RUBIS

Mindful that employee commitment is key to the Group’s success, Rubis ensures that individuals have the opportunity for professional development, with the aim of attracting, developing and retaining its talents. To do so, Rubis focuses its efforts on promoting diversity and equal opportunities (section 4.4.1), employee skills development (section 4.4.2), health, safety and well-being at work (section 4.4.3) and involving employees in the Group's value creation (section 4.4.4).

Group risk mapping has identified the main human resources risks related to the Group’s activities. These risks mainly concern the health and safety of employees and external service providers working at Group sites. Apart from these risks, a key challenge relating to human resource management was identified by the relevant Management in each division: attracting, developing and retaining talent while the Group grows and where human resources must be adapted to Rubis’ development strategy. This challenge is dealt with in this chapter.

In line with its corporate culture and in order to make the most of its human capital and better address the specificities involved in the Group’s activities, the deployment of Rubis' human resources policy has been decentralised. Rubis Énergie, its subsidiaries and the Rubis Terminal JV manage their human resources autonomously in line with Rubis’s values and implement local actions adapted to their needs and challenges.

In addition, in order to support skills development and foster internal mobility, a project relating to establishing a process for identifying and supporting Talents was initiated within Rubis Énergie at the end of 2021. It should be implemented starting in 2023.

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.

Diversity and inclusion are part of the Group’s DNA. They are an asset to the Company and key to the effectiveness of its teams. The Group is committed to ensuring that there is no discrimination based on origin, religion, gender or sexual orientation, health status and/or disability, political views, religious beliefs or family status. These values are clearly stated in the Group’s Code of Ethics. To ensure that each individual is protected against discrimination, a whistleblowing system (Rubis Integrity Line) has been rolled out across the entire Group so that any situation undermining the Group’s values and those of its subsidiaries can be reported. The Integrity Line allows all Group employees as well as external and temporary workers to securely report any such situation via a website (see section 4.5.1.1).

Since combating discrimination is a major issue in the area of employment, the Group has set itself the target of there being zero proven reports of discrimination, notably through the application of its ethics hotline.

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.

Rubis Énergie’s business lines (Retail & Marketing and Support & Services), which are described in greater detail in chapter 1, entail industrial and environmental risks that may have impacts of varying nature and scope depending on the activities and the type of products handled (fuels, heating fuels, bitumen, liquefied gases). In most countries, these activities are subject to multiple stringent environmental, health and safety regulations requiring the implementation of risk prevention systems (the European Seveso regulations for industrial facilities or the ADR for the carriage of hazardous materials by road, for instance).

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.

Challenges	Main risks	Monitoring indicators	Contribution to SDGs
Limiting our environmental impact	•Water and soil pollution (section 4.2.2.1)	•Number of accidental spills > 200 liters
	•Atmospheric emissions (section 4.2.2.2)	•Polluting emissions from major industrial sites (NOx, VOC, SO2)
	•Use of resources (section 4.2.2.3) •Preserving water resources	•Used/treated water
Operating in a safe environment	•Operational safety (section 4.2.3.1)	•Zero major industrial accident target
	•Personal safety (section 4.2.3.2) •Health and safety at work	•Frequency rate of occupational accidents and zero fatalities target
	•Health and safety of customers and local residents (section 4.2.3.2.2)	•Certifications (ISO 9001, 14001 and 45001)
Fighting against climate change	•Greenhouse gas emissions (section 4.3) •Adapting activities (section 4.3)	•Emissions of  greenhouse gases •Indicators of the carbon intensity of activities
Attracting, developing and retaining talents	•Diversity and equal opportunity (section 4.4.1)	•Rate of  epresentation of women (workforce, management committees)
	•Skills development (section 4.4.2)	•Percentage of employees receiving training (particularly safety training)
	•Quality of life at work (section 4.4.3)	•Turnover and absenteeism rate for non-occupational illnesses
	•Employees’ involvement in the Group’s value creation (section 4.4.4)	•Wage increases and other compensation measures
Working responsibly and with integrity	•Fighting corruption (section 4.5.1.1)	•Qualitative indicator for the anticorruption programme
	•Responsible purchasing (section 4.5.1.2)	•CSR criterion in calls for tenders (Rubis Terminal JV)
	•Regional, economic and social impact (section 4.5.2)	•Number of indirect jobs •Number of beneficiaries of community investment

The Group puts personal health and safety at the very heart of its social policy. These risks affect both employees and staff from outside companies, as well as customers and local residents living near sites operated by Group entities. This subject is addressed in section 4.2.3.2.

