4.2 Limitin our environmental impact and operating in a safe environment

Protecting people and the environment is everyone’s business and a priority for Rubis. As a committed and responsible company, the Group continuously works to protect its environment (section 4.2.2) and seeks to operate safely (section 4.2.3). To manage this approach to quality, health, safety and the environment, the Group has defined a general framework and a governance system has been implemented for each activity (section 4.2.1).

4.2.1 Our QHSE approach / NFIS /    General principles

A general framework for quality, health, safety and the environment (QHSE) has been defined in order to prevent risks and to limit the negative impacts of our activities.

The QHSE policy framework, which is referred to in the Group’s Code of Ethics, states that each employee must act responsibly when performing his/her duties, comply with the health, safety and environmental protection procedures on site, and pay particular attention to compliance with these rules by all parties (colleagues, suppliers, external service providers, etc.). This framework constitutes the common foundation for all the Group’s activities.

In order to account for the challenges and risks that are specific to Rubis Énergie’s activities and those of the Rubis Terminal JV, each of them has drawn up their own QHSE policy consistent with the Group’s general principles.

Concerning Rubis Photosol, the integration work will focus on potential adjustments to its QHSE policy during 2023 and the setting of an action plan and related objectives. These policies clarify the Group’s principles by transposing them into operational requirements. Dedicated governance has been set up for the implementation of these policies.

The main objective of these QHSE policies is to prevent risks in order to better protect physical and environmental integrity and to minimise the impacts of a major accident (see section 4.2.3). This is reflected in the implementation of the measures required to limit incidents as far as possible and thereby reduce the probability of a severe event occurring. In addition, the Group also strives to reduce its environmental footprint (see section 4.2.2).    Management system


The implementation of QHSE policies is overseen by facility Managers who are assisted by Rubis Énergie’s and the Rubis Terminal JV’s industrial, technical and HSE Departments. At larger sites, quality and/or HSE engineers are also involved in this process. The General Managers of Rubis Énergie’s subsidiaries and their functional departments report on their HSE work at Management Committee meetings that are held within each division twice a year, in the presence of Rubis SCA’s Management Board. The Rubis Terminal JV’s management reports on the implementation of its HSE policy and its results to its Board of Directors, on which Rubis SCA has representatives.

Rubis Énergie (Retail & Marketing and Support & Services activities)

Rubis Énergie believes that it is essential to protect the health and safety of people and property located in or near its facilities. As such, Rubis Énergie has established a “Health, Safety and Environment (HSE) Charter”, which requires its affiliated companies to comply with HSE objectives that it considers to be fundamental (and which sometimes go beyond locally applicable regulations), and with the additional aim of heightening employee awareness about safety.

These general objectives are to be achieved through the following key measures:

•   disseminating Rubis Énergie’s fundamental HSE principles within its subsidiaries in order to create and strengthen HSE culture;

•   implementing sector-specific best business practices;

•   having document systems established in accordance with “quality” standards ensuring reliability and safety of operations;

•   regularly assessing technological risks;

•   enhancing preventive facility maintenance;

•   regularly inspecting facilities and processes (transport activities included) and addressing any identified deficiencies;

•   analysing all incidents and proposing to all subsidiaries lessons learned documents on notable events in order to avoid their recurrence;

•   regularly training employees and raising awareness about technological risks.

Depending on the activity, the following actions are also taken:

•   taking care to analyse the state of facilities in light of specific Group standards and local regulations and, as necessary, scheduling work to bring them up to standard;

•   joining organisations or associations (GESIP, JIG, IATA, Oil Spill Response Ltd, WLPGA, Eurobitume, Energy Institute) in order to share feedback and implement the best practices of the profession, as well as to benefit from specialised expertise for operations or in the event of an incident (see details in section and maritime pollution liable to occur during loading/unloading operations in Rubis Énergie’s depots.

Rubis Terminal JV (Storage activity)

The Management of the Rubis Terminal JV has rolled out the shared cultural values, including the principles of the “Always safe” safety culture, to all its subsidiaries and joint ventures.

Its three fundamental principles are:

•   “safety is in our DNA”, the integration of safety as a priority at all levels of the Company;

•   “prevention culture”, openly share knowledge and experiences in order to improve prevention and integrate it upstream of design and operations;

•   “proactive attitude”, reflect and analyse in order to act before an event occurs by having a positive, honest and transparent attitude to help each other detect dangerous situations and correct them quickly.

The Rubis Terminal JV considers that protecting health and safety contributes to the Company’s success and should therefore never be neglected, and that action must be taken upstream to avoid accidents and occupational illness. The Management of each Rubis Terminal JV industrial site has the obligation to ensure that regular audits assessing compliance with safety principles and standards take place. Performance indicators have been put in place in order to trigger and monitor a continuous improvement process with respect to health and safety.

The Rubis Terminal JV’s General Management and that of each facility make an annual commitment to employees, customers, suppliers, governments and local residents, pledging to apply a QHSE policy incorporating safety improvement targets specific to each site. Managers also agree to adhere to recognised international QHSE standards, which are set out below.

Finally, the Rubis Terminal JV has committed to a multi-year quantified programme for reducing its energy consumption and its CO2 and atmospheric emissions through the internal distribution of a document entitled “Group objectives for environmental impacts and energy consumption” to limit its environmental footprint.

Following its materiality analysis carried out in 2022, a roadmap “Rubis Terminal Infra Sustainability Mid Term Roadmap 2022-2030” was drawn up with medium-term commitments and was validated by its Board of Directors.

This document, built on the principle of the 3Ps (People, Planet, Prosperity), taking into account the materiality of its activity on its environment, details objectives in terms of reducing greenhouse gas emissions, and monitoring sustainable and safe operational methods, while mitigating its impact on the environment. In addition, the environmental policies of the Rubis Terminal JV define the monitoring and improvements of energy and water consumption and waste management, the results of which are presented in the corresponding sections of this chapter (section for the carbon intensity of the activity, section for water consumption and section for waste management).

The following actions are also implemented:

•   monitoring of programmes such as HACCP or GMP+ (see table below), under which the Rubis Terminal JV has committed to complying with the sector’s regulatory provisions and professional recommendations for its various activities, comparing its practices with best industrial practices and to constantly seek to improve its performance in the areas of safety, health and environmental protection;

•   regarding the chemical product storage depots, joining the Chemical Distribution Institute – Terminals (CDI-T), a non-profit foundation working to improve safety at industrial sites in the chemicals industry.

Site certification

Certain operated sites are certified, particularly those classified as Seveso.

  Some of Rubis Énergie’s distribution or industrial activities (Vitogaz France, Sigalnor, SARA, Lasfargaz, Rubis Energia Portugal, Vitogaz Switzerland, Rubis Energy Kenya, Vitogas España and Easigas) are ISO 9001-certified (quality management system), as are all of the Rubis Terminal JV’s depots.
  The activities of SARA (refinery), Vitogaz Switzerland, Vitogas España and Rubis Energia Portugal (Retail & Marketing) are ISO 14001-certified (environmental management system), as are all of the Rubis Terminal JV depots with a chemical product storage activity. This standard provides a framework for controlling environmental impacts and seeks to ensure the continuous improvement of its environmental performance.
  The activities of Vitogaz Switzerland and the Rubis Terminal JV’s Spanish depots are certified ISO 45001, while the activities of Rubis Energia Portugal and the Rubis Terminal JV’s Spanish depots are OHSAS 1800-certified (occupational health and safety management)
  For the Rubis Terminal JV’s chemical product depots, the Chemical Distribution Institute – Terminals (CDI-T) is in charge of inspections and audits of the transport and storage elements of the global chemical product supply chain.
  The Rubis Terminal JV’s Dunkirk site has a continuous risk management approach regarding the storage of foodstuffs. Employees are trained in best practices through the analysis of food risks. They apply the principles of this approach, known as HACCP, and know how to meet the particular needs of the food sector, such as product traceability throughout the logistics chain. Moreover, the terminal has declared that it stores products used for animal feed. This has been registered with the DDPP (Direction départementale de la protection des populations – Regional Directorate for the Protection of Populations). Finally, this site is preparing to obtain GMP+B3 certification for the transhipment and bulk storage of liquids used for animal feed.
  Vitogaz France has held NF Service Relation Client (NF345) certification since 2015. It was the first French company to obtain certification under the new version 8, in December 2018.
Revised in 2018, NF Service Relation Client certification is based on international standards ISO 18295- 1 & 2. A guide to best practices in customer relationship management, it takes customer expectations into account and aims to guarantee constant improvements to service quality. For Vitogaz France, this approach to seeking excellence in customer experience aims at establishing a long-lasting commercial relationship, delivering quality service over time, ensuring that transmitted information is exhaustive and clear, and acting promptly in accordance with its commitments.
  The Spanish depots of the Rubis Terminal JV, as well as the Rotterdam and Dunkirk terminals, are certified ISCC, and ISCC+ for Dunkirk. This certification indicates that traceability is ensured from the collection of raw materials (from biomass or waste and residues) to the transformation process, in accordance with this international sustainability standard applicable to all sectors.

32% of Rubis Énergie’s industrial sites (Retail & Marketing and Support & Services activities) have at least one certification (ISO 9001, 14001 and 45001).

100% of the Rubis Terminal JV’s industrial sites have at least one certification.

4.2.2 Limiting our environmental impact

The risks to the environment stemming from Group activities are monitored and managed very closely.


