Table of content:
- Severe impact risk mapping
- Action Principles
- Assessment procedures
- Awareness and training actions
- Whistleblowing mechanisms
- Monitoring procedures
- Report on implementation of the Vigilance Plan
Background and Group commitments
In accordance with Article L. 225-102-4 of the French Commercial Code, the vigilance plan (hereafter referred to as the “Vigilance Plan”) aims to set out the reasonable measures of vigilance put in place within the Group in order to identify the risks and prevent severe impacts on human rights and fundamental freedoms, human health and safety and the environment resulting from the activities of the Company and those of the companies it controls as defined in point II of Article L. 233-16 of the French Commercial Code, directly or indirectly, as well as the activities of subcontractors or suppliers with which it has an established commercial relationship, where such activities are linked to this relationship.
Total operates in over 130 countries in a variety of complex economic and socio-cultural contexts and in business areas that are likely to present risks that fall within the scope of the Vigilance Plan.
The One Total company project, which embodies the Group’s ambition to become the responsible energy major, is based specifically on Safety and Respect for Each Other, the two core values central to the Group’s collective principles. In addition to complying with applicable legislation in each country where the Group operates which most often aims at preventing severe impacts in the scope of Article L. 225-102-4 of the French Commercial Code, Total relies on structured frameworks and stringent risk management systems for the conduct of its operations.
The Vigilance Plan and its implementation are part of a dynamic process aimed at continual improvement of the Group’s practices with regard to the issues identified within each of the areas concerned.
Method and preparation of the Vigilance Plan
The Vigilance Plan covers the activities (hereafter referred to as the “Activities”) of TOTAL S.A. and its fully consolidated subsidiaries as defined in II of Article L. 233- 16 of the French Commercial Code (hereafter referred to as the “Subsidiaries”). Certain companies, such as Hutchinson, Saft Groupe and SunPower, have set up risk management and severe impact prevention measures specific to their organizations and activities; those measures related to Article L. 225-102-4 of the French Commercial Code are specified in the Group’s Vigilance Plan. In addition, for newly acquired companies, reasonable vigilance measures are intended to be implemented progressively during the integration phase of these companies into the Group systems. They do not therefore fall within the scope of the Vigilance Plan for 2018.
The Vigilance Plan also covers the activities of suppliers of goods and services with which TOTAL S.A. and its Subsidiaries have an established commercial relationship, where such activities are associated with that relationship (hereafter referred to as the “Suppliers”). In accordance with legal provisions, suppliers with which the Group does not have an established commercial relationship do not fall within the scope of the Plan.
The Vigilance Plan sets out the rules and measures which, as part of risk management systems, enable the Group to identify and prevent actual or potential severe impacts related to its Activities and to mitigate their effects thereof, as the case may be. It does not guarantee that the risks identified will not materialize. It reflects the responsible purchasing principles applicable to relationships with Suppliers, but is not aimed at replacing the measures in place at those Suppliers.
Dialogue with stakeholders
Total sets up dialogue procedures with its stakeholders at every level of its organization.
In accordance with the Group’s framework on societal matters, stakeholders are identified, mapped and prioritized according to their levels of expectations and involvement. This mapping is kept up to date. A structured dialogue with the stakeholders is established and maintained, initially at local level but also at the central level.
At the local level, Total has deployed since 2006 its internal Stakeholder Relationship Management (SRM+) methodology. This approach aims to list the main stakeholders of each Subsidiary and site (depots, refineries, etc.), to categorize them, to schedule consultation meetings to better understand their expectations, concerns and opinions. This approach then permits to define action plans to manage the impacts of activities and to take into account local development needs in order to build a long-term trusting relationship. This mechanism is used to explain the Group’s Activities to communities and other stakeholders, and to pay particular attention to potentially vulnerable local populations. It has been integrated in almost all the Subsidiaries. The system is supplemented by a network of mediators with local communities, deployed within the Exploration & Production segment to maintain a constructive dialogue with neighboring communities.
At the central level, the relevant departments of the Holding also ensure that dialogue is maintained with the Group’s stakeholders. For example, in 2018 upon publication of the Information Document on Human Rights, the Human Rights Department of the Civil Society Engagement Division consulted certain of its stakeholders on the risk map published in the 2017 Vigilance Plan. This consultation led to the conclusion that the mapping could thus be maintained.
Among these numerous stakeholders, Total maintains regular dialogue with the Group’s employees and their representatives who have a privileged position and role.
Severe impact risk mapping
The mapping work presented below was carried out using the Group’s existing risk management tools. This work was supplemented with regard to Suppliers by a mapping of the risks related to procurement, by category of goods and services, on the basis of questionnaires completed by the managers of each purchasing category.
Human rights and fundamental freedoms
The risks of severe impacts on human rights and fundamental freedoms have been identified in accordance with the criteria set out in the UN Guiding Principles Reporting Framework, namely the scale, scope and remediability of the impact.
