4.5 Methodological note  


This section contains a methodological note and a cross-reference table designed to facilitate understanding of the CSR information. Accordingly, it has been decided to present the CSR reporting scope and methods for reporting CSR information and the key definitions contained in the internal standards for reporting employee and environmental information. These publications will enable the reader to have a more precise understanding of the field of application and the relevance of each piece of information.


4.5.1 CSR scope


As of 2020, the rules relating to the entry and exit dates of an entity are defined as follows:


any acquisition of an entity (external to the Group) made during a given year is included in the CSR reporting scope as of January 1 of the subsequent year. This rule allows for better integration of HR processes, safety standards and Group commitments;
unless otherwise indicated, CSR data for an entity sold or liquidated during the fiscal year is excluded from CSR reporting when it is removed from the financial scope. ENVIRONMENTAL DATA


The reporting scope for environmental information corresponds to the Group’s financial scope, unless expressly stated otherwise. Controlled companies are fully consolidated, with the exception of data relating to the Bilan Carbone® (see below).


Environmental data for the Rubis Terminal JV, which is jointly controlled by Rubis SCA and its partner and accounted for by the equity method, are presented at 100% and in accordance with the percentage of capital held by Rubis SCA (55%).


The exact scope of environmental data reporting may vary according to the environmental indicators, depending on their relevance and the accounting methods applied.


Environmental data is published by activity. Figures are published for the activities with the most significant environmental impacts (support & services activities at Rubis Énergie, as well as the activities of the Rubis Terminal JV).


The CO2 emissions of the Group’s activities and the CO2 emissions related to the use by customers of products sold for final use have been evaluated and are published for all the entities in the financial scope, with the exception of Rubis SCA/Rubis Patrimoine, due to its immaterial impact (24 employees, no operating activity). These data are proportionally consolidated. SOCIAL DATA


Unless otherwise stated, the reporting scope for social information corresponds to the Group’s financial scope. Controlled companies are fully consolidated.


The social data of the Rubis Terminal JV, jointly controlled by Rubis SCA and its partner and accounted for by the equity method, are presented at the rate of 100%.


The information is presented separately for Rubis SCA/Rubis Patrimoine, Rubis Énergie (retail & marketing and support & services activities) and for the Rubis Terminal JV and/or by region.


The exact scope of social data reporting may vary according to the social indicators, depending on their relevance and the accounting methods applied


For the Rubis Énergie subsidiaries Rubis Energy Kenya, Gulf Energy Holdings Ltd, Rubis Energy Ethiopia, Rubis Energy Rwanda, Rubis Energy Uganda and Rubis Energy Zambia, data relating to occupational accidents and absenteeism have been excluded. Work is underway to make these more reliable and to integrate them into the reporting scope. The reporting scope for these indicators accordingly covers 90.5% of the headcount. COMMUNITY/ETHICAL DATA


The reporting scope for community information corresponds to the Group’s financial scope. The applicable reporting method is proportional consolidation.



4.5.2 Data reporting methods


The production of CSR information is carried out jointly between the subsidiaries and the parent company. It is subject to systematic internal audits.


For several years, the Group has been running a process to identify and map significant environmental risks. The information used to identify, manage and monitor these risks is described in chapters 3 and 4 of this Universal Registration Document. COMPARABILITY AND RELIABILITY OF INFORMATION


Reporting protocols have been designed to ensure the comparability of results between Group entities.


However, environmental performance is only comparable at the level of a given activity.


As the strength of the Group’s business has resulted in significant external growth, the CSR reporting scope also changes on a regular basis, and therefore does not allow for true comparability of data across several years in the absence of ratios.


