4.2 Limiting our environmental impact and operating in a safe environment


Protecting people and the environment is everyone’s business and a priority for Rubis. As a committed and responsible company, the Group works continuously to protect its environment (section 4.2.2), and seeks to operate in complete safety (section 4.2.3). To manage this quality, health, safety and environmental approach, the Group has defined a general framework and governance implemented for each activity (section 4.2.1).




A general framework for quality, health, safety and the environment (QHSE) has been defined to prevent risks and limit the negative impacts of our activities.


The QHSE policy framework, referred to in the Group’s Code of Ethics, states that each employee must act responsibly when performing their duties, comply with the health, safety and environmental protection procedures on site, and pay particular attention to compliance by all parties (colleagues, suppliers, external service providers, etc.). This common framework is shared by all Group activities.


To take into account the specific challenges and risks of Rubis Énergie’s activities and those of the Rubis Terminal JV, they have each drawn up their own QHSE policy in line with the Group’s general principles. Dedicated governance has been set up for the implementation of these policies for each of the business lines, clarifying the Group’s principles by translating them into operational requirements.


The main objective of these QHSE policies is to prevent risks so as to better protect physical and environmental integrity and minimize the impacts of a major accident (see section 4.2.3). This is reflected in the implementation of the measures required to limit incidents as far as possible and thereby reduce the probability of a severe event occurring. In addition, the Group is also keen to mitigate its environmental footprint (see section 4.2.2). MANAGEMENT SYSTEM




The implementation of QHSE policies is overseen by facility Managers, assisted by the Rubis Énergie and Rubis Terminal JV Industrial, Technical and HSE Departments. At larger sites, quality and/or HSE engineers are also involved in this approach. The Directors of Rubis Énergie subsidiaries and their functional departments report on their work in the field of HSE to Management Committee meetings held twice a year within each division, in the presence of Rubis SCA’s General Management. The Management of the Rubis Terminal JV reports on the implementation of its HSE policy and its results to its Board of Directors, on which Rubis SCA has representatives.


Rubis Énergie (retail  & marketing and support  & services activities)


As Rubis Énergie considers it vital to ensure the health and safety of people and property located in or near its facilities, Rubis Énergie has established a Health, Safety and Environment (HSE) Charter, which requires its affiliated companies to comply with HSE objectives considered fundamental, sometimes over and above regulations in force locally, as a means of preserving the safety of people and property and to heighten employee awareness on these issues.


These general objectives are to be achieved through the following key measures:


spreading of Rubis Énergie’s fundamental HSE principles among subsidiaries to create and strengthen the HSE culture;


implementation of the industry’s best business practices;


documentation of systems established in accordance with “quality” standards ensuring reliability and safety of operations;


regular assessment of technological risks;
strengthening of preventive maintenance of facilities;
regular inspection of the facilities and processes (transportation activities included) and addressing of any discrepancies identified;
analysis of incidents through lessons learned documents;
regular training of employees and raising their awareness of technological risks.


Depending on the activity, the following actions are also taken:


taking care to analyze the state of the facilities in light of specific Group standards and local regulations and, if 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 feedback 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 assists in the event of any maritime pollution that may occur during loading/ unloading operations in Rubis Énergie terminals.


Rubis Terminal JV (storage activity)


The Management of the Rubis Terminal JV has circulated a document to all its subsidiaries setting out “the principles of Rubis Terminal’s safety culture.”


These principles note, through the commitments given by the joint venture’s Management, that:


safety is a core value and must be shared, on a personal level, by all employees;
Managers are responsible for staff safety and must be held accountable.


The Rubis Terminal JV considers that protecting health and safety contributes to the success of the Company, and should therefore never be neglected, and that action must be taken upstream to avoid workplace injury or occupational illness. The Management of each Rubis Terminal JV industrial site has the obligation to ensure regular audits assessing compliance with safety principles and standards. Performance indicators have been set up in order to trigger and monitor a process of continuous improvement with respect to health and safety.


The Rubis Terminal JV’s 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 at each site. Managers also agree to adhere to recognized international QHSE standards, set out below.


Lastly, the Rubis Terminal JV has committed to a detailed multi-year program to reduce its energy consumption and its CO2 and atmospheric emissions, by circulating 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 in the years to 2020, the results of which are presented in the corresponding sections of this chapter (section for the carbon intensity of the activity, section for water consumption and section for waste management).


The following actions are also implemented:


monitoring of programs such as HACCP or GMP+ (see table below), under which the Rubis Terminal JV has committed to complying, in its various activities, with the regulations and professional recommendations of the sector, to benchmarking best industrial practices and to seeking continuous improvement in its performances in the areas of safety, protection of health and the environment;
joining the Chemical Distribution Institute -Terminals (CDI-T) for the Rubis Terminal JV chemical product storage depots, a non-profit foundation working to improve the safety of industrial sites in the chemicals industry;





Certain sites operated 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 and Easigas) are ISO 9001-certified (quality management system), as are all of the Rubis Terminal JV terminals.
  The activities of SARA (refinery), Vitogaz Switzerland and Rubis Energia Portugal (retail  & marketing) are ISO 14001-certified (environmental management system), now replaced by ISO 45001, as well as certain French and international terminals of the Rubis Terminal JV. This standard provides a framework to controlling the environmental impacts, and is designed to ensure the continuous improvement of its environmental performance.
  The activities of Vitogaz Switzerland and Rubis Energia Portugal are ISO 18001-certified (occupational health and safety management), as is the Rubis Terminal JV site in Dörtyol (Turkey).
  For the 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 transportation and storage.
  The Rubis Terminal JV Dunkirk site has an ongoing risk management policy for 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. In addition, the terminal has declared that it stores products used for animal feed. This business has been registered with the DDPP (Direction Départementale de la Protection des Populations – Regional Directorate for the Protection of Populations). Lastly, 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 in 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 guide to best practice in customer relationship management, it takes due account of customer expectations and aims to guarantee constant improvements to service quality. For Vitogaz France, this promotion of excellence in the customer experience should help establish a long-lasting commercial relationship, deliver quality service over time, ensure that information transmitted is complete and clear, and act promptly to meet its commitments.




22.5% of Rubis Énergie’s industrial sites (retail  & marketing and support  & services activities) have at least one certification.


100% of the Rubis Terminal JV’s industrial sites have at least one certification.



4.2.2 Limiting our environmental impact


The risks to the environment stemming from Group activities are monitored closely and managed responsibly.




Rubis’ businesses are organized around two divisions, retail  & marketing and support  & services, and the Rubis Terminal JV operating a bulk liquid storage business (fuels, chemicals, fertilizers, edible oils and molasses) on behalf of a diversified industrial customer base. They present industrial risks that, depending on the activities and the nature of the products handled (fuels, biofuels, liquefied gases, bitumen, chemical and agrifood products), may have environmental impacts of varying nature and scale. These risks are described in each part of this section.


The environmental impact of Rubis Énergie’s retail  & marketing activities (liquefied gases; fuels: gasoline, diesel, biofuels, jet fuel; bitumen) stems mainly from the risks of accidental spills or leakage of products from various sites (storage depots, gas stations, filling plants for LPG cylinders, customer facilities, aviation or marine refueling facilities), generally limited in size.


The environmental impact of Rubis Énergie’s support  & services activity stems mainly from the Group’s sole refinery in the French Antilles (SARA), due to its industrial processing activities, as well as the shipping business.


The environmental impact of the Rubis Terminal JV’s storage activity results from the large size of the depots (and the quantity of products being stored and transferred there) and the nature of some of the products handled, which require energy-intense facilities (boilers, for example).




This chapter details the preventive measures put in place and key monitoring data for the following priority environmental risks, identified by means of a pictogram : 


prevent water and soil pollution likely to be caused by accidental product spillages (section;


assess and limit atmospheric emissions from industrial activity (section;


contribute to combating climate change (section, which presents the Bilan Carbone® of the Group’s activities);


optimize the use of resources by protecting water resources (section


Another risk that the Group does not consider to be a priority in terms of its activities, but which is nevertheless significant, is that of waste management (section WATER AND SOIL POLLUTION  




The risks of contamination of water and soil related to the Group’s operations result mainly from accidental spillages of stored and/or transported products, which at some sites may result from activities preceding the Group’s presence. In general, the entities are gradually investing in the sites to improve the safety of their facilities and eliminate pollution risks as far as possible.




Retail  & marketing business




The petroleum products distribution business is liable to generate risks of water and soil contamination through accidental spills, tank overflows, spills, tank and/or pipe leaks, and wastewater discharges (at fuel depots, gas stations, and customer facilities). Road haulage of products, which is necessary to supply distribution sites and customers (fuel, bitumen) is also liable to result in accidental spills.


