4.1 Non-Financial Information Statement / NFIS /

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.

4.1.1 A model for sustainable growth

A diagram presenting the Group’s business model is available in chapter 1 of this document on pages 16-17.   Activities structured around three businesses and one joint venture

As an independent player in the energy sector, present in around 40 countries in Europe, the Caribbean and Africa, Rubis is structured around three businesses:

•   two operated by Rubis Énergie:

•   Retail & Marketing of fuels, liquefied gas and bitumen,

•   Support & Services, supporting the Retail & Marketing activity: trading-supply, shipping and refining;

•   a new Renewable Electricity Production division created in 2022, Rubis Renouvelables, including:

•   Rubis Photosol, one of the leading independent producers of photovoltaic electricity in France,

•   the acquisition of an 18.5% stake in the capital of HDF Energy, a global pioneer in hydrogen electricity.

In addition, the Rubis Terminal JV carries out a Bulk Liquid Storage activity (petroleum and chemical products, biofuels, fertilisers, agrifood products) on behalf of diverse industrial customers.

(1) Including, for this Non-Financial Information Statement, the activities of the Rubis Terminal JV, in which Rubis SCA holds a 55% stake and over which it lost exclusive control on 30 April 2020.

Details of the scope of the NFIS

Exclusion of Rubis Photosol for financial year 2022

In accordance with the rules defined by Rubis, any acquisition of an entity (change in scope) is gradually taken into account in the CSR scope and not before the first full financial year occurring after the date of integration of the entity in the financial scope. For the sake of consistency with the financial scope, it was decided to exceptionally take into account social data (excluding training data) from the financial year 2022. The other CSR stakes require an analysis of the risks and opportunities, the definition of policies to address them and associated objectives during the financial year 2023, as this is a new activity for the Group. For further information, please refer to the methodological note in section 4.6 of this chapter.

In accordance with the EU Taxonomy Regulation 2020/852, Rubis Photosol has been included in the 2022 taxonomy indicators since its consolidation in the financial scope, i.e., 1st April 2022.

Contribution of the Rubis Terminal JV

In accordance with the applicable regulations (Article L. 225-102-1 of the French Commercial Code), the activities of the Rubis Terminal JV, which Rubis SCA holds at 55% and over which it lost exclusive control on 30 April 2020, are included in this Non-Financial Information Statement. The Rubis Terminal JV data are presented as follows: environmental data presented at 100% and Group share (55%); greenhouse gas emissions at 55% in accordance with official methodologies; social/health and safety data at 100%, societal data at 100%. For further information, please refer to the methodological note in section 4.6 of this chapter.

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 (SDGs).   Empowerment and freedom of initiative: people at the heart of the organisation

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 company, 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.    Strengthened CSR governance thanks to committed management that is aware of ethics, social and environmental risks

The CSR policy is driven by Rubis SCA’s Managing Director in charge of New Energies, CSR and Communication in conjunction with the Management Board. She is supported by the Group CSR & Compliance Department, which is responsible for proposing the CSR policy’s guidelines and driving the 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.

In 2022, Rubis continued to expand its CSR teams, both at Group level and in Rubis Énergie’s CSR & Climate Department. A network of 35 CSR Advisors throughout the subsidiaries has been set up to ensure the deployment of Rubis’ CSR approach in all entities.

Rubis Photosol created the position of CSR Manager in January 2023, whose mission is to roll out and adapt the Group’s CSR strategy to this new photovoltaic electricity activity.



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 ethics, social and environmental risks and the corrective measures taken to prevent such risks (see chapter 5, section 5.3.2).   A continuous improvement approach

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.



2022 was an opportunity for the Rubis Group to consolidate the implementation of its new CSR approach. Initiated in 2021, with the publication of the CSR Roadmap Think Tomorrow 2022-2025, the Group actively continued to roll out its commitments, in particular with:

•   the acceleration of investments in renewable energies, with the completion of the acquisition of an 80% stake in Photosol;

•   the conclusions of the assessment mission on the decarbonisation of activities, making it possible to identify operational actions to achieve the climate strategy defined in 2021;;

•   continued strengthening of teams to accelerate the implementation of the CSR approach;

•   the launch of a biodiversity project, with the initial assessment of the biodiversity footprint of the main Rubis Énergie business units;

•   the organisation of a CSR seminar bringing together nearly 80 participants over three days, in particular all of the CSR Advisors as well as the General Managers of the subsidiaries;

•   the preparation of a human rights risk mapping.


