4.1 Non-Financial Information Statement


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

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


4.1.1 A model for sustainable growth


A diagram showing the Group's business model is available in chapter 1, section 1.2 of this document. ACTIVITIES STRUCTURED AROUND TWO DIVISIONS AND A JOINT VENTURE


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


retail & marketing of petroleum products (fuels, liquefied gases and bitumen);
support & services in support of the distribution activity: trading-supply, shipping and refining.


A bulk liquid storage business (petroleum and chemical products, biofuels, fertilizers, agrifood products) on behalf of diversified industrial customers is also carried out by the Rubis Terminal JV.


Rubis’ development strategy is based on specialized market positioning, a robust financial structure and a dynamic acquisition policy. It also incorporates non-financial objectives that allow the Group to pursue sustainable growth in addition to these commercial and financial aspects. The regularity of the teams’ performance stems from a corporate culture that values the spirit of entrepreneurship, flexibility, accountability and the embracing of socially responsible conduct. Rubis conducts its activities in keeping with a CSR approach that contributes to the United Nations’ Sustainable Development Goals (SDG). EMPOWERMENT AND FREEDOM OF INITIATIVE: PEOPLE AT THE HEART OF THE ORGANIZATION


In keeping with its motto: “The will to undertake, the corporate commitment”, Rubis puts people at the heart of its organization. Empowering the individual men and women who contribute to its activities means promoting freedom of initiative as well as the ethical, social and environmental values that Rubis wishes to see respected by everyone.


Across its entire scope, the Group aims to act with professionalism and integrity. This requirement safeguards against any wrongdoing that could be harmful to the Group, to employees, to business relations or to any other external public or private stakeholder, and is reflected in the following principles, detailed in the Rubis Group Code of Ethics (see section 4.4.1):


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


(1) Including, in accordance with the regulations for this Non-Financial Information Statement, the activities of the Rubis Terminal JV, in which Rubis SCA holds a 55% stake and over which it lost exclusive control on April 30, 2020. The data of the Rubis Terminal JV are presented as follows in this Non-Financial Information Statement: environmental data presented at 100% and Group share (55%), Bilan Carbone® data at 55% in accordance with official methodologies, social/health and safety data at 100%, societal data at 100%. For further information, please refer to the methodological note in section 4.5 of this chapter.


The CSR policy is driven by Rubis SCA’s Managing Director, appointed in 2020, in conjunction with the General Management. She is supported by the CSR & Compliance Department, which is responsible for laying down the policy guidelines and leading the approach, in coordination with the various departments involved (Climate, HSE, Human Resources, Legal, and Social Engagement).


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


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


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


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


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



The Group aims to accelerate its trajectory, and took major initiatives to consolidate the foundations of its CSR approach in 2020. They included:


the creation of a Climate Committee to support the Group’s strategic thinking on this subject, and a Climate & New Energies team that coordinates the operational efforts of Rubis Énergie’s subsidiaries (see section;
setting a target for the reduction of CO2 emissions related to Rubis Énergie’s operations (see section;
setting targets for the number of women in management bodies (see section and chapter 5, section 5.2.3);
the implementation of a digital CSR reporting solution to make the reported data more reliable and to better manage its CSR strategy. As some of the data have been made more reliable, discrepancies may be observed in relation to the data reported for 2019. Any such issues are addressed in explanatory notes.


In 2021, the Group plans to finalize its first multi-year CSR roadmap, which will cover climate, social, environment and compliance issues. It will be rolled out in the subsidiaries, which will adapt it to their local challenges.




Rubis SCA wishes to continue its transparency efforts and to interact more proactively with non-financial rating agencies. MSCI renewed Rubis’ AA rating on December 14, 2020. Rubis is also included in the Ethical Sustainability Index (ESI) Excellence Europe.


Lastly, the Group is currently preparing its response to the 2021 CDP Climate Change questionnaire.





The use by Rubis in this document of any data produced by MSCI ESG Research LLC or its affiliates (“MSCI”), and the use of MSCI logos, trademarks, service marks or index names herein, do not constitute a sponsorship, endorsement, recommendation, or promotion of Rubis by MSCI. MSCI services and data are the property of MSCI or its information providers, and are provided ‘as-is’ and without warranty. MSCI names and logos are trademarks or service marks of MSCI.



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


In accordance with Articles L. 225-102-1 and R. 225-105 of the amended French Commercial Code, Rubis has conducted a new three-stage analysis of its main non-financial risks (section, which identified 13 main risks around four priority issues (section THREE-STEP RISK ANALYSIS




Risk mapping, prepared by the Group’s functional departments (CSR, HSE, Operations, Finance, Legal, etc.), is completed locally by the operating subsidiaries, analyzed on a consolidated scale and then reported to the Rubis SCA Managing Partners and presented to the Accounts and Risk Monitoring Committee. It is used to assess (impact and probability) events likely to have a significant adverse impact on the Group’s business, financial position, reputation or outlook, on a scale of one to five. These risk maps are updated annually in line with changes in the Group’s business lines and operations, as well as the observations of employees, stakeholders and the Accounts and Risk Monitoring Committee (see chapter 3, section This process is part of a co-construction approach aimed at achieving a shared diagnosis.







