This section includes Rubis’ CSR strategy, in line with the Non-Financial Information Statement (NFIS) requirements provided for by European Directive 2014/95/EU transposed by French Government Order 2017-1180 and implementing decree 2017-1265. This NFIS presents:

• •the main risks related to the Group’s activities(1);
• •the policies implemented to address those risks;
• •monitoring indicators and their results.

A diagram presenting the Group’s business model is available in chapter 1 of this document.

An independent player in the logistics and distribution of petroleum products operating in some 40 countries in Europe, the Caribbean and Africa, Rubis is structured around two divisions operated by Rubis Énergie:

• •Retail & Marketing of petroleum products (fuels, heating fuels, liquefied gases and bitumen);
• •Support & Services backing the distribution activity: trading-supply, shipping and refining.

In addition, Rubis Terminal JV carries out a bulk liquid Storage activity (petroleum and chemical products, biofuels, fertilisers, agri-food products) on behalf of diverse industrial customers.

Rubis’ development strategy is based on specialised market positioning, a robust financial structure and a dynamic acquisition policy. In addition to these commercial and financial elements, the development strategy also incorporates non-financial objectives that allow the Group to pursue sustainable growth. The regularity of the teams’ performance stems from a corporate culture that values entrepreneurial spirit, flexibility, accountability and the embracing of socially responsible conduct. Rubis conducts its activities by implementing a CSR approach that contributes to the United Nations’ Sustainable Development Goals (SDG).

In keeping with its motto: “The will to undertake, the corporate commitment”, Rubis puts human relationships at the heart of its organisation. Individually empowering men and women who contribute to its activities means promoting freedom of initiative and the ethical, social and environmental values that Rubis wishes to see respected by all.

The Group aims to act with professionalism and integrity across its entire scope. This requirement safeguards against any wrongdoing that could be prejudicial to the Group, employees, business relations or to any other external stakeholder, and is reflected in the following principles, detailed in the Rubis Group Code of Ethics (see section 4.5.1):

• •compliance with applicable legislation and regulations;
• •promotion of safety and respect for the environment;
• •respect for individuals;
• •rejection of all forms of corruption;
• •prevention of conflicts of interest and insider trading;
• •compliance with competition rules.

The CSR policy is driven by Rubis SCA’s Managing Director in charge of New Energies, CSR policy and Communication in conjunction with the Managing Partners. She is supported by the CSR & Compliance Department, which is responsible for proposing the CSR policy’s guidelines and leading the CSR approach in coordination with the various departments involved (Climate, HSE, Human Resources, Finance, Legal, and Social Engagement).

Since 2015, part of the Managing Partners' annual variable compensation has been linked to ethics, social and environmental criteria (see chapter 5, section 5.4.2). These criteria are also included in the framework letters that set out the annual objectives of Rubis Énergie’s Senior Managers.

A presentation of the initiatives taken and results obtained is made to the Supervisory Board’s Accounts and Risk Monitoring Committee each year.

The Rubis Terminal JV continues to implement the CSR policy it has defined to date, in line with Rubis’ general principles. In accordance with regulations, as a subsidiary that is 55% owned by Rubis SCA, the Rubis Terminal JV continues to report its annual CSR data to the Group so that they can be included in this Non-Financial Information Statement. However, as this entity is jointly controlled by Rubis SCA and its partner, the CSR policy is now steered and monitored by the joint venture’s Board of Directors, on which Rubis SCA is represented. The joint venture’s CSR objectives are adopted by its Board of Directors. As a shareholder, Rubis SCA ensures that the Rubis Terminal JV complies with CSR standards that are at least equivalent to its own.

Lastly, the Rubis SCA Accounts and Risk Monitoring Committee monitors the analysis of the Group’s main ethical, social and environmental risks and the corrective measures taken to prevent such risks (see chapter 5, section 5.3.2).

Since 2011, the year in which Rubis issued its first CSR report, the Group has been committed to a continuous improvement process in its approach to CSR.