Rubis’ business lines are organised around three activities: Retail & Marketing, Support & Services, and Photovoltaic Electricity Production (the latter being outside the scope of the NFIS for the financial year 2022), as well as a Bulk Liquid Storage activity on behalf of a diversified industrial customer base, operated by the Rubis Terminal JV. These activities present industrial risks that, depending on the activities and the nature of the products being handled (fuels, biofuels, liquefied gas, bitumen, chemical and agrifood products and solar electricity), may have environmental impacts of varying nature and scale. These risks are described in each part of this section.

The environmental impact of Rubis Énergie’s Retail & Marketing activities stems mainly from the risks of accidental spills or the leakage of products from various Group sites (storage depots, service stations, filling plants for LPG cylinders, customer facilities, aviation or marine refuelling facilities) that are generally limited in size.

The environmental impact of Rubis Énergie’s Support & Services activity stems mainly from the Group’s sole refinery in the French Antilles (SARA) due to its industrial processing activities, and from its shipping business.

The environmental impact of the Rubis Terminal JV’s Storage activity results from the large size of the depots (and therefore the quantity of products being stored and transferred) and the nature of some of the products being handled, which require energy-intense facilities (boilers, for example).


This chapter details the preventive measures put in place and key monitoring data for the following priority environmental risks, identified by means of pictogram / NFIS /:

•   preventing water and soil pollution that may be caused by accidental product spillages (section;

•   assessing and limiting atmospheric emissions from industrial activities (section;

•   optimising the use of resources by conserving water resources (section

Another risk the Group does not consider to be a priority in terms of its activities but that is significant nevertheless is that of waste management (section

The Group’s climate strategy and all the actions it implements to reduce the environmental impact of its activities, also aim to protect biodiversity (section Water and soil pollution / NFIS /


The risks of water and soil contamination related to the Group’s operations result mainly from accidental spillages of stored and/or transported products, which at some sites may result from activities that predate the Group’s presence at the site. In general, the entities are gradually investing in the sites to improve the safety of their facilities and to eliminate pollution risks to every possible extent.


Retail & Marketing activity


The petroleum products distribution business is liable to generate risks of water and soil contamination resulting from accidental spills, tank overflows, spreading, tank and/ or pipe leaks, and wastewater discharges (at fuel depots, service stations, and customer facilities). Road transport of products, which is necessary to supplying distribution sites and customers (fuel, bitumen) is also liable to result in accidental spills.

Measures to prevent and contain pollution

Tanks containing hazardous products and associated pipework undergo systematic inspections at storage sites in accordance with international standards during regular mandatory on-site visits, generally once every 10 years. Moreover, to prevent groundwater and soil pollution in the event of accidental spillage, storage tanks are often installed in watertight retention basins. These basins are kept shut. They are only opened for manual emptying after checks have been performed confirming the absence of pollutants. In the loading/unloading zones at storage sites for tank trucks, the retention platforms are purpose-designed for each type of product being handled and, as a general rule, are connected to oil-water separators connected to treatment plants or buffer basins. Water discharged into the environment after treatment is analysed quarterly.

Equipment used at Rubis Énergie service stations that is liable to generate soil pollution (mainly tanks and piping) is checked periodically (particularly in respect of the absence of defects and water-tightness) and is gradually being replaced by double-wall technology. This includes double-walled underground tanks and pipes that are equipped with leak detectors which provide continuous oversight to guard against any possible pollution. The medium-term (2030) objective is to replace single-walled tanks that are over 30 years old.The regions most affected by this measure are the Bahamas, Jamaica, the West Indies, Haiti and East Africa. As an example, the tanks at seven service stations, i.e., approximately 25 tanks, were replaced in the Caribbean region in 2022, representing an overall investment of approximately US$5 million.

In parallel, Rubis Énergie is reinforcing its preventive maintenance programmes for this equipment (see section and is continuously improving the safety/ environmental training of service station managers, notably to ensure that they have the resources available to immediately detect any loss of product due to defective equipment/practices or fraud.

Rainwater that may have been polluted through contact with roadways is increasingly being treated before being discharged into the environment; service stations requiring them are equipped with rainwater collection and treatment systems whenever road repair work is planned.

Regarding the road haulage of petroleum products, in addition to the application of the regulations applicable to the transport of hazardous materials, additional measures are taken to prevent the risk of traffic accidents. Courses in defensive driving have been introduced in countries where this risk is heightened due to driving habits, distances driven or poor road infrastructure quality.

Moreover the cleaning of gas cylinders takes place in a closed circuit, which limits water consumption and the risk of wastewater contamination.

Support & Services activity


The Support & Services business (refining and shipping) could give rise to water and soil pollution in the event of accidental spillage or leaks and through the use of wastewater (desalination water, stripping treatments, tank draining), bulk tank drain water and ballast wastewater.

Moreover, the shipping activity can generate risks of water pollution during vessel loading/unloading operations or in the event of a shipping accident.

Measures to prevent and contain pollution

For vessel chartering, Rubis Énergie calls on the services of a specialised company that systematically vets the vessels in question. This company collects information about the vessel’s condition (construction date, maintenance, etc.) and the operator’s quality (crew reliability, etc.). It then submits a recommendation on the risks of using the vessel that the teams rely on before signing the charter agreement.

Rubis Énergie has also taken preventive measures to address maritime pollution at its terminals during product loading/unloading operations.


Water pollution

    Suspended solids released into water*   Petroleum products released into water
(in kg)   2022   2021   2020   2022   2021   2020
Refining (Support & Services)   2,390   1,884   2,120   71   159   277
Retail & Marketing   Not available   Not available   Not available   Not available   Not available   Not available
* Suspended solids released into water: see definition in section 4.6.3.

In the refinery, the commissioning of a new lamellar separator in early 2019 made it possible to significantly reduce the amount of suspended solids and petroleum products in wastewater. Without calling into question the improved performance achieved following this investment, it must be emphasised that the sharp reduction in discharges observed in 2020 is attributable to shutdowns of production units due to two major scheduled shutdowns for periodic facility maintenance. The overall decrease in flows of pollutants at the refinery in 2021 and 2022 can be explained by improved performance in residual water treatment and a lower intake of process water resulting from the manner in which the facilities operate.

Soil pollution

In accordance with professional practices, Rubis Énergie monitors accidental spillages of liquid petroleum products with a unit volume of more than 200 litres. In 2022, the subsidiaries recorded 14 incidents (mainly due to facility leaks, traffic accidents or non-compliance with operating procedures).This decrease compared to 2021 (23 incidents reported) is the result of better awareness-raising among local teams and actions to upgrade HSE standards.

Any significant spill must be followed by remedial action aimed at returning the environment to its initial state as quickly as possible.

Rubis Terminal JV


The Storage activity can generate accidental pollution of water and soil, in particular by overflows from secondary retention tanks surrounding tanks, piping or transfer stations located on the sites, by leaks from pipes outside the sites, as well as discharges into wastewater.

Measures to prevent and contain pollution

At storage sites and transport pipelines in the public sector, a preventive maintenance programme is in place for all tanks and equipment containing hazardous products. The systematic inspection of tanks containing hazardous products and their associated pipes is carried out in accordance with international standards, during various periodic visits. Moreover, to prevent groundwater and soil pollution in the event of accidental spreading, storage tanks are (with some exceptions) installed in watertight retention basins (lined with concrete or clay compounds). These basins are kept shut.They are opened manually after checks have been performed confirming the absence of pollutants.

In the loading/unloading zones for tank trucks, railway tanker wagons and at each wharf for vessels and barges carrying hazardous products, the retention platforms are purpose-designed for each type of product handled and, as a general rule, are connected to oil-water separators connected to treatment plants or buffer basins. Water is tested at discharge points at least every half-year, and monthly at the outflows from treatment plants. Weekly or monthly checks are carried out on nearly all sites to verify that there is no floating pollution in the groundwater monitoring wells located downstream of facilities.


Water pollution

    Suspended solids released into water*   Petroleum products released into water
(in kg)   2022   2021   2020   2022   2021   2020
Rubis Terminal JV   4,296   4,672   3,843   384   274   366
•  of which Group share   2,363   2,570   2,114   211   151   201
* Suspended solids released into water: see definition in section 4.6.3.

The volume of suspended solids discharged into the water is very low compared to the volume of water discharged (over 380,000 m3). The change between 2021 and 2022 is small.

Soil pollution

The incidents of reported soil pollution by hazardous products correspond to pollution where volumes are greater than 200 litres occurring during the year. In 2022, no incidents were reported.   Emissions from industrial activity / NFIS /

With the exception of refining in the French Antilles, Rubis Énergie’s activities are not classified as industrial transformation processes. Due to their size, the Rubis Terminal JV’s storage sites are the other significant source of atmospheric pollutants within the Group. The Group is committed to implementing a policy to limit these emissions.

To this end, the various sources of pollutant emissions are being evaluated progressively. The carbon footprint assessment is published in section 4.3.4 relating to climate change.


Retail & Marketing activity


The petroleum products distribution business generates VOC (volatile organic compounds) emissions; however, these emissions remain relatively low.

In liquefied gas distribution, VOC emissions are generated by connection/disconnection operations when filling cylinders and trucks and when degassing cylinders for technical inspections. Other VOCs are made up of the solvents contained in paints used for cylinders.