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


Existing frameworks (the SASB Materiality Map® in particular), segment benchmarks (IPIECA) or those of trade organizations/associations (Medef, ORSE, C3D) and CSR publications from other companies were used to assess the most material risks to which the business segment is exposed. The concerns voiced by stakeholders (investors, ESG analysts, civil society) were also analyzed to weight the risk analysis and to take into consideration the importance of these risks to them.





Regular dialog with communities

Committed to local populations, the Group values dialog with stakeholders and its role in promoting dynamic activity in the regions where it operates, as much at the economic and employment levels as in the area of “living together.”


Dialog with stakeholders takes place, depending on the capacity or mission of said stakeholders, at local level (subsidiary), at the level of entire divisions or directly with the parent company (Rubis SCA) (see section 4.4.2).


Rubis also engages in an active and targeted sponsorship policy, via its endowment fund, Rubis Mécénat, and through its subsidiaries’ local initiatives. Most of its initiatives are focused on education and health (see section




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


The result of this risk analysis was validated by Rubis Énergie’s Senior Management and then by Rubis SCA’s General Management and the Risk Committee.


The Rubis Terminal JV has followed the same risk assessment process, validated by its Senior Management. The completion of the sale of 45% of the capital of the storage activity to an infrastructure fund in 2020 is unlikely to modify, at this stage, the analysis of CSR risks relating to the joint venture, whose business is unchanged. The periodic review of this analysis will now be presented by the joint venture to its shareholders at meetings of its Board of Directors, which will validate the objectives. THIRTEEN RISKS GROUPED AROUND FOUR KEY CHALLENGES


The analysis of CSR risks highlights 13 main risks relating to the retail & marketing and support & services activities (Rubis Énergie) and the Rubis Terminal JV(1). These risks are grouped around the following four challenges:


limiting the environmental impact of activities;
protecting the health and safety of people working on the sites, as well as local residents, and the safety of facilities;
attracting, developing and retaining talents;
business ethics demonstrated by operating responsibly and with integrity.
Challenges Main risks Monitoring indicators Contribution to SDGs
Limiting our
environmental impact
 Water and soil pollution (section  Number of accidental discharges > 200 liters
 Atmospheric emissions (section  Pollutant emissions from major industrial sites (NOX , VOC, SO2 )
 Climate change (section  Emission reduction objective
 Carbon intensity indicators for activities

 Use of resources (section
 Preservation of water resources


 Used/treated water
Operating in
a safe environment
•  Operational safety (section  Zero major industrial accident target

•  Personal safety (section 
  Health and safety at work


 Frequency rate of occupational accidents and zero fatalities target
  Health and safety of customers and local residents  Certifications


(1) As far as possible, the description of the risks relating to the Rubis Terminal JV is presented separately from the risks relating to the retail & marketing and support & services activities. However, for the sake of clarity for the reader and to limit repetition, some risks are not presented in separate paragraphs as they are similar and subject to similar management measures.


Challenges Main risks Monitoring indicators Contribution to SDGs
Attracting, developing and retaining talents  Diversity and equal opportunity
(section 4.3.1)
 Objectives for the representation of women
 Skills development
(section 4.3.2)
 Percentage of employees receiving training (particularly safety training)
 Quality of life at work (section 4.3.3)  Turnover and absenteeism rate for non-occupational illnesses
 Employees’ involvement in the Group’s value creation (section 4.3.4)  Wage increases and other compensation measures
Working responsibly and with integrity  Fighting corruption (section  Qualitative indicator on the anti-corruption program
 Responsible purchasing(section  Inclusion of a CSR criterion in all Rubis Terminal JV calls for tender by 2020
 Regional, economic and social impact(section 4.4.2) •  Indirect jobs
   Number of beneficiaries of community investment




Appropriate procedures to deal with the issues identified as part of the risk analysis are implemented.


Health and safety risks for individuals operating on the sites and local residents, as well as risks relating to the environmental impact of the activities, are subject to enhanced preventive measures, implemented under regular inspection and major investment programs (see section 4.2).


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


Other issues, such as ethical and corruption risks, are also subject to specific policies and procedures drawn up as part of the continuous improvement process (see section 4.4).


Details of the main risks relating to the Non-Financial Information Statement, as well as to related policies and indicators, appear in sections 4.2 to 4.4 of this document. The main risks are identified using the pictogram hereafter:  Other challenges, which were not identified as priority risks in the risk analysis but which are nevertheless considered important for both the Group and its stakeholders, or which must be disclosed in accordance with current regulations, are also included in sections 4.2 to 4.4.


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



4.1.3 Comparability, reliability and control of social and environmental information


The comparability and reliability of information stem primarily from the standardization of methods used for reporting detailed employee-related and environmental data, as described in the methodological note (see section 4.5).


The information reported is checked as part of verification procedures and analyses. Internal audits relating to certain non-financial information (ethics, anti-corruption) are also being carried out.


To facilitate the reading of this chapter, a cross-reference table with the provisions of the French Commercial Code is provided in section 4.5.4.