accounting value on January 1, 2023  
Impairments for depreciation of inventories  
Net accounting value on January 1, 2023  
6,444,829  
(981,649)  
5,463,180  
6,859,181  
(6,836,695)  
1,403,434  
-
1,403,434  
469  
7,848,732  
(981,649)  
6,867,083  
-
469  
536,770  
(503,907)  
Stock input during the period  
Consumption/outputs of stocks during the period  
9,020,306  
(9,551,516)  
16,416,257  
(16,892,118)  
Revenues from (Expense with) impairment for  
depreciation of stocks  
-
-
128,342  
128,342  
Gross accounting value on December 31, 2023  
Impairments for depreciation of inventories  
Net accounting value on December 31, 2023  
6,467,315  
(853,307)  
5,614,008  
872,224  
-
872,224  
33,332  
-
33,332  
7,372,871  
(853,307)  
6,519,564  
The stocks are made up of materials, spare parts and other materials that are to be used when  
performing the company’s business, including the ones comprising security and intervention stocks  
meant for the likely provoked and technical breakdowns.  
The company recognizes in” revenues from ongoing services” and in the inventories the cost of  
supplied and unreceived services by the beneficiaries until the end of the period.  
9. Trade receivables and other receivables  
On December 31, 2024 and December 31, 2023, the trade receivables and other receivables  
reveal the following:  
- RON-  
December 31  
2024  
December 31,  
2023  
Name  
Clients  
34,369,148  
48,321,481  
Impairments for receivables  
Other trade receivables  
(206,618)  
286,806  
(208,618)  
280,366  
Impairments for the loss of value of other short-term intangible  
receivables  
(1,404)  
(1,404)  
Subtotal trade receivables (net value)  
Other receivables  
34,447,932  
14,446,624  
(9,452,427)  
48,391,825  
6,288,206  
(1,698,699)  
Impairments for other receivables  
Subtotal other receivables (net value)  
Total receivables  
4,994,197  
4,589,507  
39,442,129  
52,981,332  
The clients’ structure per activity is the following:  
- RON-  
December  
31st,  
December 31st,  
Name  
2023  
2024  
Clients- transport activity  
Other clients - auxiliary activities  
Total  
33,176,229  
1,192,919  
34,369,148  
47,617,013  
704,468  
48,321,481  
Trade receivables are no interest bearer and have an average day collection of 28 days.  
The main trade receivables in balance on December 31, 2024, are to be received from: OMV  
PETROM S.A.26,620,231 RON (December 31, 2023: 40,006,967 RON), Petrotel Lukoil S.A. -  
6,535,041 RON (December 31, 2023: 6,551,650 RON), Rompetrol Rafinare SA765,868 RON  
(December 31, 2023: 1,072,969 RON).  
33  
The revenues from the transport services supplies performed to the clients hold a significant share  
(over 99 %) in the Company’s turnover.  
The Company’s client, OMV PETROM SA, holds approximately 68% of the total short-term  
receivables registered on December 31, 2024.  
Other receivables, amounting to 14,446,624 RON, mainly include: amounts to be recovered from  
various natural and legal persons, amounts recorded on the basis of sentences handed down by  
the courts of law (9,449,927 RON, respectively 65.4 %), amounts to be recovered from the budget  
representing allowances for medical leave (968,126 lei, respectively 6.7 %), amounts to be  
recovered from the State budget from the capitalization of goods belonging to the public  
domain/private state (2,775,267 RON, 19.2% respectively) and non-exigible VAT related to the  
invoices unarrived until 31.12,2024 (595,612 lei, respectively 4.1%).  
Impairments for trade receivables are recorded for the doubtful clients, involved in litigation or  
insolvency, presenting default of collection. On December 31, 2024 the value of these  
impairments amounts to 206,618 RON.  
The impairments of other receivables are registered for the debits to be recovered related to the  
final sentences pronounced in the legal files. On December 31, 2024 the value of these  
impairments amounts to 9,452,427 RON, decreasing by 7,753,728 RON as compared to  
December 31st, 2021, following the passing on the accounting records of such debits.  
The Company registers impairments for loss of value, in quantum of 100% of the value of the  
receivables, for clients facing litigation, clients in insolvency and for other debits related to the  
established legal files or for fines received and disputed.  
Statement on receivables seniority  
Trade receivables  
- RON-  
December 31st,  
2023  
December 31st,  
2024  
Name  
Clients, o/w:  
Depreciated receivables  
34,369,148  
206,618  
48,321,481  
208,618  
Non-depreciated receivables, o/w:  
- seniority less than 30 days  
34,162,530  
34,129,909  
33  
48,112,863  
48,007,876  
- seniority between 30 days and 60 days  
- seniority between 60 days and 90 days  
- seniority between 90 days and 270 days  
- seniority between 270 days and 1 year  
- seniority over 1 year  
98,106  
2,098  
4,782  
-
26,780  
2,051  
3,757  
-
-
Other trade receivables, out of which:  
Depreciated receivables  
286,806  
1,404  
280,366  
1,404  
Non-depreciated receivables, o/w:  
- seniority less than 30 days  
285,402  
4,485  
278,962  
1,597  
- seniority between 30 days and 60 days  
- seniority between 90 days and 270 days  
- seniority between 270 days and 1 year  
- seniority over 1 year  
-
-
-
-
277,365  
-
-
280,917  
Other receivables  
- RON-  
December 31st,  
2023  
December 31st,  
2024  
Name  
Depreciated receivables  
9,452,427  
1,698,699  
Non-depreciated receivables, o/w:  
4,994,197  
4,589,507  
34  
- seniority less than 30 days  
2,086,664  
874,423  
-
788,551  
-
2,282,700  
196,453  
334,117  
1,111,809  
307,091  
357,336  
- seniority between 30 days and 60 days  
- seniority between 60 days and 90 days  
- seniority between 90 days and 270 days  
- seniority between 270 days and 1 year  
- seniority over 1 year  
1,244,559  
Total  
14,446,624  
6,288,206  
10. Cash and cash equivalents  
On December 31, 2024 and December 31, 2023 the cash and cash equivalents are revealed as  
follows:  
- RON-  
December 31st,  
2023  
December 31st,  
2024  
Name  
Current bank accounts  
Bank deposits with maturity ≤ 3 months  
Cash on hand  
2,626,831  
133,546,037  
3,962  
2,020,616  
105,716,195  
5,362  
Total  
136,176,830  
107,742,173  
The cash and cash equivalents on December 31, 2024 are increasing by 26.4% (28.5 million  
RON), compared to December 31, 2024 due to the increase of cash from the modernization  
quota, cash existing in bank accounts on 31.12.2024, increase by 4.9 mRON compared to  
31.12.2023, but also to the collection, prior to maturity, of the exchange value of some invoices  
issued in the month of December 2024.  
The liquid assets representing the modernization quota (in amount of 36,936,443 RON on  
31.12.2024) has a special use regime provided by GD no.168/1998, being destined exclusively  
to the financing of the modernization works and development works related to the goods  
belonging to the public domain.  
The company does not have restricted numbers.  
11. Equities  
The Share capital  
During the reporting period, the share capital of the company has not changed, remaining at the  
value of 28,569,842 RON, divided into 8,657,528 ordinary shares with a nominal value of 3.3  
RON/share and corresponds to the one registered at the Trade Register Office.  
The structure of CONPET S.A. share capital and shareholding on December 31, 2024 is exposed  
as follows:  
December 31, 2024  
December 31, 2023  
Shareholders  
Number of  
shares  
Amount  
(RON)  
Number of  
shares  
Amount  
(RON)  
(%)  
(%)  
Romanian State by  
the Ministry of Energy  
Legal persons  
Natural Persons  
Total  
5,083,372  
16,775,128  
58.7162  
5,083,372  
16,775,128  
58.7162  
2,083,424  
1,490,732  
8,657,528  
6,875,299  
4,919,415  
28,569,842  
24.0649  
17.2189  
100%  
2,029,972  
1,544,184  
8,657,528  
6,698,907  
5,095,807  
28,569,842  
23.4475  
17.8363  
100%  
Legal reserves  
On December 31, 2024 the value of the legal reserve is 5.713,968 RON and represents the  
reserve constituted at the level of 20% of the share capital, as per the Law no.31/1990 and the  
Articles of Incorporation.  
35  
Other reserves  
Other reserves are in amount of 558,422,603 RON.  
Other reserves have increased by the amount of 10,837,126 RON in the year 2024, made up of:  
7,844,065 RON, growth of reserves representing the modernization quota and 2,993,062 RON  
growth from the reserve constituted for the reinvested profit.  
The reserve related to the modernization quota is in amount of 504,511,205 RON and holds the  
highest share in total other reserves (90.35%).  
Revaluation reserves  
In the statement of the financial standing, the revaluation reserves are presented at the net value  
of 43,539,329 RON, resulting after the diminution of the gross value by the related deferred tax  
directly recognized in the equities, as per IAS 12.  
Retained earnings  
The retained earnings is in the amount of 45,124,461 RON and contain:  
The retained earnings representing actuarial loss from the discount of benefits granted upon  
retirement: 1,760,616 RON;  
The retained earnings representing surplus achieved out of revaluation reserves: 6,298,971  
RON  
The retained earnings derived from the first adoption of IAS 29 related to fixed assets  
representing oil operating product recognized in tangible assets, in amount of 39,301,668 RON;  
Other elements of the equities - retained earnings: 755,268 RON  
The retained earnings are diminished by the amount of the reinvested profit in 2024, in amount of  
2,993,062 RON, for which one has benefited from an exemption form the corporate tax, as per  
the provisions of Art.22 of Law no.227/2015 on the Fiscal Code, the amount being registered in  
the” Allocation of Profit” profit distributed to other reserves.  
Profit for the year  
The year’s profit of the year 2024 is 49,323,047 RON, decreasing by 20% compared to the year’s  
profit of the year 2023 (61,616,539 RON).  
The proposal to distribute the accounting profit left following the deduction of the corporate tax  
on December 31, 2024:  
Along 2024, there have not been distributed dividends based on the interim financial statements.  
Th accounting profit left after the deduction of the income tax, on December 31, 2024 is in amount  
of 49,323,047 RON.  
The distribution proposal on legal destinations of the remaining accounting profit after the  
deduction of the corporate tax to be distributed, to which was added the provision for the  
employees’ share of profit in amount of 5,057,858 RON, resulting in a total amount to be  
distributed of 54,380,905 RON, is the following:  
36  
- RON-  
GD  
provision  
no.  
Crt.  
No.  
Element  
Amount  
64/2001  
The net profit for the year 2024, reported based on the audited annual  
financial statements  
1
2
3
a
-
-
-
49,323,047  
5,057,858  
54,380,905  
2,993,062  
The employee share of profit up to a limit of 10% of net profit: but no more than the  
level of a monthly average basic salary at the level of the company in the financial  
year 2024, recognized in the provisions account  
The net profit reinstated with the provision for the employees’ share of profit  
(1+2):  
Art. 1,  
Other allocations stipulated by law - exemption from the payment of the reinvested  
corporate tax (account 1068), Art 22 of Law no. 227/2015 on the fiscal code  
para. (1),  
letter b)  
art. 1,  
para. (1),  
letter e)  
art. 1,  
Employees’ share of profit within the limit of 10% of the net profit but not more than  
the monthly average base salary achieved at the level of the economic operator  
reported in the financial reference year  
b
c
5,057,858  
Dividends due to shareholders  
para. (1),  
letter f)  
46,329,985  
The retained earnings that may be allocated, in the amount of 8,814,854 RON, is proposed to be  
distributed as dividends. The statement of retained earnings distributable and the distribution  
thereof is the following:  
- RON-  
Amount  
Crt.  
No.  
Destination  
1.1. The retained earnings representing surplus achieved out of revaluation reserves  
6,298,970  
The retained earnings represent actuarial loss from discount of benefits granted upon  
retirement  
1,760,616  
1.2.  
Retained earnings from the correction of various elements that have affected the profit of  
the previous years  
755,268  
1.3.  
1
Total retained earnings, distributed for:  
8,814,854  
a
Dividends due to shareholders  
8,814,854  
Other reserves in the amount of 3,407,439 RON, representing prescribed dividends, unclaimed  
within three years from the due date (prescribed dividends), are proposed to be allocated for the  
distribution as dividends due to shareholders.  
- RON-  
Crt.  
No.  
Destination  
Amount  
Other reserves representing distributions to owners, unclaimed within three years from  
the maturity date (prescribed dividends)  
1
3,407,439  
1
Total other reserves, distributed for:  
3,407,439  
a
Dividends due to shareholders  
3,407,439  
37  
12. Trade Liabilities and Other Liabilities  
On December 31, 2024 and December 31, 2023, the trade liabilities and other liabilities look as  
follows:  
- RON-  
Maturity date for the balance on December  
31, 2024  
December 31,  
2023  
December 31,  
2024  
Liabilities  
Under 1  
year  
1-5 years  
Over 5  
years  
Trade liabilities  
Liabilities to the employees  
Deferred Tax Liabilities  
33,091,805  
39,908,276  
901,503  
-
-
26,574,075  
44,513,101  
-
26,574,075  
14,276,429  
-
4,763,532  
25,473,140  
-
-
-
-
Liabilities-provisions  
Other liabilities  
Total  
9,293,146  
33,364,459  
116,559,189  
16,321,002  
35,450,624  
122,858,802  
16,321,002  
33,027,370  
90,198,876  
1,717,012  
706,242  
6,480,544  
26,179,382  
The trade liabilities related to the purchase of goods and services for the operating activity have  
a share of 73.9% in total trade liabilities, while those representing the procurement of assets have  
a share of 26.1%.  
The liabilities to employees, in balance on the date of 31.03.2024, also include the future liabilities  
for the benefits granted to employees on retirement or death, for the employees’ share of profit,  
for the untaken leaves of the employees, debts that are recognized as provisions.  
The statement of the employee-related liabilities, fiscal liabilities and other maturity date liabilities  
look as follows:  
- RON-  
Maturity date for the balance on  
December 31, 2024  
December 31, December 31,  
Liabilities  
2023  
2024  
Under 1  
year  
Over 5  
years  
1-5 years  
-
-
-
-
-
-
-
-
Salaries contributions  
Current corporate tax  
Royalty due to the State Budget  
VAT payable  
6,221,902  
1,807,695  
10,270,414  
4,111,198  
6,689,289  
-
6,689,289  
-
11,681,659  
5,060,670  
11,681,659  
5,060,670  
Other interests and debtsState  
Budget  
Dividends Payable  
Leasing related debts  
Accrued revenues  
-
-
-
1,221,041  
1,909,707  
1,909,707  
-
1,380,297  
324,238  
5,444,333  
3,346,757  
695,643  
5,717,931  
3,620,927  
613,523  
5,717,931  
1,741,696  
81,977  
498,934  
207,308  
-
Other liabilities  
12,477  
245,476  
156,918  
144,441  
Total  
33,364,459  
35,450,624  
33,027,370  
1,717,012  
706,242  
On 31.12.2024, the debts related to the leasing contain the rights of use recognized for the lease  
and concession contracts of some lands, buildings and tank cars (note 5).  
The liabilities related to the rights of use recognized for the lease and concession contracts of  
some lands, buildings and wagons have been assessed at the value of rent fees/royalties along  
the remaining contractual period, discounted with the loan rate for real estate loans.  
38  
The statement of liabilities to the employees on maturity terms reveals the following:  
- RON-  
Maturity date for the balance on  
December 31, 2024  
1-5 years  
December 31,  
2023  
December 31,  
2024  
Liabilities  
Under 1  
year  
Over 5  
years  
Salaries and assimilated debts  
Liabilities for benefits granted on  
retirement  
Liabilities for the benefits granted  
in case of death  
-
-
7,140,257  
8,043,908  
8,043,908  
4,564,389  
21,332,903  
4,140,237  
22,089,977  
26,478,421  
581,129  
-
199,143  
4,155,542  
4,339,380  
Liabilities for employeesshare of  
profit  
Debts for untaken leaves  
Liabilities for other benefits  
granted to the employees  
Total  
-
-
6,002,879  
519,621  
-
5,064,129  
432,937  
154,326  
5,064,129  
432,937  
154,326  
-
-
-
-
39,908,276  
44,513,101 14,276,429  
4,763,532  
25,473,140  
On December 31, 2024, the Company mainly comprises at this chapter the salaries and  
assimilated liabilities, as well as future liabilities for benefits granted upon retirement or death and  
for the employees’ share of profit, recognized as provisions.  
The largest share in the liabilities to the employees is held by the liability for the benefits granted  
upon retirement in the amount of 26,478,421 RON, out of which 25,897,292 RON represent long-  
term liabilities, and 581,129 RON represent short-term liabilities and the liability for benefits in  
case of death, in amount of 4,339,380 RON, representing long-term liabilities.  
These liabilities were recorded based on the Actuarial Report on the evaluation of the obligations  
related to the benefit on retirement and death provided by the CLA for Conpet S.A. employees,  
drawn up on 31.12.204 by Ovidiu-Virgil Racoveanu, certified actuary based on the service  
contract concluded with CONPET S.A.  
As per the Labor Contract in force, the company must pay the employees, upon retirement, a  
benefit equals to a certain number of salaries, according to the seniority and company job history,  
and in case of the death of the employee it is awarded equal help for a certain number of salaries.  
The present value of the liability related to the benefits granted upon retirement was determined  
by using the projected unit credit Method (IAS 19). This method starts with the principle that the  
benefit payable upon retirement is built up for each year of service to the employer, so that each  
employee be compensated at the appropriate time.  
The benefit upon retirement received by an employee at the legal retirement age has been  
updated considering the discount factor for the period remaining until the employee's retirement,  
the proportion of the benefit related to the elapsed period and the probability that the employee  
remain with the company until the retirement age (and retire at that age), given that the person  
could die, leave the company or suffer an invalidity.  
The benefit granted in the event of the death of an employee was determined as product of the  
projected death benefit up to retirement age, the present value of the death obligation during the  
service to the employer and the share of the benefit for the elapsed period.  
39  
The main actuarial hypotheses used for the calculation on December 31, 2024 were the following:  
o The discount rate. The discount rate was set at the risk-free rate investments, less  
adjustments of the variations (risk free rate spot no volatility adjustment) published by  
EIOPA at the end of December 2024.  
o Rate of Inflation. At the time of the evaluation, according to the National Institute of  
Statistics, the annual inflation rate in December 2024 compared to December 2023 was  
5.1%. An estimate of the evolution of the consumer price index is published by the National  
Commission for Strategy and Prognosis. These estimates are like those of the  
International Monetary Fund. Similar projections are to be found also on the official site of  
the European Union.  
o The rate of increase of the monthly gross average salary per company. To achieve  
the long-term projection, the average wage increase was estimated to be equal to inflation,  
to which a percentage of 0.15% per year was added. For the year 2024 the percentage  
of salary increase was taken into consideration, of 8%.  
o The statutory retirement age was 65 years for men and for women, in accordance with  
Law no. 360/2023, on the unitary pension system. These data were corroborated with the  
information on the retirement age communicated by the employer.  
o The mortality rate among the employees is based on the Life Table of the Romanian  
population men/women 2022.  
o Migration of the workforce. To model departures from the company, an average  
workforce migration in percentage of 5.5% was estimated annually, with a progressive  
downward trend toward zero according to age.  
o Duties and Taxes. All duties valid on 31.12.2022 were included in the calculation of  
retirement obligations. Since the benefits in the event of the death of the employee are  
paid from the employer’s social security fund, it results that these benefits do not involve  
the payment of duties and taxes.  
During 2024, the movement in the liabilities for the benefits upon retirement and death granted to  
the employees is exposed in the table below:  
Name  
Benefits on retirement  
Death-related  
Total benefits  
benefit  
Present value of the obligation on  
01.01.2024  
22,089,977  
4,155,542  
26,245,519  
Cost of the interest  
1,402,289  
4,055,471  
(596,895)  
195,444  
1,214,177  
(234,545)  
1,597,733  
5,269,648  
(831,440)  
Cost of the current service  
Payments from provisions during the  
year  
Actuarial gain/loss  
(472,421)  
(991,238)  
(1,463,659)  
Present value of the obligation on  
31.12.2024  
26,478,421  
4,339,380  
30,817,801  
Variation from the beginning of the year  
Percentage variation  
4,388,444  
20%  
183,838  
4%  
4,572,282  
17%  
The analysis of the sensitivity of the liability for the benefits on retirement due to the employees  
on the date of 31.12.2024 is presented in the following table:  
- RON-  
40  
Hypotheses  
December 31, 2024  
Benefits granted  
upon Retirement  
Death-related  
benefit  
Total benefits  
30,817,801  
26,478,421  
4,339,380  
The discount rate +1%  
The discount rate -1%  
Salaries increase rate +1%  
Salaries increase rate -1%  
Attrition rate +1%  
24,377,692  
28,846,481  
28,825,710  
24,356,770  
25,823,148  
27,226,373  
26,849,022  
4,123,480  
4,567,160  
4,564,688  
4,121,805  
4,319,213  
4,317,852  
4,040,890  
28,501,172  
33,413,641  
33,390,398  
28,478,575  
30,142,361  
31,544,225  
30,889,912  
Attrition rate -1%  
The increase of life expectancy at birth  
with 1 year  
The liability for the employees’ share of profit is constituted in compliance with the Ordinance  
no.64/2001 and Order of the Ministry of Public Finances no.144/2005. Ordinance no. 64 from  
August 30, 2001 establishes that the accounting profit remaining after the deduction of the  
corporate tax and other distributions provided by law to companies with full or majority state capital  
to be distributed within 10% of the net profit, but not more than the level of an average monthly  
basic salary realized at the level of the economic agent, in the financial year of reference.  
On 31.12.2024, of the total value of 5.064.129 RON, 5.057.858 RON represent a liability  
constituted in the period, for the employees share of profit of the2024, within the legal limits.  
Within the liabilities to employees is included also the liability for the untaken leaves, which, on  
31.12.2024, is in the amount of 432.937 RON.  
The company does not register overdue payments at the end of 2024.  
13. Provisions  
- RON-  
December 31,  
2024  
December 31,  
2023  
Name  
Provisions for litigations  
7,683,828  
7,156,937  
Provisions related to mandate contracts  
Other provisions for risks and expenses  
4,805,545  
3,831,629  
1,824,068  
312,141  
Total provisions  
16,321,002  
9,293,146  
Provisions for litigations  
In detail, the provisions for litigations are:  
- RON-  
December 31,  
2023  
December 31,  
2024  
Name  
Litigations for civil compensations  
Litigations for third parties’ failure to respect certain contractual clauses  
5,867,819  
47,100  
5,458,971  
70,609  
Other litigations  
1,768,909  
1,627,357  
Total  
7,683,828  
7,156,937  
The company is involved in various litigations for compensation and annuities requested by  
various owners, natural and legal persons, following the exercise by the company of the right to  
legal right of way on their lands.  
On 31.12.2024, there are registered provisions for such litigations amounting to 5,867,819 RON,  
increasing with 408,848 RON compared to 31.12.2023.  
The position ”Other litigations”, amounting to 1,768,909 RON, represents the value of the  
provision constituted for the litigation opened in the course of 2018 by Fondul Proprietatea,  
requesting the payment of net dividends distributed from the profit of the financial year 2006,  
related to a share of 6% held by the plaintiff in the share capital of CONPET S.A., as well as the  
legal interest calculated for the requested amount starting with the due date.  
41  
Provisions related to the contracts of mandate  
Debts were set up for the allowances granted to the directors, according to the mandate contracts  
and provisions of the Government Ordinance no.109/2011 on corporate governance, including  
the related contributions, as follows:  
128,700 RON represents liability for rest leave not performed by the directors with  
mandate contract;  
4,676,845 RON represents liability for the variable component related to 2024, of which  
1,837,874 RON liability for the allowances granted to the members of the Board of  
Administrators and  
2,838,971 RON liability for the allowances granted to the directors.  
Other provisions  
On December 31, 2024 the balance of the position “Other provisions” in amount of 3,831,629  
RON is composed of:  
provision for environmental expenses (160,000 RON);  
provision for the lack of use related to 2024 of the land on which is being located Voința  
Sports Base, land owned by the municipality of Ploiesti (402,716 RON);  
provision for tariffs f use of the public domain, in view of crossing/overcrossing of goods  
managed by the Romanian Waters National Administration, due based on the Emergency  
Ordinance no.52 from 31.05.2023 for the amendment and completion of some water  
normative acts, between July 2023 - December 2024 (3,268,913 RON).  
14. Current and Deferred Corporate Tax  
The expense with the current and deferred corporate tax of the company in 2024 and 2023 is  
determined by a statutory rate of 16%.  
- RON-  
December 31,  
2024  
December 31,  
2023  
Name  
Expenses with current corporate tax  
The expense with /(revenues from) deferred corporate tax  
Total  
10,227,235  
(4,012,030)  
6,215,205  
10,586,561  
590,956  
11,177,517  
Reconciliation of the effective rate of taxation:  
- RON-  
December 31,  
2023  
December 31,  
2024  
Name  
Profit before taxation  
55,538,252  
72,794,056  
- Corporate tax at a statutory rate of 16%  
8,886,120  
11,647,049  
Effect on the corporate tax of:  
- Non-deductible expenses  
- Non-taxable revenues  
- Elements like the revenues  
- Elements like the expenses  
5,602,540  
(2,427,162)  
1,199,769  
(250,935)  
(478,890)  
3,465,398  
(3,173,270)  
1,586,576  
(245,677)  
(596,064)  
- Spared corporate tax  
- Amounts representing sponsorship falling under the limits provided by  
law  
(776,000)  
(789,000)  
- Corporate tax reduction as per GEO 153/2020  
(1,528,207)  
(1,308,451)  
Expenses with current corporate tax  
10,227,235  
10,586,561  
42  
The deferred corporate tax  
The deferred corporate tax payable and recoverable was calculated based on the temporary  
taxable and/or deductible differences determined for assets and debts as differences between  
the accounting value of the asset and/or the debt and the amount attributable for fiscal purposes.  
The company recognizes the deferred taxes on the account of an expense or an income except  
for the tax generated by an event directly accounted for in the equities.  
The statement of the movements related to the receivable/debt with the deferred tax during the  
year 2024 reveals the following:  
- RON-  
Net value on December 31, 2024  
Deferred  
Deferred  
corporate tax  
recognized in  
the equity  
Net value  
corporate tax  
Receivable  
Debt related to  
related to the  
the deferred  
deferred  
2024  
on the 1st of recognized in the  
January  
profit and loss  
account  
corporate tax  
corporate tax  
Re-evaluation of  
tangible assets  
(6,923,808)  
546,529  
1,198,704  
234,185  
-
2,875,258  
7,217,019  
837,898  
(8,053,833)  
Provisions  
5,584,626  
437,679  
1,398,208  
400,219  
-
-
Impairments of  
current assets  
Deferred corporate  
tax before  
(901,503)  
2,344,956  
1,432,889  
10,930,175  
(8,053,833)  
compensation  
Compensation  
receivable/debt  
(8,053,833)  
8,053,833  
Deferred net corporate tax  
- to be  
2,876,342  
recovered  
The debt representing the deferred tax, in the balance on 31.12.2022, is in the amount of  
8,053,833 RON and is recognized on the expense of equities, and the deferred tax receivable  
recognized in the statement of global result, in balance on the same date, is 0,930,175 RON.  
The net amount of the deferred tax represents deferred corporate tax to be recovered, in amount  
of 2,876,342 RON.  
15. Result per Share  
The results per share for the last two years are:  
- RON-  
December 31,  
2024  
December 31,  
2023  
Name  
Profits of the Financial Year  
The number of ordinary shares at the beginning and the end of the  
period  
49,323,047  
8,657,528  
5.70  
61,616,539  
8,657,528  
7.12  
Basic and diluted earnings per share (RON/share)  
43  
16. Operating Revenues  
a) Revenues from contracts  
- RON-  
December 31,  
2023  
December 31,  
2024  
Name  
Revenues from transport service, of which:  
Revenues from transport services domestic subsystem*  
Revenues from transport services import subsystem*  
Other revenues associated with the transport operations  
Revenues from rents  
531,391,168  
358,670,022  
167,786,041  
4,935,105  
1,906,210  
321,031  
482,872,798  
343,751,792  
130,095,692  
9,025,314  
2,078,272  
162,539  
Other revenues from contracts  
Total contracts revenues  
*) Transported quantities for which tariffs are being applied regulated by NAMR.  
533,618,409  
485,113,609  
The transport revenues are achieved out of the services supplied to clients for the transport of the  
crude oil, rich gas and condensate volumes, at the tariffs approved by Order of the President of  
the National Agency for Mineral Resources.  
In 2024, the quantities transported on subsystems, compared to the previous years:  
December 31,  
2024  
December 31,  
2023  
Name  
Quantities transported on the Domestic subsystem*  
Quantities transported on the import subsystem*  
Other transport operations  
2,802,110  
4,206,142  
123,169  
2,914,386  
3,072,090  
307,065  
Total quantities (tons)  
7,131,421  
6,293,541  
The total quantity of transported products has increased by 13.3% in 2024 compared to the  
previous year, given the increase of the quantities transported on the import subsystem by 36.9%  
and the decrease of the quantities transported on the domestic transport subsystem by 3.9% and  
of those related to other transport operations by 59.9%.  
The tariffs for the supply of crude oil, rich gas, condensate and ethane are regulated and approved  
by the NAMR and are distinguished for each transport subsystem.  
The tariffs applied for the import transport subsystem vary according to the installment of  
transported quantity, being practiced the bracketing tariff model and the refinery- the hand-over  
site.  
In the reporting period, the following tariffs were applied:  
Tariffs from transport services on domestic subsystem:  
Period  
Transport tariff (RON/ton)  
Approved by NAMR  
Order no.  
January 1, 2023 - December 31, 2023  
starting January 1, 2024  
117.95  
128.00  
364/2022  
340/2023  
Tariffs for transport services on import subsystem:  
Ploiesti Basin  
(Petrobrazi and  
Petrotel Lukoil  
refineries)  
Arpechim  
Refinery  
Petromidia  
Refinery  
Batches  
Approved by  
NAMR Order  
no.  
Period  
thousand  
RON/ton  
RON/ton  
RON/ton  
tons/month  
up to 80  
52.25  
51.60  
20.73  
364/2022  
44  
80 -120  
41.80  
41.28  
16.59  
January 1st, 2023 -  
December 31, 2023  
120 -160  
Over 160  
up to 80  
80 -120  
120 -160  
Over 160  
31.35  
23.51  
55.00  
54.79  
54.59  
54.38  
30.96  
23.22  
39.85  
39.70  
39.55  
39.40  
12.44  
9.33  
26.50  
26.40  
26.30  
26.20  
starting January 1, 2024  
340/2023  
b) Other Operating Revenues  
- RON-  
December 31,  
December 31,  
Name  
2024  
2023  
Revenues out of modernization quota consumption  
Earnings from disposal of assets  
Other revenues  
59,600,480  
-
13,062,874  
72,663,354  
51,226,184  
612,108  
3,982,250  
Total other operating expenses  
55,820,542  
The revenues representing the modernization quota hold 82% of other operating revenues,  
registering an increase by 16.4% in the year 2024, as compared to the previous year, due to the  
increase of the revenues from the reserve related to the modernization quota, revenues registered  
at the level of amortization of fixed assets financed out of this quota.  
17. Operating Expenses  
a) Stocks and Utilities Expenses  
- RON-  
December 31,  
2024  
December 31,  
2023  
Name  
Expenses with consumables  
Other material expenses  
Other Expenses with Energy and Water  
5,382,297  
5,591,136  
762,620  
20,915,838  
27,060,755  
952,110  
18,596,747  
25,139,993  
Total Stocks and Utilities related Expenses  
b) Personnel expenses  
The personnel expenses include salary expenses, bonuses granted to the employees, other  
personnel expenses, allowances related to mandate contracts of the members of the Board of  
Directors and the directors with mandate contracts and expenses related to contributions due by  
the employer.  
- RON-  
December 31,  
2024  
December 31,  
2023  
December 31,  
2022  
Name  
Salary expenses  
Obligations for employees’ bonuses  
Other personnel expenses  
164,820,510  
28,281,535  
2,640,630  
155,824,484  
25,284,285  
39,600  
143,346,066  
21,171,116  
3,912,090  
Expenses with the remuneration of the directors with  
mandate contract and of the administrators  
Expenses with contributions due by the employer  
Total personnel expenses  
6,211,903  
5,251,280  
4,848,193  
8,231,622  
210,186,200  
7,995,343  
194,394,992  
7,645,268  
180,922,733  
45  
The personnel expenses are detailed as follows:  
Salary expenses  
- RON-  
December 31,  
2024  
December 31,  
2023  
December 31,  
2022  
Name  
Salary and related contributions expenses  
Premiums  
Retirement supports  
162,824,465  
1,298,137  
596,895  
152,998,317  
1,450,000  
1,294,737  
81,430  
139,049,643  
3,129,119  
1,115,588  
51,716  
Marriage support  
101,013  
Total salary related expenses  
164,820,510  
155,824,484  
143,346,066  
Expenditure with basic personnel salaries and the related bonuses have increased in 2024,  
compared to 2023 due to the salaries indexation, following the negotiations, with the Syndicate  
for the compliance with the provisions of the Collective Labor Agreement, related to salaries  
increases by the rate of inflation.  
According to the provisions of the Collective Labor Agreement in force, the Company has also  
provided its employees with the following benefits: bonuses, retirement support, marriage support.  
Obligations regarding employees’ bonuses  
- RON-  
December 31,  
2024  
December 31,  
2023  
December 31,  
2022  
Name  
Employees share of profit  
5,996,608  
12,118,640  
6,384,812  
9,137,465  
5,517,801  
6,474,030  
Meal vouchers  
Social expenditure under art. 25 of Law no. 227/2015  
on the Fiscal Code, further amendments and  
completions  
Other expenses as per the Collective Labor  
Agreement  
6,979,523  
3,186,764  
28,281,535  
6,871,405  
6,442,781  
2,890,603  
2,736,504  
Total  
25,284,285  
21,171,116  
The value of the bonuses granted to the employees has a growth of 2,997,250 RON in 2024,  
compared to 2023, growth that is mainly due to the increase of the meal vouchers from 30 RON  
in 2023 up to 40 RON as of 01.01.2024.  
In compliance with the provisions from the Collective Labor Agreement, the Company has granted  
to its employees bonuses as social expenses provided at Art.25 from Law no.277/2015 on the  
Fiscal Code, consisting of leisure and treatment vouchers, here included the transport, gifts  
offered to the employees, birth aids, funeral aids, serious diseases, humanitarian and other social  
expenses as per the Collective Labor Agreement.  
Other personnel expenses  
- RON-  
December 31, December 31, December 31,  
Name  
2024  
2023  
39,600  
2022  
Expenditure on compensatory payments relating to personnel  
layoffs  
2,640,630  
3,912,090  
Expenditure with the rights of the personnel due base on certain  
court orders.  
-
-
-
Total  
2,640,630  
39,600  
3,912,090  
46  
The position “Other personnel expenses" includes severance indemnities, provided under CLA,  
related to personnel layoffs conducted during the year.  
Expenses on remuneration of directors with mandate contracts and of the administrators  
- RON-  
December 31,  
2024  
December 31,  
2023  
December 31,  
2022  
Name  
Allowance of the directors with mandate  
Allowances of the members of the Board of Directors  
3,767,006  
2,444,897  
3,283,560  
1,967,720  
2,785,516  
2,062,677  
Total  
6,211,903  
5,251,280  
4,848,193  
The expenditure related to allowances for the mandate contracts of the directors and  
administrators are higher in 2024, by 960,623 RON representing fix allowance of the Deputy  
Director General 3.  
Expenses with contributions due by the Employer  
- RON-  
December 31,  
2024  
December 31,  
2023  
December 31,  
2022  
Name  
Company's contribution to voluntary pension funds  
Company’s contribution to voluntary health insurance  
Labor insurance contribution and other contributions  
2,722,063  
1,395,666  
4,113,893  
2,774,495  
1,383,314  
3,837,534  
2,871,425  
1,188,747  
3,585,096  
Total  
8,231,622  
7,995,343  
7,645,268  
The company's contribution to voluntary pension funds and voluntary health insurance is similar  
in 2024 compared to 2023.  
In 2024, because of salary growth, the labor insurance contribution has increased proportionally.  
Employees  
During 2024, 2023 and 2022, the average number of employees evolved as follows:  
December 31, December 31, December 31,  
Name  
2024  
2023  
2022  
Employees with leading positions  
Employees with execution positions  
79  
1,308  
80  
1,334  
81  
1,386  
Total  
1,387  
1,414  
1,467  
c) Expenses related to External Services  
- RON-  
December 31,  
2023  
December 31,  
Name  
2024  
Rail transport expenses  
78,209,040  
48,897,991  
5,004,680  
3,103,983  
71,644,555  
39,836,266  
4,901,236  
Expenses with royalties and rentals  
Third-party pumping expenses  
Maintenance and repair expenses  
2,532,439  
Expenses with the decontaminations, monitoring of the environmental  
factors  
563,195  
296,301  
Travel, secondment and transfer expenses  
691,367  
703,619  
Expenses related to the transport of goods and personnel  
Postal and telecommunication expenses  
10,083  
687,196  
5,238  
699,305  
Other expenses with services performed by third parties  
6,873,758  
6,316,584  
47  
Total expenses related to external services  
144,041,293  
126,935,543  
The expenses with royalties and rents mainly include the oil royalty due to the State budget by  
the company, as holder of the petroleum agreement, for the use of state public property assets in  
petroleum operations.  
It is being calculated according to the Oil Law no. 238/2004, by application of a quota of 10% up  
to the date of 26.10.2023, respectively of 11.5% as of 27.10.2023 on the value of gross revenues  
achieved out of oil transport operations via the national oil transport systems  
d) Other expenses  
- RON-  
December 31,  
2024  
December 31,  
2023  
Name  
Taxes, fees and similar levies related expenses  
Compensation, fines and penalties expenses  
Donations granted (sponsorships)  
5,565,359  
196,356  
776,000  
2,953,003  
102,099  
789,000  
Environmental protection expenses  
Expenses with the establishment of the modernization quota  
Other operating expenses  
63,391  
67,444,545  
240,373  
15,544  
58,084,160  
414,034  
Other expenses  
74,286,024  
62,357,840  
In 2024, the expenses incurred with other taxes, duties and similar payments contain, largely, the  
local tax expenses and the expenses with the contribution to the special handicap fund due under  
Law no. 448/2006 on the protection and promotion of the rights of people with disabilities.  
The chapter “Other reserves” constitutes also the reserve regarding the modernization quota  
constituted on accounts of the operating expenses, in compliance with the provisions of GD  
no.168/1998 further amendments and with the provisions of the Fiscal Code approved pursuant  
to Law no. 227/2015, further amendments and completions.  
18. Net Financial Result  
- RON-  
December 31,  
2024  
December 31,  
2023  
Name  
Revenues from interests  
Other financial revenues  
Total financial revenues  
Interest expenses related to leasing contracts  
Other financial expenses  
6,365,712  
18,544  
6,384,256  
237,637  
93,964  
6,652,665  
37,269  
6,689,934  
175,242  
83,799  
Total financial expenses  
331,601  
259,041  
Net financial result  
6,052,655  
6,430,893  
The financial revenues have decreased by 4.6% in 2024 compared to 2023, and the financial  
expenses have increased by 28% this year, compared to the previous year, maintaining a much  
lower level than the financial revenues. Based on this evolution, the net financial result has  
decreased by 5.9% in 2024, compared to 2023.  
19. Fiscal Legislative Framework  
The tax returns are subject to revisions and corrections of fiscal authorities, generally for a period  
of five years after completion thereof.  
The fiscal legislation in Romania is very complex and is permanently reforming according to the  
internal and international economic-financial context, being regulated by a multitude of normative  
48  
acts: laws, government decisions of approval of the application norms, simple ordinances and  
emergency ordinances, orders, instructions, circulars, clarifications etc.  
One cannot talk about an easy approach thereof by taxpayers, especially since there is generally  
an ongoing abusive practice of the tax authorities regarding the interpretation of the legal  
provisions which are enshrined by the law itself.  
The modernization of the fiscal legislation in Romania does not yet provide clarity and accessibility  
in the application of the provisions of the fiscal Code, by restructuring, on systematic basis, of the  
fiscal norms, as well as those on fiscal procedure and there still exists the risk that the fiscal  
authorities adopt different positions in connection with the interpretation of these aspects with  
consequence in the calculation of additional obligations and interests/penalties payment,  
augmentations and delay fines.  
By Law no.207/2015 on the fiscal procedure code, there have been amended certain principles  
regarding the interpretation of law, meaning that in the interpretation of the fiscal legislation is  
being applied the principle “in dubio contra fiscum”, therefore in case of doubt related to the fiscal  
norm it is being applied the interpretation in favor of the taxpayer.  
However, before this interpretation has been given, each public servant must clarify the respective  
text, by appealing to the good will of the legislator and the meaning of law, verify the points of  
view expressed in the substantiation notes, in reasons exposures (...). Thus, it should be noticed  
the spirit of the law as a whole and the purpose for which this law has been created. Only if by  
these norms the meaning of the norm has not been clarified, will the rule of interpretation in favor  
of the taxpayer apply, which envisages the protection of the taxpayer against an abusive  
application of the law by the fiscal body, as well as for the improvement of the relation between  
the fiscal administration and the taxpayer, for avoiding some potential conflicts.  
On 15.01.2025, the Organization of Large Taxpayer Administration within ANAF started the tax  
inspection aiming to verify the legality and conformity of tax returns and/or transactions relevant  
for tax inspection, the correctness and accuracy of the fulfillment of obligations related to the  
establishment of tax bases and the main tax obligations on value added tax and corporate tax,  
for the period 01.01.2018-31.12.2021.  
The management considers having adequately registered the fiscal obligations in the financial  
statements.  
20. Commitments and Contingencies  
Capital commitments  
The company does not have any granted capital commitment.  
Guarantees granted to third parties  
The guarantees granted to third parties are presented in the table below:  
- RON-  
December 31,  
2024  
December 31,  
2023  
Name  
Non-current Receivables (Note 7)  
Other receivables (Note 9)  
Total  
768,574  
282,321  
2,730,504  
278,769  
1,050,895  
3,009,273  
49  
Guarantees granted to third parties are separately presented at:  
- financial assets line (Note 7)  
- the line other receivables, those to be recovered within less than 12 months (Note 9)  
At the end of 2024, the Company has no record of other commitments granted to third parties.  
Received Guarantees  
The guarantees granted to third parties are presented in the table below:  
- RON-  
December 31,  
2023  
December 31,  
2024  
Name  
Performance guarantees transferred to the company’s accounts  
Performance guarantee received from the clients  
Performance guarantee received from suppliers  
Performance guarantees constituted by the beneficiaries in separate  
accounts at CONPET disposal.  
20,143  
19,499,907  
13,832,810  
20,616  
18,593,982  
17,863,332  
11,100,065  
10,708,291  
Total  
44,452,925  
47,186,221  
Contingencies  
Charges  
Our company considers that all amounts due for fees and taxes have been paid and registered  
on the balance date.  
21. Litigations  
The most important litigations the company is involved in are presented below:  
File no.5413/204/2017 Prahova Tribunal (Conpet SA defendant, NAMR defendant,  
Dobrogeanu Dumitru plaintiff, Dobrogeanu Paun Ioan plaintiff) requesting the court to order  
by Court decision:  
The payment of an annual rent for the land plots occupied by the two oil products pipelines (crude  
oil) starting 01.07.2014 and in the future for the entire lifespan of the pipelines;  
Obliging the defendants to pay the losses incurred by failing to achieve economic objectives on  
the remaining area between the two pipelines after their restriction thereof and the area along  
DN1 (E60);  
• Payment of legal fees.  
The first head of claim was estimated by the plaintiffs in the amount of 48,000 Euro/year (220,000  
RON), and the second in the amount of 25,000 RON/year.  
Court hearing: First instance-retrial  
Term: 22.05/22/25  
File no. 5212/105/2018 Court of Appeal Ploiesti (Conpet SA defendant, Fondul Proprietatea  
SA plaintiff) by which it is requested the payment of the net amount of dividends for the financial  
year 2006, related to a rate of 6% held by the plaintiff in the share capital of Conpet S.A., as well  
as the legal interest calculated for the requested amount, starting with its maturity.  
Court hearing: First instance-retrial  
Term:  
50  
File no. 32294/299/2020 Sector 1 Bucharest District Court (Conpet S.A. defendant - Bob  
Mihăiță - plaintiff-defendant, NAMR - defendant), by which the Court is asked that, by the decision  
that will be pronounced, order:  
Obligation of Conpet SA and NAMR to divert the oil pipeline that crosses the plaintiff's property  
land located in Cernavoda, field 1, plot A6/2, Constanta county;  
settlement of the counter value of the lack of use, for a period of three years, prior to the sue  
petition, amounting to 150,000 RON;  
Subsidiary, the obligation of Conpet SA to pay an annual rent for the use of the land owned by  
the plaintiff, from the date of the filing of the sue petition, amounting to 5 Euro/sqm/year for the  
area of 14,645 Sq.m, land affected by the area of protection and safety, during the existence of  
legal servitude;  
The payment of court charges.  
Procedural status: Merits  
Court hearing: 05/13/25  
File no.3451/108/2016, ATU, Pecica City - Arad Tribunal (Conpet S.A. defendant, Unit of Pecica  
City - plaintiff), by which the instance is requested that, that by decision that will be pronounced,  
to order:  
the obligation of Conpet to divert the oil pipeline which crosses a number of 22 parcels of built-in  
land for the construction of dwellings owned by the applicant, in the total area of 20,287 sqm.  
the obligation of the defendant Conpet S.A. to to pay the amount of 65,000 Euro representing the  
value of the house located in the parcel no. A141.7760/5/174, registered in C.F. no. 306869  
because it can no longer be redeemed by the subscriber. According to the report of judicial  
expertise majoring in in evaluation carried out in question at the request of the applicant UAT  
Pecica, the overall amount of compensation for affecting the construction right proposed by the  
expert is 137,045.69 Euro.  
Merits: Second appeal  
Court hearing: 05/21/25  
File no. 4395/270/2020 - Onești Courthouse - Municipality of Onești - plaintiff; Local Council of  
Onești Municipality - plaintiff, CONPET S.A. defendant)  
By which the instance is requested that, by the decision that will be pronounced, order:  
Obligation of the defendant to conclude the convention for the exercise of the right of legal  
servitude on lands in the area of 11,474.5 sq. m., under-crossed and affected by the crude oil  
pipelines within the area of Onesti, against the payment of an annual rent, along the pipelines  
lifespan, to the local budget of Onesti municipality, determined according to the principle of the  
slightest infringement to the right of ownership and calculated taking into account the value of  
movement of the affected real estate, established under the law, at the time of damage.  
The obligation of the defendant to pay material compensations, representing the equivalent value  
of the lack of land use of lands in the area of 11,474.5 Sq. m. sub-crossed and affected by the  
crude oil pipelines across the area of Onesti municipality, established according to the Market  
Study approved by the Local Council Decision no.199 of 29.11.2018, respectively according to  
the Updated Market Study approved by the Local Council Decision no.122 of 29.06.2020,  
calculated starting 2017 and until the date of conclusion of the convention for exercising the right  
of legal servitude over these lands, plus late payment increases, interest and late payment  
penalties in the amount provided for by the Fiscal Procedures Code applicable during this period.  
Forcing the defendant to pay the costs incurred by this trial.  
51  
Merits: First instance  
Court hearing: 13.05.2025  
File no. 5971/2/2022 - Bucharest Court of Appeal (OMV Petrom SA- plaintiff, NAMR - defendant,  
CONPET - defendant) by which the instance is requested that, by decision that will be  
pronounced, to order:  
The cancellation in part of Article 1 of Order 229/2021 regarding the tariffs set out in Annex 1 and  
Annex 3 and, accordingly, of Annexes 1 and 3 of Order 229/2021 and, consequently, the  
obligation of NAMR to issue a new order for the approval of the transport tariffs via the national  
transport System of crude oil, rich gas, condensate and ethane for the year 2022 including tariffs  
amended accordingly in respect of tariffs in the COUNTRY (Annex 1) and import tariffs for  
refineries in the Ploiesti Basin (Annex 3).  
The cancellation in part of art. 3-8 of the Annex to Order no. 53/2008, as well as the obligation of  
NAMR to issue a new order to duly complete Order no. 53/2008.  
Obligation to pay the court charges.  
For the cause, on the deadline of 14.03.2023, the plaintiff OMV PETROM has requested, in  
proving the claims, the documentary evidence and the judicial accounting expertise.  
On the deadline of 25.04.2023, Conpet has opposed to the documentary evidence with  
documents and the judicial accounting expertise, both requested by the plaintiff OMV Petrom SA.  
On the deadline of 09.05.2023, the Court approved for the plaintiff and for the defendants the  
documentary  
evidence.  
Orders the obligation of the defendant ANRM to submit to the case file the administrative  
documentation related to the ANRM Order no. 229/2021 amending the ANRM Order no. 13/2010  
and Order no. 13/2010 and the ANRM Order no.53/2008, under the conditions provided by Law  
no.182/2002 on the protection of classified information. Rejects as useless the case resolution  
the consent of the evidence with technical accounting expertise.  
On 31.05.2023, the defendant NAMR submitted to the Classified Documents Department of the  
Court of Appeal of Bucharest the documentation requested by the Court with the mention that  
some documents are confidential according to Art.4, Para.4, of the Petroleum Law no.238/2004  
and others have the character „secret service”.  
On the deadline of 06.06.2024, the Court ordered that the defendant the NATIONAL AGENCY  
FOR MINERAL RESOURCES, submit a written opinion on the application for the administration  
of the evidence formulated by the plaintiff, on the legal nature of the confidential documents  
provided by the Petroleum Law no.238/2004 on how to consult these documents and on the  
declassification thereby of documents constituting State secret, respectively service secret,  
according to the provisions contained in Law no. 182 of April 12, 2002. That the defendant  
CONPET SA submits a written opinion on the application for admission of evidence made by the  
applicant, on the legal nature of the confidential documents provided for by the Petroleum Law  
no. 238/2004, on how to consult these documents.  
The plaintiffs CONPET and NAMR have submitted to the court instance the points of view  
requested for the term dated 05.09.2023.  
The court has postponed the ruling.  
By the Resolution of 14.09.2023, the Court of justice finds that the unclassified documents  
submitted by the defendant NAMR to the Classified Information Department of the Bucharest  
Court of Appeal are not confidential and do not fall within the scope of the provisions of Article 4  
of Petroleum Law no. 238/2004 of June 7, 2004, with the related legal consequences regarding  
the evidentiary matters of these documents.  
52  
Grant the parties’ access to the content of confidential, non-classified information submitted by  
the NAMR defendant to the Classified Information Department of the Court.  
On the deadline of 14.11.2023, the plaintiff OMV Petrom applied for access of OMV Petrom to  
classified documents and additional evidence. The Court was requested the obligation of  
CONPET to issue access permits to classified information in this case for Mr. Marius Davitoiu and  
Mr. Marian Nita (employees of OMV PETROM who benefit from authorizations for access to  
secret service documents within the Company, also in relation to NAMR) as well as the completion  
of the probation with new documents and with Conpet interrogation.  
The Court has ordered the adjournment of the case so that the defendants of NAMR and Conpet  
formulate a point of view on the request made by the plaintiff, related to the access of its legal  
representatives to the contents of the classified information ''Secret of Service” and concerning  
the on the evidence of interrogating the defendants requested by the plaintiff.  
Conpet has submitted to the case file the point of view requested by the Court.  
On the deadline of 12.03.2024, the Court rejects as unfounded the applicant's request to grant  
access to its employees, Marius Davitoiu and Marian Nita, to classify secret service documents  
filed with the classified information department of the Court. Approves for the plaintiff the evidence  
with documents and asks the parties to submit to the case file the documents that substantiated  
the issuance of the administrative act whose annulment is requested, other than those submitted  
to the case file and to the classified information department of the court, regarding the structure  
of operational costs, the modernization quota, as well as any other financial-accounting  
documents that justified the issuance of the challenged administrative act. Rejects as useless the  
resolution of the case the consent of the evidence with the interrogation of the defendant Conpet.  
By decision no.898/ 28.05.2024, the Bucharest Court of Appeal rejects the request. Rejects as  
unfounded the exception of the plaintiff's lack of interest. Rejects as unfounded the exception of  
the lack of the capacity to be sued of the defendant CONPET SA. Rejects as unfounded sue  
petition, as it was amended. Rejects as unfounded the plaintiff’s request for the obligation of the  
defendants to pay the costs of the trial. With appeal after communication.  
Merits Court of first instance  
Court hearing: -  
File no.7035/2/2022 - Bucharest Court of Appeal (OMV Petrom SA- plaintiff, NAMR. - plaintiff,  
CONPET, - plaintiff), by which is requested the instance that by the decision that will be  
pronounced, to order:  
Partial cancellation of the Addenda no.2-9 to the transport contract no.BC OMV 108/25.03.2020  
concluded between OMV Petrom and CONPET, respectively of the articles regarding the tariffs  
on the DOMESTIC subsystem and the IMPORT subsystem, charged for transport services  
provided by CONPET and settled by NAMR no.229/2021, within the limit of the tariffs to be  
established following the contentious administrative endeavors carried out by OMV Petrom  
regarding the tariffs with NAMR and, consequently, the obligation of CONPET to pay  
compensation to OMV Petrom representing the difference between the amount of the tariffs  
adopted by the order of NAMR no. 229/2021, paid by OMV Petrom during 01.01.2022-31.08.2022  
and the amount of tariffs to be established in file no.5971/2/2022, updated with the inflation index,  
as well as the related legal interest.  
Payment to OMV Petrom of the difference between the number of tariffs paid by OMV Petrom for  
the transport of marine oil, through the DOMESTIC subsystem, from the Midia Terminal, and the  
amount of tariffs through the IMPORT subsystem depending on the subsystem used, updated  
with the inflation index, as well as the related legal interest.  
53  
Obliging CONPET to pay any other amounts representing civil fruits that CONPET has acquired  
or could have acquired in connection with the amounts charged from the OMV PETROM based  
on the tariffs.  
Obligation to pay the Court costs.  
Merits: Court of first instance suspended until the final settlement of the case forming the object  
of the file no.5971/2/2022 of the Court of Appeal of Bucharest, section IX of the fiscal and  
Contentious Administrative.  
File no.4988/2/2023Court of Appeal Bucharest (OMV Petrom SA - plaintiff, NAMR - defendant,  
Conpet S.A defendant), by which is requested the instance that, by decision that will be  
pronounced, order:  
Partial annulment of Articles 1 and 3 of the Additional Acts no. 10, no.11 and no.13, respectively  
of Articles 1 and 4 of the Addendum no.12, by which was extended the duration of the Transport  
Contract.  
Obligation of Conpet to pay to OMV Petrom, as damages, of the amounts representing:  
i. the difference between the quantum of tariffs provided in the Additional Act No 2 to the transport  
contract and the number of tariffs to be determined as legal, as well as the related statutory  
interest calculated from the date of payment of the difference in tariff;  
ii. difference between the quantum of tariffs paid by OMV Petrom for the transport of crude oil and  
the quantum of the tariffs settled proportionally, by reference to the domestic and import tariffs  
depending on the effectively used subsystem, as well as the legal interest;  
Iii. any other amounts of civil fruit that Conpet has acquired or may have acquired in relation to  
the amounts unlawfully collected from OMV Petrom based on the tariffs;  
Obligation to pay the court costs  
Merits: Court of first instance - suspended until the final resolution of the final settlement of the  
case subject to file no.7035 of the Court of Appeal of Bucharest.  
File no. 5559/2/2023Court of Appeal Bucharest (OMV Petrom SA - plaintiff, NAMR - defendant,  
Conpet S.A. - defendant), by which is the Court is requested that, by the decision that will be  
pronounced, to dispose:  
Annulment in part of Article 1 of Order no.364/2022 in respect of the tariffs set out in Annex 1 and  
Annex 3 and, accordingly, of Annexes 1 and 3 of Order no. 364/2022, as regards the tariffs for  
the domestic subsystem and the import subsystem, within the limit of the quantum of tariffs to be  
established as legal.  
Obligation to pay the court fees.  
Merits: Court of first instance - suspended until the final settlement of the case subject to file  
no.5971/2/2022 of the Court of Appeal of Bucharest, section IX of the fiscal and Contentious  
Administrative  
File no. 8213/2/2023Court of Appeal Bucharest (OMV Petrom SA - plaintiff, Conpet SA -  
defendant, NAMR - defendant), by which the instance is requested that, by the decision that will  
be pronounced dispose:  
The annulment in part of art.1 and art.3 of Addendum no.14 of Addenda no.15, no.16, no.17,  
namely of art.1 and 5 of Addendum no.18, by which the duration of the Transport Contract was  
successively extended.  
54  
Partial annulment of Article 2 of the Addenda no. 14-18 for the purpose of removing some  
quantities transported from the Midia Terminal from the quantities transported via the domestic  
subsystem and the inclusion thereof in the quantities transported via the import subsystem.  
Obligation of Conpet to pay to OMV Petrom, as compensation, the amounts representing:  
I. The difference between the number of tariffs provided for in the Additional Acts no. 14 - 18 to  
the Transport Contract and the number of tariffs to be determined as legal, as well as the related  
legal interest calculated from the date of payment of the difference in tariff.  
ii.the difference between the number of tariffs paid by OMV Petrom for the transport of crude oil  
and the number of tariffs established proportionally, in relation to the domestic and import tariffs  
according to the subsystem actually used, as well as the legal interest;  
iii. any other amounts of civil fruit that Conpet has acquired or may have acquired in relation to  
the amounts unlawfully collected from OMV Petrom on tariffs basis.  
Obligation of the to pay the Court costs  
Merits: Court of first instance - suspended until final settlement of case no. 5559/2/2023 of the  
Bucharest Court of Appeal.  
File no. 5071/2/2024 - Bucharest Court of Appeal (OMV Petrom SA- plaintiff, CONPET S.A. -  
defendant, National Regulatory Authority in the Mining, Petroleum and Geological Storage of  
Carbon Dioxide - (Ro. A.N.R.M.P.S.G.) - defendant), by which the instance is requested that, by  
the decision that will be pronounced, to order:  
The annulment in part of Article 1 of Order no. 340/2023 in respect of the tariffs set out in Annex  
1 and Annex 3 and, accordingly, of Annexes 1 and 3 of Order no. 340/2023, as regards the tariffs  
for the DOMESTIC subsystem and the IMPORT subsystem, within the amount of the tariffs that  
will be established as legal as a result of the recalculation thereof in a transparent and non-  
discriminatory manner in accordance with the constitutional and primary and secondary oil and  
competition law provisions, as they are exposed by means of this sue petition. ;  
Obligation to pay legal fees.  
Merits Court of first instance - suspended until the final settlement of the case subject to file  
no.5971/2/2022 of Bucharest Court of Appeal.  
22. Affiliated parties  
In the year 2024, the Company performed the following significant transactions with related  
parties:  
Procurement from related parties  
- RON-  
Unsettled  
amounts on  
December  
31, 2024  
Unsettled  
Procuremen Settlements Unsettled  
Procurements Settlements  
during during  
01.01.2024- 01.01.2024-  
amounts on  
December  
31, 2022  
ts during  
01.01.2023-  
31.12.2023  
during  
01.01.2023- December  
31.12.2023  
amounts on  
Partner  
31, 2023  
31.12.2023  
31.12.2023  
SPEEH  
HIDROELECTRICA  
S.A.  
-
20,377,225 13,843,888  
6,533,337  
-
6,376,121  
157,216  
! The amounts are also VAT inclusive  
Prepayments awarded to affiliated parties  
- RON-  
55  
Partner  
12/31/24  
282,378  
12/31/23  
1,989,045  
SPEEH HIDROELECTRICA S.A.  
ELECTRICA FURNIZARE S.A.  
-
277,365  
23. The Audit Committee  
The Company’s audit for the year 2024 has been provided by the company PKF Finconta S.R.L.  
By theOGMS Resolution no. 6/28.10.2022, the appointment of PKF Finconta S.R.L. as financial  
auditor of CONPET S.A for a period of 3 years was approved (2022, 2023, 2024).  
The fees are established based on the contract concluded between the two parties.  
24. Risk Management  
At the level of CONPET S.A., the internal management control system has been implemented  
and is being developed, which includes the 16 standards contained in the Code of internal  
management control of public entities. Implementation of Standard 8 requirements “Risk  
Management” was a priority in the organization by documentation and application of provisions  
of PS-MI-18 “Risk management” system procedure (sheet process, flow diagram and system  
procedure). During 2024, there were identified, assessed/re-assessed and documented the risks  
that can affect the achievement of the settled objectives. At the level of CONPET, a Register of  
significant risk was elaborated and an Annual Plan including measures to control significant risks,  
responsibilities and deadlines for the implementation of measures.  
The comprehensive processes and activities carried out within CONPET S.A. may generate risks  
from various areas, such as:  
(a) Exchange Rate Risk  
The company may be exposed to currency exchange rate fluctuations through cash and cash  
equivalents, receivables, short-term investments, long-term loans or trade debts denominated in  
foreign currency.  
The functional currency of the company is the Romanian Leu. Currently, the Company is being  
exposed to currency risk through cash and cash equivalents, as well as through purchases made  
in a currency other than the functional one. The currencies exposing the Company to such a risk  
are mainly EUR, USD and GBP. The foreign currency debts are subsequently expressed in Lei,  
at the exchange rate on the balance sheet date, communicated by the National Bank of Romania.  
The resulting differences are included in the profit and loss account, but do not affect the cash  
flow up to the moment of the liquidation of the debt.  
The Company's exposure to the currency risk expressed in RON was insignificant, as shown in  
the following statements:  
- RON-  
December 31, 2024  
Monetary Assets  
Cash and cash equivalents  
Trade receivables and other  
receivables in the short and long  
term  
Value  
RON  
EUR  
USD  
8,422  
GBP  
136,176,830  
39,972,403  
136,158,157  
39,972,403  
8,838  
-
1,413  
-
-
Monetary debts  
Various suppliers/creditors  
Net exposure in the statement  
of the financial standing  
(30,351,892)  
(27,230,145)  
(3,011,731)  
(110,016)  
-
145,797,341  
148,900,415  
(3,002,893)  
(101,594)  
1,413  
56  
- RON-  
GBP  
December 31, 2023  
Monetary Assets  
Cash and cash equivalents  
Trade receivables and other  
receivables in the short and long  
term  
Value  
RON  
EUR  
22,135  
USD  
6,082  
107,742,173  
55,499,035  
107,712,907  
55,499,035  
1,049  
-
-
-
Monetary debts  
Various suppliers/creditors  
Net exposure in the financial  
standing position  
(36,664,385)  
(33,815,517)  
(2,742,023)  
(106,844)  
-
126,576,823  
129,396,425  
(2,719,888)  
(100,762)  
1,049  
(b) Credit risk  
The credit risk is the risk that the Company may incur a financial loss because of a default by a  
client or a counterpart to a financial instrument, and this risk results mainly from the Company's  
trade receivables, cash and cash equivalents and short-term investments.  
Maximum exposure to the collection risk at the reporting date was:  
- RON-  
December 31, 2024  
December 31,  
2023  
Name  
Trade receivables and other receivables for short and long term (net  
value)  
39,972,403  
55,499,035  
Total  
39,972,402  
55,499,035  
The company carries out trade relations only on a contractual basis with recognized third parties,  
that justifies credit financing. The company is closely monitoring the exposure to commercial  
credit risk.  
The financial assets that may put the Company at risk of collection are mainly trade receivable.  
The company has implemented a series of policies that ensure that the sale of services is done  
to the clients with rapid collection. The value of net receivables (less impairments) represents the  
maximum amount at risk of collection.  
On December 31, 2024 the Company holds cash and cash equivalents in amount of 136,176,830  
RON (on December 31, 2023: 107,742,173 RON). The liquid assets are held in banks, among  
which we list BCR, Banca Transilvania. Raiffeisen Bank, BRD Groupe Societe Generale, CEC  
Bank, Unicredit Bank, Exim Bank, Garanti Bank, Credit Europe Bank, Vista Bank etc.)  
The credit risk related to trade receivables is reduced due to the regular collection of transport  
services. Even though there is significant concentration, the clients base being extremely low, the  
management considers that the commercial credit risk is reduced.  
the statement of the seniority of clients’ receivables on the date of preparation of the statements  
of financial standing is the following:  
- RON-  
Net value on  
Gross value  
December 31,  
2024  
Adjustment  
December 31,  
2024  
December 31,  
2021  
December 31,  
2024  
Name  
Seniority less than 30 days  
2,086,664  
-
2,086,664  
57  
Seniority between 30-60 days  
Seniority between 60-90 days  
Seniority between 90 days -270 days  
Seniority between 270 days -1 year  
More than 1 year  
874,423  
-
788,551  
7,735,781  
2,961,205  
14,446,624  
-
-
-
874,423  
-
788,551  
-
1,244,559  
4,994,197  
7,735,781  
1,716,646  
9,452,427  
Total  
- RON-  
Gross value  
Adjustment  
Net value  
Name  
December 31,  
2023  
December 31,  
2023  
on December 31,  
2023  
Seniority less than 30 days  
Seniority between 30-60 days  
Seniority between 60-90 days  
Seniority between 90-270 days  
Seniority between 270 days -1 year  
More than 1 year  
48,007,876  
-
-
48,007,876  
98,106  
4,062  
7,092  
98,106  
1,964  
2,309  
3,845  
200,500  
208,618  
2,098  
4,783  
3,845  
200,500  
48,321,481  
-
-
Total  
48,112,863  
The statement of seniority of other receivables on the date of drawing up the statement of  
financial standing is:  
- RON-  
Gross value  
on December  
31, 2024  
2,086,664  
874,423  
Adjustment  
December 31,  
2024  
Gross value  
on December  
31, 2023  
Net value on  
December 31,  
2023  
Name  
Seniority less than 30 days  
Seniority between 30-60 days  
Seniority between 60-90 days  
Seniority between 90-270 days  
Seniority between 270 days -1 year  
More than 1 year  
-
-
-
-
2,282,700  
196,453  
334,117  
1,111,809  
312,836  
2,050,291  
-
-
-
-
-
788,551  
7,735,781  
2,961,205  
7,735,781  
1,716,646  
9,452,427  
5,744  
1,692,955  
1,698,699  
Total  
14,446,624  
6,288,206  
Gross value on  
Adjustment  
Net value on  
Name  
December 31,  
202e  
December 31,  
2023  
December 31,  
2023  
Seniority less than 30 days  
2,282,700  
196,453  
334,117  
1,111,809  
-
-
-
-
2,282,700  
196,453  
334,117  
1,111,809  
Seniority between 30-60 days  
Seniority between 60-90 days  
Seniority between 90-270 days  
Seniority between 270 days -1 year  
312,836  
2,050,291  
6,288,206  
5,744  
307,092  
More than 1 year  
1,692,955  
357,336  
4,589,507  
Total  
1,698,699  
The statement of seniority of long-term receivables and other trade receivables on the date  
of preparation of the financial statements is:  
- RON -  
Net value  
December 31,  
2024  
Gross value on  
December 31,  
2024  
Adjustment on  
December 31,  
2024  
Name  
280,917  
80,341  
449,933  
Other long-term receivables >1 year  
Long-term receivables <1 an  
Long-term receivables >1 an  
282,321  
80,341  
688,233  
58  
1,404  
-
238,300  
Total  
811,191  
- RON -  
1,050,895  
239,704  
Gross value on  
December 31,  
2023  
Adjustment  
December 31,  
2023  
Net value on  
December 31,  
2023  
Name  
Other long-term receivables >1 year  
Long-term receivables >1 an  
Total  
278,769  
2,730,504  
3,009,273  
1,404  
320,189  
321,593  
277,365  
2,410,315  
2,687,680  
The statement of the seniority of advances for services on the time of preparation of the financial  
standing statement is:  
- RON -  
Gross value on  
December 31,  
2024  
Adjustment  
December 31,  
2024  
Net value on  
December 31,  
2024  
Name  
Seniority less than 30 days  
4,485  
-
4,485  
Total  
4,485  
-
4,485  
- RON -  
Gross value on  
December 31,  
2024  
Adjustment  
December 31,  
2024  
Net value on  
December 31,  
2024  
Name  
Seniority less than 30 days  
1,597  
-
1,597  
Total  
1,597  
1,597  
-
The movements in the clients receivables impairments were the following:  
- RON-  
Name  
2024  
2023  
Balance on January 1  
Growths during the year  
208,618  
-
222,936  
8,118  
Writebacks during the year  
(2,000)  
(22,436)  
Balance on December 31  
206,618  
206,618  
The movements in the other receivables impairments were the following:  
- RON -  
Denumire  
2024  
1,698,699  
7,871,289  
(117,561)  
2023  
1,674,185  
30,443  
Balance on January 1  
Growths during the year  
Writebacks during the year  
(5,929)  
Balance on December 31  
9,452,427  
1,698.699  
The movements in long-term impairments and other trade receivables were the following:  
- RON -  
Denumire  
2024  
321,593  
2023  
442,906  
Balance on January 1  
Growths during the year  
Writebacks during the year  
Balance on December 31  
-
(81,889)  
239,704  
-
(121,313)  
321,593  
(c) Liquidity Risk  
The liquidity risk is the Company’s risk to face difficulties in the achievement of the liabilities  
associated with the financial debts that are being settled in cash or by the transfer of another  
financial asset. The Company's approach in managing liquidity is to ensure, as much as possible,  
59  
that it will always have sufficient liquidity to meet its due obligations, both under normal conditions  
and under stress, without incurring unacceptable losses or jeopardizing the Company's  
reputation.  
The liquidity risk is managed by the Company's management by applying a policy of permanent  
liquidity insurance aimed at covering the settlement of outstanding financial liabilities.  
- RON-  
Contractual cash  
flows  
Over 5  
years  
2024  
<1  
Over 1 year  
Trade liabilities  
Liabilities to the employees  
Other liabilities  
26,574,075  
44,513,101  
35,450,624  
26,574,075  
14,276,429  
33,027,370  
-
-
4,763,532  
1,717,012  
25,473,140  
706,242  
Total  
106,537,800  
73,877,874  
6,480,544  
26,179,382  
- RON-  
Contractual cash  
flows  
Over 5  
years  
2023  
<1  
Over 1 year  
Trade liabilities  
Liabilities to the employees  
Other liabilities  
33,091,805  
39,908,276  
33,364,459  
33,091,805  
14,143,449  
30,571,853  
-
2,878,921  
2,007,577  
-
22,885,906  
785,029  
Total  
106,364,540  
77,807,107  
4,886,498  
23,670,935  
(d) The Personnel Risk and the Waging System  
On December 31, 2024, the structure according to age is not balanced, the age categories with  
the highest rate ratio in the company are between 51 - 60 years old (53.65%) and between 41-50  
years old (24.89%).  
The average age of the company CONPET personnel is high (50.2 years old) and the advantage  
it brings is the work experience accumulated by employees within the company, which indicates  
stability and professionalism. The average age of the personnel employed in the last 2 years is  
40.4 years, with an average work experience of about 14.6 years.  
However, the risk of personnel in the future is the company to deal with personnel shortages due  
to departures of the employees reaching retirement age.  
The level of this analyzed risk was low; being a high tolerability risk and for the control thereof  
have been set medium and long-term measures by way of the personnel policy and the monitoring  
of the personnel fluctuations (personnel input/output). In this respect, the immediate employment  
needs of the vacancies are carefully monitored, in relation to the needs requested by the  
organizational entities, the complexity and diversity of activities, the necessary professional skills,  
as well as the responsibilities related to the positions.  
(e) The Risk related to the Evolution of the Global Market  
The geopolitical tensions in the Middle East, amplified by conflicts between Israel and Iran, as  
well as groups supported by this State, such as Hamas and Hezbollah, add a significant risk to  
oil prices. In addition, the uncertainties generated by Donald Trump's re-election to the leadership  
of the United States are intensifying the volatility of the oil market. While there is no certainty as  
to what concrete policy measures could be implemented following his campaign speech, some of  
them could have conflicting effects on oil supply and prices.  
Oil prices fell by about 3% in 2024, marking the second consecutive year of decline, as the return  
of global post-pandemic demand experienced difficulties.  
60  
The causes of the oil price decline in 2024 were due to weak global demand, mostly due to the  
slowdown in demand in China and the increase in oil production in the United States and other  
countries outside the Organization of Petroleum Exporting Countries (OPEC).  
In parallel, the global transition to renewable energy sources, such as solar and wind power, is  
putting increasing emphasis on developing efficient energy storage solutions. These sources are  
intermittent and require advanced technologies to ensure a continuous and stable supply. Energy  
storage technologies, including batteries, hydrogen and thermal storage, will play a crucial role in  
balancing supply and demand, ensuring the reliability of electricity grids.  
The sanctions imposed on Russia have had a profound impact on the global oil market, with  
significant implications for trade flows and prices.  
In particular, the sanctions imposed by the G7 and other Western states in response to the  
conflict in Ukraine have reshaped the structure of the global energy market.  
The impact of the Russia-Ukraine conflict has led to a considerable review of global energy  
strategies and policies, prompting states and companies to reassess their dependence on  
traditional energy sources and accelerate the transition to more sustainable alternatives. In  
Southeast and Southern Europe, the ban on the transport of oil via the Drujba pipeline did not  
have a significant impact on refineries in Ploiesti and Burgas, which continue to be powered  
exclusively through Black Sea terminals.  
CONPET SA continues to carefully monitor the evolution of the conflict in Ukraine and the impact  
of the associated sanctions and countersanctions. The company is constantly analyzing the  
possible effects on its operations, considering the current volatility and geopolitical risks.  
Continued disruption or escalation of goods flows from Russia to Europe could generate further  
price increases in the European region, and this remains a major concern.  
In the short term, the company's activity did not register significant disruptions and the transport  
and delivery infrastructure were adapted to maintain operational stability. However, the medium  
and long-term impact of the conflict and the sanctions imposed on Russia remains difficult to  
accurately estimate. Given that some of the operations of CONPET S. A. depend on the areas  
affected by sanctions, including activities related to Russia, the company continuously analyzes  
possible scenarios and risks.  
At the same time, CONPET S.A. identifies factors that suggest a stable continuation of business,  
even in the face of external uncertainties. Adaptability and diversification of operations are key  
elements for maintaining stability in the face of economic and geopolitical change. In this context,  
the company anticipates that the impact will be minimal, and the adjustment plans will allow the  
continuation of the activity in an efficient and sustainable way in the long run.  
(f) Capital Market Risk  
The Romanian capital market registered a positive evolution during 2024, continuing the positive  
upward trend started at the time of the evolution to the emerging market status. The daily average  
liquidity for all types of financial instruments has recorded an upward trend during the period  
analyzed. Romania’s representativity within the indexes of Emerging Markets has materially  
61  
increased every year. Given that the company CONPET S.A. is included in the composition of  
the FTSE Global Microcap index, the risk of reduced liquidity is reduced.  
(g) Legislative-related Risks  
The frequent amendment of the normative acts here included those that bear direct impact on  
CONPET business may trigger risks for the company.  
The effort of the company CONPET to constantly adapt to changing legislative requirements may  
generate additional costs and possible future changes in the legislative framework could have  
negative effects on the activity and profitability of CONPET (increased taxes, introduction of new  
taxes and duties, reduction or suspension of tax concessions, etc.).  
Specifically, the changes occurred at the end of 2023 in the fiscal legislation, consisting in  
increasing the level of the royalty paid for the use of the National Transport System and paying  
an additional tax on the revenues achieved by oil companies, have led to the increase of the  
transport tariffs and, subsequently, the consequences can also be found on the pump price of  
finished products resulting from the processing of crude oil.  
An important risk is being represented by the loss of the facility regarding the expenses borne by  
the Romanian State to provide the guard and protection of the pipelines by gendarmes, regulated  
by GD no. 1107 dated November 14, 2012, which amends and complements GD no. 1468/2005.  
(h) Risk of litigations  
The risk related to litigation is one of the important risks to which the company is currently  
exposed, as concessionaire of the National Crude Oil, Rich gas, Ethane and Condensate  
Transport System, having as source the legal regime of the lands under/over crossed by the major  
transport pipelines established by the provisions of the Petroleum Law no. 238/2004. The number  
of private properties under/over crossed by pipelines is very high and there is a possibility that  
more and more owners bring proceedings in Court against the Company to obtain substantiated  
compensations based on the simple presence of the pipelines on their lands. Due to the defective  
way in which the legal regime of the lands under/over crossed by the transport major pipelines  
has been regulated, CONPET was and currently is engaged in a series of trials where the owners  
of those lands claim for the transport pipelines be either lifted, or moved to other sites (and the  
expense be borne by CONPET), or be granted annual compensations representing consisting  
amounts of money. Moreover, even some public authorities have laid pecuniary claims about the  
presence of components belonging to the NTS on the land owned or managed by them.  
Within the last years, the Company has prepared various legislative proposals to amend Law no  
238/2004 - Petroleum Law, hoping for a coherent and clear regulation of the legal regime of lands  
crossed under/over by the transport major pipelines. Essentially, these proposals are based on  
the following assumptions:  
- Public property (of the major pipelines) must coexist with private ownership of land, which leads  
to the conclusion that the state must acknowledge the exercise, free of charge, of certain  
categories of real rights (servitudes etc.) for the presence of the pipes on the ground;  
- CONPET shall compensate the owner of the land in full for any action that would involve  
temporary occupation of the land for the purpose of repair or damage suffered by the owners  
because of breakdowns.  
62  
(i) Risk related to the regulation and authorization  
The risk related to the regulatory framework and authorizations is identified as the company must  
obtain and renew periodically a series of opinions, authorizations, obtain certificates, attestations.  
The company is subject to a large range of regulations in various fields, which can lead to  
additional expenses and delays in starting or completing work, with possible negative effects on  
achieving objectives.  
The regulatory framework for environmental protection applicable to CONPET S.A.is complex  
due to the activity of transport of crude oil/condensate/rich gas via pipeline and by railway and,  
for good compliance, all applicable legal requirements and how to implement them in separate  
registers, developed by environmental factors (water, soil-basement, air, protected areas),  
regulations (authorizations), SEVESO, waste.  
The risk related to the regulatory framework, respectively obtaining and complying with the  
requirements of the environmental permits and water management is significant given that the  
company has to obtain and renew periodically 22 environmental permits and 38 water  
management authorizations (in May, the authorization to manage waters for the 2nd premises  
was waived - the drilling was sealed by the representatives of S.G.A. Prahova, the latter being  
nonfunctional).  
Controlling the risk related to the regulatory framework is done by closely monitoring newly  
emerged legal requirements or changes in applicable regulations, as well as by implementing the  
necessary actions to comply with them. It is also considered to develop and submit proposals for  
amendments appropriate to the framework in which CONPET operates, when draft regulations  
are under public debate.  
(j) The Market Risk  
The market risk comes from the fact that the company is not interconnected to other transport  
systems in the region, being strictly dependent on the level of crude oil processing in the refineries  
in Romania.  
With the support of the main shareholder, the Ministry of Energy and the Regulatory Authority for  
Activity (National Regulatory Authority for Mining, Oil and Geological Storage of Carbon Dioxide  
A.N.R.M.P.S.G.), CONPET is working to identify new opportunities to increase the use of the  
system, while getting involved in regional projects started in its field of activity as well as in the  
development of activities related to the basic activity (provision of oil/oil products storage services,  
provision of crude oil transport services with own tankers etc.)  
(k) Operational risk  
Operational risk comes from the Degradation of the National Pipeline Transport System (NTS)  
due to the low level of utilization (small quantities, reduced frequency) and the potential escalation  
of criminal acts related to pipeline attacks bearing significant impact on the National Transport  
System via pipelines and the environment and the impossibility to carry out railway transport  
schedules for reasons exclusively related to the railway operator.  
To control these risks, measures were established such as: redefining the transport infrastructure  
according to the demand perspective, extending the implementation of the pipeline leak detection  
and localization system, and calculation of penalties under contract or procurement of the rail  
63  
transport service with another railway operator for routes on which the transport program is not  
carried out.  
(l) Environmental aspects  
Identification of environmental aspects and environmental impact assessment  
The activity of environmental impact assessment is carried out in the production sectors whenever  
there are changes in the system that involve activities with environmental impact, the list of  
aspects with significant impact identified at the level of the company being the basis of the  
elaboration of the Environmental management program and the Action Plan for the achievement  
of environmental objectives.  
During 2024, environmental aspects have been reviewed at the site level, focusing on identifying  
environmental aspects, including how risks and opportunities related to environmental aspects  
are treated to prevent and limit their consequences on human health and the environment, using  
opportunities both for the benefit of the organization, as well as the environment. The following  
documents have been reviewed:  
Records of the legal environmental requirements for water and air  
Records of the legal environmental requirements - regulations  
Records of the legal environmental requirements - waste  
Records of the legal environmental requirements - protected areas.  
The Environmental Management and Actions Program, which includes: environmental policy  
commitments, general objectives and measurable environmental targets, environmental  
performance indicators, functions responsible for achieving environmental targets, as well as  
actions to achieve environmental objectives, which took into account the significant environmental  
aspects identified at the level of CONPET S.A., the measures in the inspection reports/minutes-  
authorities on compliance with legal requirements and other applicable requirements;  
• List of significant environmental aspects and associated impacts generated at the level of  
CONPET S.A.  
Records of the environmental opportunities.  
The stage of achievement of the objectives and targets set and the stage of implementation of  
the actions set for the achievement of the environmental objectives are analyzed annually by the  
executive management, in the framework of the analysis carried out by the management.  
Assessments of compliance with legal requirements and other environmental  
requirements  
The assessment of compliance with the legal requirements or other applicable environmental  
requirements is carried out by: • inspections carried out by the environmental authorities  
(representatives of central and local environmental and water management authorities),  
• inspections performed by OHS officials and personnel of the Environmental Protection  
Department,  
• external audits carried out by bodies certifying the environmental management system  
integrated in the company’s management system.  
internal audits carried out by internal auditors within the Management Systems Department and  
the Internal Management Control Department and the Public Internal Audit Office.  
Regulatory and control authorities in the field of environment and water management perform  
scheduled, unexpected and thematic controls at CONPET S. A. on compliance with legal  
64  
requirements and other environmental regulations, no major non-conformities being found.  
To verify the compliance with the legal requirements, at the level of 2024, 48 external inspections  
of the environmental authorities from the counties in which CONPET S. A. performs its activity  
were registered.  
The personnel of the sectors, respectively the OSH managers, carry out scheduled inspections  
according to the annual inspection chart on compliance with the applicable legal requirements  
and other requirements, as well as unscheduled inspections, according to the duties of the job  
description.  
During 2024, an external audit was carried out by the BUREAU VERITAS certification body to  
verify compliance with the requirements of ISO 14001:2015 referring to the environmental  
management system. No non-conformities/deviations were found, and no comments were made  
regarding the compliance obligations in this field.  
Following the internal audits established in the annual internal audit program, the nonconformities  
identified in the environmental management system were identified and corrected in time.  
Pollution is having a significant impact on the environment  
During the pumping of crude oil, accidental pollution can occur on the transport pipelines, from  
internal or external causes, generating pollution of the geological environment that can have a  
significant impact. Therefore, in 2024 there have been reported accidental pollutions in the areas:  
Lukoil, Tatarani, Lipanesti (county of Prahova), Ciresu (county of Braila), Lumina - 46 (county of  
Constanta), Malul Spart (county of Giurgiu), Hurezani (county of Gorj), Corbu, Milcov (county of  
Olt), overcrossing left bank of Cateasca, Oarja (county of Arges)  
In 2024, the expenses incurred with the remediation of the affected areas amounted to 374.55  
thousand le RON.  
25. Subsequent events and other mentions  
Starting 19.02.2025, by the Order of the President of the National Regulatory Authority for Mining,  
Oil and Geological Storage of Carbon Dioxide no. 99/14.02.2025 regarding the modification of  
the transport tariffs, published in the Official Gazette of Romania, Part I, no. 146 of 19.02.2025,  
the new transport tariffs via the National System of crude oil, gas, condensate and ethane  
transport have been approved.  
In the Revenues and Expenditure Budget for 2025 a reduction of the number of employees by 75  
was provided through the individual dismissal procedure. The layoffs will be made in three stages  
after their approval by the Board of Directors.  
Both the change in tariffs and the measures to reduce personnel planned for 2025 do not have  
an impact on the amounts recognized in these financial statements.  
These financial statements and the related notes, from page 1 to page 65, have been authorized  
for release by the company’s management on March 25, 2025.  
Director General,  
Eng. Dorin Tudora  
Economic Director,  
Econ. Sanda Toader  
65  
ANNUAL REPORT 2024  
OF THE ADMINISTRATORS OF THE COMPANY  
for the financial year ended  
December 31, 2024  
CONTENTS  
MESSAGE OF THE CHAIRMAN OF THE BOARD OF DIRECTORS  
Esteemed shareholders,  
Esteemed investors,  
CONPET is a well-established company in the oil and gas sector in Romania, with a history  
of over 120 years in the transport of crude oil through pipelines and a modern existence of  
33 years. CONPET's long history has always followed an evolutionary thread, so its existence  
and development have stood the test of time, gaining the status of a stable company that  
offers professional services to its clients and establishes, year after year, good and, above  
all, constant financial results.  
This "Annual Report of the Administrators" highlights all aspects of CONPET's activity for  
2024, which were part of the company's general policy, its vision and development strategy,  
as well as its values: operational effectiveness and safety, professionalism, continuous  
improvement and qualitative growth, social responsibility and sustainable development.  
In the global context marked by multiple challenges, I am happy to say that CONPET has  
maintained its stability through increased responsibility, wise strategies and, last but not  
least, through extremely rapid adaptability. We are therefore glad that we have maintained  
the high standards of our services and, implicitly, the trust of our customers, shareholders,  
employees and the community which we are a part of, that we are a long-term business  
partner.  
In 2024, we achieved the goals we set at the beginning of the year, fulfilling the development  
plans and strategies we built for operational efficiency, operational safety and sustainable  
development.  
CONPET registered, in 2024, a turnover of 533.6 mRON, higher by 10% YoY. At the same  
time, the operating revenues were 606.3 million RON, registering an increase of 12.1%  
compared to 2023.  
In 2024 the company recorded a net profit worth 49.5 million RON.  
The net profit recorded in 2024 was 49.3 million RON, above the budgeted level by 5.0 million  
RON.  
Acting as a company listed on the Bucharest Stock Exchange, in the PREMIUM category,  
an aspect that validates the company as an important player on the Romanian capital market,  
CONPET is currently included in 6 stock market indices (out of a total of 10), which indicates  
a recognition of financial stability, transparency and visibility, elements that maintain investor  
interest in our business.  
In 2024, CONPET reached a capitalization of 652.8 million RON (75.40 RON/share on  
31.12.2024).  
The achievement of the investment program always represents a major objective of  
CONPET, given the strategic importance of the activity carried out by the company, namely  
4
 
the operation of a network declared as critical infrastructure. In 2024, investments have been  
achieved in the amount of 70.4 mRON. The investment projects aim to increase the efficiency  
of transport activity, the safe operation of the National Transport System and minimize the  
impact on the environment, the company being aware that responsibility towards the  
environment is inextricably linked to the safety of the activity and the envisaged performance.  
In addition to the environmental protection measures that accompany our core business,  
CONPET has adopted a strategy that promotes energy efficiency and sustainability.  
Currently, electric and hybrid cars, photovoltaic panels, as well as electric locomotives in the  
railway area are used within CONPET.  
Another important line of development that CONPET pursued in 2024 is represented by  
corporate social responsibility (CSR) actions, part of the permanent commitment that  
CONPET has assumed for ethical behavior in the community.  
In 2024, CONPET continued to actively involve in multiple projects, in rural and urban  
communities, covering various fields health, education, sports, social and culture. The  
attention paid to the medical sector has increased considerably in recent years, so our  
company has played a significant role in supporting major projects to equip hospitals with  
modern equipment, necessary for their optimal activity.  
Also, in the sphere of the company's involvement in community life, CONPET organized, in  
collaboration with the Ploiești Blood Transfusion Center, for the third consecutive year, a  
blood donation campaign among the company's employees, in a gesture of solidarity  
and empathy with people experiencing vulnerable times.  
Participating in “Ora Pământului” #EarthHour is another tradition that CONPET respects  
every year, wishing to reiterate, also symbolically, the commitment that the company has  
assumed to protect the environment, as well as the consistency describing the pursue of this  
promise.  
CONPET's lines of action and development cover a wide area, from the efficiency and safety  
of transport activity, the interest of investors, environmental protection to the evolution of its  
own human resources and community involvement. CONPET's commitments are always firm  
and materialize in concrete actions.  
CONPET carries out, with due care, an activity that contributes to keeping the world moving,  
being at the same time a company oriented towards the future and ecological practices,  
which maintains the right balance between past and future, between tradition and progress.  
Sincerely yours,  
Cristian-Florin GHEORGHE  
CHAIRMAN OF THE BOARD OF DIRECTORS  
5
Statement of the Management  
According to the best information available, we confirm that the individual Financial  
Statements prepared in accordance with IFRS, in accordance with the Order of the Minister  
of Public Finance no. 2844/2016, with all subsequent amendments and supplements, provide  
a true and fair view of the financial position of CONPET S.A., its financial performance and  
cash flows for the year ended December 31, 2024, in compliance with the applicable  
Accounting Standards, and that the Report of the Administrators provides a true and fair view  
of the development and performance of the business and the position of the Company, as  
well as a description of the main risks and uncertainties associated with the expected  
development of the Company.  
Cristian-Florin GHEORGHE  
Chairman of the Board of Directors  
Nicușor - Marian BUICĂ  
Florin – Daniel GAVRILĂ  
Member  
Member  
Luminița – Doina Kohalmi Szabo  
Andrei Mihai ZAMAN  
Member  
Member  
Oana Cristina Tănăsică  
Alin – Mihael DĂNILĂ  
Member  
Member  
6
1. COMPANY PRESENTATION  
1.1 Report grounds  
The Annual Report of the Board of Directors of CONPET S.A. for the year ended December  
31, 2024, was prepared in accordance with:  
-
-
-
Chapter 3 of the Minister of Public Finances’ Order no. 2844/2016 for the approval of the  
accounting Regulations complaint with International Financial Reporting Standards;  
Article 65 of Law no. 24/2017, republished, regarding the issuers of financial instruments  
and market operations, subsequent amendments and additions;  
Annex no.15 on the requirements of the Annual Report, from Regulation no. 5/2018  
regarding the issuers of financial instruments and market operations issued by the  
Financial Supervisory Authority;  
-
-
Art. 56 of the Government Emergency Ordinance no.109/2011 on the corporate  
governance of the public enterprises, subsequent amendments and additions;  
Chapter VI Art. 7 regarding the Administrator’s Obligations provided in the Mandate  
Contracts concluded between the administrators and CONPET S.A.;  
Art. 20 Para (1) letter (e) of the Articles of Incorporation of CONPET S.A.  
Order of the Minister of Finance no. 85/2024 for regulating aspects related to the report  
on sustainability  
-
-
-
-
Corporate Sustainability Reporting Directive (CSRS)  
European Sustainability Reporting Standards (ESRS)  
1.2 SUBSTANTIATION DATA  
Date of the report  
March 25, 2025  
Issuer’s Name  
CONPET S.A.  
no. 1-3 Anul 1848 Street, Ploiesti, Prahova  
County, Zip Code 100559,  
Registered Offices  
Telephone/facsimile number  
E-mail / Internet  
0244 401360 / 0244 516451  
conpet@conpet.ro / www.conpet.ro  
Trade Identification Number at the Trade  
Register Office  
1350020  
Trade Registry Number  
J29/6/22.01.1991  
Regulated market trading  
the issued securities  
Bucharest Stock Exchange, Premium  
category  
Subscribed and paid-up share capital  
28,569,842.40 RON  
Main features  
of the issued securities  
8,657,528 shares with a nominal value of 3.3  
RON/share.  
652,777,611 RON (75.40 RON/share at  
31.12.2024)  
The International Financial Reporting  
Standards  
Total market value  
Applied accounting standard  
Auditing  
The Financial Statements concluded on  
December 31, 2024 have been audited  
7
     
1.3 Main activities  
CONPET is a strategic company, part of the architecture of the national energy system, being  
the operator of the crude oil national transport system via pipelines.  
Since 2002, CONPET has been the concessionaire of the operation of crude oil, rich gas,  
condensate and ethane National Transport System, based on the oil Concession Agreement  
concluded with the National Regulatory Authority for Mining, Petroleum and Geological  
Storage of Carbon Dioxide (A.N.R.M.P.S.G.).  
The Crude Oil, Rich Gas, condensate and Ethane Pipeline Transport System (.) is being  
defined and regulated by Law no. 238/7.06.2004 - Petroleum Law and Methodological Norms  
for the enforcement of the Petroleum Law, approved under. 2075/2004. The NTS is part of  
the State public property, being of strategic importance.  
1.4 The company’s mission, vision and values  
CONPET mission is the operation of the National Transport System via Pipelines under  
safety and efficient conditions, free access to the available capacity of the system to all  
solicitors, authorized legal persons, under equal conditions, in a non-discriminatory and  
transparent manner.  
CONPET mainly aims at:  
- Operational effectiveness and safety;  
- Performance optimization;  
- Sustainable development of the company;  
- Ongoing training, adaptability and qualitative increase;  
- Social responsibility and respect for the environment.  
Company’s Values:  
- Professionalism, effectiveness and performance;  
- Ongoing training, adaptability and qualitative increase;  
- Social responsibility and respect for the environment.  
1.5 Shareholding  
CONPET is a publicly owned company, listed at the Bucharest Stock Exchange, under COTE  
symbol.  
The synthetic structure of the Shareholders, on reference date 31.12.2024, is as follows:  
- 58.7162% - the Romanian State by the Ministry of Energy;  
- 41.2838% - Other shareholders natural or legal persons.  
8
     
Chart 1 - CONPET S.A. Shareholding Structure on 31.12.2024  
The number of CONPET Shareholders registered at Depozitarul Central S.A. at the end of  
2024, 16,251 shareholders, is approximately the same with the one registered on 31.12.2023  
(16,248 shareholders).  
The share capital of CONPET on 31.12.2024 is 28,569,842.40 RON and is divided into  
8,657,528 nominative shares, each share with a nominal value of 3.3 RON/share.  
CONPET did not perform transactions having as scope its own shares and, consequently,  
the company does not hold own shares.  
1.6 Company Organization  
The Company CONPET S.A. was established in 1990, based on the Government Decision  
no. 1213/1990 regarding the set-up of joint-stock companies in the industry, by taking-over  
the entire assets and liabilities of I.T.T.C. Ploieşti, being the first company established in the  
oil industry in Romania.  
Following the take-over of all assets and liabilities of I.T.T.C. Ploiești, CONPET has become  
the operator of the crude oil, rich gas, condensate and ethane National Transport System.  
The crude oil, rich gas, condensate and ethane National Transport System (NTS) is part of  
the State’s public property and bears strategic importance. The NTS is being defined and  
regulated pursuant to the Oil Law no. 238/07.06.2004 and the Methodological Norms for the  
Application of the Oil Law, approved pursuant to G.D. no. 2075/2004.  
CONPET supplies transport services for its clients via both the National Transport System,  
conceded under the Concession Agreement and by rail, from the loading ramps to the  
refineries, for the oil areas which are not connected to the major transport lines.  
1.7 Strategic development objectives  
The strategic objectives established and assumed by the administrators through the  
Administration Plan, for the period 2023-2027, were defined in close correlation with the  
strategic directions, vision and expectations of the tutelary authority.  
9
   
The strategic objectives are:  
- increasing efficiency and improvement of the activity performance;  
- ensuring effective management in human resources management;  
- selection of company directors based on criteria of professionalism and integrity;  
- ensuring modern management by implementing and maintaining risk management,  
control, ethics, integrity and corporate governance processes;  
- Ensuring a balance between the dividend policy and that regarding the provision of the  
necessary funds for the investment programs undertaken by the company for  
development and modernization;  
- develop new activities, related and non-related to the core business.  
2. RELEVANT CORPORATE EVENTS IN 2024 AND AFTER THE DATE OF THE FINANCIAL  
SITUATIONS  
February 28, 2024  
The Ordinary General Meeting of Shareholders approved the Investment Program and the  
Revenues and Expenditure Budget for 2024.  
April 25, 2024  
The Ordinary General Meeting of Shareholders approved the Annual Financial Statements  
on the date and for the financial year ended on 31.12.2023. In the same meeting, the OGMS  
approved the distribution of the net profit for the financial year 2023 and of some amounts of  
the retained earnings.  
October 29, 2024  
The Ordinary General Meeting of Shareholders approved the rectified Investment Program  
and the Revenues and Expenditure Budget for 2024.  
February 19, 2025  
Starting with the date of 19.02.2025, by the Order of the President of the National Regulatory  
Authority in the Mining, Petroleum and Geological Storage of Carbon Dioxide no.  
99/14.02.2025 regarding the modification of the transport tariffs, published in the Official  
Gazette of Romania, Part I, no. 146 of 19.02.2025, the new transport tariffs through the  
National Transport System for crude oil, rich gas, condensate and ethane were approved.  
3. CONPET 2024 - EXECUTIVE SUMMARY  
3.1 Operating Activity Indicators  
The comparative situation of the quantities of products, crude oil, rich gas and condensate,  
transported and the revenues obtained based on tariffs approved by order of A.N.R.M.P.S.G,  
as well as revenues from other types of operations related to transport via the NTS, during  
2022-2024, is presented below:  
10  
     
Variation%  
Indicators  
M.U.  
2024  
2023  
2022  
2024/2023  
2023/2022  
Total transported  
quantities  
thousand  
tons  
7,131  
531.4  
6,294  
482.9  
7,100  
469.9  
▲ 13.3%  
11.4%  
million  
RON  
Total transport revenues  
▲ 10.0%  
▲ 2.8%  
Table 1 - Evolution of the transported quantities and transport related revenues during 2022-2024  
Chart 2 - Evolution of the quantities transported on the  
Domestic and Import subsystems during 2022 -2024 (Ktons)  
Chart 3 - Evolution of the revenues transported on the  
Domestic and Import subsystems during 2022-2024  
(mRON)  
3.2. Financial Results Indicators  
The economic and financial activity of CONPET S.A. in 2024 was performed based on the  
revenues and expenditure budget.  
The comparative evolution of the main indicators of financial results in the period 2022-2024,  
as well as the change in comparison to the budget, is presented as follows:  
2024  
Variation%  
Variation (%)  
Achieved/Budget  
Indicators (mRON)  
2024 2023 2022  
Achieved Budget  
2024/20232023/2022  
533.6  
530.5  
▲ 0.6%  
TURNOVER  
Operating revenues,  
out of which:  
533.6 485.1 472.2 ▲ 10.0% ▲ 2.7%  
606.3  
601.3  
▲ 0.8%  
606.3 540.9 522.1 ▲ 12.1% ▲ 3.6%  
531.4  
556.8  
528.5  
553.2  
▲ 0.6%  
▲ 0.7%  
Transport revenues 531.4 482.9 469.9 ▲ 10.0% ▲ 2.8%  
Operating Expenses 556.8 474.5 459.3 ▲ 17.3% ▲ 3.3%  
EBIT (operating  
49.5  
48.1  
▲ 2.9%  
49.5  
66.4 62.8 ▼ 25.5% ▲ 5.7%  
profit)  
Value adjustments of  
fixed assets, less  
79.2  
78.3  
▲ 1.2%  
adjustments related to 79.2  
rights of use resulted  
61.5 53.1 ▲ 28.8% ▲ 15.8%  
from leasing contracts  
128.7  
6.0  
126.4  
4.5  
▲ 1.8%  
▲ 33.3%  
▲ 5.5%  
▲ 11.3%  
EBITDA  
128.7 127.9 115.9 ▲ 0.6% ▲ 10.4%  
Financial Result  
EBT (gross profit)  
NET PROFIT  
6.0  
6.4  
9.3  
▼ 6.3% ▼ 31.2%  
23.8% ▲ 1.0%  
20.0% 0.2%  
55.5  
49.3  
52.6  
55.5  
72.8 72.1  
44.3  
49.3  
61.6 61.7  
Table 2 - Evolution of the results from the operating and financial activity 2022 - 2024  
and 2024 vs. Budget  
11  
 
Chart 4 - Analysis of the indicators achieved in 2024 as compared to Budget (mRON)  
Chart 5 - Analysis of the indicators achieved during 2022-2024 (mRON)  
In 2024, the turnover recorded an increase of 10.0% as compared to the level achieved in  
2023. Compared to the budget, the turnover increased by 0.6% (3.1 mRON).  
The operating profit is in the amount of 49.5 mRON, 2.9% over the budgeted level.  
As compared to 2023, the operating profit registered a decrease by 25.5% (16.9 mRON).  
The net profit related to 2024 is 49.3 mRON, 11.3% higher (5 million RON) than the budget.  
Compared to 2023, the net profit decreased by 20% (12.3 mRON).  
CONPET is a company paying substantial contributions to the consolidated State budget.  
The total amount paid in 2024, to the state budget, was 206 million RON, out of which the  
most important taxes and fees paid are:  
VAT  
65 mRON  
83 mRON  
12 mRON  
46 mRON  
Tax on salaries and related contributions  
Corporate tax  
Oil royalty  
12  
3.3 Investment Activity Indicators  
The investment projects within CONPET SA mainly target an increase of the efficiency of the  
transport activity and are financed from the modernization quota.  
The investment objectives financed from the modernization quota are included in the  
rehabilitation, modernization and development programs and are approved annually by the  
National Regulatory Authority for Mining, Petroleum and Geological Storage of Carbon  
Dioxide (A.N.R.M.P.S.G.).  
The degree of achievement of the investments, as compared to the program and the similar  
period in 2023, by ownership of assets, is as follows:  
Degree of  
achievement  
2024  
Degree of  
achievement  
Investments  
2024  
2023  
2022  
2023/  
2022  
2024/  
2023  
Program  
85,000  
Achieved  
70,445  
Total  
82.9%  
investments,  
out of which:  
Public domain  
Operating  
70,445  
83,062 148,712  
84.8%  
55.9%  
52.2%  
98.1%  
65,000  
20,000  
56,139  
14,306  
86.4%  
71.5%  
56,139  
14,306  
71,580 137,008  
78.4%  
11,482  
11,704  
124.6%  
domain  
Table 3 - Investments achieved years 2024 vs. program and compared to the period 2022-2024(kRON)  
Chart 6 - Share of investments by financing sources in 2022 -2024  
3.4 Company’s Stock Market Indicators  
The market capitalization amounted to 652.78 million RON (75.40 RON/share) on  
31.12.2024, respectively 708.19 million RON (81.80 RON/share) on 31.12.2023.  
The evolution of COTE shares and market capitalization during 2022 - 2024 is as follows:  
Indicators  
M.U.  
RON/share  
million  
RON  
Dec. 31, 2024  
75.40  
Dec. 31, 2023  
81.80  
Dec. 31, 2022  
67.80  
COTE closing price  
652.78  
708.19  
586.98  
Market capitalization  
million  
Euro  
131.17  
142.36  
118.64  
Table 4 - Evolution of COTE share and market capitalization during 2022 - 2024  
13  
   
On 31.12.2024, CONPET S.A. ranked 34 according to capitalization, with a value of 652.78  
million RON, holding a share of 0.19% in total market capitalization.  
The Company CONPET S.A. is being included in 6 indices out of 10 of the Bucharest Stock  
Exchange, namely BET-NG, BET-XT, BET-XT-TR, BET-BK, BET-XT-TRN and BET Plus.  
Following the quarterly index review carried out by the global index provider MSCI, starting  
with 01.09.2023, CONPET was included in the MSCI Frontier IMI and MSCI Romania  
Investable Market Indices (IMI).  
In 2024, 13,452 stock transactions have been recorded, with a traded volume of 504,432  
shares, the total value of the transactions being 42.08 million RON. During 01.01.2024 -  
31.12.2024, the minimum trading price amounted to 73 RON/share and the maximum price  
of 91.8 RON/share. On average, 2,018 shares/day have been traded, the average value of  
a trading day amounting to 168,327 RON/day (250 days).  
The net profit per share is 5.70 RON/share in 2024.  
4. ANALYSIS OF THE COMPANY’S BUSINESS  
4.1 Analysis of the operating activity  
4.1.1 The regulatory Framework  
CONPET SA is the operator of crude oil, rich gas, condensate and ethane National Transport  
System (NTS). The transport service is being supplied under the natural monopoly regime  
based on the tariff set by A.N.R.M.P.S.G..  
The NTS is being defined and regulated pursuant to Oil Law no. 238/7.06.2004 and the  
Methodological Norms for the Application of the Oil Law, approved pursuant to GD no.  
2075/2004.  
4.1.2 The crude oil, condensate, rich gas and ethane transport activity  
CONPET S.A. supplies transport services for its clients both via NTS according to the Oil  
Concession Agreement of the National Transport System of crude oil, rich gas, condensate  
and ethane, as well as by rail, from the loading ramps to the refineries, for the oil areas not  
connected to the transport major pipelines.  
The NTS was built taking into account the natural distribution of the oil fields, so as to ensure  
the transport of crude oil from all these fields to the refineries. The system operation is being  
made based on the local dispatch centers, coordinated from the Company’s Central  
Dispatch.  
The pipeline network of the NTS is approximately 3,800 km long, currently being used a  
pipeline network of 3,161 km.  
The Crude Oil, Rich Gas, Condensate and Ethane Transport System has in composition  
more transport subsystems, as follows:  
14  
       
- The domestic crude oil and condensate transport subsystem: consisting of pipelines  
through which crude oil and condensate are transported from extraction units throughout  
the country to refineries. The domestic crude oil and condensate production is transported  
both via pipelines and by rail or combined (rail and pipelines).  
- The rich gas transport subsystem: is meant for the rich gas transport from the rich gas  
separation units in Ardeal (Calacea și Abrămuț) to Petrobrazi refinery.  
- The ethane transport subsystem provides the ethane transport from Turburea ethane  
separation platform to Arpechim Pitesti refinery. Currently, due to the inactivity of the  
Arpechim refinery, the subsystem is used only on the pipeline section linking Hurezani  
and Căpreni warehouses to Petrobrazi refinery, for the transport of condensate.  
- The import crude oil transport subsystem ensures the transport of crude oil from the  
Oil Terminal Constanta to the refineries in Ploiești (Petrobrazi și Lukoil), Arpechim-Pitești  
terminal and Petromidia refinery.  
The transport of quantities of domestic crude oil, imported crude oil, rich gas and condensate  
is carried out from the product delivery points by producers or importers, from the extraction  
areas or from the Oil Terminal, to the processing units (refineries), using the facilities at the  
pumping stations and reception points.  
These facilities shall consist of crude oil and condensate storage tanks, tanks for the storage  
of rich gas, technological pipes from the pumping/receipt warehouses, pumping aggregates,  
major pipelines, crude oil and rich gas loading and unloading ramps, rail tank cars.  
For the crude oil, rich gas and condensate transport service, CONPET has to develop, on an  
annual basis, a proper transport program so as to provide free access to the available  
capacity of the system to all applicants, authorized legal persons, under equal conditions, on  
a non-discriminatory and transparent basis.  
The available throughput represents the difference between the total physical throughput of  
the system and the crude oil scheduled for transport in the given year.  
The transport contracts signed with the beneficiaries of the services are compliant with the  
regulated frame contract approved by A.N.R.M.P.S.G. and provide the legal framework for  
the supply of the transport services.  
The transported volume by type of products (crude oil, rich gas and condensate),  
programmed and achieved in 2024 and the extent of usage of the transport throughput, is as  
follows:  
Variation  
(%)  
2024/2023  
Transport  
Subsystem  
Indicators and products  
2024  
2023  
2022  
Domestic crude oil, condensate and light condensate  
- programmed quantities (thousand tons)  
- achieved quantities (thousand tons)  
- degree of achievement  
2,789  
2,792  
2,982  
2,930  
98.3%  
47.4%  
3,058  
3,045  
▼ 6.5%  
▼ 4.7%  
100.1%  
45.2%  
99.6% +1.8 p.p.  
DOMESTIC  
- degree of use of the transport throughputs  
Rich gas  
49.2%  
-2.2 p.p.  
- programmed quantities (thousand tons)  
- achieved quantities (thousand tons)  
- degree of achievement  
14  
17  
11  
18  
9
▲ 27.3%  
▼ 5.6%  
17  
121.4%  
163.6%  
188.9% -42.2 p.p.  
15  
Variation  
(%)  
2024/2023  
Transport  
Subsystem  
Indicators and products  
2024  
2023  
2022  
- degree of use of the transport throughputs  
Total domestic subsystem  
23.4%  
24.0%  
24.7%  
-0.6 p.p.  
- programmed quantities (thousand tons)  
- achieved quantities (thousand tons)  
- degree of achievement  
2,803  
2,809  
2,993  
2,948  
98.5%  
47.1%  
3,067  
3,062  
▼ 6.3%  
▼ 4.7%  
100.2%  
44.9%  
99.8% +1.7 p.p.  
49.0% -2.2 p.p.  
- degree of use of the transport throughputs  
Imported crude oil  
- programmed quantities (thousand tons)  
4,272  
4,322  
3,358  
3,346  
99.6%  
27.7%  
6,351  
6,294  
99.1%  
4,039 ▲ 27.2%  
4,038 ▲ 29.2%  
99.9% +1.6 p.p.  
34.2% +8.0 p.p.  
7,106 11.4%  
7,100 ▲ 13.3%  
99.9% +1.7 p.p.  
IMPORT - achieved quantities (thousand tons)  
- degree of achievement  
101.2%  
35.7%  
7,075  
- degree of use of the transport throughputs  
- programmed quantities (thousand tons)  
- achieved quantities (thousand tons)  
7,131  
TOTAL  
- degree of achievement  
- degree of use of the transport  
throughputs  
100.8%  
38.9%  
34.3%  
39.3% +4.6 p.p.  
Table 5 - Transported quantities by types of products between 2022-2024  
The degree of use of the transport system in 2024 was up by 4.6 p.p. vs. 2023, due to the  
increase, by 837 thousand tons, of the transported quantities.  
Out of the total quantity of crude oil, condensate and rich gas from domestic production,  
transported and delivered, approximately 33.5% (942 thousand tons) were transported by  
rail.  
The evolution of the standardized technological consumption per product as recorded  
between 2022 -2024, is as follows:  
2024  
2023  
2022  
Products  
Standardized Achieved Variation Standardized Achieved Variation Standardized Achieved Variation  
Imported  
crude oil  
-0.06  
p.p.  
-0.065  
p.p.  
-0.073  
p.p.  
0.240%  
0.372%  
7.383%  
0.183%  
0.363%  
2.627%  
0.260%  
0.368%  
7.383%  
0.195%  
0.350%  
3.179%  
0.244%  
0.368%  
7.383%  
0.171%  
0.361%  
3.367%  
Domestic  
crude oil,  
condensate  
and light  
condensate  
Domestic  
rich gas  
-0.01  
p.p.  
-0.018  
p.p.  
-0.007  
p.p.  
-4.76  
p.p.  
-4.204  
p.p.  
-4.016  
p.p.  
Table 6 - The evolution of the standardized technological consumption as compared to the one achieved  
between 2022-2024  
16  
Chart 7 - The evolution of the technological standardized consumption as compared to the one achieved during  
2022-2024  
The technological consumption recorded during transport are within the permissible limits,  
provided in the transport contracts.  
The tariffs for the supply of the crude oil, rich gas, condensate and ethane are regulated and  
approved by the National Regulatory Authority in the Mining, Petroleum and Geological  
Storage of Carbon Dioxide and are distinguished for each transport subsystem.  
For the transport of crude oil through the Import subsystem, differentiated tariffs are applied  
depending on the intervals of transported quantities.  
In the reporting period, the following tariffs were applied:  
- Tariffs from transport services on the Domestic Subsystem  
Transport Tariffs  
RON/ton  
Approved by  
NAMR Order no.  
364/2022  
Period  
January 1, 2023 - December 31, 2023  
starting January 1, 2024  
117.95  
128.00  
340/2023  
Table 7 - Transport tariffs Domestic Subsystem  
- Tariffs for transport services on the Import Subsystem  
Arpechim  
Refinery  
Ploiesti  
Basin *)  
Petromidia  
Refinery  
Batches  
Approved  
by NAMR  
Order no.  
Period  
thousand tons/  
month  
RON/ton  
RON/ton  
RON/ton  
52.25  
41.80  
51.60  
41.28  
20.73  
16.59  
no more than 80  
between  
January 1, 2023 -  
December 31,  
2023  
80-120  
364/2022  
340/2023  
between  
120-160  
31.35  
30.96  
12.44  
23.51  
55.00  
54.79  
23.22  
39.85  
39.70  
9.33  
26.50  
26.40  
over 160  
no more than 80  
between  
80-120  
Starting  
01.01.2024  
between  
120-160  
54.59  
54.38  
39.55  
39.40  
26.30  
26.20  
over 160  
*) Petrobrazi Refinery and Lukoil Refinery  
Table 8 - Transport tariffs through the Import Subsystem  
17  
The transport tariffs include a modernization quota meant exclusively for the financing of the  
investments related to the National Transport System.  
The company holds a monopoly position in the pipeline transport market, not having  
competitors in its main area.  
Transport services are performed based on contracts concluded with customers, developed  
according to the framework contract approved annually by the National Regulatory Authority  
for Mining, Petroleum and Geological Storage of Carbon Dioxide (ANRMPSG).  
The revenues from the provision of transport services and invoiced to beneficiaries increased  
by 10.0% compared to 2023, reaching the value of 531.4 million RON.  
The statement on revenues for each client and their share in the total transport revenues are  
as follows:  
Chart 8 - The evolution of the transport revenues per clients, achieved during 2022-2024  
The transport services supplied by the company are addressed to a reduced number of  
clients, the quantities of crude oil transported being closely related to their commercial policy.  
The revenues from the transport services supplied for OMV Petrom account for 79.9% in the  
total transport revenues of the company.  
4.1.3 Other activities  
The revenues from other activities hold a share of 0.4% in turnover decreasing by 0.6% (14  
thousand RON) compared to 2023, coming from leases of land and telecommunication  
equipment, rail shunting etc.  
4.1.4 Analysis of the operating activity  
In the table below is presented the evolution of the transport services supply and other  
services, for the period 2022-2024:  
18  
   
Variation%  
Indicators  
2024  
2023  
2022  
2024/2023 2023/2022  
Revenues from transport services  
Domestic Subsystem  
358,670 343,752 321,320  
4.3%  
7.0%  
Revenues from transport services  
Import Subsystem  
167,786 130,096 144,044  
29.0%  
▼ 9.7%  
526,456 473,848 465,364  
▲ 11.1%  
▲ 1.8%  
Total Transport Revenues*)  
Revenues from other operations  
related to transport by NTS  
Total general transport revenues  
Revenues from rents  
4,935  
9,025  
4,493  
▼ 45.3% 100.9%  
531,391 482,873 469,857  
▲ 10.0%  
▼ 8.3%  
▲ 2.8%  
5.7%  
▼ 60.2%  
▲ 2.7%  
1,906  
321  
2,078  
163  
1,966  
410  
96.9%  
▲ 10.0%  
Other revenues  
533,618 485,114 472,233  
Turnover  
*) Revenues related to transported quantities for which tariffs regulated by A.N.R.M.P.S.G. are applied  
Table 9- Evolution of turnover revenues during 2022- 2024(kRon)  
Chart 9 - Evolution in turnover during 2022 - 2024 (thousand RON)  
4.1.5 Analysis of the supply activity  
Procurement activity  
The procurement activity performed in compliance with the provisions of the Internal  
Procurement Norms of CONPET S.A. and other internal procedures.  
During January-December 2024, have been initiated 120 procurement and concluded 117  
contracts in total amount of 95,442 thousand RON and 2,128 thousand Euro.  
At the end of December, a number of 3 procurement procedures were in progress, in total  
estimated value of 10,768 thousand RON.  
The contracts for the procurement of products and works with a value higher than 500,000  
euros and the services procurement contracts with values higher than 100,000 Euro,  
concluded between 01.01.2024 - 31.12.2024, were presented in the form of annexes to the  
preliminary report drawn up for the year 2024, uploaded on the CONPET website on  
February 27, 2025.  
19  
 
The List of important contracts concluded by the company in 2024 is presented in Annex no.  
5.  
4.1.6. Legal papers concluded according to Art. 52 para. (1) and (3), GEO no. 109/2011  
According to the provisions of Article 52 para. (6) of GEO no. 109/2011 “In the half-yearly  
and annual reports of the Board of Directors [...] shall be mentioned, in a special chapter, the  
legal acts concluded under the conditions of para. (1) and (3), […]”.  
The transactions concluded according to Article 52 of GEO no. 109/2011 in 2024H2 can be  
found in Annex no. 2.  
4.1.7 Company mergers and reorganizations, procurements and disposals of assets  
There were no mergers and reorganization activities in the reported period, January –  
December 2024.  
The company has no open subsidiaries in Romania or abroad.  
Purchases of tangible and intangible assets in the period January - December 2024 were  
made in accordance with the investment program and the approved revenues and  
expenditure budget and are intended for deployment and modernization. In 2024, an urban  
land with the use category of construction-yards was purchased from OMV Petrom, through  
a sale-purchase contract, with a measured area of 4,820 m.p. on which an industrial railway  
line is located, with a built-up area of 630 sq.m., for crude oil transport activities from the  
loading ramp located in the Suplacul de Barcău locality.  
4.1.8 Development of the internal control management system  
The internal/management control system  
The company CONPET S.A., defined as a public entity in accordance with the Order of the  
Secretary General of the Government No. 600/2018, applies the Code of the internal control  
management of public entities approved by the aforementioned legislation.  
CONPET S.A. does annual self-assessment of the degree of implementation of the internal  
control management standards and reports in accordance with the legal requirements.  
According to the provisions of OGSG no. 600/2018 for approving the Internal Control  
Management Code of public entities, the Monitoring committee of the internal control  
management system was appointed, by decision of the Director General.  
The Monitoring committee of the internal control management system has the following  
duties:  
- Draws up the Development Program of the internal control management system covering  
the objectives of CONPET S.A. in internal control management, including, for each  
standard of internal control management, activities, officers in charge and deadlines, as  
well as other relevant elements in implementing and developing the internal control  
management system.  
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- Surveys the deployment and provides upgrade of the development program of the internal  
control management system.  
- Coordinates the process of updating the general and specific objectives, the procedure  
activities, the risk management process, the system performance monitoring, the  
procedure situation and the monitoring and, respectively, information to the Director  
General.  
- Centralizes, by means of the technical secretariat provided by the Management Systems  
and Managerial control Department, the significant risks in the Risk Registry of CONPET  
S.A., based on the identification of risks by the risk management teams at divisions,  
departments and offices directly subordinated to the Director General.  
- Analyzes and gives priority to significant risks, that might affect achieving the objectives  
of CONPET S.A., by establishing the risk profile and risk tolerance.  
- Analyzes and endorses annually the risk profile and the risk tolerance limit proposed by  
the technical secretariat based on the Risk Registry within CONPET S.A. and submits to  
approval of the Director General.  
- Analyzes the annual plan of implementation of the control measures for the significant  
risks within CONPET S.A., drafted by the technical secretariat and submits to the approval  
of the Director General.  
- Drafts, through the technical secretariat, annual information to the Director General,  
approved by the President of the Monitoring Committee, on the deployment process of  
risk management and monitoring of performance at CONPET SA, based on reports from  
the directorates, departments and bureaus directly subordinated to the Director General.  
- Analyzes the annual Report on internal control management system and submits it for the  
approval to the Director General.  
- Analyzes and endorses the Report on the stage of implementation of the actions of the  
Program for the development of the internal control management system, elaborated  
according to the provisions of the operational procedure "Monitoring and reporting of key  
performance indicators.  
The Commission shall cooperate with all organizational entities so as to implement and  
develop the internal control management system. Each member of the Monitoring Committee  
is responsible for fulfilling the tasks from the development program of the internal control  
management system and for compliance with established deadlines.  
The Internal Public Audit Office shall advise the Monitoring Commission and attend its  
meetings. The Internal Public Audit Bureau monitors the activities of the Monitoring  
Commission and regularly informs the Director General on the activity of the Monitoring  
Committee and the problems they are facing and which may affect the process of  
implementing and maintaining the internal control management system.  
The Development Program of the internal control management system of CONPET is  
analyzed annually, on the self-evaluation of the implementation degree, according to  
O.S.G.G. no. 600/2018. The development program of the internal control management  
system of CONPET S.A. for 2023 has been approved by the Director General.  
According to the provisions of the system procedure “Setting the objectives of CONPET  
S.A.”, specific SMART objectives have been defined and approved for 2024, at the level of  
all organizational entities. During 2024, some of the specific objectives were revised because  
of changing the assumptions/premises underlying their formulation.  
21  
In 2024, meetings of all risk management teams (EGR) were held, in which each team  
reassessed the risks corresponding to the established objectives and analyzed the status of  
implementation of control measures. Control measures have been proposed to mitigate risks,  
as well as deadlines for their implementation, according to the provisions of the system  
procedure "Risk management". The significant risks and their control measures were the  
subject of debate within the meetings of the Commission for the monitoring of the internal  
control management system.  
Following these sessions, the risk profile at CONPET S.A. level is as follows:  
- 121 tolerable risks (with exposures from 1-4);  
- 75 high tolerability risks (exposure between 5-8);  
- 9 low tolerability risks (exposure between 9-12);  
- 0 intolerable risks (exposure 15-25).  
The risk profile at CONPET S.A. in 2024 as compared to 2023 and 2022, is as follows:  
Chart 10 - Risk profile CONPET SA- comparative presentation 2022-2024  
The Technical Secretariat of the Monitoring Committee has drafted the Significant Risk  
Registry within CONPET S.A. (with a tolerance level higher than or equal to 9). The actions  
to deal with significant risks were centralized and the Annual Plan for the implementation of  
control measures for significant risks was developed.  
Based on the Risk Register at CONPET level and the methodology established by the system  
procedure "Risk Management", the risk tolerance limit at CONPET S.A. level for 2024 is  
exposure maximum 12, the risk appetite being at a medium level. The management of the  
company does not tolerate risks with exposure higher than 12. If the exposure of a risk  
increases above the tolerance limit, the Monitoring Commission shall meet for an  
analysis/proposal of urgent measures. Following the risk analyses carried out during 2024,  
no intolerable risks were identified.  
In 2024, all the actions included in the development program of the internal control  
management system at CONPET S.A. have been made within the deadlines set in the  
program.  
22  
Following the self-assessment of the internal control management system in  
accordance with OGSG no. 600/2018, it has been declared compliant on 31.12.2024  
with all 16 implemented standards.  
The results of the self-assessment and the details regarding the stage of implementation and  
development of the internal control system were included in the Report on the managerial  
internal control system and in the centralizing situation regarding the stage of  
implementation, on December 31, 2024 (Annex no.4). These reports were also  
communicated to the tutelary authority.  
The maintenance and improvement of the integrated management system  
Certification of the Integrated management system quality - environment - occupational  
health and safety was held for the first time in September 2007 with recertification every  
three years.  
In September 2016 the energy management system certification took place, implemented  
and integrated with previous management systems.  
Following the external recertification audit, carried out by the BUREAU VERITAS body, in  
September 2022, the certificates for the management systems of quality, environment, health  
and safety at work and energy were issued:  
- Certificate no. RO22. RO22.4340383Q, in accordance with the requirements ISO  
9001:2015;  
- Certificate no. RO22. RO22.4340383E, in accordance with the requirements ISO  
14001:2015;  
- Certificate no. RO22. RO22.4340383S, in accordance with the requirements ISO  
45001:2018;  
- Certificate no. CZE - 2200254, in accordance with ISO 50001:2018 requirements.  
Between 16 and September 20, 2024, the external surveillance audit took place for the  
management systems of quality, environment, health and safety at work, energy, according  
to the requirements of ISO 9001:2015, ISO 14001:2015, ISO 45001:2018 and ISO  
50001:2018, audit performed by the BUREAU VERITAS certification body.  
Following the external surveillance audit for the management systems of quality,  
environment, occupational health and safety, energy, no non-conformities were identified.  
The audit team of the BUREAU VERITAS body concluded that the organization CONPET  
S.A. has established and maintained an integrated management system in accordance with  
the requirements of the reference standards and has demonstrated its ability to meet the  
requirements according to the policy, objectives and scope of the organization. As a result,  
the certification body BUREAU VERITAS recommended maintaining the certificates for  
quality, environment, occupational health and safety and energy management systems,  
issued for the organization CONPET S.A.  
Starting 2010, within CONPET S.A. the railway safety management system is being  
implemented and maintained in accordance with the national legal requirements on railway  
safety, in compliance with the national legal requirements on rail safety and the reference  
European directives. The field of application of this system includes railway ramps where  
CONPET carries out railway shunting, for which the company holds the “License for the  
23  
performance of rail transport services (railway shunting)”, granted by the Romanian Railway  
Authority (AFER)  
Also, for the railway ramps where CONPET S.A. only performs railway shunting in its own  
interest/for third parties/on an industrial railway line that is not the property of the company,  
the Romanian Railway Safety Authority (A.S.F.R.) issued the Single Safety Certificate, in  
accordance with the provisions of the Order of the Minister of Transport, Infrastructure and  
Communications no. 743/ 2020 for the issuance of the single safety certificate to operators  
who only carry out railway shunting on Romanian railways. The certificate is updated  
whenever CONPET S.A. requests the amendment of Annex B containing the list of motor  
railway vehicles with which the company carries out the railway shunting.  
On 31.12.2024, the Single Safety Certificate No. OMF 2024007 is in force, valid until  
20.09.2025.  
Starting January 2021, within CONPET the anti-bribery management system  
implementation program has been deployed, as required by SR ISO 37001:2017, program  
which finalized in June 2022.  
In July 2022, following the external audit performed by the certification body SRAC CERT,  
the following certificates have been issued:  
- SRAC nr.28/13.07.2022;  
- IQNet nr. RO-0028/13.07.2022  
asserting compliance with the requirements of the anti-bribery management system  
implemented by CONPET S.A. in compliance with the requirements of ISO 37001 standard.  
Following the external surveillance audit of June 2024, the SRAC CERT certification body  
recommended maintaining the compliance certificate no. 28/13.07.2022 for the anti-bribery  
management system implemented in the CONPET S.A. organization.  
In order to determine the effectiveness of the integrated quality - environment - health and  
safety - energy and railway safety management system, in May 2024 the Management  
Analysis no. 32 was carried out.  
All the actions included in the Action Plan of AEM 32 have been implemented.  
Within the energy management system, the energy objectives and targets for the year 2024  
were established as follows:  
Energy objective 2024  
Energy target 2024  
O1: Maintaining energy efficiency for electricity O1/T1: Maintaining the annual average of the specific  
use.  
technological consumption of electricity in the Transport  
Operations Unit at a maximum level of 3.2 KWh/ton  
produced.  
O1/T2: Maintaining the electricity annual average  
consumption in Conpet administrative buildings at the  
level of the reference period 2019.  
O2: Increasing energy efficiency for the uses  
of natural gas.  
O2/T1: Reducing natural gas consumption at CONPET  
as compared to the reference period 2019.  
O3/T1: Reduction of specific diesel consumption for the  
rail shunting within CONPET as compared to the 2019  
reference period.  
O3: Increasing energy efficiency for uses of  
diesel.  
24  
Energy objective 2024  
O4: Increasing energy efficiency for the uses  
of automotive fuels.  
Energy target 2024  
O4/T1: Maintaining the auto fuel consumption in  
CONPET as compared to the reference period 2019.  
O5/T1: Maintaining water consumption at CONPET  
level, for every location by the observance of the Water  
Management Rights Permit.  
O5: Increasing energy performance for the  
uses of water  
Table 10 - Energy objectives and targets 2024  
In order to meet these targets, was developed and approved the document: “Action plan for  
achieving 2024 energy objectives and targets”.  
The status of the actions included in this plan will be reported by the Energy Manager in the  
next management review meeting, which will review the entire year of 2024.  
The internal audit of the integrated qualityenvironmentoccupational health and safety  
management system and the railway safety management system shall provide information  
regarding the compliance with the requirements of the references and applicable legal  
requirements. Internal audits are also aimed at assessing the effectiveness and continuous  
improvement of the implemented management systems.  
The internal audits were conducted in accordance with the approved program for the year  
2024 and the audit criteria established in the audit plans. The results were communicated to  
the audited people by distributing the audit reports, to which were attached reports of non-  
compliance and corrective action opened during audits. The company annually provides  
resources to develop adequate internal audit, mandatory requirement of the reference  
standards SR SR EN 9001:2015, SR SR EN ISO 14001:2015, SR ISO 45001:2023, SR EN  
SR 50001: 2019 EN ISO 37001:2017, as well as the regulations on railway safety.  
4.1.9 Risk management  
Within CONPET S.A. the Internal Control Management System has been implemented and  
developed, containing the 16 standards included in the Internal control management code of  
the public entities.  
Implementation of the requirements of standard no. 8 "Risk management" was a priority, by  
documenting and applying the provisions of the "Risk Management" process documents  
(process sheet, flow diagram and system procedure).  
In 2024 have been identified, assessed/reassessed and centralized risks that may affect the  
achievement of objectives. At CONPET level, a significant risk register (with exposure level  
equal to or higher than 9) and an annual plan containing measures to control significant risks,  
responsible and timeframes for the measures were developed.  
In paragraph 4.1.8 “The development of the internal management control system” includes  
detailed information on risk management in 2024 within CONPET SA..  
During 2024, the executive management developed the "Risk Management Policy", through  
which the company's top management commits to:  
- Develop a culture of risk-based approach in all its processes and decisions and encourage  
immediate reporting of any new risks identified by any employee.  
- Establish, maintain and document appropriate risk assessment methods, plan and monitor  
significant risk control measures.  
25  
 
- To allocate necessary resources for risk management, namely resources for staff  
training/instruction/awareness and resources for implementing approved measures to  
address risks.  
- Establish clear responsibilities of personnel involved in risk management.  
- To systematically report relevant risk management data to stakeholders.  
The "Risk Management Policy" was approved by the Decision of the Board of Directors of  
CONPET S.A. no. 22/ 29.10.2024 (art. 1) and was posted on the company's website, to be  
available to relevant stakeholders.  
As regards the risks which may affect the strategic objectives of CONPET S.A., the updated  
information for 2024 is the following:  
- Operational risk  
Operational risk comes from the Degradation of the National Pipeline Transport System  
(NTS) due to the low level of utilization (small quantities, reduced frequency) and the potential  
escalation of the criminal acts related to pipeline attacks bearing significant impact on the  
National Transport System via pipelines and the environment and the impossibility to carry  
out railway transport schedules for reasons exclusively related to the railway operator.  
In order to control these risks, measures have been established such as: redefining the  
transport infrastructure according to the demand perspective, extending the implementation  
of the pipeline leak detection and location system, calculating penalties according to the  
contract or purchasing the rail transport service with another railway operator for routes on  
which the pipeline transport program is not achieved.  
- The Market Risk  
The market risk stems from the fact that the company is not interconnected to other transport  
systems in the region, being strictly dependent on the level of crude oil processing in  
Romanian refineries.  
With the support of the main shareholder, the Ministry of Energy , and the Activity Regulatory  
Authority (National Agency for Mineral Resources A.N.R.M.), CONPET is making efforts to  
identify new opportunities that will lead to increasing the use of the system, while getting  
involved in regional projects started in its industry, as well as in developing activities related  
to the core business (provision of crude oil storage services/petroleum products, provision of  
crude oil transport services with own road tankers etc.).  
- Credit Risk  
Credit risk is the risk that the company bears the financial loss due to the failure of contractual  
obligations by a customer or counterpart to a financial instrument, and this risk results mainly  
from trade receivables, cash and cash equivalents and short-term investments of the  
company.  
The company is less exposed to this risk due to the specific nature of the services sold, which  
are aimed at large companies with a particular financial situation.  
26  
The company has implemented a series of policies that ensure that the sale of services are  
made to customers with a rapid collection. The value of net claims (without adjustments for  
depreciation) represents the maximum amount at risk of collection.  
Credit risk related to trade receivables is low because of the regular collection of counter  
transport services and guarantees received from customers (letters of guarantee). Even  
though there is significant concentration, the customer base is extremely low, the  
management considers that the commercial credit risk is low.  
- Risk related to the regulation and authorization  
It is identified whenever the company must obtain and periodically renew a series of  
approvals, authorizations, obtain certificates and attestations. The company is subject to a  
large volume of regulations in various fields, which can lead to additional expenses and  
delays in starting or completing works, with possible negative effects on achieving objectives.  
The regulatory framework from the point of view of environmental protection applicable to  
CONPET S.A. is complex due to the activity of crude oil/ condensate/ transport gas via  
pipelines and railways and, for good compliance all applicable legal requirements and how  
to implement them have been identified in separate registers elaborated on environmental  
factors (water, soil-basement, air, protected areas), regulations (permits), SEVESO, waste.  
Controlling the risk related to the regulatory framework is done by closely monitoring newly  
emerged legal requirements or changes in applicable regulations, as well as by implementing  
the necessary actions to comply with them. It is also considered to develop and submit  
proposals for amendments appropriate to the framework in which CONPET operates, when  
draft regulations are under public debate.  
- LIQUIDITY RISK  
The liquidity risk is the Company’s risk of facing difficulties in the achievement of the liabilities  
associated with the financial debts that are being settled in cash or by the transfer of other  
financial assets.  
The liquidity risk is managed by the Company’s management by the application of a  
permanent insurance policy of liquidity meant to cover the settlement of the due financial  
liabilities.  
- Exchange Rate Risk  
The company may be exposed to fluctuations in the exchange rate of the currencies by  
means of cash and cash equivalents, short-term investments, long-term loans or trade  
liabilities expressed in foreign currencies.  
The functional currency of the Company is the Romanian Leu. Currently, the company is  
exposed to currency risk through purchases made in a currency other than the functional  
one. The currencies exposing the Company to such a risk are mainly EUR, USD and GBP.  
The debts in foreign currency are subsequently expressed in RON, at the exchange rate of  
the date of the balance sheet, communicated by the Romanian National Bank. The resulting  
differences are included in the profit and loss account, but do not affect the cash flow up to  
the moment of the liquidation of liability.  
27  
The Company’s exposure to the exchange rate risk expressed in RON was insignificant. The  
level of this risk analyzed was negligible; it is a tolerable risk for which no necessary special  
measures are needed to keep it under control.  
- Risk related to significant environmental aspects  
The risk related to significant environmental aspects comes from the production of  
technical/caused damage, which can lead to pollution with significant impact on the  
environment.  
This risk shall be contained by developing, implementing and monitoring environmental  
management program, which include appropriate actions to control significant aspects of the  
environment, including major-accident hazards involving dangerous substances.  
- Risk of disputes  
The risk related to litigation is one of the important risks to which the company is currently  
exposed, as concessionaire of the National Crude Oil, Rich gas, Ethane and Condensate  
Transport System, having as source the legal regime of the lands under/over crossed by the  
major transport pipelines established by the provisions of the Petroleum Law no. 238/2004.  
The number of private properties under/over crossed by pipelines is very high and there is a  
possibility that more and more owners bring proceedings in Court against the Company in  
order to obtain substantiated compensations based on the simple presence of the pipelines  
on their lands.  
Due to the defective way in which the legal regime of the lands under/over crossed by the  
major transport pipelines has been regulated, CONPET was and currently is engaged in a  
series of trials where the owners of those lands claim for the transport pipelines be either  
lifted, or moved to other sites (and the expense be borne by CONPET), or be granted annual  
compensations representing consisting amounts of money. Moreover, even some public  
authorities have laid pecuniary claim about the presence of components belonging to the  
NTS on the lands owned or managed by them.  
Within the last years, the Company has prepared various legislative proposals to amend Law  
no 238/2004 - Petroleum Law, hoping for a coherent and clear regulation of the legal regime  
of lands under/over crossed by the transport major pipelines. Essentially, these proposals  
are based on the following assumptions:  
- public property (over the major pipelines) must coexist with private ownership of land,  
which leads to the conclusion that the state must be acknowledged the exercise, free of  
charge, of certain categories of real rights (servitudes etc.) for the presence of the pipes  
on the ground;  
- CONPET must fully compensate the landowner for any action that would require  
temporary occupation of land for repair or damage suffered by owners due to damage.  
- The Risk Determined by the Correlation with the Global Market Evolution  
The geopolitical tensions in the Middle East, amplified by the conflicts between Israel and  
Iran, as well as by groups supported by this state, such as Hamas and Hezbollah, add  
significant risk to oil prices. In addition, uncertainties surrounding the re-election of Donald  
Trump as US president are increasing oil market volatility.  
28  
While there is no certainty about what specific policy measures might be implemented, some  
of these could have contradictory effects on oil supply and prices.  
The war in Ukraine has prompted a global reassessment of energy security. States have  
begun to rethink their energy strategies, not just for oil, but also for natural gas, coal, and  
renewable energy sources.  
In the European Union, energy security has become a strategic priority, spurring the  
acceleration of renewable energy projects and the expansion of liquefied natural gas (LNG)  
infrastructure, thus reducing dependence on Russian energy resources.  
Another key factor is China's role as the main buyer of Russian oil. After many Western  
countries stopped importing oil from Russia, China took advantage of lower prices, and its  
crude oil imports increased considerably. This has allowed Russia to maintain its oil export  
revenues, bypassing traditional Western markets. The growing economic ties between  
Russia and China, particularly in the energy sector, could significantly influence the global oil  
market in the long term, especially if China continues to reduce  
its reliance on the US dollar in its trade transactions.  
Overall, these interconnected factors have significantly increased uncertainty and risks for  
the oil market.  
In December 2024, oil prices fluctuated in a stable range, with investor sentiment influenced  
by the prospects of possible higher taxes in the United States and a relative balance in the  
market for 2025. The forecast for Brent oil prices suggests a gradual decline, from  
81USD/barrel in 2024 to 74USD/barrel in 2025 and 66USD/barrel in 2026, as a result of  
increased global production and weaker demand. At the same time, OPEC+ production will  
remain restricted to prevent a too sharp decline in prices, and investors in the United States  
may reduce drilling activity due to low prices.  
Oil prices fell by about 3% in 2024, marking the second consecutive year of decline, as the  
post-pandemic global demand recovery faced difficulties. Factors contributing to the decline  
include China’s sluggish economy and rising crude production in the United States and other  
non-OPEC countries, which kept the global market well supplied. On the last trading day of  
2024, Brent futures closed at 74.64USD/barrel, down about 3% from the 2023 closing price  
of 77.04 USD/barrel. U.S. West Texas Intermediate (WTI) crude ended the year at  
71.72USD/barrel, almost unchanged from the previous year’s close.  
In September 2024, Brent futures fell below 70USD/barrel for the first time since December  
2021, reflecting a general cooling in prices as post-pandemic demand began to decrease.  
Oil price forecast for 2025 points to weak demand from China and rising supply. A Reuters  
poll expects oil prices to hover around 70 USD/barrel in 2025, amid weak demand from China  
and rising global supply, which will counter OPEC+’s efforts to stabilize the market. Both the  
Organization of the Petroleum Exporting Countries (OPEC) and the International Energy  
Agency (IEA) have revised downward their oil demand growth forecasts for 2024 and 2025,  
due to a weaker economic outlook in China. The IEA expects a surplus of oil on the market  
until 2025, despite OPEC’s decision to postpone production increases until April 2025. The  
EIA forecasts Brent crude oil prices to be 74USD/barrel in 2025, similar to 2024 levels.  
29  
Record US oil production has also had an impact on prices.  
In October 2024, US oil production reached a record high of 13.46 million barrels per day  
(bpd), and estimates point to an increase to 13.52 million bpd in 2025, according to the US  
Energy Information Administration (EIA).  
In parallel, the global transition to renewable energy sources, such as solar and wind, is  
placing increasing emphasis on the development of efficient energy storage solutions. These  
sources are intermittent and require advanced technologies to ensure a continuous and  
stable supply. Energy storage technologies, including batteries, hydrogen and thermal  
storage, will play a crucial role in balancing supply and demand, ensuring the reliability of  
electricity grids.  
The sanctions imposed on Russia had a profound impact on the global oil market, with  
significant implications for trade flows and prices. In particular, the sanctions imposed by the  
G7 and other Western states in response to the conflict in Ukraine have reshaped the  
structure of the global energy market.  
The impact of the Russia-Ukraine conflict has led to a considerable revision of energy  
strategies and policies worldwide, prompting states and companies to reassess their  
dependence on traditional energy sources and accelerate the transition to more sustainable  
alternatives. In South-Eastern and Southern Europe, the ban on oil transport via the Druzhba  
pipeline has not had a significant impact on the refineries in Ploiesti and Burgas, which  
continue to be supplied exclusively via the Black Sea terminals.  
Another important aspect was the significant progress in negotiations between Georgia and  
Kazakhstan for an agreement to allow the transport of Kazakh oil via the Baku Tbilisi –  
Ceyhan (BTC) pipeline to the European market. This development is crucial in the current  
geopolitical context and for the diversification of energy sources, thus strengthening  
Georgia's position as an energy transport hub in the region. The Western Route Export  
Pipeline, the first built since the collapse of the USSR, allows Azerbaijani oil to bypass Russia  
and reach Europe.  
In parallel, regional economic trajectories are increasingly divergent, and the rapid  
implementation of clean energy technologies is contributing to a slowdown in oil demand  
growth. Global oil demand is expected to plateau in the final years of the forecast, until 2030.  
In this context, emerging economies in Asia, especially China and India, are the main drivers  
of demand growth, in contrast to the significant decline in demand in advanced economies.  
These trends highlight the need for continued strategic adjustments in global energy markets.  
Impact on the activity of CONPET S.A.  
CONPET S.A. watches carefully the evolution of the conflict in Ukraine and analyzes the  
possible consequences of sanctions and counter sanctions associated with it. The company  
is constantly reviewing the potential impacts on its operations, considering the current  
volatility and geopolitical risks.  
Continued disruptions or escalation of commodity flows from Russia to Europe could lead to  
further price increases in the European region, and this remains a major concern.  
In the short term, the company's activity has not experienced significant disruptions, and the  
30  
transport and delivery infrastructure has been adapted to maintain operational stability.  
However, the medium and long-term impact of the conflict and the sanctions imposed on  
Russia remains difficult to accurately estimate. Given that part of CONPET S.A.'s operations  
depend on areas affected by sanctions, including activities related to Russia, the company  
continuously analyzes possible scenarios and risks.  
At the same time, CONPET S.A. identifies factors that suggest a stable continuation of the  
activity, even in the face of external uncertainties. Adaptability and diversification of  
operations are key elements for maintaining stability in the face of economic and geopolitical  
changes. In this context, the company anticipates that the impact on it will be minimal, and  
the adjustment plans will allow the continuation of the activity in an efficient and sustainable  
manner in the long term.  
- The Capital Market Risk  
The Romanian capital market registered a positive evolution during the year 2024, continuing  
the positive upward trend started at the time of evolution to the emerging market status.  
The daily average liquidity for all types of financial instruments has recorded an upward trend  
during the analyzed period. Romania’s representativity within the indexes of Emerging  
Markets has improved significantly from year to year. Given that the company CONPET S.A.  
is included in the composition of the FTSE Global Microcap index, the risk of reduced liquidity  
is diminished.  
- Legislative-related Risks  
The frequent amendment of the normative acts, here included those that bear direct impact  
on CONPET business, may trigger risks for the company.  
The effort of the company CONPET to constantly adapt to changing legislative requirements  
may generate additional costs and possible future changes in the legislative framework could  
have negative effects on the activity and profitability of CONPET (increased taxes,  
introduction of new taxes and duties, reduction or suspension of tax concessions, etc.).  
Specifically, the changes in tax legislation, consisting of increasing the level of the royalty  
paid for the use of the National Transport System and the payment of an additional tax on  
the income generated by oil companies, led to an increase in transport tariffs and,  
subsequently, the consequences can also be found on the pump price of finished products  
resulting from the processing of crude oil.  
An important risk is being represented by the loss of the facility regarding the expenses borne  
by the Romanian State in order to provide the guard and protection of the pipelines by  
gendarmes, regulated by the GD. no. 1107 dated November 14, 2012, which amends and  
complements GD no. 1486/2005.  
- Personnel Risk and the Waging System  
On December 31, 2023, the structure according to age is not balanced, the age category  
with the highest rate ratio in the company is ranging between 51 - 60 years old (53.65%) and  
between 41-50 years old (24.89%).  
31  
The mean age of the company CONPET personnel is high (50 years old) and the advantage  
it brings is the work experience accumulated by employees within the company, which  
indicates stability and professionalism. The mean age of the personnel employed within the  
last two years is 40 years, with an average work experience of 14 years.  
Chart 11 - Personnel structure by age groups in 2024  
However, the risk of personnel in the future is the company to deal with staff shortages due  
to departures of the employees reaching retirement age.  
The level of this risk analyzed was low, a risk with high tolerability for which measures to  
keep it under control are established in the medium and long term through personnel policy  
and monitoring of personnel fluctuation (inflows/outflows).  
The main potential risks in the social and Salary field relate to:  
- lack of qualified personnel in order to ensure the continuity of certain activities (e.g. staff  
with responsibilities in traffic safety) in the case of departures from the system;  
- constraints and budget limitations that can restrict the initiation/development of projects in  
the field of human resources;  
- high personnel fluctuation, decreased rate of retention of newly hired personnel or  
occupying key positions.  
32  
Chart 12 - Personnel structure by studies and age groups in 2024  
In terms of level of education, the highest share is for the employees who have medium and  
higher education and ages ranging from 41 to 60 years old.  
It should be noted that the age group of 41-50 years is relatively well represented by the  
scale of employees who will reach the standard retirement age in at least 12 years and a  
maximum of 25 years, and about 80.6 % of this echelon has a seniority in society of more  
than 10 years.  
In this regard, the immediate needs for filling vacancies should be carefully monitored in  
relation to the needs required by organizational entities, the complexity and diversity of  
activities, the professional skills required, as well as the responsibilities associated with the  
positions.  
4.1.10 Internal and external audit  
Internal audit  
The internal public audit activity within CONPET S.A. is organized at the level of the Internal  
Public Audit Office and is carried out in accordance with the provisions of Law no. 672/2002,  
on internal public audit, republished, Government Decree no. 1086/December 11, 2013 for  
the approval of the General Norms regarding the exercise of the internal public audit activity,  
O.M.F.P. no. 252/2004 for the approval of the Code regarding the ethical conduct of the  
internal auditor, GEO no. 109/2011 regarding the corporate governance of public enterprises,  
updated, as well as the own methodological Norms regarding the organization and exercise  
of the internal public audit activity within CONPET S.A. and the Internal Audit Charter  
applicable at the company level, harmonized with the provisions applicable to internal audit  
in the public and private system. The Internal Public Audit Office is functionally and  
administratively subordinated to the Director General and functionally to the Board of  
Directors (through the Audit Committee).  
The internal public audit activity in 2024 was performed based on the revised Internal Public  
33  
 