Measures to prevent and contain pollution


Tanks containing hazardous products, and associated pipework, undergo systematic inspections at storage sites in accordance with international standards during regular mandatory on-site visits, generally once every 10 years. Moreover, to prevent groundwater and soil pollution in the event of accidental spillage, storage tanks are often installed in watertight retention basins lined with concrete. These basins are kept shut. They are only opened for emptying manually after checks have been performed confirming the absence of pollutants. In the loading/unloading zones of the storage sites for tank trucks, the retention platforms are purpose-designed for each type of product and, as a general rule, connected to oil-water separators linked to treatment plants or buffer basins. Groundwater is tested at discharge points every quarter.


Equipment used at Rubis Énergie gas stations that is liable to generate soil pollution (mainly tanks and piping) is checked regularly (particularly in respect of the absence of defects and its water proofness), and is gradually being replaced by double-wall technology. This includes double-wall underground tanks and pipes, equipped with leak detectors which provide continuous oversight to guard against any possible pollution. The medium-term (2027) objective is to replace single-wall tanks that are more than 30 years old. The regions most affected by this measure are the Bahamas, Jamaica, the West Indies, Haiti and East Africa. By way of example, the tanks of six gas stations, i.e. about 20 tanks, were replaced in 2020 in the Caribbean zone, representing an overall investment of approximately US$3 million.


At the same time, Rubis Énergie is strengthening its preventive maintenance programs for this equipment (see section, and is working continuously to improve the safety/ environmental training of gas station managers, notably to ensure that they have the resources available to immediately detect any loss of product due to faulty equipment/practices or fraud.


Rainwater liable to have been polluted through contact with roadways is increasingly being treated before discharge into the environment; gas stations are equipped with systems for the collection and treatment of rainwater whenever road repair work is planned.


Regarding the road haulage of petroleum products, in addition to the application of the regulations applicable to the transportation of hazardous materials, additional measures are taken in order to prevent the risk of traffic accidents. Courses in defensive driving have been introduced in countries where this risk is heightened due to driving habits, distances or the poor quality of road infrastructure.


Support  & services business




The support  & services business (refining and shipping) could give rise to water and soil pollution in the event of accidental spillage or leaks, as well as through the use of wastewater (desalination water, stripping treatments, draining), bulk tank drain water and ballast wastewater.


Moreover, shipping activity can generate risks of pollution during ship loading/unloading operations or in the event of a shipping accident.


Measures to prevent and contain pollution


For vessel chartering, Rubis Énergie calls on the services of a specialized company that systematically vets the vessels in question. This company collects information relating to the vessel’s condition (construction date, maintenance, etc.), as well as the operator’s quality (reliability of the crew, etc.). It then submits a recommendation on the risks in using the vessel, which the teams take into account before signing the charter agreement.


Rubis Énergie has also taken preventive measures in the event of maritime pollution in its terminals, during product loading/unloading operations. Rubis Énergie has partnered with Oil Spill Response Ltd, an organization that provides specialized assistance in managing this type of occurrence.




Water pollution


  Suspended solids Petroleum products
  released into water* released into water
(in kg) 2020 2019 2020 2019
Refining (support  & services) 2,120 2,587 277 454
Retail  & marketing Not measured Not measured Not measured Not measured


* Suspended solids released into water: see definition in section 4.5.3.



In the refinery, the start-up of a new lamellar separator in early 2019 has significantly reduced the amount of suspended solids and petroleum products in the wastewater. Without calling into question the improved performance made possible by this investment, it must be emphasized that the sharp reduction in discharges observed in 2020 is attributable to shutdowns of production units for the two major scheduled shutdowns of facilities for periodic maintenance.


Soil pollution


In accordance with professional practices, Rubis Énergie monitors accidental spillages of liquid petroleum products with a unit volume of more than 200 liters. In 2020, the subsidiaries recorded 20 incidents (mainly related to installation leaks, traffic accidents or non-compliance with operating procedures). This increase compared with the prior year (six incidents reported) is attributable first to an improvement in the quality of reporting (implementation of a digital CSR reporting solution, better awareness of local teams) and second to an extension of the reporting scope to new entities recently acquired in East Africa, where measures to upgrade HSE standards are underway. A new HSE Director in charge of the area has been recruited for this purpose.


Any significant spill must be followed by remedial action aimed at returning the environment to its initial state as quickly as possible.








The storage activity may generate accidental water and soil pollution, in particular as a result of bulk tank overflows, spillage, bulk tank and/or pipe leaks, and discharges into residual water.


Measures to prevent and contain pollution


Tanks containing hazardous products, and associated pipework, undergo systematic inspections at storage sites in accordance with international standards during regular mandatory on-site visits. Moreover, to prevent groundwater and soil pollution in the event of accidental spillage, storage tanks are (with some exceptions) installed in watertight retention basins (lined with concrete or clay compounds). These basins are kept shut. They are only opened manually after checks have been performed confirming the absence of pollutants.


In the loading/unloading zones for tank trucks, the retention platforms are purpose-designed for each type of product and, as a general rule, connected to oil-water separators linked to treatment plants or buffer basins. Water is tested at discharge points at least every half-year, and monthly at the outflows from treatment plants. Weekly or monthly checks are carried out on nearly all sites to verify that there is no floating pollution in the groundwater monitoring wells downstream of facilities.




Water pollution


  Suspended solids Petroleum products
  released into water* released into water
(in kg) 2020 2019 2020 2019
Rubis Terminal JV 3,843 3,619 366 380
of which Group share 2,114 NA 201 NA
* Suspended solids released into water: see definition in section 4.5.3.


The volume of suspended solids discharged into the water is very low compared with the volume of water used (over 450,000 m3). The change between 2019 and 2020 can be explained by the fact that two sites that did not previously report their figures have been included since 2020. A slight reduction was measured at the other sites.


Soil pollution


No incidents of uncontained pollution were reported in 2020 (four occurred in 2019). The reported incidents correspond to pollution in excess of 200 liters in the course of one year. ATMOSPHERIC EMISSIONS FROM INDUSTRIAL ACTIVITY  


With the exception of refining in the French Antilles, the activities of Rubis Énergie are not classed as industrial transformation processes. The storage sites of the Rubis Terminal JV, due to their size, are the other significant source of atmospheric pollutants within the Group, which is committed to implementing a policy to limit these emissions.


To this end, the various sources of atmospheric pollutant emissions are gradually being evaluated. The Bilan Carbone® is published in section on climate change.




Retail  & marketing business




The distribution of petroleum products activity generates some VOC (volatile organic compounds) emissions; however, these emissions remain relatively low.


In liquefied gas distribution, VOC emissions are generated by connection/disconnection operations when filling cylinders and trucks and degassing cylinders for technical inspections. Other VOCs are made up of the solvents contained in paints used for cylinders.


Automotive fuel distribution, storage and distribution facilities generate VOC emissions from gasoline. These emissions are particularly low due to measures taken to collect gasoline fumes, as described below.


The retail  & marketing activity does not emit significant volumes of NOx.


Limitation measures


In fuel depots, particularly those equipped with loading stations, gasoline vapors are collected during tank truck loading; in France, where regulations have required it for several years, they are treated in vapor recovery units (VRUs) that condense them before returning them to the storage tanks. In addition, top loading stations are gradually being replaced by source loading stations, and gasoline storage tanks are increasingly being equipped with floating screens that considerably limit the release of vapors into the atmosphere during the storage phase.


In gas stations, vapors emitted during reception and delivery to customers are gradually being recovered, especially in France where regulations have required this for several years.


Support  & services business




The refining activity generates emissions into the air due to its industrial transformation processes. The main emission sources are furnaces and combustion turbines, as well as boilers and flares.


Shipping generates SO2 emissions due to the fuels consumed by vessels. However, these emissions have been much lower since the entry into force on January 1, 2020 of the Low Sulfur regulation implemented by the International Maritime Organization (IMO 2020).



Limitation measures


The continuous monitoring of the refinery’s air emissions is strengthened by putting into service analyzers of dust and carbon monoxide in the two units generating the highest emissions. Measures to collect gasoline vapors have also been implemented, as described in the section on retail  & marketing activities above.


Each year, a refinery fume control campaign is carried out by a body authorized to approve the findings of our self-monitoring system (campaign carried out in September 2020).