In partnership with the Management of the subsidiaries concerned, a set of reporting standards for environmental and employee-related information was drawn up. These standards provide a precise definition for each data item mentioned in the information reporting protocols, with the aim of reducing the risk of differences in interpretation of terminology. CONTROL MEASURES


The data collected are subject to consistency checks at the local level and then by the functional departments of Rubis Énergie or the Rubis Terminal JV and by Rubis SCA’s CSR & Compliance Department. Consistency between the financial scope and the social data reporting scope is ensured by Rubis SCA’s CSR & Compliance Department. CHANGE OF METHODOLOGY


Unless otherwise provided, methodology cannot be changed after the start of the information reporting process within Group entities. Changes of methodology are prepared and/or overseen by Rubis SCA’s CSR & Compliance Department after consultation with Rubis Énergie and the Rubis Terminal JV. They take into consideration, where applicable, observations made by stakeholders on the relevance and quality of the definitions contained in the framework. METHODOLOGICAL LIMITATIONS


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


the absence of harmonization of national laws, and in particular the particularities of the labor laws of certain countries;
the heterogeneity of the data managed in the Group’s subsidiaries;
changes in definition that may affect their comparability;
practical methods of collecting data;
the availability of source data as of the reporting date.


Some indicators should be interpreted with caution, particularly the averages, since they are global data that require a more detailed analysis at the level of the geographical areas, countries and professions concerned. DATA REPORTING TOOLS


With the exceptions mentioned below, the data are reported by the operating entities via the reporting software implemented by the Group in 2020.




As the various Group activities have specific environmental impact (see section 4.2.1), the data calculation methods may vary according to the activity. The definitions are, however, standardized at the level of each division, within “standards for reporting environmental data” that has been integrated into the Group’s CSR data reporting software.


Rubis Énergie’s data are reported by the entities in the reporting software, with the exception of data from SARA (refinery), which is the subject of a specific report issued by its HSE teams, and data relating to the number of Seveso sites transmitted on a consolidated basis by headquarters.


Data from entities within the scope of the Rubis Terminal JV are reported on a consolidated basis by the Operations Department of the Rubis Terminal JV for inclusion in the Group’s reporting software.




For all entities, the reporting protocols dealing with social data include similar information based on the standardized definitions set out in the “standards for reporting social data” that has been integrated into the Group’s CSR data reporting software.




Community/ethics data are reported via the reporting software, based on standardized definitions applicable to all entities and partly produced by Rubis SCA (Group ethics policy). With regard to charitable and sponsorship initiatives, as well as dialog with stakeholders and commitment to local areas, the information collected may come from public communications by subsidiaries and/or a community information reporting protocol at Rubis Terminal.




4.5.3 Definitions


Terms   Definitions
1) Environmental information
Bilan Carbone®   See definition of “Greenhouse gases (emissions)”.
Volatile organic compounds (VOC)  

Rubis Énergie

Consolidated VOC emissions are those reported in respect of the year (with a one-year lag) on all French sites subject to a reporting requirement under the regulations in force. In the refining activity, measurements of VOC emissions are the subject of a biennial sniffing campaign conducted by an accredited independent body.

Rubis Terminal JV

Consolidated VOC emissions are those reported in respect of the fiscal year (with a one-year lag) on all French sites and on the Antwerp, Rotterdam and Dörtyol (Turkey) sites.

Energy consumption  

There is no imperative legal definition in this regard.

Rubis Énergie

The Rubis Énergie distribution activities are for the most part not energy-intense. They therefore do not require that an overall measuring system be set up at division level. In the refining activity, the refinery uses part of the crude oil stored to produce energy (electricity and steam). An internal database monitors the site’s real-time power generation and consumption.

Rubis Terminal JV

The data are the sum of the quantities of automotive or heating fuels or electricity purchased, converted into GJ, with the exception of fuel used by administrative staff (headquarters and site management) for transportation.

Hazardous waste  

Rubis Énergie

Most distribution activities do not produce hazardous waste. They are not as such required to demonstrate the establishment of an overall measuring system at divisional level. In the refining activity, waste amounts to the values declared during the year (time lag of one year).