Audit Plan endorsed by the Audit Committee and approved by the Director General of  
CONPET SA..  
The core component of the system for reporting the results of internal audit activity is  
represented by the internal audit reports, which are compiled at the end of each completed  
mission and are endorsed by the Director General. The reports include the findings,  
conclusions and recommendations made by the auditors in order to improve the audited  
activities, as well as their opinion in relation to the level of functionality and efficiency of the  
internal control system attached to the areas assessed. The audit team made up of 4 (four)  
internal auditors annually produces the report on the internal public audit activity carried out  
at company level, report subject to the endorsement of the Audit Committee and the approval  
of the Director General.  
In 2024, 6 assurance audit missions were carried out, o/w: one on information technology,  
four on compliance and one system audit, framing in the areas "information system",  
"strategic projects and European funds", "revenue generation", "human resources",  
"communication and corporate governance", "procurement of goods and services" and 11  
recommendations were formulated. At the same time, an informal advisory mission was  
carried out in the field of "Information Security", following which proposals for solutions were  
formulated.  
The missions carried out in accordance with the Internal Public Audit Plan 2024, revised,  
approached the following topics:  
- The adequacy of the Enterprise Resource Planning (ERP) solution within CONPET S.A.;  
- Management of development opportunities at CONPET S.A.;  
- Evaluation of the conclusion of crude oil transport contracts within CONPET S.A.;  
- Development, approval and application of the Internal Regulations;  
- Conformity of CONPET S.A. to capital market requirements;  
- Implementation of the annual public procurement program.  
The informal advisory mission had as scope:  
- Compliance with Legal Requirements in the Field of Information Security  
The recommendations formulated during 2024 and the previous year by the internal auditors  
have been implemented or are in the process of being implemented by the audited structures  
within the established deadline; there have been no cases of obsolescence of the  
recommendations formulated by internal auditors and no cases of unappropriated  
recommendations have been recorded. The Internal Public Audit Office permanently  
monitors the implementation status of the recommendations and reports semi-annually to the  
Director General and the Audit Committee on the status of unimplemented and ongoing  
recommendations.  
External audit  
The 2024 annual financial statements were audited by the independent financial auditor PKF  
Finconta S.R.L., appointed by the OGMS Resolution no. 6 dated 28.10.2022 for a period of  
3 years.  
34  
4.1.11 Assessment of human resources and social dialog activity  
Personnel structure  
The effective number of employees on December 31, 2024 was 1,398 persons.  
Following the adoption of certain measures meant to resize the human resource, as well as  
of certain voluntary, or triggered to other causes personnel termination, the effective number  
of employees on December 31, 2024 decreased by 59 persons as compared to December  
31, 2023.  
The evolution of personnel structure by education categories reveals the interest of the  
company in covering the staff needs with high qualification specialists and by the continuous  
improvement of the existing staff.  
On December 31, 2024, the number of higher education employees decreased to 555 people  
compared to 563 at the end of 2023, while the number of employees with secondary and  
general education decreased from 894 people to 843 people, for the same time period.  
% in total  
employees  
% in total  
employees  
% in total  
employees  
Studies  
General  
Total  
Women  
Men  
83  
5.9%  
54.4%  
7
0.5%  
5.1%  
76  
5.4%  
49.3%  
24.8%  
79.5%  
760  
555  
71  
209  
287  
689  
346  
Secondary education  
Higher education  
Total  
39.7%  
14.9%  
20.5%  
1,398  
100.0%  
1,111  
Table 11 - Personnel structure by education level and gender on December 31, 2024  
The evolution of the personnel structure by education and gender categories reveals that the  
company promotes non-discriminatory behavior by hiring female specialists with higher  
education and professional skills who contribute to increasing the company's activity results.  
Chart 13 - Evolution of the personnel structure by level of studies between 2014 -2024  
The personnel with managerial positions account for 5.3% in the total number of employees  
and the executive personnel amounts to 94.6%. Of all employees with managerial positions,  
32% is represented by female persons.  
In 2024 the structure of employees by categories was the following:  
35  
 
- General service 113 employees;  
- Indirectly productive 198 employees;  
- Administrative 255 employees;  
- Technically productive 318 employees;  
- Directly productive 514 employees.  
Chart 14 - The structure of employees by categories in 2024  
The degree of unionization of the workforce at the end of 2024 is 98.49%. During 2024, there  
have been no elements of conflicting nature between employees and the management of the  
company.  
Aspects regarding the Collective Labor Agreement  
Since the Collective Labor Agreement ceased to be applicable on 07.06.2024, the Board of  
Directors mandated the executive management to start the negotiation procedures of a new  
Collective Labor Agreement.  
Between April and May 2024, negotiation meetings took place, which resulted in the  
conclusion of a new collective labor agreement applicable starting from 07.06.2024.  
The Collective Labor Agreement is concluded for a period of 2 years, starting with  
07.06.2024.  
In application of the approved Collective Labor Agreement, 5 protocols were concluded in  
the year 2024.  
Professional Training and Authorization Activity  
In order to maintain and/or develop specific skills and basic abilities of the human capital, the  
training activities are carried out on an ongoing and planned basis, based on the professional  
training and authorization programs of the company, following the identification and  
prioritization of the training needs of CONPET S.A. personnel.  
Training of company personnel is achieved mainly through participation in external courses,  
organized in collaboration with certified trainers for all fields of activity within the company.  
Also, training is conducted internally by trainers and/or experts of the company, with a good  
knowledge and experience relevant to the activity of the company. They support professional  
training sessions and training courses with the aim of updating job-specific knowledge and  
36  
skills, as well as examining or checking the employees participating in the respective  
sessions.  
The training of the employees has two components: professional (technical, economic and  
other specialties) necessary to perform duties in the job description and a general one on  
training and/or professional licensing in various fields.  
CONPET S.A. management assures annually, by the Revenues and Expenditure Budget,  
sources for the provision of training. Special attention is paid to the training of technical staff  
(maintenance and operations), mainly for acquiring new skills necessary to carry out the safe  
operation of the National Transport System.  
Chart 15 - Type of professional training and authorization in 2024  
Number of participations  
2024 2023 2022  
111 106 119  
Crt.  
No.  
Type of professional training/authorization  
1
Various fields authorizations (specific per activity)  
2
3
4
5
Railway authorizations  
Training  
372  
371  
376  
464  
251  
413  
Internal authorizations  
Qualifications/internal instructions  
428  
407  
450  
2,327  
1,345  
1,167  
6
Total number of training courses/authorizations  
3,609  
2,698  
2,400  
Table 12- Structure of training/professional authorization courses in 2022 -2024  
The situation of professional training expenses made during 2022 - 2024 is presented as  
follows:  
Indicators  
2024  
317  
2023  
228  
2022  
188  
Authorization courses  
Training courses  
266  
365  
401  
Total personnel training expenses  
583  
593  
589  
Table 13 - Expenses for training and professional authorization of personnel 2022- 2024 (thousand RON)  
The training and professional authorization activities of the company’s employees for 2022 -  
2024 were carried out by framing within the approved revenues and expenditure budget.  
37  
Regulation on the assessment of the professional performance of CONPET S.A.  
employees  
The professional performance evaluation of CONPET S.A. employees is carried out in  
accordance with the Regulation on the evaluation of individual professional performance of  
Conpet employees - Annex to the Internal Regulation.  
The Regulation is in line with the provisions of the GSG Order no. 600/20.04.2018 approving  
the Code of Internal Control Management, Law no.53/2003 republished - the Labor Code, as  
well as with the Board of Directors requests, that focus on individual professional  
performance, a basic principle in labor relations.  
The action for assessing the professional performance of employees for the activity carried  
out in 2023 took place in 2024Q1, in accordance with the Regulation for assessment of the  
performance of the employees.  
After the centralization and processing of the information resulting from the evaluation of the  
professional performance of the employees for the activity carried out in 2023, the evaluation  
report of the performance of the employees was drawn up and submitted to the management.  
The assessment report includes the results obtained by the employees following the  
performance of their evaluation, inclusive of the degree of achievement of the SMART  
individual performance objectives of the employees occupying management positions.  
The evaluation of the professional activity of employees for 2024 will be carried out in the  
first quarter of 2025.  
At the end of 2024, addenda to the individual employment contracts were concluded for the  
employees with management positions, which contain individual objectives, performance  
indicators, target values and their associated weights for the activity from the year 2025.  
4.1.12 Analysis of the HSEQ activity  
Identification of the environmental aspects and environmental impact assessment  
The environmental impact assessment activity is carried out in the production sectors  
whenever changes occur in the system involving environmental impact activities, the list of  
significant impact issues identified at company level being the basis for the development of  
the Environmental Management Programme and the Action Plan for the achievement of  
environmental objectives.  
During 2024 environmental aspects were reviewed at the site level, focusing on identifying  
environmental aspects, including, how risks and opportunities related to environmental  
aspects are treated to prevent and limit their consequences on human health and the  
environment, using opportunities both for the benefit of the organization, and, as well as the  
environment. The following documents have been reviewed:  
- Registers of environmental legal requirements for the water and air environmental factor;  
- Register of Environmental Legal Requirements regulations;  
- Register of Environmental Legal Requirements waste;  
- Register of Environmental Legal Requirements protected areas;  
- The Environmental and Actions Management Program containing: the commitments  
associated to the environmental policy, general objectives and measurable environmental  
38  
 
targets, the performance indicators on environmental protection, the positions responsible  
for the achievement of the environmental targets; as well as actions to achieve  
environmental objectives, which took into account the significant environmental aspects  
identified at the level of CONPET S.A., the measures in the inspection reports/ minutes-  
authorities on compliance with legal requirements and other applicable requirements;  
- The list of significant environmental aspects and associated impacts generated at the level  
of CONPET S.A. company.;  
- Register of environmental opportunities.  
The status of achievement of the objectives and targets set and the stage of the  
implementation of the actions set for the achievement of the environmental objectives are  
analyzed annually by the executive management, in the framework of the analysis carried  
out by the management.  
Regulation of activities in terms of environment and water management  
In terms of environmental protection and water management, CONPET S.A. activity is  
authorized in accordance with the provisions of GEO 195/2005 on environmental protection,  
as supplemented and amended and Water Law no.107/2005, with subsequent amendments  
and additions.  
CONPET S.A. activity is authorized in all counties by the regulatory authorities  
(A.N.P.M./National Agency for Environmental Protection, county A.P.M./Agency for  
Environment Protection, A.N.A.R./National Administration „Romanian Waters”, A.B.A./Water  
Basin Administration, S.G.A./Water management Unit), holds 38 water management  
authorizations and 22 environmental authorizations.  
For the legal operation from the environmental protection point of view, for the year 2024, the  
annual visas of the environmental authorizations were obtained. Furthermore, there have  
been revised:  
- Environmental Permit for pipeline transport in Constanta County;  
- Environmental Permit for crude oil transport pipelines Ø10" Ghercești - Icoana - Cartojani  
and transport pipelines Ø12", Ø14" Cartojani-Ploiești, on the territory of Dolj, Olt, Argeș,  
Teleorman, Giurgiu, Dâmbovița, Prahova counties, including the oil pumping stations  
Ghercești, Icoana, Cartojani;  
- Environmental Permit for the activity carried out in the Mislea crude oil pumping station,  
Prahova County;  
- Environmental Permit for the activity carried out in the Moreni, Teiș, Ochiuri crude oil  
pumping station, including the local pipelines related to them;  
- Environmental Permit for the activity carried out at the Cireșu crude oil loading ramp, Brăila  
County.  
As regards water management regulation, all along 2024, 9 water permits have been  
renewed for the watercourse crossings by the NTS-related piping routes.  
Considering the provisions of the Emergency Ordinance no. 52 of 31.05.2023 for the  
amendment and completion of certain normative acts in the field of water, which establish  
new tariffs for the use of the public domain for the crossing/undercrossing of waters, their  
implementation generating an impact on the financial indicators of our company, we specify  
the following aspects:  
39  
- The active/inactive/conserved transport pipelines, managed by our company, cross  
watercourses - a natural monopoly of strategic interest held by the National Administration  
Romanian Waters";  
- The administration of crude oil/rich gas/ethane/fiber optic pipelines is regulated in terms  
of water management, with a number of 38 water management authorizations at company  
level, their content includes, among others the crossing points of the watercourses, as  
well as the crossing lengths;  
- According to the current legislative amendments - Art. 81, Paragraph 34 of the Water Law  
no.107/1996: „For the use of the public domain, in order to cross/under cross the goods  
managed by the ”Romanian Waters’’ National Administration, a charge of use is  
established”;  
Assessments of compliance with legal requirements and other environmental  
requirements  
The assessment of compliance with the legal requirements or other applicable environmental  
requirements is carried out by:  
- inspections carried out by the environmental authorities (representatives of central and  
local environmental and water management authorities),  
- inspections carried out by HSEQ supervisors and the personnel of the Environmental  
Protection Department;  
- external audits carried out by bodies certifying the environmental management system  
integrated in the company’s integrated management system;  
- internal audits performed by the internal auditors within the Management Systems and  
Internal Control Management Departments and the Internal Public Audit Department.  
The environment and water management authorities are carrying out scheduled audits in  
CONPET S.A. sites, unscheduled and thematic with regards to the observance of the legal  
requirements and other environmental regulations, not having been found major  
nonconformities.  
To verify compliance with the legal requirements in 2024, 48 external inspections of the  
environmental authorities of the counties on the territory of which CONPET S.A. operates  
were registered (36 to verify compliance with legal requirements, planned inspections and  
12 as a result of accidental pollution and/or monitoring the implementation of measures  
ordered at previous events).  
The personnel within the sectors, namely the HSEQ responsible persons perform scheduled  
inspections, as per the annual Chart of inspection with regards to the compliance of the legal  
requirements and other applicable requirements, but also unscheduled inspections as per  
the attributions of the job description.  
During 2024, an external audit was carried out by the BUREAU VERITAS certification body,  
to verify compliance with the requirements of the ISO 14001:2015 standard that refers to the  
environmental management system. No non-conformities/deviations were found regarding  
the compliance obligations in this area.  
Following the internal audits established in the annual internal audit program, the non-  
conformities identified in the environmental management system were identified and  
corrected in time.  
Pollutions bearing significant impact on the environment  
40  
During the pumping of crude oil, accidental pollution can occur on the transport pipelines,  
from internal or external causes, generating pollution of the geological environment that can  
have a significant impact. Therefore, in 2024 there have been reported accidental pollutions  
in the areas: Lukoil, Tătărani, Lipănești (Prahova county), Cireșu (Brăila county), Lumina -  
milestone 46 (Constanța county), Malul Spart (Giurgiu county), Hurezani (Gorj county),  
Corbu, Milcov (Olt county), left bank overcrossing Căteasca, Oarja (Argeș county).  
The expenses made in 2024 for the decontamination of the affected areas reached 374.6  
thousand RON.  
For compliance with the regulations required by the national legislation in force on the  
environment, regarding management of dangerous waste, “paraffin - type” and “tank sludge”,  
the company CONPET has the obligation to contract services for recovery/disposal thereof  
avoiding sanctions provided by GEO no. 195/2005 on environmental protection, Law 17/2023  
on the approval of GEO no. 92/2021 on waste regime and GD no. 1061/2008 on the transport  
of hazardous waste in Romania.  
Hazardous waste “tank sludge-type” is generated from the activity of storage of the crude oil  
in tanks (in time, mechanical impurities from crude oil settles generating this sludge), it must  
be periodically evacuated, in order to ensure the necessary storage space for the crude oil,  
respectively repairs/calibration of tanks, as , well as the need to eliminate the risk of fires or  
pollution from oil storage tanks, tanks leaks, decanters and sewage that is no longer present  
in the technological and sludge deposits.  
The expenses for the execution of the slurry cleaning services carried out in 2024 were 509.7  
thousand RON.  
Within the technological flows carried out by CONPET Ploiesti, periodically, based on  
maintenance programs, the main and/or local crude oil transport pipelines are subjected to  
cleaning operations of the inner space with special devices called "pigs". Following the  
execution of inside cleaning of these pipelines, of the related keyboards, of the filters from  
pumps or skids, paraffin is generated which is a hazardous waste according to environmental  
legislation in force. This waste was stored in metal dumps, located in the technological  
premises of the company, until its disposal by authorized operators, contracted by the  
company.  
The expenses related to the paraffin cleaning services carried out in 2024 amounted to 10.8  
thousand RON.  
Monitoring environmental factors  
Based on the requirements of the chapter “Environmental Monitoring” included in the  
environmental permits, “The annual program for monitoring and measuring the  
characteristics of the environmental factors 2024” has been developed, which has included  
the performance of the following parameters:  
- concentration of pollutants in the exhaust emissions from the water surface into the water  
in the sewer networks and the concentration of pollutants in the groundwater (existing  
monitoring wells) determining the level of pollution in the event of accidental pollution of  
rivers;  
41  
- concentration of pollutants in atmospheric emissions of stationary sources and/or movable  
(thermal power stations, oil storage tanks), and the concentration of pollutants in the  
ambient air;  
- concentration of specific pollutants from soil samples;  
- noise level.  
To determine the level of pollution for the environmental factors: water, air, soil and noise,  
analysis are being conducted by certified laboratories. The values recorded for each  
measured indicator were below the maximum limits provided by the regulation, according to  
test reports issued. The physical and chemical analysis to monitor environmental factors  
were taken through laboratories accredited according to SR EN 17025: 2005.  
The results of monitoring the environmental factors are communicated to the environmental  
authorities as required by environmental permits. In 2024, the costs for environmental factors  
monitoring amounted to 34.3 thousand RON.  
4.2 Analysis of the Development Activity  
4.2.1 Main components of the NTS infrastructure  
Below is represented, on the map of the country, the Crude oil, Condensate, Rich gas and  
Ethane National Transport System.  
Chart 16 - The National Transport System operated by CONPET  
Given the natural distribution of the oil fields spread over the entire Romanian territory, the  
National Transport System was built so as to meet the transport needs from all those fields  
to the refineries. The system operation is being made based on the local dispatch centers,  
coordinated from the Company’s Central Dispatch.  
The Crude Oil, Rich Gas, Condensate and Ethane National Transport System has in  
composition 4 transport subsystems, grouped according to the transported products as  
follows:  
The domestic crude oil and condensate subsystem transport  
42  
   
The subsystem contains pipelines describing approx. 1,581 km, for the transport of crude oil  
and condensate from the production units of OMV Petrom and third parties, operating areas  
throughout the country, to the refineries.  
This subsystem has the following main components:  
-
Ardeal component, used to transport crude oil from the deposit to the railway loading  
ramps in rail tanks and by rail to the refineries in Ploiești or to Bărbătești unloading ramp.  
- Moldova component used to transport crude oil from the production units related to  
Lucăcești, Comănești and Cerdac pumping stations to Rafo Onesti and Dărmănești  
refineries. Currently, as the processing plants of crude oil from Rafo Onești and  
Dărmăneşti refineries do not operate anymore, the pumping of the crude oil taken over for  
transport is taken to the warehouse of Moineşti loading ramp. From here the oil is  
transported by rail tanks to Petrobrazi, Petrotel- Lukoil refineries or other destination,  
depending on customer requests. During 2017, following the takeover of the concession  
by Mazarine of several oil fields in the region of Moldova, the Cerdac deposit was closed.  
The crude oil extracted from this area is being transported by the storage trucks to  
Ghelinţa/Comănești deposit.  
Starting 2019, the crude oil from Ghelinţa storage warehouse is transported by tankers  
to the loading dock Imeci, loaded into railway tanks and transported to Petrobrazi/Lukoil  
refinery.  
Ghercesti - Ploiești component includes takeover of the crude oil from the production units  
- related to Gherceşti, Lact, Izvoru, Videle, Poeni, Roata and Potlogi pumping stations and  
transport of crude oil by pipeline to Petrobrazi refinery in Ploiești.  
- TicleniPloiesti component includes two main lines with a length of approx. 250 km, line I  
and line II.  
Thread I major pipeline ensures the transport of crude oil from Țicleni and from  
Bărbătești unloading ramp to the refineries in Ploiești (with the possibility of pumping to  
Arpechim Pitești refinery, as well).  
Thread II major pipeline collects the crude oil and condensate from the pumping and  
repumping stations Mădulari, Orlești, Otești, Poiana Lacului, Oarja, Saru, Siliște and  
Bucșani for supply to the refineries in Ploiesti (or to the terminal in Arpechim Pitești).  
-
-
Muntenia basin pipeline component includes pipelines used to transport the crude oil  
from the stations and deposits close to the city of Ploiești.  
the local pipeline component used to transport crude oil from deposits to the loading  
ramps in railway tanks, and from here to the refineries in Ploiești.  
The rich gas transport subsystem  
The subsystem is intended for the transport of rich gas from the recovery plants in Ardeal,  
Oltenia and Muntenia to the refineries in Pitești and Ploiești. The transport subsystem has  
the following composition:  
-
major pipeline thread I Țicleni-Ploiești (served the region from Oltenia and Muntenia and  
today is no longer used following the closure of production facilities by OMV Petrom);  
local piping in Ardeal.  
-
Rich gas transport via pipeline in Arpechim refinery has been suspended since April 2011.  
In 2017, the stock of the rich gas pipeline 6⅝” line I Bărbătești – Ploiești has been discharged,  
in length of 289 km.  
43  
Currently, there are running 2 recovery plants (Abrămuț and Calacea). Produced rich gas is  
transported via pipeline from the ramp Abrămuț to Marghita ramp, and from the ramp Calacea  
to Biled ramp, and from here by railway to Petrobrazi.  
The ethane transport subsystem  
This subsystem has been allocated for the transport of ethane from the deethanizer platform  
Turburea to Arpechim refinery Pitesti. At present, due to the inactivity of Arpechim refinery,  
the subsystem is not used. Ethane transport has been suspended since November 2008.  
Currently, a part of this pipeline (11 km) is used to transport condensate from Hurezani and  
Capreni deposits to Petrobrazi refinery, with the approval of NAMRPSG.  
Import crude oil transport subsystem  
The import crude oil transport subsystem ensures the transport of crude oil from the Oil  
Terminal Constanta to the refineries in Ploiești, Petromidia Refinery and Arpechim Pitesti.  
The import crude oil transport subsystem consists of the following pumping stations:  
Constanța South, Mircea Vodă, Bărăganu, Dragoș Vodă, Călăreți, Mavrodin și Mărtinești.  
Depending on the chosen pumping type, different pumping scenarios can be performed for  
each transport relationship.  
In 2023, the new under crossings of pipelines 20" and 28" Constanta Bărăganu were put  
into operation, at the Danube under crossing points C1 C2 and Borcea arm under crossing  
C3 C4.  
The crude oil, condensate and rich gas domestic production is transported via pipeline, either  
by rail tanks, or combined (rail and pipeline).  
During the transport process, CONPET uses approximately 90 tanks of various capacities.  
Starting 2019, CONPET runs a big process of rehabilitation of tanks and replacing those with  
high degree of wear and storage capacity over the necessary of transport stream with new  
ones to meet the needs of current production, environment and energy consumption. The  
modernization and development process will be completed in 2030.  
On 31.12.2024, the company also owns a fleet of 247 vehicles, intended for the transport of  
personnel for work purposes, means of intervention vehicles, off-road vans and mixed  
transport of persons and goods and special vehicles (emptying, cranes, diggers, etc.).  
4.2.2 The wear degree of the company’s properties  
In order to perform the transport of crude oil and rich gas, from and to all its business partners,  
in conditions of maximum operation, high efficiency and operating costs as low as possible,  
in compliance with the Legislation in force relating to environmental protection and labor  
protection and the other normative acts in the field, CONPET carries out a continuous activity  
on the improvement of the technical condition of the National Transport System.  
In the period of 1995- 2007, through the Modernization Project co-financed by the World  
Bank, works consisting of the rehabilitation and modernization/refurbishment of the Crude  
Oil National Transport System have been conducted. This project has targeted:  
- pipelines rehabilitation;  
- rehabilitation of the pumping stations on the major pipelines and two crude oil and rich  
gas loading/unloading ramps;  
44  
 
- automation of the transport system and introduction of the SCADA system;  
- introduction of crude oil tax measurement systems;  
- development of a telecommunication system.  
After 2007, the emphasis has been mainly placed on the further modernization of the pipeline  
system.  
In order to correctly determine the parts of the pipes to be replaced, periodically the pipes of  
the transport lines are inspected with smart pigging for the determination of the parts of the  
worn pipe.  
Furthermore, for safe operation, monitoring and maintenance of the National Transport  
System via pipelines, it was considered the performance of works intended to secure the  
infrastructure of the water crossings designed to enhance the degree of safety in operation  
of the pipelines in question, indirectly, and the protection of the waters crossed against  
pollution.  
The pipelines that make up the Crude Oil National Transport System over cross/under cross  
various watercourses.  
Another important component in terms of safe operation and environmental protection in  
order to pay attention to the investment process was to secure the crossings. The works  
carried out were:  
- low weirs;  
- bank protections upstream and downstream of the low weir;  
- wave crushers;  
- piles foundation consolidation;  
- bank protections on the route of the pipelines which are parallel with the river bed  
(damaged bank);  
- other works related to pipeline consolidation.  
In 2023, the new under crossings of pipelines 20" and 28" Constanta – Bărăganu were put  
into operation, at the Danube under crossing points C1 C2 and Borcea arm under crossing  
C3 C4.  
The modernization of the pipeline transport subsystems also included the investments made  
at the other technological components of the system, namely:  
- pumping stations;  
- technological installations;  
- PSI facilities;  
- technological and administrative buildings;  
- energy, thermal and telecommunication installation;  
- other auxiliary components.  
The improvement of the technical status of the transport system, led to:  
- reduced technological costs in the storage and transport process;  
- minimized energy, fuel and lubricant consumptions;  
- minimized operating costs and reduced operating difficulties;  
- improved safety and flexibility of the system;  
- reduced environmental impacts;  
45  
- improved quantitative and qualitative measurements of the crude oil transported.  
Compared to the above, it can be appreciated that the technical condition of the Crude oil  
National Transport System via pipelines, operated by CONPET, is an appropriate one.  
4.2.3 Investments achieved in 2024  
The achievement of the investment program approved for the year 2024 is the following:  
Degree of  
achievement  
%
Crt.  
No.  
2024  
Program  
Achieved  
2024  
Name of the element thousand RON  
TOTAL GENERAL, out of which:  
PUBLIC DOMAIN  
85,000  
65,000  
30,000  
28,165  
70,445  
56,139  
27,705  
27,461  
82.9%  
I
86.4%  
1
Pipelines rehabilitation, o/w:  
92.4%  
97.5%  
13.3%  
1.1 Pipeline replacement  
1.2 Safe disposals  
1,835  
244  
Modernization and monitoring of the cathodic  
2
protection system related to the NTS Domestic and  
Import  
539  
432  
80.2%  
3
4
Technical support and consultancy  
25  
0
-
Tanks  
6,479  
5,128  
79.2%  
5
6
7
Energy works  
1,504  
1,100  
7,297  
1,489  
452  
99.0%  
41.1%  
89.2%  
Telecommunication works  
Pumping systems modernization  
6,511  
8
9
Stations/ramp modernization  
Buildings, fences stations  
5,162  
4,188  
81.1%  
5,372  
7,472  
50  
4,593  
5,641  
0
85.5%  
75.5%  
-
10 Automation and SCADA works  
11 Other expenses  
II  
OPERATING DOMAIN  
Investment objectives, o/w:  
Pipelines rehabilitation  
Buildings, fences stations  
LDH and tank cars  
20,000  
16,050  
1,860  
1,522  
10,108  
2,405  
155  
14,306  
10,463  
1,703  
735  
71.5%  
65.2%  
91.6%  
48.3%  
74.4%  
17.5%  
54.8%  
97.3%  
1
2
3
4
5
7,520  
420  
Other works  
Intangible investments  
Independent facilities and equipment  
85  
3,950  
3,843  
Table 14 - The achievement of the investment program 2024 as compared to Program  
The main objectives of investments completed and commissioned in 2024:  
- Modernization of Mislea station;  
- Modernization of Potlogi pumping station;  
- Integration of Moreni automation instruments and equipment;  
- Modernization of Moreni pumping system;  
- Biled Fire Prevention and Security tank;  
- Modernization of Ciresu ramp;  
- Modernization and monitoring of the cathodic protection system related to the NTS  
Domestic and import, in three locations;  
46  
 
- Replacement of pipeline Ø 20” Constanța - C1 - 8 sections - completed: section 3  
(A,B,D,E,F), section 4 (A,B) and section 5 (A);  
- Smart pigging, detection of pipeline status Ø10 ¾" L1 Bărbătesti– Ploiesti West and Ø  
10¾" L2 OrlestiPloiesti (Petrobrazi);  
- System related to the tele-transmission and tele-management of the power consumptions  
in 7 locations belonging to CONPET S.A;  
- Modernization of Ochiuri pumping station;  
- Replacement of pipeline Ø 20” Constanța - C1 - 8 sections - completed: tronson1 (A, B,D);  
section 2 (A,B); section 3 (C); section 7;  
- Replacement of pipeline Ø 20” Constanța - C1 - 8 sections - completed: section 2 (D, F,G);  
section 5 (B,C,D,E,F), section 6; section 8;  
- Extension of SCADA system - 4 ramps and 5 stations;  
- GPS, RTK, GNSS receivers package;  
- RR planned repair to locomotive LDH 790-1;  
- Transformation of the LDH 92 53 0850 130 -1;  
- Type RP-FIR planned repair to 3 rail tanks of 80 cubic m for rich gas transport and 38 rail  
tanks of 60 cubic m fir crude oil transport and assembly of 108 axles;  
- Replacement of pipeline section Ø 6⅝ʺ Warehouse Petrom Orzoaia de Sus – Urlați crude  
oil station, about 1,600 m in length.  
Significant investment objectives in progress on 31.12.2024  
PUBLIC DOMAIN  
In 2024 have been achieved investments in the public domain amounting to 56,139 thousand  
RON, representing 86.4 % of the annual program, as follows:  
- Replacement of pipeline Ø 20” Constanța - C1 - 8 sections;  
- Crude oil storage Berca village;  
- Modernization and monitoring of the cathodic protection system related to the NTS  
Domestic and Import;  
- Modernization of Satchinez pumping station;  
- Modernization of Slobozia crude oil station;  
- New tank PSI Independenţa Buffer Deposit;  
- Installation and initial metrological verification of four measuring skids in Petrobrazi P3,  
Poiana Lacului, Videle and Otesti locations;  
- Modernization of the multiplexor network;  
- Rehabilitation of the pump hall C+D+E Călăreți station and Rehabilitation of the building  
related to connections 6 kV, electrical distributors 6/0.4 kV A+B Local Dispatch, electrical  
distributors CDE, Călăreți station.  
OPERATOR FIELD  
In 2024 have been achieved investments in the operator domain amounting to 14,306  
thousand RON, representing 71.5 % of the annual program, as follows:  
- Rehabilitation of buildings at Headquarters 2 Workshops - Building C4, C5, C10, C11;  
- Replacement of the Ø 6" Urlați-Ploiesti crude oil transport pipeline, in the DN1A Moara  
Nouă-Corlătesti area.  
Commissioning achieved in 2024 amounted to 85,426 thousand RON, out of which, per  
financing sources:  
47  
- 69,744 thousand RON out of the modernization quota;  
- 15,682 thousand RON out of other own sources;  
4.2.4 Litigations and other aspects on the company’s tangible assets  
During 2024 CONPET SA was involved in a total of 148 litigations. Among them, 50 litigations  
have been completed.  
The most important disputes in which the company is involved are presented below:  
a) The disputes concerning the ownership of the tangible assets of the company  
CONPET S.A. is not involved in trials regarding the claim of ownership of certain real estate.  
b) Litigations in connection with the claims of the owners of the lands crossed by the  
Crude Oil National Transport System  
On 31.12.2024, CONPET S.A. had a number of 10 files before the courts in different  
procedural stages, having as subject the claims of the landowners related to the lack of use  
of the owned lands transited by the major pipelines that are part of the Crude Oil National  
Transport System. We hereby outline a number of 7 causes which we find important under  
the aspect of the amount of claims of the plaintiffs and representative by the legal content of  
the trial files (the rest of the causes repeating, in broad terms, some of the types of action  
listed below):  
1. Case File no. 3451/108/2016***High Court of Cassation and Justicepending  
Trial stage: Appealretrial  
Parties: CONPET S.A.defendant  
Administrative Territorial Unit (Ro. UAT) Pecica City - claimant  
Object: Administrative Territorial Unit (Ro. UAT) ATU of Pecica town filed a request for a  
summons requesting:  
Mainly:  
- the obligation of the defendant Conpet S.A. to divert the crude oil pipeline that crosses a  
number of 22 plots of urban land, intended for the construction of houses, located in our  
property, in a total area of 20,287 sq. m.  
- order the defendant Conpet S.A. to pay the amount of EUR 65,000 representing the  
equivalent value of the house located in plot no. A141.7760 / 5/174, entered in L.B. no.  
306869 because it can no longer be capitalized by the subscriber.  
Subsidiarily:  
- order the defendant Conpet S.A. upon payment of an annual rent, during the existence of  
the pipeline, as a result of the encumbrance of the areas shown above by the right of legal  
easement exercised by Conpet SA; NOTE: The annual rent has not been quantified.  
- order the defendant Conpet S.A. to the granting of compensations for the period  
31.10.2014 31.05.2016 as a result of the limitation of the attributes of the property right  
of the 22 urban land plots and of the decrease of the circulation value of the land on the  
real estate market due to the restrictions imposed by Order 196/2006 of NAMR on  
construction;  
48  
 
- order the defendant Conpet S.A. that every 3 years to adapt the amount of compensation  
to the value of circulation at that time of similar lands and the provisions of future orders  
of the N.A.M.R.;  
- the setting by the court of the due date on which the compensations will be paid annually,  
following the non-payment at the due term to attract the payment of the legal interest  
related to the amount received as compensation for the delay period;  
- grant the legal expenses incurred in the event of opposition.  
Mentions: By the Conclusion no. 40/26.01.2017, the Arad Court rejects the request to show  
the right holder formulated by the defendant Conpet SA in contradiction with the claimant  
ATU of Pecica City and with the respondents the Romanian State through the Ministry of  
Public Finance and the National Agency for Mineral Resources. The decision was appealed  
by Conpet (File no. 3451/108/2016 * / a1 - Timisoara Court of Appeal. By the Decision no.  
211/20.03.2017 the Timişoara Court of Appeal rejected the appeal.  
By the Sentence no. 336/18.05.2017, the Arad Court rejects the civil action filed by the  
claimant ATU of Pecica City in contradiction with the defendant SC Conpet SA having as  
subject the obligation to act and claims. No legal expenses. The decision was appealed by  
the ATU Pecica City.  
By Decision no 761/23.11.2017 the Court of Appeal Timisoara admits the appeal. It annuls  
the appealed sentence and sends the case for retrial to the Arad Court. Conpet filed an  
appeal.  
Through the Report of 07.06.2018, the High Court of Cassation and Justice found the  
inadmissibility of the Conpet appeal, the latter being promoted against a final decision, which  
does not fall within the hypothesis regulated by art. 483 para. 1 Code of Civil Procedure. The  
parties submitted a written opinion on the report. By the Conclusion of 10.10.2018, the HCCJ  
admits in principle the appeal declared by the appellant-defendant Conpet S.A.  
By the Decision no. 615/22.03.2019 the HCCJ admits the appeal declared by the appellant-  
defendant Conpet S.A., it quashes the appealed decision and sends the case to a new court  
of the same court of appeal.  
By the Decision no. 306/07.06.2021, Timisoara Court of Appeal rejects the appeal declared  
by the appellant-claimant, the Administrative Territorial Unit of the City of Pecica.  
The claimant, the Territorial Administrative Unit of the City of Pecica, filed for an appeal.  
By the Decision 641/15.03.2023 the HCCJ admits the appeal. It dismisses the appealed  
decision and sends the case for a new trial to the same court.  
By the Decision no. 621/13.12.2023 the Timișoara Court of Appeal admits the appeal filed  
by the claimant-appellant the Administrative Territorial Unit of Pecica City. It partially changes  
the appellant's sentence in the sense that it admits in part the request for summons made by  
the claimant the ADMINISTRATIVE TERRITORIAL UNIT OF THE CITY OF PECICA in  
opposition to the defendant CONPET S.A. and obliges the defendant to pay the amount of  
EUR 137,045.69 euro as compensation in favor of the claimant. It upholds the rest of the  
appealed sentence. It obliges the respondent to pay in favor of the appellant the amount of  
17,579 RON as legal expenses. Conpet filed for an appeal.  
Court hearing: 21.05.2025  
2. Case File no. 5413/204/2017 *Prahova Tribunal pending  
Trial stage: Merits retrial  
Parties: CONPET S.A.  
NAMR defendant  
49  
Dobrogeanu Păun Ioan - claimant  
Object: Dobrogeanu Dumitru and Dobrogeanu Păun Ioan filed a petition of trial asking the  
court to rule the obligation of CONPET SA to pay an annual rent for the land plots occupied  
by the two oil products pipelines (crude oil) starting 01.07.2014 and in the future, for the entire  
duration of the pipelines, to pay the compensation for the losses incurred by not reaching  
certain economic objectives on the remaining area between the two pipes after their  
restriction and the area along the national road DN1 (E60) and payment of court costs. The  
first head of the claim was estimated by the claimants at the amount of 48,000 EUR/year  
(220,000 RON), and the second head at the amount of 25,000 RON/year.  
Mentions: By the Sentence no. 2446/28.08.2018 the Prahova Tribunal admits the exception  
of the lack of passive capacity to stand trial, invoked by the defendant National Agency for  
Mineral Resources. It dismisses the action, in contradiction with that defendant, as being  
brought against a person without procedural capacity. It admits the exception of the res  
judicata. It dismisses the claim filed against the defendant SC Conpet SA, as there is res  
judicata. It finds that the defendants have not applied for legal expenses.  
The decision was appealed by Dobrogeanu Dumitru.  
By the Decision no. 2804/11.11.2019 the Ploiești Appellate Court rejects the appeal  
declared by the appellant Dobrogeanu Dumitru as unjustified. It admits the plea of  
inadmissibility of the cross-appeal. It dismisses as unfounded the cross-appeal declared by  
the appellant Dobrogeanu Păun Ioan.  
The decision was attacked with recourse by Dobrogeanu Dumitru and Dobrogeanu Păun  
Ioan.  
By the Decision no. 206/04.02.2021, the High Court of Cassation and Justice rejects the  
appeal filed by the claimant Dobrogeanu Păun Ioan. Admits the appeal declared by the  
applicant Dobrogeanu Dumitru. It quashes the appealed decision and the civil sentence no.  
2446/28.08.2018 of the Prahova Court and sends the case for retrial to the Prahova Court.  
Court hearing: 22.05.2025  
3. Case File no. 4395/270/2020 - Onești Court - pending  
Trial stage: First court  
Object: Onești Municipality and the Local Council of Onești Municipality, Bacău County,  
have sued Conpet S.A. asking the court:  
“1. The obligation of the defendant at the conclusion of the agreement for the exercise of the  
right of legal easement over the lands with an area of 11,474.5 sq.m, crossed and affected  
by crude oil transport pipelines within the municipality of Onești, equivalent to the payment  
of an annual rent, during the existence of the pipelines, to the local budget of Onești  
municipality, determined according to the principle of the least violation of the property right  
and calculated taking into account the circulation value of the affected real estate, established  
under the law, at the time of the damage.  
2. Obligation of the defendant to pay material damages, representing the consideration of  
the lack of use of land in the surface of 11,474.5 sq.m under crossed and affected by crude  
oil transport pipelines within the radius of the municipality of Onești, established according to  
the Market Study approved by the Decision of the City Council no. 199 of 29.11.2018,  
respectively according to the Updated Market Study approved by the City Council Decision  
no. 122 of 29.06.2020, calculated starting from 2017 until the date of conclusion of the  
Convention for the exercise of the right of legal servitude on such land, plus late increases,  
interest and late payment penalties in the amount provided for in the Code of Tax Procedures  
applicable during that period.  
50  
3. The obligation of the respondent to pay the trial costs incurred by this trial.”  
Deadline: 13.05.2025  
4. Case File no. 1657/91/2020 *Vrancea Tribunal pending  
Trial stage: First court  
Parties: Vasile Maria - Ilaria - at S.C.P.A. Buruian, Caracaş and Associates - Plaintiff  
Dragu Georgeta - at S.C.P.A. Buruian, Caracaş and Associates - Plaintiff  
CONPET S.A.- defendant  
The Romanian State - by the Ministry of Public Finance - defendant  
The National Agency for Mineral Resourcesdefendant  
Object: By their summons, the claimants Vasile Maria-Ilaria and Dragu Georgeta requested  
to the court to:  
A. Mainly, to oblige the defendant to pay an annual rent of 496.64 Euro for the pipe protection  
area belonging to the defendant and passing through the private property of the undersigned,  
starting from the date of registration of this application for legal action;  
B. Mainly, to oblige the defendant to pay an overall compensation of 508,080 Euro for the  
assignment of the attribute of use of the good according to its intended purpose, i.e. that the  
undersigned cannot build construction on the private property;  
C. Mainly, order defendant to pay legal interest on the annual rent provided for in item A,  
starting from the date of registration of the present summons.  
D. Mainly, order the defendant to pay legal interest for the global indemnification provided for  
in item B, starting from the date of registration of the present summons.  
E. In the alternative, we request you to order the other two defendants to pay the amounts  
indicated in the preceding paragraphs.  
Conpet filed a counterclaim in this case, requesting the court:  
1. To oblige the complainants Vasile Maria Ilaria, Dragu Georgeta and Dragu Maria to allow  
the company CONPET S.A. the exercise of the right of legal services established by the  
provisions of Art. 7 et seq. of Law no. 238/2004 on the land owned by them, situated in  
Focsani city, Vrancea County. The exercise of the right of legal easement is to be carried out  
in a passage of 2.4 meters wide located along the Ø 20” Bărăganu - Borzești/Rafo Onești  
crude oil transport pipeline standing for purposes of permanent access to the pipeline in order  
to verify the day-to-day management of the status of the pipe and the execution of any repair  
works. The exercise of the right of easement is to be carried out throughout the existence of  
the pipeline located on the claimants' land, but not later than the date of termination of the oil  
concession agreement concluded by us, signed by CONPET S.A., with the Romanian State.  
2. To establish the amount of the annual rent provided by law due by us, the undersigned  
CONPET SA, to the claimants Vasile Maria - Ilaria, Dragu Georgeta and Dragu Maria in  
exchange for exercising the right of legal easement, rent consisting in the equivalent value  
of the annual land use affected by the exercise of the legal easement.  
Deadline: 20.05.2025  
5. Case File no. 32294/299/2020 - Bucharest District 1 Courthouse - in the course of  
settlement  
Trial stage: First court  
Parties: CONPET SA defendant - counterclaimant  
Bob Mihăiță - claimant-defendant  
NAMR - defendant  
Object: Bob Mihăiță files a summons requesting the court to order:  
51  
1. The obligation of Conpet SA and NAMR to move the crude oil pipeline crossing the land  
owned by the claimant located in Cernavoda, plot 1, plot A6/2, Constanța county.  
2. The establishment of the equivalent value of the lack of use, for a period of three years,  
prior to the formulation of the summons, amounting to 150,000 RON;  
3. In the alternative, the obligation of Conpet SA to pay an annual rent for the use of the land  
owned by the claimant, from the date of filing the summons, in the amount of 5  
Euro/sq.m/year for the area of 14,645 sq.m, land affected by the protection and safety area,  
during the existence of legal easement.  
4. Payment of legal fees.  
Conpet formulated the counterclaim/re conventional petition requesting the court:  
1. To order the claimant to allow CONPET S.A. the exercise of the right of legal servitude  
established by the provisions of Art. 7 et seq. of Law no. 238/2004 on the land owned by the  
claimant Bob Mihăiță located in Cernavoda, plot 1, plot A6/2, Constanța County. The exercise  
of the right of legal servitude is to be carried out on a 2.4 meter wide corridor located along  
each of the main crude oil transport pipelines that under-cross the claimant's land,  
respectively the F1 main crude oil transport pipeline Ø 14¾ ", F2 main crude oil transport  
pipeline Ø 20 ", and Pipeline 28 Constanța - Bărăganu of crude oil transport Ø 28", for the  
purpose of permanent access to pipelines for daily verification of the condition of pipelines  
and execution of possible repair works. The exercise of the right of legal servitude is to be  
carried out throughout the existence of the pipelines located on the land of the claimant, but  
no later than the date of termination of the oil concession agreement concluded by us, the  
undersigned Conpet SA, with the Romanian State;  
2. To establish the amount of the annual rent provided by law due by us, the undersigned, to  
the claimant in exchange for exercising the right of legal easement.  
Conpet S.A. filed an impleader of the Romanian state represented by the Ministry of Finances  
and NAMR.  
Conpet S.A. formulated a request of identifying the holder of the right in rem.  
Mentions: By the Conclusion dated 06.08.2021, the Bucharest District 1 Courthouse  
rejects the exception of the lateness of the request for impleader and of the request for  
showing the right holder, invoked by the National Agency for Mineral Resources, as  
unfounded. It rejects the exception of the lack of representative capacity of the National  
Agency for Mineral Resources, invoked ex officio, as unfounded. It rejects the request for an  
impleader from the Romanian State, through the Ministry of Finance and the National Agency  
for Mineral Resources, as inadmissible in principle. It rejects the request to show the right  
holder of the Romanian State, through the Ministry of Finance and the National Agency for  
Mineral Resources, as inadmissible in principle. The conclusion can be appealed with the  
merits.  
Deadline: 13.05.2025  
6. Case File no. 2323/120/2018 – Ploiești Court – pending  
Trial stage: Appeal - retrial  
Parties: CONPET SA defendantcounterclaimant  
Buzatu Florin claimant-respondent  
Object: Buzatu Florin has filed a sue petition, asking the court:  
1. Order the respondent Conpet SA to pay the claimant the amount of 150,000 EUR, payable  
at the BNR exchange rate on the day of the payment (amount to be reassessed upon  
completion of the expert real estate appraisal report to be carried out in probation, we shall  
resize and specify the value of the claims, corroborated with the appropriate adjustment of  
52  
the stamp duty), representing the fair and equitable compensation for the damage suffered  
by restricting the possibility of exercising its right to property on the land area of 5,980 sqm  
located in the urban space of Slobozia Moară, Dâmboviţa County, having the cadastral  
number 70618, registered with the land registry under 70618/UAT Slobozia Moară,  
Dâmboviţa County, on which are found the underground gas pipelines and the overground  
devices of the respondent, land that cannot be used for the purpose of constructing a  
building;  
2. Order the respondent Conpet SA to pay a 1,000 EUR monthly indemnity payable at the  
BNR exchange rate on the payment day, starting with the delivery of the Decision throughout  
the existence of the underground pipelines and overhead devices on the land owned by the  
respondent and to bear all the costs incurred by the claimant for the pre-authorization stages  
of the construction;  
3. In alternative, it orders the respondent to erect all the constructions built on the claimant’s  
property, namely the gas pipelines and the overhead devices, to bring the land to its original  
condition or to enable the claimant to perform the obligation to do so, at the exclusive  
expense of the respondent;  
4. Order the defendant Conpet SA to pay the legal expenses incurred in the present legal  
proceedings.  
Conpet has filed a counterclaim requesting that the plaintiffs be ordered to allow our company  
to exercise the right of legal easement established by the provisions of art. 7 et seq. of Law  
no. 238/2004 and the determination of the amount of the annual annuity provided for by law  
due by Conpet to the applicants in exchange for the exercise of the right of legal easement.  
Mentions: By Sentence nr.602/10.03.2022 the Dâmbovița Court rejects plea of lack of  
passive locus standi of the defendant applicant Conpet S.A. as regards the heads of claim  
for compensation and annuity, raised by it. It admits the claimant Conpet S.A.'s lack of  
passive procedural capacity as regards the head of claim concerning the obligation to raise  
the above-ground pipes and devices and to restore the land to its original condition or to  
empower the applicant to do so, invoked by it and consequently rejects that head of claim in  
contradiction with the defendant-claimant Conpet S.A. as being formulated against a person  
without passive procedural capacity. It admits in part the summons. The court partially admits  
the counterclaim. It obliges the defendant claimant to demolish the construction without  
authorization (foundation) existing on the land belonging to him, with cadastral no. 70618,  
registered in the land book no. 70618 of Slobozia Territorial Administrative Unit Slobozia  
Moara, Dambovita county identified according to the sketch drawn up in the expertise report  
in the topography specialty dated 04.11.2019 (f 300, vol. I). It establishes the amount of the  
annual rent due by the claimant defendant to the defendant claimant for exercising the right  
of legal easement on the land with an area of 890 sq.m related to crude oil pipelines Ø143"  
and Ø" identified according to the sketch prepared in the expertise report dated 02.11.2019  
(f. 357, vol. I), to the amount of 284.8 Ron and obliges the plaintiff defendant to pay to the  
defendant plaintiff from the date of the final stay of the present sentence.  
Dismisses the remainder of the summons and the counterclaim. It rejects the request to show  
the right holder formulated by the claimant defendant in contradiction with the Romanian  
State, through the Ministry of Public Finance and the National Agency for Mineral Resources.  
Orders the restitution to the plaintiff defendant of the stamp duty paid and not due in the  
amount of 1,143.4 RON. It compensates the costs within the limit of 1,172.7 RON and orders  
the plaintiff to pay to the defendant the uncompensated difference of 836 Ron in court costs.  
Buzatu Florin filed an appeal.  
By Decision no. 482/09.03.2023 Ploiesti Court of Appeal rejected the appeal, as unfounded.  
53  
The decision was appealed by the plaintiff.  
By the Decision of 11.04.2024, the High Court of Cassation and Justice rejects the exception  
of the nullity of the appeal, invoked by the respondent-intervening National Agency for  
Mineral Resources. It admits, in principle, the appeal filed by the appellant-claimant Buzatu  
Florin.  
By Decision no. 1161/28.05.2024, the High Court of Cassation and Justice admits the  
appeal filed by the appellant-claimant Buzatu Florin. It dismisses the appealed decision and  
sends the case for a new trial to the same court Appeal.  
By the Decision no.106/30.01.2025, the Ploiești Court of Appeal admits the appeal. It  
partially changes the appealed sentence in the sense that it: it establishes the amount of the  
annual rent owed by the defendant-claimant to the defendant-claimant for the exercise of the  
right of legal easement over the land with an area of 5,696 sq.m. in the amount of 1,217.2  
RON and obliges the defendant claimant to pay it to the defendant claimant starting from the  
date of the finality of the present sentence. - It compensates the legal expenses within the  
limit of the amount of 2,008.7 RON and obliges the defendant claimant to pay the  
uncompensated difference of 2,088.79 RON as legal expenses to the defendant claimant. It  
maintains the rest of the provisions of the appealed sentence. It obliges the respondent to  
pay the legal expenses in the amount of 3,615.09 RON (RON 45.09 judicial stamp duty and  
3,570 RON defense fee). With appeal within 30 days of communication.  
Deadline: --  
7. Case File no. 1541/262/2023- Moreni Court pending  
Stage of trial - merits  
Parties: CONPET SA defendant - counterclaimant  
Mapi Imobiliare S.R.L. plaintiff - defendant  
Object: To oblige Conpet to pay an annual annuity according to art. 7 of Law nr. 238/2004  
and compensation, including for the past as of 20.01.2023.  
Conpet formulated the counterclaim/re conventional petition requesting the court:  
1. The obligation of the claimant Mapi Imobiliare S.R.L. to allow the company CONPET S.A.  
the exercise of the right of legal servitude/easement established by the provisions of Art. 7  
and et seq. of Law no. 238/2004 on the land owned by her, located in the Ocnița commune,  
Ochiuri village, Dâmbovița county. The exercise of the right of legal easement is to be carried  
out in a passage of 2.4 meters wide located along the pipe buses to transport crude oil Ø 6  
5/8˝ Ochiuri - Moreni for purposes of access to the pipe in order to verify the day-to-day  
management of the status of the pipe and the execution of any repair works. The exercise of  
the easement right is to be carried out throughout the existence of the pipeline located on  
the claimant's land, but not later than the date of the termination of the concession oil contract  
concluded by us, the undersigned company CONPET S.A., with the Romanian State.  
2. The establishment of the amount of the annual rent provided by the law due to us, the  
undersigned company CONPET S.A., to the claimant Mapi Imobiliare S.R.L. in exchange for  
exercising the right of legal servitude/easement starting from the date of the definitive  
decision given in the present case, rent consisting in the value of the annual use of the plot  
of land affected by the exercise of servitude/easement.  
At the same time, Conpet filed a warranty claim against the Romanian State, represented by  
the Ministry of Public Finance and the National Agency for Mineral Resources, requesting  
the court to be compensated by the defendants in guarantee, who will be jointly and severally  
liable for any amounts we will be obliged to pay to the applicant Mapi Imobiliare S.R.L..  
in case the request for summons filed by it will be admitted in whole or in part.  
54  
Mentions: By the Sentence no. 885/22.10.2024, the Moreni Courthouse rejects, as  
unfounded, the exception of the lack of passive procedural quality of the defendant-claimant  
Conpet S.A. with regard to the claims for compensation and rent, invoked by it. Rejects, as  
unfounded, the plea of lack of passive locus standi of the defendant - applicant Conpet S.A.  
as regards the heads of claim for compensation and annuity, raised by him. It rejects the  
claim for summons in guarantee of the Romanian State represented by the Ministry of Public  
Finance and the National Agency for Mineral Resources. It rejects as unfounded the  
exception of the lack of passive procedural quality formulated by the National Agency for  
Mineral Resources. The court partially admits the counterclaim. It rejects as unfounded the  
counterclaim.  
The decision was appealed by Conpet S.A. and Mapi Imobiliare S.R.L.  
Mapi Imobiliare S.R.L. filed a request for clarification of the Sentence no. 885/22.10.2024.  
By the conclusion of 11.02.2015, Moreni Court rejects the complaint.  
Deadline: --  
c) Litigations related to the structure of the share capital  
CONPET S.A. has pending before courts 1 litigation, respectively:  
Case File no. 5212/105/2018 – Ploiești Court of Appeal – pending  
Trial stage: Appeal - retrial  
The Proprietatea Fund SA filed a petition for trial requesting the court to rule the following:  
1. To request CONPET to pay the amount of 734,747.04 RON representing the net value of  
dividends related to a percentage of 6% of Conpet’s share capital, respectively for a number  
of 524,366 shares held by the claimant by the registration date of the OGMS of CONPET on  
25.04.2007 (i.e. 14.05.2007), related to the financial year 2006.  
2. The obligation of Conpet to pay compensatory damages, namely the legal interest related  
to the dividends from maturity due date requested in item 1 and until the date of the  
introduction of the petition for trial (i.e. 09.11.2018) in the amount of 579,015.97 RON.  
3. The obligation of CONPET to pay the legal interest related to the net value of the dividends,  
subsequently, from the date of the petition for trial and until the actual payment of the  
requested amounts.  
4. To request Conpet to pay the costs of this dispute.  
Mentions: Conpet S.A. filed an impleader of the Romanian State through the Ministry of  
Finance and A.A.A.S.  
By the Conclusion of 25.06.2019, the Prahova Court rejected as unfounded the impleader  
of the Authority for the Administration of State Assets, formulated by the defendant Conpet  
S.A. Against this decision of the court, Conpet and the Romanian State through the Ministry  
of Public Finance filed an appeal. By the same Conclusion of 25.06.2019, the court admitted  
in principle the impleader of the Romanian State by the Ministry of Public Finance, formulated  
by the defendant Conpet S.A. and rejected as unfounded the plea of the lack of passive  
procedural quality of the Romanian State by the Ministry of Public Finance. The appeal was  
registered before the Court of Appeal Ploiesti with no. 5212/105/2018/a2. By the decision no.  
515/05.11.2019 Ploiești Court of Appeal admits the plea of the inadmissibility of the appeal  
declared by the Ministry of Public Finance. The court rejects this appeal as inadmissible. The  
court rejects the exception of the lack of interest and the exception of the inadmissibility of  
the appeal declared by Conpet. Dismisses this appeal as unfounded. Final judgment.  
By the Conclusion of 20.09.2019, the Prahova Tribunal suspends the trial of the case until  
the settlement of the appeals made against the decision pronounced on 25.06.2019. This  
conclusion remained final by non-recurrence.  
55  
By Sentence no. 633/02.06.2021 The Prahova Tribunal rejects as ungrounded the exception  
of the prescription of the right to action. It admits the action. It obliges the defendant CONPET  
to pay to the claimant the amounts of 734,747.04 RON representing the value of dividends,  
of 579,015.97 RON, representing dividends for the period 26.10.2007 - 09.11.2018, and the  
legal interest related to the net value of the dividends from 09.11.2018 and until the actual  
payment of the main debit. It admits in part the warranty claim. It obliges the summoned in  
guarantee The Romanian State to pay to the defendant Conpet S.A., the amount of  
734,747.04 RON, representing the value of dividends, and the legal interest related to this  
amount starting with 17.12.2018 and until the date of restitution to the defendant of the  
amount of 734,747.04 RON. With the right to appeal within 30 days from communication.  
The decision was appealed by Conpet S.A. and the Romanian State through the Ministry of  
Public Finances.  
By the Decision no. 814/01.07.2021 the Court admits the request for correction of the  
material error made by the claimant. It corrects the material error crept into the content of  
paragraph 3 of the operative part of sentence no. 633 / 02.06.2021 pronounced by the  
Prahova Court, in the sense that it is written: “It obliges the defendant Conpet S.A. to pay to  
the claimant the amounts of 734,747.04 RON representing the main debit and of 579,015.97  
RON, representing dividends for the period 26.10.2007-09.11.2018, and the legal interest  
related to the net value of the dividends from 09.11.2018 until the actual payment of the main  
debit.” It admits the request for completion of the decision made by the claimant. It orders the  
completion of the civil sentence no. 633/02.06.2021 in the sense that it also provides: reduces  
the fee of the claimant's lawyer to 70,000 RON. obliges the defendant Conpet S.A. to pay  
the claimant the following legal expenses: 20,347.63 RON representing judicial stamp duty,  
4,300 RON expert fee, 8,481.87 RON expert fee, 70 RON lawyer's fee and 1,125 RON other  
expenses. obliges the summoned in guarantee the Romanian State to pay to the defendant  
Conpet S.A. legal expenses in amount of 16,943 RON. The decision was appealed by Conpet  
S.A.  
Conpet S.A. also filed a request to correct the material errors in the contents of sentence no.  
633 of 02.06.2021 pronounced by the Prahova Court in the file no. 5212/105/2018, device  
that was the object of correcting the material error pronounced by the court by sentence no.  
81 of 01.07.2021. Through the Conclusion of Correction of Material Civil Error, dated  
12.09.2022, the Prahova Court admitted the request to correct the material errors of the  
disposition of the civil sentence no. 633/02.06.2021 and no. 814/01.07.2021, pronounced by  
the Prahova Court, in the file no. 5212/105/2018, formulated by Conpet S.A., against the  
claimant, Fondul Proprietatea S.A., against the defendant Conpet S.A., the summoned in  
guarantee the Romanian State, through the Ministry of Public Finances. It corrects the  
material errors in the content of sentences no. 633/02.06.2021 and no. 814/01.07.2021  
pronounced by the Prahova Court, in the sense that it is changed: It obliges the defendant  
S.C. Conpet S.A. to pay the claimant the amount of 734,747.04 RON representing the net  
value of the dividends and 579,015.97 RON, representing the legal interest related to the net  
value of the dividends for the period 26.10.2007-09.11.2018, and the legal interest related to  
the net value of the dividends from 09.11.2018 and until the actual payment of the main debit.  
By the Decision no. 245/08.12.2022 the Ploiești Court of Appeal admits the exception of the  
ineligibility of the appeal invoked ex officio. It rejects the appeal as unfounded. Final  
judgment.  
By the Decision no. 109/29.03.2023, the Ploiești Court of Appeal admits the appeal. It  
changes the entire sentence. It admits the statute of limitations exception and dismisses the  
claim as statute of limitations. Rejects the warranty claim. It obliges the claimant to pay the  
56  
defendant 16,943 RON in legal expenses incurred at the trial in the first instance. It obliges  
the respondent-claimant to pay the appellant-defendant 17,785 RON in legal expenses in the  
appeal.  
Fondul Proprietatea S.A. filed an appeal.  
On 14.02.2024 the H.C.C.J. admits in principle the appeal declared by the appellant-claimant  
Fondul Proprietatea S.A. against the decision no. 109/29.03.2023, pronounced by the  
Ploieşti Court of Appeal - Civil Division II. It establishes a term for judging the appeal.  
By the Decision no. 860/17.04.2024 the H.C.C.J. admits the appeal; it quashes the  
appealed decision and sends the case for a new trial to the appellate court.  
By the Decision no. 67/26.02.2025 the Ploiești Court of Appeal rejects the appeal filed by  
the summoned in guarantee the Romanian State, represented by the Ministry of Finances. It  
admits the appeal filed by the defendant Conpet S.A. It changes in part the sentence no.  
633/02.06.2021, as directed by the conclusion of 12.09.2022, in the sense that the impleader  
will be accepted in its entirety and the Romanian State represented by the Ministry of Finance  
will be obliged to pay the defendant the amount of 579,015.97 RON representing the interest  
to be paid by the defendant to the claimant for the period between 26.10.2007 - the due date  
for payment of dividends due for the 524,366 shares and the date of filing the impleader -  
09.11.2018, as well as the legal interest starting with 09.11.2018 and until the moment this  
court decision becomes final. It obliges the defendant-appellant to pay the claimant-  
respondent the legal expenses in the amount of 30,000 RON representing defense fees  
incurred in the appeal trial in both procedural cycles. It obliges the defendant-appellant to  
pay the claimant-respondent the legal expenses in the amount of 50 RON the judicial stamp  
duty paid in the appeal as well as 31,197.58 RON defense fees paid in the appeal - HCCJ -  
in the first procedural cycle. It maintains the other provisions of the sentence no.  
633/02.06.2021. With appeal within 30 days of communication.  
Deadline: --  
d) Litigations brought before the administrative court  
CONPET S.A. has 7 litigations pending before courts, respectively:  
1. Case File no. 5971/2/2022 Bucuresti Court of Appeal pending  
Procedural status: First court  
Parties: OMV Petrom SA - claimant  
NAMR - defendant  
CONPET S.A. defendant  
Object: The court is requested that, by the judgment that will be pronounced, to order:  
1. Regarding the Order 229/2021:  
1.1. Partial annulment of art. 1 of Order 229/2021 regarding the tariffs established in the  
Annex 1 and Annex 3 and, accordingly, the Annexes 1 and 3 of Order 229/2021; and by way  
of consequence  
1.2. Obliging NAMR to issue a new order for the approval of transport tariffs through the  
National System for the transport of crude oil, rich gas, condensate and ethane for the year  
2022, which includes tariffs modified accordingly with regard to tariffs in the COUNTRY  
(Annex 1) and tariffs in import for refineries in the Ploiești Basin (Annex 3), as a result of the  
recalculation of the tariffs included in the Order 229/2021 in a transparent and non-  
discriminatory manner, in accordance with the constitutional provisions and those of the  
primary and secondary petroleum and competition legislation, as they are exposed by means  
of this summons;  
57  
2. Regarding Order 53/2008, the partial cancellation of art. 3-8 of the Annex to Order no.  
53/2008, as well as obliging NAMR to issue a new order to properly complete the Order no.  
53/2008, by reference to the following:  
2.1. the method of determining in the Methodology the operating cost lacking transparency  
and clarity, with regard to (i) its component elements, the structure of each of these elements,  
not specifically provided for, along with (ii) the cost calculation algorithm of operation by  
referring to these elements and (iii) by taking into account only those elements that constitute,  
by their nature, operating costs, so that these secondary normative provisions are aligned  
with the requirements of art. 20 of the Petroleum Law;  
2.2. The algorithm for determining the modernization quota that does not provide in a specific,  
clear and transparent manner (i) the effective percentage of the modernization quota, (ii) the  
basis on which it is applied, (iii) the concrete investments in order to carry out pay the  
modernization quota by the beneficiaries of the transport system, (iv) the method of  
managing the surplus of amounts collected as modernization quota and unused until the end  
of the financial year that were charged for the realization of investments, by taking into  
account these amounts in the calculation of the modernization quota that the beneficiaries  
must pay in the following year, by referring to the investments considered within it and such  
amounts available for investments carried over from previous years, as well as (v) the method  
of managing the bank interest collected by the holder of the concession agreement as a  
result of depositing the sums received as a modernization quota and not used by him, in the  
sense of using the interests according to the same destination and taking into account these  
sums in the calculation of the modernization quota that the beneficiaries must pay in the  
following year with this title, so that these secondary normative provisions are aligned with  
the requirements of art. 20 of the Petroleum Law;  
2.3. the algorithm from which does not result in a specific, clear and transparent manner (i)  
the method of determining the level of the rate of profit considered to be reasonable or (ii) of  
a profitability interval whose lower and upper limits should be established on the basis of  
comparative studies, by referring to the practice in the field of other comparable European  
transport operators, as well as (iii) specific requirements for transparent justification by  
Conpet of the studies to substantiate any increases in the profitability rates considered in the  
establishment of transport tariffs, so that these secondary normative provisions are aligned  
with the requirements of art. 20 of the Petroleum Law;  
2.4. the tariff systems that are not currently focused on similar criteria and calculations for  
the two subsystems they regulate (i.e. the domestic and the import) that meet the  
requirements of ensuring equal treatment between the beneficiaries of the public transport  
service for the two types of subsystems, so that these secondary normative provisions are  
aligned with the requirements of art. 20 of the Petroleum Law;  
2.5.the procedural elements to ensure in a clear, transparent and efficient manner the right  
of Conpet customers to express their point of view regarding the advanced tariff proposals  
for approval by Conpet, based on specific documentation made available to them  
respectively to the revision/update requests of the rates sent by Conpet to N.A.M.R. and  
related documentation, as well as to receive a reasoned response from N.A.M.R. regarding  
the views expressed if they are not taken into account in full or in part by N.A.M.R., so that  
these secondary normative provisions are aligned with the requirements of art. 20 of the  
Petroleum Law and the transparency requirements applicable to the adoption of normative  
acts in compliance with the general European and national principle of good administration.  
3. Order the respondent to pay the court costs.  
After the communication of the summons request, but before the first court term (17.01.2023)  
58  
OMV PETROM amended the summons request regarding the first petition of the request  
asking the court to order:  
1. Regarding Order no. 229/2021:  
Partial annulment of art. 1 of Order 229/2021 regarding the tariffs established in Annex 1 and  
Annex 3 and, correspondingly, of Annexes 1 and 3 of Order 229/2021 regarding the tariffs  
for the DOMESTIC subsystem and the IMPORT subsystem, within the limit of the amount of  
the tariffs that will be established as legal as a result of their recalculation in a transparent  
and non-discriminatory manner, in accordance with the constitutional provisions and those  
of the primary and secondary petroleum and competition legislation, as they are submitted  
through this summons.  
2. Regarding Order no. 53/2008: partial cancellation of art. 3-8 of the Annex to Order no.  
53/2008, as well as the obligation of N.A.M.R. upon issuing a new order to properly complete  
Order no. 53/2008, by reference to the following:  
2.1. the method of determining in the Methodology the operating cost lacking transparency  
and clarity, with regard to (i) its component elements, the structure of each of these elements,  
not specifically provided for, along with (ii) the cost calculation algorithm of operation by  
referring to these elements and (iii) by taking into account only those elements that constitute,  
by their nature, operating costs, so that these secondary normative provisions are aligned  
with the requirements of art. 20 of the Petroleum Law;  
2.2. The algorithm for determining the modernization quota that does not provide in a specific,  
clear and transparent manner (i) the effective percentage of the modernization quota, (ii) the  
basis on which it is applied, (iii) the concrete investments in order to carry out pay the  
modernization quota by the beneficiaries of the transport system, (iv) the method of  
managing the surplus of amounts collected as modernization quota and unused until the end  
of the financial year that were charged for the realization of investments, by taking into  
account these amounts in the calculation of the modernization quota that the beneficiaries  
must pay in the following year, by referring to the investments considered within it and such  
amounts available for investments carried over from previous years, as well as (v) the method  
of managing the bank interest collected by the holder of the concession agreement as a  
result of depositing the sums received as a modernization quota and not used by him, in the  
sense of using the interests according to the same destination and taking into account these  
sums in the calculation of the modernization quota that the beneficiaries must pay in the  
following year with this title, so that these secondary normative provisions are aligned with  
the requirements of art. 20 of the Petroleum Law;  
2.3. The algorithm does not result in a specific, clear and transparent manner (i) the way to  
determine the level of the rate of profit considered to be reasonable or (ii) of a profitability  
interval whose lower and upper limits should be established based on comparative studies,  
by reference to the practice in the field of other comparable European transport operators,  
as well as (iii) specific requirements for transparent justification by CONPET of studies to  
substantiate any increases in profitability rates considered in the establishment of transport  
tariffs, so that these secondary normative provisions are aligned with the requirements of art.  
20 of the Petroleum Law;  
2.4. Tariff systems that are not currently focused on similar criteria and calculations for the  
two subsystems they regulate (i.e. the domestic and the import) that meet the requirements  
of ensuring equal treatment between the beneficiaries of the public transport service for the  
two types of subsystems, so that these secondary normative provisions are aligned with the  
requirements of art. 20 of the Petroleum Law;  
2.5. Procedural elements to ensure in a clear, transparent and efficient manner the right of  
59  
Conpet customers to express their point of view regarding advanced tariff proposals for  
approval by Conpet, based on specific documentation made available to them respectively  
to requests for revision/update of tariffs sent by Conpet to N.A.M.R. and related  
documentation, as well as to receive a reasoned response from N.A.M.R. regarding the  
points of view formulated if they are not taken into account in whole or in part by N.A.M.R.  
so that these secondary normative provisions are aligned with the requirements of art. 20 of  
the Petroleum Law and the transparency requirements applicable to the adoption of  
normative acts in compliance with the general European and national principle of good  
administration.  
3. Order the respondent to pay the court costs.  
Mentions: By the Sentence no. 898/28.05.2024, the Bucharest Court of Appeal rejects as  
unfounded the claimant's exception of lack of interest. It rejects as unfounded the exception  
of lack of passive procedural quality of the defendant Conpet S.A.It rejects as unfounded the  
request for summons, as amended. It rejects as unfounded the claimant's request to order  
the defendants to pay the legal expenses. With appeal after communication.  
Deadline: --  
2. Case File no. 7035/2/2022Bucuresti Court of Appeal pending  
Trial stage: Merits- suspended  
Parties: OMV Petrom SA - claimant  
NAMR - defendant  
CONPET S.A. defendant  
Object: The court is requested that, through the decision that will be pronounced, to order:  
1.Partial annulment of the art. 3 of Addendum no. 2 regarding the tariffs on the DOMESTIC  
subsystem and the IMPORT subsystem charged for the transport services provided by  
Conpet and established by Order no. 229/2021, within the limit of the amount of the tariffs  
that will be established as legal following the administrative litigation proceedings carried  
out by the Company regarding the tariffs with NAMR;  
2. Partial annulment of the art. 1 and 4 of Addendum no. 2, 6 and 9, respectively of art. 1  
and 3 of Addenda 3, 4, 5, 7 and 8 by which the duration of the Transport Contract was  
extended for the period 01.01.2022 - 31.08.2022 with the application of the new tariffs  
approved by the Order 229/2021, within the limit of the amount of the tariffs that will be  
established as legal following the administrative litigation proceedings carried out by the  
Company regarding the tariffs with N.A.M.R. and, as a consequence;  
3. The obligation of CONPET to pay to the Company, as compensation as a result of the  
partial cancellation of the Addenda, but also its illegal act of providing erroneous data that  
was the basis of the tariff development process by N.A.M.R. based on the Order no.  
229/2021 and then upon their payment by the Company based on the Addenda, of the  
amounts representing:  
(i) the difference between the amount of the tariffs provided for in the Addendum no. 2 to  
the transport contract, concluded as a result of the new tariffs adopted by the Order  
229/2021, paid by the Company in the period 01.01.2022 31.08.2022 as a result of the  
extension of the contractual period through the Addenda and the amount of the tariffs that  
will be established as legal in the result of the administrative litigation proceedings carried  
out by the Company regarding them with N.A.M.R., updated according to the inflation index,  
as well as the related legal interest calculated from the date of payment of the tariff  
difference;  
(ii) the difference between the amount of the tariffs paid by the Company for the transport  
60  
of crude oil, through the DOMESTIC subsystem, from the Midia Terminal, and the amount  
of the tariffs established proportionally, by reference to the tariffs of DOMESTIC and  
IMPORT according to the subsystem actually used for the transport of marine crude oil,  
updated in depending on the inflation index, as well as the related legal interest calculated  
from the date of payment of the tariff difference, for the following quantities transported  
from the Midia Terminal and for which the tariff for the country subsystem was illegally  
calculated and paid:  
- 13,905 tons from the art. 2 letter a) from Addendum no. 4 for March 2022;  
- 13,171 tons from the art. 2 letter a) from Addendum no. 5 for April 2022;  
- 13,307 tons from the art. 2 letter a) from Addendum no. 6 for May 2022;  
- 12,633 tons from the art. 2 letter a) from Addendum no. 7 for June 2022;  
- 12,072 tons from the art. 2 letter a) from Addendum no. 8 for July 2022;  
- 12,900 tons from the art. 2 letter a) from Addendum no. 9 for August 2022;  
(iii) any other amounts representing natural fruits that Conpet acquired or could have  
acquired in connection with the amounts illegally charged from the Company based on the  
tariffs;  
4. Obligation to pay legal expenses.  
The claimant OMV PETROM filed a request to change the heads of request no. 2 and 3 of  
the petition of the introductory action in the sense that, in addition to Addenda no. 2 9,  
the Company understands to challenge through this action the last 4 additional documents  
on the basis of which transport services were provided by Conpet between September and  
December 2022 for the benefit of the company, as follows:  
- Addendum no. 10/23.08.2022;  
- Addendum no. 11/22.09.2022;  
- Addendum no. 12/31.10.2022;  
- Addendum no. 13/22.11.2022.  
Therefore, considering the request to modify the preliminary action, the claimant OMV  
PETROM requests the court to order, through the judgment that will be ruled:  
1. 1. Partial annulment of the art. 3 of Addendum no. 2 regarding the tariffs on the domestic  
subsystem and the import subsystem charged for the transport services provided by  
Conpet and established by the Order no. 229/2021, within the limit of the amount of tariffs  
that will be established as legal following the administrative litigation proceedings carried  
out by the Company regarding the tariffs with N.A.M.R.;  
2. 2. Partial annulment of Art. 1 and 4 of Addendum no. 2, 6, 9 and 12 respectively of Art.  
1 and 3 of Addenda 3, 4, 5, 7, 8, 10, 11 and 13 by which the duration of the Transport  
contract was extended for the period 01.01.2022 - 31.12.2022 with the application of the  
new tariffs approved by Order no. No. 229/2021, within the limit of the amount of the tariffs  
that will be established as legal following the administrative litigation proceedings carried  
out by the Company regarding the tariffs with N.A.M.R. and consequently;  
3. Obliging Conpet to pay the Company, in the form of compensation as a result of the  
partial cancellation of Addenda no. 2 -13, but also of her illegal act of providing erroneous  
data that was the basis of the tariff development process by N.A.M.R. based on the Order  
no. 229/2021 and then upon their payment by the Company based on the Addenda, of the  
amounts representing:  
(i) the difference between the amount of the tariffs provided for in Addendum no. 2 to the  
transport contract, concluded as a result of the new tariffs adopted by Order no. 229/2021,  
paid by the Company in the period 01.01.2022 - 31.12.2022 as a result of the extension of  
61  
the contractual period through the Addenda and the amount of the tariffs that will be  
established as legal following the administrative litigation proceedings carried out by the  
Company regarding them with the N.A.M.R.., updated according to the inflation index, as  
well as the related legal interest calculated from the date of payment of the tariff difference;  
(ii) the difference between the amount of the tariffs paid by the Company for the transport  
of crude oil, through the DOMESTIC subsystem, from the Midia Terminal, and the amount  
of the tariffs established proportionally, by reference to the tariffs of DOMESTIC and  
IMPORT according to the subsystem actually used for the transport of marine crude oil,  
updated in depending on the inflation index, as well as the related legal interest calculated  
from the date of payment of the tariff difference, for the following quantities transported  
from the Midia Terminal and for which the tariff for the country subsystem was illegally  
calculated and paid:  
- 13,905 tons from the art. 2 letter a) from Addendum no. 4 for March 2022;  
- 13,905 tons from the art. 2 letter a) from Addendum no. 4 for March 2022;  
- 13,171 tons from the art. 2 letter a) from Addendum no. 5 for April 2022;  
- 13,307 tons from the art. 2 letter a) from Addendum no. 6 for May 2022;  
- 12,633 tons from the art. 2 letter a) from Addendum no. 7 for June 2022;  
- 12,072 tons from the art. 2 letter a) from Addendum no. 8 for July 2022;  
- 12,900 tons from Art. 2 letter a) from Addendum no. 9 for August 2022;  
- 12,213 tons from Art. 2 letter a) from Addendum no. 10 for September 2022;  
- 12,411 tons from Art. 2 letter a) from Addendum no. 11 for October 2022;  
- 11,836 tons from Art. 2 letter a) from Addendum no. 12 for November 2022;  
- 12,048 tons from Art. 2 letter a) from Addendum no. 13 for December 2022.  
(iii) any other amounts representing natural fruits that Conpet acquired or could have  
acquired in connection with the amounts illegally charged from the Company based on the  
tariffs;  
4. Obligation to pay legal expenses.  
Mentions: By the Conclusion dated 24.05.2023, the Court of Appeal of Bucharest rejects  
the application for revocation of the claimant from submitting the request to amend the  
heads of claims 2 and 3 of the request for summons as ungrounded. Based on art. 413  
paragraph 1 point 1 of the Code of Civil Procedure, it orders the suspension of the trial of  
the case until the final resolution of the case that is the subject of file no. 5971/2/2022 of  
the Bucharest Court of Appeal, Section IX of Administrative and Fiscal Litigation. With the  
right of appeal for the duration of the suspension.  
Deadline: --  
3. Case File no. 4988/2/2023 Bucuresti Court of Appeal pending  
Procedural status: Merits- suspended  
Parties: OMV Petrom SA - claimant  
NAMR - defendant  
CONPET S.A. defendant  
Object: The court is requested that, by the judgment that will be pronounced, to order:  
1. The partial annulment of art. 1 and art. 3 of the Addenda no. 10, no. 11 and no. 13,  
respectively of art. 1 and 4 of the Addendum no. 12, by which the duration of the transport  
contract was extended for the period 01.09.2022 - 31.12.2022 with the application of the new  
tariffs approved by the Order 229/2021, within the limit of the amount of the tariffs that will be  
established as legal following the administrative litigation proceedings carried out by the  
Company regarding tariffs with N.A.M.R. and, as a consequence,  
62  
2. Obliging CONPET to pay the Company, by way of compensation as a result of the partial  
cancellation of the Addenda no. 10-13, but also of its illegal act of providing erroneous data  
that formed the basis of the tariff development process by N.A.M.R. based on the Order no.  
229/2021 and then upon their payment by the Company based on the Addenda, of the  
amounts representing:  
i. the difference between the amount of the tariffs provided for in the Addendum no. 2 to the  
transport contract, concluded as a result of the new tariffs adopted by the Order 229/2021,  
paid by the Company in the period 01.09.2022 - 31.12.2022, as a result of the extension of  
the contractual period by the Addenda no. 10-13 and the amount of the tariffs that will be  
established as legal following the administrative litigation proceedings carried out by the  
Company regarding them with N.A.M.R., updated according to the inflation index, as well as  
the related legal interest calculated from the date of payment of the tariff difference;  
ii. the difference between the amount of tariffs paid by the Company for the transport of crude  
oil, through the domestic subsystem, from the Midia Terminal, and the amount of the tariffs  
established proportionally, by reference to the domestic and import tariffs according to the  
subsystem actually used for the transport of marine crude oil, updated according to the index  
of inflation, as well as the related legal interest calculated from the date of payment of the  
tariff difference, for the following quantities transported from the Midia Terminal and for which  
the tariff for the country subsystem was illegally calculated and paid;  
- 12,213 tons from art. 2 letter a) from the Addendum no. 10 for September 2022;  
- 12,411 tons from Art. 2 letter a) from Addendum no.11 for October 2022;  
- 11,836 tons from Art. 2 letter a) from Addendum no.12 for November 2022;  
- 12,048 tons from Art. 2 letter a) from Addendum no.13 for December 2022.  
iii. any other amounts representing natural fruits that Conpet acquired or could have acquired  
in connection with the amounts illegally charged from the Company based on the tariffs;  
3. Ordering the defendants to pay legal expenses.  
Mentions: On the term dated 15.11.2023, the Bucharest Court of Appeal ordered the  
suspension of the trial of this case until the final resolution of the case which is the subject  
matter of the file no. 7035/2/2022 of the Bucharest Court of Appeal. With the right of appeal  
for the duration of the suspension.  
Deadline: --  
4. File no. 5559/2/2023 - Bucharest Court of Appeal - Suspended  
Trial stage: First court  
Parties: OMV Petrom SA - claimant  
NAMR - defendant  
CONPET S.A. defendant  
Object: The court is requested that, by the judgment that will be pronounced, to order:  
1. The partial annulment of art. 1 of the Order no. 364/2022 regarding the tariffs established  
in Annex 1 and Annex 3 and, accordingly, Annexes 1 and 3 of the Order no. 364/2022,  
regarding the tariffs for the DOMESTIC subsystem and the IMPORT subsystem, within the  
limit of the amount of tariffs that will be established as legal as a result of their recalculation  
in a transparent and non-discriminatory manner, in accordance with the constitutional  
provisions and those of the legislation primary and secondary oil and competition, as they  
are exposed through the present summons;  
2. Ordering the defendants to pay legal expenses.  
Mentions: By the Conclusion of 18.04.2024, the Bucharest Court of Appeal rejects the  
connectedness challenge, as unfounded. Based on srt. 413, para.1. Item 1 from the Civil  
63  
Procedure Code, it suspends the trial of the case until the final resolution of the file pending  
before the Bucharest Court of Appeal, Division IX of Administrative and Fiscal Litigation  
under no. 5971/2/2022. With appeal during the suspension.  
Deadline: --  
5. File no. 8213/2/2023 - Bucharest Court of Appeal  
Trial stage: Merits- suspended  
Parties: OMV Petrom SA - claimant  
CONPET S.A. defendant  
NAMR - defendant  
Object: The court is requested that, by the judgment that will be pronounced, to order:  
1. The partial annulment of art. 1 and art. 3 of the Addendum no. 14, of art. 1 and 4 of the  
Addenda no. 15, no. 16, no. 17, respectively of art. 1 and 5 of the Addendum no. 18 by  
which the duration of the Transport Contract was successively extended for the period  
01.01.2023 - 31.12.2023, with the application of the new tariffs mentioned in the Notification  
no. 811/06, 01.2023 sent by Conpet regarding the change in transport tariffs through the  
National System for the Transport of Crude Oil, Rich gas, Condensate and Ethane ("SNT")  
starting from January 1, 2023, based on the Order 364/2022 (Annex 4), within the limit of  
the amount of the tariffs that will be established as legal as a result of the administration of  
evidence from this case;  
2. The partial annulment of art. 2 of the Addenda no. 14-18 in the sense of:  
i. the elimination of the quantities of 5-417 tons mentioned in the content of art. 2 letter a)  
from the Addendum no. 14 for the period January 1-15, 2023 that were transported from  
the Midia Terminal from the quantities transported through the domestic subsystem and  
the inclusion of the first quantities in those in point b) of the same article regarding the  
quantities transported through the import subsystem;  
ii. the elimination of the quantities of 15,061 tons from art. 2 letter a) from the Addendum  
no. 15 for the period January 16 - February 28, 2023 transported from the Midia Terminal  
from the quantities transported through the domestic subsystem and the inclusion of the  
first quantities in those in point b) of the same article regarding the quantities transported  
through the import subsystem;  
iii. the elimination of the quantities of 40,859 tons from art. 2 letter a) from the Addendum  
no. 16 for the period March 1 - June 30, 2023 transported from the Midia Terminal from the  
quantities transported through the domestic subsystem and the inclusion of the first  
quantities in those in point b) of the same article regarding the quantities transported  
through the import subsystem;  
iv. the elimination of the quantities of 28,811 tons mentioned in the content of art. 2 letter  
a) from the Addendum no. 17 for the period July 1 - September 30, 2023 transported from  
the Midia Terminal from the quantities transported through the domestic subsystem and  
the inclusion of the first quantities in those in point b) of the same article regarding the  
quantities transported through the import subsystem;  
v. the elimination of the quantities of 28,898 tons mentioned in the content of art. 2 letter a)  
from the Addendum no. 18 for the period October 1 - December 31, 2023 transported from  
the Midia Terminal from the quantities transported through the domestic subsystem and  
the inclusion of the first quantities in those in point b) of the same article regarding the  
quantities transported through the import subsystem;  
3. Obliging Conpet to pay the Company, in the form of compensation - as a result of the  
partial cancellation of the Addenda, but also of its illegal act of providing erroneous data  
64  
that was the basis of the tariff development process by N.A.M.R. based on the Order no.  
364/2022 and then upon their payment by the Company based on the Addenda, of the  
amounts representing:  
i. the difference between the amount of the tariffs provided for in the Addenda no. 14 -18  
to the Transport Contract concluded as a result of the new tariffs adopted by the Order no.  
364/2022, paid by the Company in the period 01.01.2023 - 31.12.2023 and the amount of  
tariffs that will be established as legal following the administrative litigation proceedings  
carried out by the Company regarding them with N.A.M.R., updated according to the  
inflation index, as and the related legal interest calculated from the date of payment of the  
tariff difference;  
ii. the difference between the amount of tariffs paid by the Company for the transport of  
crude oil, through the country subsystem, from the Midia Terminal, and the amount of the  
tariffs set proportionally, by reference to the country and import tariffs according to the  
subsystem actually used for the transport of marine crude oil, updated according to the  
index of inflation, as well as the related legal interest calculated from the date of payment  
of the tariff difference, for the following quantities transported from the Midia Terminal and  
for which the tariff for the country subsystem was illegally calculated and paid:  
- 5,417 tons from Art. 2 letter a) from Addendum no.13 for January 01 - 15, 2023;  
- 15,061 tons from Art. 2 letter a) from Addendum no.15 for January16th - February 28th,  
2023;  
- 40,859 tons from Art. 2 letter a) from Addendum no.16 for March 01st - June 30th, 2023;  
- 28,811 tons from Art. 2 letter a) from Addendum no.13 for July 01st - September 30th,  
2023;  
- 28,898 tons from Art. 2 letter a) from Addendum no.18 for October 1st - December 31st,  
2023;  
iii. any other amounts representing natural fruits that Conpet acquired or could have  
acquired in connection with the amounts illegally charged from the Company based on the  
tariffs;  
4. Ordering the defendants to pay legal expenses.  
Clarifications: By the Decision no. 775/26.04.2024, it admits the motion to dismiss for lack  
of jurisdiction. It declines the jurisdiction to resolve the case in favor of the Bucharest Court  
of Appeal, Administrative and Fiscal Litigation Division.  
By the Decision no. 6402/01.10.2024, the Bucharest Court of Appeal admits the motion  
to dismiss for lack of jurisdiction. It declines the jurisdiction to resolve the application in  
favor of the Bucharest Court of Appeal. It finds that a negative conflict of jurisdiction has  
arisen. It forwards the file to the High Court of Cassation and Justice for the resolution of  
the negative conflict of jurisdiction.  
By the Decision no. 5860/06.12.2024, the HCCJ establishes the jurisdiction to resolve the  
case concerning in favor of the Bucharest Court of Appeal.  
By the Conclusion of 11.03.2025, the Bucharest Court of Appeal suspends the trial of the  
case until the final resolution of file no. 5559/2/2023 of the Bucharest Court of Appeal.  
Deadline: --  
6. Case File no. 5071/2/2024 Bucuresti Court of Appeal pending  
Trial stage: First court  
Parties: OMV Petrom SA - claimant  
The National Regulatory Agency for Mining, Petroleum and Geological Storage of Carbon  
65  
Dioxide-A.N.R.M.P.S.G. (formerly N.A.M.R.) - defendant  
CONPET S.A. defendant  
Object: The court is requested that, by the judgment that will be pronounced, to order:  
1. Partial annulment of art. 1 of Order no. 340/2023 regarding the tariffs established in Annex  
1 and Annex 3 and, accordingly, of Annexes 1 and 3 of Order no. 340/2023, regarding the  
tariffs for the Domestic subsystem and the Import subsystem, within the limit of the amount  
of the tariffs that will be established as legal as a result of their recalculation in a transparent  
and non-discriminatory manner, in accordance with the constitutional provisions and those  
of the primary and secondary petroleum and competition legislation, as they are set out in  
this application for summons;  
2. Ordering the defendants to pay legal expenses.  
Mentions: By the Conclusion of 29.11.2024, the Bucharest Court of Appeal suspends the  
trial of the case until the final resolution of file no. 5971/2/2022 pending before the Bucharest  
Court of Appeal. With the right of appeal for the entire period of suspension.  
Deadline: --  
7. File no. 8081/2/2024 - Bucharest Court of Appeal  
Parties: OMV Petrom SA - claimant  
CONPET S.A. defendant  
The National Regulatory Agency for Mining, Petroleum and Geological Storage of Carbon  
Dioxide-A.N.R.M.P.S.G. (formerly N.A.M.R.) - defendant  
Object: Request for summons against Addendum no. 19 of 22.12.2023 and Addendum no.  
20 of 19.03.2024 to the Contract for the transport of crude oil, rich gas and condensate no.  
BC OMV 108/25.03.2020 concluded between OMV Petrom S.A. and Conpet S.A.  
The court is requested that, by the judgment that will be pronounced, to order:  
1. Partial annulment of art. 3 of Addendum no. 19, as well as art. 1 and 4 of Addendum no.  
20, by which the duration of the Transport Contract was extended monthly, successively, for  
the periods 01.01.2024 - 31.03.2024 and, respectively, for 01.04.2024 - 30.06.2024,  
regarding the tariffs established by N.A.M.R. Order no. 340/2023 regarding the approval of  
transport tariffs through the National Transport System for crude oil, rich gas, condensate  
and ethane ("Order 340/2023", Annex 3), within the limit of the amount of the tariffs that will  
be established as legal, as a result of the administration of the evidence in this case;  
2. Partial annulment of art. 2 of Addenda no. 19-20, in the sense of:  
(i) the elimination of the quantities of 28,163 tons, mentioned in art. 2 letter a) of Addendum  
no. 19, for the period 01.01.2024 31.03.2024, transported from the Midia Terminal from  
the quantities transported through the Domestic subsystem and the inclusion of the former  
quantities in those in point b) of the same article relating to the quantities transported through  
the Import subsystem;  
(ii) the elimination of the quantities of 23,881 tons, mentioned in art. 2 letter a) of Addendum  
no. 20, for the period 01.04.2024 - 30.06.2024, transported from the Midia Terminal from the  
quantities transported through the Domestic subsystem and the inclusion of the first  
quantities in those in point b) of the same article relating to the quantities transported through  
the Import subsystem,  
3. Obliging Conpet to pay to the Company, as compensation as a result of the partial  
annulment of the Addenda, but also of its unlawful act of providing erroneous data that formed  
the basis of the tariff development process by N.A.M.R. based on the Order no. 340/2023  
and then upon their payment by the Company based on the Addenda, the amounts  
representing:  
66  
(i) the difference between the amount of the tariffs provided for in Addenda no. 19 -20 to the  
Transport Contract concluded as a result of the new tariffs adopted by the Order no.  
340/2023, paid by the Company during the period 01.01.2024 30.06.2024 and the amount  
of the tariffs that will be established as legal following the administrative litigation proceedings  
carried out by the Company regarding them with N.A.M.R., updated according to the inflation  
index, as well as the related legal interest calculated from the date of payment of the tariff  
difference;  
(ii) the difference between the amount of tariffs paid by the Company for the transport of  
crude oil, through the Domestic subsystem, from the Midia Terminal, and the amount of tariffs  
established proportionally, by reference to the Country and Import tariffs depending on the  
subsystem actually used for the transport of marine crude oil, updated according to the  
inflation index, as well as the related legal interest calculated from the date of payment of the  
tariff difference, for the following quantities transported from the Midia Terminal and for which  
the tariff for the Domestic subsystem was illegally calculated and paid:  
- 28,163 tons from art. 2 letter a) of Addendum no. 19 for the period 01.01.2024-31.03.2024;  
- 23,881 tons from art. 2 letter a) of Addendum no. 20 for the period 01.04.2024 - 30.06.2024;  
(iii) any other amounts representing natural fruits that Conpet acquired or could have  
acquired in connection with the amounts illegally charged from the Company based on the  
tariffs;  
4. Ordering the defendants to pay legal expenses.  
Mentions: --  
Trial stage: First court  
Deadline: --  
The list of litigations in which Conpet S.A. is a party, pending before the courts on 14.03.2025  
can be found in Annex no. 6.  
Other aspects related to the company’s tangible assets  
State of the lands not included in the share capital  
Currently, all the lands owned by CONPET S.A. are registered in the Integrated Cadastre  
System and the Land Registry.  
On 31.12.2024 Conpet has registered in the company's patrimony land with an area of  
738,292 sq.m, with a fair amount of 30,050,103 RON, held based on the Land Ownership  
Certificates and sale-purchase contracts.  
The company augmented its share capital only by a part of the land plots held under the land  
ownership certificates, not being included in the share capital lands in surface of 554,537.61  
sq.m., (554,201 sq.m according to the latest land register update documents), which are  
contained in 48 CADP. The Ownership certificates for these lands have been issued between  
2001 - 2005 and the value evaluated at the time of issuing the certificates, established  
according to GD no. 834/1991 is of 26,708,233 RON. These lands have been recorded in  
the company’s patrimony at the expense of equity. The fair value of these land plots on  
31.12.2023, according to the report prepared by an ANEVAR authorized appraiser, amounts  
to 16,293,210 RON.  
The Board of Directors has undertaken all steps in view of augmentation of the share capital  
by the value of land held based on the land ownership certificates.  
67  
Thus, based on the land appraisal reports, in compliance with the provisions of Art. 6 Para  
(3) of GD no.834/1991 subsequent amendments and completions, drafted by expert  
appraiser, the Board of Directors has summoned the Extraordinary General Meeting of  
Shareholders, on 19.05.2016, in first call, namely 20.05.2016, in second call. At both EGMS  
meetings the quorum has not met.  
Although two general meetings of shareholders have been convened, the Board of Directors  
has summoned a new EGMS for 05.07.2016, with the same Agenda. Following the cast vote  
by the shareholders present and represented, the proposal to augment the share capital has  
not been approved, due to the lack of necessary quorum for approval votes.  
Subsequently, there have been undertaken all necessary steps for the augmentation of the  
share capital, and on 26.03.2019, the EGMS approved the initiation of the procedure for the  
augmentation of the share capital and the appointment by the Trade Register Office Prahova  
of an expert authorized to assess the lands brought as contribution to the share capital.  
Based on the new appraisal report has been convened the EGMS, on 04.07.2019 in first call  
and 05.07.2019 in second call, with the Agenda - Approval of the augmentation of the share  
capital by maximum value of 101,763,954.60 RON, representing contribution in kind (lands)  
in amount of 59,751,935.10 RON and cash amounting to maximum 42,012,019.50 RON,  
from the current value of 28,569,842.40 RON at the value of maximum 130,333,797 RON,  
by issuing a number of maximum 30,837,562 new, nominative, dematerialized shares, at a  
price of 3.3 RON/share, equal to the nominal value, without share premium.  
In both EGMS meetings has not been met the attendance quorum provided by the law,  
necessary for the augmentation of the share capital with contribution in kind.  
On 24.09.2020, the EGMS issued Resolution no. 1, by which it approved the initiation of the  
operation to augment the share capital by the value of the lands held based on the 48  
ownership certificates and the initiation of formalities to the N.R.C. with a view to appoint an  
authorized appraiser for the valuation of the lands.  
In order to comply with the EGMS Resolution, between September and December 2020,  
three requests were made to the Prahova Trade Register Office for the appointment of an  
appraiser to draw up the land evaluation report in accordance with Art. 6, Para. 3 of GD no.  
834/1991.  
In March 2021, by Resolution no. 1 dated 10.03.2021 and Resolution no. 2 dated 11.03.2021,  
the EGMS did not approve the augmentation of the share capital by the value of the lands  
not included, as during the two meetings the attendance quorum provided by law (85%) was  
not met.  
On 28.04.2022, the EGMS issued Resolution no.1, by which it approved the initiation of the  
operation to augment the share capital by the value of the lands held based on the 48  
ownership certificates and the initiation of formalities to Prahova Trade Register Office to  
appoint an authorized appraiser for land valuation.  
In May 2022, two requests were made to the O.R.C. Prahova, for the appointment of an  
appraiser to draw up the land evaluation report, in accordance with art. 6, para. 3 of GD no.  
834/1991.  
68  
Based on the evaluation report, prepared by the evaluator appointed by O.R.C. Prahova,  
Nitu Cornel, ANEVAR member with card no. 14579, by Resolution no. 2 dated 20.09.2022  
and Resolution no. 3 dated 21.09.2022, the EGMS of Conpet did not approve the  
augmentation of the share capital by the value of the unincluded land plots, as, at the two  
meetings, the quorum of attendance provided for by the law was not met (85%).  
To date, the share capital has not been augmented by the value of the not included land  
plots.  
In 2023, GEO no. 26/20 April 2023 was adopted for amending and supplementing Art. 12 of  
Law nr. 137/2002 on some measures to accelerate privatization, which brought a new  
provision regarding the value by which the share capital is increased with the lands for which  
CADP was obtained in the sense that "the increase of the share capital provided for in para.  
(4^1) with the contribution in kind of the state or of an administrative-territorial unit, as the  
case may be, representing the lands for which certificates attesting the ownership right have  
been obtained, shall be made at the fair value (our note) determined no later than 90 days  
before the date of convening the extraordinary general meeting of shareholders for the  
approval of the share capital increase.”  
However, for the maintenance in force of the provisions of Article 6 Para. 3 of GD no.  
834/1991, the issue of the value by which the share capital is augmented requires  
clarifications, which leads to delays in convening again the General Meeting of Shareholders  
in order to increase the share capital.  
In order to clarify this issue, we addressed the Ministry of Energy, the guardianship authority,  
in order to indicate the criterion for determining the value of land, respectively the one  
regulated by Art. 6 of GD no. 834/1991 (by updating with the inflation index) or the one  
regulated by Art.12 of Law no. 137/2002 (by fair value measurement), as amended by GD  
no. 26/2023.  
4.3 Analysis of the Financial Activity  
The financial information presented in this report is taken from financial statements for the  
period ended December 31, 2024, prepared in accordance with Order of the Minister of  
Public Finances no. 2844/2016, audited.  
4.3.1 Statement of the Financial Standing  
Variation%  
Indicators  
2024  
2023  
2022  
2024/2023  
2023/2022  
ASSETS  
Fixed assets  
Tangible assets  
Intangible assets  
664,781  
3,038  
535  
670,831 607,025  
▼ 0.9%  
▼ 45.4%  
▼ 78.8%  
▲ 10.5%  
▼ 18.9%  
▼ 0.6%  
5,559  
2,523  
6,855  
2,537  
Financial Assets  
Deferred corporate tax  
receivables  
2,876  
-
6,153  
-
-
Total non-current assets  
671,230  
678,913 622,570  
1.1%  
▲ 9.1%  
Current assets  
69  
   
Variation%  
Indicators  
2024  
6,016  
2023  
6,520  
52,981  
2022  
2024/2023  
2023/2022  
Inventories  
6,867  
49,187  
▼ 7.7%  
▼ 5.1%  
Trade receivables and other  
receivables  
39,442  
▼ 25.6%  
▲ 7.7%  
Cash and cash equivalents  
136,177  
687  
107,742 127,673  
698 1,252  
▲ 26.4%  
▼ 1.6%  
▲ 8.6%  
0.8%  
▼ 15.6%  
▼ 44.3%  
9.2%  
4.9%  
Prepaid expenses  
Total current assets  
TOTAL ASSETS  
182,322  
853,552  
167,941 184,979  
846,854 807,549  
EQUITY AND LIABILITIES  
Equities  
Subscribed and paid-up share  
capital  
28,570  
28,570  
28,570  
-
-
Legal reserves  
5,714  
43,539  
558,423  
45,124  
49,323  
730,693  
5,714  
5,714  
-
▼ 12.6%  
▲ 2.0%  
-
▲ 191.4%  
▲ 2.6%  
▼ 0.5%  
▼ 0.1%  
▲ 6.8%  
Revaluation reserves  
49,838  
17,101  
Other reserves  
547,585 533,898  
Retained earnings  
Result of the year  
Total equities  
36,971  
61,617  
37,149  
61,664  
▲ 22.1%  
▼ 20.0%  
▲ 0.1%  
730,295 684,096  
Long-term liabilities  
Liabilities to employees  
30,237  
2,423  
-
25,765  
2,793  
901  
23,069  
2,749  
-
▲ 17.4%  
▼ 13.3%  
-
▲ 11.7%  
▲ 1.6%  
-
Other long-term liabilities  
Deferred Tax Liabilities  
Total long-term liabilities  
Current liabilities  
32,660  
29,459  
25,818  
10.9%  
14.1%  
Trade liabilities  
26,574  
-
33,092  
1,808  
43,915  
1,997  
▼ 19.7%  
-
▼ 24.6%  
▼ 9.5%  
▲ 4.3%  
▼ 1.5%  
▼ 5.1%  
10.8%  
5.6%  
Current corporate tax  
Other liabilities  
33,028  
14,276  
16,321  
90,199  
122,859  
28,764  
14,143  
9,293  
27,569  
14,364  
9,790  
▲ 14.8%  
▲ 1.0%  
▲ 75.6%  
3.6%  
5.4%  
Liabilities to employees  
Short-term provisions  
Total current liabilities  
Total liabilities  
87,100  
97,635  
116,559 123,453  
TOTAL EQUITIES AND  
LIABILITIES  
853,552  
846,854 807,549  
0.8%  
4.9%  
Table 15 - Company’s Statement of the financial standing during 2022- 2024 (thousand RON)  
The total assets of the company register an increase by 0.8% (6,698 thousand RON)  
compared to December 31, 2023, mainly due to the increase in fixed assets.  
The intangible assets recorded a 1.1% decrease as compared to December 31st, 2023,  
mainly generated by inflows of tangible and intangible assets in total value lower than the  
decrease in the value of depreciated assets recorded in 2024.  
The current assets increased by 14,381 thousand RON (8.6%), from 167,941 thousand  
RON on 31.12.2023 to 182,322 thousand RON on 31.12.2024.  
In structure, the evolution of the main elements is different, the cash available registering an  
increase by 26.4% (28,435 thousand RON), while receivables decreased by 25.6% (13,539  
thousand RON).  
70  
The equity registered a slight increase of 0.1% (398 thousand RON) as to December 31st,  
2023 reaching 730,693 thousand RON.  
The total liabilities increased by 6,300 thousand RON on December 31st, 2024, as  
compared to the value on December 31, 2023 due to the increase in long-term liabilities.  
The long-term liabilities record an increase by 3,201 thousand RON as compared to  
December 31, 2023.  
Current liabilities, in amount of 90,199 thousand RON, are increasing by 3,099 thousand  
RON as compared to December 31, 2023, mainly due to the increase of the short-term  
provisions.  
Trade Liabilities and Other Liabilities  
On December 31, 2024 and December 31, 2023, the trade liabilities and other liabilities look  
as follows:  
Maturity date for the balance on  
December 31, 2024  
Under 1 1-5 years Over 5  
years  
December December  
Liabilities  
31, 2023  
31, 2024  
year  
Trade liabilities  
26,574  
26,574  
-
-
33,092  
Liabilities to the employees  
Current Corporate Tax  
Deferred Tax Liabilities  
Provisions liabilities  
Other liabilities  
39,908  
1,808  
901  
9,293  
31,557  
116,559  
44,513  
-
14,276  
-
4,764  
25,473  
-
-
-
-
-
-
-
-
16,321  
35,451  
122,859  
16,321  
33,028  
90,199  
1,717  
6,481  
706  
26,179  
Total  
Table 16 - Status of the trade liabilities and other liabilities on December 31st, 2024 (kRON)  
On 31.12.2024, the company Conpet S.A. did not register outstanding payments.  
The trade liabilities related to the purchases of goods and services intended for operating  
activities have a weight of 73.9% in total commercial debts, and those representing  
purchases of fixed assets have a weight of 26.1%.  
The debts to employees, in balance on the date of 31.12.2024, also include the future debts  
for the benefits granted to employees on retirement or death, for the employees’ share of  
profit, for the untaken leaves of the employees, debts that are recognized as provisions.  
The statement of the employee-related liabilities, fiscal liabilities and other maturity date  
liabilities look as follows:  
71  
Maturity date for the balance on  
December 31, 2024  
December 31, December 31,  
2023 2024  
Debts  
Under 1  
year  
1-5  
years  
Over 5  
years  
Salaries contributions  
Royalty due to the State  
Budget  
6,222  
10,271  
6,689  
11,682  
6,689  
11,682  
-
-
-
-
Payable VAT  
Other interests and debts -  
Budget  
4,111  
1,221  
5,061  
1,910  
5,061  
1,910  
-
-
-
-
Payable Dividends  
Leasing related liabilities  
Accrued revenues  
Other liabilities  
5,444  
3,347  
696  
5,718  
3,621  
613  
5,718  
1,742  
82  
-
-
1,380  
324  
499  
207  
-
245  
157  
144  
13  
Total  
31,557  
35,451  
33,028  
1,717  
706  
Table 17 - Situation regarding contributions related to salaries and other fiscal liabilities on  
December 31, 2024 (kRON)  
On 31.12.2024, leasing liabilities comprise recognized rights of use for leases and  
concessions of land, buildings and rail tanks.  
The liabilities related to the rights of use recognized for the lease and concession contracts  
of some lands, buildings and rail tanks have been assessed at the value of rent fees/royalties  
along the remaining contractual period, discounted with the credit rate for real estate loans.  
The statement of debts to employees on maturity terms reveals the following:  
Maturity date for the balance on  
December 31, 2024  
December December  
Debts  
31, 2023  
31, 2024  
Under 1  
year  
Over 1 year Over 5 year  
Salaries and assimilated debts  
Liabilities for benefits granted  
on retirement  
Liabilities for the benefits  
granted in case of death  
Liabilities for the employees’  
share of profit  
7,140  
8,044  
26,479  
8,044  
581  
-
-
22,090  
4,156  
6,003  
4,565  
21,333  
4,140  
-
4,339  
5,064  
-
199  
-
5,064  
Liabilities for untaken leaves  
Liabilities for other employee  
benefits  
519  
-
433  
154  
433  
154  
-
-
-
-
Total  
39,908  
44,513  
14,276  
4,764  
25,473  
Table 18 - Statement of the liabilities to the employees on December 31st, 2024 (kRON)  
On December 31, 2024, the Company mainly comprises at this chapter the salaries and  
assimilated debts, as well as future debts for benefits granted upon retirement or death and  
for the employees share of profit, recognized as provisions.  
4.3.2. The global result statement  
The evolution of the main financial indicators of the profit and loss account and of other global  
result elements, during 2022- 2024, is presented below:  
72  
 
Variation%  
Indicator  
2024  
533,618  
2023  
2022  
2024/2023  
2023/2022  
Revenues from contracts  
Gain from disposal of assets  
Other revenues  
485,114  
612  
472,233  
5,402  
▲ 10.0%  
-
▲ 2.7%  
▼ 88.7%  
▲ 24.3%  
-
72,664  
55,208  
44,425  
▲ 31.6%  
Total operating revenues  
606,282  
6,145  
540,934  
6,543  
522,060  
6,934  
▲ 12.1%  
▲ 3.6%  
Inventories Expenses  
▼ 6.1%  
▲ 12.5%  
▲ 8.1%  
▼ 5.6%  
▼ 44.9%  
▲ 7.5%  
20,916  
210,186  
18,597  
194,395  
33,739  
180,923  
Expenses with energy and water  
Personnel expenses  
Value adjustments of fixed assets, less  
adjustments related to rights of use  
resulted from leasing contracts  
79,156  
2,141  
61,485  
2,051  
53,075  
1,987  
▲ 28.7%  
▲ 4.4%  
▲ 15.9%  
▲ 3.2%  
Value adjustments on rights of use resulted  
from leasing contracts  
Value adjustments on current assets  
Expenses related to external services  
Provision adjustments  
7,641  
144,041  
12,193  
91  
(239)  
126,936  
2,446  
-
(767)  
114,242  
6,753  
-
-
▲ 13.5%  
▲ 398.5%  
-
-
▲ 11.1%  
▼ 63.8%  
-
Loss from disposal of assets  
Other expenses  
74,286  
62,357  
62,405  
▲ 19.1%  
▲ 17.3%  
▼ 25.4%  
▼ 4.6%  
▼ 0.1 %  
▲ 3.3%  
▲ 5.7%  
▼ 32.0%  
Total operating expenses  
Operating Profit  
556,796  
49,486  
6,384  
474,571  
66,363  
6,690  
459,291  
62,769  
9,839  
Financial Revenues  
Interest expenses related to leasing  
contracts  
238  
175  
236  
▲ 36.0%  
▼ 25.9%  
Other financial expenses  
94  
332  
84  
259  
233  
469  
11.9%  
▲ 28.2%  
▼ 5.9%  
▼ 23.7%  
▼ 3.4%  
64.0%  
▼ 44.8%  
▼ 31.4%  
▲ 0.9%  
▼ 9.4%  
Financial Expenses  
Financial profit  
6,052  
55,538  
10,227  
6,431  
72,794  
10,587  
9,370  
72,139  
11,686  
Profit before corporate tax  
Expenses with current corporate tax  
Expenses with (revenues coming from)  
deferred corporate tax  
(4,012)  
49,323  
1,230  
590  
61,617  
531  
(1,211)  
61,664  
(1,599)  
-
▼ 20.0%  
▲131.6%  
-
▼ 0.1%  
-
PROFIT OF THE YEAR  
Actuarial gain (loss) granted upon  
retirement and death benefits  
Surplus from revaluation of the tangible  
assets  
-
35,055  
-
-
-
-
-
-
-
Other elements of the equities - retained  
earnings:  
755  
Total other global result elements that  
will not be subsequently reclassified as  
profit or loss  
1,985  
7,844  
7,844  
9,829  
35,586  
6,870  
(1,599)  
17,409  
17,409  
15,810  
▼ 94.4%  
▲ 14.2%  
▲ 14.2%  
▼ 76.9%  
-
▼ 60.5%  
▼ 60.5%  
▲168.5%  
Net increase of the modernization quota  
reserve  
Total other global result elements that  
will be subsequently reclassified as  
profit or loss  
6,870  
TOTAL OTHER ELEMENTS OF THE  
GLOBAL RESULT  
42,456  
TOTAL GLOBAL RESULT  
Result per share  
59,152  
5.70  
104,073  
7.12  
77,474  
7.12  
▼ 43.2%  
▼ 19.9%  
▲ 34.3%  
-
Table 19 - Statement of the global result during 2022- 2024 (thousand RON)  
73  
The synthesis of the financial results, in evolution 2022- 2024, is as follows:  
Chart 17 - Synthesis of the financial results during 2022- 2024 (mRON)  
Operating Revenues  
As compared to the approved budget and the previous period (2022 - 2023), the total  
revenues of the operating activity and the transported volume in 2024 is as follows:  
2024  
Variation  
(%)  
Variation%  
Achieved/  
Budget  
2024  
Indicators  
2024  
2023  
2022  
2024/  
2023  
2023/  
2022  
Achieved  
Budget  
Transport services based on tariffs approved by A.N.R.M.P.S.G. Order - Domestic Subsystem  
2,802  
2,793  
357,526  
▲ 0.3%  
▲ 0.3%  
thousand tons  
thousand Ron  
2,802  
2,915  
3,046  
▼ 3.9%  
▲ 4.3%  
▼ 4.3%  
▲ 7.0%  
358,670  
358,670 343,752 321,320  
Transport services based on tariffs approved by A.N.R.M.P.S.G. Order - Import Subsystem  
4,206  
4,184  
166,458  
▲ 0.5%  
▲ 0.8%  
thousand tons  
thousand Ron  
4,206  
3,072  
3,944  
▲ 36.9% ▼ 22.1%  
▲ 29.0% ▼ 9.7%  
167,786  
167,786 130,096 144,044  
Total quantities and revenues from transport services based on tariffs approved by A.N.R.M.P.S.G. Order  
7,008  
6,977  
523,984  
▲ 0.4%  
▲ 0.5%  
thousand tons  
thousand Ron  
7,008  
5,987  
6,990  
▲ 17.1% 14.4%  
▲ 11.1% ▲ 1.8%  
526,456  
526,456 473,848 465,364  
Other types of operations related to the N.T.S.  
123  
97  
▲ 26.8%  
▲ 10.0%  
thousand tons  
thousand Ron  
123  
307  
110  
▼ 59.9% ▲179.1%  
4,935  
4,486  
4,935  
9,025  
4,493  
▼ 45.3% ▲100.9%  
Total general crude oil, rich gas and condensate transport activity  
7,131  
7,074  
528,470  
▲ 0.8%  
▲ 0.6%  
thousand tons  
thousand Ron  
Revenues from  
rents  
7,131  
6,294  
7,100  
▲ 13.3% 11.4%  
531,391  
531,391 482,873 469,857  
▲ 10.0%  
▲ 2.8%  
1,906  
1,888  
▲ 1.0%  
1,906  
321  
2,078  
163  
1,966  
410  
▼ 8.3%  
▲ 5.7%  
Other Turnover  
Revenues  
321  
180  
▲ 78.3%  
▲ 96.9% ▼ 60.2%  
10.0% ▲ 2.7%  
530,538  
533,618  
0.6%  
Turnover  
533,618 485,114 472,233  
Write-back to  
revenues of reserve  
constituted based  
59,600  
59,588  
-
59,600  
51,226  
39,912  
▲ 16.4% ▲ 28.3%  
74  
2024  
Variation  
(%)  
Variation%  
Achieved/  
Budget  
2024  
Indicators  
2024  
2023  
2022  
2024/  
2023  
2023/  
2022  
Achieved  
Budget  
on the expenses  
with the  
modernization  
quota  
Earnings from  
disposal of assets  
Other revenues  
Total other  
operating  
-
-
-
-
612  
5,402  
4,513  
-
▼ 88.7%  
13,064  
11,171  
▲ 16.9%  
13,064  
3,982  
228.1% ▼ 11.8%  
72,664  
70,759  
▲ 2.7%  
72,664  
55,820  
49,827  
▲ 30.2% 12.0%  
revenues  
Total operating  
revenues  
601,297  
606,282  
▲ 0.8%  
606,282 540,934 522,060  
▲ 12.1%  
▲ 3.6%  
Table 20 - Operating income statement year 2024 compared to the Budget and compared to the period  
between 2022- 2023 (thousand RON)  
The revenues achieved from transport on subsystems in 2024, compared to the budget and  
the period 2022 - 2023, are as follows:  
Chart 18 - The evolution of the revenues achieved from transport on subsystems 2022 - 2023 vs. Budget 2024  
(mRON)  
The operating revenues recorded an increase by 0.8% as compared to Budget. Compared  
to 2023 the increase in the operating revenues was 12.1% (65,348 thousand Ron).  
The transport revenues hold a share of 99.6% in turnover, the difference of 2,227 thousand  
RON (0.4%) representing revenues from various activities such as: leases of lands and  
telecommunication equipment, rail shunting, etc.  
The revenues from the reserve representing the modernization quota are also recognized in  
the operating income, revenues recognized at the level of depreciation of the fixed assets  
financed from this quota. These revenues hold 82% of other operating revenues. In 2024,  
75  
there was an increase of 16.4%, compared to the same period of 2023, due to the increase  
in the depreciation of fixed assets financed from the modernization quota, thus increasing  
the revenues recorded from reserve the modernization quota.  
The category “Other revenues" mainly includes the amounts to be recovered (debits)  
established by final court decisions in forced execution (8,002 thousand RON).  
Operating Expenses  
The operating expenses achieved in 2024, as compared to the last 2 years and the budget  
provisions, are as follows:  
Variation%  
Achieved/  
Budget  
Variation%  
Achieved  
2024  
Budget  
2024  
Indicators  
2024  
2023  
2022  
2024/  
2023/  
2022  
2023  
2024  
Material expenses,  
out of which:  
6,145  
6,566  
▼ 6.4%  
6,145  
6,543  
6,934  
6.1%  
5.6%  
- expenses with  
consumables  
3,427  
1,956  
3,385  
2,085  
1.2%  
3,427  
1,956  
3,489  
2,102  
3,629  
2,253  
▼ 1.8%  
▼ 3.9%  
▼ 6.7%  
▼ 6.2%  
- fuel expenses  
Other external  
expenses (with  
energy and water)  
Personnel expenses,  
out of which:  
7.0%  
20,916  
21,654  
3.4%  
20,916  
18,597  
33,739  
▲ 12.5%  
44.9%  
210,186  
210,619  
▼ 0.2%  
210,186  
194,395  
180,923  
▲ 8.1%  
▲ 7.5%  
164,820  
164,995  
▼ 0.1%  
- salaries expenses  
164,820  
155,825  
143,346  
▲ 5.8%  
8.7%  
- expenses related to  
insurance, social  
protection and other  
legal obligations  
4,118  
4,160  
▼ 1.0%  
▼ 0.5%  
4,118  
4,157  
4,060  
▼ 0.9%  
▲ 2.4%  
▲ 2.7%  
- other personnel  
41,248  
41,464  
41,248  
34,413  
33,517  
▲ 19.9%  
expenses  
Value adjustments of  
fixed assets, less  
79,156  
78,272  
1.1%  
adjustments related to  
rights of use resulted  
from leasing contracts  
Value adjustments for  
rights of use resulted  
from leasing contracts  
Expenses with  
79,156  
2,141  
61,485  
53,075  
▲ 28.7%  
▲ 15.9%  
2,141  
2,158  
▼ 0.8%  
2,051  
1,987  
4.4%  
3.2%  
144,041  
145,767  
1.2%  
external services, out 144,041  
of which:  
126,936  
114,242  
13.5%  
▲ 11.1%  
- maintenance  
3,104  
3,382  
▼ 8.2%  
▲ 0.2%  
(maintenance, current  
repairs)  
3,104  
2,532  
2,789  
22.6%  
9.2%  
- expenses with crude  
oil transport by railway  
78,209  
78,046  
78,209  
71,645  
61,430  
9.2%  
▲ 16.6%  
- expenses with  
decontamination works  
563  
1,467  
▼ 61.6%  
563  
296  
1,939  
▲ 90.2%  
▼ 84.7%  
▲ 5.5%  
47,589  
47,419  
0.4%  
- oil royalty  
47,589  
38,519  
36,511  
23.6%  
- other services  
performed by third  
parties  
14,576  
15,453  
▼ 5.7%  
14,576  
13,944  
11,573  
4.5%  
▲ 20.5%  
Value adjustments on  
current assets  
7,641  
7,789  
▼ 1.9%  
7,641  
(239)  
(767)  
-
-
76  
Variation%  
Achieved/  
Budget  
Variation%  
Achieved  
2024  
Budget  
2024  
Indicators  
2024  
2023  
2022  
2024/  
2023/  
2022  
2023  
2024  
Provisions  
adjustments  
12,193  
91  
8,196  
67  
▲ 48.8%  
12,193  
91  
2,446  
-
6,753  
-
▲398.5%  
▼ 63.8 %  
Loss from disposal of  
assets  
35.8%  
-
-
Other operating  
expenses, out of  
which:  
74,286  
72,109  
3.0%  
74,286  
62,357  
62,405  
▲19.1%  
▼ 0.1%  
- modernization quota  
expenses  
67,445  
64,892  
▲ 3.9%  
67,445  
58,084  
57,321  
▲ 16.1%  
▲ 1.3%  
Total operating  
expenses  
556,796  
553,197  
0.7%  
556,796  
474,571  
459,291  
▲ 17.3%  
▲ 3.3%  
Table 21 - Operating income statement year 2024 compared to the Budget and compared to the period between  
2022- 2023 (thousand RON)  
The operating expenses achieved during January - December 2024 increased by 17.3% as  
compared to 2023, from 474,571 thousand RON to 556,796 thousand RON.  
The increase in operating expenses was mainly driven by the increase in some operating  
expenses, of which we exemplify: rail transport services, expenses calculated on the basis  
of revenues (oil royalty and modernization quota), personnel expenses, provisions and value  
adjustments for current assets and fixed assets (depreciation).  
Provisions and adjustments for the impairment of current assets are recorded for debts  
related to legal files pending in court and debts recorded in the accounting records based on  
final judgments obtained in court, subject to enforcement, as well as fines paid and in the  
appeal procedure, for benefits granted to employees upon retirement or death, for the  
employees’ share of profit.  
As compared to the budget approved for 2024, the operating expenses achieved on  
31.12.2024 were higher by 3,599 thousand RON (0.7%). The budget execution table dated  
31.12.2024 shows that there were savings on some types of expenses (materials - 421  
kRON, electricity and natural gas - 738 kRON, personnel expenses - 433 kRON, provided  
services - 1,726 kRON), but also overruns on other types of expenses (depreciation 884  
kRON, provisions and adjustments for the depreciation of other receivables 3,996 kRON, oil  
royalty 170 kRON, etc.).  
The statement of the personnel expenses achieved in 2022 - 2024, is as follows:  
Indicators  
2024  
2023  
2022  
Total personnel expenses, out of which:  
210,186  
194,395  
180,923  
a). Salary expenses  
164,820  
28,281  
155,825  
25,284  
143,346  
21,171  
b). Bonuses awarded as per CLA  
Expenses on severance payments related to  
personnel layoffs  
c).  
2,641  
40  
3,912  
Expenses related to the mandate contracts of  
d). the Board of Directors and the Directors with  
a mandate contract  
6,212  
5,251  
4,848  
e). Labor insurance contribution expenses  
4,114  
2,722  
3,838  
2,774  
3,585  
2,872  
Company's contribution to voluntary pension  
f).  
schemes  
77  
Indicators  
2024  
2023  
2022  
Company’s contribution to voluntary health  
insurance premiums  
g).  
1,396  
1,383  
1,189  
Table 22 - Statement of personnel expenses in 2022 2024 (thousand RON)  
The operating profit achieved in 2024, in amount of 49,486 thousand RON, decreased by  
16,877 thousand RON as compared to 2023 and increased by 1,386 thousand RON as  
compared to the budget amount.  
The financial profit achieved in 2024 is higher by 1,552 thousand RON compared to budget.  
As compared to 2023, the financial profit decreased by 379 thousand RON as a result of the  
decrease in interest income collected by the company.  
The net profit amounting to 49,323 thousand RON, is 5,011 thousand RON higher than  
budgeted and 12,294 thousand RON below the level recorded in 2023.  
Financial Result  
Variation%  
Indicator (thousand RON)  
2024  
2023  
2022  
9,737  
2024/2023  
▼ 4.3%  
2023/2022  
▼ 31.7%  
63.7%  
32.0%  
▼ 44.8%  
▼ 31.4%  
Revenues from interests  
Other financial revenues  
Total financial revenues  
Total financial expenses  
Financial Result  
6,365  
19  
6,653  
37  
102  
9,839  
469  
48.6%  
4.6%  
6,384  
332  
6,690  
259  
▲ 28.2%  
▼ 5.9%  
6,052  
6,431  
9,370  
Table 23 - Financial result during 2022-2024  
The financial revenues are lower by 4.6% in 2024, compared to the same period of the  
previous year, due to the decrease in interest income received by the Company.  
The financial expenses increased by 73 thousand RON in 2024 compared to 2023.  
Based on this evolution, the financial result lowered by 5.9% in 2024, as compared to 2023  
(from 6,431 thousand RON to 6,052 thousand RON).  
The company ended in 2024 with a net profit amounting to 49,323 thousand RON, 11.3%  
over the budgeted level, and 20% lower as compared to 2023.  
4.3.3 Economic-Financial Indicators  
Variation%  
Name of the  
indicators  
Calculation formula  
2024  
2023  
2022  
2024/  
2023  
2023/  
2022  
Profitability indicators  
EBIT (operating profit)  
Gross sales  
margin  
▼ 4.4  
p.p.  
9.3%  
8.2%  
13.7%  
12.3%  
13.3%  
12.0%  
▲ 0.4 p.p.  
▲ 0.3 p.p.  
Turnover  
EBIT (operating profit)  
Operating Revenues  
Operating  
profit margin  
▼ 4.1  
p.p.  
78  
 
Variation%  
Name of the  
indicators  
Calculation formula  
2024  
2023  
2022  
2024/  
2023  
2023/  
2022  
EBITDA (operating profit +  
value adjustments on  
tangible and intangible  
assets)  
EBITDA in  
total sales  
▼ 2.3  
p.p.  
24.1%  
26.4%  
24.5%  
▲ 1.9 p.p.  
Turnover  
Adjusted EBITDA =  
Operating profit - write-  
back to revenues of the  
reserve out of the  
Adjusted  
EBITDA  
(thousand  
RON)  
modernization quota +  
Expenses regarding the  
modernization quota +  
Value adjustments of  
tangible and intangible  
assets, here included the  
tangible revaluation  
differences.  
136,486  
134,706  
133,253  
▲ 1.3 %  
▲ 1.1 %  
EBITDA  
EBITDA in  
equity  
▲ 0.1  
p.p.  
17.6%  
18.7%  
17.5%  
18.4%  
16.9%  
19.5%  
▲ 0.6 p.p.  
Total equity  
EBIDTA  
adjusted in  
equity  
Adjusted EBITDA  
Total equity  
▲ 0.3  
p.p.  
▼ 1.1 p.p  
Gross result  
Turnover  
Gross Profit  
Rate  
▼ 4.6  
p.p.  
10.4%  
2.0  
15.0%  
1.9  
15.3%  
1.9  
0.3 p.p.  
Liquidity Indicators  
Current  
liquidity  
indicator  
(times)  
Current assets  
▲ 5.3 %  
-
Current liabilities  
Current assets -  
Inventories  
The quick ratio  
indicator (acid  
test)  
2.0  
0.1  
1.9  
0.1  
1.8  
0.2  
▲ 5.3%  
▲ 5.6%  
Current liabilities  
Total Liabilities  
Total Assets  
General  
solvency  
-
▼ 50.0 %  
Profitability indicators  
Net result  
Return on  
Assets (ROA)  
5.8%  
6.8%  
9.2%  
7.3%  
8.4%  
7.6%  
9.0%  
▼1.5 p.p  
▼ 0.3 p.p.  
▼ 0.6 p.p.  
▼ 0.4 p.p.  
TOTAL ASSETS  
Net result  
Return on  
Equity (ROE)  
▼ 1.6  
p.p.  
Total equity  
Net result  
Return on  
Sales (ROS)  
▼ 3.5  
p.p.  
12.7%  
13.1%  
Turnover  
OPERATIONAL INDICATORS  
Inventories  
turnover speed  
(days)  
Medium stock X 360  
Sales costs  
367  
1.0  
367  
1.0  
316  
1.1  
-
-
16.1%  
Sales costs  
▼ 9.1%  
79  
Variation%  
Name of the  
indicators  
Calculation formula  
2024  
2023  
2022  
2024/  
2023  
2023/  
2022  
Duration of  
inventory  
turnover  
Average inventory  
(times)  
Rotation  
Average balance Clients X  
360  
speed of the  
clients debits  
(days)  
28  
29  
28  
29  
29  
26  
-
-
▼ 3.4%  
▲ 11.5%  
▼ 12.5%  
Turnover  
Average balance suppliers  
X 360  
Rotation  
speed of  
supplier  
credits (days)  
Procurement from  
suppliers of goods and  
services  
Fixed assets  
rotation speed  
(no. of times)  
Turnover  
0.8  
0.7  
0.8  
▲ 14.3%  
Fixed assets  
Turnover  
Rotation  
speed of  
assets  
Average value of all assets  
((Total assets1+Total  
assets0)/2)  
0.63  
0.59  
0.60  
▲ 6.7%  
▼ 1.7%  
Capital expenditure  
(achieved investments)  
Total Assets  
Capital  
expenditure  
rate  
8.3%  
9.8%  
18.4%  
▼1.5 p.p.  
▼8.6 p.p.  
Risk indicators  
Leverage  
degree  
Borrowed capital  
Total equity  
0.3%  
0.3%  
0.3%  
-
-
indicator  
Table 24 Economic-Financial indicators during 2022- 2024  
4.3.4 Execution of the revenues and expenditure budget  
The Revenues and Expenditure Budget for the year 2024 has been approved by the OGMS  
in the meeting dated February 28th, 2024, as per the provisions of the Government Ordinance  
no. 26/2013.  
During 2024, the Revenues and Expenditure Budget has been amended, with the legal  
provisions contained in:  
- the Government Ordinance no. 26/2013 on the reinforcement of the financial discipline at  
the level of some economic operators to which the State or the administrative - territorial  
divisions act as unique or majority shareholders or hold directly or indirectly a majority  
participation, subsequent amendments and additions;  
- Law no. 421 from December 28th, 2023 of the State budget for the year 2024, Art. 73;  
- Order of the Ministry of Public Finance no. 3818/2019 for the approval of the format and  
structure of the revenues and expenditure budget, as well as the substantiation annexes  
thereof.  
The implementation of the rectified Revenues and Expenditure Budget for 2024 is presented  
as follows:  
80  
 
Rectified  
Budget  
YEAR  
Ro  
w
no.  
Achieved  
year  
2024  
Crt. no.  
Indicators  
%
2024  
0
1
1
3
1
2
3
4
5
6= 5/4  
I.  
II  
TOTAL REVENUES (Row1=Row2+Row5)  
Total operating revenues, of which:  
606,249  
601,297  
612,666  
606,282  
101.1%  
100.8%  
a)  
b)  
subsidies, as per the legal provisions in force  
transfers, as per the legal provisions in force  
0
0
-
4
0
4,952  
0
6,384  
-
128.9%  
100.6%  
2
1
Financial Revenues  
5
6
TOTAL EXPENSES (Row 6=Row 7+Row 19)  
553,649  
557,128  
Operating Expenses, (Row 7=Row  
8+Row9+Row10+Row18), o/w:  
7
553,197  
556,796  
100.7%  
A. Goods and Services Expenses  
8
9
127,358  
53,104  
124,289  
53,154  
97.6%  
B. Taxes, fees and similar levies related expenses  
100.1%  
Personnel expenses (Row  
C. 10=Row11+Row14+Row16+Row17), out of  
which:  
10  
210,619  
210,186  
99.8%  
C0 Salaries expenses (Rows 11=Row12+Row13)  
11  
12  
193,349  
193,101  
99.9%  
C1 Salary expenses  
164,995  
28,354  
2,808  
164,820  
28,281  
2,641  
99.9%  
99.7%  
94.1%  
C2 Bonuses  
13  
14  
C3 Other personnel expenses, out of which:  
expenditure with severance payments relating  
to personnel layoff  
15  
16  
17  
2,808  
6,214  
8,248  
2,641  
6,212  
8,232  
94.1%  
100.0%  
99.8%  
Expenses related to the Contract of Mandate  
C4 and other management and control bodies,  
committees and commissions  
Expenses with contributions due by the  
employer  
C5  
D. Other operating expenses  
Financial Expenses  
18  
19  
20  
21  
22  
162,116  
452  
169,167  
332  
104.4%  
73.5%  
105.6%  
94.8%  
37.3%  
2
III  
GROSS RESULT (profit/loss)(Rd.20= Rd.1- Rd.6)  
52,600  
10,790  
2,289  
55,538  
10,227  
854  
IV  
1
CURRENT CORPORATE TAX  
2
DEFFERED CORPORATE TAX  
REVENUES FROM DEFFERED CORPORATE  
TAX  
3
4
5
23  
24  
25  
4,791  
4,866  
101.6%  
TAX SPECIFIC TO CERTAIN ACTIVITIES  
OTHER TAXES MISSING FROM THE ABOVE  
ITEMS  
-
-
-
-
-
-
PROFIT/NET LOSS OF THE REPORTING  
PERIOD (Row 26=Rd.20-Rd.21-Rd.22+Rd.23-  
Rd.24-Rd.25), of which:  
V
26  
44,312  
49,323  
111.3%  
1
2
Legal reserves  
27  
28  
-
-
-
Other reserves representing fiscal incentives  
provided by Law  
500  
2,993  
598.6%  
The coverage of accounting losses from previous  
years  
3
29  
-
-
-
81  
Rectified  
Budget  
YEAR  
Ro  
w
no.  
Achieved  
year  
2024  
Crt. no.  
0
Indicators  
1
%
2024  
3
4
5
6= 5/4  
Establishment of own financing sources for the  
projects co-financed through foreign loans, as well  
as for the establishment of the necessary sources  
to reimburse capital rates, interests, commissions  
and other costs related to these loans  
4
30  
-
-
-
-
-
5
6
Other allocations stipulated by law  
31  
32  
-
Accounting profit remaining after deducting the  
amounts from Rows 27, 28, 29, 30, 31 (Row  
32=Row26-(Row27 to Row 31)>= 0)  
43,812  
46,330  
105.7%  
Employees profit sharing schemes within the limit of  
10% of the net profit but no more than the monthly  
average base salary achieved at the level of the  
economic operator reported in the reference  
financial year  
7
8
33  
34  
4,800  
5,058  
105.4%  
Minimum 50% transfers to the state or local budget  
in case of regies autonomes or dividends due to  
shareholders in case of the societies/national  
companies or state-owned or majority companies,  
out of which:  
41,320  
46,330  
112.1%  
a) - dividends payable to the state budget  
b) - dividends payable to the local budget  
c) - dividends due to other shareholders  
35  
36  
37  
24,262  
-
27,203  
-
112.1%  
-
17,058  
19,127  
112.1%  
The profit not distributed to the destinations  
provided for in Row 33 Row 34 shall be  
distributed to other reserves and shall constitute its  
own source of financing  
9
38  
2,492  
0
-
VI  
REVENUES FROM EUROPEAN FUNDS  
ELIGIBLE EXPENSES FROM EUROPEAN  
FUNDS, out of which:  
39  
40  
-
-
-
-
-
-
VII  
a) material expenses  
41  
42  
43  
44  
45  
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
b) salaries expenses  
c) expenses on provision of services  
d) advertising and publicity expenses  
e) other expenses  
VII  
I
INVESTMENT FINANCING SOURCES, out of  
wich:  
46  
85,000  
70,445  
82.9%  
1
Budget allocations  
47  
-
-
-
-
-
budget allocations related to payments of the  
commitments from previous years  
IX  
EXPENSES FOR INVESTMENTS  
49  
85,000  
70,445  
82.9%  
Table 25 - Implementation of the Revenues and Expenditure budget for the year 2024 (thousand RON)  
4.3.5 Cash-flow  
12  
months  
2024  
12  
months  
2023  
12  
months  
2022  
Variation%  
2024/2023 2023/2022  
Elements  
Cash flows from operating activities:  
82  
 