As regards shipping, different solutions have been implemented in order to comply with the International Maritime Organization’s Low Sulphur regulation:


Rubis Énergie has fitted one of its five directly owned vessels with a scrubber, which captures the sulfurous emissions by washing the exhaust fumes. These chimney evacuation filters treat exhaust gas, eliminating up to 90% of sulfur dioxide (SO2) and fine particles;


the other four directly owned vessels, as well as those operated on a time-charter basis by Rubis Énergie, now use low-sulfur fuel oil (0.5% maximum), the availability of which in the three zones of activity (Caribbean, Europe and Indian Ocean) is very satisfactory.


  Understanding air pollutants and greenhouse gases  


Human activities (transport. accommodation, industry, agriculture) are sources of greenhouse gas emissions and air pollution. Although they are closely linked and some measures thus aim to reduce both air pollutants and greenhouse gases (for example, improved efficiency of heating systems at the storage sites and optimization of distances covered by delivery trucks), they should not be confused with one another.


→   Made up of toxic gases or harmful particles, air pollutants have a direct and generally local effect on health and the environment when they exceed certain thresholds. Over and above human activities, they can also come from natural sources, such as volcanoes (sulfur dioxide). Due to their negative impacts, the release of these air pollutants resulting from human activities is supervised and monitored. Air pollutant emissions measured in the Rubis storage activities and support  & services activities concern:


•   nitrogen oxides (NOx), which are formed in particular during fossil fuel combustion processes;


•   sulfur dioxide (SO2), which arises from several industrial processes and the consumption of fossil fuels containing sulfur;


•   volatile organic compounds (VOC), including benzene, which is found in paint and automotive fuel in particular.


→   Greenhouse gases occur naturally in the atmosphere and play a vital role in regulating and maintaining the Earth’s average temperature (natural greenhouse effect). Contrary to air pollutants, greenhouse gases have little direct effects on health. However, an excess of greenhouse gases released by human activities is largely responsible for global warming (the so-called additional greenhouse effect).


In its activities, the greenhouses gas released by Rubis is carbon dioxide (CO2), which is measured (Bilan Carbone®) and subject to reduction measures (see section






  NOx emissions VOC emissions SO2 emissions
(in tonnes) 2020 2019 2020 2019 2020 2019
Refining (support  & services) 185 206* 182 262 240 262*


* Data adjusted following the publication of the 2019 URD – Data published in 2019: 230 t of NOx emissions and 343 t of SO2 emissions.


In 2020, atmospheric emissions from refining activities decreased due to the shutdowns of production units for the two major scheduled shutdowns of facilities for periodic maintenance.







The storage activity releases VOCs (volatile organic compounds) from the surface of the products stored which, depending on their physico-chemical properties, may vaporize according to the storage and handling conditions.


Limitation measures


Gasoline vapor collection in the French storage terminals of the Rubis Terminal JV


Vapors recovered when tank trucks discharge their loads are piped to vapor recovery units (VRU), where they are condensed into liquid fuel before being reinjected into the storage tanks.


In addition, fuel storage tanks are equipped with floating screens, and loading is performed through bottom-loading stations so as to minimize VOC discharges into the atmosphere.


Collection and treatment of VOCs in the chemical depots of Antwerp and Rotterdam


From their creation, both these sites were designed to collect and treat all VOC vapors occurring above liquids and pushed out of tanks during transfers.


Reduction of energy consumption in storage terminals


As the energy consumed by the storage terminals is derived from the same source as the energy generating CO2 (pumps and boilers), the actions taken by the Rubis Terminal JV to reduce energy consumption on sites, in terms of both existing and new heating systems, are described below (section




  NOx emissionS VOC emissions
(in tonnes) 2020 2019 2020 2019
Rubis Terminal JV 11 11 311 406
of which Group share 6.1 NA 171 NA


In the storage sites, the low values calculated still show a very limited NOX impact from this activity in 2020, unchanged despite an increase in heating over the past year. Concerning VOCs, the 23% reduction recorded for Rubis Terminal in 2020 reflects the full-year operation of a more efficient vapor recovery unit treatment system for gasoline emissions at the Rouen site.


SOX emissions are not measured by Rubis Terminal because the fuels used are either standard low-SOX liquid fuels (imposed in the EU countries where the subsidiaries are located) or natural gas or LNG, which contains almost no SOX, in Turkey. CLIMATE CHANGE  



The Group is aware of the challenges facing its sector in terms of energy transition. The oil and gas industry plays a key role in energy access, and energy is essential to meet people’s basic needs (transportation, heating, keeping cool, lighting, cooking) and support their development. Nevertheless, even today, a large proportion of the population in many of the regions in which Rubis operates (Africa in particular) is deprived of access to energy. The Group accordingly has a key role to play.


That said, the changing expectations of society and the need to reduce greenhouse gas emissions worldwide are prompting the Group to strike a balance between the expectations of customers who want access to affordable energy and the need to contribute to the fight against climate change by reducing CO2 emissions related to its activities.


Today, Rubis has undertaken to further integrate energy transition challenges into its strategy.


In 2020, to make concrete progress towards growth that is less dependent on fossil fuels, the Group set up a governance system involving all levels of management.


In this context, Rubis has identified as the main pillars of its Climate strategy:


reducing the carbon impact of its activities by optimizing its energy consumption; to this end, Rubis Énergie has set a target of reducing its CO2 emissions (scopes 1 and 2) by 20% in 2030 (versus 2019); and
contributing to the development of a less carbon-intense society by continuing to develop energy transition solutions and promoting the use of low-carbon energies (biofuels, HVO, etc.) by its customers.


Although there are many avenues to be explored, significant technological, societal and economic challenges remain in relation to reducing the proportion of fossil fuels in the energy mix and making less carbon-intense energies available to all.


In order for these solutions to be successful and drive progress, they must be adapted to the specific characteristics of each of our regions. Lastly, to be sustainable, growth must also be inclusive. It is therefore essential that the policies implemented to promote the transition to a low-emission and climate-change-resilient economy have a positive social impact.


Rubis is already directly involved in the innovation and rollout of low-carbon solutions (synthetic diesel, green hydrogen, CO2 capture by algae, biological carbon sink), while developing training and employment and improving the local and global environmental footprint.




Climate challenges are included in the Group’s risk analysis processes, particularly its risk mapping.


The climate risks to which Rubis, and more specifically Rubis Énergie, is exposed, are described in chapter 3, section, and are grouped into two main categories: physical risk and transition risk.


These risks do not have the same materiality for Rubis Énergie and for the Rubis Terminal JV due to the different nature of their activities. The



main activity of the Rubis Terminal JV is to provide storage capacity for bulk liquid products for third parties (fuels as well as biofuels, chemical products and agrifood products) and, more marginally, to distribute small volumes of petroleum products.


Climate challenges present opportunities to develop new offers and products both for Rubis Énergie and the Rubis Terminal JV. The Group’s adaptation, by reducing the carbon footprint of its activities and diversifying its offering, is a key factor in pursuing sustainable growth.


To address these risks and define its transition trajectory, Rubis follows the “measure, reduce, offset” approach. To better assess its carbon footprint, the Group has commissioned comprehensive Bilan Carbone® assessments of its activities since 2019. The scope covered included the activities of the Rubis Terminal JV, as well as products sold, so as to identify the most effective means of reducing it. The assessment was carried out in accordance with the methodology designed by Ademe (Agence de l’Environnement et de la Maîtrise de l’Énergie), based on the recommendations of ISO 14064-1 and the GHG Protocol (see the methodological note in section for more details on the reporting scope), and was carried out in the first year with the support of an Ademe-certified firm that trained Rubis’ teams in carbon accounting.


This carbon accounting method records carbon emissions across three scopes:


scope 1: direct emissions from the fixed or movable facilities located within the Company’s organizational scope;
scope 2: indirect emissions related to the production of electricity, heat and cold used;
scope 3: other indirect emissions generated by third-party activities upstream or downstream from the Company’s activities.


(in kt CO2 eq.) 2020 2019
Scope 1(1) Direct greenhouse gas emissions    
Retail & marketing 31 28(2)
Support & services (refining/shipping) 179 206(3)
Total scope 1 Retail & marketing/support & services 210 234
Rubis Terminal JV – Group share(4) 10 NA
Scope 2(1) Indirect emissions related to the sites’ energy consumption    
Retail & marketing 6 4.4
Support & services 1.8 1.4(5)
Total scope 2 Retail & marketing/support & services 7.8 5.8
Rubis Terminal JV – Group share(4) 3 NA
Scope 3(1) Other indirect emissions    
Retail & marketing/support & services 12,319 13,719
of which customers’ end use of products sold 12,165 13,537
Rubis Terminal JV – Group share(4) 355 NA


(1) See breakdown of items calculated for each of scopes 1, 2 and 3 in the methodological note, section 4.5.
(2) Change in the breakdown of emissions between the support & services division and the retail & marketing division, with no change in the total for 2019.
(3) Restatement due to a change in methodology: certain emissions relating to shipping are smoothed out over four years, 25% each year, due to management methods.
(4) Share based on the Group’s shareholding, i.e. 55%.
(5) Restatement due to a material error (overestimation of electricity consumption in 2019).





