4.6Methodology note /NFIS/
This section contains a description of methodology and a cross-reference table designed to facilitate understanding of CSR information. Accordingly, it was decided to present the scope and methods for reporting CSR information and the key definitions contained in the internal standards on reporting labour and environmental information. These clarifications will enable the reader to have a more precise understanding of each information item’s scope and relevance.
4.6.1CSR scope
The rules relating to an entity’s date of inclusion within and exit from the CSR scope are defined as follows:
- •any acquisition of an entity (external to the Group) is included in the CSR reporting scope starting the first full financial year occurring after the entity is included in the financial scope, at the earliest. This rule allows HR processes, safety standards and Group commitments to be better integrated within the acquired entity, along with the corresponding monitoring indicators;
- •unless otherwise indicated, the CSR data of an entity that was sold or liquidated during the financial year is excluded from CSR reporting for the entire fiscal year in which it was sold or liquidated.
4.6.1.1Environmental data
The reporting scope for environmental information corresponds to the Group’s financial scope unless expressly stated otherwise. Controlled companies are fully consolidated, with the exception of data relating to the greenhouse gases emissions (see below).
Environmental data for the Rubis Terminal JV, which is jointly controlled by Rubis SCA and its partner and accounted for using the equity method, are presented both at 100% and in accordance with the percentage of capital held by Rubis SCA (55%).
The exact scope of reporting of environmental data may vary according to the environmental indicators, depending on their relevance and the accounting methods applied. The environmental data is collected at the legal entity level.
Environmental data is published by activity. Figures are published for the activities that have the most significant environmental impacts (Support & Services activities at Rubis Énergie and the activities of the Rubis Terminal JV).
The greenhouse gases emissions from the Group’s activities and the greenhouse gases emissions related to the use by customers of products sold for final use have been evaluated and are published for all the entities in the financial scope of consolidation, with the exception of Rubis SCA/Rubis Patrimoine due to their immaterial impact (24 employees, no operating activity). In accordance with the principles of the GHG Protocol, this data is proportionally consolidated by applying the percentage of the stake held.
4.6.1.2Social data
Unless expressly stated otherwise, the reporting scope for social information corresponds to the Group’s financial scope of consolidation. Controlled companies are fully consolidated.
Social data regarding the Rubis Terminal JV, which is jointly controlled by Rubis SCA and its partner and accounted for using the equity method, are presented at the rate of 100%.
The information for Rubis SCA/Rubis Patrimoine, Rubis Énergie (Retail & Marketing and Support & Services activities) and the Rubis Terminal JV is presented separately and/or by region.
The exact scope of social data reporting may vary according to the social indicators, depending on their relevance and the accounting methods applied. Social data is collected at the legal entity level.
Moreover, the shipping activity requires the use of crews hired under temporary contracts. These non-permanent employees of the Group (84 individuals in 2021) are not taken into account when monitoring published social indicators.
4.6.1.3Societal/ethics data
The reporting scope for societal and ethics information corresponds to the Group’s financial scope of consolidation. The applicable reporting method is proportional consolidation (percentage of stake held). The societal/ethics data are collected at the business unit level.
4.6.2Data reporting methods
The production of CSR information is carried out jointly by the subsidiaries and the Group’s parent company and is subject to systematic internal audits.
For several years now, the Group has used a risk mapping process to identify significant risks. This identification process and risk management and monitoring arrangements are described in chapters 3 and 4 of this Universal Registration Document.
4.6.2.1Comparability and reliability of information
Reporting protocols have been designed to ensure the comparability of results between Group entities. However, environmental performance is only comparable at the level of a given activity.
As the strength of the Group’s business has resulted in significant external growth, the CSR reporting scope also changes on a regular basis, and therefore does not, in the absence of ratios, allow for true comparability of data across several financial years.
A set of reporting standards for environmental and labour-related information was defined by management in partnership with the relevant subsidiaries. These standards provide a precise definition for each data item referred to in the information reporting protocols with the aim of reducing the risk that concepts will be interpreted differently.