Information including key performance indicators relating to the main risks

• •Total number of employees at the end of the period, male/female breakdown;
• •Absenteeism rate;
• •Number of hours of training, including safety training;
• •Workplace accident frequency rate;
• •Number of work-related illness;
• •Energy consumption;
• •VOC emissions;
• •CO2 emissions;

• •Implementation of the anti-corruption program.

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. 

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.

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

		Some of Rubis Énergie’s distribution or industrial activities (Vitogaz France, Sigalnor, SARA, Lasfargaz, Rubis Energia Portugal, Vitogaz Switzerland, Rubis Energy Kenya, Vitogas Espana and Easigas) are ISO 9001-certified (quality management system), as are all of the Rubis Terminal JV’s terminals.
		The activities of SARA (refinery), Vitogaz Switzerland and Rubis Energia Portugal (Retail & Marketing) are ISO 14001-certified (environmental management system), as are certain of the Rubis Terminal JV’s French and international terminals. This standard provides a framework for controlling environmental impacts and seeks to ensure the continuous improvement of its environmental performance.
		The activities of Vitogaz Switzerland are certified ISO 45001, and the activities of Rubis Energia Portugal are OHSAS 18001 certified (occupational health and safety management).
		Regarding Rubis Terminal JV’s chemical product depots (Salaise-sur- Sanne, Grand-Quevilly, Val-de-la-Haye, Strasbourg, Dunkirk, Beveren, Rotterdam), the Chemical Distribution Institute - Terminals (CDI-T) is responsible for global chemical product supply chain inspections and audits specific to the transportation and storage activity.
		The Rubis Terminal JV’s Dunkirk site has a continuous risk management approach regarding the storage of foodstuffs. Employees are trained in best practices through the analysis of food risks. They apply the principles of this approach, known as HACCP, and know how to meet the particular needs of the food sector, such as product traceability throughout the logistics chain. Moreover, the terminal has declared that it stores products used for animal feed. This has been registered with the DDPP (Direction Départementale de la Protection des Populations – Regional Directorate for the Protection of Populations). Finally, this site is preparing to obtain GMP+ B3 certification for the transshipment and storage of liquids used for animal feed.
		Vitogaz France has held NF Service Relation Client (NF345) certification since 2015. It was the first French company to obtain certification under the new version 8, in December 2018. Revised in 2018, NF Service Relation Client certification is based on international standards ISO 18295-1 & 2. A true guide of the best practices in customer relationship management, it takes customer expectations into account and aims to guarantee constantly improving service quality. For Vitogaz France, this approach to seeking excellence in customer experience aims at establishing a long-lasting commercial relationship, delivering quality service over time, ensuring that transmitted information is exhaustive and clear, and acting promptly in accordance with its commitments.

A proactive occupational health and safety policy has been implemented. It covers both preventing occupational accidents and preventing occupational and non-occupational illnesses.

The Group’s subsidiaries place particular importance on the health and safety of local residents and customers.

In general, risk prevention efforts continued, with 54% of employees trained in health and safety. The increase in this rate compared with the previous financial years (40% in 2020 and 23.2% in 2019) is attributable to the pandemic, which prompted subsidiaries to step up their health and safety training and awareness-raising efforts (protective measures, work in confined spaces and psychosocial risks).

Collective and individual commitment is indispensable to adopting ethical behaviors that meet the Group’s values. To ensure that the rules of conduct are shared and complied with by all, Rubis has included within in its Code of Ethics a common framework for all its subsidiaries, including the Rubis Terminal JV.

This Code of Ethics (which is accessible to the public through the Group’s website: www.rubis.fr/en) lays down the values that Rubis considers to be fundamental:

• •compliance with applicable laws and regulations wherever the Group operates;
• •fighting against corruption, fraud, misappropriation of funds and money laundering;
• •preventing conflicts of interest;
• •complying with competition, confidentiality and insider trading rules, as well as with specific laws that apply to war and/or embargo zones;
• •respecting individuals, including by observing fundamental rights and human dignity, safeguarding privacy, and fighting against discrimination and harassment;
• •complying with workplace health and safety rules and environmental protection rules;
• •managing relationships with external service providers;
• •reliability, transparency and auditability of accounting and financial information;
• •protecting the Group’s image and reputation.