Regarding automotive fuel distribution, storage and distribution facilities generate VOC emissions from petrol. These emissions are particularly low due to measures taken to collect petrol fumes, as described below.

The Retail & Marketing activity does not emit significant volumes of NOx.

Limitation measures

In fuel depots, particularly those equipped with source loading stations, petrol vapours are collected during tank truck loading; in France, where regulations have required it for several years, these vapours are treated in vapour recovery units (VRUs) that condense them before returning them to the storage tanks. In addition, top loading stations are gradually being replaced by source loading stations, and petrol storage tanks are increasingly being equipped with floating screens that considerably limit the release of vapours into the atmosphere during the storage phase.

In service stations, vapours emitted during reception and delivery to customers are gradually being recovered, especially in France where regulations have required this for several years.

Support & Services activity


The refining activity generates atmospheric emissions into the air due to its industrial transformation processes. The main emission sources are furnaces, combustion turbines, boilers and flares.

Shipping generates SO2 emissions due to the fuels consumed by vessels. However, these emissions have been much lower since the 1st January 2020 entry into force of the Low Sulphur regulation implemented by the International Maritime Organization (IMO 2020), which limits the maximum sulphur content of marine fuels to 0.5% (compared to 3.5% previously).

Limitation measures

The continuous monitoring of the refinery’s atmospheric emissions is strengthened by the commissioning of dust and carbon monoxide analysers in the two units generating the highest emissions. As described in the section on Retail & Marketing activities above, measures to collect petrol vapours have also been implemented.

Each year, a refinery smoke control campaign is carried out by an authorised body to validate the results of its self-monitoring.

Regarding the shipping activity, various solutions have been implemented in order to comply with the International Maritime Organization’s Low Sulphur regulation:

•   Rubis Énergie has fitted one of its eight directly owned vessels (as of 31 December 2022) with a scrubber. This scrubber captures sulphur emissions by washing exhaust fumes. These chimney evacuation filters treat exhaust gas, eliminating up to 90% of sulphur dioxide (SO2) and fine particles;

•   the seven other directly owned vessels, as well as those operated on a time-charter basis by Rubis Énergie, now use low-sulphur fuel oil (0.5% maximum).The availability of this low-sulphur fuel oil in the three activity zones (Caribbean, Europe and Africa) is very satisfactory.

Understanding air pollutants and greenhouse gases

Human activities (transport, accommodation, industry, agriculture) are sources of greenhouse gas emissions and air pollutants. Although they are closely linked and some measures thus aim to reduce both air pollutants and greenhouse gases (for example, improved efficiency of heating systems at the storage sites and optimisation of distances covered by delivery trucks), they should not be confused with one another.

•   Made up of toxic gases or harmful particles, air pollutants have a direct and generally local effect on health and the environment when they exceed certain thresholds. Over and above human activities, they can also come from natural sources, such as volcanoes (sulphur dioxide). Due to their negative impacts, the release of these air pollutants resulting from human activities is supervised and monitored. Air pollutant emissions measured in the Rubis Storage and Support & Services activities concern:

•  nitrogen oxides (NOx), which are formed in particular during fossil fuel combustion;

•  sulphur dioxide (SO2), which arises from several industrial processes and the consumption of fossil fuels containing sulphur;

•  volatile organic compounds (VOC), including benzene, which is found in paint and automotive fuel in particular.

•   Greenhouse gases occur naturally in the atmosphere and play a vital role in regulating and maintaining the Earth’s average temperature (natural greenhouse effect). Contrary to air pollutants, greenhouse gases have little direct effects on health. However, an excess of greenhouse gases released by human activities is largely responsible for global warming (the so-called additional greenhouse effect).

The greenhouse gas released by Rubis’ activities is carbon dioxide (CO2), which is measured (carbon footprint assessment) and subject to reduction measures (see section 4.3.4).


  NOx emissions VOC emissions SO2 emissions
(in tonnes) 2022 2021 2020 2022 2021 2020 2022 2021 2020
(Support & Services)
181 125 185 186 205 182 288 62 240

In 2020 and 2021, atmospheric emissions from refining activities decreased due to the shutdowns of production units resulting from two major scheduled shutdowns for periodic facility maintenance.



The storage activity releases VOCs (volatile organic compounds) from the surface of the stored products which, in accordance with their physico-chemical properties, may vaporise, depending on the storage and handling conditions.

Limitation measures

Collection of petrol vapour in the Rubis Terminal JV’s fuel distribution terminals

These vapours are recovered when tank trucks discharge their loads and are piped to vapour recovery units (VRU), where they are condensed into liquid fuel before being reinjected into the storage tanks.

In addition, fuel storage tanks are equipped with floating screens, and loading is performed via source loading stations that make it possible to minimise VOC discharges into the atmosphere. At chemical product storage sites, toxic product vapours are collected. In addition, any chemical vapours, including VOCs, in the Antwerp and Rotterdam depots are collected and treated.

These two sites were designed from the start to collect and treat all vapours, including VOCs, found above liquids and pushed out of tanks during transfers.

Reduction of energy consumption in storage terminals

As the energy consumed by the storage terminals is derived from the same source as the energy generating CO2 (pumps and boilers), the actions taken by the Rubis Terminal JV to reduce energy consumption at sites, in terms of both existing and new heating systems, are described below (section


   NOx emissions  VOC emissions
(in tonnes)   2022   2021   2020   2022   2021   2020
Rubis Terminal JV  4.9  10.5  11  290  269  311
  of which Group share  2.8  5.8  6.1  159.5  148  171

In the storage sites, the low values calculated once again show a very limited NOx impact from this activity in 2022, with a decrease partly due to changes in scope vs the previous year (4.5 tonnes).

In terminals where boilers are installed, i.e., chemical and mixed terminals, NOx emissions are declining due to the start-up of gas boilers in Strasbourg and Rouen to replace heavy oil-fired boilers.

Concerning VOCs, the reduction of more than 13% recorded in 2021 reflected the full-year operation of a more efficient vapour recovery unit treatment system for petrol emissions at the Rouen site. There was an increase of 7.8% in 2022, which is explained by a structural increase in petrol activities at the terminals of 21% in France over the same period.

SO2 are not measured by the Rubis Terminal JV because the fuels used are either gas or standard low-SO2 liquid fuels (mandatory in the EU countries where the terminals are located). Use of resources

In line with principles of the good governance of its activities, Rubis makes optimum use of the natural resources needed by its value chain, which is a key component of its corporate responsibility (section Moreover, although the Group produces little waste, it ensures that the quantities of waste are limited and that waste is recycled (section PRESERVATION OF WATER RESOURCES / NFIS /


The Retail & Marketing activity does not require recurrent and significant use of water for industrial processes. Water is consumed in only very limited quantities for fire drills and periodic storage tank requalification and for cleaning and the requalification of LPG cylinders at cylinder filling plants.

The Support & Services activity (refining) consumes water mainly through its industrial transformation processes (boilers, etc.) and for its facilities’ fire-fighting systems.

Water consumption of Rubis Terminal JV mainly comes from fire drills carried out to test the effectiveness of the systems in place, the needs for the dosing of liquid fertilisers and urea-based solutions for the reduction of NOx from diesel engines. This usual consumption is increased by occasional water requirements for hydraulic testing (resistance tests) for new tanks.

Measures to reduce water consumption

In the activities with the highest level of consumption (refining and the Rubis Terminal JV), significant efforts are made to reduce the net consumption of freshwater:

•   the use of rainwater for refilling fire reservoirs and for dosing fertiliser. The facilities concerned have dedicated collection tanks;

•   treating wastewater enables the Rubis Terminal JV storage sites to report a higher volume of treated wastewater than the volume of freshwater used, as rainwater collected on sealed surfaces is also treated. In the refinery, all process water is collected and treated before being discharged into a modern residual water treatment unit. Systematic sampling and regular analyses make it possible to check that the water discharged after the various treatment stages complies with regulatory standards;

•   an investment project for industrial water production facilities at the refinery through the desalination of sea water (based on the principle of reverse osmosis) will significantly reduce the net consumption of freshwater. This project, called Green Water, commissioned in 2022, should make it possible to cover all the refinery’s industrial water requirements (capacity of 30 m3/h for demineralisation lines and 5 m3/h for service water requirements). Ultimately, it should enable the refinery’s city water consumption to be reduced by 80%. Domestic water (sanitary, kitchen) will continue to be supplied through the drinking water network.


   Water used*     Water treated*     
(in m3)  2022  2021  2020  2022  2021  2020  
Refining (Support & Services)   252,906   150,104   174,014   88,319   65,417   92,209  
Rubis Terminal JV  180,309  308,370  305,640  386,655  465,692  471,056  
  of which Group share  99,170  169,604  168,102  212,660  256,131  259,081  
* Used and/or treated water can be either standing (reservoirs or lakes) or flowing water (rivers) above ground, sea water, groundwater or water from the distribution network supplying the site. Discharged water is extracted water, as well as rainwater, which explains the higher volume of water treated than water used for the Rubis Terminal JV.

Water consumption related to the refinery remained below the regulatory threshold prescribed in the prefectural order authorising the operation of the refinery.

Since 2018, the Rubis Terminal JV’s water consumption has been optimised. The ending of significant water table abstraction, which was designed to protect groundwater against surface pollution following the clean-up of a large site, made it possible to reduce water consumption by 98% since 2013.

