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).

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 have drawn up their own QHSE policy consistent with the Group’s general principles. 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).

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 Directors 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 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) in view of protecting the safety of people and property and to heighten employee awareness about these issues.

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

• •disseminating Rubis Énergie’s fundamental HSE principles within the 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 (transportation 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 the GESIP (Groupe d’Étude de Sécurité des Industries Pétrolières et Chimiques – Group for Safety Research in the Petroleum and Chemical Industries) in order to share lessons learned and implement industry best practices;
• •joining the professional aviation groups/associations JIG and IATA and signature of a Shell Aviation technical support agreement, with the goal of accessing expertise in the reception, storage and transfer of aircraft fuel and in aircraft fueling operations at airports for the relevant Rubis Énergie entities;
• •joining Oil Spill Response Ltd, a company that provides assistance in the event of maritime pollution that may occur during loading/unloading operations at Rubis Énergie’s terminals.

The Rubis Terminal JV’s Management has circulated a document to all its subsidiaries setting out “the principles of Rubis Terminal’s safety culture.”

These principles note, through the commitments made by the joint venture’s Management, that:

• •safety is a core value that must be shared by all employees as a personal value;
• •Managers are responsible for staff safety and must be held accountable.

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 workplace injuries 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 that incorporates 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 by circulating internally a document entitled “Group objectives for environmental impacts and energy consumption” to limit its environmental footprint. The document sets out objectives for reducing greenhouse gas emissions, energy and water consumption, and waste management, the results of which are presented in the corresponding sections of this chapter (section 4.3.4.3 regarding the activity’s carbon intensity, section 4.2.2.3.1 regarding water consumption and section 4.2.2.3.2 regarding 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 Rubis Terminal JV’s 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.

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

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

Rubis businesses are organised around two activities, Retail & Marketing and Support & Services, as well as the Rubis Terminal JV which operates a bulk liquid Storage activity on behalf of a diverse industrial customer base. These activities present industrial risks that, depending on the activities and the nature of the products being handled (fuels and heating fuels, biofuels, liquefied gases, bitumen, chemical and agrifood products), 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 sites (storage depots, service stations, filling plants for LPG cylinders, customer facilities, aviation or marine refueling 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 4.2.2.1);
• •assessing and limiting atmospheric emissions from industrial activities (section 4.2.2.2);
• •optimising the use of resources by conserving water resources (section 4.2.2.3.1).

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 4.2.2.3.2).

The Group’s climate strategy and the actions it implements to reduce the environmental impact of its activities also aim to protect biodiversity. Rubis would like to enhance the analysis of environmental risks to include the issue of biodiversity. To do so, in 2022, Rubis will conduct a special study on biodiversity challenges in order to fine tune its assessment and define the priority areas of its action plan for responding to these issues and any additional management mesures required.

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 the extent possible.

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 transportation of products, which is necessary to supplying distribution sites and customers (fuel, bitumen) is also liable to result in accidental spills.

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 fuel retail 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 six service stations, i.e., about 20 tanks, were replaced in 2020 in the Caribbean zone, representing an overall investment of approximately US$3 million.

In parallel, Rubis Énergie is reinforcing its preventive maintenance programmes for this equipment (see section 4.2.3.1) 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 transportation 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.

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 ship loading/unloading operations or in the event of a shipping accident.

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. Rubis Énergie has partnered with Oil Spill Response Ltd, an organisation that provides specialised assistance in managing this type of event.

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 made possible by 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 facility shutdowns for periodic maintenance. The overall decrease in flows of pollutants at the refinery in 2021 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.

In accordance with professional practices, Rubis Énergie monitors accidental spillages of liquid petroleum products with a unit volume of more than 200 liters. In 2021, the subsidiaries recorded 23 incidents (mainly due to facility leaks, traffic accidents or non-compliance with operating procedures). This slight increase compared with the prior year (20 reported incidents) is attributable, first, to an improvement in reporting quality (implementation of a digital CSR reporting solution, improved awareness of local teams) and, second, to an extension of the reporting scope to new entities recently acquired in East Africa, where measures to upgrade HSE standards are underway. A new HSE Director in charge of the area was recruited for this purpose.

