4.6 Methodology 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.

4.6.1 CSR 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, Group commitments and the corresponding monitoring indicators to be better integrated. Thus, for the financial year 2022, Rubis Photosol is not included in the NFIS except for data relating to the workforce and some qualitative information on the Group’s climate strategy;

•   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 financial year in which it was sold or liquidated.

In January 2022, the activities of the Rubis Terminal JV in Turkey were sold. The quantities presented for year Y and the comments on changes include this change in scope. In the tables, the reference quantities for Y-1 remain identical to those reported in 2021 without change of scope.    Environmental data

Unless expressly stated otherwise, the reporting scope for environmental information corresponds to the Group’s financial scope of consolidation. Controlled companies are fully consolidated, with the exception of data relating to greenhouse gas 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 gas emissions from the Group’s activities and the greenhouse gas 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 (25 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.    Social 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), Rubis Photosol 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. The breakdown of the workforce by age, job category and work time covers 99.98% of the workforce; four entities, due to a small workforce (three or less employees) representing a total of eight employees, are not included.

In addition, the shipping activity requires the use of crews hired on temporary contracts (with a Group entity or on an interim basis). These non-permanent employees of the Group (224 individuals in 2022) are not taken into account when monitoring published social indicators.    Societal/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.

4.6.2 Data reporting methods

The production of CSR information is carried out jointly by the subsidiaries and the Group’s parent company. It 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.    Comparability 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.    Control measures

The data collected is checked for consistency at the local level, then by the functional departments of Rubis Énergie or the Rubis Terminal JV and by the Group CSR & Compliance Department. Consistency between the financial scope and that of the social data is ensured by the Group CSR & Compliance Department.    Changes 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 the Group CSR & Compliance Department after consultation with Rubis Énergie and the Rubis Terminal JV. They take into account, where applicable, comments and observations made by stakeholders on the relevance and quality of the definitions used in the reference system.    Methodological limitations

It is important to note that the indicators may have methodological limitations due to:

•   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 worldwide data that requires a more detailed analysis at the level of the relevant geographical areas, countries and business lines.    Data reporting tools

Data are reported by the operating entities within the scope of consolidation via the reporting software implemented by the Group in 2020, unless otherwise specified below.


Because the Group’s various activities have environmental impacts that are specific to such activities (see section 4.2.2), 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 in the reporting software, with the exception of (i) data from 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.


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 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 social engagement initiatives, as well as 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 for the Rubis Terminal JV.

4.6.3 Definitions

(in alphabetical order)
1) Environmental information
Energy consumption  

There is no mandatory legal definition for this issue.

Rubis Énergie

The Retail & Marketing activities are for the most part not energy intense. They are not therefore such as to justify that an overall 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 represent 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 transport.

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 carbon footprint assessment audit being conducted, the scope of which is detailed in the definitions of “Scope 1”, “Scope 2” and “Scope 3”.
Hazardous waste  

Rubis Énergie

Most Retail & Marketing activities do not produce hazardous waste. The activities are not of a nature that justifies that an overall measuring 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 (one-year lag) for all sites.

Industrial sites  

Rubis Énergie

The following are considered to be industrial sites: the refinery; any storage sites (depots) for liquefied gas, petroleum products, or bitumen with a storage capacity > 50 tonnes of liquefied gas and/or 500 m3 of petroleum   products/bitumen; any 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.

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 travelling 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.

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 linked 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, for example, the purchase of raw materials, services or other products, employee travel, upstream and downstream transport 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’ carbon footprint assessment: purchases of goods and   services, fixed assets, upstream energy, upstream and downstream transport of merchandise, waste generated, use of products sold. For purchases of goods and services for capital expenditures, 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’ carbon footprint assessment, 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.

Scope 3A   All indirect emissions induced upstream as a result of the Company’s activities for its production and marketing of products (e.g., employee travel, logistics, end-of-life of products, etc.), excluding products sold (see definition of scope 3B).
Scope 3B   Indirect emissions induced downstream by the products and/or services sold by the Company when they are   used by customers (category 11).
Sulphur dioxide (SO2)   SO2emissions are assessed in the refining activity. These emissions are evaluated by the refinery’s ProductionTechnical Office using a spreadsheet. The flow of SO2 is calculated based on the fuel supply (based on the reconciled materials balance) and the sulphur 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. This calculation method is audited annually by a qualified independent body.
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

Regular Retail & Marketing 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, the Rubis Terminal JV 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.

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 (one-year lag) for all sites.

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 the Retail & Marketing 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 quantities of water withdrawn or discharged are the values declared during the financial year (one-year lag) for all sites.

2) Social information
Absenteeism rate   Percentage of days of absence (absences due to non-occupational illness or occupational illness or occupational   accidents or unjustified absences) in relation to the total number of days worked per year.
Apprenticeship contract
or occupational training
  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 exception is provided for in the applicable legislation)) that entitles such person to call themselves an employee of the signatory company.
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.
Departure by mutual  
  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.

This category includes:

  full-time or part-time contracts, whether or not the work is performed in shifts;

   apprenticeship contracts and occupational training contracts (in countries where this legislation applies).

This category does not include:

   internship contracts;

   external service providers working for Group entities that have not signed an employment contract with the entity in question;

   temporary staff who are the employees of an external service provider (temporary staffing company) notwithstanding the fact that they work on a Group entity’s site.

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.


To enable global harmonisation of reporting, employees were distinguished as follows:


non-executive and non-senior executive employees.

Executives: employees:

   with managerial duties and responsibilities, without being part of the General Management or a member of the Management Committee, or being a site Manager; or

   with the status of cadre under French law.

Senior executives: senior executives are executives belonging to the General Management or members of the Rubis Énergie or Rubis Terminal JV Management Committee, Directors of subsidiaries and site Managers and the executives that report directly to them.

  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.
Number of days  
worked per year
  The total number of days worked 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.
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).
Unilateral decision   A decision taken unilaterally by the Management of the Group entity in question after discussion with the employee representatives (as applicable).

4.6.4 Cross-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    

Description of policies and results

   environment (general policy, pollution, circular economy, safety)

   social (employment, equal treatment,
work organisation, training, health
and safety, social dialogue)





Respect for human rights    
Fighting corruption    
Fighting tax evasion    
Climate change, use of goods and services   4.3    

Societal commitments

   sustainable development

   circular economy

   food waste

   fighting food insecurity

   respect for animal welfare

   responsible, fair and sustainable food

   actions aimed at promoting the practice of physical and athletic activities

   collective agreements and impacts

   fighting against discrimination and promoting diversity

   measures to support disabled people




Not included

Not included

Not included

Not included

Not included


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)

   technological accident risk prevention policy implemented by the Company

   ability of the Company to cover its civil liability in respect of property and persons due to the operation of such facilities

   means provided by the Company to manage the compensation of victims in the event of a technological accident involving its liability and 4.2.3

Methodology note   4.6    
Report of the independent third party on the information presented in the NFIS   4.7