On a like-for-like basis, the 8% increase in treated water corresponds to a high level of rainfall in France, not recorded since 1959. The 30% reduction in water used corresponds to a year with less commissioning of new tanks than the previous year, generating less water consumption associated with hydraulic tests. WASTE MANAGEMENT

Given their respective business lines, the Group’s activities generate little hazardous waste and, therefore, there is no significant risk in this regard. The main sources of waste generation are storage and refining activities. In order to minimise its impact, to the extent possible, the Group limits the quantity of waste generated and recycles such waste. Subsidiaries ensure that residual waste that cannot be recycled is treated as required by applicable standards.

Analysis by activity

The Retail & Marketing activity generates virtually no hazardous waste, other than in the storage activity. The only hazardous waste produced is mainly made up of residues and sludge, which are treated as required by locally applicable standards, as outlined below in respect of the storage activity.

The Support & Services activity (refining only) produces hazardous waste, mainly petroleum product residues and sludge (which are recovered when waste water from tanks and/or separators is treated during maintenance work) and chemical products.

The Rubis Terminal JV (provision of bulk liquid storage capacity) generates three types of hazardous waste (construction and demolition waste are not taken into account):

•   waste generated by the subsidiaries’ regular activity, particularly following maintenance and inspection, which is mainly comprised of residues and sludge removed when tanks (and/or separators) are cleaned during maintenance operations or when switching between products. Like all other waste, residue and sludge removal is systematically registered, declared and sent to authorised recycling or destruction plants. Residue and sludge with combustion power are usually sent to authorised thermal recovery centres;

•   goods not delivered to customers, which can sometimes only be removed from sites as “hazardous waste” from an administrative point of view;

•   waste from clean-up work, particularly from certain recently acquired sites that contain legacy pollution that predates Rubis Terminal JV’s arrival.


Measures to limit and recycle waste

Innovative procedures and tools have been implemented to limit the production of both hazardous and non-hazardous waste. To this end, the entities are continuing their efforts to increase the number of sites using thermal recycling networks, when such treatment facilities are available nearby.

A continuous inventory of hazardous materials and substances is regularly reported to the local authorities (in the European Union). A register is kept available for inspection by the Regional Directorates of Environment, Planning and Housing (DREALs) at each French site.

The Rubis Énergie refinery and the Rubis Terminal JV have also established a system of systematic sorting of non-hazardous industrial waste, which corresponds to all waste that is neither hazardous nor inert.

This sorting is performed through the use of suitable and appropriately positioned containers on each site.


   Volumes of hazardous waste  Waste recovery rate  
(in tonnes)  2022  2021  2020  2022  2021  2020  
Refining (Support & Services)  69  144  255  94%  73%  59%  
Rubis Terminal JV  2,964  3,032  2,314  51%  38%  22%  
  of which Group share  1,630  1,668  1,273  NA  NA  NA  

In 2021 and 2022, volumes of reported hazardous waste related to the refining activity were down significantly compared to 2020. This significant change is mainly attributable to the fact that a significant volume of chemical products had to be destroyed in 2020 in the context of the dismantling of the Sulférox 17 unit, which had also generated 400 tonnes of non-hazardous waste (concrete, waterproofing, stainless steel, ferrous metals). Waste recycling consists of reusing petroleum sludge and other waste soiled by petroleum products as fuel or another energy source. Oils are regenerated for reuse. Metals and metallic compounds are recycled or recovered.

The production of waste classified as hazardous at the Rubis Terminal JV sites was stable at constant scope. The significant increase in the waste recovery rate is explained by an additional management effort made on several sites, as well as by an exceptional event: the washing of several molasses tanks at the Rouen site, from which the waste at the bottom of the tanks was able to be fully recovered.

Plastic Odyssey: a round-the-world expedition to fight plastic pollution

Rubis Énergie supports and sponsors the Plastic Odyssey project, which is sailing around the world on a ship that is an ambassador for solutions to fight plastic pollution at sea.

The objectives of this expedition are to:

raise awareness of plastic waste reduction and waste recycling, particularly in emerging countries;

circulate know-how and technologies throughout the world;

produce conferences, films and photo reports during the expedition.

Plastic Odyssey has developed open source, low-cost plastic recycling technologies to treat waste generated on land before it ends up at sea. The aim of these machines is to economically develop the plastic waste treatment sector: to create jobs while fighting against pollution at the source.

In order to test these solutions and share them in the countries most affected by pollution, these machines have been taken aboard the MV Plastic Odyssey, a 40-metre former oceanographic research vessel, for a three-year expedition to Africa, South America and South-East Asia. This anti-pollution ambassador is promoting solutions to drastically reduce waste production and build a more sustainable future. Biodiversity

In 2022, Rubis conducted a preliminary analysis of environmental risks from a biodiversity perspective within Rubis Énergie (Retail & Marketing and Support & Services). This specific study of the biodiversity challenges will enable it to fine tune its assessment in 2023 and define the priorities of its action plan to respond to them as well as any additional management measures.

This initial inventory was carried out on the basis of interviews with seven representatives of entities, followed by the sending of a questionnaire to each business unit. The Encore (Exploring Natural Capital Opportunities, Risks and Exposure) database developed by Natural Capital Finance Alliance in partnership with UNEP-WCMC (UN Environment Programme – World Conservation Monitoring Centre) was used to identify marine and land biodiversity hotspots as well as water-stressed areas located close to our sites. This approach has made it possible to raise both the operational teams’ awareness of biodiversity challenges and to identify the most exposed subsidiaries and sites in the Retail & Marketing and Support & Services activities.

In general, the Rubis Group’s main direct impacts on biodiversity are related to site operations and the shipping and ground transport necessary for the activities (atmospheric, soil and water emissions; energy consumption; noise and light pollution).

Some sites are located in areas that are more sensitive in terms of land or marine biodiversity or water stress.

The Group’s climate strategy and the actions it implements to reduce the environmental impact of its activities also aim to protect biodiversity.

For example, the SARA refinery, the entity that consumes the most water for its industrial transformation processes, is not located in an area of water stress. Nevertheless, it has implemented the Green Water project, enabling it to desalinate and demineralise seawater using reverse osmosis, and thus take less potable water from the public network so that the population can benefit from it. This water, once treated and resalinated to a level close to that of seawater, can then be discharged.

The SRPP (Réunion Island) has implemented measures to reduce the light pollution from its depot by reorienting the lighting to limit the dazzling of Mascarene petrels, an endemic species of critically endangered birds. European Green Taxonomy PRESENTATION OF THE MAIN PRINCIPLES OF THE TAXONOMY REGULATION

The European Green Taxonomy, provided for by the EU Taxonomy Regulation 2020/852 of 18 June 2020, is a system for classifying economic activities considered as environmentally sustainable by the European Commission on the basis of scientific criteria. This regulation is the result of the action plan for sustainable finance launched in 2018 by the European Commission in order to direct capital flows towards the activities that it has identified as priorities according to their ability to contribute to one of the following six environmental objectives (see diagram below). An activity is considered “eligible” when it is described in the corresponding delegated regulations (concerning the two climate objectives, in Annexes I and II of Delegated Regulation EU 2021/2139 of 4 June 2021 published on 9 December 2021).


An activity can contribute to both of the European Taxonomy’s climate objectives:

•   through its intrinsic performance (for the Rubis Group, for example, the production of electricity from renewable sources);

•   when it directly enables other sustainable activities. It is then qualified as an enabling activity; or

•   if it promotes the transition to a carbon neutral economy and cannot be replaced by technically and economically feasible low-carbon alternatives. It is then qualified as transitional. This is the case, for example, for transport activities.

Then, to be considered sustainable within the meaning of the taxonomy, an “eligible” activity must be “aligned”. To do this, it must be demonstrated that the said activity meets the requirements set out in Article 3 of the Taxonomy Regulation:

•   it makes a substantial contribution to one of the six environmental objectives, i.e., it meets the technical criteria specified in the delegated regulations;

•   it does not harm the other five environmental objectives (principle of Do No Significant Harm);

•   it complies with minimum safeguards.

In accordance with the Taxonomy Regulation and delegated regulations, three indicators based on the Group’s consolidated financial statements are published: the share of revenue, capital expenditure (“capex”) and operating expenditure (“opex”), together with economic activities considered, on the one hand, as eligible and, on the other hand, as aligned with the technical criteria of the taxonomy, concepts detailed in section 2 below.

For the second year of application of these provisions, non-financial companies must publish:

•   the share of their eligible and ineligible activities under the taxonomy for the three aforementioned indicators;

•   the share of their aligned and non-aligned activities under the taxonomy for the three aforementioned indicators;

•   the indicators relating to data for the financial year 2022.

In this context, a review of Rubis’ activities in the light of the European Green Taxonomy was carried out in order to determine the share of the Group’s activities eligible under the European Green Taxonomy. In accordance with the Taxonomy Regulation, the indicators to be published relate to consolidated financial data. Consequently, the storage activities of the Rubis Terminal JV, an equity associate in Rubis SCA’s financial statements, are not included in Rubis’ taxonomy indicators.

The Group has adopted assumptions and methods as described in this document when they are material and which may change depending on the interpretations and Frequently Asked Questions published by the European Commission. ANALYSIS OF THE GROUP’S ACTIVITIES WITH REGARD TO THEIR ELIGIBILITY AND ALIGNMENT


The assessment of Rubis’ eligible activities was carried out on the basis of a detailed analysis of its various activities with regard to the activities described in the Taxonomy Regulation. This analysis was carried out jointly by the CSR and Consolidation teams, with support from the HSE and Climate/New Energies teams. Rubis’ accounting plans were studied in order to establish an accounting methodology.