4.6.2.2Control measures
The collected data is subject to consistency checks at the local level and then by the functional departments of Rubis Énergie or the Rubis Terminal JV and by Rubis SCA’s CSR & Compliance Department. Consistency between the financial scope of consolidation and the labour data reporting scope is ensured by Rubis SCA’s CSR & Compliance Department.
4.6.2.3Changes in methodology
Unless otherwise provided, the methodology cannot be changed after the information reporting process within Group entities has begun. Changes in methodology are prepared and/or overseen by Rubis SCA’s CSR & Compliance Department after consultation with Rubis Énergie and the Rubis Terminal JV. As appropriate, changes take into account observations made by stakeholders about the relevance and quality of the definitions contained in the framework.
4.6.2.4Methodological limitations
- •a lack of harmony in national laws, and in particular the specificities of Labour laws in certain countries;
- •the heterogeneity of the data managed within the Group’s subsidiaries;
- •changes in definition that may affect their comparability;
- •practical arrangements for collecting data;
- •the availability of source data as of the reporting date.
Some indicators should be interpreted with caution, particularly averages, since they consist of world-wide data that requires a more detailed analysis at the level of the relevant geographical areas, countries and trades.
4.6.2.5Data reporting tools
With the exceptions mentioned below, the operating entities report data using the reporting software put in place by the Group in 2020.
Environmental data
Because the Group’s various activities have environmental impacts that are specific to such activities (see section 4.2.1), data calculation methods may vary depending on the activity. However, the definitions are standardised at the level of each division, within a “standard for reporting environmental data” that has been incorporated into the Group’s CSR data reporting software.
Rubis Énergie’s data is reported by the entities into the reporting software, with the exception of (i) data from the SARA (refinery), which is the subject of a specific report issued by SARA’s HSE teams, and (ii) data relating to the number of Seveso sites, which are submitted by headquarters on a consolidated basis.
Data from entities within the scope of the Rubis Terminal JV are reported on a consolidated basis by the Rubis Terminal JV’s Operations Department for inclusion in the Group’s reporting software.
Social data
For all entities, the social data reporting protocols include similar information based on standardised definitions set out in the “standard for reporting social data” that has been incorporated into the Group’s CSR data reporting software.
Societal/ethics data
Societal/ethics data are reported using the reporting software on the basis of standardised definitions that apply to all entities and that are partly produced by Rubis SCA (Group ethics policy). Regarding charitable and sponsorship initiatives, dialogue with stakeholders and commitment to local areas, the information collected may come from public communications by subsidiaries and/or a societal information reporting protocol at Rubis Terminal.
4.6.3Definitions
Concepts |
Definitions |
|---|---|
1) Environmental information |
|
Volatile organic compounds (VOC) |
Rubis Énergie Consolidated VOC emissions correspond to the values reported during the financial year (with a one-year lag) with respect to all French sites that are subject to reporting obligations under applicable regulations. In the refining activity, measurements of VOC emissions are the subject of a biennial sniffing campaign conducted by an accredited independent body. Rubis Terminal JV Consolidated VOC emissions correspond to the values reported during the financial year (with a one-year lag) with respect to all French sites and at the Antwerp, Rotterdam and Dörtyol (Turkey) sites. |
Energy consumption |
There is no mandatory legal definition for this issue. Rubis Énergie Rubis Énergie’s distribution activities are for the most part not energy intense. They therefore are not such as to justify that a comprehensive measuring system be set up at the division level. In the refining activity, the refinery uses part of the crude oil it stores to produce energy (electricity and steam). An internal database monitors the site’s real-time power generation and consumption. Rubis Terminal JV The data represents the sum of the quantities of automotive or heating fuels or electricity purchased, converted into GJ, with the exception of fuel used by administrative staff (headquarters and site management) for transportation. |
Hazardous waste |
Rubis Énergie Most or Rubis Énergie’s distribution activities do not produce hazardous waste. The activities are not of a nature that justifies that a comprehensive measurement system be set up at the division level. In the refining activity, waste amounts to the values reported during the financial year (time lag of one year). Rubis Terminal JV Waste amounts to the values reported during the financial year (with a one-year lag) at all French sites and at the Antwerp, Rotterdam and Dörtyol (Turkey) sites. |