Rubis Terminal JV

The amounts of waste are those reported in respect of the year (with a one-year lag) on all French sites and on the Antwerp, Rotterdam and Dörtyol (Turkey) sites.

Sulfur dioxide (SO2 )   SO2 emissions are monitored in the Rubis Énergie refining activity. Such emissions are evaluated through a calculation file by the refinery’s Production Technical Office. The flow of SO2 is in turn calculated based on the fuel source (based on the reconciled materials balance) and sulfur content of the fuels analyzed by the refinery’s laboratory. The SO2 concentration is deduced on the basis of the gas volume calculated using the net calorific value (NCV) of each fuel. The calculation is checked annually by an accredited independent body.
Water used  

This is standing water (e.g. reservoirs and lakes) or running water (e.g. rivers) above ground, sea water, rainwater, underground water and water from the distribution network used in the activities of the Group entity. Discharged water is abstracted water, plus some rainwater.

Rubis Énergie

Most Rubis Énergie distribution operations do not require recurrent use of large quantities of water in industrial processes.
In the refining activity, water consumption is measured on the basis of meter readings. The volume of water discharged corresponds to the value recorded by the meter at the exit of wastewater treatment.

Rubis Terminal JV

The amounts of water abstracted or discharged are those reported in respect of the year (with a one-year lag) on all French sites and on the Antwerp, Rotterdam and Dörtyol (Turkey) sites.

Greenhouse gases (emissions)   Only carbon dioxide (CO2) is assessed, as Group activities do not generally involve other greenhouse gases (Annex II of Directive 2003/87/EC). The CO2 emissions led to a Bilan Carbone® audit for which the scope is detailed in the “scope 1”, “scope 2” and “scope 3” definitions.
Suspended solids  

These are particles suspended in water, the nature of which depends on the activities carried out on the polluted site.

Rubis Énergie

Rubis Énergie’s regular activities generate little specific water pollution. In the refining activity, suspended solids are analyzed and evaluated by the laboratory of the refinery, then audited by a qualified independent body.

Rubis Terminal JV

Given the very broad scope of particles likely to come under the definition of suspended solids, Rubis Terminal retains only the compounds most representative of pollution that may be produced by its main activities. Data for the French sites are the only values reported to authorities; in other cases the values are those established for Group reporting.





Terms   Definitions
Nitrogen oxides (NOX)  

Rubis Énergie

To the best of our knowledge, Rubis Énergie’s retail & marketing activities do not produce any NOX. Therefore, an overall measuring system does not need to be set up at division level.
In the refining activity, NOX activities are evaluated through a calculation file by the refinery’s Production Technical Office. This is an estimate based on the emission factor of each fuel and the operating time of the DeNOX combustion turbines. The calculation is audited annually by a qualified independent body.

Rubis Terminal JV

NOX is calculated based on consumption of fuel over the fiscal year, excluding electricity. The fuel used by administrative staff (headquarters and site management) when traveling is not taken into account. Concentrations of NOX in fumes are considered in the calculation as being equal to the highest permitted level of emissions or, in the absence of an upper limit, 150, 200, 300 or 550 mg/Nm3 for boilers, depending on the fuel used, or 2 g/kWh for engines, in the absence of representative measurements.

Industrial site  

Rubis Énergie

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

Rubis Terminal JV

Storage sites for fuels, chemical products, bitumen, food products and liquid fertilizers.

Scope 1   Direct emissions from fixed and mobile facilities within the organizational scope, i.e. emissions from sources held or controlled by the organization, such as combustion generated by own industrial facilities or trucks, industrial processes, etc.
Scope 2   Indirect emissions from the generation of electricity, heat or steam purchased for the organization’s activities.
Scope 3   Other emissions indirectly caused by the organization’s activities that are not accounted for under scope 2 but are linked to the entire value chain such as the purchase of raw materials, services or other products, employee travel, upstream and downstream transportation of merchandise, management of waste generated by the organization’s activities, use and end of life of products and services sold, capitalization of goods and production equipment, etc. The following items are included in scope 3 of Rubis’ Bilan Carbone®: purchases of goods and services, fixed assets, upstream energy, upstream and downstream transportation of goods, waste generated, use of products sold. For purchases of goods and services for investments, the Rubis Terminal JV has counted the annual depreciation of this value in 2020 and not the values purchased.
2) Social information
Occupational accident  

An accident affecting an employee of a Group entity, where a medical certificate or investigative findings establish that the accident was directly caused by the employee’s work at the entity concerned, and which leads to labor disruption (total or partial).