The Group would like to accelerate its CSR trajectory and has taken numerous steps over the past few years to structure and consolidate the foundations of its CSR approach. In 2021, Rubis laid the groundwork for developing its objectives and fully incorporating CSR concerns into its activities, including in particular:

• •publishing its first CSR Roadmap, Think Tomorrow 2022-2025, which includes climate, social, environmental, compliance and societal issues structured around three pillars and 19 indicators (see inset below);
• •defining a clear climate strategy that is based on three pillars (see section 4.3);
• •membership of the United Nations’ Global Compact, reaffirming the Group's attachment to the 10 universally recognised principles regarding protecting human rights and the environment, complying with international labour standards and fighting against corruption;
• •membership of the Sea Cargo Charter, an initiative promoting responsible maritime transport, which is an essential step in the Group’s climate strategy to reduce the carbon footprint of chartered vessels;
• •strengthening our teams in order to guide the implementation of the CSR approach throughout the Group, with the appointment of a CSR point of contact in each business unit.

In September 2021, the Group published its first CSR Roadmap, Think Tomorrow 2022-2025.

By publishing this roadmap, Rubis is bolstering and steering its CSR strategy in line with the United Nations’ Sustainable Development Goals (SDGs). This roadmap was built around three pillars broken down into nine commitments:

• •pillar 1: reducing its environmental footprint;
• •pillar 2: offering a safe and stimulating working environment;
• •pillar 3: contributing to a more virtuous society.

These commitments are combined with 19 objectives and indicators, such as:

• •reducing CO2 emissions resulting from operations: -30% by 2030 (2019 baseline) in scopes 1 and 2 (Rubis Énergie scope, representing 100% of the Group’s consolidated revenues), an objective that was revised upwards compared to the objective communicated previously (-20 % announced in June 2021, same scope) and which will be supplemented by additional objectives such as setting a target for the reduction of scope 3A CO2 emissions in 2022;
• •reducing the number of accidental spills in excess of 200 liters of products with an impact on the environment (number of spills in 2025 < than that of 2020, i.e. 20);
• •reducing occupational accidents with sick leave involving employees and service providers working at our facilities in 2025; frequency rate < 4.5 for employees and a lower number of accidents with sick leave involving service providers;
• •increasing the number of women in senior management: 30% women on average in Management Committees by 2025;
• •training employees about business integrity: 100% of employees trained in ethics and anticorruption by 2023.

Comprehensive information about this roadmap (which has been rolled out in the subsidiaries, which adapt the roadmap according to their local concerns) is available on our website at: https://www.rubis.fr/uploads/attachments/Rubis_CSR%20roadmap_2022_2025-EN.pdf 

Rubis SCA wishes to continue its transparency efforts and to interact more proactively with non-financial rating agencies. In 2021, Rubis’ efforts were recognised by, in particular:

• •MSCI, which renewed Rubis AA rating and positions the Group in the top 7% of its sector;
• •CDP, which awarded Rubis a B score for the Group’s first response to CDP’s Climate Change questionnaire. 
  This places Rubisamong the 25%of companies ranked in the Oil & Gas sector with a score of B or above.
•  

In accordance with Articles L. 225-102-1 and R. 225-105 of the amended French Commercial Code, Rubis has conducted a three-stage analysis of its main non-financial risks (section 4.1.2.1), which identified 15 main risks grouped around five priority issues (section 4.1.2.2).

Risk maps are prepared by the Group’s functional departments (CSR, HSE, Operations, Finance, Legal, etc.) and are completed locally by the operating subsidiaries. They are analysed on a consolidated basis and are then reported to Rubis SCA’s Managing Partners and presented to the Accounts and Risk Monitoring Committee. Risk mapping makes it possible to assess (impact and probability) the events that are likely to have a significant adverse impact on the Group’s business, financial situation, reputation or outlook on a scale of 1 to 5. These risk maps are updated annually in view of changes in the Group’s business lines and facilities and the observations made by employees, stakeholders and the Accounts and Risk Monitoring Committee (see chapter 3, section 3.2.3.2). This process is part of a co-building approach that aims to reach a shared assessment.