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

The storage activity may generate accidental water and soil pollution, in particular as a result of bulk tank overflows, spreading, bulk tank and/or pipe leaks, and discharges into residual water.

Tanks containing hazardous products and associated pipework undergo systematic inspections at storage sites in accordance with international standards during regular mandatory on-site 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, the retention platforms are purpose-designed for each type of handled product 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.

The volume of suspended solids discharged into the water is very low compared to the volume of water used (over 450,000 m3). The change between 2020 and 2021 can be explained by the fact that two sites in France that did not previously report their figures have been included starting in 2021 and that 2021 represents a full year of reporting for the Spanish sites. A slight reduction was measured at constant scope.

The reported incidents correspond to pollution in excess of 200 liters in the course of one year. One incident was reported in financial year 2021, which related to a leak of 500 liters of diesel fuel from an external pipeline valve. All polluted soils were treated or removed for treatment.

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 atmospheric pollutant emissions are being evaluated progressively. The carbon emissions assessment is published in section 4.3.4 relating to climate change.

The petroleum product distribution activity generates some 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.

In fuel depots, particularly those equipped with source loading stations, petrol vapors are collected during tank truck loading; in France, where regulations have required it for several years, these vapors are treated in vapor 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 vapors into the atmosphere during the storage phase.

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

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 1 January 2020 entry into force of the Low Sulfur regulation implemented by the International Maritime Organisation (IMO 2020), which limits the maximum sulfur content of marine fuels to 0.5% (compared to 3.5% previously).

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 vapors have also been implemented.

Each year, a refinery fume control campaign is carried out by an authorised body to validate the findings of our self-monitoring system (the 2021 campaign was postponed to March 2022 due to unit shutdowns).

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

• •Rubis Énergie has fitted one of its six directly owned vessels with a scrubber, which captures sulfurous emissions by cleaning the exhaust fumes. These chimney evacuation filters treat exhaust gas, eliminating up to 90% of sulfur dioxide (SO2) and fine particles;
• •the other five directly owned vessels, as well as those operated on a time-charter basis by Rubis Énergie, now use low-sulfur fuel oil (0.5% maximum). The availability of this low-sulfur fuel oil in the three activity zones (Caribbean, Europe and Indian Ocean) is very satisfactory.

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

These vapors are recovered when tank trucks discharge their loads and are piped to vapor 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.

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

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 4.2.3.2).

At the storage sites, the low values calculated still show a very limited NOx impact from this activity in 2021 which was unchanged despite an increase in heating over the past year. In spite of Tepsa’s consolidation, the impact remains limited as the Spanish subsidiary does not use much fuel. At constant scope, NOx emissions are decreasing due to the commissioning of gas-fired boilers in Strasbourg and Rouen which replaced boilers fired by heavy fuel-oil, as well as the near complete switch to heated LNG at Dörtyol.

Concerning VOCs, the over 13% reduction recorded for Rubis Terminal in 2021 once again reflects the full-year operation of a more efficient vapor recovery unit treatment system for petrol emissions at the Rouen site.

SOx emissions are not measured by Rubis Terminal because the fuels used are either standard low-SOx liquid fuels (mandatory in the EU countries where the subsidiaries are located) or natural gas, or LNG in Turkey, which contains almost no SOx.

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 4.2.2.3.1). Moreover, although the Group produces little waste, it ensures that the quantities of waste are limited and that waste is recycled (section 4.2.2.3.2).

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.

The water consumption at the Rubis Terminal JV mainly comes from fire drills carried out to test the effectiveness of the systems in place and from the need for dosing liquid fertilisers. This usual consumption is increased by occasional water requirements resulting from the filling of new bulk tanks with water (resistance tests).

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 allows 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 Rubis Énergie’s 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 aimed at producing industrial water at Rubis Énergie’s 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, is under way (civil engineering works, piping) and 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). Commissioning, which had been scheduled for the fourth quarter of 2020, was postponed to the first half of 2021 due to the Covid-19 pandemic. The project should reduce the refinery’s city water consumption by 80%. Domestic water (sanitary, kitchen) will continue to be supplied through the drinking water network.

Water consumption related to Rubis Énergie’s refinery (Support & Services activity) is down slightly (notably due to the two major technical shutdowns) and remains below the regulatory threshold set by the prefectural decree authorising the refinery to operate.