In each of these areas, the Rubis Code of Ethics details the general principles that employees must observe while performing their duties. The Code of Ethics is furnished to new arrivals. Subsidiaries organise training sessions to explain the Code’s contents and to answer employees’ questions. Rubis SCA’s CSR & Compliance Department is the point of contact for subsidiaries and employees on ethics issues.

Respecting human rights is above all about promoting a model of a responsible employer that protects the fundamental rights of all Group employees in all countries where the Group has a presence. In addition to its legal obligations, Rubis advocates for the respect of individuals as a management principle and prohibits harassment and discrimination. These values are enshrined in the Code of Ethics put in place in 2015, which is distributed to employees.

In practical terms, the Group ensures that in all countries where it operates its human resources policy complies with the principles relating to human rights at work as set out in the International Labour Organisation’s fundamental conventions in the areas of:

• •freedom of association and collective bargaining;
• •eliminating discrimination in hiring and professional discrimination;
• •eliminating forced or compulsory labour;
• •abolishing child labour.

In 2021, the Group joined the United Nation’s Global Compact in order to reaffirm its commitment to integrating and promoting the principles of protecting human rights, complying with international labour and environmental protection standards and combatting corruption.

In 2020, the Group’s CSR & Compliance Department, in conjunction with Rubis Énergie’s operational management, conducted an analysis of modern slavery risks in its value chain in order to ensure that adequate preventive measures are in place. This analysis will be supplemented in 2022 by a broader mapping of the human rights challenges in the Group’s activities.

Preventing the risk of forced labour in the shipping business is a major focus. A crew management manual drawn up by the Rubis subsidiary in charge of managing wholly owned vessels sets detailed standards to be complied with in terms of crew recruitment and working conditions (under a temporary international contract with a Group entity), in line with the principles of the ILO Maritime Labour Convention, which include the rejection of forced labour. Enhanced vigilance is exercised when dealing with crew recruitment agencies. Contracts with these agencies include specific clauses relating to the obligation to comply with international standards, and the ILO Maritime Labour Convention in particular. Annual audits are carried out on these recruitment agencies. For chartered vessels, the services of a leading vetting company are used. Compliance with the Maritime Labour Convention is included in the pre-approval criteria for each vessel.

As regards the working conditions of service station managers, who are not Group employees, an initial assessment has been carried out on two subsidiaries with service station networks in two countries that are particularly exposed, Madagascar and Haiti. No cases of forced or child labour were identified by the commercial inspectors, who regularly inspect service stations, sometimes unannounced. An ethics clause, in which the service station operator undertakes to comply with Rubis’ ethics rules, including compliance with applicable Labour laws, the prohibition of forced or child labour, and compliance with employee health and safety rules, is included in certain contracts and must be systematically included when renewing or signing new contracts.

The Group’s whistleblowing line, Rubis Integrity Line, which has been rolled out across all Group entities, is available not only to Rubis employees but also to external and occasional workers and enables them to report non-compliance with rules in a strictly confidential way (see the "Fighting corruption” section on the previous page). The deployment of the line to reach external employees, including the employees of service station managers, must be strengthened.

In addition, the Group ensures that systems for protecting the health and safety of all persons working within in subsidiaries are in place (see section 4.2.3.2.1).

Rubis SCA has chosen as its partner a major infrastructure fund that has a long-term investment policy. This fund, which has a global footprint, invests in line with the best international ESG standards.

The Group ensures that its interests as a partner are protected, notably through the signature of a shareholders’ agreement, its representation on the joint venture’s governance bodies (Board of Directors) and regular reporting from Rubis Terminal Infra’s Management (see section 3.2.4).

Contractual arrangements enabling conflicts and deadlocks within the partnership to be resolved are included in the shareholders’ agreement.

Rubis ensures that the same level of standards as those implemented in its controlled entities are complied with by Rubis Terminal Infra’s Management teams by monitoring indicators and reports submitted by Management.

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.

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.

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.