In addition to analysing pre-existing risk maps, Rubis’ CSR teams use work carried out by other companies and trade organisations to verify the consistency of the risk items identified in their risk mapping (stage one) and to add to the risk map if necessary.

Existing frameworks (the SASB Materiality Map® in particular), sector benchmarks (IPIECA) or those of trade organisations/associations (Medef, ORSE, C3D) and CSR publications from other companies were used to assess the most material risks in view of the business sector. The concerns voiced by stakeholders (investors, ESG analysts, civil society) are tracked using a monitoring system put in place by the Group. The results make it possible to weight the risk analysis and account for the importance of these risks to such stakeholders and to identify weak signals and key trends with respect to the principal areas the Group is expected to act on. 

The consolidated result of risk mapping revised in view of the benchmark described above was presented to HSE Managers (environmental and safety components) and to officers responsible for social issues (personal safety and HR) for review and validation from a non-financial perspective. This review was the subject of regular meetings and discussions with Rubis SCA’s CSR & Compliance Department.

The result of this risk analysis was approved by Rubis Énergie’s General Management and then by Rubis SCA’s Managing Partners and the Accounts and Risk Monitoring Committee.

The Rubis Terminal JV has followed the same risk assessment process, which was validated by its General Management. At this stage, the completion of the sale of 45% of the capital of the storage activity to an infrastructure fund in 2020 is unlikely to jeopardise the analysis of CSR risks relating to the joint venture, whose business remains unchanged. The periodic review of this analysis is now presented by the joint venture to its shareholders at meetings of its Board of Directors, which will validate the objectives.

The analysis of CSR risks highlights 15 main risks relating to the Retail & Marketing and Support & Services activities (Rubis Énergie) and the Rubis Terminal JV(2). These risks are grouped around the following five challenges:

• •limiting the environmental impact of activities;
• •protecting the health and safety of people working on-site and of local residents, and facility security;
• •fighting against climate change;
• •attracting, developing and retaining talents;
• •business ethics demonstrated by operating responsibly and with integrity.

Appropriate procedures are implemented to address the issues identified in the risk analysis.

Health and safety risks for individuals working at the sites and for local residents and the risks relating to the activities’ environmental impact are subject to enhanced preventive measures, which are carried out in the framework of regular inspection programmes and major investments (see section 4.2).

In line with the Group’s values, social risks are managed in a decentralised way to make the most of human capital and to take into account the specific nature of the Group’s activities. In addition to workplace health and safety, which as an industrial group are Rubis’ priorities, the issues of well-being at work, equal opportunities in the workplace and the sharing the Group’s growth with employees are carefully monitored (see section 4.3).

Other issues, such as ethics and corruption risks, are also subject to specific policies and procedures drawn up as part of the continuous improvement process (see section 4.5).

Details about the main risks relating to the Non-Financial Information Statement and on the related policies and indicators appear in sections 4.2 to 4.5 of this document. The main risks are identified using the following pictogram: /NFIS/ Other challenges, which were not identified as priority risks in the risk analysis but that are nevertheless considered as important for both the Group and its stakeholders or that must be disclosed in accordance with current regulations, are also included in sections 4.2 to 4.5.

The Rubis Terminal JV’s risk prevention policy, which has been in place for many years, was developed in line with Rubis Group standards. Now a co-shareholder of this joint venture, Rubis SCA representatives on the JV’s Board of Directors continue to promote Rubis’ standards vis a vis the partner and to monitor the joint venture’s efforts and performance.

The comparability and reliability of information primarily results from the standardisation of methods used for reporting employee-related and environmental data, as described in the methodology note (see section 4.6).

The reported information is checked using verification procedures and analyses. Internal audits relating to certain non-financial information (ethics, anticorruption) are also carried out.

A cross-reference table listing the provisions of the French Commercial Code is provided in section 4.6.4 in order to facilitate the reading of this chapter.