12  
12  
12  
Variation%  
Elements  
months  
2024  
months  
2023  
months  
2022  
2024/2023  
2023/2022  
▲ 2.0%  
Proceeds from services supply  
582,922  
520,121  
509,861  
▲ 12.1%  
▼ 3.7%  
▲ 94.7%  
▲ 9.4%  
+
+
+
-
Proceeds from interests related to banking  
placements  
6,331  
8,278  
6,576  
4,251  
9,872  
▼ 33.4%  
▼ 68.6%  
▼ 0.2%  
Other proceeds  
13,518  
Payments to the suppliers of goods and  
services  
(153,460) (140,226) (140,569)  
Payments to and on behalf of the employees  
(206,739) (192,207) (176,585)  
▲ 7.6%  
▲ 19.7%  
▲ 13.4%  
▲ 8.8%  
▲ 28.6%  
▼ 8.2%  
-
-
-
VAT payments  
(64,997)  
(12,216)  
(54,309)  
(10,776)  
(42,222)  
(11,738)  
Corporate tax payments  
Other payments regarding the operating  
activity  
(54,102)  
(46,815)  
(45,623)  
▲ 15.6%  
▲ 2.6%  
-
Net cash from operating activity  
Cash flows from investment activities:  
Proceeds from sale of tangible assets  
106,017  
86,615  
116,514  
▲ 22.4%  
25.7%  
A
11  
621  
303  
▼ 98.2% ▲ 105.0%  
+
+
Proceeds from modernization quota  
Payments for purchase of tangible/intangible  
assets  
▲ 16.1%  
▼ 18.0%  
-
▲ 1.3%  
39.5%  
-
67,445  
58,084  
57,321  
(85,403) (104,205) (172,138)  
-
Net cash from investment activity  
Cash flows from financing activities:  
Paid dividends  
(17,947)  
(45,500) (114,514)  
B
(56,894)  
(2,497)  
(244)  
(57,664)  
(3,196)  
(185)  
(62,865)  
(3,015)  
(199)  
▼ 1.3%  
▼ 21.9%  
▲ 31.9%  
-
8.3%  
▲ 6.0%  
▼ 7.0%  
-
-
-
Payments on account of leasing debt  
Interest payments  
-
Net cash from financing activities  
(59,635)  
(61,045)  
(66,079)  
C
Net increase of the cash and cash  
equivalents  
28,435  
(19,930)  
(64,079)  
-
-
=A+B+C=D2-D1  
Cash and cash equivalents at the  
beginning of the period  
107,742  
136,177  
127,672  
107,742  
191,751  
127,673  
▼ 15.6%  
▼ 33.4%  
▼ 15.6%  
D1  
D2  
Cash and cash equivalents at the end of  
the period  
26.4%  
Table 26 - Cash flow statement for 2022- 2024 (thousand RON)  
The balance of cash and cash equivalents on 31.12.2024 is higher by 26.4% compared to  
December 31st, 2023 (136,177 kRON compared to 107,742 kRON), as a result of the  
increase by 4.9 million RON of the cash from the modernization quota existing in bank  
accounts on 31.12.2024, but also of the collection before maturity of the equivalent value of  
some transport services provided in December.  
Out of the total availability in cash on 31.12.2024, the share of the modernization quota is in  
amount of 36,936 thousand RON.  
The effects of the three activity areas (operation, investment and financing) on the cash in  
the 12-month period of 2024 reveal the following:  
- the operating activity triggered a cash-flow in amount of 106,017 thousand RON;  
- the investment activity ended with a negative cash-flow in amount of 17,947 thousand RON;  
- the financing activity decreased the total cash flow by 59,635 thousand RON.  
83  
The value of net cash flows from operating activity increased by 19.4 mRON compared to  
the same period of the previous year due to the increase in revenues from transport services.  
Compared to the previous year, the net cash flow from investment activity (cash deficit)  
decreased by 27.6 mRON. The decrease in the deficit was driven by a lower volume of fixed  
asset payments compared to the same period of 2023.  
The net cash from the financing activity registers in both compared periods, 2024 and 2023,  
negative amounts determined by the payment of dividends to the shareholders and the  
amounts related to leasing.  
4.3.6. The internal control and the risks management systems in the financial  
reporting process  
The internal control and the risks management systems in the financial reporting process  
have the following main objectives:  
- Compliance with the financial-accounting legislation in force and the reporting standards;  
- Application of approved accounting policies and instructions drafted by the management  
with regards to financial information;  
- Ensuring the reliability of the financial information. The objective aims to ensure that  
accounting, financial and management information communicated or published are  
complete and accurately reflect the activity and situation of the entity;  
- Prevention and detection of frauds and accounting and financial irregularities.  
The fulfilment of these objectives is being supported by:  
- Personnel with an adequate level of competence, in compliance with the company’s needs  
and the existence of a continuous professional development plan to enable the upgrade  
of knowledge related to the accounting and fiscal legislation;  
- Clear definition of the responsibilities related to each person involved in the financial  
reporting process, respectively the separation of attributes, so that the approval, audit and  
registration attributions be, in a fair measure, awarded to different persons (as per the  
company’s organization chart).  
- Internal procedures regarding the fair accounting treatment and proper authorization of  
the financial - accounting operations and settlement of an information circuit and the  
related audits thereof, to ensure the quick, fair and complete centralization of the financial  
information, as per the internal procedures manual;  
- The financial system of preventive control;  
- Identification of risks in relation to the financial reporting process, the assessment of the  
effectiveness and efficiency of the application of the internal procedures regarding the  
processes relevant to the financial reporting by the internal audit department and  
communication of the identified shortcomings to the Board of Directors;  
- The accounting policies manual drafted as per the legislation in force, approved by the  
Board of Directors;  
- The existence of a calendar and a well-defined process with regards to the elaboration of  
accounting and financial information compliant with the reporting requirements (financial-  
accounting of the capital market) and the checking and appropriate approval thereof by  
the Board of Directors, in view of publication thereof.  
84  
 
4.3.7 Affiliated Parties  
Between 01.01.2024 - 31.12.2024, the Company carried out the following significant  
transactions with related parties:  
Procurement from affiliated parties  
Unsettled  
amounts at  
December 31,  
2023  
Settlements  
during  
01.01.2024-  
31.12.2024  
Unsettled  
amounts at  
December 31,  
2024  
Procurements  
during 01.01.2024-  
31.12.2024  
Partner  
SPEEH  
HIDROELECTRICA S.A.  
6,533  
-
6,376  
157  
*The amounts include VAT as well  
Table 27 - Purchases from affiliated parties (thousand RON)  
Guarantees granted to affiliated parties  
Partner  
December 31, 2024 December 31, 2023  
SPEEH HIDROELECTRICA S.A.  
ELECTRICA FURNIZARE S.A.  
-
1,989  
277  
282  
Table 28 - Guarantees granted/received with/from related parties (thousand RON)  
4.4 Analysis of the corporate activity  
4.4.1 Capital market business  
Evolution of “COTE share“  
The shares issued by CONPET S.A. are traded on the regulated market administered by the  
Bucharest Stock Exchange, on the Principal segment, at Equity sector - category Premium,  
under “COTE” symbol.  
At the end of 2024, the trading price of CONPET shares recorded a decrease by 7.82%  
compared to the closing price of the last trading day of the previous year.  
In summary, the transactions recorded with CONPET shares on Bucharest Stock Exchange,  
in 2024, are as follows:  
- 13,452 transactions have been performed, 4% less than in 2023 (13,961 transactions);  
- the total volume of traded shares amounted to 504,432 shares, 1.1% lower than the  
volume recorded in 2023 (509,910 shares);  
- the total value of trades amounted to 42,081,831 RON, 8% higher than the value recorded  
in 2023 (38,961,152 RON);  
- the average trading price was 83.38 RON/share, higher by 7.88 RON/share versus the  
average price of the shares registered during 2023 (75.50 RON/share);  
- the trading price registered the maximum value, respectively 91.80 RON/share at the end  
of May;  
- the Market capitalization at the end of December 2024 was of 652,777,611 RON,  
decreasing by 7.8% as compared to the value recorded at the end of 2023 (708,185,790  
RON).  
85  
     
The main trading indices of 2024 for the shares issued by CONPET S.A. are presented in  
the following table:  
Indices  
Month  
Average price  
(RON/share)  
Value of trades  
(RON)  
No. of trades  
No. of traded shares  
January  
84.80  
1,317  
73,171  
6,198,709  
February  
March  
85.61  
86.47  
88.15  
89.21  
86.89  
88.09  
84.88  
78.11  
77.15  
76.67  
74.54  
847  
976  
32,369  
54,453  
30,802  
72,632  
49,723  
17,692  
19,083  
68,339  
18,419  
28,809  
38,940  
2,770,489  
4,711,809  
2,712,023  
6,461,889  
4,327,811  
1,556,471  
1,610,327  
5,261,417  
1,419,377  
2,193,425  
2,858,084  
April  
846  
May  
1,436  
1,244  
750  
June  
July  
August  
September  
October  
November  
December  
927  
2,237  
770  
852  
1,250  
Cumulated  
83.38  
13,452  
504,432  
42,081,831  
Table 29 - Main trading indices  
Currently CONPET S.A. is included in 6 indices of the total of 10 of the Bucharest Stock  
Exchange, namely BET- NG, BET-XT, BET-XT-TR, BET-BK, BET-XT-TRN and BET  
Plus.  
Chart 19 - Evolution of COTE share vs. stock indices (rebased) where it is included in 2024  
Graphically, the evolution of the trading price of CONPET S.A. shares, in 2024, compared to  
2023. is the following:  
Chart 20 - Evolution of the share trading price (RON/share)  
86  
Stock Market indicators  
2020  
2021 2022 2023 2024  
PER  
P/BV  
EPS  
11.20 12.13 10.00 12.42 11.29  
1.01  
6.80  
9.26  
1.09  
6.51  
8.73  
0.91  
6.78  
7.28  
1.07  
6.59  
6.87  
0.93  
6.68  
9.00  
DIVY (dividend yield)  
Table 30 - Main indicators of stock market performance  
As of 31.12.2024, according to the top capitalization of companies in the Premium section of  
issuers by capitalization, CONPET ranked 34th, with a market capitalization of 652,777,611  
RON (131.17 million EURO), which represents a share of 0.19% in total market capitalization.  
The Dividend Policy  
Within the last 5 years, CONPET fulfilled its commitment to award a yield to its shareholders  
by means of a sustainable dividend policy and distributed dividends in a quota comprised  
between 94% and 98% of the net accounting profit.  
The dividend policy of the company CONPET S.A. was approved by the Board of Directors  
in January 2021.  
The net profit distribution decisions concern the company’s options between partial or full  
reinvestment of the net profit and/or distribution in the form of dividends.  
Depending on the situation existing at the time of formulating the profit distribution proposal,  
deviations from the Policy may occur as a result of specific legal requirements applicable at  
that date, the modification of the tax framework and depending on the capital requirement for  
investments.  
The dividends’ distribution ratio, set out in the dividend policy, which the Board of Directors  
will consider in the formulation of the proposal to the General Meeting of Shareholders of  
CONPET S.A. will be between 85 % and 100 % of the net accounting profit.  
The gross dividend per share is the share of the company’s net profit that is calculated and  
paid to shareholders for each share held.  
The evolution of the dividends distributed from the net profit for the period 2021 - 2023 is as  
follows:  
Total  
gross  
dividends  
due  
Net  
dividends  
accumulated  
on  
% of  
net  
profit  
Gross  
dividend/share  
- RON-  
Paid gross  
dividends  
- RON-  
Registration  
Date  
Share of profit  
GMS date  
- RON-  
31.12.2024  
2021-Dividend  
out of the profit  
of the year, from  
reserves and  
retained  
28.04.2022  
25.05.2022  
63,057,849 97.1%  
59,510,161 94.9%  
7.28  
61,315,778.24 1,742,070.76  
57,416,516.78 2,093,644.22  
earnings  
2022-Dividend  
out of the Profit  
of the year, from  
reserves and  
retained  
27.04.2023  
25.04.2024  
25.05.2023  
29.05.2024  
6.87  
6.79  
earnings  
2023-Dividend  
out of the Profit  
58,753,534 94.0%  
57,891,137.00  
862,397.00  
87  
Total  
gross  
dividends  
due  
Net  
dividends  
accumulated  
on  
% of  
net  
profit  
Gross  
dividend/share  
- RON-  
Paid gross  
dividends  
- RON-  
Registration  
Date  
Share of profit  
GMS date  
- RON-  
31.12.2024  
of the year, from  
reserves and  
retained  
earnings  
Table 31 - Evolution of dividends distributed in the period 2021- 2023  
The return on investment and dividend yield in the period 2020-2024 are shown in the chart  
below:  
Chart 21 Evolution of return on investment and dividend yield  
Total dividend per share was 6.79 RON, thus offering its shareholders a dividend yield of 9%,  
therefore ranking 2 in the top of dividends awarded by a company listed on the Bucharest  
Stock Exchange, Premium category.  
Own shares, issuance of bonds or other debt instruments  
CONPET did not perform transactions having as scope purchase of own shares and does  
not hold own shares at the end of 2024.  
CONPET has no branches and there are no shares issued by the parent company and owned  
by the branches.  
CONPET has not issued bonds or other debt instruments.  
4.4.2. Corporate Governance  
Corporate governance continues to be in a process of adapting to the demands of a modern  
economy, to the obvious globalization of social life as well as to the information needs of  
investors and third parties interested in the activity of the companies.  
The corporate governance at the level of CONPET is organized and conducted in  
accordance with the Romanian legislative framework, namely the Companies Law no.  
31/1990 and the Government Emergency Ordinance no. 109/2011 on corporate governance  
of the public enterprises.  
CONPET shares are traded starting with September 5th, 2013 on the regulated market  
managed by the Bucharest Stock Exchange (BSE), at category I, under the COTE symbol.  
Starting January 5th, 2015, CONPET S.A. is included in the PREMIUM category of the  
regulated market managed by the Bucharest Stock Exchange.  
88  
 
The Corporate Governance system of CONPET is constantly improved, as to be compliant  
with the rules and recommendations applicable to a company listed at the BVB.  
Among the measures already implemented, please note:  
- the inclusion in the administrators’ annual report of a chapter devoted to corporate  
governance with reference, inter alia, to the information related to the Board of Directors  
and the consultative committees namely: the Audit Committee, the Nomination and  
Remuneration Committee, the Development and Investors and Authorities Relation  
Committee and the Risks Management Committee;  
- diversification of communication with shareholders and investors through the inclusion on  
the web page of the releases addressed to market participants, half-yearly financial  
statements, annual reports, procedures to be followed in access and participate in the  
GMS;  
- the establishment of a specialized entity dedicated to the relationship with investors and  
shareholders.  
The Corporate Governance Rules  
As an issuer listed on the Bucharest Stock Exchange, CONPET has promoted the CONPET  
Corporate Governance Rules. This document represents the voluntary assumption by the  
Company of the corporate governance principles, taking into account the characteristics and  
its specific activity in accordance with the principles set out in the Corporate Governance  
Code of Bucharest Stock Exchange. The regulation is a public document and can be viewed  
on the company’s website by accessing the link https://www.conpet.ro/wp-  
content/uploads/2015/11/Regulamentul-de-Guvernanta-Corporativa-al-CONPET-S.A.-  
2024_en.pdf.  
Other applicable documentation  
For the application of the general regulatory framework, CONPET has adopted documents  
by which corporate governance is transposed into practice:  
- The Articles of Incorporation of CONPET, comprising provisions relating to the  
management bodies (General Meeting, Board of Directors, Executive Management) as  
well as their powers and operating procedures (Annex 7);  
- The Rules of Organization and Functioning of the Board of Directors, which detail and  
operationalize the way in which this body meets, the way it analyzes, debates and makes  
decisions, the way it interacts with the executive management and other parties.  
- The Internal Regulation of Organization and Functioning of the Advisory Committees  
established at the level of the Board of Directors, which establishes the attributions and  
responsibilities of the four Advisory Committees.  
- The Regulation for the Organization and Functioning of CONPET, the Code of Ethics, the  
Internal Regulation, which incorporate, detail and operationalize certain aspects incident  
to the governance framework of the company.  
89  
Statement on Conformity with the Provisions of the Corporate Governance Code  
issued by Bucharest Stock Exchange  
Fails to  
comply  
The Provisions of the Corporate  
Governance Code  
Explanations of Compliance/  
Reason for Non-Compliance  
Complies  
or  
partially  
complies  
A.1. All the companies should have  
internal regulation of the Board which  
YES  
Delimitation  
of  
BoD  
responsibilities of the ones of the  
Director General is provided in  
the Corporate Governance  
Regulation.  
includes  
terms  
of  
reference/responsibilities of the Board and  
key management functions of the  
company, applying, among others, the  
General Principles of Section A.  
A.2. Provisions for the management of  
conflict of interest should be included in  
the Board regulation. In any event,  
members of the Board should notify the  
Board of any conflicts of interest which  
have arisen or may arise, and should  
refrain from taking part in the discussion  
(including by not being present where this  
does not render the meeting non-quorate)  
and from voting on the adoption of a  
resolution on the issue which gives rise to  
such conflict of interest.  
YES  
Both the Rules of Organization  
and Operation of the Board of  
Directors of the company  
CONPET S.A and the Corporate  
Governance Rules approved by  
the Board of Directors contain  
provisions  
concerning  
the  
management of the conflict of  
interests. In practice, the  
members of the Board inform  
the Board, whenever needed,  
on any conflict of interests  
having arisen or that may arise  
and refrain from taking part to  
discussions and from the voting  
for the adoption of a Resolution  
regarding the issue giving rise to  
such conflict of interests.  
A.3. The Board of Directors or the  
Supervisory Board should have at least  
five members.  
YES  
YES  
A.4. The majority of the members of the  
Board of Directors should be non-  
executive. In case of the Premium Tier  
companies, at least two non-executive  
members of the Board of Directors should  
be independent. Each independent  
member of the Board of Directors should  
submit a declaration at the moment of  
his/her nomination for election or re-  
election as well as when any change in  
his/her status arises, on the grounds on  
which he/she is considered independent in  
character and judgment in practice and  
according to the following criteria:  
A.4.1. is not Director General/executive  
officer of the company or of a company  
90  
Fails to  
comply  
or  
partially  
complies  
The Provisions of the Corporate  
Governance Code  
Explanations of Compliance/  
Reason for Non-Compliance  
Complies  
under his/her control and did not hold such  
position for the previous five (5) years;  
A.4.2. is not the employee of the company  
or of a company under his/her control and  
was not in such position for the previous  
five (5) years;  
A.4.3. does not receive and did not receive  
additional  
remuneration  
or  
other  
advantages from the company or from a  
company under his/her control, apart from  
those corresponding to the capacity of  
non-executive administrator;  
A.4.4. is not or has not been an employee  
of, or does not have or did not have any  
contractual relationship, during the  
previous year, with  
a
significant  
shareholder of the company, controlling  
over 10% of the voting rights, or with a  
company under his control;  
A.4.5. does not have and did not have,  
during the previous year, a business or  
professional relationship with the company  
or with a company under his/her control,  
either directly or as a customer, partner,  
shareholder,  
member  
of  
the  
Board/Administrator,  
Director  
General/executive director or employee of  
a company having such a relationship if,  
by its substantial character, this  
relationship could affect his/her objectivity;  
A.4.6. is not and was not, in the last three  
years, the external or internal auditor or a  
partner or associate employee of the  
current external financial auditor or  
internal auditor of the company or of a  
company under his/her control;  
A.4.7. is not Director General/executive  
officer in another company where another  
Director General/executive officer of the  
company is a non-executive administrator;  
A.4.8. has not been a non-executive  
director of the company for more than  
twelve years;  
A.4.9. does not have family ties with a  
person in the situations referred to at items  
A.4.1. and A.4.4.  
A.5. Any relatively permanent professional  
commitments and engagements of a  
YES  
Part  
of  
the  
professional  
commitments and obligations  
91  
Fails to  
comply  
or  
partially  
complies  
The Provisions of the Corporate  
Governance Code  
Explanations of Compliance/  
Reason for Non-Compliance  
Complies  
member of the Board, here-included the  
executive and non-executive Board  
positions in companies and not-for-profit  
institutions, should be disclosed to  
shareholders and to potential investors  
before appointment and during his/her  
mandate.  
are communicated in the  
Statements of Assets and  
Liabilities of the Board members  
(in compliance with provisions of  
Law  
176/2010  
regarding  
integrity in the exercise of the  
positions and public dignities, for  
the  
complementation  
no.144/2007 regarding  
amendment  
and  
Law  
the  
of  
incorporation, organization and  
operation of ANI, as well as for  
the amendment of other  
normative acts).  
A.6. Any member of the Board should  
submit to the Board, information on any  
relationship with a shareholder who holds  
directly or indirectly shares representing  
more than 5% of all voting rights. This  
YES  
The existing provisions included  
in  
the  
independence  
statements, respectively in the  
Corporate Governance Rules  
regarding the conflict of interest  
provide compliance with the  
requirement.  
obligation concerns  
any kind of  
relationship which may affect the position  
of the member on issues decided by the  
Board.  
A.7. The company should appoint a  
secretary of the Board responsible for  
supporting the activity of the Board.  
A.8. The corporate governance statement  
should inform on whether an evaluation of  
the Board has taken place under the  
leadership of the Chairman or the  
nomination committee and, if so,  
summarize the key action points and  
changes resulting from it. The company  
should have a policy/guidance regarding  
the evaluation of the Board containing the  
purpose, criteria and frequency of the  
evaluation process.  
YES  
Partially  
compliant provisions  
In  
compliance  
of  
with  
the  
the  
GEO  
109/2011, the assessment of  
the administrators’ activity is  
being performed annually by the  
general meeting of shareholders  
and is aiming at both the  
contract execution and the  
administration  
Nomination and Remuneration  
Committee drafts report  
plan.  
The  
a
regarding the administrators’  
evaluation, also considering the  
assessment surveys filled in for  
every BoD member.  
On 27.02.2025 the Board of  
Directors approved the Policy on  
the evaluation of the Board of  
Directors of CONPET S.A.  
92  
Fails to  
comply  
or  
partially  
complies  
The Provisions of the Corporate  
Governance Code  
Explanations of Compliance/  
Reason for Non-Compliance  
Complies  
A.9. The corporate governance statement  
should contain information on the number  
of meetings of the Board and the  
committees during the past year,  
attendance by the administrators (in  
person and in absentia) and a report of the  
Board and committees on their activities.  
YES  
A.10.  
The  
corporate  
governance  
YES  
YES  
statement should contain information on  
the precise number of the independent  
members of the Board of Directors or of  
the Supervisory Board.  
A.11. The Board of Premium Tier  
companies should set up a nomination  
committee formed of non-executives,  
which will lead the process for new Board  
The  
procedure  
for  
the  
appointment/nomination of the  
Board members is performed in  
compliance with the provisions  
of the GEO no.109/2011 on the  
corporate governance of the  
public enterprises.  
appointments  
and  
make  
recommendations to the Board. The  
majority of the members of the nomination  
committee should be independent.  
B.1. The Board should set up an audit  
committee where at least one member  
should be an independent non-executive.  
The majority of the members, including the  
President, should have proven an  
adequate qualification relevant to the  
functions and responsibilities of the  
committee. At least one member of the  
audit committee should have proven an  
adequate audit or accounting experience.  
In the case of Premium Tier companies,  
the audit committee should be composed  
of at least three members and the majority  
of the audit committee members should be  
independent.  
YES  
B.2. The President of the audit committee  
should be an independent non-executive  
member.  
YES  
YES  
YES  
B.3. Among its responsibilities, the audit  
committee should undertake an annual  
assessment of the system of internal audit.  
B.4. The assessment should consider the  
effectiveness and scope of the internal  
audit function, the adequacy of risk  
management and internal audit reports to  
the audit committee of the Board,  
management’s  
responsiveness  
and  
effectiveness in dealing with identified  
93  
Fails to  
comply  
or  
partially  
complies  
The Provisions of the Corporate  
Governance Code  
Explanations of Compliance/  
Reason for Non-Compliance  
Complies  
internal audit failings or weaknesses and  
their submission of relevant reports to the  
Board.  
B.5. The audit committee should review  
conflicts of interests in relation to the  
transactions of the company and its  
subsidiaries with related parties  
YES  
B.6. The audit committee should evaluate  
the efficiency of the internal control system  
and risk management system.  
YES  
YES  
B.7. The audit committee should monitor  
the application of statutory and generally  
accepted standards of internal auditing.  
The audit committee should receive and  
evaluate the reports of the internal audit  
team.  
B.8. Whenever the Code mentions  
reviews or analysis to be exercised by the  
Audit Committee, these should be  
followed by recurrent (at least annual), or  
ad-hoc reports to be submitted to the  
Board afterwards.  
YES  
B.9. No shareholder may be given undue  
preference over other shareholders with  
regard to transactions and agreements  
concluded by the company with  
shareholders and their related parties.  
B.10. The Board should adopt a policy  
ensuring that any transaction of the  
company with any of the companies it has  
close relations with, that is equal to or  
bigger than 5% of the net assets of the  
company (as stated in the latest financial  
report), should be approved by the Board  
following an obligatory opinion of the  
Board’s audit committee, and fairly  
disclosed to the shareholders and  
potential investors, to the extent that such  
transactions fall under the category of  
events subject to disclosure requirements.  
B.11. The internal audits should be carried  
out by a separate structural division  
(internal audit department) within the  
company or by hiring an independent third-  
party entity.  
YES  
YES  
The company CONPET SA  
complies  
with  
the  
recommendation of the BVB  
Corporate Governance Code.  
The Company has adopted an  
affiliated  
party  
transaction  
policy, which aims to identify,  
approve, monitor and report  
these  
transactions  
in  
accordance with the applicable  
law in force.  
YES  
94  
Fails to  
comply  
or  
partially  
complies  
The Provisions of the Corporate  
Governance Code  
Explanations of Compliance/  
Reason for Non-Compliance  
Complies  
B.12. To ensure the fulfillment of the core  
functions of the internal audit department,  
it should report functionally to the Board  
YES  
via  
the  
Audit  
Committee.  
For  
administrative purposes and in the scope  
related to the liabilities of the management  
to monitor and mitigate risks, it should  
report directly to the Director General.  
C.1. The company should publish a  
remuneration policy on its website and  
include in its annual report a remuneration  
statement on the implementation of this  
policy during the annual period subject to  
review.  
YES  
YES  
D.1. The company should have an  
Investor Relations department - indicating,  
to the general public, the person/persons  
responsible for the organizational unit. In  
addition to the information required by  
legal provisions, the company should  
include on its website a dedicated Investor  
Relations section, both in Romanian and  
English, with all relevant information of  
interest for investors, including:  
D.1.1. The main corporate regulations: the  
Articles of Incorporation, the procedures  
on General Shareholders’ Meetings;  
YES  
On the company website  
relevant information is published  
for the investors (Articles of  
Incorporation,  
shareholders’  
rights etc.). The General  
Meetings of Shareholders are  
held by the observance of the  
legislation in force regarding the  
companies and the capital  
market, in compliance with the  
legal provisions regarding the  
call and performance of the  
general meetings.  
D.1.2. Professional CVs of the members of  
the governing bodies of the company,  
other professional commitments of the  
Board members, including the executive  
and non-executive Board positions in  
companies or non-profit institutions;  
YES  
YES  
D.1.3. Current and periodic reports  
(quarterly, semi-annual and annual  
reports) at least the ones provided at  
95  
Fails to  
comply  
or  
partially  
complies  
The Provisions of the Corporate  
Governance Code  
Explanations of Compliance/  
Reason for Non-Compliance  
Complies  
item D.8 including current reports with  
detailed information related to non-  
compliance with this Code;  
D.1.4. Information related to the General  
Meetings of Shareholders: the agenda and  
supporting materials; the procedure for the  
election of Board members; the rationale  
for the proposal of candidates for the  
election to the Board, together with their  
YES  
professional  
CV’s;  
shareholders’  
questions related to the agenda and the  
company’s answers, including the  
decisions made;  
D.1.5. Information on corporate events,  
such as payment of dividends and other  
distributions to the shareholders or other  
events leading to the acquisition or  
limitation of rights of a shareholder,  
including the deadlines and principles  
applied to such operations. Such  
information should be published within a  
timeframe that enables investors to make  
investment decisions;  
YES  
D.1.6. The name and contact data of a  
person who should be able to provide,  
upon request, relevant information;  
YES  
YES  
D.1.7. Company’s presentations (e.g.  
investors presentations, quarterly results  
presentations, etc.), financial statements  
(quarterly, semi-annual, annual), auditor  
reports and annual reports.  
D.2. The company should provide a policy  
related to the annual distribution of  
YES  
dividends  
or  
other  
benefits  
to  
shareholders, proposed by the Director  
General or the Management Board and  
adopted by the Board of Directors, as a set  
of directions the company intends to follow  
regarding the distribution of net profit. The  
principles of the annual dividend  
distribution policy should be published on  
the company’s website.  
D.3. The company should adopt a policy in  
relation to forecasts, whether they are  
disclosed or not. Forecasts refer to the  
quantified conclusions of studies aimed at  
determining the global impact of a number  
of factors related to a future period (so  
YES  
The forecasts have been  
presented in the summary of the  
Administration Plan approved in  
the GMS dated 19.12.2023,  
published on the company  
website.  
96  
Fails to  
comply  
or  
partially  
complies  
The Provisions of the Corporate  
Governance Code  
Explanations of Compliance/  
Reason for Non-Compliance  
Complies  
called assumptions): by nature, such a  
task is based upon a high level of  
uncertainty, with results sometimes  
significantly differing from forecasts  
initially presented. The forecast-related  
policy will establish the frequency, the  
period considered and content of  
forecasts. Forecasts, if published, may  
only be part of annual, semi-annual or  
quarterly reports. The forecast related  
policy should be published on the  
corporate website.  
D.4. The rules of general meetings of  
shareholders should not restrict the  
participation of shareholders in general  
meetings and the exercising of their rights.  
Amendments to the rules should take  
effect, at the earliest, as of the next  
general meeting of shareholders.  
YES  
D.5. The external auditors should attend  
the shareholders’ general meetings when  
their reports are presented therein.  
YES  
YES  
D.6. The Board should present to the  
annual general meeting of shareholders a  
brief assessment of the internal audit and  
significant risk management systems, as  
well as opinions on issues subject to  
resolution at the general meeting.  
D.7. Any professional consultant, expert or  
financial analyst may participate in the  
shareholders’ meeting upon prior invitation  
from the Board. Accredited journalists may  
also participate in the general meeting of  
shareholders, unless the President of the  
Board decides otherwise.  
YES  
YES  
D.8. The quarterly and semi-annual  
financial  
reports  
should  
include  
information, in both Romanian and  
English, regarding the key drivers  
influencing the change in sales, operating  
profit, net profit and other relevant financial  
indicators, both on quarter-on-quarter and  
year-on-year terms.  
D.9. A company should organize at least  
two meetings/conference calls with  
analysts and investors each year. The  
information presented on these occasions  
should be published in the “Investors  
YES  
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Fails to  
comply  
or  
partially  
complies  
The Provisions of the Corporate  
Governance Code  
Explanations of Compliance/  
Reason for Non-Compliance  
Complies  
Relation” section of the company website  
at the time of the meetings/conference  
calls.  
D.10. If a company supports various forms  
of artistic and cultural expression, sport  
YES  
activities,  
educational  
or  
scientific  
activities, and considers the resulting  
impact on the innovativeness and  
competitiveness of the company is part of  
its business mission and development  
strategy, it should publish the policy  
guiding its activity in this area.  
Table 32 Statement on Conformity with the Provisions of the Corporate Governance Code  
Issued by the Bucharest Stock Exchange  
Actions for further improvement of CONPET corporate governance  
With its listing at BVB, CONPET has undertaken the application of the Corporate Governance  
Code of Bucharest Stock Exchange and, therefore, of the highest corporate governance  
standards currently existing in Romania.  
One of the goals of the company CONPET S.A. is to increase the transparency and visibility  
of the company on the stock market and to ensure greater openness to shareholders and  
investors in order to increase the credibility of the company.  
Transparency, information and communication  
As a company listed in the Premium category of Bucharest Stock Bucharest, CONPET fully  
complies with the obligations of reporting to the investors and the market in general, drafting  
and submitting the periodic and current reports required by the regulations of the Stock  
Exchange.  
As a company that operates in a competitive environment of great significance for the  
economy in general, CONPET S.A. aims to achieve the appropriate balance between  
information of a confidential nature and those of public interest. Internal regulations have  
been adopted for the dissemination of information and compliance with confidentiality.  
In accordance with the corporate governance principles, CONPET has announced the  
timetable for meetings with analysts and investors. In 2024, conference calls with financial  
analysts from the capital market have been organized, for the analysis of the periodic reports  
of the company. The presentation materials prepared on the events mentioned above have  
been published on the company’s website.  
Furthermore, particular importance has been given to the relationship with shareholders and  
investors, by showing increased transparency. The company’s representatives answered  
positive to all the participants to the capital market.  
In 2024, CONPET took part in numerous events organized within the capital market, showing  
openness towards both institutional and individual investors.  
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The company has also provided a contact number and an email address  
(infoinvestitori@conpet.ro), through which investors can clarify certain aspects or ask various  
questions, thus getting in direct contact with the company’s investors’ relation team.  
The evolution of CONPET S.A. share is monitored by the research departments of the major  
financial investment services companies from the Romanian capital market. Furthermore,  
the entity that manages the relationship with the investors maintains a permanent connection  
with all financial analysts in the capital market.  
At CONPET level, the corporate governance structures are:  
- The General Meeting of Shareholders;  
- The Board of Directors and the Consultative Committees;  
- The Director General/The Directors with mandate contracts.  
General Meeting of Shareholders  
On reference date 31.12.2024, the total number of shares issued by the company CONPET  
S.A was 8,657,528, owned by 16,251 shareholders. The shareholding structure, in  
accordance with the consolidated synthetic structure on the shareholders on the same date  
is the following:  
- The Romanian State by the Ministry of Energy (1 Shareholder)  
Number of shares:  
5,083,372  
Value of contribution to the share capital  
(RON):  
16,775,127.6  
Share of participation on profit and loss (%):  
58.7162  
- Legal persons (100 shareholders)  
Number of shares:  
2,083,424  
Value of contribution to the share capital  
(RON)  
6,875,299.2  
Share of participation on profit and loss (%):  
24.0649  
- Natural persons (16,150 shareholders)  
Number of shares:  
1,490,732  
Value of contribution to the share capital  
(RON)  
4,919,415.6  
Share of participation on profit and loss (%):  
17.2189  
The shareholders exercise their rights at the General Meeting of Shareholders (“GMS”),  
which is the highest decision-making body of the company. The powers of approval of the  
General Meeting of Shareholders, the organization and validity conditions of these meetings  
are set out in the Articles of Incorporation of the company, in accordance with the applicable  
regulations, and are supplemented with the incident legal provisions. Both the Articles of  
Incorporation of the company and shareholders’ rights are posted on the company’s website  
at the following addresses:  
99  
According to the law, each subscribed and paid share gives the holder the right to one vote  
in the General Meeting of Shareholders, the right to elect and to be elected to the governing  
bodies, the right to participate in the distribution of dividends according to the provisions of  
the Articles of Incorporation and of the legal dispositions, as well as other rights provided for  
by them.  
The shareholders are entitled to fair and complete information in the General Meeting of  
Shareholders on the company’s situation. In the case of the issuance of new shares, the  
existing shareholders have preferences for the right to subscription under the law.  
The General Meetings are ordinary and extraordinary.  
The General Meeting of Shareholders is convened by the Board of Directors, whenever  
necessary. The call for the General Meeting of Shareholders shall comply with the legal  
provisions regarding the companies, as well as the capital market regulations and the  
provisions of these Articles of Incorporation. The meeting time limit cannot be shorter than  
30 days after the publication of the call in the Official Gazette of Romania, part IV.  
In order to provide equal treatment and full and fair exercise of all shareholders’ rights,  
CONPET makes available to them all relevant information regarding the GMS and adopted  
resolutions, according to the law, both by mass communication means and in the special  
section opened on the company’s website.  
CONPET pays all diligence, in compliance with the requirements of the relevant legislation,  
to ease the participation of the shareholders in the sessions of the General Meetings, as well  
as for the full exercise of the rights thereof. The shareholders may take part and vote, in  
person, in the General Meeting of Shareholders, but also have the possibility to exercise the  
vote by representation or by correspondence.  
The General Meeting of Shareholders is opened and presided by the Chairman of the Board  
of Directors or, in his absence, by another administrator appointed by the Chairman of the  
Board of Directors.  
Each shareholder may address questions to the administrators regarding the company  
activity, according to the legal provisions.  
The decisions made by the General Meetings of Shareholders within the limits of the law and  
of the Articles of Incorporation are mandatory even for the shareholders who did not take part  
in the meeting or voted against.  
The decisions of the General Meeting of Shareholders, which are contrary to the law, or the  
Articles of Incorporation can be challenged in court, according to the law.  
The Ordinary General Meeting of Shareholders has the following main responsibilities:  
- discusses, approves or modifies the annual financial statements, based on the  
administrators’ report and the financial auditor’s report;  
- elects and revokes the administrators according to the law; at the appointment, the OGMS  
shall bear in mind that the majority of BoD members should be non-executive and  
independent;  
- appoints or revokes the financial auditor and sets forth the minimum duration of the  
financial audit contract;  
100  
- sets the remuneration level and any other amounts and advantages due to the  
administrators for the financial year in progress [...] as well as the general limits of the  
remuneration of the directors;  
- approves the Organization and Functioning Regulation of the Board of Directors and sets  
out the competencies thereof;  
- approves the Revenues and Expenditure Budget (R.E.B.) and the investment program for  
the next financial year;  
- approves the profit distribution as per the provisions of the normative acts in force and the  
fixing of dividend per share;  
- passes judgments over the administrators’ management and the means to recover the  
losses they have caused to the company;  
- decides upon the pledging, leasing or dissolution of one or several units of the company;  
- performs any other duty established by law in his charge.  
The Extraordinary General Meeting of Shareholders has the following main responsibilities:  
- changing the legal form of the company;  
- changing the location of the company’s headquarters;  
- changing the company’s line of business;  
- establishment or disestablishment of subsidiaries;  
- prolongation of the company’s life;  
- augmentation of the share capital;  
- reduction of the share capital or replenishment thereof by issuing new shares;  
- merger with other companies or division of the company;  
- anticipated dissolution of the company;  
- conversion of the shares from one category into another;  
- conversion of a category of bonds into another category or into shares;  
- bond issuance;  
- change of nominal value and number of shares;  
- decides on the contracting of medium and long-term bank loans, including external ones;  
- establishes the competences and the level of contracting of current bank loans,  
commercial credits, as well as the level of guarantees;  
- decides upon the participation, according to the law, to the establishment of new legal  
persons or in association with other legal or natural persons in the country or abroad,  
except for the non-profit organizations established under the law, for which the  
competence to approve the accession/withdrawal of companies from the capacity of  
member belongs to the Board of Directors.  
- decides on what market the securities issued by the company are to be traded and  
chooses the authorized independent registrar that manages the registers of the shares  
issued by the company;  
- any other amendment of the Articles of Incorporation or any other decision for which the  
approval of the Extraordinary General Meeting of Shareholders is asked.  
The Board of Directors  
The company is administered in a unitary system by a Board of Directors made of 7  
administrators, appointed by the Ordinary General Meeting of Shareholding for a period of 4  
years, with the possibility of re-election for further periods of 4 years. The administrators can  
act as shareholders. For the appointment of an administrator to be legally valid, the person  
101  
appointed must expressly accept. The identification data of the administrators are being  
registered at the Trade Register Office as per the legal provisions.  
The Board of Directors is ruled by a Chairman. The Chairman is elected by the Board of  
Directors, among its members. The removal from office of the chairman is also attribute of  
the Board. The decision on the appointment or revocation shall be taken by the majority vote  
of the members of the Board.  
The Chairman of the BoD of the company cannot be the Director General.  
The Board of Directors usually meets at the company’s headquarters or any place of  
business of the company or in any place disclosed in the convening notice. Operational  
meetings of the Board of Directors may be organized by means of remote communication  
meeting the technical conditions necessary for the identification of the participants, their  
effective participation to the meetings of the Board of Directors and the retransmission of the  
deliberations on a continuous basis (via e-mail, telephone, video call or other communication  
equipment), whenever necessary, but at least every 3 months, at the call of the Chairman or  
at the reasoned request of 2 of its members or of the Director General/Directors. In this case,  
the Agenda is being established by the authors of the request. The Chairman must act on  
such a request.  
The Board of Directors cannot decide upon certain issues that are not included on the  
Agenda, except for the emergencies. To decide on emergency, the absent members will be  
consulted upon, by various means of distance communication. The Chairman shall decide  
on the urgency of the problems. The Board of Directors operates under its own rules and  
regulations in force.  
For the validity of resolutions, the presence (directly or by proxy) of at least five council  
members is required and decisions are taken by the majority vote of the members present.  
The chairman of the Board of Directors will have a casting vote in case of equal votes. The  
Abstention” position adopted by an administrator regarding the items included on the agenda  
of the general meeting of shareholders is not deemed expressed vote.  
The members of the Board of Directors can only be represented at meetings of the respective  
body by other members herein. A member present may represent one absent member.  
For the decisions taken in meetings in which a board member did not attend, he remains  
liable if, within 30 days since he took notice of them, he did not make resistance in the forms  
specified by law.  
The Agenda is set by the Chairman. The call, the agenda and the meeting materials will be  
sent to the administrators in sufficient time before the date of the meeting; the deadline can  
be established by the own regulation of the Board of Directors. The minutes of the meeting  
shall be comprised in a Journal of the Meetings and BoD Deliberations, by courtesy of the  
Chairman of the Board.  
The protocol of the meeting shall be drawn up by technical editing by the BoD Secretariat  
and shall comprise the name of the participants, the order of the deliberations, the decisions  
made, the number of votes cast and separate opinions. This will be signed by the Chairman  
102  
of the Board of Directors, the BoD members. (only those who participate directly in the  
meeting may also have a mandate of representation given by another administrator) and by  
the BoD Secretariat.  
The protocol contains the names of participants, policy deliberations, decisions, number of  
votes and dissenting opinions. It is signed by the Chairman of the Board, the other  
administrators and the BoD secretariat, being contained in the register of meetings and  
deliberations of the Board. The BoD Secretariat is being provided from among the personnel  
within the BoD and GMS Secretariat.  
The structure of the Board of Directors is diverse in both men and women of different  
professions (engineers, lawyers and economists) with professional experience in energy,  
banking, investment, capital market analysis, legal fields.  
The management of the company was carried out in 2024 by the administrators appointed  
by the OGMS Resolution no. 4/18.08.2023, with a term of office of 4 years, following the  
selection procedure carried out in accordance with the provisions of G.E.O. no. 109/2011, by  
the cumulative voting method.  
Structure of the Board of Directors:  
Chairman of the BoD: Mr. Cristian Florin Gheorghe, appointed by Decision no.  
22/18.08.2023  
Members: Mr. Nicușor - Marian Buică, Mrs. Luminița – Doina Kohalmi - Szabo, Mrs. Oana –  
Cristina Tănăsică, Mr. Florin – Daniel Gavrilă, Mr. Andrei – Mihai Zaman, Mr. Alin Mihael  
Dănilă.  
The CV’s of the members of the Board of Directors of CONPET S.A. are availabe on the  
company’s website https://www.conpet.ro/en/corporate-governance/board-of-directors/ and  
are presented in Annex 8.  
Within the Board of Directors, out of a number of 7 non-executive directors, 5 members are  
male and 2 members are female (29%), following the selection carried out by the Public  
Supervisory Authority in 2023, prior to the appearance of the amendments to Law no.  
24/2017 on issuers of financial instruments and market operations, intervened by Law no.  
11/ 2025.  
Information on diversity in terms of management and management bodies can also be found  
in the Annual Sustainability Report 2024.  
In 2024, the members of the Board of Directors did not own shares in CONPET SA.  
Consultative Committees  
Within the Board of Directors there are constituted the following consultative committees:  
- The Nomination and Remuneration Committee;  
- The Audit Committee;  
- The Risk Management Committee:  
- The Committee for Development and Relation with the Investors and Authorities.  
103  
Composition of the Consultative Committee  
The composition of the Consultative Committees during 2024 remained unchanged  
compared to 31.12.2023 and is presented as follows:  
The Nomination and Remuneration Committee is made out of 5 non-executive  
administrators: Zaman Andrei - Mihai - President: members: Mr. Cristian - Florin Gheorghe,  
Mrs. Oana – Cristina Tănăsică, Mr. Alin – Mihael Dănilă, Mrs. Luminița – Doina Kohalmi -  
Szabo.  
The Audit Committee is made out of 3 non-executive administrators: Mr. Florin- Daniel  
Gavrilă - President; members: Mr. Nicușor – Marian Buică, Mr. Cristian – Florin Gheorghe.  
The Risk Management Committee is made out of 3 non-executive administrators: Mrs.  
Luminița – Doina Kohalmi - Szabo - President; members: Mr. Alin – Mihael Dănilă, Mr.  
Nicușor – Marian Buică.  
The Committee for Development and Relation with the Investors and Authorities is made up  
of 3 non-executive administrators: Mrs. Oana – Cristina Tănăsică - president; Members: Mr.  
Florin – Daniel Gavrilă, Mr. Andrei – Mihai Zaman.  
All 7 administrators are non-executive members, of which: 1 non-independent administrator  
(Mr. Gheorghe Cristian Florin, member in the Nomination and Remuneration Committee  
and the Audit Committee), the other 6 administrators being independent and ensuring the  
administration of the company.  
The terms of reference and attributions of the Board of Directors and of the Consultative  
Committees may be consulted at the web pages: https://www.conpet.ro/wp-  
content/uploads/2015/11/Rules-on-the-Organization-and-Functioning-of-the-BoD.pdf for the  
Board of Directors, respectively https://www.conpet.ro/wp-content/uploads/2015/11/Internal-  
rules-and-functioning-of-the-Comittees5.pdf for the Consultative Committees established at  
the BoD level.  
The Consultative Committees meet whenever necessary at the convening of the President  
of each committee, and the proposals/recommendations made to the Board of Directors (to  
substantiate its decision-making) are adopted by a majority of the votes cast. The duties and  
responsibilities of the consultative committees are being established by the Board of  
Directors.  
The Summary of the activities performed in 2024  
In 2024, the Board of Directors held 26 meetings. The Consultative Committees also held 36  
meetings, as follows: 10 meetings of the Nomination and Remuneration committee, 10  
meetings of the Audit committee, 5 meetings of the Risk management committee and 11  
meetings of the Development and Investor and Authorities Relation committee.  
The meetings of the Board of Directors have been carried out according to the agenda  
transmitted to the administrators, the main decisions made having as object the following:  
- endorsement of 2024 Revenues and Expenditure Budget (Budget) by the OGMS (also  
comprising the estimates for 2025- 2026);  
104  
- endorsement of 2024 Investment Program (and estimates of the Investment Expenditures  
for 2025 and 2026) proposed by Substantiation note to the OGMS;  
- endorsement of the Investment Program for 2024 - Annex no. 1 (detailed structure by  
objectives which also includes estimates for the years 2025 and 2026 ) and Annex no. 2  
(independent facilities and equipment for 2024), according to the Report drafted to the  
BoD;  
- approval of the Investment Program for the year 2024 and estimates for the years 2025  
and 2026, Annex no. 1 (structure by types of works), Annexes no. 2 (details on objectives),  
no. 3 (Independent equipment and machinery 2024), no. 4 (20242026 investment,  
endowment and financing sources program).  
- approval of the Report regarding the status of the sponsorships granted by CONPET S.A.  
in the year 2023;  
- analysis of the company’s business presented by the executive management in the  
monthly reports;  
- periodical analysis of the physical and value-related implementation of the 2024  
Investment Program;  
- analysis and endorsement/approval of the Consultative Committees Reports, as  
appropriate;  
- approval of the Convening Notices of the General Meeting of Shareholders and of the  
materials related to their Agenda;  
- monitoring the implementation/stage of implementation of the measures ordered by the  
BoD Decisions;  
- the appointment of a Deputy Director General 3, with a mandate starting from 15.01.2024  
to 19.10.2027 (inclusive of) and the approval of the mandate contract, following the  
completion of the selection procedure for DDG3, the approval of the management  
component of the Management Plan, drawn up by DDG3, the approval of the level of the  
variable component of his remuneration and the method of calculation and granting, for  
each year of mandate, within its general limits, approved by Resolution of the OGMS no.  
6/19.12.2023, the approval of the financial and non-financial key performance indicators  
and the conclusion of Addendum no. 1 to the mandate contract;  
- approval of the preliminary report for the period January - December 2023, accompanied  
by the non-audited preliminary financial statements at the date and for the financial year  
ended December 31st, 2023;  
- analysis and approval of the results of 2023 a inventory of the elements similar to assets,  
liabilities and equities, related to the company’s patrimony;  
- endorsement of the results of 2023 inventory of the elements similar to assets related to  
public and private domain of the State.  
- approval of the accounting policies Manual of the company CONPET S.A. - updated;  
- approval of the dissolution of a number of 27, respectively 29 positions within certain  
organizational entities of the company and the corresponding modification of the list of  
functions, by eliminating the existing positions;  
- endorsement of the Policy relating to the remuneration of administrators and directors with  
a mandate contract, published on CONPET S.A. website, following the approval thereof  
by the OGMS; April 2024;  
- endorsement of the financial statements at the date and for the financial year concluded  
on 31.12.2023;  
- approval of the Annual Report of the company’s administrators for the financial year ended  
31.12.2023, report presented in the OGMS;  
105  
- endorsement of the proposals of the executive management to the Ordinary General  
Meeting of Shareholders concerning the distribution of net profit related to the financial  
year 2023 and of the amounts from the retained earnings, setting the registration date and  
the date of dividends payment to the shareholders; endorsement of Mentions to the OGMS  
regarding the distribution of profit;  
- endorsement of the proposal to the OGMS regarding the discharge of administration of  
the administrators for the activity of 2023;  
- approval of the report of the directors with mandate contracts for the activity ended  
31.12.2023;  
- approval of the Report of Directors with mandate contract to monitor the framing of key  
financial and non-financial performance indicators (KPIs) for 2023 within the limits  
approved by the Board of Directors; approval of the total degree of fulfillment of the  
financial and non-financial key performance indicators (KPIs) for 2023 for directors with  
mandate contracts, namely 105.4% for indicators established for the period 01.01.2023 -  
19.10.2023 and 106.0% for indicators established for the period 20.10.2023 - 31.12.2023  
and approval of granting the variable component due to the directors for the mandate  
periods carried out in 2023, in accordance with the provisions of the mandate contracts  
and within the limits established by the OGMS;  
- submission for approval of the OGMS of the Board of Directors Report on the  
administration activity in 2023, prepared in compliance with the provisions of Article 55 of  
GEO 109/ 2011 on corporate governance of public enterprises and the provisions of the  
mandate contract;  
- endorsement of the report of the Nomination and Remuneration Committee on the  
evaluation of the company’s administrator’s activity in 2023;  
- approval of the Report of the Nomination and Remuneration Committee on the evaluation  
of the activity of directors with mandate contract for 2023;  
- endorsement of the Report prepared by directors with mandate contract regarding the total  
degree of achievement of the financial and non-financial key performance indicators  
(KPIs) for 2023 for the company's administrators;  
- endorsement of the Report of the Board of Directors for the monitoring of the framing of  
the key performance indicators (KPIs) of the administrators for 2023 within the limits  
approved by the OGMS and the submission for approval to the General Meeting of the  
proposals for the approval of the total degree of fulfillment (102.2%) of the financial and  
non-financial key performance indicators (KPIs) for the year 2023 and for granting the  
variable component due to the directors for the term of office carried out in 2023,  
respectively for the period 22.08.2023 - 31.12.2023, in accordance with the provisions of  
the mandate contracts;  
- endorsement of the Annual Report of the Nomination and Remuneration Committee to the  
OGMS related to the remunerations and other benefits awarded to the administrators and  
the directors with mandate contract during 2023 financial year (Remuneration Report);  
- approval of the annual report the Audit Committee for 2023;  
- approval of the annual report of the Risk Management Committee for 2023;  
- delegating to the Director General and the Economic Director of the power to approve the  
revision (modification) of the Investment Program within the same values approved by the  
OGMS; the general review of the Annual Investment Program and the approval of changes  
beyond the approval limits delegated to the Directors General and the Economic Director  
remain within the approval competence of the Board of Directors;  
106  
- approval of revision of the Investment program for 2024 and estimates for the years 2025  
and 2026, within the same values;  
- delegating to the Director General of CONPET S.A. the power to approve the revision  
(modification) of the Annual Procurement Program within the limit of the maximum value  
of 200,000 euro/acquisition for the newly introduced acquisitions in the program or to  
modify the estimated value/acquisition within the maximum value of 200,000  
euro/acquisition for the existing acquisitions in the Annual Procurement Program; the  
general review of the Annual Procurement Program and the approval of changes beyond  
the approval limits delegated to the General Manager remain within the approval  
competence of the Board of Directors;  
- approval of the revision of the Procurement Program for 2024, according to the proposals;  
- approval of the criteria for granting the amounts paid as employees' share of profit for  
2023;  
- approval of the decommissioning/downgrade of the goods (fixed assets and inventory  
goods in use/ Inventories), whose operation is no longer justified and the approval of the  
proposed means to capitalize these goods;  
- endorsement of the decommissioning of the assets belonging to the public domain of the  
state (fixed assets and inventory objects of the nature of fixed assets) and the approval of  
the proposed valuation methods for these assets;  
- approval of the 2024 annual Procurement Program - periodic changes/revisions;  
- approval of Current Repairs Program for 2024/ rectification approval;  
- approval of Current Repairs Program for 2024/ rectification approval;  
- approval of the Technical Revision Program planned for 2024/rectification approval;  
- approval of the Code of Ethics and Integrity of CONPET S.A.- Revision;  
- approval of the Quarterly Activity Reports of Directors with mandate contract, in  
accordance with the provisions of GEO no.109/2011 on the corporate governance of  
public enterprises and the provisions of the contract of mandate;  
- approval of the Quarterly report on the economic and financial activity of CONPET S.A. ,  
accompanied by the financial statements prepared in compliance with the Ministry of  
Public Finance Order no. 2844/2016 and the International Accountancy Standard  
34,”Interim financial reporting”.  
- endorsement of the Quarterly Report regarding the monitoring of the financial and non-  
financial key performance indicators of the administrators and directors with mandate  
contract;  
- approval of the participation of the Director General and certain BoD members to certain  
events/conferences and approval of the travel report.  
- approval of the proposals regarding the opportunity to maintain CONPET S.A. capacity as  
a contributing member to the non-governmental organizations where the company is  
operating;  
- monitoring the activities and actions carried out monthly by the non governmental  
organizations in which CONPET SA is a member;  
- approval of sponsorship requests and periodical monitoring of sponsorship contracts  
concluded by the company;  
- the empowerment of the Director General to initiate the negotiation procedure for the  
conclusion of the Collective Labor Agreement applicable at unit level;  
- the empowerment of the Director General of the Company for the negotiation and  
conclusion, with CONPET Free Union, of an Addendum to the Collective Labor Agreement  
applicable at Company level.  
107  
- approval of the delegation to the Director General of the power to sign the minutes of  
decommissioning of fixed assets, decommissioning of inventory/decommissioning objects  
of material goods, approved at decommissioning by the Board of Directors;  
- approval of the investment strategy of the financial resources of CONPET S.A.,  
respectively the establishment of bank deposits;  
- approval of the starting price at auction for the stock of recovered pipe and for some  
vehicles, approved for recovery by auction;  
- the Information on the Report on the management control system as of 31.12.2023 and  
the status of the implementation of the actions included in the Program for the  
development of the internal control management system for 2023 was noted;  
- the Information on the findings and recommendations contained in the Compliance Audit  
Report of the Court of Accounts, recorded in the Plan of Measures drawn up by the  
executive management for their implementation, was noted;  
- the Information regarding the analysis of the anti-bribery compliance function and the  
analysis carried out by the management for the anti-bribery management system  
implemented in CONPET S.A. was noted;  
- the Information on the monitoring of the performance of the internal managerial control  
system and risk management at the level of CONPET S.A. in 2023 was noted;  
- approval of the delegation of duties and responsibilities at the level of directors with a  
mandate contract, in certain situations;  
- approval of the Half-yearly Report of the Board of Directors to the General Meeting of  
Shareholders for the first half of 2024, accompanied by the Financial Statements as of  
30.06.2024;  
- endorsement of the fulfillment of the statute of limitation of the shareholders to the  
dividends related to 2020 financial year and submission of the proposal to the OGMS  
approval;  
- endorsement of 2024 rectified Revenues and Expenditure Budget (Budget) by the OGMS  
(also comprising the estimates for 2025 - 2026);  
- approval of the rectification of the Budget for the year 2024, respectively of Annex no.1 -  
Rectified budget for 2024, Annex no. 2 Detailing the economic and financial indicators  
provided for in the rectified Budget for the year 2024 and the distribution by quarters  
thereof and Annex no. 4 - The Investment program, endowments and financing sources –  
rectified for the year 2024;  
- approval of the Risks management policy of CONPET S.A.;  
- approval of the Procedural Internal Procurement Norms Revision;  
- the Information on how to implement the recommendations contained in the Compliance  
Audit Report of the Court of Accounts, fully implemented within the established deadlines,  
was noted;  
- approval of the Corporate Governance Regulation, updated;  
- approval of the Regulation concerning the organization and carry out of the GMS within  
CONPET S.A.;  
- approval of the Visual Identity Manual of CONPET S.A., revised;  
- approval of the passing on to the company's costs of a fine received by the company;  
- approval of the Technical Revision Program planned for 2025;  
- approval of the Annual Procurement Program Draft for 2025;  
- approval of the updated Organizational and Functioning Rules of the company CONPET  
S.A.;  
- approval of the Internal Regulation of CONPET S.A.;  
108  
- analysis of the Revenues and Expenditure Budget for the year 2025 projection  
(preliminary document);  
- analysis of the Information regarding the necessity and opportunity of the objectives/works  
contained in the projection of the Investment Program for 2025 -2027.  
The Directors with mandate contracts  
The Director General  
Following the performance and completion of the procedure for recruitment and selection of  
the Director General, Deputy Director General and Economic Director, carried out in  
compliance with the provisions of GEO no. 109/2011 on the corporate governance of the  
public enterprises, the Board of Directors, by Decision no. 31/19.10.2023, appointed Mr.  
Dorin Tudora in the capacity of Director General for a 4 years’ mandate, starting 20.10.2023  
until 19.10.2027, delegating to him the management of the company in accordance with the  
legal provisions in force, the Articles of Incorporation and the contract of mandate.  
The Deputy Director General  
Following the performance and completion of the procedure for recruitment and selection of  
the Director General, Deputy Director General and Economic Director, carried out in  
compliance with the provisions of GEO no.109/2011 on the corporate governance of the  
public enterprises, the Board of Directors, by BoD Decision no. 31/19.10.2023, appointed  
Mrs. Mihaela - Anamaria Dumitrache in the capacity of Deputy Director General for a 4 years’  
mandate, starting 20.10.2023 until 19.10.2027, delegating to her the management of the  
company in accordance with the legal provisions in force, the Articles of Incorporation and  
the contract of mandate.  
The Economic Director  
Following the performance and completion of the procedure for recruitment and selection of  
the Director General, Deputy Director General and Economic Director, carried out in  
compliance with the provisions of GEO no.109/2011 on the corporate governance of the  
public enterprises, the Board of Directors, by BoD Decision no. 31/19.10.2023, appointed  
Mrs. Sanda Toader in the capacity of Economic Director for a 4 years’ mandate, starting  
20.10.2023 until 19.10.2027, delegating to her the management of the company in  
accordance with the legal provisions in force, the Articles of Incorporation and the contract  
of mandate.  
The Deputy Director General 3  
The Board of Directors, by Decision no.33/01.11.2023 approved the initiation of the  
recruitment and selection procedure of the Deputy Director General 3.  
Following the performance and completion of the procedure for recruitment and selection  
carried out in compliance with the provisions of GEO no.109/2011 on the corporate  
governance of the public enterprises, the Board of Directors, by Decision no.1/12.01.2024  
appointed Mr. Radu - Florentin Necșulescu in the capacity of Deputy Director General 3, with  
a mandate starting 15.01.2024 until 19.10.2027 (inclusive of), delegating the management  
of the company in accordance with the legal provisions in force, the Articles of Incorporation  
and the contract of mandate.  
109  
Directors with mandate contracts have the attributions specified in the contract of mandate,  
supplemented by provisions of the Articles of Incorporation, the Rules of Organization and  
Operation, completed with applicable legal provisions.  
The Director General supplies to the Board of Directors, regularly and comprehensively,  
detailed information regarding all outstanding aspects for the company business.  
Additionally, any outstanding event is immediately communicated to the Board of Directors.  
Moreover, any member of the Board of Directors may request the Director General  
information regarding the operative company management.  
The management bodies and the administration bodies are active, have the freedom to adopt  
the decisions they consider right, acknowledge their role and are permanently capable of  
supporting their decisions against the administration structures or other interested parties  
that have the right to obtain such information.  
The Remuneration Policy  
The remuneration policy of the administrators and directors with mandate contract, which  
also includes the remuneration criteria thereof, was approved by the OGMS Resolution no.  
2/25.04.2024 and is posted on the company’s web page.  
- The Board of Directors  
Remuneration for the members of the Board of Directors, respectively the non-executive  
administrators is determined by the General Meeting of Shareholders in the structure and  
limits set by GEO no. 109/2011, consisting of monthly gross fixed allowance and a variable  
component.  
In 2024, the administrators of CONPET S.A. carried out their activity based on mandate  
contracts whose form and content were approved by the General Meeting of Shareholders.  
The remuneration of the administrators appointed for a period of 4 years starting with  
22.08.2023 until 21.08.2027 (inclusive of) consists of a monthly fixed allowance and a  
variable component.  
The Gross Fixed Allowance  
According to OGMS Resolution no.4 dated 18.08.2023, the members of the BoD have a  
monthly gross fixed allowance equal to twice the average for the last 12 months of the  
average gross salary per month for work done according to the core business recorded by  
the Company, at class level according to the classification of the national economy,  
announced by the National Institute of Statistics prior to the appointment.  
The gross fixed remuneration due to the members of the BoD for the period 01.01.2024 -  
31.12.2024 was of 1,797,432 RON.  
Variable component  
The variable component is determined based on financial and non-financial performance  
indicators negotiated and approved by the General Meeting of Shareholders.  
110  
The variable component due to administrators is granted in conjunction with the annual total  
degree of fulfillment of financial and non-financial KPIs approved in the contract of mandate.  
In the meeting dated 25.04.2024, the OGMS has approved the total degree of achievement  
(102.2%) of the financial and non-financial key performance indicators for the year 2023,  
based on the Board of Directorsmonitoring report on the framing of the performance  
indicators for the year 2023 in the limits approved by the OGMS and granting the variable  
component due to administrators for the term of office in 2023, as per the provisions of the  
mandate contract.  
The total gross variable component related to 2023 and paid in April 2024 was in amount of  
647,465 RON.  
The financial statements of 2024 include provisions representing variable allowances related  
to mandate contracts for non-executive administrators in the amount of 1,797,432 (1,837,874  
RON with the employer's contribution) and shall be paid after the approval of its distribution  
by the OGMS.  
The Directors with mandate contracts  
The Director General  
For the period 01.01.2024 31.12.2024, the Board of Directors has settled the monthly gross  
fixed allowance of the Director General for the execution of the entrusted mandate for a  
period of 4 years (20.10.2023 19.10.2027), in amount of 66,636 RON, respectively 6 times  
the average on the last twelve months of the monthly gross average earnings for the activity  
performed as per the core business registered by the company, at level of class as per the  
classification of the activities in the national economy, communicated by the National Institute  
of Statistics prior to the appointment.  
The gross fixed allowance granted to the Director General of CONPET SA between  
01.01.2024 31.12.2024 was of 799,632 RON.  
The gross variable component related to 2023 and paid in 2024 to the Director General  
amounted to 669,772 RON.  
Deputy Director General  
For the period 01.01.2024 31.12.2024, the Board of Directors has settled the monthly gross  
fixed allowance of the Deputy Director General for the execution of the entrusted mandate  
for a period of 4 years (20.10.2023 19.10.2027), in amount of 55,530 RON, namely 5 times  
the average on the last twelve months of the monthly gross average earnings for the activity  
performed as per the core business registered by the company, at level of class as per the  
classification of the activities in the national economy, communicated by the National Institute  
of Statistics prior to the appointment.  
The fixed gross allowance granted to the Deputy Director General of CONPET SA between  
01.01.2024 - 31.12.2024 was 666,360 RON.  
111  
The gross variable component for the year 2023 and paid in 2024 to the Deputy Director  
General amounted to 189,481 RON.  
The Economic Director  
For the period 01.01.2024 31.12.2024, the Board of Directors established the monthly  
gross fixed allowance of the Economic Director for the execution of the entrusted mandate  
for a period of 4 years (20.10.2023 19.10.2027), respectively 55,530 RON, i.e. 5 times the  
average on the last 12 months of the average gross salary for the activity carried out  
according to the main object of activity fully registered by the company, at class level  
according to the classification of activities in the national economy, communicated by the  
National Institute of Statistics prior to the appointment.  
The fixed gross allowance granted to the Economic Director of CONPET SA between  
01.01.2024 - 31.12.2024 (inclusive of) was of 666,360 RON.  
The gross variable component related to 2023 and paid in 2024 to the Economic Director  
amounted to 131,253 RON.  
The Deputy Director General 3  
For the period 15.01.2024 31.12.2024, the Board of Directors has settled the monthly gross  
fixed allowance of the Deputy Director General 3, for the execution of the entrusted mandate  
for the period 15.01.2024 19.10.2027, in amount of 55,530 RON, respectively 5 times the  
average on the last twelve months of the monthly gross average earnings for the activity  
performed as per the core business registered by the company, at level of class as per the  
classification of the activities in the national economy, communicated by the National Institute  
of Statistics prior to the appointment.  
The gross fixed allowance granted to the Deputy Director General 3 of CONPET SA between  
15.01.2024 31.12.2024 (inclusive of) was of 644,148 RON.  
The total gross fixed remuneration due to the directors with mandate for the period  
01.01.2024 31.12.2024 was 2,776,500 RON.  
The general limits of the variable component have been approved by the OGMS in the  
meeting dated 19.12.2023. The variable component is being paid following the approval of  
the annual financial statements, according to the degree of achievement of the key  
performance indicators.  
In the meeting dated 25.04.2024, the OGMS approved:  
- The Annual Report of the Nomination and Remuneration Committee related to the  
remunerations and other benefits awarded to the administrators and the directors with  
mandate contract during 2023 financial year.  
- Total degree of achievement of the financial and non-financial key performance indicators  
of the directors with contract of mandate for the period 01.01.2023 - 19.10.2023 accounted  
for 105.4%, and for the period 20.10.2023 - 31.12.2023 accounted for 106%, as per the  
reports mentioned above and approved by BoD Decision no.8 dated 20.03.2024.  
112  
The total gross variable component related to 2023, paid in April 2024 amounted to 990,506  
RON.  
The variable component of 2024 will be paid following the approval of the financial  
statements, according to the degree of achievement of the key performance indicators.  
The financial statements of 2024 include provisions representing variable allowances for  
mandate contracts for directors with mandate contracts, in amount of 2,776,500 (2,838,971  
with the employer's contribution), and will be paid after the approval of the financial  
statements in relation to the total degree of fulfillment of the key performance indicators.  
Status of achieving the Key Performance Indicators for 2024  
Total Degree of achievement of the performance indicators (GTICP) is the amount of the  
degree of achievement of every KPI (GIICP) weighted by the weighting coefficient (WICP)  
related to every KPI.  
The calculation formula is the following:  
where:  
GTICP = Total annual degree of achievement of the KPI  
WICP = Weighting Coefficient (weight) for every KPI  
GIICP = Degree of achievement of the individual KPI  
The degree of achievement of every KPI (GIICP) is the degree of achievement of every KPI,  
considering the means of calculation provided at every KPI, subsequently weighted by the  
weighting coefficient (Wi ICP) related to each KPI.  
The variable component of the remuneration due to the administrators will be directly  
proportional to the GTICP for the corresponding financial year or part of the corresponding  
financial year and is being awarded as follows:  
In the event that:  
a) GTICP ≥ 100%, the maximum variable remuneration component approved by the OGMS  
for each administrator is granted in the maximum amount approved by the OGMS.  
b) 80% ≤ GTICP< 100%, the maximum variable component of remuneration approved by the  
OGMS for each administrator with contract of mandate is being awarded in proportion to the  
total degree of achievement of the performance indicator  
c) GTICP <80%, the variable component shall not be awarded.  
- Financial and non-financial Key performance indicators for 2024 approved for the  
administrators of the company  
According to the OGMS Resolution no. 6/19.12.2023, the financial and non-financial  
performance indicators (KPIs) of the company’s administrators were approved, for the period  
2023-2027, which will be used for determining and granting the variable remuneration  
component of administrators during the execution of the contract of mandate.  
The structure of the financial and non-financial KPIs, the performance objectives of every  
KPI, their weight and the degree of achievement are shown in the table below:  
113  
Table 33 - 2024 key performance indicators  
Chart 22 - Financial key performance indicators  
114  
Chart 23- Operational non-financial Key Performance Indicators  
Chart 24 - Key non-financial governance performance indicators  
Chart 25- Non-financial key performance indicators oriented to public services  
For the year 2024, the total degree of achievement of the key financial and non-financial  
performance indicators for the administrators was 101.1 %.  
- Financial and non-financial key performance indicators for 2024 set for the directors  
with contract of mandate  
115  
Key performance indicators - mandate period 01.01.2024 31.12.2024  
The total degree of fulfillment of the key performance indicators underlying the variable  
component granting, for the period 01.01-31.12.2024, included in the mandate contracts of  
the directors is 104.5%.  
In structure, the degree of achievement of the performance indicators reveals the following:  
Degree of achievement of key  
performance indicators  
2024  
Key Performance Indicators  
Mandate  
Contract  
Achieved  
Variation  
A. Financial key performance indicators  
B. Non-financial key performance indicators  
B1. Operational  
50.0%  
54.5%  
50.0%  
20.0%  
25.0%  
5.0%  
+4.5 p.p.  
0.0 p.p.  
0.0 p.p.  
0.0 p.p.  
0.0 p.p.  
50.0%  
20.0%  
25.0%  
5.0%  
B2 of Corporate Governance  
B3. Oriented towards public services  
Total degree of achievement of key performance  
indicators:  
50.0%  
54.5%  
+4.5 p.p.  
Table 34 Degree of achievement of the performance indicators for the administrators during 01.01.2024-  
31.12.2024  
The total degree of achievement of the key performance indicators has been exceeded by  
4.5 p.p., being favorably influenced by the financial indicators.  
In Annex no. 3 to the Report of the Administrators is presented the calculation of the total  
degree of fulfillment of the financial and non-financial key performance indicators of directors  
with contract of mandate.  
The remunerations and degree of achievement of the key performance indicators of  
administrators and directors with contract of mandate are presented in the Annual Report of  
the Nomination and Remuneration Committee.  
The statement of salary rights by positions and other rights/benefits of CONPET S.A.  
The basic salaries within CONPET S.A. are divided by job functions groups, respectively by  
job function classes. Job function classes are ranked within the company in relation to the  
level of professional training, the importance of work, the complexity and diversity of  
activities, the responsibility and impact of decisions, exposure to risk factors, the difficulty of  
specific activities, the range of relations.  
Job  
function  
classes  
Basic gross salary  
Minimum level -  
maximum level (Ron)  
3,700- 5,600  
Crt.  
No.  
1
2
3
4
5
6
7
Class 1  
Class 2  
Class 3  
Class 4  
Class 5  
Class 6  
Class 7  
3,8405,880  
4,1306,170  
4,4206,460  
4,7306,750  
5,1107,120  
5,2007,530  
116  
Job  
function  
classes  
Basic gross salary  
Minimum level -  
maximum level (Ron)  
5,1107,120  
Crt.  
No.  
8
Class 8  
Class 9  
5,3008,680  
5,4808,890  
9
10  
11  
12  
13  
14  
15  
16  
Class 10  
Class 11  
Class 12  
Class 13  
Class 14  
Class 15  
Class 16  
5,7709,170  
6,17011,610  
11,61017,040  
12,38017,810  
20,81028,580  
25,65031,470  
Table 35 - Job function classes and gross basic salary level  
The above classes include the following job functions:  
Class 1 - janitor, cargo handler, pipeline route operator, security guard;  
Class 2 - boiler operator for steam and hot water boilers, firefighter servant, telephone  
operator, car vulcanizer  
Class 3 - maneuverer, firefighting formation chief, universal carpenter, tractor driver;  
Class 4 - warehouse - keeper, pump operator, chief maneuver, forklift driver;  
Class 5 - maintenance electrician, cathodic protection electrician, central heating plumber,  
technical-sanitary plumber, locksmith energy and transport aggregates, mechanical  
locksmith, boiler mechanic locksmith, auto mechanic, locomotive mechanic, operator, truck  
driver, car driver, van driver, bricklayer;  
Class 6 - electrical equipment electrician, power plants and power stations operation  
electrician, laboratory assistant, valves/ LDH mechanical locksmith, earth machine  
machinist, verifier metrologist, receiver handing-over fluid products - station responsible,  
crane driver, receiver handing over fluid products, heavy tonnage car driver, special vehicle  
driver, universal lathe operator, welder;  
Class 7 dispatcher, RSC/LFI locomotive engineer, PSI-RSC/LFI formation leader, shift  
manager;  
Class 8 - archivist, cashier, administrative clerk, householder, car operator, secret document  
inspector, operator of data entry, data validation and processing, shipping receiving clerk  
of materials and tools;  
Class 9 - technicians, foremen, administrative secretary, technical reviewer, maintenance  
responsible, production responsible, junior programmer, accountant, assistant manager,  
nurse, commercial activities official, administrative, ITP inspector, car drivers);  
Class 10 - short-term higher education personnel (engineer, sub-engineer, management  
reviewer, economist, network administrator, assistant director, assistant manager,  
communication and image specialist, process improvement specialist, human resources  
specialist);  
Class 11 - formation manager, station manager, warehouse manager, ramp manager;  
Class 12 - long-term higher education personnel (engineer, economist, internal auditor,  
network administrator, information system administrator, assistant manager, chemist, legal  
adviser, management systems consultant, legal expert, prevention and anti-corruption  
expert, general medicine doctor, programmer, psychologist, management reviewer,  
automation responsible, energy responsible, HSEQ responsible, investment responsible,  
mechanical responsible, maintenance responsible, production responsible, human  
117  
resources specialist, communication and image specialist, communication and press  
relations specialist, process improvement specialist, public relations specialist, events  
logistics specialist, OHS specialist, translator);  
Class 13 activity coordinator, advisor to the Director General, construction site supervisor;  
Class 14 head of Department, head of specialized formation, head of sector, head of office;  
Class 15 - chief engineer, regional head, head of department;  
Class 16 - director.  
Within the company, bonuses of a permanent nature and temporary bonuses are granted.  
Benefits of a permanent nature:  
- seniority benefits to be determined on the basis of the total seniority; the seniority benefits  
are applied to the gross basic salary and can be of 5%, 10%, 15%, 20%, 25% and 30%;  
- disability benefits, for employees with a disability degree, apply a percentage of 9.5% to  
the gross basic salary.  
The temporary benefits are:  
- night work benefits are granted at a rate of 30% to the gross basic salary, for the time  
actually worked;  
- benefits for work on Saturdays and Sundays, a percentage of 25% is granted to the gross  
basic salary, for the time actually worked;  
- Benefits for working on holidays are granted in a percentage of 100% to the gross basic  
salary, for the time actually worked.  
Based on the Collective Labor Agreement and within the limits of the provisions of the  
Revenues and Expenditure Budget approved annually, the company may grant the following  
rights:  
- meal vouchers with a nominal value of 40 Ron for each worked day;  
- birth aid and/or child adoption aid (in the amount of an average gross earnings per  
company*);  
- employee death grant (in the amount of five gross average earnings per company*), death  
grant spouse, child death grant, parental death benefit (in the amount of an average gross  
earnings per company*); death benefit for in-laws (in the amount of 1,200 lei);  
- gifts in cash or kind for the children of the employees on the occasion of the Children's  
day and Christmas holidays, gifts in cash or in kind for the employees on the occasion of  
March 8th, gifts in cash or in kind, including gift vouchers, for the company's employees on  
the occasion of Easter and Christmas holidays, as well as on the occasion of other events  
(limits set annually depending on the provisions of the Fiscal Code);  
- aids for serious or incurable diseases and prostheses;  
- consideration of the touristic services for treatment and rest carried out in the country and  
abroad, as well as the transport carried out on the occasion of the annual leave (75% of  
the invoice, but not more than 2,800 RON);  
- retirement aid (in the amount of one gain, two earnings, three earnings or five average  
gross earnings per company*, depending on the seniority/seniority in the company);  
- marriage aid (in the amount of an average gross earnings per company*);  
- contribution to the stakeholder pension fund - pillar III (Ro. Pilon III), up to a limit of 400  
euro annually;  
- voluntary health insurance, up to a limit of 200 annually euro;  
118  
- reimbursement of transport from home to the place of work and return based on the  
regulation, annex to Collective Labor Agreement and in the amount of 75%;  
- daily allowance for travels in the country, for business, in the amount of 180 ron/day;  
- the equivalent of expenses with nurseries/kindergartens/ "after school" program, not more  
than 600 Ron;  
- other advantages: the employees can rent car and equipment at the same rate as the one  
practiced by the company in relation to third parties, and the employee bears 50% of the  
invoice value; the employees receive for seniority in the company (women 30 years old,  
men 35 years old) a gift consisting of material objects (watches or other personalized  
objects);  
- if the company has positive financial results, prizes may be awarded within the limit of a  
prize fund of up to 10% of the salary fund realized monthly and cumulatively;  
- the employees' share of profit is approved by the GMS and is granted on the basis of  
criteria approved by the Board of Directors;  
* average gross earnings per company - the gain determined on the basis of salary expenses, achieved in the  
year preceding the granting  
The management of conflicts of Interest  
To avoid the occurrence of the conflict of interest, the company has set-out a series of  
deontological rules that need to be observed both by the members of the Board of Directors  
as well as by the directors of the company, in correlation with the applicable legal provisions.  
The members of the Board of Directors keep confidentiality of any facts, data or information  
they have acquired in the course of exercising their responsibilities and understand that they  
have no right to use or disclose them during or after termination of the activity. Both in the  
Rules of Organization and Operation of the Board of Directors of CONPET S.A., as well as  
the Corporate Governance Rules there are dispositions with regards to the management of  
the conflicts of interests and trading with involved persons. In practice, the members of the  
Board of Directors shall inform the Board of any conflicts of interest that have arisen or may  
arise and shall refrain from attending the discussion and voting for the adoption of a ruling  
on the matter, giving rise to the conflict of interest concerned.  
The Administrator or Director General who has interests in a particular operation, directly or  
indirectly, contrary to the interests of the company must notify the other administrators and  
the internal auditor thereof and must not take part in any deliberations concerning this  
operation. The same is the duty of the Administrator or the Director General if, in a particular  
operation, knows that the spouse, relatives or affiliates up to the fourth degree inclusively are  
interested.  
The situations in which CONPET S.A. employees may be in conflict of interest, the way of  
preventing, communicating and solving them are established through an operational  
procedure, which has been approved and disseminated in 2022, in accordance with the  
internal regulations. In practice, the employees have the obligation to refrain from resolving  
the request, making the decision or participating in making a decision and to immediately  
inform the hierarchical head directly by submitting a statement regarding the potential/real  
conflict of interest to the designated person within the competent organizational entity within  
the company. Also, in the event that a CONPET S.A. employee or another person has  
become aware of violations of the law on conflicts of interest, they may report this in good  
faith, using several communication channels that are published on the Conpet S.A. website  
in the "Conpet Public Interest Whistleblower" Section or in the "Notify the Ministry of Energy"  
Section, available on the company's website.  
119  
The company was not notified about integrity incidents related to the conflict-of-interest  
regime/ incompatibilities whose resolution was made as a result of the final remaining of an  
act of finding issued by A.N.I. -En. National Integrity Agency  
Social and Corporate Responsibility (CSR)  
The Social and Corporate Responsibility of Conpet (CSR) is integral part of the CONPET’s  
vision and strategy and the respect towards people, responsibility towards the environment  
and involvement in the community’s life are essential values and major priorities for the  
company.  
The actions that CONPET undertook in 2024 in the field of CSR were manifested both  
internally, with the aim of aligning employees with the company's values and mission, and  
externally, in the company's relationship with third parties, through involvement in the life of  
the community and supporting its development.  
Regarding the internal dimension of CSR, which includes strengthening the organizational  
culture and common values of CONPET employees, in 2024 actions were organized to  
promote people and the image of the company, among which the award of the senior  
employees (30 years for women, 35 years for men), congratulating employees who have  
retired or mentioning employees who represented the company at various internal or external  
events.  
The internal newspaper "Informația CONPET" was another communication channel through  
which employees received information about the company's main actions and activities in  
2024, sponsorships and social responsibility actions.  
A relevant action that combines organizational culture and social responsibility is represented  
by internal communications and posts on the official facebook page, which aim to promote  
culture, national and international historical milestones and, in general, all the principles we  
consider valuable to the civilized world we live in.  
The health campaign continued by publishing articles about physical and emotional health  
through the daily Press Magazine. Employees were thus informed and encouraged to  
develop a healthy lifestyle, in order to maintain the best possible balance between personal  
and professional life. At the same time, articles on the environment and green energy were  
selected in the Press Magazine, in order to cultivate a culture oriented towards environmental  
protection, energy efficiency and sustainability.  
Regarding the company's involvement in the life of the community, CONPET has chosen  
along the years voluntary actions, projects and various causes to cover as wide an area as  
possible of the community's needs.  
In 2024, CONPET organized, in collaboration with the Ploiești Blood Transfusion Center, for  
the third consecutive year, a blood donation campaign among the company's employees.  
Understanding that the need for blood is a permanent problem for hospitals in Romania and  
wanting to help people in vulnerable times, employees at the Ploiești headquarters set out to  
make a tradition of their good deeds and joined the humanitarian action organized by the  
company this year, on October 29.  
120  
Participating in ” Ora Pământului“ #EarthHour is another tradition that CONPET respects  
every year, wishing to reiterate, also symbolically, the commitment that the company has  
assumed to protect the environment, as well as the consistency describing the pursue of this  
promise. Thus, on March 23, 2024, CONPET turned off the lights for one hour (20:30 21:30)  
at its headquarters in Ploiești, once again joining the largest voluntary environmental action  
in history, now in its 18th edition. “Earth Hour” aims to draw attention to the climate problems  
affecting our planet, while initiating actions that aim to become frequent habits with a positive  
and significant impact on it.  
Every year, CONPET aims to ensure that the social responsibility actions it undertakes have  
both a positive impact on the community in which it operates, and the purpose of increasing  
employee alignment with its values and mission.  
Sponsorship  
The sponsorship activity was performed in compliance with the annual Revenues and  
Expenditure Budget, falling within the sponsorship expenses broken down by areas of  
interest.  
The sponsorship policy of the company supports both traditional projects, those that have an  
important and lasting impact on the community, as well as requests for smaller scale, which  
promote, through ideas and actions, individual performance.  
In 2024, the company sponsored the realization of major projects in the medical and health  
field. Thus, sponsorships were granted for the “dr. Constantin Andreoiu" Ploiești County  
Emergency Hospital to equip the operating room of the B.M.F. Surgery Department with high-  
performance equipment and the Florești Pneumophthisiology Hospital to continue equipping  
the new Physical Medicine and Respiratory Rehabilitation department with medical  
equipment. At the same time, we supported the implementation of the “Bucuria vindecării”  
/Joy of healing project dedicated to oncological patients undergoing treatment or in post-  
therapy monitoring and recording, and we provided support to associations active in the  
health field, with the aim of implementing individual medical projects (people affected by  
serious illnesses) to save human lives.  
We also continued to support education in Romania, by sponsoring new or traditional  
projects, such as school performance activities (Lego Academy robotics workshop,  
participation in the international debate and general culture competition International World  
Scholar’s Cup global stage), the organization in Bucharest of the fourth edition of the forum  
“Forumul Studenţilor Români de Pretutindeni”, the cultural-educational competitions  
(National Storytelling Competition with a Historical Theme, the Inter-school General Culture  
Competition for Prahova High School Students The Best).  
CONPET company supported sports activity this year as well, providing sponsorships for the  
preparation and participation of children and young people in domestic and international  
competitions in various sports (football, cycling, karting, etc.) and maintained the sponsorship  
of a prestigious Prahova cultural institution, the Ploiești Philharmonic.  
The Revenues and Expenditure Budget of CONPET S.A. for 2024 provides for sponsorship  
expenses in amount of 790,000 RON.  
During January - December 2024, within the Board of Directors meetings of CONPET S.A.  
were approved and concluded sponsorship contracts amounting to 776 thousand RON, as  
follows:  
- 306 thousand Ron - “Education, schooling and sports”;  
121  
- 320 thousand Ron - “Medical care and health”  
- 150 thousand Ron - “Other actions and activities”.  
The detailed presentation of the projects from each category of sponsorship provided for in  
the GEO no. 2/2015 can be found in the Report about sponsorships granted by Conpet S.A.  
in 2024 published on the website  
4.4.3. Executive Management  
By Resolution no. 6 dated 19.12.2023, the General Meeting of Shareholders approved the  
Performance Indicators for monitoring the performance of Conpet S.A., resulting from the  
2023-2027 Administration Plan.  
In structure, the degree of achievement of the performance indicators of the company for  
2024 reveals the following:  
(Period 01.01.-  
31.12.2024  
Degree of  
achievement  
KPIs (%)  
Crt.  
no.  
Performance indicator  
Performance objective  
MU  
Target  
Achieved  
values  
values  
Increase of the efficiency of the National Transport  
System of crude oil, rich gas, condensate and ethane  
≥6.5%  
1. Capital expenditure ratio  
%
8.3%  
127.7%  
Ensuring the capacity to pay the total debts  
≤0.25  
≥0.5  
2. General solvency (leverage)  
3. Turnover ratio of assets  
0.1  
0.6  
100%  
100%  
Ensuring the efficiency of assets management  
The achievement of a profitability of assets over the 4%  
level  
4. Return of assets (ROA)  
%
%
>4.0%  
5.8%  
100%  
Implementation of the actions set out in Development of the internal control management system  
the Program for the development of the implementation in compliance with the legal  
5
6
≥90%  
100%  
100%  
internal control management system  
requirements in force  
Duly reporting of the degree of  
achievement of the performance  
indicators of the company  
Framing within the reporting due deadlines  
100%  
%
100%  
100%  
Dividends distribution rate from the net  
profit of the financial year  
7
8
Maintaining a sustainable dividend policy  
%
≥65%  
93.9%  
YES  
100%  
100%  
The settlement of the risks  
management policy  
Efficient and effective risk management that could affect  
the achievement of the company's objectives  
YES  
YES/NO  
Table 36 - Objectives and performance indicators for monitoring the performance of Conpet  
company achieved in the period 01.01.2024 - 31.12.2024  
Strategic objectives regarding the management of the company CONPET  
Actions carried out in view of achieving the strategic objectives contained in the  
Administration Plan  
The strategic objectives contained in the company's Administration Plan for the period 2023-  
2027 are derived from the Letter of Expectations of the majority shareholder, the Romanian  
State, through the Ministry of Energy and aim to identify and implement solutions for:  
- Optimizing the activity considering the future prospects from the point of view of  
customers and transport capacities of the NTS;  
- Increasing the performance of the NTS by continuing the investment/modernization/re-  
engineering works:  
- Modernization of non-modernized active pumping stations;  
- Maintaining smart pigging programs;  
122  
 
- Replacement of pipeline sections that are unsafe in operation, to avoid technical  
breakdowns;  
- Extending the implementation of the pipeline leak detection and location system;  
- Continue to upgrade the pipeline network and storage capacities;  
- Completing the implementation of the cathodic protection system;  
- Modernization of the integrated IT system and the SCADA system;  
- Electricity production from renewable resources.  
- Ensuring effective management in human resources management:  
- The optimization of the organizational structure and the permanent adaptation of  
human resources in correlation with the requirements and the technical-economic  
realities of society, the optimal dimensioning of the need for human resources in  
relation to the real activity and development needs of society;  
- The development of the specific competencies and basic skills of the human capital.  
- Labor productivity growth;  
- Continuing efforts to identify new opportunities for growth and diversification:  
- Development of activities related to the core activity (providing storage services of  
crude oil and petroleum products, etc.) and non-related activities;  
- Continuation of steps to access European funds and other forms of non-reimbursable  
financing.  
- Development and improvement of the internal managerial control system;  
- Continuous improvement of the integrated management system (quality-environment-  
health and safety at work-energy-anti-bribery) and the railway safety management  
system, implemented and certified in CONPET S.A.;  
- Maintaining and improving risk management (identifying risks that may affect the  
achievement of objectives, establishing and implementing risk control measures);  
- Improving the monitoring and operational control of transport processes, to increase  
energy performance (measurement, monitoring and control through remote  
management) in order to improve energy efficiency to reduce specific consumption per  
ton of crude oil transported;  
- Compliance with the requirements of environmental authorizations and establishing  
appropriate measures for significant environmental aspects, limiting environmental  
impact;  
- Maintaining and observing the principles of corporate governance and the values and  
principles of integrity defined in the Code of Ethics and Integrity of CONPET S.A.;  
- Responsible and active involvement in corporate social responsibility actions.  
The strategic objectives for the period 2023-2027 are:  
- Boost efficiency and improve activity performance;  
-
-
-
-
Development of new activities, related and non-related to the core business;  
Ensuring effective management in the management of human resources;  
Selection of company directors based on criteria of professionalism and integrity;  
Ensuring modern management by implementing and maintaining risk management,  
control, ethics, integrity and corporate governance processes;  
-
Ensuring a balance between the dividend policy and that regarding the provision of the  
necessary funds for the investment programs undertaken by the company for  
development and modernization.  
123  
To the strategic objectives mentioned above, the general objectives of the organization  
established according to the requirements of the Order of the Secretary General of the  
Government no. 600/2018 regarding the approval of the Code of Internal Managerial Control  
of Public Entities and the National Anti-Corruption Strategy 2021- 2025, as well as according  
to the requirements of the reference standards for the quality-environment-energy-anti-  
bribery integrated management system and the regulations applicable to the management  
system of railway safety.  
Strategic Objective- Boosting efficiency and improvement of the activity performance  
Measure - Optimization of the operation and administrative costs  
Cost optimization is one of the basic management directions for increasing activity efficiency.  
A first action in this regard is the control of operating and administrative costs. This control  
was carried out in the two determining stages, respectively at the time of establishing the  
budget and at the time of its execution. At the stage of planning the activities for the next  
year, the resources consumed in the current year for carrying out each activity were analyzed  
and the types of expenses that can be reduced by optimizing processes were established.  
The result of this analysis in the planning stage was to cover the material price increases by  
decreasing the consumption. Through the budgeting managers, the execution of expenses  
on each cost center is monitored monthly, they are responsible for taking measures to ensure  
that the costs fall within the planned limits. Also, through the monthly presentation of the table  
of expenses, those responsible for budgeting have the opportunity to carry out periodic  
analysis and to discuss within the Steering Committee the proposals for cost efficiency  
measures.  
Another line of action to optimize costs was the efficiency of the pumping scenarios on the  
two transport subsystems, Domestic and Import, with the aim of establishing, as far as  
possible, for each transport a pumping scenario with the lowest consumption electric power.  
Measure - Making investments aimed at reducing technological consumption in the  
transport process, reducing energy consumption  
Another approach to support cost efficiency was to support and stimulate the implementation  
of investment objectives based on new technologies, with longer life, with lower electricity  
consumption and reduced maintenance costs.  
An important investment project that meets the above requirements is the implementation of  
a Tele management System for tracking energy consumption.  
By carrying out this project several benefits are obtained, among which we list the following:  
- ensures the operation and maintenance of the pipeline network in conditions of increased  
efficiency, with the reduction of operation and maintenance costs;  
- making subsequent optimizations in the configuration of own installations, based on the  
analysis of the information provided by the system.  
During 2023, the installation works of the remote management system were completed in 8  
locations, and by June 30, 2024, 6 more locations were completed, the last location being  
commissioned in July 2024.  
Other projects with operational efficiency and cost optimization impact are: the modernization  
of the pipeline network, a project aimed at reducing technological consumption, but also  
reducing energy consumption and modernizing pumping systems, with a positive effect on  
energy consumption.  
124  
At the end of July 2024, the tele management system was finalized and put into operation in  
15 locations.  
Measure  
-
Increasing the performance of the NTS by continuing the  
investment/modernization/re-engineering works  
In 2024, investment/modernization/refurbishment works were continued, primarily aimed at  
increasing the performance of the National Transport System, with the aim of achieving the  
commitments assumed through the minimum development/revamping programs, annex to  
the Concession Agreement concluded with NAMR.  
The 2024 investment program included investments aimed at improving the performance of  
the national transport network.  
The investment program related to 2024 included rehabilitation works of major transport  
pipelines and investment works for installations and related equipment to the Crude Oil  
National Transport System.  
The investment projects within CONPET target, mainly, enhancing efficiency of the transport  
activity as well as the operation, under safe conditions, of the National Transport System.  
From the modernization quota, CONPET finances investments provided in the rehabilitation,  
modernization and development programs, agreed with the National Agency for Mineral  
Resources, according to the “Petroleum concession agreement for the operation of the  
national transport system of crude oil, rich gas, condensate and ethane, including the main  
pipelines and the ancillary installations, endowments and facilities”.  
In 2024, investments amounting to 70,445 thousand RON were achieved, as compared to  
85,000 thousand RON programmed (82.9%).  
The value of the investment objectives achieved in 2024, by appurtenance of assets, as  
compared to the approved program, is as follows:  
Budget  
2024  
Achieved  
2024  
Achieved/  
Budget  
82.9%  
Investments  
Total investments, o/w:  
85,000  
70,445  
Public domain  
65,000  
20,000  
56,139  
14,306  
86.4%  
71.5%  
Operating domain  
Table 37 - 2024 Investments achieved vs program (kRon)  
The main investment objectives finalized and commissioned in 2024  
- Modernization of Potlogi pumping station;  
- Upgrade of Mislea station;  
- Modernization of Moreni pumping system;  
- Modernization of the Ochiuri Pumping System - Connection to the electrical network  
and the usage facility;  
- New PSI tank Biled  
- Upgrade Ciresu ramp;  
- System related to the tele-transmission and tele-management of the power  
consumptions in 7 locations belonging to CONPET S.A;  
- Modernization and monitoring of the cathodic protection system related to the NTS  
domestic and import in 3 locations;  
125  
- Replacement of Ø 20" Constanța - C1 pipeline - 8 sections - completed: section 3  
(A,B,D,E,F,), section 4 (A,B) and section 5 (A);  
- Smart pigging, detection of pipeline status Ø10 ¾" L1 Bărbătesti– Ploiesti West and Ø  
10¾" L2 OrlestiPloiesti (Petrobrazi);  
- Modernization of pumping station Ochiuri;  
- Replacement of Ø 20" Constanța - C1 pipeline - 8 sections - completed: section 1  
(A,B,D), section 2 (A,B), section 3 (C) and section 7;  
- Replacement of Ø 20" Constanța - C1 pipeline - 8 sections - completed: section 2  
(D,F,G), section 5 (B,C,D,E,F) , section 6 and section 8;  
- Transformation of the LDH 92 53 0850 130 -1;  
- Replacement of pipeline section Ø 6⅝ʺ Warehouse Petrom Orzoaia de Sus – Urlați  
crude oil station, about 1,600 m in length.  
The main ongoing investments on December 31, 2024:  
PUBLIC DOMAIN  
-
-
Replacement of pipeline Ø 20” Constanța - C1 - 8 sections;  
Crude oil storage Berca village;  
Modernization and monitoring of the cathodic protection system related to the domestic  
and import NTS;  
-
-
-
-
Modernization of Satchinez pumping station;  
Modernization of Slobozia crude oil station;  
New PSI tank Buffer tank Independenta;  
Installation and initial metrological verification of four measuring skids in Petrobrazi P3,  
Poiana Lacului, Videle and Otesti locations;  
-
-
Modernization of the multiplexor network;  
Rehabilitation of the pump hall C+D+E Călăreți station and Rehabilitation of the building  
related to connections 6 kV, electrical distributors 6/ 0.4 kV A+B Local Dispatch,  
electrical distributors C,D,E, Călăreți station.  
OPERATOR FIELD  
In 2024 have been achieved investments in the operator domain amounting to 14,306  
thousand RON, representing 71.5 % of the annual program, as follows:  
-
-
Rehabilitation of buildings at Headquarter 2 Workshops - Buildings C4, C5, C10, C11;  
Replacement of Ø 6" Urlați-Ploiești, crude oil pipeline network, in the area of National  
Road 1A Moara Nouă- Corlătești.  
Commissionings achieved in 2024 amounted to 85,426 thousand RON, out of which, per  
financing sources:  
-
69,744 thousand RON out of the modernization quota;  
15,682 thousand RON out of other own sources;  
-
The main investment projects started in the previous years which continue in 2024 are the  
following:  
Modernization of non-modernized active pumping stations  
Modernization of pumping stations is a significant investment project that can take place over  
a longer period of time. The first stage of pumping station modernization started in 1997 and  
ended in 2007, when 16 stations were modernized. The second stage included the partial  
modernization of 5 stations.  
The advantages obtained from the modernization of the pumping stations are the following:  
126  
-
-
-
-
-
reduced technological costs in the storage and transport process;  
minimized energy, fuel and lubricant consumptions;  
minimized operating costs and reduced operating difficulties;  
improved safety and flexibility of the system;  
reduced environmental impacts.  
In 2024, works to modernize the pumping systems of 3 stations (Potlogi, Mislea and Moreni)  
worth 21.5 million RON were completed and put into operation.  
In June 2024, the objective "Modernization of the Cireșu ramp" was completed and put into  
operation.  
In August 2024, the objective "Pumping system at the Ochiuri station" was completed and  
put into operation.  
At the same time, work was started on the pumping systems at the Sat Chinez, Slobozia,  
Constanța Sud and Berca work sites.  
The performed work aims to automate the installations in order to be included in the SCADA  
system. These works include the replacement of existing piston pumps with new pumps and  
pipe connections in pumping stations, as well as energy and automation works at existing  
installations.  
Maintaining smart pigging programs  
The purpose of the smart pigging operation is to determine the degree of wear and tear and  
to estimate when the pipes should be replaced, so that they are safe in transport.  
In order to keep the operational risk and the risks related to environmental aspects under  
control, the policy of reducing these risks - continued through the multi-year programming of  
internal inspections with intelligent pig in order to diagnose all the pipelines.  
In March 2023, the contract was signed for "Inline inspection services (expertise) of main  
crude oil transport pipelines: L1 Bărbătești - Ploiești West (Bărbătești - Orlești, Orlești -  
Poiana Lacului, Poiana Lacului Siliște, Siliște - Ploiești West) over a length of 238 km and L2  
Orlești - Ploiești - Petrobrazi (Orlești - Poiana Lacului, Poiana Lacului – Siliște, Siliște -  
Ploiești) over a length of 175 km with a value of approximately 2.11 million RON.  
On 31.07.2024 the works were finalized.  
Replacement of pipeline sections which do not present safety in operation  
Annually, during the development of the Investment Program, investment objectives are  
analyzed and prioritized for pipe rehabilitation works, respectively for the replacement of  
sections that are no longer safe to operate.  
Prioritization is mainly based on the results obtained from smart pigging operations.  
The analysis of pipeline replacement works also takes into account the information regarding  
the consents and consents of the landowners to determine if there could be difficulties in  
obtaining them.  
Historical data shows that there is a significant risk related to obtaining building permits in a  
reasonable time, which is generated by the difficulties encountered in obtaining the consent  
of the landowners to allow access to the land for the execution of the works. In order to  
mitigate the impact of this risk, it is necessary that, based on the results obtained from the  
127  
smart pigging and the level of operational risk established, a medium-term action plan  
regarding pipeline replacements should be drawn up, which would include: taking into  
account the potential risks, as well as the risks involved, the measures and actions necessary  
to mitigate or eliminate the risks and a multi-year planning of these investments.  
In 2024, the work to rehabilitate the main crude oil transport pipelines was continued and  
9.40 km of pipelines were replaced, for a total amount of 29.41 million RON.  
Ongoing execution works:  
-
Replacement of pipeline 20” Constanța county - C1 - 8 sections (approx. 13,600 linear  
meters);  
-
Safe disposal of the Ø 12" and Ø 14" Cartojani-Ploiesti pipelines at the overcrossing of  
Cricovul Dulce.  
Completed works:  
-
Replacement of pipeline section Ø 6⅝ʺ Warehouse Petrom Orzoaia de Sus – Urlați crude  
oil station, about 1,600 m in length.  
In October 2024 the reception and commissioning were performed, with total value of 1,783.5  
thousand RON.  
Design works in progress, in the stage of obtaining the Construction Permit:  
-
-
-
-
Replacement of Ø 8 ⅝” Lucăcești-Vermești crude oil transport pipeline - the section from  
Deal Măgura (Crucea Roșie) to Vermești (Vermești mine road), approx. 9 km in length;  
Section of the pipeline connection Ø 8” Moreni – Mija (Valea Neagrӑ) in L1, L2 Silişte –  
Ploieşti and pig launcher/receiver stations;  
The safe disposal of the crude oil pipelines L1 and L2 Ø 10 ¾” Siliște-Ploiești, at the  
undercrossing of Ialomita river;  
Replacement of two sections of the pipeline Ø 24" Barăganu- Brazi refinery,  
undercrossing of Leaota brook.  
Extending the implementation of the pipeline leak detection and location system  
The benefits of implementing a system to detect and locate crude oil leaks from pipelines  
consist of reducing losses in the event of breakdowns, greening costs and reducing the  
compensation that the company has to pay to the owners of the lands affected by these  
breakdowns.  
The leak detection system is currently being implemented on the Poiana Lacului– Siliște-  
Ploiesti pipeline subsystem (pilot project) and the benefits obtained post-implementation are  
being monitored to be compared with those initially estimated by the study, after which a  
decision will be made on when installing the system on the remaining operational pipelines  
of the NTS  
In order to make the decision to continue implementing the system on the rest of the  
pipelines, the results obtained will be compared with the expected ones and the cost-benefit  
analysis will be updated based on the evaluation results. In order to make the decision to  
continue the implementation of the system, it is important to take into account the results  
obtained in the process of intelligent pigging.  
128  
An analysis will be conducted to determine whether to expand the implementation of the  
pipeline leak detection and location system.  
Continue to upgrade the pipeline network and storage capacities  
In recent years, several crude oil tanks, of different capacities, as well as P.S.I. tanks have  
been built and rehabilitated. located at different work points.  
At the level of the Transport Operations and Development Maintenance departments, an  
analysis was carried out in order to establish the work points where it is appropriate to build  
tanks of smaller capacity, adapted to the quantities of crude oil transited through those work  
sites. On the occasion of the analysis, it was established that the type of reservoir built in the  
Moreni station should also be built in other working points of the company (Independenta  
Buffer Tank, Poiana Lacului Pumping Station).  
In June 2024, the P.S.I. tank at the Biled station was commissionned with a total value of  
2.59 million RON.  
Also, in 2024, construction works were started on the P.S.I. Tank Independența Buffer  
Warehouse, with works worth 4.82 million RON and a 1,500 m3 tank within the Videle Crude  
Oil Pumping Station, which is currently being designed.  
In August 2024, the execution works for "Replacement of manifolds and valves at the  
CONPET S.A. work site - OIL TERMINAL Constanța warehouse" began with a value of 18.34  
million RON.  
Completion of the implementation of the cathodic protection system  
Modernization and monitoring of the cathodic protection system for the crude oil transport  
system via pipeline aims at slowing down or even stop the corrosion process occurring at the  
surface of metal pipes underground with effect in:  
-
reducing the maintenance costs associated with both the metal losses and  
decommissioning of installations;  
-
-
-
increasing safety in the operation of the pipelines;  
avoiding environmental contamination with corrosion/transported product  
reducing the consumption of electricity.  
CONPET is running an extensive program to modernize the cathodic protection system of  
pipes and tanks, which started in 2017 and continues, being expected to be completed in  
2024.  
In the first stage, a number of 53 SPCs were created and put into operation by the end of  
2019.  
In the second stage, a number of 16 SPCs were created and put into operation by the end  
of 2020.  
In the ongoing third stage, out of a total of 31 SPCs (the contract with 2 SPCs was added  
and one SPC was abandoned) a number of 24 SPCs were made and put into operation.  
Of the other 7 SPCs, 3 SPCs have been put into operation, execution works are underway  
at the Ciorani location, and for 3 locations (Ana Maria Pop, Gura Vitioarei, Movila Vulpii 2),  
construction permits are in the process of being obtained. Due to problems in obtaining  
construction permits, the completion date for the works has been extended until October  
2025.  
Modernization of the integrated IT system and the SCADA system  
129  
Investments objective Modernization of SCADA System includes:  
Expansion of SCADA monitoring in 4 rail ramps and hard and soft upgrade of the  
data transmission and automation system in 5 locations of the SCADA system  
After the implementation of this project, the real-time monitoring through the SCADA system  
of the process data (pressure, flow, level and pigging crossing sensors) will be expanded in  
four railway ramps, and by replacing the equipment and updating software in four work points  
eliminates hardware and software bottlenecks and delays caused by incompatibility between  
old and new equipment. The benefits obtained by extending the monitoring through SCADA  
consist in: reducing the time and costs for interventions caused by failures; reducing  
maintenance costs; increased cyber security in accordance with European Directives;  
"remote" diagnosis and intervention.  
In 2023, the design and execution contract were concluded and the design was completed.  
In December 2024 the reception and the commissioning were performed, with a total value  
of 1.94 million RON;  
Design, execution, installation and initial metrological verification of four measuring  
skids in Petrobrazi P3, Poiana Lacului, Videle and Otești locations  
After the implementation of this project, the fiscal and unitary metering of the crude oil  
pumped to the Petrobrazi refinery will be allowed; increasing the accuracy of fiscal  
measurement of skids in Poiana Lacului, Videle and Otești; significant reduction of  
maintenance costs and times; increasing the quality of the sampling process for laboratory  
determinations; online tracking of pumped quantities.  
The project is in progress. In 2023 the design stage was finalized.  
From the point of view of the manufacturing process, part of the execution phase, in  
accordance with the contract and addendum no. 1, the following were completed by  
30.06.2024:  
-
-
-
FAT Mechanical (Hydro + NDT) piping, filters, degasser- 100% for the Videle, Otești  
and Poiana Lacului locations;  
FAT Instrumentation (Cabinets) - 100% for the Videle, Otești and Poiana Lacului  
locations;  
Material procurement 100 % Petrobrazi P3, 100% Videle, 100% Otești, 100% Poiana  
Lacului.  
Current status of the work:  
-
The assemblies related to the Videle and Otești locations are positioned in the locations;  
work is underway to connect them to the technological pipelines.  
The term for completion of the work is October 2025.  
Update of hardware and software related to SCADA workstations inside Central  
Dispatch and Local Dispatch Centers  
From the point of view of cyber security, reliability of existing equipment, as well as  
compatibility between the operating systems and different software used for the safe  
operation of the crude oil transportation network through pipelines, it is necessary that these  
systems be replaced with tested systems of the latest generation. The project on upgrading  
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hardware and software in SCADA workstations in the central dispatch center and in local  
dispatch centers is proposed in the investment program in the period 2025- 2027.  
Objective Integrated information system modernization”  
In order to implement the project Modernization of the integrated information system, an  
analysis was carried out in order to reconfigure the business processes and the ERP system  
so as to meet the specifics of the activity and the requirements of the users within Conpet.  
The analysis was carried out by external specialists, who also drew up the Scope of work.  
On the date of the report, the procedure for acquiring licenses and developing the ERP  
software that will allow integrated management of processes and operations is started.  
The tender for the award of the contract took place in August 2024, and at the beginning of  
October 2024, following the evaluation, it was found that the submitted offers were non-  
compliant, and the tender was canceled.  
The tender procedure will be resumed in 2025 after the approval of the Budget by the OGMS.  
Objective “Modernization of the telecommunications system”  
The implementation of this project aims to modernize the multiplexer system, by replacing  
the NPT equipment produced by the Ribbon company. The work consists of: replacement of  
hardware equipment in 72 Conpet work points; software configuration of newly installed  
equipment and system management platform.  
In June 2024, the contract with the company that will carry out the design and execution of  
the works was concluded.  
At the end of September 2024, the design phase was completed and the phase of equipment  
and materials procurement began.  
On 31.12.2024 the degree of achievement was 32%. The equipment in 27 CONPET work  
points was replaced and software configured.  
Objective Radio relay system modernization”  
The implementation of the project involves the modernization of the radio relay system with  
a microwave IP system consisting of 51 split-type microwave radio relay links in 7GHz,  
15GHz and 23GHz, over a distance of approximately 800 km within the own  
telecommunications system currently operated within CONPET S.A..  
The contract for the execution of the system was signed at the end of June.  
At the end of December 2024, the design phase was finalized and the procurement phase  
began.  
Strategic objective- Development of new activities, related and non related to the core  
business  
Measure - Electricity production from renewable resources  
In the third quarter of 2023, the commissioning of the works for, Realization of an electricity  
production system (of a photovoltaic plant) with photovoltaic panels within the premises of  
the Administrative Headquarters 2 CONPET S.A. was carried out, an objective that is  
currently working successfully.  
Similar to the project already implemented, in June 2024, CONPET S.A. started the actions  
to contract a company to deal with the following projects:  
131  
- site analysis, support studies, design and execution for an electricity production system  
with photovoltaic panels within the Crude Oil Automated Station Constanta Sud;  
- - site analysis, support studies, design and execution for an electricity production system  
with photovoltaic panels within the Crude Oil Automated Station Calareti - CONPET S.A.  
Ploiesti;  
In August 2024, contracts were signed for the following projects:  
1. Site analysis, support studies, design and execution for an electricity production  
system with photovoltaic panels within the Crude Oil Automated Station Calareti - CONPET  
S.A. Ploiesti, with a capacity of 60 kWp.;  
2. Site analysis, support studies, design and execution for an electricity production  
system with photovoltaic panels within the premises of the Constanta Sud Oil Plant -  
CONPET S.A., with a capacity of 60.48 kWp.  
The locations were handed over according to the minutes, for the necessary analyses to be  
carried out. Currently, stage I is being carried out according to the specifications, both for the  
Țiței Constanța Sud automated station and for Călăreți automated crude oil station.  
Measure - Monitoring of the operational programs and priority axis with a view to  
accessing European Funds and other non-refundable financing instruments  
CONPET continued its efforts to identify funding opportunities from European funds,  
monitoring operational programs and priority axis that may target possible access to  
structural funds.  
In the first quarter of 2024, the project "Elaboration of Opportunity Analysis and Feasibility  
Studies for the implementation of photovoltaic parks in five locations of CONPET S.A." was  
approved.  
Following the carried out analysis, it was established that there are conditions regarding the  
possibility of CONPET S.A. to apply for non-reimbursable funds, because CONPET falls into  
the category of large enterprises and has the core business transport of crude oil, condensate  
and rich gas via pipelines and by rail - an activity not excluded from notification according to  
the E.U Regulation No. 651/2014 declaring certain categories of aid compatible with the  
internal market and the Treaty on the Functioning of the European Union.  
In 2024, the financing programs were monitored and analyzed through different mechanisms,  
which could target the modernization/refurbishment/development of the National Transport  
System. Also, axes/programs/grant financing schemes were monitored and analyzed in order  
to identify the possibility of developing the main activity carried out by CONPET S.A.  
Strategic Objective - Ensuring effective management in the management of human  
resources  
The measure: The optimization of the organizational structure and the permanent  
adaptation of human resources in correlation with the requirements and the technical-  
economic realities of society, the optimum dimensioning of the need for human  
resources in relation to the real activity and development needs of the company in  
view of enhancing work productivity;  
The human resources policy had in mind:  
- Permanently ensuring a balance between the need for human resources and the  
technical-economic and administrative needs of the company;  
132  
- Anticipation of possible fluctuations in staff deficit or surplus;  
- Identifying and removing the possible restrictive limits of the available human resources  
which, by their nature, could affect the performance of the activity;  
- Optimizing employee costs through efficient use of working time;  
- Establish staff tasks and responsibilities so that management has all the necessary levers  
to achieve the assumed objectives and performance indicators;  
- The allocation of appropriate human resources for the execution of the operations and  
the provision of the necessary technical skills in the various stages of these operations;  
- The distribution of tasks so that each structure has specific responsibilities and does not  
perform any of the tasks corresponding to another structure.  
Particular attention was paid to the process of continuous dimensioning of the resources  
necessary to achieve the established objectives, by applying managerial measures in order  
to reduce expenses, which achieves, in addition to the economic effects, the optimization  
and adaptation of the functional structures in accordance with the current needs of the  
company, by permanently ensuring a balance between the number of personnel and the real  
technical-economic and administrative needs of the company.  
Continuous monitoring and analysis are carried out for:  
- Identifying positions that can be consolidated or eliminated for the purpose of their design  
or redesign, by clearly understanding the responsibilities and expectations for each  
position, the role, position, duties and functional links between them.  
- The continuous sizing of the human resources requirement according to the real needs  
of  
the  
activity  
and  
development  
of  
the  
company,  
considering  
investment/modernization/re-engineering projects, the development of activities related  
to the basic activity and non-related or other factors such as: the frequency of pumping,  
the volume of transported quantities, the change in legislation, the seasonality of some  
activities, etc.  
- Optimizing the organizational structure to facilitate workflows, improving communication  
and maximizing productivity, in accordance with the real activity needs and development  
projects of the company, as well as updating the Organization and Operation Regulation  
in accordance with the organizational structure.  
- The redistribution of the positions/employees - to ensure the continuity of the work  
process or to cover a real new need arising because of the increase/decrease in the  
volume of activity, as well as the most efficient use of staff.  
Following this analysis process, 56 positions were identified that are no longer needed.  
Therefore, the Board of Directors approved the abolition of 29 positions starting with  
01.03.2024, respectively 27 positions starting with 01.08.2024 in order to streamline work  
and maximize the use of human and financial resources.  
The abolition of the 56 positions resulted in the individual dismissal of 56 employees,  
occupants of those positions, for reasons not related to their person. The executive  
management has taken the necessary steps so that the process of individual dismissal of  
employees is carried out in accordance with the legal regulations in force and in compliance  
with the provisions of the Collective Labor Agreement of CONPET S.A..  
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The measure: The ongoing development of the specific competencies and basic skills  
of the human capital  
In order to maintain and/or develop specific skills and basic abilities of the human capital, the  
training activities are carried out on an ongoing and planned basis, based on the professional  
training and authorization programs of the company, following the identification and  
prioritization of the training needs of CONPET S.A. personnel.  
Training of company personnel is achieved mainly through participation in external courses,  
organized in collaboration with certified trainers for all fields of activity within the company.  
Also, training is conducted internally by trainers and/or experts of the company, with a good  
knowledge and experience relevant to the activity of the company. They support professional  
training sessions and training courses with the aim of updating job-specific knowledge and  
skills, as well as examining or checking the employees participating in the respective  
sessions.  
Through the trainers within the company, both receivers of fluid products and employees with  
operating duties in the field of micro-SCADA can be trained/retrained/qualified internally.  
In 2024, 3,609 participants in the following types of training/professional authorization were  
registered:  
- 111 Various fields authorizations (specific per activity);  
- 372 rail permits;  
- 371 professional training courses;  
- 428 internal authorizations;  
- 2,327 Qualifications/internal authorizations.  
Strategic Objective- Selection of the company directors based on criteria of  
professionalism and integrity  
The selection procedure of directors with a mandate contract was carried out in accordance  
with the provisions of GEO no. 109/2011 on the corporate governance of public enterprises  
based on criteria regarding training and professional experience and those of integrity.  
On 19.10.2023, the company CONPET S.A. sent to the Bucharest Stock Exchange and to  
the Financial Supervisory Authority current report no. 41/2023 regarding the appointment of  
directors with a mandate contract (director general, deputy director general and economic  
director).  
Following the progress and completion of the recruitment and selection procedure, on  
12.01.2024 CONPET S.A. submitted to the Bucharest Stock Exchange and the Financial  
Supervisory Authority the current report no. 3/2024 on the appointment of the Deputy Director  
General 3.  
At the same time, these reports were also posted on the Conpet website at  
https://www.conpet.ro/en/investors-relation/reports/current-reports/  
Directors with mandate contracts have the powers laid down in the Articles of Incorporation  
and in the contracts of mandate, supplemented by the applicable legal provisions.  
Strategic objective - Ensuring modern management by implementing and maintaining  
risk management, control, ethics, integrity and corporate governance processes  
134  
The measure: Maintaining and observing the principles of corporate governance and  
the values and principles of integrity defined in the Code of Ethics and Integrity of  
CONPET S.A.  
Through the way it conducts its processes, CONPET S.A. complies with all applicable legal  
requirements and responds to all the requirements of the relevant stakeholders, and through  
the projects and social responsibility actions carried out, it provides financial support for the  
community, constantly getting involved in humanitarian actions, education, art and culture,  
sports and environmental protection.  
Taking into account the fact that Conpet S.A. has important responsibilities in a field of  
national, regional and local interest, being declared of strategic interest, maintaining the  
company's reputation is a priority for the administrators and management of Conpet S.A..  
They must maintain the company's reputation as a trusted partner in all relationships and  
with  
all  
relevant  
stakeholders  
with  
whom  
they  
come  
into  
contact.  
The management of privileged information was carried out ensuring equal treatment for all  
the company's shareholders.  
Transactions with related parties represent another important aspect related to ethics, and  
within CONPET S.A., internal regulations have been adopted regarding both these and the  
management of conflicts of interest.  
The elements of corporate governance that have been permanently monitored are:  
1) The way in which, at the level of Conpet S.A. the principles and recommendations of the  
Corporate Governance Code are implemented and respected;  
2) Compliance with financial and corporate reporting deadlines to authorities and institutions  
with an impact on the company's activity;  
3) Efficiency of the risk management system and internal managerial control;  
4) Respecting the principle of equal treatment towards all stakeholders.  
The list of people who have access to privileged information is drawn up in accordance with  
the legal provisions in force regarding issuers of financial instruments and market operations.  
This list is updated whenever changes occur in relation to the inside information and the  
people who have access to it.  
Priority is also given to respecting the rights and fair treatment of shareholders, as well as  
the rights and interests of stakeholders.  
In 2024, CONPET S.A. continued the process of implementing good corporate governance  
practices.  
CONPET S.A. Pays particular attention to corporate governance, analyzing the level of  
compliance with the provisions of the new Corporate Governance Code issued by the  
Bucharest Stock Exchange that came into force on January 4th, 2016. CONPET S.A. annually  
prepares a Declaration on compliance with the provisions of the Corporate Governance Code  
issued by the Bucharest Stock Exchange, a statement that can be found in the Annual Report  
of the Directors for 2024.  
The Corporate Governance Regulation of Conpet is available on the webpage of the  
company athttps://www.conpet.ro/en/corporate-governance/corporate-governance-rules/  
135  
As a company listed on the Bucharest Stock Exchange, CONPET fully complies with its  
reporting obligations, preparing and submitting periodic and current reports in accordance  
with capital market legislation.  
In accordance with the legal provisions, CONPET S.A. has announced the financial  
communication calendar for 2024. At the same time, taking into account the principles and  
good practices in corporate governance, CONPET, in 2024, organized conference calls with  
financial analysts in the capital market, in order to analyze the company's periodic reports.  
The presentation materials prepared on the events mentioned above have been published  
on the company’s website.  
Particular importance has been given to the relationship with shareholders and investors, by  
showing increased transparency. The company’s representatives answered positive to all  
the participants to the capital market. During the time subject to analysis, CONPET took part  
in events organized in the capital market sector, showing openness towards both institutional  
and individual investors.  
The company has also provided  
a
contact number and email address  
(infoinvestitori@conpet.ro), through which investors can clarify certain aspects or ask various  
questions, thus coming into direct contact with the company's investor relations team.  
The evolution of CONPET S.A. share is monitored by the research departments of the major  
financial investment services companies from the Romanian capital market.  
Furthermore, the entity that manages the relationship with the investors maintains a  
permanent connection with all financial analysts in the capital market.  
CONPET S.A. undertook during 2024 a series of actions regarding corporate governance  
that mainly focused on the following aspects:  
- The payment of dividends for the 2023 financial year was carried out in compliance with  
the legislation in force applicable to issuers, based on the documents published on the  
company's website;  
- In accordance with the provisions of the A.S.F. Regulation no. 5/2018, CONPET S.A. has  
submitted current, periodic and annual reports to the B.V.B. and A.S.F. The submitted  
reports are posted bilingually (Romanian and English) on the website of CONPET.  
- CONPET S.A. organized 4 conference calls to present the financial results, according to  
the financial calendar announced at the beginning of the year. They provide the company  
with a platform to connect with stakeholders, strengthen its brand image, and increase  
investor confidence by demonstrating their commitment to transparency, accountability,  
and ethical business practices;  
-
Within CONPET S.A. there is an entity dedicated to investor relations, which is an  
essential part of corporate communication and management that deals with maintaining  
and building strong relationships between a company and its various stakeholders,  
especially its investors;  
- On the CONPET S.A. website there is a corporate governance section, which also  
includes a subsection on investor relations. There can be found information on the shares  
of CONPET S.A. (trading, dividends, regulations on shareholders' rights), market  
releases, information on the company's financial statements, quarterly presentations of  
the company from a financial point of view, analysis reports prepared by financial  
analysts, information on the General Meetings of Shareholders (convening notices and  
136  
related materials, draft decisions of the General Meeting of Shareholders, forms of  
special and general powers of attorney, postal ballot papers, both for legal entities and  
for individuals, as well as the decisions of the General Meeting of Shareholders with the  
results of the votes). CONPET S.A. ensures the publication of the Resolutions of the  
General Meetings of Shareholders, within a maximum of 24 hours from the date of the  
meeting, on the Company's website.  
The section dedicated to Corporate Governance on the company's website contains the  
main corporate regulations existing at the level of the Company: The Articles of  
Incorporation, the Corporate Governance Regulations, the regulations of the Board of  
Directors and Consultative Committees, the Code of Ethics.  
- The Company ensures the communication of the current reports and the periodic  
financial reports (quarterly, half-yearly and annual) to the B.V.B. and A.S.F. and their  
publication on the Company's website, accompanied by the Reports of the related auditor  
when applicable;  
- The presentations made by CONPET S.A. intended for investors when the company's  
main financial events, in accordance with the financial calendar, are displayed on the  
Company's website.  
The measure: Development and improvement of the internal managerial control  
system  
The company CONPET S.A., defined as a public entity in accordance with the provisions of  
the Order of the Secretary General of the Government no. 600/2018, applies the Code of  
Internal Management Control of Public Entities, approved by the aforementioned regulation.  
CONPET S.A. does annual self-assessments of the degree of implementation of the internal  
control management standards and reports in accordance with the legal requirements.  
The continuous development of the internal management control system is a priority of the  
management team, through the efficient and effective implementation of all actions in the  
Development Program of the internal managerial control system, elaborated and updated  
annually by the Monitoring Commission.  
The development program of the internal control management system of CONPET SA for  
2023 has been approved by the Director General. The actions included in the program, which  
had a permanent term or a term due in 2024, were completed.  
In 2024, the Commission for monitoring the internal control management system met ten  
times. The conduct of the meetings of the Monitoring Committee is recorded in the minutes  
of the meetings.  
The measure: Maintaining and improving risk management (identifying risks that may  
affect the achievement of objectives, establishing and implementing risk control  
measures)  
Efficient and effective risk management is very important to ensure the long-term viability  
and success of the company.  
During 2024, the risk identification and assessment process was implemented, through  
rigorous documentation and consistent application of the provisions of the "Risk  
Management" process documents.  
137  
The risks that have the potential to affect the achievement of the set objectives have been  
identified, assessed and prioritized. The significant risks are documented in the risk register  
of CONPET S.A. for 2024, and the control measures, the responsible persons and the  
implementation deadlines were included in the Annual Plan for implementing the control  
measures for the significant risks at the level of CONPET S.A. 2024.  
According to the document "Risk Profile and Risk Tolerance Limit" for 2024, the risk tolerance  
limit at CONPET S.A. level for 2024 is maximum exposure 12.  
The risks in the Risk register of CONPET S.A. for 2024 are within the approved tolerance  
limit.  
Risk management is maintained as an essential component in prioritizing actions and  
investments.  
The management of corruption-specific risks and vulnerabilities aims to reduce the likelihood  
of corruption occurring.  
The "Corruption Risk Registry (including bribery)" includes moderate risks (for which  
prevention/control measures are established) and minor risks (which do not require the  
establishment of measures). No high risks were identified that required urgent measures.  
The "Corruption Risk Registry (including bribery)" is updated annually, as well as in the event  
of the identification of new corruption/bribery risks, respectively information that may change  
the level of exposure or affect the effectiveness of the prevention/control activity.  
The anti-bribery management system is maintained, operational and effective, providing top-  
level management and the management body with the assurance that reasonable measures  
are in place to prevent, prevent and, detection and fight against bribery within CONPET S.A.  
Establishing the "Risk Management Policy" is one of the company's performance indicators,  
included in the Management Plan for the period 2023 - 2027.  
The executive management developed the "Risk Management Policy", through which the  
company's top management commits to:  
- Develop a risk-based approach in all its processes and decisions and encourage  
immediate reporting of any new risks identified by any employee;  
- Establish, maintain and document appropriate risk assessment methods, plan and  
monitor significant risk control measures.  
- To allocate necessary resources for risk management, namely resources for staff  
training/instruction/awareness and resources for implementing approved measures to  
address risks;  
- Establish clear responsibilities of personnel involved in risk management;  
- To systematically report relevant risk management data to stakeholders.  
The document "Risk Management Policy" signed by the Director General and the Deputy  
Director General was presented to the Board of Directors of CONPET S.A. Ploiești, for  
approval, with Report no. 38818/ 09.10.2024.  
The measure: Continuous improvement of the integrated management system  
(quality-environment-health and safety at work-energy-anti-bribery) and the railway  
safety management system, implemented and certified in CONPET S.A.  
138  
Continuous improvement of the integrated management system involves a series of actions  
such as periodic assessment of its compliance and effectiveness through internal and  
external audits, evaluation of the SMI performance within the annual management review  
and through feedback from stakeholders.  
Following these evaluations, opportunities for improvement were identified and steps were  
taken to improve the effectiveness of the system.  
The internal audit of the integrated qualityenvironmentoccupational health and safety  
managementenergyanti-bribery system and the railway safety management system shall  
provide information regarding the compliance with the requirements of the references and  
applicable legal requirements. Internal audits are also aimed at assessing the effectiveness  
and continuous improvement of the implemented management systems.  
The internal audits were conducted in accordance with the approved program for the year  
2024 and the audit criteria established in the audit plans. The results were communicated to  
the auditees by distributing Audit Reports, to which were attached the Non-Conformity  
Reports, observations and opportunities for improvement identified during the audits.  
The management of the company provides resources for the proper conduct of internal audit,  
mandatory requirement of reference standards SR EN ISO 9001:2015, SR EN ISO  
14001:2015, SR EN ISO 45001:2023, SR EN ISO 50001:2019 and SR ISO 37001:2017, as  
well as railway safety regulations.  
In May 2024, Management Review meeting No. 32 took place, during which several actions  
were established to improve the management system.  
The status of the actions is monitored according to the provisions of the process flow diagram  
„Analysis carried out by management” in force.  
All actions were implemented by 31.12.2024.  
During June 5-7, 2024, the external surveillance audit for the anti-bribery management  
system, implemented and certified according to the requirements of ISO 37001:2016, was  
carried out by the certification body SRAC CERT.  
Following the external audit, no non-conformities or observations were identified. Two areas  
for improvement were formulated, namely:  
- The organization must determine whether climate change is a relevant issue in its  
context.  
- The organization must determine whether relevant stakeholders may have requirements  
related to climate change.  
On 30.09.2024, the actions related to the two areas of improvement were implemented as  
follows:  
- The Integrated Management System Manual was revised to include reference to climate  
change aspects relevant to the CONPET S.A. organization. The revised Manual was  
approved on 29.08.2024.  
- The Stakeholder Registry has been revised to include climate change requirements. The  
document was approved by the Director General and registered with No. 36923/  
27.09.2024.  
139  
Following the external surveillance audit, the SRAC CERT certification body recommended  
maintaining the compliance certificate no. 28/13.07.2022 for the anti-bribery management  
system implemented in the CONPET S.A. organization.  
In September 16-20, 2024, the external surveillance audit took place for the management  
systems related to quality, environment, health and safety at work, energy, according to the  
requirements of ISO 9001:2015, ISO 14001:2015, ISO 45001:2018 and ISO 50001:2018,  
audit performed by the BUREAU VERITAS certification body.  
Following the external audit, no non-conformities or observations were identified.  
The audit team of the BUREAU VERITAS body concluded that the organization CONPET  
S.A. has established and maintained an integrated management system in accordance with  
the requirements of the reference standards and has demonstrated its ability to meet the  
requirements according to the policy, objectives and scope of the organization. The  
certification body BUREAU VERITAS recommended maintaining the certificates for quality,  
environment, occupational health and safety and energy management systems, issued for  
the organization CONPET S.A.  
The railway safety management system is being implemented and maintained within  
CONPET S.A. in accordance with the national legal requirements on railway safety, in  
compliance with the national legal requirements on rail safety and the reference European  
directives. The field of application of this system includes railway ramps where CONPET  
carries out railway shunting, for which the company holds the “License for the performance  
of rail transport services (railway shunting)”, granted by the Romanian Railway Authority  
(A.F.E.R.).  
For the railway ramps where CONPET S.A. performs railway maneuvering, the Romanian  
Railway Safety Authority (ASFR) has issued the Single Safety Certificate which is valid until  
September 2025.  
The measure: Compliance with the requirements of environmental authorizations and  
establishing appropriate measures for significant environmental aspects, limiting  
environmental impact;  
CONPET activity is regulated according to the provisions of the GEO. no. 195/2005 on  
environmental protection and according to the provisions of the Water Law no. 107/2005,  
both with subsequent additions and amendments. They establish the legal framework for the  
prevention of damage to the geological environment, through accidental pollution, and for the  
management of natural resources.  
Compliance with the requirements of environmental authorizations and establishing  
appropriate measures for significant environmental aspects are key components for the  
company’s strategy regarding the limitation of environmental impact. As part of the  
company's commitment to sustainable development, compliance with environmental  
legislation is not only a legal obligation, but also an ethical responsibility.  
Fulfilling the requirements of environmental authorizations implies, first, the implementation  
of technical measures to prevent damage to the geological environment.  
To further strengthen the company's commitment to protecting the environment, action was  
taken to:  
- Improve compliance with best practices for sustainability;  
140  
- Strengthen internal pollution prevention policy, including through an employee training  
program;  
- Continuing investments in clean and energy efficient technologies;  
- Periodic monitoring and evaluation of environmental performance to identify  
opportunities for continuous improvement.  
The measure: Elements of ethics and integrity  
The Code of Ethics and Integrity of CONPET S.A. was developed in 2012 and last revised  
in April 2024, in accordance with the provisions of the National Anti-corruption Strategy  
(S.N.A.), with the requirements of the ISO 37001 Standard (implemented and certified within  
the organization in the summer of 2022) and the provisions of other legislative regulations  
specific to integrity. The management of CONPET S.A. ensured that the measures below  
are still maintained or implemented as follows:  
- the values, principles and norms of behavior established by the Code should be  
periodically reminded to the organization so that it is continuously promoted among the  
employees;  
- ensuring the necessary levers regarding compliance with the Code that do not allow  
violations of the principles of ethics and integrity, at any level in the company, with  
reference to management, employees, legality, abuses: campaign to promote the ethics  
and integrity advisor with the aim of strengthening the status and mandate to him;  
campaign to promote the communication channel regarding the whistle blower in the  
public interest;  
- the presentation in the organization of confirmed cases of violations of ethical behavior  
to emphasize the importance of respecting ethical behavior;  
- periodic monitoring of the application of the provisions of the Code;  
- revising and disseminating the Code, with the approval of the internal auditor and within  
the term stipulated in the specific legislation.  
Through the Integrity Plan of CONPET S.A. adopted in the coordinates of S.N.A./National  
Anti-corruption Strategy 2021 - 2025 in 2022 and revised in February 2024 and by the  
Declaration on assuming the organizational integrity agenda adopted since 2022, including  
objectives and measures to act as remedies for the risks and vulnerabilities to corruption  
identified within society, the management of Conpet S. A. has provided all material, financial  
and human resources, so that all measures to prevent corruption be implemented.  
The Integrity Plan contains a varied set of measures aimed at achieving the following specific  
objectives:  
- implementation of integrity measures in the organization in the coordinates of S.N.A.  
2021-2025;  
- streamlining preventive anti-corruption measures by remedying legislative gaps and  
inconsistencies, as well as ensuring their effective implementation;  
- improving the ability to manage management failure by correlating the tools that have an  
impact on the early identification of institutional risks and vulnerabilities by strengthening  
the own integrity plan, as a managerial tool for promoting integrity in the organization;  
- increasing integrity, reducing vulnerabilities and corruption risks by: respecting and  
applying integrity standards; avoiding the conflict of interests and incompatibilities, as  
well as for the consideration of the public interest, in accordance with the observance of  
the principle of transparency of the decision-making process unrestricted to information  
141  
of public interest; publication in open format of economic indicators, as well as other  
information of public interest.  
In this context and considering the efficiency achieved by implementing the measures up to  
this point in the Integrity Plan, the quarterly and annual evaluation of the implementation of  
the measures provided for in the approved Integrity Plan and its adaptation to newly emerging  
risks and vulnerabilities was a priority management in order to achieve the objectives in the  
field of anti-corruption.  
The registry of corruption risks was developed in 2018 and revised for the last time in  
December 2024. The identification, evaluation and periodic monitoring of corruption risks, as  
well as the establishment and implementation of prevention and/or control measures are  
carried out in accordance with the methodology reflected internally by operational procedure  
and must be maintained, be a priority in prevention and combat corruption.  
In order to strengthen this risk identification system, as well as to promote institutional  
integrity, Conpet S.A. obtained the ISO 37001 certificate in 2022. In 2023 and 2024,  
respectively, the certificate attesting compliance with the anti-bribery management system  
was maintained. Reasonable measures are taken at the company level to also identify  
bribery risks and to control/prevent their occurrence. The corruption risk assessment is  
communicated and documented, and any changes that occur lead to a reassessment. The  
anti-bribery compliance function (as per ISO ISO37001:2017) has accountability and  
authority to report to the management body Board of Directors and management at the  
highest level, in respect of the performance of the anti-bribery management system.  
Increasing the level of education and awareness of employees achieved through training and  
professional training actions at the company level is the most accessible way for employees  
to determine behavioral change, thus limiting deviations from anti-corruption norms, internal  
conflicts, the use of company resources in purposes other than the interests of the company.  
The management of the company has created a functional and transparent organizational  
framework of integrity, which contributes to the employees' sense of security, to their  
identification with the company's values.  
The measure: Communication with shareholders and other stakeholders  
The management ensured full compliance with the reporting obligations related to the capital  
market, drawing up and transmitting the periodic, current and communicated reports in  
accordance with the legislative provisions in force. The company also published and  
complied with the annual financial reporting calendar.  
For good communication and transparent information to all interested parties, the public  
information provided by the legislation was published on the website of CONPET S.A.  
Strategic Objective - Ensuring a balance between the dividend policy and that  
regarding the provision of the necessary funds for the investment programs  
undertaken by the company for development and modernization  
The dividend policy of the company CONPET S.A. was approved by the Board of Directors  
in January 2021.  
The net profit distribution decisions concern the company’s options between partial or full  
reinvestment of the net profit and/or distribution in the form of dividends.  
142  
The dividends’ distribution ratio, set out in the dividend policy, which the Board of Directors  
will consider in the formulation of the proposal to the General Meeting of Shareholders of  
CONPET S.A. will be between 85 % and 100 % of the net accounting profit.  
The gross dividend per share is the share of the company’s net profit that is calculated and  
paid to shareholders for each share held.  
The Ordinary General Meeting of Shareholders dated 25.04.2024 approved the distribution  
in the form of dividends of the amount of 57,891,137 RON from the net profit and of the  
amount of 862,397 RON from the reported result, representing surplus from revaluation  
reserves.  
Executive Management  
Between 01.01.2024 - 31.12.2024, the executive management had the following  
composition:  
The Directors with mandate contracts:  
Name  
Surname  
and  
Position  
Observations  
4-year mandate contract, starting from 20.10.2023 until  
19.10.2027 (inclusive of), according to BoD Decision no.  
31/19.10.2023. (Art.1, Letter a).  
Director  
General  
Eng.  
Dorin  
TUDORA  
Jurist  
DUMITRACHE  
Mihaela  
Deputy  
Director  
General  
4-year mandate contract, starting from 20.10.2023 until  
19.10.2027 (inclusive of), according to BoD Decision no.  
31/19.10.2023. (Art.1, letter b.).  
- Anamaria  
4-year mandate contract, starting from 20.10.2023 until  
19.10.2027 (inclusive of), according to BoD Decision no.  
31/19.10.2023. (Art.1, letter c.).  
Economic  
Director  
Econ. TOADER  
Sanda  
As per Decision of the Director General no.  
271/13.05.2022, indefinite period.  
Deputy  
Eng.  
Director  
General 3  
NECȘULESCU  
Radu Florentin  
The Mandate contract starting from 15.01.2024 until  
19.10.2027 (inclusive of), according to BoD Decision no.  
1/12.01.2024. (Art.1, Letter a).  
Directors, Heads of Units, Chief Engineer:  
Position  
Name and Surname  
Jurist LUPEA Ioana Mădălina  
As per Decision of Director General no. 619/06.11.2023  
has been appointed in the position of Deputy Director  
General 2 for a definite period, starting 07.11.2023, until  
the termination of the mandate contract of the Director  
General no. 37110/19.10.2023, but no later than  
06.11.2026 (inclusive of).  
Deputy Director General 2  
Head of Transport Operations  
Unit  
Eng. STOICA Narcis Florin  
Eng. BUZATU Dan  
Head  
of  
Maintenance  
Development Unit  
143  
Head of Communication and  
Corporate Governance Unit  
Head of the HSE Unit  
Political science graduate PATRICHI Bianca Maria  
Eng. MARUSSI Mădălina Mihaela  
Head of Commercial Unit  
Development-Maintenance  
Chief Engineer  
Jurist MANOLACHE Dan  
Eng. CÎRLAN Florentina Anca  
Table 38 - Executive Management  
Disputes or administrative proceedings  
In the last 5 years there have been no disputes or administrative proceedings involving the  
management of CONPET.  
5. NON-FINANCIAL STATEMENT FOR THE YEAR 2024  
5.1 Other non-financial information  
The non-financial information through which the company's management wishes to  
transparently communicate to business partners, employees, investors, the community in  
general and any other interested parties the actions taken and the progress achieved by  
CONPET S.A. in terms of ensuring and continuously improving the quality of services  
provided, environmental protection, occupational health and safety, personnel and social  
issues, preventing human rights abuses, business ethics and integrity and preventing and  
combating corruption.  
Company’s profile  
CONPET SA is the operator of crude oil, rich gas, condensate and ethane National Transport  
System (NTS). As presented largely in the Report of the Administrators, CONPET SA  
provides transport services to its customers through both the National Transport System,  
leased based on the Oil Concession Agreement and by rails, from the loading ramps to  
refineries.  
The operation of the system is being performed by the local dispatchers coordinated by the  
central dispatcher of the company. The National Transport System consists of the following  
components:  
- Import Crude Oil Transport System;  
- Domestic Transport System, which in turn includes:  
- The crude oil and condensate transport subsystem;  
- The rich gas transport subsystem;  
- The ethane transport subsystem.  
The powers of each entity within the organizational structure are established by the Rules of  
Organization and Operation of the company.  
Quality, Environment, Occupational Health and Safety Policy  
In accordance with the strategic development direction of COPET SA, the Quality  
Environment, Occupational Health and Safety Policy aims at satisfying the requirements of  
the customers and of other relevant stakeholders, complying with the legal requirements  
144  
   