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

With this roadmap, Rubis is bolstering and steering its CSR strategy in line with the United Nations’ Sustainable Development Goals (SDGs). It is built around three areas broken down into nine commitments presented in the NFIS risk table in section of this chapter:

•   pillar 1: reducing our environmental footprint;

•   pillar 2: providing 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), an objective that was revised upwards compared to the objective communicated previously (-20% initially announced in June 2021, same scope). An additional target of a 20% reduction in scope 3A CO2 emissions by 2030 (2019 baseline) (Rubis Énergie scope, mainly outsourced maritime and road transport items, i.e., 45% of scope 3A) was defined in 2022;

•   reducing the number of accidental spills in excess of 200 litres of products with an impact on the environment (number of spills in 2025 < than that of 2020, i.e., 20);

•   continuously reducing occupational accidents with lost time for employees and service providers at our facilities: until 2025, frequency rate < 4.5 for employees, and number of accidents with lost time decreasing for service providers and achieving the objective of “zero fatal accidents” each year;

•   increasing the number of women in senior management: 30% women on average in Management Committees by 2025;

•   raising awareness of employees about business integrity: 100% of employees to improve their awareness of ethics and anti-corruption rules in 2023.

Comprehensive information about this roadmap (which has been rolled out in the subsidiaries, which adapt the roadmap according to their local challenges) 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 2022, Rubis’ efforts were recognised by, in particular:

•   MSCI, which renewed Rubis’ AA rating;

•   CDP, which awarded Rubis a B rating on the Climate Change questionnaire.



Rubis’ approach, as well as the associated objectives and actions, are in line with the 17 UN Sustainable Development Goals (SDGs), some of which relate more directly to the Group’s activities through their positive contributions:


4.1.2 The main CSR risks associated with the Group’s activities

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, which identified 15 main risks grouped around five priority challenges (section   A three-step risk analysis


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 operations and the observations made by employees, stakeholders and the Accounts and Risk Monitoring Committee (see chapter 3, section 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 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 segment. 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 its stakeholders and to identify weak signals and key challenges with respect to the principal areas the Group is expected to act on.



Regular dialogue with communities

Committed to local populations, the Group values dialogue with its stakeholders and promotes dynamic activity in the regions where it operates, both on an economic and employment level and on the issue of “living as a community.”

Depending on the status or mission of these stakeholders, dialogue with stakeholders takes place at the local level (subsidiary), at the level of entire divisions or directly by the parent company (Rubis SCA) (see section

Rubis is also committed through an active and targeted social engagement policy, via its artistic endowment fund Rubis Mécénat and its community investment with subsidiaries, mainly focused on education and health (see section


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 the Group CSR & Compliance Department.

The result of this risk analysis was approved by Rubis Énergie’s General Management and then by Rubis SCA’s Management Board 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 Rubis Terminal JV to its shareholders at meetings of its Board of Directors, which validates the objectives.

Rubis Photosol, which is outside the scope of the NFIS for financial year 2022 due to its joining the scope of the Group during the financial year, will formalise an analysis of its non-financial risks in 2023.   Fifteen risks grouped around five key challenges

The analysis of CSR risks highlights 15 main risks relating to the Retail & Marketing and Support & Services activities of Rubis Énergie, and the Rubis Terminal JV*. The Photovoltaic Electricity Production activity (Rubis Photosol) was integrated into Rubis during the financial year 2022. Given the specific nature of this activity requiring dedicated risk analyses and the implementation of related management measures, this activity is not therefore included in the scope of the NFIS for the financial year 2022. It will be included from financial year 2023.

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.

Limiting our environmental impact   Water and soil pollution   Number of accidental spills reaching the environment > 200 litres   By 2025, reduce the number of accidental spills reaching the natural environment > 200 litres to less than 20 (2020 baseline)   Rubis Énergie   14   23   Reduce accidental product spills
      0 accidental leaks, excluding containment, in accordance with the GHS leak classification system(2)   Rubis Terminal JV   0   1    
  Emissions   Emissions from major industrial sites (NOx, VOC, SO2)   Vapour recovery devices; installation of floating screens on storage tanks   Rubis Énergie Rubis Terminal JV   NOx
Rubis Énergie (refining): 181 tonnes

Rubis Terminal JV –
Group share: 2.75 tonnes
Rubis Énergie (refining): 125 tonnes

Rubis Terminal JV –
Group share: 5.8 tonnes
Rubis Énergie (refi ning): 186 tonnes
Rubis Terminal JV –
Group share: 159.5 tonnes
Rubis Énergie (refi ning): 205 tonnes
Rubis Terminal JV –
Group share: 148 tonnes
Rubis Énergie (refining): 288 tonnes