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. Nevertheless, in 2021 as in 2020, the variation in water used corresponds to hydraulic tests on many tanks that were commissioned or refurbished in 2021. As regards treated water, the difference with the volume of water used corresponds to the calculated variation in rainfall on the sites.

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.

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 products 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:

• •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 centers;
• •goods not delivered to customers, which can sometimes only be removed from sites as “hazardous waste” from an administrative point of view;
• •waste from decontamination work, particularly from certain recently acquired sites that contain legacy pollution that predates Rubis Terminal JV’s arrival.

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.

In 2021, volumes of reported hazardous waste related to the refining activity were down significantly compared with 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.

Reported generation of hazardous waste at the Rubis Terminal JV’s sites increased by 30% due to the integration of Tepsa in 2021. The increase in the waste recovery rate is attributable to additional efforts made at several sites. However, construction waste incorrectly identified during maintenance activities or operations further negatively affect this result.

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).

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. meets the technical criteria specified in the delegated regulations;
• •it does not hinder the other five objectives (“Do No Significant Harm” principle); and
• •it complies with minimum social standards.

For the first time for the 2021 financial year, in accordance with the Taxonomy Regulation and delegated regulations, Rubis SCA is required to publish the eligible portion of its activities (revenue, capital expenditure and operating expenditure) on the first two environmental objectives relating to climate change: mitigation and adaptation. The delegated regulations relating to the other four objectives, still under negotiation or preparation at the date of publication of this Universal Registration Document, are scheduled for 2022 and should enter into force 12 months after their publication (i.e., a first publication in 2024 for the 2023 financial year).

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 for 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 first assessment of Rubis’ eligible activities was carried out on the basis of a detailed analysis of its various consolidated activities with regard to the activities described in the taxonomy. This analysis was carried out jointly by the CSR and Finance teams (consolidation), with support from the HSE and Climate/New Energies teams. Rubis Énergie’s accounting plans were studied in order to establish an accounting methodology.

The Group has not identified any eligible revenue. Under the first two objectives of climate change mitigation and adaptation applicable from the 2021 financial year, the European Commission has prioritised the business sectors that have a major contribution to greenhouse gas emissions at European Union level. The retail and marketing of energy is not considered within the meaning of the taxonomy as having a substantial contribution with regard to these primary climate objectives and as a priority sector for the taxonomy. This is focused on low-carbon energy production activities.

Due to the absence of eligible revenue, the capital expenditure and operating expenditure related to the activities contributing to the revenue cannot be classified as eligible. The analysis of eligibility for capital expenditure and operating expenditure was, therefore, focused on “individual measures”, which explains the low eligible amounts.

In addition, given the highly technical nature of the regulations, and the fact that the delegated regulation on the climate and the regulation clarifying Article 8 were published respectively on 9 and 10 December 2021, Rubis adopted a conservative position for the 2021 financial year, by excluding from eligible activities, and in particular from the numerator of the CapEx ratio, investments made in its facilities for the storage and distribution of fossil-based products (petroleum products, liquefied gases, bitumen). The Group will revise its valuation methodology and the resulting figures as necessary, depending on changes in regulations and their interpretation.

The eligible “revenue” ratio referred to in the Taxonomy Regulation is calculated by taking into account:

• •in the denominator: net revenue, i.e., “the amount resulting from the sale of products and the provision of services, net of sales discounts, value added tax and other taxes directly related to revenue”. The definition also refers to paragraph 82 (a) of IAS 1 and must, therefore, correspond to revenue presented in the income statement. Revenue does not include joint ventures (JVs) presented using the equity method, discontinued operations and reciprocal internal transactions;
• •in the numerator: the share of net revenue associated with activities identified as eligible.

Rubis Énergie’s main activity is the retail and marketing of fuels and other petroleum products to private individuals and professionals. Their NAF code is 4671Z: wholesale trade in fuel and related products, corresponding to NACE code 46.71 (“Wholesale of solid, liquid and gaseous fuels and related products”). This NACE code is not mentioned among the codes of the Taxonomy’s various eligible activities.