When we focus on the Rubis Group’s operating emissions, i.e. excluding emissions related to the use of products sold, they mainly come from:


emissions from the shipping of distributed products, i.e. 129 kt representing 62% of the CO2 emissions of Rubis Énergie’s complete emissions excluding products sold;
the energy consumption of Rubis Énergie’s industrial facilities, i.e. 67 kt representing 32% of the CO2 emissions of Rubis Énergie’s total emissions excluding products sold. 86% of these emissions come from the SARA refinery (58 kt Group share), an industrial transformation activity requiring the consumption of energy for its completion;
the energy consumption of the Rubis Terminal JV’s industrial facilities, i.e. 13 kt (scopes 1 and 2 of the Rubis Terminal JV’s complete emissions) through the use of boilers to maintain the temperature of certain products requiring hot storage.


The energies used by the Group’s industrial facilities (electricity, steam, fuels) contribute to the smooth day-to-day operation of industrial facilities, including safety equipment (power-driven fire pumps, back-up generators, etc.).


As regards emissions relating to the use of products sold, Rubis Énergie (and the Rubis Terminal JV, very marginally) distribute petroleum products that release CO2 when used by the customer. This is the Group’s most significant source of CO2 emissions and accounts for nearly all scope 3 emissions, although in 2020, 54% of the gross margin came from sales of liquefied gas and bitumen, products that emit little or no CO2 during use. These emissions account for 12% of the Group’s total emissions.




Rubis has set up a structured governance to ensure that climate challenges are fully integrated into the Group’s strategy.


A position of Managing Director in charge of New Energies, CSR and Communication has been created at Rubis SCA. She is a member of the Group’s Management Committee and is responsible for these issues.


She also chairs the Climate Committee, which has met three times since its creation in May 2020. This Committee is made up of Rubis’ Head of CSR & Compliance, the Rubis Énergie's Senior Management and Finance, HSE and Risk-Resources Directors (Rubis Énergie's being the leading contributor to the Group’s Bilan Carbone®), and a representative of the Rubis Terminal JV. Rubis Énergie’s Climate & New Energy team, created in 2020, provides input to the Climate Committee and coordinates the operational efforts made by all of the Group’s subsidiaries.


The key role of this Committee is to:


monitor the Climate action plan, based on the three pillars, “measure, reduce, offset”;
monitor change in the carbon footprint and ways to reduce it; and
propose solutions for the transition to low-carbon growth in the distribution of energy products.


The importance given by the Group to climate issues is reflected, among other things, in the inclusion of an energy efficiency performance criterion for the allocation of the annual variable compensation of the General Management. It is based on the achievement of target improvements in the carbon intensity (operational efficiency) of the retail & marketing and support & services activities (Rubis Énergie).


At all levels of the Group, the people involved in this transition have been trained in carbon accounting techniques and climate challenges.


      Reduction target     


Rubis Énergie has developed an action plan to reduce its CO2 emissions. The plan was designed after extensive consultation with subsidiaries and functional departments, with the support of consultants specialized in each of its key business lines (land transportation, shipping, refining, storage site management). On the basis of this consolidated action plan, defined for the 2019-2030 period, the Group has set a target for reducing emissions directly linked to its operational activities (scopes 1 and 2).


The levers identified to achieve this target are based on initiatives by Rubis Énergie and its subsidiaries, as well as on technological and regulatory advances by partners and suppliers in the means used directly by the Group to operate.


The target is a 20% reduction by 2030, with the aim of taking it to -32% under favorable technological and regulatory conditions.


Ultimately, the goal is to reduce the carbon footprint across all scopes.


The Rubis Terminal JV will set its target in 2021. It will be submitted for approval to its two shareholders at a Board of Directors meeting.




To share its efforts and in the interest of transparency, the Group will complete the CDP Climate Change 2021 questionnaire. As part of this initiative, Rubis will share its Climate strategy and action plan.


  Rubis Énergie’s participation in the testing phase of the ACT® initiative
(Assessing low-Carbon Transition)


Assessing low-Carbon Transition (ACT®) is an initiative of Ademe and CDP, supported by the French government as part of the UNFCCC’s Global Climate Action Agenda, which has developed a methodology to measure the commitment of French and foreign companies to reducing their greenhouse gas emissions. In 2020, Rubis Énergie was one of 12 companies in its business segment that took part in the pilot phase of the methodology’s development. During this project, Rubis Énergie benefited from the support of consultants trained by the Bilan Carbone ABC association. These discussions and reflections helped Rubis Énergie structure its low-carbon strategy.






The measures taken by the Group to control and reduce the carbon footprint related to its activities and thereby strengthen its climate resilience can be organized into three categories:


optimizing and reducing the energy consumption of fixed and mobile sources within its scope;
developing new projects and supporting the Group’s future medium- and long-term strategic guidelines in order to reduce the carbon intensity of products sold;
implementing support and awareness-raising measures for customers to reduce their emissions by showing them to consume better and less.


Improving the energy efficiency of the Group’s sites


The Group makes significant efforts on a daily basis to reduce energy consumption in its



industrial activities, optimize operating expenses and reduce the climate change impact of its activities. Particular attention is paid to the most energy-intense industrial sites. As energy consumption also results in air emissions other than greenhouse gases, some of the measures described below are also aimed at reducing the pollutant emissions discussed in section


In 2020, Rubis Énergie was assisted by a consulting firm specializing in energy savings to identify the emission reduction potential of the sites operated by the Group. The aim of this work was to identify and list actions aimed at controlling scope 1, 2 and 3 emissions, excluding products, of the facilities operated by Rubis.


Rubis Énergie


Various actions to reduce the energy consumption of the sites have been implemented or started, including:


actions relating to the Group’s vessels, such as route optimization, controls and monitoring of bitumen heating to reduce bunker consumption, etc. To continue this reduction trajectory, the subsidiaries are currently conducting studies to consider the possibility of integrating biofuels into the bunkers used. In addition, for chartered vessels, Sea Cargo Charter clauses are gradually being introduced into contracts;
replacement of four furnaces in the refinery. This change will result in a 15% reduction in the fuel consumption of these furnaces (corresponding to approximately 7,000 tonnes of CO2 per year);
energy saving actions in service stations, such as replacing lane lighting with LEDs or, solarizing stations in Kenya and the Caribbean by installing photovoltaic panels to reduce electricity purchases but also improve the reliability of access to electricity;
ISO 50001 certification process initiated by the SARA refinery to be proactive in the fight against climate change. SARA’s objective is to obtain certification by mid-2021.


Rubis Terminal JV


Reduced energy consumption by heating systems


As part of modernization programs, the boilers at Rubis Terminal sites are being replaced by heat pumps or mixed systems (heat pumps and boiler) or, local conditions permitting, by greener heating systems (geothermal for instance).


Diversification of activities


In line with its DNA, the Group favors a decentralized approach to identify solutions adapted to the specific characteristics of each local environment (climatology, vehicle fleet, etc.).


Some subsidiaries have already launched projects to diversify their activities and market fuels with a less carbon-intense life cycle.


Rubis Énergie


Marketing of HVO biodiesel in vehicles


The Rubis Énergie retail & marketing subsidiary operating in the Channel Islands (FSCI) launched a biofuel marketing campaign in 2019. HVO (Hydrotreated Vegetable Oil) is a synthetic diesel fuel that complies with the European renewable energy directive. This biofuel is made from raw materials: vegetables, residues and waste. It has the same chemical structure as a standard fuel but is non-fossil and reduces carbon emissions by at least 50%. It can be used in most diesel engines without any prior modification, which taps into the full potential of its environmental qualities.


The aim is to extend this practice to other Group subsidiaries.


Marketing of bitumen for infrastructure development


The use of bitumen does not emit CO2. Indeed, as a residue of refining intended for non-fuel use, any bitumen produced implies a similar amount of heavy fuel oil not produced. Rubis continues to develop its distribution of quality bitumen and contributes to regional accessibility through the construction of infrastructure in Africa.


Rubis Terminal JV


The Rubis Terminal JV is gradually diversifying its activities by developing the mix of products stored in its terminals.