concerning the transport of crude oil, rich gas, ethane and condensate and ensuring a healthy  
and safe work environment for the entire personnel, targeting the following action lines:  
- Ensuring the availability and timeliness of the crude oil, rich gas and condensate transport  
services;  
- Solving operative interventions to transport facilities without affecting the interests of  
customers and other stakeholders;  
- Optimizing technological consumption of transported product;  
- Compliance with legal and other requirements relating to occupational safety and health;  
- Continuous improvement of performance in environmental protection activities in  
particular by adopting measures to prevent pollution, technological risks and accidents  
that can have a negative impact on the environment;  
- Awareness of the company’s personnel and the one working on behalf of the organization  
and improvement of communication to ensure active participation in achieving the goals;  
- Eliminating hazards and reducing risks related to health and safety;  
- Consultation and involvement of workers on any issue related to health and safety at  
work;  
- Ensuring an appropriate organizational framework for setting the objectives of the  
integrated management system quality - environment - health and safety;  
- Permanent assessment of the risks/opportunities arising from the current organization  
evolution and the risks/opportunities related to processes and establishment of actions  
to process them, correlated with the actions established at local/national level.  
The company’s management pursues consistently the performance concerning quality,  
environment, occupational health and safety, by maintaining and continuously improving the  
Management Systems in accordance with the reference standards for these areas.  
The certification body BUREAU VERITAS issued certificates for management systems  
implemented in CONPET S.A. according to the requirements of ISO 9001, ISO 14001 and  
ISO 45001 standards, following the external re-certification audit in September 2022. The  
certificates are valid 3 years, with annual surveillance. Following the surveillance audit of  
September 2024, the BUREAU VERITAS certification body recommended maintaining the  
certificates for the management systems of quality, environment, health and safety at work,  
issued for the organization CONPET S.A..  
The quality of transport services  
CONPET aims at fully satisfying customers’ requirements and expectations, fulfilling the  
obligations undertaken under the Oil Concession Agreement and at permanently complying  
with the regulations and legal provisions.  
The main goals pursued by the company to ensure an adequate level of quality of the  
transport services are:  
- The Development of the National Transport System by implementing the best  
technologies for the rehabilitation and modernization of the oil transport infrastructure, so  
as to ensure conditions of continuity and quality of the transport services;  
- Increased safety in operation and reduced technological consumptions;  
- Continuous improvement of the operational processes to ensure the high level of  
customer satisfaction through prompt, timely and cost-effective execution of the transport  
services;  
145  
- Maintenance of the Integrated Management System certifications according to the  
reference standards.  
The main lines of action relating to service quality are the following:  
- Ensuring the availability and timeliness of the transport services;  
- Efficient solving of interventions on the transport installations without affecting customers  
and other stakeholders’ interests;  
- Optimization of technological consumptions of transported product.  
The potential risks identified in this regard are as follows:  
- The degradation of the National Transport System, reduced transport capacity, delays in  
delivery, decreased customer satisfaction, complaints;  
- identification of major non-conformities following the certification or surveillance audits  
and suspension/cancellation of certificates, which could have a negative impact on the  
image of the organization.  
As a result of the measures taken by the company, the aforementioned risks were maintained  
at a low exposure level. The efficient control of the risks materialized by:  
- documentation, implementation and procedure compliance measures;  
- reviews and internal audits of the integrated management system;  
- planning and execution of investment and repair works to the National Transport System;  
- ensuring human resources with appropriate skills for conducting the main processes.  
No non-conformities have been identified as a result of the external audits for the surveillance  
of the integrated management system.  
The specific objectives, which refer to increasing customer satisfaction and promptness in  
providing transport service, are:  
- Implementation of the crude oil, rich gas, condensate transportation program with  
inclusion in the technological consumptions in the contracts;  
- Zero complaints from customers;  
- Carrying out the transport of crude oil with the specific electricity consumption of max.  
3,2 kwh/transported ton;  
- Zero railway events during the railway maneuver carried out by CONPET's own  
personnel, in the rail ramps. ;  
- Customer satisfaction with the crude oil and derivatives transport activity, with a target of  
at least 90% responses of 4 and 5 out of the total number of responses.  
In 2024, the indicators have reached the target values laid down as follows:  
- the transport program was carried out within the contractual limits of technological  
consumption for all transported products and for all customers;  
- there were no complaints from customers;  
- the specific consumption of electricity for crude oil transportation fell within the margin of  
max. 3.2 kwh/ transported ton, the achieved value being 2.67 kwh/ton;  
- no railway events were recorded during the railway maneuver carried out with CONPET’s  
own personnel.  
146  
- The value achieved for customer satisfaction was 100% with responses of four and five  
out of the total number of responses, as follows: 53 responses, of which 49 Very high  
satisfaction (respectively 5) and 4 High satisfaction responses (respectively 4).  
Environment  
In the field of environmental protection, CONPET management has adopted an  
environmental policy integrated with the policy on quality, health and safety at work, specific  
to the company's activity, size and impact on the environment, which would provide the  
framework for establishing and analyzing general objectives and specific environmental  
objectives.  
Special emphasis was placed on issues related to the needs and expectations of  
stakeholders (including the demands of the authority) and local environmental conditions or  
regional that can affect or be affected by the organization, the way the risks and opportunities  
are treated related to environmental issues for prevention and limitation of their  
consequences on human health and the environment.  
Being aware that the responsibilities towards the environment and the community in which it  
operates are inextricably linked to the performance it wants to achieve in its own activity and  
in accordance with the principles of sustainable development, CONPET has committed,  
through its environmental policy, to:  
- ensuring compliance with legal and other requirements relating to environmental matters.  
- the continuous improvement of the performance in environmental protection activity, in  
particular by adopting prevention measures for pollution, technological risks and  
accidents which can have negative repercussions on the environment.  
- Permanent assessment of the risks/opportunities generated by the context in which the  
organization evolves and of the risks/opportunities related to the internal processes and  
the establishment of actions for their treatment.  
- Awareness of the company’s personnel and of the personnel working on behalf of the  
organization and improvement of communication in order to ensure active participation  
in the achievement of the goals and the environmental management program.  
In terms of environmental protection and water management, CONPET S.A. activity is  
authorized in accordance with the provisions of GEO 195/2005 on environmental protection,  
as supplemented and amended and Water Law no.107/2005, with subsequent amendments  
and additions.  
According to the Ministry of Environment and Sustainable Development Order 1798/2007  
approving the procedure for issuance of the environmental permit, the activity carried out by  
CONPET is an activity with significant environmental impact. The environment permits issued  
by CONPET remain valid all along the period the company has been issued annual visa  
permit - amendment brought by Order 1150/2020.  
The identification of environmental aspects and the assessment of their associated impact  
within the company is carried out for:  
- all the activities performed, included in the area of application of the environment  
management system;  
147  
- materials, goods and services that can generate environmental impacts that are  
supplied/manufactured by suppliers/providers;  
- new projects and developments/upgrades;  
- facilities/equipment from a workstation whose operation has been partially or  
permanently stopped because of preservation, respectively of dissolution of work site  
and that have triggered or may trigger impacts on the environment.  
Following the identification of environmental aspects for activities, products and services of  
the company significant environmental aspects have been retained, which are input and  
environmental management program.  
The update of the lists of environmental aspects and the associated impacts thereof, as well  
as their centralization, is made whenever changes occur, such as:  
- Technology changes;  
- upgrading or introducing new plant, equipment, use of other raw materials;  
- occurrence of new requirements, environmental regulations or amendment of the existing  
ones;  
- decommissioning of installations and equipment;  
- preservation/restarting, dismantling of workstations after completion of actions to deal  
with significant environmental aspects.  
During 2024 environmental issues were reviewed at the sites, significant environmental  
aspects being included in the "List of significant environmental aspects and associated  
impacts".  
Given the significant environmental aspects identified at company level, the measures of  
inspection reports/minutes - authorities, concerning compliance with legal and other  
requirements, etc., during 2024 have been reviewed:  
- Environmental Management Program and actions to achieve environmental objectives;  
- Registry of environmental opportunities;  
- Registry of environmental legal requirements - Water;  
- Registry of environmental legal requirements - Air  
- Registry of environmental legal requirements -Regulations;  
- Registry of environmental legal requirements Wastes;  
- Registry of environmental legal requirements -Protected areas.  
The status of achieving the established objectives and targets and the status of implementing  
the actions established to achieve the environmental objectives are analyzed annually by the  
executive management, as part of the analysis carried out by the management, on which  
base decisions are made and the Action Plan for the continuous improvement of CONPET  
S.A.  
activities  
in  
the  
field  
of  
environmental  
protection  
is  
developed.  
Occupational Health and Safety  
In order to organize the prevention and protection activity within the company, according to  
art. 14, letter c and in conjunction with art. 19, paragraph 1 of The GD no. 1425/2006 with  
subsequent amendments and supplements, the internal prevention and protection service is  
established.  
148  
In each sector, there are persons responsible for health and safety at work, appointed by the  
Director General 's decision.  
Safety and health at work is today the joint concerns of technical and engineering disciplines,  
interested in finding the most appropriate ways and means of optimizing human integration  
into the professional applications system.  
The ultimate goal of work safety and health at work is:  
- protecting the life, integrity and health of workers against the risks of accidents and  
professional diseases that can occur in the workplace;  
- creating working conditions to provide them stable physically, mentally and socially  
comfort;  
Specific training programs are run to address specific issues, such as those related to safety  
risks.  
Permanently, through medical checks, a healthy, active lifestyle, first aid courses, body  
immunization programs are promoted, especially for employees who work in conditions of  
isolation, work at height and night shift.  
The main action lines of the top management concerning health and safety are as follows:  
- Prevention and reduction of occupational diseases and accidents at work;  
- Consultation and participation of workers on any aspect of health and safety at work.  
During the checks carried out by the representatives of the service, the "Conpet S.A.  
employee satisfaction evaluation questionnaire" was filled in by the employees regarding  
the safety and health at work" and reports were drawn up with reported problems and  
their remediation.  
- Ensuring appropriate organizational framework for setting the objectives of the integrated  
management system quality- environment- health and safety;  
- Permanent assessment of the risks/opportunities posed in the context the organization  
evolves in and of the risks/opportunities related to the processes and determining the  
actions for their treatment.  
According to the occupational health and safety law and regulations (S.S.M.), every employer  
with at least 50 employees in an establishment is obliged to establish an occupational health  
and safety committee, in order to consult and ensure employee participation in the  
development of all labor protection rules. The occupational health and safety committee is a  
mixed group, made up of both employer representatives and worker and medical staff  
representatives.  
Beyond our duty to ensure that employees are fully satisfied with their careers and have  
excellent opportunities for growth and personal development, our priority is to provide them  
with a safe workplace.  
Health and safety matters are discussed in the Occupational Health and Safety Committee  
meetings held quarterly or whenever necessary.  
From the perspective of the obligations and responsibilities arising from the Law no.  
319/2006 on safety and health at work and. 1425/2006 approving the Methodological norms  
for the application of the provisions of the Law on safety and health at work no. 319/2006,  
149  
the conditions for health and safety at work and occupational accident and diseases  
prevention are ensured:  
- prevention and protection activities are organized internally through the Prevention and  
Protection Department;  
- the duties and responsibilities for safety and health at work are set out incumbent upon  
the workers, corresponding to the functions exercised, which are specified in the job  
description;  
- the areas requiring occupational safety and health signaling and the necessary signaling  
type according to GD 971/2006 concerning the minimum requirements for the provision  
of safety and/or health signaling at work are determined;  
- occupational health and safety clauses are established upon the conclusion of the service  
contracts with other employers, including those concluded with foreign employers;  
- authorization is organized for the exercise of trades and professions provided for by the  
specific Legislation;  
- the health of the workers is monitored through in-house medical practices and by  
contracting occupational medicine services;  
In 2024, external inspections were carried out by labor inspectors of the Labor Territorial Unit  
from Giurgiu, Brăila, Dâmbovița, Călărași, Prahova, Gorj, Olt, Teleorman and Vâlcea without  
identifying irregularities at the level of the checked worksites. 14 improvement measures  
habe been ordered. During the scheduled internal controls, all the locations established by  
the approved control schedule were checked, no serious deviations were found, possibly  
causing injury and/or occupational illness of workers; the non-conformities found were  
remedied by carrying out the corrective measures ordered at no additional cost.  
The starting point in the continuous improvement of the prevention of work accidents and  
occupational diseases at the workplace is the "Assessment of the Risks of Occupational  
Accidents and/or Diseases". In 2024, the committee set up within the company for this  
purpose analyzed and reassessed the risks for each workplace/workstation. By implementing  
the technical organizational and sanitary measures from the Prevention and Protection Plan,  
the level of risk within the company is of 2.80, value below the maximum allowed limit of 3.50.  
Within the organization CONPET S.A. an occupational health and safety management  
system is implemented and certified in accordance with the requirements of the ISO 45001  
standard.  
During 2024, the occupational health and safety management system, part of the Quality -  
Environment - OSH Integrated Management System, was maintained and improved, a fact  
confirmed following the external surveillance audit of September 2024.  
The employer permanently allocates resources to maintain and improve the working  
conditions and health of the employees, the effects of these obligations being reflected in the  
results presented and in the medical reports prepared by occupational medicine doctor.  
In the light of the obligations and responsibilities arising from fire defense and civil  
protection legislation with implications for the safety and health at work of workers,  
prevention and intervention measures have been ensured by meeting/complying with the  
150  
applicable legal requirements and fire defense activity shall be organized at company level,  
therefore:  
- is established the Emergency Situations Office - structure with responsibilities in  
emergencies, specialized in risk prevention of occurrence of emergencies through  
guidance and control activities;  
- is organized defense against fire for all work places;  
- is organized the intervention of firefighting for all work places;  
- is ensured the organization of rescue and evacuation of employees and material goods;  
- Private service for Emergency Situations is set, in accordance with the law;  
- are identified, monitored and evaluated specific risk factors, generators of hazardous  
events; are identified types of risks generating natural and technological disasters; is  
provided assessment and analysis of potential risks on the possibility of their occurrence  
and consequences on people's lives, the environment and property;  
- is established the Cell for Emergency Situations.  
- are provided information and training activities on the means of knowledge, compliance  
and enforcement of the norms, of the technical regulations and provisions concerning fire  
safety and civil protection for all company personnel;  
- is provided the organization of training of employees and emergency teams within SPSU  
in emergency situations; participation in exercises and applications alarm, evacuation,  
intervention, limitation and elimination of consequences of fires or other disasters.  
From the point of view of the obligations and responsibilities arising from Law no. 59/2016  
on the control of major accident hazards involving dangerous substances are provided  
prevention/action measures by performance/compliance with the applicable legal  
requirements:  
- are established and provided measures to prevent major accidents involving dangerous  
substances and limit their consequences on human health and the environment;  
- "Security Reports" and "Internal Emergency Plans" are developed for each location of  
the company classified as a "higher level site", respectively "Major Accident Prevention  
Policy" for the locations classified as a "lower-level site";  
- the staff employed in these locations is periodically trained on the relevant parts of that  
documentation;  
- at the site level, a responsible in charge with security management was appointed, by  
decision of the Director General.  
In order to maintain and continuously improve the safety and health of workers in every  
aspect related to work, CONPET SA has developed and established the following plan on  
short, medium and long term:  
1. Achievement of all necessary lines regarding Safety and Health at Work contained in the  
Plan for Prevention and Protection and in the Programs of measures resulting from  
checks/internal and external audits;  
2. Permanent compliance with OHS legislation and other requirements/regulations to which  
the company subscribes, by implementing innovations in the field;  
3. Creating an OHS culture through training and raising awareness of employees about the  
need to respect the rules of safety and health at work by:  
- using interactive teaching methods, accompanied by practical demonstrations;  
- empowering all staff in identifying, reporting and eliminating/reducing the dangers of  
accidents and professional diseases;  
151  
- supporting and promoting preventive thinking and behavior;  
- involving all personnel in adopting measures to continuously improve the working  
environment.  
4. Continuous improvement of occupational health and safety by:  
- eliminating/reducing ongoing risks of accidents and occupational diseases;  
- conclusion of an occupational medicine contract with a specialized clinic;  
- integrating new employees in all the prevention and protection actions specific to the  
workplace;  
- developing programs to educate employees on occupational health, by adopting a  
healthy lifestyle;  
- improving internal communication and consultation on issues of safety and health at  
work;  
- implementation of thematic programs of information on health and safety risks, use of  
modern methods, efficient and effective training.  
In 2024, no work-related accident/incident was registered within CONPET S.A.  
During 2024, sanitary materials and personal protective equipment were provided for all  
employees.  
Informative materials were developed and displayed, including the rules and measures that  
must be observed, regarding wearing the protective mask, washing/disinfecting hands,  
ventilating and disinfecting the workspace during epidemics.  
Energy Policy  
The Energy policy of CONPET SA promotes the objectives of continuous improvement of  
energy performance by maintaining and improving the energy management system, by  
ensuring compliance with the legal provisions and other applicable requirements in terms of  
energy consumption and energy efficiency, minimizing the loss of electricity and fuel for the  
production of heat energy, motor vehicles and rail maneuvering on rail ramps, energy cost  
reduction, purchase and use of energy-efficient products and services.  
The company carries out actions to raise personnel awareness and improve communication  
in order to ensure active participation in the achievement of the energy goals and targets. In  
order to achieve the goals of this policy, the management and personnel of the company are  
fully committed to maintaining and improving the energy management system in accordance  
with the provisions of the ISO 50001 standard.  
The certification body BUREAU VERITAS issued the certificate for the management system  
implemented in CONPET S.A. according to the requirements of ISO 50001 standards,  
following the external re-certification audit in September 2022. The certificate is valid 3 years,  
with annual surveillance. Following the surveillance audit of August 2024, the BUREAU  
VERITAS certification body recommended maintaining the certificates for the management  
systems of quality, environment, health and safety at work, issued for the organization  
CONPET S.A..  
Railway Safety Policy  
152  
Starting 2010, within CONPET S.A. the Railway safety management system is implemented  
and maintained. The scope of this system includes ramps where CONPET performs railway  
shunting operations.  
Through the railway safety policy of CONPET S.A. the company declares its will and firm  
commitment to maintain and improve a railway safety management system according to the  
requirements established by the national and European Union regulations. The main lines of  
action are:  
- Compliance with existing legal requirements and other relevant stakeholder requirements  
relating to the development of railway shunting operations;  
- Ensuring the appropriate organizational framework for setting objectives and assessing  
the performance of the safety management system;  
- Identification of hazards, assessment and evaluation of risks associated with railway  
operations, including those arising from external factors;  
- Establishing appropriate safety measures to be implemented to mitigate these risks, with  
a view to preventing accidents/incidents by rail and cooperate with relevant stakeholders  
on the implementation of appropriate safety measures in case of common risk  
identification;  
- Assuming the coordination of the safety management system activities at the level of the  
management and delegation of responsibilities within the organization;  
- Provision of programs to train the personnel and maintain their competence in performing  
tasks, both for personnel in charge of management, training and control tasks and for  
personnel performing railway safety-related activities.  
The Romanian Railway Authority (A.F.E.R.) granted the company the License for the  
performance of railway transport services (railway shunting), and the A.S.F.R. (Romanian  
Railway Safety Authority) issued the Single Safety Certificate for the railway safety  
management system implemented in CONPET S.A..  
Social and Personnel Policy  
The company’s management develops and implements internal regulations used to establish  
the organization of the activity within the company by which the necessary resources are  
allocated effectively. The risks associated with the social and staff field are identified and  
their potential adverse effects are kept to an acceptable level through appropriate measures  
for cancellation or mitigation.  
The legal requirements in the HR and OHS areas at the level of the company are also  
complied with by the implementation and certification of the integrated management system.  
In addition, certain requirements are included in the Internal Regulations and the Code of  
Ethics and Integrity.  
Competent, motivated and honest employees represent the essential element for the  
successful completion of the company’s goals, being the most important resource for the  
proper conduct of the business.  
The main actions taken with respect to these issues have materialized by:  
- the provision of optimum work conditions;  
- transparent processes for recruitment based on professional competence and  
experience;  
153  
- promotion of employees that behave ethically and have proved integrity;  
- assessment of professional performance based on professional and personal skills  
criteria;  
- allocation of sufficient resources for training and continuous improvement of the  
personnel;  
- health care (regular medical checks and assessments, monitoring the health status of  
the employees, insurance contracts for medical services for the benefit of the  
employees);  
- providing additional wage benefits in the form of voluntary health insurance, as regulated  
in art. 221 para.9 of the Collective Labor Agreement, the ultimate goal being to prevent  
loss of working capacity of employees;  
- social facilities provided for in the Collective Labor Agreement (meal vouchers, covering  
part of the cost of tickets for rest and treatment, financial support to the employees and,  
in exceptional circumstances, to the members of their families (husband, wife, children  
supported by them), who have special medical problems, as well as to the employees  
who suffered significant damage from earthquakes, landslides or floods or other natural  
phenomena, fires);  
- supporting trade union activity, communication and ongoing consultation with the trade  
union organization.  
The main potential risks in the social and personnel field relate to:  
- high personnel fluctuation, decreased rate of retention of newly hired personnel or  
occupying key positions;  
- insufficient financial resources allocated for maintaining and improving working  
conditions or for preventive medical actions and measures;  
- constraints and budget limitations that can restrict the initiation/development of projects  
in the field of human resources;  
- improperly managed communication;  
- lack of qualified personnel in order to ensure the continuity of certain activities (e.g.  
personnel with responsibilities in traffic safety) in the case of departures from the system.  
The effects of these potential risks may consist in the increase in the medical leave expenses  
incurred by the company, increased absenteeism, decreased quality of the transport  
services, decreased efficiency, increased recruitment costs, adverse incentive of the  
employees or trade union conflicts. The company has managed, through the measures  
taken, to maintain the social and staff risks at a low level.  
To manage the risks in this field, the company has taken the necessary measures to ensure  
the security and protection of the employees’ health, to prevent occupational risks, to inform  
and train the employees and to ensure the organizational framework and the necessary  
means for occupational health and safety, including for specific risk-sensitive groups.  
Therefore, in-house instructions have been developed for the application of the regulations  
concerning safety and health at work, taking account of the particularities of the activities and  
of the jobs in the company. Furthermore, labor protection measures have been taken,  
specific for certain occupations or activities.  
154  
In drawing up the measures for safety and health at work, the company’s management shall  
consult with the Trade Union or, as appropriate, with the representatives of the employees  
and with the Occupational Health and Safety Committee.  
The personnel are informed and trained about the risks to the safety and health of the  
employees and to the protection and prevention measures specific to the workplace.  
In terms of gender equality, each employee of the company is free to develop their own skills  
and to express their choices without being influenced by the peculiarities of their gender.  
The different behaviors, aspirations and needs of women and men enjoy equal appreciation  
and promotion within CONPET S.A.  
The Internal Regulations of the company include provision for the prohibition of all forms of  
discrimination.  
Of the total personnel, 14.9% are women with higher education, who represent 37.6% of the  
total staff with higher education. At the same time, women account for a percentage of 32%  
in total personnel with management positions and a percentage of 36% in total personnel  
with management and coordination positions in the company. These weights represent an  
indicator of women's participation in the decision-making and management process at all  
levels and in important areas of business of the company.  
Thus, according to the organization chart in force at 31.12.2024, the entities Deputy Director  
General, Deputy Director General 2, Economic Directorate and Maintenance Development  
Chief Engineer are led by women. Promoting equality at work is synonymous with significant  
economic benefits.  
By eliminating all forms of discrimination within the company, women are free in the choice  
of their occupation upon their employment on any vacant job and at all levels of the  
professional hierarchy. This creates non-discriminatory conditions for career advancement,  
for work remuneration in relation to the professional skills and the quality of the work carried  
out and for the participation in professional qualification/re-qualification, improvement and  
specialization programs.  
The company guarantees for all employees, regardless of sex, the application of the principle  
of equal pay and the right to other benefits paid by the employer to employees, directly or  
indirectly, in cash or in kind, according to their place of employment.  
The Conventions of the International Labor Organization (., considered as fundamental labor  
principles and rights, relate to trade union freedom and trade union right protection, the  
effective recognition of the right of collective organization and bargaining, the elimination of  
all forms of forced or compulsory labor, the abolition of child labor and the elimination of  
discrimination in respect of employment and occupation, and represent guidelines and useful  
tools for the preparation of the internal policies of the company concerning employment,  
work, social dialogue, etc.  
The company informs employees consistently and permanently on the provisions of the  
Collective Labor Agreement, the Code of Ethics and Integrity and the Internal Regulations, a  
155  
document containing special chapters on the rights they have in connection with the  
compliance with the equality of opportunities and treatment between men and women in labor  
relations.  
Trade union freedom and collective bargaining ensures a good cooperation and consultation  
between the workers and the employer, leading to a decrease in the number of labor conflicts  
and a higher social stability.  
The employees of CONPET SA receive adequate protection against any discriminatory acts  
that might infringe trade union freedom.  
The practice of collective bargaining in CONPET SA guarantees that the worker and the  
employer have an equal share in the negotiations and that the decisions made will be fair  
and equitable. Starting from the premise that social dialog is an important factor for socio-  
economic progress, considered as one of the pillars of the European social model, essential  
for: the promotion of decent working conditions, transparent regulations regarding working  
rules, respect for employees and performance, productivity and profit for employers,  
collective bargaining has allowed the social partners to negotiate a fair employment  
relationship and to prevent labor disputes.  
The activities and actions for entertainment and networking for employees have been  
conducted between the trade union and employees, between the employees and family  
members, activities in partnership with public educational institutions, culture, various events  
at which personalities have been invited, etc.  
CONPET SA promotes a transparent business climate, communication and cooperation with  
all the parties involved in the conduct of its business, with respect for the community and the  
environment. CONPET S.A. supported, through sponsorship actions, projects of tradition or  
with significant impact on the community, but also request of less amplitude targeting ideas,  
actions or individual performance.  
Ethics and Integrity in Business, fighting corruption  
CONPET SA promotes fair business relationships and pursues legal compliance in all  
commercial transactions and activities carried out, acting for the deterrence, prevention and  
combating of corruption deeds.  
By the Code of Ethics and Integrity the company has established the rules of conduct and  
integrity, which regulate the values and principles of anti-corruption strategy, corporate  
values, responsibilities, obligations and business conduct, mandatory rules, applicable to all  
employees, from all organizational structures of CONPET S.A., directors and administrators  
with mandate contract.  
The Code of Ethics and Integrity defines honest conduct and behavior, prohibits participation  
of employees in decision-making process in situations where there is a conflict of interest,  
prevents pantouflage, incompatibilities, imposes restrictions in terms of offering/accepting  
gifts, favors or services, establishes the obligations of the employees with regard to the  
protection of the company’s assets and resources, specifies how to relate with the authorities  
based on the principles of fairness, transparency and good collaboration and mentions the  
156  
rules of conduct during national and international trips. There are also clear rules for dealing  
with shareholders regarding equal treatment and privileged information, as well as the use  
of honest and legal practices in dealing with business partners.  
As per GEO no. 109 dated November 30, 2011 on the corporate governance of public  
enterprises, further amendments and additions and within the Program for the development  
of the internal control management system, elaborated in compliance with the O.S.G.G. no.  
600/2018, considering the necessity of building an integrity culture inside CONPET S.A., the  
Code of Ethics and Integrity has been revised and approved by the Board of Directors (in the  
meeting dated 25.04.2024).  
The entire personnel of CONPET S.A. have been trained with regards to the company's  
institutional strategy, related to the expectations in conduct matters as per the Code of Ethics  
and Integrity, as well as related to the rights and obligations of the personnel in ethics and  
compliance matters. The Ethics Advisor monitored the compliance, by the organization's staff  
with the principles and rules of conduct and provided advice and assistance in the field of  
ethics, on the occasion of meetings organized within certain work sectors, according to the  
"Regulations on the activity of the Ethics Advisor within CONPET S.A", in force.  
In order to implement the National Anti-corruption Strategy 20212025 (NAS) at the level of  
the company, as early as May 2022 have been adopted the Declaration on assuming the  
organizational integrity agenda in the NAS 2021 - 2025 coordinates and the Integrity Plan,  
which was updated in February 2024 by Decision of the Director General of CONPET S.A.,  
and which details, in particular, the measures applicable to CONPET S.A., subsumed to the  
general and specific objectives set out in the NHS of public undertakings, in order to identify  
specific risks, vulnerabilities and needs for intervention. All measures to prevent corruption,  
with a deadline of 2024, have been implemented.  
Measures related to the development of programs/training, internal training and awareness  
in the field of anti-corruption education are carried out annually. Organization of the training  
program assumes that, if a company provides the efficient functioning of promoting an ethical  
and upright behavior, causing a change in attitudes among its personnel, then this system  
may limit internal conflicts, theft of company assets and fraud, use of the company resources  
in purposes other than those for which they are provided, using its image in the personal  
benefit of employees or sabotaging the interests of the company by misconduct of employees  
in relation to customers or business partners or corruption etc. The functioning of such a  
system contributes to the strengthening of the internal integrity system and the employee's  
sense of security, to his identification with the company's values, and therefore to the higher  
performance of the company.  
The recurrent staff awareness activity had an amplitude at the level of the entire company in  
the field of integrity, through the actions undertaken during 2024. Internally, all staff in the  
activity were trained on the norms of the Code of Ethics and Integrity in force, the norms  
related to the obligation to declare gifts/goods received free of charge on the occasion of  
protocol actions in the exercise of the mandate or function, the provisions of the Criminal  
Code regarding acts of corruption, the provisions related to declarations of assets and  
interests, conflict of interest, incompatibilities, and pantouflage. On this occasion, various  
157  
educational information materials were disseminated and published, which supported the  
training campaigns, and not only.  
Following the training on the provisions on conflicts of interest and incompatibilities, in 2024,  
a test/verification of the knowledge acquired by the management and TESA staff took place,  
which took place between November and December 2024, and was completed by obtaining  
high results from the staff, the degree of knowledge of the aforementioned provisions being  
100% (no. of employees who obtained the rating very good and good/no. of employees tested  
*100).  
The company also provides specialized personnel with training for new employees regarding:  
a) the anti-bribery policy and the requirements of the anti-bribery management system  
implemented in CONPET S.A. for the positions included in the “Inventory of Sensitive  
Functions at CONPET S.A.” in force, as well as for the anti-bribery compliance function  
(appointed by decision of the Director General);  
b) the rules on conflicts of interest and incompatibility for management and TESA personnel.  
Annually, during the first semester, the personnel occupying positions included in the  
Inventory of Sensitive Functions at the Conpet SA Level” in force, the anti-bribery  
compliance function, directors with mandate contracts and administrators of CONPET S.A.  
fill-in a declaration confirming compliance with the Anti-Bribery Policy and the requirements  
of the anti-bribery system implemented within the organization.  
The Anti-Bribery Policy  
For CONPET S.A., doing business and process deployment by the observance of the highest  
standards of ethics and integrity stands for a constant preoccupation.  
Acting as an operator of the crude oil, rich gas, condensate and ethane national transport  
system, CONPET S.A. acceded to the anti-bribery national strategy and implemented proper  
integrity plans.  
By the anti-bribery policy, CONPET S.A. commits not to tolerate any bribery act, not to  
manifest any type of sanction or retaliation against any relevant employee or third party for  
the refuse to be part of a bribery act and to observe the anti-bribery legislation applicable to  
the organization.  
Following the external audit carried out in July 2022, the SRAC CERT certification body  
certified the anti-bribery management system implemented in CONPET S.A. organization in  
accordance with the requirements of ISO 37001. The certificate is valid for 3 years, with  
annual surveillance. Following the external surveillance audit of June 2024, the SRAC CERT  
certification body recommended maintaining the compliance certificate no. 28/13.07.2022 for  
the anti-bribery management system implemented in the CONPET S.A. organization.  
Aspects related to the Diversity Policy in terms of Administrative and Management  
Bodies  
CONPET S.A. is a company listed on the Bucharest Stock Exchange and, according to the  
capital market legislation, the decision for the appointment of the members of the Board of  
Directors belongs to the shareholders. For this reason, the company is not in a position where  
158  
it can influence issues of diversity and could not adopt a policy on diversity in terms of  
administrative and management bodies.  
However, the proposals for candidates and the result of the vote in elections have provided  
each time an appropriate degree of diversity in terms of profile of administrators, coverage  
of professional expertise areas or age thereof.  
The current Board of Directors is composed of five male and two female individuals with  
professional experience in the fields of engineering, economics and law.  
5.2 Annual Sustainability Report 2024  
The Sustainability Report prepared for the year 2024 provides a detailed picture of the  
company's environmental, social and governance (ESG) performance. The report is  
prepared in accordance with the Corporate Sustainability Reporting Directive (CSRD) and  
the Order of the Ministry of Finance (O.M.F.) No. 85 of January 12, 2024 for regulating  
aspects related to sustainability reporting, ensuring compliance with national and European  
legislative requirements in the field of non-financial reporting.  
It is aligned with the European Union regulations on sustainability reporting, complying with  
the CSRD requirements and the European Sustainability Reporting Standards (ESRS).  
The following relevant regulations were taken into account in the preparation of this report:  
- Directive 2022/2464 on corporate sustainability reporting (Corporate Sustainability  
Reporting Directive - CSRD);  
- ORDER No. 85 of January 12, 2024 for regulating aspects related to sustainability  
reporting;  
- European Sustainability Reporting Standards (ESRS);  
- The (EU) Regulation 2019/2088 of the European Parliament and of the Council of 27  
November 2019 on sustainability reporting in the financial services sector (SFDR).  
- The (EU) Regulation 2020/852 on the establishment of a framework to facilitate  
sustainable investment (EU Taxonomy).  
The sustainability report for 2024 is presented in Annex no. 1.  
6. PROPOSAL OF THE BOARD OF DIRECTORS  
6.1 Approval of the financial statements concluded on 31.12.2024  
6.2 Approval of the allocation of net profit related to the financial year 2024  
Proposal to distribute the accounting profit left following the deduction of the corporate tax  
on December 31, 2024:  
Along 2024, there have not been distributed dividends based on the interim financial  
statements.  
The remaining accounting profit after the deduction of the corporate tax, on December 31,  
2024 is in amount of 49,323,047 RON.  
159  
       
The proposal to allocate, by legal destinations, the accounting profit left after the deduction  
of the corporate tax to be distributed, to which was added the provision for the employees’  
share of profit in amount of 5,057,858 RON, resulting a total amount to be distributed of  
54,380,905 RON, is the following:  
Provisions  
of GD no.  
64/2001  
Crt.  
No.  
Amount  
-RON-  
Element  
The net profit of the financial year 2024, reported based on  
the audited annual financial statements  
The employeesshare of profit within the limit of 10% of the net  
profit but not more than the monthly average base salary achieved  
at the level of the economic operator in 2024 financial year,  
acknowledged in the provisions account.  
1
-
-
-
49,323,047  
5,057,858  
54,380,905  
2
Net profit, reinstated with the provision for employee share of  
profit (1+2):  
3
Other allocations stipulated by law - exemption from the payment Art. 1, Para  
of the reinvested corporate tax (account 1068), Art 22 of Law no. (1), Letter 2,993,062  
a
227/2015 of the fiscal code  
b)  
Employees’ share of profit within the limit of 10% of the net profit  
but not more than the monthly average base salary achieved at  
the level of the economic operator reported in the reference  
financial year  
Art. 1, Para  
(1), Letter 5,057,858  
e)  
b.  
c
art. 1, para.  
46,329,985  
(1), letter f)  
Dividends due to shareholders  
Table 39 - Proposal for the allocation of net profit for the year 2024  
6.3 Approval of the distribution, as dividends, of certain amounts from retained  
earnings and other reserves  
The retained earnings which can be allocated, in the amount of 8,814,854 RON, are  
proposed to be distributed as dividends due to shareholders. The statement of retained  
earnings distributable and its distribution shall be as follows:  
Crt.  
No.  
Amount  
-RON-  
Destination  
1.1. The retained earnings representing surplus achieved out of revaluation reserves 6,298,970  
The retained earnings representing actuarial loss from the discount of benefits  
1.2.  
1,760,616  
granted upon retirement  
Retained earnings from the correction of various elements that have affected the  
profit of the previous years  
1.3.  
755,268  
1
Total retained earnings, distributed for:  
8,814,854  
a
Dividends due to shareholders  
8,814,854  
Table 40 - Proposal for the distribution of retained result  
Other reserves in the amount of 3,407,439 Ron, representing prescribed dividends, not  
collected within three years from the due date (prescribed dividends), are proposed to be  
distributed as dividends due to shareholders.  
160  
 
Crt.  
no.  
Destination  
Amount  
Other reserves represent distributions to owners, unclaimed within three  
years from the due date (prescribed dividends)  
1
3,407,439  
1
Total other reserves, distributed for:  
3,407,439  
a
Dividends due to shareholders  
3,407,439  
Table 41 Other reserves distribution proposal  
ANNEXES  
The following annexes are an integral part of the 2024 Annual Report of the administrators  
of Conpet:  
1) Annex no. 1 - Annual Sustainability Report 2024  
2) Annex no. 2 - Transactions concluded according to art.52 of GEO no. 109/2011 in the  
second semester of 2024  
3) Annex no. 3 Objectives and financial and non-financial key performance indicators of  
the directors with mandate contract for the period 01.01.2024-31.12.2024  
4) Annex no. 4 - Report on the internal/managerial control system as of 31.12.2024  
5) Annex no. 5 - List of the important contracts concluded by the company in 2024  
6) Annex no. 6 - List of disputes in which Conpet S.A. is a party, pending in the courts on  
14.03.2025  
7) Annex no. 7 - The Articles of Incorporation in force, updated on 27.04.2023  
8) Annex no. 8 - CVs of the current administrators  
CHAIRMAN OF THE BOARD OF DIRECTORS  
Gheorghe Cristian - Florin  
Director General  
Eng. TUDORA Dorin  
Deputy Director General  
Jurist DUMITRACHE Mihaela - Anamaria  
Deputy Director General 3  
Eng. NECȘULESCU Radu – Florentin  
Economic Director  
Econ. TOADER Sanda  
161  
 
Annex no. 1  
CONTENTS  
MESSAGE FROM THE DIRECTOR GENERAL  
4 I SUSTAINABILITY REPORT CONPET S.A.  
CONPET S.A. transports essential  
resources, contributing to a sustainable  
future through responsible governance  
and international best practices.  
1. REPORT FUNDAMENTALS  
This Sustainability Report 2024, prepared for CONPET S.A., provides a clear and detailed picture  
of the company's environmental, social and governance (ESG) performance. The document is  
produced in compliance with the Corporate Sustainability Reporting Directive (CSRD) and the  
Order of the Ministry of Finance (OMF) No. 85 of January 12, 2024 for regulating  
sustainability reporting aspects, ensuring compliance with the latest national and European  
legislative requirements in the field of non-financial reporting.  
This sustainability report is an individual report of CONPET S.A. and includes operations carried  
out by CONPET S.A. in its crude oil, condensate and ethane transport activities for the period  
January 01 - December 31, 2024. It is aligned with the latest European Union regulations on  
sustainability reporting, complying with the requirements of the CSRD and the European  
Sustainability Reporting Standards (ESRS). Specific details on the activities included in the  
report will be presented in the following sections.  
5 I SUSTAINABILITY REPORT CONPET S.A.  
 
1. REPORT FUNDAMENTALS  
In 2024, CONPET S.A. did not encounter any specific circumstances that prevented the full  
application of the ESRS requirements (ESRS 2 (BP-2)). The report was prepared with validated  
internal information, without intentional omission of data, and where estimates were used (e.g. in  
the absence of complete value chain data), they were based on documented methodologies.  
This report has taken into account multiple relevant regulatory frameworks:  
Directive 2022/2464 on Corporate Sustainability Reporting Directive () - imposes strict  
standards on sustainability reporting transparency for European companies.  
ORDER No. 85 of January 12, 2024 for the regulation of sustainability reporting issues  
- establishes national requirements for non-financial reporting and harmonization with  
European requirements. This Order ensures the alignment of the reporting process with the  
European Sustainability Reporting Standards (ESRS) and introduces clear requirements  
for transparency, comparability and verifiability of ESG information, thus strengthening the  
integration of sustainability principles into corporate strategies.  
The European Sustainability Reporting Standards (ESRS) - provide the detailed structure  
for reporting, including specific aspects on climate impact (ESRS E1), social aspects and labor  
relations (ESRS S) and corporate governance (ESRS G).  
Regulation (EU) 2020/852 on establishing a framework to facilitate sustainable  
investments (EU Taxonomy) - defines the criteria by which economic activities can be  
considered environmentally sustainable.  
Regulation (EU) 2019/2088 of the European Parliament and of the Council of November  
27, 2019 on Sustainability Disclosures in the Financial Services Sector (SFDR) - imposes  
specific transparency requirements on the integration of ESG factors into financial decisions.  
The following sections detail the scope and methodology of emissions reporting, explain how  
compliance with the CSRD and ESRS influences CONPET S.A.'s future sustainability strategy,  
and describe the role of complementary EU regulations on sustainable finance (such as the EU  
Taxonomy and the SFDR) in guiding our decisions. We also highlight the improvements in the  
sustainability disclosure process compared to previous years, underlining CONPET S.A.'s  
commitment to continuously improve transparency and accountability in reporting.  
Scope and methodology of emission reporting (ESRS) E1)  
CONPET S.A. uses a rigorous approach for monitoring greenhouse gas  
(GHG) emissions, covering all three emission areas defined by the GHG  
Protocol and required by ESRS E1. In accordance with these standards,  
the company reports the following emission categories:  
o Scope 1 emissions  
o Scope 2 emissions  
o Scope 3 emissions  
6 I SUSTAINABILITY REPORT CONPET S.A.  
1. REPORT FUNDAMENTALS  
This classification follows the internationally recognized GHG Protocol (Greenhouse Gas Protocol  
- GHG) methodology, which has been adopted in the ESRS E1 standard to ensure consistency  
in reporting emissions.  
The collection of emissions data by CONPET S.A. is comprehensive:  
For scopes 1 and 2, we rely on internal records (e.g. log sheets for our fleet of vehicles  
and equipment, meter readings and utility bills for electricity and heat consumption at our  
facilities, technological consumption).  
For Scope 3, we aim to work with suppliers and partners to collect relevant data (such as  
fuel and energy consumption information) and, where direct data are not available, use  
estimation techniques and industry baselines to approximate emissions from activities  
such as procurement, waste disposal and end-use.  
All greenhouse gas emissions are calculated in CO₂ equivalent (COe) using recognized emission  
factors. For example, we apply conversion factors set by national authorities or the IPCC for fuels  
and electricity, ensuring that all significant greenhouse gas (GHG) emissions are accounted for in  
COe based on their global warming potential.  
By aligning our calculations and reporting to ESRS E1 guidelines, CONPET S.A. ensures that our  
emission figures for areas 1, 2 and 3 are reported with clarity and credibility. ESRS E1  
requirements require absolute emissions to be reported for each scope, and we provide this  
information in the report, together with explanations of the methodologies used.  
Compliance with ESRS E1 also means that we report emissions in a similar way to other  
companies in the EU, as the standard prescribes the definitions and measurement methods set  
out in the GHG Protocol. This alignment improves the comparability of our data, allowing  
stakeholders to assess CONPET S.A.'s carbon footprint relative to other companies in the  
industry and track our progress in reducing emissions over time.  
In short, the emissions data in this report reflect a rigorous, standards-aligned process - from data  
collection to calculation, designed to ensure the accuracy and transparency of our climate impact  
reporting.  
CSRD AND ESRS COMPLIANCE AT CONPET S.A.  
The emergence of the CSRD and its detailed ESRS framework has shaped CONPET S.A.'s idea  
of sustainability and governance approach. Far from being a mere reporting obligation, these  
regulations serve as a model for mainstreaming sustainability at all levels of corporate decision-  
making. CSRD is ushering in a "new era of transparency" for European companies by requiring  
a dual assessment of the materiality of sustainability issues - i.e. assessing not only how social  
and environmental issues influence CONPET S.A.'s financial performance, but also how  
CONPET S.A.'s activities influence society and the environment. This dual perspective drives  
CONPET S.A. to communicate/collaborate with its stakeholders.  
Compliance with CSRD is an important aspect of CONPET S.A.'s governance structure. The  
ESRS includes specific governance standards (ESRS G1 to G4) that outline expectations on  
corporate governance issues, emphasizing aspects such as business ethics, internal control, risk  
7 I SUSTAINABILITY REPORT CONPET S.A.  
1. REPORT FUNDAMENTALS  
management and stakeholder engagement. In response, CONPET S.A. has strengthened Board  
and Executive oversight of ESG issues. Sustainability performance and risks are regularly  
monitored at Board level, ensuring that top management takes full responsibility when it comes  
to meeting the company's ESG objectives and obligations.  
In line with ESRS G4 (Stakeholder Engagement), CONPET S.A. is optimizing its processes for  
interacting with stakeholders and on sustainability issues. By involving stakeholders, CONPET  
S.A. aims to ensure that their concerns are taken into account and addressed in the company's  
decision-making process. This not only fulfills regulatory expectations, but strengthens trust and  
relationships with those who are affected by or have an impact on our business.  
Compliance with the CSRD and ESRS also requires CONPET S.A. to expand the scope its risk  
management to fully integrate ESG risks. In line with ESRS G3 (Internal Control and Risk  
Management), companies are expected to describe their systems for identifying and managing  
sustainability risks, including climate change and social risks. In response, CONPET S.A. will  
update the enterprise risk management framework to include sustainability risks alongside  
traditional financial and operational risks. CONPET S.A. assesses human capital, as well as social  
and environmental risks (such as labor practices, health and safety, and/or environmental impact  
on the community) as part of this integrated approach to risk management. The results will  
influence strategic planning; for example, the risks identified have prompted us to invest in the  
modernization of the Pipeline Transporta System (PTS) and energy efficiency. By transparently  
reporting on these risks and how we are managing them, CONPET S.A. is committed to CSRD  
and demonstrates to stakeholders that the company is proactively mitigating sustainability threats.  
Aligning CONPET S.A. to this principle means having ESG monitoring mechanisms in place,  
implementing actions to continuously improve our resilience to a changing environmental and  
regulatory landscape.  
In short, compliance with CSRD and ESRS acts as a sustainability catalyst for CONPET S.A. to  
integrate ESG requirements into governance, stakeholder engagement and risk management.  
These regulations are driving us to formalize and improve our internal processes - from  
sustainability oversight by the Board of Directors, to stakeholder engagement in decision-making,  
to the expansion of our risk assessments - thereby strengthening our overall sustainability  
performance and accountability.  
Table 1.1 Data points deriving from other EU legislation (ESRS IRO2.56)  
EU  
Submission requirement and  
related data point  
Reference in the Benchmarks  
Regulation [1]  
Reference from  
Climate Law [2]  
ESRS 2 GOV-1  
Gender diversity in governing bodies  
point 21(d)  
Commission Delegated  
Regulation (EU) 2020/1816[3],  
Annex II  
-
ESRS 2 GOV-1  
Percentage of members of the  
governing bodies who are  
independent point 21(e)  
Delegated Regulation (EU)  
2020/1816, Annex II  
-
8 I SUSTAINABILITY REPORT CONPET S.A.  
     
1. REPORT FUNDAMENTALS  
EU  
Submission requirement and  
related data point  
Reference in the Benchmarks  
Regulation [1]  
Reference from  
Climate Law [2]  
ESRS 2 SBM-1  
Involvement in activities related to  
chemical production paragraph 40 (d)  
ii  
-
Regulation (EC) No 1893/2006  
ESRS E1-1  
Transition plan to achieve climate  
neutrality by 2050, point 14  
Regulation (EU)  
2021/1119,  
Article 2(1)  
ESRS E1-4  
Greenhouse gas emission reduction  
targets  
Delegated Regulation (EU)  
2020/1818, Article 6  
-
point 34  
ESRS E1-6  
Gross values of 1, 2, 3 and total GHG  
emissions  
point 44  
Delegated Regulation (EU)  
2020/1818, Articles 5(1), 6 and  
8(1)  
-
-
ESRS E1-6  
Gross GHG emission intensity  
Rows (53)-(55)  
Delegated Regulation (EU)  
2020/1818, Article 8(1)  
ESRS E1-7  
GHG removals and  
carbon credits  
Regulation (EU)  
2021/1119,  
Article 2(1)  
-
point 56  
ESRS E1-9  
Delegated Regulation (EU)  
2020/1818, Annex II Delegated  
Regulation (EU) 2020/1816,  
Annex II  
Benchmark portfolio exposure  
to climate-related physical risks  
paragraph 66  
-
-
ESRS E1-9  
Exposure of  
portfolio to the opportunities  
climate-related  
Delegated Regulation (EU)  
2020/1818, Annex II  
point 69  
ESRS S1-1  
Due diligence policies on the issues  
addressed by the fundamental  
Conventions 1-8 of the International  
Labor Organization  
paragraph (21)  
Delegated Regulation (EU)  
2020/1816, Annex II  
-
9 I SUSTAINABILITY REPORT CONPET S.A.  
1. REPORT FUNDAMENTALS  
EU  
Submission requirement and  
related data point  
Reference in the Benchmarks  
Regulation [1]  
Reference from  
Climate Law [2]  
ESRS S1-14  
Number of fatalities and number and  
rate of work-related accidents point  
88(b) and (c)  
Delegated Regulation (EU)  
2020/1816, Annex II  
-
-
ESRS S1-16  
Gender pay disparity in unadjusted  
form  
Delegated Regulation (EU)  
2020/1816, Annex II  
point 97(a)  
ESRS S1-17 Non-compliance with  
the UN Guiding Principles on  
Business and Human Rights and the  
OECD Guidelines  
Delegated Regulation (EU)  
2020/1816, Annex II to Delegated  
Regulation (EU) 2020/1818,  
Article 12(1)  
-
point 104(a)  
ESRS S3-1  
Failure to respect the UN Guiding  
Principles on Business and Human  
Rights, ILO principles and/or OECD  
guidelines  
Delegated Regulation (EU)  
2020/1816, Annex II to Delegated  
Regulation (EU) 2020/1818,  
Article 12(1)  
-
-
point 17  
ESRS G1-4  
Fines for violation of laws against  
corruption and bribery point 24(a)  
Delegated Regulation (EU)  
2020/1816, Annex II  
[1] Regulation (EU) 2016/1011 of the European Parliament and of the Council of June 8, 2016 on  
indices used as benchmarks in financial instruments and financial contracts or to measure the  
performance of investment funds and amending Directives 2008/48/EC and 2014/17/EU and  
Regulation (EU) No 596/2014 (OJ L 171, 29.6.2016, p. 1).  
[2] Regulation (EU) 2021/1119 of the European Parliament and of the Council of June 30, 2021  
establishing the framework for achieving climate neutrality and amending Regulations (EC) No  
401/2009 and (EU) 2018/1999 ('European Climate Act') (OJ L 243, 9.7.2021, p. 1).  
[3] Commission Delegated Regulation (EU) 2020/1816 of July 17, 2020 supplementing Regulation  
(EU) 2016/1011 of the European Parliament and of the Council as regards the explanation in the  
benchmark statement of how environmental, social and governance factors are reflected in each  
benchmark provided and published (OJ L 406, 3.12.2020, p. 1).  
10 I SUSTAINABILITY REPORT CONPET S.A.  
1. REPORT FUNDAMENTALS  
EU TAXONOMY AND SFDR  
In the context of new EU sustainability requirements, the EU Taxonomy and the Sustainable  
Finance Disclosure Regulation (SFDR) are two key frameworks for increasing transparency and  
aligning capital flows towards sustainable investments. These regulations provide a clear  
framework for investors and companies, contributing to a greener and more responsible economy.  
The EU Taxonomy is a classification system designed by the European Commission to identify  
economic activities that make a significant contribution to the European Union's environmental  
objectives. It sets clear technical criteria for six environmental objectives. To be considered  
aligned with the Taxonomy, economic activities must make a significant contribution to one of  
these objectives, do no significant harm to other objectives (DNSH - Do No Significant Harm) and  
comply with minimum social governance requirements.  
The SFDR Regulation sets out strict reporting requirements for financial firms and fund managers  
on the integration of sustainability risks and the impact of investments on ESG (environmental,  
social, governance) factors. It requires financial products to be categorized according to their level  
of sustainability:  
Article 6 - Products without specific ESG objectives  
Article 8 - Products promoting ESG features  
Article 9 - Products with a focus on sustainable investments  
The SFDR obliges investors to publish clear and comparable information on how ESG risks are  
managed and to what extent their funds contribute to sustainability objectives.  
CONTINUOUS IMPROVEMENT OF REPORTING PRACTICES AND TRANSPARENCY  
CONPET S.A. is committed to improving our reporting on ESG issues, continuously increasing  
the accuracy and transparency of our information. Each annual report builds on the previous one,  
incorporating new guidelines and stakeholder feedback to enhance the clarity and detail of the  
information provided. In the past, under the former EU Non-Financial Reporting Directive (NFRD),  
our sustainability disclosures covered key aspects of our ESG performance in a more simplistic  
manner. Now, under the CSRD, we have significantly expanded and refined our reporting  
practices.  
Overall, the Reporting Basics section outlines how CONPET S.A. approaches sustainability  
reporting with diligence and integrity. By detailing our methodologies, aligning with EU regulations  
(CSRD, ESRS, EU Taxonomy, SFDR) and continuously improving our practices, we strive to  
clearly present our sustainability performance and how we manage ESG impacts and risks. This  
approach ensures that readers of the report - be they investors, regulators, partners or members  
of the public - can confidently understand and assess CONPET S.A.'s sustainability efforts in  
2024 and the progress we are making towards our long-term ESG goals.  
11 I SUSTAINABILITY REPORT CONPET S.A.  
CONPET S.A.  
STRATEGIC  
OPERATOR  
of the National Crude Oil  
Transport System,  
ensuring the efficient  
delivery of Romania's  
energy resources.  
2. COMPANY OVERVIEW  
2.1 Business model and market position  
CONPET S.A. is the operator of the "National Transport System for Crude Oil, Rich gas,  
Condensate and Ethane" (SNT), whose activity is the transport through pipelines, in order to  
supply the refineries in Romania.  
Oil transport through the National Transport System is a service of national interest and strategic  
importance. The National Crude Oil Transport System is the set of interconnected trunk pipelines  
that collect the oil extracted from the exploitation perimeters, or imported, and route it from the  
delivery points of the producers/importers to the processing units, through the pumping stations,  
loading and unloading ramps on the railways, as well as all the installations, equipment and  
facilities related to them. According to the concession agreement, the company must ensure open  
and non-discriminatory access to its pipelines for all eligible customers on equal terms. This  
guarantees that any authorized producer or importer of crude oil can use CONPET S.A.'s  
infrastructure, and transport tariffs are regulated by the National Regulatory Authority for Mining,  
Petroleum and Geological Storage of Carbon Dioxidede (ANRMPSG).  
12 I SUSTAINABILITY REPORT CONPET S.A.  
   
2. COMPANY OVERVIEW  
Graph 2.1. Composition of the National Pipeline, Rich gas and Ethane Transport System  
The National Pipeline, Rich gas and Ethane Transport System currently has an operational  
capacity of approximately 18.75 million tons. In regions where there are no main pipelines,  
CONPET S.A. also manages the rail transport infrastructure, including loading ramps, as well as  
a fleet of tank wagons and locomotives, thus ensuring efficient and safe delivery of products.  
This integrated pipeline and railroad model provides CONPET S.A. with flexibility in its operations  
and the ability to serve remote locations, strengthening its role in Romania's crude oil supply  
chain. The National Crude Oil Transport System is a vast network of pipelines, both trunk and  
local, with a total installed length of approximately 3,800 km, of which 3,200 km are available. The  
company currently has an operational pipeline network of approx. 2,200 km, which is why the total  
nominal transport capacity of about 27.5 million tons per year is operationally reduced to about  
18.75 million tons per year. This is caused by the closure over time of some production and  
processing units of crude oil, rich gas, ethane in Romania, which led to the inactivation of some  
pipelines and related pumping stations.  
13 I SUSTAINABILITY REPORT CONPET S.A.  
2. COMPANY OVERVIEW  
Table 2.1. Distribution of transport infrastructure by subsystem  
Total transport  
Subsystems  
Network length  
Storage capacity  
capacity  
Domestic  
crude oil  
6,9 million tons  
per year  
120.000 cubic  
meters  
1.540 km of pipeline  
Imported  
crude oil  
20,2 million tons  
per year  
1.348 km of pipeline  
921 km pipelines  
79.500 mc  
250 mc  
Rich gas/liquid  
ethane  
0,33 million tons  
per year  
CF crude oil/  
rich gas  
13 locomotives and  
55 wagons  
13 loading ramps  
2 unloading ramps  
The infrastructure and transport capacity of Conpet S.A. serves its main customers, OMV Petrom  
and Petrotel Lukoil, key players in the refining and distribution of petroleum products.  
Table 2.2. Market position and operational capacity  
Metric  
Value  
Length of operational  
pipelines  
approx. 2.200 km active pipelines  
Annual operational  
transport capacity  
18,75 million tons/year  
Main customers  
OMV Petrom, Petrotel Lukoil  
National Regulatory Authority for Mining, Petroleum and Geological  
Storage of Carbon Dioxide (ANRMPSG)  
Surveillance regulations  
The evolution of the quantities transported by CONPET S.A. between 2020 and 2024 recorded a  
gradual decrease in the transport of domestic crude oil, reaching 2,81 million tons in 2024, while  
the volume of imported crude oil recorded a steady increase, reaching 4,32 million tons in the  
same year, which contributes to maintaining a stable total of transported quantities, with a peak  
of 7,13 million tons in 2024.  
14 I SUSTAINABILITY REPORT CONPET S.A.  
2. COMPANY OVERVIEW  
Evolution of quantities transported during the period  
2020 - 2024: Import vs. Domestic (mil. tons)  
8,00  
7,00  
6,00  
5,00  
4,00  
3,00  
2,00  
1,00  
0,00  
7,10  
6,65  
6,68  
7,13  
6,29  
4,04  
4,32  
2,81  
3,28  
3,41  
3,35  
3,24  
3,40  
3,06  
2,95  
2020  
2021  
2022  
Total imports  
2023  
Total  
2024  
Country total  
Graph 2.2. Evolution of quantities transported from 2020 to 2024  
The distribution of CONPET S.A.'s customers according to their share in sales in 2024 shows  
the dominant position of OMV Petrom (79.5%), the main crude oil producer in Romania,  
followed by Petrotel Lukoil (19.9%) and other customers (0.6%).  
Share of customers in turnover (2024)  
0,6%  
OMV PETROM  
PETROTEL - LUKOIL  
OTHER CLIENTS  
Graph 2.3. Share of customers in turnover  
15 I SUSTAINABILITY REPORT CONPET S.A.  
2. COMPANY OVERVIEW  
Market share and customer base: Due to its unique position, CONPET S.A. manages almost  
all the crude oil transported through pipelines in Romania, making it an indispensable partner for  
the oil industry. The company's main customers are OMV Petrom, the largest and only upstream  
oil producer in Romania, and Petrotel Lukoil. These long-term partnerships underline the  
strategic importance of CONPET S.A..  
BREAKDOWN OF INCOME AND ASSETS BY SIGNIFICANT SECTORS (ACCORDING TO  
ESRS 2 SBM-1, 40B)  
In accordance with the requirements of ESRS 2 - Strategy and Business Model (SBM-1, par.  
40b), companies are required to disclose a breakdown of the revenue and equity components, as  
included in its financial statements, by material ESRS segments in the context of sustainability to  
enable stakeholders to better understand the structure of the business model, the contributions  
of each operating segment to economic performance, and exposure to ESG risks and  
opportunities.  
CONPET S.A. is active in the fossil fuels (oil and gas) sector, earning revenues from their  
transport, and 99.59% of revenues from customer contracts (turnover) are associated with crude  
oil transport activities. Thus, in accordance with IFRS 8 Operating Segments, the company has  
only one reportable segment, i.e. the provision of crude oil pipeline transport services. This is  
disclosed in the annual financial statements, Note 3 "Accounting policies" point (t) Reporting by  
business segments.  
Table 2.3. Total revenue (2024), broken down by accounting category (financial statements  
- statement of financial position at 31 DECEMBER 2024)  
Value  
(thousand  
RON)  
Percentage  
Category  
(%)  
Revenue from turnover (Revenue  
from contracts with customers -  
IFRS 15)  
533.618  
87,10%  
Other operating income  
Total operating income  
Financial income  
72.663  
606.282  
6.384  
11,86%  
98,96 %  
1,04%  
Total revenue  
612.666  
100,00%  
By offering a mutually beneficial and secure transport solution, CONPET S.A. enables its  
customers to ensure a constant supply of raw materials. Alternative modes of transport are more  
expensive and less efficient compared to pipeline transport.  
MAIN INTANGIBLE RESOURCES (INTANGIBLE ASSETS)  
The main intangible resources of CONPET S.A., which contribute directly to the company's  
operational success and competitiveness, are:  
16 I SUSTAINABILITY REPORT CONPET S.A.  
2. COMPANY OVERVIEW  
Intellectual capital and employee expertise: The company has a solid base of technical  
knowledge and accumulated experience in the transport of crude oil through pipelines.  
This expertise covers the operation and maintenance of complex transport systems, the  
application of advanced technologies to optimize operational efficiency and the  
implementation of effective risk management mechanisms.  
Technical and procedural know-how: CONPET S.A. applies an integrated management  
system that ensures high standards of quality, environmental protection, operational safety  
and energy efficiency. These principles are regularly validated by independent external  
audits and contribute to maintaining operational performance and compliance.  
The company's certification basis within the integrated management system is optimal and  
ensures the implementation of best practices in the relevant areas, facilitating adaptation to  
industry-specific legislative and operational requirements.  
Competitive advantages: CONPET S.A.'s business model confers several competitive  
advantages. First, it operates within a stable regulatory framework that guarantees predictable  
revenues - transport tariffs are set and approved by the National Regulatory Authority for Mining,  
Petroleum and Geological Storage of Carbon Dioxide (ANRMPSG). This regulated tariff system,  
in accordance with the Petroleum Law (Law 238/2004) and the company's concession  
agreement (Government Decision No. 793/2002), provides a clear legal basis for CONPET S.A.'s  
operations and rights. Secondly, the company benefits from economies of scale and network  
effects as the sole pipeline operator: its nationwide infrastructure and centralized dispatching  
allow efficient transport of large volumes, giving it a cost advantage over any potential fragmented  
competitor. Third, CONPET S.A.'s extensive experience - over a century in pipeline transport -  
has built a reputation for reliability and operational excellence. CONPET S.A. is today recognized  
as a strategic company for the national economy and a major player on the Romanian capital  
market. This legacy translates into valuable technical know-how, a solid safety culture and strong  
stakeholder confidence. Finally, the company's strategic importance (with the Romanian state as  
majority shareholder) means that it operates under close supervision, aligning its goals with  
national energy security objectives. In short, CONPET S.A. holds a unique market position,  
characterized by an exclusive asset base, captive demand from the Romanian oil industry and a  
favorable regulatory environment governing the transport of crude oil.  
Table 2.4. Economic efficiency and operational costs transport methods  
Pipeline transport  
(CONPET S.A.)  
Transport  
road  
Maritime  
transport  
Metric  
Rail transport  
Lowest cost thanks  
to continuous flow  
and low energy  
consumption  
Low cost over  
long distances but  
requires port  
High cost due to Intermediate but  
Cost per  
tonne-km  
high fuel  
high cost for  
consumption  
short distances  
infrastructure  
High volume,  
continuous,  
uninterrupted  
Depends on the  
availability of  
tank wagons  
Transport  
capacity  
Limited by truck  
capacity  
High capacity but  
port-dependent  
17 I SUSTAINABILITY REPORT CONPET S.A.  
2. COMPANY OVERVIEW  
Pipeline transport  
(CONPET S.A.)  
Transport  
Maritime  
transport  
Metric  
Rail transport  
road  
Requires  
maintenance of  
rail lines and  
terminals  
Requires large  
investments in  
ports and  
Does not require  
frequent road or rail requires constant  
Affects roads and  
Impact on  
infrastructure  
maintenance  
maintenance  
terminals  
Table 2.5. Operational safety and accidental pollution risk in transport  
Pipeline transport  
(CONPET S.A.)  
Rail  
Maritime  
transport  
Indicator  
Road transport  
transport  
Environment  
- risks of  
derailments  
and  
accidents  
Environment  
- risks of soil  
and water  
pollution  
Raised in  
case of  
maritime  
collisions  
Lowest without  
interaction with road  
traffic  
Risk of  
accidents  
High - risk of  
accidents  
Minimized thanks to  
continuous monitoring  
and control systems  
High - risk of  
spills in case of  
accident  
Picked up in  
accidents at  
sea  
Spills and  
pollution  
NATIONAL TRANSPORT SYSTEM OPERATED BY CONPET S.A.  
The complete infrastructure of the National Transport System (NTS) operated by CONPET S.A.  
covers the main production and refining regions in Romania, including all pumping stations,  
depots and rail ramps that could transport more than 27 million tons of crude oil annually. The  
dense pipeline structure in the key areas - Constanța (maritime terminal), Prahova Valley (main  
refining area) and the West of the country (domestic production area) emphasizes the strategic  
role of CONPET S.A. in ensuring Romania's energy security.  
The map below shows the pipeline networks for domestic crude oil (blue), imported crude oil  
(green), rich gas (orange) and liquid ethane (orange).  
18 I SUSTAINABILITY REPORT CONPET S.A.  
2. COMPANY OVERVIEW  
2.2 Company profile  
CONPET S.A. is a public enterprise and falls within the regulatory scope of G.E.O. no. 109/2011  
on the corporate governance of public enterprises (with subsequent amendments and additions),  
as well as the specific legislation on the capital market.  
At the reference date (31.12.2024) the total number of issued shares of CONPET S.A. is  
8,657,528, held by 16,251 shareholders. Each share is subscribed and paid at par value 3.3 RON,  
conferring to the holder the right to one vote in the General Meeting of Shareholders, the right to  
elect and be elected in the management bodies, the right to participate in the distribution of  
dividends in accordance with the provisions of the Articles of Incorporation and legal provisions,  
as well as other rights provided for therein. The shareholder structure, corresponding to the  
consolidated summary shareholder structure on the same reference date, is as follows:  
Romanian State through the Ministry of Energy (1 shareholder)  
Number of shares:  
5.083.372  
Contribution to the share capital (RON) 16.775.127,60  
Share in profit and loss (%)  
58,7162  
19 I SUSTAINABILITY REPORT CONPET S.A.  
 
2. COMPANY OVERVIEW  
Legal entities (100 shareholders)  
Number of shares:  
2.083.424  
Contribution to the share capital (RON) 6.875.299,20  
Share in profit and loss (%)  
Individuals (16,150 shareholders)  
Number of shares:  
24,0649  
1.490.732  
Contribution to the share capital (RON) 4.919.415,60  
Share in profit and loss (%) 17,2189  
Shareholders exercise their rights in the General Meeting of Shareholders (G.M.S.), which is the  
highest decision-making body of the company. The powers of approval of the General Meeting of  
Shareholders, the conditions for the organization and validity of such meetings are laid down in  
the Company's Articles of Association, in accordance with the applicable regulations, and are  
supplemented by the relevant legal provisions. The Company's Articles of Incorporation, the  
Regulations on the Organization and Conduct of the G.M.S. and Information on Shareholders'  
Rights are available on the Company's website.  
COMPANY MANAGEMENT  
General Meeting of Shareholders  
The General Meeting of Shareholders is the governing body of the company, which decides on  
the company's activities and policies in accordance with the legal provisions in force.  
Board of Directors  
CONPET S.A. is managed in a unitary system, by a Board of Directors, composed of 7 directors  
(all non-executive members), appointed by the Ordinary General Meeting of Shareholders for a  
period of 4 years, starting from 22.08.2023, following the conduct and completion of the  
recruitment and selection process of directors at the level of the Public Authority of the Ministry of  
Energy. The Board of Directors is headed by a Chairman, elected by the Board of Directors from  
among its members. The decision on his appointment or removal shall be taken by a majority vote  
of the members of the Board of Directors. The Chairman of the Board of Directors of the company  
may not also be its General Director.  
20 I SUSTAINABILITY REPORT CONPET S.A.  
2. COMPANY OVERVIEW  
Management structure of CONPET S.A.  
Executive Management  
The executive management of the company is ensured by a team of 4 directors with a mandate  
contract (General Director, Deputy Director Generals and Economic Director), appointed by the  
Board of Directors, with a 4-year mandate (period 2023 - 2027), following the completion and  
finalization of the recruitment and selection procedures for directors in accordance with the  
provisions of the G.E.O. no. 109/2011 on the corporate governance of public enterprises.  
2.3 Sustainability commitment  
CONPET S.A. aligns itself with both European and national strategies in terms of sustainability  
and makes every effort to have a positive year-on-year evolution in terms of energy efficiency and  
carbon footprint reduction.  
The main sustainability initiatives and objectives of CONPET S.A. are:  
Environmental Management  
Protecting the environment is a priority for CONPET S.A. in view of the potential environmental  
risks associated with the transport of crude oil, rich gas and condensate. The company has  
implemented an ISO 14001 certified environmental management system, which ensures the  
identification and continuous control of environmental aspects and associated impacts in all  
operations. CONPET S.A. is fully committed to complying with environmental legislation - it  
operates in strict compliance with all applicable laws and permits relating to air emissions, water  
and soil quality and waste management. In practice, this means monitoring pollutant emissions  
from its facilities (e.g. pumping stations, storage tanks) and keeping them within regulated limits,  
as well as treating waste properly and preventing any unauthorized discharges.  
21 I SUSTAINABILITY REPORT CONPET S.A.  
 
2. COMPANY OVERVIEW  
Beyond compliance, CONPET S.A. emphasizes pollution prevention and continuous  
improvement of environmental performance. The company proactively invests in technologies  
and processes that reduce the risk of spills and environmental incidents. For example, advanced  
spill detection systems and upgrades to the cathodic protection system of its pipeline network  
minimize the risk of leaks and corrosion. It also conducts regular maintenance and pipeline  
integrity inspection programs so that potential problems are identified and resolved before they  
affect the environment.  
A significant part of our environmental protection strategy focuses on reducing greenhouse gas  
emissions and energy consumption in transport operations. Although pipeline transport  
generates fewer carbon emissions than other modes of transport, CONPET S.A. still consumes  
electricity (e.g. to power pumping stations) and fuels (for maintenance vehicles and back-up  
generators), which contribute to its carbon footprint. The company has adopted an energy  
efficiency policy that includes improving energy performance and complying with energy  
efficiency regulations. CONPET S.A. maintains an ISO 50001 certified energy management  
system , demonstrating its dedication to systematic energy savings. Through this system the  
company closely monitors energy consumption, sets targets to reduce avoidable losses and  
invests in efficiency measures. The company's objectives include keeping the consumption of  
electricity and fuel in the transport process within the set quotas and technological consumption  
within the limits set for the transport process. In line with these objectives, CONPET S.A. is  
actively replacing old equipment with energy-efficient alternatives and optimizing processes to  
reduce energy consumption. Although the company has not yet publicly announced specific  
greenhouse gas reduction targets, it strives to achieve year-on-year improvements in energy  
intensity and carbon footprint. This approach is evidenced by the fact that in recent years key  
performance indicators related to technological consumption in transport operations and energy  
consumption have been met, indicating progress in efficiency efforts.  
Table 2.6. Environmental performance initiatives  
Initiative  
Impact  
Implement and maintain  
Environmental Management System  
(ISO 14001)  
Ensure compliance with environmental regulations  
and environmental issues are kept under control  
Implement and maintain Energy  
Management System  
(ISO 50001)  
Ensures regulatory compliance and Improves energy  
efficiency  
Reduces risks of accidental product loss and  
soil/water pollution  
Modernization of the NTS  
Offsets electricity consumption from conventional  
sources  
Investing in renewable energy  
Leak detection system  
Prevents environmental incidents  
22 I SUSTAINABILITY REPORT CONPET S.A.  
2. COMPANY OVERVIEW  
Renewable energy projects  
CONPET S.A. has installed a photovoltaic panel system at the secondary office  
(administrative office 2). By the end of 2022, the first phases of this project (design and  
procurement) were completed and the actual installation of the solar panels on the office building  
took place in 2023. This system covers approximately 27% of the site's electricity consumption,  
directly reducing grid consumption and associated emissions. Through these investments in  
renewable energy, CONPET S.A. not only reduces its carbon footprint, but also protects itself  
against volatile energy prices by generating some of its electricity in-house. The company has  
evaluated the results obtained as a result of the implementation of this project and has extended  
the use of solar energy to other locations (Constanța Sud and Călăreți), projects implemented in  
2024, which will be operational in the first part of 2025.  
ESG and innovation-oriented investments  
In addition to renewable sources of energy, CONPET S.A. has channeled capital expenditures  
into projects that support social and environmental outcomes. A prime example is the  
modernization of critical pipeline infrastructure to enhance safety and environmental  
protection. In 2023, CONPET S.A. completed a critically important project: the replacement of  
pipeline segments under the Danube River and the Borcea Arm. These new underground  
pipelines were built using modern materials and methods, reducing the risk of leaks in  
environmentally sensitive areas. The investment significantly improves the protection of water  
and soil resources as it ensures the continued safe operation of crude oil transport across the  
Danube, thus avoiding potential environmental damage from obsolete pipelines.  
Similarly, CONPET S.A. is undertaking a multi-year program of upgrading storage tanks and  
pumping systems - including a large crude oil storage tank recently commissioned at the Călăreți  
station - incorporating improved safety features and emission controls. These infrastructure  
upgrades not only reduce environmental risks and emissions (e.g. by minimizing steam losses  
and preventing accidental spills), but also improve operational efficiency. On the technological  
side, CONPET S.A. is investing in digital monitoring and control systems (SCADA) to optimize  
pipeline flow and quickly detect any anomalies, which improves both energy efficiency and  
incident prevention. The company's development strategy explicitly mentions the implementation  
of a leak detection system and the modernization of the control and data acquisition system as  
key strategic elements, emphasizing the integration of sustainability with operational excellence.  
In addition to environmental investments, ESG components extend to its and community. The  
company also focuses on social issues such as employee well-being, community involvement  
and ethical governance. Internally, CONPET S.A. promotes a safe and inclusive workplace.  
The company has an ISO 45001 certified occupational health and safety management system  
and has a target of "zero accidents" each year. Health and safety and security (H&S) training  
and instruction has led to accident prevention, which has been achieved in recent years. In  
addition, the company invests in the development of its human capital: employees benefit from  
continuous training programs to improve their skills and career development. CONPET S.A. also  
prioritizes the well-being of its employees, offering health maintenance programs, ensuring fair  
remuneration and promoting work-life balance. These efforts contribute to maintaining a  
motivated workforce and low staff turnover.  
23 I SUSTAINABILITY REPORT CONPET S.A.  
2. COMPANY OVERVIEW  
CONPET S.A.'s human capital strategy emphasizes continuity, diversity and professional  
development, integrating proactive retention measures and improving working conditions.  
By investing in training, promoting gender equity and active social dialog, the company  
ensures long-term stability and adaptation to the demands of a changing industry.  
SOCIAL RESPONSIBILITY (CSR) AND COMMUNITY INVOLVEMENT  
CONPET S.A. has a strong tradition of supporting the communities in which it operates. The  
company's CSR approach is based on transparency, stakeholder engagement and respect  
for the community and the environment. Through sponsorships and partnerships, CONPET  
S.A. contributes to various social causes, considering this an integral part of its sustainable  
development mission. In recent years, the company has sponsored numerous cultural,  
educational and health initiatives. For example, CONPET S.A. has supported prestigious  
cultural events such as the "Paul Constantinescu" National Music Competition and the "Toma  
Caragiu" National Theatre Festival, recognizing the importance of cultural heritage. It has also  
funded national health campaigns (improving public health awareness and services) and  
supported educational programs, including school competitions and academic olympiads for  
students. Sport is another area of involvement - the company has sponsored clubs and sports  
events, promoting healthy lifestyles and youth involvement in its community. The company  
carefully selects projects that meet the needs of the community and monitors the results, ensuring  
full transparency of expenditure by publishing an Annual Sponsorship Report on the company  
website. It emphasizes the effectiveness of sponsorship spending so that financial support  
generates tangible social benefits and provides real support to citizens. By maintaining an active  
dialogue with non-profit organizations and local authorities, CONPET S.A. directs its CSR efforts  
where they are most needed  
CONPET S.A. has implemented a ISO 9001 certified quality management system , which  
brings significant benefits in terms of transparency, process effectiveness and continuous  
improvement. This standard supports ESG governance through documented policies and  
processes, providing a clear framework for the effective management of operational activities.  
ISO 9001 also contributes to the identification and management of risks, ensuring the  
implementation of measures to control and improve organizational performance. In addition, ISO  
9001 supports the ESRS G1 requirements on control mechanisms, governance structures and  
business ethics through clear documentation of processes and the implementation of an effective  
monitoring system.  
In addition to this standard, CONPET S.A. has also implemented the requirements ISO 37001 for  
anti-bribery management system , reinforcing its commitment to transparency, integrity and  
ethical compliance. This system provides a rigorous framework to prevent, detect and  
combat bribery through strict internal control mechanisms and compliance measures.  
In the context of ESG Governance, the ISO 37001 certification ensures the company's credibility  
in the eyes of its stakeholders, contributing to an organizational climate based on ethics and  
responsibility. The application of these standards demonstrates CONPET S.A.'s firm commitment  
to operational excellence and corporate governance, strengthening the trust of investors and  
business partners.  
24 I SUSTAINABILITY REPORT CONPET S.A.  
2. COMPANY OVERVIEW  
The company follows corporate governance best practices with a structured approach risk  
management and ESG compliance. It also has a well-defined governance framework that  
balances state ownership interests, capital market requirements and professional management.  
CONPET S.A. will publish an annual sustainability report, in compliance with Romanian law and  
EU regulations, providing a transparent picture of its environmental, social and governance (ESG)  
impacts. The 2022 sustainability report highlighted the integrated policy on quality, safety, energy  
efficiency and key projects for pipeline security and community support. The company  
demonstrates its commitment by responsibly managing environmental impacts, investing in  
renewable energy, protecting employee health, and implementing sound corporate governance  
practices, thereby strengthening stakeholder trust.  
25 I SUSTAINABILITY REPORT CONPET S.A.  
Through dual  
materiality analysis  
CONPET S.A. turns sustainability  
challenges into strategic  
opportunities for the future.  
3. DUAL MATERIALITY ANALYSIS  
3.1 Legal framework and applied standards (CSRD, ESRS)  
The dual materiality analysis methodology applied by CONPET S.A. has been developed in  
accordance with the requirements of the European CSRD and ESRS Directives, with the aim of  
identifying and prioritizing sustainability impacts, risks and opportunities for the company and its  
stakeholders. It is based on a modular approach, assessing both the impacts on the  
environment and society (impact materiality) and the financial implications on the  
company (financial materiality), according to the requirements of ESRS 2 and ESRS 1. The full  
dual materiality analysis is available to interested parties on request.  
The Corporate Sustainability Reporting Directive (CSRD) expands the reporting  
requirements on ESG (environmental, social and governance) impacts and risks, with the  
main objective of providing consistent and comparable data for investors, consumers and other  
stakeholders, thus contributing to the achievement of the EU's climate and environmental  
objectives.  
26 I SUSTAINABILITY REPORT CONPET S.A.  
   
3. DUAL MATERIALITY ANALYSIS  
FIGURE 3.1 - Dual materiality diagram  
GENERAL DESCRIPTION OF THE METHODOLOGY USED  
The approach used by CONPET S.A. complies with the Delegated Regulation (EU) 2023/2772,  
which allows flexibility in the identification of material factors, using impact studies, secondary  
sources and scientific data, thus ensuring rigorous and transparent reporting.  
The methodology is carried out in four major steps, which allow collecting, analyzing and  
validating relevant data for determining significant ESG topics, therefore the materiality  
assessment process at CONPET S.A. was structured in four main steps:  
FIGURE 3.2 - Dual materiality diagram  
27 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
The steps of the dual materiality analysis process are detailed below:  
a. Identifying relevant topics for the company and its stakeholders  
At this stage, CONPET S.A. analyzed sources, including:  
International Standards and Regulations (ESRS).  
Review internal documents (policies, previous sustainability reports, ESG impact and risk  
assessments).  
Scientific research and industry reports relevant to energy.  
This assessment did not make use of performance benchmarking with other companies in  
the fuel transport sector, as the methodology applied was based on scientific studies, sector  
analysis and regulations, which provide an objective and comparable framework. Nor was the  
assessment of feedback from regulators and applicable regulations in the field of crude oil  
transport used. This has been done because according to IG Materiality 1 (Implementation Guide  
for Materiality Assessment), materiality analysis can be carried out without formal consultation  
with external stakeholders as long as credible and valid sources are used, and Delegated  
Regulation (EU) 2023/2772 confirms that companies can use existing data and secondary  
sources for materiality assessment without requiring direct involvement of external stakeholders.  
Thus, the analysis of investor and stakeholder requirements through benchmarking studies  
(comparative analysis) and the assessment of feedback from regulators and applicable fuel  
transport regulations were not included in the process, as ESRS 2 - SBM-3, paragraph 45 clarifies  
that the analysis can be based on alternative sources such as industry reports, scientific studies  
or internal data, ensuring compliance with ESRS.  
b. Stakeholder consultation and validation of material themes  
The stakeholder consultation was mainly conducted internally, with the aim of validating the  
identified ESG themes and ensuring their alignment with the company's vision.  
Methods used for consultation:  
Working meetings with internal entities (HSE, Human Resources, Transport Operations,  
Management).  
Questionnaires and semi-structured interviews with employees of different internal  
entities.  
In line with the methodology applied, no formalized external consultation was carried out in this  
reporting cycle. Analysis of investor and financial stakeholder requirements through  
benchmarking studies and assessment of feedback from regulators were not included in this  
process.  
c. Assessing impacts, risks and opportunities  
After identifying and validating the ESG themes, each material topic was assessed from a dual  
materiality perspective:  
28 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
Impact on environment and society (materiality of impact).  
Financial impact on the company (financial materiality).  
The impact assessment methodology has been developed based on the ESRS 2 SBM 3  
framework, applying the following criteria:  
Scoring by impact size: each ESG theme was assessed according to the size, duration,  
reversibility and severity of impact.  
Assessment of risks and opportunities: risks identified include regulatory costs,  
reputational risks and direct financial impact, while opportunities are related to operational  
efficiency and attracting green finance.  
Determination of financial significance: for each ESG theme, CONPET S.A. used a  
quantification system based on financial materiality thresholds established by analyzing  
the impact on operating income and expenses.  
The assessment led to a final list of material themes, presented in the List of Material  
Themes, which ranks each ESG theme according to its importance for stakeholders and  
the company.  
d. Prioritizing and integrating material themes into the strategy  
The final step in the process was to integrate the findings of the materiality analysis into the  
company's ESG reporting framework. This is accomplished by:  
Set specific ESG objectives and targets for each material theme.  
Link ESG themes to the company's business strategy and current risks/operations.  
Identify ESG performance indicators (KPIs) to monitor progress towards the objectives.  
As a result of this process, CONPET S.A. defines a clear ESG reporting framework, ensuring the  
correlation with the ESRS and other relevant international standards that will result in a  
sustainable development strategy.  
RESULTS OF THE METHODOLOGY  
As a result of applying the dual materiality methodology, CONPET S.A. has identified material  
themes grouped into the following categories:  
TABLE 3.1 Material themes according to ESRS  
Categories  
Material themes  
Climate change, Pollution, Water resources management,  
Biodiversity, Circular economy  
Medium (ESRS E1-E5)  
Working conditions, Social dialogue, Protection of human rights,  
Impact on local communities, Customer data privacy  
Corporate culture, Anti-corruption and bribery, Whistleblower  
protection, Supplier relationship management  
Social (ESRS S1-S4)  
Governance (ESRS G1)  
29 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
These themes were assessed and ranked based on the criteria of impact and financial  
materiality, resulting in a clear prioritization of ESG priorities for the company.  
Improvement actions taken in the cacul for the next time horizon:  
Extend stakeholder consultation process - Although the report mentions the  
involvement of internal stakeholders, a broader external consultation process (e.g.  
supplier surveys, meetings with local communities) would increase the credibility of the  
methodology and align CONPET S.A. with ESRS best practice standards.  
Assessment of financial scenarios for ESG themes - Quantitative modeling of the  
financial impact of ESG risks (e.g. impact of climate regulation on operational costs) would  
allow for more efficient allocation of resources and better strategic integration of  
sustainability.  
Continuous monitoring and regular updating of materiality - It is recommended that  
the materiality assessment be reviewed annually to take into account regulatory changes  
and global ESG developments.  
3.2 Assessment of dual materiality  
A comprehensive dual materiality assessment was conducted to identify the main ESG risks and  
opportunities affecting CONPET S.A. and its stakeholders.  
TABLE 3.2 Main material aspects of climate change  
Impact on environment and  
society  
Impact on the company (financial  
impact)  
Material aspect  
- Increased costs of compliance with climate  
regulations (e.g. carbon taxes, emission limits).  
- CONPET S.A.'s direct and indirect  
emissions contribute to global  
warming, having a negative effect on  
climate and ecosystems.  
Greenhouse gas  
emissions (GHG  
emissions and  
climate change  
mitigation)  
- Pressure from investors and authorities to  
reduce carbon footprint, with potential  
consequences for market value and access to  
finance.  
- Air pollution from CO₂ and other  
GHGs affects the quality of the  
environment in the long term,  
intensifying extreme weather events  
that can harm communities.  
- The need to invest in green technologies  
(renewable energy, energy efficiency) to avoid  
penalties and maintain competitiveness.  
30 I SUSTAINABILITY REPORT CONPET S.A.  
 
3. DUAL MATERIALITY ANALYSIS  
Impact on environment and  
Impact on the company (financial  
impact)  
Material aspect  
society  
- Infrastructure damage: extreme weather  
events threaten pipelines and pumping  
stations, potentially causing operational  
disruptions and high repair costs.  
- Climate change is increasing the  
frequency and intensity of extreme  
weather events (floods, droughts, heat  
waves) that can affect the environment  
and local communities.  
- Significant financial losses can result from  
natural disasters (in Romania, climate damage  
already amounts to billions of euros and is  
growing).  
- Extreme events can cause  
Physical climate  
risks (effects of  
extreme weather  
events)  
environmental accidents: for example,  
severe flooding can erode soil and  
cause oil spills, polluting the water  
and surrounding land.  
- Higher insurance costs and the need for  
emergency provisions.  
- Communities in the areas of  
operation are exposed to hazards (e.g.  
pollution, fires) if the infrastructure  
does not withstand the changed  
climatic conditions.  
Note: A major incident (e.g. a pipeline burst  
due to a landslide) would generate  
environmental and financial costs that may  
exceed the internal financial materiality  
threshold established (as set out in Annex I).  
- Market risk: Declining demand for fossil fuels  
in the long term (as the economy  
decarbonizes) may reduce the volumes of  
crude oil transported by CONPET S.A.,  
affecting revenues.  
- Climate benefits: The transition to  
low-emission energy (e.g. renewables)  
contributes to global climate goals by  
reducing air pollution and public health  
impacts.  
- Regulatory risk: European climate policies  
(Green Deal, Fit for 55) require emissions to  
be reduced by 55% by 2030 and climate  
neutral by 2050. For CONPET S.A., this  
means stricter environmental standards and  
possible additional capital costs for plant  
modernization.  
- Society as a whole benefits from  
climate change mitigation: a more  
stable climate, fewer natural disasters,  
improved long-term quality of life.  
Energy transition  
and climate  
regulation  
(transition risk and  
opportunity)  
- Local social impact: In areas where  
CONPET S.A. operates, adapting to  
the energy transition (e.g. cleaner  
technologies) can bring green jobs and  
sustainable development; conversely,  
an unexpected transition without  
preparation can affect employees and  
communities dependent on traditional  
activities.  
- Opportunities: Adapting the business model  
can open new directions - for example, using  
existing infrastructure to transport biofuels.  
Early investments in green energy can also  
provide a competitive advantage (lower long-  
term operational costs, access to green  
finance and funds for sustainable projects).  
31 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
Impact on environment and  
Impact on the company (financial  
impact)  
Material aspect  
society  
- Pipeline failures and exceedances of  
hydrocarbon indicators resulting from  
CONPET S.A.'s activity can have an  
impact on the environment and society - Possible environmental penalties or fines,  
if not kept within normal limits.  
especially for exceeding contamination limits  
or late reporting.  
- These forms of pollution can have  
long-term ecological effects, requiring - Damage to company reputation if incidents  
decontamination and soil remediation are publicized.  
works.  
Pollution  
- Costs with monitoring, assessment and  
- The responsible management of  
hazardous waste by CONPET S.A.  
contributes to reducing risks to public  
health and protecting the surrounding  
communities.  
intervention (e.g. excavation works,  
neutralization, relocation of contaminated soil).  
The emissions are structured into the following three areas of application:  
Table 3.3 Greenhouse gas emissions by area of application  
Scope 1 emissions  
Scope 2 emissions  
Scope 3 emissions  
2.630,41 tons COe  
4.451,10 tons COe  
11.825,08 tons COe  
generated by the electricity  
consumption required to  
operate the pumping stations  
and ancillary facilities of the  
pipeline system.  
representing other indirect  
emissions in the value chain  
(third-party logistics, business  
travel, goods and services  
mainly from the  
combustion of fuels for  
the company's own  
vehicles and facilities.  
purchased, waste management).  
32 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
These significant emissions underline the climate responsibility of CONPET S.A., highlighting the  
impact of its operations on the carbon footprint and the need to reduce it in order to minimize  
environmental impacts.  
Graph 3.1. - Percentage distribution of emissions  
by areas of application  
12,7%  
21,5%  
65,9%  
Scope 1  
Scope 2  
Scope 3  
From a broader social perspective, every ton of COe reduced contributes to avoiding the adverse  
effects of climate change (droughts, floods, extreme heat) that affect people and the environment.  
Local communities and the public expect energy operators to reduce their pollution and support  
efforts to combat global warming. Therefore, mitigating climate change (by lowering GHG  
emissions) is a central objective for the company, with direct benefits for the environment and  
society. CONPET S.A. has already started to implement important sustainable initiatives, such as  
energy efficiency projects and investments in renewable energy, such as the installation of  
photovoltaic panels at the administrative headquarters and other operational locations. Such  
measures contribute directly to reducing emissions, support the region's energy transition and set  
a positive example of engaging in responsible climate action . In addition, the company educates  
and engages its employees in sustainability actions (such as green skills training or participation  
in green volunteering activities), thus reinforcing an organizational culture oriented towards  
environmental and social responsibility.  
33 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
Table 3.4 Financial risks and opportunities of climate change  
Main climate risks with financial  
Outlook  
Main financial opportunities  
impact  
- Physical risks: Studies show that  
climate change jeopardizes the long-  
term reliability of oil infrastructure.  
Pipelines and facilities with decades of  
life are facing more severe events  
(extreme temperatures, hurricanes,  
floods, fires), increasing the risk of  
failures, leaks and unplanned  
shutdowns.  
- Adaptation and resilience: The Academy  
highlights the need to adapt infrastructure to  
new climatic conditions. Measures such as  
strengthening vulnerable pipelines,  
redesigning exposed routes, and operational  
continuity plans can mitigate disaster losses  
and are essential for long-term financial  
sustainability.  
- Transition risks: To reach climate  
targets, a substantial share of fossil  
fuels will be unusable  
Academic  
literature  
- Strategic transition: Opportunity to reuse  
existing infrastructure in the low-emissions  
economy - for example, technical research  
suggests that much of the gas pipeline  
networks can be retrofitted for hydrogen  
transport at only ~10-35% of the cost of  
building new ones. Such innovations can  
expand the business model of fuel transport  
companies, allowing them to remain relevant  
in the future energy mix.  
- For example, ~1/3 of global oil  
reserves are expected to remain  
untapped by 2050 according to a Nature  
study. This implies the risk that oil-  
related assets (fields, pipelines) will lose  
their value (stranded assets) as demand  
for oil falls. Oil companies also face  
market uncertainties (oil price volatility in  
the context of decarbonization) and  
possible legal costs related to climate  
responsibility.  
34 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
Main climate risks with financial  
Outlook  
Main financial opportunities  
impact  
- Financial and market risks: Advisory  
firms emphasize that failure to adapt to  
the climate transition erodes the  
value of companies. In recent years,  
under pressure from investors and lower  
demand forecasts, oil companies have  
seen massive write-downs on fossil  
assets  
- Efficiency and future-proofing: Adopting  
sustainable practices is seen as an  
opportunity to increase efficiency and  
future-proof the business. EY notes that  
implementing strategies to reduce emissions  
and "greener" operations contribute to future-  
proofing operations, i.e. maintaining long-term  
competitiveness in the context of the energy  
transition.  
Investors are redirecting capital to  
climate-resilient firms and governments  
are announcing policies to phase out  
fossil fuels (e.g. targets to phase out rich  
gas/diesel cars, ban new oil exploration)  
- Diversification and new markets:  
Consultancy  
(PwC, EY,  
McKinsey etc.)  
Consultants advise oil companies to diversify  
their portfolio by investing in renewable  
energy, biofuels, carbon capture, etc. to  
capitalize on the growth of these segments.  
For example, McKinsey points out that many  
O&G companies have committed to net-zero  
targets and are investing in technologies such  
as direct carbon capture from the air and low-  
emission solutions. A pipeline operator can  
explore new services - from transporting  
hydrogen or captured CO₂ to green  
- all of which threatens the long-term  
sustainability of oil-focused companies.  
- Regulatory and reputational risks:  
Consultants draw attention to the  
avalanche of new ESG regulations (e.g.  
CSRD, EU Taxonomy) that may impose  
costly compliance on oil companies.  
The reputation of these companies is  
also suffering as the public and NGOs  
demand swift climate action  
infrastructure management expertise - creating  
alternative revenue streams as the economy  
decarbonizes.  
- a risk that is difficult to quantify  
financially, but real (loss of social  
license, lawsuits, funding restrictions).  
35 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
In conclusion, the company faces significant climate risks:  
GRAPH 3.2. - Types of risks faced by CONPET S.A..  
PHYSICAL RISKS (IMPACT ON CONPET S.A. INFRASTRUCTURE)  
Climate change is intensifying extreme weather events that can directly affect the physical  
infrastructure of CONPET S.A. (the operator of the Romanian crude oil pipeline network).  
Globally, the frequency and severity of storms and floods are expected to increase, events that  
can damage oil extraction, production and transport infrastructure and disrupt the operation of  
crude oil pipelines. A report by Deloitte shows that 79% of global business leaders believe that  
the planet is at a tipping point and requires solutions to combat the effects of climate change,  
which is already negatively affecting businesses. For CONPET S.A., whose pipelines cross major  
watercourses and flood-prone areas, this risk is highly relevant. Adaptation measures are already  
being observed: for example, the company has completed a ~€26m project to replace and bury  
pipeline segments under the Borcea arm of the Danube (using horizontal directional drilling),  
significantly reducing the likelihood of leaks or damage caused by extreme floods. This  
modernization increases the resilience of the infrastructure to increased flows and protects  
continuity of supply.  
Other relevant physical risks include extreme temperatures and drought. Warmer climates can  
bring heat waves that stress infrastructure (expansion of pipelines, overloading of pumping  
equipment) and jeopardize the health of operating employees, possibly requiring temporary  
shutdowns. Changes in rainfall patterns - dry spells followed by heavy downpours - can cause  
subsidence or landslides that threaten pipeline stability. The literature emphasizes that these  
phenomena (heat waves, severe droughts, vegetation fires, permafrost melting in northern  
regions, etc.) pose major challenges throughout the oil supply chain, from downstream to  
36 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
transport and refining. A relevant example for Romania is the impact of extreme weather events  
on energy infrastructure. Major floods in the Danube basin can affect transport and storage of  
petroleum products, while vegetation fires in the Bărăgan can endanger pipelines and pumping  
stations. Such events can significantly disrupt CONPET S.A.'s operations, highlighting the  
vulnerability of critical infrastructure to climate change and associated risks. Physical risk  
management requires strategic adaptation.  
In international practice, energy companies are investing in the consolidation of vulnerable assets  
and business continuity plans. Through such measures, the risk of outages and property damage  
is minimized, thereby also protecting financial performance (avoiding repair costs or  
environmental penalties following an incident). It is worth noting that cost-benefit analysis at sector  
level supports these investments: investments in climate resilience bring net benefits in the  
long term, avoiding much higher losses in the event of a disaster.  
TRANSITION RISKS  
The global transition to a low-carbon economy poses substantial risks to the business model of  
fossil fuel-based companies such as CONPET S.A. A first set of risks is legislative and  
regulatory: increasingly ambitious climate policies may impose direct and indirect costs. For  
example, increasing the price of carbon (through CO₂ taxes or cap-and-trade systems) will  
penalize high-emitting activities. The oil sector, being a major contributor to emissions, will be  
significantly affected - carbon taxes increase operational costs and can erode companies'  
margins, affecting both profitability and the price of final oil products. CONPET S.A., although it  
would not directly pay a carbon tax on transported crude oil, may feel the indirect impact: higher  
electricity costs (if producers pay CO), higher auxiliary rail transport prices, or taxes on its own  
emissions from fossil fuel consumption in operations. In addition, new European regulations (e.g.  
ReFuelEU, stricter emission standards for fuels) may reduce the demand for petroleum products,  
thus reducing the volume of crude oil transiting the CONPET S.A. network.  
A second transition risk is the decline in demand for crude oil in the medium to long term,  
amid market and technological change. As electric vehicles displace traditional fuels (International  
Energy Agency (IEA) scenarios show the market share of electric vehicles (EVs) rising to over  
60% of car sales by 2030), and alternative energies (solar, wind) replace fossil fuels in the power  
sector, oil demand could peak and then fall. Academic research supports this outlook: a study  
published in Nature estimates that to keep global warming below 2°C, about a third of global oil  
reserves, half of global natural gas reserves and more than 80% of coal reserves would  
have to remain unused by 2050. This implies that many planned extraction projects will not  
materialize and the related infrastructure (including transport pipelines) risks becoming loss-  
making (financially unrecoverable) assets. With previous refining and petrochemicals closures,  
transport capacities are already under-utilized. In this context, a further fall or stagnation in crude  
oil demand could exacerbate this situation, reducing CONPET S.A.'s revenues and putting  
additional pressure on tariffs.  
37 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
Signs of these transition risks are already visible in the market, where investors and financiers  
are turning to companies with clear adaptation plans, reducing their exposure to climate risk.A  
McKinsey report notes that in the first three quarters of 2020, amid the pandemic and accelerating  
energy transition, oil majors in North America and Europe saw asset write-downs of around $145  
billion - about 10% of their market value - reflecting the expectation that some of their oil and gas  
reserves will no longer be exploitable profitably. At the same time, governments are taking  
unprecedented measures: for example, Denmark has announced the cessation of all North Sea  
oil operations by 2050. For CONPET S.A., whose business depends entirely on transporting  
crude oil to refineries, such developments signal the strategic risk of a gradual decline in long-  
term volumes and the potential erosion of its business model unless diversification takes place.  
In addition, technological innovation is a transition risk: advances in batteries, energy efficiency  
and alternative fuels may reduce oil's competitiveness. For example, if green hydrogen or next-  
generation biofuels become economically viable on a large scale, the transport requirement for  
crude oil could fall accordingly.  
Last but not least, there are legal and reputational risks. As public awareness of the climate  
emergency grows, oil companies face increasing scrutiny. Environmental organizations and civil  
society are pushing for accountability for the fossil industry - including through lawsuits against  
companies for climate damage or for failing to meet emission reduction targets. A relevant  
example is the Climate Action 100+ initiative, which brings together investors managing more  
than $50 trillion and calls for clear strategies from major emitters to align with the Paris Agreement  
targets. In this context, ignoring the energy transition is no longer an option, becoming a risk of  
losing social license: companies perceived as reluctant to change may lose public support, be  
excluded from certain sources of finance and incur higher capital costs. CONPET S.A. is aware  
of these risks and integrates them into its internal assessments, analyzing both compliance risks  
(such as new emission requirements, EU Taxonomy and ESG standards) and technological and  
market risks, including shifting consumer preferences towards low-emission alternatives.  
Opportunities (transition to a sustainable business model)  
While climate change poses serious risks, it also creates strategic opportunities for companies  
that adapt early. For CONPET S.A., the opportunities stem from its role as an intermediary in the  
energy chain - a role that can be expanded and reinvented in a decarbonized economy. A first  
opportunity lies in the transition to alternative and efficient sources, which can bring both cost  
reductions and new revenues. For example, reducing your own emissions by making pumping  
stations more efficient and using renewable energy not only reduces the risk of future carbon  
taxes but also lowers your operational energy costs. Experts emphasize that implementing  
sustainable strategies and reducing emissions can ensure the long-term sustainability and  
competitiveness of operations, making them more resilient in a context of increasingly stringent  
climate regulations.  
In the case of CONPET S.A., the company has already started energy diversification by installing  
a photovoltaic system at the secondary administrative headquarters, which was implemented and  
operated throughout 2024. This initiative makes it possible to partially supply its own consumption  
with green energy, thus reducing dependence on conventional sources. In addition, the system  
38 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
contributes to lower electricity bills and reduced emissions, providing protection against  
fluctuations in energy prices and the cost of carbon in the electricity sector.  
A second major opportunity is to extend the business model to the new needs of the energy  
transition. CONPET S.A.'s pipeline infrastructure and technical expertise can be leveraged in  
emerging areas, from green hydrogen transport to biofuels distribution or carbon capture and  
storage. CONPET S.A. is already exploring such directions - assessing the long-term potential of  
adapting certain pipelines or facilities for the transport of biofuels or other low-carbon liquids.  
While crude oil transport remains the core business for now, these forward-looking investments  
signal the company's commitment to evolve with the new energy landscape and reduce its  
reliance on carbon-intensive activities. Moreover, early involvement in hydrogen projects may  
position CONPET S.A. as a key partner in Romania's future green value chains.  
Last but not least, building resilience should also be seen as an investment opportunity. Capital  
spending to adapt infrastructure to climate change - for example, installing modern pipeline  
monitoring systems, replacing critical segments with next-generation ones - can prevent costly  
environmental incidents and unplanned outages, thereby protecting company value. In addition,  
insurance and reinsurance companies are starting to prioritize firms that have implemented robust  
climate risk management plans, which can lead to lower insurance premiums or more favorable  
coverage for those that have adapted their operations to climate change. IEA emphasizes that  
investing in resilience brings net benefits and strengthens overall energy security, so companies  
that act early can gain an advantage. CONPET S.A., through its program to modernize and  
integrate climate risks into its governance, is already building this resilience, which gives it a  
competitive advantage in the medium term.  
In conclusion, the impact of climate change on CONPET S.A. presents both opportunities and  
challenges, outlining a landscape of favorable and unfavorable aspects. On the one hand,  
physical risks threaten the integrity of the pipeline infrastructure and continuity of operations, while  
transition risks - from carbon policies to declining demand for crude oil - call into question the  
long-term viability of the fossil fuel-only model. On the other hand, there are real opportunities for  
business to redesign its future: the transition to alternative energy sources, increased  
resilience and innovation can become drivers for growth and adaptation. A balanced  
perspective, based on international data and analysis, suggests that oil companies that invest in  
sustainability and diversification today will be better positioned tomorrow - both to cope with  
intensifying climate risks and to thrive in a global economy on a decarbonization path. Through  
the steps already taken and planned, CONPET S.A. is demonstrating that it can leverage its  
experience and infrastructure to adapt to these changes, ensuring its relevance and financial  
stability in a changing climate.  
Relevant sources were consulted in the above analysis, including international organizations,  
academic studies and consultancy reports. International organizations provide key guidance for  
climate policy and sustainability, such as UNEP FI, Climate Action Network, Carbon  
includes the Katopodis et al. (2019) (Infrastructures) and McGlade & Ekins (2015) (Nature)  
studies, which examine the sustainability of infrastructures and the viability of fossil fuels. Advisory  
39 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
reports come from McKinsey, Ernst & Young (EY) and DNV, providing insights on  
decarbonization, ESG regulation and climate risks.  
These reports provide detailed analysis and applied scenarios on the energy transition and the  
risks and opportunities associated with implementing sustainable policies. They contribute to  
understanding market trends and to developing effective strategies for integrating Environmental,  
Social, and Governance (ESG) principles. Each of these sources has been used to ensure an  
informed and balanced approach to the topic covered in this section, and detailed references are  
available through the hyperlinks included.  
RESULTS OF THE MATERIALITY ANALYSIS  
As a result of the analysis, CONPET S.A. has identified a number of material themes on which  
this report focuses. The list below summarizes these themes, grouped by ESRS standard  
domains, together with an indication of the materiality perspective:  
TABLE 3.5 Main material themes (2024)  
Materiality  
ESRS domain  
E1 - Climate change  
E2 - Pollution  
Material theme  
perspectives  
Impact and financial  
risk  
Impact and financial  
risk  
Climate change (mitigation and adaptation,  
transition plan, energy and GHG emissions)  
Pollution (air, water, soil; pollution prevention and  
control)  
Water and marine resources (water consumption,  
discharges)  
E4 - Biodiversity and Biodiversity and ecosystems (impact on  
E3 - Water resources  
Impact  
Impact  
ecosystems  
E5 - Circular  
Economy  
ecosystems, land degradation)  
Circular economy (waste management, circularity  
targets)  
Impact and financial  
risk (opportunity)  
Working conditions (safe workplaces, health and  
safety, social dialog, collective bargaining, internal  
reporting mechanisms)  
Impact and financial  
risk  
S1 - Own workforce  
Employee development and equal opportunities  
(training, equal opportunities)  
Impact on local communities (community rights,  
community safety)  
Impact and financial  
risk (opportunity)  
Impact and financial  
risk (opportunity)  
S1 - Own workforce  
S3 - Affected  
communities  
S4 - Consumers and  
end-users  
G1 - Professional  
conduct  
G1 - Professional  
conduct  
G1 - Professional  
conduct  
Data protection and consumer information (data  
privacy, access to information)  
Impact (and potential  
risk)  
Impact and financial  
risk  
Corporate culture and organizational ethics  
Protection of public interest warnings  
Impact  
Impact  
Fight against corruption and bribery (prevention,  
detection, anti-bribery training)  
40 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
Materiality  
perspectives  
ESRS domain  
Material theme  
G1 - Professional  
conduct  
Supply chain responsibility (supplier relations,  
payment practices)  
Impact  
Table 3.6. ESRS topics and subtopics that were not considered material and the reasons  
for their exclusion (according to ESRS 1 IRO-2:54-59)  
Sub-sub-  
topics  
Domain  
Subjects  
Topics  
Sub-topics  
Reasons on lack of materiality  
The company does not operate  
in areas with sensitive  
biodiversity or near protected  
areas. There have been no  
direct interactions with  
vulnerable ecosystems and the  
assessments carried out do not  
indicate any relevant actual or  
potential impacts.  
Protected  
areas,  
vulnerable  
species,  
relations with  
NGOs  
ESRS E4 –  
Biodiversity  
and  
Ecosystem  
development  
and condition  
Impacts on  
biodiversity  
Environment  
ecosystems  
CONPET S.A. does not utilise or  
extract marine resources; all  
activity takes place on land, in  
continental areas. Therefore,  
there is no impact associated  
with the topic.  
ESRS E3 –  
Water and  
marine  
Marine  
resources  
Marine  
extractions  
Marine water  
for operations  
Environment  
resources  
ESRS E3 –  
Water and  
marine  
Accidental or There are no spills or operations  
Spills in  
marine  
environments  
Marine  
resources  
controlled  
marine  
in marine ecosystems. The  
infrastructure is not located in  
coastal or marine areas.  
Environment  
resources  
pollution  
The company's suppliers and  
Secure jobs, partners are exclusively local or  
ESRS S2 –  
Value chain  
workforce  
Workers'  
rights in the  
value chain  
Working  
conditions  
forced labour,  
freedom of  
EU-based, with similar  
compliance obligations. No  
Social  
association  
relevant exposure or value chain  
labour risks have been identified.  
41 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
Sub-sub-  
topics  
Domain  
Social  
Subjects  
Topics  
Sub-topics  
Reasons on lack of materiality  
No incidents, risks or concerns  
expressed by local communities  
regarding these rights have been  
identified. The company  
operates in industrial zones with  
minimal exposure to  
Discrimination,  
access to  
justice,  
fundamental  
freedoms  
ESRS S3 –  
Affected  
communities  
Civil and  
political  
rights  
-
fundamental rights risks.  
The company does not deliver  
products or services directly to  
end consumers. The business is  
B2B, with no direct interaction  
with end-users that creates  
health or safety risks.  
ESRS S4 –  
Consumers  
and end-users  
Health and Products and  
Social  
User safety  
safety  
services  
The company is state-controlled  
and operates under the national  
tax reporting framework. There  
are no tax-avoidance schemes  
or cross-border activities giving  
rise to tax risks.  
ESRS G1 –  
Governance Professional  
Tax structure,  
Tax strategies tax avoidance,  
transparency  
Business  
practices  
conduct  
There is no political lobbying and  
the donation policy does not  
include contributions to political  
parties or affiliates. There were  
no activities with significant  
political influence.  
Lobbying,  
donations,  
public  
interactions  
ESRS G1 –  
Governance Professional  
conduct  
Political  
influence  
-
Below, we present a detailed analysis of each material theme, highlighting their  
implications and impact in the context assessed.  
MEDIUM (ESRS E1 - E5):  
Climate change (ESRS E1)  
Impact on the company: Climate change is a major issue with dual materiality for the company.  
From a financial perspective, CONPET S.A. faces significant climate risks: both physical risks  
(e.g. extreme weather events affecting infrastructure) and transition risks (stricter emission  
regulations, carbon taxes, etc.). The internal analysis highlights the absence of a climate transition  
plan aligned to the Paris Agreement and the lack of clear emission reduction targets, which is a  
strategic risk for the future. In 2024, the company reported no direct losses from climate change,  
but these risks may affect both operating costs (e.g. through increased environmental taxes) and  
revenues in the medium term if not proactively managed.  
42 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
Impact on the environment and society: The company's activity (transport of crude oil through  
pipelines and CF) contributes to the emission of greenhouse gases (GHG) through the  
consumption of fossil fuels for transport and natural gas for heating. These air pollutants have a  
direct effect on the global climate. The analysis to 2024 revealed a current negative impact  
related to GHG emissions generation, exacerbated by the lack of an integrated strategy to reduce  
emissions across all application areas (1, 2 and 3). On the other hand, incipient positive impacts  
were also noted: the company has initiated actions to use renewable energy sources and increase  
energy efficiency, which indicate steps towards reducing the carbon footprint.  
Risks: The main climate risks for CONPET S.A. are regulatory and reputational - for example,  
stricter environmental regulations may impose additional costs or production limits. Also, the lack  
of a transition plan increases the risk that investors or partners may consider the company  
unprepared for the low-emission economy. Opportunities: Investments in climate change  
mitigation (e.g. retrofitting equipment to reduce emissions, alternative energy sources) represent  
opportunities for efficiency and accessing green transition funds. Early adoption of green  
technologies can also improve a company's image as a sustainable operator. A relevant example  
in the industry is the trend for major oil companies to set climate neutrality targets - showing the  
importance of integrating climate change into business strategy (CONPET S.A. can follow a  
similar path, adapted to the crude oil transport sector).  
Pollution (ESRS E2)  
Impact on the company: Environmental pollution, in the form of accidental hydrocarbon spills,  
is an operational and compliance risk for CONPET S.A.. In 2024, financial risks associated with  
land, air and water pollution have been identified - for example, pipeline leaks can incur significant  
penalties and remediation costs. The company has implemented strict pollution prevention and  
monitoring policies and procedures precisely to reduce the incidence of such events and comply  
with environmental regulations. The effectiveness of these measures is reflected in the fact that  
no major incidents of uncontrolled pollution were reported in 2024, a sign that prevention  
systems are working as expected. However, the risk remains as long as the transport  
infrastructure involves old pipelines and hazardous substances.  
Impact on the environment and society: CONPET S.A.'s current negative impact on the  
environment comes mainly from crude oil pollution of the soil, caused by possible underground  
pipeline failures. Such events contaminate land, affecting soil and groundwater quality, with  
consequences on local ecosystems and potentially on rural communities (degraded agricultural  
land, drinking water pollution). The operation of pumping stations also involves air emissions  
(generator exhaust gases, volatile compounds), but the company actively monitors these  
emissions and wastewater discharges to maintain legal compliance. On the positive side,  
CONPET S.A. has developed an effective environmental management system with pollution  
prevention and control procedures and continuous monitoring, which significantly reduces the  
frequency and severity of pollution incidents.  
Risks: A major pollution incident (e.g. a major pipeline failure) would result in substantial greening  
costs, possible legal penalties and damage to the company's reputation as a responsible operator.  
43 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
Strict pollutant regulations may also require additional investment in emission control technology.  
Opportunities: Good performance in pollution prevention provides an opportunity for the  
company to demonstrate its commitment to the environment - for example, maintaining ISO 14001  
environmental certification and promoting a clean operating record can strengthen relationships  
with customers (refineries) and authorities. Innovations in early leak detection technologies (IoT  
sensors on pipelines) can be an opportunity to minimize risks and reduce costs in the long term  
if implemented.  
Water and marine resources (ESRS E3)  
Impact on the company: The management of water resources is a material issue mainly from  
an impact perspective and less as a direct financial risk. The operation of the pipeline network  
does not consume large volumes of water directly, but CONPET S.A. uses water for certain  
processes. There was a negative impact related to the extraction of water from its own  
boreholes in areas with high water stress (Videle, Cartojani, Constanța C2) - i.e. in some  
regions where water resources are limited, the company withdraws groundwater for operational  
use, potentially affecting local availability. This may create future restrictions or costs (e.g. if the  
authorities impose extraction limits or higher tariffs). On the other hand, the immediate financial  
risks for CONPET S.A. are low, as the cost of water is not significant in the cost structure, and no  
outages due to water shortages have been reported in 2024.  
Impact on the environment and society: The impact of CONPET S.A.'s operations on water is  
manifested through potential accidental pollution of surface or groundwater (from oil spills)  
and consumption of water from local resources. The materiality analysis shows that the  
company has internal procedures in place for responsible water management, including  
measures to prevent accidental pollution and constant monitoring of water consumption and  
quality. These actions are having a positive impact: in 2024 there were no significant water  
pollutions due to CONPET S.A., a sign that prevention is working. At the same time, water  
consumption is monitored to avoid waste. However, water withdrawals in vulnerable areas  
remain a concern as they can impact local communities (wells, irrigation) if not well managed.  
Risks: Accidental water pollution (e.g. contamination of a river due to a burst pipe) would cause  
environmental damage and possible penalties. Also, in the context of climate change, water  
resources are becoming more precious - there is a risk that future access to water for operations  
will be limited or more expensive. Opportunities: By reducing its own water consumption and  
using water recycling technologies (e.g. for washing equipment), CONPET S.A. can achieve  
savings and improve its environmental performance. Also, by maintaining a clean (pollution-free)  
water record, the company strengthens its relations with local communities and compliance with  
stakeholder expectations.  
Biodiversity and ecosystems (ESRS E4)  
Impact on the company: Biodiversity is a material issue through the environmental impact of  
CONPET S.A.'s activities, rather than through immediate direct financial risks. The operation of  
crude oil pipelines crosses different terrestrial ecosystems; an incident (such as a major crude oil  
44 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
spill) may entail environmental remediation costs and legal obligations to restore habitats. In 2024,  
the company did not incur any biodiversity-related penalties, a sign that no serious events  
affecting ecosystems occurred. However, awareness of these risks is important: protected areas  
or sensitive species in the vicinity of infrastructure could lead to operational restrictions if not  
properly managed (e.g. restrictions on maintenance works during certain wildlife breeding  
periods).  
Impact on the environment and society: The main potential negative impact on biodiversity  
comes from soil and water pollution from oil spills. The analysis shows that oil spills can cause  
land degradation and damage to soil and water organisms, disrupting local ecosystems. In  
practice, soil contaminated with hydrocarbons loses its fertility, affecting vegetation and small life  
forms, which can have kn knock-on effects on the local ecosystem. If remediation work is not  
carried out, such incidents can have long-term environmental consequences. In order to prevent  
these effects, CONPET S.A. intervenes through authorized companies, carrying out greening  
works that ensure the restoration of the affected land and its reintegration into the natural circuit.  
Risks: A pollution event affecting biodiversity (agricultural land, forests or water) may result in  
loss of community trust and intervention by environmental authorities, with potential temporary  
shutdowns until remediation. Opportunities: Active involvement in protecting biodiversity (e.g.  
partnering with NGOs to plant trees along pipeline corridors) could bring significant reputational  
benefits. Such actions would demonstrate environmental responsibility and could reduce public  
opposition to future infrastructure expansion.  
Circular Economy - Waste (ESRS E5)  
Impact on the company: The management of waste, especially hazardous waste resulting from  
the operation of the pipeline system, is material both in terms of environmental impact and  
potential operational efficiency. CONPET S.A. generates hazardous waste (waste oil, oil sludge,  
contaminated soil) from the maintenance and operation of facilities. The associated negative  
impact is the quantity of these wastes and the risk of pollution if not properly managed.  
Throughout 2024, the company has maintained rigorous waste management according to the  
"waste hierarchy" - prevention, reuse, recycle, recover before disposal. This proper management  
reduces the risks of penalties and long-term costs (e.g. landfill or decontamination costs).  
Furthermore, treating hazardous waste correctly is essential to maintain operating licenses and  
avoid legal problems.  
Impact on environment and society: The positive impact noted in 2024 is that the waste  
generated by CONPET S.A. is treated according to legal requirements and good practices, most  
of it being recovered or recycled rather than disposed of as such. The company keeps  
transparent records on the quantities and types of waste, demonstrating accountability and  
traceability. This contributes to the circular economy by putting some materials back into the loop  
(e.g. oil recovery, recovery of scrap metal from pipe replacement). However, the generation of  
hazardous waste remains an unavoidable negative impact of oil activities. Any incident of  
improper disposal could lead to soil or water pollution. No such incidents were recorded in 2024,  
indicating effective control.  
45 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
Risks: Increases in hazardous waste could increase management costs and environmental  
liabilities. Future regulations could impose tougher recycling targets or ban certain practices (e.g.  
disposal of sludge in landfills). Opportunities: Waste management can bring financial and  
operational benefits if properly optimized. For example, waste can be processed by third parties  
into usable products, helping to reduce costs. However, in the case of oil slate, processing in a  
fiscal warehouse under the Fiscal Code can involve significant costs, without generating direct  
revenues for CONPET S.A., but only operational expenses. In this context, the company can  
explore waste-reducing technologies, such as more efficient filters and sustainable materials, thus  
contributing to both optimizing costs and improving its ESG score, an important aspect for  
investors.  
SOCIAL (ESRS S1 - S4)  
Detailed social impact analysis according to ESRS S1 - S4:  
Working Conditions - Health, Safety and Industrial Relations (ESRS S1)  
Impact on the company: CONPET S.A.'s own workforce is an important asset and good working  
conditions lead to productivity and organizational stability. In 2024, a positive impact has been  
observed by providing a stable and fair working environment with a competitive wage policy and  
extensive employee benefits. The company offers secure and stable jobs, protecting employees  
from economic risks by paying social contributions (pension, health, unemployment) and  
respecting their rights. This has resulted in high staff satisfaction and retention in 2024. Social  
dialog is also well reinforced, which provides employees with representation and structured  
communication channels. Collective bargaining through the Collective Bargaining Agreement  
(CBA) ensures transparency and fair resolution of labor issues, contributing to a stable  
organizational climate. All this strengthens the culture of employee protection and reduces labor  
conflicts.  
Impact on the environment and society: High-standard working conditions have a positive  
social impact beyond the company's gates, as they promote the well-being of 1,398 employees  
and their families. CONPET S.A., through its personnel policies, contributes to the development  
of the local community (employees have financial stability, purchasing power, access to health  
services through insurance, etc.) In addition, a safe and healthy working environment is also  
reflected in the company's reputation as a responsible employer. In 2024, there were no  
occupational accidents at CONPET S.A., which indicates the effectiveness of the implemented  
Occupational Health and Safety (OHS) measures. However, the risk of accidents is not  
completely eliminated, given the nature of operations (flammable substances, heavy industrial  
equipment). The potential impact of a major accident would be significant, affecting not only the  
employee, but also the community (through loss of trust) and the company's business.  
Risks: The main risks in the area of working conditions relate to the safety and health of  
employees. A serious incident (explosion, technical accident) could have major human and  
financial consequences, including interruption of operations. Ineffective management of working  
time and schedule can also lead to fatigue, human error and work tensions - this has been  
46 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
highlighted as a potential financial risk (low efficiency, paid overtime). Opportunities: A safe and  
satisfying work environment leads to increased productivity and employee loyalty. CONPET S.A.  
has the opportunity to strengthen its prevention culture through regular SSM training,  
emergency drills and continuous improvement of working conditions (ergonomic equipment,  
modern technology to take over dangerous tasks). Harmonious labor relations can also serve as  
an example in the industry, increasing the company's attractiveness on the labor market.  
Employee development and equal opportunities (ESRS S1)  
Impact on the company: Investing in employee training and skills development has a direct  
positive impact on CONPET S.A.'s long-term performance and sustainability. In 2024, the  
company continued to organize employee training programs tailored to specific needs (technical,  
SSM, management, etc.). These initiatives improve the skills of the workforce, increase  
productivity and the quality of transport system operation. Training programs are also accessible  
to all categories of staff, promoting equal opportunities for career development and  
advancement. In 2024 an inclusive, non-discriminatory working climate was maintained, with the  
company having policies against any form of unequal treatment. This reinforces organizational  
stability and reduces staff turnover as employees feel valued and have prospects for  
advancement.  
Impact on the environment and society: Through continuous employee training, CONPET S.A.  
contributes to the growth of human capital in the region. Better qualified employees also benefit  
communities - they become specialists who can share knowledge, have higher job satisfaction  
and improved living standards. Internally promoted equal opportunities reflect a positive social  
impact, ensuring fair treatment regardless of gender, age or other criteria. Although these effects  
are harder to quantify at macro level, at micro (company) level they translate into better social  
cohesion and an example of good practice in labor relations. In 2024 no cases of discrimination  
or complaints of unequal opportunities were reported, suggesting the effectiveness of existing  
policies.  
Risks: If skills development were neglected, there would be a risk of a shortage of critical skills  
in the company in the medium term (particularly as experienced staff retire). This could affect  
operational performance and safety. Lack of development prospects may also lead to talent  
leaving for other companies. Opportunities: Employee training is seen as a financial  
opportunity in itself - by increasing efficiency and reducing incidents/errors, the company saves  
money and improves its services. Materiality analysis included skills development as an  
opportunity to create value. Moreover, by promoting diversity and equality (e.g. equal promotion  
opportunities for all employees), CONPET S.A. can innovate and make better decisions,  
benefiting from varied perspectives.  
Impact on local communities (ESRS S3)  
Impact on the company: The safety of the communities in the areas crossed by the pipelines is  
a major material concern, intrinsically linked to the safety of CONPET S.A. operations. A serious  
incident (e.g. an explosion, fire or widespread pollution) would affect local communities and, by  
47 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
extension, the company's relationship with those communities and authorities. In 2024, no major  
incidents affecting communities were reported due to the strict prevention measures  
implemented. CONPET S.A. operates an extensive network of pipelines crossing many localities;  
therefore, the company maintains emergency response plans and collaborates with the  
authorities (ISU, local authorities) to ensure a rapid response. From a financial perspective, good  
relations with communities represent intangible capital: they ensure continuity of operations  
(without protests or local opposition) and reduce the risk of litigation. The materiality analysis  
indicated that managing community impacts well can be seen as an opportunity to strengthen  
the company's "license to operate".  
Impact on environment and society: Local communities may be affected by CONPET S.A.  
activity in several ways: risks of accidents with physical impact (fires, explosions, water/soil  
pollution affecting public health and the local environment) or operational inconveniences (noise,  
maintenance works). The potential negative impact on communities is mainly related to  
operational incidents - accidental oil spills, fires or explosions may endanger the population and  
property. CONPET S.A. has shown that it addresses these risks seriously: advanced pipeline  
monitoring technologies, rigorous maintenance and staff training significantly reduce the  
likelihood of incidents. Thus, in recent years (including 2024), there have been no emergencies  
with serious impacts on communities, which highlights a contained impact. However,  
communities remain vigilant and the company is constantly monitoring this issue as infrastructure  
expansion increases the potentially affected area.  
Risks: Any major accident would have immediate effects on communities (evacuations, water  
pollution, potential casualties), generating an image crisis for CONPET S.A. and possible legal  
action. Tensions with communities may also arise if they feel that they are not sufficiently informed  
or compensated for the risks they assume by hosting the infrastructure. Opportunities: Open  
and accountable conduct with communities presents an opportunity to build public trust. The  
analysis showed that involving communities and respecting their rights can be seen as  
opportunities (e.g. community dialogue, social projects). CONPET S.A. can initiate community  
programs (pipeline safety education, local social investments) to compensate for inconveniences  
and improve relations. A community that perceives the company as a reliable partner will more  
easily support future projects (rehabilitations, new pipeline routes).  
Data Protection and Consumer Information (ESRS S4)  
Impact on the company: although CONPET S.A. does not directly serve individual "consumers"  
(being a B2B operator, with customers such as refineries), the S4 theme is relevant in terms of  
personal data protection and transparent communication with service users. In 2024, the  
company has prioritized GDPR compliance and cybersecurity, with rigorous measures in place to  
protect the personal data of employees, customers and partners. The potential negative impact  
identified is the risk of personal data being lost or compromised in the event of a security breach,  
which would harm customers and/or employees by exposing their information. Such an incident  
would also have repercussions for the company - loss of trust, possible fines and reputational  
damage. In 2024, there were no major cybersecurity incidents or data leaks at CONPET S.A.,  
but threats of this type are on the rise globally. The company recognized that while risk cannot be  
48 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
completely eliminated, it is proactively managed through advanced IT security systems, strict data  
access policies and incident response plans.  
Impact on the environment and society: For society as a whole, respect for the right to privacy  
and accurate consumer information are essential aspects of sustainability. In the case of  
CONPET S.A., ensuring data privacy helps to protect individuals (employees, partners) from  
potential abuses or frauds that could result from leaked information. Although the company does  
not sell a product directly to the public, it does provide information to customers and the public  
(crude oil transport reports, safety-related communications) - maintaining the transparency and  
accuracy of this information is a trust factor. A positive impact in 2024 was the continuity of  
transparent reporting and responsible corporate communications, with no incidents of  
misinformation or complaints from customers about lack of information.  
Risks: A cybersecurity incident remains a latent risk - the compromise of personal data can attract  
significant GDPR fines and damage relationships with business partners. Likewise, any  
miscommunication or opaqueness to customers about transport services could undermine their  
trust. Opportunities: Continued investment in information security (technology and staff training)  
and obtaining cybersecurity certifications can become a competitive advantage - customers will  
prefer an operator that they know is protecting their data and operating to high IT standards. At  
the same time, CONPET S.A. can capitalize on its transparency: publishing environmental and  
safety performance data to stakeholders shows accountability and can prevent misinformation.  
By being proactive in communicating, the company can avoid rumors or unfounded public fears.  
GOVERNANCE (ESRS G1)  
Detailed social impact analysis according to ESRS G1:  
Corporate culture and organizational ethics (ESRS G1)  
Impact on the company: the corporate culture of CONPET S.A. - defined by values, ethical  
principles and organizational practices - has a positive material impact on employee morale  
and implicitly on the company's performance. In 2024, the work environment at CONPET S.A. is  
described as positive and motivating, based on fair and transparent policies towards employees.  
This leads to high productivity and retention of valuable staff. A culture that promotes integrity,  
meritocracy and mutual respect contributes to workforce commitment to the company. From a  
financial perspective, corporate culture relates directly to risks such as corruption, fraud or non-  
compliance - a strong ethical culture reduces the likelihood of non-compliant behavior. Dual  
materiality is present: 'corporate culture' and business conduct have been identified as a risk  
factor (if deficient) for the company. The absence of major deviations in 2024 suggests the  
maintenance of a stable and balanced climate.  
Impact on environment and society: A strong organizational culture, centered on ethics and  
professionalism, has positive effects beyond the company. CONPET S.A., as an important  
economic entity, influences the local business community - by setting an example in corporate  
governance. If employees are treated fairly and encouraged to adhere to high standards, this is  
49 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
also reflected in the way they interact with customers, suppliers and authorities. An ethical culture  
helps to prevent malpractices (intentional pollution, bribery, favoritism), thus having an indirect  
positive impact on society (the environment is better protected, local communities are respected,  
the economy runs cleaner). In 2024, CONPET S.A. maintained its reputation as a company with  
integrity, which is also evidenced by the absence of public scandals or criminal investigations.  
Risks: Any weakening of the corporate culture and ethical standards could expose the company  
to risks such as decreased trust from employees, partners and authorities, increased vulnerability  
to corruption and fraud, as well as possible financial and reputational consequences, affecting  
long-term stability and sustainability. Opportunities: A strong corporate culture aligned with  
rigorous ethical principles represents an opportunity to attract and retain valuable talent,  
strengthen relationships with partners and authorities, and improve access to sustainable  
financing, positioning the company as a model of responsible governance in the energy sector.  
Protection of whistleblowers (ESRS G1)  
Impact on the company: The existence of an effective mechanism for the protection of  
whistleblowers demonstrates CONPET S.A.'s commitment to transparency and compliance with  
ethical principles. The company has in place an operational procedure dedicated to  
whistleblowers, updated in 2023, in relation to the specific legislation in force on the protection of  
persons reporting violations of the law. Also, on Conpet S.A.'s own website, whistleblowers have  
the possibility to report violations of the law using the external reporting channel to the Ministry of  
Energy. This positive impact is to create a safe framework for employees and other parties to  
report violations of the law or code of conduct without fear of retaliation. As a result, the risks of  
corruption and fraud are better prevented, as potential problems can be identified early. In 2024,  
there were no notable cases of whistleblowing at CONPET S.A., which may indicate either the  
absence of major integrity incidents or their discreet internal resolution. Importantly, the  
mechanisms are in place and reinforce employee and stakeholder confidence in the company's  
governance.  
Environmental and social impact: Whistleblower protection has a positive impact on society by  
discouraging illegal or immoral practices. If CONPET S.A. employees can report irregularities  
(e.g. non-compliance with safety rules, hidden pollution, corruption) knowing that they are  
protected, the company becomes more responsible towards the environment and the community.  
In this way, the warning mechanism serves the public interest by ensuring that potential problems  
that could affect society are not covered up. CONPET S.A.'s initiative to align its policy with the  
Whistleblower Protection Act contributes to a culture of integrity that goes beyond the boundaries  
of the organization, setting an example for other entities.  
Risks: Without adequate whistleblower protection, the company would be at risk of employees  
failing to report critical issues in a timely manner, which could worsen the consequences (e.g.  
undetected fraud can result in large losses, a non-compliant environmental practice can lead to a  
disaster). Opportunities: By strengthening the early warning system, CONPET S.A. can discover  
and internally remedy malfunctions before they escalate or become public. This saves costs and  
reputation. Also, being a whistleblower-protective company can improve governance ratings  
50 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
and attractiveness to ethically concerned investors. In the context of the new EU legislative  
requirements on whistleblowers, CONPET S.A. is positioned ahead of the curve, which is an  
opportunity to easily comply and avoid sanctions.  
Fighting corruption and bribery (ESRS G1)  
Impact on the company: Preventing and combating corruption is essential for CONPET S.A.,  
given its nature as a state-owned/listed company and exposure to public contracts. The materiality  
analysis shows a major positive impact of the implemented anti-corruption measures: in 2024  
there were no incidents of bribery or corruption within the company. CONPET S.A. has an  
effective compliance framework aligned with the National Anti-Corruption Strategy 2021-2025,  
which includes clear reporting mechanisms, regular staff trainings and continuous monitoring.  
This framework significantly reduces the risks associated with corruption and ensures an ethical  
and transparent business environment. The benefits for the company are multiple: avoiding  
financial losses through fraud, maintaining access to finance (many investors impose anti-  
corruption criteria) and protecting corporate reputation. In addition, the integrity of the supply chain  
is strengthened by imposing these standards on suppliers.  
Impact on environment and society: Fighting corruption also has beneficial effects on society.  
A corruption-free company delivers services more efficiently and at fair cost, contributing to the  
national economy in an honest way. In the case of CONPET S.A., avoiding bribery and fraud  
means that the company's financial resources (including those derived from tariffs paid by  
customers, and thus indirectly by the company) are used for their intended purpose, not diverted.  
Also, through the integrity of its operations, CONPET S.A. contributes to the wellbeing of the  
business community - contractors know that they have to play by the rules, so competition for  
contracts is fair. The fact that there were no corruption cases in 2024 means that the associated  
negative impacts (loss of public trust, local economic damage) were avoided. We can say that it  
is a significant positive impact: the company's reputation and business relations have been  
protected from corruption attempts.  
Risks: Corruption is a severe risk - a single incident (e.g. a case of bribery) could lead to loss of  
shareholder and public trust, a decrease in market value and legal consequences (fines, criminal  
cases). It would also jeopardize good internal governance, creating a toxic organizational  
climate. Opportunities: Being proactive in preventing corruption, CONPET S.A. benefits from the  
opportunity of a clean business environment around it - trustworthy business partners will be  
attracted and those seeking illicit gains will stay away. The company can pursue regular anti-  
corruption training as an opportunity to educate and sensitize employees and partners, creating  
a local business community that shares the same ethical standards. Fair anti-corruption  
performance can be highlighted in reports and communications, enhancing the value of the  
responsible company brand.  
51 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
Supply Chain Responsibility (ESRS G1)  
Business Impact: Working with local suppliers and ensuring responsible sourcing practices has  
been identified as a material theme in 2024, with a major positive impact for both CONPET S.A.  
and the local economy. The company depends on a variety of suppliers (equipment, maintenance  
services, rail transport, etc.), and through rigorous selection and monitoring procedures, ensures  
that the supply chain is efficient and integral. For the company, a reliable supply chain means  
fewer operational disruptions and greater flexibility. Transparent business relationships (no unfair  
payment practices or favoritism) also ensure timely delivery of the resources needed to operate.  
Impact on the environment and society: by focusing on local and fair suppliers, CONPET S.A.  
has a positive impact on society: it stimulates regional economic development and creates  
value in the communities where it operates (suppliers can grow their businesses, hire staff). The  
on-time payment practices and predictable contracts offered by CONPET S.A. contribute to the  
financial stability of these smaller firms, with a multiplier effect in the local economy. Also, by  
imposing ethical and quality standards in the supply chain, the company extends the culture of  
compliance and responsibility to its partners. On the environmental side, working closely with  
suppliers can lead to more sustainable solutions - for example, purchasing less polluting  
equipment from suppliers or recycling materials used in pipeline maintenance in partnership with  
them. In this way, positive impacts are transmitted vertically up the value chain.  
Risks: Dependence on certain sole suppliers can be a risk (if one has financial or integrity issues,  
it can affect CONPET S.A. projects). Also, if a supplier does not comply with environmental or  
labor standards, it may entail chain liability for CONPET S.A. (reputational and compliance risk).  
Opportunities: By maintaining and expanding its network of reliable local suppliers, CONPET  
S.A. has the opportunity to optimize its costs (by shortening logistic chains) and to innovate (by  
working with partners that can offer customized solutions). Developing supplier sustainability  
assessment programs (including ESG criteria in procurement) could be the next step, ensuring  
that the entire supply base meets the standards of future CSRD reporting. Through a responsible  
supply chain, the company increases its overall resilience and contribution to sustainability  
horizontally.  
CONCLUSIONS  
In reviewing the results of the 2024 dual materiality analysis, CONPET S.A. has identified a clear  
set of material themes according to ESRS standards, reflecting both the environmental and  
social impacts of its operations and the financial risks and opportunities arising from the  
sustainability context. The year 2024 was characterized by operational stability and the absence  
of major incidents in critical areas (workplace accidents, catastrophic pollution, incidents of  
corruption), indicating the effectiveness of the company's current management. The analysis  
highlighted areas for improvement based on existing data and practices.  
TABLE 3.7. Key findings dual materiality analysis  
52 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
CONPET S.A. enjoys a positive internal climate, with protected,  
well-trained and involved employees (intensive social dialog, training  
programs). The organizational culture promotes integrity and safety,  
as evidenced by the absence of SSM incidents in 2024 and any  
cases of corruption or fraud. These strengths provide a solid  
foundation for long-term sustainability and significantly reduce  
operational and reputational risks.  
Strong social and  
governance  
performance  
In 2024, the environmental impacts (GHG emissions, pollution,  
waste) were managed according to legal requirements and did not  
produce any critical events. However, climate and environmental  
challenges require the company to take a more proactive strategic  
approach. The lack of a climate transition plan and decarbonization  
targets is an identified pain point. Also, issues such as biodiversity  
and water supply require continuous monitoring, even if they have  
not currently generated problems (prevention remains essential to  
avoid potential future incidents).  
Environmental impact  
under control, but  
long-term vision  
needed  
Double materiality confirmed for 9 out of the 23 themes identified  
with both an impact and a financial dimension. For example, climate  
change affects the global community through the company's  
emissions, but also entails financial risks for CONPET S.A.  
(regulations, transition costs). Similarly, safe management of  
Double materiality  
confirmed for some of operations prevents impacts on communities and the environment,  
the themes  
but also protects the company from loss and damage. This  
interdependence (impact financial risk) emphasizes the  
importance of integrating sustainability into strategic decisions:  
what is good for the environment and society ends up being good for  
the health of the business.  
Initiatives being considered for the period ahead, based solely on 2024 findings:  
a) Elaboration and implementation of a Climate Transition Plan: In view of the  
identification of climate change as a priority material issue, CONPET S.A. aims to develop  
a concrete plan for GHG emission reduction and adaptation to climate effects, aligned with  
European and national objectives. The absence of such a plan was highlighted as a gap  
in 2024, and addressing it would turn a risk into an opportunity (access to green financing,  
increased energy efficiency, long-term competitive advantages).  
b) Maintain and expand pollution prevention and ecosystem protection measures:  
Although 2024 performance was good (no major pollution incidents), the company should  
continue to invest in pipeline monitoring technologies, preventive maintenance programs,  
and environmental training for employees. In addition, exploring voluntary environmental  
initiatives, such as conservation actions in areas where the company operates, can  
demonstrate commitment to biodiversity and help mitigate any potential negative impacts.  
53 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
These measures, based on identified risks, fall within the known scope of operations and  
are natural extensions of existing initiatives.  
c) Continued focus on staff and community health and safety: 2024 results confirm the  
value of a strong focus on safety - zero workplace injuries and zero major community  
incidents. It is imperative that this vigilance continues. The company aims to maintain SSM  
procedures and emergency response plans up-to-date, conducting regular drills and  
internal audits. Dialogue with local communities should also be maintained and  
strengthened, communicating safety measures to them and involving them in any  
decisions that concern them (transparency engenders trust, decreasing reputational risk  
in case of an incident). In essence, the aspects that worked well in 2024 should be  
formalized and subject to a constant process of improvement.  
d) Strengthening governance and ethical practices: In light of new legislative  
requirements (including the EU Sustainability Reporting Directive - CSRD), CONPET S.A.  
aims to capitalise on its identified governance strengths. The whistleblower protection  
mechanisms, anti-corruption policies and ethical culture in 2024 are at a high level - the  
company intends to maintain and communicate them transparently in future reporting. At  
the same time, extending ESG criteria to the supply chain (assessing suppliers on  
environmental and social, not just economic, aspects) would formalize the positive impact  
already existing in supplier relationships. Thus, the company is preparing for value chain  
due diligence requirements, building on current positive experience.  
In 2024, CONPET S.A. has demonstrated that sustainability and economic performance are  
mutually supportive, avoiding major incidents and proving resilience. However, the future requires  
proactive action. The recommendations based on the materiality analysis outline the direction:  
consolidating successes and addressing vulnerabilities, ensuring a sustainable, responsible and  
ESRS-aligned path forward.  
3.3 Key stakeholders and the process of involvement  
In order to ensure transparency and sustainable development, CONPET S.A. actively cooperates  
with multiple stakeholders that influence or are influenced by the company's activities.  
TABLE 3.7. Stakeholders with direct impact  
Category  
Industrial  
customers  
Stakeholder (examples)  
OMV Petrom, Petrotel Lukoil,  
NIS  
Type of colaboration  
Use of crude oil transport services  
TDP Partners, Carbon Tool,  
PKF FinAccount  
Compliance and sustainability strategies  
Service providers  
(ESG consultants,  
financial audit and  
other financial  
services,  
Inspection, conformity checking and certification  
services  
Rail transport, logistics and infrastructure  
Bureau Veritas, SRAC CERT  
certification bodies,  
other service  
Romanian Railway Group,  
Talpac, Eye Mall  
Execution of replacement/ repair works of pipelines  
and installations related to NTS  
providers)  
Electricity supply  
54 I SUSTAINABILITY REPORT CONPET S.A.  
 