More broadly, Rubis Énergie’s Retail & Marketing activities, regardless of the products concerned, are not eligible for the taxonomy. The eligible activities described in the Delegated Climate Regulation focus on the production (of energy, chemical products, etc.) and do not necessarily include all downstream or upstream activities in the value chain. Specifically, the distribution of certain products to private individuals or professionals, even if they are products otherwise identified as eligible (for example, biofuels) is excluded from the eligible activities.

The activities comprising the shipping of fuels and bitumen are excluded from the eligible activities for Rubis Énergie. Indeed, the regulation EU 2021/2139 expressly excludes the activities of fossil fuels transportation. The transportation 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 as fossil fuels transportation. Therfore, it is not included at this stage in eligible activities.

In addition to these activities, the activities of the SARA refinery were dealt with specifically. Its income-generating activities were also excluded, in particular because they mainly concern fuel production, which is strictly excluded from the taxonomy. Certain activities such as the capture of CO2 by micro-algae or by the refinery stacks, which would come under category 3.2 “Other low-carbon manufacturing technologies”, are currently not included because these projects are in the study phase and do not generate any costs.

No Rubis Énergie revenue-generating activity (Retail & Marketing and Support & Services) has, therefore, been identified as eligible for the European Green Taxonomy, leading Rubis Énergie to a ratio of revenue eligible for the European Green Taxonomy of 0%.

The eligible “CapEx” ratio referred to in the Taxonomy Regulation is calculated by taking into account:

• •in the denominator: capital expenditure including increases in property, plant and equipment and intangible assets and right-of-use assets for the year (before revaluation, impairement and depreciatio and excluding changes in fair value) as well as increases related to business combinations. These are capital expenditures and increases in right-of-use assets covered by the following IFRS standards: IAS 16 “Property, plant and equipment”, IAS 38 “Intangible assets”, IFRS 16 “Leases”;
• •in the numerator: capital expenditure:
  • •in connection with an eligible activity, i.e. CapEx linked to assets or processes associated with a commercial economic activity eligible for the taxonomy,
  • •in connection with assets or processes subject to a plan to develop the economic activities aligned with the taxonomy or to enable eligible economic activities to become aligned (hereinafter referred to as the “CapEx plan”), and
  • •“individual” capital expenditures enabling the target activities to become low-carbon or leading to greenhouse gas reductions, including economic activities listed in the delegated regulations provided that these measures are implemented and operational within 18 months.

Due to the non-eligibility of its activities, Rubis’ eligible CapEx (i) do not include the CapEx directly related to its activities and (ii) only concerns the CapEx implemented under “individually sustainable measures”, as defined by the Taxonomy Regulation, aimed at reducing greenhouse gas emissions. In order not to overestimate the eligible CapEx and in view of the outstanding questions of interpretation, Rubis has adopted a conservative position regarding the data relating to the 2021 financial year. The following expenses were, therefore, not included in “individual” capital expenditure:

• •expenses relating to shipping and road transport dedicated to the transport of fossil fuels and bitumen; and
• •expenses relating to work on logistics and distribution facilities for fossil-based products. Indeed, within the technical criteria for the “Adaptation to climate change” objective, there is a clear exclusion for these activities of buildings “intended for the extraction, storage, transport or manufacture of fossil fuels”.

This position may be reconsidered for the reporting on the 2022 financial year. However, it should be noted that as part of its Climate initiative, Rubis Énergie has undertaken work to improve the energy efficiency of its logistics facilities. In 2021, it also implemented a mission to assess the carbon reduction actions of its activities, the results of which will be known in 2022 and which will make it possible to confirm its carbon reduction trajectory (see section 4.2.2.4.3 Additional information).

With regard to capital expenditure related to individual measures, the review of Rubis Énergie’s activities, and in particular ongoing projects, made it possible to identify several activities giving rise to capital expenditure. The share of capital expenditure eligible for the European Green Taxonomy is 2.6% for the 2021 financial year out of a total of €235,875 thousand (this amount corresponds to the increases as well as the entries in the scope of consolidation included in the changes in scope of the year presented respectively in the notes 4.1.1, 4.1.2 and 4.3 of the notes to the Group’s consolidated financial statements). This concerns individual measures related to the activities listed in the table below.