In 2020, fuels represented 60% of revenue from stored products. Other liquid products, such as chemical products, fertilizers, edible oils and molasses are also stored. They represented 40% of the joint venture’s revenue.


LNG storage project


Elengy and the Rubis Terminal JV have signed a cooperation agreement to launch preliminary studies for the installation of an LNG storage facility at the Reichstett terminal (Bas-Rhin). The objective is to meet the retail LNG needs of central-western Europe for road and river transport, and for industry.


Energy transition initiatives at subsidiaries


Renewable energy production at the Martinique refinery


SARA has chosen to capitalize on the advantages of its geography and industrial process to produce renewable energy sources that will ultimately enable it to reduce its emissions linked to the consumption of conventional energy needed for its activities.


A veritable laboratory in the field of energy transition, SARA has for several years been developing projects to convert the hydrogen produced by its activities into green electricity (ClearGen) and to build a photovoltaic power plant to supply green electricity to around 3,000 Martinique residents. SARA is actively playing its role in the fight against climate change through new projects.


Microalgae CO2 capture (PIAN)


This industrial ecology project is the largest demonstrator in French Guiana. Its objective is to create new sustainable industries, including third-generation biofuels, based on the biological recovery of industrial CO2 through the large-scale production of microalgae.


Production of green hydrogen for mobility use in Guadeloupe (Hydrogen Green Island)


This project consists in producing renewable hydrogen by electrolysis of water, powered by photovoltaic electricity. It has been designed for Guadeloupe, with the objective of producing hydrogen mobility for a fleet of buses.




Development in partnership of a photovoltaic electricity production site based on the agrivoltaic principle.


Hydrane de Guyane


Anaerobic digestion of local aquatic biomass cultivated for this purpose. The biogas produced will be used for space fuel (future Ariane launcher) and/or electricity production.



The ambition is to make this project a positive energy biological carbon sink.


West Guiana Power Plant (CEOG)


Innovative power plant project consisting of photovoltaic panels, batteries and hydrogen storage produced with electrolyzers.


Measures aimed at consumers


Aware that customer use of the fuels it distributes generates CO2 emissions, Rubis Énergie implements initiatives aimed at encouraging consumers to make better use of these products in their day-to-day lives. The quantitative data regarding CO2 emissions relating to customers’ use of products sold by the Group are reported in the Bilan Carbone® table at the start of this section.


Supporting consumers in energy saving programs


Through Vitogaz France, Rubis Énergie conducts information and awareness-raising programs focusing on consumers’ energy consumption patterns.


Since the introduction of the energy saving certificates scheme in July 2005, which aims to achieve energy saving actions in certain sectors (building, small and medium-sized industry, agriculture and transport), Group entities have funded various energy saving projects.


In addition, in order for France’s overseas departments to benefit more from these initiatives, Rubis Énergie is directly involved in bids for programs to develop and finance more widespread energy-saving awareness-raising, information, training and measures to be applied in their energy consumption and in their use of mobility services.


Accordingly, in 2019, Rubis Énergie joined forces with EDF and Total to launch the implementation of a program extending beyond its regulatory obligation and expressing a proactive and local approach to contribute to energy-saving actions by becoming a player and not only a purchaser of certificates.


Promoting the use of liquefied gas as a transitional energy in the distribution activity


Liquefied gas is an integral part of the energy transition. Some 20 Rubis Énergie subsidiaries are positioned on the liquefied gas distribution market (bottled and bulk) and encourage its use as a substitute for the most CO2-emitting energies, such as fuel oil for heating and wood or coal for cooking. In 2020, liquefied gas accounted for nearly 24% of the volumes of products sold by Rubis Énergie.


Liquefied gas is an everyday energy through its domestic, industrial and fuel uses. It meets many energy needs at competitive economic conditions. Its characteristics make it possible to respond to concerns about access to energy in emerging countries where a large part of the population is in a situation of energy insecurity. Liquefied gas is a clean alternative to charcoal that prevents massive deforestation.


The example of Haiti: micro-filling plants


To provide easier access to energy for consumers far from urban areas and preserve the remaining forests, our subsidiary in Haiti has built micro-filling plants for liquefied gas. They are easily accessible by consumers in rural areas and allow them to fill their cylinders only partially according to their means. The gradual increase in the price of charcoal is making liquefied gas more competitive, which is beneficial for the environment.


The example of Madagascar: providing access to smaller cylinders


In Madagascar, more than 97% of households still rely on firewood and charcoal for cooking energy. To stop the massive deforestation this entails, the Malagasy government has identified various measures, including the use of alternative energy.


Vitogaz Madagascar has a part to play in this energy policy by promoting the use of bottled liquefied gas and facilitating access to this product for households. The extension of retail gas outlets in Madagascar has removed one of the barriers to the purchase of liquefied gas cylinders. This offer also came with a discount on the purchase price of a Fatapera kit (a stove that attaches to the gas cylinder for cooking), sold to nearly 1,100 new customers in Antananarivo between June and December 2020.


The example of Vitogaz Maroc: liquefied gas as an alternative to heavy fuel oil for the energy transition in industry


Vitogaz Maroc has helped its client Nestlé in its transition towards this less carbon-intense energy source. The El Jadida plant is to replace 5,500 tonnes of heavy fuel oil per year with liquefied gas. The initiative will enable Nestlé Morocco to reduce its CO2 emissions by more than 6,400 tonnes per year from 2021.


In addition, Vitogaz France, Vitogas España and Vitogaz Switzerland promote the use of liquefied gas as fuel. A vehicle running on LPG emits up to 20% less CO2 than a gasoline vehicle, and practically no pollutants (particles, sulfur dioxide SO2 or nitrogen oxides NOX) (see boxed text on pollutant emissions in section




As a result of a decrease in the Group’s activity due to the health situation, emissions decreased in absolute terms between 2019 and 2020 (see Bilan Carbone® table above).


The decrease in scope 1 emissions was mainly attributable to lower emissions related to energy consumption (reduction of approximately 21 kt CO2) from the refinery and shipping (reduction of approximately 3 kt CO2). Scope 1 and 2 emissions from retail & marketing subsidiaries increased slightly. This increase is mainly attributable to the availability and better quality of data reported by certain subsidiaries (such as Rubis Energy Kenya, Togo, Bahamas) and also concerns electricity consumption (scope 2). For scope 3 emissions excluding the use of products sold, the decrease in emissions (reduction of approximately 19 kt CO2) is mainly related to emissions relating to the depreciation of vessels and purchases of goods and services. Lastly, with regard to scope 3 emissions linked to the use of products sold, the reduction (1,158 kt CO2) results from a decrease in the volume of products sold.




Indicator 2020 2019
kg CO2 /MWh sold 5.35 5.32


The activity’s carbon intensity indicator (Rubis Énergie scope 1 and 2 CO2 emissions as a proportion of volumes of products sold in MWh) increased slightly between 2019 and 2020, despite the decline in the absolute value of direct emissions.


This increase is notably linked to the increase in sales of bitumen, which contribute to increasing CO2 emissions from activities (numerator) without adding MWh distributed (denominator) since bitumen is not used by our customers for energy (used for road infrastructure projects in particular).


Rubis Énergie is considering an indicator that will better reflect the diversity of its activities and the results of its actions to reduce carbon emissions.


Indicator 2020 2019
kgCO2 /tonne moved 2.06 1.73*
* The indicator published in 2019 (4.13) corresponded to a partial activity indicator and did not take into account the specific nature of the various types of storage sites.


A change in method was introduced between 2019 and 2020, under which the Rubis Terminal JV will now consider outgoing product volumes (throughput out) instead of incoming and outgoing product volumes (throughput in + out) in order to align our reference with other financial indicators also based on use throughput out.


The increase in this indicator since 2018 corresponds to a change in the activity of the Rubis Terminal JV in favor of a growing share of storage of chemical products, biofuels and agro-industrial products and a decrease in the storage of fuels. The trend reflects the Rubis Terminal JV’s determination to promote the energy transition and reduce its dependence on fossil fuels in order to increase the sustainability of its activities. Counter-intuitively, the provision of services in Rubis Terminal JV terminals for products with lower overall emission factors during their use results in an increase in operating emissions (scopes 1 and 2). In fact, these products require more heating, blending, cooling or vapor treatment, which do not exist or are limited for fuels. Nevertheless, since 2013 – and thanks to significant work to improve the energy efficiency of its facilities and actions to reduce consumption – the Rubis Terminal JV has reduced its carbon intensity in the two storage activities that constitute it:


-25% CO2 emitted per tonne of product stored in mixed depots and -76% in fuel oil depots compared to 2013 (for a target set at -20%);
-16% kWh per tonne of product stored in mixed depots and -58% in fuel oil depots compared to 2013 (for a target set at -10%).