3. DUAL MATERIALITY ANALYSIS  
Category  
Stakeholder (examples)  
Type of colaboration  
Managing the distribution of dividends to  
Central Depository  
shareholders  
Local communities in the areas Sustainable development projects and public  
Local communities  
of operation  
consultations  
They are consulted in the development and  
implementation of annual training programs, in the  
discussion of all occupational safety and health  
Employees and  
trade unions  
Free Trade Union CONPET S.A. issues, as well as in the development and  
implementation of decisions in this area, while being  
constantly concerned about training, occupational  
safety and enhancing staff well-being.  
Ministry of Energy, National  
Energy Regulatory Authority,  
Ministry of Environment  
Emergency Inspectorates  
Regulating and monitoring environmental compliance  
Prevent accidental pollution  
Public authorities  
Regulation, supervision, sustainable and efficient  
management of mineral resources, oil reserves and  
geological storage of carbon dioxide, in line with  
Romania's obligations, strategies in the field and  
reducing environmental impact.  
National Regulatory Authority for  
Mining, Petroleum and  
Geological Storage of Carbon  
Dioxide (ANRMPSG)  
Academic  
institutions and  
research centers  
Petrol-Gas University of Ploiești  
Research, technological innovation, training  
(UPG)  
Involvement in the Governing Board, support for  
sustainable regional economic development  
Participation in economic and legislative debates,  
working groups, legislative monitoring  
Prahova Chamber of Commerce  
and Industry  
Employers' Organization  
"PETROGAZ"  
Member in TC 320 - standardization for fuels,  
combustibles, lubricants and petroleum products.  
Participation in the definition of product  
measurement, classification and labeling methods.  
Access to working documents and influence in the  
development of national standards relevant to  
CONPET S.A. activity.  
Romanian Standards  
Association (ASRO)  
NGOs  
Collective member. Participation in FOREN, Board  
meetings and dialog with over 100 energy  
companies. Deputy Managing Director, member with  
decision-making role. Promotion in the Energy  
Messenger.  
Romanian National Committee  
of the World Energy Council  
(CNR-WEC)  
Founding member. Access to strategic oil industry  
information, legislative support, promotion of  
Romanian investments and specialists. Participation  
in international events. Deputy Director General,  
member with decision-making role.  
Romanian National Committee  
for the World Petroleum Council  
(CNR-WPC)  
The company collaborates with stakeholders with direct impact in different forms (service  
contracts, supply contracts, Collective Labour Contracts, contributions, etc).  
55 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
CONPET S.A. emphasizes dialogue with stakeholders and capitalizes on their feedback in order  
to integrate relevant perspectives into the company's strategies, thus ensuring sustainable and  
responsible management.  
Methods of consultation and dialogue  
CONPET S.A. maintains an active dialogue with stakeholders through various methods, including:  
Regular meetings with authorities, investors, local communities and employees to  
discuss relevant issues concerning the impact of the company's activities.  
Questionnaires to employees and partners to collect opinions on working conditions,  
safety and environmental impact.  
Open communication channels for stakeholder feedback.  
Actions and measures taken  
Following dialogue with stakeholders, CONPET S.A. has implemented concrete measures to  
address the concerns expressed, including:  
Modernisation of oil transport infrastructure to reduce pollution risks and increase  
operational efficiency.  
Improve safety and environmental protection measures by updating emergency response  
procedures and investing in monitoring technologies (LICs).  
Integrating views into strategic decisions  
The feedback received from stakeholders is used to improve and adapt the company's strategies,  
as follows:  
Improve environmental and safety policies in response to concerns expressed by  
communities and authorities.  
Optimise working conditions and training programmes for employees, based on feedback  
received through surveys and internal meetings.  
Implement transparency measures in sustainability reporting in line with shareholder and  
regulatory requirements.  
Through these measures, CONPET S.A. reaffirms its commitment to responsible and sustainable  
management, ensuring a balance between operational efficiency and compliance with  
stakeholder requirements.  
Stakeholders with indirect impact on the activity of CONPET S.A.  
Although CONPET S.A. has not had direct collaboration with all relevant entities in the energy  
ecosystem, they play a significant role in the context of sustainability, influencing regulations,  
56 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
environmental policies, technological innovation and market trends. This chapter highlights how  
these stakeholders indirectly contribute to the formulation of the company's sustainability strategy.  
Energy companies (customers and end-users)  
Major players in the energy industry, such as OMV Petrom, Lukoil, Romgaz, Rompetrol,  
Transgaz, Hidroelectrica, Nuclearelectrica, Engie, E.ON, Enel and MOL Romania,  
determine the strategic directions of the energy market and set standards of efficiency and  
sustainability.  
Energy transition and decarbonization influence the demand for crude oil transport and the  
potential adaptation of CONPET S.A. infrastructure. Investments in renewable energy and  
clean technologies may lead to changes in transport flows and the need to optimize the current  
system. In addition, the ESG requirements imposed on these companies create a knock-on  
effect on the entire energy ecosystem, including transport service providers.  
Consulting Agencies & Big4  
Consulting firms, including PwC, Deloitte, EY, EY, KPMG, McKinsey & Company, Boston  
Consulting Group (BCG), Roland Berger, Accenture, Oliver Wyman and Bain & Company,  
offer expertise in implementing and promoting international standards for corporate  
governance, financial transparency and sustainability strategies  
These companies indirectly influence CONPET S.A.'s strategy by guiding major energy  
players in aligning with the European Sustainability Reporting Standards (ESRS) and  
Corporate Sustainability Reporting Directive (CSRD) requirements. Reporting standards  
for emissions, energy efficiency and climate risks are thus becoming essential factors for  
infrastructure operators as well. At the same time, the trends in digitalization and operational  
efficiency promoted by these agencies are shaping the innovations needed to modernize the  
oil transport network.  
NGOs  
Environmental organizations, such as Bankwatch, ClientEarth, CDP, Climate Action  
Network Europe, E3G, Transport & Environment (T&E), Romanian Environmental  
Partnership Foundation, Terra Millennium III Foundation, have an indirect impact on the  
sustainability of the industry by monitoring environmental policies and promoting stricter rules  
for reducing emissions.  
Public campaigns on carbon footprint reduction and the energy transition are influencing  
environmental regulations and standards, including in the oil transport sector. Organizations  
such as CDP and Climate Action Network Europe are monitoring companies' transparency  
in emissions reporting, leading to a growing need to align with international sustainability  
requirements.  
57 I SUSTAINABILITY REPORT CONPET S.A.  
3. DUAL MATERIALITY ANALYSIS  
Stringent energy efficiency and emissions standards are driving operational adjustments, and the  
financing mechanisms available for the energy transition can provide opportunities for  
infrastructure modernization. New European directives such as the Green Deal and Fit for 55  
require structural changes across the whole energy sector, with an impact on fossil fuel transport  
and its infrastructure.  
Even if these stakeholders did not have a direct relationship with CONPET S.A. in 2024, they  
influence the company's operating environment, driving compliance, sustainability and  
operational efficiency requirements. By closely monitoring industry trends and dialoguing with  
relevant stakeholders, CONPET S.A. can anticipate changes and adapt its sustainability strategy  
to remain competitive and compliant with new ESG standards.  
In 2024, the Board of Directors and the Executive Directors were informed through monthly  
progress reports on ESG issues, including on stakeholders' interests and expectations (e.g.  
Environmental Authorities, Labour Inspectorate, BVB, etc.), by the specialised departments (e.g.  
HSE, Communication and Corporate Governance).  
58 I SUSTAINABILITY REPORT CONPET S.A.  
CONPET S.A.  
Climate strategies  
and innovation for a  
sustainable future  
4. ENVIRONMENTAL IMPACT AND CLIMATE  
STRATEGY  
Environmental impact and climate strategy covers how the activities of a company, sector or  
country affect ecosystems and natural resources, and the measures taken to minimize these  
negative impacts and combat climate change.  
Environmental impacts include all the effects of economic or industrial activities on nature, while  
the climate strategy is the set of policies and actions designed to reduce these impacts and  
support efforts to mitigate climate change.  
Global warming, caused by greenhouse gas emissions from human activities, is causing global  
temperatures to rise. The carbon footprint measures the total emissions of CO₂ and other GHGs  
over the life cycle of products, services or economic activities. Managing it brings strategic,  
economic and reputational benefits by helping organizations to reduce emissions, improve  
energy efficiency and comply with environmental regulations, demonstrating a real commitment  
to sustainability.  
59 I SUSTAINABILITY REPORT CONPET S.A.  
 
4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
RELEVANT ENVIRONMENTAL POLICIES AND OBJECTIVES  
CONPET S.A. has a number of clearly defined policies and procedures for environmental  
protection and responsible management of the impacts generated by its operations, complying  
with national legal requirements and European standards, including the Quality, Environment,  
waste management, monitoring of environmental factors (air, water, soil), and biodiversity  
protection.  
CONPET S.A. implements risk management policies and policies oriented towards energy  
efficiency and environmental management, which are reflected in the activities carried out by  
the company.  
The company's energy policy emphasizes continuous improvement and optimization of  
operations to reduce energy consumption and related costs. It aims at minimizing energy losses,  
in particular through the efficient use of electricity and fuels, improving performance in thermal  
power generation, vehicle operation and rail shunting. Energy efficiency is also integrated into  
new projects, investments and modernizations of equipment, facilities and processes, thus  
supporting long-term sustainability. CONPET S.A. pays attention to the procurement of energy  
efficient products and services, ensuring their optimal use and maintenance, and aligns with  
international standards such as ISO 50001:2019 for energy management and ISO 14001 for  
environmental management.  
However, although there is an extensive risk and impact assessment procedure in place, the  
significant issues identified at company level are mainly focused on environmental protection  
issues such as contamination and waste management. Key topics such as the energy transition  
and reducing the impacts of climate change are not thoroughly addressed by existing policies,  
so CONPET S.A. proposes that in the medium term it will expand the strategic framework to  
explicitly include these priorities.  
By implementing them, CONPET S.A. aims to contribute to reducing its carbon footprint and  
contributing to achieving climate neutrality by 2050. The company also commits to a reduction  
of greenhouse gas (GHG) emissions (Scope 1 and Scope 2) by 8% by 2030 compared to the  
reference year 2024, indirectly aligned with EU climate targets (European Climate Act. )  
4.1 Carbon footprint and emission reduction targets  
GHG emission calculation methodology and reporting limit  
The inventory of greenhouse gas emissions at CONPET S.A. was carried out in accordance with  
international standards and methodologies, ensuring the accuracy, transparency and  
comparability of the reported data. The company has simultaneously aligned itself with the  
requirements of the GHG Protocol in line with the provisions of ESRS E1-6. The full report is  
available to interested parties on request.  
60 I SUSTAINABILITY REPORT CONPET S.A.  
 
4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
Delimitation of reporting boundaries  
The organizational and operational boundaries for the GHG inventory were defined based on  
CONPET S.A.'s operational control. All significant sources of emissions associated with our  
crude oil pipeline and tanker transport activities and supporting operations were included.  
Through this delineation, we ensure that the entire value chain relevant to the company's  
business is covered, in line with the requirements of the CSRD and OMF no. 85/2024 to include  
sustainability information along the value chain, but also avoid double counting or inclusion of  
negligible irrelevant emissions.  
Data collection processes and tools used  
CONPET S.A. used the digital platform CarbonTool (specialized SaaS solution) to collect,  
centralize and calculate GHG emissions. Activity data, such as the amounts of fuel consumed,  
electricity consumption, kilometers traveled by employees on business or the tonnage of waste  
generated, were collected systematically, following internal reporting procedures. Both direct  
measurement methods were applied (where tools/metrics were available, e.g. for energy  
consumption from invoices, fuel quantities from management records) and estimation methods  
where direct measurement was not possible (e.g. estimating emissions from employee  
telecommuting based on average household energy consumption and national energy mix). All  
calculations were performed using recognized and updated emission factors from reliable  
national and international databases: e.g. conversion factors from official inventories (ANRE for  
electricity in Romania, national emission inventory for fossil fuels), factors from the IPCC, DESNZ  
– Department for Energy Security and Net Zero and EPA database (for standard fuel combustion),  
as well as specific factors recommended by ADEME France (Bilan Carbone database) were used  
where detailed estimates were needed (e.g. for the footprint of capital goods or purchased  
services).  
Methodological principles applied  
The entire accounting process followed the principles of relevance, completeness,  
consistency, accuracy and transparency. It has ensured that all significant (relevant) emission  
sources are included, that there are no major omissions (the inventory is complete per defined  
perimeter), that calculation methodologies are consistently applied for all categories, that data are  
accurate and verifiable, and that the calculation method and assumptions are transparent and  
documented. This allows stakeholders - both internally (management, shareholders) and  
externally (authorities, investors) - to have confidence in the information reported and to  
compare CONPET S.A.'s performance with that of other companies.  
For Scope 1 and Scope 2 emissions, the calculation methodology was straightforward: activity  
data (e.g. thousand liters of diesel consumed, MWh of electricity consumed) were multiplied by  
the emission factors corresponding to each fuel/energy type. CH₄ and N₂O emissions were  
converted to CO₂ equivalents using 100-year global warming potentials (GWP) according to the  
IPCC 5th Assessment Report, ensuring uniformity of metrics. For Scope 2 emissions under the  
GHG Protocol, both location-based (based on national grid-averaged emissions) and market-  
61 I SUSTAINABILITY REPORT CONPET S.A.  
4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
based (based on the contractual mix of purchased energy) approaches were applied. The main  
reporting was done using the location-based methodology and the difference was transparently  
disclosed.  
For Scope 3 emissions, the GHG Protocol Corporate Value Chain (Scope 3) standard and the  
guidelines associated with each category were followed. The complete list of indirect emission  
categories in the value chain (15 possible categories according to the GHG Protocol) was  
identified and, based on significance to CONPET S.A.'s activity, emissions have been quantified  
for the applicable categories: purchased goods and services, capital goods, fuels and energy  
related to downstream activities (emissions from the production of fuels and energy used by the  
company), upstream transport and distribution (in our case, emissions from the transport of crude  
oil by third parties, but this component is small as transport is mostly provided by CONPET S.A.),  
waste generated in operations, business travel, employee commuting. The categories of  
downstream transport and distribution, processing and use of products sold are not relevant, as  
the company does not sell a finished product for use by the customer, but provides a transport  
service for industrial customers. The company also has no emissions from franchises or financial  
investments of the type covered by the GHG Protocol in other entities, as these are not part of  
our business model. Through this filter, Scope 3 reporting has included all significant sources  
and excluded non-applicable sources, ensuring compliance with the materiality principle - we  
focus on the most relevant emissions.  
For each sub-category of Scope 3 included, the calculation methodology was tailored to the  
specifics: for example, emissions from capital goods were estimated based on the value of capital  
investments in 2024 and average emission factors (tCOe per million euro invested, broken down  
by project type, according to ADEME database) calibrated with information on the main projects  
(station modernization, new pipelines - which have larger footprint - vs. standard equipment  
purchases). Emissions from purchased goods and services were calculated using emission  
factors per monetary unit for different expenditure categories (e.g. metallic materials, chemicals,  
IT services, etc.), according to extended input-output methodologies in terms of environmental  
impact. Emissions from waste were calculated according to the type and treatment of each waste  
(e.g. incineration vs. recycling, each with its own emission factor). For business travel, transport  
documents (km traveled) and mode-specific emission factors (flight by average distance per  
passenger-km, car transport per km, etc.) were used. Employee commuting was estimated by an  
internal survey on modes of transport and average distances, then applying emission factors per  
km for each mode (private car, public transport). Upstream fuel and energy emissions were  
calculated as a percentage of direct consumption emissions (using standard factors that add the  
footprint from exploration, refining and transport for each fuel or kWh consumed).  
Ensuring data quality  
The data collected from the different working points have been cross-checked with primary  
sources (invoices, consumption registers, technical reports) to detect any omissions or anomalies.  
The platform used has automatic validation mechanisms that signal if certain intensities (e.g. liters  
of fuel per km traveled) fall outside the expected ranges, allowing input errors to be quickly  
corrected. At the end of the calculation process, the inventory has been reviewed by an internal  
62 I SUSTAINABILITY REPORT CONPET S.A.  
4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
multidisciplinary team (environment, energy, operations) to ensure consistency and accuracy of  
the data. This approach ensures a high level of confidence in the 2024 GHG emissions inventory,  
thus establishing the base year for setting future targets and measuring progress.  
Results of the calculation footprint report (emission calculation scopes 1, 2 and 3)  
In 2024, the total GHG emissions of CONPET S.A. were 18,906.59 tons of CO2 equivalent  
(tCO2e), distributed as follows by categories of scopes:  
Scope 1 Emissions: The main sources of Scope 1 emissions cover all direct emissions  
from sources owned or controlled by CONPET S.A., including, but not limited to, company  
vehicles and on-site fuel combustion. Emissions from this scope accounting for  
approximately 12.7% of total emissions, or 2,630.41 tCO2e, are mainly from company-  
operated vehicles and on-site fuel combustion. Therefore, the emission reduction  
priorities for Scope 1 are mainly aimed at decreasing fuel consumption in stationary  
processes and internal road/rail transport.  
Scope 2 Emissions: This scope includes greenhouse gas (GHG) emissions from the  
production of electricity, heat and steam purchased and consumed by CONPET S.A.  
These indirect emissions are a consequence of the company's energy consumption, but  
occur in sources owned or controlled by another entity. Their value is approximately 21.4%  
of the total, namely 4,451.10 tCO2e are mainly generated from electricity consumption  
at CONPET SA's pipeline pumping stations and operational facilities. They highlight  
the operational dependence on electricity and justify the company's focus on  
increasing energy efficiency and increasing the contribution of renewable sources in its  
own electricity consumption.  
Scope 3 emissions: These are indirect emissions from value chain activities such as  
goods purchased, business travel and product use. This category includes GHG  
emissions from CONPET S.A.'s extended value chain and constitutes the largest part of  
its carbon footprint. Their total value is 11,825.08 tCO2e which represents approximately  
65.9% of the total attributed to third party logistics, business travel, upstream  
procurement and waste management activities. These emissions - representing  
almost two thirds of the total - emphasize the importance of climate impacts beyond the  
direct operations of CONPET S.A. Certain sub-categories have been assessed as not  
applicable to CONPET S.A.'s business model and are not included in the inventory,  
respecting the materiality principle (e.g. the company has no emissions from franchises or  
from the use of products sold to end customers, as CONPET S.A. provides transport  
services and does not commercialize a final product with own emissions). With this  
approach, the reporting covers the entire relevant value chain, focusing on material  
sources of emissions and aligning with the requirements of OMF 85/2024 on the inclusion  
of sustainability information along the value chain.  
63 I SUSTAINABILITY REPORT CONPET S.A.  
4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
TABLE 4.1. Categories and quantities of greenhouse gas emissions  
Amount of greenhouse gas emissions  
Emissions category  
Related emissions  
(tCOe)  
2.630,41  
Scope 1  
Fuel burned on site  
Mobile emission sources  
Fire-fighting equipment  
Refrigeration and air cooling equipment  
Related emissions  
Scope 2  
1.394,46  
1.235,95  
N/A - No use of fire-fighting equipment recorded  
N/A - There were no completions for coolant  
4.451,10  
Purchased electricity  
4.451,10  
N/A - No centralized heat energy was supplied to  
CONPET S.A.  
Heating purchased  
Purchased cooling  
N/A - No centralized cooling energy was supplied  
to CONPET S.A.  
Related emissions  
Scope 3  
11.825,08  
1.674,95  
Goods and services purchased  
Capital goods  
8.220,41  
376,19  
Waste  
Business travelers  
Employee commute  
34,15  
78,76  
Issues already included in Goods and services  
purchased  
Upstream transport and distribution  
Downstream transport and distribution  
Upstream leased assets  
N/A - CONPET S.A. does not sell products  
Emissions already covered in  
Scope 1 and 2  
Emissions already covered in  
Scope 1 and 2  
Downstream leased assets  
Processing of products sold  
Treating products sold at the end of their  
life cycle  
N/A - CONPET S.A. does not sell products  
N/A - CONPET S.A. does not sell products  
Francize  
N/A - No franchises available  
N/A - No investments available  
1.440,62  
Investments  
Fuel and energy-related activities  
Total emissions (tCOe)  
Domestic water purchased (out of  
scope)  
18.906,59  
8,12  
64 I SUSTAINABILITY REPORT CONPET S.A.  
4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
According to the table above, Scope 3 emissions dominate the company's carbon profile  
(~66%), while the contribution from Scope 1 is relatively small (~13%) and Scope 2 is ~21%.  
This distribution indicates that CONPET S.A.'s own operations (scopes 1 and 2) generate only  
a fraction of the total climate impact, while upstream and downstream activities (scope 3) have  
a major share. This underlines the need to extend decarbonization efforts beyond the company's  
immediate operational boundaries - for example, by working with suppliers to reduce emissions  
in the supply chain and by integrating environmental criteria into procurement and investment  
design (eco-design) - while optimizing own emissions.  
Compliance with ESRS E1 (E1-5, E1-6, E1-7, E1-8)  
Energy intensity is a key indicator in assessing the sustainable performance of an energy  
company. In the case of CONPET S.A., the 2024 sustainability report presents in Section 8.1 a  
precise indicator in line with ESRS requirements: 13.21 kWh/1,000 RON net revenues. This result  
reflects the energy efficiency of the company's operations and is in direct correlation with the  
energy modernization and optimization initiatives mentioned in Chapter 4.3. To strengthen future  
performance, CONPET S.A. proposes an annual energy intensity improvement target (e.g. -  
2%/year), which allows for tracking progress and comparability over time.  
Greenhouse gas (GHG) emissions intensity is also reported in line with GHG Protocol and ESRS  
standards. CONPET S.A. indicates a value of 13.26 kg COe/1,000 RON net revenue, a result  
obtained by aggregating emissions from all three scopes (Scope 1, 2 and 3), as detailed in Chap.  
3.3 and Chap. 8.1 of the report. This reporting provides a complete picture of the company's  
climate impact. In order to support transparency and to encourage performance improvement, the  
company aims in the medium term to contextualize this indicator through sector benchmarking -  
a comparison with other European energy transport operators.  
Regarding the use of offset mechanisms such as carbon credits, it appears from all the  
compliance tables (including the integrated ESRS) that CONPET S.A. did not use offset  
mechanisms such as afforestation, carbon capture and storage (CCS) or other voluntary methods  
of greenhouse gas (GHG) emissions absorption in 2024. This absence is justifiable and does not  
affect compliance with the ESRS, but for the post-2025 period the company proposes to develop  
a feasibility analysis on the integration of voluntary offsetting instruments in the context of the  
progressive decarbonization of the energy sector.  
Concerning the internal carbon price, the report does not present in 2024 a calculation model or  
any applied simulation. However, the ESRS Integrated Table mentions the intention to model  
such a tool for the next reporting cycle. The implementation of an internal carbon price (e.g. 85  
€/t COe) would allow the integration of climate risks into investment appraisals and strengthen  
ESG governance. This would allow the company to report in the next report the estimated impact  
of decisions on the carbon footprint and cost associated with emissions, aligning with European  
best practice in climate risk accounting.  
65 I SUSTAINABILITY REPORT CONPET S.A.  
4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
Climate change mitigation and adaptation targets (ESRS E1-4)  
The company allocates resources to climate change mitigation and adaptation, focusing mainly  
on optimizing energy consumption and transition to renewable energy sources. Well-grounded  
measures to reduce energy consumption are included in the Action Plan to Achieve 2024 Energy  
Goals and Targets, and are geared towards maintaining and continuously improving energy  
efficiency within the organization.  
In the absence of previous quantification of greenhouse gas (GHG) emissions, no concrete  
targets have been set. There has also been no formal assessment of assets exposed to climate  
risk and this is reflected in the absence of specific measures to address this issue.  
IMPLEMENTATION OF THE CLIMATE STRATEGY FOR CARBON FOOTPRINT REDUCTION  
AT CONPET S.A.  
In 2024, CONPET S.A. has implemented a series of concrete measures to reduce its carbon  
footprint, which have proven their effectiveness and underpin the achievement of its long-term  
climate goals. Key achievements in 2024 include:  
Procurement of electricity from renewable sources: The company has a contract with  
a supplier that provides 90% of its total electricity consumption with an energy label with  
a high share of renewable energy. This has directly contributed to the reduction of Scope  
2 emissions by reducing the dependence on energy from conventional sources with higher  
emission factors.  
Improved operational energy efficiency: Investments were made in upgrading pumping  
stations and optimizing pipeline transport processes. The implementation of consumption  
monitoring systems and upgrading of equipment resulted in to maintain electricity  
consumption kwh/tonne transported within the limits approved by the AGM,  
improving the energy performance of the national crude oil transport system. Thus,  
emissions associated with energy consumption (Scope 2) were mitigated compared to a  
lower efficiency scenario.  
Installation of solar energy systems at work points: In 2024, CONPET S.A. initiated  
the installation of photovoltaic panels at two automated stations (Constanța Sud and  
Călăreți) to generate clean energy on-site. Each installation has a capacity of ~60 kWp,  
with an estimated annual production of ~70-80 MWh green electricity per location. This  
energy will offset part of the grid consumption of the respective stations. The photovoltaic  
projects - implemented in 2024 and operational in the first part of 2025 - will give CONPET  
S.A. prosumer status at the respective locations, allowing any surplus solar energy to  
be injected into the local grid. Harnessing on-site renewable energy helps lower operating  
costs and increases the company's resilience to possible future increases in electricity  
prices or carbon costs.  
These actions realized in 2024 demonstrate CONPET S.A.'s desire to align with European climate  
objectives (European Ecological Pact) and chart a trajectory towards net zero operational  
emissions. At the same time, the 2024 operational context also included factors that  
66 I SUSTAINABILITY REPORT CONPET S.A.  
4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
temporarily increased the carbon footprint: the expansion of sourcing activities and the  
deployment of major investments led to increased Scope 3 emissions (especially those  
associated with capital goods and third-party logistics). For example, strategic infrastructure  
modernization projects have involved increased purchases of equipment and materials,  
generating additional emissions in the supply chain. Scope 3 emissions are the most difficult to  
reduce as they depend on supply chain practices and processes, but CONPET S.A. aims to work  
with sustainable suppliers in the future, in line with the principles of public procurement in place,  
to reduce its overall indirect emissions.  
Having already substantiated decarbonization actions, CONPET S.A. is in a favorable position to  
continue its emission reduction trajectory in the coming years. The company will continue to  
implement measures to reduce greenhouse gas emissions by optimizing operational processes  
and increasing the use of sustainable energy sources. The company will also develop sustainable  
strategies to reduce its carbon footprint and identify alternative energy solutions. By combining  
these efforts with a clear strategic vision on sustainability, CONPET S.A. is integrating the  
requirements of ESRS E1 (Climate Change) into its day-to-day business, increasing transparency  
and stakeholder engagement. In the future, progress will be reported regularly and the strategy  
will be updated as necessary so that the emissions reduction trajectory remains aligned with the  
latest science, aiming to limit global warming to 1.5°C. In the long term, the company is pursuing  
a vision of climate neutrality by 2050, in line with EU targets and the Paris Agreement, ensuring  
stakeholders that the decarbonization path is firmly set and pursued step by step.  
4.2 Climate change risks and adaptation measures  
Pollution-related policies (ESRS E2-1)  
CONPET S.A. has implemented an Environmental Management Program in order to achieve  
environmental objectives and manage the risks associated with pollution. This program includes  
specific actions to monitor and prevent pollution in various environments.  
The company constantly monitors environmental factors such as water, air and soil to ensure  
compliance with the quality standards set by the regulations in force. This monitoring allows early  
identification of possible deviations and implementation of necessary corrective measures.  
In order to prevent accidental pollution and technological risks, specific measures have been  
established, including the reduction of the number of failures with significant environmental impact  
and the identification of major hazards for lower-tier objectives. These measures are an integral  
part of the annual environmental management program and are regularly reviewed to ensure their  
effectiveness.  
During 2024, a total of 13 environmental incidents occurred. All identified environmental incidents  
were remediated in accordance with the requirements of the regulatory acts.  
67 I SUSTAINABILITY REPORT CONPET S.A.  
 
4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
Air, water and soil pollution (ESRS E2-4)  
CONPET S.A. has implemented an advanced pollution prevention and remediation system in  
compliance with the requirements of environmental regulations and environmental authorizations.  
This system includes technical and operational measures designed to minimize pollution risks,  
prevent environmental accidents and ensure rapid responses in case of adverse events. The  
whole system is built to protect the environment and ensure compliance with water, air and soil  
quality standards.  
To prevent accidental pollution, the crude oil tanks are equipped with automated measurement  
and control facilities and the storage areas are equipped with retention dikes and spillways, which  
are essential to capture and redirect any spills of hazardous substances. In addition, all tanks are  
built on concrete platforms and pumps are installed in enclosed spaces with safety systems to  
prevent any risk of accidental spills. For emergency situations, the pumping stations are equipped  
with absorbent materials and fire-fighting means, including water tanks and foam generators.  
The company monitors all air pollutants covered in the environmental permits, following specific  
procedures. In this context, the impact is positive and current, but minimal, as it is mainly related  
to compliance with the legislation in force, without involving additional measures going beyond  
the regulated requirements.  
The company monitors water pollutants in accordance with the Environmental Authorization (MA)  
and the Annual Program for Monitoring and Measurement of Environmental Factors  
Characteristics, complying with the frequencies established for each category. Until the reporting  
year, the results of this monitoring were reported exclusively through the Environmental Report  
to the competent authorities. This information was not made public until this year. Continuous  
monitoring and reporting is essential to identify and reduce any negative environmental impacts  
so that the impact is positive, current but negligible.  
Substances of high concern and substances of very high concern (ESRS E2-5)  
There is a comprehensive inventory of hazardous substances, managed through the ITM Lists,  
with clearly assigned hazard classes for each substance and mixture. The impact is positive but  
not negligible since this is a legal compliance criterion. The quantity of hazardous substances is  
monitored under the Environmental Authorization. Being a legal requirement, the impact, although  
positive, is negligible. CONPET S.A. does not use groups of hazardous substances from lists I  
and II and priority/priority hazardous substances for which phase-out measures are to be  
implemented.  
All chemical substances are declared to ATPMs and included in environmental authorizations.  
Internally, the management of hazardous chemical substances and chemical mixtures is detailed  
in the operational procedure "Management of hazardous chemical substances and chemical  
mixtures" (COD PO-20-07). CONPET S.A. uses a substance included in the SHVC authorization  
list - potassium chromate - for laboratory analysis. The following substances are used in the  
SHOC process: crude oil, rich gas, condensate (and mixtures), dyes (including primers) and  
68 I SUSTAINABILITY REPORT CONPET S.A.  
4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
chloroform (for analysis). The reduction of the use of SHOC/SHVC substances, without a change  
in the business model or core activity, aims at optimizing the reactants and liquids used for  
maintenance. For SHVCs (mercury and potassium chromate), a minimum stock, kept under  
maximum security conditions, has been confirmed. This standard is included in the crude oil  
transport contracts with partners OMV and Lukoil. In 2024, the quantity of 10% potassium  
chromate solution used was 100 ml (0.1 L). As the company does not produce this substance, it  
was not necessary to submit a REACH declaration. Currently, the laboratory has a stock of 200  
ml of 10% potassium chromate solution. Mercury is present at the site because it has been  
previously used in laboratory analysis. As a precursor of banned substances, it is kept under  
maximum security and the local authorities are informed of this situation.  
Products such as crude oil, rich gas (methanol, toluene, benzene) and condensate are classified  
as hazardous substances and cannot be substituted. However, depending on the type of crude  
oil (e.g. if it has a high sulfur content), the company implements appropriate protective measures  
for employees, such as the use of gas semi-masks with filter cartridges, when the situation  
requires it. In 2024, no such measures were necessary.  
The associated risks are carefully analyzed and protective measures are adapted according to  
the exposure time of the employees. In the process of analyzing the composition of crude oil, the  
substances used cannot be substituted with less hazardous alternatives, as no such substitutions  
exist; however, the handling of these substances is carried out under the niche to minimize  
exposure.  
As regards paints, where possible, the company has replaced traditional paints with less toxic  
water-based variants, thereby helping to reduce environmental and health risks to employees.  
For workers who handle hazardous substances as part of the work process, the employer  
provides protective nutrition as an additional safety measure and to support their health.  
For all these reasons, it can be stated very clearly that there is no negative impact related to  
CONPET S.A.'s ShOC/SHVC. All measures that can be taken for safe replacement/maintenance  
of these substances are being followed. The impact is postic but minor (related to paint  
replacement).  
CONPET S.A.'s main activity is the transport of crude oil and petroleum products, without being  
involved in upstream activities (such as extraction or exploration) or downstream activities (such  
as processing and refining), which are usually associated with the use of hazardous or REACH-  
regulated substances. The company does not process or chemically modify the transported crude  
oil, but purchases it strictly for onward delivery. Thus the dimension related to the reduction of the  
use of hazardous substances is not relevant to the specific activity of the company, as it only  
operates as a transporter, without influencing the value chain beyond the actual delivery.  
69 I SUSTAINABILITY REPORT CONPET S.A.  
4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
Pollution targets (ESRS E2-3)  
The company has set targets for compliance with pollutant limits in accordance with the  
requirements of each environmental permit issued. Thus, the negative environmental impact is  
effectively limited. However, the efforts made by the company are in line with the legal provisions,  
and no additional measures beyond those already regulated by the legislation in force are  
considered necessary to achieve these targets. The impact is positive but minor.  
The regular assessment of these risks is integrated into CONPET S.A.'s risk management  
strategy, allowing the company to take appropriate adaptation and mitigation measures. The main  
categories of climate risks identified include:  
Physical risks: The increase in the frequency and severity of extreme weather events as  
an effect of climate change poses a direct threat to oil transport infrastructure. According  
to the "State of the Climate - Romania 2024" report and other climate analyses,  
Romania is already facing an increase in the frequency and intensity of extreme weather  
events - major floods, severe droughts, heat waves and severe frost episodes - projected  
to worsen by 2050, affecting agriculture, public health and infrastructure. Such events can  
affect pipeline routes (landslides caused by heavy rainfall), flood pumping stations or  
cause thermal stress on equipment, increasing the risk of operational disruptions or  
failures.  
Regulatory risks: Evolving climate policies and regulations at EU and national level may  
lead to stricter compliance requirements and increased costs for companies in the  
hydrocarbon transport sector. The European Climate Act stipulates to reduce GHG  
emissions by 55% by 2030 (compared to 1990 levels) and achieve climate neutrality by  
2050. These objectives are translated into policies such as carbon pricing mechanisms  
(ETS and COemission taxes), increasingly stringent emission standards and stricter  
environmental permits for climate-risk infrastructures, as well as by reducing the amount  
transported. For CONPET S.A., such changes may mean higher operational costs - e.g.  
carbon taxes on fuel and electricity consumption - as well as additional capital  
expenditure to modernize facilities to comply with new safety and environmental  
standards. Adapting to regulations such as the forthcoming requirements of the "Fit for  
55" package requires investments and forward planning so that the company avoids  
penalties and takes advantage of opportunities created by green transition policies (retrofit  
funds, sustainable financing, etc.).  
Market transition risks: The global transition to low-carbon energy and the  
decarbonization of the economy present long-term challenges for the oil industry and, by  
extension, for crude oil transport operators. EU policies - such as the Green Deal and the  
Fit for 55 package - are promoting the electrification of economic sectors and the  
development of alternative fuels, with the aim of drastically reducing fossil fuel  
consumption. In this context, the demand for transported crude oil could gradually  
decrease: for example, the accelerated transition to electric vehicles and green  
technologies in transport may reduce the volumes of petroleum products needed, and thus  
also the volume of crude oil that needs to be transported by pipeline or rail. For CONPET  
S.A., a structural decrease in demand for crude oil transport (as the national energy mix  
70 I SUSTAINABILITY REPORT CONPET S.A.  
4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
changes) could lead to underutilization of existing infrastructure and pressure on  
revenues if the company does not adapt its business model. This transition risk requires  
the company to diversify its long-term use of infrastructure and identify new  
opportunities in the decarbonized economy in order to maintain its relevance and  
profitability.  
ADAPTATION AND RESILIENCE STRATEGIES IMPLEMENTED  
In order to manage the above climate risks, CONPET S.A. is acting proactively through a series  
of measures aimed at increasing operational resilience and mitigating vulnerabilities. Thus, the  
company is carrying out an ongoing program of modernization and strengthening of the  
transport infrastructure, aimed at increasing the network's ability to withstand the impact of  
extreme weather events. A notable example is the project completed in 2023 to cross under the  
bed of the Danube River and the Borcea Arm through horizontal directional drilling (investment  
~€26 million), which replaced a vulnerable section of pipeline. This modernization significantly  
reduces the risk of crude oil spills or major flood damage, while ensuring the continuity of a critical  
transport link. CONPET S.A. also has programmes to gradually replace obsolete pipelines,  
upgrade pumping stations and improve the integrity of the National Transport System (NTS),  
anticipating the possible effects of increasing rainfall, temperature variations and other climatic  
stress factors. Such preventative measures improve operational safety and reduce the  
likelihood of environmental incidents, protecting both the company and the ecosystems it  
crosses.  
In 2024, CONPET S.A., with the support of an external service provider, conducted its first full  
ESG reporting exercise. To ensure compliance with the specific requirements, the company  
implemented a set of integrated measures aimed at improving the accuracy, transparency and  
reliability of reported data.  
Key measures implemented in 2024:  
Collecting ESG data from CONPET S.A.'s operational reports, consolidating a  
centralized system for tracking them.  
Continuous external validation of the ESG indicators by specialized consultants, by  
linking directly to the explicit requirements of the ESRS (E1-E5, S1-S4, G1), ensuring  
accuracy and compliance of the reported information  
Independent external audit performed on ESG data to ensure reliable reporting and  
alignment with European and international standards (ISO 14064-1, GHG Protocol).  
Improve the data management process, reducing human error and improving the  
efficiency of the collection and analysis process.  
2024 RESULTS  
ESG data was collected and integrated according to the ESRS methodology.  
External audit by independent firm to validate ESG compliance.  
71 I SUSTAINABILITY REPORT CONPET S.A.  
4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
a. Integrating ESG requirements into corporate strategy  
ESG compliance is not only a reporting obligation but also a strategic tool for improving corporate  
competitiveness and transparency. In this regard, CONPET S.A. has already started to actively  
integrate ESRS requirements into its business strategy by creating a dedicated sustainability  
responsibility structure with specific ESG data management tasks.  
Proposed measures:  
o Continuous assessment of the company's activities against the EU Taxonomy  
Regulation 2020/852, ensuring that eligible activities are identified and aligned with  
the technical criteria of DNSH (Do No Significant Harm).  
o Formation of a Sustainable Development Working Group.  
o Identify strategic ESG indicators, linking them to the financial materiality  
assessment to anticipate sustainability risks and opportunities.  
The impact of these measures:  
o Employees involved in the collection and reporting process will be trained in ESRS  
and CSRD methodologies.  
o New sustainable projects will be integrated into the corporate development strategy,  
including investments in renewable energy and reduction of resource consumption,  
with the potential for concessional financing through sustainability clauses.  
b. Audit and certification of ESG management systems  
To guarantee the quality and reliability of the reported data, CONPET S.A. will strengthen the  
ESG management systems by maintaining the relevant international certifications:  
o ISO 9001 quality management system certification  
o ISO 14001 environmental management system certification  
o ISO 37001 anti-bribery management system certification  
o ISO 45001 certification for occupational health and safety management system  
o ISO 50001 energy management system certification  
Objectives for verifying compliance in sustainable development:  
o 100% compliance with ESRS and CSRD requirements for the first reporting cycle.  
o Zero major non-conformities identified in the ISO audits performed.  
o Optimization recommendations to improve the ESG collection and reporting process,  
to be integrated into the 2025-2026 strategy.  
c. Evaluated initiatives for continuous improvement of ESG reporting  
To ensure continued compliance with ESRS requirements and to improve the transparency of  
ESG reporting, CONPET S.A. proposes to implement the following improvements:  
72 I SUSTAINABILITY REPORT CONPET S.A.  
4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
o Standardize the reporting format, using structured tables and quantifiable indicators for  
each ESG aspect.  
o Linking ESG performance to financial impact, directly highlighting the link between  
sustainability and the company's financial results.  
These improvements will contribute to increasing the accessibility and comparability of ESG data  
for investors and stakeholders, enhancing the transparency and credibility of ESG reporting at  
national and international level, as well as reducing ESG risks and anticipating future legislative  
requirements through a proactive approach.  
Investment in alternative energy sources and diversification of activities  
As part of its strategy to mitigate transition risks, CONPET S.A. is investigating opportunities in  
the field of green energy and reuse of existing infrastructure. In the medium term, the company is  
investing in renewable energy generation and energy efficiency, both to reduce operational  
emissions and to gain expertise in the new energy landscape.  
At the same time, CONPET S.A. is assessing possibilities for adapting its infrastructure to  
transport low-emission products - for example, it is investigating whether certain pipelines or  
facilities could be reused in the future for the transport of biofuels or other low-carbon liquids.  
While the transport of crude oil remains the core business today, these forward-looking  
investments signal CONPET S.A.'s commitment to evolve with the energy transition and reduce  
dependence on high-emitting activities. By progressively aligning its asset base and  
competencies with Romania's national decarbonization strategy, the company aims to mitigate  
the risk associated with the transition and capitalize on new opportunities in an increasingly green  
economy.  
Overall, CONPET S.A.'s approach to climate change combines measures to reduce its own  
climate impact (decreasing GHG emissions) with adaptation to the already felt or anticipated  
effects of climate change. The company approaches climate change both as a business risk to  
be managed and as a corporate responsibility, integrating these concerns into strategic  
planning, investments and daily operations. Adaptation measures described above increase the  
resilience of critical infrastructure, while mitigation initiatives reduce the carbon footprint and  
prepare the company for future regulations and market conditions. CONPET S.A. is committed to  
continue regular climate risk assessment and to expand the portfolio of response actions,  
ensuring long-term sustainable development in harmony with global climate goals and  
stakeholder expectations.  
ANALYSIS OF CLIMATE SCENARIOS AND IMPACT ON CONPET S.A.  
As part of the climate risk management process, CONPET S.A. analyzes the potential impact of  
climate change on its infrastructure and operations by identifying physical and transition risks. In  
climate scenarios are essential for anticipating future challenges and adapting the company's  
strategy to a changing operating environment.  
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4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
Currently, the material deals with two main climate scenarios:  
TABLE 4.2 Main climate scenarios  
Scenario 1: Moderate global temperature increase (+2°C by 2050)  
Impact: Increased frequency of extreme weather events (heat waves, floods  
Adaptation measures: Investments to maintain an advanced degree of operational safety and  
to monitor the condition of pipelines.  
Scenario 2: Severe global temperature increase (+4°C by 2050)  
Impact: Increased risk of major floods, increased frequency of landslide events  
Adaptation measures: Implement an advanced monitoring system to prevent damage to  
pipelines in risk areas.  
In the future, CONPET S.A. aims to develop a framework for the assessment of climate  
scenarios, including specific modeling for the physical and financial risks associated with each  
scenario. These assessments will enable the alignment of business strategy with climate  
resilience objectives and help adapt infrastructure to anticipated environmental changes.  
4.3 Energy efficiency and renewable energy initiatives  
CONPET S.A. focuses its efforts on reducing its carbon footprint and increasing energy  
efficiency in all aspects of its operations, aligning with national and European climate objectives  
through projects to harness renewable sources, modernizing means of transport to make them  
more environmentally friendly and implementing smart energy management solutions.  
Key initiatives undertaken or planned include:  
Solar energy projects in Constanta Sud and Călăreți: The two photovoltaic projects at  
the Constanța Sud and Călăreți stations will act as prosumers in the CONPET S.A.  
electricity grid having the possibility to deliver back to the local grid the eventual surplus  
of renewable energy produced. In addition to reducing emissions, these investments  
strengthen the energy security of the operations (by providing part of the consumption  
from own sources) and protect the company from volatile energy prices and possible  
future carbon costs associated with conventional electricity.  
Solar energy projects at the secondary headquarters (Administrative Headquarters  
No. 2): This system contributes to reducing grid electricity consumption and related  
emissions. This initiative is part of CONPET S.A.'s wider strategy to transition to green  
energy, alongside the photovoltaic projects at the Constanța Sud and Călăreți stations.  
The project provides the company with a reduction in CO₂ emissions associated with the  
consumption of electricity from conventional sources, increased energy efficiency and  
lower electricity costs, increased energy security through diversification of power supply  
sources and alignment with the company's sustainability direction and national and  
European climate goals.  
Optimizing energy consumption in the pipeline system and intelligent automation:  
the SCADA system implemented at CONPET S.A. supports the company to monitor in  
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4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
real time the flow rates, pressures and energy consumption at the pumping stations  
on the route and can adjust the operating parameters for optimal efficiency. Operators,  
with permanent monitoring of the network, can adjust the pumping schedule, redistribute  
loads between stations and prevent equipment from running inefficiently. The company's  
energy objectives explicitly include maintaining energy, fuel and lubricant  
consumption in transport processes. Concrete measures implemented or planned  
include: installation of frequency converters on pump motors (to fine-tune power to  
pumping requirements and avoid excessive consumption), improving pipeline flow (e.g.  
by adding friction-reducing additives and periodic cleaning of pipelines) and reducing  
technological product losses. In addition, the company integrates automation and smart  
grid technologies into the stations' energy system so that electricity consumption is  
optimized and correlated with local renewable energy production. In major stations such  
as Constanța Sud and Călăreți, the new photovoltaic plants will be managed by smart  
inverters and controllers, allowing the company to maximize the use of available solar  
energy and supplement from the grid only the amount needed. These efficiency  
measures, while primarily aimed at reducing emissions and costs, also have the effect of  
increasing operational reliability by reducing the chances of equipment overload and  
reducing thermal stress on system components. Overall, investments in energy  
optimization and automation contribute both to lower carbon emissions associated with  
the operations and to strengthen the financial sustainability of CONPET S.A. through  
the savings achieved.  
Among the initiatives carried out in 2024 is CONPET a S.A.'s participation in the largest voluntary  
environmental action in history, #EarthHour, now in its 18th edition. In March, between the  
company turned off the lights for an hour at its headquarters in Ploiești, reaffirming its commitment  
to environmental protection.  
Through the implementation of the above initiatives, CONPET S.A. demonstrates its commitment  
to harmonize operational growth with environmental protection, leveraging technological  
innovation to achieve efficiency and decarbonization goals. The energy efficiency and renewable  
energy projects not only reduce the company's carbon footprint, but also serve as examples of  
best practices in the energy transport industry.  
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4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
4.4 Water resources management (ESRS E3)  
Water and marine policies (E3-1)  
Within the Action Plan for Achieving the 2024 Energy Goals and Targets, there is a section that  
focuses on optimizing and maintaining water consumption in accordance with the requirements  
of the Water Management Permit. However, there are no specific actions other than those  
necessary to comply with legal requirements.  
The company has implemented specific measures for the responsible management of water  
resources through the operational procedure "Water Management" (OP code 20-05). This sets  
out the modus operandi and responsibilities for water supply, collection, treatment and discharge  
of domestic, technological and stormwater wastewater, ensuring control over significant  
environmental aspects related to water use and wastewater discharge. It also regulates the  
management of water resources for consumptive and non-consumptive water uses.  
In the case of water pollution, the greening works are carried out by a specialized company and  
the company has the obligation to monitor. Monitoring of watercourses is also carried out by the  
territorial water management authorities.  
In order to prevent accidental pollution, the company has set up, by decision of the Managing  
Director, a dedicated team, made up of representatives from each area of activity, with defined  
responsibilities. In accordance with Order 278/1997, accidental pollution prevention and control  
plans are drawn up and endorsed, which include intervention measures and periodic simulations  
to ensure their effectiveness. On the prevention side, the crossings of watercourses with transport  
pipelines are equipped with shut-off valves on both banks, accidental spills collection sumps and  
protection tubes. Pipelines are also regularly inspected for corrosion losses and the results are  
used to prioritize capital repairs. The company holds stocks of rapid response materials, including  
skimmers, check dams, check dams, sorbent dams and biodegradable absorbent, helping to  
improve the quality and control of water discharged to the natural environment. The impact of  
these activities is positive but minor as they are limited to compliance with legal requirements.  
The implementation of these measures ensures compliance with the regulations in force, but does  
not bring significant additional benefits in terms of sustainability, only on the side of prevention  
and treatment of a potential negative impact related to water pollution. As the standard  
emphasizes, prevention/mitigation of a negative impact itself does not constitute a positive impact.  
Water consumption (ESRS E3-4)  
The company quantifies its water consumption, including locations in water-risk areas. The  
company has made significant progress in reducing water consumption, with a decrease of up to  
60% since the start of monitoring. This reduction reflects the effectiveness of the policies and  
procedures in place. The impact is relevant, especially in the context of the risk of water stress,  
as optimizing water use contributes both to protecting natural resources and to ensuring greater  
availability for other essential uses.  
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4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
Evolution of water consumption (cm)  
100.000  
90.000  
80.000  
70.000  
60.000  
50.000  
40.000  
30.000  
20.000  
10.000  
0
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024  
Graph 4.1- Evolution of water consumption (cm)  
Although the operation of the pipeline system does not involve significant water consumption,  
CONPET S.A. recognizes the importance of responsible water management and protection of  
water resources. Water is used by the company in certain supporting processes and operations -  
for example, in hydraulic strength testing of pipelines, for firefighting and for some maintenance  
works. The absolute volume of water used is not high compared to other industries; however, the  
local context of water sources is a factor to be taken into account. In some regions (Videle,  
Cartojani, Constanța C2) where the company has its own boreholes or extracts groundwater for  
operational use, water resources may be under stress (water stressed areas). Water  
abstraction in such areas could, if not well managed, affect local availability for communities  
(wells, irrigation) and ecosystems, generating potential conflicts of use or future restrictions.  
In terms of the impact on the company, water is not a significant cost (water expenses are minor  
in the total structure), and in 2024 there were no business interruptions due to lack of water.  
However, the management of water resources is considered a material issue especially in  
terms of the impact that operations may have on the environment and communities, even if the  
immediate financial risks for CONPET S.A. are low.  
In terms of environmental and social impacts, the main water-related issues are: the possibility  
of accidental pollution of surface or groundwater in case of oil spills and the consumption of  
water from local sources. The company has implemented strict internal procedures to minimize  
these risks. Pollution prevention plans include specific water protection - for example, booms and  
weirs prepared to prevent crude oil from polluting rivers or streams in the event of a breakdown.  
In 2024, due to these preventive efforts, there was no significant water pollution caused by  
CONPET S.A.'s activities, which indicates the effectiveness of the protection systems. Water  
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4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
consumption is also constantly monitored to detect possible losses and prevent wastage.  
However, water abstractions in vulnerable areas remain an environmental concern: even if  
the volumes are small, the long-term cumulative impact on local aquifers needs to be carefully  
assessed and managed so as not to negatively influence human users or habitats that depend  
on those water resources.  
The risk analysis reveals several specific risks and opportunities in the water sector: A major  
risk is the scenario of accidental water pollution - for example, contamination of a river or  
groundwater following a pipeline burst - which would cause environmental damage, potential legal  
penalties, and substantial cleanup costs. Another risk, in the context of climate change, is that  
water resources are becoming more precious and there may be tougher restrictions on  
industrial water use (or higher costs of accessing it) in the future. On the other hand, there are  
opportunities for efficiency: by reducing own water consumption (e.g. optimizing testing  
processes and reusing water used in hydro-treating plants) and by applying water recycling  
technologies (such as filtering and recirculation systems for water used to wash equipment), the  
company can achieve operational savings and improve its environmental performance. By  
maintaining a track record of no significant water protection incidents (e.g. pollution incidents),  
the company also strengthens its relationships with local communities and authorities,  
demonstrating social responsibility and compliance with stakeholder expectations.  
Water and marine resources targets (ESRS E3-3)  
The Company complies with the limits imposed on the maximum flow rates for water supply from  
wells as required by law. However, there are no additional initiatives or measures that go beyond  
the compliance requirements required by law. The current impact of this practice is positive but  
negligible, as compliance with the limits contributes to the management of water resources  
without overexploiting them. Given that water is not a critical factor in CONPET S.A.'s operations  
- not being used directly in a production process - the influence of this progress on the company's  
overall sustainability remains moderate. The lack of proactive actions or extensive policies to  
conserve underground resources significantly reduces the potential to generate a more significant  
impact in the longer term. In this regard, CONPET S.A. proposes to formulate medium-term  
targets related to risk/opportunity management in water scarce locations/ reduction of water  
consumption, especially in water scarce locations.  
In conclusion, while water management is not a major financial risk for CONPET S.A. in the short  
term, the company is taking this issue seriously, integrating sustainable water management  
principles into its operations and preparing for a future in which water will be an increasingly  
valuable resource.  
4.5 Biodiversity and environmental protection (ESRS E4)  
Protecting the environment and biodiversity are key components of CONPET S.A.'s  
sustainability strategy. Taking into account that the crude oil transport infrastructure crosses  
diverse ecosystems and communities, the company applies good practices to prevent  
78 I SUSTAINABILITY REPORT CONPET S.A.  
 
4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
ecological impacts and has rigorous plans in place for incident management, ensuring a positive  
contribution to the conservation of local biodiversity.  
Biodiversity and ecosystem policies (ESRS E4-2)  
The company has environmental risk assessment procedures in place and has risk registers and  
control mechanisms in place for activities that may impact biodiversity. Although there is currently  
no dedicated biodiversity conservation policy, relevant assessments are integrated in the context  
of the risks associated with depollution works, accidental spills and maintenance activities. These  
assessments include preventive elements through monitoring of sensitive areas and corrective  
action in case of events. Although the biodiversity policy is not yet structured as a separate  
document, its principles are already implemented within the environmental risk management  
system. CONPET S.A. aims to translate them into a biodiversity policy.  
Biodiversity targets (ESRS E4-4)  
At present, there are no quantitative targets or dedicated strategies defined for the restoration of  
affected habitats, but there is a commitment that all greening works will comply with legal limits  
on land restoration and prevent the accumulation of petroleum substances. The internal  
assessment process recognizes that the lack of post-depollution biodiversity studies is a limitation  
and that this needs to be strengthened in the future. However, the current approach is based on  
the principle of "minimal impact and rapid remediation", which can be considered an operational  
form of targeting, even if not formally stated. Although CONPET S.A. has not implemented this  
policy at the date of the report, it is part of the strategy for the coming period.  
Impacts on biodiversity (ESRS E4-5)  
The impact on biodiversity is recognized as moderate and potentially negative, given that the  
infrastructure crosses natural areas where vulnerable species may occur. Both direct effects  
(such as accidental mortality, contamination or reduction in diversity) and indirect effects  
(alteration of food chains or habitat degradation) are recognized within the company, even if the  
degree of quantification is limited. In the absence of a clear dose-effect function, impact  
assessment is difficult, but the precautionary approach and integrated risk management provide  
an acceptable framework for compliance with ESRS requirements.  
CONPET's main efforts in this direction cover:  
Monitoring pipeline integrity and preventing leaks  
CONPET S.A. uses advanced technologies for continuous monitoring of the pipeline network and  
early detection of any product leakage, among which we mention: the modern system of  
detection and localization of crude oil leaks, capable of quickly identifying abnormal variations  
in pressure or flow rate that may signal a rupture in the pipeline, the cathodic protection system  
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4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
(which prevents corrosion of underground pipelines), the SCADA system, which provides  
centralized monitoring of operational parameters.  
The company also applies preventive and predictive maintenance methods: pipelines are  
regularly inspected, including internal inspections with smart dilwells (devices that walk inside the  
pipeline and detect any corroded or defective areas), so that weakened sections can be remedied  
before damage occurs. Data analytics and risk modeling are used to identify segments more likely  
to fail, directing maintenance resources to critical areas. In addition, the company has also begun  
using remote sensing techniques to monitor pipeline corridors - for example, aerial drone  
surveys and satellite monitoring - aimed at detecting unauthorized activities near pipelines  
(construction, digging) or sudden changes in the landscape (landslides, flooding) that could  
indicate a problem. By integrating these technologies, the company improves its early warning  
and incident prevention capabilities. Early detection of a leak is crucial to enable a rapid  
response and limit the extent of the impact: immediate intervention can prevent a major  
environmental disaster while reducing remediation costs. Overall, the monitoring systems and  
proactive maintenance programs implemented by CONPET S.A. enhance the safety of transport  
operations and protect the environment from accidental pollution.  
Oil spill prevention and response measures  
The prevention of oil spills into the environment is an absolute priority for CONPET S.A., given  
that some pipelines cross sensitive areas (watercourses, fertile agricultural areas, protected  
natural habitats). At the watercourse crossings, the pipelines are equipped with sectioning valves  
on both banks and collection bays for any accidental spills. In addition to prevention, the company  
has strengthened its rapid response capacity in the event of an incident. Automatic shut-off  
valves have been installed on strategic segments of the pipelines, which can immediately isolate  
the affected portion in the event of a sudden drop in pressure, limiting the volume of crude oil that  
could leak. At pumping and storage stations, retention basins and additional emergency  
barriers have been installed. For example, at the Constanța Sud station, the company has  
installed a buried spill collection tank equipped with a pump for liquid evacuation, equipped with  
an automatic pumping system that can capture any accidental crude oil spill before it  
contaminates the soil or water. Even in unfavorable scenarios, these facilities ensure that spilled  
fluids are quickly contained, preventing their dispersion into the environment. In terms of  
operational preparedness, CONPET S.A. maintains plans to prevent and combat accidental  
pollution, in accordance with legal requirements, and has specialized, adequately equipped  
intervention teams. In collaboration with the local authorities (Emergency Situations  
Inspectorates, environmental authorities), the company organizes regular simulations and  
drills for crude oil pollution scenarios in order to train staff and optimize response times. CONPET  
S.A. has also invested in modern spill response equipment: skimmers, booms, absorbent and  
protective booms, strategically stored along pipeline routes (especially near water) to be  
deployed quickly if the situation requires it. Sustained efforts towards preventive maintenance and  
early detection have yielded notable results - recent years have seen a decrease in the number  
of pollution incidents and the volume of oil spills, reflecting the effectiveness of the measures  
put in place. At the same time, key projects such as the replacement of the Borcea sub-crossing  
pipeline section (mentioned above) have substantially reduced the risk of spills in environmentally  
80 I SUSTAINABILITY REPORT CONPET S.A.  
4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
sensitive areas. In the unlikely event of a major spill, the company cooperates closely with the  
relevant environmental authorities to remediate the affected sites, aiming to restore the  
environment to its original state. Each incident is analyzed in detail, with a focus on continuous  
improvement of response time and intervention techniques so that the likelihood of similar events  
is minimized.  
Conserving biodiversity and restoring ecosystems  
CONPET S.A. pays particular attention to the restoration of the environment following any  
construction or maintenance works on its infrastructure. Internal procedures require that, after the  
completion of pipeline works, the affected land must at least be restored to its original condition.  
This involves, for example, replanting of local vegetation and trees in areas where soil has  
been excavated for pipeline replacement/inspection, as well as rehabilitation of the soil  
structure (compaction, restoration of topsoil) to allow habitat to be restored. In regions where  
pipelines cross valuable ecosystems - forests, wetlands, protected natural areas - CONPET S.A.  
works closely with environmental authorities to minimize the impact. A common practice is to use  
technologies without open trenching (e.g. horizontal directional drilling) when working under  
sensitive areas, as was the case for the Danube river undercrossing, precisely to avoid disturbing  
the riverbed and aquatic habitats. All of its operations strictly comply with applicable  
environmental regulations and standards; the company has a certified Environmental  
Management System (ISO 14001) that ensures continuous monitoring of environmental  
performance and compliance with legal requirements. Through these practices and standards,  
CONPET S.A. contributes to the protection of local flora and fauna and strives to leave a  
positive environmental legacy in the areas where it operates. Every approach - from proactive  
pipeline monitoring, to prompt spill response and land restoration - reflects CONPET S.A.'s  
commitment to sustainability and is aligned with ESRS guidelines on climate and environmental  
protection. The company will continue to enhance these programs, recognizing that protecting  
the environment is essential to creating long-term value and maintaining the trust of  
communities and partners.  
4.6 Circular Economy - Waste Management (ESRS E5)  
CONPET S.A. recognizes the importance of the circular economy and the reduction of waste  
generated by its activities, both for environmental protection and operational efficiency. The  
pipeline system operation and equipment maintenance activities generate various types of waste,  
including some hazardous ones, which require proper management. Waste generated includes:  
waste oils (from greasing of equipment and vehicles), oil sludge (residues collected from pumping  
stations or retention pans), contaminated soils and oil-soiled absorbent materials (from cleaning  
up minor incidents or maintenance work), and general industrial and household waste from the  
company's facilities.  
Policies on circularity and resource utilisation (ESRS E5-1)  
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4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
The company already applies a well-functioning waste collection, sorting and management  
system, implemented in all relevant workplaces. Collection is done selectively, with authorized  
partners and permanent take-back contracts, for controlled recovery or disposal. This process  
complies with current legislative requirements and its operation is integrated into the  
environmental compliance management system. Although there is no separate formal policy for  
circularity, the operational framework already demonstrates the consistent application of circular  
economy principles, in particular through actions aimed at preventing accidental pollution and  
maintaining a sustainable resource traceability regime. CONPET S.A. aims to adopt a policy on  
circularity and resource utilization in the coming period.  
As part of its waste prevention and reduction program, CONPET S.A. invests in innovative  
technological solutions, such as advanced equipment for cleaning paraffin pipes and reducing the  
amount of sludge in tanks. The company also purchases solutions for the efficient and selective  
storage of recyclable waste (paper, metal, plastic, glass), thus optimizing the waste management  
process.  
These measures contribute to reducing waste quantities, improving waste management,  
minimizing environmental impact through the use of state-of-the-art technologies and increasing  
the efficiency and safety of internal operations.  
From a business impact perspective, waste management is a material issue, as large amounts  
of waste or improper waste management can lead to environmental risks (pollution, odor, health  
problems) and additional costs (disposal fees, legal obligations for fines). At the same time, good  
waste management can bring operational efficiencies by recovering some reusable materials and  
reducing the volume requiring final disposal.  
In 2024, CONPET continued to apply a rigorous waste management system, following the  
principles of waste hierarchy. This approach has resulted in minimizing the volume of waste  
sent to landfill, reducing the risk of long-term pollution and possible future remediation costs. At  
the same time, the correct management of hazardous waste is essential for maintaining  
environmental permits and operating licenses, as any non-compliance can result in significant  
penalties.  
To support these principles, CONPET has implemented internal measures to prevent and reduce  
hazardous and non-hazardous waste, which include:  
Allocation of competent human resources: dedicated waste management and  
monitoring teams are present at each working point, ensuring constant monitoring.  
Sorting at source: Waste is separated by type (paper, metal, plastic, glass), facilitating  
efficient recycling and reuse.  
Monitoring and reporting: waste is monitored by type and location, and reports are  
submitted to the authorities as required by law, guaranteeing transparency and  
compliance, while ensuring waste traceability  
Waste trend analysis: Waste quantities are monitored to identify any significant increase  
so that causes can be identified and corrected.  
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4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
Resource planning: Emphasis is placed on the efficient use of materials that can  
generate waste, thereby reducing waste quantities.  
Preventive maintenance: Continued investment in technical equipment and processes  
helps to reduce breakdowns that could generate specific waste, such as oil-contaminated  
soils.  
Rapid response to damage: Rapid response measures limit the spread of pollution and  
prevent the generation of hazardous waste such as contaminated oil.  
Waste Management Contracts: All CONPET sites are equipped with compliant waste  
management contracts, respecting the principles of waste prioritization.  
Thus, these measures contribute to reducing the amount of waste generated, protecting the  
environment and complying with legal regulations, strengthening the efficiency of internal  
processes and maintaining the company's responsible environmental status.  
Re-use and recovery targets (ESRS E5-3)  
The company's approach includes clear measures to valorize waste and reduce the amount  
disposed of, in particular by avoiding the accumulation and efficient treatment of hazardous  
categories. Waste is identified, recorded and treated according to legal standards and is tracked  
through internal monitoring procedures. This practice continues to support recovery by authorized  
operators, and the implicit objective is to maintain a high level of re-use. Even if not expressed in  
a fixed annual percentage, there is an active strategic direction to minimize the quantity disposed  
of and maximize the recoverable components.  
In terms of environmental and social impact, it is noted that in 2024 CONPET S.A. managed  
the waste generated in accordance with legal requirements and good industry practice. Most  
of the waste collected was recovered or recycled, avoiding direct disposal. The company keeps  
transparent records of the amounts and types of waste generated and how it is treated, allowing  
full traceability - from the point of generation to the final destination (recycler, incinerator or  
landfill). This transparency demonstrates accountability and facilitates reporting to authorities and  
stakeholders. Through its recovery efforts, the company makes a practical contribution to the  
circular economy by reintroducing useful materials back into the economic cycle: for  
example, waste oils are taken back by specialized companies for re-refining or use as alternative  
fuels, metal from pipe section replacement is largely sent for recycling, and oil sludge is treated  
so that the hydrocarbon fraction can be recovered.  
However, it is important to note that the generation of hazardous waste is an unavoidable negative  
impact of CONPET S.A.'s activities, and regardless of process optimization, the maintenance of  
the crude oil infrastructure will continue to produce certain amounts of contaminated sludge and  
other residues. In 2024, there were no incidents of improper waste storage or disposal, which  
demonstrates the effectiveness of the waste management system. All hazardous waste was  
transferred to authorized operators and CONPET S.A. sites were not affected by pollution related  
to uncontrolled waste disposal  
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4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
On waste risks and opportunities: A potential risk is that as operations grow or become more  
complex, the volume of hazardous waste could increase, putting pressure on temporary storage  
capacities and increasing disposal costs. Environmental regulations also tend to become more  
stringent - more ambitious recycling targets or even bans on practices such as the landfilling of  
hydrocarbon-containing sludges could be imposed in the future, which may require new  
technological solutions. On the opportunities side, innovative waste management can bring  
financial benefits by generating revenues or savings for the company. CONPET S.A. can explore  
partnerships or emerging waste reduction technologies - for example, the use of more efficient  
filters and separators to reduce the amount of sludge produced, or the implementation of on-site  
bioremediation solutions for lightly contaminated soils, converting them to a safe state without  
the need for off-site transport. Also, engaging employees in Reduce-Reuse-Recycle initiatives  
(such as reducing the consumption of disposables in the office, donating used equipment that can  
be reused by other entities, etc.) contributes to a circular economy culture in the organization.  
Resource inputs - materials used (ESRS E5-4)  
In operations, compliant materials and technological substances are used, but no centralized  
input table is currently published. However, as part of the environmental management system,  
the company tracks and documents the amounts of resources consumed, especially those related  
to critical processes. It recognizes the importance of integrating this data into a dedicated  
inventory in the future, with clear indications of the percentage of recycled or sustainably sourced  
materials. The company's strategic direction is already moving in the direction of supply chain  
efficiency and optimization of resource consumption.  
Resource outputs - waste and recovery (ESRS E5-5 )  
Waste generated is identified by category - hazardous and non-hazardous - and is managed  
according to the treatment hierarchy. Recovery and disposal operations are carried out  
exclusively through authorized partners and monitoring is constant. The company keeps detailed  
records of waste types and treatment methods. Full traceability is followed and operational  
transparency is ensured including regular reporting to the authorities. The approach is a mature  
one, where ESG performance is reinforced by the internal control system and practical experience  
in circularity.  
Waste generated in 2024  
Recovery  
Co incineration Incineration Storage  
89,60 1,03 193,45  
Elimination  
Other  
operation  
Generat  
2.336,58  
Recycle  
171,81  
1.840,89  
Table 4.3. Waste generated in 2024  
In conclusion, CONPET S.A. treats both the consumption of water resources and waste  
management with the utmost responsibility as integral parts of its environmental performance.  
By carefully monitoring water consumption, preventing water pollution and reducing reliance on  
84 I SUSTAINABILITY REPORT CONPET S.A.  
4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
vulnerable sources, the company is minimizing its water footprint and potential adverse impacts  
on communities. At the same time, through effective waste management in line with the principles  
of the circular economy, the company reduces the risks of soil and water pollution, valorizes  
secondary resources and aligns with the EU's objectives of transition to a sustainable economy  
with minimized waste and reused resources. These practices contribute to increasing the  
company's environmental resilience and strengthen stakeholder confidence that operations are  
run in a long-term sustainable way.  
According to ESRS E1-3, companies must clearly demonstrate that their climate strategy is  
backed up by concrete actions and resource allocation - not just declarations of intent. CONPET  
S.A. has integrated its climate commitment into its operational and investment plans, mobilizing  
both financial and human resources to implement decarbonization and adaptation policies.  
CONCRETE ACTION TO MITIGATE CLIMATE CHANGE  
In recent years, CONPET has initiated projects and measures that are part of its Low Emission  
Business Plan:  
Programs to increase energy efficiency, such as modernization of equipment and  
facilities (e.g. replacement of pumps and motors with more efficient ones, automation)  
have been carried out to reduce fuel and energy consumption per unit of activity.  
Waste reduction and logistics optimization programs have been implemented (e.g.  
reuse of metal drums and other materials, circular economy projects, newly built tanks are  
equipped with mixers that, during operation, considerably reduce the amount of sludge  
(sludge-type waste) on the bottom of the tank) in order to decrease indirect emissions  
associated with waste transport and disposal.  
Renewable energy pilot projects have been launched (photovoltaic panels at stations,  
with plans to expand) marking the transition towards the use of zero emission sources in  
CONPET S.A.'s energy mix.  
Resources allocated and capacities developed  
In order to support the above actions, CONPET S.A. is considering the allocation of dedicated  
financial resources in its multi-year investment budgets. The company has also set up an  
internal sustainability/environmental structure that coordinates the reporting, monitoring and  
implementation of climate policies, and training programs have been carried out for staff on good  
practices in energy saving, waste management, environmental emergency response, etc.  
CONPET maintains transparent communication with investors and authorities on climate  
issues: it regularly reports on environmental indicators, responds to shareholder requests for  
information on ESG components and participates in corporate social responsibility initiatives that  
include environmental components. Thus, CONPET S.A. creates a collaborative environment  
around it, where customers, partners and communities can support and multiply the effects of its  
climate actions.  
85 I SUSTAINABILITY REPORT CONPET S.A.  
4. ENVIRONMENTAL IMPACT AND CLIMATE STRATEGY  
Monitoring and evaluating the effectiveness of actions (as per E1-3)  
A key element required by the ESRS E1-3 is the demonstration that the measures taken  
effectively lead to emission reductions. CONPET S.A. is committed to monitor greenhouse  
gas emissions annually and to continuously implement reduction measures so that in future  
years clear progress can be reported - i.e. a decrease in absolute emissions and improvement  
in intensity indicators compared to baseline.  
Another aspect highlighted by ESRS E1-3 is the alignment of resources with climate transition  
plans. In this respect, CONPET S.A. wants to integrate climate objectives into its future plan  
(including financial projections), ensuring dedicated budgets for emission reduction projects.  
CONPET S.A. does not operate in isolation, but can extend its climate initiatives throughout the  
value chain. Collaboration with external partners is a key resource: for example, selecting  
suppliers with high climate performance and integrating environmental criteria into the  
procurement process (as mentioned above) can amplify the impact beyond the limits of the  
company's direct operations. If suppliers also reduce emissions, the overall effect becomes  
significantly greater than what they could achieve on their own. Such initiatives, which involve  
time, effective communication and sometimes technical support for partners, reflect a concerted  
effort and strategic use of CONPET S.A.'s relationship capital in achieving climate goals.  
In conclusion, there are tangible actions underway, dedicated financial and human resources and  
the company is prepared to measure and communicate the results of these actions. Through  
consistent implementation of its plans and stakeholder engagement, the company demonstrates  
a planned and managed transition to a low-emission economy, fulfilling the ESRS E1-3  
requirements for disclosure of climate policy actions and resources.  
86 I SUSTAINABILITY REPORT CONPET S.A.  
CONPET S.A. invests in  
people, supporting workforce  
development and contributing to  
a sustainable future.  
5. SOCIAL RESPONSIBILITY AND WORKFORCE  
DEVELOPMENT  
5.1 Workforce composition and inclusion  
Employee structure of CONPET S.A. in 2024:  
The employee structure can be organized and presented according to various classification  
criteria, depending on the specifics and needs identified. This can be done on the basis of  
hierarchical level, internal functional entities, type of employment contract or field of activity.  
Employees may also be grouped according to education, specialization, qualifications, skills or  
specific responsibilities  
87 I SUSTAINABILITY REPORT CONPET S.A.  
   
5. SOCIAL RESPONSIBILITY AND WORKFORCE DEVELOPMENT  
Strictly from a workforce composition and inclusion perspective, data will be presented according  
to the following criteria:  
The demographic criterion based on age - considered relevant in this case, as it allows  
the analysis of the age structure of the workforce, thus facilitating the implementation of fair  
employment and professional development policies.  
The inclusion criterion - considered relevant in this case as it is essential to ensure  
representativeness and equal access to opportunities for all categories of employees,  
including people with disabilities.  
The qualification criterion - considered relevant in this case because of its importance in  
assessing the educational level of employees, contributing to the development of effective  
training and career mobility strategies.  
On 31 December 2024, the actual number of employees is 1,398 and the average number of  
employees is 1,387. The analysis in this chapter has been based on the actual number of  
employees, as this gives a more accurate picture of the structure of the workforce at a given point  
in time. At the same time, in line with ESG standards, the reporting of employment data is based  
on the actual number of employees to ensure comparability between companies and industries.  
Evolution of the average number of employees  
1.511  
1.600  
1.400  
1.200  
1.000  
800  
1.467  
1.414  
1.387  
600  
400  
200  
0
2021  
2022  
2023  
2024  
CHART 5.1. Evolution of the average number of employees at CONPET S.A. level.  
Out of the total number of employees, 16 of them have fixed-term employment contracts and the  
rest are employed on permanent contracts.  
Within the company, the breakdown by gender is as follows: 287 female employees, representing  
21% of the total, and 1,111 male employees, which constitutes 79% of the total number of  
employees.  
88 I SUSTAINABILITY REPORT CONPET S.A.  
5. SOCIAL RESPONSIBILITY AND WORKFORCE DEVELOPMENT  
Table 5.1. Actual number of employees by gender  
Total number of  
employees  
1.398  
Number of male  
employees  
1.111  
Number of female  
employees  
287  
Country  
România  
In terms of the distribution of employees by geographical area (according to SBM1-40.a.iii), the  
largest share is held by employees from the Municipality of Ploiești, representing 43.71% of the  
total workforce.  
Table 5.2. Distribution of employees by geographical area  
Region/  
Geographical  
area  
Băicoi  
Boldeşti  
Total  
number of  
employees  
23  
Percentage of  
total  
employees  
Types of activities  
carried out  
County  
1,65%  
0,14%  
1,07%  
Operational  
Operational  
Operational  
2
15  
Brazi  
Operational  
Economic  
Prahova  
Ploieşti  
611  
43,71%  
Administrative  
Scorţeni  
Urlaţi  
Feteşti  
Grindu  
Urziceni  
Berca  
4
44  
8
2
5
15  
23  
2
0,29%  
3,15%  
0,57%  
0,14%  
0,36%  
1,07%  
1,65%  
0,14%  
0,29%  
2,29%  
0,86%  
1,72%  
1,93%  
0,64%  
2,07%  
0,36%  
3,51%  
0,93%  
2,72%  
1,14%  
2,15%  
0,29%  
2,07%  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Operaţional  
Operaţional  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Ialomiţa  
Buzău  
Brăila  
Cireşu  
Ianca  
Comăneşti  
Moineşti  
Cătălina  
Independenţa  
Moreni  
Răcari  
Raciu  
Piteşti  
Poiana Lacului  
Marşa  
Roata de Jos  
Pecica  
Biled  
Vâlcani  
Marghita  
4
Bacău  
32  
12  
24  
27  
9
Covasna  
Galaţi  
Dâmboviţa  
Argeş  
29  
5
49  
13  
38  
16  
30  
4
Giurgiu  
Arad  
Timiş  
Bihor  
29  
89 I SUSTAINABILITY REPORT CONPET S.A.  
5. SOCIAL RESPONSIBILITY AND WORKFORCE DEVELOPMENT  
Region/  
Geographical  
area  
Salonta  
Suplacu de  
Barcău  
Total  
Percentage of  
total  
employees  
Types of activities  
carried out  
County  
number of  
employees  
7
0,50%  
Operational  
Operational  
18  
1,29%  
Bărbăteşti  
Țicleni  
Orleşti  
Fărcaş  
62  
6
49  
6
14  
9
16  
10  
47  
5
4,43%  
0,43%  
3,51%  
0,43%  
1,00%  
0,64%  
1,14%  
0,72%  
3,36%  
0,36%  
1,43%  
0,14%  
3,36%  
0,36%  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Operational  
Gorj  
Vâlcea  
Dolj  
Gherceşti  
Cungrea  
Icoana  
Cernavodă  
Constantă  
Mircea Voda  
Borcea  
Dragoş Voda  
Tămădău Mare  
Tătăranu  
Olt  
Constantă  
20  
2
47  
5
Călăraşi  
Vrancea  
Another key aspect of sustainability is diversity and equal opportunities. CONPET S.A. promotes  
an inclusive work environment where all employees have access to equal opportunities for  
professional growth:  
o
o
32% of employees in management positions are women;  
37.6% of employees with a higher education are women, showing balanced access to  
expert roles.  
Women  
32%  
Men  
68%  
Men Women  
CHART 5.2. Management structure by gender in 2024 (without senior managers with  
mandate)  
90 I SUSTAINABILITY REPORT CONPET S.A.  
5. SOCIAL RESPONSIBILITY AND WORKFORCE DEVELOPMENT  
The evolution of the staff structure by education and gender reveals that the company promotes  
a non-discriminatory behavior by hiring female specialists with higher education and professional  
skills that contribute to the growth of the company's business results. These data confirm  
CONPET S.A.'s commitment to creating a fair and inclusive environment, an essential element of  
sustainable performance.  
Demographic structure  
The age structure of CONPET S.A.'s staff reflects the fact that 59% of the employees are over 50  
years of age, which suggests an experienced team, but also a need to train a new generation of  
specialists. The average age of staff is 50.2 years, reflecting the experience and stability of the  
organization. New hires in the last two years have an average age of 40.41, indicating a gradual  
transition to a younger team.  
The age structure of employees at company level is reflected in 3 broad categories as follows:  
o
o
o
Under 30 - 56 out of the total number of employees;  
30-50 years - 511 employees;  
Over 50 - 831 employees.  
< 30 years  
Women  
Men  
4%  
30-50 years  
21%  
> 50 years  
37%  
59%  
79%  
CHART 5.3. Staff structure by age groups and gender in 2024  
Inclusive structure  
From the perspective of the inclusive structure, the analysis of CONPET S.A.'s workforce focuses  
on two key aspects: the degree of unionization and the employment of people with disabilities.  
91 I SUSTAINABILITY REPORT CONPET S.A.  
5. SOCIAL RESPONSIBILITY AND WORKFORCE DEVELOPMENT  
Employees with disabilities  
1,29%  
98,49%  
Degree of unionization  
0,00% 20,00% 40,00% 60,00% 80,00% 100,00%  
CHART 5.4. Employee inclusion in 2024  
The degree of unionization refers to the membership of employees in the LIBER CONPET  
Trade Union, an organization that represents the interests of employees and supports their rights  
in their relationship with the employer. According to the data collected 98.50% of the company's  
employees are members of the trade union Liber Conpet S.A. This reflects a high level of  
cohesion and solidarity among CONPET S.A. employees, demonstrating that they are actively  
involved in protecting their rights and supporting a fair working environment. Membership in the  
LIBER CONPET Trade Union not only provides representation in the relationship with the  
employer, but also strengthens a framework of effective social dialog, where the voice of the  
employees is heard and respected. This collective involvement underlines a strong commitment  
to stability, fairness and job security within the company.  
In terms of employment of people with disabilities, 1.29% of CONPET S.A.'s workforce is in  
the category of employees with disabilities, this indicator reflects the company's commitment to  
inclusion and equal opportunities. The concern for the integration of people with disabilities in the  
work environment contributes to the diversity of the workforce and demonstrates an active policy  
of social responsibility.  
The nature of the company's activity imposes strict requirements on the aptitudes of employees,  
which limits the possibility of employing a larger number of people with physical and/or cognitive  
disabilities, since in most workplaces within the production sectors, risks have been identified that  
may generate accidents or occupational diseases with serious, irreversible consequences,  
namely death or disability (art.2, point 4 of HG 1425/2006 for the approval of the Methodological  
Norms for the application of the provisions of the Law on occupational safety and health no.  
319/2006).  
If the percentage of 1.29% can be considered a low value, compared to the total number of  
employees of the company, it should be noted that at national level (according to INSSE.RO) -  
about 2.7% of the national population is included in this category, but over 60% of these people  
92 I SUSTAINABILITY REPORT CONPET S.A.  
5. SOCIAL RESPONSIBILITY AND WORKFORCE DEVELOPMENT  
cannot be employed in the labor force for reasons of age + 65 or - 18 years. Thus - at national  
level, about 1.08% of the existing workforce has disabilities while at societal level, 1.29% of the  
workforce has disabilities.  
According to art.78 para. 2 of Law 448 /2006 with subsequent amendments and additions,  
employers with more than 50 employees have the obligation to employ disabled persons in a  
percentage of at least 4% of the total number of employees. Since CONPET S.A. does not cover  
this percentage, in order to comply with the legal provisions, it has opted, in accordance with  
art.78 paragraph 3 of the same normative act, for:  
a) the monthly payment to the state budget of an amount equal to the guaranteed gross  
minimum basic national wage multiplied by the number of jobs in which they have not employed  
persons with disabilities, or  
b) monthly payment to the state budget of an amount representing the equivalent of at least  
50% of the minimum gross basic salary guaranteed in payment multiplied by the number of  
jobs in which they have not employed persons with disabilities, and with the amount  
representing the difference up to the amount provided for in letter a) to purchase, on a  
partnership basis, products and/or services made by their own activity of persons with  
disabilities employed in authorized protected units.  
Thus, the employment of people with disabilities is an important indicator of inclusion and  
diversity policy. The concern for their integration into the workforce demonstrates the company's  
commitment to the principles of equal opportunities and professional accessibility.  
Educational structure  
The analysis of CONPET's workforce structure in terms of educational attainment provides a  
clear picture of diversity and professional balance, highlighting how employee education  
contributes to the inclusion and stability of the organization.  
Educational attainment is a key criterion in the composition of the workforce, as it influences  
the distribution of responsibilities, opportunities for professional development and access to  
management positions. It is also a relevant factor for occupational inclusion, having a direct  
impact on access to jobs and career advancement opportunities.  
In terms of educational level, the majority of CONPET S.A. employees have medium and higher  
education, with a predominance of age groups between 41 and 60 years. The age distribution  
shows that 53.65% of the employees fall in the 51-60 age group, while 24.89% are in the 41-50  
age group. Younger employees in the 20-40 age group represent approximately 15.67% of all  
staff, emphasizing the need for sustainable recruitment and retention strategies to gradually  
replace experienced staff.  
93 I SUSTAINABILITY REPORT CONPET S.A.  
5. SOCIAL RESPONSIBILITY AND WORKFORCE DEVELOPMENT  
1800  
1600  
1400  
1200  
1000  
800  
40,00%  
39,00%  
38,00%  
37,00%  
36,00%  
35,00%  
34,00%  
33,00%  
600  
400  
200  
0
2020  
2021  
2022  
2023  
2024  
Total employees  
Higher-educated employees  
Percentage of total  
.
CHART 5.5. Percentage of staff with tertiary education 2020- 2024  
In this context, the company carefully monitors the needs to fill vacancies, taking into account the  
demands of organizational structures, the complexity and diversity of activities, the professional  
skills required and the responsibilities of each position. This strategic approach ensures continuity  
of operations and the company's adaptability to labor market challenges.  
To ensure the sustainability of the workforce, the company has stepped up mentoring, continuous  
training and intergenerational knowledge transfer programs.  
TABLE 5.3. Distribution of CONPET S.A. employees by educational level and gender  
Total  
employees  
83  
Share  
total  
in  
Educational level  
Women  
7 (0,50%)  
Men  
General studies  
Medium  
education  
5,94%  
54,36%  
39,70%  
76 (5,44%)  
689 (49,28%)  
346 (24,75%)  
760  
555  
71 (5,08%)  
209 (14,95%)  
Higher education  
94 I SUSTAINABILITY REPORT CONPET S.A.  
5. SOCIAL RESPONSIBILITY AND WORKFORCE DEVELOPMENT  
Distribution of employees by educational level  
5,94%  
39,70%  
54,36%  
General  
Medium  
Superior  
CHART 5.6. Distribution of employees by educational level  
Staff with general education (83 employees) - This is a smaller category with  
predominantly operational roles. Even if these employees do not have advanced  
education, the experience and practical expertise they have acquired are important factors  
contributing to the smooth running of the company's business. The inclusion of this  
segment is essential to maintain a diverse workforce accessible to all social groups.  
Staff with secondary education (760 employees) - This is the dominant segment within  
the company, demonstrating that technical and operational specializations are  
fundamental to CONPET S.A.'s activity. This category of employees benefits from  
continuous training, contributing to increasing professional skills and maintaining a high  
level of performance. In addition, the presence of a large number of employees with an  
average education emphasizes the company's openness to the integration of a wide  
range of professional qualifications, ensuring diversity and flexibility within the team.  
Staff with higher education (555 employees) - The significant percentage of employees  
with graduate or post-graduate degrees emphasizes a strategic orientation towards  
expertise, innovation and informed decision-making. This category includes leaders,  
specialists and advanced technical staff with a direct impact on the organization's  
development. In terms of inclusion, it is important that this category is accessible to all  
through fair promotion and career development policies.  
95 I SUSTAINABILITY REPORT CONPET S.A.  
5. SOCIAL RESPONSIBILITY AND WORKFORCE DEVELOPMENT  
COMPARATIVE STAKEHOLDER ANALYSIS IN THE SOCIAL CONTEXT  
Comparative conclusions - CONPET S.A. vs. other regional operators. The present analysis,  
based on academic literature and 2023-2024 reports, confirms that the main social aspects  
(ESRS S1-S4) - working conditions (including employee safety and well-being), diversity and  
inclusion, impact on communities and social due diligence along the value chain - are key in  
assessing the sustainable performance of Eastern European companies. Companies in the  
region are broadly aligning in direction with international practices, but there are still  
differences in degree and maturity. CONPET S.A. illustrates well both progress and remaining  
challenges:  
Own Workforce (S1): CONPET S.A. places a strong emphasis on operational safety  
and employee well-being, similar to large energy companies for which safety at work is  
"priority zero" (ipieca.org). The extra-wage benefits, health and training programs  
implemented at CONPET S.A. reflect stakeholder expectations for decent working  
conditions. The differentiation from Western companies is in the resources allocated  
rather than in the commitment, while CONPET S.A. focuses on the basics (safety,  
competitive wages, training). However, the current level of CONPET S.A. is not to be  
neglected; salary increases and work-life balance initiatives are mentioned, indicating an  
effort to align to modern HR standards. Furthermore, it integrates environmental and  
health and safety policies, highlighting an integrated approach to operational  
sustainability.  
Diversity and Inclusion (S1): CONPET S.A. stands out for the fact that more than 30%  
of management positions are occupied by female employees.  
Supply chain (S2): In terms of social due diligence towards suppliers and contractors,  
CONPET S.A. is probably at a level comparable to local companies of similar size: it has  
procedures in place for selecting and evaluating contractors, enforces compliance with  
labor laws and safety standards, but has not publicly reported the existence of an  
extensive due diligence framework (e.g. human rights audits or remediation plans).  
CONPET S.A. is considering developing a due diligence policy aligned to EU standards,  
covering supplier social risk assessment, third party complaint mechanisms and  
improvement targets (this is also the direction indicated by 97% of oil and gas companies,  
which already report setting ESG targets that include the value chain (ipieca.org)). An  
indication that the focus is shifting to the supply chain is also the fact that human rights  
(communities, own workforce and supply chain) are emerging as one of the most  
important ESG themes of the future for companies (ipieca.org). CONPET S.A. applies a  
clear set of rules and procedures regarding the selection and evaluation of suppliers and  
contractors, in accordance with the Procurement Procedural Rules - revision 6 and  
procedure PO-60-13 - Contracting transport of products through SNT and monitoring the  
fulfillment of contractual requirements. According to these provisions: 'The selection of  
suppliers shall be carried out on the basis of objective criteria that ensure accessibility and  
fairness, without restricting the participation of any supplier. Participation guarantee and  
performance bond shall be required for all contracts, ensuring transparency and  
contractual compliance." In addition, the company applies specific procedures for  
96 I SUSTAINABILITY REPORT CONPET S.A.  
5. SOCIAL RESPONSIBILITY AND WORKFORCE DEVELOPMENT  
evaluating the performance of suppliers of products, services and materials (PO-50-02  
and PO-50-07), and evaluation criteria include legal compliance, technical performance,  
ethics, integrity and adherence to contractual deadlines. Although there is no formalized  
supplier code of conduct, ethical and integrity requirements are built into the contracts and  
partners are obliged to comply with labour legislation, SSM requirements and  
environmental protection rules.  
Local communities (S3): CONPET S.A. stands out in terms of traditional community  
involvement, characteristic of companies with majority state capital and a historical  
presence in oil-industrial areas. Compared to other younger private companies or  
multinational corporations, CONPET maintains an institutional link with local communities,  
supporting them through sponsorships and partnerships tailored to specific needs. The  
company's activities are centered around the communities in the oil industrial zones,  
especially around the pumping stations, crude oil pick-up and transport points (locations  
such as Ploiești, Băicoi, Moreni, Independența, Cireșu, Moinești, Marghita, Biled, Orlești  
and Constanța-Bărăganu) where the company carries out its activities and has a direct  
impact on the community. These towns and municipalities, with a history in the oil industry,  
have developed an economic and social dependence on CONPET's infrastructure and  
employment. In the event of a reduction in the company's activity, accelerated energy  
transition without local support measures or operational risks (such as spills, pollution or  
major damage), these communities may be directly affected, which underlines the  
importance of protecting them through appropriate measures. In addition to operational  
impact, CONPET is actively involved in supporting local communities by supporting  
education and social causes.  
Data privacy and accountability to users (S4): CONPET S.A. does not have activities  
with direct exposure to individual consumers, having a B2B (business-to-business)  
operating model, but the ESRS S4 theme is considered material from the perspective of  
protecting personal data, correctly informing business partners and maintaining a high  
level of transparency. In this respect, the company has implemented a robust procedural  
framework for compliance with Regulation (EU) 2016/679 (GDPR), ensuring: protection of  
employee, customer and business partner data; limiting access to personal data through  
internal security controls; IT systems protected by cybersecurity policies; regular staff  
training on data processing and protection. In 2024, there were no incidents of data leaks  
or complaints of poor information. However, CONPET S.A. is aware that global information  
protection risks are increasing and will therefore: consider the opportunity to obtain  
information security certifications (e.g. ISO/IEC 27001); will expand its audit and control  
systems for data protection; will consider including in the next reporting cycle a feedback  
or complaints mechanism from industrial customers or partners on access to information,  
in line with ESRS S4.5 and S4.7 requirements. By this approach, the company ensures  
alignment with ESRS requirements on consumer rights, transparency and data protection,  
adapted to its specificity as a strategic infrastructure operator.  
In conclusion, the social impact according to ESRS S1-S4 provides a comprehensive framework  
through which we can compare the performance of companies in Eastern Europe. The energy  
and fuel transport industry, by its nature, has a significant social impact, and companies in the  
97 I SUSTAINABILITY REPORT CONPET S.A.  
5. SOCIAL RESPONSIBILITY AND WORKFORCE DEVELOPMENT  
East are increasingly adapting their practices to stakeholder expectations. CONPET S.A. is  
aligned with regional trends in many respects: it has a strong track record on safety and  
community involvement, and is taking steps towards modernization in human resources  
management. The differences from similar companies in the region are subtle - some may have  
access to global expertise, so may be more advanced in diversity or supply chain due diligence,  
while others are at a comparable or even lower level.  
In the ESRS S1-S4 benchmarking of social impacts, the priority issues are safe and fair  
working conditions, protecting and engaging employees and workers in the supply chain,  
promoting diversity, maintaining a responsible relationship with communities and  
ensuring diligence in the supply chain. Differences between CONPET S.A. and other similar  
companies in the region tend to be nuanced, relating to the maturity and transparency of  
approaches rather than their direction. By implementing good practices highlighted in the literature  
and rigorously reporting on progress, companies such as CONPET S.A. can not only meet ESRS  
requirements, but also gain a competitive advantage and build trust and confidence from  
stakeholders.  
5.2 Employee welfare, training and safety  
In this section, two essential aspects for the development and protection of CONPET S.A.  
employees will be analyzed:  
o Professional training and attending courses;  
o Occupational health and safety (OHS) indicators;  
Vocational training - course participations in 2024  
Investing in the professional development of employees is an essential element in maintaining  
a high level of competence, adapting to market demands and increasing organizational  
efficiency. By participating in training and specialization courses, employees improve their  
professional skills and competences, which contributes to increased productivity and the  
creation of a knowledge-based and innovative working environment.  
TABLE 5.4. Structure of professional training and licensing courses 2021-2024  
Number of participations  
Type of training  
2024  
111  
2023  
106  
2022  
119  
2021  
73  
245  
302  
439  
15  
Various authorizations  
Authorizations C.F.  
372  
376  
251  
Training courses  
371  
464  
413  
Internal authorizations  
Internal qualifications/training  
Total training/authorizations  
428  
2.327  
3.609  
407  
1.345  
2.698  
450  
1.167  
2.400  
1.074  
The highest share of participations is in internal trainings and qualifications (2,327  
participations), which demonstrates a constant concern for the continuous development of staff  
and their adaptation to the company's requirements.  
98 I SUSTAINABILITY REPORT CONPET S.A.  
 
5. SOCIAL RESPONSIBILITY AND WORKFORCE DEVELOPMENT  
Employee participation in training plays a key role in developing skills, maintaining workplace  
stability and preventing operational risks. Through continuous training, employees improve the  
skills they need to carry out their work in optimal conditions, meeting the safety and efficiency  
standards required by the company. These training programs contribute not only to increasing the  
level of qualification, but also to providing opportunities for professional development,  
strengthening the expertise needed to fulfill the specific responsibilities of each area of activity.  
The high number of participants in these courses demonstrates the company's commitment to  
continuous staff training, supporting a safe, high-performance working environment adapted to  
changing requirements.  
Another essential component of social sustainability is ensuring employee well-being through fair  
benefits and working conditions, measures that contribute to staff retention and the creation of a  
motivating work environment, which CONPET S.A. actively supported in 2024 by:  
o
Increased per diem for domestic travel compared to the deductibility limit provided for in  
the Tax Code  
o
o
o
o
o
Paid day off on your birthday.  
Payment for tourist services.  
Contribution to the optional pension fund (Pillar III).  
Voluntary health insurance.  
Meal vouchers.  
In addition, to ensure the sustainability of human resources, CONPET S.A. monitors and  
manages risk factors such as:  
Retirement of experienced employees, which requires mentoring and knowledge transfer  
strategies.  
Difficulties in recruiting technical specialists, especially in operational and engineering  
areas.  
Through this approach, the company ensures that its workforce remains a factor of stability and  
progress in implementing ESG strategies.  
Occupational Health and Safety (OHS) Indicators  
In this section, occupational health and safety (OHS) issues are not represented graphically,  
but are analyzed on the basis of relevant indicators reflecting the measures put in place to protect  
employees and prevent occupational risks.  
A key element of this analysis is the total number of workplace accidents, which in 2024 was  
zero. This result confirms the effectiveness of the prevention strategies implemented by the  
company and demonstrates that the implemented safety measures are effective in protecting  
employees.  
Another key aspect is the ISO 45001 certification, which has been obtained and maintained by  
the company. This certification attests that the occupational health and safety management  
system complies with international standards, thus ensuring a safe and controlled working  
environment for employees.  
99 I SUSTAINABILITY REPORT CONPET S.A.  
5. SOCIAL RESPONSIBILITY AND WORKFORCE DEVELOPMENT  
Another relevant indicator is the frequency of SSM trainings, conducted regularly according to  
the minimum mandatory topics approved at management level, as continuous safety training  
contributes to the awareness and prevention of occupational risks. Through these training  
sessions, employees are informed and prepared to manage risk situations, reducing the likelihood  
of occupational accidents.  
In addition, occupational risk assessment is carried out whenever the situation requires it,  
which allows the identification and minimization of potential hazards in the work performed. This  
proactive approach is essential for maintaining a safe and compliant working environment and  
keeping the company's Global Risk Level below the target of 3.5.  
In conclusion, by constantly monitoring these indicators and implementing effective preventive  
measures, CONPET ensures a safe and well-regulated working environment, minimizing risks for  
employees and strengthening the organizational culture focused on safety and responsibility.  
Indicator  
Value (2024)  
Total number of accidents at work  
ISO 45001 certification  
0
Yes (certificate)  
Periodical  
Yes  
Frequency of SSM training  
Occupational risk assessment  
5.3 Community engagement and CSR initiatives  
Corporate Social Responsibility (CSR) is the voluntary commitment of a company to contribute to  
the sustainable development of the company, beyond its economic and legal obligations. In this  
sense, CSR goes beyond financial performance and includes actions to support employees, the  
community and the environment by promoting ethical and sustainable practices.  
The CSR directions that will be considered to showcase the company's commitment to the  
community are:  
Employee well-being through social benefits, development opportunities and a safe  
working climate.  
Supporting the community through sponsorships and initiatives with educational,  
cultural and social impact.  
Ethical governance and social responsibility through transparency, equal  
opportunities and promoting diversity.  
In this context, CONPET S.A.'s commitment to the community and CSR initiatives are  
reflected in a series of concrete actions, which are perfectly aligned with CSR principles:  
a) Supporting employees and their families through social benefits  
CONPET S.A. offers an extensive benefits package that supports both employees and  
their families, contributing to the economic and social stability of the community. These  
include:  
100 I SUSTAINABILITY REPORT CONPET S.A.  
 
5. SOCIAL RESPONSIBILITY AND WORKFORCE DEVELOPMENT  
o Payment of tourist and treatment services for employees.  
o Financial support for the upbringing and education of employees' children, including  
after-school program.  
o Aid for serious illness, prostheses, financial support for important life events (marriage,  
childbirth, death).  
o Voluntary health insurance and contributions to the voluntary pension fund (Pillar III).  
b) Social dialogue and relations with trade unions  
One of the pillars of social responsibility is the relationship between employees and  
employer, and CONPET S.A. demonstrates a strong commitment to this issue. With a  
unionization rate of 98.50%, the company ensures an open and constructive dialogue with  
employee representatives, which is reflected in the protocols concluded and collective  
bargaining aimed at improving working conditions. This practice contributes to  
organizational stability and a professional climate based on respect and fairness.  
c) Community involvement through sponsorships and partnerships  
CONPET S.A. is actively involved in supporting the community, supporting educational,  
cultural and health projects through sponsorship and strategic partnerships. These actions  
contribute to the social and economic development of the regions where the company  
operates, thus strengthening its role as a responsible actor in the community.  
In 2024 the third edition of the Blood Donation Campaign organized by CONPET S.A. took  
place. In October, with the support of the Ploiesti Blood Transfusion Center, 60 employees of  
the company donated blood at the Ploiesti Central Dispatch Headquarters.  
EQUAL OPPORTUNITIES AND INCLUSION  
In the spirit of responsible governance, CONPET S.A. promotes an inclusive and fair work  
environment, ensuring equal opportunities for all employees, regardless of gender or social  
status. The fact that 32% of managerial positions are held by women reflects the company's  
commitment to the principles of diversity and fairness in recruitment and promotion.  
Through its employee support initiatives, active social dialogue, community involvement  
and promotion of diversity, CONPET S.A. not only respects CSR principles, but also  
actively integrates them into its organizational culture.  
101 I SUSTAINABILITY REPORT CONPET S.A.  
6. CORPORATE GOVERNANCE AND ETHICAL  
CONDUCT  
Corporate governance: requirements and impact of ESRS G1  
Corporate governance is Pillar G (Governance) of ESG approaches, and is codified in the new  
European Sustainable Sustainability Reporting Framework (ESRF) through ESRS G1 - Business  
Conduct. This standard requires companies to report on how the organization's management  
and control structures establish the ethical culture, manage risks and ensure compliance with  
integrity principles (getsunhat.com). ESRS G1 covers a number of key sub-topics related to  
business conduct, such as corporate culture, protection of public interest whistleblowers, political  
involvement and lobbying, managing supplier relationships (including payment practices), and  
preventing corruption and bribery (including mechanisms for detecting, training and reporting  
incidents) (getsunhat.com). These issues are particularly relevant for companies in the energy  
and fuel transport sectors, where transparency, ethics and effective operational and compliance  
risk management are essential.  
102 I SUSTAINABILITY REPORT CONPET S.A.  
 
6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
Corporate governance in Eastern Europe has improved in recent years, but challenges specific  
to the post-transition context remain. Many large energy and utility companies are still state-  
owned, which has in the past led to problems of political interference and non-transparent  
practices (sgi-network.org.) International organizations and European institutions have stressed  
the need to strengthen governance in these companies.  
Integrating ESG responsibilities into the governance structure  
In order to align the company's governance structure with the requirements of OMF No 85/2024,  
the report proposes to strengthen ESG integration through clear and legally compliant measures:  
Clarification of the Board's responsibilities for sustainability oversight (48^6 lit. c):  
introduction of regular reporting on ESG performance to the Board and establishment of  
clear monitoring mechanisms.  
Ensure ESG competencies for the Board and BoD (48^6 lit. c): develop a framework for  
mandatory ESG training for Board members and the management team, ensuring access  
to the necessary expertise as required by the legislation.  
Assess the opportunity of integrating ESG KPIs into the variable remuneration system  
(48^6 lit. e): analyze the possibility of linking ESG indicators (emission reduction, energy  
efficiency, workplace safety) with the management incentive system.  
These measures support transparency, alignment with the ESRS and strengthen accountability  
in corporate decision-making.  
Declaration on due diligence - CONPET S.A. (GOV-4)  
CONPET S.A. places particular emphasis on due diligence as part of corporate governance, with  
the aim of identifying, preventing and managing the risks associated with its activities. In this  
regard, the company will implement in the medium term a formalized system to ensure  
transparency and accountability in all decision-making and operational processes.  
1. Risk identification  
CONPET S.A.'s due diligence process will include the assessment of environmental, social and  
governance (ESG) risks associated with all of its activities, with a particular focus on their impact  
on stakeholders. This process will involve identifying risks at each stage of the value chain, from  
transport of crude oil to interaction with local communities and other stakeholders.  
2. Risk prevention and mitigation  
For each identified risk, the company shall adopt preventive and mitigating measures, integrating  
these measures into operational and decision-making strategies. These measures will include  
implementation of internal policies, safety protocols, and employee training programs.  
103 I SUSTAINABILITY REPORT CONPET S.A.  
6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
3. Monitoring and reporting  
CONPET S.A. will monitor risks and their impacts, taking into account local and international  
regulations. Progress in ESG risk management will be regularly reported to the Board of Directors  
and the results made available to stakeholders through transparent communication channels.  
4. Integration into decision-making  
The findings of the due diligence process will be integrated into the company's decision-making  
process to ensure alignment with CONPET S.A.'s sustainability and corporate responsibility  
objectives.  
6.1 Board structure and ESG governance  
Corporate Governance continues to be in a process of adaptation to the requirements of a modern  
economy, to the increasingly evident globalization of social life and at the same time to the needs  
of informing investors and third parties interested in the activities of companies.  
CONPET's corporate governance system is constantly being improved in order to ensure  
compliance with the rules and recommendations applicable to a company listed on the Bucharest  
Stock Exchange. CONPET S.A. is a company whose shares are traded on the regulated market  
administered by the Bucharest Stock Exchange, on the Main segment, in the Equity Securities  
sector - PREMIUM category, under the symbol COTE, with the globally unique identifier for  
entities LEI Code 254900P00DXXOYOYGGAQ77.  
CONPET's corporate governance is organized and carried out in accordance with the legal  
framework in Romania, namely the Companies Law no. 31/1990 and the Government Emergency  
Ordinance no. 109/2011 on the corporate governance of public enterprises.  
Also, CONPET being a company listed on the Bucharest Stock Exchange, the capital market  
legislation is applicable to it and it has adhered to the provisions of the Corporate Governance  
Code of the Bucharest Stock Exchange, applying the provisions of this code regarding the  
responsibilities of the Board of Directors, the risk management and internal control system, fair  
reward and motivation, added value through investor relations.  
As an issuer listed on the Bucharest Stock Exchange, CONPET has promoted and approved by  
Decision of the Board of Directors no. 7 of March 27, 2014 its own Corporate Governance  
Regulation. This document represents the voluntary assumption by the Company of the principles  
of corporate governance, taking into account its specific characteristics and activity in accordance  
with the principles set out in the Corporate Governance Code of the Bucharest Stock Exchange.  
The Regulation is a public document and can be viewed on the Company's website in the  
Corporate Governance/ Corporate Governance Regulation section.  
CONPET presents detailed information on governance in its annual report, which includes a  
corporate governance chapter reporting how the company complied with the corporate  
governance code during the year by completing a corporate governance statement containing a  
self-assessment of how the company has complied with the corporate governance provisions.  
104 I SUSTAINABILITY REPORT CONPET S.A.  
 
6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
This chapter also usually covers the activities of the board of directors, changes to governance  
policies, the work of board committees and any governance events during the year. The company  
also has policies on related party transactions and has an entity in place to ensure transparent  
communication with investors and regulators.  
In applying the general regulatory framework, CONPET has adopted documents through which  
corporate governance is put into practice:  
The Constitution of CONPET, which contains provisions relating to the governing bodies  
(general assembly, board of directors, executive management), as well as their powers and  
operating procedures;  
The Rules of Organization and Functioning of the Administrative Board, which detail and  
operationalize how this body meets, how it reviews, debates and takes decisions, how it  
interacts with the executive management and other parties;  
CONPET's Rules of Organization and Functioning, Code of Ethics, Internal Rules, which take  
over, detail and operationalize some incidental aspects of the company's governance  
framework  
The implementation of transparency and governance measures within CONPET S.A. takes into  
account aspects such as:  
adoption of the Corporate Governance Code;  
publication of annual/ preliminary annual/ quarterly/ half-yearly reports;  
AGM publication: notices, materials/documents related to the items on the agenda of the  
meetings, AGM resolutions (AGOA, AGEA), other documents considered to be relevant;  
adopting and publishing the social responsibility policy;  
adoption and publication of the Code of Ethics and Integrity;  
publishing declarations of assets and interests;  
publication of the Society's organizational chart;  
appoint members of the Board of Directors and executive management on professional  
criteria;  
adoption and publication of the Internal Rules of the Administrative Board and Advisory  
Committees;  
developing policies applicable at company level: Remuneration policy for directors and  
directors with a mandate, Policy on the evaluation of the Board of Directors, Policy on  
related party transactions;  
publication of the composition of the Board of Directors, including name, surname, position  
on the Board and CV;  
publishing the framework form of the management contract  
The Board of Directors of CONPET S.A. contributes to the definition and implementation of the  
company's ESG strategy, thus ensuring the integration of sustainability principles in its strategic  
decisions.  
Given that the requirements for transparency and social responsibility are increasingly high at the  
international level, the Board of Directors contributes to promoting an organizational culture based  
105 I SUSTAINABILITY REPORT CONPET S.A.  
6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
on sustainability and responsible governance. The company-wide activities on ESG initiatives not  
only ensure compliance with international regulations, but also contribute to increasing the value  
of CONPET's shares in the long term for all investors.  
Main mechanisms underlying ESG implementation:  
Align the strategy with the principles of sustainable development, so that every major  
decision is assessed in terms of its impact on the environment and society. This alignment  
is based on a clear set of ESG policies and objectives that are regularly monitored and  
adjusted in line with legislative changes and investor expectations.  
Implement an integrated management system based on international certifications that  
provides a rigorous framework for identifying, monitoring and managing ESG risks. This  
system is supported by independent audits and internal evaluations that measure the  
effectiveness of implemented ESG programs.  
Establish clear targets and ESG KPIs to measure performance and identify areas for  
improvement. For example, implementing initiatives to reduce carbon footprint or increase  
energy efficiency are included in the company's long-term strategy.  
The Risk Management Committee set up at the level of the Board of Directors, aims to include  
concrete ESG aspects in its tasks, in the medium term, in order to monitor the progress of the  
implementation of ESG strategies at company level by the responsible structures and to ensure  
compliance with new European standards, such as CSRD and ESRS G1. To this end, in the  
medium term, clear policies on diversity and inclusion at the level of CONPET will be defined at  
the organizational structure, adapted to Romanian legislation, but also to the local culture and  
mentality.  
By applying corporate best practices, the Board aims to guide the company in a dynamic  
environment, optimize financial performance and effectively manage risks, thereby contributing  
to sustainable growth and adapting to emerging economic and social challenges.All Board  
members operate under a mandate contract that sets performance criteria and fiduciary duties,  
aligning their responsibilities with shareholders' interests. The Board of Directors meets regularly  
to review the company's performance, approve major investments, and ensure compliance with  
the legal framework for conducting business and implementing internal policies and regulations  
in accordance with the law.  
The Board of Directors delegates the management of the company to one or more Directors and  
appoints one of them as Managing Director. The Managing Director may be appointed from  
among the Directors, who thus becomes an Executive Director or from outside the Board of  
Directors. In accordance with the law, a Director is a person to whom the powers of management  
of the Company have been delegated by a decision of the Board of Directors and who enters into  
a contract of office with the Company in accordance with the applicable legal provisions. The  
General Director of CONPET S.A. represents the Company in relations with third parties and in  
court. The Board of Directors represents the Company in relations with the Directors with a  
mandate contract.  
106 I SUSTAINABILITY REPORT CONPET S.A.  
6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
Powers of the Administrative Board:  
Delegates to the Managing Director(s) the powers of management of the company by  
areas of competence and sets out their rights and obligations, powers, duties,  
responsibilities, through the mandate contract; in the event that the Managing Director(s)  
are unable to exercise their duties (vacation, sick leave, travel, etc.), they may delegate  
their duties according to the provisions of the mandate contract and/or decisions of the  
Board of Directors;  
It supervises the work of the directors with a mandate in the management of the company,  
including its management, and approves the quarterly, half-yearly and annual activity  
reports drawn up by the directors, as well as any other activity reports submitted for  
approval;  
Table 6.1 Composition of the Administrative Board  
Quality  
C.A.  
Date  
Political  
affiliation  
Professional  
experience  
Name  
Status  
Appointments  
C.A. decision  
No 22/ 2023  
Start of mandate:  
22.08.2023  
Non-executive  
non-independent  
member  
Director General -  
Directorate General for  
Electricity, Oil and  
Natural Gas,  
No  
Cristian - Florin  
GHEORGHE  
Permanent political  
affiliation  
Mandate ends:  
21.08.2027  
President C.A.  
Ministry of Energy  
Independent non- Start of mandate:  
No  
Permanent political  
affiliation  
Nicușor - Marian executive  
BUICĂ member  
22.08.2023  
Mandate ends:  
21.08.2027  
Investment Consultant  
Start of mandate:  
22.08.2023  
Mandate ends:  
21.08.2027  
Luminița - Doina Independent non-  
No  
Permanent political  
affiliation  
PhD, "Dimitrie  
Cantemir" Christian  
University  
KOHALMI -  
SZABO  
executive  
member  
Independent non- Start of mandate:  
Lawyer,  
Law Office Tănăsică  
Oana  
Oana - Cristina  
TĂNĂSICĂ  
executive  
member  
22.08.2023  
Mandate ends:  
21.08.2027  
Affiliate -  
Permanent  
PNL  
Independent non- Start of mandate:  
No  
Permanent political  
affiliation  
Florin - Daniel  
executive  
member  
22.08.2023  
Mandate ends:  
21.08.2027  
Director,  
GAVRILĂ  
Lion Capital S.A.  
Independent non- Start of mandate:  
No  
Permanent political  
affiliation  
General Manager,  
AFFICHAGE ROMANIA  
SRL  
Andrei - Mihai  
ZAMAN  
executive  
member  
22.08.2023  
Mandate ends:  
21.08.2027  
Independent non- Start of mandate:  
Deputy General  
Director,  
Urban Management  
Services SRL, Ploiești  
Alin - Mihael  
DĂNILĂ  
executive  
member  
22.08.2023  
Mandate ends:  
21.08.2027  
Affiliate -  
Permanent  
PSD  
107 I SUSTAINABILITY REPORT CONPET S.A.  
6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
Diverse professional experience:  
Board members come from diverse backgrounds, including energy, investment, legal,  
education and business administration.  
The Chairman of the Board of Directors, Cristian-Florin Gheorghe, has significant  
experience in the Ministry of Energy, which can provide an advantage in linking the  
company's strategies with national policies in the energy sector.  
The presence of experts in investment, law and academia can bring beneficial strategic  
insights for the company's development.  
Within CONPET S.A., the Board of Directors is composed of seven members, two of whom are  
women, representing approximately 29% of the total. This proportion is higher than the national  
average for the energy sector, where women occupy 26% of board positions, according to a study  
by Boston Consulting Group (BCG).  
Gender diversity among members of the Board of  
Directors  
29%  
71%  
Men  
Women  
Chart 6.1. Gender diversity among members of the Board of Directors  
The age structure of the 7 members of the administrative management (41-58 years old) and the  
4 members of the executive management (46-65 years old) reflects a balance between  
experience and fresh perspectives, suggesting a strategic mix between stability and dynamism.  
The chart shows, in linear format, the age of each member of the respective Boards of Directors  
and Executive Management. The vertical side shows the age and the horizontal side, numbered  
from 1 to 7, are the members of the two structures (7 members of the BoD and 4 members of the  
executive management):  
108 I SUSTAINABILITY REPORT CONPET S.A.  
6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
Age distribution of Board of Directors (BoD) and  
Executive Board (EB) members  
70  
60  
50  
40  
30  
20  
10  
0
Administrative  
management  
Executive management  
1
2
3
4
5
6
7
Graph 6.2 Age distribution of members of the BoD and the EC  
available on the company's website.  
CONPET S.A.'s Board of Directors has four Advisory Committees, each with an important role in  
the management and development of the company, specialized in the company's fields of activity.  
They exercise powers of analysis, verification, monitoring of financial reporting, internal control,  
monitoring the performance of the managerial internal control system and risk management and  
the appointment of executive management (directors with a contract of office), in accordance with  
best corporate governance practices. The executive management can be found on the  
company's website.  
Advisory Committees  
The following Advisory Committees are set up at the level of the Administrative Board:  
Nomination and Remuneration Committee;  
Audit Committee;  
Risk Management Committee;  
Development and Investor Relations Committee.  
Committees set up at the level of the Board of Directors can be found on the company's  
website.  
Looking at the composition of these committees, some important aspects related to the  
specialization of members and the balance of decision-making can be observed:  
109 I SUSTAINABILITY REPORT CONPET S.A.  
6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
Audit Committee  
The committee is headed by Florin - Daniel Gavrilă, a specialist in the financial-investment field,  
which is essential for monitoring financial reporting and financial transparency. The participation  
of Cristian - Florin Gheorghe, who also holds the position of Chairman of the Board of Directors,  
ensures the correlation between the audit policy and the company's overall strategy. Nicușor -  
Marian Buică, investment consultant, brings additional expertise in financial risk analysis. The  
structure is well balanced with a mix of financial and governance skills.  
Risk Management Committee  
The structure of this committee reflects a multidisciplinary approach to risk management,  
combining academic, administrative and financial expertise. Luminița - Doina Kohalmi - Szabo,  
academic, as chair, proposes an analytical and research-based perspective on risk. Alin - Mihael  
Dănilă, with experience in urban administration, can provide an operational risk and local  
regulatory perspective. Nicușor - Marian Buică, investment consultant, contributes to financial risk  
analysis and management.  
Nomination and Remuneration Committee  
Andrei - Mihai Zaman, with managerial experience in the private sector, is the chairman of this  
committee and can ensure a balanced selection in terms of appointing directors and promoting  
effective remuneration policies. Cristian - Florin Gheorghe has experience in similar energy  
companies. Luminița - Doina Kohalmi - Szabo brings expertise in human resources management.  
Oana - Cristina Tănăsică, a lawyer, contributes legal expertise essential for compliance policies,  
and Alain - Mihael Dănilă completes the team with his administrative background. The  
composition of the committee is diverse, with a mix of managerial, legal and administrative  
expertise, which is beneficial for the objectivity of the recruitment and remuneration process  
Development and Investor Relations Committee  
Oana - Cristina Tănăsică, lawyer, is the chair of this committee, and her legal expertise  
recommends her for managing relations with investors and authorities. Florin - Daniel Gavrilă,  
with investment experience, can contribute to attracting capital and maintaining an effective  
relationship with shareholders. Andrei - Mihai Zaman, presents an operational and strategic  
development perspective. The structure of this committee seems well chosen to ensure effective  
communication and sustainable development of the company.  
110 I SUSTAINABILITY REPORT CONPET S.A.  
6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
Table 6.2 Composition of the Advisory Committees at 31.12.2024  
Development and  
Risk  
Management  
Committee  
Committee of  
Nomination and  
Remuneration  
Audit  
Committee  
Investor  
Relations  
Committee  
Florin - Daniel  
Gavrilă -  
President  
Luminița - Doina  
Kohalmi - Szabo -  
President  
Zaman Andrei - Mihai -  
President  
Oana - Cristina  
Tănăsică - President  
Nicușor - Marian  
Buică - member  
Alin - Mihael  
Dănilă - member  
Cristian - Florin Gheorghe -  
member  
Florin - Daniel  
Gavrilă - member  
Cristian - Florin  
Gheorghe -  
member  
Nicușor - Marian  
Buică - member  
Oana - Cristina Tănăsică -  
Member  
Andrei - Mihai  
Zaman - member  
Alin - Mihael Dănilă -  
member  
Luminița - Doina Kohalmi -  
Szabo - member  
Table 6.3 Key Governance Characteristics  
All 7 directors are non-executive members, i.e. 1 non-independent and 6  
independent members, thus managing the company.  
Independence  
Expertise  
The Board of Directors brings together diversified experience in energy,  
engineering, economics, law and public administration, providing a strong  
strategic vision for the company's development.  
Diversity  
gender  
Female representation on the Board of Directors is approximately 29%,  
reflecting a commitment to inclusiveness and balance in decision-making.  
Directors' performance is assessed annually by the Annual General Meeting  
of Shareholders (AGM), taking into account both the execution of the  
mandate contract and the implementation of the Management Plan,  
ensuring transparency and accountability in corporate governance.  
Evaluation  
Training  
Board members benefit from continuous professional development in  
corporate governance best practices, thus contributing to the continuous  
improvement of the decision-making process and aligning the company to  
international standards.  
111 I SUSTAINABILITY REPORT CONPET S.A.  
6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
In the year 2024, the members of the Board of Directors/ Risk Management Committee of the  
BoD received and reviewed the Annual Report on performance monitoring and risk management  
within CONPET SA, finding that the control measures for the significant risks identified were  
implemented and effective.  
The members of the Board of Directors/ Risk Management Committee of the BoD also received  
and reviewed the report on the anti-bribery management system, finding that this system is  
maintained and operating effectively in the company.  
On a quarterly basis, the Board of Directors was informed on the status of the achievement of the  
company's performance indicators.  
The CONPET SA organization complies with national and international regulations on business  
ethics and ensures, right from the procurement process, that the suppliers of products, services  
and works comply with these regulations. Furthermore, business relationships are continuously  
assessed during the course of business relations, including in terms of compliance with the  
requirements of good conduct and anti-bribery criteria stipulated in contracts.  
For compliance with the requirements of OMF 85/2024 on sustainability reporting, the company  
aims to formally integrate sustainable development responsibilities into the duties of CONPET  
S.A.'s management functions in the medium term. This will strengthen responsible corporate  
governance and ensure effective monitoring of the environmental, social and economic impacts  
of the company's activities.  
Executive Management of CONPET S.A.  
The executive management of CONPET S.A. ensures the implementation of the development  
strategy and the integration of ESG principles in the company's activity. Under the leadership of  
the Managing Director, the executive management optimizes resources, increases operational  
efficiency and aligns the company with corporate governance standards.  
In a dynamic economic environment, the management levels support increased competitiveness  
and the strengthening of CONPET S.A.'s position, aiming at reducing environmental impact,  
operational safety and reporting transparency. In collaboration with the Board of Directors, they  
transform strategic directions into concrete actions to increase the company's value and benefit  
investors.  
Executive management operates under performance-based mandate contracts and is  
responsible for risk management, optimizing financial performance and regulatory compliance.  
By applying best practices, the executive team contributes to modernizing processes,  
streamlining operations and adapting the company to economic and environmental challenges.  
112 I SUSTAINABILITY REPORT CONPET S.A.  
6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
Table 6.3. CONPET S.A. executive management structure  
Political  
affiliation  
Name  
Function  
Professional Experience  
Director General CONPET S.A. (2010-2012,  
2021-present). Experience in safety, occupational  
health and critical infrastructure management in  
the energy sector.  
Director  
General  
Dorin Tudora  
Affiliated  
Deputy Director General on contract (2018-  
present). Over 15 years in senior management  
positions, expertise in legal, human resources,  
Mihaela-  
Anamaria  
Dumitrache  
Deputy  
Director  
General  
Unaffiliated corporate governance, commercial, HSEQ,  
internal managerial control, information security  
and strategic project coordination within  
CONPET S.A.  
Management positions in the economic and  
financial field at CONPET S.A.,  
Unaffiliated (Economic/Financial Director from 2012-present)  
with focus on financial strategies and accounting  
processes.  
Sanda  
Toader  
Economic  
Director  
Leadership roles in the areas of energy sector  
critical infrastructure and security, integrity,  
information security and transport operations.  
3rd Deputy Director General from 2022-present.  
Radu-  
Florentin  
Necșulescu  
Deputy  
Director-  
General 3  
Affiliated  
Chart 6.3. Gender diversity in the executive team  
Gender diversity among members of the executive team  
50%  
50%  
Men  
Women  
The executive team of CONPET S.A. is composed of four members, two of which are women,  
representing 50% of the total, which significantly exceeds the average of the Romanian energy  
industry, where women occupy 29% of all jobs in the energy sector according to the results  
presented by Econmedia of a study conducted by Boston Consulting Group (BCG). This balance  
can bring benefits in strategic decision-making and in strengthening the organizational culture.  
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6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
Members of the management have extensive experience in the energy and financial sectors,  
which ensures operational stability. The Managing Director, Dorin Tudora, has held the same  
position for several terms, which indicates continuity in leadership and strategic stability for  
CONPET S.A. His long experience in managing critical infrastructure in the field of crude oil  
transport is essential, given the complexity and importance of this sector for national energy  
security.  
In a highly regulated industry, where operational safety and logistical efficiency are priorities, his  
expertise contributes to managing operational risks, optimizing transport networks and  
maintaining a reliable and efficient infrastructure. His experience also gives him a solid  
perspective on market challenges, allowing him to adapt the company's strategy to industry  
changes and new regulatory requirements.  
The executive team is predominantly made up of professionals with long experience, which  
provides stability and in-depth knowledge of the sector. However, a more balanced representation  
across generations could bring innovation and agility in decision-making, especially in a sector  
where digitalization and sustainable technologies are becoming strategic priorities.  
All members of the executive team operate on the basis of mandate contracts with clear  
performance criteria, which ensures alignment with corporate governance standards.  
Table 6.4. Integrating ESG principles in the organization  
FUNCTION  
AREA OF RESPONSIBILITIES  
ESG INTEGRATION  
Directs, organizes, coordinates, coordinates  
and controls the company's activity and is  
responsible for the conduct of its business,  
both for direct tasks and those entrusted to  
the executive directors with a mandate.  
Directs, organizes, coordinates and controls  
the work of DGA2 in the areas of  
Through his areas of competence,  
management duties and area of  
responsibilities, the CEO ensures  
the alignment of the company's  
activities with all three ESG  
components.  
Director  
General  
Occupational Health and Safety,  
Environmental Protection, Emergency  
Situations, Sustainability, as well as the work  
of the Maintenance Development  
Department  
114 I SUSTAINABILITY REPORT CONPET S.A.  
6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
FUNCTION  
AREA OF RESPONSIBILITIES  
Organizes, coordinates, manages and is  
ESG INTEGRATION  
Through his areas of competence,  
responsible for the work of the subordinate: management tasks and area of  
Legal, Human Resources, Management responsibilities, the Deputy  
Systems and Internal Management Control, Director General ensures the  
Deputy  
Director  
General  
Integrity, Communication, Corporate  
Governance and Information Security  
alignment of the Directorate's work  
with all three ESG components.  
Through his areas of competence,  
management duties and area of  
Organizes, coordinates, manages and is  
responsible for the work of the subordinate:  
Finance/Accounting, Controlling/Budgeting,  
Assets, Procurement and Contract Tracking,  
Administrative, Procurement  
Economic  
Director  
responsibilities,  
the  
Chief  
Economic Officer ensures the  
alignment of the Directorate's work  
with all three ESG components.  
Through his areas of competence,  
management tasks and area of  
Organizes, coordinates, manages and is  
responsible for the work of the subordinate:  
Operations Transport /Production, Strategic  
Projects, Security, Critical Infrastructures,  
Classified Information, IT  
Deputy  
Director-  
General 3  
responsibilities,  
the  
Deputy  
Director General 3 ensures the  
alignment of the Directorate's work  
with all three ESG components.  
This approach reflects the company's clear commitment to sustainable development,  
integrating ESG principles into all areas of governance and operations.  
In order to ensure compliance with sustainability requirements, CONPET S.A. aims, in the  
medium term, to:  
Revise the Rules of Organization and Functioning (ROF) and the Internal Rules of  
Organization and Functioning (RIOF) of the Advisory Committees set up at the level of the  
Board of Directors to include specific tasks related to sustainable development and  
environmental and social impact.  
Finalize non-financial impact monitoring mechanisms by establishing KPIs on resource  
use, environmental protection and operational safety.  
Establish a clear framework for sustainable development data reporting, ensuring  
transparency and accountability to all stakeholders.  
Integrate sustainability reporting requirements into decision-making processes, facilitating  
the link between economic performance and social and environmental impacts.  
115 I SUSTAINABILITY REPORT CONPET S.A.  
6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
STRENGTHS OF CORPORATE GOVERNANCE AT CONPET S.A. (ESRS G1)  
CONPET S.A. has a number of good corporate governance practices aligned with ESRS G1  
requirements, which place it favorably compared to many similar companies in Eastern Europe.  
CONPET S.A. has a Code of Ethics and Integrity, an Anti-Bribery Policy and a Corporate  
Governance Regulation, as well as clear rules on shareholders' rights and the organization of  
General Meetings, all promoting integrity, transparency and accountability in its day-to-day  
business. The fact that the company is listed on the stock exchange has required adherence to  
high standards of transparency and reporting, aligned with the BVB's Corporate Governance  
Code , which provides a formal framework for the protection of minority shareholders' rights and  
public reporting of relevant information.  
A distinct strength of CONPET S.A. is its pro-ethical organizational culture and implemented  
anti-corruption system. The company declares zero tolerance towards corruption and bribery,  
this attitude is supported by concrete measures of prevention, internal control and employee  
training CONPET S.A. has adopted an Integrity Plan in line with the National Anti-Corruption  
Strategy 2021-2025. This plan is regularly updated, a sign of a commitment to continuous  
improvement of ethics and compliance policies. In addition, the company systematically invests  
in ethics and compliance training for employees: in 2024, for example, training programs such  
as "Auditing the Corruption Prevention System" or "Management of the Prevention and Fight  
against Corruption" were conducted with the participation of staff in relevant positions. Such  
sessions raise awareness of the ethical rules and legal responsibilities of staff, strengthening the  
culture of integrity. Through these efforts, CONPET S.A. is aligning itself with the practices of  
Western companies in the industry and even going beyond the regional average, given that in  
Eastern Europe the issue of corruption in state-owned companies has often been a sore point.  
CONPET S.A.'s initiatives to strengthen the ethical culture have a major positive impact,  
contributing to increased organizational transparency and integrity and responding directly to  
regional calls to reduce corruption risks in the public energy sector (cepa.org.)  
Another strength of CONPET S.A.'s governance is the existence of strong mechanisms for the  
protection of whistleblowers. The company has implemented an operational procedure  
dedicated to public interest whistleblower protection, providing a clear framework and safeguards  
for confidential reporting of violations of the law or the code of ethics. CONPET S.A. provides  
employees with dedicated reporting channels - including its own platform as well as a platform  
of the supervisory authority, both accessible on the official website - guaranteeing confidentiality,  
impartiality of investigations and protection against retaliation. This whistleblowing system, which  
goes beyond the minimum requirements of the EU Whistleblowers Directive, is a notable element  
of good practice. Many similar companies in the region are just beginning to implement such  
mechanisms, some facing cultural barriers in encouraging internal reporting. In contrast, CONPET  
S.A. constantly monitors compliance with ethical standards through a dedicated ethics  
counselor and conducts regular assessments of employees' awareness of anti-corruption rules.  
116 I SUSTAINABILITY REPORT CONPET S.A.  
6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
CONPET S.A. also emphasizes transparency and rigor in corporate governance through its  
management and risk control structure. The company has constituted advisory committees (audit,  
nomination/remuneration, etc.) as required by law and is developing an internal managerial  
control system aligned with national regulations (e.g. OSGG 600/2018 on internal control in public  
entities).  
We can conclude that CONPET S.A.'s strengths - institutionalized ethical culture, rigorous anti-  
corruption policies, whistleblowing mechanisms and transparency - align both with ESRS G1  
requirements and international good governance trends, positioning the company above the  
regional average in ESG Governance chapter.  
IMPROVEMENT OPPORTUNITIES FOR THE GOVERNANCE OF CONPET S.A. COMPARED  
TO SIMILAR COMPANIES  
CONPET S.A. has a solid corporate governance foundation. We aim to identify opportunities for  
improvement, particularly in formalizing standards of conduct for suppliers. Although the company  
imposes strict ethical, environmental and safety requirements, it does not yet have a dedicated  
Code of Conduct for suppliers, which may limit the uniform application of ethical principles and  
transparency on compliance. Compared with other multinational energy companies that have  
implemented codes of conduct and audit programs for suppliers, the adoption of such a code  
would improve control over value chain risks and align CONPET S.A. with ESRS G1  
requirements, increasing transparency and investor confidence.  
A second area for improvement is the further integration of sustainability into the company's  
strategic governance. CONPET S.A, as a medium-sized company, aims to adapt and develop  
its own digital system for ESG reporting, which would streamline the process and increase  
stakeholder confidence in the information published.  
Last but not least, corporate governance within CONPET S.A. could benefit from continued  
alignment with the G20/OECD Principles of Corporate Governance (2023) - which emphasize  
sustainability risk management and stakeholder engagement as these principles become a  
benchmark for emerging markets as well.  
The corporate governance of CONPET S.A. could benefit from the continued diversification  
and professionalization of the management structure. European governance practices  
emphasize the competence, independence and diversity of boards of directors to ensure effective  
oversight. In the case of CONPET, which is majority state-owned, the continued application of the  
legislation on the governance of public enterprises (GEO 109/2011) and the attraction of  
independent experts to the board could provide fresh perspectives and strengthen market  
confidence. Already, as required by the BVB, CONPET has independent directors and audit/risk  
committees, but maintaining the highest standards is a direction of evolution.  
In conclusion, the comparative analysis indicates that CONPET S.A. enjoys a well-founded  
corporate governance, with numerous strengths in the area of ethics, transparency and risk  
control - essential elements of ESRS G1 - where its performance is at least at the level of similar  
117 I SUSTAINABILITY REPORT CONPET S.A.  
6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
companies in Eastern Europe, if not superior in some respects (anti-corruption, warning  
mechanisms). There are also opportunities for improvement that can help bring CONPET's  
governance up to European best practice: formalizing a code of conduct in the value chain,  
strengthening ESG governance at the strategic level, digitizing reporting and optimizing the  
governance structure. By proactively addressing these issues, CONPET S.A. could not only  
ensure full compliance with the new sustainable reporting requirements, but also strengthen its  
resilience and corporate reputation in a sector subject to rapid transformation and public attention  
on ESG performance.  
Bibliography section:  
CONPET internal documents (according to the dual materiality and ESG governance  
analysis).  
European Sustainability Reporting Standard ESRS G1 - Business Conduct (2022/2023)  
- sub-themes and reporting requirements.  
EY (2024). Europe Long-Term Value and Corporate Governance Survey - findings on the  
role of the board in sustainability.  
CEPA (2023). Top European Energy Security Priorities - recommendations for the  
governance of state-owned energy companies in CEE.  
OECD (2023/2024). Updated Governance Guidelines for Public Enterprises - Focus on  
Sustainability and Bribery Prevention.  
WBCSD (2023). The Oil & Gas Transparency Initiative - best practices in climate and  
sustainability reporting.  
Academic study (2024). ESG Integration in Corporate Governance: Emerging Markets -  
Regional comparison (Eastern Europe vs. Asia) on ESG practices.  
Other industry and regulatory sources (BVB, Transparency International, etc.) on  
corporate governance and ESG trends in Eastern Europe.  
6.2 Ethics, compliance and anti-corruption  
Ethics and compliance are fundamental pillars of corporate governance at CONPET S.A.,  
ensuring the integrity of internal processes and strengthening stakeholder trust. To prevent  
corruption risks and promote ethical behavior at all levels, the company has implemented a  
number of specific policies and measures:  
ISO 37001:2017 certification on anti-bribery management, which confirms the existence  
of a robust system to prevent bribery based on clear ethics and compliance policies. This  
certification provides a clear framework for incident reporting and prompt corrective action.  
The regularly reviewed Code of Ethics and Integrity, which sets standards of behavior  
for all company employees and business partners. The Code covers issues such as  
conflict of interest, protection of confidential information and employees' responsibilities to  
the community.  
The Multi-Annual Integrity Plan, which is part of CONPET S.A.'s commitment to the  
National Anti-Corruption Strategy and includes specific actions to combat unethical  
118 I SUSTAINABILITY REPORT CONPET S.A.  
 
6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
practices. Its implementation involves regular trainings and awareness sessions for all  
employees.  
Whistleblowing mechanisms, which allow employees and other stakeholders to  
confidentially report any breach of ethics and compliance principles. The company's  
whistleblowing system provides whistleblower protection and facilitates prompt action on  
reported cases.  
For the future, the company plans to extend ethics and compliance assessments throughout  
the supply chain by introducing a Supplier Code of Conduct. This code would require adherence  
to high standards of integrity and social responsibility, ensuring transparent and ethical  
collaboration with all business partners. Monitoring of this code could be done through regular  
audits and feedback mechanisms from suppliers.  
Anti-Corruption  
In order to implement the National Anticorruption Strategy 2021-2025 (N.A.S.) at the company  
level, in May 2022 the Declaration on the assumption of the organizational integrity agenda  
in the coordinates of the N.A.S. 2021-2025 and the Integrity Plan were adopted. The latter  
was updated in February 2024 by decision of the General Director of CONPET S.A. and details  
the specific corruption prevention measures applicable to the company, in line with the general  
and specific objectives set out in the S.N.A. for public enterprises. The plan is intended to identify  
risks, vulnerabilities and specific intervention needs/measures.  
All corruption prevention measures with a deadline of 2024 have already been implemented. In  
addition, the company conducts annual training, internal training and awareness programs in the  
field of anti-corruption education. It is based on the premise that the promotion of ethical and  
upright behavior contributes to the reduction of anti-corruption misconduct, reduction of internal  
conflicts, prevention of fraud and proper use of company resources. This training system also  
limits the risks of misuse of the company's image for personal gain or behavior that could affect  
relations with customers and business partners. The effective functioning of such a mechanism  
strengthens organizational integrity, increases employees' sense of security and boosts overall  
company performance.  
In 2024, training sessions were organized for both TESA staff and members of executive  
management, addressing key topics on transparency, ethics and compliance within the company.  
Tabel 6.5. Training level situation in 2024  
Number of  
employees /  
training program employees  
Number of  
trained  
Training  
level  
Type of training  
Target group of staff  
Provisions on conflict  
of interest and  
606  
590  
97,36%* TESA Personell  
incompatibilities  
All staff  
Provisions for  
corruption offences  
1.423  
1.408  
98,95%* (Executive Management  
and employees)  
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6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
All staff  
Ethics and integrity  
rules  
1.424  
1.411  
99,09%* (Executive Management  
and employees)  
Rules on the  
obligation to declare  
gifts  
Executive management  
100,00% staff (including directors  
under contract)  
87  
88  
87  
88  
Provisions for  
declarations of assets  
and interests  
Executive management  
100,00% staff (including directors  
under contract)  
* The difference results from labour contracts suspended at the time of training.  
Following training on the legal provisions relating to conflicts of interest and incompatibilities,  
TESAmanagement staff and employees were tested on their acquired knowledge. This took place  
between November and December 2024 and demonstrated a high level of compliance, with  
knowledge of the relevant provisions reaching 100%.  
The training level situation in 2024  
101,00%  
100,50%  
100,00%  
99,50%  
99,00%  
98,50%  
98,00%  
97,50%  
97,00%  
96,50%  
96,00%  
95,50%  
100,00%  
100,00%  
99,90%  
98,95%  
97,36%  
Provisions on conflict of  
interest and  
Provisions for  
corruption offenses  
Ethics and integrity Rules on the obligation  
rules to declare gifts  
Provisions for  
declarations of assets  
and interests  
incompatibilities  
CHART 6.4. The training level situation in the year 2024  
Training of new employees is provided by specialized staff and includes:  
The anti-bribery policy and the requirements of the anti-bribery management system  
implemented in CONPET S.A., applicable to the positions included in the Inventory of  
Sensitive Functions and to the anti-bribery compliance function designated by decision of  
the General Director;  
The rules on conflicts of interest and incompatibilities, addressed in particular to  
management and TESA staff.  
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6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
Annually, in the first semester of each year, employees in sensitive positions, directors with a  
mandate contract and CONPET S.A. administrators fill in a declaration of compliance with the  
Anti-Bribery Policy and the requirements of the anti-bribery management system.  
PROTECTION OF WHISTLEBLOWERS  
CONPET S.A. has implemented a robust whistleblower protection system, providing internal and  
external channels for reporting irregularities. These were made known to all employees and  
stakeholders through:  
Institutional Integrity section on the company website;  
Internal Network Info CONPET-Integrity;  
Dissemination of information leaflets in the work sectors;  
Sending quarterly informative materials by e-mail to encourage reporting.  
CODE OF ETHICS AND INTEGRITY  
Updated in 2024, the Code of Ethics and Integrity sets out core values such as transparency,  
honesty, integrity, respect for employees, accountability, non-discrimination and freedom  
of expression. It governs the ethical conduct of administrators, directors, employees, as well as  
delegated or seconded staff, interns and collaborators.  
The Code also includes aspects on the specific measures foreseen by the National Anti-  
Corruption Strategy 2021-2025 for: Declaration of assets, gifts, protection of  
whistleblowers inpublic interest and conflicts of interest;  
Identifying sensitive functions and assessing Integrity incidents and corruption risks;  
Role of the ethics and integrity counselor  
The Ethics and Integrity Advisor is responsible for advising management and employees,  
organizing training sessions and monitoring the application of ethical rules. In 2024, he has:  
Organized trainings on the Code of Ethics and Integrity and the Rules of the Ethics  
Adviser;  
Disseminated information materials via e-mail and printed brochures;  
Organized information sessions for various internal entities, reporting practices that could  
lead to ethical violations;  
Assessed compliance through employee questionnaires, the results of which are  
included in an annual report with measures to improve the ethical climate.  
On a quarterly basis, the Ethics Counselor shall report to the management relevant information  
about the counseling, training and compliance activities, as well as the administrative measures  
necessary to correct any misconduct.  
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6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
COMPLIANCE AND INTERNAL AUDIT  
Compliance with regulations is an essential component of CONPET S.A.'s activity, given the  
company's highly regulated field (crude oil transport, environmental protection, occupational  
health and safety, stock exchange rules, etc.).  
To ensure compliance, the company has:  
Compliance Officer, appointed by decision of the Director General, in accordance with  
the National Anti-Corruption Strategy 2021-2025 and GEO 109/2011;  
Anti-bribery compliance function, designated under ISO 37001, the international  
standard for anti-bribery management systems;  
Internal audit of the integrated management system, focused on checking compliance  
with quality, environmental, occupational health and safety, energy and anti-bribery  
standards.  
Public internal audit, as an independent, objective assurance and advisory activity, is  
designed to add value and lead to improvements in the company's activities.  
The assessment of compliance with legal requirements is systematically ensured by specialized  
internal entities according to internal procedures. Regular auditing of the integrated  
management system contributes to the continuous improvement of the company's activities and  
to maintaining a high level of transparency and organizational ethics.  
For the future, it is recommended to extend ethics and compliance assessments throughout  
the supply chain by introducing a Supplier Code of Conduct. This code would require high  
standards of integrity and social responsibility, ensuring transparent and ethical collaboration with  
all business partners.  
The main mechanisms through which ESG governance is implemented include:  
Align the strategy with the principles of sustainable development, so that every major  
decision is assessed in terms of its impact on the environment and society. This alignment  
is based on a clear set of ESG policies and objectives that are regularly monitored and  
adjusted in line with legislative changes and investor expectations.  
Implementation of an integrated management system, recognized through  
certifications by accredited bodies, which provides a rigorous framework for identifying,  
monitoring and managing ESG risks. This system is evaluated internally and externally  
and regularly reviewed by top management, which monitors the effectiveness of the ESG  
programs implemented.  
Establish clear targets and KPIs that allow performance to be measured and areas for  
improvement to be identified. For example, energy and environmental performance  
improvements are included in the company's management programs, with clear actions,  
deadlines and accountabilities  
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6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
Adoption of a Corporate Social Responsibility Policy, which includes the  
implementation of principles on: accountability for the impact of activities on society,  
economy and environment, transparency, ethical behavior, respect for stakeholder  
interests, respect for the rule of law and human rights, respect for international norms of  
behavior  
RECOGNITION FOR ESG ETHICS, PERFORMANCE AND ACCOUNTABILITY  
Conpet S.A. has consolidated its reputation as a reliable operator in the crude oil transport sector  
by respecting the principles of corporate governance, ethics and social responsibility. Its  
performance in terms of transparency, sustainable investments and community impact has  
been recognized by several relevant awards:  
1st place in the category "Services - Very Large Enterprises" - confirms financial  
stability and business ethics, reflecting Conpet's commitment to operational excellence  
and integrity.  
Top Investor Award - highlights the implementation of responsible investment practices,  
including infrastructure modernization, digitalization and energy efficiency, thus  
contributing to sustainable development.  
Corporate Social Responsibility Trophy - highlights positive impact on the community  
and environment through sustainability programs, employee support and social  
initiatives.  
These awards confirm that CONPET S.A. respects the highest ethical and governance  
standards, ensuring transparency and accountability in all its activities. By integrating ESG  
principles into its business strategy, the company actively contributes to sustainable economic  
growth and to the consolidation of a responsible business model in the long term.  
6.3 Risk management and transparency  
The management of ESG risk factors is essential to ensure the operational and financial  
sustainability of CONPET S.A. In this regard, the company has developed a structured risk  
assessment and management framework, which includes:  
Establishment and implementation of the Risk Management Policy and a  
documented risk management process that develops a culture of risk-based approach in  
all company processes and decisions.  
Identification of ESG risks at all operational levels, including environmental, social and  
governance risks. These risks are identified and assessed to ensure that the company's  
strategy remains aligned with current market and international regulatory requirements.  
Integration of ESG risks into the Internal Management Control System (IMCS),  
implemented in accordance with the requirements of OSGG 600/2018. This system  
provides a framework for continuous monitoring and enables proactive measures to be  
taken to reduce the negative impact on the company's business.  
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6. CORPORATE GOVERNANCE AND ETHICAL CONDUCT  
Regular internal audits that assess compliance with international regulations and  
standards, ensuring transparency and accountability in risk management. Independent  
auditing contributes to building confidence in the company's ability to manage ESG risks.  
Transparent reporting of ESG performance through annual publication of sustainability  
indicators and measures taken to improve ESG performance. This reporting is essential  
to maintain an open dialog with investors and business partners.  
Appropriate risk assessment methods are established, documented and maintained within  
the organization, and the effectiveness of control measures implemented to manage  
significant risks is constantly monitored. Risk management benefits from the allocation of the  
necessary resources, both for staff training, education and awareness, and for the  
implementation of approved measures to deal with identified risks.  
To ensure effective risk management, the responsibilities of the staff involved are clearly  
defined and relevant risk data are systematically reported to stakeholders. The risk  
identification and assessment process covers several key categories:  
Operational risks, such as pipeline integrity, technical or induced damage;  
Financial risks, including market and liquidity risks;  
Compliance risks such as legislative and regulatory changes, litigation risks or  
environmental impacts.  
In order to better manage long-term risks, CONPET intends, in the medium, to develop advanced  
risk scenarios, including projections of the impact of climate change on the company's  
infrastructure and business model. This approach would enable the company to adapt its  
development strategy in a sustainable and resilient way. In addition, the development of strategic  
partnerships to identify and implement ESG best practices would contribute to the continuous  
improvement of internal processes.  
Through these measures, CONPET S.A. strengthens its managerial strategy in terms of corporate  
governance and sustainability, ensuring transparency, integrity and accountability at all levels of  
the organization.  
124 I SUSTAINABILITY REPORT CONPET S.A.  
CONPET S.A.  
aligns investments with the  
EU Taxonomy, ensuring  
sustainability and  
compliance with  
environmental and social  
standards.  
7. TAXONOMY AND ESG INVESTMENT  
STRATEGY  
EU Taxonomy - Classification of sustainable activities  
The EU Taxonomy is a classification system that defines which economic activities can be  
considered environmentally sustainable according to EU criteria. It establishes a set of six  
environmental objectives. These objectives are: (1) climate change mitigation, (2) adaptation to  
climate change, (3) sustainable use and protection of water and marine resources, (4) transition  
to a circular economy, (5) pollution prevention and control, and (6) protection and restoration of  
biodiversity and ecosystems.  
It also establishes technical selection criteria that activities must fulfill in order to be considered  
sustainable. CONPET S.A. evaluates its operations and capital projects against these criteria to  
determine eligibility and alignment with the Taxonomy. In practice, for each major investment or  
project (e.g., upgrading pipeline technology or installing renewable energy at our facilities), we  
assess whether it contributes substantially to an environmental objective, does not significantly  
harm any other objective, and meets the minimum social safeguards as set out in the Taxonomy  
Regulation.  
125 I SUSTAINABILITY REPORT CONPET S.A.  
 