Rubis Terminal JV: NA
Rubis Énergie (refining): 62 tonnes

Rubis Terminal JV: NA
  Use of resources   Used/treated water  

Green Water project (Rubis Énergie): seawater desalination to significantly reduce freshwater consumption at the SARA refinery

Use of rainwater, wastewater treatment

  Rubis Énergie Rubis Terminal JV   Water used
Rubis Énergie (refining): 252,906 m3
Rubis Terminal JV –
Group share: 99,170 m3
  Water used
Rubis Énergie (refining): 150,104 m3
Rubis Terminal JV –
Group share: 169,604 m3
          Water treated
Rubis Énergie (refining): 88,319 m3
Rubis Terminal JV – Group share: 212,660 m3
  Water treated
Rubis Énergie (refining): 65,417 m3
Rubis Terminal JV –
Group share: 256,131 m3
    Operational safety   Number of major industrial accidents   “Zero major industrial accidents” target   Rubis Énergie Rubis Terminal JV   Rubis Énergie: 0
Rubis Terminal JV: 0
  Rubis Énergie: 0
Rubis Terminal JV: 0
Operating in a safe environment   Personal safety Health and safety at work   Frequency rate of accidents with lost time > 1 day declared (excluding commuting accidents) (employees)   Maintain a lost-time accident frequency rate <4.5 until 2025   Rubis Énergie   4.7   4   Reduce personal injury operating accidents with lost time
    Number of accidents with lost time > 1 day declared (service providers)   Maintain the number of accidents with lost time <32 until 2025 (2020 baseline)   Rubis Énergie   11   20  
    Change in Total Incident Rate (TIR)   Reduce employee TIR by 25% by 2025 (vs 2020)   Rubis Terminal JV   -3%   -5%   -
    Number of occupational accidents with lost time   Achieve 0 accidents with lost time   Rubis Terminal JV   13   8    
    Number of deaths following an occupational accident (excluding commuting accidents)   Achieve and maintain the objective of “zero fatal accidents” each year   Rubis Énergie   0   1 employee; 2 service providers   Zero fatal accidents
    Defensive driving training rate for drivers in the most exposed countries(3)   100% of drivers in the most exposed countries trained in 2023   Rubis Énergie   81% (91% of employee drivers and 78% of external drivers)   62% (76% of employee drivers and 59% of external drivers)   Raise awareness of traffic accidents in our activities
  Safety/health of customers and local residents   Percentage of industrial sites holding at least one certification (mainly ISO 9001, 14001 and 45001)   Maintain and renew our certifications   Rubis Énergie
Rubis Terminal JV
  Rubis Énergie: 32%
Rubis Terminal JV: 100%
  Rubis Énergie: 27%
Rubis Terminal JV: 100%
* As far as possible, the description of the risks relating to the Rubis Terminal JV is presented separately from the risks relating to the Retail & Marketing and Support & Services activities. However, for the sake of clarity for the reader and to limit duplication, as certain risks are similar and are subject to similar management measures, they are not presented in separate paragraphs.
Fighting against climate change   GHG emissions   Greenhouse gas emissions  

Decarbonisation plan for operations (by 2030, target of -30% for scopes 1 and 2 (vs 2019, at constant scope))

  scopes 1 and 2 emissions

  activity carbon intensity indicator (scopes 1 and 2/EBITDA)