  Energy production Energy consumption
(in GJ) 2020 2019 2020 2019
Refining (support & services) 406,231 604,977 1,193,241 1,750,229
Rubis Terminal JV NA NA 363,155 362,913
of which Group share NA NA 199,735 NA


The refinery is equipped with a cogeneration turbine for the production of electricity (3.5 MW) and superheated steam (9 t/h); two boilers also produce superheated steam, one main (22 t/h) and the other secondary (15 t/h). In 2020, the Rubis Énergie refining activity produced 143% of its electricity requirements (74,447 GJ of electricity produced compared with 51,976 GJ used) and the total volume of energy produced (electricity and steam) accounted for 34.5% of the energy consumed over the period, stable compared to 2019.


In 2020, the net energy consumption of the Rubis Terminal JV sites was stable compared with 2019. This stability is linked to the diversification of products and the increase in the storage of heated products requiring energy to keep them at temperature (carbon black at 50°C and bitumen at 170°C), to treat toxic vapors and to ensure inerting (a process aimed at eliminating/reducing the risk of accidental phenomena linked to the handling of explosive or flammable products), while throughput was down in 2020. OF RESOURCES


In line with principles of good governance of its activities, Rubis makes optimum use of the natural resources required by its value chain, a key component of its corporate responsibility (section In addition, although the Group produces little waste, it ensures that quantities are restricted, and waste is recycled (section PRESERVATION OF WATER RESOURCES  





The distribution activity does not require the recurrent and significant use of water for industrial processes. Water is consumed in only very limited quantities for fire drills and periodic checks of storage tanks, as well as for washing and requalification of LPG cylinders at filling plants.


The support & services activity (refining) consumes water mainly through its industrial transformation processes (boilers, etc.) and facilities’ fire-fighting systems.


The water consumption at the Rubis Terminal JV mainly comes from fire drills carried out to test the effectiveness of the systems in place and the need for dosing liquid fertilizers. This usual consumption is increased by occasional water requirements resulting from the filling of new bulk tanks with water (resistance tests).


Measures to reduce water consumption


In the activities with the highest level of consumption (refining and the Rubis Terminal JV), significant efforts are made to reduce the net consumption of freshwater:


the use of rainwater for refilling fire reservoirs and for dosing fertilizer. The facilities concerned have dedicated collection tanks;
treating wastewater allows the Rubis Terminal JV storage sites to report a higher volume of treated wastewater than the volume of freshwater used, as rainwater collected on sealed surfaces is also treated. In the Rubis Énergie refinery, all process water is collected and treated before being discharged into a modern residual water treatment unit. Systematic sampling and regular analyses make it possible to check that the water discharged after the various treatment stages complies with regulatory standards;


the investment project aimed at producing industrial water at the Rubis Énergie refinery by way of sea water desalination (based on the principle of reverse osmosis) will significantly reduce the net consumption of freshwater. This project, called Green Water, is under way (civil works, piping) and should make it possible to cover all the refinery’s industrial water requirements (capacity of 30 m3/h for demineralization lines and 5 m3/h for service water requirements). Its start-up of operations, scheduled for the fourth quarter of 2020, has been postponed to the first half of 2021 due to the Covid-19 pandemic. It should reduce the refinery’s city water consumption by 80%. Domestic water (sanitary, kitchen) will continue to be supplied via the drinking water network.




  Water used* Water treated*
(in m3) 2020 2019 2020 2019
Refining (support & services) 174,014 227,894 92,209 92,208
Rubis Terminal JV 305,640 259,185 471,056 453,512
of which Group share 168,102 NA 259,081 NA
* The water used and/or treated can be either standing (reservoirs or lakes) or flowing water (rivers) above ground, sea water, groundwater or water from the distribution network supplying the site. Discharged water is abstracted water, plus, on occasion, rainwater.


Water consumption related to the Rubis Énergie refinery (support & services activity) is down slightly (notably due to the two major technical shutdowns), and remains below the regulatory threshold prescribed in the prefectural decree authorizing the refinery to operate.


Since 2018, the Rubis Terminal JV’s water consumption has been optimized. The ending of major temporary water table abstraction, designed to protect groundwater against surface pollution following the clean-up of a large site, made it possible to reduce water consumption by 98% since 2013. Nevertheless, in 2020, the increase in water used corresponds to the hydraulic tests of many tanks that were commissioned or refurbished in 2020. As regards treated water, the difference with the volume of water used corresponds to the variation in rainfall on the sites. WASTE MANAGEMENT



The Group’s activities generate little hazardous waste, given their respective business lines, and therefore do not constitute a significant risk. The main sources of waste generation are storage and refining activities. In order to minimize its impact, the Group does its utmost to limit the quantity of waste generated and to recycle wherever possible. Subsidiaries ensure that residual waste that cannot be recycled is treated as required by applicable standards.


Analysis by business line


The retail & marketing activity generates virtually no hazardous waste, other than in the storage activity. The only hazardous waste produced mainly comprises residues and sludge, which are treated as required by the locally applicable standards, as outlined below in respect of the storage activity.


The support & services activity (refining only) produces hazardous waste, mainly petroleum products residues and sludge (recovered when wastewater from tanks and/or separators is treated during maintenance work) and chemical products.


The Rubis Terminal JV (provision of bulk liquid storage capacity) generates three types of hazardous waste:


waste generated by the subsidiaries’ regular activity, particularly following maintenance and inspection, which are mainly comprised of residues and sludge removed when tanks (and/or separators) are cleaned during maintenance operations or when switching between products. Like all other waste, residue and sludge removal is systematically registered, declared and sent to authorized recycling or destruction plants. Residue and sludge with combustion power are usually sent to authorized thermal recovery centers;
goods not delivered to customers, which can sometimes only be removed from sites as “hazardous waste”;
waste from decontamination work, particularly on some recently acquired sites that contain legacy pollution that predates Rubis Terminal JV’s arrival.



Measures to limit and recycle waste


Innovative procedures and tools have been implemented to limit the production of both hazardous and non-hazardous waste. To this end, the entities are continuing their efforts to increase the number of sites using recycling networks for heat recovery, when such treatment is available nearby.


A continuous inventory of hazardous materials or substances is regularly reported to the local authorities (in the European Union). A register is kept available for inspection by the Regional Directorates of Environment, Planning and Housing (DREALs) at each French site.


The Rubis Énergie refinery and the Rubis Terminal JV have also established a system of systematic sorting of non-hazardous industrial waste, a classification covering all waste that is neither hazardous nor inert.


This sorting is performed through the use of suitable and appropriately positioned containers on each site.




  Volumes of hazardous waste Waste recovery rate
(in tonnes) 2020 2019 2020 2019
Refining (support & services) 255 102* 59% 97%*
Rubis Terminal JV 2,314 4,056 22% 38%
of which Group share 1,273 NA NA NA
* Data restated after publication of the 2019 URD – Data published in 2019: 98 t of hazardous waste and 78% recovery.


The volumes of hazardous waste related to the refining activity and reported in 2020 were up significantly compared with 2019. This significant variation is mainly attributable to the fact that a significant volume of chemical products had to be destroyed in 2020 with the dismantling of the Sulférox 17 unit, which also generated 400 tonnes of non-hazardous waste (concrete, waterproofing, stainless steel, ferrous metals). Waste recycling consists in reusing petroleum sludge and other waste soiled by petroleum products as fuel or another energy source. Oils are regenerated for reuse. Metals and metallic compounds are recycled or recovered.


Generation of hazardous waste as reported at the Rubis Terminal JV fell by 34% between 2019 and 2020. The drop in the waste recovery rate is attributable to the fact that incorrectly identified waste at the Dunkirk and Rouen sites could not be recovered, despite a sharp increase in waste recovery at the Strasbourg, Rotterdam, Antwerp and Salaise sites.


In general, the targets set by the Rubis Terminal JV in 2013 in terms of waste production and recovery were not achieved. The numerous transformations of the industrial facilities carried out in 2020 generated demolition and construction waste, increasing the volume of waste per tonne of product stored (+24% compared to 2013, the target being -5%).


4.2.3 Operating in a safe environment  


The safety of operations is a constant concern for the HSE teams of Rubis Énergie and the Rubis Terminal JV, due to the nature of their activities. Rubis Énergie operates 15 industrial sites classified as Seveso sites (high and low threshold, including a refinery) in the European Union, together with 43 similar sites elsewhere (petroleum or chemical product storage sites and LPG cylinder filling plants). The Rubis Terminal JV operates 24 classified industrial sites (excluding Tepsa, acquired in 2020).