As of 31 December 2022, the Group’s activities were as follows:

•   Retail & Marketing of fuels, liquefied gas (LPG) and other types of products such as bitumen (Rubis Énergie);

•   Support & Services, which includes the supply, transport and service activities carried out for the needs of Retail & Marketing activities (Rubis Énergie);

•   Photovoltaic Electricity Production via ground-based solar power plants (Rubis Photosol).The Group manages the entire cycle of photovoltaic projects (financing, construction and operation of power plants);

•   Bulk Liquid Storage (Rubis Terminal JV). As this joint venture is accounted for using the equity method in Rubis’ financial statements, no information is reported in the Group’s taxonomy indicators.

During its taxonomy analysis, the Group identified two activities, from among those listed by the European Regulation as being fully eligible under the first applicable objective of climate change mitigation:

•   activity 4.1 – Electricity generation using solar photovoltaic technology: the Group has an activity, via Rubis Photosol, for the construction and operation of photovoltaic power plants in France on its own behalf and that of third parties;

•   activity 7.6 – Installation, maintenance and repair of renewable energy technologies as part of its construction and operation of solar power plants: the Group, via Rubis Photosol, performs technical and material maintenance activities for its own network and on behalf of third parties through maintenance contracts.

The analysis revealed the absence of eligible revenue for the rest of the Group’s activities (in particular in connection with its Retail & Marketing activities not mentioned in the Regulation). The analysis of eligibility for investments and operating expenses was therefore focused on “individual measures”:

•   activity 4.1 – Electricity generation using solar photovoltaic technology: the Group supports an investment policy for the installation of photovoltaic panels on roofs in its Retail & Marketing subsidiaries (via its subsidiary Rubis Énergie, in the French Antilles and Jamaica);

•   activity 4.10 – Storage of electricity: the Group is developing (via its subsidiary Rubis Énergie, as part of the RSB project) photovoltaic energy production infrastructures coupled with hydrogen electricity storage capacities to ensure continuity of energy distribution;

•   activity 5.1 – Construction, extension and operation of water collection, treatment and supply systems: the Group (via its subsidiary Rubis Énergie) operates a seawater desalination unit at the SARA refinery (in Martinique), which enables the autonomous production of fresh and demineralised water for the refining process and any water needs on the island. This consists of an osmosis unit and reduces the pressure on the potable water network;

•   activity 6.5 – Transport by motorbikes, passenger cars and light commercial vehicles: for the head office and its subsidiaries, the Group has its own vehicles as well as long-term leases for light commercial vehicles;

•   activity 7.2 - Renovation of existing buildings: the Group carried out renovation work on buildings (excluding storage and distribution facilities for fossil-based products);

•   activity 7.7 – Acquisition and ownership of buildings: the Group, within the meaning of the Regulation (including the inclusion by IFRS 16 of its long-term leases) has the use and ownership of its buildings for administrative and/ or operational use, for all its activities in France and abroad.

In addition, as of 31 December 2022, non-material capital expenditure (less than €1 million) was committed for activities 1.2, 6.10, 6.15, 7.3 and 7.6.

It should be noted that in 2022, as in 2021, the Rubis Group has considered the shipping of fuels and bitumen as ineligible.

Delegated Regulation EU 2021/2139 explicitly states that fossil fuel transport activities cannot be considered as aligned under the substantial contribution criterion of the climate change mitigation objective. The transport of bitumen, which is not a fuel but a derivative of crude oil, is not directly referred to in the texts. However, for the sake of consistency with the taxonomy spirit and given the non-material nature of this activity, Rubis has treated this activity in the same way as fossil fuel transport. Therefore, it is not included at this stage in eligible activities. The Rubis Group has deemed it more prudent not to present as an eligible activity an activity that structurally, according to the text, could never be aligned.

As a result, in line with this interpretation, investments made and operating expenses for facilities dedicated to the storage and distribution of products from fossil sources (petroleum products, liquefied gas, bitumen) are also excluded by the Group from eligible activities.

It should be noted that the Group’s eligible capex for the financial year 2022 amounted to €423 million out of a total of €679 million. The eligibility ratio thus stands at 62% of consolidated capex. This high ratio is explained by the acquisition of Photosol on 1st April 2022, for which the fair value of non-current assets is included for €417 million including right-of-use assets. The acquisition of Photosol meets the Group’s objective to integrate low-carbon energy production into its activities. However, this change in scope cannot be considered for the purposes of the 2023 taxonomy reporting.


Description of the method used for the substantial contribution and DNSH criteria

In order to assess the alignment of its activities, Rubis SCA and the subsidiaries concerned systematically verified compliance with the criteria of substantial contribution to climate change mitigation as well as DNSH (Do No Significant Harm).

The analysis carried out demonstrated the alignment of its operations for activities 4.1 relating to the generation of electricity using photovoltaic technology (via Rubis Photosol and Rubis Énergie for individual measures) and 7.6 relating to equipment installation and maintenance (via Rubis Photosol):

Taxonomy activity         Activity 4.1 – Electricity generation using solar photovoltaic technology
Substantial contribution to climate change mitigation  Comments on alignment   Opinion on alignment for the entity
Mitigation criterion: the activity consists of producing electricity using solar PV technology.  For the company, this means qualifying the activity that is carried out.  The installation and operation of PV solar panels meets the definition of the substantial contribution criterion. Proof of alignment: purpose of contracts signed with third parties.
Do No Significant Harm  Comments on alignment  Opinion on alignment for the entity
DNSH 2 –
Climate change adaptation:
This activity complies with the criteria set out in Appendix A of the Delegated Acts.
  The company must demonstrate that it has carried out a study to identify and anticipate the risks related to climate hazards.  The Rubis Photosol and Rubis Énergie subsidiaries conducted a physical risk analysis for each of the sites declared as eligible and aligned. Proof of alignment: Risk analysis and adaptation plan.
DNSH 3 –
Sustainable use and protection of water and marine resources:

  -  -
DNSH 4 –
Transition to a circular economy:
The activity consists of assessing the availability and, as far as possible, using equipment and components that are highly durable and recyclable and that are easy to dismantle and refurbish.
  The company must demonstrate the existence of a sourcing strategy and its implementation, as far as possible.  Projects to install solar panels at the Rubis Énergie subsidiary’s service stations and Rubis Photosol’s solar power plants are accompanied by actions to promote the sustainability and recyclability of PV panels (sourcing strategy, environmental tax, commitment on the dismantling of PVs, business cases, etc.) Proof of alignment: Profitability and sustainability analysis, sourcing strategy, payment of environmental tax.
DNSH 5 –
Pollution prevention and control:

   -     -  
DNSH 6 –
Protection and restoration of biodiversity and ecosystems:
This activity complies with the criteria set out in Appendix D of the Delegated Acts.
  The company must demonstrate that it has carried out a study on its impacts within the ecosystems. Compliance is automatic in France.  The conduct of an environmental impact study is governed by French law. In   other jurisdictions, specialised firms are commissioned to carry out impact studies. Proof of alignment: Administrative authorisation for construction, impact studies.
Taxonomy activity         Activity 7.6 – Installation, maintenance and repair of renewable energy technologies
Substantial contribution to climate change mitigation  Comments on alignment  Opinion on alignment for the entity
Mitigation criterion: The activity consists in one of the following individual measures, if installed on-site as technical building systems:
(a) installation, maintenance and repair of solar photovoltaic systems and the ancillary technical equipment; (…)
  For the company, this means qualifying the activity that is carried out.       The installation and maintenance of PV solar panels meets the definition   of the substantial contribution criterion. Proof of alignment: Purpose of contracts signed with third parties.
Do No Significant Harm   Comments on alignment  Opinion on alignment for the entity
DNSH 2 –
Climate change adaptation:
This activity complies with the criteria set out in Appendix A of the Delegated Acts.
  The company must demonstrate that it has carried out a study to identify and anticipate the risks related to climate hazards.  The Rubis Photosol subsidiary conducted a physical risk analysis for each of the sites declared as aligned. Proof of alignment: Risk analysis   and adaptation plan.
DNSH 3 –
Sustainable use and protection of water and marine resources:

  -  -
DNSH 4 –
Transition to a circular economy:

  -    -  
DNSH 5 –
Pollution prevention and control:

  -  -
DNSH 6 –
Protection and restoration of biodiversity and ecosystems:

  -  -

The other activities were not considered aligned with regard to the DSNH or the substantial contribution criteria.

Description of the method used for minimum safeguards

The analysis of compliance with minimum safeguards was carried out at the Rubis Group level by the Group CSR & Compliance Department, in conjunction with the CSR Advisors of the various entities.

The Group’s compliance with the minimum safeguards criterion is based on Rubis’ commitment to the United Nations Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, as well as the Group’s commitment to respect the principles and rights set out in the eight fundamental conventions mentioned in the declaration by the International Labour Organization.

The procedures that the Group puts in place to comply with these commitments include, among other things, membership of the UN Global Compact, the mapping and publication of risk factors inherent to Rubis’ activity and the implementation of a Group alert mechanism.