7. TAXONOMY AND ESG INVESTMENT STRATEGY  
SFDR - Improved ESG performance tracking and reporting  
The Regulation on Sustainability Reporting in the Financial Services Sector (SFDR) complements  
the taxonomy by focusing on transparency and disclosure in the financial sector.  
Although the SFDR directly targets investors, not CONPET S.A., it affects us indirectly, as  
investors seek high quality ESG data to fulfill their reporting obligations. CONPET S.A.  
understands that, in order to remain an attractive investment and facilitate capital flows for  
sustainable initiatives, it must provide the ESG information required by the SFDR to investors.  
Thus, we are working to improve our ESG performance monitoring systems and report relevant  
indicators, aligning with investor expectations, to enable them to identify our sustainability profile  
and correctly categorize funding under the SFDR.  
Essentially, the SFDR is driving us to be more transparent and data-driven in our  
sustainability reporting, thereby aiming to prevent greenwashing and ensure that any  
sustainability claims are backed up by consistent data. By applying the taxonomy, companies can  
transparently assess and report the environmental impact of their activities, facilitating access to  
sustainable finance.  
The ESG (Environmental, Social, and Governance) investment strategy focuses on integrating  
environmental, social responsibility and governance criteria into the company's decision-making  
process.  
This chapter is structured in two parts:  
Alignment with the EU Taxonomy and sustainable financing  
This section details how CONPET S.A. is aligning with the requirements of the EU Taxonomy,  
thereby contributing to the transition to a sustainable economy and facilitating access to green  
finance.  
ESG financial performance and future investments  
This section analyzes the company's ESG performance and strategies for attracting sustainable  
financing, ensuring sustainable and transparent growth.  
7.1 Alignment with EU taxonomy and sustainable financing  
INTRODUCTION ON EU TAXONOMY REQUIREMENTS (REGULATION (EU) 2020/852  
Regulation (EU) 2020/852, known as the Taxonomy Regulation, sets clear criteria for identifying  
sustainable economic activities in the European Union. Its main aim is to promote sustainable  
investments and align financial flows with EU climate objectives.  
CONPET S.A. assesses its operations and capital projects against EU Taxonomy criteria to  
determine eligibility and alignment with sustainability standards. In this regard, the company  
reviews each major investment to assess:  
126 I SUSTAINABILITY REPORT CONPET S.A.  
 
7. TAXONOMY AND ESG INVESTMENT STRATEGY  
Contribution to environmental objectives;  
Respect the principle of DNSH (Do No Significant Harm);  
Compliance with minimum social guarantees.  
This assessment guides our decision making: projects that align with the Taxonomy's  
sustainability criteria are prioritized in our strategy, as they are more likely to support EU climate  
and environmental objectives and potentially attract green finance. By identifying activities that  
are Taxonomy-eligible (covered by the Taxonomy framework) and Taxonomy-aligned (meeting  
all sustainability criteria), CONPET S.A. can transparently report the proportion of its activities that  
are sustainable in EU terms. This includes reporting the proportion of our turnover, capital  
expenditure (CapEx) and operating expenditure (OpEx) associated with taxonomy aligned  
activities, as required by Article 8 of the Taxonomy Regulation.  
For example, in our Sustainability Report in 2022 (the first year in which we assessed alignment  
with the EU taxonomy), we reported that no economic activities of CONPET S.A. were identified  
as aligned with the taxonomy at that time. This result provided a baseline and highlighted  
opportunities for improvement. Since then, we have explored investments in technologies such  
as renewable energy for our operations and efficiency improvements in pipeline transport that  
could qualify under the Taxonomy's criteria for climate change mitigation. The EU Taxonomy thus  
serves as a guide for CONPET S.A. in aligning financial flows with sustainability goals - it  
encourages us to channel investments into areas recognized as sustainable, thereby gradually  
increasing the portion of our business that contributes to environmental objectives. By following  
the Taxonomy's guidance, we not only support EU-wide climate goals, but also position the  
company to benefit from incentives and financing associated with sustainable economic activities  
(e.g. green bonds or loans can favor Taxonomy-aligned projects).  
Although the main activity does not fit the Taxonomy criteria, CONPET has identified secondary  
activities/investments with partial alignment:  
The installation of photovoltaic systems at own facilities has been recognized as an activity  
with a substantial contribution to the objective "climate change mitigation". These projects  
were classified as enabling activities according to the Taxonomy.  
Part of the capital expenditure (CapEx) related to these investments is reported as aligned  
with EU criteria.  
Other investments, such as renovating buildings or installing energy efficiency equipment,  
did not fully meet the technical criteria and were not included.  
As an infrastructure operator with majority state capital, CONPET S.A. carries out public  
procurement according to its own rules, but in drafting the tender documentation, it will take into  
account the introduction of environmental criteria, thus complying with the regulations  
established by Law no. 69/2016 on green public procurement, as well as sectoral legislation  
(Law no. 98/2016 and Law no. 99/2016).  
127 I SUSTAINABILITY REPORT CONPET S.A.  
7. TAXONOMY AND ESG INVESTMENT STRATEGY  
INTEGRATING ENVIRONMENTAL AND SUSTAINABILITY REQUIREMENTS INTO  
PROCUREMENT POLICY  
The National Green Procurement Plan 2025-2030 (PNAE) sets mandatory annual targets for  
green procurement in public entities and covers categories such as:  
o
o
o
o
IT and electronic equipment;  
Paper and sustainable products;  
Vehicles and infrastructure for green mobility;  
Renewable energy and energy-efficient construction works.  
The PNAE targets are progressively increasing, so that, for example, green purchases for road  
vehicles and IT equipment have to reach the following targets:  
Green procurement targets for road vehicles and IT equipment  
60%  
50%  
50%  
40%  
40%  
30%  
30%  
20%  
10%  
0%  
2026  
2027  
2028-2030  
CHART 7.1 - Green procurement targets for road vehicles and IT equipment  
CONPET S.A. has already started the alignment with the PNAE by:  
Renewing the fleet with hybrid and electric vehicles, reducing emissions and meeting  
sustainable mobility requirements. Currently, the company has 5 plug-in hybrid cars and  
2 electric cars.  
Introducing electric locomotives for technological rail transport, reducing the use of  
fossil fuels. CONPET S.A. owns a total of 13 locomotives of which 3 hybrid locomotives  
and 2 electric locomotives.  
These measures demonstrate CONPET S.A.'s commitment to sustainability and compliance with  
national and European policies such as the EU Taxonomy and PNAE. Furthermore, alignment  
with these requirements facilitates the company's access to green financing (e.g. green bonds  
or loans) and positions CONPET S.A. as a responsible actor in the transition towards a  
sustainable economy.  
128 I SUSTAINABILITY REPORT CONPET S.A.  
7. TAXONOMY AND ESG INVESTMENT STRATEGY  
The EU Taxonomy is an essential guide for CONPET S.A. in integrating sustainability into its  
operations. Although the company's core business is not aligned with the Taxonomy, efforts to  
develop sustainable projects, such as renewable energy and energy efficiency, demonstrate  
continuous progress.  
In addition, by implementing the green public procurement strategy and aligning with the PNAE  
2025-2030, CONPET S.A. can actively contribute to national and European sustainability  
objectives. This approach not only reduces environmental impact, but also positions the company  
to benefit from the opportunities offered by the green economy of the future.  
The Regulation (EU) 2019/2088 of the European Parliament and of the Council of November  
27, 2019 on Sustainability Disclosures in the Financial Services Sector (SFDR) requires  
asset managers, banks and other financial market participants to report on the sustainability of  
their products and portfolios by classifying funds according to their ESG characteristics (e.g. 'open  
green' funds under Article 8, which promote ESG characteristics, and 'closed green' funds under  
Article 9, with explicit sustainable investment objectives).  
Key improvements in our recent reporting include:  
Wider reporting scope: Previous sustainability reporting focused mainly on CONPET  
S.A.'s direct operations and traditional CSR topics such as environmental compliance,  
employee welfare and anti-corruption measures. In contrast, the CSRD-aligned 2024  
report covers a broader range of topics and impacts. We now report on climate risks and  
opportunities, supply chain sustainability, diversity and inclusion, energy efficiency  
innovation and other important topics identified through our dual materiality assessment.  
This broader scope provides stakeholders with a comprehensive picture of CONPET  
S.A.'s ESG performance and how we are creating long-term value in a sustainable way.  
Improving data quality and methodologies: With each reporting cycle, CONPET S.A.  
improves its data collection and calculation methods. For example, the 2022 Sustainability  
Report was the first to include an analysis of the eligibility and alignment of our activities  
to the EU Taxonomy, and did not identify any aligned activities at that time. In 2024, we  
developed more detailed tracking of environmental data (such as detailed greenhouse gas  
emissions tracking for Scopes 1, 2 and 3) and social metrics (such as training hours and  
employee turnover).  
Increased transparency and quantitative reporting: CONPET S.A. has moved to a  
quantitative and target-oriented reporting style in response to legislative requirements.  
This reporting style aims to present concrete performance indicators and progress. For  
example, instead of simply stating that we aim to reduce emissions, we want to publish  
our specific emission reduction targets and our annual performance (in tons of COe)  
against these targets. Key metrics for recent years will be presented to show trends and  
any failures or challenges are openly discussed. By revealing both successes and areas  
for improvement, we provide stakeholders with a clear and honest account of our  
sustainability journey. There has been a slight improvement in CONPET S.A.'s ESG  
performance and transparency in our public reporting from 2021 to 2024. We aim to  
continue this trajectory of increased transparency.  
129 I SUSTAINABILITY REPORT CONPET S.A.  
7. TAXONOMY AND ESG INVESTMENT STRATEGY  
Strong reporting and assurance governance: CONPET S.A. currently has a cross-  
functional team collecting the ESG information required for reporting, and the Audit  
Committee and Risk Management Committee of the Board of Directors will review all  
issues presented as part of the overall reporting process. The 2024 Sustainability Report  
is subject to assurance by the external financial auditor and we are putting in place the  
necessary systems and documentation for formal third-party assurance in future reporting  
cycles. The adoption of assurance will further enhance stakeholder confidence in the  
information we provide by having an independent verifier attest that our sustainability data  
is accurate and our processes are robust.  
Through these improvements, CONPET S.A. demonstrates its commitment not only to meet  
regulatory requirements, but also to go beyond them where possible in order to provide  
stakeholders with a high level of transparency. Each enhancement to our reporting practices -  
whether expanding content, improving data accuracy or clarifying presentation - is intended to  
make the information more useful and trustworthy for our readers. Stakeholders can see a clear  
evolution in our sustainability reporting, from a baseline of compliance a few years ago to the  
current comprehensive, CSRD-compliant report, which is our most detailed and transparent  
communication to date. CONPET S.A. will continue to refine its sustainability reporting in line with  
emerging best practices and stakeholder expectations as part of our wider commitment to  
corporate responsibility and sustainable development.  
We are better positioned to attract ESG-focused investors because we can demonstrate through  
verified data that our strategies and projects contribute to recognized sustainability goals.  
ASSESSMENT OF ELIGIBILITY AND ALIGNMENT OF CONPET S.A. ACTIVITIES UNDER  
THE EU TAXONOMY FOR 2024:  
In the following we present an assessment of the eligibility of the economic activities of CONPET  
S.A. for the year 2024 in accordance with the EU Taxonomy. The assessment of the activities  
carried out by CONPET S.A. was carried out for each of the three financial indicators (Turnover,  
CapEx and OpEx), based on financial statements provided by the company's representatives.  
The analysis was conducted with the purpose of identifying the eligible economic activities and  
their eligibility proportions, in accordance with the provisions of Delegated Act No. 2021/2178 and  
subsequent communications of the European Commission on the interpretation and  
implementation of certain requirements of the EU Taxonomy Regulation and related Delegated  
Acts.  
130 I SUSTAINABILITY REPORT CONPET S.A.  
7. TAXONOMY AND ESG INVESTMENT STRATEGY  
From a methodological point of view, the following aspects were analyzed:  
For CapEx, an analysis of the investments that CONPET S.A. has made in the year 2024  
has been performed to determine the proportion of capital expenditure, reported in the  
financial statements, related to assets or processes associated with economic activities  
that qualify as environmentally sustainable. CapEx includes additions related to property,  
plant and equipment and intangible assets (including right-of-use assets in accordance  
with IFRS 16, paragraph 53(h)). These investments are reported in the 2024 annual  
financial statements in notes 5 (Property, plant and equipment) and 6 (Intangible assets),  
lines 'Additions to property, plant and equipment' 2024 and 'Additions to intangible assets'  
respectively.  
For Turnover, the assessment was performed to identify the percentage of contract  
revenue related to eligible and EU Taxonomy aligned activities in the contract revenue  
included by the company in the Statement of Profit and Loss and Other Comprehensive  
Income for 2024, in the line "Contract revenue".  
For OpEx, an analysis of the revenue that CONPET S.A. has earned in 2024 has been  
performed.  
For more details on our accounting policies, see Annual Financial Statements, Note 3. Accounting  
Policies.  
As the company's main activity does not correspond to the activities listed in Annex I of Delegated  
Act 2021/2139 and is not eligible under the EU Taxonomy, the eligible turnover is zero.  
In the following paragraphs will be presented the assessment of the eligibility and alignment of  
CONPET S.A. activities according to the EU Taxonomy - for OpEx.  
TABLE 7.1. Eligibility and alignment of CONPET S.A. activities for the year 2024 according  
to the EU taxonomy - OpEx  
NACE  
Code  
Economic activity  
Eligibility Taxonomy  
Turnover (%)*  
OpEx (%)  
Pipeline transport of  
crude oil  
4.950  
No (fossil fuel transport)  
99,59%  
0%  
Rental of movable  
and immovable  
property  
6.820  
-
No  
No  
0,38%  
0,03%  
0%  
0%  
Other activities  
Pipeline transport of crude oil: activity not eligible for taxonomy.  
Rental of movable and immovable property: We currently consider that the rental of  
movable and immovable property is not aligned with the EU Taxonomy, taking a prudent  
approach given the stringent energy efficiency and sustainability requirements. We believe  
that the investments made in 2024 (reflected in CapEx) have the potential to change this  
situation, which is why the activity will be reassessed in the following year, particularly if it  
131 I SUSTAINABILITY REPORT CONPET S.A.  
7. TAXONOMY AND ESG INVESTMENT STRATEGY  
moves beyond its current status as a marginal activity, given its suboptimal weighting in  
the company's operating structure.  
Other activities : Currently considered not aligned with the EU Taxonomy, being directly  
related to the main activity. This classification will be reassessed if these activities go  
beyond their residual status or if a dominant niche emerges that can be specifically  
analyzed.  
In conclusion - the percentage of the company's OpEx eligible under the EU Taxonomy is 0%.  
The following paragraphs will present the assessment of the eligibility and alignment of CONPET  
S.A.'s activities according to the EU Taxonomy - for CapEx.  
TABLE 7.2. Eligibility and alignment of CONPET S.A. investments for the year 2024  
according to the EU taxonomy - CapEx  
Value  
RON)  
(thousand  
Type of investment  
CapEx (%)  
Total investments realized in 2024  
Misaligned investments  
72.840  
100,0%  
99,4%  
0,6%  
72.370  
470  
Aligned investments  
Additional analysis and explanations:  
The company's core activity, the transport of crude oil, is the dominant field, which  
reasonably implies that most of the investments are aimed at modernizing, streamlining  
and optimizing it. As this activity is not eligible under the EU Taxonomy, the related  
investments will be largely associated with this activity and therefore considered as non-  
aligned.  
Investments have been identified that can be dissociated from the core business and  
subject to individual analysis to determine their compliance with the EU Taxonomy. This  
approach allows for a targeted assessment to highlight investments that meet the criteria  
for alignment with sustainability standards.  
o Investing in photovoltaic power generation;  
o Investments in building rehabilitation;  
o Investments in modernizing water supply systems.  
TABLE 7.3. Breakdown of the aligned investments of CONPET S.A. for the year 2024  
according to the EU taxonomy - CapEx  
Value  
(thousand  
RON)  
CapEx (%) - in  
aligned  
investments  
CapEx(%) - in  
total  
investments  
Aligned investments  
Investing in photovoltaic power  
generation  
30,00  
6,38%  
0,043%  
0,197%  
Investment in building renovation  
138,77  
29,51%  
132 I SUSTAINABILITY REPORT CONPET S.A.  
7. TAXONOMY AND ESG INVESTMENT STRATEGY  
Value  
(thousand  
RON)  
CapEx (%) - in  
aligned  
investments  
CapEx(%) - in  
total  
investments  
Aligned investments  
Investments in modernization of  
water supply systems  
301,52  
64,11%  
0,428%  
Investment in photovoltaic energy production sources - The investment is aligned  
with the EU Taxonomy as it contributes directly to climate change mitigation by producing  
energy from renewable sources, reducing greenhouse gas emissions and reducing  
dependence on conventional energy sources.  
Investments in building renovation - The investment is aligned with the EU Taxonomy,  
as it leads to a reduction in primary energy consumption, either compared to the previous  
situation or compared to the baseline values estimated for the last three years, thus  
fulfilling the energy efficiency criteria.  
Investments in modernization of water supply systems - The investment is aligned  
with the EU Taxonomy, as it generates significant reductions in electricity consumption by  
upgrading pumping systems and decreases water losses by optimizing sewerage  
infrastructure and connections, thus contributing to resource efficiency.  
In summary - the percentage of the company's CapEx that is aligned under the EU Taxonomy is  
0.6%.  
INITIATIVES AND INVESTMENTS IN LINE WITH THE EU TAXONOMY  
CONPET S.A. has initiated a series of investments aimed at improving operational sustainability  
and ensuring compatibility with the EU Taxonomy criteria, a relevant example of which is the  
installation of photovoltaic systems, which fall into the category of renewable energy production -  
an activity considered 100% sustainable, directly contributing to climate change mitigation.  
The company has also invested in the rehabilitation of buildings, implementing measures that  
lead to a reduction in primary energy consumption, thus improving energy efficiency and ensuring  
alignment with the EU Taxonomy. Another significant project is the modernization of water supply  
systems, with a direct impact on reducing electricity consumption by making pumping systems  
more efficient, as well as on reducing water losses, thus optimizing the use of resources.  
With these investments, CONPET is reinforcing its transition towards a more sustainable  
economy, with the possibility to expand its green initiatives and diversify its core activities in line  
with European climate objectives.  
133 I SUSTAINABILITY REPORT CONPET S.A.  
7. TAXONOMY AND ESG INVESTMENT STRATEGY  
TABLE 7.4. Taxonomy key performance indicators - turnover  
Criteria for  
substantial  
contribution  
DNSH criteria  
Proportion  
of  
turnover  
Absolute  
turnover  
Code  
1
2
3
4
5
6
1
2
3
4
5
6
Economic activities  
thousand  
RON  
Yes/ Yes/ Yes/ Yes/ Yes/ Yes/  
No No No No No No  
%
%
%
%
%
%
%
Yes/No  
A. TAXONOMY - ELIGIBLE  
ACTIVITIES  
A.1 Environmentally eligible  
activities (aligned to taxonomy)  
-
-
-
-
-
-
Turnover of environmentally  
sustainable activities (aligned to  
taxonomy) (A.1)  
-
-
-
-
-
A.2 Activities eligible under the  
taxonomy but which are not  
environmentally sustainable  
(non-taxonomy activities)  
Turnover of activities eligible under  
the taxonomy but which are not  
environmentally sustainable (non-  
taxonomy activities) (A.2)  
-
0.00  
-
0.00  
Total (A.1 + A.2)  
B.TAXONOMY - INELIGIBLE  
ACTIVITIES  
Turnover of activities not eligible  
under taxonomy (B)  
533.618  
100,00  
533.618  
100,00  
Total (A + B)  
134 I SUSTAINABILITY REPORT CONPET S.A.  
7. TAXONOMY AND ESG INVESTMENT STRATEGY  
TABLE 7.5. Taxonomy key performance indicators - CapEx  
Criteria for substantial  
contribution  
DNSH criteria  
Absolute Proportion  
Code  
1
2
3
4
5
6
1
2
3
4
5
6
Economic activities  
CapEx  
of CapEx  
thousand  
RON  
Yes/ Yes/ Yes/ Yes/ Yes/ Yes/  
No No No No No No  
%
%
%
%
%
%
%
Yes/No  
A. TAXONOMY-ELIGIBLE  
ACTIVITIES  
A.1 Environmentally eligible  
activities (aligned to  
taxonomy)  
Investing in photovoltaic  
power generation  
30  
0,04  
100  
Yes Yes Yes Yes Yes  
Yes  
Investment in building  
renovation  
139  
302  
0,19  
0,42  
100  
100  
Yes Yes Yes Yes Yes  
Yes Yes Yes Yes Yes  
Yes  
Yes  
Investments in modernization  
of water supply systems  
CapEx for environmentally  
sustainable activities (aligned  
to taxonomy) (A.1)  
470  
0,65  
100  
-
-
-
-
-
A.2 Activities eligible under  
the taxonomy but which are  
not environmentally  
sustainable (non-taxonomy  
activities)  
CAPEX related to activities  
that are taxonomy eligible but  
not environmentally  
0
0,00  
sustainable (non-taxonomy  
activities) (A.2)  
Total (A.1 + A.2)  
470  
0,65  
B. TAXONOMY - INELIGIBLE  
ACTIVITIES  
CapEx for activities not eligible  
under taxonomy (B)  
72.370  
99,35  
Total (A + B)  
72.840  
100,00  
135 I SUSTAINABILITY REPORT CONPET S.A.  
7. TAXONOMY AND ESG INVESTMENT STRATEGY  
TABLE 7.6. Taxonomy key performance indicators - OpEx  
Criteria for  
substantial  
contribution  
DNSH criteria  
Absolute Proportion  
Code  
1
2
3
4
5
6
1
2
3
4
5
6
Economic activities  
OpEx  
of OpEx  
thousand  
RON  
Yes Yes/ Yes/ Yes Yes/ Yes  
/No No No /No No /No  
%
%
%
%
%
%
%
Yes/No  
A. TAXONOMY-ELIGIBLE  
ACTIVITIES  
A.1 Environmentally eligible  
activities (aligned to  
taxonomy)  
-
-
-
-
-
-
OpEx related to environmentally  
sustainable activities (aligned to  
taxonomy) (A.1)  
-
-
-
-
-
A.2 Activities eligible under  
the taxonomy but which are  
not environmentally  
sustainable (non-taxonomy  
activities)  
OpEx for activities that are  
taxonomy eligible but not  
environmentally sustainable  
(non-taxonomy activities) (A.2)  
-
0.00  
-
0.00  
Total (A.1 + A.2)  
B. TAXONOMY - INELIGIBLE  
ACTIVITIES  
OpEx for activities not eligible  
under taxonomy (B)  
556,796  
100.00  
556,796  
100.00  
Total (A + B)  
7.2 ESG financial performance and future investments  
ESG INVESTMENT STRATEGY AT CONPET S.A.  
In recent years, CONPET S.A. has made efforts to align itself with sustainability standards,  
preliminary steps that can be concretized in the future through a firm Strategy for integrating ESG  
criteria in investment planning and capital expenditure, recognizing that environmental, social and  
governance performance is closely linked to sustainable financial performance.  
The company's management has closely followed the implementation of the planned investments,  
with the well-defined aim of optimizing the operational activity, increasing the performance of the  
National Transport System (NTS) and improving operational safety. An eloquent example of a  
successfully completed ESG investment (and at the same time one of the most important  
investments of the last decade for CONPET S.A.) is the replacement of the crude oil transport  
136 I SUSTAINABILITY REPORT CONPET S.A.  
 
7. TAXONOMY AND ESG INVESTMENT STRATEGY  
pipelines under the Danube River and the Borcea Arm. The project, finalized in the second  
quarter of 2023, involved the installation of new, underground pipelines, made of modern  
materials and technologies, in place of the old pipelines crossing the Danube. With an investment  
value of ~€22 million (excluding VAT) , this large-scale project was a first for CONPET S.A. and  
demonstrated the company's commitment to environmental protection. The new pipelines, put  
into operation under maximum safety conditions, significantly reduce the risk of crude oil spills in  
sensitive natural areas, thus protecting the surrounding water and soil resources. The investment  
ensures the continued safe transport of crude oil across the Danube, avoiding potential  
environmental incidents caused by outdated infrastructure. In parallel, through subsequent  
investments visibly oriented towards sustainability, CONPET S.A. is carrying out a "multi-year  
program" of modernization of crude oil storage and pumping facilities. In 2020, the company  
commissioned a high-capacity storage tank at the Călăreți station, equipped with modern safety  
and emission control systems  
According to the information available on the company's website, the company has carried out a  
multi-year program of modernization of crude oil storage and pumping facilities. Under this  
program, in 2020, the construction of a new crude oil tank (R3) in the Călăreți Automated  
Transport Station (A.T.S.) with a capacity of 31,500 cubic meters was completed, with a value of  
15,933 thousand RON. This project was part of the company's investment strategy for 2020-2025,  
which includes the modernization and expansion of the crude oil transport and storage  
infrastructure.  
Also, in 2021, the replacement of the 14-inch crude oil pipeline between Bărăganu and Călăreți,  
with a length of 15,972 meters, was carried out with a value of 16,047 thousand RON. These  
investments reflect CONPET S.A.'s commitment to improve the efficiency and safety of its  
operations, as well as to reduce the environmental impact.  
Such upgrades to the existing infrastructure reduce pollution risks (by preventing accidental spills  
and minimizing hydrocarbon evaporation) and simultaneously improve the operational  
efficiency of the NTS. On the technological component, CONPET S.A. invests in digital SCADA  
pipeline monitoring and control systems, which allow the optimization of transport flows and the  
rapid detection of any anomalies. This increases energy efficiency and prevents incidents,  
combining environmental and operational safety objectives. The company's development strategy  
explicitly mentions the implementation of an advanced leak detection system and the  
modernization of the data acquisition system as key strategic directions, emphasizing the  
integration of sustainability principles into CONPET S.A.'s operational excellence. Overall,  
CONPET S.A.'s current portfolio of ESG investments reflects a balanced approach:  
environmental projects (reducing emissions and pollution, increasing energy efficiency),  
investments in occupational health and safety (e.g. maintaining the zero accidents goal through  
ISO 45001 certification and continuous SSM training), as well as initiatives with positive social  
impact (developing employee skills and community involvement through sponsorships and  
partnerships). This improved ESG performance is also reflected in stable financial results: for  
example, in 2023 CONPET S.A. achieved an operating profit of RON 66.4 million, above the  
previous year's level, demonstrating that investments in sustainability can go hand in hand with  
increased shareholder value. By optimizing operational costs and reducing environmental risks  
(which could otherwise turn into costs or penalties), the ESG approach contributes to the  
137 I SUSTAINABILITY REPORT CONPET S.A.  
7. TAXONOMY AND ESG INVESTMENT STRATEGY  
company's financial resilience. At the same time, by maintaining a high standard of corporate  
governance and transparency, CONPET S.A. continues to strengthen investor confidence and  
access to capital markets.  
PLANNING NEW SUSTAINABLE FINANCING OPPORTUNITIES  
Recognizing the accelerated dynamics of green funding, CONPET S.A. has established internal  
mechanisms for continuous monitoring of funding opportunities and proactive planning of  
future projects. Dedicated teams closely follow the launch of European and national calls for  
projects and funding guidelines, evaluating the eligibility of the company's project ideas against  
the criteria of these programs. At the same time, CONPET S.A. coordinates with relevant  
authorities (e.g. the Ministry of Energy) and industry partners to identify co-financing  
opportunities or consortia to access funds (an example would be working with other energy  
companies on regional green infrastructure projects). Through this integrated planning, the  
company ensures optimal alignment between its sustainability strategy and the timing of funding  
opportunities, minimizing the risk of missed funding opportunities and maximizing the impact of  
equity constrained investments.  
Although CONPET S.A. does not have a well-defined sustainability strategy, but as a national  
operator for pipeline transport it appears in national analyses for possible participation in the  
national decarbonization strategy. Thus in the PNIESC (National Integrated Energy and Climate  
Change Integrated National Plan) CONPET S.A. was nominated as a company that can provide  
CO2 transport through pipelines. In the framework of the PNIESC an estimation of the possibility  
of CO2 transport through pipelines of approx. 16mil t/year.  
POLICY RECOMMENDATIONS - ESG FUNDING AND TRANSPARENCY  
In order to increase access to ESG funding and to continuously improve the transparency of  
reporting, CONPET S.A. will focus its efforts on several clear strategic directions:  
Increasing the share of Taxonomy-eligible investments: the company will continue to  
develop projects aligned with climate goals (e.g. renewable energy, energy efficiency) so  
that an increasing share of annual CapEx is eligible and subsequently aligned with the EU  
Taxonomy. This will increase the company's financial resilience and attractiveness to  
financiers, as Taxonomy-compliant projects can benefit from lower capital costs and  
preference from institutional investors. The medium-term objective is for investments with  
climate and environmental benefits to represent a segment in the investment plan,  
enabling the company to report annually on the increase in the percentage of sustainable  
activities in accordance with Art. 8 of the Taxonomy Regulation.  
Full alignment with ESRS and OMF 85/2024 reporting standards: CONPET S.A. is  
fully committed to the European Sustainability Reporting Framework. In line with the  
new ESRS standards and OMF 85/2024 (which transposes the CSRD requirements at  
national level), the company treats climate, environmental and social reporting with the  
same degree of importance and rigor as traditional financial indicators. Sustainability  
reporting is thus integrated into the corporate reporting system, ensuring transparency,  
comparability and accuracy. The organisation is partially prepared for the collection and  
management of data to be audited and compliant with ESRS requirements. In doing so,  
138 I SUSTAINABILITY REPORT CONPET S.A.  
7. TAXONOMY AND ESG INVESTMENT STRATEGY  
the company continuously improves transparency and the ability to demonstrate ESG  
progress.  
Proactive communication with investors and stakeholders on ESG: Given the  
requirements of the Sustainable Financial Transparency Regulation (EU) 2019/2088  
(SFDR), CONPET S.A. recognizes the importance of providing relevant information that  
allows investors to correctly classify their investment in the company from an ESG  
perspective. In this regard, the company will continue to publish ESG key performance  
indicators and link its sustainability objectives to financial market expectations. The dialog  
with investors will include a clear presentation of how CONPET S.A. contributes to  
environmental objectives (e.g. emission reduction, green energy generated) and how it  
manages climate or transition risks. Such proactive communication, backed by solid data  
(aligned with the Taxonomy and ESRS), will increase investor confidence and highlight  
the company's positioning as an attractive opportunity for ESG-oriented investment funds.  
In addition, CONPET S.A. aims to strengthen its relationship with institutional financiers  
and banks by presenting its ESG performance indicators in annual reports and analyst  
meetings, highlighting annual progress (e.g. increasing percentage of green CapEx,  
decreasing emissions intensity, achieving safety targets).  
Through these strategic directions, CONPET S.A. aims both to facilitate access to sustainable  
financing and to improve ESG performance in an integrated way. The integrated approach - from  
targeting investments towards sustainable projects, to the effective use of green financial  
instruments, to transparent reporting according to international standards - ensures that the  
company is aligned with corporate sustainability best practices. In this way, CONPET S.A.  
strengthens its long-term position as a responsible energy operator, ready to face the challenges  
of the climate transition and to capitalize on the development opportunities arising from it, for the  
benefit of shareholders, the environment and society.  
139 I SUSTAINABILITY REPORT CONPET S.A.  
CONPET S.A.  
measures and monitors ESG  
indicators to ensure  
transparency, compliance and  
sustainable performance.  
8. PERFORMANCE INDICATORS AND COMPLIANCE  
WITH ESRS  
8.1 Key ESG indicators and objectives  
Non-financial reporting has become an indispensable element in demonstrating organizations'  
commitment to sustainability principles. This chapter outlines CONPET S.A.'s approach to  
measuring, monitoring and reporting environmental, social and corporate governance (ESG)  
performance indicators in line with the requirements of the European ESRS, the CSRD Directive  
and national legislation implemented by OMF no. 85/2024. These indicators reflect not only the  
company's current performance, but also its commitment to a sustainable future in which  
economic growth, social responsibility and environmental protection are harmoniously integrated  
into the business strategy.  
CONPET S.A.'s approach to sustainability aims to continuously improve its environmental, social  
and governance performance. In the current context of the transition to a green economy, the  
company aims to implement a comprehensive monitoring framework of ESG indicators, aiming to  
align with international best practices and comply with the requirements of ESRS standards.  
140 I SUSTAINABILITY REPORT CONPET S.A.  
   
8. PERFORMANCE INDICATORS AND COMPLIANCE WITH ESRS  
These indicators provide a transparent picture of the company's progress towards its sustainability  
goals and facilitate evidence-based decision-making.  
Performance indicators and ESRS compliance (2024)  
The year 2024 represents the first full year that CONPET S.A. reports its ESG (Environment,  
Social and Governance) performance. The ESG data and information used comes from internal  
sources (energy consumption, water and waste management reports and records) and external  
sources (compliance audits and standardized reporting according to the GHG Protocol and ISO  
14064-1), and is subject to validation by independent external audits.  
ESG Performance - Environment (ESRS E1-E5)  
TABLE 9.1. Greenhouse gas (GHG) emissions in 2024  
2.630,41 tCOe (direct emissions from fossil fuels used in own  
Total Scope 1 emissions  
vehicles and installations).  
4.451,10 tCOe (indirect emissions from purchased electricity).  
Total Scope 2 emissions  
11.825,08 tCOe (indirect emissions associated with the value  
Total Scope 3 emissions  
chain, estimated by standardized methodologies in the  
absence of detailed primary data).  
Table 9.2. Resource use and waste management in 2024  
Water used  
124.400 m³ with a recirculation rate of 65%  
800 tons, 100% treated according to legal  
requirements  
Hazardous waste generated  
Non-hazardous waste generated  
Material consumption  
4.200 tons, 78% recycled  
9.856 tons (down on the previous year)  
ESG PERFORMANCE - SOCIAL (ESRS S1, S3, S4)  
Working conditions and employee health  
CONPET S.A. maintains its commitment to a stable and fair work environment by implementing  
competitive wage policies and offering extensive social protection to employees. The company  
has implemented clear and rigorous processes to prevent accidents at work and manage  
occupational health and safety, obtaining and maintaining ISO 45001 certification.  
In parallel, CONPET S.A. promotes an active and constructive social dialogue, with an extremely  
high unionization rate (98.50%), reflected by the effective negotiation and signing of the Collective  
Bargaining Agreement (CBA) in 2024. It establishes a transparent framework for addressing  
employees' rights and obligations, ensuring organizational stability and a favorable climate for all  
staff.  
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8. PERFORMANCE INDICATORS AND COMPLIANCE WITH ESRS  
Skills development and training opportunities (ESRS S1)  
In 2024, CONPET S.A. has intensified its efforts on the professional development and continuous  
training of its employees, offering them clear and well-structured opportunities to improve their  
professional skills, adapted to operational requirements and sustainability standards.  
CONPET S.A.:  
Ensure regular training and certification of staff according to specific operational  
requirements;  
It offers continuous training programs to develop technical, digital and managerial  
skills;  
Monitors training needs and tailors training programs to meet strategic business  
requirements;  
Support internal and external training through collaborations with accredited  
institutions and training providers.  
Investing in training  
In 2024, CONPET S.A. continued to prioritize human resources development, investing in  
training and certification courses for its staff. According to internal reporting in 2024, there was a  
significant increase in the total number of participants in training and certification sessions from  
2,698 in 2023 to 3,609 participants in 2024.  
These training sessions cover both technical training and the skills required to operate the  
critical infrastructure managed by the company, the breakdown of which is given below:  
3%  
10%  
Technical specializations and  
specific authorizations  
10%  
12%  
C.F. Certifications  
Vocational training  
Internal authorizations  
Internal training/qualifications  
64%  
Chart 8.1. Training sessions - 2024  
142 I SUSTAINABILITY REPORT CONPET S.A.  
8. PERFORMANCE INDICATORS AND COMPLIANCE WITH ESRS  
ESRS S1 alignment and impact on the workforce  
According to ESRS S1 - Own Workforce, CONPET S.A. actively monitors the effects of training  
programs on employees. Their main benefits include:  
Increase the safety and quality of operational activities through better staff training;  
Improve workforce stability through access to professional development opportunities;  
Increase the competitiveness of employees by developing the technical and  
managerial skills needed by the industry.  
Training impact assessment and future perspectives  
In accordance with ESRS S1, CONPET S.A. constantly evaluates the effectiveness of its training  
programs, analyzing their impact on:  
Employees' individual and collective performance through the internal competency  
appraisal system;  
Degree of compliance with oil and energy regulations.  
For the coming years, CONPET S.A. intends to increase the number of training programs  
oriented towards digitalization, energy efficiency and sustainability, thus contributing to the  
modernization and optimization of operational processes.  
ESG PERFORMANCE - GOVERNANCE (ESRS G1)  
Anti-corruption policies and corporate integrity  
CONPET S.A. is committed to maintaining an ethical and transparent business environment in  
accordance with ESRS G1 and national corporate compliance legislation. In this regard, the  
company has implemented clear mechanisms to prevent corruption and fraud by:  
Code of Ethics and Business Conduct - sets out the principles of integrity,  
transparency and compliance in all company activities.  
Anti-bribery policies - explicitly prohibit any form of bribery, favoritism or unfair  
business practices in dealings with partners and authorities.  
Regular training for employees - training programs on anti-corruption and  
corporate ethics, risk awareness and regulatory compliance.  
CONPET S.A. aims to increase reporting and compliance through internal and external audits  
and will improve mechanisms monitoring and sanctioning integrity violations.  
Effective reporting and protection mechanisms for public interest warnings  
In order to ensure transparency and encourage reporting of unethical behavior, CONPET S.A.  
has strengthened whistleblower protection mechanisms, aligning with EU Directive 2019/1937 on  
the protection of whistleblowers and ESRS G1:  
Secure reporting channels - implementing an internal platform where employees can  
anonymously report any irregularities.  
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8. PERFORMANCE INDICATORS AND COMPLIANCE WITH ESRS  
Protection mechanism against retaliation - ensuring legal protection for those who  
report ethical or corruption violations.  
Transparent investigation process - each complaint is analyzed by a committee  
established according to internal procedures.  
CONPET S.A. will take measures to increase the awareness of employees about their rights and  
the use of reporting mechanisms.  
Monitoring relationships with suppliers and business partners  
CONPET S.A. operates in a complex business ecosystem and ESG risk management in the  
supply chain is an important component of corporate governance. CONPET S.A. plans to  
implement in the medium term the following:  
Sustainable procurement policies - integrating ESG criteria into the supplier  
selection and evaluation process. The company will aim to increase the number  
of partnerships with suppliers that comply with legal environmental and  
workplace safety requirements (e.g. ISO 14001 and ISO 45001 certifications).  
ESG contract clauses - compliance standard in commercial contracts.  
ESRS G1-4 (corruption incidents):  
During the year 2024, no incidents of corruption, bribery or ethical misconduct were reported or  
found within CONPET S.A. This information is a result of the affirmative action found in the  
sustainability report, in the section dedicated to training (Chart 7.3), where it is shown that 100%  
of employees in sensitive and management positions were trained and signed declarations of  
compliance, including on the topic of combating corruption and conflicts of interest . Also, the  
indicator on professional conduct and ethics (ESRS G1), states that there were no allegations of  
corruption during the reporting period. CONPET S.A. maintains its commitment to publish  
annually the status of incidents, including when it is nil, in the spirit of transparency as required  
by ESRS G1-4.  
ESRS G1-5  
CONPET S.A. did not carry out lobbying or organized political influence activities in 2024, in the  
sense of participating in legislative initiatives, actively promoting regulations or financing  
campaigns or organizations with the purpose of influencing.  
According to the dual materiality analysis the topic "Political influence and lobbying activities"  
under ESRS G1-5 was not identified as a material theme because:  
the company does not have organizational practices or structures in place to support  
such approaches;  
the legislation regulating the activity of CONPET S.A. is imposed by the regulatory  
authority (ANRMPSG);  
the company is not a member of any EU or national lobbying structures that influence  
environmental, energy or transport regulations.  
Consequently, ESRS theme G1-5 is considered immaterial for the reporting period.  
144 I SUSTAINABILITY REPORT CONPET S.A.  
8. PERFORMANCE INDICATORS AND COMPLIANCE WITH ESRS  
ESRS G1-6 (payment terms to suppliers):  
In 2024, the payment terms applied by CONPET S.A. were 30 days from the receipt of the invoice  
through the e-invoice system. All payments were made on the due date.  
ESG CORPORATE GOVERNANCE AND RISK MANAGEMENT  
CONPET S.A. has started the process of integrating ESG factors into its governance structure  
and decision-making processes, aligning with the ESRS G1 requirements:  
Monitoring the implementation of ESG components - The Board of Directors will  
oversee and assess the progress of sustainability initiatives, ensuring the alignment of the  
company's future strategy with ESG principles.  
ESG risk identification - As a first step, the company will conduct internal assessments  
to identify environmental, social impact and governance risks, with the intention to  
subsequently implement a formalized ongoing reporting system.  
Strengthening ESG risk management - CONPET S.A. aims to integrate ESG risks into  
its decision-making process and operational strategy, thus strengthening sustainability as  
an important element of its activities.  
To achieve these objectives, the company aims to implement the following measures in the  
medium term:  
Establish specific ESG specific tasks and responsibilities within advisory committees  
at Board level.  
Integrate ESG risks into the company's overall risk management system.  
Increase transparency in ESG performance reporting.  
Through these initiatives, CONPET S.A. reaffirms its commitment to a responsible and  
sustainable governance model.  
8.2 Alignment with European regulations and standards  
(ESRS)  
REPORTING CONTEXT AND ESRS REQUIREMENTS  
The year 2024, marks CONPET S.A.'s first sustainability reporting in accordance with the  
requirements of the Corporate Sustainability Reporting Directive (EU) 2022/2464 (CSRD) and the  
European Sustainability Reporting Standards (ESRS). This represents an important step in  
integrating the principles of transparency, corporate responsibility and sustainability into the  
company's activities.  
As the first ESRS reporting, CONPET S.A. has implemented only initial compliance measures,  
with the aim of fully integrating ESG reporting requirements and standards into its operational  
and decision-making processes in the coming years. This year:  
A preliminary analysis of the ESRS requirements and their impact on the company's  
activities has been carried out.  
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8. PERFORMANCE INDICATORS AND COMPLIANCE WITH ESRS  
Sustainability data was collected and structured, but without ongoing reporting  
mechanisms or external audit.  
No dedicated targets and policies have yet been set in line with the ESRS, these will  
be defined in the coming period, based on expert recommendations and stakeholder  
feedback (e.g. Ministry of Public Finance, Financial Supervisory Authority, etc).  
Main issues covered in this report  
In line with the ESRS requirements, the current report includes general information on the  
company's ESG performance, but does not yet reflect specific measures to align with all European  
standards. However, the following relevant areas for reporting have been identified:  
ESRS E1 - Climate Change  
o Reporting GHG emissions for scopes 1 and 2 according to the GHG Protocol  
methodology.  
o Overall emission reduction target  
o Initial investments in energy efficiency and use of renewable energy (e.g. photovoltaic  
panels).  
ESRS S1 - Own workforce  
o Employee structure and training policy.  
o Implementing health and safety measures in the workplace.  
ESRS G1 - Corporate Governance  
o Management structure and internal managerial control mechanisms.  
o Ethics and compliance policies, no ESG system in place.  
CHALLENGES AND NEXT STEPS FOR ESRS COMPLIANCE  
Given that ESG policies and reporting mechanisms fully aligned with the ESRS have not yet been  
developed, the main challenges and objectives for the coming years include:  
Create a dedicated ESG strategy, based on ESRS and CSRD requirements.  
Improve the ESG data collection process by implementing an internal system for  
monitoring and reporting on sustainability indicators.  
Set measurable and realistic targets on climate change, circular economy, workforce  
diversity and corporate governance.  
Increase the integration of ESG principles into strategic decisions, including by  
aligning procurement and investment processes with sustainability criteria.  
Integrated ESG data collection, monitoring and validation system  
In 2024, the first year of reporting under the ESRS, CONPET S.A. began steps to improve the  
transparency and accuracy of its ESG reporting. In the absence of a dedicated data collection  
146 I SUSTAINABILITY REPORT CONPET S.A.  
8. PERFORMANCE INDICATORS AND COMPLIANCE WITH ESRS  
system, the company adopted a step-by-step approach, relying on internal sources of information  
and external expertise from consultants specialized in ESG reporting.  
Measures implemented in this first reporting year:  
Decentralized collection of ESG data by entities in the relevant business areas (e.g.  
Environment, Human Resources, Finance, Operations, Transport, Integrity).  
Preliminary validation of information through internal mechanisms with the help of  
specialized consultants.  
Recruitment of ESG experts for:  
o Assistance in collecting and interpreting data specific to sustainability reporting.  
o GHG emission calculations and compliance with ESRS requirements.  
o Prepare internal staff for future reporting cycles and improve the ESG reporting  
system.  
The company aims over the next years (2025-2027) to gradually develop its ESG reporting  
system, which would involve:  
Create a flow to ensure consistency and traceability of ESG information.  
Train internal staff to autonomously manage the ESG reporting process with the  
support of consultants.  
Establish a regular data verification mechanism to improve compliance with ESRS and  
the credibility of future reporting.  
Own methodology adapted to the requirements of dual materiality  
Being the first ESG reporting of CONPET S.A. under CSRD and ESRS, the company does not  
yet have a fully standardized methodology for dual materiality, but has initiated the first steps to  
align with these requirements. In this respect, CONPET S.A. has implemented the following  
measures:  
Preliminary identification of relevant ESG themes for CONPET S.A., based on ESRS  
requirements and ESG risks and opportunities analysis.  
Stakeholder mapping.  
Analysis of the impact of company activities on the environment and society, without  
a complete financial quantification of these impacts.  
Hiring specialized consultants for:  
o Defining the materiality analysis methodology.  
o Assistance in assessing ESG risks and opportunities.  
o Training internal teams on the application of the principle of dual materiality in future  
reporting.  
For the coming years, CONPET S.A. aims to strengthen the methodology by:  
147 I SUSTAINABILITY REPORT CONPET S.A.  
8. PERFORMANCE INDICATORS AND COMPLIANCE WITH ESRS  
Elaborate own methodology based on ESRS and GRI requirements.  
Set up a structured stakeholder consultation process to validate material themes and  
ESG priorities.  
Extending the materiality analysis to include direct and indirect impacts as required by  
the ESRS.  
Continuous training of staff to understand and apply the materiality methodology in  
future reporting.  
CERTIFIED MANAGEMENT SYSTEMS TO ENSURE COMPLIANCE  
CONPET S.A. continuously maintains and improves its certified management systems to ensure  
compliance with implemented standard requirements, which include compliance with legal  
requirements, international regulations and industry best practices. By certifying its management  
systems, the company demonstrates its commitment to sustainability by aligning with both  
corporate governance and reporting requirements in accordance with ESRS (European  
Sustainability Reporting Standards).  
Certifications Management systems implemented at CONPET S.A.  
To ensure efficient and sustainable management, CONPET S.A. holds the following essential  
certifications:  
1. ISO 9001:2015 - Quality Management System  
o Ensures high quality standards for pipeline oil transport services.  
o It involves continuously monitoring and improving processes, maintaining tight  
control of activities and increasing customer satisfaction.  
o ESG Benefits: Increased operational efficiency and process optimization to reduce  
waste and negative environmental impacts.  
2. ISO 14001:2015 - Environmental Management System  
o It supports environmental protection initiatives and promotes responsible  
resource management.  
o Ensures compliance with national and European environmental regulations and the  
implementation of sustainable practices in the operation of transport infrastructure.  
o ESG benefits: Minimizing environmental impacts, reducing greenhouse gas (GHG)  
emissions and improving energy efficiency.  
3. ISO 45001:2018 - Occupational Health and Safety Management System  
o Provides safe working conditions for employees, reducing the risks associated with  
operational activities.  
o Contribute to improving occupational health and safety (OHS) performance by  
assessing and controlling OHS risks.  
o ESG benefits: Protecting the health and safety of employees, reducing workplace  
accidents and creating a safe working environment.  
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8. PERFORMANCE INDICATORS AND COMPLIANCE WITH ESRS  
4. ISO 50001:2018 - Energy Management System  
o It aims to improve energy performance, streamline energy consumption and reduce  
the energy impact of CONPET S.A. operations.  
o Facilitates the monitoring and optimization of energy consumption, including the  
integration of renewable energy sources (e.g. photovoltaic panels).  
o ESG benefits: Alignment with the 10% emission reduction target through more  
efficient energy management.  
5. ISO 37001: 2016 - Anti-Bribery Management System  
o Ensures compliance with anti-bribery legislation applicable to the organization and  
zero tolerance of bribery.  
o It contributes to the highest standards of ethics and integrity in the conduct of  
business and processes.  
o ESG benefits: increased confidence in commercial negotiations and improved  
reputation of CONPET S.A.  
Integrating certifications into ESG strategy and ESRS compliance  
Certified management systems are not only compliance requirements but also essential tools for  
implementing and reporting ESG strategy. ESRS alignment is reflected in the following areas:  
Chart 8.2. ESRS domains  
THE BENEFITS OF MANAGEMENT SYSTEM CERTIFICATION FOR STAKEHOLDERS  
By maintaining these international certifications, CONPET S.A. brings tangible benefits for:  
149 I SUSTAINABILITY REPORT CONPET S.A.  
8. PERFORMANCE INDICATORS AND COMPLIANCE WITH ESRS  
Employees - Safer working environment, health protection and continuous training.  
Investors - Increase transparency and trust in the company's ESG practices.  
Regulators - Strict compliance with legislative requirements and international standards.  
Customers and partners - High quality services and guaranteed operational  
sustainability.  
Prospects and improvements for the future  
For the coming years, our company aims to maintain its ISO certifications and will also analyze  
the possibility of implementing new integrated management systems, including:  
Increased automation and digitization ESG and environmental processes.  
Stricter alignment with the EU Taxonomy and requirements for sustainable  
investments.  
Develop a sustainable development management system based on the requirements  
of the ESRS and the new CSRD regulations  
8.3 ESG 2024 risks and opportunities (ESRS E1-E5)  
During 2024, CONPET S.A. carried out a detailed analysis of the ESG risks and opportunities  
associated with its operational activities. This assessment, conducted in accordance with ESRS  
standards and the principle of dual materiality (financial impact and ESG impact), led to the  
identification of the following relevant issues with clear implications for the company's business  
and financial performance.  
SIGNIFICANT ESG RISKS IDENTIFIED IN 2024  
In the year 2024, the ESG analysis according to the dual materiality methodology highlighted  
several operational and strategic risks impacting the company's sustainability and resilience:  
1. Sustainable management of water resources and exposure to water risks  
The company utilizes facilities and has water extraction wells in areas of moderate to high water  
vulnerability. In the absence of a risk mitigation plan, a possible reduction in the availability of  
water resources could lead to operational constraints and the need for adaptive measures, such  
as optimizing consumption, diversifying water sources and investing in alternative technologies.  
2. Exposure to environmental risks associated with operational activities  
The transport and handling of petroleum products inevitably entails risks related to technical  
incidents and potential accidental spills, which can affect large areas of land. To prevent  
environmental impacts, continuous measures are needed to upgrade infrastructure, implement  
advanced leak detection technologies and optimize rapid response processes.  
3. Increased requirements for waste management and the circular economy  
The generation and disposal of hazardous and non-hazardous waste is subject to stringent  
regulations, and legislative trends at the European level indicate an intensification of reporting  
requirements and minimization of environmental impacts. The company needs to ensure  
continued compliance with legal requirements for waste management and actively contribute to  
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8. PERFORMANCE INDICATORS AND COMPLIANCE WITH ESRS  
the circular economy in the context of frequent legislative changes and compliance cost  
pressures.  
4. Risk of high capitalization cost and limited access to sustainable funding  
Increased requirements in green finance and sustainable insurance ratings add additional risk for  
companies that do not have a robust ESG risk analysis and a concrete plan to mitigate  
environmental impacts. In the absence of proactive measures, the company could face higher  
capitalization costs and restricted access to green finance sources or advantageous insurance  
products. Alignment with EU taxonomy requirements and the implementation of clear climate  
transition and mitigation strategies are essential to maintain financial and operational  
competitiveness.  
ESG OPPORTUNITIES SEIZED IN 2024  
CONPET S.A. acted proactively to transform ESG challenges into strategic and sustainable  
growth opportunities by implementing specific projects and initiatives, which had measurable  
results in 2024.  
In 2024, CONPET S.A. has implemented several initiatives aimed at transforming sustainability  
challenges into strategic ESG opportunities, generating value for both the company and its  
stakeholders. The capitalized ESG opportunities focus on three main pillars: environmental, social  
and governance. These initiatives are aligned with the European Sustainability Reporting  
Standards (ESRS) and support the company's policies to reduce environmental impacts, increase  
operational efficiency and improve corporate governance.  
1. Environmental opportunities (ESRS E1, E2, E5)  
a) Increased energy efficiency and use of renewable energy  
o
o
o
Expansion of solar energy capacity by installing photovoltaic panels at Constanta Sud  
and Călăreți stations and other operational units.  
Future objective: to reduce energy consumption from conventional sources and  
decrease COemissions, contributing to the GHG reduction target.  
ESG Impact: Alignment with ESRS E1 (Climate Change) and ESRS E5 (Circular  
Economy).  
b) Optimizing resource consumption and waste management  
o
Implement advanced waste reduction and recovery measures in the maintenance of  
oil transport infrastructure.  
o
ESG Impact: Application of circular economy principles through reuse of materials and  
minimization of hazardous waste generated by operations (ESRS E5).  
c) Upgrade infrastructure to reduce accidental spills  
o
Upgrade the leak detection system in the oil transport network to reduce accidental  
spills.  
o
ESG impact: Increased operational safety and decreased risk of accidental pollution,  
alignment with ESRS E2 (Pollution).  
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8. PERFORMANCE INDICATORS AND COMPLIANCE WITH ESRS  
2. Social opportunities (ESRS S1, S3, S4)  
a) Employee skills development and safety at work  
o
Increase in the number of training programs for technical and administrative staff, with  
a total of 3,609 participants in training and licensing sessions in 2024, a significant  
increase from the previous year.  
o
ESG Impact: Providing a safe and motivating work environment as per ESRS S1 (Own  
workforce).  
b) Community involvement and social responsibility initiatives  
o
Education and professional development program for students and young  
professionals, through which CONPET S.A. offers internships.  
o
o
Participate in blood donation campaigns and support public health initiatives.  
ESG Impact: Strengthening the relationship with the local community and creating a  
positive social impact (ESRS S3 - Affected Communities).  
c) Diversity and inclusion  
o
Promoting equal opportunities in the company by increasing the representation of  
women in management positions and implementing inclusive and non-discrimination  
policies.  
o
ESG Impact: Alignment with ESRS S1 - Working Conditions and Inclusion.  
8.4 ESG 2024 Performance and Compliance (ESRS & CSRD)  
In 2024, CONPET S.A. achieved notable results, reflecting an improvement in ESG performance  
and compliance:  
Environmental performance  
o
The company has achieved a share of about 27% of its energy produced from  
renewable sources at its administrative site 2, thanks to investments in photovoltaic  
systems.  
o
It has implemented operational measures to recycle 78% of non-hazardous waste and  
treat 100% of hazardous waste, confirming its commitment to the circular economy  
and waste management targets set in the area of waste management.  
Social performance  
o
In 2024, CONPET S.A. carried out 22,237 hours of professional training, which  
represented an average of approximately 16 hours/employee, significantly improving  
technical, operational and managerial skills.  
o
A positive organizational climate has been maintained, evidenced by a very high  
degree of unionization (98.50%) and the signing of the Collective Bargaining  
Agreement, guaranteeing social stability and clear working conditions and competitive  
benefits.  
152 I SUSTAINABILITY REPORT CONPET S.A.  
 
8. PERFORMANCE INDICATORS AND COMPLIANCE WITH ESRS  
o
No occupational accidents have been reported, confirming the effectiveness of  
preventive measures and the maintenance of the occupational health and safety  
management system in compliance with ISO 45001.  
Performance in corporate governance:  
o
CONPET S.A. has implemented a secure and anonymous digital mechanism for  
warnings/warnings on the rules of ethical conduct leading to the identification and  
transparent management of 2 minor incidents, promptly resolved through training and  
internal corrective measures.  
o
The company achieved ISO 37001:2016 anti-bribery management system certification  
in 2022, and through annual surveillance demonstrates the organization's strategic  
commitment to preventing corruption and increasing stakeholder confidence.  
THE NEED TO CONTINUE ESG STRATEGIC INVESTMENTS AND DEVELOP A  
SUSTAINABLE INVESTMENT STRATEGY  
The ESG impact assessment confirms the need to accelerate strategic investments to improve  
sustainable performance and strengthen operational resilience:  
Reducing greenhouse gas (GHG) emissions: In line with the GHG Protocol and ESRS  
reporting standards, an effective plan to reduce direct and indirect emissions and transition  
to renewable energy sources needs to be developed.  
Optimize water consumption and reduce exposure to water risks: Implementing  
advanced water monitoring and reuse systems, diversifying sources, and integrating  
alternative solutions will help reduce reliance on vulnerable resources and minimize  
operational risks.  
Improving operational safety and preventing environmental incidents: Investments  
in advanced prevention technologies, early leak detection systems and optimized  
response procedures are needed to reduce reputational and compliance risks.  
Continuous alignment to legal requirements for waste management and  
contribution to the circular economy: Frequent legislative changes require a constant  
adaptation of waste management strategies, the development of partnerships for recycling  
and the use of sustainable solutions to minimize environmental impacts.  
Increasing access to sustainable finance and reducing capitalization costs:  
Integrating ESG criteria into strategic decisions, running ESG financial stress scenarios  
and aligning with climate reporting standards (TCFD, ISSB, ESRS) are key to attracting  
green finance, sustainable insurance and improving sustainability ratings.  
153 I SUSTAINABILITY REPORT CONPET S.A.  
CONPET S.A.  
Aresponsiblefuture is  
built through concrete  
actions in the present.  
9. FUTURE SUSTAINABILITY PERSPECTIVES  
AND OBJECTIVES  
To ensure a sustainable and efficient transition, it is essential to strengthen and optimize the policy  
framework through concrete measures to reduce emissions, responsible management of water  
resources and implementation of the circular economy principles.  
CONPET S.A. implements a diverse range of sustainability initiatives structured along the three  
ESG dimensions (environmental, social and governance). In the area of environmental protection,  
the company focuses on energy efficiency, renewable energy and infrastructure modernization to  
prevent technical failures. Social priorities include employee safety, professional development  
and support for local communities. The governance dimension is strengthened through ethical  
practices and transparency in dealing with all stakeholders.  
154 I SUSTAINABILITY REPORT CONPET S.A.  
 
9. FUTURE SUSTAINABILITY PERSPECTIVES AND OBJECTIVES  
Table 9.3. Achievements for sustainability and environmental protection  
Initiative  
Description  
Impact  
Maintain the energy management  
system (ISO 50001) and upgrade  
equipment to reduce energy  
consumption  
Modernizing equipment to reduce  
energy consumption  
Reducing energy  
consumption and carbon  
emissions  
Energy efficiency  
Maintenance of environmental  
management system (ISO 14001)  
Ensuring compliance with  
environmental protection  
requirements and monitoring the  
impact of company activities  
Improving  
environmental  
performance  
Keeping environmental  
aspects and associated  
impacts under control  
27% of the premises'  
electricity consumption  
covered by renewable  
sources  
Installation of photovoltaic systems at  
the secondary building (Administrative  
Building no. 2)  
Photovoltaic panels  
Replacement of pipeline segments  
under the Danube and Borcea arm  
using advanced technologies  
Reducing the risk of spills  
and protecting aquatic  
ecosystems  
Modernization of  
NTS infrastructure  
Implementing advanced leak  
detection systems and upgrading the  
cathodic protection system  
Prevent environmental  
incidents and protect soil  
and water  
Monitoring and  
preventing oil spills  
Active contribution to  
maintaining the  
technological consumption  
within the maximum limits  
allowed for crude oil at  
CONPET S.A. level.  
Compliance with specific consumption  
limits for crude oil transport  
Monitoring  
technology  
consumption  
Monitoring specific  
annual average  
specific  
consumption of  
electricity for  
technological  
purposes  
Compliance with the maximum  
allowable specific annual electricity  
consumption  
Maintain energy efficiency  
by optimizing consumption  
and preventing overshooting  
limits  
155 I SUSTAINABILITY REPORT CONPET S.A.  
9. FUTURE SUSTAINABILITY PERSPECTIVES AND OBJECTIVES  
Initiative  
Description  
Impact  
The constant realization of selective  
collection and the permanent  
existence of valid contracts for the  
waste generated in CONPET S.A.  
locations, for the purpose of  
recovery/disposal.  
Operate in compliance with  
legal and other requirements  
applicable to own identified  
environmental issues.  
Ensuring selective collection  
at CONPET S.A. locations.  
Sorting waste at  
source  
To reduce the number of incidents  
with significant environmental impact  
so that the number of incidents is ≤  
the number recorded in the previous  
year.  
Constantly improving  
environmental performance  
and reducing incidents with  
significant impact each year.  
Preventing and  
combating  
accidental pollution  
Table 9.4. Achievements for sustainability and social responsibility initiatives  
Initiative  
Description  
Impact  
Health and safety at  
work  
Maintaining the occupational health  
and safety management system (ISO  
45001)  
Zero accidents at work  
in recent years  
Increasing skills and  
motivation  
Ongoing training programs to develop  
employee skills  
Professional  
development  
workforce  
Community  
sponsorships  
Active contribution to the  
social and cultural  
development of communities  
Support for cultural, educational and  
health events in local communities  
156 I SUSTAINABILITY REPORT CONPET S.A.  
9. FUTURE SUSTAINABILITY PERSPECTIVES AND OBJECTIVES  
Table 9.5. Achievements for sustainability and corporate governance  
Initiative  
Description  
Impact  
Maintaining anti-bribery standards  
(ISO 37001) and transparent  
reporting of activities  
Building stakeholder trust and  
enhancing reputation  
Transparency and  
ethics  
Increase operational efficiency  
and optimize internal  
processes  
Improving  
performance  
Maintaining the quality management  
system (ISO 9001)  
Roadmap for sustainability  
CONPET S.A.'s Sustainability Roadmap 2025-2030 sets out the company's vision for the coming  
years, with ambitious targets covering all three ESG dimensions. On the environmental  
dimension, the company aims to reduce GHG emissions. Social initiatives focus on developing  
employees' green skills and community-based green regeneration programs. In the area of  
governance, CONPET S.A. aims to be a benchmark in the application of ESG standards,  
integrating sustainability into all strategic decisions. This reflects the company's commitment to a  
responsible and sustainable future.  
Table 9.6. Sustainability initiatives 2025-2030  
Initiative  
Description  
Launch a regular sustainability awareness and training program  
for employees, aiming not only to inform but also to create an  
internal sustainability culture to guide company decisions and  
actions.  
Training staff in sustainability  
Elaborate an integrated ESG strategy and transition plan to align  
corporate governance with sustainability best practices.  
Developing an ESG strategy  
and transition plan  
Progressively increasing the installed renewable energy capacity,  
reaching 180 kWp by 2026 and expanding to 360 kWp by 2030.  
Increasing renewable energy  
capacity  
Support a programme to regenerate ecosystems and support  
local communities through sustainable development initiatives.  
Community program for  
environmental and economic  
regeneration  
157 I SUSTAINABILITY REPORT CONPET S.A.  
9. FUTURE SUSTAINABILITY PERSPECTIVES AND OBJECTIVES  
Initiative  
Description  
Developing and  
Elaborate a sustainable strategy to reduce carbon footprint and  
identify alternative energy solutions.  
implementing a strategic  
framework for reducing the  
carbon footprint  
Implementation of measures to reduce greenhouse gas  
emissions by at about 8% (Scopes 1 and 2), by optimizing  
operational processes, increasing the use of sustainable energy  
sources and increasing the percentage of energy consumed from  
renewable energy suppliers.  
Reducing emissions  
GES  
Raising ESG awareness by implementing a training program and  
educational initiatives within the company and in the  
communities.  
Developing an ongoing ESG  
awareness program  
Leadership in ESG practices at the national level and integration  
of sustainability into the company's decision-making and strategic  
processes.  
Strengthening your role  
leadership in ESG practices  
Providing a minimum of 10 hours of training and education per  
employee to train and develop professional skills and knowledge.  
Education and training of  
own staff  
Preparation, training, evaluation and periodic internal testing of  
CONPET S.A. staff, carried out within the framework of anti-  
corruption awareness and education programs.  
Implement integrity as  
required by law  
Ensuring women's access to management positions, with the  
objective of maintaining a minimum of 30% of female managers  
out of the total number of management positions at CONPET  
S.A..  
Respecting gender equality  
These initiatives can be translated into specific investment projects as follows:  
Reducing greenhouse gas emissions  
An indicative reduction target for Scope 1 and Scope 2 emissions by 2030 is being considered,  
benchmarked to 2024 and in line with the general directions of the European Ecological Pact. In  
this context, energy efficiency initiatives are being analysed to reduce these emissions by around  
8% through a series of projects such as:  
o Selection of electricity suppliers so that, on average, at least 50% of energy purchased  
comes from renewable energy suppliers;  
o Installation of renewable electricity generation systems contributing to this initiative  
These measures aim to contribute to the process of reducing greenhouse gas emissions by at  
about 8%.  
158 I SUSTAINABILITY REPORT CONPET S.A.  
9. FUTURE SUSTAINABILITY PERSPECTIVES AND OBJECTIVES  
Circular economy and waste management  
It is envisaged to continue the selective collection of waste to enable its continuous collection for  
recovery or disposal.  
Strengthening compliance mechanisms  
Increased attention will be given to the achievement of the proposed sustainability targets,  
including by integrating these issues into operational meetings, where dedicated time will be  
allocated to review progress and identify solutions to improve sustainability performance. The aim  
is to integrate the company among the top performing organizations in terms of sustainability  
practices.  
Improved reporting and transparency  
Digital mechanisms for collecting and analyzing sustainability data will be adopted, facilitating the  
generation of detailed and accessible stakeholder reports. These measures will contribute to  
building stakeholder trust and improve the company's ranking among ESG best practice  
organizations.  
In addition, the following initiatives could be considered:  
Adapting to climate change  
A carbon footprint reduction framework can be implemented, which will include energy efficiency  
measures and transition to renewables. In this regard, the company can continue to invest in  
infrastructure modernization to reduce climate change risks such as accidental spills and  
excessive energy consumption. At the same time, environmental regeneration initiatives and the  
protection of vulnerable ecosystems can be pursued, contributing to the resilience of operations.  
These measures would support the company's alignment with the objectives of the European  
Ecological Pact and international sustainability standards.  
Digitizing operations  
The current remote management system can be developed to optimise operational processes  
with significant impact and monitor energy consumption, ensuring compliance with energy  
efficiency and sustainability objectives. Automating workflows and digitizing reporting processes  
would help reduce time spent on administrative tasks and increase transparency. A centralized  
system for monitoring technology consumption can also be introduced, facilitating real-time data-  
based decision-making. These measures would support the integration of ESG into corporate  
strategy and improve operational efficiency.  
By implementing these initiatives, CONPET S.A. strengthens its commitment to  
sustainability and demonstrates a strategic vision oriented towards adaptation, innovation  
and long-term responsibility.  
159 I SUSTAINABILITY REPORT CONPET S.A.  
9. FUTURE SUSTAINABILITY PERSPECTIVES AND OBJECTIVES  
CONCLUSIONS  
CONPET is a company with a notable activity in the oil and gas industry in Romania, which in  
over 30 years of activity, through modernization projects and large-scale investments, has  
responded to all the challenges posed by the dynamics of an industry essential for the energy  
sector.  
We responsibly carry out an activity that contributes to keeping the world on the move, being a  
forward-looking and environmentally friendly company that understands how to maintain the right  
balance between past and future, between tradition and progress. CONPET's investment projects  
are aimed at increasing the efficiency of the transport activity, the safe operation of the National  
Transport System and minimizing the impact on the environment, in the context of the energy  
transition process and the company's policy of aligning with the new European  
environmental standards.  
With this first sustainability report, CONPET S.A. reaffirms its strong commitment to transparency,  
corporate responsibility and long-term sustainable development. The detailed and in-depth  
analysis of ESG indicators reflects a broad understanding and integrated approach to the  
operational impact on the environment, society and the economy. In the face of climate challenges  
and the increasingly stringent requirements of ESG standards, CONPET S.A. adopts a proactive  
and forward-looking approach, constantly identifying responsible investment opportunities. The  
company is committed to reducing greenhouse gas emissions, managing natural resources  
efficiently and supporting the energy transition. At the same time, CONPET S.A. aligns its  
strategies with national and European objectives, actively contributing to the implementation of  
environmental and sustainable development policies.  
CONPET S.A. will integrate ESG criteria into its decision-making and operational processes,  
promoting transparency and integrity. The active involvement of stakeholders - employees,  
communities, suppliers and partners - remains essential, and the company will continue to  
improve dialog and feedback mechanisms for responsible development. We would like to express  
our deep appreciation to all stakeholders for their continued support, active engagement and  
valuable collaboration to date. We strongly reaffirm our commitment to continuous progress in an  
ethical, transparent and accountable manner, ensuring a positive and lasting contribution for  
present and future generations.  
Finally, all our lines of action are aimed at the sustainable development of the company, in  
harmony with the European energy strategy and with the responsibility imposed by the  
management of a strategic activity for Romania's energy security.  
160 I SUSTAINABILITY REPORT CONPET S.A.  
Annexes  
Annexes  
ESRS compliance table  
ESRS  
ESRS  
Status in  
2024  
Detailed explanations and sources  
Standard requirement  
The report details climate policies in Chap. 4.1,  
documented through the implementation of ISO  
14001 and ISO 50001 management systems. The  
policies cover pollution prevention, energy efficiency  
and climate compliance. Reference is also made to  
climate impact management in the section on dual  
materiality (Chap. 3).  
E1-1  
E1-2  
E1-3  
Climate policies Fully met  
Chaps. 4.2 and 4.3 of the Report clearly document  
concrete actions: installation of photovoltaic panels  
(27% of consumption covered at the secondary site),  
modernization of pipelines under the Danube,  
upgrading of pumping stations. Investments in  
renewable energy and energy efficient technologies  
are indicated.  
Mitigation and  
adaptation  
actions  
Fully met  
Although significant investments are mentioned (e.g.  
€26m for the Borcea pipelines), the report does not  
present a consolidated ESG budget or a budget  
chapter dedicated to climate action. There is no  
breakdown by type of resources. For the next report  
it is intended to introduce ESG resources with an  
estimated budget structure.  
Financial and  
technical  
resources  
allocated  
Partially  
met  
Chap. 4.3 and Chart 2.5: the company aims to  
reduce GHG emissions by ~8% by increasing the  
share of renewables in the purchased mix (from 52%  
to 85.4% in 2025). A strategic direction to reduce  
emissions intensity is also mentioned.  
Climate targets  
(GHG  
reductions)  
E1-4  
E1-5  
E1-6  
Fully met  
Fully met  
Fully met  
Section 8.1 of the Report provides the indicator:  
13.21 kWh/1,000 RON net revenue, calculated  
according to ESRS requirements. It correlates with  
the energy efficiency initiatives presented in Chapter  
4.3.  
Energy intensity  
(kWh / income)  
The indicator is calculated: 13.26 kg CO₂e / 1,000  
RON income, according to the GHG Protocol, based  
on total emissions domains 1-3 (Chap. 3.3 + 8.1).  
The methodology is transparent and aligned with  
ESRS.  
GHG intensity  
(kg CO₂e /  
income)  
GHG removals  
and carbon  
credits  
In all the tables (including the integrated ESRS), it is  
mentioned that no carbon credits or GHG offset  
measures (e.g. afforestation, CCS) were used.  
Not  
applicable  
E1-7  
E1-8  
The report contains no model calculation or  
simulation of an internal carbon price. The ESRS  
Table only mentions the modeling intent for 2025  
Internal carbon Not yet  
price addressed  
161 I SUSTAINABILITY REPORT CONPET S.A.  
 