The eligible “OpEx” ratio referred to in the Taxonomy Regulation is calculated by taking into account:

• •in the denominator: direct non-capitalisable costs covering research and development (R&D), short-term leases, upkeep, maintenance and repair of assets, building renovation measures as well as any other expenses related to the daily maintenance of assets;
• •in the numerator: operating expenses:
  • •in connection with an aligned activity, i.e., OpEx linked to assets or processes associated with an economic activity eligible for the taxonomy,
  • •in connection with activities being aligned, and
  • •in connection with “individual” measures enabling the target activities to become low-carbon or leading to greenhouse gas reductions.

Due to the non-eligibility of its activities, Rubis’ eligible OpEx (i) do not include OpEx directly related to its activities and (ii) only concerns OpEx implemented under “individually sustainable measures”, as defined by the Taxonomy Regulation. Rubis examined the definition of the denominator relating to operating expenses presented in point 1.1.3.2 of Annex I of Delegated Regulation 2021/2139 as well as the FAQs published by the European Commission on 11 February 2022 (question 11) specifying the eligible operating expenses. OpEx taxonomy, consisting of upkeep, repair and maintenance costs of assets, and non-capitalised research and development costs, are negligible. In accordance with the Taxonomy Regulation, as OpEx taxonomy is not material, the Group has not calculated the share of eligibility for this indicator.

The share of operating expenses eligible for the European Green Taxonomy is considered non-material.

The oil and gas industry 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 December 2021, Rubis announced the creation of a new division dedicated to the development of renewable or low-carbon energies. This division will house Photosol France, a photovoltaic energy producer, when the acquisition is finalised (first half-year 2022). It is important to note that the ratios presented above do not include the activity related to this announced acquisition of Photosol, which should have a material impact on Rubis’ taxonomy ratios (4.1 Electricity production using solar photovoltaic technology and 7.6 Installation, maintenance and repair of renewable energy technologies). In the medium term, this activity should represent 25% of the Group’s gross operating income.

In addition, in June 2021, the Group acquired an 18.5% stake in HDF Energy (hydrogen-electricity) as part of a strategic partnership. Due to the nature of the transaction (minority interest through the acquisition of shares for an amount of €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 been working with HDF Energy on the West Guiana Power Plant (CEOG) project, in which SARA holds a 30% stake. This is an innovative power plant, consisting of photovoltaic panels, batteries and hydrogen storage produced using electrolysers. From the start-up of its operations scheduled for mid-2024, it will provide the equivalent of 10,000 households with stable, guaranteed and non-polluting electricity. A similar project was launched 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 JV, 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.

Alongside its taxonomy reporting, for the first time in 2021, 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 a virtuous CapEx from an environmental point of view are decarbonation (reduction of CO2 emitted) and the ability to promote the energy transition. While these expenses represent a limited amount in 2021 (less than 1% of total investments), they are expected to show strong growth in 2022 and 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 4.2.2.4.4, 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 2021, around 10 buildings had been solarised.

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.

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. The Rubis Terminal JV was analysed as a whole, although it is accounted for under the equity method in Rubis’ financial statements, given that the JV is currently 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 for the European Green Taxonomy.

No revenue-generating activity of the Rubis Terminal JV has been identified as eligible for the European GreenTaxonomy, 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 for the taxonomy, thanks to its storage activity for the manufacturing industry:

• •chemical products storage activity: this represents 37% of the revenue of the Rubis Terminal JV as of 31 December 2021, with these products then being used in various industries (3.11 carbon black activity, 3.16 nitric acid activity, 3.17 basic plastics 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 10% of the revenue of the Rubis Terminal JV as of 31 December 2021;
• •blending and rebalancing activity allowing the resale of processed products: the Rubis Terminal JV is involved, in particular, in blends that make it possible to include a portion of regulatory biofuel in the fuels sold (activity 4.13 of Delegated Regulation 2021/2139).

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 safety 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 46 similar sites located outside the European Union (petroleum or chemical product storage sites and LPG cylinder filling plants). As of the date of this document, the Rubis Terminal JV operates 27 classified industrial sites (excluding Turkey, which was removed from the scope in January 2022).

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 2021, they amounted to €133 million for Rubis Énergie (compared with €131 million in 2020). The Rubis Terminal JV invested €27 million in 2021.