The Group’s HSE teams are committed to a continuous process of improving measures and procedures for the security of property and the safety of people, particularly employees, as well as external service providers, customers and local residents. Strict industrial health and safety benchmarks are used by all Group subsidiaries. Efforts are focused on the safety of the facilities, so as to prevent major accidents, as well as on personal safety, to prevent workstation accidents and to prevent the safety of customers and local residents from being compromised.


The Group continues to invest regularly to upgrade its facilities to the highest environmental and safety standards, and to guarantee the protection of people and their environment (air, water, soil and urban areas near its facilities). This investment guarantees the reliability of its operations and, as a result, the Group’s competitiveness. The amount of investments on safety/maintenance and facility adaptations increased sharply. In 2020, it was €131 million for Rubis Énergie (compared with €86 million in 2019), including work carried out by the refinery during the two major shutdowns. The Rubis Terminal JV invested €25.1 million in 2020 (including Tepsa for two months).


    What is a Seveso site?    


Generally, all industrial or agricultural facilities liable to create risks or cause pollution or nuisance for local residents are qualified as installations classified for the protection of the environment (ICPE). Some of these ICPEs are classified as Seveso since their operation in France is subject to authorization by the prefect. Indeed, when an industrial site handles hazardous products, an accident can quickly have serious consequences.


Following an industrial accident that occurred in 1976 at a chemical plant in Italy, the European public authorities adopted a directive known as the Seveso directive, named after the town near the plant where the accident occurred, to prevent major industrial accidents. The European Seveso Directive, which has been amended three times since its adoption in 1982, classifies industrial facilities according to the level of danger they would represent in the event of an accident. The classification is based on the quantity of hazardous products stored at a Seveso site, with a “high threshold” or a “low threshold”. The prevention measures to be implemented by operators are adapted to the type of site. They are based on a regularly updated hazard study.





Most of Rubis Énergie’s facilities, and those of the Rubis Terminal JV, in France and the rest of Europe (storage sites and LPG cylinder filling plants) are classified as Seveso sites, and are consequently subject to very strict regulations in respect of environmental protection and industrial safety (regular risk assessments, implementation of measures to prevent and, where necessary, manage the consequences of potential accidents). These standards are being phased in gradually by non-European subsidiaries, taking into account the constraints of the local environment.




Risk mapping is performed by subsidiary Management assisted by the Managers of the retail & marketing activity, the industrial facilities and the shipping business (see chapter 3, section


With regard to the safety of operations, the main risk would be the occurrence of a major accident in industrial or distribution facilities (gas stations), including an explosion or fire that could cause damage to people, the environment and/or property, etc.




In order to reduce the industrial risks inherent to its activities, whether or not they are subject to European regulations, and in accordance with the “zero major accidents” target the Group has set for itself, QHSE teams are required to work on the following factors.


Improve preventive maintenance of facilities and the perception of risks by employees


Rubis Énergie and the Rubis Terminal JV continued to roll out their respective software for the preventive maintenance of facilities (computerized maintenance management system). Once the relevant information has been loaded into the database, these systems allow the planning of monitoring and preventive maintenance work. Its other functions are to list all past maintenance operations so as to create a service history, to anticipate spare parts requirements, to assess maintenance costs in connection with the management of equipment, and to prepare budget estimates.


In addition, Rubis Énergie is gradually involving its employees in a continuous effort to improve the safety of facilities, respecting the rule Plan – Do – Check – Act (see diagram below).



Moreover, to improve the understanding of the systems and the assessment of the risks bearing on Seveso facilities, the Rubis Terminal JV has also developed Piping and Instrument Diagrams (PID). PIDs are a system used to identify the pipes, tanks and pumps of a site digitally, and to harmonize disparate existing blueprints and to replace them with a single reliable plan that can be duplicated on all sites.


Use of lesson learned procedures


The organizational arrangements of these procedures vary depending on the relevant operations.


Rubis Énergie uses its extranet to circulate a documentary base with, in particular, lesson learned, to all its subsidiaries. Recommendations can then be made after analyzing accidents.


They can include the adaptation of organizational measures, the updating of risk prevention procedures, the strengthening of employee training activities, the modification of facilities or the improvement of the monitoring of equipment.


The procedure for reporting incidents, near misses and accidents by subsidiaries, which




gives rise to lesson learned, is an excellent indicator of the safety culture prevailing in the various entities. It is also an important feature of the continuous improvement process. For example, in 2020 Rubis Énergie was able to circulate to all subsidiaries some 20 lesson learned reports detailing the description, consequences and main causes of each incident, as well as the main recommendations to be implemented to prevent such incidents from recurring. These reports covered a wide variety of areas, including the inspection of liquefied gas cylinders before filling, securing containers on trailers, works at gas stations, loading tank trucks at depots, automotive fuel deliveries to customers, etc.


The Rubis Terminal JV has developed a safety-sharing software (Rubis Terminal Operational Platform) in order to facilitate and encourage the collection and exchange of safety-related information. This interface collates incident reports produced by each terminal. It comes with a lesson learned management module, as well as reports and a selection of indicators. It is used by local QHSE teams and promotes interactions between sites in order to limit the repetition of risk events.


Prevent and control technological risks: the preventive safety mechanism at facilities


Prevention of technological risks is ensured through regular inspections of the Group’s sites and subsidiaries by the Industrial and Technical Departments of Rubis Énergie and the Rubis Terminal JV. They are detailed in reports prepared in consultation with the Managers of the relevant facilities and the Managers of the subsidiaries concerned, in order to analyze potential anomalies and/or shortcomings and take steps to remedy them.


In addition to inspections and lesson learned, each entity implements preventive measures appropriate for its own business, including:


internal inspections of all liquefied gas and fuel bulk storage tanks, generally scheduled every 10 years;
installation and maintenance of safety equipment such as gauges, level alarms, fire defenses, gas detection systems, etc.;
routine verification that all substances stored, existing or new, have been covered beforehand by an operating permit if required;
systematic analysis and management of risks identified in the Material Safety Data Sheet (MSDS) and systematic training of staff in the handling of any potentially hazardous products;
pursuant to Seveso regulations, a procedure to prevent major accidents on the French facilities involving hazardous substances, supplemented by “Instrumented Risk Control Measures” (IRCMs);
periodic inspection of fire-fighting systems and regular updating of contingency plans, in consultation with local authorities. In addition, these facilities are regularly tested through exercises simulating potential accident conditions as closely as possible.


Should a major event occur despite the implementation of these rigorous preventive measures, provision has been made for:


establishment of a crisis management organization that can be triggered rapidly if there is a major event. For example, the relevant high-risk facilities have emergency response plans that aim to bring incidents under control as quickly as possible, using local resources, to guarantee the best possible protection of people and goods. These plans are combined with 24/7 on-call crisis management procedures that may be activated depending on the severity of the event. Lastly, some subsidiaries organize regular training sessions on crisis communications via accident simulation exercises, allowing them to test pre-established communications protocols;
the option to obtain assistance from specialist companies. Rubis Énergie, for example, has partnered with Oil Spill Response Ltd to receive assistance in the event of maritime pollution at its fuel depots. Rubis Énergie also partners with professional bodies such as the GESIP (Groupe d’Étude de Sécurité des Industries Pétrolières et Chimiques – Group for Safety Research in the Petroleum and Chemical Industries), the Joint Inspection Group (JIG) and the International Air Transport Association (IATA), expert bodies in the area of aviation refueling that provide general operational, training and safety support.


At the Rubis Terminal JV, the Seveso-type storage sites in question have both internal and external resources to respond to pollution incidents. For example, specialized companies are contacted to manage any river spills that could be carried along by the current.




In 2020, in line with the target set by the Group, no major accidents occurred as a result of Rubis Énergie and the Rubis Terminal JV activities.


Over and above the constant concern to prevent major industrial accidents, the Group also continues to make efforts to minimize the occurrence of more minor industrial accidents as far as possible. PERSONAL SAFETY  



Personal safety is a direct result of operational safety. Rubis is just as keen to ensure workplace safety (section as it is to ensure the safety of customers and local residents (section The objective is to have no fatalities on facilities operated by Group subsidiaries, including the Rubis Terminal JV, and to reduce as far as possible the number of accidents liable to result in lost time for both subsidiary staff and external contractors. With regard to road traffic accidents (particularly on the African continent, where the accident rate is high), each subsidiary is responsible for implementing the instructions and training plans needed to reduce, as far as possible, the rate of accidents recorded in line with local constraints. OCCUPATIONAL HEALTH AND SAFETY  



A proactive policy on health and safety at work has been implemented. It covers both the prevention of occupational accidents and the prevention of occupational and non-occupational illnesses.