  Rubis Énergie   235 kt CO2 eq scope 1 9.8 kt CO2 eq scope 2 0.360   196 kt CO2 eq scope 1 10.9 kt CO2 eq scope 2 0.375   Reduce the carbon footprint of our industrial sites, vessels and trucks (scopes 1 and 2)
      By 2030, target of -20% of scope 3A (excluding products sold) (Rubis Énergie scope, mainly outsourced maritime and road transport items, i.e., 45% of scope 3A) (vs 2019) Scope 3A emissions   Rubis Énergie   225 kt CO2 eq scope 3A   183 kt CO2 eq scope 3A   Reduce the carbon footprint of our value chain
  Adaptation of activities   Percentage of business units that organised an energy efficiency awareness campaign among their customers   From 2022, each business unit will be required to organise at least one awareness-raising initiative per year   Rubis Énergie   48%   NA   Raise our customers’ awareness of energy efficiency
    Carbon intensity indicators for products sold   A target for reducing the carbon intensity of our products will be set in 2023(4)
Scope 3B emissions
  Rubis Énergie   13,034 kt CO2 eq scope 3B   12,867 kt CO2 eq scope 3B   Reduce the carbon intensity of our products and diversify our business lines
Attracting, developing and retaining talents   Diversity and equal opportunities   Percentage of women in governing bodies   By 2025, an average of 30% of Management Committee members to be women   Rubis Énergie   28.6%   27.4%   Strengthen the diversity of our teams
      Maintain a proportion of at least 30% of the least represented gender on the Group’s Management Committee   Rubis SCA   Gender parity   Gender parity  
      By 2030, 40% of the Executive Committee should be women   Rubis Terminal JV   25%   25%    
  Developing skills   Percentage of employees trained   100% of employees trained each year   Rubis Énergie   90.1%   82.4%   Support the development of our employees’ skills
      10% of employees trained in changes in our business lines (energy transition, CSR, etc.) each year to 2025   Rubis Énergie   28%   NA  
  Quality of life at work   Absenteeism rate for non-occupational illnesses   Maintain a social environment conducive to employee well-being and retention   Rubis Énergie Rubis Terminal JV   Rubis Énergie: 2.17%
Rubis Terminal JV: 7.1%
  Rubis Énergie: 1.81%
Rubis Terminal JV: 5.93%
  Be an attractive employer
  Employees’ involvement in the Group’s value creation   Percentage of employees receiving a pay rise during the year   Group social policy promoting employee commitment to work   Rubis Énergie Rubis Terminal JV   Rubis Énergie: 66.1%
Rubis Terminal JV: 50.6%
  Rubis Énergie: 50%
Rubis Terminal JV: 53.6%
Working responsibly and with integrity   Fighting corruption   Percentage of employees made aware of ethics and anti-corruption rules   100% of employees made aware in 2023   Rubis Énergie Rubis Terminal JV   Rubis Énergie: 88%
Rubis Terminal JV: 98%
  Rubis Énergie: 76%
Rubis Terminal JV: 77%
  Strengthen our employees’ understanding and adherence to our ethics rules and principles
  Responsible purchasing   Integration of CSR/ethics criteria   Launch of a responsible purchasing approach in 2023: mapping of high-risk purchases, action plan, responsible purchasing charter   Rubis Énergie   NA   NA   Ensure responsible management of our supply chain
  Regional, economic and social impact   Number of beneficiaries of community investment   Continuation of international social engagement policy   Group (Rubis SCA, Rubis Énergie and the Rubis Terminal JV)   Nearly 50,000 beneficiaries(5)   Nearly 200,000 beneficiaries   Contribute to local development and address global societal challenges
    Rate of business units implementing community investment that meets a local need   100% of business units in 2025   Group (Rubis SCA, Rubis Énergie and the Rubis Terminal JV)   67%   67%  
(1) CSR Roadmap Think Tomorrow 2022-2025, concerning the Rubis Énergie scope, since it was published, before the acquisition of Rubis Photosol finalised in April 2022. The Rubis Terminal JV, jointly controlled by Rubis SCA and its partner, has defined its own roadmap, the Mid Term Sustainability Roadmap 2022-2030.
(2) The accidents taken into account are classified according to the GHS (Globally Harmonised System for the Classification and Labelling of Chemicals).
(3) The countries in which the Group operates considered to be the most exposed to road safety risks are among the 100 countries identified by the WHO as having the highest number of accidents: https://www.who.int/data/gho/data/indicators/indicator-details/GHO/estimated-road-traffic-death-rate-(per-100-000-population).
(4) The Group planned to define a target for reducing the carbon intensity of products sold in 2022. Nevertheless, as the acquisition of Rubis Photosol led to a change in the product mix sold, through the integration of new activities, the definition of this objective was postponed.
(5) Excluding beneficiaries of the exceptional donation to the Fondation de France’s Ukraine Solidarity Fund. Change in the calculation method in 2022 vs 2021: the number of beneficiaries is calculated pro rata to the amounts paid to each association.


Appropriate procedures are implemented to address the challenges 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 capital expenditures (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 sharing the Group’s growth with employees are carefully monitored (see section 4.4).

Other challenges, 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, via its representatives on the joint venture’s Board of Directors, continues to promote the Group’s standards vis-à-vis the partner and to monitor the Rubis Terminal JV’s efforts and performance.

4.1.3 Comparability, reliability and control of social and environmental information

The comparability and reliability of information primarily results from the standardisation of methods used for reporting social 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, anti-corruption) 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.