Annexes  
ESRS  
ESRS  
Status in  
2024  
Detailed explanations and sources  
Standard requirement  
Chapter 4.4 of the report details the policy for  
prevention and monitoring of soil, water and air  
pollution. It mentions: ISO 14001 certification, the  
existence of leak detection systems, inspection plans  
and environmental interventions. There are  
responsible allocations and response structures for  
each site.  
Pollution  
E2-1  
Fully met  
policies  
Table 9.4 of the report (sustainability initiatives)  
explicitly formulates an annual target: "Reduce the  
number  
of  
incidents  
with  
significant  
Pollution  
prevention  
targets  
environmental impact to less than or equal to the  
previous year." This is an operational and  
quantifiable ESG target applicable to accidental  
pollution risks. Also confirmed in the dual materiality  
analysis.  
E2-3  
E2-4  
Fully met  
Fully met  
The existence of a rigorous monitoring system for air,  
water and soil pollutants is confirmed in Chap. 4.4.  
No significant incidents are recorded for 2024.  
Measures include regular inspections, automatic  
leak detection, greening by authorized firms.  
Air, soil and  
water pollution  
This is covered in the supporting technical documents.  
The WFD analysis includes safety data sheet tables  
(SVHC) and documentation submitted to ITM and the  
Dangerous  
Substances  
(SVHC/REACH)  
Ministry of Environment.  
The WFD mentions  
E2-5  
Fully met  
neutralization and traceability procedures for  
hazardous substances. The materiality methodology  
confirms the inclusion of these topics in the ESG  
assessment.  
Chap. 4.4 of the report deals with sustainable water  
use policies. It mentions continuous monitoring of  
consumption, the use of own sources (boreholes),  
Water and  
marine policies  
E3-1  
Fully met  
pollution  
prevention  
and  
compliance  
with  
environmental legislation. No incidents are reported.  
Water  
consumption  
targets  
The company complies with the limits imposed on  
the maximum flow rates for water supply from wells  
as required by law.  
E3-3  
E3-4  
Fully met  
Fully met  
Chap. 8.1 presents the total annual water  
consumption by location in m³/year. The sources  
(own boreholes and network supply) and monitoring  
shall be indicated.  
Reporting total  
water  
consumption  
Chap. 4.4 mentions measures to prevent impacts on  
biodiversity, including monitoring and greening after  
works. It is clearly stated that activities do not take  
place in protected areas or vulnerable ecosystems.  
Biodiversity and  
ecosystems  
policies  
E4-2  
Fully met  
162 I SUSTAINABILITY REPORT CONPET S.A.  
Annexes  
ESRS  
ESRS  
Status in  
2024  
Detailed explanations and sources  
Standard requirement  
There is no formal or voluntary biodiversity protection  
target. It is mentioned that no protected areas are  
affected, but no "0 incidents" or "X% habitat  
Biodiversity  
targets  
Not  
E4-4  
addressed restoration" target is set. Also confirmed as missing  
in ESRS tables. Voluntary targets are sought for next  
reporting.  
Chap. 4.4 and Table 3.5 confirm no incidents in 2024  
affecting natural ecosystems. There are no direct  
interactions with significant biodiversity and the  
areas crossed are outside protected sites.  
Biodiversity  
impact  
indicators  
E4-5  
E5-1  
Fully met  
Chap. 4.4 of the report describes waste  
management policies, the application of the waste  
hierarchy (prevention, reuse, recycling) as well as  
technological measures to minimize waste  
generation. Appropriate management of hazardous  
waste is mentioned.  
Policies on  
circularity and  
resource use  
Fully met  
The report states that "most waste is recovered or  
recycled, avoiding direct disposal". However, there is  
neither a formal target nor a quantifiable percentage  
in the narrative text. The intention for the next report  
is to insert more explicit targets.  
Circularity and Partially  
reuse targets met  
E5-3  
E5-4  
The report does not provide an inventory of the  
materials used (e.g. steel, industrial liquids, energy  
inputs) and does not mention the proportion of  
recycled or sustainable materials. The lack is also  
reported in the compliance tables. A table of  
materials used, including recycled or sustainable  
materials, is planned for the next report.  
Resource inputs Partially  
- materials used met  
Chap. 4.4 provides qualitative and operational  
information on types of waste generated (including  
Resource  
E5-5  
S1-1  
outputs - waste Fully met  
and recovery  
hazardous),  
treatment  
methods  
(recycling,  
recovery), incident prevention and traceability. It  
states that there were no major incidents in 2024.  
Ch. 5.1 details the structure of the workforce: gender,  
age, types of contracts, diversity policies and  
organizational stability. An inclusive approach is  
documented.  
Composition  
and inclusion of Fully met  
the workforce  
Pay, benefits  
and contractual Fully met  
conditions  
Chaps. 5.1-5.2 confirm timely payment, existence of  
CCM, fringe benefits (insurance, vacation), no salary  
arrears.  
S1-2  
S1-3  
S1-4  
Health and  
safety at work  
(H&S)  
Ch. 5.2 and Ch. 8 mention the ISO 45001 certified  
SSM system, the goal of zero accidents, regular  
training and no incidents in 2024.  
Fully met  
Fully met  
Social dialogue  
and  
Ch. 5.1 confirms the existence of a valid Collective  
Bargaining  
Agreement,  
active  
consultation  
representation  
structures and no industrial disputes in 2024.  
163 I SUSTAINABILITY REPORT CONPET S.A.  
Annexes  
ESRS  
ESRS  
Status in  
2024  
Detailed explanations and sources  
Standard requirement  
Skills  
development  
and training  
Chap. 5.2 mentions technical and managerial  
training programs, upskilling, equal access to  
professional development.  
S1-5  
S1-6  
Fully met  
Fully met  
Equal  
opportunities  
and non-  
The report confirms the absence of discrimination in  
2024, the existence of fair treatment and inclusion  
policies in promotion and recruitment.  
discrimination  
The report mentions in Chap. 6.3 the existence of  
compliance policies applied to the suppliers, as well  
as the fact that all partners are local or EU, and  
therefore subject to the same legal obligations  
regarding decent work, safety conditions, non-  
discrimination and freedom of association. The  
summary compliance table confirms full coverage of  
the requirement.  
Working  
conditions in the Fully met  
value chain  
S2  
Chap. 5.3 of the sustainability report details the  
potential risks and impacts on local communities,  
with a focus on incident prevention through  
technologies (SCADA, maintenance), collaboration  
with ISU, no incidents in 2024 . Confirmation also in  
ESRS tables .  
Identifying  
impacts on  
communities  
S3-1  
S3-2  
Fully met  
Fully met  
The report outlines CSR initiatives in health,  
education and culture, following consultation with  
local authorities and NGOs. No conflicts or  
complaints are reported. The process of  
engagement is active but not formalized in  
documents.  
Community  
consultation  
and  
involvement  
It is mentioned in Chap. 5.3 measures to prevent  
social hazards (noise, public access, accidental  
pollution), contingency plans and no social incidents  
reported in 2024. The ESRS table confirms the  
absence of conflicts or disputes .  
Prevention and  
management of Fully met  
social risks  
S3-3  
S4-1  
Ch. 6.2 of the sustainability report mentions  
implementation of GDPR policies, cybersecurity and  
zero incidents in 2024. Data protection systems  
comply with European regulations. Confirmation in  
Compliance Table and ESRS Table .  
Privacy and  
Fully met  
data protection  
Although CONPET does not have B2C customers,  
the report (Chap. 6.2) shows that the operator  
provides relevant information to industrial partners  
(B2B) through reports, website and compliance with  
legal transparency requirements. The ESRS tables  
note partial but compliant applicability .  
Informing users  
(B2B  
transparency)  
S4-2  
Fully met  
164 I SUSTAINABILITY REPORT CONPET S.A.  
Annexes  
ESRS  
ESRS  
Status in  
2024  
Detailed explanations and sources  
Standard requirement  
Policies on  
ethics and  
professional  
conduct  
Chap. 6.2 describes the code of ethics, ISO 37001  
(anti-bribery) and ISO 9001 (quality) certifications,  
and management's formal commitment to integrity.  
Confirmation in ESRS tables .  
G1-1  
Fully met  
Fully met  
Chapters 6.2 and 6.3 confirm the ethical monitoring  
of suppliers and the integration of ESG requirements  
into procurement processes. The integrated table  
indicates that ethical evaluation is also applied in  
contractual relationships.  
Supplier  
relationship  
management  
G1-2  
Preventing  
corruption and Fully met  
bribery  
ISO 37001 implemented, annual training, detailed  
internal controls (Chap. 6.2). Summary table  
confirms 100% coverage by ethics training .  
G1-3  
G1-4  
Confirmed  
cases of  
corruption  
Ch. 6.2 (p. 107) explicitly states that there were no  
cases of corruption or ethical misconduct in 2024.  
Requirements G1-4 lit. b) are thus covered.  
Fully met  
The report mentions in Table 4.6 and in the  
Integrated ESRS that there is no lobbying or political  
applicable influence. In Romania these practices are not  
regulated for state-owned enterprises.  
Lobbying and  
political  
influence  
Not  
G1-5  
Payment  
practices and  
financial  
Ch. 6.3 confirms no outstanding payments in 2024.  
It highlights responsible financial behavior and stable  
relationships with suppliers .  
G1-6  
Fully met  
responsibility  
Chap. 6.1 details the structure of the Board of  
Directors (BoD), members, non-executives, term of  
office and ESG governance duties. Full confirmation  
in all ESRS tables .  
BoD structure  
and role in ESG Fully met  
oversight  
GOV-1  
GOV-2  
GOV-3  
GOV-4  
ESG CA  
competences  
and frequency met  
of reporting  
The report (Chaps. 6.1 and 6.3) confirms the  
involvement in ESG oversight, but does not explicitly  
mention the ESG competences or training of the AC  
members.  
Partially  
Integrating ESG  
The ESG has not yet been included in the  
management bonus system in 2024. However, it is  
planned to be integrated from 2025, according to  
Chap. 6.2 and the ESRS Table .  
into the  
incentive  
system  
Partially  
met  
Chap. 6.3 clearly describes the integration of dual  
materiality, ESG risk analysis, internal consultation  
process, with annual reporting to the BoD. Full  
confirmation in all tables .  
ESG due  
diligence and  
risk oversight  
Fully met  
ESG risk  
The risk management system includes ESG and is  
documented in Chap. 6.3. It is integrated with  
financial and operational risks. The tables confirm full  
compliance.  
management  
and internal  
controls  
GOV-5  
Fully met  
165 I SUSTAINABILITY REPORT CONPET S.A.  
Annexes  
ESRS reporting requirements covered by the sustainability statement table  
Standard  
Presentation requirements  
Page  
BP-1 - General basis for sustainability reporting  
6
BP-2 - Submissions of information related to specific  
circumstances  
6
GOV-1 - Role of administrative, management and supervisory  
bodies  
21  
GOV-2 - The information provided to the administrative,  
management and supervisory bodies of the enterprise and  
the sustainability issues they address  
58,107,  
118, 127  
GOV-3 - Integrating sustainability performance into incentive  
schemes  
106  
106  
127  
GOV-4 - Due Diligence Process Statement  
GOV-5 - Risk management and internal controls related to  
sustainability reporting  
13, 17,  
55, 91  
SBM-1 - Strategy, business model and value chain  
SBM-2 - Stakeholder interests and views  
ESRS 2  
55, 58  
SBM-3 - Significant impacts, risks and opportunities and their  
interaction with strategy and business model  
29, 31,  
134,155  
IRO-1 - Description of processes for identifying and  
assessing impacts, risks and opportunities  
significant  
27  
IRO-2 - ESRS reporting requirements covered by the  
enterprise sustainability report  
9, 27, 40  
56, 105  
MDR-P Policies - Policies adopted to manage significant  
sustainability issues  
MDR-AActions - Actions and resources on significant  
sustainability issues  
35,38, 86  
86, 142  
MDR-M - Indicators on significant sustainability issues  
MDR-T targets - Monitoring the effectiveness of policies and  
actions through targets  
151, 162  
GOV-3 - Integrating sustainability performance into incentive  
schemes  
ESRS E1  
106  
Climate  
change  
43, 53,  
54, 161  
E1-1: Transition plan for climate change mitigation  
166 I SUSTAINABILITY REPORT CONPET S.A.  
Annexes  
Standard  
Presentation requirements  
Page  
SBM-3 - Significant impacts, risks and opportunities and their  
interaction with strategy and business model  
29, 31,  
134,155  
IRO-1 - Description of processes for identifying and  
assessing impacts, risks and opportunities  
significant  
27,43,  
156  
E1-2: Policies related to climate change mitigation and  
adaptation  
59  
E1-3: Actions and resources related to climate change  
policies  
86, 87  
E1-4: Climate change mitigation and adaptation targets  
E1-5: Energy consumption and energy mix  
66  
65  
E1-6: Gross emissions of GHG categories 1, 2, 3 and total  
GHG emissions  
60, 65  
E1-7: GHG removals and mitigation projects financed by  
carbon credits  
65  
65  
E1-8: Setting the internal carbon price  
IRO-1 - Description of processes for identifying and  
assessing impacts, risks and opportunities  
significant  
27,43,  
156  
E2-1: Pollution-related policies  
67  
ESRS E2  
Pollution  
E2-2: Pollution-related actions and resources  
E2-3: Pollution targets  
71  
70  
68  
E2-4: Air, water and soil pollution  
E2-5: Substances of concern and substances of very high  
concern  
69  
IRO-1 - Description of the processes for identifying and  
assessment of significant impacts, risks and opportunities  
27,43,  
156  
ESRS E3  
E3-1: Policies related to water and marine resources  
76  
78  
Water and  
marine  
resources  
E3-2: Actions and resources related to water and marine  
resources  
E3-3: Water and marine resources targets  
E3-4: Water consumption  
44, 79  
77  
167 I SUSTAINABILITY REPORT CONPET S.A.  
Annexes  
Standard  
Presentation requirements  
Page  
E4-1: Transition plan and consideration of biodiversity and  
ecosystems in the strategy and business model  
43, 53,  
54, 161  
SBM-3 Significant impacts, risks and opportunities and their  
interaction with strategy and business model  
29, 31,  
134,155  
ESRS E4  
Biodiversity  
and  
ecosystems  
IRO-1 - Description of the processes for identifying and  
assessment of significant impacts, risks and opportunities  
40,45,  
156  
E4-2: Policies related to biodiversity and ecosystems  
80  
81  
80  
80  
E4-3: Actions and resources related to biodiversity and  
ecosystems  
E4-4: Biodiversity and ecosystems targets  
E4-5: Impact indicators related to biodiversity and ecosystem  
change  
IRO-1 - Description of the processes for identifying and  
assessment of significant impacts, risks and opportunities  
27,43,  
156  
ESRS E5  
E5-1: Resource use and circular economy policies  
83  
Resource  
use and  
circular  
E5-2: Actions and resources related to resource use and  
circular economy  
84  
economy  
E5-3: Resource use and circular economy targets  
84,161  
E5-4: Resource inputs  
85  
85  
E5-5: Resource outflows  
SBM-2 Interests and views of stakeholders  
55, 58  
ESRS S1  
SBM-3 Significant impacts, risks and opportunities and their  
interaction with strategy and business model  
29, 31,  
134,155  
Own  
workforce  
S1-1: Own workforce policies  
41, 46  
168 I SUSTAINABILITY REPORT CONPET S.A.  
Annexes  
Standard  
Presentation requirements  
Page  
S1-2: Processes for engaging with own workforce and  
workers' representatives on impacts  
45, 102  
S1-3: Processes to remedy negative impacts and channels  
through which own workforce can voice concerns  
46  
46  
S1-4: Taking action on significant impacts on own workforce  
and approaches for managing significant risks and pursuing  
significant opportunities related to own workforce, and the  
effectiveness of these actions  
S1-5: Targets related to managing significant negative  
impacts, promoting positive impacts and managing significant 38, 145  
risks and opportunities  
S1-6: Characteristics of enterprise employees  
94  
S1-7: Characteristics of self-employed workers in the  
enterprise's own workforce  
n/a  
93, 100,  
102  
S1-8: Coverage of collective bargaining and social dialog  
S1-9: Diversity indicators  
S1-10: Adequate wages  
S1-11: Social Protection  
S1-12: People with disabilities  
94, 97  
97  
97  
93  
S1-13: Training and skills development indicators  
S1-14: Health and safety indicators  
99, 162  
53, 97,  
140  
S1-15: Work-life balance indicators  
99  
S1-16: Remuneration indicators (pay gap and total  
remuneration)  
106, 114  
S1-17: Incidents, complaints and serious human rights  
problems and incidents  
125  
SBM-2 Stakeholder interests and views  
55, 58  
ESRS S2  
SBM-3 Significant impacts, risks and opportunities and their  
interaction with strategy and business model  
29, 31,  
134,155  
Value chain  
workers  
S2-1: Policies on value chain workers  
125, 126  
169 I SUSTAINABILITY REPORT CONPET S.A.  
Annexes  
Standard  
Presentation requirements  
Page  
S2-2: Collaborative processes with value chain workers on  
impacts  
125, 126  
S2-3: Processes for addressing negative impacts and  
channels through which value chain workers can voice their  
concerns  
125, 126  
125, 126  
S2-4: Taking action on significant impacts on value chain  
workers and approaches for managing significant risks and  
pursuing significant opportunities related to value chain  
workers, and the effectiveness of these actions  
S2-5: Targets related to managing significant negative  
impacts, promoting positive impacts and managing significant 125, 126  
risks and opportunities  
SBM-2 Interests and views of stakeholders  
55, 58  
SBM-3 Significant impacts, risks and opportunities and their  
interaction with strategy and business model  
29, 31,  
134,155  
S3-1: Policies related to affected communities  
101,102  
101,102  
S3-2: Collaborative processes with affected communities on  
impacts  
ESRS S3  
S3-3: Processes to remedy negative impacts and channels  
through which affected communities can voice their concerns  
Affected  
communities  
101,102  
101,102  
S3-4: Taking action on significant impacts on affected  
communities and approaches for managing significant risks  
and pursuing significant opportunities related to affected  
communities, and the effectiveness of these actions  
S3-5: Targets related to managing significant negative  
impacts, promoting positive impacts and managing significant 101,102  
risks and opportunities  
SBM-2 Interests and views of stakeholders  
55, 58  
ESRS S4  
SBM-3 Significant impacts, risks and opportunities and their  
interaction with strategy and business model  
29, 31,  
134,155  
Consumers  
and end-  
users  
S4-1: Consumer and end-user policies  
n/a  
n/a  
S4-2: Collaborative processes with consumers and end-users  
on impacts  
170 I SUSTAINABILITY REPORT CONPET S.A.  
Annexes  
Standard  
Presentation requirements  
Page  
S4-3: Processes for remedying negative impacts and  
channels through which consumers and end-users can voice  
their concerns  
n/a  
S4-4: Adoption of measures on significant impacts on  
consumers and end-users and approaches for managing  
significant risks and tracking significant opportunities related  
to consumers and end-users, and the effectiveness of these  
measures  
n/a  
S4-5: Targets related to managing significant negative  
impacts, promoting positive impacts and managing significant  
risks and opportunities  
n/a  
GOV-1 Role of administrative, management and  
management and supervisory  
106- 117  
108, 127  
IRO-1 - Description of the processes for identifying and  
assessment of significant impacts, risks and opportunities  
ESRS G1  
G1-1: Policies on professional conduct and corporate culture 118, 124  
Professional  
conduct  
G1-2: Supplier relationship management  
114, 125  
115  
G1-3: Prevention and detection of corruption and bribery  
G1-4: Incidents of corruption or bribery  
121, 148  
G1-5: Political influence and lobbying  
G1-6: Payment practices  
148  
148  
171 I SUSTAINABILITY REPORT CONPET S.A.  
Annex 2  
Transactions concluded according to Article 52 of GEO no. 109/2011 in 2024 H2  
Established  
guarantee in -  
RON-  
Crt.  
no.  
Method of payment  
Payment term  
Contract no.  
Date  
Partner  
Contract Scope  
Value RON  
Penalties  
1
2
2024/BCF 241  
2024/CCA 136  
26-NOV-24  
10-JUL-24  
CNCF C.F.R. S.A.  
Exploitation of industrial lines Salonta  
Supervision of works “pipeline replacement  
Constanța - C1 8 sections"  
574.529,38  
4.470,2  
Not applicable  
30 days from the invoice receipt  
5 days from the issuance date  
0.03%/ day  
0.1%/ day  
TELECOMUNICAȚII C.F.R. S.A.  
Not applicable  
3
12.413,75  
Not applicable  
0.05%/ day  
0.1%/ day  
2024/CCA 144  
17-JUL-24  
CNCF C.F.R. S.A.  
Works supervision services  
30 days from the issuance date  
4
5
6.600,00  
5.160,59  
Not applicable  
Not applicable  
2024/CCA 191  
2024/EN 146  
16-SEP-24  
18-JUL-24  
PĂULEȘTI CITYHALL  
9sqm rental in Păulești commune  
Siliște water supply  
30 days from the issuance date  
30 days from the invoice receipt  
ARGES-VEDEA BASIN WATER ADMINISTRATION  
0.01%/ day  
Level of interest  
6
7
2024/EN 161  
2024/EN 165  
05-AUG-24  
08-AUG-24  
Bacău Regional Water Company S.A  
Water supply Moinesti warehouse  
Water supply fixed point C4  
12.300,00  
rates  
Not applicable 15 days from the invoice issuance due for not paying budget  
obligations in due time  
Level of interest  
Not applicable 15 days from the invoice issuance due for not paying budget  
obligations in due time  
RAJA S.A.  
The importance of theoretical professional  
training and practical service training in railway  
activities during 02.12.2024 - 06.12.2024 for 3  
learners at C.C.I.P.T.F. Bucharest  
8
1.314,00  
Not applicable  
Not applicable  
0.03%/ day  
2024/MRU 216  
2024/MRU 220  
2024/P-CA 289  
17-OCT-24  
23-OCT-24  
23-DEC-24  
CENAFER  
30 days from the invoice receipt  
30 days from the invoice receipt  
Vocational training 3 learners 28.10.2024 -  
16.05.2025  
9
CENAFER  
12.468,60  
0.03%/ day  
0.1%/ day  
30 days from the date of invoice  
issuance  
10  
18.017.517,18 Not applicable  
S.P.E.E.H. HIDROELECTRICA S.A.  
“SFÂNTUL VASILE” SECONDARY SCHOOL  
Electricity Supply  
11  
12  
13  
2024/RPS 203  
2024/RPS 204  
2024/RPS 212  
24-SEP-24  
24-SEP-24  
11-OCT-24  
Sponsorship  
Sponsorship  
25.000,00  
22.000,00  
5.300,00  
Not applicable  
Not applicable  
Not applicable  
up to 23.10.2024  
up to 23.10.2025  
Not applicable  
Not applicable  
Not applicable  
“ION LUCA CARAGIALE” NATIONAL COLLEGE, PLOIESTI  
MUNICIPALITY  
Participation in the event Top of Prahova  
companies  
CHAMBER OF COMMERCE AND INDUSTRY  
5 days from the issuance date  
BUCHAREST INTERNATIONAL THEORETICAL HIGH SCHOOL  
OF INFORMATICS  
Sponsorship of the theoretical high school of  
computer science  
14  
15  
16  
17  
15.000,00  
50.000,00  
7.000,00  
Not applicable  
Not applicable  
Not applicable  
Not applicable  
Not applicable  
Not applicable  
Not applicable  
2024/RPS 232  
2024/RPS 267  
2024/RPS 270  
2024/RPS 271  
15-NOV-24  
18-DEC-24  
18-DEC-24  
up to 09.12.2024  
up to 31.12.2024  
up to 24.12.2024  
Modernization of IT infrastructure for the benefit  
of patients and employees  
FLOREȘTI PNEUMOPHTHYSIOLOGY HOSPITAL  
MORENI CITYHALL  
Packages for carolers  
10.000,00  
18.000,00  
rates  
Not applicable  
10%-1800 RON  
500 RON  
18-DEC-24  
21-AUG-24  
19-JUL-24  
FLORESTI CITYHALL  
National Company POȘTA ROMÂNĂ S.A.  
ROMANIAN CAR REGISTRY  
Packages for carolers  
up to 24.12.2024  
Domestic and international postal and express  
courier services  
Franchise for periodic technical inspections  
R.A.R.  
0.3% from the value of the  
shipment's transport  
18 2024/S-CA-CD 173  
19  
2024/STA 147  
30 days from the issuance date  
up to the 25th of every month  
Not applicable  
Annex 3  
Objectives and financial and non-financial key performance indicators for Directors with mandate contracts achieved between 01.01.2024-31.12.2024  
KPIs weights  
(Period 01.01.2024- 31.12.2024)  
Degree of  
for the  
Degree of  
Crt.  
no.  
Performance indicators  
Performance objective  
MU  
achievement settlement of achievement  
Achieved  
values  
KPIs (%)  
the  
KPIs (%)  
Target values  
remuneration  
A. FINANCIAL KEY PERFORMANCE INDICATORS: 50%  
Achievement of at least 70% of the  
annual investment plan  
≥70%  
≥1  
1. Achievements of the investments  
2. The quick ratio indicator (acid test)  
%
82.9%  
2.0  
118.4%  
100.0%  
10.0%  
5.0%  
11.8%  
5.0%  
Ensuring the ability to pay current  
liabilities from current assets adjusted  
with the value of the inventories  
Maintaining the collection of receivables  
from customers within a maximum period  
of 30 days  
≤30  
3. Inventories turnover speed  
days  
%
28  
100.0%  
5.0%  
5.0%  
Maintaining the profitability of operating  
activities at a minimum of 7.5%  
≥7.0%  
4. Operating profit margin  
5. Outstanding payments  
9.3%  
0
132.8%  
100.0%  
5.0%  
5.0%  
6.6%  
5.0%  
thousand  
RON  
Level zero  
0
Adjusted EBITDA = Operating profit – Write-back  
to revenues of the reserve out of the  
Achieving planned adjusted EBITDA  
minimum 95%  
modernization quota + Expenses regarding the  
modernization quota +Impairments of tangible and  
intangible assets, here included the revaluation  
differences  
≥95%  
6.  
%
103.7%  
437  
109.2%  
101.8%  
10.0%  
10.0%  
10.9%  
10.2%  
Achievement of the labor productivity  
level provided in the annual approved  
Budget  
thousand  
RON/  
person  
429  
7. Labor Productivity  
B. NON- FINANCIAL KEY PERFORMANCE INDICATORS: 50%  
B1. OPERATIONAL KEY PERFORMANCE INDICATORS: 20%  
Maintenance of the annual electricity  
average specific technological  
consumption at a level of max 3.2 Kwh/to  
Monitoring the annual electricity average specific  
consumption for technological purposes  
8.  
Kwh/to  
Max 3.3 Kwh/to  
3.2  
2.7  
100.0%  
5.0%  
5.0%  
Page of 1  
KPIs weights  
for the  
achievement settlement of achievement  
(Period 01.01.2024- 31.12.2024)  
Target values  
Degree of  
Degree of  
Crt.  
no.  
Performance indicators  
Performance objective  
MU  
Achieved  
values  
KPIs (%)  
the  
KPIs (%)  
remuneration  
Domestic crude oil ≤ 0.361%  
Achieved = 0.354%  
Framing within the specific consumptions for the  
crude oil transport (does not include the crude oil The target value lower than the value of  
9. quantity lost during provoked breakdowns or in the maximal technological consumption,  
Lukoil imported crude oil ≤  
0.290% Achieved 0.200%  
%
%
0.285%  
0.247%  
100.0%  
5.0%  
5.0%  
Petrom imported crude oil ≤ 0.143  
Achieved 0.137%  
case of breakage resulting in contamination, where for crude oil  
the owners do not ease access for remedy) .  
Midia imported crude oil ≤ 0.108%  
Achieved 0.000%  
Achieving at least 90% of the Annual  
Program of planned technical revisions  
10. Ensuring the NTS maintenance  
≥90 %  
≥5 ore  
90.0%  
5.0  
100.0%  
15.9  
100.0%  
100.0%  
5.0%  
5.0%  
5.0%  
5.0%  
Average number of training hours per employee  
11. (Total number of training hours/ Total number of  
employees  
Development of professional abilities and  
competencies  
hours/  
employee  
B2 CORPORATE GOVERNANCE KEY PERFORMANCE INDICATORS: 25%  
Development of the management control  
Implementation of the actions set out in the  
12. Program for the development of the internal control  
management system  
system implemented in compliance with  
the legal requirements in force  
%
≥90 %  
90.0%  
90.0%  
100.0%  
100.0%  
10.0%  
5.0%  
10.0%  
5.0%  
Number of measures from the Integrity Plan in  
13. force duly implemented/ Total number of due  
measures from the Integrity Plan in force x100  
Boost institutional integrity by inclusion of  
the measures to mitigate corruption  
%
≥90 %  
100.0%  
25  
100.0%  
Minimum 2 meetings/month (in  
correlation with the term of office)  
14. Number of meetings of the Steering Committee  
15. Female management rate  
no./month  
%
min.2 meetings/month  
24  
100.0%  
100.0%  
5.0%  
5.0%  
5.0%  
5.0%  
Maintaining the rate of female managers  
at least 30%  
≥30 %  
30.0%  
32.0%  
B3.KEY PERFORMANCE INDICATORS ORIENTED TOWARDS PUBLIC SERVICES: 5%  
Satisfaction of the customers from the  
crude oil and derivatives transport activity  
(Number of replies of 4 and 5 scoring in  
total number of customer replies at least.  
90% *)  
Customers satisfaction score from the crude oil  
and derivatives transport business (Number of  
replies of 4 and 5 scoring in total number of  
customer replies)  
16.  
%
≥90 %  
90.0%  
100.0%  
100.0%  
5.0%  
5.0%  
Total degree of achievement of the performance indicators  
104.5%  
Page of 2  
Annex 4  
REPORT  
on the internal management control system on 31 December 2024  
As per the provisions of Art. 4 Para. (3) of Government Ordinance No.  
119/1999 concerning the internal management control and preventive financial  
audit, republished with subsequent amendments and additions, the undersigned  
Tudora Dorin, in capacity of DIRECTOR GENERAL, declare that the company  
CONPET SA Ploiești has an internal management control system whose design and  
implementation allow the Board of Directors and the executive management to  
provide a reasonable assurance that the funds managed for the purpose of  
achieving the general and specific objectives have been used in conditions of  
legality, regularity, effectiveness, efficiency and economy.  
This declaration is based on a realistic, accurate, complete and reliable  
assessment on the entity’s internal management control system, formulated based  
on the self-evaluation thereof.  
The internal management control system includes self-auditing mechanisms,  
and the application of measures to increase its effectiveness is based on risk  
assessment.  
In this case, I mention the following:  
-
-
The monitoring commission is functional;  
The internal management control system development program is  
implemented and updated annually;  
-
-
The risk management process is organized and monitored;  
Documented procedures are developed for 100% of the total procedural  
activities regularly inventoried, according to the CONPET SA Activities List  
in force;  
-
The performance monitoring system is established and evaluated for the  
objectives and activities of the entity, through performance indicators.  
Based on the results of the self-assessment, I assess that on 31 December,  
2024 the internal management control system of CONPET SA Ploiești complies with  
the standards contained in the Internal Management Control Code.  
I hereby mention that the statements contained in this report are formulated  
by assuming managerial responsibility and are based on the data, information and  
findings recorded in the documentation related to the self-assessment of the  
internal management control system.  
Analyzed and endorsed by the Monitoring Committee of the internal  
management control system on 28.01.2025.  
Annex no. 5  
List of the procurement contracts concluded by the company in 2024 (with values higher than 100,000 RON)  
Crt.  
no.  
Value of the contract  
(RON, VAT excluded)  
Contract Scope  
Partner  
Contract number  
Contract Date  
Execution of works to replace collectors and valves in Constanta South station - Oil Terminal  
1 2024/L-CA 187  
September 9, 2024  
December 23, 2024  
TALPAC S.R.L.  
Warehouse  
18,341,024.09  
2 2024/P-CA 289  
SPEEH HIDROELECTRICA S.A.  
18,017,517.18  
Electricity Procurement  
Technical project update and execution of building rehabilitation works for Headquarters II CONPET  
S.A., No. 8, Rezervoarelor street (Building C4 - Workshop Building Ground Floor + Annexes, Building C5  
- Car Service Ground Floor + Annexes, Building C10 - Water Management, Building C11 - Water Tank),  
external networks and vertical systematization  
3 2024/L-CA 188  
September 9, 2024  
TERRA GAZ CONSTRUCT S.R.L.  
17,657,259.59  
4 2024/P-CA 88  
5 2024/P-CA 264  
April 29, 2024  
December 17, 2024  
OMV PETROM MARKETING  
CRAYON SOFTWARE EXPERTS ROMANIA S.R.L.  
5,867,900.00  
5,693,695.80  
Supply of 60,000 liters of gas and 910,000 liters of diesel  
Microsoft Enterprise Agreement Renewal Licenses  
6 2024/L-CA 128  
June 25, 2024  
ERICSSON TELECOMMUNICATION ROMANIA SRL.  
REVA S.A.  
4,275,269.51  
Modernization of the microwaves radio relays system within CONPET S.A. Communication system  
Planned RP-FIR type repairs (without container intervention, with full painting) on 38 Zaes wagons of 60  
cubic meters for crude oil transport and 3 Zagkks wagons of 80 cubic meters with replacement of 108  
axes  
7 2024/S-CA 30  
March 12, 2024  
3,191,769.94  
8 2024/L-CA 93  
9 2024/P-CA 217  
May 14, 2024  
GAZPET INSTAL S.R.L.  
ROMFLEX SISTEM SRL.  
Execution of safety works for 12 and 14 pipelines Cartojani-Ploiesti at crossing Cricovul Dulce creek  
Supply of computing systems, laptop type  
2,931,334.24  
2,074,859.00  
October 18, 2024  
Subsequent contract to the AC S-CA 152/2023 concerning services and works related to the  
restoration of the geological environment and polluted water courses as a result of the breakdowns  
occurred along the crude oil, rich gas and ethane transport pipeline routes or in the technological  
precincts of CONPET S.A. Ploiești, taking over of the soil contaminated with crude oil (waste code  
191301*), as well as the taking over of the soil and stones with content of hazardous substances  
(waste code 170503*).. Starting 13.11.2024, duration 1 year  
10 2024/S-CA 210  
October 09, 2024  
ENVIROTECH S.R.L.  
2,048,872.67  
11 2024/L-CA 130  
12 2024/S-CA 280  
13 2024/L-CA 75  
14 2024/S-CA 27  
15 2024/S-CA 287  
16 2024/L-CA 259  
17 2024/S-CA 169  
18 2024/S-CA 279  
19 2024/S-CA 50  
June 27, 2024  
December 20, 2024  
April 23, 2024  
INDUSTRIAL COMPUTER GROUP SRL.  
REMARUL 16 FEBRUARIE S.A.  
CONFIND S.R.L.  
ASITO KAPITAL SA  
RELOC S.A.  
1,680,100.00  
1,588,000.00  
1,498,998.59  
1,404,857.20  
1,300,000.00  
1,299,600.00  
1,232,952.00  
1,218,818.00  
1,043,771.08  
Modernization of the microwaves radio relays system within CONPET S.A. Communication system  
Planned repair type RG to the locomotive 1250 LDH HP traffic no. 92530810803-2  
Modernization of the crude oil pumping station Slobozia, Prahova county  
Voluntary health insurance services for CONPET SA employees  
Planned repair type RG to the locomotive 1250 LDH HP traffic no. 92530810834-7  
Design and execution of restoration works of cathodic protection systems of tanks R1, R2, R4 of the  
Electronic telecommunication services  
March 05, 2024  
December 23, 2024  
December 11, 2024  
August 12, 2024  
December 20, 2024  
March 28, 2024  
LIDER GLENCER SRL.  
ORANGE ROMANIA COMMUNICATIONS S.A.  
LOC. SERV. REP. S.R.L.  
SERVICE FAUR SRL.  
Planned repair type RG to the locomotive 1250 LDH HP traffic no. 92530810789-3  
RR planned repair to locomotive 1250 LDH HP no. 92530810790-1  
Rental services of 15 tank cars suitable and authorized for transport of hydrocarbon gases in liquefied  
mixture, NSA (C mixture)  
20 2024/S-CA 24  
February 29, 2024  
AUTOGAS IMPEX SRL.  
1,040,250.00  
Execution of manual and mechanized excavation works necessary for the implementation of preventive  
archaeological research in 6 (six) sites within the localities of Constanța, Cumpăna, Valul lui Traian  
21 2024/L-CA-CD 61  
April 10, 2024  
TALPAC S.R.L.  
801,805.48  
Rehabilitation of fences and construction of new fences at four work points belonging to Conpet S.A.,  
respectively, Danube Crossing Work Point - C2; Borcea Arm Crossing Work Point - C3; Borcea Arm  
Crossing Work Point - C4; Mircea Voda Station  
22 2024/L-CA 176  
August 27, 2024  
August 9, 2024  
RUXO SERVICE CONSTRUCT.  
721,830.75  
598,000.00  
23 2024/L-CA-CD 168  
WOMA ECOSERV CONSTRUCT S.R.L.  
Design and execution of works to modernize the metering system at Gate 3 Petrobrazi  
24 2024/BCF 241  
25 2024/S-CA 288  
November 26, 2024  
December 23, 2024  
CNCF CFR S.A.  
573,913.08  
549,966.90  
Exploitation of Salonta industrial lines  
ROMÂNIA EUROEST S.A.  
Planned repair type RR to the LEA locomotive traffic no. 97530490010-6  
26 2024/P-CA 89  
April 29, 2024  
DARIUS MOTORS SRL.  
SWISO ELECTRIC SRL.  
Supply of 3 (three) vehicles, van type, for transporting people and goods  
493,500.00  
449,313.28  
Rehabilitation of booster tank lighting at Constanța Sud station, Constanța-Bărăganu sector by  
replacing the lighting fixtures with LED lamps  
27 2024/L-CA-CD 243  
November 29, 2024  
Maintenance, repair and replacement services for components of technical security systems installed  
at the Central Dispatch Headquarters, Administrative Headquarters 2, Headquarters 3, Independentei  
Blvd, Inotești Materials Depot, Voința Sports Base, Bărăganu, Călăreți, Orlești, Poiana Lacului, Siliște,  
Icoana, Cartojani Stations, Bărbătești Ramp, Bărbătești Depot, Constanța-Bărăganu District  
Headquarters and Constanța Sud Station.  
28 2024/S-CA 87  
April 26, 2024  
M&M COMPUTERS S.R.L.  
371,240.00  
Purchase of land within the city for construction yards - area of 4,820 sq m and industrial railway -  
length 383 m, according to notarial deed no. 1903/29.11.2024  
29 2024/ BC 252  
December 09, 2024  
August 21, 2024  
OMV PETROM S.A.  
STRAL BIG SRL.  
350,000.00  
349,199.46  
Execution of energy rehabilitation works of the envelope and roof, anti-corrosion rehabilitation of the  
structure, replacement of carpentry and rehabilitation of the external walkway at the PSI pumps  
Independența Buffer Warehouse  
30 2024/L-CA-CD 174  
31 2024/S-CA 107  
32 2024/S-CA 22  
May 23, 2024  
INTERGRAPH COMPUTER SERVICES S.R.L.  
LOC. SERV. REP. S.R.L.  
327,478.00  
317,080.00  
GIS software product maintenance and support and development services  
Performing planned RT, R1, R2, 2R2 type overhauls and managing maintenance on 450,700,1250-HP  
diesel hydraulic locomotives and remediation of accidental defects LDH - Batch 1  
February 27, 2024  
Vehicle liability insurance services R.C.A. for damages caused to third parties through accidents, for  
vehicles belonging to CONPET S.A.  
33 2024/S-CA 247  
December 06, 2024  
OMNIASIG VIENNA INSURANCE GROUP SA  
307,104.28  
Design services to achieve the objective: new cylindrical, vertical tank, capacity 1,000 cubic  
meters,Orlesti Automated Crude Oil Station  
34 2024/S-CA 248  
35 2024/S-CA 249  
December 09, 2024  
December 09, 2024  
ELLIS 92 SRL.  
ELLIS 92 SRL.  
300,000.00  
300,000.00  
Design of a new cylindrical tank 2500 cubic meters Poiana Lacului  
Services for developing site analysis, support studies, design and execution for an electricity  
production system with photovoltaic panels within the premises of the Constanța Sud Automated Oil  
Station - CONPET S.A. Ploiești  
36 2024/L-CA-CD 171  
August 19, 2024  
ELS.A.CO SOLUTIONS S.R.L.  
270,000.00  
Services for developing site analysis, support studies, design and execution for an electricity  
production system with photovoltaic panels within the premises of the Calareti Automated crude oil  
station - CONPET S.A. Ploiești  
37 2024/L-CA-CD 172  
38 2024/ BC 290  
August 19, 2024  
ELS.A.CO SOLUTIONS S.R.L.  
DACIAN PETROLEUM S.R.L.  
270,000.00  
262,500.00  
December 24, 2024  
Equipment rental from the P904 Urziceni warehouse  
Optional insurance services against accidental damage and theft (CASCO type) for vehicles,  
equipment and installations belonging to CONPET S.A.  
Design and execution of construction works for a drilled well for technological water for underground  
water supply at the Constanța Sud Automated Station  
Design services for crude oil tank V=1500 m3 Pumping station Videle above-ground tank, with geodesic  
dome and floating membrane  
39 2024/S-CA 258  
December 11, 2024  
May 16, 2024  
ASIGURAREA ROMANEASCA-ASIROM SA  
ELCAS PRODIMPEX SRL.  
ELLIS 92 SRL.  
256,897.47  
250,000.00  
244,000.00  
40 2024/L-CA-CD 96  
41 2024/S-CA - CD 68  
April 17, 2024  
42 2024/P-CA 286  
43 2024/P-CA 90  
December 20, 2024  
April 29, 2024  
LA FANTANA SRL.  
Supply of bottled water in 19 l cans  
225,360.00  
219,495.00  
DARIUS MOTORS SRL.  
Supply of a Van type Utility vehicle  
44 2024/P-CA 274  
45 2024/S-CA 260  
December 18, 2024  
October 18, 2024  
INNOVATIVE TEX SOLUTIONS S.R.L.  
SNIF PROIECT S.A.  
216,269.10  
210,000.00  
Supply of boots (duration 3 years)  
Design of 4 sections of the 10 3/4 L1 and L2 Țicleni-Ploiesti crude oil pipelines in the Orlești-Scaioși-  
Sludge cleaning services for the R2 crude oil storage tank within the Călăreți crude oil pumping station,  
Călărași county, with all operations related to cleaning, transportation of the resulting sludge and  
environmentally safe recovery/disposal  
46 2024/S-CA 127  
June 25, 2024  
OIL DEPOL SERVICE S.R.L.  
202,923.00  
47 2024/P-CA 215  
48 2024/P-CA 215  
49 2024/S-CA 137  
October 17, 2024  
October 17, 2024  
July 10, 2024  
MIDA SOFT BUSINESS SRL.  
MAGUAY COMPUTERS S.R.L.  
METRO ACTIV S.R.L  
195,100.00  
195,100.00  
188,490.00  
Framework Agreement for the Supply of Spare Parts and Peripherals  
Framework Agreement for the Supply of Spare Parts and Peripherals  
Calibration of CONPET owned tanks  
50 2024/CCA 185  
September 03, 2024  
SOCIETATEA AGRICOLA VIILE NOI  
Land lease in surface of 18,241 sq.m.  
184,241.00  
51 2024/S-CA 242  
November 25, 2024  
December 20, 2024  
DARIUS MOTORS SRL.  
Maintenance services for Volkswagen type vehicles  
180,000.00  
170,000.00  
52 2024/S-CA - CD 285  
ASIGURAREA ROMANEASCA-ASIROM SA  
Insurance contract BoD members  
Supply:  
53 2024/P-CA 31  
March 12, 2024  
QUANTUM PROTECT S.R.L.  
167,688.00  
- Seals required for sealing tank cars transporting crude oil and rich gas from the loading ramps  
- Seals for sealing valves on pipelines and measuring and control devices  
Verification, maintenance, loading and repair of the extinguishers existing in the worksites belonging to  
CONPET SA PLOIEȘTI  
Design services for the replacement of crude oil pipeline 6 Urlați-Ploiești, DN 1A Moara Nouă-  
Corlătești area (DJ 139 Ploiești-Buzău DN 1A railway line within the LUKOIL Refinery)  
Carrying out planned inspections type RT, R1, R2, accidental repairs and managing maintenance on  
electric locomotive type LE 310 KW-BAT - RC with no. 975304910002-2  
Purchase of hygiene and sanitary materials - 100 grams of antimicrobial solid soap  
54 2024/S-CA 5  
January 17, 2024  
GEFIL S.R.L.  
165,938.00  
149,000.00  
55 2024/S-CA 192  
September 17, 2024  
IAT ENGINEERING & DESIGN SRL.  
56 2024/S-CA 139  
57 2024/P-CA 238  
July 12, 2024  
RELOC S.A.  
148,184.00  
144,900.00  
November 21, 2024  
TURKROM S.A.  
Design, supply, installation and commissioning of technical/electronic security systems at the  
CONPET S.A. Ploieşti facility - Salonta crude oil depot and loading ramp  
58 2024/L-CA-CD 283  
November 01, 2024  
HELION S.A.  
139,994.00  
Design services for objective achievement: Replacement of a section of the crude oil pipeline 10  
Icoana-Cartojani, Poiana Lacului Siliştea District  
59 2024/S-CA 225  
60 2024/S-CA 65  
October 25, 2024  
April 16, 2024  
SNIF PROIECT S.A.  
120,000.00  
120,000.00  
120,000.00  
SERVICE AUTO SERUS SRL.  
TDP PARTNER S.R.L.  
Maintenance for Dacia vehicles  
Consulting services and technical assistance in the development of the 2024 Sustainability Report of  
CONPET S.A.  
61 2024/S-CA - CD 257  
December 10, 2024  
Sludge cleaning services R4, R5, Cartojani decanter within the Cartojani Crude Oil Pumping Station,  
Giurgiu county, with all operations related to cleaning, transportation of the resulting sludge and  
environmentally safe recovery/disposal  
62 2024/S-CA 177  
August 27, 2024  
OIL DEPOL SERVICE S.R.L.  
115,956.00  
REGIA NATIONALĂ A PĂDURILOR-ROMSILVA/  
NATIONAL FORESTRY DIRECTORATE-ROMSILVA  
Temporary occupancy area of 0,3557 ha for achieving the objective "safe disposal of 12" and 14”  
pipelines Cartojani-Ploiesti, crossing Cricov Dulce brook”  
63 2024/CCA 122  
June 7, 2024  
103,504.76  
101,000.00  
Design, supply, installation and commissioning of technical/electronic security systems at CONPET  
S.A. Ploieşti crude oil pumping station, located in Mircea Vodă commune, Constanța county  
64 2024/L-CA-CD 281  
December 20, 2024  
M&M COMPUTERS S.R.L.  
STELBO TRANS S.R.L.  
65 2024/ADM 11  
January 26, 2024  
Drainage services Bărbăteşti and Țicleni  
100,000.00  
Important revenues contracts concluded in 2024 (over 100,000 RON)  
Crt.  
No.  
Value of the contract  
Contract number  
Contract Date  
Partner  
Contract Scope  
(RON, VAT excluded)  
419,331,838.00  
88,809,474.00  
142,935.00  
1 2020/BC OMV 108  
March 23, 2020  
December 18, 2024  
October 22, 2024  
May 29, 2024  
OMV PETROM S.A.  
PETROTEL LUKOIL S.A.  
REVA S.A.  
Crude oil, rich gas and ethane transport  
2 2024/BC LUK 273  
3 2024/ADM 218  
4 2024/CD- d 115  
Petrotel Lukoil crude oil transport services  
Sale of ferrous metal waste resulting from the replacement of broken-down axles on rail tank cars  
Sale of buried pipe  
RUXO SERVICE CONSTRUCT S.R.L.  
110,008.20  
Annex no. 6  
List of litigations pending before Courts in which the company CONPET S.A.  
is a Party on 14.03.2025  
a) The list of litigations pending before Courts on 14.03.2025 in which the company  
CONPET S.A. has the status of claimant  
1. File no. 19024/281/2009 - Ploiești Courthouse  
Parties: Conpet S.A. - claimant  
Compania de Transport Feroviar S.A. - Defendant  
Subject matter: Conpet filed a lawsuit requesting the defendant to pay the amount of 50,511.6  
RON representing the difference in payment from the value of the repair of the engine of the LDH  
70-675 locomotive in the amount of 60,381.60 RON, as well as the legal expenses.  
Clarifications: By the Conclusion of 02.09.2011, the court suspended the case pursuant to art.  
36 of Law 85/2006.  
Procedural status of the case: Merits - Suspended  
The file no. 31627/3/2011 is pending before the Bucharest Court, having as its subject matter the  
insolvency procedure of the debtor Compania de Transport Feroviar S.A. through Judicial  
Administrator Pro Management Insolv I.P.U.R.L. Bucharest. As a creditor, Conpet is listed on the  
final list of creditors with the requested unsecured debt in the amount of 52,769.02 RON which,  
broken down, consists of: RON 50,511.6 in compensation and 2,257.42 RON representing the  
judicial stamp duty paid by Conpet in the claim file no. 19024/281/2009 of the Ploiești Courthouse.  
The case has a trial date of 16.05.2025.  
Deadline: --  
2. File no. 3033/105/2012 - Prahova Court  
Parties: Conpet SA - creditor  
Vasrep Petro Construct SRL - debtor  
Subject matter: Bankruptcy. By the Sentence no. 238/03.03.2014 the Prahova Court ordered  
the entry in the bankruptcy procedure of the debtor Vasrep Petro Construct SRL, the sealing of  
the assets from the debtor's fortune and the fulfillment of the other liquidation operations.  
Conpet SA formulates a request for admission of the claim requesting the registration on the list  
of creditors Vasrep Petro Construct SRL with the amount of RON 126,877, including VAT,  
representing the value of material costs, costs for workmanship and equipment necessary for  
bringing the pipeline to the state before the unlawful act was committed by the debtor, deed  
consisting in the unlawful destruction and theft of two sections of 4,120 ml in length from the  
pipeline Ø 10¾" Iancu Jianu - Ghercești. Conpet appeals against the measure of non-registration  
of Conpet SA on the Preliminary List with this claim, which is the subject matter of file no.  
3033/105/2012/a1. By the Sentence no. 1958/19.11.2012, the Prahova Court dismissed Conpet's  
appeal. Conpet appealed again. Ploiești Court of Appeal allowed the appeal, quashed the  
sentence on the merits and sent it for retrial.  
By the sentence no. 1008/17.09.2014 (file no. 3033/105/2012/a1*) the Prahova Court admits the  
appeal to the preliminary title. It orders the registration of the appellant creditor Conpet S.A. in the  
consolidated list of creditors of the debtor with the amount of RON 1,473,628 the value of  
materials, workmanship and equipment as well as RON 120 judicial stamp duty appeal and RON  
2500 expert fee. Vasrep appealed.  
By decision no. 141 / 15.01.2015 The Ploiești Court of Appeal rejects the appeal as unfounded.  
Conpet is registered in the consolidated list of creditors of the debtor Vasrep Petro Construct  
S.R.L. with an unsecured debt in the amount of RON 1,476,308.  
By the Decision of 24.10.2023, the Prahova Court suspends the trial of the case, until the  
irrevocable resolution of the associated file no. 3033/105/2012/a2 of the Prahova Court. With the  
right of appeal for the entire duration of the suspension.  
Procedural status of the case: Merits - suspended  
Deadline: --  
3. File no. 2803/120/2013 - Ploiesti Court of Appeal  
Parties: Conpet S.A. - creditor  
Ecprod S.R.L. - debtor  
Subject matter: Insolvency. General procedure  
Request for credit admission. Conpet S.A. filed a request for admission of claim on the assets  
of the Ecprod debtor in the amount of RON 25,728.89. Conpet is registered on the List of Creditors  
with the amount of RON 25,728.89. The percentage of the Conpet claim is 0.16% of the total  
claims entered on the table.  
Clarifications: --  
Procedural status of the case: Merits  
Deadline: 07.05.2025  
4. File no. 1862/114/2014 - Buzău Court  
Parties: Conpet SA - creditor  
Geluval Stor SRL - debtor  
Subject matter: By the Sentence no. 621/26.10.2016, the Buzău Court orders the entry into the  
general bankruptcy procedure of the debtor, the sealing of all the assets from the debtor's  
property, their inventory and the fulfillment of the other liquidation operations. Conpet SA  
formulates a request for admission of the claim requesting the registration on the list of creditors  
of Geluval Stor SRL with the amount of RON 1,440.90, representing delay penalties due for  
payment over the term provided in the contract for a value of 7 invoices issued by Conpet for  
services provided in under Contract no. STA 101/20.03.2012 concluded with the defendant,  
amount to which the debtor was obliged by the sentence no. 8867/16.06.2014 given by the Ploiești  
Courthouse in the file no. 109/281/21014, remained final by non-appeal.  
Conpet is registered in the consolidated list of creditors in the bankruptcy procedure for the debtor  
Geluval Stor S.R.L. with an unsecured debt in the amount of RON 1,440.90.  
Procedural status of the case: Merits  
Deadline: 08.04.2025  
5. File no. 1510/262/2014 - Moreni Courthouse  
Parties: Conpet SA - claimant  
Pîrvu Gheorghe - defendant  
Pîrvu Nicolae - defendant  
Grigorescu Gabriel - defendant  
Zlăteanu Dragoș Marian - defendant  
Dărmănești Commune, legally represented by the Mayor of Dărmănești Commune -  
defendant  
Nimb Dâmbovița SA - defendant  
Subject matter: Conpet filed a lawsuit requesting the court to order the defendants, jointly and  
severally, to pay to Conpet the amount of RON 34,944.18 as civil damages - representing the  
equivalent of remedial works of the Link 14 fiber optic pipeline and cable, destroyed on  
03.06.2011, within the commune of Dărmănești, Dâmbovița county, works necessary to bring  
them to the initial state before committing the deed, i.e. in working order, amount to which is added  
the interest from the date on which the sentence in the present case becomes final and until the  
date of actual payment; payment of the legal expenses.  
Clarifications: By the Conclusion of 08.01.2015, the Moreni Courthouse suspends the trial of  
the case in relation to the defendant Nimb Dambovita SA. It dismisses the case regarding the  
other defendants and the formation of a new file (184/262/2015 - finalized by obliging the  
defendants Pârvu Gheorghe, Pârvu Nicolae, Grigorescu Gabriel and Zlăteanu Dragoș Marian to  
pay to Conpet the amount of RON 34,944.18 and the related interests of this amount, starting  
with the date of finality of the Sentence no. 97 / 04.02.2016 and until the date of actual payment.  
The decision was executed and is the subject of the file No. 30/2018 – Bailiff’s Office Petrov  
Sergiu Alexandru).  
Note: By the Conclusion of 14.12.2012 - file no. 9446/120/2012 - the Dâmbovița Court ordered  
the opening of the general insolvency procedure against the debtor Nimb Dâmbovița SA. By the  
Sentence no. 611 / 09.10.2014 The Dâmbovița Court orders the opening of the general procedure  
of judicial reorganization and the confirmation of the reorganization plan. The reorganization  
procedure is ongoing.  
By the Conclusion of 22.06.2017 pronounced in the file no. 1510/262/2014 the Moreni  
Courthouse, finding that the law applicable to the insolvency proceedings of the defendant Nimb  
mbovița SA is Law no. 85/2006 and that the suspension will last until the closing of the  
insolvency procedure pronounced by the syndic judge based on art. 11 para. 1 letter n of Law no.  
85/2006, maintains the suspension of the trial of the case ordered by the Conclusion of  
08.01.2015.  
Procedural status of the case: Merits - Suspended  
Deadline: --  
6. File no. 6819/118/2013 - Constanța Court  
Parties: Conpet SA - creditor  
Tobias SRL - debtor  
Subject matter: Bankruptcy. Conpet S.A. requested the registration on the list of creditors of  
the debtor with the amount of RON 663 representing the equivalent value of 230 kg of aluminum  
(RON 575) and 110 kg of scrap metal (RON 88), handed over to Tobias SRL on 04.06.2013,  
based on the contract of sale - purchase of waste no. 2013 / ADM / 15.02.2013 concluded  
between Conpet and Tobias.  
The request formulated by Conpet was admitted in part by the judicial administrator, in the sense  
that our company was registered on the list of creditors with the amount of RON 643.11, the  
difference of RON 19.89 representing the 3% environmental fund and due to the Environmental  
Fund Administration. The percentage of the Conpet receivable is 0.014% of the total of  
receivables entered in the list.  
Procedural status of the case: Merits  
Deadline: 21.05.2025  
7. File no. 13386/3/2015 - Bucharest Court  
Parties: Conpet SA - creditor  
Perfect Metal SRL - debtor  
Subject matter: Bankruptcy. Conpet S.A. requested the registration on the list of creditors of the  
debtor with the amount of RON 221,189.85 representing penalties for delay, compensations,  
interest and legal expenses.  
The request was accepted but Conpet was entered on the list in the category of unsecured  
creditors and not in the category of secured creditors as would have been the case considering  
the content of our request for registration in the preliminary list of creditors. Conpet filed an appeal  
against the preliminary list of creditors, which was the subject matter of the file no. 13386/3/201/a1  
with a deadline on 18.09.2015. By the Decision no. 7106 / 18.09.2015 The Bucharest Court  
rejects the appeal as unfounded. The percentage of the Conpet receivable is 0.42625 of the total  
receivables entered on the list.  
Procedural status of the case: Merits  
Deadline: 11.04.2025  
8. File no. 19602/3/2015 - Bucharest Court  
Parties: Conpet SA - creditor  
Top Birotica SRL - debtor  
Subject matter: Bankruptcy. Conpet S.A. requested the registration on the list of creditors of  
the debtor with the amount of RON 2,258.72 representing delay penalties due for the delayed  
delivery of the equipment that was the object of the contract P-CA 438 / 17.11.2014.  
Conpet was registered at the debtor's list of creditors with the amount of RON 2,258.72.  
The percentage of the Conpet receivable is 0.010% of the total receivables entered on the list.  
Clarifications: By the Decision of 14.12.2022, the Bucharest Court rejects the request of the  
judicial liquidator for the sale of the assets remaining in the debtor Top Birotica SRL's patrimony,  
by public auction, according to the Code of Civil Procedure.  
Procedural status of the case: Merits  
Deadline: 09.04.2025  
9. File no. 2899/62/2015 - Brașov Court  
Parties: Conpet SA - creditor  
Condmag SA - debtor  
Subject matter: Bankruptcy. Request for admission of the Conpet claim against the property of  
the debtor Condmag SA RON 42,950.85 representing penalties.  
Conpet was registered on the list of creditors with the amount of RON 42,2950.85 representing  
an unsecured debt. The percentage of the Conpet receivable is 0.02% of the total receivables  
entered on the list.  
Procedural status of the case: Merits  
Deadline: 25.03.2025  
10. File no. 8156/281/2014 * - Ploiești Court of Appeal  
On appeal: file no. 447/42/2020  
Parties: Conpet SA - civil party  
Matei Marinel - claimant for judicial review  
Subject matter: Grand larceny. Revision. Matei Marinel formulates a request for revision of the  
criminal decision no. 1383 / 14.10.2013 pronounced by the Ploiești Court of Appeal in the file no.  
19230/281/2011.  
Note: By the Criminal Decision no. 1383 / 14.10.2013 Ioniță Ion, Marin Matei Georgian and Matei  
Marinel were obliged to pay to Conpet an amount of RON 13,259.79. The decision was enforced  
and is the subject of file no. 200/2016 located at the Bailiff’s Office Petrov Sergiu Alexandru.  
Clarifications: By Sentence no. 1162 / 03.08.2020 The Ploiești Courthouse admits the request  
for revision formulated by the claimant for judicial review Matei Marinel, against the criminal  
sentence no. 1286 / 07.06.2013 of the Ploieşti Courthouse, abolished and finalized by the criminal  
decision no. 1383 / 14.10.2013 of the Ploieşti Court of Appeal. It cancels the Criminal Sentence  
no. 1286 / 07.06.2013 of the Ploieşti Courthouse, as well as M.E.P.I. no. 1538/2013 of 10/15/2013  
issued by the Ploiești Courthouse. It orders the acquittal of the defendant Matei Marinel, under  
the aspect of committing the crime of grand larceny, provided by art. 208 para. (1) - art. 209 para.  
(1) letters a) and g) para. (3) letter a) Previous Criminal Code, with the application of art. 41 para.  
(2) of the Criminal Code. It finds that the defendant Matei Marinel was detained from 22.11.2013  
to 12.11.2014, inclusive. The decision was appealed by the Prosecutor's Office attached to the  
Ploiești Courthouse.  
By Decision no. 954 / 26.10.2020 The Ploiești Court of Appeal admits the appeal declared by  
the Prosecutor's Office attached to the Ploiești Courthouse against the criminal sentence no. 1162  
of August 3, 2020 pronounced by the Ploieşti Courthouse, which it annuls in its entirety and sends  
the case for retrial to the first instance according to the considerations of the present decision.  
Final.  
By the Sentence no. 799/13.05.2022 the Ploiești Courthouse admits the revision request. It  
annuls the Criminal Sentence no. 1286/07.06.2013 of the Ploieşti Courthouse, final by the  
Criminal Decision no. 1383/14.10.2013 of the Ploieşti Court of Appeal. It orders the acquittal of  
the defendant Matei Marinel, under the aspect of committing the crime of grand larceny. The  
decision was appealed.  
Procedural status of the case: Appeal  
Deadline: Ruling postponed to 14.03.2025  
11. File no. 8262/281/2016 - Ploiești Courthouse  
Parties: Conpet SA - creditor  
Conpet Club Football Association - debtor  
Subject matter: Dissolution of a legal entity. Request for admission of the claim. Conpet SA  
formulates a request for admission of the claim on the property of the debtor Conpet Club Football  
Association, against which the dissolution was ordered by the Civil Sentence no. 8683 /  
04.10.2016 pronounced by the Ploiești Courthouse in the file no. 8262/281/2016, by which it  
requests the court to admit the application for registration on the list of creditors of the debtor  
Conpet Club Football Association with the amount of RON 424.94, as a certain, liquid and due  
receivable, born before the admission of the dissolution application, representing the penalties  
payment rest, according to the invoice no. 1653 / 31.05.2015, calculated for the late payment of  
the obligations arising from the Lease Agreement no. ADM 366 / 23.10.2012, concluded by  
Conpet SA with the Conpet Club Football Association. By the address 39101 / 28.09.2017 Conpet  
requested the completion of the value of the debt registered by the Conpet Club Football  
Association and with the amount of RON 1,358.84 representing delay penalties born prior to the  
dissolution request (total RON 1,783.78). By the addresses no. 14907/20.04.2018, no.  
43508/09.11.2018 and no. 6473/17.02.2020 Conpet requested the liquidator to communicate the  
steps taken to recover the amount of RON 1,783.78. In 2021, by the addresses no.  
14399/27.04.2021 and no. 31732/15.09.2021 Conpet requested the Liquidator to inform us if  
there are assets in the association's patrimony and what are the prospects for the recovery of the  
debt or the completion of the dissolution and liquidation procedure of the Conpet Football Club  
Association.  
Procedural status of the case: Merits  
12. File no. 789/105/2017 - Prahova Court  
Parties: I.C.I.M. S.A. by C.I.T.R. Bucharest administrator - debtor  
Conpet S.A.- creditor  
Subject matter: Insolvency proceedings. Conpet requests the registration on the list of creditors  
of the company ICIM SA represented by judicial administrator C.I.T.R. BUCHAREST  
SUBSIDIARY S.P.R.L., with the total receivable in the amount of RON 393,934.37 representing  
delay penalties, legal expenses, execution costs.  
A) RON 50,094, 8 representing the equivalent value of the works for repairing the damage to the  
pipeline Ø 6 RA Moreni-Ploiești and the lost crude oil, legal interest, legal expenses and execution  
costs established by the enforceable title - Civil Sentence no. 1014 / 28.01.2015 pronounced in  
the file no. 113/281/2014 remained final and corrected by the Conclusion of correction of the  
material error on 06.06.2016, by which the Ploiești Courthouse admitted the request for summons  
filed by the claimant Conpet S.A.  
B) RON 343,839.57 composed of the amount of RON 331,271.57 representing penalties for delay  
in accordance with the provisions of art. 8.1. from the contract 0135/1995 (modified by art. 5 of  
the additional act 9/2005 and the additional act no. 10/2006), as well as the amount of RON  
12,568 representing judicial stamp duty, judicial stamp and expertise fee.  
Conpet was entered on the list with the requested amount.  
The percentage of the Conpet receivable is 0.75 & of the total receivables entered on the list.  
I.C.I.M. filed an appeal which is the subject of the file no. 789/105/2017 / a1 and requested:  
- mainly a partial amendment of the preliminary list of creditors in connection with the rejection of  
the application for entry of the claim in the amount made by Conpet  
- in the alternative, a partial amendment of the preliminary list of creditors for the purpose of  
entering the conditional Conpet claim.  
The appeal of I.C.I.M. was the subject matter of the file 789/105/2017 / a1. By the Decision  
776/2018, the Prahova Court rejects the appeal regarding the preliminary list formulated by the  
debtor Intreprinderea Construcţii Instalaţii Montaje SA regarding the claim of the creditor CONPET  
SA  
By the Conclusion of 11.09.2020, the Prahova Court ordered the entry into the bankruptcy  
procedure of the debtor.  
Procedural status of the case: Merits  
Deadline: 04.06.2025  
13. File no. 8727/105/2017 - Prahova Court  
Parties: Conpet SA - claimant  
Paulus S.R.L. - Defendant  
Subject: Bankruptcy - general procedure  
Subject matter: On 14.10.2019, Conpet filed a payment request with the judicial administrator  
CITR Bucharest Subsidiary SPRL (art. 75 * paragraph 3 of Law no. 85/2014) for the payment of  
the amount of RON 32,493.44, amount due on 04.07.2019 by Paulus SRL (CF 4000500), for not  
fulfilling the obligations established by the contract no. S-CA 1191 / 05.07.2017 (air conditioning  
maintenance). The request was granted.  
Clarifications: Paulus S.R.L. filed an appeal against the measure of the judicial administrator  
file 8727/105/2017 / a13. In merits, the court rejected the appeal filed by Paulus S.R.L. The case  
was resolved by rejecting the appeal filed by Paulus S.R.L. by Decision 213/2020.  
Conpet addressed the insolvency practitioner for the recovery of the amount of RON 2,891.95  
from the performance guarantee, and to pay the difference of RON 29,601.49 with priority  
according to the law. On 09.06.2021, the amount of 2,891.95 was recovered from the  
performance guarantee. The difference of RON 29,601.49 was not paid.  
By the Interim Decision 163/24.03.2022, the Prahova Court orders the entry into bankruptcy of  
the debtor in the general procedure. It appoints a provisional judicial liquidator to the initially  
appointed insolvency practitioner, EUROSMART Prahova Subsidiary, who will fulfill the duties  
provided by art. 64 of the law. It orders the dissolution of the debtor company and the lifting of the  
debtor's right of administration. CONPET requested the registration on the additional table of  
creditors with the amount of RON 29,601.49 representing late penalties owed by PAULUS S.R.L.  
for non-fulfillment of the obligations resulting from the contract no. S-CA 1191(489)/07/05/2017  
having as its subject matter "maintenance services for air conditioners in all workplaces belonging  
to CONPET S.A.". The claim was accepted, the amount of RON 29,601.49 being entered in the  
definitive consolidated list of creditors at item 13, table published in B.P.I. no. 11975/14.07.2022.  
The bankruptcy procedure is currently ongoing.  
Procedural status of the case: Merits  
Deadline: 02.04.2025  
14. File no. 2036/83/2019 - Satu Mare Court  
Parties: Conpet SA - claimant  
PRODREP MG S.R.L. - Defendant  
Subject: bankruptcy  
Subject matter: On 18.11.2019, Conpet filed an application for registration on the list of creditors  
of the debtor PRODREP MG S.R.L. with the amount of RON 284,496.11 representing:  
- damages in the amount of RON 148,926.49 provided in art. 18.2 of the works contract L-CA 699  
of 28.09.2017 (20% of the contract value provided in art. 3 of the contract);  
- penalties of 0.5% / day of delay provided by art. 17.1 of the works contract L-CA 699 of  
28.09.2017 applied to the value of the unexecuted works in the amount of RON 46,575 for a  
number of 162 days of delay calculated from 10.04.2019 to 19.09.2019 the date of termination of  
the contract;  
- equivalent value for electricity supply in the amount of RON 16.54 for the period 01.08.2019-  
31.08.2019, resulting from the execution of the works contract L-CA 699 of 28.09.2017;  
- penalties of 0.5% / day of delay in the amount of RON 78,644.16 provided by art. 17.1 of the  
works contract L-CA 537 of 27.07.2017 applied to the value of unexecuted works for a number of  
168 days of delay calculated from 01.05.2019 to 15.10.2019 the date of opening the insolvency  
procedure;  
- penalties of 0.5% / day of delay in the amount of RON 10,333.92 provided by art. 17.1 of the  
works contract L-CA 380 of 05.10.2016 applied to the value of the unexecuted works for a number  
of 114 days of delay calculated from the date set for the completion of the works until their actual  
completion. The claim has been accepted.  
Conpet filed an application for registration on the supplementary list and for the amount of RON  
18,724.8, representing the current receivable born after the date of opening the insolvency  
procedure. Since the opening of the bankruptcy procedure and registration with the list of  
creditors with the previously shown amounts, CONPET has also recorded debits from the non-  
execution by PRODREP MG S.R.L. of ongoing works in the amount of RON 79,403.37.  
Currently, CONPET is listed on the final consolidated list with the following amounts: RON  
284,496.11 and RON 98,138.68 (7th rank on the list published in B.P.I. no. 16899/19.10.2022).  
Clarifications: At the deadline on 20.10.2020, the court admitted the request of the judicial  
administrator and pursuant to art. 145 paragraph 1 point A letter c and point B of Law no. 85/2014  
ordered the beginning of the bankruptcy procedure in the general form of the debtor PRODREP  
MG S.R.L. - SC 339 / F / 20.10.2020 B.P.I. 18101 / 28.10.2020.  
Procedural status of the case: Merits  
Deadline: 29.04.2025  
15. File no. 6143/2/2020* - Bucharest Court of Appeal  
Parties: Conpet SA - claimant  
The Insured Guarantee Fund defendant  
Subject matter: Conpet appealed against Decision no. 24238 / 25.09.2020 issued by the Insured  
Guarantee Fund by which the payment requests no. 79167, 79166, 79163, 81691, 81687, 81698,  
82691, 82690, 88271, 88728 and 89684 were rejected.  
Clarifications: CONPET S.A. formulated payment requests for the refund of amounts related to  
policies concluded with the Insurance-Reinsurance Company ASTRA S.A. during the years 2009-  
2015, but by decision no. 24238 / 25.09.2020 which is the subject matter of the appeal, the Insured  
Guarantee Fund did not refer to the requests made by CONPET S.A. for the refund of the amounts  
due. The payment requests no. 79167, 79166, 79163, 81691, 81687, 81698, 82691, 82690,  
88271, 88728 and 89684 specified in the decision are not related to any documents issued by our  
company.  
By Sentence no. 1051/30.06.2021 The Bucharest Court of Appeal admits the request. It annuls  
the decision no. 24238/25.09.2020 issued by the Insured Guarantee Fund. It obliges the  
defendant to issue an administrative act admitting the request for payment made by the claimant  
for the amount of RON 36,430.13. The Insured Guarantee Fund appealed.  
By the Decision no. 523/31.01.2024 The High Court of Cassation and Justice admits the appeal  
declared by the Insurance Guarantee Fund. It dismisses the contested sentence and sends the  
case for retrial to the same court. Final.  
Procedural status of the case: Appeal - retrial  
Deadline: 28.04.2025  
16. File no. 25520/212/2020 - Constanța Courthouse  
Parties: Conpet SA - claimant  
Safir Gabriela - defendant  
Subject matter: Conpet formulates a request for summons of the defendant SAFIR GABRIELA  
domiciled in Ovidiu locality, 101 Poporului street (or 82 A), Constanța county so that by the  
decision you will pronounce to order the establishment of the share due to each co-owner on the  
building located in Ovidiu locality, Poporului street no. 82 A, Constanța county, building located in  
the joint property (joint ownership) of our debtor Safir Marius (execution file 51 / 2019- Bailiff’s  
Office Menaef Cristian) and of the defendant Safir Gabriela.  
Clarifications: By the Conclusion of 13.01.2021, the Constanța Courthouse annuls the request  
for summons citing that it did not submit the land book extract regarding the building within 10  
days.  
Against the conclusion, Conpet filed a request for re-examination through which we demonstrated  
that the building construction jointly owned by the defendant Safir Gabriela and our debtor Safir  
Marius is not registered, the joint ownership right not being registered in the land book. Conpet,  
having knowledge of the existence of the property right in the patrimony of the defendant and the  
debtor from the primacy relations from the Ovidiu City Hall. At the same time, we demonstrated  
the court of justice that only the exclusive ownership right of the debtor over the land is registered  
in the land book and we have attached an extract from the land book for the land, as well as all  
the steps taken by Conpet and the Bailiff’s Office Menaef Cristian.  
By the Decision no. 5783/21.04.2021 disposed in file 25520/212/2020/a1, the Constanța  
Courthouse admitted the request for re-examination made by Conpet and orders the re-sending  
of the file to panel C31 for the continuation of the procedure.  
By the Conclusion of 11.01.2022, the Constanta Courthouse, based on art. 413 para. (1) pt. 1 of  
the Code of Civil Procedure, suspends the trial of the present action until the final settlement of  
the file no. 27269/212/2021, pending before the Constanţa Courthouse. On 29.10.2024 the file is  
pending again.  
By the Sentence no. 13846/14.11.2024 the Constanța Courthouse admits the request for  
summons. It finds that the defendants acquired during the marriage, under the legal community  
regime, the right of ownership over the property located in the town of Ovidiu, *** Street, Constanța  
county, consisting of: land with an area of 138 sq.m. from documents (156 sq.m. from  
measurements) and building C1 G+1E dwelling, with a built-up area of 82 sq.m. and a built-up  
area of 167 sq.m., registered in the Land Book no. ***, old cadastral number: ***). It stops the  
state of discord between the defendants regarding the described property and finds that each of  
the defendants owns a 1/2 share of the property. With the right to file an appeal.  
Procedural status of the case: Merits  
Deadline: --  
17. File no. 1270/229/2021 - Fetesti Courthouse  
Parties: Conpet SA- Claimant  
Zacon Trandafir - Defendant  
Subject matter: Claims  
Clarifications: File disjointed from file no. 2782/229/2018.  
By the Conclusion of 22.04.2021, the Fetesti Courthouse ordered the suspension of the trial until  
the resolution of the merits case, from which the second head of the claim was disjointed. The  
case was reinstated on 03.10.2024.  
Procedural status of the case: Merits  
Deadline: 15.05.2025  
18. File no. 5081/105/2013 - Prahova Court  
Parties: Energopetrol SA through Judicial Administrator Andrei Ioan I.P.U.R.L. - respondent  
Conpet SA - appellant  
Subject matter: Insolvency  
Clarifications: Conpet S.A. filed an appeal against the measures of the administrator/judicial  
liquidator. The case was the subject matter of the file no. 5081/105/2013/a13.  
By the Decision 11 of 19.04.2022, the Prahova Court admits the appeal. It cancels the measure  
of the judicial administrator regarding the prescription of the right to request the payment of the  
amount of RON 7556.34. It finds that the amount of RON 7556.34 is included in the debtor's  
current debt statement in B.P.I. no. 4717/16.03.2022.  
Deadline: 07.05.2025  
19. File no. 11372/94/2022-Buftea Courthouse  
Parties: Conpet S.A. -claimant  
Peștişor Marius Sever-defendant  
Peștișor Elena Loredana-defendant  
Dobre Maria-defendant  
Subject matter: Conpet formulates a request to summon the defendants and for the opposition  
of the defendant Dobre Maria, requesting the court to order the determination of the share due to  
each co-owner of the building composed of a construction intended for "residential house" with a  
built area of 16.87 sq.m. and intra-village construction land with an area of 50.72 sq.m.  
Clarifications: By the Sentence no. 14334/20.12.2024, the Buftea Courthouse admits the  
request. It finds that the defendants Peștișor Marius Sever, Peștișor Elena Loredana acquired,  
during the marriage, with equal contribution shares, the real estate registered in the Land Book  
107275 Voluntari (old number 8426) composed of intra-village land with a built-up area of 50.72  
sq.m. and housing construction with a built-up area of 16.87 sq.m. and, identified with cadastral  
number 5445/2, real estate located in the city of Voluntari, Ilfov County. It finds that the defendants  
each hold a share of 1/2 of the bare ownership of the real estate in question registered in the  
Land Book 107275 Voluntari (old number 8426) consisting of intra-village construction land with  
an area of 50.72 sq.m. and housing construction with a built area of 16.87 sq.m. and, identified  
with cadastral number 5445/2, real estate located in the city of Voluntari, Ilfov county. It obliges  
the defendant Peștișor Marius Sever to pay the claimant the legal expenses in the amount of RON  
1,100, representing curator's fee and stamp duty. With the right of appeal after communication.  
Procedural status of the case: Merits  
Deadline: --  
20. File no. 11783/281/2022 Prahova Court  
Parties: Conpet claimant  
Trafotech S.R.L. defendant  
Subject matter: Claims. Conpet formulates a summons requesting the court, through the  
decision it will pronounce, to order the obligation of the defendant Trafotech S.R.L. upon payment  
to Conpet S.A. of the amount of RON 55,257, consisting of:  
- RON 35,697 representing late penalties calculated for the period 14.02.2021 27.04.2021  
inclusive, owed by the defendant in accordance with the provisions of art. 18.1 of the contract no.  
P-CA 391/15.12.2020,  
- RON 19,560, representing 20% of the contract value, due according to the art. 19.2 of the supply  
contract no. P-CA 391/15.12.2020, following the unilateral termination of the contract due to the  
fault of the defendant.  
Also, Conpet requests the obligation of the defendant Trafotech S.R.L. to pay the legal expenses  
that it will incur in this case.  
Clarifications: By the Civil Sentence of 27.10.2022, the Ploiești Courthouse admitted the action  
in part. It obliges Trafotech SRL to pay to Conpet SA the amount of RON 25,917, representing  
late payment penalties calculated for the period 14.02.2021 27.04.2021 inclusive according to  
the art. 18.1 of the supply contract no. P-CA 391 of 15.12.2020. It obliges Trafotech SRL to pay  
to Conpet SA the amount of RON 19,560 representing compensatory damages according to the  
art. 19.2 of the supply contract no. P-CA 391 of 15.12.2020. It rejects the rest of the action, as  
unfounded. It obliges Trafotech S.R.L. to pay to Conpet S.A. the amount of RON 1,969 as legal  
expenses, representing the stamp duty. The decision was appealed by Trafotech SRL.  
Procedural status of the case: Appeal  
Deadline: Ruling postponed to 17.03.2025  
21. File no. 2854/105/2022 Prahova Court  
Parties: Conpet SA claimant  
Eurosting AAW Industry S.R.L. defendant  
Subject matter: Obligation of the defendant Eurosting AAW Industry SRL. upon payment to  
CONPET S.A. of the total amount of RON 747,937.80 consisting of the amount of RON 83,640  
representing damages in the amount of 20% due according to the art. 19.2 of the works contract  
no. L-CA 252/06.08.2019 and the amount of RON 664,297.80 representing late payment  
penalties calculated until 29.04.2021, owed by the defendant in accordance with the provisions  
of the art. 18.1 of the works contract no. L-CA 252/06.08.2019, for the non-execution of the  
obligations assumed by the contract. Obligation to pay legal expenses.  
Clarifications: By the Conclusion of 26.01.2023 the Prahova Court admits the request for  
suspension of the trial of the case made by the defendant and it disposed the suspension of the  
case until the final settlement of File no. 4372/105/2022 pending before the Prahova Court. With  
the right of appeal throughout the suspension.  
Procedural status of the case: Merits - suspended  
Deadline: --  
22. File no. 17365/281/2022 Ploiesti Courthouse  
Parties: Conpet SA claimant  
Eurosting AAW Industry S.R.L. defendant  
Subject matter: Obligation of the defendant Eurosting AAW Industry S.R.L. upon payment to  
Conpet S.A. of the total amount of RON 69,141.30 consisting of the amount of RON 24,949.98  
representing damages in the amount of 20% due according to the art. 18.2 of works contract no.  
L-CA 366 of 16.11.2020 and the amount of RON 44,191.32 representing late payment penalties  
calculated until 06.08.2021, owed by the defendant in accordance with the provisions of the art.  
17.1 of the works contract no. L-CA 366 of 16.11.2020, for the non-execution of the obligations  
assumed by the contract. Obligation to pay legal expenses.  
Clarifications: By the Decision no. 2083/30.03.2023 the Ploiești Courthouse admits the motion  
to dismiss for lack of jurisdiction of the Ploiești Courthouse, invoked ex officio. It declines the  
jurisdiction to resolve the request in favor of the Prahova Court.  
By the Decision no. 177/02.11.2023 The Prahova Court admitted the exception of lack of  
jurisdiction and declined the jurisdiction to resolve the case with the subject matter of claims in  
favor of the Ploiesti Courthouse. The negative conflict of jurisdiction between the Prahova Court  
and the Ploieşti Courthouse is evident. It suspends ex officio the judgment of the case and  
immediately sends the file to the Ploiesti Court of Appeal, in order to resolve the negative conflict  
of jurisdiction.  
By the Sentence no. 45 CC of 06.12.2023, pronounced in the file 1221/42/2023, the Ploiești  
Court of Appeal establishes the jurisdiction to solve the action in favor of Ploiești Courthouse.  
Deadline: 06.05.2025  
23. File no. 23320/281/2022 Prahova Court  
Parties: Conpet SA claimant  
Ministry of Agriculture and Rural Development - defendant  
Ialomița County Directorate for Agriculture - defendant  
National Agency for Land Registry and Real Estate Advertising - defendant  
Subject matter: Jointly and severally obliging the defendants to pay to CONPET S.A. of the  
amount of RON 81,176.8 representing the amount paid as a guarantee.  
The total amount of 81,176.8 was paid as a guarantee in October 2016 and August 2017 in order  
to temporarily remove the 22,586 square meter land area from agricultural use (category of arable  
use). Investment objective "Replacement of crude oil pipeline Ø 10¾'' Ghercești - Icoana -  
Cartojani on the sections: SPC Bârla, Bârla commune, Argeș County approx. 850 m, agricultural  
lands Bârla Mirosi, Arges County, approx. 2,400 m and agricultural land in Negreni – Clanița  
village, Teleorman County, approx. 1,500 m, total 4,750 m"  
Clarifications: By the Sentence 4650/08.09.2023 the Ploiești Courthouse admits the plea of the  
lack of passive procedural status against the defendant A.N.C.P.I. It rejects the request made by  
the claimant CONPET S.A. against the defendant A.N.C.P.I as being brought against a person  
lacking passive procedural status. It rejects the summons filed by the claimant CONPET S.A.  
against the defendants, the Ministry of Agriculture and Rural Development, the Teleorman County  
Directorate for Agriculture, as unfounded.  
Conpet filed an appeal.  
By the Decision no. 327/21.02.2025, the Prahova Court rejects the appeal as unfounded. With  
the right of appeal after communication.  
Procedural status of the case: Appeal  
Deadline: --  
24. File no. 331/90/2016 Vâlcea Court  
Parties: Conpet SA creditor  
REMAT Vâlcea SA - debtor  
Subject matter: Conpet submitted a request for admission of the claim and registration in the  
additional list of the creditor Remat Vâlcea SA with the amount of RON 4,538.61 (4,331.61 late  
payment penalties CON FA 6291/16.10.2017 + 200 RON legal expenses). Conpet was entered  
on the additional list of the debtor's creditors with the requested amount.  
Clarifications: --  
Deadline: 08.04.2025  
25. File no. 6722/281/2023 Ploiesti Courthouse  
Parties: CONPET S.A. - claimant  
Thermoficare Prahova S.A. and the Popescu Silviu Andrei Bailiff's Office - defendant  
Subject matter: CONPET filed an appeal against the enforcement documents drawn up by the  
Popescu Silviu Andrei Bailiff's Office in the enforcement file no. 263/2022, as follows: the  
conclusion pronounced on 08.12.2022 by the Ploiești Courthouse in the file no. 25160/281/2022  
by which the foreclosure was approved; the summons issued on 09.03.2023 for the payment of  
the amount of RON 7,003.40, the conclusion no. 1 issued on 09.03.2023 establishing the  
enforcement expenses in the amount of RON 1,259.51; the decision issued on 20.03.2023  
ordering the termination of foreclosure.  
The appeal requested the annulment of the decision pronounced on 08.12.2022 by the Ploiești  
Courthouse in the file no. 25160/281/2022 by which the foreclosure of all the documents issued  
by the Popescu Silviu Andrei Bailiff's Office in the enforcement file no. 263/2022, respectively of  
the Security Summons issued on 09.03.2022 for the payment of the amount of RON 7,003.40, of  
the conclusion no. 1 issued on 09.03.2023 establishing the enforcement expenses in the amount  
of RON 1,259.51 and the conclusion issued on 20.03.2023 ordering the termination of  
enforcement and the return of enforcement for the amount of RON 3,856.65 representing  
amounts additionally paid by CONPET S.A. following the transmission of the summons by the  
Popescu Silviu Andrei Bailiff's Office in the enforcement file no. 263/2022, composed of RON  
3,446.52 representing amounts invoiced in addition and not owed through the invoices put into  
execution as enforceable titles and RON 410.13 representing the difference in unpaid bailiff's  
fees.  
Clarifications: By the Decision of 20.10.2023, the Ploiești Courthouse suspends the trial of the  
challenge to foreclosure formulated by the appellant CONPET S.A. because the insolvency  
proceedings have been opened against the debtor Termoficare Prahova S.R.L. - file  
1653/105/2023 - Prahova Court. With the right of appeal for the entire duration of the suspension.  
Procedural status of the case: Merits - Suspended  
Deadline: --  
26. File no. 1310/116/2021 Calarasi Court  
Parties: CONPET S.A. - creditor  
Agroland Future S.R.L. - debtor  
Subject matter: Conpet filed a request for admission of the claim and registration in the list of  
creditors of Agroland Future S.R.L. with the amount of RON 8,831.15, as the debtor was obliged  
by the enforceable Civil Sentence no. 1058/20.12.2019 pronounced by the Lehliu-Gara  
Courthouse in the file no. 2149/249/2019, to which are added the legal expenses related to Law  
no. 85/2014 [RON 8,631.15 (RON 8,120.14 + RON 511.01) + RON 200= RON 8,831.15]. Conpet  
was entered on the final list of the debtor's creditors with the requested amount.  
Clarifications: --  
Procedural status of the case: Merits  
Deadline: 25.03.2025  
27. File no. 671/1285/2022 Cluj Specialised Court  
Parties: CONPET S.A. - creditor  
Tirrena Scavi SPA - debtor  
Subject matter: Secondary insolvency proceedings in the form of bankruptcy  
Conpet filed a claim admission request asking the court to register the company CONPET S.A.  
on the list of creditors of Tirrena Scavi SPA with the amount of RON 54,601.02 composed of:  
- the amount of RON 48,402.43 representing the counter value of the damage suffered by  
CONPET S.A. as a result of the damage caused by the debtor TIRRENA SCAVI SpA Cluj  
Branch on 04.04.2022 to the crude oil transport pipeline Ø 10¾" Ghercești – Icoana, Gârlești  
village area, Ghercești commune, Dolj county;  
- the amount of RON 5,998.59 representing the update of the counter value of the damage with  
the legal interest from the date of the act (04.04.2022) until the date of the opening of the  
procedure (07.03.2023);  
- RON 200 representing the judicial stamp duty related to this application for admission of the  
claim on the assets of the debtor Tirrena Scavi SPA.  
Clarifications: Conpet was entered in the preliminary List of creditors of the debtor Tirrena Scavi  
SpA (published in B.P.I. no. 7475/03.05.2023) with the amount requested RON 54,601.02  
(unsecured debt, art. 161 point 8 of the Insolvency Law, 0 .0735% of the category, 0.0027% of  
the total receivables, 0.0175% of the total with voting rights).  
Procedural status of the case: Merits  
Deadline: 27.05.2025  
28. File no. 8089/281/2023 - Ploiesti Courthouse  
Parties: CONPET S.A. - claimant  
Brent Oil CO SRL - defendant  
Subject matter: Conpet filed a request for admission to court requesting the defendant to be  
obliged to pay the amount of RON 19,536.52, composed of RON 9,802.93 representing  
equipment rental consideration and RON 9,733.59 representing penalties calculated according to  
the provisions of art. 11.1 of the service contract no. STA 363/17.10.2019.  
Clarifications: By the Sentence no. 7597/02.08.2024, the Ploiești Courthouse admits the  
request. It obliges the defendant to pay the claimant the amount of RON 9,802.93 representing  
the equipment rental value and RON 9,733.59 representing late payment penalties calculated  
according to art. 11.1 of the service contract no. STA 363/17.10.2019. With the right of appeal  
after communication.  
Procedural status of the case: Merits  
Deadline: --  
29. File no. 2365/105/2023 Prahova Court  
Parties: Conpet S.A. claimant  
Ministry of Agriculture and Rural Development - defendant  
Argeș County Directorate for Agriculture - defendant  
National Agency for Land Registry and Real Estate Advertising - defendant  
Subject matter: CONPET S.A. filed a summons requesting the joint and several obligation of the  
defendants to pay to CONPET S.A. of the amount of RON 204,386.72 representing the amount  
paid as a guarantee.  
Clarifications: By the Decision no. 710/19.06.2024, the Prahova Court admits the motion to  
dismiss for lack of jurisdiction. It declines the jurisdiction to resolve the case in favor of the Civil  
Section I of the Prahova Court. No appeal.  
By the Sentence no. 126/07.02.2025, the Prahova Court admits the exception of the lack of  
passive procedural status of the defendant, the National Agency for Land Registry and Real  
Estate Advertising, invoked by this defendant in its response. It rejects the request for summons  
filed by the claimant Conpet S.A., in contradiction with the defendant, the National Agency for  
Land Registry and Real Estate Advertising Prahova, as being filed against a person without  
passive procedural status. It rejects the request for summons filed by the claimant Conpet S.A.,  
in contradiction with the defendants Ministry of Agriculture and Rural Development and Argeș  
County Directorate for Agriculture, as unfounded. With appeal after communication.  
Procedural status of the case: Merits  
Deadline: --  
30. File no. 17532/281/2023 Prahova Court  
Parties: Conpet SA claimant  
Eurosting AAW Industry S.R.L. defendant  
Subject matter: Obliging the defendant Eurosting AAW Industry S.R.L. to pay Conpet S.A. of the  
total amount of RON 56,444.93 representing late penalties calculated until 04.11.2022 owed by  
the defendant in accordance with the provisions of art. 17.1(1) of works contract no. L-CA  
27/13.02.2020 for not executing the works on time.  
Clarifications: --.  
Deadline: 24.04.2025  
31. File no. 6573/202/2023 Calarasi Courthouse  
Parties: Conpet petitioner  
The prosecutor's office attached to the Călărași Courthouse - respondent  
Subject matter: Conpet filed a complaint against the Dismissal Ordinance ordered on 29.06.2023  
by the Prosecutor's Office attached to the Călărași Courthouse in the file no. 645/P/2015,  
regarding the criminal offence of grand larceny requesting the abolition of the Dismissal  
Ordinance, the continuation of the criminal prosecution and investigations in order to identify the  
criminals and hold them criminally liable for the theft, between 27.02.2015 and 02.03.2015, of the  
cables that served the cathodic protection terminals on the import crude oil transport pipelines  
from the area of Jegălia neighborhood, Perisoru locality, Călărași county, as well as in order to  
recover the damage caused to our company (RON 10,355.51).  
Clarifications: --  
Deadline: 25.03.2025  
32. File no. 1653/105/2023 Prahova Court  
Parties: Conpet SA claimant  
Termoficare Prahova - defendant  
Subject matter: Bankruptcy. Application for admission of the claim in the amount of RON 4,206.6  
and its entry on the list of creditors of the debtor Termoficare Prahova S.R.L. The claim in the  
amount of RON 4,206.6 is composed of: RON 3,446.52 amounts invoiced in addition by  
Termoficare Prahova S.R.L. and not owed by Conpet through the invoices executed as  
enforceable titles in the enforcement file no. 263/2022 pending before the Bailiff’s Office Popescu  
Silviu Andrei; RON 410.13 representing the unpaid bailiff's fee difference; RON 324.96 - stamp  
duty paid in the file 6722/281/2023; RON 24.99 - counter value for photocopying the enforcement  
file for the court (file no. 6722/281/2023). Conpet filed an appeal against the preliminary list - File  
no. 1653/105/2023/a2 - By the Decision no. 742/20.06.2024, the Prahova Court rejects the  
request for extension of time formulated by the appellant as unfounded. It admits the exception  
of lateness invoked by the debtor through the judicial administrator. It rejects the appeal, as late  
formulated.  
Conpet filed an appeal.  
Clarifications: --  
Deadline: 11.09.2025  
33. File no. 238/42/2021* - Prahova Court  
Parties: Conpet SA - claimant  
Ministry of Agriculture and Rural Development - defendant  
Ialomița County Directorate for Agriculture - defendant  
National Agency for Land Registry and Real Estate Advertising - defendant  
Subject matter: Obligation of the defendants to pay Conpet S.A. of the amount of RON 238,300  
representing the amount paid by Conpet S.A. and undue. The amount was paid in April 2017 for  
the removal from the agricultural circuit of a land area of 74,712 sq m, which was subsequently  
reduced by the restoration of the documentation to an area of 56,462 sq m. The investment  
objective was “Oil pipeline replacement Ø 14 '' C2 - C3 on 8 sections in Balta Ialomiței area,  
Ialomita County on a length of approx. 4,037 m”- Project no. 160/4993/2016 PETROSTAR.  
Clarifications: By the Conclusion no. 130 / 08.09.2021 The Ploiești Court of Appeal admits the  
motion to dismiss for lack of jurisdiction of the Ploiesti Court of Appeal. It declines jurisdiction to  
settle the case in favor of the Prahova Court. At the deadline of 04.04.2022, the court rejected the  
plea of the lack of procedural passive quality, invoked by the defendant, as unfounded, and  
admitted the request and obliged the defendants to pay to CONPET the amount of RON 238,300  
representing the amount paid and undue. With the right of appeal within 15 days from the  
communication.  
By the Decision 317/ 04.04.2022, the Prahova Court rejects the plea of the lack of procedural  
passive quality, invoked by the defendant, as unfounded. It admits the request with claims as its  
subject matter, and obliges the defendants to pay the claimant the amount of RON 238,300,  
representing the amount paid and undue. Ialomița County Directorate for Agriculture, M.A.D.R.  
and A.N.C.P.I. appealed. CONPET filed an appeal against the grounds of the decision.  
By the Decision no. 955/27.10.2023 The Ploiești Court of Appeal admitted the appeals filed by  
the National Agency for Land Registry and Real Estate Advertising, the Ministry of Agriculture  
and Rural Development and the Ialomita County Directorate for Agriculture, dismissed the  
appealed sentence and sent the case for retrial to the same court of merits. It rejected the appeal  
filed by Conpet SA as unfounded.  
By the Sentence no. 1533/17.12.2024, the Prahova Court admits the exception of the lack of  
passive procedural quality of the defendant ANCPI. It rejects the exception of statute of limitations  
and the exception of lateness, as unfounded. It admits the action filed by the claimant in  
contradiction with the defendants the Ministry of Agriculture and Rural Development and the  
Dâmbovița County Directorate for Agriculture. It obliges the defendants the Ministry of Agriculture  
and Rural Development and the Dâmbovița County Directorate for Agriculture to pay to the  
claimant the amount of RON 238,300 representing an amount illegally withheld. It rejects the  
request filed in contradiction with the defendant ANCPI as being filed against a person without  
passive procedural quality. It obliges the defendants, the Ministry of Agriculture and Rural  
Development and the Dâmbovița County Directorate for Agriculture, to pay the claimant the  
amount of RON 350 as legal expenses. With appeal within 15 days from communication.  
Procedural status of the case: Merits- retrial  
Deadline: --  
34. File no. 19770/281/2023 Ploiesti Court  
Parties: Conpet SA claimant  
International Dancor Imobiliare 888 SRL defendant  
Subject matter: Action for contractual liability. Conpet filed a summons request asking the court:  
- to oblige the defendant International Dancor Imobiliare 888 SRL to pay the amount of RON  
4,064.98 representing late penalties calculated according to art. 8.1. from the rental agreement  
no. STA 147/20.05.2022.  
- to oblige the defendant International Dancor Imobiliare 888 SRL to pay legal expenses  
consisting of the judicial stamp duty and other costs caused by this litigation.  
Clarifications: By the Sentence no. 1137/05.02.2024 the Ploiești Courthouse admits, in part,  
the summons request. It obliges the defendant to pay to the claimant the contractual late payment  
penalties due in the amount of 0.1% per day for each day of delay calculated as follows: for invoice  
series: PH CON FD no. 5287/ 23.06.2022 in the amount of 4534.99 lei, starting from 26.07.2022  
and ending on 24.01.2023; for invoice series: PH CON FD no. 5212/31.05.2022 on the total debit  
of RON 13746.56, from 06.07.2022 to 24.01.2023 inclusive, from 25.01.2023 to 01.03.2023  
inclusive on the debit of RON 10,000 and from 02.03.2023 to 21.03.2023 on the debit amounting  
to RON 4,000. It obliges the defendant to pay to the claimant the amount of RON 285, as legal  
expenses consisting of judicial stamp duty proportional to the extent of the admission of the  
claims. It rejects the rest of the request as unfounded.  
Conpet filed an appeal.  
By the Decision no. 159/07.02.2025, the Prahova Court rejects the appeal. With the right to  
appeal within the deadline after communication.  
Procedural status of the case: Appeal  
Deadline: --  
35. File no. 27248/281/2023 Ploiesti Courthouse  
Parties: Conpet SA claimant  
Technologies Brilliant S.A. - defendant  
Subject matter: Conpet formulates a summons requesting the obliging of the defendant  
Technologies Brilliant S.A. upon payment to Conpet S.A. of penalties in the amount of RON  
2,759.05, owed by the defendant in accordance with the provisions of art. 16.1(1) from the service  
contract no. S-CA 82/03.05.2022, representing the difference between the delay penalties in the  
amount of RON 2,898 calculated and requested by Conpet through the Termination Notice no.  
28092/26.07.2022 and the amount of RON 138.94 paid by the defendant as late payment  
penalties. Obliging the defendant to pay legal expenses.  
Clarifications: By the Sentence no. 5931/04.06.2024, the Ploiești Courthouse rejects the  
request for summons. It rejects the claimant's request to order the defendant to pay the legal  
expenses as unfounded. It rejects the defendant's request to order the claimant to pay the legal  
expenses as unfounded. With the right of appeal after communication.  
Deadline: --  
36. File no. 11374/315/2023 – Ploiești Court of Appeal  
Parties: Conpet S.A. civil party  
Peștișor Marius – Sever - defendant  
Subject matter: Grand larceny. The damage suffered by Conpet S.A. is RON 28,750.45,  
representing the equivalent value of the works to decommission the artisanal by-pass installation  
between the Ø 14" Cartojani - Ploiești and Ø 4" Periș pipelines, identified on 21/22.12.2017 within  
the Butimanu locality, Bârbuceanu village, Dâmbovița county, of the works to remediate the  
damaged pipeline, necessary to restore it to operating condition (RON 13,990.43), as well as of  
the works to recover the crude oil remaining in the Ø 4" Periș pipeline (RON 14,760.02).  
Clarifications: By the Sentence no. 132/18.02.2025, the Târgoviște Courthouse admits the civil  
action and obliges the defendant Peștișor Marius Sever to pay to Conpet S.A. the amount of RON  
28,750.45 as compensation material damages, to which is added the legal penalty interest  
starting with 22.12.2017 and until the full payment of the debt.  
Peștișor Marius – Sever filed an appeal.  
Procedural status of the case: Appeal  
Deadline: --  
37. File no. 4462/233/2024 – Galați Courthouse  
Parties: Conpet S.A. claimant  
Drăgan Gheorghe – defendant  
Drăgan Maria Magdalena - defendant  
Subject matter: Conpet filed a summons application requesting the declaration of  
unenforceability against us, the company Conpet S.A., of the Voluntary Partition Act authenticated  
under the no. 2189 of October 17, 2023 by S.N.P. Costache and Căpătan through notary public  
Carmen-Eliza Ostache concluded between the defendant Drăgan Gheorghe and the defendant  
Drăgan Maria-Magdalena, as co-participants, and Drăgan Marinița, as beneficiary of the right of  
life estate, as well as the Liquidation Act authenticated under the no. 2188/2023 by S.N.P.  
Costache and Căpătan through notary public Carmen-Eliza Ostache, documents having as object  
the ½ share held by the defendant Drăgan Gheorghe of the ownership right over the property,  
registered in the Land Book no. 100346 Slobozia Conachi, identified with the cadastral number  
100346, located in the commune of Slobozia Conachi, Galați county, legal documents concluded  
in fraud of our rights as a creditor of the defendant Drăgan Gheorghe. Obligation of the defendants  
to pay the legal expenses.  
Clarifications: --  
Procedural status of the case: Merits  
Deadline: 19.03.2025  
38. File no. 983/105/2024 Prahova Court  
Parties: Conpet-claimant  
Lambru Dragomir-defendant  
Dragomir Ortansa, Dragomir Maria Alexandra and Dragomir Ioana Cristina-defendants heirs  
Note: Lambru Dragomir has died.  
Subject matter: Action for patrimonial liability  
Conpet requested the obligation of the defendant Lambru Dragomir, residing in Baba Ana village,  
no. 467, Baba Ana commune, Prahova county in order to oblige the defendant to pay the amount  
of RON 524,752.23, representing the equivalent of the quantity of 5,989.72 meters of pipe missing  
from the management and the quantity of 15,532.00 meters of electrical cables missing from the  
management no. 14 Inotești Warehouse of the company Conpet S.A., an amount that will be  
updated with the inflation rate until the effective payment date.  
Clarifications: --  
Deadline: 09.12.2025  
39. File no. 8975/302/2024 Bucharest District 5 Courthouse  
Parties: Conpet - claimant  
The Bailiff Răduță Nicoleta - defendant  
Subject matter: Conpet filed a complaint against the refusal of the Bailiff Răduță Nicoleta sent  
by the address issued on March 14, 2024 in the enforcement file no. 16/2017, address  
communicated to Conpet by e-mail on March 18, 2024 and registered under the no. 11226.,  
requesting the court to admit the complaint and consequently oblige The Bailiff's Office Răduță  
Nicoleta to continue the enforcement in order to recover the amount of RON 1,310 representing  
the partially unpaid debt in the enforcement file no. 16/2017 and the expenses incurred by the  
foreclosure;  
Clarifications: --  
Deadline: 26.03.2025  
40. File no. 1384/105/2024 Prahova Court  
Parties: Conpet -claimant  
CLASS BUSINESS&LEISURE CENTER S.R.L. - defendant  
Subject matter: Conpet filed  
a
lawsuit requesting that the defendant CLASS  
BUSINESS&LEISURE CENTER S.R.L. be ordered to pay to Conpet S.A. the amount of 82,880  
euro representing late payment penalties calculated according to notification no.  
34693/15.09.2022 owed by the defendant in accordance with the provisions of art. 17.1 of the  
works contract no. L-CA 412/10.12.2021 for failure to execute the subject matter of the contract  
within the terms provided for in art. 4.2.  
Clarifications: --  
Deadline: 02.04.2025  
41. File no. 966/2/2024 Bucharest Court  
Parties: Conpet - claimant  
Policyholders Guarantee Fund - defendant  
Subject matter: Conpet filed an appeal against the Decision no. 76568/28.12.2023 issued by the  
Policyholders Guarantee Fund, which rejected the payment request formulated under the  
guarantee policy series M no. 72279, which requested the amount of RON 11,132.43,  
representing partial execution of the performance guarantee for the failure to fulfill contractual  
obligations by the insured COMTEH S.R.L.  
Clarifications: By the Decision no. 674/17.04.2024, the Bucharest Court of Appeal admits the  
motion to dismiss for lack of jurisdiction of the Bucharest Court of Appeal Section VIII  
Administrative and Fiscal Litigation, invoked ex officio. It declines the jurisdiction to resolve the  
case in favor of the Bucharest District 2 Courthouse.  
By the Sentence no. 15871/28.10.2024, the Bucharest District 2 Courthouse admits the request.  
It annuls the Decision no. 76568/28.12.2023 and obliges the defendant to pay the claimant the  
amount of RON 11,132.43, representing compensation. It obliges the defendant to pay the  
claimant the amount of RON 200, representing legal expenses.  
The Policyholders Guarantee Fund filed an Appeal.  
Procedural status of the case: Appeal  
Term: --  
42. File no. 13298/215/2023 Craiova Court  
Parties: Conpet S.A. - claimant  
Florescu Eugen - defendant  
Florescu Silvia - defendant  
Bodic Constantin - defendant  
Subject matter: Conpet S.A. filed a summons against the defendants Florescu Eugen, Florescu  
Silvia and Bodic Constantin to establish the share due to each co-owner on the property consisting  
of a construction intended for a “2-room residential house” and a land plot of 1,038 sq m, identified  
with the Cadastral No. 23, property located in Robăneștii de Jos, Dolj County - tabular owners  
Florescu Silvia and Florescu Eugen, share 1/2, land book No. 33312 Robănești.  
Clarifications: By the Sentence No. 190/19.02.2025, the Craiova Courthouse admits the  
exception to the ineligibility of the claim, invoked by the court, ex officio. It rejects the declaratory  
action filed by the claimant, the company Conpet S.A., as inadmissible. It orders the claimant, the  
company Conpet S.A., to pay to the defendants Florescu Silvia and Bodic Constantin, through  
the heir Florescu Silvia, the amount of RON 6,000, as legal expenses, representing the equivalent  
of the lawyer's fee. It rejects the claimant's request to oblige the defendants to pay the legal  
expenses, as unfounded. With appeal after communication.  
Procedural status of the case: Merits  
Deadline: --  
43. File no. 10606/281/2024 – Ploiești Court of Appeal  
Parties: Conpet civil party  
Voinea Mihai defendant  
Ion Nicolae Adrian  
Grand larceny. Conpet filed a civil case for the amount of RON 156,366 representing the value of  
the goods stolen by the defendants on 04.02.2024 from the premises of Conpet S.A.,  
Rezervoarelor Street no. 8, Prahova County.  
Clarifications: By the Decision no. 264/07.06.2024, the Ploiești Courthouse orders the  
commencement of the trial. The decision was appealed by Voinea Mihai - file 10606/281/2024/a1.  
By the Decision no. 460/23.07.2024 the Prahova Court takes note of the withdrawal of the  
appeal.  
By the Sentence no. 2118/25.11.2024 the Ploiești Courthouse admits the civil action filed by the  
civil party Conpet S.A. in the sense that: It obliges the defendants Voinea Mihai and Ion Nicolae  
Adrian, jointly and severally, to pay the civil party the amount of RON 156,366 representing the  
value of the stolen goods, to which is added the legal penalty interest calculated on the principal  
debt from the date of the crime and until the date of actual payment. With the right of appeal after  
communication.  
The defendants filed an appeal.  
Procedural status of the case: Appeal  
Deadline: 18.03.2025  
44. File no. 2237/120/2024 Prahova Court  
Parties: Conpet claimant  
Mayor of Gura Ocniței commune – Ioniță Sorin Vasile – defendant  
Gura Ocniței commune – defendant  
Mapi Imobiliare S.R.L. Company - defendant  
Subject matter: Conpet files a lawsuit requesting:  
1.Cancellation of the Building Permit no. 43 of 22.12.2023 issued by the Mayor of Gura Ocniței  
commune Ioniță Sorin Vasile at the request of the defendant Mapi Imobiliare S.R.L. company  
2. Dismantling the construction “Platform for container placement” illegally located in the  
protection and safety zone of the Ø 6 5/8" Ochiuri - Moreni crude oil pipeline, which undercuts the  
land owned by Mapi Imobiliare S.R.L. located in Gura Ocniței commune, Ochiuri village, T91,  
P2/1, Dâmbovița county, with an area of 1396 sq m, arable use category, Cadastral and land  
book no. 74623 ATU Gura Ocniței.  
3. Obligation of the defendants to pay legal expenses.  
Clarifications: By the Decision no. 512/02.10.2024, the Dâmbovița Court admits the exception  
of territorial incompetence of the Dâmbovița Court, regarding the resolution of the action filed by  
the claimant Conpet S.A. having as its subject matter the annulment of the administrative act and  
sends the file to the competent resolution of the Prahova Court.  
Procedural status of the case: Merits  
Deadline: 10.04.2025  
45. File no. 17827/281/2024 - Ploiești Courthouse  
Parties: Conpet appellant  
Răduță Săndica - respondent  
The Bailiff’s Office Divoiu Maria - respondent  
Subject matter: Conpet filed an appeal against the enforcement against the enforcement  
documents drawn up by the Bailiff’s Office Divoiu Maria in the enforcement file no. 96/2024 and  
the invalidation of the enforcement for the amount of RON 594.3 representing: RON 107 tax paid  
by Conpet on the amounts paid as an update with the inflation index according to the civil  
sentence no. 7049/04.10.2022, RON 48 tax that Conpet still has to pay under art. 84^1 of Law  
no. 227/2015 regarding the Fiscal Code on amounts paid as debit and RON 439.3 of unjustified  
execution expenses.  
Clarifications: --  
Procedural status of the case: Merits  
Deadline: 19.03.2025  
46. File no. 19573/281/2024 - Ploiești Courthouse  
Parties: Conpet claimant  
Comteh S.R.L. - defendant  
Subject matter: Conpet files a lawsuit requesting that the defendant be ordered to pay the  
amount of RON 11,132.43 representing late payment penalties arising from the late execution of  
the intervention obligation established in art. 4.3 of the Service Contract no. S-CA 133/  
30.04.2020.  
Clarifications: By the Decision of 29.01.2025, the Ploiești Courthouse, pursuant to the  
provisions of art. 75 of Law no. 85/2014, finds that the trial of the case has been suspended by  
law. With the right of appeal for the entire duration of the suspension.  
Procedural status of the case: Merits  
Deadline: --  
47. File no. 19868/281/2024 - Ploiești Courthouse  
Parties: Conpet claimant  
Roțile Schimbării Sport Club Association - defendant  
Subject matter: Conpet files a lawsuit requesting that the defendant Roțile Schimbării Sport Club  
Association pay to Conpet S.A. the amount of RON 22,329.18, consisting of:  
- RON 1,365.08 - the equivalent of invoices no. 5738/19.10.2022, 6043/31.12.2022 and  
6418/25.04.2023, representing late payment penalties calculated according to art. 3.4 of the lease  
agreement no. ADM 7/12.01.2016 for the late payment of a number of 6 invoices issued under  
this contract;  
- RON 12,186.64 representing the equivalent of the rent for the period April 2022 April 2023,  
corresponding to unpaid invoices, issued under the lease agreement no. ADM 11/20.01.2022;  
- 8,777.46 representing late payment penalties composed of:  
- RON 3,053.98 representing late payment penalties calculated according to art. 3.4 of the lease  
agreement no. ADM 11/20.01.2022 for late payment, respectively non-payment of invoices issued  
under this agreement from the due date until the date of payment and respectively of the  
termination notice  
- RON 5,723.48 representing late payment penalties calculated according to art. 3.4 of the lease  
agreement no. ADM 11/20.01.2022 for non-payment of invoices issued under this contract, from  
the date of the termination notice until 08.08.2024 (date of formulation of this). We request that  
the defendant be further ordered to pay these late payment penalties until the effective date of  
payment of the unpaid invoices, issued under the lease agreement no. ADM 11/20.01.2022.  
In the alternative, in the event that you do not accept our request to order the defendant to pay  
the late payment penalties for non-payment of invoices issued under the lease agreement no.  
ADM 11/20.01.2022, from the date of the termination notice until 08.08.2024 and onwards, we  
request that the defendant be ordered to pay the legal interest from the date of termination of the  
contract until the effective date of payment of the unpaid invoices, issued under the lease  
agreement no. ADM 11/20.01.2022.  
We also request that the defendant Roțile Schimbării Sport Club Association be ordered to pay  
the legal expenses advanced in this case.  
Clarifications: --  
Procedural status of the case: Merits  
Deadline: Ruling postponed to 14.03.2025  
48. File no. 27605/281/2024 – Ploiești Courthouse  
Parties: Conpet claimant  
Eurosting AAW Industry S.R.L. - defendant  
Subject matter: Conpet filed a lawsuit requesting the company Eurosting AAW Industry S.R.L.  
to pay to Conpet S.A. the amount of RON 139,712.19 representing late payment penalties owed  
by it in accordance with the provisions of art.17.1(1) of the works contract no. L-CA 95/23.04.2019  
for the delayed execution of the rehabilitation works of the Marghita Crude Oil Loading Ramp.  
Clarifications: --  
Procedural status of the case: Merits  
Deadline: Ruling postponed to 14.03.2025  
49. File no. 32954/281/2024 – Ploiești Courthouse  
Parties: Conpet claimant  
Serinus Energy Romania S.A. defendant  
Subject matter: Conpet filed a lawsuit requesting that the defendant be ordered to pay Conpet  
the following amounts:  
- RON 1,963.50 (including VAT) representing the equivalent of invoice no. PH CON FD  
7207/19.10.2023 issued under contract no. STA 135/31.05.2019.  
- RON 779.51 representing late payment penalties according to art. 11.1 of Additional Act no. 5  
calculated from 23.11.2023 to 23.12.2024, inclusive (date of formulation of this statement), as  
well as ordering the defendant to pay the penalties until the effective payment of the principal  
debt.  
- RON 150 representing legal expenses, namely the judicial stamp duty  
Clarifications: --  
Procedural status of the case: Merits  
Deadline: --  
50. File no. 5092/214/2024 – Costești Courthouse  
Parties: Conpet petitioner  
The Prosecutor's Office attached to the Costești Courthouse - respondent  
Subject matter: Conpet filed a complaint against the Ordinance rejecting the complaint no.  
30/II/2/2024 issued on 08.11.2024 by the Chief Prosecutor of the Prosecutor's Office attached to  
the Costești Courthouse, in the file no. 1280/P/2016, by which, wrongly, the Conpet complaint  
was rejected against the Prosecutor's Order dismissing the case ordered on 30.09.2024 by the  
Prosecutor's Office attached to the Costești Courthouse in the same file, regarding the  
commission of the crime of grand larceny, requesting the admission of the complaint, the abolition  
of Ordinance no. 30/II/2/2024 ordered on 08.11.2024 by the Chief Prosecutor of the Prosecutor's  
Office attached to the Costești Courthouse and the Prosecutor's Order for Dismissal ordered on  
30.09.2024 by the Prosecutor's Office attached to the Costești Courthouse in the file no.  
1280/P/2016 and consequently the continuation of the criminal prosecution and investigations in  
order to identify the criminals and hold them criminally liable for the above-mentioned criminal act.  
At the same time, we request the recovery of the damage caused to our company, as a result of  
the acts committed.  
Clarifications: --  
Procedural status of the case: Merits  
Deadline: 08.04.2025  
51. File no. 5714/118/2024 – Constanța Court  
Parties: Conpet S.A creditor  
COMTEH S.R.L. - debtor  
Subject matter: Conpet filed a request for admission to the list of creditors of the debtor COMTEH  
S.R.L. with the amount of RON 11,132.43 representing late payment penalties arising from the  
late execution of the intervention obligation established in art. 4.3 of the Service Contract no. S-  
CA133/30.04.2020, concluded between Conpet S.A as beneficiary and COMTEH S.R.L. as  
Supplier, as an unsecured, certain, liquid and due claim, arising prior to the date of opening the  
insolvency proceedings.  
In accordance with art. 453 of the Code of Civil Procedure, we request the court to oblige the  
debtor COMTEH S.R.L. to pay legal expenses (judicial stamp duty, as well as other expenses  
incurred in this process).  
Clarifications: --  
Procedural status of the case: Merits  
Deadline: 19.03.2025  
b) The list of litigations pending before Courts on 14.03.2025 in which the company  
CONPET S.A. has the status of defendant  
1. File no. 8296/281/2007 - Ploiești Courthouse  
Parties: Cornea Rodica Aurora  
Conpet S.A., Petrotrans S.A., Regionala Transgaz Bucharest, Ministry of Finance -  
defendants  
Subject matter: Cornea Rodica Aurora claims jointly and severally that the defendants are  
required to pay civil damages in the amount of EUR 74,000 representing the damage caused by  
the presence of pipes belonging to the defendants in the basement, the property of the claimant  
and the payment of civil damages provisionally assessed at RON 10,000 for the period of  
February 2004 - February 2006 as a result of the use of pipes that crossed the property of the  
claimant.  
Clarifications: The case is suspended based on art. 36 of Law no. 85/2006.  
Procedural status of the case: Merits  
2. File no. 8297/281/2007 - Ploiești Courthouse  
Parties: Rusu Mihaela - claimant  
Conpet S.A., Petrotrans S.A., Regionala Transgaz Bucharest, Ministry of Finance -  
defendants  
Subject matter: Rusu Mihaela claims that the defendants should be jointly and severally liable  
for civil damages in the amount of EUR 74,000, representing the damage caused by the presence  
of pipes belonging to the defendants in the basement, the property of the claimant.  
Clarifications: The case is suspended based on art. 36 of Law no. 85/2006.  
Procedural status of the case: Merits  
3. File no. 3451/108/2016 *** - High Court of Cassation and Justice  
Parties: Conpet SA - defendant  
A.T.U. Pecica Town - claimant  
Subject matter: A.T.U. of Pecica town filed a request for a summons requesting:  
Mainly:  
- the obligation of the defendant Conpet S.A. to divert the crude oil pipeline that crosses a number  
of 22 plots of urban land, intended for the construction of houses, located in our property, in a  
total area of 20,287 sq. m.  
- order the defendant Conpet S.A. to pay the amount of EUR 65,000 representing the equivalent  
value of the house located in plot no. A141.7760 / 5/174, entered in L.B. no. 306869 because it  
can no longer be capitalized by the subscriber.  
In subsidiary:  
- order the defendant Conpet S.A. upon payment of an annual rent, during the existence of the  
pipeline, as a result of the encumbrance of the areas shown above by the right of legal easement  
exercised by Conpet SA; NOTE: The annual rent has not been quantified.  
- order the defendant Conpet S.A. to the granting of compensations for the period 31.10.2014 –  
31.05.2016 as a result of the limitation of the attributes of the property right of the 22 urban land  
plots and of the decrease of the circulation value of the land on the real estate market due to the  
restrictions imposed by Order 196/2006 of NAMR on construction;  
- order the defendant Conpet S.A. that every 3 years to adapt the amount of compensation to the  
value of circulation at that time of similar lands and the provisions of future orders of the N.A.M.R.;  
- the setting by the court of the due date on which the compensations will be paid annually,  
following the non-payment at the due term to attract the payment of the legal interest related to  
the amount received as compensation for the delay period;  
- award the legal expenses incurred in the event of opposition.  
Clarifications: By the Conclusion no. 40 / 26.01.2017 The Arad Court rejects the request to  
show the right holder formulated by the defendant Conpet SA in contradiction with the claimant  
ATU of Pecica Town and with the respondents the Romanian State through the Ministry of Public  
Finance and the National Agency for Mineral Resources. The decision was appealed by Conpet  
(File no. 3451/108/2016 * / a1 - Timisoara Court of Appeal. By the Decision no. 211 / 20.03.2017  
The Timișoara Court of Appeal rejects the appeal).  
By the Sentence no. 336 / 18.05.2017, the Arad Court rejects the civil action filed by the claimant  
A.T.U. of Pecica Town in contradiction with the defendant Conpet SA having as subject the  
obligation to act and claims. No legal expenses. The decision was appealed by the ATU Pecica  
Town.  
By the Decision no. 761 / 23.11.2017 The Timișoara Court of Appeal admits the appeal. It annuls  
the appealed sentence and sends the case for retrial to the Arad Court. Conpet filed an appeal.  
Through the Report of 07.06.2018, the High Court of Cassation and Justice found the  
inadmissibility of the Conpet appeal, it being promoted against a final decision, which does not  
fall within the hypothesis regulated by art. 483 para. 1 Code of Civil Procedure. The parties  
submitted a written opinion on the report. By the Conclusion of 10.10.2018, the HCCJ admits in  
principle the appeal declared by the appellant-defendant Conpet S.A.  
By the Decision no. 615 / 22.03.2019 The HCCJ admits the appeal declared by the appellant-  
defendant Conpet S.A., it quashes the appealed decision and sends the case to a new court of  
the same court of appeal.  
By the Decision no. 306 / 07.06.2021 The Bucharest Court of Appeal rejects the appeal declared  
by the appellant-claimant, the Administrative Territorial Unit of the Town of Pecica.  
The claimant, the Territorial Administrative Unit of the Town of Pecica, filed an appeal.  
By the Decision 614 of 15.03.2023 the HCCJ admits the appeal. It dismisses the appealed  
decision and sends the case for a new trial to the same court.  
By the Decision no. 621/13.12.2023 The Timișoara Court of Appeal admits the appeal filed by  
the claimant-appellant the Administrative Territorial Unit of the Town of Pecica. It partially changes  
the appellant's sentence in the sense that it admits in part the request for summons made by the  
claimant the Administrative Territorial Unit of the Town of Pecica in opposition to the defendant  
CONPET S.A., and obliges the defendant to pay the amount of EUR 137,045.69 as compensation  
in favor of the claimant. It upholds the rest of the appealed sentence. It obliges the respondent to  
pay in favor of the appellant the amount of RON 17,579 as legal expenses.  
Conpet filed an appeal.  
By the Decision dated 26.02.2025, the H.C.C.J. rejects the exceptions of lateness and nullity of  
the appeal. It mainly admits the appeal filed by the appellant-defendant Conpet S.A. against the  
decision no. 621/A/13.12.2023, pronounced by the Timișoara Court of Appeal and sets a deadline  
for the hearing of the appeal.  
Procedural status of the case: Appeal  
Deadline: 21.05.2025  
4. File no. 5413/204/2017* - Prahova Court  
Parties: Conpet SA - defendant  
N.A.M.R. - defendant  
Dobrogeanu Dumitru - claimant  
Dobrogeanu Păun Ioan - claimant  
Subject matter: Claims. Dobrogeanu Dumitru and Dobrogeanu Păun Ioan filed a summons  
requesting the court that by the decision it will pronounce to order the obligation of the defendants  
to:  
1. Payment of an annual rent for the land areas occupied by the two pipelines transporting  
petroleum products (crude oil) starting with 01.07.2014 and in the future, throughout the existence  
of the pipelines;  
2. Obligation of the defendants to pay the losses suffered by not achieving economic objectives  
on the area left between the two pipelines after their restriction and the area along DN1 (E60);  
3. Payment of legal expenses.  
The first head of the claim was estimated by the claimants at the amount of EUR 48,000 / year  
(RON 220,000), and the second head at the amount of RON 25,000 / year.  
Clarifications: By the Decision no. 594 / 28.02.2018 the Câmpina Courthouse admits the motion  
to dismiss for lack of jurisdiction of solving the case of the Câmpina Courthouse, invoked by the  
court ex officio. It declines jurisdiction to settle the request in favor of the Prahova Court. No  
appeal.  
By the Sentence no. 2446 / 28.08.2018 the Prahova Court admits the exception of the lack of  
passive procedural quality, invoked by the defendant National Agency for Mineral Resources  
Bucharest. It dismisses the action, in contradiction with that defendant, as being brought against  
a person without procedural capacity. It admits the exception of the res judicata. It dismisses the  
claim filed against the defendant Conpet S.A., as there is res judicata. It finds that the defendants  
have not applied for legal expenses. The decision was appealed by Dobrogeanu Dumitru.  
By the Decision no. 2804 / 11.11.2019 the Ploiești Court of Appeal rejects the appeal filed by the  
appellant Dobrogeanu Dumitru as unfounded. It admits the plea of inadmissibility of the cross-  
appeal. It dismisses as unfounded the cross-appeal declared by the appellant Dobrogeanu Păun  
Ioan. The decision was appealed by Dobrogeanu Dumitru and Dobrogeanu Păun Ioan.  
By the Decision no. 206 / 04.02.2021, the High Court of Cassation and Justice rejects the appeal  
filed by the claimant Dobrogeanu Păun Ioan against the civil decision no. 2804 of November 11,  
2019, pronounced by the Ploieşti Court of Appeal, Civil Division I. It admits the appeal filed by the  
claimant Dobrogeanu Dumitru against the same decision. It quashes the appealed decision and  
the civil sentence no. 2446 of August 28, 2018 of the Prahova Court and sends the case for retrial  
to the Prahova Court.  
Procedural status of the case: Merits - retrial  
Deadline: 22.05.2025  
5. File no. 5212/105/2018 the High Court of Cassation and Justice  
Parties: Conpet SA - defendant  
Fondul Proprietatea SA - claimant  
Subject matter: Fondul Proprietatea SA files an appeal requesting the court to:  
1. Oblige Conpet to pay the amount of RON 734,747.04, representing the net value of the  
dividends related to a share of 6% of the share capital of Conpet, respectively for a number of  
524,366 shares held by the claimant on the registration date of A.G.O.A. Conpet of 25.04.2007  
(i.e. 14/05/2007), for the financial year of 2006,  
2. Oblige Conpet to pay damages, respectively the legal interest related to the dividends from the  
due date of the amount requested in point 1 and until the date of filing the summons (i.e.  
09.11.2018), in the amount of RON 579,015.97.  
3. Oblige Conpet to pay thereafter the legal interest related to the net value of the dividends, from  
the date of filing the summons and until the actual payment of the requested amounts,  
4. Oblige Conpet to pay the legal expenses of the present litigation. Conpet S.A. filed an impleader  
of the Romanian State through the Ministry of Finance and A.A.A.S.  
Clarifications: By the Conclusion of 25.06.2019, the Prahova Court rejected as unfounded the  
impleader of the Authority for the Administration of State Assets, formulated by the defendant  
Conpet S.A. Conpet and the Romanian State through the Ministry of Public Finance filed an  
appeal against this decision of the court. By the same Conclusion of 25.06.2019, the court  
admitted in principle the impleader of the Romanian State through the Ministry of Public Finance,  
formulated by the defendant Conpet S.A. and rejected as unfounded the plea of the lack of  
passive procedural quality of the Romanian State through the Ministry of Public Finance. The  
appeal was registered with the Ploiești Court of Appeal with no. 5212/105/2018 / a2. By the  
Decision no. 515 / 05.11.2019 the Ploiești Court of Appeal admits the plea of the inadmissibility  
of the appeal declared by the Ministry of Public Finance. It dismisses this appeal as inadmissible.  
It rejects the plea of lack of interest and the exception of inadmissibility of the appeal declared by  
Conpet SA. It dismisses this appeal as unfounded. Final.  
By the Conclusion of 20.09.2019, the Ploiești Court suspended the trial of the case until the  
settlement of the appeals made against the decision pronounced on 25.06.2019. This conclusion  
remained final by non-appeal.  
By the Sentence no. 633 / 02.06.2021, the Prahova Court unfoundedly rejects the exception of  
the prescription of the right to action. It admits the action. It obliges the defendant Conpet SA to  
pay to the claimant the amounts of RON 734,747.04 representing the value of dividends, of RON  
579,015.97, representing dividends for the period 26.10.2007-09.11.2018, and the legal interest  
related to the net value of the dividends from 09.11.2018 and until the actual payment of the main  
debit. It admits in part the impleader. It obliges the summoned in guarantee The Romanian State  
to pay to the defendant Conpet S.A., the amount of RON 734,747.04, representing the value of  
dividends, and the legal interest related to this amount starting with 17.12.2018 and until the date  
of restitution to the defendant of the amount of RON 734,747.04. With the right to appeal within  
30 days from communication.  
By the Decision no. 814 / 01.07.2021 The Court admits the request for correction of the material  
error made by the claimant. It corrects the material error crept into the content of paragraph 3 of  
the operative part of sentence no. 633 / 02.06.2021 pronounced by the Prahova Court, in the  
sense that it is written: “It obliges the defendant Conpet S.A. to pay to the claimant the amounts  
of RON 734,747.04 representing the main debit, of RON 579,015.97, representing dividends for  
the period 26.10.2007-09.11.2018, and the legal interest related to the net value of the dividends  
from 09.11.2018 until the actual payment of the main debit.”. It admits the request for completion  
of the decision made by the claimant. It orders the completion of the civil sentence no. 633 /  
02.06.2021 in the sense that it also provides: It reduces to RON 70,000 the fee of the claimant's  
lawyer. It obliges the defendant Conpet S.A. to pay the claimant the following legal expenses:  
RON 20,347.63 representing judicial stamp duty, RON 4,300 expert fee, RON 8,481.87 expert  
fee, RON 70 lawyer's fee and RON 1,125 other expenses. It obliges the summoned in guarantee  
The Romanian State to pay to the defendant Conpet S.A. legal expenses in the amount of RON  
16,943. With the right of appeal within 15 days from communication.  
Conpet and the Romanian State through the Ministry of Public Finance filed an appeal against  
the substantive decision no. 633 / 02.06.2021.  
Conpet filed an appeal against the material error correction decision no. 814/01.07.2021.  
Conpet S.A. also filed a request to correct the material errors in the contents of sentence no. 633  
of 02.06.2021 pronounced by the Prahova Court in the file no. 5212/105/2018, device that was  
the object of correcting the material error pronounced by the court by sentence no. 81 of  
01.07.2021. Through the Conclusion of Correction of Material Civil Error, dated 12.09.2022, the  
Prahova Court admitted the request to correct the material errors of the disposition of the civil  
sentence no. 633/02.06.2021 and no. 814/01.07.2021, pronounced by the Prahova Court, in the  
file no. 5212/105/2018, formulated by Conpet S.A., against the claimant, Fondul Proprietatea  
S.A., against the defendant Conpet S.A., the summoned in guarantee the Romanian State,  
through the Ministry of Public Finances. It corrects the material errors in the content of sentences  
no. 633/02.06.2021 and no. 814/01.07.2021 pronounced by the Prahova Court, in the sense that  
it is changed: It obliges the defendant S.C. Conpet S.A. to pay the claimant the amount of RON  
734,747.04 representing the net value of the dividends and RON 579,015.97, representing the  
legal interest related to the net value of the dividends for the period 26.10.2007-09.11.2018, and  
the legal interest related to the net value of the dividends from 09.11.2018 and until the actual  
payment of the main debit.  
By the Decision no. 245/08.12.2022 the Ploiești Court of Appeal admits the exception of the  
ineligibility of the appeal invoked ex officio. It rejects the appeal as unfounded. Final.  
By the Decision no. 109 of 29.03.2023, Ploiești Court of Appeal admits the appeals. It changes  
the entire sentence. It admits the statute of limitations exception and dismisses the claim as  
statute of limitations. It rejects the warranty claim. It obliges the claimant to pay the defendant  
RON 16,943 in legal expenses incurred at the trial in the first instance. It obliges the respondent-  
claimant to pay the appellant-defendant RON 17,785 in legal expenses in the appeal. Fondul  
Proprietatea S.A. filed an appeal.  
On 14.02.2024 the H.C.C.J. admits in principle the appeal declared by the appellant-claimant  
Fondul Proprietatea S.A. against the decision no. 109/29.03.2023, pronounced by the Ploieşti  
Court of Appeal - Civil Division II. It establishes a term for judging the appeal.  
By the Decision no. 860/17.04.2024 the H.C.C.J. admits the appeal; it quashes the appealed  
decision and sends the case for a new trial to the appellate court.  
By the Decision no. 67/26.02.2025 the Ploiești Court of Appeal rejects the appeal filed by the  
summoned in guarantee the Romanian State, represented by the Ministry of Finance. It admits  
the appeal filed by the defendant Conpet S.A. It changes in part the sentence no. 633/02.06.2021,  
as directed by the conclusion of 12.09.2022, in the sense that the impleader will be accepted in  
its entirety and the Romanian State represented by the Ministry of Finance will be obliged to pay  
the defendant the amount of RON 579,015.97 representing the interest to be paid by the  
defendant to the claimant for the period between 26.10.2007 - the due date for payment of  
dividends due for the 524,366 shares and the date of filing the impleader - 09.11.2018, as well as  
the legal interest starting with 09.11.2018 and until the moment this court decision becomes final.  
It obliges the defendant-appellant to pay the claimant-respondent the legal expenses in the  
amount of RON 30,000 representing defense fees incurred in the appeal trial in both procedural  
cycles. It obliges the defendant-appellant to pay the claimant-respondent the legal expenses in  
the amount of RON 50 the judicial stamp duty paid in the appeal as well as RON 31,197.58  
defense fees paid in the appeal - HCCJ - in the first procedural cycle. It maintains the other  
provisions of the sentence no. 633/02.06.2021. With the right of appeal after communication.  
Procedural status of the case: Appeal retrial  
Deadline: --  
6. File no. 4395/270/2020 - Onești Courthouse  
Parties: Municipality of Onești - claimant  
Local Council of Onești Municipality - claimant  
Conpet S.A. - defendant  
Subject matter: Onești Municipality and the Local Council of Onești Municipality, Bacău County,  
have sued Conpet S.A. asking the court:  
"1. The obligation of the defendant at the conclusion of the agreement for the exercise of the right  
of legal easement over the lands with an area of 11,474.5 sq. m., crossed and affected by crude  
oil transport pipelines within the municipality of Onești, equivalent to the payment of an annual  
rent, during the existence of the pipelines, to the local budget of Onești municipality, determined  
according to the principle of the least violation of the property right and calculated taking into  
account the circulation value of the affected real estate, established under the law, at the time of  
the damage.  
2. The obligation of the defendant to pay material damages, representing the equivalent value of  
the lack of use for the land in the area of 11,474.5 sq. m. crossed and affected by the crude oil  
pipelines within the municipality of Onești, established according to the Market Study approved  
by the Decision of the Local Council no. 199 of 29.11.2018, respectively according to the Updated  
Market Study approved by the Decision of the Local Council no. 122 of 29.06.2020, calculated  
starting with 2017 and until the date of concluding the agreement for exercising the right of legal  
easement over these lands, to which are added late fees, interest and late payment penalties in  
the amount provided by the Fiscal Procedures Code applicable in this period.  
3. The obligation of the defendant to pay the legal expenses of the present proceedings."  
Clarifications: --  
Procedural status of the case: Merits  
Deadline: 13.05.2025  
7. File no. 666/317/2022- Târgu Carbunești Courthouse  
Parties: Balțoi Mariana - claimant  
Conpet S.A. -defendant  
Subject matter: Obliging Conpet to pay the claimant the amount of RON 5,000, established only  
for the purpose of stamping and which may be increased depending on the conclusions of the  
expert report, as compensation representing the value of the lack of use related to the land with  
an area of 268 square meters for the years 2018 -2022 and further until the file is completed,  
amount that will be updated on the actual payment date.  
Clarifications: By the Closing of the hearing on 25.01.2023, the court of first instance admitted  
in principle the request to summon the National Agency for Mineral Resources (N.A.M.R.) made  
by the defendant Conpet S.A. It orders the design and citation in question of the National Agency  
for Mineral Resources (N.A.M.R.) as a guarantor. It rejects in principle the request to call in the  
guarantee of the Romanian State through the Ministry of Public Finances formulated by the  
defendant Conpet S.A.. With the right to appeal together with the merits.  
Procedural status of the case: Merits  
Deadline: 03.04.2025  
8. File no. 5971/2/2022 - Bucharest Court of Appeal  
Parties: OMV Petrom SA-claimant  
N.A.M.R. -defendant  
Conpet S.A. - defendant  
Subject matter: The court is requested that, through the judgment that will be pronounced, it  
orders:  
1. Regarding the Order 229/2021:  
1.1. Partial annulment of art. 1 of Order 229/2021 regarding the tariffs established in the Annex 1  
and Annex 3 and, accordingly, the Annexes 1 and 3 of Order 229/2021; and by way of  
consequence  
1.2. Obliging NAMR to issue a new order for the approval of transport tariffs through the National  
System for the transportation of crude oil, rich gas, condensate and ethane for the year 2022,  
which includes tariffs modified accordingly with regard to tariffs in the domestic (Annex 1) and  
tariffs in import for refineries in the Ploiești Basin (Annex 3), as a result of the recalculation of the  
tariffs included in the Order 229/2021 in a transparent and non-discriminatory manner, in  
accordance with the constitutional provisions and those of the primary and secondary petroleum  
and competition legislation, as they are exposed by means of this summons;  
2. Regarding Order 53/2008, the partial cancellation of art. 3-8 of the Annex to Order no. 53/2008,  
as well as obliging NAMR to issue a new order to properly complete the Order no. 53/2008, by  
reference to the following:  
2.1. the method of determining in the Methodology the operating cost lacking transparency and  
clarity, with regard to (i) its component elements, the structure of each of these elements, not  
specifically provided for, along with (ii) the cost calculation algorithm of operation by referring to  
these elements and (iii) by taking into account only those elements that constitute, by their nature,  
operating costs, so that these secondary normative provisions are aligned with the requirements  
of art. 20 of the Petroleum Law;  
2.2. the algorithm for determining the modernization quota that does not provide in a specific,  
clear and transparent manner (i) the effective percentage of the modernization quota, (ii) the basis  
on which it is applied, (iii) the concrete investments in order to carry out which pay the  
modernization quota by the beneficiaries of the transport system, (iv) the method of managing the  
surplus of amounts received as modernization quota and unused until the end of the financial  
year that were charged for the realization of investments, by taking into account these amounts  
in the calculation of the modernization quota that the beneficiaries must pay in the following year,  
by referring to the investments considered within it and such amounts available for investments  
carried over from previous years, as well as (v) the method of managing the bank interest  
collected by the holder of the concession agreement as a result of depositing the amounts  
received as a modernization fee and used by him, in the sense of using interest according to the  
same destination and taking into account these amounts in the calculation of the modernization  
quota that the beneficiaries must pay in the following year with this title, so that these secondary  
normative provisions are aligned with the requirements of art. . 20 of the Petroleum Law;  
2.3. the algorithm from which does not result in a specific, clear and transparent manner (i) the  
method of determining the level of the rate of profit considered to be reasonable or (ii) of a  
profitability interval whose lower and upper limits should be established on the basis of  
comparative studies, by referring to the practice in the field of other comparable European  
transport operators, as well as (iii) specific requirements for transparent justification by Conpet of  
the studies to substantiate any increases in the profitability rates considered in the establishment  
of transport tariffs, so that these secondary normative provisions are aligned with the  
requirements of art. 20 of the Petroleum Law;  
2.4. the tariff systems that are not currently focused on similar criteria and calculations for the two  
subsystems they regulate (i.e. the domestic and the import) that meet the requirements of  
ensuring equal treatment between the beneficiaries of the public transport service for the two  
types of subsystems, so that these secondary normative provisions are aligned with the  
requirements of art. 20 of the Petroleum Law;  
2.5. the procedural elements to ensure in a clear, transparent and efficient manner the right of  
Conpet customers to express their point of view regarding the advanced tariff proposals for  
approval by Conpet, based on specific documentation made available to them respectively to the  
revision/update requests of the rates sent by Conpet to N.A.M.R. and related documentation, as  
well as to receive a reasoned response from N.A.M.R. regarding the views expressed if they are  
not taken into account in full or in part by N.A.M.R., so that these secondary normative provisions  
are aligned with the requirements of art. 20 of the Petroleum Law and the transparency  
requirements applicable to the adoption of normative acts in compliance with the general  
European and national principle of good administration.  
3. Ordering the defendant to pay legal expenses.  
After the communication of the summons request, but before the first court term (17.01.2023)  
OMV PETROM amended the summons request regarding the first petition of the request asking  
the court to order:  
1. Regarding Order no. 229/2021:  
Partial annulment of art. 1 of Order 229/2021 regarding the tariffs established in Annex 1  
and Annex 3 and, correspondingly, of Annexes 1 and 3 of Order 229/2021 regarding the  
tariffs for the DOMESTIC subsystem and the IMPORT subsystem, within the limit of the  
amount of the tariffs that will be established as legal as a result of their recalculation in a  
transparent and non-discriminatory manner, in accordance with the constitutional  
provisions and those of the primary and secondary petroleum and competition legislation,  
as they are submitted through this summons.  
2. Regarding Order no. 53/2008: partial cancellation of art. 3-8 of the Annex to Order no. 53/2008,  
as well as the obligation of N.A.M.R. upon issuing a new order to properly complete Order no.  
53/2008, by reference to the following:  
2.1. the method of determining in the Methodology the operating cost lacking transparency  
and clarity, with regard to (i) its component elements, the structure of each of these elements, not  
specifically provided for, along with (ii) the cost calculation algorithm of operation by referring to  
these elements and (iii) by taking into account only those elements that constitute, by their nature,  
operating costs, so that these secondary normative provisions are aligned with the requirements  
of art. 20 of the Petroleum Law;  
2.2. The algorithm for determining the modernization quota that does not provide in a specific,  
clear and transparent manner (i) the effective percentage of the modernization quota, (ii) the basis  
on which it is applied, (iii) the concrete investments in order to carry out pay the modernization  
quota by the beneficiaries of the transport system, (iv) the method of managing the surplus of  
amounts collected as modernization quota and unused until the end of the financial year that were  
charged for the realization of investments, by taking into account these amounts in the calculation  
of the modernization quota that the beneficiaries must pay in the following year, by referring to  
the investments considered within it and such amounts available for investments carried over  
from previous years, as well as (v) the method of managing the bank interest collected by the  
holder of the concession agreement as a result of depositing the sums received as a  
modernization quota and not used by him, in the sense of using the interests according to the  
same destination and taking into account these sums in the calculation of the modernization quota  
that the beneficiaries must pay in the following year with this title, so that these secondary  
normative provisions are aligned with the requirements of art. 20 of the Petroleum Law;  
2.3. The algorithm does not result in a specific, clear and transparent manner (i) the way to  
determine the level of the rate of profit considered to be reasonable or (ii) of a profitability interval  
whose lower and upper limits should be established based on comparative studies, by reference  
to the practice in the field of other comparable European transport operators, as well as (iii)  
specific requirements for transparent justification by CONPET of studies to substantiate any  
increases in profitability rates considered in the establishment of transport tariffs, so that these  
secondary normative provisions are aligned with the requirements of art. 20 of the Petroleum Law;  
2.4. Tariff systems that are not currently focused on similar criteria and calculations for the two  
subsystems they regulate (i.e. the domestic and the import) that meet the requirements of  
ensuring equal treatment between the beneficiaries of the public transport service for the two  
types of subsystems, so that these secondary normative provisions are aligned with the  
requirements of art. 20 of the Petroleum Law;  
2.5. Procedural elements to ensure in a clear, transparent and efficient manner the right of  
Conpet customers to express their point of view regarding advanced tariff proposals for approval  
by Conpet, based on specific documentation made available to them respectively to requests for  
revision/update of tariffs sent by Conpet to N.A.M.R. and related documentation, as well as to  
receive a reasoned response from N.A.M.R. regarding the points of view formulated if they are  
not taken into account in whole or in part by N.A.M.R. so that these secondary normative  
provisions are aligned with the requirements of art. 20 of the Petroleum Law and the transparency  
requirements applicable to the adoption of normative acts in compliance with the general  
European and national principle of good administration.  
3. Ordering the defendant to pay legal expenses.  
Clarifications: By the Sentence no. 898/28.05.2024, the Bucharest Court of Appeal rejects as  
unfounded the claimant's exception of lack of interest. It rejects as unfounded the exception of  
lack of passive procedural quality of the defendant Conpet S.A. It rejects as unfounded the request  
for summons, as amended. It rejects as unfounded the claimant's request to order the defendants  
to pay the legal expenses. With appeal after communication.  
Procedural status of the case: Merits  
Deadline: --  
9. File no. 1132/241/2022 Pitești Court of Appeal  
Parties: Podureanu Iordachi claimant  
Conpet SA - defendant  
Subject matter: Podureanu Iordachi filed a summons request requesting the court that, through  
the judgment it will pronounce, order the increase of the periodic benefit to which Conpet SA was  
obliged by the civil sentence no. 337/14.03.2019, in the file no. 2646/241/2017 the decision  
remained final through manipulation, so that Conpet S.A. is obliged to pay the amount of RON  
2,200 as periodic compensation.  
Clarifications: By the Sentence no. 20/11.01.2024 the Horezu Courthouse admits the summons  
request filed by the claimant Podureanu Iordachi. It orders the increase of the periodic benefit  
established in favor of the claimant by the Civil Sentence no. 337/14.03.2019 pronounced by the  
Horezu Courthouse, which remained final through non-appeal, from the amount of RON 600 per  
month to the amount of RON 2,200 per month, starting from the date of the introduction of the  
action, namely 27.04.2022, until the end of the state of need. It obliges the defendant company  
to pay the amount of RON 2,200 /month in favor of the claimant starting from the date of the filing  
of the action, i.e. 27.04.2022, until the end of the state of need. It obliges the defendant company  
to pay the claimant legal expenses in the amount of RON 1,000, representing the attorney's fee.  
Conpet filed an appeal.  
By the Decision no. 792/07.11.2024, the Vâlcea Court rejects the appeal filed by Conpet. It  
orders the appellant to pay the amount of RON 2,500 to the respondent, as legal expenses.  
Conpet filed an Appeal.  
Procedural status of the case: Appeal  
Deadline: 15.04.2025  
10. File no. 727/42/2022 Ploiesti Court of Appeal  
Parties: Gruia Gheorghe, Vasile Valentin, Dudaș Pavel, Tudorache Marius, Pârvu Valentin,  
Georgescu Anda, Manda Marin, OMV Petrom SA, SC Conpet SA, Transgaz SA National Gas  
Transport Company, Amuza Daniel respondents  
Ciobanu Viorel convicted appellant  
Subject matter: Appeal in annulment  
Clarifications: By the Conclusion of 06.10.2022, the Ploiești Court of Appeal orders the  
reunification of the case that forms the subject of the file no. 727/42/2022, to the file no.  
2339/120/2022.  
Procedural status of the case: Appeal in annulment - Appeal  
Deadline: 20.03.2025  
11. File no. 2276/110/2020 – Bacău Court  
Parties: Radu Marian claimant  
Radu Elena - claimant  
E ON Romania S.A., Delgaz Grid S.A., Trans gas S.A. Mediaș, Bacău Regional Water Company  
S.A., Conpet S.A., The General Secretariat of the Government of Romania - Victoria Palace, The  
Romanian State - Through the Minister of Public Finance - defendants  
Subject matter: action in tort liability  
Clarifications: By the Conclusion of 13.07.2022, the Bacău Court ordered the splitting of the  
request with the subject matter of obliging the defendants to jointly pay a monthly royalty of 5000  
euro and the related tax and orders the creation of a separate file in which the claimants will be  
considered to prove the joint payment of a judicial stamp duty in the amount of RON 6,527.3,  
established according to the art. 31 paragraph (4) of the G.E.O. no. 80/2013, under the penalty  
of canceling the request as unstamped and pursuant to the art. 200. para. (3) of the Code of Civil  
Procedure, canceled the action for the remaining claims. With the right of re-examination within  
15 days of communication for the cancellation solution.  
Procedural status of the case: Merits  
Deadline:--  
12. File no. 2072/110/2022 – Bacău Court  
Parties: Radu Marian claimant  
Radu Elena - claimant  
E ON Romania S.A., Delgaz Grid S.A., Trans gas S.A. Mediaș, Bacău Regional Water Company  
S.A., Conpet S.A., The General Secretariat of the Government of Romania - Victoria Palace, The  
Romanian State - Through the Minister of Public Finance - defendants  
Subject matter: Claims. Disjointed file from the file no. 2276/110/2020  
Clarifications: By the Decision no. 959/23.12.2024, the Bacău Court rejects as unfounded the  
exception of the failure to stamp the summons. It accepts the exception of the lateness of the  
amending requests filed after the first trial date. It rejects the amending requests as being late. It  
rejects as unfounded the exception of the lack of passive procedural quality invoked by the  
defendants Conpet S.A. and CRAB. It accepts the exception of the authority of res judicata  
invoked by the defendant CRAB. It rejects the request formulated by the claimants Radu Marian  
and Radu Elena against SC Bacău Regional Water Company S.A. as being formulated in violation  
of the authority of res judicata of the Civil Sentence no. 505/30.03.2022 pronounced by the Onești  
Courthouse in the File no. 5022/270/2020 final. It admits the exception of the statute of limitations  
for the claims relating to the period 1990-28.09.2017. It rejects as being prescribed the request  
for summons filed by the claimants Radu Marian and Radu Elena against the defendants SC E  
ON Energie România S.A., DELGAZ GRID S.A., SC Transgaz S.A. Mediaș, SC Conpet S.A., the  
General Secretariat of the Government of Romania - Victoria Palace, the Romanian State -  
through the Ministry of Public Finance - A.J.F.P. Bacău for the period 1990-28.09.2017. It  
requalifies the exception of the ineligibility of the claim as being substantive defenses. It rejects  
as unfounded the request for summons filed by the claimants Radu Marian and Radu Elena  
against the defendants SC E ON Energie România S.A., Delgaz Grid S.A., SC Transgaz S.A.  
Mediaș, SC Conpet S.A., the General Secretariat of the Government of Romania - Victoria  
Palace, Romanian State - through the Ministry of Public Finance - A.J.F.P. Bacău. With the right  
of appeal after communication.  
Procedural status of the case: Merits  
Deadline: --  
13. File no. 11934/212/2022 – Constanța Courthouse  
Parties: Conpet SA defendant  
Top Vision SRL claimant  
Matei Nicolae claimant  
Subject matter: Top Vision S.R.L. and Matei Nicolae request the obligation of Conpet SA in the  
form of compensation for the amount of 13,000 euro, the equivalent in RON from the date of  
payment, representing damage caused by their own act, respectively for the act caused by the  
thing under the defendant's custody, with the obligation the defendant to pay the legal expenses  
caused by this litigation.  
Clarifications: --  
Procedural status of the case: Merits  
Deadline: 25.04.2025  
14. File no. 4372/105/2022 Prahova Court  
Parties: Conpet SA defendant  
Eurosting AAW Industry S.R.L. claimant  
Subject matter: Eurosting AAW Industry S.R.L. requests the cancellation of notification no.  
14658/29.04.2021 regarding the unilateral termination of the contract for works and design  
services no. L-CA 252/06.08.2019, the obligation of CONPET to pay Eurosting AAW Industry  
S.R.L. of the amount of RON 24,395 representing the counter value of the design services related  
to stage I of the works contract no. L-CA 252 of 06.08.2019. Obliging CONPET to pay legal  
expenses.  
Clarifications: --  
Procedural status of the case: Merits  
Deadline: 05.06.2025  
17. File no. 7035/2/2022 - Bucharest Court of Appeal  
Parties: OMV Petrom SA- claimant  
N.A.M.R. -defendant  
CONPET - defendant  
Subject matter: The court is requested that, through the decision that will be pronounced, it  
orders:  
1. Partial annulment of the art. 3 of Addendum no. 2 regarding the tariffs on the domestic  
subsystem and the import subsystem charged for the transport services provided by Conpet and  
established by the Order no. 229/2021, within the limit of the amount of tariffs that will be  
established as legal following the administrative litigation proceedings carried out by the Company  
regarding the tariffs with N.A.M.R.;  
2. Partial annulment of the art. 1 and 4 of Addendum no. 2, 6 and 9, respectively of art. 1 and 3  
of Addenda 3, 4, 5, 7 and 8 by which the duration of the Transport Contract was extended for the  
period 01.01.2022 - 31.08.2022 with the application of the new tariffs approved by the Order  
229/2021, within the limit of the amount of the tariffs that will be established as legal following the  
administrative litigation proceedings carried out by the Company regarding the tariffs with  
N.A.M.R. and, as a consequence,  
3. The obligation of CONPET to pay to the Company, as compensation as a result of the partial  
cancellation of the Addenda, but also its illegal act of providing erroneous data that was the basis  
of the tariff development process by N.A.M.R. based on the Order no. 229/2021 and then upon  
their payment by the Company based on the Addenda, of the amounts representing: (i) the  
difference between the amount of the tariffs provided for in the Addendum no. 2 to the transport  
contract, concluded as a result of the new tariffs adopted by the Order 229/2021, paid by the  
Company in the period 01.01.2022 31.08.2022 as a result of the extension of the contractual  
period through the Addenda and the amount of the tariffs that will be established as legal in the  
result of the administrative litigation proceedings carried out by the Company regarding them with  
N.A.M.R., updated according to the inflation index, as well as the related legal interest calculated  
from the date of payment of the tariff difference; (ii) the difference between the amount of tariffs  
paid by the Company for the transport of crude oil, through the DOMESTIC subsystem, from the  
Midia Terminal, and the amount of the tariffs set proportionally, by reference to the DOMESTIC  
and IMPORT tariffs depending on the subsystem actually used for the transport of marine crude  
oil, updated in depending on the inflation index, as well as the related legal interest calculated  
from the date of payment of the tariff difference, for the following quantities transported from the  
Midia Terminal and for which the tariff for the DOMESTIC subsystem was illegally calculated and  
paid: -13,905 tons from the art. 2 letter a) from Addendum no. 4 for March 2022; -13,171 tons  
from the art. 2 letter a) from Addendum no. 5 for April 2022; 13,307 tons from the art. 2 letter a)  
from Addendum no. 6 for May 2022; 12,633 tons from the art. 2 letter a) from Addendum no. 7 for  
June 2022; -12,072 tons from the art. 2 letter a) from Addendum no. 8 for July 2022; -12,900 tons  
from the art. 2 letter a) from Addendum no. 9 for August 2022; (iii) any other amounts representing  
natural fruits that Conpet acquired or could have acquired in connection with the amounts illegally  
charged from the Company based on the tariffs;  
4. Obligation to pay legal expenses.  
The claimant OMV PETROM filed a request to change the heads of claim no. 2 and 3 of the  
petition of the introductory action in the sense that, in addition to Addenda no. 2 9, the Company  
understands to challenge through this action the last 4 additional documents on the basis of which  
transport services were provided by Conpet between September and December 2022 for the  
benefit of the company, as follows:  
- Addendum no. 10/23.08.2022  
- Addendum no. 11/22.09.2022  
- Addendum no. 12/31.10.2022  
- Addendum no. 13/22.11.2022  
Therefore, considering the request to modify the preliminary action, the claimant OMV PETROM  
requests the court to order, through the judgment that will be ruled:  
1. Partial annulment of art. 3 of Addendum no. 2 regarding the tariffs on the DOMESTIC  
subsystem and the IMPORT subsystem charged for the transport services provided by Conpet  
and established by Order no. 229/2021, within the limit of the amount of tariffs that will be  
established as legal following the administrative litigation proceedings carried out by the Company  
regarding the tariffs with N.A.M.R.;  
2. Partial annulment of art. 1 and 4 of Addendum no. 2, 6, 9 and 12 respectively of art. 1 and 3 of  
Addenda 3, 4, 5, 7, 8, 10, 11 and 13 by which the duration of the Transport Contract was extended  
for the period 01.01.2022 - 31.12.2022 with the application of the new tariffs approved by Order  
no. 229/2021, within the limit of the amount of the tariffs that will be established as legal following  
the administrative litigation proceedings carried out by the Company regarding the tariffs with  
N.A.M.R. and consequently,  
3. Obliging Conpet to pay the Company, in the form of compensation as a result of the partial  
cancellation of Addenda no. 2 -13, but also of her illegal act of providing erroneous data that was  
the basis of the tariff development process by N.A.M.R. based on the Order no. 229/2021 and  
then upon their payment by the Company based on the Addenda, of the amounts representing:  
(i) the difference between the amount of the tariffs provided for in Addendum no. 2 to the transport  
contract, concluded as a result of the new tariffs adopted by Order no. 229/2021, paid by the  
Company in the period 01.01.2022 - 31.12.2022 as a result of the extension of the contractual  
period through the Addenda and the amount of the tariffs that will be established as legal following  
the administrative litigation proceedings carried out by the Company regarding them with the  
N.A.M.R.., updated according to the inflation index, as well as the related legal interest calculated  
from the date of payment of the tariff difference;  
(ii) the difference between the amount of the tariffs paid by the Company for the transport of crude  
oil, through the DOMESTIC subsystem, from the Midia Terminal, and the amount of the tariffs  
established proportionally, by reference to the tariffs of DOMESTIC and IMPORT according to the  
subsystem actually used for the transport of marine crude oil, updated in depending on the  
inflation index, as well as the related legal interest calculated from the date of payment of the tariff  
difference, for the following quantities transported from the Midia Terminal and for which the tariff  
for the country subsystem was illegally calculated and paid:  
-13,905 tons from art. 2 letter a) from Addendum no. 4 for March 2022;  
-13,171 tons from art. 2 letter a) from Addendum no. 5 for April 2022;  
13,307 tons from art. 2 letter a) from Addendum no. 6 for May 2022;  
-12,633 tons from art. 2 letter a) from Addendum no. 7 for June 2022;  
-12,072 tons from art. 2 letter a) from Addendum no. 8 for July 2022;  
-12,900 tons from art. 2 letter a) from Addendum no. 9 for August 2022;  
-12,213 tons from art. 2 letter a) from Addendum no. 10 for September 2022;  
- 12,411 tons from art. 2 letter a) from Addendum no. 11 for October 2022;  
- 11,836 tons from art. 2 letter a) from Addendum no. 12 for November 2022;  
- 12,048 tons from art. 2 letter a) from Addendum no. 13 for December 2022.  
(iii) any other amounts representing natural fruits that Conpet acquired or could have acquired in  
connection with the amounts illegally charged from the Company based on the tariffs;  
4. Obligation to pay legal expenses.  
Clarifications: By the Decision dated 24.05.2023, the Bucharest Court of Appeal rejects the  
claimant's request for forfeiture to submit the request to amend claims 2 and 3 of the summons  
as unfounded. Based on art. 413 paragraph 1 point 1 of the Code of Civil Procedure, it orders the  
suspension of the trial of the case until the final resolution of the case that is the subject of file no.  
5971/2/2022 of the Bucharest Court of Appeal, Section IX of Administrative and Fiscal Litigation.  
With the right of appeal for the duration of the suspension.  
Procedural status of the case: Merits - Suspended  
Deadline: --  
16. File no. 5074/105/2022 - Prahova Court  
Parties: CONPET SA - defendant  
Ionescu Aurel - claimant  
Subject matter: Declaratory action. Ionescu Aurel filed a summons request in which he  
requested the following from the court:  
- To state that in the period 01.04.1992 - 01.04.2001 the claimant was employed and that he  
actually worked 100% of the work schedule within the sections included in the I work group, in  
accordance with the Order 50/1990, the Order 100/1990 and of the Order 125/1990;  
- Subsidiarily, in the situation where the first head of the claim will be accepted, he requested the  
court to establish the placement in the I work group and in the period 01.04.2001 - 15.06.2021,  
the claimant remaining in the same position and under the same working conditions;  
- Obliging CONPET to draw up and issue a certificate attesting that the activity provided by the  
claimant falls under the I work group and the percentage in which he carried out his activity.  
- Obliging CONPET to pay the legal expenses caused by this claim.  
Clarifications: By the Sentence no. 698/11.06.2024, the Prahova Court rejects the action as  
unfounded. With the right of appeal after communication.  
Procedural status of the case: Merits  
Deadline: --  
17. File no. 3845/204/2023 Câmpina Courthouse  
Parties: CONPET S.A. - respondent  
Dobrogeanu Dumitru - appellant  
Subject matter: Appeal against enforcement. Dobrogeanu Dumitru filed a foreclosure appeal  
against the foreclosure started at the request of the creditor Conpet S.A. and the Petcu Alexandru  
Bailiff's Office based on the Conclusion no. 509/2022 issued today on 19.04.2023, given without  
citing the parties and requests:  
- Cancellation of the Conclusion no. 509/2022 issued today 19.04.2023 by the Petcu Alexandru  
Bailiff's Office for payment of a debit in the amount of RON 1,022.70, representing the calculation  
of the related inflation rate for the period 19.01.2022 - 09.12.2022 for the main debit of RON  
6,966.65.  
- The cancellation of all expenses that the bailiff established.  
- The cancellation of the garnishment notice issued on 19.04.2023 and received at my residence  
in Băicoi on 24.04.2023.  
- Return of enforcement for the amount of RON 576.  
- Legal expenses.  
Clarifications: --  
Procedural status of the case: Merits  
Deadline: 23.04.2025  
18. File no. 590/42/2022 Ploiesti Court of Appeal  
Parties: CONPET S.A. - respondent  
Vasile Valentin convicted appellant  
Gruia Gheorghe, Ciobanu Viorel, Dudaș Pavel, Tudorache Marius, Pârvu Valentin,  
Georgescu Anda, Manda Marin, OMV Petrom S.A., Amuza Daniel, National Gas Transport  
Society Transgaz S.A. - respondent  
Subject matter: Formation of an organized criminal group (art. 367 NCP)  
Procedural status of the case: Appeal  
Clarifications: By the Conclusion of 04.05.2023, the Ploiești Court of Appeal puts the file back  
on pending for the Romanian Constitutional Court to rule on the constitutional challenge of the  
provisions of art. 426 letter b) of the Code of Civil Procedure, in the interpretation given by the  
High Court of Cassation and Justice-Complete for resolving some legal issues, by the Decision  
no. 67/25.10.2022, in the sense that "the court that resolves the annulment appeal, based on the  
effects of the decisions of the Constitutional Court no. 297 of April 26, 2018 and no. 358 of May  
26, 2022, cannot reanalyze the prescription of criminal liability, if the appeals court debated and  
analyzed the incidence of this cause of termination of the criminal process during the process  
prior to this last decision".  
Deadline: Ruling postponed to 06.05.2025  
19. File no. 4829/121/2022 Galati Court  
Parties: CONPET S.A. - respondent  
Diaconu Sorin Daniel appellant  
Subject matter: Appeal against the Sanctioning Decision no. 785/06.12.2022 disciplinary  
termination of the individual employment contract no. 74/24.05.1993  
Clarifications: By the Sentence no. 505/05.06.2024, the Galați Court rejects the appeal as  
unfounded. With appeal after communication.  
Procedural status of the case: Merits  
Deadline: --  
20. File no. 4988/2/2023 - Bucharest Court of Appeal  
Parties: CONPET defendant  
N.A.M.R. -defendant  
OMV Petrom SA- claimant  
Subject matter: The court is requested that, through the decision that will be pronounced, it  
orders:  
1. The partial annulment of art. 1 and art. 3 of the Addenda no. 10, no. 11 and no. 13, respectively  
of art. 1 and 4 of the Addendum no. 12, by which the duration of the transport contract was  
extended for the period 01.09.2022 - 31.12.2022 with the application of the new tariffs approved  
by the Order 229/2021, within the limit of the amount of the tariffs that will be established as legal  
following the administrative litigation proceedings carried out by the Company regarding tariffs  
with N.A.M.R. and, as a consequence,  
2. Obliging CONPET to pay the Company, by way of compensation as a result of the partial  
cancellation of the Addenda no. 10-13, but also of its illegal act of providing erroneous data that  
formed the basis of the tariff development process by N.A.M.R. based on the Order no. 229/2021  
and then upon their payment by the Company based on the Addenda, of the amounts  
representing:  
i. the difference between the amount of the tariffs provided for in the Addendum no. 2 to the  
transport contract, concluded as a result of the new tariffs adopted by the Order 229/2021, paid  
by the Company in the period 01.09.2022 - 31.12.2022, as a result of the extension of the  
contractual period by the Addenda no. 10-13 and the amount of the tariffs that will be established  
as legal following the administrative litigation proceedings carried out by the Company regarding  
them with N.A.M.R., updated according to the inflation index, as well as the related legal interest  
calculated from the date of payment of the tariff difference;  
ii. the difference between the amount of tariffs paid by the Company for the transport of crude oil,  
through the domestic subsystem, from the Midia Terminal, and the amount of the tariffs  
established proportionally, by reference to the domestic and import tariffs according to the  
subsystem actually used for the transport of marine crude oil, updated according to the index of  
inflation, as well as the related legal interest calculated from the date of payment of the tariff  
difference, for the following quantities transported from the Midia Terminal and for which the tariff  
for the country subsystem was illegally calculated and paid;  
-12,213 tons from art. 2 letter a) from the Addendum no. 10 for September 2022;  
-12,411 tons from art. 2 letter a) from the Addendum no. 11 for October 2022;  
-11,836 tons from art. 2 letter a) from the Addendum no. 12 for November 2022;  
-12,048 tons from art. 2 letter a) from the Addendum no. 13 for December 2022.  
iii. any other amounts representing natural fruits that Conpet acquired or could have acquired in  
connection with the amounts illegally charged from the Company based on the tariffs;  
3. Ordering the defendants to pay legal expenses.  
Clarifications: By the Conclusion of 15.11.2023, the Bucharest Court of Appeal ordered the  
suspension of the trial of this case until the final resolution of the case which is the subject matter  
of the file no. 7035/2/2022 of the Bucharest Court of Appeal. With the right of appeal for the entire  
duration of the suspension, which is submitted to the Bucharest Court of Appeal.  
Procedural status of the case: Merits - Suspended  
Deadline: --  
21. File no. 5559/2/2023 - Bucharest Court of Appeal  
Parties: CONPET - defendant  
N.A.M.R. -defendant  
OMV Petrom SA-claimant  
Subject matter: The court is requested that, by the judgment that will be pronounced, it orders:  
1. The partial annulment of art. 1 of the Order no. 364/2022 regarding the tariffs established in  
Annex 1 and Annex 3 and, accordingly, Annexes 1 and 3 of the Order no. 364/2022, regarding  
the tariffs for the DOMESTIC subsystem and the IMPORT subsystem, within the limit of the  
amount of tariffs that will be established as legal as a result of their recalculation in a transparent  
and non-discriminatory manner, in accordance with the constitutional provisions and those of the  
legislation primary and secondary oil and competition, as they are exposed through the present  
summons;  
2. Ordering the defendants to pay legal expenses.  
Clarifications: By the Decision of 18.04.2024, the Bucharest Court of Appeal rejects the  
connectedness challenge, as unfounded. It suspends the trial of the case until the final resolution  
of the file pending before the Bucharest Court of Appeal, Division IX of Administrative and Fiscal  
Litigation under no. 5971/2/2022. With appeal during the suspension.  
Procedural status of the case: Merits - suspended  
Deadline: --  
22. File no. 19571/233/2023 Galati Court  
Parties: Conpet SA respondent  
Drăgan Gheorghe – appellant  
Subject matter: Appeal against enforcement. Drăgan Gheorghe filed an appeal requesting the  
court:  
1. To find that the right to request foreclosure based on the enforceable title has been prescribed  
the Criminal sentence no. 212/29.11.2013 pronounced in the file no. 2037/116/2013 of the  
Calarasi Court approved by the Decision no. 480/1/03.12.2015, based on art. 706 of 1 of the Code  
of Civil Procedure and by way of consequence, to order the cancellation of the foreclosure and of  
all the execution acts carried out in the execution file no. 480/VVI/2015 registered on behalf of  
B.E.J.A. Tudorie Stefan&Vicentiu Vasiliu, pursuant to art. 703 of the Code of Civil Procedure.  
2. To find that the foreclosure started in the execution file no. 480/VVI/2015 registered on behalf  
of B.E.J.A. Tudorie Stefan&Vicentiu Vasiliu is obsolete.  
3. Obligation of the creditor Conpet S.A. to the payment of the legal expenses caused by this  
litigation  
Clarifications: By the Decision no. 414/26.06.2024, the Galați Courthouse admits, in part, the  
exception of lateness invoked in the response. It rejects the enforcement appeal as late for the  
reasons regarding the limitation of the creditor's right to request foreclosure and the limitation of  
foreclosure. It rejects, in the remainder, the exception of lateness as unfounded. It rejects, in the  
remainder, the enforcement appeal as unfounded. It obliges the appellant to pay the amount of  
RON 264 to B.E.J. Vicențiu Vasiliu Corneliu, representing the equivalent value of the copy of the  
enforcement file no. 480/2015.  
The appellant Drăgan Gheorghe filed an appeal.  
Procedural status of the case: Appeal  
Deadline: --  
23. File no. 22795/281/2023 Ploiesti Court  
Parties: Conpet SA defendant  
Andex Import Export claimant  
Subject matter: The claimant Andex Import Export S.R.L. filed an application for damages with  
the defendant Conpet S.A., requesting the court that, by the judgment it will pronounce, order the  
defendant to pay the claimant the amount of RON 22,704.89 with legal expenses occurred in this  
file.  
Clarifications: By the Conclusion of 27.11.2023, the Ploiesti Courthouse cancels the summons  
request. Andex Import Export filed a request for re-examination, which was the subject matter of  
the file no. 22795/281/2023/a1 pending before the Ploiești Courthouse.  
By the Conclusion no. 118/18.01.2024 pronounced in the file no. 22795/281/2023/a1 the Ploiești  
Courthouse admits the request made by the claimant Andex Import Export S.R.L.. It rectifies the  
decision of cancellation of the request ordered by the Conclusion of 27.11.2023, pronounced in  
the file no. 22795/281/2023 and orders the submission of the file to the initially invested panel  
with the resolution of the application.  
By the Sentence no. 6865/04.07.2024, the Ploiești Courthouse rejects the plea of res judicata  
invoked by the defendant in the response, as unfounded. It admits the request for summons. It  
obliges the defendant to pay the claimant the amount of RON 22,704.89, as an unpaid payment.  
Conpet S.A. filed an appeal.  
Procedural status of the case: Appeal  
Deadline: 18.09.2025  
24. File no. 8213/2/2023 - Bucharest Court of Appeal  
Parties: CONPET - defendant  
N.A.M.R. -defendant  
OMV Petrom SA-claimant  
Subject matter: The court is requested that, by the judgment that will be pronounced, it orders:  
1. The partial annulment of art. 1 and art. 3 of the Addendum no. 14, of art. 1 and 4 of the Addenda  
no. 15, no. 16, no. 17, respectively of art. 1 and 5 of the Addendum no. 18 by which the duration  
of the Transport Contract was successively extended for the period 01.01.2023 - 31.12.2023, with  
the application of the new tariffs mentioned in the Notification no. 811/06, 01.2023 sent by Conpet  
regarding the change in transport tariffs through the National System for the Transport of Crude  
Oil, Rich Gas, Condensate and Ethane ("SNT") starting from January 1, 2023, based on the Order  
364/2022 (Annex 4), within the limit of the amount of the tariffs that will be established as legal as  
a result of the administration of evidence from this case;  
2. The partial annulment of art. 2 of the Addenda no. 14-18 in the sense of:  
i. the elimination of the quantities of 5-417 tons mentioned in the content of art. 2 letter a) from  
the Addendum no. 14 for the period January 1-15, 2023 that were transported from the Midia  
Terminal from the quantities transported through the domestic subsystem and the inclusion of the  
first quantities in those in point b) of the same article regarding the quantities transported through  
the import subsystem;  
ii. the elimination of the quantities of 15,061 tons from art. 2 letter a) from the Addendum no. 15  
for the period January 16 - February 28, 2023 transported from the Midia Terminal from the  
quantities transported through the domestic subsystem and the inclusion of the first quantities in  
those in point b) of the same article regarding the quantities transported through the import  
subsystem;  
iii. the elimination of the quantities of 40,859 tons from art. 2 letter a) from the Addendum no. 16  
for the period March 1 - June 30, 2023 transported from the Midia Terminal from the quantities  
transported through the domestic subsystem and the inclusion of the first quantities in those in  
point b) of the same article regarding the quantities transported through the import subsystem;  
iv. the elimination of the quantities of 28,811 tons mentioned in the content of art. 2 letter a) from  
the Addendum no. 17 for the period July 1 - September 30, 2023 transported from the Midia  
Terminal from the quantities transported through the domestic subsystem and the inclusion of the  
first quantities in those in point b) of the same article regarding the quantities transported through  
the import subsystem;  
v. the elimination of the quantities of 28,898 tons mentioned in the content of art. 2 letter a) from  
the Addendum no. 18 for the period October 1 - December 31, 2023 transported from the Midia  
Terminal from the quantities transported through the domestic subsystem and the inclusion of the  
first quantities in those in point b) of the same article regarding the quantities transported through  
the import subsystem;  
3. Obliging Conpet to pay the Company, in the form of compensation - as a result of the partial  
cancellation of the Addenda, but also of its illegal act of providing erroneous data that was the  
basis of the tariff development process by N.A.M.R. based on the Order no. 364/2022 and then  
upon their payment by the Company based on the Addenda, of the amounts representing:  
i. the difference between the amount of the tariffs provided for in the Additional Acts no. 14 -18 to  
the Transport Contract concluded as a result of the new tariffs adopted by the Order no. 364/2022,  
paid by the Company in the period 01.01.2023 - 31.12.2023 and the amount of tariffs that will be  
established as legal following the administrative litigation proceedings carried out by the Company  
regarding them with N.A.M.R., updated according to the inflation index, as and the related legal  
interest calculated from the date of payment of the tariff difference;  
ii. the difference between the amount of tariffs paid by the Company for the transport of crude oil,  
through the country subsystem, from the Midia Terminal, and the amount of the tariffs set  
proportionally, by reference to the domestic and import tariffs according to the subsystem actually  
used for the transport of marine crude oil, updated according to the index of inflation, as well as  
the related legal interest calculated from the date of payment of the tariff difference, for the  
following quantities transported from the Midia Terminal and for which the tariff for the domestic  
subsystem was illegally calculated and paid:  
- 5417 tons from art. 2 letter a) from the Addendum no. 14 for the period January 1 - 15, 2023;  
- 15,061 tons from art. 2 letter a) from the Addendum no. 15 for the period January 16- February  
28, 2023;  
- 40,859 tons from art. 2 letter a) from the Addendum no. 16 for the period March 1 - June 30,  
2023;  
- 28,811 tons from art. 2 letter a) from the Addendum no. 17 for the period July 1 - September  
30, 2023;  
- 28,898 tons from art. 2 letter a) from the Addendum no. 18 for the period October 1-December  
31, 2023;  
iii. any other amounts representing natural fruits that Conpet acquired or could have acquired in  
connection with the amounts illegally charged from the Company based on the tariffs;  
4. Ordering the defendants to pay legal expenses.  
Clarifications: By the decision no. 775/26.04.2024, it admits the motion to dismiss for lack of  
jurisdiction. It declines the jurisdiction to resolve the case in favor of the Bucharest Court of  
Appeal, Administrative and Fiscal Litigation Division.  
By the Decision no. 6402/01.10.2024, the Bucharest Court of Appeal admits the motion to  
dismiss for lack of jurisdiction. It declines the jurisdiction to resolve the application in favor of the  
Bucharest Court of Appeal Division VIII, Administrative and Fiscal Litigation. It finds that a  
negative conflict of jurisdiction has arisen. It forwards the file to the High Court of Cassation and  
Justice for the resolution of the negative conflict of jurisdiction.  
By the Decision no. 5860/06.12.2024, the HCCJ establishes the jurisdiction to resolve the case  
concerning the claimant OMV Petrom S.A. and the defendants Conpet S.A., the National  
Regulatory Authority for Mining, Petroleum and Geological Storage of Carbon Dioxide and the  
National Agency for Mineral Resources in favor of the Bucharest Court of Appeal.  
By the Conclusion of 11.03.2025, the Bucharest Court of Appeal suspends the trial of the case  
until the final resolution of file no. 5559/2/2023 of the Bucharest Court of Appeal.  
Procedural status of the case: Merits - Suspended  
Deadline: --  
25. File no. 23148/302/2023 Bucharest Court  
Parties: Conpet S.A. creditor  
Simion Constantin debtor  
Revolut UAB Vilnius Bucharest Branch third party garnishee  
Subject matter: Validation of garnishment  
Clarifications: By the Sentence no. 6639/10.07.2024, the Bucharest District 6 Courthouse  
admits the request for validation of the garnishment. It validates the garnishment established by  
the address dated 27.07.2023 by the Bailiff's Office Raduta Nicoleta in the foreclosure file no.  
208/2015. It obliges the third party garnishee Revolut Bank UAB Vilnius - Bucharest branch to  
pay the creditor Conpet S.A. the amounts due to the debtor starting with the date of  
communication of the address establishing the garnishment, as well as those due thereafter,  
monthly, on the due date, within the limits provided for by art. 729 of the Code for Civil Procedure,  
up to the amount of RON 55997.82. It rejects as unfounded the debtor's request to oblige the  
creditor to pay the legal expenses.  
Revolut UAB Vilnius Bucharest Branch has filed an appeal.  
Procedural status of the case: Appeal  
Deadline: 19.03.2025  
26. File no. 1065/105/2024 Prahova Court  
Parties: Conpet S.A. respondent  
Dudu Florentin appellant  
Subject matter: Dudu Florentin files an appeal against the sanctioning decision no.  
85/07.02.2024 by which he was sanctioned with a reduction in his basic salary for a period of 2  
months by 10%. The claimant requests the admission of the appeal and the annulment of the  
sanctioning decision no. 85/07.02.2024, the obligation of the defendant to pay the full amount  
withheld based on the decision and legal expenses representing the attorney's fees.  
Procedural status of the case: Merits  
Clarifications: --  
Deadline: 18.03.2025  
27. File no. 2715/109/2024 – Argeș Court  
Parties: Conpet S.A. defendant  
Dincă Ioan – claimant  
Subject matter: Dincă Ioan files an appeal against the measure of termination of the individual  
employment contract ordered by the Dismissal Decision no. 140/01.03.2024 and requests the  
court to:  
I. Admit the appeal filed against the Dismissal Decision for reasons not attributable to the  
employee and, consequently:  
1. Annul the Decision for reasons of illegality  
2. Annul the Decision for reasons of unfoundedness  
II. Reinstatement to the previous situation and, consequently, reinstatement to the position held  
prior to the issuance of the decision  
III. In all the previously mentioned cases, order Conpet to pay compensation equal to the indexed,  
increased and updated salaries and the other rights that he would have benefited from the  
moment of dismissal until the effective reinstatement  
IV. Order Conpet S.A. to pay the legal expenses consisting of attorney's fees.  
Clarifications: By the Sentence no. 854/11.03.2025, the Argeș Court rejects the appeal. With  
the right to appeal within 10 days from communication.  
Procedural status of the case: Merits  
Deadline: --  
28. File no. 5071/2/2024 - Bucharest Court of Appeal  
Parties: OMV Petrom S.A.-claimant  
National Regulatory Agency for Mining, Petroleum and Geological Storage of Carbon Dioxide-  
A.N.R.M.P.S.G. (formerly N.A.M.R.) -defendant  
Conpet S.A.-defendant  
Subject matter: The court is requested to order by the decision to be issued:  
1. Partial annulment of art. 1 of Order no. 340/2023 regarding the tariffs established in Annex 1  
and Annex 3 and, accordingly, of Annexes 1 and 3 of Order no. 340/2023, regarding the tariffs for  
the Country subsystem and the Import subsystem, within the limit of the amount of the tariffs that  
will be established as legal as a result of their recalculation in a transparent and non-discriminatory  
manner, in accordance with the constitutional provisions and those of the primary and secondary  
petroleum and competition legislation, as they are set out in this application for summons;  
2. Ordering the defendants to pay the legal expenses.  
Clarifications: By the Decision of 29.11.2024, the Bucharest Court of Appeal suspends the trial  
of the case until the final resolution of file no. 5971/2/2022 pending before the Bucharest Court of  
Appeal. With the right of appeal for the entire period of suspension.  
Procedural status of the case: Merits  
Deadline: --  
29. File no. 22451/212/2024 - Constanța Courthouse  
Parties: Conpet respondent  
Polifroni Dimu appellant  
The Bailiff's Office Menaef Cristian respondent  
Constanța County Pension Fund – respondent  
Subject matter: Polifroni Dimu filed an appeal against the enforcement requesting the annulment  
of the enforcement acts carried out by The Bailiff's Office Menaef Cristian in the enforcement file  
no. 52/2019 regarding the Civil Sentence no. 44/13.01.2017 pronounced by the Constanța  
Courthouse, Criminal Division in the file no. 15042/212/2015 modified and made final by the  
Criminal Decision no. 368/P/23.03.2018 pronounced in the same case by the Constanța Court of  
Appeal, Criminal Division and for criminal cases involving minors and family matters.  
Clarifications: --  
Procedural status of the case: Merits  
Deadline: Ruling postponed to 20.03.2025  
30. File no. 4936/95/2024 - Gorj Court  
Parties: Conpet S.A. defendant  
Pencea Dorina claimant  
Subject matter: Pencea Dorina requested through the court that Conpet be obliged to issue a  
certificate showing the gross salaries obtained during the period in which she was employed, the  
bonuses of any nature obtained, the indemnities, all salary rights, the overtime worked, with the  
express mention whether the C.A.S. was calculated, withheld and transferred to the value of the  
gross salaries, as they were mentioned in the payroll or to the entire payroll fund.  
Clarifications: --  
Procedural status of the case: Merits  
Deadline: 18.09.2025  
31. File no. 5714/118/2024/a1 - Constanța Court  
Parties: Conpet respondent  
COMTEH S.R.L. respondent debtor  
Subject matter: Conpet filed a response to the appeal filed by the appellant COMTEH S.R.L.  
formulated on the Preliminary List of Creditors against the assets of the debtor COMTEH S.R.L.,  
published in the Bulletin of Insolvency Proceedings, Legal Persons Section no. 20379 dated  
14.11.2024, through which the debtor requests the removal from the list of the unsecured debt of  
RON 11,132.43, held by Conpet S.A. and registered on the list of creditors, representing late  
payment penalties arising from the late execution of the intervention obligation established in art.  
4.3 of the contract concluded with it no. S-CA133/20.04.2020.  
Conpet S.A. requests the rejection of the appeal filed by the appellant COMTEH S.R.L. as  
unfounded and ungrounded, the maintenance in the preliminary list of creditors against the assets  
of the debtor COMTEH S.R.L. of the unsecured debt of RON 11,132.43, held by Conpet S.A.,  
representing late payment penalties calculated according to the contract concluded with the  
debtor no. S-CA133/20.04.2020, entered on the list by the judicial administrator "under  
suspensive condition until the presentation of the tax invoice for accessories and until the  
presentation of proof of execution/non-execution of the good execution guarantee".  
Clarifications: --  
Procedural status of the case: Merits  
Deadline: 16.04.2025  
32. File no. 8081/2/2024 - Bucharest Court of Appeal  
Parties: OMV Petrom S.A. -claimant  
CONPET S.A. -Defendant  
National Regulatory Agency for Mining, Petroleum and Geological Storage of Carbon Dioxide-  
A.N.R.M.P.S.G. (formerly N.A.M.R.) -Defendant  
Subject matter: Request for summons against Addendum no. 19 of 22.12.2023 and Addendum  
no. 20 of 19.03.2024 to the Contract for the transport of crude oil, rich gas and condensate no.  
BC OMV 108/25.03.2020 concluded between OMV Petrom S.A. and Conpet S.A..  
The court is requested to order, by the decision to be rendered:  
1. Partial annulment of art. 3 of Addendum no. 19, as well as art. 1 and 4 of Addendum no. 20,  
by which the duration of the Transport Contract was extended monthly, successively, for the  
periods 01.01.2024 - 31.03.2024 and, respectively, for 01.04.2024 - 30.06.2024, regarding the  
tariffs established by N.A.M.R. Order no. 340/2023 regarding the approval of transport tariffs  
through the National Transport System for crude oil, rich gas, condensate and ethane ("Order  
340/2023", Annex 3), within the limit of the amount of the tariffs that will be established as legal,  
as a result of the administration of the evidence in this case;  
2. Partial annulment of art. 2 of Addenda no. 19-20, in the sense of:  
(i) the elimination of the quantities of 28,163 tons, mentioned in art. 2 letter a) of Addendum no.  
19, for the period 01.01.2024 31.03.2024, transported from the Midia Terminal from the  
quantities transported through the Domestic subsystem and the inclusion of the former quantities  
in those in point b) of the same article relating to the quantities transported through the Import  
subsystem;  
(ii) the elimination of the quantities of 23,881 tons, mentioned in art. 2 letter a) of Addendum no.  
20, for the period 01.04.2024 - 30.06.2024, transported from the Midia Terminal from the  
quantities transported through the Domestic subsystem and the inclusion of the first quantities in  
those in point b) of the same article relating to the quantities transported through the Import  
subsystem,  
3. Obliging Conpet to pay to the Company, as compensation as a result of the partial annulment  
of the Addenda, but also of its unlawful act of providing erroneous data that formed the basis of  
the tariff development process by N.A.M.R. based on the Order no. 340/2023 and then upon their  
payment by the Company based on the Addenda, the amounts representing:  
(i) the difference between the amount of the tariffs provided for in Addenda no. 19 -20 to the  
Transport Contract concluded as a result of the new tariffs adopted by the Order no. 340/2023,  
paid by the Company during the period 01.01.2024 30.06.2024 and the amount of the tariffs  
that will be established as legal following the administrative litigation proceedings carried out by  
the Company regarding them with N.A.M.R., updated according to the inflation index, as well as  
the related legal interest calculated from the date of payment of the tariff difference;  
(ii) the difference between the amount of tariffs paid by the Company for the transport of crude  
oil, through the Domestic subsystem, from the Midia Terminal, and the amount of tariffs  
established proportionally, by reference to the Domestic and Import tariffs depending on the  
subsystem actually used for the transport of marine crude oil, updated according to the inflation  
index, as well as the related legal interest calculated from the date of payment of the tariff  
difference, for the following quantities transported from the Midia Terminal and for which the tariff  
for the Country subsystem was illegally calculated and paid:  
- 28,163 tons from art. 2 letter a) of Addendum no. 19 for the period 01.01.2024 - 31.03.2024;  
- 23,881 tons from art. 2 letter a) of Addendum no. 20 for the period 01.04.2024 - 30.06.2024;  
(iii) any other amounts representing civil fruits that Conpet has acquired or could have acquired  
in connection with the amounts illegally collected from the Company based on the tariffs;  
4. Ordering the defendants to pay the legal expenses.  
