RUBIS - 2019 Universal Registration Document

4 CSR AND NON-FINANCIAL INFORMATION - Non-Financial Information Statement

4.1 Non-Financial Information Statement In accordance with European Directive 2014/95/EU transposed by order No. 2017-1180 and implementing decree No. 2017-1265, in this section Rubis publishes its Non-Financial Information Statement (Déclaration de Performance Extra-Financière-DPEF) presenting the principal risks relating to its activities. Detailed information on these risks appears in sections 4.2 to 4.4.

4.1.1 A SUSTAINABLE GROWTH MODEL A computer graphic showing Rubis’ business model can be seen in chapter 1, section 1.2 of this document. and the embracing of socially responsible conduct.

• rejection of all forms of corruption; • prevention of conflicts of interest and insider trading; • compliance with competition rules.

4.1.1.2 EMPOWERMENT AND FREEDOM

BUSINESSES ORGANIZED INTO 3 DIVISIONS

4.1.1.1

OF INITIATIVE: PEOPLE AT THE HEART OF THE ORGANIZATION

4.1.1.3 AN INVOLVED

MANAGEMENT, AWARE OF ETHICAL, SOCIAL AND ENVIRONMENTAL RISKS

As an independent player in the downstream petroleum and chemicals industry, operating in some 40 countries across Europe, the Caribbean and Africa, Rubis is structured around 3 divisions: • the storage of liquids (petroleum and chemical products, fertilizers, edible oils and molasses) on behalf of a diversified industrial client base (Rubis Terminal); • the distribution of petroleum products (fuels, LPG and bitumen) (Rubis Énergie); • the support and services activity , in support of the distribution activity: refining, trading-supply and shipping (Rubis Énergie). Rubis’ development strategy is based on unique market positioning, a robust financial structure and a dynamic acquisition policy. However 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

In keeping with its motto: “The will to undertake, the corporate commitment”, Rubis puts People at the hear t of its organization. Empowering the individual women and men 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, everywhere. In the countries where it operates, 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, details of which are contained 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;

The CSR polic y implemented by the s ub s i d ia r i e s i s ove r s e e n by Rub i s’ Management. A portion of the Managing General Partners variable compensation is linked to ethical, social and environmental criteria (see chapter 5, section 5.5.1.1.3), which are also included in guidelines for Senior Managers of subsidiaries. Rubis’ Management draws up polic y guidelines and monitors both their relevance and their effectiveness. The CSR policy is then implemented jointly by the Group’s functional departments (legal, compliance, finance, operations, HSE, HR etc.). These departments have local contacts in each area of business. Lastly, the Rubis Account s and Risk Monitoring Commit tee monitors the analysis of the Group’s ethical, social and environmental risks, as well as the corrective measures taken to prevent such risks (see chapter 5, section 5.3.7.1).

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