•  for the Group’s entities operating in France, the information includes employees’ commuting accidents occurring off-site, in accordance with applicable law;

•  for the Group’s entities operating outside France, the inclusion or exclusion of employees’ commuting accidents depends on local laws.

Job categories  

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

Non-executives: non-executive and non-senior executives employees.

Executives: employees:

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

•  with the status of cadre (executive) under French law.

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

Management Committee   A Management Committee is a Committee composed of the main Directors or Managers of a Group entity, meeting regularly to make strategic decisions and monitor the entity’s results.
Apprenticeship contract or occupational training contract   A contract between a person following an academic training course (at university or in a training center) and a Group entity, in principle, for a fixed term of six months or more (except where there is an exception provided for in the applicable legislation), entitling them to call themselves an employee of the signatory company.
Unilateral decision   A decision taken unilaterally by the Management of the Group entity concerned, after discussion with the employee representatives, if applicable.
Number of days worked per year   The total number of working days per year, which is used as the basis for the calculation of absenteeism rates, results from the conversion of the average number of hours worked each day, and may vary slightly from one subsidiary to another, taking into account applicable laws and the nature of the activities carried out locally.
Number of hours worked per year   The number of hours worked per year may be calculated on the basis of a daily average established under prevailing law.
Departure by mutual agreement   The departure of an employee of a Group entity (including those on trial periods) as a result of an amicable agreement between the two parties that was not imposed by one of the parties on the other. Accordingly, departures by mutual agreement are not considered as dismissals or resignations by the applicable legislation.



Terms   Definitions

This category includes:

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

•  in countries where this legislation applies: apprenticeship contracts and vocational training contracts.

This category does not include:

•  internship contracts;

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

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

Expatriate employees or seconded employees as well as employees involved in intra-group mobility should be accounted for in the entity in which they effectively and usually work.

Absenteeism   Percentage of days of absence (absences due to non-occupational illness or accidents, absence due to occupational illness or occupational accidents, unjustified absences) in relation to the total number of days worked per year.


4.5.4 Cross-reference table


The information contained in this chapter was compiled in response 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 have been treated, and information provided, in view of their relevance to the Group’s businesses.


Topics   or section      
Business model   1.2      
Overview of main non-financial risks relating to the Company’s activity      
Description of policies and results          
Environment (general policy, pollution, circular economy, safety)   4.2      
Social (employment, equal treatment, work organization, training, health and safety, social dialog)   4.3      
Respect for human rights      
Fighting corruption      
Fighting tax evasion      
Climate change, use of goods and services      
Societal commitments          

•  Sustainable development

•  Circular economy

•  Food waste

•  Fighting food insecurity

•  Respect for animal welfare

•  Responsible, fair and sustainable food

•  Collective agreements and impacts

•  Fighting against discrimination and promoting diversity

•  Measures to support disabled people



Not included

Not included

Not included

Not included




Given the nature of its activities, Rubis does not believe that these topics constitute a material risk and that there is any need to expand on them in this document
Specific information (Article L. 225-102-2 of the French Commercial Code)          
•  Technological accident risk prevention policy implemented by the Company and 4.2.3      
•  Ability of the Company to cover its civil liability in respect of property and persons due to the operation of such facilities      
•  Means provided by the Company to manage the compensation of victims in the event of a technological accident involving its liability      
Methodological note   4.5      
Report of the independent third party on the information presented in the NFIS   4.6