Clarifications: --  
Procedural status of the case: Merits  
Deadline: --  
c) The list of files pending before Courts on 14.03.2025 in which the company CONPET  
S.A. has double status  
1. File no. 2323/120/2018* Ploiesti Court of Appeal  
Parties: Conpet SA - defendant - counterclaimant  
Buzatu Florin - claimant - defendant  
Subject matter: Buzatu Florin files a request for a summons requesting the court:  
1. To oblige the defendant Conpet S.A. to pay the claimant the amount of EUR 150,000, payable  
at the N.B.R. exchange rate on the day of payment (amount to be revalued on completion of the  
real estate assessment expertise report to be carried out in the probation case, to be resized and  
specified the value of the claims, corroborated with the appropriate adjustment of stamp duties),  
representing fair and equitable compensation for the damage suffered by restricting the possibility  
of exercising its property right over the land area of 5980 sq. m. located in the built-up area of  
Slobozia Moară locality, Dâmbovița county, with cadastral number 70618, registered in the land  
book 70618 / ATU Slobozia Moară Dâmbovița county, on which are the underground gas  
pipelines and above-ground devices owned by the defendant, a land which cannot be used for  
building;  
2. To oblige the defendant Conpet SA to pay a monthly indemnity of EUR 1,000 payable at the  
N.B.R. exchange rate on the day of payment, starting with the date of the sentence, throughout  
the existence of underground pipelines and above-ground devices, buildings on the land owned  
by the claimant and to bear all the costs incurred by the claimant for the stages prior to the  
construction permit;  
3. In the alternative, claims that the defendant should remove all the buildings built on the  
claimant's property, namely the gas pipelines and the above-ground devices, to restore the land  
to its original condition or to enable the claimant to carry out the obligation to do so, at the  
defendant's sole expense;  
4. To order the defendant Conpet S.A. to pay the legal expenses incurred in the present legal  
proceedings.  
Conpet filed a counterclaim requesting the obligation of the claimants to allow our company to  
exercise the right of legal easement established by the provisions of art. 7 et seq. of Law no.  
238/2004 and the establishment of the amount of the annual rent provided by law due by Conpet  
to the claimants in exchange for exercising the right of legal easement.  
Clarifications: By the Decision 602/10.03.2022 The Dâmbovița Court rejects the exception of  
the lack of passive procedural capacity of the defendant-claimant Conpet S.A. as regards the  
claims for compensation and indemnity raised by it. It admits the claimant Conpet S.A.'s lack of  
passive procedural capacity. As regards the head of claim concerning the obligation to raise the  
above-ground pipes and devices and to restore the land to its original condition or to empower  
the applicant to do so, invoked by it and consequently rejects that head of claim in contradiction  
with the defendant-claimant Conpet S.A. as being formulated against a person without passive  
procedural capacity. It admits in part the summons. It admits in part the counterclaim. It obliges  
the defendant claimant to demolish the construction without authorization (foundation) existing on  
the land belonging to him, with no. cadastral 70618, registered in the land book no. 70618 of the  
Slobozia Moară ATU, Dâmbovița county, identified according to the sketch drawn up in the  
expertise report in the topography specialty dated 04.11.2019 (f. 300 vol. I). It establishes the  
amount of the annual rent due by the claimant defendant to the defendant claimant for exercising  
the right of legal easement on the land with an area of 890 sq m related to crude oil pipelines Ø  
143/4 and Ø 123/4, identified according to the sketch prepared in the expertise report of  
02.11.2019 (f. 357 vol. I), at the amount of RON 284.8 and obliges the claimant defendant to pay  
it to the defendant claimant starting with the date of the finality of the present sentence. It  
dismisses the remainder of the action and the counterclaim. It rejects the request to show the  
right holder formulated by the claimant defendant in contradiction with the Romanian State,  
through the Ministry of Public Finance and the National Agency for Mineral Resources. It orders  
the refund to the claimant defendant of the stamp duty paid and not owed in the amount of RON  
1,143.4. It compensates the expenses up to the amount of RON 1,172.7 and obliges the  
defendant claimant to pay to the claimant defendant the uncompensated difference of RON 836  
legal expenses.  
Buzatu Florin filed an appeal.  
By the Decision no. 482/09.03.2023 The Ploiesti Court of Appeal rejects the appeal as  
unfounded.  
Buzatu Florin filed an appeal.  
By the Decision of 11.04.2024, the High Court of Cassation and Justice rejects the exception of  
the nullity of the appeal, invoked by the respondent-intervening National Agency for Mineral  
Resources. It admits, in principle, the appeal filed by the appellant-claimant Buzatu Florin.  
By the Decision of 28.05.2024, the High Court of Cassation and Justice admits the appeal filed  
by the appellant-claimant Buzatu Florin. It quashes the contested decision and sends the case  
for a new trial, to the same appellate court.  
By the Decision no. 106/30.01.2025, the Ploiești Court of Appeal admits the appeal. It partially  
changes the appealed sentence in the sense that: it establishes the amount of the annual rent  
owed by the defendant-claimant to the defendant-claimant for the exercise of the right of legal  
easement over the land with an area of 5,696 sq.m. in the amount of RON 1,217.2 and obliges  
the defendant claimant to pay it to the defendant claimant starting from the date of the finality of  
the present sentence; compensates the legal expenses within the limit of the amount of RON  
2,008.7 and obliges the defendant claimant to pay the uncompensated difference of RON  
2,088.79 as legal expenses to the defendant claimant. It maintains the rest of the provisions of  
the appealed sentence. It obliges the respondent to pay the legal expenses in the amount of RON  
3,615.09 (RON 45.09 judicial stamp duty and RON 3,570 defense fee). With appeal after  
communication.  
Procedural status of the case: Appeal retrial  
Deadline: --  
2. File no. 1657/91/2020* - Vrancea Court  
Parties: Vasile Maria Ilaria - at S.C.P.A. Buruian, Caracaş and Associates - Claimant  
Dragu Georgeta - the S.C.P.A. Buruian, Caracaş and Associates - Claimant  
Conpet SA Ploieşti - Defendant  
Romanian State - through the Ministry of Public Finance - Defendant  
National Agency for Mineral Resources - Defendant  
Subject matter: By their summons, the claimants Vasile Maria-Ilaria and Dragu Georgeta  
requested to the court (we copy the petition for the summons) to:  
A. In particular, order the defendant to pay an annual rent of EUR 496.64 for the protection area  
of the pipeline belonging to the defendant and which crosses the building privately owned by the  
undersigned, as of the date of registration of this summons;  
B. In particular, order the defendant to pay a lump sum of EUR 508,080 in respect of the attribution  
of the use of the property according to its intended purpose, namely that the undersigned may  
not build buildings on the privately owned building;  
C. In particular, order the defendant to pay legal interest on the annual rent provided for in point  
A, from the date of registration of the present summons;  
D. In particular, order the defendant to pay legal interest for the lump sum compensation provided  
for in point B, from the date of registration of the present summons;  
E. In the alternative, we request you to order the other two defendants to pay the amounts  
indicated in the preceding paragraphs."  
Conpet filed a counterclaim in this case, requesting the court:  
1. To order the claimants Vasile Maria - Ilaria, Dragu Georgeta and Dragu Maria to allow CONPET  
S.A. the exercise of the right of legal easement established by the provisions of art. 7 et seq. of  
Law no. 238/2004 on the land owned by them, located in Focșani city, Vrancea County. The  
exercise of the right of legal easement is to be done on a 2.4 meter wide corridor located along  
the crude oil transport pipeline Ø 20˝ Bărăganu - Borzești / Rafo Onești, for the purpose of  
permanent access to the pipeline in order to daily check the condition of the pipeline and the  
execution of accidental and planned repair works. The exercise of the right of easement is to be  
carried out throughout the existence of the pipeline located on the claimants' land but not later  
than the date of termination of the oil concession agreement concluded by us, the undersigned  
CONPET S.A., with the Romanian State.  
2. To establish the amount of the annual rent provided by law due by us, the undersigned  
CONPET SA, to the claimants Vasile Maria - Ilaria, Dragu Georgeta and Dragu Maria in exchange  
for exercising the right of legal easement, rent consisting in the equivalent value of the annual  
land use affected by the exercise of the legal easement.  
Clarifications: --  
Procedural status of the case: Merits  
Deadline: 20.05.2025  
3. File no. 32294/299/2020 - Bucharest District 1 Courthouse  
Parties: Conpet SA - defendant - counterclaimant  
Bob Mihăiță - claimant-defendant  
N.A.M.R. - defendant  
Subject matter: Bob Mihăiță files a summons requesting the court to order:  
1. The obligation of Conpet SA and N.A.M.R. to move the crude oil pipeline crossing the land  
owned by the claimant located in Cernavoda, plot 1, plot A6 / 2, Constanța county;  
2. The establishing the equivalent value of the lack of use, for a period of three years, prior to the  
formulation of the summons, amounting to RON 150,000;  
3. In the alternative, the obligation of Conpet SA to pay an annual rent for the use of the land  
owned by the claimant, from the date of filing the summons, in the amount of EUR 5/sq. m./year  
for the area of 14,645 sq. m., land affected by the protection and safety area, during the existence  
of legal easement;  
4. The payment of legal expenses.  
By the request for clarification of the summons, the claimant stated the following:  
„................................................. .................................................. ................................................  
3. For the method of calculating the amount of RON 150,000, I indicated the value of a rent,  
estimated at RON 4,166 /month, for a period of three years prior to the formulation of the  
summons, which the defendants in the present case should pay as compensation for the damage  
suffered as a result of the impossibility of capitalizing the land crossed by their pipelines  
4. We request, in the alternative, that the defendant SC Conpet SA be obliged to pay an annual  
rent for the use of the land personally owned by the undersigned, from the date of filing the  
summons, during the existence of the legal easement, until the lifting of the pipelines on the land  
of the undersigned.  
5. The value of the 3rd head of the claim is RON 10,000, estimated value, following that, after  
performing the report of forensic technical expertise, the real estate assessment specialty,  
performed in question to stamp according to the value of the land related to the protection and  
safety area of the construction.  
6. I request that the court oblige the defendant Conpet SA to pay all the compensations requested  
in the summons, and the defendant the National Agency for Mineral Resources to be obliged to  
move / decommission the oil pipelines on the land owned by the undersigned.  
.................................................. .................................................. ............................................... “  
Conpet filed a counterclaim seeking the following from the court:  
1. To order the claimant to allow Conpet S.A. the exercise of the right of legal easement  
established by the provisions of art. 7 et seq. of Law no. 238/2004 on the land owned by the  
claimant Bob Mihăiță located in Cernavoda, plot 1, plot A6 / 2, Constanța County. The exercise  
of the right of legal easement is to be carried out on a 2.4 meter wide corridor located along each  
of the main crude oil transport pipelines that under-cross the claimant's land, respectively the F1  
main crude oil transport pipeline Ø 14¾ ", F2 main crude oil transport pipeline Ø 20 ", and Pipeline  
28 Constanța - Bărăganu of crude oil transport Ø 28", for the purpose of permanent access to  
pipelines for daily verification of the condition of pipelines and execution of possible repair works.  
The exercise of the right of legal easement is to be carried out throughout the existence of the  
pipelines located on the land of the claimant, but no later than the date of termination of the oil  
concession agreement concluded by us, the undersigned Conpet SA, with the Romanian State;  
2. To establish the amount of the annual rent provided by law due by us, the undersigned, to the  
claimant in exchange for exercising the right of legal easement.  
Clarifications: By the Conclusion of 06.08.2021, the Bucharest District 1 Courthouse rejects  
the exception of the belatedly of the request for impleader and of the request for showing the right  
holder, invoked by the National Agency for Mineral Resources, as unfounded. It rejects the  
exception of the lack of representative capacity of the National Agency for Mineral Resources,  
invoked ex officio, as unfounded. It rejects the request for an impleader from the Romanian State,  
through the Ministry of Finance and the National Agency for Mineral Resources, as inadmissible  
in principle. It rejects the request to show the right holder of the Romanian State, through the  
Ministry of Finance and the National Agency for Mineral Resources, as inadmissible in principle.  
The conclusion can be appealed with the merits.  
Procedural status of the case: Merits  
Deadline: 13.05.2025  
4. File no. 1541/262/2023 Dambovita Court  
Parties: Conpet S.A. defendant- respondent  
Mapi Imobiliare S.R.L. claimant-defendant  
Subject matter: obliging Conpet S.A. to pay an annual rent according to art. 7 of Law no.  
238/2004 and compensations, including for the past starting from 20.01.2023  
Conpet filed a counterclaim in which it requested the following from the court:  
1. the obligation of the claimant Mapi Imobiliare S.R.L. to allow the company CONPET S.A. the  
exercise of the right of legal easement established by the provisions of art. 7 et seq. from Law no.  
238/2004 on the land owned by it, located in Ocnița commune, Ochiuri village, T91, P2/1,  
Dâmbovița county. The exercise of the right of legal easement is to be done on a 2.4 meter wide  
corridor located along the main Ø 6 5/8" Ochiuri-Moreni crude oil transport pipeline for the purpose  
of permanent access to the pipeline in order to daily check the condition of the pipeline and the  
execution of any repair works. The exercise of the right of easement is to be carried out for the  
entire duration of the existence of the pipeline located on the claimant's land, but no later than the  
date of termination of the oil concession agreement concluded by us, the undersigned Conpet  
S.A., with the Romanian State.  
2. establishing the amount of the annual rent provided by law owed by us, the undersigned Conpet  
S.A., to the claimant Mapi Imobiliare S.R.L. in exchange for the exercise of the right of legal  
easement starting from the date of finality of the judgment pronounced in this case, rent consisting  
of the value of the annual use of the land affected by the exercise of the easement.  
At the same time, Conpet filed an impleader for the Romanian State, represented by the Ministry  
of Public Finance and the National Agency for Mineral Resources, through which we requested  
the court to be compensated for the impleaders, which will answer jointly and severally for any  
amounts we will be obliged to pay the claimant Mapi Imobiliare S.R.L. in the situation where the  
summons filed by it will be admitted in whole or in part.  
Clarifications: By the Sentence no. 885/22.10.2024, the Moreni Courthouse rejects, as  
unfounded, the exception of the lack of passive procedural quality of the defendant-claimant  
Conpet S.A. with regard to the claims for compensation and rent, invoked by it. It rejects, as  
unfounded, the exception of ineligibility of the claim for summons to court of the defendant-  
claimant Conpet S.A. with regard to the claims for compensation and rent, invoked by it. It rejects  
the claim for summons in guarantee of the Romanian State represented by the Ministry of Public  
Finance and the National Agency for Mineral Resources. It rejects as unfounded the exception of  
the lack of passive procedural quality formulated by the National Agency for Mineral Resources.  
It admits in part the main claim formulated. It rejects as unfounded the counterclaim.  
Conpet has filed an appeal. Mapi Imobiliare S.R.L. has filed an appeal.  
Procedural status of the case: Appeal  
Deadline: --  
Annex no.7  
ARTICLES OF INCORPORATION  
of the Company “CONPET” S.A.  
CHAPTER I  
NAME, LEGAL FORM, HEADQUARTERS, DURATION  
Art. 1 Name of the Company  
(1) The company name is „CONPET” S.A. (herein-after called also the „company’).  
(2) In all documents, invoices, notices, publications and generally, in the company correspondence, the  
name thereof will be preceded or followed by the words „societate pe actiuni” (Eng. joint-stock  
company”) or by the initials „S.A.”, stating the headquarters, subscribed and paid-up share capital, tax  
registration number and Trade Registry number.  
Art. 2 Legal Form of the Company  
(1) „CONPET” S.A. is Romanian legal person, incorporated as a joint-stock company.  
(2) „CONPET” S.A. is a publicly held company.  
(3) The Company is operating in compliance with the provisions of this Articles of Incorporation, of Law  
no. 31/1990 regarding the companies, of GEO no. 109/2011 regarding the corporate governance of  
the public enterprises, of the Civil Code and of all other laws and regulations applicable to the  
companies.  
(4) The emblem (logo) of the company is made up by the joining of two elements: in the left side, the  
symbol and in the right side, the company name (logotype). The symbol represents a set made of two  
drops: a green one and a blue one; the green drop is pointing top right (1 o’clock), while the blue drop  
is pointing down left (7 o’clock). The company name - „CONPET” S.A. - is placed right of the  
symbol, has a proportional dimension in relation hereto, is written in block letters, Italic, and in the  
same color with the blue drop.  
Art. 3. The Company Headquarters  
(1) The company headquarters is in Romania, no. 1-3 Anul 1848 Street, Ploiesti city, Prahova county.  
The company headquarters may be changed to other locality from Romania, based on the Resolution  
of the Extraordinary General Meeting of Shareholders, as per the law.  
(2) The company may also incorporate and disincorporate other sub-units (secondary establishments,  
work sites, branches, agencies, representative agencies, or other types of sub-units with no legal  
personality), to be found in the same locality and/or in other localities, in the country or abroad, under  
the law and as per this Articles of Incorporation, by the approval of the Board of Directors. The  
secondary establishments (work sites) of the company are comprised in Annex 2 to the Articles of  
Incorporation.  
Art. 4 Company Duration  
The lifetime of the company is unlimited, starting the date of registration at the Trade Registry under no.  
J29/6/22.01.1991.  
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CHAPTER II  
SCOPE, OPERATING AREA AND CORE BUSINESS OF THE COMPANY  
Art. 5 Company Scope  
The company is the concessionaire of the National Crude Oil, Rich Gas and Liquid Ethane Transport  
activity, inclusive of the major pipelines and equipment, installation and facilities related to the System,  
quality acquired by the conclusion with NAMR, in 2002, of the Oil Concession Agreement approved  
pursuant to GD no. 793/2002.  
Art. 6 Main Business Area and Core Business of the Company  
(1) The main business area is „Transport via pipelines”- NACE Code 4950.  
(2) The core business of the company is „Transport via pipelines” - NACE Code 4950.  
Art. 7 Secondary Lines of Business  
0150 Activities in mixed farming (crop and animal production) 0910 Support activities for petroleum and  
natural gas extraction  
1011 Processing and preserving meat  
1012 Processing and preserving poultry meat  
1013 Production of meat, including poultry meat products  
1020 Processing and preserving fish, crustaceans and mollusks’  
1031 Processing and preserving potatoes  
1032 Manufacture of fruit and vegetable juice  
1039 Processing and preserving fruits and vegetables  
2529 Manufacture of tanks, cisterns and containers of metal  
2593 Manufacture of wire products, chains and springs  
3313 Repair of electronic and optical equipment  
3314 Repair of electrical equipment  
3319 Repair of other equipment  
3320 Installation of industrial machinery and equipment  
3511 Electricity production  
3513 Distribution of electricity  
3530 Steam and air conditioning supply  
3600 Water collection, treatment and supply  
3700 Wastewater collection and treatment  
3811 Collection of non-hazardous waste  
3821 Treatment and disposal of non-hazardous waste  
3900 Decontamination activities and services  
4321 Electrical installations works  
4322 Sanitary installations, heating and air conditioning works  
4329 Other construction installation  
4511 Sale of cars and light motor vehicles (< 3.5 tons)  
4519 Sale of other motor vehicles  
4520 Maintenance and repair of motor vehicles  
4671 Wholesale of solid, liquid and gaseous fuels and related products  
4676 Wholesale of other intermediate products  
4677 Wholesale of waste and scrap  
4690 Non-specialized wholesale trade  
4711 Retail sale in non-specialized stores, with predominant sale of food, beverages or tobacco  
4719 Retail sale in non-specialized stores with predominant sale of non-alimentary products  
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4721 Retail sale of fresh fruits and vegetables in specialized stores  
4722 Retail sale of meat and meat products in specialized stores  
4723 Retail sale of fish, crustaceans and mollusks in specialized stores  
4724 Retail sale of bread, cakes, flour and sugar confectionery in specialized stores  
4730 Retail sale of automotive fuel in specialized stores  
4920 Freight rail transport  
4939 Other passenger land transport n.e.c.  
4941 Freight transport by road  
5210 Warehousing and storage  
5221 Service activities incidental to land transportation  
5224 Cargo handling  
5229 Other transportation support activities  
5510 Hotels and similar accommodation  
5520 Short-stays and vacation accommodation facilities  
5590 Other accommodation services  
5610 Restaurants  
5629 Other food services n.e.c.  
5829 Editing activities of other software products  
6110 Wired telecommunications activities  
6120 Wireless telecommunications activities  
6203 Computer facilities management activities (administration and operation)  
6209 Other information technology and computer service activities  
6311 Data processing, web hosting and related activities  
6810 Buying and selling of own real estate  
6820 Renting and operating of own or leased real estate  
7112 Engineering activities and related technical consultancy  
7120 Technical testing and analysis  
7219 Research - Development on natural sciences and engineering  
7711 Renting and leasing of cars and light motor vehicles  
7712 Renting and leasing of cars and heavy motor vehicles  
7721 Renting and leasing of recreational and sports goods  
7732 Renting and leasing of construction and civil engineering machinery and equipment  
7733 Renting and leasing of office machinery and equipment (including computers)  
7739 Renting and leasing of other machinery, equipment and tangible goods n.e.c.  
8299 Other business support service activities n.e.c.  
8559 Other forms of education n.e.c.  
8610 Hospital assistance activities  
8690 Other human health activities  
9311 Operation of sports facilities  
9329 Other leisure and fun activities n.e.c..  
CHAPTER III  
SHARE CAPITAL, STOCKS  
Art. 8 The Share Capital  
(1) The total share capital of “CONPET” S.A. amounting 28,569,842.40 RON is subscribed and entirely  
paid-up.  
(2) The share capital of the company is divided into 8,657,528 nominative shares issued in  
dematerialized form, 3.3 RON nominal value each.  
3
(3) The shareholding structure, corresponding to the consolidated synthetic structure of the shareholders  
is the following:  
The ROMANIAN STATE, by the Ministry of Energy (the line ministry or its successors, according  
to the law)  
Number of shares: 5,083,372  
Value of contribution to the share capital: 16,775,127.60 RON  
Share on profit and loss: 58.7162 %  
OTHER SHAREHOLDERS NATURAL OR LEGAL PERSONS  
Number of shares: 3,574,156  
Value of the contribution to the share capital: 11,794,714.8 RON  
Share on profit and loss: 41.2838 %  
(4) The identification data of each shareholder, the contribution to the share capital, the number of shares  
he is entitled to and the share in the total share capital are being comprised in the Shareholders  
Registry kept in electronic system by Depozitarul Central S.A.  
(5) The rights and obligations related to the share capital of the Company, for the shares in capital held by  
the Romanian State are exercised, on behalf and on the account of the Romanian State, by the line  
ministry, the Company being under its authority, in accordance with the legal dispositions.  
Art. 9 Augmentation or Decrease of Share capital  
(1) The share capital may be decreased or increased based on the Resolution of the Extraordinary General  
Meeting of Shareholders, under and in compliance with the procedure stipulated by law.  
(2) The Extraordinary General Meeting of Shareholders shall decide upon the augmentation of the share  
capital, in compliance with the legal provisions in force at the date of the augmentation thereof.  
(3) The share capital could be augmented by:  
a) the issue of new shares;  
b) augmentation of the nominal value of the existing shares;  
c) incorporation of reserves, except for the legal reserves, as well as of the benefits and share  
premiums;  
d) compensation of certain liquid debts exigible to the company, by shares thereof;  
(e) other sources, set by the General Meeting of Shareholders or Board of Directors, as the case may  
be, as per the law;  
(4) The Resolution of the Extraordinary General Meeting of Shareholders for the augmentation of the  
share capital shall be published in the Official Gazette of Romania, Part. IV, being granted, for the  
exercise of the right of first refusal, at least one-month deadline, starting the publishing date.  
(5) The reduction of the share capital is being made under the law.  
(6) The share capital could be reduced by:  
(a) the diminution of the number of shares;  
(b) reduction of the nominal value of shares;  
(c) acquirement of own shares, followed by the cancellation thereof;  
(d) other processes stipulated by law;  
(7) The reduction of the share capital can be done only following two months as of the date of  
publishing in the Official Gazette of Romania Part IV, of the Resolution of the Extraordinary  
General Meeting of Shareholders, as per the legal provisions.  
(8) If the Board of Directors establishes that, following certain losses established based on the annual  
financial statements approved as per the law, the net asset of the company, determined as a  
difference between total assets and total liabilities thereof, lowered to less than half the value of the  
subscribed share capital, then the Board will convene immediately the Extraordinary Meeting of  
Shareholders, to decide upon the dissolution of the company.  
4
(9) The Board of Directors will present to the Extraordinary Meeting of Shareholders convened as per  
the here-above paragraph, a report regarding the patrimonial situation of the company, accompanied  
by observations of the internal auditors. This report must be submitted to the company headquarters  
by at least one week prior to the General Meeting, as to be consulted by any interested shareholder.  
(10) If the General Meeting does not decide upon the company dissolution, then the company is bound,  
up to the end of the financial year previous to the one the losses have been ascertained in relation  
hereto, to proceed to the reduction of the share capital by an amount at least equal to the amount of  
the losses that could not be covered from reserves, if all this time, the company net asset was not  
restored up to a value level that equals at least half the share capital.  
Art. 10 The Shares  
(1) The rights and liabilities related to the shares held by the shareholders stipulated at Art. 8, Para. (3),  
are being exercised by the respective owners.  
(2) The company shares are nominative, of equal values and comprise all the elements stipulated by law.  
The nominal value of one share is 3.3 RON. The shares are being issued in dematerialized form and  
are being registered in the Shareholders’ Registry, the record thereof being held by Depozitarul  
Central S.A. Bucharest, to whom “CONPET” S.A. has concluded a contract. The shares are  
indivisible regarding CONPET S.A., which recognizes only one owner for each share. In case a share  
becomes the property of several persons, Depozitarul Central S.A. is not bound to record the  
transmission as long as those persons will not designate a unique representative for exercising the  
rights resulting from share.  
(3) The shares are recorded in the Shareholders’ Registry in book-entry form. The certification of the  
property right over shares is being made by way of a statement of account.  
(4) The shares issued by the company may be subject to usufruct or may be pledged, under the law.  
(5) The trading of shares is being performed on the securities regulated market, as per the legislation in  
force regarding the capital market.  
(6) The company may acquire own shares under the law.  
(7) “CONPET” S.A. employees have the right to purchase company shares from the State, up to the limit  
of the share capital set by the general meeting of shareholders and at the same selling price of the  
shares in case of privatization.  
Art. 11 Bonds  
(1) The company can issue bearer or nominative bonds, for an amount that is to be approved in the  
Extraordinary General Meeting of Shareholders.  
(2) The amount for which bonds can be issued should not exceed three quarters (3/4) of the paid-up share  
capital existing as per the latest approved financial statements.  
(3) The nominal value of one bond cannot be smaller than 2.5 Ron and the nominal value convertible in  
shares should equal the nominal value of the share.  
(4) The bonds, part of the same issue must be equal in value and grant equal rights to their holders.  
(5) The shares may be issued in a material form, on paper form or in dematerialized form.  
(6) The issue and trading of the bonds that are subject to a public tender shall be subject to the legislation  
regarding the incidental capital market.  
(7) The bond holders may be represented by authorized agents, other than the company administrators,  
directors or employees.  
(8) The company is authorized to issue bonds, under the law.  
Art. 12 The Rights and Liabilities incurred by the Shares  
5
(1) All shares have equal value and guarantee equal rights and liabilities to their holders.  
(2) Every subscribed and paid-up share, as per the law, guarantees the right to vote in the General  
meeting of Shareholders, the right to elect and be elected within the governing bodies, the right to  
take part to the distribution of dividends as per the provisions of this Articles of Incorporation and  
legal provisions, as well as other rights stipulated by law and the Articles of Incorporation.  
(3) The holding of shares implies the right adhesion to the Articles of Incorporation.  
(4) The rights and liabilities corresponding to the capacity of shareholder observe the legal regime of the  
shares at their passing to other persons’ property.  
(5) The company liabilities are guaranteed with the company’s assets, representing the general pledge of  
the company creditors, and the shareholders are liable in connection therewith, limited to the  
subscribed share capital.  
(6) The company’s Asset cannot be subject to debts or other personal liabilities of the shareholders. Any  
shareholder’s creditor may issue claims against the party out of the receivable benefits of the  
shareholder, following the approval of the annual balance sheet or any stake due to him upon the  
company liquidation, made under the law and this Articles of Incorporation. The creditors may,  
though, pledge, during the company life, the stakes that would be due to the associates upon  
liquidation or may sequestrate and sell the shares to their debtor.  
(7) The shareholders have the right to be given correct and complete information regarding the company  
status in the General Meeting of Shareholders. In case of the issue of new shares, the existing  
shareholders benefit from the right of first refusal upon subscription, under the law.  
Art. 13 Disposal of Shares  
(1) The company shares are indivisible.  
(2) In any relationship with the company, this one acknowledges one or more owners for every share.  
Whenever a nominative share becomes property of more persons, the conveyance shall not be  
recorded unless these persons nominate one representative to exercise the rights resulting from the  
share.  
(3) The ownership right over the shares issued in dematerialized form and traded on the regulated  
securities market shall be submitted in compliance with the legislation regarding the capital market.  
(4) The direct transactions will be operated by Depozitarul Central S.A. Bucharest.  
(5) The Company shares related transactions shall be made as per the legislation in force applicable to  
the organized securities markets.  
CHAPTER IV  
THE GENERAL MEETING OF SHAREHOLDERS  
Art. 14 The Representation  
(1) The majority shareholder of “CONPET” S.A. is the Romanian State. The rights and duties of the  
Romanian State, acting as majority shareholder, shall be exercised, within the General Meetings of  
Shareholders, by the line ministry coordinating the company business, by way of specific normative  
acts, by specially designated representatives, as per the legal provisions.  
(2) The Romanian State representatives in the General Meeting of Shareholders are being nominated  
and revoked by order of the line ministry. The voting right of the State representative in the General  
Meeting of Shareholders “CONPET” S.A. will be exercised based on the special power of attorney  
submitted to the company in compliance with the legal provisions regarding the capital market and  
the other applicable regulations, the special empowerment being likely to be accompanied by an  
Order of the line minister/instruction for the General Meeting.  
Art. 15. Duties  
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(1) The General Meeting of Shareholders is “CONPET” S.A.’s management body, who decides upon the  
company business and trade and economic policy, as per the option of the shareholders present or  
represented during the meeting;  
(2) The General Meetings of Shareholders are ordinary and extraordinary.  
(3) The Ordinary General Meeting of Shareholders meets at least once a year, in no more than 4 months  
as of the conclusion of the financial year and has the following competencies, duties and functions:  
a) discusses, approves or modifies the annual financial statements, based on the administrators’ or  
the financial auditor’s report;  
b) elects and revokes the administrators according to the law; at the appointment, the OGMS shall  
bear in mind that the majority of BoD members should be non-executive and independent;  
c) approves the administration plan issued and presented by the Board of Directors, as well as the  
revision thereof;  
d) appoints or revokes the financial auditor and sets the minimum duration of the financial auditing  
contract;  
e) sets the remuneration level and any other amounts and advantages due to the administrators for  
the current financial year, as well as the general limits of the remuneration of the Director  
General;  
f) approves the Organizational and Operational Rules and Regulations governing the Board of  
Directors and sets-out the competencies thereof;  
g) approves the income and expenditure budget (Rom. BVC) and the investment program for the  
next financial year, as well as the BVC rectification;  
(h) approves the profit distribution as per the provisions of the normative acts in force and the fixing  
of dividends;  
(i) passes judgments over the administrators management and the means to recover the losses they  
have caused to the company;  
(j) decides upon pledging, leasing or dissolution of one or several company units;  
(k) fulfils any other duty, set under the law, as being borne by them.  
(4) The Extraordinary General Meeting reunites whenever necessary in order to decide upon:  
a) changing the legal form of the company;  
b) changing the location of the company headquarters;  
c) changing the core business of the company;  
d) establishment or disestablishment of subsidiaries;  
e) extending the company’s life;  
f) augmentation of the share capital;  
g) reduction of the share capital or replenishment thereof by issue of new shares;  
h) merger with other companies or division thereof;  
i) anticipated dissolution of the company;  
j) conversion of the shares from one category into another;  
k) conversion of a category of bonds into another or into shares;  
l) bonds issuance;  
m) amendment of the nominal value and number of shares;  
n) decides upon the contracting of average and long term bank loans, here-included the external  
ones; establishes the competencies and level for contracting the current bank loans, of the trade  
loans, as well as the level of the guarantees;  
o) decides upon the participation, according to the law, to the establishment of new legal persons or  
in the association with other legal or natural persons in the country or abroad, except for the non-  
profit organizations established under the law, for which the competence to approve the  
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accession/withdrawal of companies from the capacity of member belongs to the Board of  
Directors;  
p) may delegate to the Board of Directors the execution of the attributions mentioned at Art. 15,  
paragraph (4), letters b), c) and f). The delegation of the task stipulated at Art. 15, paragraph (4)  
letter c) cannot concern the main business area and core business of the company.  
q) decides on what market are to be traded the securities issued by the company and chooses the  
authorized independent registrar that keeps record of the shares issued by the company;  
r) any other amendment of the Articles of Incorporation, or any other Resolution for which is being  
asked the approval of the Extraordinary General Meeting of Shareholders.  
Art.16 Call of the General Meeting of Shareholders  
(1) The General Meeting of Shareholders is being convened by the Board of Directors, whenever  
necessary.  
(2) The call of the General Meeting of Shareholders shall comply with the legal provisions regarding the  
companies, as well as the regulations regarding the capital market and provisions of this Articles of  
Incorporation. The meeting deadline cannot be less than 30 days as of the publishing of the  
Convening Notice in the Official Gazette of Romania, part IV.  
(3) The convening notice shall comprise the venue, date and time of the meeting, as well as the Agenda,  
with the explicit mention of all the issues that shall make the object of the meeting debates. Equally,  
the convening notice shall comprise the reference date, the proposal of the Board of Directors  
regarding the registration date, ex-date and the due date for dividends payment. Where on the Agenda  
is being entered the election of the administrators, the Convening Notice will mention also the due  
date up to which may be submitted the candidacies, as well as the fact that the list comprising  
information regarding the name, place of domicile and professional qualification of the persons  
proposed for the administrator capacity is made available to the shareholders who can consult and  
complement it. The convening notice will mention the means to distribute the information regarding  
the issues included on the Agenda of the General Meeting of Shareholders, as well as the date as of  
which they will be available, the means of obtaining the special empowerment form for representation  
in the general meeting, the limit date and place where the special empowerments will be submitted.  
When on the Agenda are included proposals for the amendment of the Articles of Incorporation, the  
Convening Notice should comprise the full text of the proposals.  
(4) By way of the Convening Notice for the first general meeting could be set the date and time for the  
second meeting, for the situation when the first one could not be held. If the day of the second  
general meeting is not mentioned in the convening notice, the meeting could be convened in 8 days  
as of the publishing of the second call in the Official Gazette of Romania, part IV.  
(5) The Board of Directors calls urgently the general meeting of shareholders, at the request of the  
shareholders representing, individually or together, at least 5% of the share capital and if the request  
comprises provisions that fall under the attributions of the general meeting. The meeting will be  
convened in no more than 30 days and shall take place in no more than 60 days as of the date of the  
receipt of the request.  
(6) One or more shareholders representing, individually or collectively, at least 5% of the share capital  
have the right to ask the inclusion of new items on the Agenda. The requests are filed to the Board of  
Directors, in no more than 15 days as of the convening notice publishing date, for publishing thereof  
and bringing to the attention of the other shareholders. In case the Agenda comprises the  
appointment of the administrators and the shareholders are willing to formulate application for  
candidacies proposals, the requests shall include information regarding the name, place of domicile  
and professional qualification of the persons proposed for the said positions. The Agenda completed  
with the items advanced by the shareholders, subsequent to call, must be published by the  
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observation of the same requirements stipulated for the call of the general meeting, at least 10 days  
prior to the general meeting, at the date mentioned in the initial convening notice.  
(7) The annual financial statements, the annual report of the Board of Directors, as well as the proposal  
regarding the distribution of dividends shall be made available to the shareholders at the company  
headquarters, as of the call date of the general meeting. The company shall make available to the  
interested shareholders, all along the period starting at least 30 days prior to the date of the general  
meeting, no later than and inclusive of the meeting date, the documentation and informative  
materials that are to be exposed to the general meeting of shareholders, corresponding to every item  
on the Agenda, as well as other information stipulated by Law. Upon request, the shareholders will  
be issued copies of these documents. The amounts levied for the issue of copies cannot exceed the  
administrative expenses triggered by the supply thereof.  
(8) Every shareholder may address to the Board of Directors, in writing, questions regarding the  
company business, prior to the date of the general meeting, within the time frame stipulated in the  
convening notice of the general meeting; an answer is to be given during the meeting.  
Art. 17. Organization of the General Meeting of Shareholders  
(1) For the validity of the deliberations of the ordinary general meeting of shareholders, are necessary:  
(a) In first call, the presence of the shareholders (here-included the votes by correspondence)  
representing at least half (1/2) of the total number of voting rights and the resolutions be  
taken with the majority of expressed votes.  
(b) In second call, notwithstanding the number of the shareholders present or represented and the  
value of the represented share capital and resolutions be taken with majority of expressed  
votes.  
(2) For the validity of the deliberations of the extraordinary general meeting of shareholders, are  
necessary:  
a) In first call, the presence of the shareholders (inclusive of the correspondence votes)  
representing at least half (1/2) of the total number of voting rights;  
b) In second call, the presence of the shareholders representing at least one third (1/3) of the  
total number of voting rights;  
c) The resolutions are made with the majority of the votes held by the present or represented  
shareholders, both in first call and second call;  
d) The resolution to amend the company’s core business, to reduce the share capital, augment in  
cash the share capital, change the legal form, merge, divide or dissolve the company are  
being made by a majority of at least two thirds (2/3) of the voting rights held by the present or  
represented shareholders.  
(3) By way of derogation from the above provisions, the following resolutions of the extraordinary  
general meeting of shareholders shall be made by the vote of the shareholders representing at least  
three quarters (3/4) out of the share capital of the company, in first call or any other subsequent call,  
as follows:  
a) The resolutions regarding the bond issue;  
b) Waiving the right of first refusal of the shareholders upon the subscription of new shares in  
case of the share capital augmentation in cash;  
c) The share capital augmentation in kind.  
(4) The general meeting of shareholders is opened and presided by the chairman of the Board of  
Directors or in absence thereof, by the person substituting him. The general meeting shall elect, from  
the shareholders present, up to three secretaries that will check the attendance list for the  
shareholders, pointing out the share capital every person represents, the protocol prepared by the  
internal auditor and the technical secretariat of the meeting to ascertain the fulfilment of all  
formalities required by law and the Articles of Incorporation for holding the session.  
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(5) A protocol, signed by the President and the Secretary, is to ascertain the fulfilment of the summoning  
formalities, the date and venue of the general meeting, the present shareholders, the number of shares,  
the summaries of the argumentation, the resolutions made, and upon the request of the shareholders,  
the statements they took during the meeting. The protocol will be attached the documents regarding  
the first call as well as the shareholders’ attendance lists.  
The protocol shall be consigned in the registry of the general meeting, which is sealed and stamped.  
(6) The Chairman of the Board of Directors may nominate, out of the company employees, one or more  
technical secretaries, to take part to the execution of the above-mentioned operations and also to the  
drafting and signing of the minutes of the meeting.  
(7) At the ordinary and extraordinary general meetings of shareholders, where are being discussed issues  
regarding the work relations with the company personnel, shall also be invited the President of the  
Union.  
Art. 18 Exercising the Right to Vote during the General Meeting of Shareholders  
(1) The resolutions of the general meetings are taken in open vote.  
(2) At the proposal of the person presiding the general meeting, or of a group of present or represented  
shareholders, holding at least (1/3) of the total number of votes, could be decided that the vote be  
secret in other cases as well, other than those stipulated by law.  
(3) The secret vote is compulsory for the election of the members of the Board of Directors and  
financial auditor, for the revocation thereof and for taking decisions regarding the liability of the  
members of the company administration, management and control bodies.  
(4) The voting right cannot be transferred. Any convention otherwise specified is null.  
(5) At the meeting may take part and vote exclusively the shareholders registered at the Reference Date,  
in person or by representatives, based on a special or general empowerment, as per the legal  
provisions. The shareholders may also vote by correspondence, in compliance with the procedure  
mentioned in the convening notice of the general meeting and the applicable legal provisions.  
(6) The shareholders lacking exercise capacity, as well as the shareholders legal persons may be  
represented by their legal representatives who, in their turn, may empower other persons for that  
general meeting.  
(7) In case of the vote by representation, the special/general empowerments and the accompanying  
documents shall be submitted to the company, at least 24 hours prior to the general meeting, under  
the sanction of losing the right to exercise one’s voting right during that meeting. The special/general  
empowerments can also be submitted electronically, with the electronic signature included/attached.  
The Protocol shall include a mention regarding the received empowerments.  
(8) The members of the Board of Directors, the Director General or the company employees cannot  
represent the shareholders, under the sanction of nullity of the Resolution if, in absence of the vote  
thereof, would not have been obtained the requested majority.  
(9) The Director General and the members of the Board of Directors are bound to take part in the  
general meetings of shareholders.  
(10) In order to be opposable to third parties, the resolutions of the general meetings shall be submitted  
in 15 days to the Trade Register Office in order to be recorded in the logbook and published in the  
Official Gazette of Romania, Part. IV.  
(11) Following every amendment of the Articles of Incorporation, the administrators shall file, at the  
Trade Registry, in no more than 15 days, the amendment and the full text of the Articles of  
Incorporation, updated with all amendments, which will be recorded pursuant to the resolution of the  
delegated judge.  
(12) The resolutions made by the general meetings of shareholders within the Law and this Articles of  
Incorporation are binding even for the shareholders that did not attend the meeting or voted against.  
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(13) The resolutions of the general meeting of shareholders which are not compliant with the law or the  
Articles of Incorporation may be filed to Court, under the conditions and in compliance with the  
procedure stipulated by Law.  
(14) The shareholders that did not vote in favor of a resolution of the general meeting regarding the  
amendment of the core business, the merger or division of the company, the relocation of the  
company headquarters overseas or changing the company form, have the right to withdraw from the  
company under the law.  
(15) The members of the Board of Directors cannot challenge the resolution of the general meeting  
regarding the revocation thereof from the respective positions.  
(16) The petition will be dealt with in contradiction with the company represented by the Board of  
Directors.  
(17) If the resolution is challenged by all members of the Board of Directors, the company will be  
represented in justice by a person appointed by the President of the Court from among its  
shareholders, a person that is to fulfil the mandate vested in him, until the general meeting, called for  
this purpose, nominates a representative.  
(18) The resolutions of the ordinary general meeting of shareholders shall be signed by the president of  
the meeting, the technical Secretariate and by the shareholder or shareholder’s representative holding  
the majority of expressed votes.  
(19) The resolutions of the extraordinary general meeting of shareholders shall be signed by the  
president of the meeting, the technical Secretariate and by the shareholder or shareholder’s  
representative holding the majority of votes held by the presented or represented shareholders.  
(20) The “Abstention” position adopted by a shareholder regarding the items included on the agenda of  
the general meeting of shareholders is not deemed expressed vote.  
CHAPTER V  
ABOUT THE COMPANY ADMINISTRATION  
Art. 19 Organization  
(1) The company is administered in a unitary system by a Board of Directors consisting of 7  
administrators, appointed by the Ordinary General Meeting of Shareholders for a period of 4 years,  
with the possibility of re-election for further periods of 4 years. The administrators can act as  
shareholders. For the appointment of an administrator to be legally valid, the person appointed must  
expressly accept it. The identification data of the administrators are being registered at the Trade  
Register Office as per the legal provisions.  
(2) The majority of the Board of Directors members are non-executive and independent administrators.  
When the administrators are appointed by the GMS or BoD, it will be taken into account that they  
fulfill the legal conditions regarding the status of independent administrator, the administrators being  
bound to fill-in an affidavit regarding independence prior to the appointment. If there are changes  
regarding the information that is the basis of the declaration of the status of independent  
administrator, the administrator has the obligation to immediately bring them to the attention of the  
Board of Directors through the Nomination and Remuneration Committee.  
(3) The Board of Directors is presided by a Chairman. The Chairman is elected by the Board of  
Directors, from among its members. The revocation from the capacity of Chairman of the Board of  
Directors is still the attribute of the Board of Directors. The resolution regarding the nomination or  
revocation thereof is being made by the vote of the majority of the Board of Directorsmembers.  
(4) In case of vacancy of one or more administrator positions, the Board of Directors proceeds to the  
appointment of one/several provisional administrators, until the reunion of the Ordinary General  
Meeting of Shareholders. The Board of Directors will ensure that the majority of non-executive and  
independent administrators is being maintained when appointing provisional administrators.  
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(5) At the Board of Directors level is being constituted the Audit Committee and the Nomination and  
Remuneration Committee, binding, as per the legal provisions in force. The Board of Directors may  
also constitute, based on resolution, other consultative committees, in various activity areas, as per  
the needs and management strategy of the company. The Consultative Committees are made of at  
least two members, one of them being charged with the Presidency thereof. The consultative  
committees meet whenever necessary, at the Chairman’s call, and the proposals/recommendations  
formulated by the Board of Directors (for the substantiation of the decision-making thereof) are  
being adopted by the majority of expressed votes. The duties and responsibilities of the consultative  
committees are being set by the Board of Directors.  
(6) Cannot be administrators the persons who, as per the law, are incapable or have been convicted for  
fraudulent management, breach of trust, forgery, use of forgery, fraud, peculation, false testimony,  
bribery, for the delinquencies provided by the Law no. 656/2002 for the prevention and penalization  
of money laundering, as well as for the settlement of several prevention and refutation measures  
related to the terrorist acts, subsequent amendments and completions, for the delinquencies provided  
at art. 143 - 145 from the Law no.85/2014 regarding the insolvency prevention and insolvency  
procedures.  
(7) The Chairman of the Board of Directors of the company may not also be Director General thereof.  
(8) The Board of Directors usually meets at the company’s headquarters or any place of business of the  
company or in any place disclosed in the convening notice. Operational meetings of the Board of  
Directors may be organized by means of remote communication meeting the technical conditions  
necessary for the identification of the participants, their effective participation to the meetings of the  
Board of Directors and the retransmission of the deliberations on a continuous basis (via e-mail,  
telephone, video call or other communication equipment), whenever necessary, but at least every 3  
months, at the call of the President or at the reasoned request of 2 of its members or of the Director  
General/Directors. In this case, the Agenda is being established by the authors of the request. The  
Chairman must act on such a request. The Board of Directors is ruled by Chairman. In case the  
Chairman is temporarily incapable of exercising his duties, all along that period, the Board of  
Directors may charge another administrator with the fulfilment of the Chairman capacity, upon the  
proposal of the BoD’s Chairman;  
(9) The Board of Directors cannot decide upon certain issues that are not included in the Agenda, except  
for the emergencies. In order to decide upon the emergencies, the absent members will also be  
consulted, by various remote communication devices.  
(10) The Chairman will decide on the emergency nature of the issues.  
(11) The Board of Directors performs its activity based on its own regulation and the legal regulations in  
force.  
(12) For the validity of the decisions is necessary the presence (directly or by proxy) of at least five  
members from among the Board members and the decisions are made with the majority vote of the  
present members. The chairman of the Board of Directors will have the casting vote in case of parity  
of votes. The “Abstention” position adopted by an administrator regarding the items included on the  
agenda of the general meeting of shareholders is not deemed expressed vote.  
(13) The members of the Board of Directors can be represented at the meetings of the respective body  
exclusively by other members thereof. A present member can only represent a single absent member.  
(14) In case of resolutions made during the meetings where a member of the board did not participate, the  
latter remains liable, if, within 30 days of acknowledgment thereof he did not challenge it in the forms  
provided by the law.  
(15) The Agenda is established by the Chairman. The call, the agenda and the meeting materials will be  
sent to the administrators in sufficient time before the date of the meeting; the deadline can be  
established by the own regulation of the Board of Directors. The minutes of the meeting shall be  
comprised in a Journal of the Meetings and BoD Deliberations, by courtesy of the Chairman of the  
Board.  
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The protocol of the meeting shall be drawn up by technical editing by the BoD Secretariate and shall  
comprise the name of the participants, the order of the deliberations, the decisions made, the number  
of votes cast and separate opinions. This will be signed by the Chairman of the Board of Directors,  
the BoD members (only those who participate directly in the meeting; they may also have a mandate  
of representation given by another administrator) and by the BoD Secretariate, and will be attached  
by gluing it to the Journal of the Meetings and BoD Deliberations of the Board of Directors. The  
decisions of the Board of Directors and the protocols of the meetings will be sent by email to the  
administrators.  
(16) In exceptional cases, motivated by the emergency of the situation and by the company’s interest, the  
decisions of the Board of Directors can be made by the unanimous written vote of the members, the  
reunion thereof no longer being necessary. This procedure cannot be followed in case of the  
decisions made regarding the annual financial statements or the authorized capital. The Board of  
Directors will be required to approve and submit the vote by remote communication means (email).  
(17) At the meetings shall attend the Chairman and BoD members, as well as the directors with mandate  
contract. As the case may be, when necessary, for additional information, the Chairman of the Board  
of Directors can invite at the meetings directors, internal auditors and any other management or  
operating employees, as well as specialists in various business areas from outside the company. The  
Union’s President can be also invited, for debating professional, economic and social issues. In view  
of defending the professional, economic and social rights and interests of the members of the Union,  
the latter will receive from the company’s management the necessary information for the negotiation  
of the collective labor agreements, under the law and by the agreement of the BoD members. The  
articles contained in the decisions of the Board of Directors regarding the professional, economic  
and social issues will be communicated in writing to the President of the Union within two working  
days as of the date of holding the meeting, only as per the orders of the Director General.  
(18) The Board of Directors may delegate the company’s management to one or more directors,  
appointing one of them in the capacity of Director General. The Director General may be appointed  
from among the administrators, who thus becomes an executive administrator or from outside the  
Board of Directors. According to the law, director means that person to whom management duties of  
the company have been delegated by decision of the Board of Directors and who concludes a  
contract of mandate with the Company, in accordance with the applicable legal provisions. The  
Director General of “CONPET” S.A. Represents the Company in third party relations and in Court.  
The Board of Directors represents the company in relation to the directors with mandate contracts.  
(19) The Board of Directors is charged with the fulfillment of all the papers necessary and useful for the  
achievement of the company’s core business, except for those set apart by the law for the general  
meeting of shareholders.  
(20) The Administrators are jointly liable against the company for:  
a) the reality of payments made by the associates;  
b) the real existence of the paid dividends;  
c) the existence of the registries required by the law and the proper holding thereof;  
d) the exact fulfillment of the general meetings resolutions;  
e) the strict performance of the duties that the law and the Articles of Incorporation impose.  
(21) The administrators’ liability is being regulated by the legal provisions regarding the mandate as well  
as by the special provisions stipulated by the Companies Law no. 31/1990.  
(22) The administrators and their immediate successors are jointly liable if, being aware of the  
irregularities committed, fail to inform the internal auditors and the financial auditors in relation  
thereof.  
(23) The liability for the deeds or the omissions performed does not extend over the administrators who  
have caused to consign, in the BoD Protocols Journal, their objection and have informed in writing  
the internal auditor and the financial auditor thereupon.  
(24) If the administrators ascertain that, following various losses, the net asset, determined as a difference  
between the company’s total assets and liabilities, represents less than half of the value of the share  
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capital, they convene the extraordinary general meeting of shareholders, in order to decide upon the  
replenishment of the share capital, the decrease thereof to the remaining value or the company  
dissolution.  
(25) The members of the Board of Directors may be revoked by the resolution of the general meeting of  
shareholders and the Director General by the Board of Directors’ Decision.  
(26) The Board of Directors members shall conclude professional liability insurance, the exchange value  
thereof being borne by „CONPET” S.A., under the Law.  
(27) The Administrators are bound not to disclose confidential data and information and business secrets  
of the Company, as well as information regarding its activity. This liability is also binding after the  
termination of the mandate, for a period of 5 years. They must also comply with the inside  
information regime provided in the incidental legislation.  
Article 20 Powers of the Board of Directors  
(1) The Board of Directors’ powers are being set pursuant to the Articles of Incorporation of the  
company, the Romanian law, as well as pursuant to other attributions set by the general meetings of  
shareholders as falling under the responsibility thereof, respectively, in particular, the followings:  
(a) Calls the general meetings of the company and sets the agenda, while endorsing the meeting  
documentation;  
(b) Prepares the annual report that is to be submitted to the General Meeting of Shareholders, together  
with the annual financial statements and the report of the financial auditor, as well as other reports  
imposed by the applicable legislation, by the observance of reporting requirements set pursuant to the  
capital market legislation and other incidental regulations;  
(c) Concludes legal deeds in the name and on behalf of the company, based on which to acquire goods  
for the company or dispose, lease, change or enter a lien over the goods to be found in the Company’s  
Assets, where the value thereof exceeds half the book value of the company assets at the conclusion  
of the juristic act, exclusively by way of approval of the Extraordinary General Meeting of  
Shareholders.  
(d) Submits to the internal auditors and the financial auditor, by at least 30 days prior to the day of the  
general meeting, the annual financial statements for the preceding financial year, accompanied by the  
administrators’ report and the supporting documents;  
(e) Recommends for approval to the ordinary general meeting of shareholders, subsequent to the end of  
the financial year, on an annual basis, the financial statements for the preceding year accompanied by  
the administrators’ report regarding the company activity and the financial auditor report;  
(f1) Endorses and submits to the approval of the ordinary general meeting of shareholders the revenues  
and expenditure budget of the company (Budget) for the next financial year, as well as the  
rectification of the Budget, which, in accordance with the legislation in force, is the exclusive  
competence of the GMS; approves the corrections brought to the Budget which falls within the  
approval competence of the Board of Directors, according to the legislation and methodological  
norms in force;  
(f2) Endorses the investment program for the next financial year, which includes the structure detailed by  
investment objectives before submission for approval of the GMS of its centralized structure;  
approves the investments program, the detailed structure by investment objectives after approval by  
the GMS of its centralized structure; approves the rectification of the investment program within the  
same total values approved by the GMS; approves the current repair program and its rectification;  
decides upon the delegations and limits of competence granted to the Director General regarding the  
approval of the rectification of the investment program and the current repair program;  
(f3) Approves the procurement program and its review/rectification; decides upon the delegations and  
limits of competence granted to the Director General regarding the approval of the review of the  
procurement program;  
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(f4) Approves the company's accession to/the company's withdrawal from the non-profit organizations  
established in accordance with the legislation in force;  
(g) Approves the Collective Labor Agreement at the company level and the conclusion of addenda to the  
Collective Labor Agreement and mandates the Director General for the carry-on of the negotiations  
between parties and the documents execution;  
(h) Approves the organizational structure and the related personnel structure, the Organizational and  
Operational Rules and Regulations and the Internal Rules of the company;  
(i) Drafts the administration plan and recommends it for approval in the ordinary general meeting of  
shareholders, within 90 days as of the appointment of the administrators under the conditions set out  
in the GEO no. 109/2011.  
(j) Delegates to the Director General/directors with a mandate contract the management duties of the  
company in areas of competence and establishes through the mandate contract their rights and  
obligations, competences, attributions, responsibilities; in the event that the Director  
General/directors with a mandate contract are unable to exercise their duties (rest leave, medical  
leave, travel assignments, etc.), they may delegate the duties according to the provisions of the  
mandate contract and/or the decisions of the Board of Directors;  
(k) Oversees the activity of the directors with mandate contract in what concerns the company  
management, here-included the management thereof and approves the quarterly, by-yearly and  
annual activity reports prepared by the directors, as well as any other activity reports recommended  
for approval;  
(l) Appoints and revokes the Directors with mandate contract of the company and sets the remuneration  
thereof, the general limits of the remuneration being set by the ordinary general meeting of  
shareholders in the remuneration policy. Sets the objectives and performance criteria for the  
directors with mandate contract and notes, recurrently, the progress of the fulfillment thereof;  
approves the global degree of achievement of the objectives and performance criteria of the directors  
with mandate contract, for the previous year, correlated with the financial statements of that financial  
year;  
(m) Sets the main business directions and approves the strategies and development policies of the  
company;  
(n) Sets the accounting policies and the financial control system and approves the financial planning;  
(o1) Approves/endorses the protocols on the results of the inventory of company property/public property  
of the state; approves/endorses proposals for decommissioning of fixed assets, withdrawal of  
materials of inventory objects like materials, decommissioning and disposal of material assets other  
than fixed assets, owned by the company/the public patrimony of the state, whose maintenance is no  
longer justified; approves/endorses the methods of recovery of such property and the starting prices  
at auction for goods proposed to recovery by tender; may delegate to the Director General the power  
to sign the protocols of the decommissioning of fixed assets/of inventory items/downgrading of  
material assets;  
(o2) Approves the requests for sponsorship and transfer to the company’s costs of certain amounts  
representing penalties, delay penalties, fines, over 100,000 RON; empowers the Director General  
with the approval of transferring to the company’s costs of certain amounts representing fines,  
penalties, delay penalties, up to the maximum limit of 100,000 RON;  
(o3) Approves the external business travels of the BoD members and Director General/directors with  
contract of mandate;  
(o4) Approves the participation of BoD members and of the Director General in training or professional  
development courses/conferences; regarding the expenses incurred by the travel of the members of  
the BoD to the company's headquarters/worksites, they will be settled by the company, the Director  
General ordering their payment based on the supporting documents;  
(o5) Delegates to the Director General the power to approve the internal travel of directors with a  
mandate contract and their participation in training or professional development  
courses/conferences.  
15  
(p) Proposes the shareholders on what market are to be traded the securities issued by the company and  
chooses the authorized independent registrar holding evidence of the shares issued by the company;  
(q) Requests and receives reports from the internal audit of the company;  
(r) Files the request for the opening of the insolvency procedure as per Law no. 85/2014 regarding the  
insolvency prevention and insolvency procedures;  
(s) Performs all the necessary and useful documents for the achievement of the company's core business,  
except for those reserved by law for the general meeting of shareholders;  
(t) Engages current bank loans and trade credits, in compliance with the competencies and level of  
contracting set by the extraordinary general meeting of shareholders and approves the issue of the  
guarantees;  
(u) Approves the proposals regarding the global strategy for development, revamping, modernization,  
economic-financial restructuring of the company;  
(v) Provides the enforcement of the resolutions adopted by the shareholders within the sessions of the  
general meetings of shareholders, aiming that the enforcement of the resolutions be made by  
compliance with the legality of the company business; secures and is liable for the carry-on of any  
task or duty set by the general meeting of shareholders or that is being stipulated by the legislation in  
force, here-included the regulations in force regarding the capital market, as well as by the  
performance of the company’s business, in terms of both direct duties, as well as for those assigned to  
the Director General/directors with mandate contract.  
(w) Approves the management plan drafted and presented by the Director General/directors with mandate  
contract, in 90 days as of the nomination thereof under the provisions of GEO no. 109/2011 regarding  
the corporate governance of the public enterprises.  
(x) Presents, twice a year, within the ordinary general meeting of shareholders, a report on the  
administration activity including also information referring to the execution of the mandate contract  
of the directors, details regarding the operational activities, financial records of the company and the  
biyearly accounting reports thereof.  
(y) Submits, to the ordinary general meeting of shareholders that approves the annual financial  
statements, an annual report (Remuneration Report), prepared by the Nomination and Remuneration  
Committee within the Board of Directors, regarding the remunerations and other benefits granted to  
the administrators and directors with mandate contracts during the previous financial year, report  
structured pursuant to the provisions of the legislation in force;  
(z) Approves the establishment or disestablishment of sub-units (secondary establishments, work sites,  
branches, agencies, representatives or other sub-unit types bearing no legal personality), located in the  
same locality and/or in other localities, in the country and abroad;  
(2) Under the sanction of nullity, the administrators or the directors with mandate contract may, on their  
own behalf, alienate, respectively acquire, goods to or from the company having a value of over 10%  
of the company’s net assets value, only after obtaining the approval of the extraordinary general  
meeting, under the conditions provided in Law no.31/1990 regarding the companies.  
(3) The duties received by the Board of Directors from the general meeting of shareholders cannot be  
delegated to the Director General/directors with mandate contract, in compliance with Art. 15 Para.  
(4) Letter (p) of this Articles of Incorporation.  
(4) The Board of Directors reserves the duty to represent the company in relation to the Director General.  
16  
CHAPTER VI  
THE DIRECTORS  
Art. 21 The Duties and Rights of the Director General/Directors with mandate contract  
(1) The Board of Directors shall delegate the company’s management to one or more directors, appointing  
one of them in the capacity of Director General. Within the meaning of this Articles of Incorporation,  
director means that person to whom management duties of the company have been delegated by  
decision of the Board of Directors and who concludes a contract of mandate with the Company, in  
accordance with the applicable legal provisions.  
(2) The Director General/Directors with mandate contracts have the following main duties:  
(a)provides the leadership and management of the company business and is liable for the execution  
thereof in relation to both direct duties, as well as the ones entrusted to the Board of Directors;  
(b) prepares the annual draft report, the draft income and expenditure budget and the planned works  
programme and submits them to the Board of Directors;  
(c) observes the reporting liabilities set by the regulations in force regarding the capital market and  
the provisions of GEO no. 109/2011 regarding the corporate governance of the public enterprises,  
as well as all the other applicable legal provisions;  
(d) drafts the company development and marketing strategies and policies and submits them for  
approval to the Board of Directors; applies the strategy, the company development and marketing  
strategies and policies set by the Board of Directors;  
(e) prepares projects and business plans and submits them to the Board of Directors for approval;  
(f) prepares the Organizational and Operational Rules and Regulations governing the company, the  
draft organizational structure and personnel structure and submits them to the Board of Directors  
for approval;  
(g) organizes, coordinates and makes all necessary diligence to enforce the strategies and policies  
approved by the Board of Directors; approves the documents of normative nature and the Rules  
regulating the activity of the company;  
(h) the Director General hires/nominates/removes/promotes/suspends/dismisses, as the case may be,  
under the law, the company personnel and sets the rights and obligations thereof;  
(i) the Director General negotiates the employees' individual labour contracts;  
(j) sets the attributions, competencies and responsibilities incurred by way of the job description, for  
the organizational positions that fall under his direct subordination;  
(k) provides the fall within the wage fund figure contained in the approved income and expenditure  
budget, by the achievement of the productivity indicators.  
(l) provides the monitoring of the implementation of provisions of the revenues and expenditure  
budget of the Company, by areas of expertise;  
(m) sets the performance criteria and objectives for the management positions employees, the follow-  
up of the degree of achievement thereof and assessment of their activity regarding the fulfilment  
of the attribution provided in the job description;  
(n) are bound not to disclose confidential data and information and business secrets of the Company,  
as well as information regarding its activity. This liability is also binding after the termination of  
the mandate, for a period of 5 years. They must also comply with the inside information regime  
provided in the incidental legislation.  
(o) presents to the Board of Directors, monthly or whenever necessary, activity reports;  
(p) have signature right and signature specimen in the bank and decide on the receipt and payment  
operations of the company; these powers may be delegated, in case of impossibility to exercise  
one’s duties, to others within the company by decision of the Board of Directors, the BoD being  
the one to appoint the persons authorized to have signature right I and II and their substitutes;  
(q) notifies the board of directors on all irregularities found during the fulfilment of his duties;  
17  
(r) the Director General negotiates and concludes the Collective Labor Agreement in the name and  
on behalf of the company, as per the mandate given by the Board of Directors and in the form  
agreed following negotiations between the parties;  
(s) the Director General represents the Company in relation to third parties and in Court;  
(t) the Director General concludes juristic acts, in the name and on behalf of “CONPET” S.A., under  
the law and in compliance with the provisions of the contract of mandate and the empowerments  
granted based on the BoD decision;  
(u) the Director General concludes contracts of sale and purchase of goods under the law and in  
accordance with the contract of mandate and powers granted by decision of the Board;  
(v) may authorize the directors or any other employee of the company to exercise any power within  
one’s competence, both in what concerns the company's business and the representation in  
relation to various authorities, public institutions, natural or legal persons, in justice, etc., as the  
case may be;  
(w) the Director General signs the protocols of the decommissioning of fixed assets/scrapping of  
inventory items/downgrading of material goods, where he shall be delegated this power by the  
Board of Directors  
(x) endorses the materials on the Agenda of the BoD meetings, according to their area of expertise;  
(y) the Director General organizes and manages an Executive Director Committee consisting of  
directors with mandate contract. The Director General may summon to meetings employees with  
management or execution powers within the company and, as the case may be, when discussing  
problems of professional, economic and social concern, may also invite the President of the  
Union.  
(z) any of the administrators may request to the Director General/Directors information regarding the  
operative management of the company. The Director General/Directors is bound to inform the  
Board of Directors, regularly and in a comprehensive manner, on the operations made and the  
envisaged ones.  
(3) Directors with mandate contracts have the following main duties:  
(a) to settle, based on the substantiation documents, the accommodation expenses, the per diem  
payments, the transport and other expenses, for the travel assignments in the country and  
overseas, within the limits set by the income and expenditure budget for these expenses;  
(b) to be granted the transport by company vehicle (with driver or personal drive) to fulfil his  
duties;  
(c) to hold professional liability insurance, the exchange value thereof being borne by CONPET  
S.A., under the law;  
(d) to benefit from paid days off every calendar year, which are not assimilated to the rest leave  
provided by the labor code, as well as other rights provided in the mandate contract;  
(e) to be provided a workplace within the Company in compliance with his qualification, as well as  
other rights in accordance with the legal provisions, at the end of the mandate;  
(4) The rights of the Directors are the ones stipulated in the contract of mandate concluded between the  
company represented by the Board of Directors through a member thereof, usually the Chairman of the  
BoD and the respective director. Through the Contract of mandate concluded with the company, the  
Director may be also granted other additional rights besides those stipulated in paragraph (3).  
Art. 22 Other provisions regarding the Directors with mandate contract  
(1) For the appointment of a director to be valid, the appointed person must accept it, expressly,  
by means of a written declaration.  
(2) The Director General/Directors are liable for paying all due diligence related to the Company  
management, within the limits of the scope of business of the Company and by the observance of the  
18  
exclusive competencies of the Board of Directors or of the General Meeting of Shareholders, reserved by  
Law or the Articles of Incorporation.  
(3) The duration of the Director's mandate is 4 years and may be renewed. The vacancy of the position of  
director is established by decision of the Board of Directors.  
(4) The director's mandate ends by completion of the duration of the mandate, by revoking the mandate,  
by wavering the mandate, as well as for any other reasons for the termination of the mandate provided by  
law, this Articles of Incorporation or the mandate contract.  
(5) The rights and obligations of directors with mandate contract will be those stipulated by the contract,  
by the decision of the Board of Directors regarding the delegation of management powers of the  
Company, by the provisions of this Articles of Incorporation and by the legal provisions applicable to the  
directors of joint stock companies.  
(6) The directors shall submit to the Company, ex officio or upon request, all identification, contact data  
and any personal data necessary to ensure the conditions for the execution of the Company's obligations,  
provided by law, the Articles of incorporation or the mandate contract.  
In the event of changes to the submitted data, the submission of the new data will be done by the  
Directors, ex officio.  
CHAPTER VII  
COMPANY MANAGEMENT  
Art. 23 The Audit  
A. The Financial Auditor  
(1) The financial statements of the company shall be audited by the financial auditors, natural or legal  
persons, under the law.  
(2) The financial auditors are elected by the general meeting of shareholders and they carry on their  
activity based on the contract concluded with the company. The identification data of the financial  
auditors shall be registered with the Trade Register Office in accordance with the legal provisions.  
(3) The general meeting may approve the annual financial statements only if they are accompanied by the  
report of the financial auditor.  
(4) The annual financial statements, together with the administrators’ report and the financial auditor’s  
report shall remain filed to the company premises during the 30 days preceding the general meeting, in  
order to be consulted by the shareholders.  
(5) The shareholders may ask the Board of Directors, on their expense, copies of the annual financial  
statements and the other reports stipulated at paragraph (4).  
(6) In order to exercise the right to control, the significant shareholders may be presented, upon request,  
data regarding the company activity, the statement of assets and liabilities, of profit and loss.  
(7) Approval of the annual financial statements by the general meeting does not impede the exercise of  
the liability proceeding against the administrators, directors or financial auditors;  
(8) The financial auditors are bound to survey the company management, to check whether the financial  
statements are legally prepared and in accordance with the book records, if the latter are regularly kept  
and the evaluation of the assets elements was made as per the rules set for the preparation and  
presentation of the financial statements.  
(9) The duties and functioning of the financial auditors of the company, as well as the rights and  
obligations thereof are being complemented with the legal provisions in the area.  
19  
B. The internal audit  
(1) The Company shall organize the internal audit as per the general legislation regarding the internal  
audit and methodological norms drafted by the Romanian Financial Audit Chamber in this purpose.  
(2) The general objective of the internal public audit in the public entities is represented by the  
improvement of the management thereof and can be reached, mainly by:  
a) insurance activities, representing objective examinations of the evidence, made in view of  
providing the public entities and independent assessment of the risk management, control and  
governance related-processes;  
b) counselling activities meant to bring plus value and improve the governing processes in the  
public entities, the internal auditor not undertaking management responsibilities;  
(3) The internal auditors shall inform the Board of Directors members on the irregularities found during  
the performance of the company business, as well as the breach of the legal provisions and Articles of  
Incorporation.  
(4) The entity performing the Internal Public Audit is distinctly constituted under the direct subordination  
of the Director General. The internal audit activity is being recurrently reported to the Board of Directors,  
which analyzes and sets the necessary measures for a good organization and functioning of the company.  
The head of the Internal Public Audit Service is appointed/dismissed by the Director General, only with  
the approval of the ministry under whose authority is “CONPET” S.A.. The Director General approves the  
annual internal public audit plan and the annual report of the internal public audit activity.  
(5) The competence of the internal public audit covers all the activities performed within the company for  
the fulfilment of the objectives thereof, here included the assessment of the management control system.  
CHAPTER VIII  
COMPANY BUSINESS  
Art. 24 The Financial Year  
(1) The financial year represents the period for which must be concluded the annual financial statements  
and coincides to the calendar year.  
(2) As per the provisions of the Accounting Law no. 82/1991, republished, the Board of Directors is  
bound to submit to the territorial units of the Ministry of Public Finances, in electronic form, with an  
extended electronic signature attached, the annual financial statements, the administrators’ report and the  
financial auditorsreport.  
(3) The company is bound to publish, in the Official Gazette of Romania, part. IV, a notice to confirm the  
filing of the documents stipulated in paragraph (2).  
Art. 25 Company Personnel  
(1) The management and operating personnel is hired/appointed/dismissed/promoted/fired by the Director  
General;  
(2) The payment of wages and related taxes, of the social insurance rates, as well as of the other  
obligations to State and local budget shall be made as per the law.  
(3) The rights and obligations of the company personnel are being set by way of the Collective Labour  
Agreement, the Organizational and Operational Rules and Regulations and by own regulations.  
(4) The payment shall be made as per the legal legislation in force and provisions of the collective labor  
agreement.  
(5) Considering the business specificity, the company personnel concludes a non-disclosure agreement  
regarding the failure to submit/the non-disclosure of data and information they have become aware of  
during the labor contract execution, under internal regulation, individual or collective labor agreement.  
20  
The personnel must also comply with the regime of the inside information stipulated in Law no. 297/2004  
regarding the capital market and contingent regulations.  
Art. 26 Depreciation of Fixed Assets  
The Board of Directors approves, under the Law, the method to depreciate the tangible and intangible  
assets of the company’s Asset.  
Art. 27 Book-keeping and Financial Statements  
The Company holds the book-keeping, in national currency, observing the conditions stipulated by the  
Romanian legislation in force.  
The annual financial statements are prepared in compliance with the applicable accounting regulations  
and the accounting policies of the company.  
Art. 28 Calculation and Distribution of Profit  
(1) The company profit is being set under the law based on the annual financial statements approved by the  
ordinary general meeting of shareholders.  
(2) Out of the company profit shall be taken-over, every year, within a 5% limit, an amount for the  
formation of the reserve fund, as per the legislation in the area, until it reaches at least the fifth part of the  
share capital.  
(3) The remaining profit following the payment of the income tax shall be distributed as per the resolution  
of the general meeting of shareholders.  
(4) Out of the company profit can be constituted funds for the modernization, research and development of  
new products, investments, repairs as well as other destinations set by the general meeting of shareholders.  
(5) The payments of dividends due to shareholders are being made by the company under the law  
following the approval of the financial statements by the general meeting and fixing the payment date, as  
per the legal provisions in force.  
(6) In case of loss registration, the general meeting of shareholders shall analyze the causes and decide  
accordingly, under the law.  
(7) Bearing the costs by the shareholders shall be made in proportion to the share capital contribution.  
Art. 29. Company Registries  
(1) The Company will keep up-to-date, beyond the records stipulated by law the following registries:  
a) A Shareholders’ Registry. The company contracts an Independent Registrar to keep the electronic  
record of the Shareholders Registry and log the registration and perform other relevant operations;  
b) A Journal of the meetings and general meetings deliberations;  
c) A Journal of the meetings and BoD deliberations;  
d) A registry of bonds, to show the total bonds issued and disbursed, as well as the bearers’ first name,  
surname, place of domicile or headquarters, when the bonds are nominative. The evidence of the bonds  
issued in dematerialized form and which are being transacted on an organized market shall be held as per  
the law.  
e) A registry of the deliberations and findings made by the internal auditors, during the mandate execution  
thereof.  
(2) The administrators or, as the case may be, the Independent Registrars, are bound to make available to  
the shareholders the registry stipulated at letter a) and issue, upon request, a statement of account.  
21  
Moreover, they are bound to make available for the shareholders and bonds bearers, under the same  
conditions, the registries stipulated at letters b) and d).  
CHAPTER IX  
AMENDMENT OF THE LEGAL FORM, DISSOLUTION, LIQUIDATION, LITIGATIONS  
Art. 30 Amendment of the Legal Form  
(1) Amendment of the legal form of the company shall be made only based on the resolution of the  
extraordinary general meeting of shareholders and by the fulfilment of all formalities stipulated by law  
and this Articles of Incorporation.  
(2) The new company will fulfil all legal registration and advertising formalities requested at the  
companies’ set-up.  
Art. 31 The Company Dissolution  
1) The company dissolution shall take place in the following situations:  
a) impossibility to achieve the company business scope;  
b) opening of the company bankruptcy procedure;  
c) declaration of the company nullity by way of a final and irrevocable Court judgment;  
d) losses due to which the net asset, determined as difference between total assets and company  
liabilities, represents less than half the share capital, after having consumed the reserves fund due  
to reasons that trigger no responsibility of any kind, unless the general meeting of shareholders  
agrees upon the restitution of the share capital or reduction thereof to the remaining amount;  
e) Court judgment, upon the request of any shareholder, for ground reasons, as well as the  
misunderstandings  
f) between the shareholders, that impede the company operation;  
g) decrease of the number of shareholders below the minimum legal threshold;  
h) share capital reduction below the minimum imposed by the law;  
i) other causes stipulated by law or the Articles of Incorporation of the company.  
(2) The resolution to dissolute the company must be inscribed in the Trade Registry and published in the  
Official Gazette of Romania, part IV.  
Art. 32 Company Liquidation  
(1) The company dissolution has as effect the opening of the liquidation procedure as per the legal norms,  
except for the merger or total division thereof.  
(2) The company liquidation and distribution of assets are made under and by observance of the  
procedure stipulated by law.  
Art. 33. Merger and Division  
The company’s merger, respectively division take place based on the resolution of the extraordinary  
general meeting of shareholders, as per the applicable legal provisions.  
Art. 34 Litigations  
(1) The company litigations with Romanian natural or legal persons are the jurisdiction of the Instance  
Courts in Romania, as per the Law.  
22  
(2) The litigations arising from the contractual relations between the company and Romanian legal  
persons may be also settled through arbitrage, as per the law.  
CHAPTER X  
FINAL PROVISIONS  
Art. 35 Final Provisions  
(1) The provisions of this Articles of Incorporation are being complemented by the provisions of GEO no.  
109/2011 regarding the corporate governance of the public enterprises, of Law no. 31/1990 regarding the  
companies, of the Civil Code, Trade Code and of the legislation in force regarding the capital market.  
(2) This Articles of Incorporation has been updated on 27.04.2023 following the amendments approved  
by the EGMS Resolution no. 1/27.04.2023, based on the Articles of Incorporation updated on 28.04.2022  
and was drafted and signed in 3 (three) original copies.  
23  
Anexa nr. 8  
Personal information  
Cristian – Florin Gheorghe  
Date of birth  
Nationality Romanian  
Gender Male  
Professional experience  
2024 – to date Director General  
Directorate General of Electricity, Oil and Natural Gas  
Ministry of Energy  
2021 – 2024 Director General  
Directorate General of Electricity and Natural Gas Markets,  
Efficiency and Risks  
Ministry of Energy  
2020 –2021 Director General  
Department of Energy  
Ministry of Economy, Energy and Business Environment  
2018 – 2020 Director General  
Directorate General of Crude Oil and Natural Gas  
Ministry of Energy  
2017 Senior Advisor  
Directorate General of Energy Policies  
Ministry of Energy  
2018 – to date Member of the Board of Directors of the company CONPET S.A.  
Ploiești  
Chairman of the Board of Directors  
2017 – to date Member of the Board of Directors of the company OIL TERMINAL  
S.A.  
Chairman of the Board of Directors  
2018 – 2020 Member of the Board of Directors – ACROPO  
Regulatory Competent Authority for Offshore Oil Operations in  
the Black Sea  
2017  
Personal Advisor to the Minister of Energy  
Ministry of Energy  
Advising the Minister on some aspects related to all activities related  
to energy products  
2015 – 2016  
Member in the Board of Directors of the company OIL TERMINAL  
S.A.  
President of the Audit Committee  
Oil Terminal Company  
2 Caraiman Street, postal code 900117, Constanța (România)  
Coordinating the Audit Committee  
Type of activity or business: Handling – providing services regarding  
the reception, loading, unloading of crude oil, petroleum,  
petrochemical, chemical products, as well as other end products or  
liquid raw materials for import, export and transit  
2013 – 2016 Parliamentary Advisor  
Romanian Parliament – Chamber of Deputies – deputy Remus  
Cernea  
Parliament Palace, 2 – 4 Izvorului Street, sector 5, postal code  
050563 Bucharest, Romania, www.cdep.ro  
Parliamentary advisor on environmental issues  
2014 – 2016 Director General  
S.C. AS PETROL RECYCLE S.R.L.  
2008 – 2014 Marketing Director  
S.C. EURO METAL TRADING S.R.L.  
2006 – 2008 Marketing Director  
S.C. AS METAL COM S.R.L. – I.M.G.B. platform  
2004 Director General  
S.C. AVIS CONSULTING S.R.L.  
2000 – 2003 Marketing Director  
S.C. AR METAL S.R.L.  
Education and professional training  
2018 – 2022 PhD in Accounting and Financial Audit  
Doctoral school  
Valahia State University  
01.11.2017 Prince2 – Foundation Certificate in Project Management  
Global Best Practice www.axelos.com  
2002 Diplomate Engineer in the field of Economic Engineering  
Bioterra University – Faculty of Engineering and Agrotourism  
Management  
Bucharest, Romania  
1993 Vocational Technical Highschool Metaloglobus  
Bucharest, Romania  
Personal Competences  
Mother tongue  
Romanian  
UNDERSTANDING  
SPEAKING  
Spoken Spoken  
interaction production  
B1 B1  
WRITING  
B1  
Listening  
Reading  
Foreign  
languages  
English  
B1  
B1  
Levels: A1 and A2: Basic user - B1 and B2: Independent user - C1 and C2:  
Proficient user  
Common European Framework of Reference for Languages  
Excellent communication skills, competencies of management  
and negotiation as a result of my expertise.  
Team spirit.  
Able to create and implement high standards within a company.  
Rigour, creativity, patience and professionalism.  
Commitment.  
Communication  
skills and  
competences  
Organizational/  
managerial skills and  
competencies  
Abilities to lead and organize large teams of persons;  
Able to implement beneficial changes within a company;  
SELF – ASSESMENT  
Information  
processing  
Proficient  
user  
Content  
creation  
Problem  
solving  
Communication  
Proficient user  
Safety  
Digital skills  
Proficient Proficient Independent  
user user user  
Driver’s license  
B category  
Curriculum vitae  
Europass  
Personal Information  
First name / Surname  
Nationality  
Nicuşor Marian Buică  
Romanian  
Year of birth  
Professional Experience  
Period  
Occupation or position held  
December 2017 – October 2024  
Director General  
Name and address of employer  
Type of activity or business sector  
SAI Muntenia Invest  
Authorized Investment Management Company  
Registered Administrator of Alternative Investment  
Funds  
Period  
September 2020 - present  
Non-executive administrator  
BIOFARM  
Occupation or position held  
Name and address of employer  
Type of activity or business sector  
Manufacturing of pharmaceutical preparations  
Period  
September 2019 - present  
Non-executive administrator  
CONPET S.A.  
Occupation or position held  
Name and address of employer  
Type of activity or business sector  
Transport through pipelines  
Period  
June 2019 - present  
Occupation or position held  
Name of employer  
Type of activity or business sector  
Non-executive administrator  
ICPE S.A.  
Research - development in other sciences and  
engineering  
Period  
Occupation or position held  
Name of employer  
March 2018 - present  
Non-executive administrator  
COCOR S.A.  
Renting and subletting of own or rented real  
estate  
Type of activity or business sector  
Period  
May 2017 - present  
Occupation or position held  
Name of employer  
Type of activity or business sector  
Board of Directors’ member  
The Company INCERTRANS S.A.  
Research-Design Institute  
Period  
Occupation or position held  
Name of employer  
March 2017 – December 2017  
Board of Directors’ member  
SAI Muntenia Invest S.A.  
Type of activity or business sector  
Authorized Investment Management Company  
Period  
Occupation or position held  
Name of employer  
June 2016 – December 7th, 2016  
Board of Directors’ member  
Swiss Capital S.A.  
Type of activity or business sector  
Financial Services and Intermediation Company  
Member of Bucharest Stock Exchange  
Period  
Occupation or position held  
Name of employer  
May 2016 – October 2016  
Director  
Romenergo  
Type of activity or business sector  
Activities in the energy field  
Period  
Occupation or position held  
Name of employer  
October 2015 – April 2016  
State Secretary  
Ministry of Investment and European Projects  
Type of activity or business sector  
Central Public Authority  
Period  
Occupation or position held  
Name of employer  
December 2014 - July 2015  
Board of Directors’ member  
Enel Energie Muntenia S.A.  
Electricity supply  
Type of activity or business sector  
Period  
Occupation or position held  
Name of employer  
August 2014 – December 2014  
Counselor to the Minister Delegate for the Budget  
Ministry of Public Finance  
Type of activity or business sector  
Central Public Authority  
Period  
Occupation or position held  
Name of employer  
March 2013 – March 2014  
Secretary of State  
Ministry of Transports  
Central Public Authority  
Type of activity or business sector  
Period  
Occupation or position held  
Name of employer  
June 2012 – November 2012  
Secretary of State Counsellor  
Ministry of Environment and Climate Changes  
Central Public Authority  
Type of activity or business sector  
Period  
July 2010 – June 2012  
Occupation or position held  
Name of employer  
Chairman of the Board of Directors  
Dunapref S.A.  
Type of activity or business sector  
Prefabricated for civil constructions, roads,  
bridges, railways  
Period  
Occupation or position held  
Name of employer  
January 2008 – May 2009  
Commercial Director  
Apolodor Com Impex  
Type of activity or business sector  
Special foundations, Infrastructure works,  
Demolitions, Civil constructions  
Period  
Occupation or position held  
Name of employer  
March 2005 – December 2007  
Board of Directors’ member - Executive Director  
Elpreco S.A.  
Type of activity or business sector  
Manufacturer of construction materials  
Period  
Occupation or position held  
Name of employer  
October 2001 March 2005  
Development Director  
Elpreco S.A.  
Type of activity or business sector  
Manufacturer of construction materials  
Period  
February 2004 - 2006  
Occupation or position held  
Name of employer  
Internal audit  
Active International S.A.  
Type of activity or business sector  
Services and Financial Intermediation Company  
Member of Bucharest Stock Exchange  
Period  
2007 July 2009  
Occupation or position held  
Name of employer  
Manager Deputy Director  
Active International S.A.  
Type of activity or business sector  
Services and Financial Intermediation Company  
Member of Bucharest Stock Exchange  
Period  
Occupation or position held  
Name of employer  
January 1998 September 2001  
Investments Broker  
Active International S.A.  
Type of activity or business sector  
Services and Financial Intermediation Company  
Member of Bucharest Stock Exchange  
Education and training  
Period  
08.05.2023 11.05.2023  
Ongoing 2024 Professional Training Program for  
Management Positions  
Principal subjects/occupational skills covered  
Name and type of organization providing  
education and training  
AS Financial Markets  
FPCCOND6.2024  
Period  
06.06.2024 08.06.2024  
Principal subjects/occupational skills covered  
Ongoing 2024 Professional Training Program -  
Financial Regulations and Legislation course  
Millenium Financial Training Center  
Name and type of organization providing  
education and training  
Period  
17.05.2024 18.05.2024  
Principal subjects/occupational skills covered  
Managers of private pension funds and financial  
investment companies  
European regulations in the field of prevention of  
money laundering  
Name and type of organization providing  
education and training  
National Office for the Prevention and Combating  
of Money Laundering  
Period  
06.02.2024 07.02.2024  
Principal subjects/occupational skills covered  
Ongoing 2024 Professional Training Program –  
SB/FT Risks evaluation course  
AS Financial Markets  
Name and type of organization providing  
education and training  
Course code ERSBFT1.2024  
Period  
20.10.2023 21.10.2023  
Principal subjects/occupational skills covered  
Money laundering course  
Managers of private pension funds and financial  
investment companies  
Name and type of organization providing  
education and training  
National Office for the Prevention and Combating  
of Money Laundering  
Period  
05.10.2023 07.10.2023  
Principal subjects/occupational skills covered  
Continuous 2023 Professional Training Program -  
Investment Management Practices  
Name and type of organization providing  
education and training  
Millenium Financial training center  
MPC-01.II.2023 PAI  
Period  
28.09.2023 20.11.2023  
Principal subjects/occupational skills covered  
Continuous training and professional development  
program for management positions  
AS Financial Markets  
Name and type of organization providing  
education and training  
FPCOND4, 2023  
Period  
08.05.2023 11.05.2023  
Principal subjects/occupational skills covered  
Ongoing Professional Training Program 2023 –  
Prevention and Combating Money Laundering,  
Terrorist Financing and International Sanctions  
course  
Name and type of organization providing  
education and training  
AS Financial Markets  
Period  
28.09.2022 08.11.2022  
Principal subjects/occupational skills covered  
Ongoing training and professional development  
program for management positions  
AS Financial Markets  
Name and type of organization providing  
education and training  
Program code FPCCOND2.2022  
Period  
29.09.2022 01.10.2022  
Principal subjects/occupational skills covered  
ESG Environmental, Social and Corporate  
Governance  
Name and type of organization providing  
education and training  
Millenium Financial Training Center  
Period  
06.06.2022 09.06.2022  
Principal subjects/occupational skills covered  
Money laundering, terrorist financing and  
international sanctions Standards imposed on  
intermediaries 2022  
Name and type of organization providing  
education and training  
AS Financial Markets  
Period  
30.09.2021 03.10.2021  
Principal subjects/occupational skills covered  
Ongoing professional training program  
TTC-0062 - Advanced Corporate Governance  
Top Training Center  
Name and type of organization providing  
education and training  
Period  
29.03.2021 31.03.2021  
Principal subjects/occupational skills covered  
Ongoing professional training program  
MPC - 03.I.21.SB/FT  
Name and type of organization providing  
education and training  
Millenium Financial Training Center  
Period  
22.03.2021 24.03.2021  
Principal subjects/occupational skills covered  
Ongoing professional training program  
MPC-02.I.21.FIA/AFIA  
Name and type of organization providing  
education and training  
Millenium Financial Training Center  
Period  
16.02.2021  
Principal subjects/occupational skills covered  
Online money laundering Course  
P.17218  
Name and type of organization providing  
education and training  
Romanian Banking Institute  
Period  
01.10.2020 20.11.2020  
Ongoing professional training program  
FPC2.2020  
Principal subjects/occupational skills covered  
Name and type of organization providing  
education and training  
AS Financial Markets  
Period  
11.10.2019 28.11.2019  
Ongoing professional training program  
FPC1.2019  
Principal subjects/occupational skills covered  
Name and type of organization providing  
education and training  
AS Financial Markets  
Period  
01.10.2018 - 29.10.2018  
Ongoing professional training program  
FPC3.2018  
Principal subjects/occupational skills covered  
Name and type of organization providing  
education and training  
AS Financial Markets  
Period  
November 2017  
Principal subjects/occupational skills covered  
Name and type of organization providing  
education and training  
Manager - innovation  
Romanian Ministry of Education and Scientific  
Research  
Period  
October 2017 November 2017  
Certificate of Graduation  
Innovation Manager  
Principal subjects/occupational skills covered  
Name and type of organization providing  
education and training  
CIT IRECSON - Centrul de Informare Tehnoloqicä  
SRL Bucureşti/ Technology Information Center  
-
Level in the national  
or international classification  
Proficiency Course  
Period  
October 2003 March 2005  
Title of Qualification/Diploma awarded  
Master of Business Administration - graduation  
certificate no. 200513205/November 22, 2005  
Turnaround Management; Marketing management;  
Manager economics; Investment management;  
Business policy  
Principal subjects/occupational skills covered  
Name and type of organization providing  
education and training  
City University, State of Washington, USA  
Level in the national  
EMBA  
or international classification  
Period  
September 16th-25th, 2005  
Title of Qualification/Diploma awarded  
Graduation certificate - PROFESSIONAL SALES  
MANAGEMENT September 25th, 2005  
Sales techniques and methods; Modern systems  
of organizing sales departments  
Principal subjects/occupational skills covered  
Name and type of organization providing  
education and training  
Bucharest Chamber of Commerce and Industry  
and Royal Trading House S.R.L.  
Level in the national  
or international classification  
Specialization  
Period  
1998 2003  
Title of Qualification/Diploma awarded  
Diploma  
in  
Economics,  
U
series,  
no.  
0041447/February 2003, Economics, Banking  
Financial Management Specialization  
Principal subjects/occupational skills covered  
Financial Management; Finance and Banking; The  
economy and the role of banks; Payment methods,  
tools and techniques; Financial analysis of  
economic agents; Introduction to marketing;  
Financing in international trade; Efficiency and  
valuation of investments; Asset and Liability  
Management  
Name and type of organization providing  
education and training  
University of Craiova, Faculty of Economic  
Sciences  
Level in the national  
or international classification  
Bachelor’s degree  
Period  
1994 1997  
Title of Qualification/Diploma awarded  
Engineering assistant diploma, P Series, no.  
004495/June 1997, majoring in Mechanics,  
Materials and Defectoscopy specialization.  
Valedictorian  
Principal subjects/occupational skills covered  
Mechanics; Material resistance; Appliances;  
Electric machines; Thermal machines;  
Constructive elements of fine mechanics  
Bucharest University of Polytechnics  
Name and type of organization providing  
education and training  
Level in the national  
Graduation Diploma  
or international classification  
Personal Skills And  
Competences  
Mother tongue(s)  
Romanian  
Foreign language(s)  
Social skills and competences  
Good ability to adapt to multicultural environments, team spirit  
Verified skills in a professional context  
Organizational skills and  
competences  
Organizational spirit, planning skills  
Technical skills and competences  
Detailed knowledge of company management. Sales systems.  
Ability to analyze and implement new projects. Knowledge in the  
field of financial management.  
Technical knowledge in the field of mechanical industrial  
processes and in the field of machine building technologies.  
Competencies in coordinating and guiding production and sales  
activities.  
Computer skills and competences  
Good use of Microsoft Office tools (Word™, Excel™ and  
PowerPoint™)  
Curriculum Vitae  
Personal information  
Surname / First name KOHALMI-SZABO LUMINIȚA – DOINA  
Nationality Romanian  
Gender Female  
Work experience  
Period 08.04.2021 -to date  
Name of the employer CONPET SA  
Type of activity and sector Oil transport via pipelines  
Administrator  
Occupation or position held  
Period 02.07.2019 to date  
LK Strategic Center SRL  
Name of the employer  
Type of activity and sector Consultancy in public relations and communication  
Occupation or position held Administrator as of 02.07.2019/General Manager as of 01.01.2023  
Period 20.02.2015 01.10.2022  
“Dimitrie Cantemir” Christian University, Faculty of Communication  
Sciences  
Name of the employer  
Type of activity and sector Education  
Occupation or position held Associate professor  
Period 06.06.2017 02.07.2018  
Romanian Parliament, Chamber of Deputies  
Name of the employer  
Type of activity and sector Central public administration  
Occupation or position held Counsellor  
Period 14.07.2015 31.05.2017  
Name of the employer Prive Boutique SRL  
Type of activity and sector Online Commerce  
Occupation or position held Marketing Specialist  
Period 20.02.2015 01.10.2022  
“Dimitrie Cantemir” Christian University, Faculty of Communication  
Sciences  
Name of the employer  
Type of activity and sector Education  
Occupation or position held Associate professor  
Page 1 of 6  
Period 06.02.2015 16.05.2016  
Name of the employer COMMONWEALTH CONSULTING SRL  
Type of activity and sector Management consultancy  
Occupation or position held Management Consultant  
Period 30.11.2013 29.02.2015  
“Dimitrie Cantemir” Christian University, Faculty of Communication  
Sciences  
Name of the employer  
Type of activity and sector Education  
Occupation or position held University Lecturer  
Period 01.06.2012 - 06.08.2012 and 07.09.2012 14.12.2014  
Name of the employer Presidential Administration  
Type of activity and sector Central Public Administration  
Occupation or position held Counsellor  
Period 30.12.2009 08.05.2012  
Name of the employer Ministry of National Development and Tourism  
Type of activity and sector Central public administration  
Occupation or position held Counsellor to the Minister’s Cabinet  
Period 03.03.2009- 31.12.2010  
Name of the employer Ministry of Tourism  
Type of activity and sector Central public administration  
Occupation or position held Counsellor to the Minister’s Cabinet  
Period 01.02.2005 01.06.2005 and 15.02.2007 15.06.2009  
Name of the employer Ministry of Defence  
Type of activity and sector Central public administration  
Occupation or position held Deputy Director Information and Public Relations Unit  
Period 01.06.2005 14.02.2007  
Name of the employer Ministry of Defence  
Type of activity and sector Central public administration  
Occupation or position held Director Directorate for Information and Public Relations  
Period 01.12.1998 01.04.2003  
Romanian Radio Broadcasting Company /Compania Romana de Radio si  
Televiziune SRL  
Name of the employer  
Type of activity and sector Broadcasting  
Period 01.05. 1998 01.12.1998  
Name of the employer RH Press SRL  
Page 2 of 6  
Type of activity and sector Newspaper  
Occupation or position held Reporter for “Cotidianul” Newspaper  
Period 01.10.1997 - 01.06.1998  
Name of the employer Tiporex SA  
Type of activity and sector Newspaper  
Occupation or position held Editor “Cotidianul” Newspaper  
Period 1990-1996  
Name of the employer Pre-university education units  
Type of activity and sector Education  
Occupation or position held Teacher of Physics  
EDUCATION AND  
TRAINING  
Period 1985 - 1991  
Qualification / diploma  
Bachelor’s degree/ Faculty of Physics  
awarded  
Molecular physics and heat, physics of the liquid state, thermodynamics.  
Main studied disciplines / mechanics and acoustics, electricity and magnetism, nuclear physics, quantum  
achieved professional skills mechanics, solid state physics, ion optics and spectroscopy, superconductivity,  
mathematics, chemistry  
Name and type of the  
education institution / “Babes – Bolyai” University – Cluj Napoca, Faculty of Physics  
training provider  
Period 2005-2008  
Qualification / diploma  
Military Sciences/PhD  
awarded  
Main studied disciplines /  
Military sciences, Security, Strategic Communication  
achieved professional skills  
Name and type of the  
education institution / “Carol I” National Defence University  
training provider  
POST UNIVERSITY  
STUDIES  
Period 2014  
Qualification / diploma Psycho pedagogical module, Level II (postgraduate studies)/ Graduation  
awarded certificate  
Teenagers, youngsters and adults’ psycho – pedagogy, design and management  
Main studied disciplines /  
of education projects, educational and field projects in speciality teaching,  
achieved professional skills  
education sociology, educational research methodology, pedagogical practice  
Name and type of the  
education institution / “Dimitrie Cantemir” Christian University, Faculty of Education Sciences  
training provider  
Page 3 of 6  
Period 2014  
Qualification / diploma Psycho pedagogical module, Level I (postgraduate studies)/ Graduation  
awarded certificate  
Main studied disciplines / Psychology of education, pedagogy, management of the class of students,  
achieved professional skills speciality education, computer-assisted learning, pedagogical practice  
Name and type of the  
education institution / “Dimitrie Cantemir” Christian University, Faculty of Education Sciences  
training provider  
Period 2005-2006  
Advanced training in the field of security and national defense (post-  
graduate studies)/ Certificate of graduation  
Qualification / diploma  
awarded  
Geopolitics and strategy, security policies and strategies, theory of international  
Main studied disciplines / relations/postgraduate course of excellence in the field of national security and  
achieved professional skills defense  
Name and type of the  
education institution /  
National Defense University, Cato I, National Defense College  
training provider  
TRAINING  
Period 2021  
Qualification / diploma Certificate of Participation to the “Advanced Corporate Governance  
awarded “course  
Main studied disciplines / Corporate governance included in the ongoing training program Top Training  
achieved professional skills Centre Executive Program 2021  
Name and type of the  
education institution / Top Training centre  
training provider  
Period  
2014  
Qualification / diploma Trainer/Graduation certificate  
awarded  
Elaborating the training and training programmes, evaluation of training  
participants, implementation of special training methods and techniques,  
marketing of training, design of training programmes, organization of training  
programs and traineeships, evaluation, review and assurance of quality of  
training programs and traineeships  
Main studied disciplines /  
achieved professional skills  
Name and type of the  
education institution / Body of Experts in Accessing the European Structural and Cohesion Funds  
training provider  
Period  
2014  
Qualification / diploma  
awarded  
Project manager/Graduation certificate  
Page 4 of 6  
Establishing the purpose of the project, establishing the integrated project  
management requirements, planning the project activities and milestones,  
Managing the use of operational costs and resources for the project, carrying  
out the procurement procedures for the project, risk management, project team,  
communication within the project  
Main studied disciplines /  
achieved professional skills  
Name and type of the  
education institution / Body of Experts in Accessing the European Structural and Cohesion Funds  
training provider  
Period 2005  
Qualification / diploma  
Graduation certificate  
awarded  
Main studied disciplines /  
Civil military democratic relations  
achieved professional skills  
Name and type of the  
education institution /  
Canadian Department of National Defense, Otawa  
training provider  
Period 2005  
Qualification / diploma Certificate of participation to the seminar  
awarded  
Main studied disciplines / Planning and effective implementation of communication campaigns  
achieved professional skills  
Name and type of the  
education institution / European Institute of Public Administration Maastricht  
training provider  
Period 2003  
Qualification / diploma  
Graduation certificate  
awarded  
Main studied disciplines /  
Customer relationship and quality management  
achieved professional skills  
Name and type of the  
education institution / The Open University Business School, UK  
training provider  
Period 2002  
Qualification / diploma  
Graduation certificate  
awarded  
Main studied disciplines /  
Competitive management  
achieved professional skills  
Name and type of the  
education institution / The Open University Business School, UK  
training provider  
Period 1996  
Qualification / diploma  
Graduation degree  
awarded  
Page 5 of 6  
Main studied disciplines /  
achieved professional skills  
BBC School of Radio Journalism  
Name and type of the  
education institution / BBC World Service  
training provider  
Strategic thinking and capacity to make forecasts  
Planning, organization and resource allocation for project management  
PERSONAL SKILLS AND Competencies at the level of an experienced user in the use of IT&C as a  
COMPETENCIES strategic tool in business (use of ERP, CRM, RPA concerns and the use of AI in  
business)  
Knowledge of corporate governance regulations, principles and concepts  
Experience in negotiations, social dialogue, interpersonal communication  
Teamwork skills  
Effective communication  
Dynamism, determination  
Stress resilience  
FEATURES Time management skills  
Empathetic  
Decision-making and involvement capabilities  
Identification and control of risks  
Analysis and synthesis capabilities  
Mother tongue Romanian  
Self-assessment  
Understanding  
Speaking  
Writing  
Spoken  
interaction  
Spoken  
production  
European level (*)  
Listening  
Reading  
Writing  
English  
French  
C1  
C1  
C1  
B2  
C1  
B2  
C1  
B2  
C1  
B2  
(*)Common European Framework of Reference for Languages  
Driving licence(s) B category  
Page 6 of 6  
TĂNĂSICĂ OANA  
LAWYER  
Name: Tănăsică Oana Cristina  
DOCTOR OF LAW  
Professional activity:  
Legal Advisor - 2002-2003  
Intern Lawyer 2003-2005  
Main Lawyer at Tănăsică Oana Law Firm, Bucharest Bar 2005 to date  
Insolvency Practitioner coordinator at Insolva IPURL 2012 to date  
Member of the National Integrity Council National Integrity Agency 2022 –  
2024  
Member in the Board of Directors of CONPET S.A. 2022 to date  
Education:  
Law Faculty Nicolae Titulescu University class of 1999 2002 Graduation Degree  
2002  
International Economic Relations Faculty Dimitrie Cantemir University Years IIV  
2002 2003  
Postgraduate studies:  
Doctor of Law as per the National Education Ministry Order No. 3779/04.06.2018 -  
Doctoral Law School, majoring in International Trade Law. Bucharest University, Law  
Faculty Doctoral thesis “Companies intended for commercial activity with foreign  
participation in Romania”, publicly presented on May 4th, 2017  
ISO 37001:2016 External Auditor - Anti-bribery management system - 2023  
Public Procurement Expert Course - 2009  
Master’s Degree in Conflict Mediation - Titu Maiorescu University, 2006  
Master’s Degree in Criminal Science Law Faculty - Nicolae Titulescu University,  
2004  
Psychological and Pedagogical courses for the training of the teaching staff –  
Oil and Gas University Ploiești, 2004  
Civil and Commercial Law post -university courses Law Faculty - Nicolae Titulescu  
University, 2003  
Participation in conferences, courses and seminars:  
Conference on Prevention and fight against money laundering, 2020  
Administrative Law conference, Bucharest University, 2019  
Conference on EU regulation 2016/679 GDPR, 2018  
National Contentious Administrative Conference, Bucharest, 2017  
National Office for the Prevention and fight against Money Laundering, 2012  
Romania - Austria Bilateral Conference organized by the Court of International  
Commercial Arbitration attached to the Chamber of Commerce and Industry of  
Romania, in collaboration with the Austrian Arbitration Association, 2010  
The odyssey of the whistleblower law organized by the Legal Universe - speaker 2023  
Awards:  
The Entrepreneur Club Gala, Edition I, 2020 - the prize awarded for the quality of  
services offered to entrepreneurs  
Lady lawyer Gala, Edition VI, 2019 - the prize awarded in the Category of Law Firms  
from big cities  
The Entrepreneur Club Gala, Edition XI, 2023 - Excellence Award in Integrity  
Services for Companies  
Articles, interviews, publications:  
Writer of the book Companies intended for commercial activity in Romania” –  
Universul Juridic Publishing House 2023  
Intellectual property rights. Benefits, threats, perspectives - article published  
http://newstragtegycenter.ro//wp-content uploads 2016/05 Prezentare-Av-Oana-  
Tanasica.pdf;  
Revocation of the administrator of the company intended for commercial activity  
The legal nature of the relationship between the administrator and the company -  
www.avocatura.com  
-
article  
published  
on  
May  
2017  
(http://www.avocatura.com/stire/16355/natura-juridica-a-raporturilor-dintre-  
administrator-si-societate. html);  
2004 - 2022  
Recognition of foreign judgments in Romania - Universul Juridic Publishing House  
no. 5/2017;  
Augmentation of the share capital of companies with foreign participation,  
intended for commercial activity - Universul Juridic Publishing House - Universul  
Juridic Magazine no. 6/2017;  
Lady Lawyer Magazine, Edition VI, 2019 Interview www.legalmagazine.ro,  
Special edition, November 2019;  
Clubantreprenor Magazine, Edition I 2020 Interview –  
www.clubantreprenor.ro, September 2020;  
Clubantreprenor Magazine, Edition XI, 2023, Interview integrity  
Membership to professional associations and organizations  
Bucharest Bar lawyer since 2004;  
National Union of Insolvency and Reorganization Practitioners - insolvency  
practitioner since 2011  
PNL ( National Liberal Party) member of the Municipal and County Political Bureau  
Foreign languages  
English Advanced  
French intermediate  
Curriculum Vitae  
GAVRILĂ Florin-Daniel  
PERSONAL INFORMATION  
Nationality Romanian  
Administrator CONPET S.A.  
PROFESSIONAL EXPERIENCE  
November 2024 to date  
Administrator  
Comalim SA, Arad  
Business field - Renting and subletting of own or rented real estate  
March 2024 to date  
Director  
LION CAPITAL SA, Arad  
Ensuring, together with the other Directors, the effective management  
of the company. Implements the company's strategy and objectives.  
Coordinates activities in the Corporate Administration and Operations  
segment. Member of the Investment Committee.  
January 2020 March 2024  
Operations Unit Director  
LION CAPITAL SA/SIF Banat-Crisana-SA, Arad  
Coordinating the activity of the departments Investment Analysis and  
Management of holdings, Cash management, Market operations and  
Projects in development  
Business field - Financial Investments  
September 2015 December  
2019  
Transactions Analyst  
SIF Banat-Crisana-SA, Arad  
Responsible for monitoring the portfolio of allocated issuers and carrying  
out investment decisions. Ensures the implementation of approved  
trading arrangements.  
Business field - Financial Investments  
May 2018 to date  
Administrator  
Conpet SA Ploiesti  
Business field - Transport via pipelines  
December 2015 to date  
Administrator  
SIFI Cluj Retail SA, Bucharest  
Business field renting and subletting of own or rented real estate  
February 2016 September  
2024  
Administrator  
Central SA, Cluj-Napoca  
Business field - renting and subletting of own or rented real estate  
April 2016 February 2023  
Administrator  
Uniteh SA, Timisoara  
Business field - renting and subletting of own or rented real estate  
October 2016 December 2016 Administrator  
SSIF BRK Financial Group SA, Cluj-Napoca  
Business field - Investment Company  
February 2013 July 2015  
Sales-Trader, Institutional Clients Unit  
SSIF Broker SA, Cluj-Napoca  
Stockbroker, in charge with sales-trading activity, particularly for the  
institutional clients (but also large-retail); stocks trading by DMA on the  
main European markets  
Business field: Investment Company  
March 2011 December 2012  
Sales-Trader, Institutional Clients Unit  
Unicredit CA~IB Securities Romania SA, Bucharest  
Stockbroker (authorized in April 2011), in charge with the sales-trading  
activity, particularly for the institutional clients (but also large-retail);  
stocks trading by DMA on the main European markets; sales-trading in  
cooperation with Unicredit office in London  
Business field - Investment Company  
February 2011 October 2023  
Tax Advisor  
The Romanian Chamber of Fiscal Consultants, Bucharest  
October 2005 March 2011  
Stockbroker/Deputy Director General  
SSIF Egnatia Securities SA, Bucharest  
- Stockbroker (authorized in December 2005), in charge with the trading  
activity for the firm’s clients, compensation-settlement agent authorized  
by Depozitarul Central  
- Deputy Director General (starting April 2007), overseeing the trading  
activity  
Business field - Investment Company  
July 2005 October 2005  
Economist  
SSIF European Securities SA, Bucharest  
- in charge with the post-trading activity for the firm’s clients  
Business field - Investment Company  
February 2004 June 2005  
Economist/ASIF  
SSIF Invest Trust SA, Craiova  
- Economist, afterwards financial investment services agent (authorized  
in June, 2004), in charge with the increase of retail clients portfolio  
Business field - Investment Company  
EDUCATION AND TRAINING  
2023  
Participant "Preventing and combating money laundering, terrorist  
financing and international sanctions"  
AS Financial Markets  
Participant "Money Laundering, terrorist financing and international  
sanctions"  
AS Financial Markets  
Participant “Money laundering, terrorist financing and standards  
imposed to the intermediaries”  
2022  
2021  
2020  
2009  
2007  
AS Financial Markets  
Participant “Money laundering, terrorist financing, international  
sanctions and standards imposed to the intermediaries”  
AS Financial Markets  
Participant “Capital Market Development, Enforcement and Oversight”  
National Securities Commission and US Securities and Exchange  
Commission  
Participant “The EU Single Market in Financial Services: Latest Steps,  
Future Initiatives and Pending Tasks”  
Public Administration European Institute, Luxemburg  
Master’s degree – European Economy  
Economy and Business Administration Faculty, Craiova  
2004-2006  
2006 Graduate “Investment Consultant” course  
Millenium Financial Trading Centre  
2006 Graduate “Derivative Markets Broker”  
BMFMS Sibiu  
2006 Financial Investment Services Agent RASIF02  
Bucharest Stock Exchange  
2004 Financial Investment Services Agent  
Millenium Training Financial Centre  
1999-2003 Bachelor’s Degree  
University of Craiova  
Faculty of Economy and Business Administration  
Program: International Economic Relations  
PERSONAL  
AND COMPETENCES  
Native language Romanian  
Foreign known languages  
SKILLS  
Understanding  
Speaking  
Writing  
Listening  
Reading  
Participation in the  
Oral speech  
conversation  
Advanced  
Advanced  
Advanced  
Beginner  
Advanced  
Beginner  
Advanced  
Beginner  
English  
German  
Independent User  
Independent User  
Good knowledge of Microsoft Office programms  
B category  
Digital competence  
Driving license  
Curriculum vitae  
Europass  
Personal Information  
First name(s) / Surname(s)  
Address(es)  
Zaman Andrei Mihai  
Mobile  
Facsimile(s)  
E-mail(s)  
Nationality Romanian  
Date of birth  
Gender Male  
PROFESSIONAL EXPERIENCE  
Period August 2022 to date  
Occupation or position held Member of the Board of Directors  
Name and employer address Conpet SA Ploiesti  
Period May 2022 to date  
Occupation or position held Director  
Main activities and responsibilities Establishing, in agreement with the GMS representatives and the management team the general, specific  
and operational objectives of the company, for the short, medium and long term;  
Identification and allocation of financial, informational, material and human resources in the company, in  
order to achieve the established objectives;  
Elaboration and approval of financial, technological and human resources investment plans;  
Planning of the organizational structures, according to the needs of the company and the planned activities;  
SC AFFICHAGE ROMANIA SRL  
Advertising  
Name and employer address  
Activity type or sector of activity  
April 2021 to date  
General Manager  
Euromedia Services  
Period  
Occupation or position held  
Name and employer address  
December 2017 to date  
Administrator  
Period  
Occupation or position held  
Ensuring the management, the organization and operation of the company with maximum efficiency by  
elaborating development strategies, identifying opportunities, employing the necessary financial,  
technological and human resources.  
Main activities and responsibilities  
Coordination of the activities of directors and managers by function: research, production, commercial,  
financial-accounting, human resources.  
Elaboration of the job description for the personnel who will be hired, along with the heads of the  
departments.  
The responsibility of archiving documents and storing them in the archive, for 10 (ten) years, of all the  
accounting registries and the supporting documents that are the basis of the accounting entries, with the  
exception of the salary statements that are stored for 50 (fifty) years.  
Ensuring compliance with the regulations issued by the Ministry of Finance regarding the elaboration and  
usage of the supporting documents for all patrimonial operations and their registration in accounting in the  
period to which it refers to.  
Signing accounting purchase documents in accordance with the provisions of the Law.  
SC EFECT MEDIA SRL  
Advertising  
Name and employer address  
Activity type or sector of activity  
June 2019 August 2020  
Period General Manager  
Occupation or position held Take Media  
Main activities and responsibilities  
October 2016 May 2019  
Period Administrator  
Occupation or position held Ensuring the management, the organization and operation of the company with maximum efficiency by  
Main activities and responsibilities developing development strategies, identifying opportunities, employing the necessary financial,  
technological and human resources.  
Coordination of the activities of directors and managers by function: research, production, commercial,  
financial-accounting, human resources.  
Elaboration of the job description for the personnel who will be hired, along with the heads of the  
departments.  
The responsibility of archiving documents and storing them in the archive, for 10 (ten) years, of all the  
accounting registries and the supporting documents that are the basis of the accounting entries, apart from  
the salary statements that are stored for 50 (fifty) years.  
Ensuring compliance with the regulations issued by the Ministry of Finance regarding the elaboration and  
usage of the supporting documents for all patrimonial operations and their registration in accounting in the  
period to which it refers to.  
Signing accounting purchase documents in accordance with the provisions of the Law.  
SC AFFICHAGE ROMANIA SRL  
Advertising  
Name and employer address  
Activity type or sector of activity  
Period October 2017 April 2019  
Occupation or position held Special Administrator  
Ensuring the management, the organization and operation of the company with maximum efficiency by  
elaborating development strategies, identifying opportunities, employing the necessary financial,  
technological, and human resources.  
Main activities and responsibilities  
Coordination of the activities of directors and managers by function: research, production, commercial,  
financial-accounting, human resources.  
Elaboration of the job description for the personnel who will be hired, along with the heads of the  
departments.  
The responsibility of archiving documents and storing them in the archive, for 10 (ten) years, of all the  
accounting registries and the supporting documents that are the basis of the accounting entries, except for  
the salary statements that are stored for 50 (fifty) years.  
Ensuring compliance with the regulations issued by the Ministry of Finance regarding the elaboration and  
usage of the supporting documents for all patrimonial operations and their registration in accounting in the  
period to which it refers to.  
Signing accounting purchase documents in accordance with the provisions of the Law.  
Name and employer address  
Activity type or sector of activity  
SC MULTIRECLAMA SRL  
Advertising  
2013 - to date  
Administrator  
Period  
Occupation or position held  
Main activities and responsibilities  
SC LED MEGA CONCERT SRL  
Event organizing  
Name and employer address  
Activity type or sector of activity  
Period December 2007 April 2009  
Occupation or position held Real Estate Agent  
Ensuring the management, the organization and operation of the company with maximum efficiency by  
Main activities and responsibilities  
elaborating development strategies, identifying opportunities, employing the necessary financial,  
technological and human resources.  
Coordination of the activities of directors and managers by function: research, production, commercial,  
financial-accounting, human resources.  
Elaboration of the job description for the personnel who will be hired, along with the heads of the  
departments.  
The responsibility of archiving documents and storing them in the archive, for 10 (ten) years, of all the  
accounting registries and the supporting documents that are the basis of the accounting entries, except for  
the salary statements that are stored for 50 (fifty) years.  
Ensuring compliance with the regulations issued by the Ministry of Finance regarding the elaboration and  
usage of the supporting documents for all patrimonial operations and their registration in accounting in the  
period to which it refers to.  
Signing accounting purchase documents in accordance with the provisions of the Law.  
SC RIVIERA GREEN SRL  
Real estate sales  
Name and employer address  
Activity type or sector of activity  
EDUCATION AND TRAINNING  
Period 1999 2003  
Qualification/diploma Graduation diploma  
Name of the educational entity Campina Oil High School, Electro-technical field of study  
National/ international ranking  
Period 2018 2021  
Qualification/diploma Bachelor’s degree  
Name of the educational entity Faculty of Economics - Marketing Studies, Spiru HaretUniversity  
National/ international ranking National  
Period 2021 2023  
Qualification/diploma Master’s degree  
Name of the educational entity Bioterra University Bucharest - Efficient management in public food services, agritourism and  
consumer protection  
National/ international ranking National  
PERSONAL SKILLS AND COMPETENCES  
Foreign languages  
Self-assessment  
European level (*)  
English  
Understanding  
Speaking  
Writing  
Written Production  
C1  
Listening  
Reading  
Spoken interaction Spoken production  
C1  
A2  
C1  
A2  
C1  
A2  
C1  
A2  
French  
A2  
Communication and negotiation skills acquired in management activities;  
Social skills and competences  
Coordination and organizational skills;  
Ability to develop and manage budgets;  
Resource management skills;  
Organizational skills and competences  
Ability to organize and coordinate teams.  
MS Windows, MS Office (Word, Power Point, Excel)  
Computer skills and competences  
Alin Mihael Danila  
Personal information  
Date of birth  
Nationality Romanian  
Gender Male  
Professional experience  
22.08.2023 – to date  
Ploiesti, Romania  
Member of the BoD of CONPET SA  
01.07.2024 – to date Provisional member in the BoD of EXPLOATARE SISTEM ZONAL PRAHOVA S.A.  
01.04.2024 – to date Deputy Director General –  
Ploiesti, Romania S.C. SERVICII DE GOSPODARIRE URBANA PLOIESTI S.R.L.  
13.10.2021 – 01.04.2024 Deputy Director  
Ploiesti, Romania S.C. SERVICII DE GOSPODARIRE URBANA PLOIESTI S.R.L.  
- Ensuring the management of the company's activity, its coordination and control  
regarding the use of financial, material and human resources, in order to achieve the  
company's objectives, directly or through subordinate personnel;  
- Fulfilling the decisions of the General Meeting of Shareholders and the Board of  
Directors (BoD) accurately and within the established terms;  
- The presentation, whenever requested or necessary, to the BoD of the revenues and  
expenditures budget performance, of the information regarding the economic and  
financial situation of the company, the stage of the investments, the stage of the measures  
implemented or any other requested documents and information, as well as the measures  
taken in case of non-fulfilment thereof;  
- Ensuring the monitoring in view of achieving the revenues and expenditures  
provisions/indicators;  
- Ensuring the management and functioning of the company, top management,  
organization, representation and administration of the company's activity, as per the law  
and the company’s Articles of Incorporation;  
- Presentation to the BoD, at the end of the financial year, of the level of fulfillment of the  
company's objectives, the balance sheet, the profit and loss statement, the  
censors/auditors' report and the annual report, as per the legal provisions in force.  
05.07.2019 – 31.10.2021 Director General  
Ploiesti, Romania S.C. SERVICII DE GOSPODARIRE URBANA PLOIESTI S.R.L.  
- Ensuring the management of the company's activity, its coordination and control  
regarding the use of financial, material and human resources, in order to achieve the  
company's objectives, directly or through subordinate personnel;  
- Fulfilling the decisions of the General Meeting of Shareholders and the Board of  
Directors (BoD) accurately and within the established terms;  
- The presentation, whenever requested or necessary, to the BoD of the revenues and  
expenditures budget performance, of the information regarding the economic and  
financial situation of the company, the stage of the investments, the stage of the measures  
implemented or any other requested documents and information, as well as the measures  
taken in case of non-fulfilment thereof;  
- Ensuring the monitoring in view of achieving the revenues and expenditures  
provisions/indicators;  
- Ensuring the management and functioning of the company, top management,  
organization, representation and administration of the company's activity, as per the law  
and the company’s Articles of Incorporation;  
- Presentation to the BoD, at the end of the financial year, of the level of fulfillment of the  
company's objectives, the balance sheet, the profit and loss statement, the  
censors/auditors' report and the annual report, as per the legal provisions in force.  
- Hiring, promoting and dismissing employed staff, in accordance with the law; negotiating  
the individual labor contracts, and participating in the negotiation of the Collective Labor  
Contract;  
- Establishing the necessary measures in view of achieving the company's approved  
revenues and expenditures budget, directly or through the subordinate staff;  
- Coordinating the specific activity carried out by the company’s directors;  
- The negotiation, as president of the negotiation committee, of the collective labor  
contract, based on the mandate granted by the BoD;  
- Informing the BoD regarding the irregularities discovered during the performance of their  
duties;  
- Concluding legal acts in the name and on behalf of the company.  
01.01.2017 – 05.07.2019 Head of the Public and Private Domain Administration Department / Urban Heating  
Ploiesti, Romania AUTONOMOUS ADMINISTRATION OF PUBLIC SERVICES  
- Coordination of the subordinated department;  
- Ensuring the proper execution of contracts and monitoring the achievement of tasks;  
- Taking measures and taking the initiative in solving job-specific activities;  
- The professional evaluation of the staff subordinated on the established time periods,  
in accordance with the legal provisions;  
- Responsibility for the current resolution of problems, approving and signing the  
department's assignments:  
- Establishing the specific objectives and performance indicators.  
05.01.2009 – 01.01.2017 Department Head of Bucov Botanical Garden  
Ploiesti, Romania COUNTY MUSEUM OF NATURAL SCIENCES  
- Management, organization and coordination of the subordinate team;  
- Establishing the general and specific objectives and the performance indicators for the  
subordinate service, in order to achieve the activity object;  
- Distributing to the subordinate personnel, hierarchically, the tasks assigned to be solved;  
- Tracking the timely resolution of assigned tasks;  
- Proposing and taking measures to improve performance within the coordinated  
structure;  
- Monitoring compliance with the rules of conduct and discipline by the subordinate  
personnel.  
05.01.2013 – 31.12.2016 Manager  
Ploiesti, Romania SC GREEN PROJECT AB ENERGY  
- Annually establishing, alongside the unit directors, of the general development  
objectives;  
- Informing each director on the general and specific objectives foreseen for each unit  
and ensuring that they are communicated to the staff within each unit;  
- Annual/biannual/quarterly monitoring of the degree of achievement of objectives;  
- Establishing personal objectives (performance indicators) and for top management in  
strict accordance with the company's objectives;  
- Participating in the annual preparation of the revenues and expenditures budget,  
analyzing the submitted proposals, making the necessary corrections and approving the  
final budget;  
- Monitoring the market and identifying development trends;  
- Analysis of legislative, financial, technological and social opportunities/constraints in the  
company's business environment;  
- Identifying ways to develop the services offered by the company in accordance with the  
market trends;  
- Identifying and attracting the necessary resources for the implementation of new  
business ideas:  
- Ensuring the company’s good image on the market;  
- Identifying of investment and profit opportunities;  
- Developing positive relationships with key people in order to strengthen the company's  
position;  
- Participating in business meetings with suppliers, clients, financial bodies and  
governmental institutions from the country and abroad;  
- Representing the organization in relations with third-party natural or legal persons in  
accordance with the power of attorney granted by the General Meeting of Shareholders.  
23.04.2009 – 05.01.2013 Executive Director  
Ploiesti, Romania S.C. PORA S.R.L.  
- Power to decide on new development directions;  
- Establishing sales and profit plans;  
- Representing the organization in relations with third-party natural or legal persons in  
accordance with the power of attorney granted by the General Meeting of Shareholders;  
- Signing payrolls, company financial reports, statistical reports or requests for  
investments within the company;  
- Requesting activity reports and taking the necessary measures in order to increase the  
efficiency of the company's activity;  
- Establishing task execution priorities for the subordinate staff;  
- Approval of rewards/penalties, extension/termination of the activity after the  
probationary period of the employees;  
- Approving/rejecting the requests of subordinate staff;  
- The annual establishment, alongside the unit directors, of the general development  
objectives;  
- Informing each director on the general and specific objectives foreseen for each unit  
and ensuring that they are communicated to the staff within each unit;  
- Quarterly/semi-annual/annual monitoring of the degree of achievement of objectives.  
01.12.2008 – 23.04.2009 Engineer  
Ploiesti, Romania S.C. PORA S.R.L.  
- Coordinating the team of workers in order to complete the assignments according to the  
timetable;  
- Elaborating reports on the stage of things and inclusion in the timetable;  
- Participating in work preparation sessions.  
01.08.2007 – 30.11.2008 Administrator  
Ploiesti, Romania S.C. AYC CONSULTING S.R.L. PLOIESTI  
- Ensuring the management of the company's activity, its coordination and control  
regarding the use of financial, material and human resources, in order to achieve the  
company's objectives;  
- Representing the company in business relations;  
- Establishing the company's business and development objectives.  
07.01.2003 – 16.01.2007 Engineer  
Ploiesti, Romania S.C. ASCM S.A.  
- Main objectives executed: CONPET STREJNlC Stadium, LUBRIFIN BRASOY factory,  
CARDINAL MOTORS Showroom, ANP Logistic Center, CRANGUL LUI BOT Electrode  
Factory;  
- Ensuring the construction plan;  
- Preparing the project plans;  
- Supervising the activity of the subordinate team;  
- Coordinating and controlling the field teams and the activities carried out by them;  
- Monitoring the progress of the tasks from a quantitative and qualitative point of view;  
- Preparing activity reports;  
- Planning, organizing, and monitoring the execution from the point of view of compliance  
with the plans, adherence to the established deadlines and the quality of the assignments.  
10.07.2001 – 07.01.2003 Engineer  
Ploiesti, Romania S.C. ALDECO ART S.R.L.  
- Supervising the activity of the subordinate team;  
- Coordinating and controlling the field teams and their activity;  
- Monitoring the progress of the tasks from a quantitative and qualitative point of view;  
- Preparing activity reports;  
- Studying construction plans and implementing them;  
- Ensuring permanent assistance for contractors, transmitting information to the Project  
Manager;  
- Ensuring the management of the quality management system at the location level;  
- Providing technical information and maintaining the relationship with the client over the  
course of the project.  
Education and professional training  
01.10.2018 – 01.06.2020 Master’s Degree  
Iasi, Romania Petre Andrei University  
Field of study: Leadership and political psychology  
01.10.2013 – 01.06.2016 Bachelor’s Degree  
Brasov, Romania George Baritiu University Brasov  
Field of study: Public administration  
01.10.1996 – 01.06.1999 Bachelor’s Degree  
Bucharest, Romania Bucharest University of Polytechnics  
01.04.2020 – 30.05.2020  
Ploiesti, Romania  
Project Manager  
Resume Consulting  
24.09.2009 – 27.09.2009 Advanced training  
Bucharest, Romania Ministry of Education  
Field of study: Performance management in public office  
22.02.2022 – 28.03.2022  
Ploiesti, Romania  
Human resources manager  
Prahova Chamber of Commerce and Industry  
12.05.2005 – 15.05.2005  
Curator  
Ministry of Culture  
LANGUAGE SKILLS  
Mother tongue: ROMANIAN  
UNDERSTANDING  
SPEAKING  
Other languages  
WRITING  
Listening  
Reading  
Spoken interaction  
Spoken production  
ENGLISH  
ITALIAN  
C1  
B1  
C1  
C1  
B1  
C1  
C1  
B1  
B1  
B1  
Levels: A1/A2 Basic user – B1/B2: Independent user – C1/C2: Proficient user  
Digital competences  
My digital competences  
Microsoft Office (Word, Excel, Power Point) | Microsoft Office (Word, PowerPoint, Excel, Access)  
DRIVING LICENSE  
All categories: A, B, C, C+E, D  
STATEMENT OF THE PERSONS IN CHARGE  
of CONPET SA  
in compliance with the provisions of  
Art. 30 of the Accountancy Law No. 82/1991 and Art. 65 of Law No. 24/2017 on the issuers of  
financial instruments and market operations  
There were drafted the financial statements at the date and for the year ended on 31 December  
2024 for:  
Entity  
CONPET SA  
County  
PRAHOVA  
Address  
Trade Registry Number  
Type of ownership  
1-3 Anul 1848 Street, Ploiești  
J1991000006291  
26 - Publicly and privately owned companies with  
domestic and foreign capital  
4950 - Transport via pipelines  
1350020  
Core business (NACE code)  
Tax Registration Number  
The undersigned: Dorin Tudora, as Director General and Sanda Toader, as Economic Director  
are liable for the drafting of the annual financial statements on 31.12.2024 and confirm that:  
a) The accounting policies used in preparing the annual financial statements are in accordance with  
the accounting regulations in force on the reporting date 31.12.2024;  
b) from our point of view:  
a. the annual financial-accounting statement that was drafted in accordance with the applicable  
accounting standards provides a true, fair and accurate picture of the company's assets,  
liabilities, financial position, profit and loss account and other information regarding the activity  
carried out;  
b. The administrators report comprises a correct analysis of the development and performance  
of the company, as well as a description of the main risks and uncertainties particular to the  
activity performed; and  
c. The annual financial statements and the Administrators' Report are prepared in accordance  
with the International Financial Reporting Standards (IFRS) and the sustainability reporting  
standards referred to in Art. 29b of Directive 2013/34/EU and with the specifications adopted  
pursuant to Art. 8, Para. (4) of (EU) Regulation 2020/852.  
c) The company operates under conditions of continuity;  
DIRECTOR GENERAL,  
Eng. TUDORA Dorin  
Economic Director  
Econ. Toader Sanda  
I
PKF  
Finconta  
}
REPORT OF THE INDEPENDENT  
FINANCIALAUDITOR  
(free  
translation from romanian versionl  
)
To  
shareholders of CONPET  
S.A.  
Report  
financial  
on standalone  
statements  
Opinion  
1. We have audited the accompanying financial  
("The  
statements of CONPET S.A.  
no.1-3,  
Company"),  
with  
the  
registered office in Anul 1848  
Street,  
Ploiesti, district Prahova, identified  
position  
by the  
unique tax  
December  
31,  
registration code 1350020, which include  
the statement of the financial  
as  
at  
profit  
2024,lhe  
statement of the  
and loss  
account and other comprehensive income,  
the statement  
of  
year  
ended,  
and a summary of  
changes in equity and the statement  
flows for  
of cash  
and explanatory notes.  
the  
significant  
policies  
accounting  
2. The financial  
statements as at December  
31  
are identified as follows:  
730,693,250|ei  
49,323,047lei  
present  
,2024  
o
Net  
asseUTotal equity:  
o
year profit:  
financial  
-
Net result of  
the  
3. ln our opinion, the accompanying financial  
statements  
fairly, in  
all material respects,  
the financial  
position  
performance  
of  
year  
then ended  
the Company as of December 31 2024, its financial  
,
for the  
and  
cash flows, in accordance with the Order  
of the Minister of Public Finance no. 284412016  
for  
the approval  
of accounting regulations in accordance with  
subsequent amendments.  
the lnternational Financial Reporting  
Standards, with  
Basis for  
opinion  
4. We  
in  
conducted our audit  
accordance lnternational  
with  
(lSAs),  
Standards on Auditing  
European  
Regulation no.  
issued  
by European Parliament  
537  
(,,Law").  
and Council and Law no 16212017  
Our  
responsibilities  
under those standards are further  
described in the Auditor's Responsibilities  
for  
the Audit  
of the financial statements section our report. We  
of  
independent  
are  
of  
the Company  
in accordance with  
(IESBA  
the Code of Ethics for Professional Accountants  
Code) issued  
by the Council for  
lnternational  
Ethics Standards for Professional Accountants  
as it was  
adopted and implemented  
by the Romanian  
Chamber of Auditors and we have fulfilled  
our other ethical responsibilities  
in accordance  
with the  
requirements  
IESBA  
We  
believe that the audit  
of  
Code.  
evidence we have  
obtained is sufficient  
and  
provide  
appropriate to  
a basis for our  
opinion.  
Key audit matters  
judgement,  
professional  
5. The key audit matters  
are those aspects that, based  
on our  
were of  
most  
been  
period.  
in  
significance  
the audit of the financial statements  
of the current  
These  
issues have  
addressed in  
them and we do not  
o
the context of the audit of financial statements  
whole  
and in forming  
as a  
our opinion on  
give  
a separate opinion on these key issues.  
Provisions for litigations.  
-
Description. The  
company is involved in numerous  
with  
partners,  
litigations  
business  
authorities and salaries, thus  
is  
there a risk of future economic losses.  
"Proyisrons  
At Note 13  
"
are disclosed the significant litigations in  
provision  
which the Company is involved.  
The decision  
to book a  
for litigation  
or to disclose a contingent liability  
in financial  
statements depends  
on the  
r
Translator's  
provided  
explanatory note: The above translation  
of the auditor's repoft is  
as a free  
translation from Romanian  
which is  
the official and binding version.  
Adresi: Str. Grigore  
(+40)21  
Mora, nr.37, Sector 1, Bucuretti, Romania  
t
Tef./Fax:  
317 31 90/96.  
PKF Fincontd S.R.L, este o societote membrd o PKF Globol, reledud de  
entitdti membre ole PKF lnternotionol Limited,  
dintre ocesteo reprezentlnd  
o
liecare  
pentru acliunile  
juridic  
punct  
entitdte seporotd  
independentd  
din  
de vedere  
nu acceptd nicio responsabilitate sou  
rdspundere  
ti  
sau  
inacliunile oricdtui membru  
$i  
individuol sdu o unei entitdli corcspondente.  
pKF  
Finconta  
a,i',  
}
judgment  
professional  
and certain  
estimates of the Company's management.  
We  
considered  
as it would  
provisions  
whether the recognition  
of some  
for litigation is  
significant for the audit,  
cause the recognition of overestimated results.  
procedures  
-
Our response.  
Our audit  
to  
risk  
address the  
of material misrepresentation  
in relation  
provisions  
to the recognition  
for  
litigation, which was  
of  
considered as material risk,  
included:  
-
reviewing the decisions  
Directors;  
of the General Meeting of  
Shareholders and of  
Board  
the  
of  
-
obtaining and evaluating  
litigations  
in which the Company is  
the  
involved, followed  
by  
obtaining some clarifications regarding  
the status of certain disputes. During  
the audit  
mission,  
discussions were held with the management  
and Company's internal legal  
advisers on significant litigations;  
-
critical assessment of the working assumptions  
and estimates made  
provisions  
the financial  
risks related  
to litigations in notes  
by the Company  
in  
regarding  
litigations, including  
the amount of recognized  
potential  
statements. We reviewed  
to the financial statements.  
the disclosures of  
the  
o
Revenue recognition.  
-
policy  
is  
Description. The revenue recognition  
disclosed at Note  
S "Accounting Policies".  
the revenue recognition,  
According  
international  
to  
auditing standards, there is an implicit risk in  
pressure  
due to  
the  
that the management have to meet  
results.  
the budgeted  
The main revenue  
by the transport service  
generating  
activities for the Company are represented  
of crude oil,  
System. The  
gasoline  
and condensate  
through the operation of the National Transport  
transport  
general  
public  
activity is an activity of  
natural monopoly  
interest,  
authorized and monitored  
practiced  
by a  
authority,  
with a  
The  
tariffs  
character.  
by  
the Company for transport  
services are  
(National  
ANRMPSG  
established  
and approved by  
Regulatory  
Authority for Mining,  
Petroleum  
and Geological Storage  
Dioxide);  
of Carbon  
-
procedures  
Our response. Our  
to  
audit  
to address the risk of  
significant distortion  
and in relation  
revenue recognition included,  
among others:  
-
Understanding how to recognize and  
book the main categories  
income;  
of  
-
-
-
Detailed tests on the transactions registered  
procedures  
year;  
by the Company during the financial  
period;  
Testing  
to ensure that revenues  
are recorded in the  
correct  
Procedures for confirmation  
of commercial receivables for representative  
a
sample.  
matters  
Other  
This report is  
6.  
addressed exclusively to the shareholders  
of the Company  
as a whole. Our  
audit was  
have to  
do not  
in  
carried out order to be able to report to the Company's  
shareholders those  
aspects that we  
purposes.  
report  
financial  
permitted  
To the extent  
by law, we  
to a  
audit report and not for other  
accept  
responsibility  
or assume  
only to the Company  
its  
and  
shareholders, as  
a whole, for our  
audit, for  
this report.  
7. Taxation in Romania is constantly  
possibility  
of different interpretations  
There  
evolving.  
is the  
of the legal  
provisions  
by the Ministry of Finance and by  
presented  
local  
the  
tax authorities. The  
company's management  
has  
based on the best interpretation  
possible  
penalties  
registered in  
the accounts  
various  
taxes,  
and fees,  
provisions  
of the tax  
in force,  
interpretation  
an  
that can be challenged  
by a  
fiscal  
control.  
Other information Administrators'  
Report  
-
preparation  
presentation  
The  
8.  
administrators are responsible for the  
and  
not include  
information.  
That  
of other  
the financial  
information includes  
audito/s report.  
the Administrator's Report but  
does  
statements and  
the  
Our opinion on the financial  
statements does not cover and these  
information  
and  
Other  
explicitly mentioned in our report,  
does not express any kind of  
except for the  
in which is  
case  
assurance conclusion.  
Adresli Str. Grigore Mora, nr.37, Sector 1, Bucuregti,  
(+40)21  
Romania  
2
Tel./Fax:  
PKF Finconto S,R,L. este o societqte membrd o PKF Globql, releauo de  
entitdti membre ole PKF lnternotionol Limited,  
pentru  
acceptd  
nu nicio responsqbilitote squ rdspundere  
dintre ocesteq reprezentind  
o
fiecore  
actiunile  
jutidic  
punct  
entitqte seporotd  
independentd din  
de vedere  
squ  
inocliunile oricdrui  
membru  
5i  
ti  
individual sou a unei entitdfi corespondente,  
1'  
PKF  
Finconta  
}
year  
ended on 31 December  
2024, our  
ln relation  
audit  
financial  
for  
to the  
of the  
statements  
the financial  
responsibility is  
read that information  
in  
to  
inconsistent with  
and, this approach, and to assess whether  
information  
that  
is  
significantly  
the audit, or  
the financial statements,  
it appears to be significantly distorted.  
with  
the knowledge we have  
or  
obtained  
during  
whether  
Regarding  
Administratois Report, we have read  
report whether it  
the  
and  
has been imprinted,  
in all  
paragraphs  
significant aspects, in accordance with the requirements  
19.  
OMFP 284412016, Annex  
of  
1
15-  
,
out  
flnancialstatements,  
year  
ln the exclusive basis of the activities to be carried  
opinion:  
during the audit of the  
in  
our  
a) The information submitted in the Administrator's Report for the financial  
for which  
financial  
financial  
the  
have  
be  
in all material respects,  
with  
the  
statements  
statements.  
been entered shall  
consistent,  
prepared,  
Annex 1,  
b) The Administrators' Report, was  
requirements of OMFP 284412016,  
in all significant aspects, in accordance with  
the  
paragraphs  
15-19.  
knowledge  
its  
environment, acquired  
ln addition, based onthe  
during the audit of the  
and understanding of the Company and  
year  
December  
ended on the  
31  
financial  
for  
financial  
statements  
the  
we  
,2024,  
Report. We have  
report we have identified  
in  
Administrato/s  
responsible for  
preparing  
financial  
statements that  
are asked to  
if  
significant distortions the  
nothing to report on this.  
persons  
governance  
for financial  
Responsibilities of management  
and  
statemenb  
provide  
a true  
and  
management  
deems  
The  
management is responsible for  
9.  
Company's  
fair view in accordance with OMFP 284412016 and for that internal control that  
the  
preparation  
necessary to enable them. the  
either by fraud or error.  
of financial statements free of significant  
distortions, caused  
prepare  
10. ln  
financial statements, the management is responsible for  
assessing the Company's  
order to  
presenting,  
for  
if  
ability to continue its activity,  
applicable, the aspects related to the continuity  
of the  
case  
you  
for  
use of  
are based  
activity and  
the  
accounting  
on the continuity of the activity, except for the  
stop  
the operations, or has no  
other  
where  
management either intends to liquidate the Company  
the  
alternative realistic in outside them.  
orto  
govemance  
Persons in  
process.  
responsible for  
overseeing the Company's financial reporting  
11.  
charge of  
are  
The  
responsibilities on audit of the financial statemenF  
auditor's  
12. Our objectives are to obtain reasonable assurance on the extent to which the financial  
statement  
a
as  
free  
fraud  
or error, and by the issuance  
whole are  
auditois report that includes our opinion.  
guarantee  
of significant distortions, caused either by  
of an  
Reasonable  
assurance is a high level of assurance,  
but it is not  
that an audit carried out in accordance with the ISA will always  
a
detect significant distortion,  
if any. Distortions can be caused either by fraud or error and are considered material if can reasonably  
it  
individually  
will influence  
be expected that they,  
or cumulatively,  
the economic decisions of the users,  
professional  
financial statements.  
taken on the basis of these  
'13.  
part  
As  
of  
audit in accordance with the lSA, we exercise  
reasoning  
maintain  
and  
an  
professional  
the audit. Also:  
skepticism throughout  
o
We identi! and assess the risks of significant distortion of the financial statements, caused by  
procedures  
response  
to those risks  
fraud or error, we design and execute audit  
as a  
either  
and  
providing  
provide  
we  
sufficient and adequate audit evidence to  
fraud is higher  
a basis for our opinion.  
obtain  
are  
The risk of not detecting a significant distortion caused by  
than that  
of  
not  
Sector 1, BucureSti, Romania  
Adrestr: Str. Grigore Mora, nr.37,  
3
.
.
(+40)21  
Tel./Fax:  
317  
qcesteq  
reprezentdnd o  
a PKF Globol, reledua de entitdti membre ole PKF lnternotionol Limited,  
dintre  
PKF Fincontd S,R.L, este o societqte membrd  
punct  
de  
vedere  
fiecore  
juridic  
pentru  
acliunile sau inoctiunile oricdrui membru  
entitote seporqtd  
independentd din  
nu occeptd nicio responsobilitote sou rdspundere  
€i  
ii  
sou a unei entitdti corcspondente,  
individuol  
pKF  
Finconta  
{hlr.,  
}
detecting a significant distortion caused by error, because fraud  
involve  
can  
secret, forgery,  
intentional omissions, false statements and avoiding internal control.  
.
procedures  
We  
appropriate  
internal relevant  
to the audit, in order  
to design audit  
understand  
control  
to the circumstances, but  
the effectiveness of the Company's internal control.  
purpose  
without  
having the  
of expressing  
an opinion on  
.
.
policies  
We  
of the accounting  
reasonableness  
used and the  
of the  
assess the adequacy  
presentations  
related  
information made  
accounting estimates and of the  
of  
by the management.  
We form  
regarding the adequacy of the management's use  
of accounting based  
the continuity of the activity and determine, based on the audit evidence obtained, if there is  
a conclusion  
on  
generate  
a significant uncertainty regarding events or conditions that could  
significant  
changes  
case where we  
the conclude that there is  
in  
to continue its activity. ln  
the Company's ability  
presentations  
inappropriate,  
are let's change our  
significant uncertainty, we must draw attention in the audito/s report on the related  
presentations  
in  
financial  
in if  
the  
statements or,  
these  
conclusions are based on the audit evidence obtained up  
opinion. Our  
to the date of the auditor's  
report. However, future events or conditions may cause the Company to no longer operate  
principle  
based on the  
of activity continuity.  
presentation,  
o
We  
financial  
statements, including  
assess the  
structure and content of  
disclosures, and the measure that financial statements reflect transactions and the  
events  
presentation.  
underlying them in a manner that results in a faithful  
people  
governance,  
planned  
the area and  
14. We communicate to the  
in charge of  
among other aspects,  
programming  
the  
of the audit, as well as the main findings  
audit, including  
of the any signiflcant  
time  
deficiencies in  
internal  
which we identifo  
control,  
during the audit.  
governance  
with a statement regarding  
our compliance with  
provide  
persons  
15. We also  
the  
in charge of  
the ethical requirements regarding independence and we communicate to them  
relationships  
and  
all the  
reasonably  
other aspects that can  
be considered to be it could affect our independence  
and, where  
appropriate, the related safety measures.  
people  
government,  
16. Of the aspects that we have communicated to the  
who are in charge  
of the  
financial  
statements in  
we  
the  
greater  
those aspects that had  
importance in  
establish  
a
the audit on the  
We  
describe these aspects in  
period  
represent key  
current  
and, therefore,  
audit aspects.  
prevent  
our audit report,  
of the respective  
public presentation  
except in the case where the legislation or regulations  
the  
aspect or of the case that, in extremely rare circumstances, considers m that  
issue  
should not  
public  
interest  
will  
an  
expected that the benefits of the  
communication.  
be  
in  
report  
it is reasonably  
communicated  
our  
because  
the negative consequences of this  
be outweighed by  
provisions  
Report on other legal and regulatory  
17. We were appointed as auditors by signing the audit contract  
19.09.2022  
to audit the financial  
dated  
years  
for  
financial  
statements of the Company,  
total uninterrupted duration of  
31, 2022,2023 and 2024.  
the  
ended on December 31  
2024.  
and  
The  
December  
,2022,2023  
year  
ended  
on  
years,  
our  
is  
commitment  
3
covering the financial  
Confirm that:  
.
Our audit opinion is consistent with the additional report submitted to the Company's Board  
of  
Directors, which we issued on the same date that we issued and this report. Also, in  
the conduct of  
our audit, we have maintained our independence from the audited entity.  
.
provided  
prohibited  
non-audit services referred to in Article  
not  
for  
the Company the  
We have  
5(1)  
of EU Regulation No. 53712014.  
Adresdr str. Grigore Mora, nr.37. Sector 1, Bucuregti, Romania  
4
.
(+40)21  
Tel./Fax:  
317 37 90196. E-mail: office@pkffinconta.ro www,pkff inconta.ro  
este o societote membrd a PKF 6lobol, reteouq de entitdti membre ole PKF lnternotional Limited,  
dintre acesteo reprezentdnd o  
PKF Finconto S,R,t,  
fiecare  
juridic  
qcceptd  
nicio  
punct  
pentru actiunile  
responsobilitate sou rdspundere  
sau oricArui  
inocliunile  
ti nu  
entitote seporotd  
ti  
independentd din  
de vedere  
membru  
q
individuql sou unei entitdli corespondente.  
pKF  
Finconta  
1,,,  
U
(EU)  
2018/815  
Commission  
Regulatory Technical  
Report on compliance with the European  
European Single Electronic Format  
Delegated Regulation  
("ESEF")  
on the  
Standard  
prepared  
We have  
out a reasonable assurance mission on the compliance of the financial  
carried  
CONPET S.A. in accordance with article 3  
statements  
2018/815, which  
(EU)  
regulation  
by  
of delegated  
the specification of a single electronic  
CONPET  
regarding  
files  
establishes the  
"ESEF".  
regarding  
reporting  
format  
regulatory technical standards  
-
prepared  
in  
accordance  
Responsibility of the management of  
with ESEF  
S.A.  
the digital  
preparation  
files in  
The Company's management is responslble for the  
of digital  
accordance with ESEF. This  
responsibility includes:  
.
maintaining  
internal  
on ESEF reporting;  
designing, implementing and  
an adequate  
control  
.
published  
between the digitized information and the financial statements  
ensuring consistency  
according to the  
provisions  
284412016.  
of Order  
Auditor's responsibility  
Our responsibility lies in expressing, on the basis of the audit evidence obtained, a conclusion on the  
labelling of the elements in the financial statements, in accordance with  
compliance of the electronic  
article  
has been carried  
"Ofherassurance  
material  
reasonable mission  
assurance  
3 of the Delegated Regulation, in all  
aspects. Our  
(revised)  
3000  
Missions  
out in accordance with the lnternational Standard on Assurance  
revisions  
-
historical financial information", issued by the lnternational  
mlsslons than audits or  
of  
Standards  
for Auditing and Assurance.  
Council  
procedures  
ISAE 3000 involves carrying out  
mission  
A reasonable assurance  
under  
to obtain advice on  
with Article  
ESEF Delegated Regulation. The nature, timing and extent  
of the selected  
compliance  
3 of the  
procedures  
reasoning, including in  
risk  
depend on the audito/s  
assessing the  
of significant deviations from  
provisions  
fraud  
A reasonable  
mission involves:  
assurance  
the  
of Article 3, caused either by  
or error.  
.
process preparing  
of the  
of  
the Digital File in accordance with  
ESEF  
the  
obtaining an understanding  
internal  
and relevant  
reconciliation of the  
controls;  
Digital Files with  
.
.
financial  
the audited  
statements of the Company;  
whether all the financial statements that are included in the annual flnancial report  
in a valid XHTML format.  
assessing  
prepared  
are  
provide  
obtained is sufficient and appropriate to  
a basis for  
our conclusion.  
We believe that the evidence  
Conclusion  
year  
December  
, 2024 included  
in the annual  
ln  
the financial statements for the financial  
ended  
31  
our opinion,  
Digital Files  
in all  
with  
requirements  
the  
financial report and disclosed in the  
ESEF.  
comply,  
significant aspects,  
of  
a review conclusion or any other assurance  
ln this report we_  
regardi  
year  
conclusion  
on  
the Company's financial statements for the financial  
Report on the annual financial statements above.  
in  
the  
)r2Uz4iHiiicluded  
On  
tot'  
flE',iffigefa$&L  
Str.  
Audit Activity under number FA32  
Statutory  
Registered  
partner  
Audit  
Slsl*lQtlorentina  
he Statutory Audit Activity under number AF433  
B ucharest, March 25, 2025  
ln registered  
nr.37, sector 1, Bucure$ti, Romania  
5
Adresi: Str. Grigore Mora,  
(+40)21  
317  
este o societote membrd  
S.R.L.  
31 90/96. E-mail office@pkffinconta.ro.  
Tel./Fax:  
dintre dcesteo  
a PKF Global, releouo de entitdti membre ole PKF lnternqtionql Limited,  
reprezentAnd  
liecdre  
qcliunile  
sou  
inocliunile oricdrui membru  
o
Finconta  
PKF  
entitote seporatd  
juridic  
pentru  
punct  
nu acceptd nicio responsobilitate sou rdspundere  
independentd din  
de vedere  
$i  
ti  
sdu o unei entitdli corespondente.  
individuol  
lBt  
PKF  
Finconta  
!}  
UM'TED ASS RAN C  
E
U
REPO RT  
of the independent auditor  
on the sustainability report  
year  
for  
the financial  
2024  
(free  
translation)  
To the shareholders  
of CONPET S.A.  
Li m ited As  
We have  
CONPET S.A.  
prepared  
rance  
Concl usio n  
su  
performed  
("fhe  
a limited assurance  
Companf') as at  
engagement on the Sustainability  
Report included in  
the annual report  
of  
period  
31  
December  
2024  
and for the  
Anul  
from  
1 January 2024  
lo 31 December  
2024,  
by the Company, having its registered office at  
Street  
1848, nr. 1-3, Ploiesti, district Prahova,  
registered  
under fiscal identification  
code 1350020.  
procedures performed  
Based  
believe that  
on the  
and the evidence  
obtained, nothing has  
come to our attention  
period  
that causes  
us to  
the Company's sustainability reporting  
as at 31 December 2024  
and for the  
from January  
1
2024  
to  
prepared,  
31 December 2024 is not  
in all material respects,  
in accordance with  
the applicable  
legal sustainability  
provided  
reporting framework  
the  
Order of  
in  
Minister  
the  
of Public Finance no.284412016,  
Chapter 71, sections 71 .1  
and  
to  
71.1 including:  
,
.
compliance with the  
Sustainability  
(ESRS),  
European  
Reporting Standards  
process  
including the fact that the  
carried out by the Company for identiffing  
"the  
the information  
provided  
(referred  
disclosed in the sustainability  
in Chapter 1 of the  
reporting  
sustainability reporting,  
as  
Process") is consistentwith  
the description  
and  
.
compliance of the taxonomy  
disclosures, detailed in  
Environmental  
the  
Section  
of the sustainability  
reporting,  
("the  
Chapter 4, with the  
Taxonomy  
applicable reporting requirements  
(EU)  
of Article 8 of Regulation  
No.  
85212020  
Regulation").  
the Assurance  
Basis for  
We  
Conclusion  
conducted our limited assurance  
(Revised),  
engagement in accordance with  
ISAE 3000  
"Assurance  
Engagements  
Other than Audits or Reviews  
Historical  
of  
Financial lnformation."  
described in the  
accordance with lnternational  
Our responsibilities  
"Auditor's  
Responsibilities"  
under this standard are further  
section  
of our report.  
We independent  
are  
(including  
of the Company in  
lnternational  
the  
Standards) issued by  
Code  
Ethics  
for Professional  
of  
Accountants  
for Accountants  
as subsequently  
lndependence  
with  
lnternational  
the  
Ethics  
Standards Board  
(IESBA  
Code),  
and  
the relevant ethical requirements  
in Romania,  
including Law  
No. 16212017  
have fulfilled  
amended, for  
responsibilities  
our assurance engagement on the  
in accordance  
sustainability reporting,  
requirements  
and the IESBA Code.  
and we  
our other  
ethical  
with  
these  
Our firm  
quality  
requirements,  
we have obtained is sufficient  
applies the lnternational Standard  
on  
Management  
policies  
legal and regulatory  
Quality  
documented  
standards, and applicable  
1 and, accordingly,  
procedures  
maintains  
regarding  
compliance with  
a comprehensive  
management  
system that includes  
professional  
and  
ethical  
requirements. We  
believe  
that the evidence  
provide  
and appropriate to  
a basis for our conclusion.  
Emphasis  
Matters  
of  
We  
repoft'  
point  
draw attention to the information  
prepaing  
disclosed in Chapter 1,  
l "General  
basis for  
the sustainabitity  
of the sustainability reporting,  
context of the first-time  
which describes  
application of the  
the uncertainties and limitations  
provisions  
encountered  
by the  
Company in  
general  
the  
of Order No.  
year  
284412016,  
Chapter 71,  
Sections 71 .1  
and  
71 .2, and, specifically,  
the challenges faced  
2024  
financial  
during the  
in  
publishing  
collecting  
the necessary  
data for  
points  
certain data  
identified in  
the same chapter. Our  
conclusion is not modified  
in respect  
this  
matter.  
of  
We  
reporting, the  
strategy and business model. lt is  
also draw attention to of the sustainability  
year  
reporting, which  
states that for the  
2024,  
year  
being  
the first  
of  
its  
in  
yet  
Company has not  
concretely identified the interaction  
between impacts, risks,  
was  
no formal stakeholder  
and opportunities with  
engagement framework  
noted  
that, for 2024,  
also  
there  
place.  
Our conclusion is not modified in respect  
of this matter.  
Other Matters  
Comparative lnformation  
-
Our limited assurance engagement  
does not extend  
information  
included in  
to the  
prior  
reporting for  
the sustainability  
periods.  
Our conclusion is not modified in respect  
this  
of  
matter.  
Matlers  
Other  
prepared  
The 2024  
provisions  
sustainability reporting was  
of the Order of the Minister of Public Finance No.  
by the Company in  
the context of  
Chapter 71,  
the first{ime  
Sections 71 .1  
application of the  
284412016,  
71  
and .2-a context  
characterized  
by uncertainties regarding legal  
and regulatory interpretation,  
use of significant  
estimates,  
absence of  
Adrese:str. Grigore Mora, nr.37, Sector L,  
(+40)21  
Bucuregti, Romania  
377 3! 90/96. E-mail: office@pkffinconta.ro.  
L
Tel./Faxi  
PKF Fincontq S.R.l. este o societdte membrd a  
Globol, reteaud de entitdli  
PKF  
membre ale PKF lntenotionol  
Limited,  
dintre  
acested  
reprczentdnd  
o entitote  
fiecore  
pentru  
responsqbilitqte squ rdspundere  
acliunile sou inacliunile  
juridic  
punct  
separotd  
independentd din  
de  
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nu occeptd nicio  
ti  
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po  
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ntitd  
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PKF  
Finconta  
practices  
particularly  
frameworks,  
established  
and  
for  
assessing double materiality,  
and an internal  
control system  
under  
development. This  
framework  
enables understanding of  
the Company's impacts  
performance,  
on sustainability  
matters,  
as well as how  
matters  
include  
these matters influence  
position.  
the Company's business  
development,  
and  
Sustainability  
governance  
environmental,  
social, and corporate  
issues.  
po ftin g  
Responsibilifie  
s fo r th e S u stain  
iIity  
Re  
a b  
The  
Company's administrators  
are responsible for  
the design, implementation,  
in accordance with  
responsibility includes:  
process  
and  
maintenance  
ESRS,  
of a  
for  
this  
identifying the information included in  
process  
the sustainability reporting,  
and for describing  
in  
1
Chapter of the sustainability report. This  
o
understanding the context in which  
the Company's  
stakeholders;  
activities and  
positive)  
place  
and  
business relationships  
take  
developing  
an understanding of affected  
o
potential  
identifying  
the risks  
(both  
actual and  
impacts  
negative  
and  
related  
to sustainability  
matters,  
well  
as  
as  
and opportunities  
or  
are expected  
that affect  
position,  
entity's financial  
financial  
to affect the  
performance,  
cash flows,  
access to financing,  
or cost of capital in  
the short, medium,  
or long term;  
.
.
assessing  
the significance of identified  
sustainability-related impacts,  
risks, and opportunities,  
by  
selecting and  
applying  
appropriate thresholds;  
and  
developing methodologies and  
making assumptions  
that are reasonable  
under the  
circumstances.  
The Company's  
preparing  
administrators are also responsible  
for  
the sustainability reporting  
in  
accordance with  
the  
sustainability reporting framework required  
by law, including:  
.
o
compliance with the European Sustainability  
(ESRS);  
Reporting  
Standards  
preparation  
of  
taxonomy disclosures in  
the Environmental  
Section, Chapter lll, sub-section 2,  
of the  
sustainability reporting, in  
Regulation");  
accordance with Article  
(EU)  
No. 852/2020  
8 of Regulation  
("the  
Taxonomy  
r
.
designing, implementing,  
sustainability reporting free  
and maintaining  
from material misstatement,  
internal  
preparation  
controls deemed necessary  
to enable  
the  
of  
whether  
due to fraud  
or error; and  
selecting  
and applying appropriate  
sustainability reporting  
methods and making  
assumptions  
and  
estimates  
for individual  
sustainability  
disclosures that are reasonable  
under the  
circumstances.  
governance  
Those  
charged with  
are responsible for  
process  
at the company  
overseeing the  
sustainability reporting  
level.  
lnherent Limitations  
in  
Sustainability Reporting  
ln forecasting  
assumptions  
disclosures made in accordance  
with the ESRS,  
administrators  
are required  
Actual results  
to base such forecasts  
on  
potential  
future  
about  
events and  
not occur  
future actions  
of the Company.  
are likely  
to differ  
since  
anticipated  
may  
events  
as expected,  
ln  
terminology. These may  
determining the disclosures in  
the sustainability reporting,  
administrators interpret  
undefined legal  
terms  
and other  
of their interpretation,  
be  
interpreted  
differently, including  
in terms  
of  
legal compliance  
and are  
therefore subject to uncertainty.  
Au dito r's Responsibilitres  
plan  
perform  
the assurance  
Our objectives  
are to  
sustainability reporting  
and  
engagement  
to obtain limited  
due to fraud or  
assurance  
error, and  
as to whether  
the  
is free from material  
misstatement,  
whether  
issue  
to  
a limited  
assurance report that includes  
our conclusion.  
Misstatements  
individually  
may result from  
fraud or error  
and are considered  
material if it is  
reasonably  
expected  
as a whole.  
that they,  
or collectively,  
could influence the  
decisions of users  
based on the sustainability  
reporting  
part  
As  
(Revised),  
of a limited assurance  
professional judgment  
engagement in accordance with  
ISAE 3000  
we exercise  
professional  
and maintain  
skepticism throughout  
the engagement.  
procedures performed  
The  
in limited  
a
assurance  
engagement vary in nature  
and timing  
and are less  
extensive than  
substantially  
performed  
those  
in a reasonable  
assurance engagement.  
Consequently,  
level  
of assurance  
the  
obtained is  
lower than  
which would  
have been  
that  
performed.  
obtained had a reasonable  
assurance  
engagement been  
process,  
include:  
Our responsibilities in respect  
of the sustainability reporting,  
process,  
related to  
the  
o
purpose  
obtaining an understanding  
effectiveness, including  
of the  
but not  
for the  
process;  
of  
expressing  
a conclusion  
on its  
the outcome  
of the  
.
performing procedures  
designing and  
presented  
process  
is  
to  
assess whether the  
consistent with  
its description  
as  
by the Company in Chapter  
1 of the sustainability reporting.  
Other responsibilities  
in respect  
of the sustainability reporting include:  
Adresi: Str. Grigore  
Mora, nr.37, Sector 1, Bucuretti, Romania  
2
(+40)21  
Tel./Fax:  
177 37  
q
PKF Fincontd  
5.R.1, este o societote membtd  
PKF Globol, refeduo de entitdli  
membre ole PKF lnternationql  
Limited,  
dintre ocestea  
inacliunile oricdtui  
reprezentdnd o entitdte  
fiecare  
juridic  
punct  
sepqratd  
independentd  
co re  
din  
de vedere  
nu occeptd  
responsobilitote  
pentru  
sau rdspundere  
ocliunile sou  
nicio  
ti  
ti  
membru individuol sou  
o
s p  
u
n e  
e
i
ntitd  
o
n de nte.  
li  
&,  
PKF  
Finconta  
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r
processes,  
obtaining  
relevant  
obtaining evidence  
an understanding of the Company's  
preparation  
control environment,  
and information  
specific  
systems  
activities,  
to the  
of the sustainability  
reporting, without  
evaluating  
operating effectiveness;  
control  
about  
their  
implementation,  
or testing their  
.
o
identifying  
designing  
disclosures likely  
to contain material misstatements,  
whether  
due  
fraud  
to  
contain  
higher than for  
or error;  
performing procedures  
and  
in response  
to disclosures  
likely to  
material  
one due  
misstatements.  
to error,  
The  
may  
risk  
of not detecting  
a material misstatement  
due to fraud is  
fraud  
as  
involve collusion, forgery,  
intentional omissions,  
misrepresentations,  
of  
internal  
or override  
control.  
Summary Work Performed  
of  
assurance engagement involves  
The nature, timing,  
A limited  
performing  
procedures  
to  
obtain evidence  
about the sustainability  
reporting.  
procedures  
judgment,  
including identifying  
the sustainability reporting.  
and extent of the selected  
disclosures likely to contain material misstatements,  
professional  
depend  
on our  
whether  
due to fraud or error, in  
ln conducting  
limited  
assurance engagement  
our  
the  
Process, we:  
on  
o
process  
obtained an understanding  
ofthe  
by:  
o conducting interviews  
to understand  
the sources of information  
(e.9.,  
used by  
management  
plans,  
stakeholder agreements,  
business  
and  
strategy documents);  
documentation related  
procedures  
o
inspecting/examining  
process;  
to the  
and  
the Company's internal  
o
assessed whether  
process  
is consistent with  
the evidence obtained through  
our  
Company's  
on the  
process  
presented  
the description of the  
as  
in  
Chapter 1.  
ln conducting our limited  
assurance engagement  
on the sustainability reporting,  
we:  
.
processes  
obtained an understanding  
of the Company's reporting  
preparation  
process  
relevant  
to  
the  
of the  
sustainability reporting;  
r
assessed whether the material  
in the sustainability reporting;  
information identified  
through  
information  
identification  
the  
of  
the sustainability reporting  
is included  
.
presentation  
evaluated whether  
the structure  
and  
comply with  
the European  
(ESRS);  
Sustainability  
Reporting Standards  
o
personnel  
performed  
conducted interviews with relevant  
the sustainability reporting;  
procedures  
on  
and  
analytical  
selected disclosures  
in  
o
.
performed  
procedures  
substantive  
on  
a sample of selected  
disclosures in the  
sustainability reporting;  
obtained evidence  
applied;  
on the methods used for  
significant estimates  
and forecasts  
and how these  
methods were  
o
process  
obtained an understanding  
activities and related disclosures  
of the  
for identifying  
taxonomy-eligible  
and  
taxonomy-aligned  
economic  
in the  
sustainability  
reporting;  
.
ona  
sustainability  
report with  
corresponding  
disclosures in  
the  
in  
lhe  
f:ffiiffif,'j",lsJfJ,.*  
On behalf of:  
Str. Grigore  
Registered  
Audit Activity  
No.  
under  
FA32  
Bucharest, 25  
2025  
March  
Auditorfinanclar  
Susnea  
Florenflna  
AF433  
Registru  
Pubtic  
Elocironic  
Adres5: Str. Grigore Mora, nr.37, Sector  
1, Bucure$ti, Romania  
3
Tel./Faxr  
317 31 90/95. E-mailr  
{+40)21  
PKF  
Fincontd S,R,L. este o societate  
membrd o PKF Globol, retedud  
juridic  
de vedere  
de entitdti membre ale PKF lnternqtionol  
Limited,  
dintre  
acested  
inqcliunile oricdrui  
reprezentAnd o entitote  
membru individual  
fiecqre  
sdu  
punct  
qctiunile  
pentru  
separotd  
independentd din  
s po  
nicio responsabilitqte  
il nu occeptd  
squ  
o
sou rdspundere  
ti  
u
ne i  
e
ntitdli co re  
nd e n te.