These procedures will be strengthened for 2023 with , in particular, the definition of an action plan based on the initial conclusions of the human rights risk mapping and the launch of work on responsible purchasing with the implementation of a dedicated system to monitor the mitigation measures taken by the Group and its suppliers.

The Group’s policies concerning the fight against corruption (in line with the Sapin II law), tax evasion and respect for human rights are presented in section 4.5.1. The measures aimed at strengthening the Group’s approach to human rights within the value chain are inspired by the French duty of vigilance (to which the Group is not legally subject). TAXONOMY INDICATORS


Definition of the indicator

As of 31 December 2022, the amounts corresponding to eligible activities (A.2), i.e., eligible revenue, correspond to almost the entire revenue of the subsidiary Rubis Photosol, for an amount of €32 million.

The amounts corresponding to aligned activities (A.1), i.e., eligible and aligned revenue, also correspond to almost the entire revenue of the Rubis Photosol subsidiary.

The denominator corresponds to the Group’s consolidated revenue (i.e., €7,135 million).


The results detailed using the regulatory tables are presented in chapter 8, section 8.5. Overall, 0.45% of Group revenue is eligible and aligned.

Capital expenditure (capex)

Definition of the indicator

As of 31 December 2022, the breakdown of the numerator of the eligibility ratio (A.2), i.e., Rubis’ eligible capex, is as follows: the Rubis Photosol subsidiary’s almost entire eligible capex since 1st April 2022 represents €413 million for activity 4.1 and €1 million for activity 7.6.

In addition, activity 7.7 generated capex of €3 million.

The increase in non-current assets related to the acquisition of Rubis Photosol on 1st April 2022 is also included in the Group’s eligible capex for activity 4.1, in the amount of €396 million (value as of 1st April 2022).

The amounts corresponding to aligned activities (A.1), i.e., eligible and aligned capex, correspond in particular to:

Rubis Photosol’s capex for activities 4.1 and 7.6.

It should be noted here that 100% of the eligible capex for activities 4.1 and 7.6 of the Rubis Photosol subsidiary are aligned with the technical criteria of the taxonomy.

The total capital expenditure used as the denominator for the calculation of the capital expenditure indicator for the taxonomy is €679 million and corresponds to increases in property, plant and equipment and intangible assets over the period, including increases in IFRS 16 right-of-use assets and business combinations. It can be reconciled with the figures shown in notes 4.1 and 4.3 to the financial statements as follows:

(in thousands of euros) Changes in scope Acquisitions Reclassifications Total
Note 4.1.1 Property, plant and equipment 316,845 224,138 (9,836) 531,147
Note 4.1.2 Right-of-use assets 51,360 42,348 - 93,708
Note 4.3 Intangible assets 46,683 7,427 205 54,315
TOTAL 414,888 273,913 (9,631) 679,170


The results detailed using the regulatory tables are presented in chapter 8, section 8.5. In summary, 62.3% of the Group’s capex were eligible and 61% were aligned in 2022.

Operating expenses (opex)

Definition of the indicator

Analysis of opex led to the identification of flows for the activities of Rubis Photosol and Rubis Énergie. For Rubis Photosol, opex related to eligible and aligned activities are not material. The maintenance of the fleet is internalised and the opex mainly consist of the purchase of spare parts and repairs. For Rubis Énergie, the opex identified by the regulation and eligible under “individually sustainable measures” are not material. They mainly relate to non-capitalised research and development costs and short-term leases.


Taking into account the analysis carried out on the opex within the meaning of the taxonomy, these represent a maximal amount of €165 million, which is not material at the Group scale. The share of eligible and aligned operating expenses under the European Green Taxonomy is deemed nil.

The results detailed using the regulatory tables are presented in chapter 8, section 8.5. ADDITIONAL INFORMATION

The oil and gas sector plays a key role in terms of access to energy, particularly in many of the regions where Rubis operates and where a large portion of the population does not have this access to energy. The need to reduce greenhouse gas emissions at the global level, reflected in the European Green Taxonomy, is well integrated by Rubis, which is investing in the energy transition and in the carbon reduction and diversification of its historical activities.

In addition, in June 2021, the Group acquired an 18.5% interest in HDF Energy (hydrogen-electricity) as part of a strategic partnership. Due to the nature of the transaction (non-controlling interest through the acquisition of shares for €78.6 million), it cannot be taken into account in the capex as defined in the taxonomy, although it corresponds to an eligible activity (activity 4.1 Electricity production using solar photovoltaic technology): the power plants developed aim to provide continuous or on-demand electricity from renewable energies (wind or solar), combined with high-power fuel cells to remedy the intermittent problems of renewable energies.

Since 2017, Rubis has collaborated with HDF Energy on the West Guyana Power Plant (CEOG), of which SARA holds 30%. CEOG is an innovative plant comprising solar panels, batteries and storage of hydrogen produced with the assistance of electrolysers. The plant will make it possible to supply the equivalent of 10,000 households with stable, guaranteed and non-polluting electricity once commissioned, which is scheduled to take place in mid-2024. A similar project is being studied in Barbados. It will help the Barbadian State achieve its target of 100% renewable energy by 2030.

In general, the development method of these projects, usually a joint venture, will not allow them to be counted in the taxonomy indicators and, therefore, to value the Group’s diversification towards less carbon-intensive activities, including when the activities are eligible or even aligned.

Virtuous investment spending

Alongside its taxonomy reporting, Rubis Énergie defined and implemented its own reference framework of capex identified as virtuous in terms of their contribution to the fight against climate change. These capital expenditures are outside the scope of the European Green Taxonomy. The main criteria used to identify virtuous capex from an environmental point of view are decarbonisation (reduction of CO2 emitted) and the ability to promote the energy transition. While these expenses represented a limited amount in 2021, they increased in 2022 and will be subject to specific reporting from 2023.

Among these capex that are virtuous but not eligible at this stage, we can note solarisation projects (facilities for the production of electricity from photovoltaic systems, with or without batteries) on the roofs of buildings or service stations, which are not included at this stage in the eligible capex (see section, paragraph capex). The electricity produced, consumed by users or resold, not only reduces CO2 emissions, but also achieves savings in electricity consumption. For example, as of 31 December 2022, 10 subsidiaries have installed photovoltaic panels on their buildings.

A more detailed presentation of the operating actions implemented to control and reduce the carbon footprint of the Group’s activities and to diversify its activities can be found in section 4.3 “Combating climate change” of this chapter.

Rubis Terminal JV

The Rubis Terminal JV specialises in the storage and handling of bulk liquid and liquefied products, such as fuels, chemical and agrifood products. It has been consolidated using the equity method in its financial statements since 30 April 2020 and is 55%-owned by Rubis SCA. It cannot therefore be included in the Group’s taxonomy indicators, in accordance with Regulation EU 2020/852. The Rubis Terminal JV was nevertheless analysed as a whole, given that the joint venture is included in the Group’s Non-Financial Information Statement. In this context, a review of the activities of the Rubis Terminal JV in the light of the European Green Taxonomy was carried out in order to determine the share of the company’s activities eligible under the European Green Taxonomy.

No revenue-generating activity of the Rubis Terminal JV has been identified as eligible under the European Green Taxonomy, given the partial and specific consideration of storage activities within the Delegated Climate Regulation. The taxonomy does not necessarily include all the activities constituting the complete production chain of the finished product, which alone may be eligible. The potentially eligible activity of the Rubis Terminal JV would have been the storage of raw materials for the production of biofuels or other products and energy. However, after a more detailed study of the texts and exchanges with the teams of the Rubis Terminal JV, it became clear that storage activities not explicitly described in the texts of the European Green Taxonomy are not eligible activities. Discussions with professional storage organisations are underway to clarify the role of storage activities.

It is important to highlight the essential contribution of the Rubis Terminal JV in the value chain of the following products, which are eligible under the taxonomy, thanks to its storage activity for the manufacturing industry:

•   chemical product storage activity: this represented 40.9% of the revenue of the Rubis Terminal JV as of 31 December 2022, with these products then being used in various industries (3.11 carbon black activity, 3.16 nitric acid activity, 3.17 plastics in primary form activity, as defined in Delegated Regulation 2021/2139);

•   energy and biofuel storage activity: the biofuel storage activity (activity 4.13 as defined in Delegated Regulation 2021/2139) represented 12% of the revenue of the Rubis Terminal JV as of 31 December 2022;

•   blending activity allowing the marketing of additive products ready for consumers: the Rubis Terminal JV is involved, in particular, in blends that make it possible to include a portion of regulatory biofuel in fuels sold (activity 4.13 of Delegated Regulation 2021/2139).

4.2.3 Operating in a safe environment / NFIS /

Due to the nature of their activities, the safety of operations is a constant concern for Rubis Énergie’s and the Rubis Terminal JV’s HSE teams. Rubis Énergie operates 16 industrial sites that are classified as Seveso sites (high and low threshold, including a refinery) in the European Union, as well as 49 similar sites located outside the European Union (petroleum or chemical product storage sites and LPG cylinder filling plants). The Rubis Terminal JV operates 27 classified industrial sites as of the date of publication of this document.

The Group’s HSE teams are committed to a continuous process aimed at improving measures and procedures relating to the security of property and the safety of people, particularly employees but also external service providers, customers and local residents. Strict industrial health and safety standards are applied by all Group subsidiaries. Efforts are focused on the safety of the facilities, so as to prevent major accidents, and on personal safety, by preventing workstation accidents and the safety of customers and local residents from being compromised.