Sulfur dioxide (SO2) |
SO2 emissions are assessed in the context of Rubis Énergie’s refining activity. These emissions are evaluated by the refinery’s Production Technical Office using a spreadsheet. The flow of SO2 is calculated based on the fuel supply (based on the reconciled materials balance) and the sulfur content of the fuels analysed by the refinery’s laboratory. SO2 concentration is deduced on the basis of the gas volume calculated using the net calorific value (NCV) of each fuel. The calculation is verified annually by an accredited independent body. |
Water used |
This is standing water (e.g., reservoirs and lakes) or running water (e.g., rivers) located above ground, sea water, rainwater, underground water and water from the distribution network that was used in the activities of the Group entity. Discharged water is abstracted water, plus some rainwater. Rubis Énergie Most of Rubis Énergie’s distribution operations do not require recurrent use of large quantities of water as part of an industrial process. In the refining activity, water consumption is measured based on meter readings. The volume of water discharged corresponds to the value recorded by the meter at wastewater treatment exits. Rubis Terminal JV The quanities of water abstracted or discharged are those reported during the financial year (with a one-year lag) at all French sites and at the Antwerp, Rotterdam and Dörtyol (Turkey) sites. |
Greenhouse gases (emissions) |
Only carbon dioxide (CO2) is assessed, as according to our estimates, Group activities do not involve other greenhouse gases, including methane (Annex II of Directive 2003/87/EC). The CO2 emissions led to a Bilan Carbone® audit being conducted, the scope of which is detailed in the definitions of “Scope 1”, “Scope 2” and “Scope 3”. |
Suspended solids |
These are particles that are suspended in water, the nature of which depends on the activities carried out on the polluted site. Rubis Énergie Rubis Énergie’s regular activities generate little water pollution. In the refining activity, suspended solids are analysed and evaluated by the refinery’s laboratory and then audited by a qualified independent body. Rubis Terminal JV Given the very broad scope of particles that may fall within the definition of suspended solids, Rubis Terminal retains only the compounds that are the most representative of the pollution that may be produced by its main activities. Values from the French sites are the only values reported to authorities; in other places, the values are those established for Group reporting. |
Nitrogen oxides (NOx) |
Rubis Énergie In the refining activity, NOx emissions are assessed by the refinery’s Production Technical Office using a spreadsheet. This is an estimate based on the emission factor of each fuel and the operating time of DeNOx from combustion turbines. This calculation is audited annually by a qualified independent body. Rubis Terminal JV NOx is calculated based on consumption of combustibles or fuels (excluding electricity) over the financial year. The fuel used by administrative staff (headquarters and site management) when traveling is not taken into account. Concentrations of NOx in fumes are considered in the calculation as being equal to the highest permitted level of emissions or, in the absence of a limit, 150, 200, 300 or 550 mg/Nm3 for boilers, depending on the fuel used, or 2 g/kWh for engines, in the absence of representative measurements. |
Industrial sites |
Rubis Énergie The following are considered to be industrial sites: the refinery; storage sites (depots) for liquefied gases, petroleum products, or bitumen with a storage capacity > 50 tonnes of liquefied gas and/or 500m3 of petroleum products/bitumen; a liquefied gas cylinder filling plant with a storage capacity > 50 tonnes. Rubis Terminal JV Storage sites for fuels and combustibles, chemical products, bitumen, food products and liquid fertilisers. |
Scope 1 |
Direct emissions from fixed and mobile facilities within the organisational scope, i.e., emissions from sources held or controlled by the organisation, such as combustion generated by owned industrial facilities or trucks, industrial processes, etc. |
Scope 2 |
Indirect emissions tied to the generation of electricity, heat or steam purchased for the organisation’s activities. These emissions are calculated using the location based methodology, i.e., by taking the country’s emissions factor into account. |
Scope 3 |