Beyond the generic risks inherent to any industrial activity, Rubis’ activities entail more specific risks in terms of health and safety at work, linked particularly to:


the intrinsic properties of products 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.



Measures taken


Rubis’ Code of Ethics sets out a general framework for the Group’s safety culture, which requires all employees to act responsibly when performing their duties, comply with the health, safety and environmental protection procedures on site, and pay particular attention to compliance of all parties (colleagues, suppliers, external service providers, etc.). On this basis, a quality health, safety and environmental (QHSE) policy has been devised by Rubis Énergie and the Rubis Terminal JV to protect the physical integrity of their workers and minimize the impacts of any major accidents.


Since 2015, variable compensation for Group General Management includes a criterion relating to the accident rate (frequency rate of occupational accidents per million hours worked), underscoring its commitment and involvement in safety issues.


Occupational accidents and operator safety


To guarantee the maximum level of safety for operators at Group sites, each entity is responsible for holding training sessions for external operators on the risks generated by the facilities and the products handled within said facilities. For example, Rubis Énergie has set itself the additional objective of maintaining a level of training that will enable it to the level of HSE performance of its employees.


The Rubis Terminal JV, whose operational teams already receive training on the subject, achieved a rate of 100% of employees at the head offices in each country having attended an HSE risk awareness training course, which is also part of the training for all new employees hired.


Moreover, prior to operating in a facility, external service providers must also approve a safety plan (sometimes called a prevention plan or safety protocol) describing the risks associated with the work, safety instructions and emergency procedures.


The target is to have no fatalities and to reduce the number of accidents likely to cause labor disruption as much as possible for both subsidiaries’ staff and for external service providers.


Occupational illnesses and health


The Group continues to pay close attention to risks relating to occupational illnesses and, for several years now, has offered ergonomic training to employees in at-risk positions.


Regarding other health risk factors, exposure measurement campaigns are conducted, notably by the SARA refinery, in particular, in relation to chemical products, noise and vibrations, Legionella and asbestos.


Regarding non-occupational illnesses, the Group is present in some countries experiencing pandemic situations. Aware of the role that companies can play in preventing these health hazards, all subsidiaries have implemented measures to combat the Covid-19 pandemic. In addition, awareness-raising and assistance programs have been developed in some subsidiaries, for example in the fight against AIDS (South Africa), the Ebola epidemic and malaria (Nigeria), plague (Madagascar), cholera (Haiti) and chikungunya (the Caribbean).


Lastly, private health coverage is taken out for employees to enable them to access healthcare (see section


Road safety


In the area of road safety, the Group is constantly seeking to improve outcomes in terms of road accidents associated with its activities, and in particular for Rubis Énergie and its subsidiaries. In addition to the application of the regulations applicable to the transportation of hazardous materials, additional measures are taken concerning road haulage. To avoid traffic accidents, some Rubis Énergie subsidiaries have decided to step up defensive driving training programs and to give specific instructions regarding local constraints such as no night driving in certain countries and/or random alcohol or drug testing.


Courses in defensive driving have been introduced in countries where this risk is heightened due to driving habits, distances, the poor quality of road infrastructure or the specific nature of the product transported. In 2020, 62% of drivers (employees and external) were trained in this way.




Furthermore, measures have been taken to modernize equipment (fleet of vehicles), notably in Haiti where, in 2018, a five-year action plan amounting to approximately US$17 million was put in place to replace 70 tank trucks belonging to carriers working for Dinasa. Some subsidiaries have rolled out on-board electronic assistance (France, Switzerland, and Portugal) and tracking systems (Nigeria, Bermuda, Jamaica, South Africa and Madagascar).


Training as a means of preventing risks


Given the risks associated with its activities, the Group is investing in training its employees in health, safety and the environment. Detailed data are provided in section 4.3.2.




Occupational accidents


The number of occupational accidents recorded by the Human Resources Departments of the subsidiaries (including the Rubis Terminal JV) was stable compared with the previous year (41 in 2020, compared with 42 in 2019). 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 and by improving QHSE procedures (see section 4.2), have gradually and significantly reduced the occupational accident frequency rate. The rate has fallen by more than 46% since 2015 at Rubis Énergie (9.9 in 2015, compared with 5.3 in 2019, per million hours worked) and by 35% at the Rubis Terminal JV (18.3 in 2015, compared with 11.9 in 2020). The frequency rate of 24.3 at Rubis SCA/Rubis Patrimoine corresponds to a commuting accident involving an employee who fell off his bicycle, which was not serious. The small number of employees in these entities (24) means that the rate rises sharply when a single accident with lost time occurs.


While the change in this frequency rate is a key monitoring indicator for the Group, the teams are working hard to ensure all accidents are reported, whatever their area of occurrence. The Group thus strives to ensure its reporting is as complete as required by European regulations. In addition to the analysis of the change in frequency rate, quality of reporting, which can lead to a rise, is thus also a key indicator of safety culture.


          Frequency rate of     Number of
  Number of     occupational accidents     occupational illnesses
  occupational accidents Of which number with sick leave (per Number of causing total and
  with sick leave > 1 day of fatalities million hours worked) occupational illnesses irreversible invalidity
  2020 2019 2020 2019 2020 2019 2020 2019 2020 2019
Rubis SCA/Rubis Patrimoine 1 0 0 0 24.3 0 0 0 0 0
Rubis Énergie (retail & marketing/ support & services) 31 30 0 1 5.3 4.7 0 3 1 0
TOTAL 32 30 0 1 4.9 4.5 0 3 1 0
Rubis Terminal JV 9 12 0 0 11.9 15.6 0 0 0 0
TOTAL INCLUDING THE JOINT VENTURE 41 42 0 1 5.5 5.8 0 3 1 0

NB: The reporting scope for this indicator covers 90.5% of employees (see methodological note, section 4.5).


There were no fatal accidents in 2020.


The rate of absenteeism due to occupational accidents and illnesses is still very low across the Group as a whole, standing at 0.09% in 2020 (0.15% including the Rubis Terminal JV). Annual fluctuations were largely due to certain long-term absences, which have a more pronounced impact on the figures of companies with few employees.




  2020 2019
Rubis SCA/Rubis Patrimoine 0.18% 0%
Rubis Énergie (retail & marketing/support & services) 0.09% 0.11%
TOTAL 0.09% NA
Rubis Terminal JV 0.22% 0.53%
*Days lost as a percentage of total working days per annum.


NB: The reporting scope for this indicator covers 90.5% of employees (see methodological note, section 4.5).


Occupational illnesses and health


No occupational illnesses were declared in 2020.





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




Where local residents live or exercise an activity close to sites, they can be exposed to any industrial risks that may occur. While most Seveso industrial sites are not located in urban areas and are only accessible to authorized persons, gas stations, which are accessible to the public, are often located in urban or suburban areas. However, the risk regarding gas stations is lower because the quantities of products stored there are limited.


Measures taken


All the measures described in the section on operational safety also protect the health and safety of local residents and customers. Depending on the sector in which they operate and the specific expectations of their customers, subsidiaries take various initiatives:


a demanding risk-prevention policy is in place in all subsidiaries, to protect all employees liable to be involved in the handling of products stored or distributed on or from its sites. This policy, which gives rise to substantial internal prevention and control systems is described throughout section 4.2.3, section 4.4.2 and in chapter 3, section 3.1;
the Seveso regulations, extremely stringent regarding health and safety obligations, are complied with by relevant European sites;
several subsidiaries have obtained ISO 9001 and 14001 certifications, others are in the process of obtaining certification (see section Recognition of this nature attests to commitments for the health and safety of individuals and respect for the environment;
a preventive maintenance and compliance program implemented in gas stations.


The quality of the customer relationship is a key element of the strategy of the subsidiaries, but also a critical factor in information relating to consumer health and safety. The resulting initiatives vary depending on the type of customer.




Vitogaz France has NF Service Relation Client (NF345) certification since 2015. Revised in 2018, NF Service Relation Client certification is based on international standards ISO 18295-1 & 2. A guide to best practice in customer relationship management, it takes due account of customer expectations and aims to guarantee constant improvements to service quality. For Vitogaz France, this promotion of excellence in the customer experience should help establish a long-lasting commercial relationship, deliver quality service over time, ensure that information transmitted is complete and clear, and act promptly to meet its commitments.