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 business (see chapter 3, section 3.2.3.2).

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 accidents” target the Group has set for itself, QHSE teams work on the following factors.

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 rule Plan – Do – Check – Act (see diagram below).

Moreover, to improve understanding of the systems and the assessment of the risks tied to Seveso facilities, the Rubis Terminal JV has also developed Piping and Instrument Diagrams (PID). PIDs are a system used to digitally 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.

The organisational arrangements of these procedures vary depending on the activities at issue.

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, in 2021 Rubis Énergie was able to circulate to all subsidiaries more than 20 lessons learned reports 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 reports produced by each terminal and comes with a lessons 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.

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.

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

• •internal inspection programmes for all liquefied gas and fuel bulk storage tanks, which are generally scheduled every 10 years;
• •installation and maintenance of safety equipment such as gauges, level alarms, fire defenses, 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;
• •systematic analysis and management of risks identified in the Material Safety Data Sheet (MSDS) and systematic training of staff on the handling of potentially hazardous products;
• •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 communications 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. Rubis Énergie 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), the Joint Inspection Group (JIG) and the International Air Transport Association (IATA), which are expert organisations in aviation refueling and provide general operational, training and safety support.

The Rubis Terminal JV’s Seveso-type 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 2021, 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 the extent possible.

Personal safety is a direct result of operational safety. Rubis is just as attentive to workplace safety (section 4.2.3.2.1) as it is to the safety of customers and local residents (section 4.2.3.2.2). 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 sick leave 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 far as possible, depending on local constraints.

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 particular tied to:

• •the intrinsic properties of products being handled (hazardous materials); and
• •transport (road safety): each year vehicles transporting products cover many kilometers.

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

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 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 issues.

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 also part of the training for all new hires.

Moreover, 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 to the extent possible the number of accidents likely to result in sick leave, with respect to both subsidiaries’ personnel and external service providers.

The Group pays close attention to risks linked to occupational illnesses 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 pandemics. Aware of the role that companies can play in preventing these health hazards, all subsidiaries have implemented measures to combat the Covid-19 pandemic. In addition, 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 4.3.3.2).

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 transportation 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. In 2021, 65% of drivers (83% of employee drivers and 58% 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).

Given the risks associated with its activities, the Group invests in training its employees on health, safety and environmental issues. Detailed data is presented section 4.3.2.

The number of workplace accidents recorded by the subsidiaries’ human resources departments (including the Rubis Terminal JV) decreased sharply compared with the previous year (35 in 2021, compared to 41 in 2020). 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 61% since 2015 at Rubis Énergie (9.9 in 2015, compared to 4 in 2021, per million hours worked) and by 50% at the Rubis Terminal JV (18.3 in 2015, compared to 9 in 2021).

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 is required by European regulations. In addition to the analysis of the change in frequency rate, the quality of reporting, which can lead to upward changes, is thus also a key indicator of safety culture.

Unfortunately, one fatal accident occurred in 2021, in Nigeria, where a driver was killed during the attempted theft of his truck.

Other occupational accidents leading to sick leave of more than one day resulted from slips and low-level falls, handling (LPG cylinders, in particular) or minor injuries (cuts, burns). Due to these minor accidents, the gravity rate (measured in terms of number of days of absence due to an occupational accident) of occupational accidents decreased in 2021 compared to 2020: 0.06 vs 0.10 (0.08 vs 0.12 if including the Rubis Terminal JV).

The absenteeism rate resulting from workplace accidents and illnesses is still very low across the Group as a whole, standing at 0.06% in 2021 (0.10% including the Rubis Terminal JV).

Monitoring of accidents occurring at Group sites and involving external providers has also been put in place: 20 accidents were reported by the subsidiaries in 2021 (compared to 32 in 2020). Unfortunately, two external providers died in 2021 at Rubis Énergie: one death involved an external driver in Haiti who was hit by two stray bullets during his delivery run and the other death involved an external provider who was carrying out repair work in the tank of a truck (explosion during soldering).

One occupational illness at the Rubis Terminal JV was reported in 2021. This resulted in an increase in the total percentage of absence, although the percentage of absence due to occupational accidents decreased by 23%.

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.

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:

• •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 4.2.1.2). 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.