The Group continues to invest regularly to upgrade its facilities to comply with the strictest environmental and safety standards and to guarantee that people and their environment are protected (air, water, soil and urban areas located near its facilities).These investments guarantee the reliability of its operations and, as a result, the Group’s competitiveness. In 2022, they amounted to €109 million for Rubis Énergie (compared to €133 million in 2021). The Rubis Terminal JV invested €27 million in 2022.

What is a Seveso site?

Generally, all industrial or agricultural facilities liable to create risks or cause pollution or nuisances for local residents are qualified as installations classified for the protection of the environment (ICPE). Some of these ICPEs are Seveso classified since their operation in France is subject to authorisation by the prefect. Indeed, when an industrial site handles hazardous products, an accident can quickly have serious consequences.

Following an industrial accident that occurred in 1976 at a chemical plant in Italy, the European public authorities adopted a directive known as the Seveso Directive, named after the town near the plant where the accident occurred, to prevent major industrial accidents. The European Seveso Directive, which has been amended three times since it was adopted in 1982, classifies industrial facilities according to the level of danger they represent in case of an accident. The classification, based on the quantity of hazardous products stored, is at either a “high threshold” or “low threshold” Seveso site. The prevention measures to be implemented by operators are adapted to the type of site. They are based on a regularly updated hazard study. Operational safety: target of zero major industrial accidents / NFIS /

Most of Rubis Énergie’s and the Rubis Terminal JV’s facilities in France and the rest of Europe (storage sites and LPG cylinder filling plants) are subject to the Seveso regulation and consequently must comply with very strict environmental protection and industrial safety standards (regular risk assessments, adoption of measures to prevent and, where necessary, manage the consequences of potential accidents). These standards are being phased in gradually by non-European subsidiaries while taking into account the constraints of the local environment.


Risk mapping is performed by the subsidiaries’ Management with the support of the heads of Retail & Marketing, industrial facilities and of the shipping activities (see chapter 3, section

With regard to operational safety, the main risk is the occurrence of a major accident in industrial or distribution facilities (service stations), including an explosion or fire that could cause damage to people, the environment and/or property, etc.


In order to reduce the industrial risks inherent in its activities (regardless of whether they are subject to European regulations) and in accordance with the “zero major industrial accidents” target the Group has set for itself, QHSE teams work on the following factors.

Improving preventive maintenance of facilities and employees’ risk perception

Rubis Énergie and the Rubis Terminal JV continued to roll out their respective preventive facility maintenance tools (computer assisted maintenance management). Once the relevant information has been loaded into the database, these systems allow monitoring and preventive maintenance work to be planned. Its other functions are to catalogue all past maintenance operations so as to create a servicing history, anticipate spare parts requirements, assess maintenance costs in connection with the management of machinery equipment, and prepare budget estimates.

In addition, Rubis Énergie is gradually involving its employees in a continuous effort to improve the safety of facilities by respecting the Plan – Do – Check – Act rule.

Moreover, to improve understanding of the systems and the assessment of the risks relating to Seveso facilities, the Rubis Terminal JV has promoted the use of Piping and Instrument Diagrams (PID). PIDs are a system for presenting process functions, which is used to catalogue a site’s pipes, tanks and pumps and to harmonise disparate existing blueprints by replacing them with a single reliable plan that can be duplicated on all sites.

Use of lesson learned procedures

The organisational arrangements of these procedures vary according to the activities.

Rubis Énergie uses its extranet to circulate to all its subsidiaries a document base that includes lessons learned. Recommendations can then be made after analysing accidents and can include adapting organisational measures, updating risk prevention procedures, reinforcing employee training activities, facilities modifications or improving equipment monitoring.

The procedure for reporting incidents, near misses and accidents by subsidiaries, which gives rise to lessons learned, is an excellent indicator of the safety culture prevailing in the various entities. It is also an important aspect of the continuous improvement process. For example, between 2021 and 2022, Rubis Énergie was able to circulate more than 20 lessons learned reports to all its subsidiaries, detailing the description, consequences and main causes of each incident and the main recommendations to be put in place to prevent such incidents from happening again. These reports covered a wide variety of areas, including the inspection of liquefied gas cylinders before filling, securing containers on trailers, works at service stations, loading tank trucks at depots, fuel deliveries to customers, etc.

The Rubis Terminal JV has developed safety-sharing software (Rubis Terminal Operational Platform) to facilitate and encourage the collection and exchange of safety-related information. This interface collates incident and near-incident reports at each terminal and comes with a lesson learned management module and a report module and dashboard. It is used by local QHSE teams and promotes interactions between sites in view of limiting the repetition of risky events.

Prevent and control technological risks: the preventive safety mechanism at facilities

Prevention of technological risks is ensured through regular inspections of the Group’s sites and subsidiaries by the Industrial and Technical Departments of Rubis Énergie and the Rubis Terminal JV. They are detailed in reports prepared in consultation with the heads of the relevant facilities and the heads of the relevant subsidiaries in order to analyse potential anomalies and/or shortcomings and to take steps to remedy them. Within Rubis Énergie, 27 subsidiaries were audited in 2022.

In addition to inspections and lessons learned, each entity implements preventive measures that are appropriate for its own activity, including:

•   internal inspection programmes for all liquefied gas and fuel bulk storage tanks, which are generally scheduled every 10 years or as required by international standards;

•   installation and maintenance of safety equipment such as gauges, level alarms, fire defences, gas detection systems, etc.;

•   systematic verification that all substances stored, whether existing or new, have been authorised in advance by an operating permit if required;

•   pursuant to Seveso regulations, a procedure to prevent major accidents at French facilities involving hazardous substances, and supplemented by “Instrumented Risk Control Measures” (IRCMs);

•   periodic inspection of fire-fighting systems and regular updating of contingency plans in consultation with local authorities. In addition, these facilities are regularly tested through exercises that simulate potential accident conditions as closely as possible.

Should a major event occur despite the implementation of these rigorous preventive measures, arrangements have been made for:

•   establishing a crisis management organisation that can be triggered rapidly if there is a major event. For example, the relevant high-risk facilities have emergency response plans that aim to bring incidents under control as quickly as possible using local resources so as to guarantee the best possible protection of people and property. These plans are combined with 24/7 on-call crisis management procedures that may be activated depending on the severity of the event. Lastly, some subsidiaries organise regular training sessions on crisis communications through accident simulation exercises, which allows them to test pre-established communication protocols;

•   the option to obtain assistance from specialist companies. For example, Rubis Énergie has partnered with Oil Spill Response Ltd to receive assistance in the event of maritime pollution at its fuel depots. It also partners with professional bodies such as GESIP (Groupe d’étude de sécurité des industries pétrolières et chimiques – Group for Safety Research in the Petroleum and Chemical Industries), WLPGA (World Liquefied Petroleum Gas Association), JIG (Joint Inspection Group) and IATA (International Air Transport Association), which are expert organisations in aviation refuelling and provide general operational, training and safety support.

The Rubis Terminal JV Seveso storage sites in question possess both internal and external resources for responding to pollution accidents. For example, specialised companies are appointed to manage any river spills that could be carried along by the current.


In 2022, in line with the target set by the Group, no major accidents occurred in the framework of Rubis Énergie’s and the Rubis Terminal JV’s activities.

In addition to the constant concern of preventing major industrial accidents, the Group also continues to make efforts to reduce the occurrence of more minor industrial accidents to every possible extent.

For more information, please refer to sections “Occupational health and safety” and “Water and soil pollution”. Personal safety / NFIS /

Personal safety is a direct result of operational safety. Rubis is just as attentive to workplace safety (section as it is to the safety of customers and local residents (section The Group’s objective is to have no fatalities at facilities operated by Group subsidiaries, including the Rubis Terminal JV, and to reduce as far as possible the number of accidents that are liable to result in lost time for both subsidiary personnel and outside contractors. With regard to road traffic accidents (particularly on the African continent, where the accident rate is high), each subsidiary is responsible for implementing the preventive instructions and training plans needed to reduce the rate of accidents recorded as much as possible, depending on local constraints. OCCUPATIONAL HEALTH AND SAFETY / NFIS /

A proactive occupational health and safety policy has been implemented. It covers both preventing occupational accidents and preventing occupational and non-occupational illnesses.


Beyond the generic risks inherent in any industrial activity, Rubis’ activities carry more specific risks in terms of occupational health and safety, which are related in particular to:

•   the intrinsic properties of products being handled (hazardous materials);

•   transport (road safety): each year vehicles transporting products cover many kilometres.

Each Group entity endeavours to offer the safest working conditions to its employees and to service providers working on its sites.

Measures taken

Rubis’ Code of Ethics sets out a general framework for the Group’s safety culture, which requires all employees to act responsibly when performing their duties, to comply with the health, safety and environmental protection procedures on site, and to pay particular attention to compliance with these rules by all parties (colleagues, suppliers, external service providers, etc.). On this basis, a quality health, safety and environmental (QHSE) policy has been prepared by Rubis Énergie and the Rubis Terminal JV to protect the physical integrity of individuals and to minimise the impacts of any major accidents.

Since 2015, variable compensation for the Group’s Management Board includes a criterion relating to changes in the accident rate (rate of frequency of occupational accidents per million hours worked), underscoring its commitment and involvement in safety challenges.

