HF Sinclair Corp

Commitment and Contingency Reserves

In the ordinary course of business, we may become party to legal, regulatory or administrative proceedings or governmental investigations, including environmental and other matters. Damages or penalties may be sought from us in some matters and certain matters may require years to resolve. While the outcome and impact of these proceedings and investigations on us cannot be predicted with certainty, based on the advice of counsel and information currently available to us, management believes that the resolution of these proceedings and investigations through settlement or adverse judgment will not have a material adverse effect, either individually or in the aggregate, on our financial condition, results of operations or cash flows.

The environmental proceedings are reported to comply with SEC regulations which require us to disclose proceedings arising under provisions regulating the discharge of materials into the environment or protecting the environment when a governmental authority is party to the proceedings and such proceedings involve potential monetary sanctions that we reasonably believe could exceed $1 million or more.

Except as described below, there have been no material changes to the legal matters previously disclosed in our Annual Report on Form 10-K for the year ended December 31, 2025.

Environmental Matters

Renewable Fuel Standard

The EPA’s August 2025 decisions granting and denying various small refinery exemption (“SRE”) petitions for our Woods Cross, Cheyenne, Casper and Parco refineries for various compliance years from 2019 to 2024 remain under challenge in the U.S. Court of Appeals for the District of Columbia Circuit (the “DC Circuit”). Those cases have been consolidated with a separate challenge to the EPA’s November 2025 grant of SREs for our Tulsa East refinery, which we are defending as an intervenor. Our opening brief was filed with the DC Circuit on July 16, 2026, and the EPA’s response brief is due by November 16, 2026.

Separately, on April 7, 2026, the DC Circuit unanimously ruled in our favor regarding our Parco refinery’s 2024 SRE petition (the “Parco 2024 Petition”), vacating the EPA’s denial and remanding the matter to the EPA for reconsideration. The EPA issued a decision on August 3, 2026, partially granting relief on the Parco 2024 Petition. At the same time, the EPA denied a 2023 SRE petition for the Parco refinery and petitions for 2023 and 2024 for our Artesia refinery. We filed a petition for reconsideration of the EPA’s decision on the Parco 2024 Petition on August 7, 2026, asserting errors in the EPA's analysis and requesting a full grant. On August 31, 2026, the EPA reaffirmed its partial grant for the Parco 2024 Petition. Additionally, on August 31, 2026, the EPA issued decisions partially granting or denying 2025 SRE petitions for our Woods Cross, Casper, Parco and Artesia refineries. The EPA also granted a 2025 SRE petition for our Tulsa East refinery.

On October 1, 2026, certain of our subsidiaries filed lawsuits in the U.S. Court of Appeals for the Tenth Circuit challenging the EPA’s denials and partial grants for various SRE petitions for our Woods Cross, Parco and Artesia refineries for various compliance years from 2023 to 2025. On October 2, 2026, we filed protective lawsuits in the DC Circuit challenging the EPA’s denials and partial grants for the same SRE petitions.

Separately, the Renewable Fuels Association and Growth Energy filed lawsuits in the DC Circuit challenging the EPA’s SRE grants and partial SRE grants in its various August 2026 decisions, including our refineries’ grants and partial grants. On October 1, 2026, the DC Circuit granted those challengers’ motions to hold their lawsuits in abeyance pending the DC Circuit’s ruling on the challenges to the EPA’s August 2025 and November 2025 decisions. On October 19, 2026, we filed a motion to intervene to defend the full and partial SREs granted to our refineries in EPA’s August 2026 decisions.

Each of these matters remain pending, and the potential impact cannot be estimated at this time.

Puget Sound

In our Annual Report on Form 10-K for the year ended December 31, 2025, we reported that HF Sinclair Puget Sound Refining LLC (“HFS Puget Sound”) has been engaged in discussions with, and has responded to document requests from, the Northwest Clean Air Agency, the EPA and the Department of Justice (collectively, the “PSR Matter Government Agencies”) regarding HFS Puget Sound’s compliance with the Clean Air Act, Emergency Planning and Community Right-to-Know Act and related regulations, and similar Washington laws and regulations, at the Puget Sound refinery. HFS Puget Sound and the PSR Matter Government Agencies continue to engage in discussions and work towards a negotiated resolution of this matter. At this time, no penalties have been demanded, and it is too early to predict the outcome of this matter.