Other emissions indirectly caused by the organisation’s activities that are not accounted for under scope 2 but are linked to the entire value chain, such as, for example, the purchase of raw materials, services or other products, employee travel, upstream and downstream transportation of merchandise, management of waste generated by the organisation’s activities, use and end of life of products and services sold, capitalisation of goods and production equipment, etc. The following items are included in scope 3 of Rubis’ Bilan Carbone®: purchases of goods and services, fixed assets, upstream energy, upstream and downstream transportation of goods, waste generated, use of products sold. For purchases of goods and services for investments, the Rubis Terminal JV has counted the annual depreciation of this value in 2020 and not the values purchased. Certain items were excluded from Rubis’ Bilan Carbone®, as these emissions represent less than 5% of scope 3 GHG emissions and are therefore not material to the Group. The emissions principally relate to depreciation of trucks and buildings. |
2) Social information |
|
Occupational accidents |
An accident affecting an employee of a Group entity, where a medical certificate or investigative findings establish that the accident was directly caused by the employee’s work at the entity at issue and which leads to medical leave (total or partial). Note:
|
Job categories |
To enable global harmonisation of reporting, employees were distinguished as follows: Non-managerial staff: non-executive and non-senior executives employees. Managerial staff: employees:
Senior executives: senior executives are executives belonging to the General Management or members of the Rubis Énergie or Rubis Terminal Management Committee, Directors of subsidiaries and site Managers and the executives that report directly to them. |
Management Committee |
A Management Committee is a Committee composed of the main Directors or Managers of a Group entity who meet regularly to make strategic decisions and monitor the entity’s results. |
Apprenticeship contract or occupational training contract |
A contract between a person pursuing an academic training course (at university or in a training centre) and a Group entity (in principle, for a fixed term of six months or more (except where an is exception provided for in the applicable legislation)) that entitles such person to call themselves an employee of the signatory company. |
Unilateral decision |
A decision taken unilaterally by the Management of the Group entity in question after discussion with the employee representatives (as applicable). |
Crews |
Persons employed under temporary contracts to work onboard vessels owned by the Group. The social indicators relating to permanent employees do not include these non-permanent workers, for which separate monitoring is more relevant. |
Number of days worked per year |
The total number of working days per year, which is used as the basis for calculating absenteeism rates, results from the conversion of an average number of hours worked each day that may vary slightly from one subsidiary to another, taking into account applicable laws and the nature of the activities carried out locally. |
Number of hours worked per year |
The number of hours worked per year may be calculated based on a daily average established under prevailing law. |
Departure by mutual agreement |
The departure of an employee of a Group entity (including those on trial periods) that results from an amicable agreement between the two parties and that was not imposed by one of the parties on the other. Accordingly, departures by mutual agreement are not considered as dismissals or resignations under the applicable legislation. |
Employees |
This category includes:
This category does not include:
Expatriate employees, seconded employees and employees who are part of an intra-group mobility programme should be accounted for in the entity for which they effectively and usually work. |
Absenteeism rate |
Percentage of days of absence (absences not due to occupational illness or non-workplace accidents, absence due to occupational illness or workplace accidents, unjustified absences) in relation to the total number of days worked per year. |
4.6.4Cross-reference table
The information contained in this chapter was compiled in order to respond to the provisions of European Directive 2014/95/EU on the disclosure of social and environmental information transposed in Articles L. 225-102-1, R. 225-105 and R. 225-105-1 of the French Commercial Code.
The indicators presented in this chapter have been addressed and included in view of their relevance to the Group’s businesses.
Topics |
Chapters or section |
|
|---|---|---|
Business model |
1 |
|
Overview of the main non-financial risks relating to the Company’s activity |
4.1.2.2 |
|
Description of policies and results
|
4.2 4.4 |
|
Respect for human rights |
4.5.1.1 |
|
Fighting corruption |
4.5.1.1 |
|
Fighting tax evasion |
4.5.1.1 |
|
Climate change, use of goods and services |
4.3 |
|
Societal commitments
|
4.5.2 4.2.2.3 Not included Not included Not included Not included Not included 4.4.3.2 4.4.1 4.4.1.4 |
Given the nature of its activities, Rubis does not believe that these topics constitute a material risk and that there is any need to expand on them in this document |
Specific information (Article L. 225-102-2 of the French Commercial Code)
|
3.1.2.1 and 4.2.3 3.3.1.2
3.3.1.2 |
|
Methodology note |
4.6 |
|
Report of the independent third party on the information presented in the NFIS |
4.7 |
|