Occupational accidents and operator safety

To guarantee the maximum level of safety for operators at Group sites, each entity is responsible for holding training sessions for external operators on the risks generated by the facilities and the products handled within such facilities. For example, Rubis Énergie has set itself the additional objective of maintaining a level of training that will enable it to maintain the HSE performance level of its employees.

The Rubis Terminal JV, whose operational teams already receive training on the subject, achieved a rate of 100% of employees at the head offices in each country who attended an HSE risk awareness training course, which is, moreover, part of the training for all new hires.

Furthermore, prior to working in a facility, each external service provider must also approve a safety plan (sometimes called a prevention plan or safety protocol) describing the risks associated with the work, safety instructions and emergency instructions.

The objective is for there to be no fatalities and to reduce as far as possible the number of accidents likely to result in lost time, with respect to both subsidiaries’ personnel and external service providers.

Occupational illness and health

The Group pays close attention to risks linked to occupational illness and, for several years now, has offered ergonomic training to employees in at-risk positions.

Regarding other health risk factors, exposure measurement campaigns are conducted, notably by the SARA refinery, regarding chemical products, noises and vibrations, Legionella and asbestos.

Regarding non-occupational illnesses, the Group is present in some countries experiencing epidemics. Awareness-raising and assistance programmes have been developed in some subsidiaries, for example in the context of the fight against AIDS (South Africa), the Ebola epidemic, malaria (Nigeria), the plague (Madagascar), cholera (Haiti) and chikungunya (the Caribbean).

Lastly, private health coverage is taken out for employees to enable them to access healthcare (see section

Road safety

In the area of road safety, the Group is constantly seeking to improve outcomes in terms of road accidents associated with its activities, and in particular those of Rubis Énergie and its subsidiaries. In addition to the application of the regulations applicable to the transport of hazardous materials, additional measures are taken concerning road haulage. To avoid traffic accidents, certain of Rubis Énergie’s subsidiaries have stepped up their road risk prevention programmes and give instructions that take local constraints into account, such as no night driving in certain countries and/or random alcohol or drug testing.

Defensive driving programmes have been introduced in countries where driving risk is heightened due to driving habits, distances travelled, poor quality road infrastructure or the specificities of the product being transported. The countries in which the Group operates considered to be the most exposed to road safety risks are among the 100 countries identified by the WHO as having the highest number of accidents: https://www.who.int/data/gho/data/ indicators/indicator-details/GHO/estimated-road-traffic-death-rate-(per-100-000-population). In 2022, 81% of the drivers (91% of employee drivers and 78% of external drivers) had been trained.

Furthermore, measures have been taken to modernise equipment (vehicle fleets), notably in Haiti where, in 2018, a five-year action plan in the amount of approximately US$17 million was put in place to replace 70 tank trucks belonging to carriers working for Dinasa. Some subsidiaries have rolled out on-board electronic assistance (France, Switzerland, and Portugal) and tracking systems (Nigeria, Bermuda, Jamaica, South Africa and Madagascar).

Training as a means of preventing risks

Given the risks associated with its activities, the Group invests in training its employees on health, safety and environmental issues. Detailed data is presented in section 4.4.2.


Workplace accidents

The number of workplace accidents recorded by the subsidiaries’ Human Resources Departments (including the Rubis Terminal JV) increased compared to the previous financial year (45 in 2022, compared to 35 in 2021). The efforts made by the operating subsidiaries in the area of health and safety over the past several years, by raising employees’ awareness of the risks associated with their activities (see section 4.4.2) and by improving QHSE procedures (see section 4.2), have gradually and significantly reduced the workplace accident frequency rate. The rate has fallen by more than 42% since 2015 at Rubis Énergie (8.2 in 2015, compared to 4.7 in 2022, per million hours worked) and by 22% at the Rubis Terminal JV (18.3 in 2015, compared to 14.3 in 2022).

While the change in this frequency rate is a key monitoring indicator for the Group, the teams work hard to ensure all accidents are reported, wherever they occur. The Group thus strives to have reporting that is as complete as that required by European regulations. In addition to the analysis of the change in frequency rate, the quality of reporting, which can lead to increases, is thus also a key indicator of safety culture.

  Number of occupational accidents with lost time > 1 day* Of which number of fatalities Frequency rate of occupational accidents with lost time (per 1 million hours worked)* Frequency rate of occupational accidents with lost time (per 200,000 hours worked)* Number of occupational illnesses Instances of total and irreversible work disability
  2022 2021 2020 2022 2021 2020 2022 2021 2020 2022 2021 2020 2022 2021 2020 2022 2021 2020
Rubis SCA/Rubis Patrimoine 0 0 1 0 0 0 0 0 24.3 0 0 4.9 0 0 0 0 0 0
Rubis Énergie 32 27 31 0 1 0 4.7 4 5.3 0.9 0.8 1.1 1 1 0 0 2 1
TOTAL 32 27 32 0 1 0 4.7 4 4.9 0.9 0.8 1.0 1 1 0 0 2 1
Rubis Terminal JV 13 8 9 0 0 0 14.3 9 11.9 2.9 1.8 2.4 0 1 0 1 0 0
TOTAL INCLUDING THE JV 45 35 41 0 1 0 5.8 4.6 5.5 1.2 0.9 1.1 1 2 0 1 2 1
* Including commuting accidents for French subsidiaries. Commencing in 2022, the indicators occupational “accidents with lost time > 1 day” and “frequency rate of occupational accidents with lost time” no longer include the commuting accidents accounted for by French entities, even if they remain considered as being occupational accidents under the declarations made to health insurance funds in accordance with French regulations. These accidents are accounted for as occupational accidents in only a small number of countries and the HSE measures defined and implemented by Group entities relate above all else to preventing accidents that take place during employees’ working hours. It should be noted that travel carried out in connection with an employee’s activity during their working hours remains included in the accounting for occupational accidents (employees who travel on business, drivers, etc.).
In 2021, four commuting accidents reported by entities within the Rubis Énergie scope resulted in lost time lasting more than one day. If the frequency rate is recalculated by excluding these commuting accidents, the frequency rate stands at 4 for Rubis Énergie and 4 for Rubis Énergie + Rubis SCA/Rubis Patrimoine combined.

In 2022, there were no fatal accidents.

Other occupational accidents leading to lost time of more than one day resulted mainly from slips and low-level falls, handling (LPG cylinders, in particular) or minor injuries (cuts, burns). The severity rate (measured in terms of number of days of absence due to an occupational accident) of occupational accidents rose in 2022 compared to 2021: 0.16 vs 0.06 (0.19 vs 0.08 if the Rubis Terminal JV is included).

The absenteeism rate resulting from occupational accidents and illnesses is still very low across the Group as a whole, standing at 0.13% in 2022 (0.16% including the Rubis Terminal JV).

Accidents involving external providers

Monitoring of accidents occurring at Group sites and involving external providers has also been put in place: 11 accidents were reported by the subsidiaries in 2022 (compared to 20 in 2021).There were no fatalities concerning service providers in 2022.


  2022 2021 2020
Rubis SCA/Rubis Patrimoine 0% 0% 0.18%
Rubis Énergie (Retail & Marketing/Support & Services) 0.13% 0.07% 0.09%
TOTAL 0.13% 0.06% 0.09%
Rubis Terminal JV 0.46% 0.35% 0.22%
TOTAL INCLUDING THE JV 0.16% 0.10% 0.15%
* Days lost as a percentage of the total number of days worked per annum. PROTECTION OF THE HEALTH AND SAFETY OF LOCAL RESIDENTS AND CUSTOMERS / NFIS /

The Group’s subsidiaries place particular importance on the health and safety of local residents and customers.


When local residents live or carry out an activity within the immediate proximity of the Group’s sites, they can be exposed to any industrial risks that may occur. While most Seveso industrial sites are not located in urban areas and are only accessible to authorised persons, service stations, which are accessible to the public, are often located in urban or suburban areas. However, the risk regarding service stations is lower because the quantities of products stored there are limited.

Measures taken

All the measures described in the section on operational safety also protect the health and safety of local residents and customers. Depending on the sector in which the subsidiaries operate and their customers’ specific expectations, subsidiaries take various initiatives, including:

•   a demanding risk prevention policy is in place in all subsidiaries, to protect all persons who are liable to be exposed to risks associated with the handling of stored or distributed products. This policy, which gives rise to substantial internal prevention and control systems, is described in section 4.2.3, section 4.4.2 and in chapter 3, section 3.1;

•   Seveso regulations, which are extremely stringent with respect to health and safety obligations, are complied with by relevant European sites;

•   several subsidiaries have obtained ISO 9001 and 14001 certifications, others are in the process of obtaining certification (see section Recognition of this nature attests to commitments made regarding the health and safety of individuals and respect for the environment;

•   a preventive maintenance and facility compliance programme is implemented in service stations.

The quality of the customer relationship is a key element of the subsidiaries’ strategy but also a critical piece of information about consumer health and safety. The resulting initiatives vary depending on the type of customer.


Vitogaz France has had NF Service Relation Client (NF345) certification since 2015. Revised in 2018, NF Service Relation Client certification is based on international standards ISO 18295-1 & 2. A guide to best practices in customer relationship management, it takes customer expectations into account and aims to guarantee constant improvements to service quality. For Vitogaz France, this quest for excellence in customer experience seeks to establish a long-lasting commercial relationship, deliver quality service over time, ensure that information provided is complete and clear, and to promptly meet its commitments.