This identification work was carried out in 2016 in consultation with internal and external stakeholders. The process included in particular workshops with representatives of key functions within the Group and Subsidiaries operating in sensitive contexts or situations particularly exposed to risks related to human rights and fundamental freedoms, and a series of interviews with independent third parties (GoodCorporation, International Alert and Collaborative Learning Project).
As a result, the following risks of severe negative impacts on human rights and fundamental freedoms were identified:
- forced labor, which corresponds to any work or service which people are forced to do against their will, under threat of punishment; as well as child labor, which is prohibited for any person aged under 15, or under 18 for all types of work deemed hazardous in accordance with International Labour Organization standards;
- discrimination, characterized by unfair or unfavorable treatment of people, particularly due to their origin, sex, age, disability, sexual and gender orientation, or membership of a political or religious group, trade union or minority;
- non-compliance with fair and safe working conditions, such as for example the absence of employment contracts, excessive working hours or lack of decent compensation;
- restriction of access to land by neighboring local communities, resulting from the Group having, for some of its projects, temporary or permanent access to the land that might result in the physical and/or economic displacement and relocation of these groups;
- impacts on the right to health of local communities, such as noise and dust emissions and other impacts generated by the Activities that might have consequences for the health of local communities, their means of subsistence and their access to vital services such as drinking water, for example; and
- the risk of disproportionate use of force, when intervention by government security forces or private security companies might be necessary to protect the Group’s staff and facilities.
Safety, health and environment
The Group defines the risk of a severe impact on safety, health or the environment as the probability of Total’s Activities having a direct and significant impact on the health or safety of employees of Group companies, employees of external contractors(1) and third parties, or on sensitive natural environments(2). This risk can materialize gradually or suddenly.
Total has developed safety, health and environment risk assessment procedures and tools applicable to operate its Activities, such as analyses performed regularly at various levels (Group, activities and/or industrial sites):
- prior to investment decisions in industrial projects of the Group, acquisition and divestment decisions;
- during operations;
- prior to releasing new substances on the market.
These analyses have highlighted the following risks of severe impacts:
- the risks to the safety of people and to the environment resulting from a major industrial accident (on an offshore site, onshore site or during the transport of products). These risks are, for example, an explosion, fire or leakage, resulting in death or injury and/or accidental pollution on a large scale or at an environmentally sensitive site;
- the risks to the safety of people and to the environment related to the physical characteristics of oil and gas fields, particularly during drilling operations, which can cause blow outs, explosions, fires or other damages;
- the risks to the safety of people and to the environment related to the overall life cycle of the products manufactured, and to the substances and raw materials used; and
- the risks associated with transportation, for which the likelihood of an operational accident depends not only on the hazardous nature of the products handled, but also on the volumes, the length of the journey and the sensitivity of the regions through which they are transported (quality of infrastructure, population density, environment).
Climate change is a global risk for the planet and results from various human actions such as energy production and consumption. As an energy producer, Total seeks to reduce its direct greenhouse gas emissions resulting from its operated Activities. In addition, Total implements a strategy to tackle climate change challenges and reports on this in details, notably in its statement of non-financial performance (refer to the “Climate” section), in accordance with Article L. 225-102-1 of the French Commercial Code.
(1) Refer to the "People's health and safety" section (Preventing occupational accidents).
(2) Sensitive natural environments include, in particular, remarkable or highly vulnerable natural areas, such as the Arctic, and/or areas covered by regulatory protection (integral nature reserves, central park areas, biotope orders in France, etc.), as well as areas covered by significant regulatory protection such as Protected Area Categories I to IV as defined by the International Union for Conservation of Nature (IUCN).
The Group has frameworks that set out the Action principles to be followed in order to respect the Group’s values and prevent severe impacts on human rights and fundamental freedoms, human health and safety and the environment (the “Action Principles”). When the legal provisions applicable to the Activities provide less protection than the Group’s Action Principles, Total strives under all circumstances to give precedence to the latter, while seeking to ensure that it does not infringe any applicable mandatory public policy.
Code of Conduct
Total’s Vigilance Plan is based primarily on the Group’s Code of Conduct(3), which specifies the Group’s values, including the two core values of Safety and Respect for the Other, particularly declining in the areas of respect for human rights, the environment and the health and safety of persons.
The Code particularly sets forth the Group’s compliance with the following international standards:
- the principles of the Universal Declaration of Human Rights;
- the United Nations Guiding Principles on Business & Human Rights;
- the principles set out in the International Labour Organization’s fundamental conventions;
- the principles of the United Nations Global Compact;
- the OECD Guidelines for Multinational Enterprises; and
- the Voluntary Principles on Security and Human Rights.
The Code of Conduct is aimed at all employees and external stakeholders (host countries, local communities, customers, suppliers, industrial and commercial partners and shareholders). It was updated in December 2018.
(3) SunPower, a company listed on the NASDAQ in the United States and in which Total has a majority interest, has a Code of professional conduct specific to the company that sets forth its values and the ethical principles with which all employees, as well as suppliers and partners, must comply. It covers subjects relating to compliance, integrity and protection of the company’s assets, as well as certain issues relating to human rights, fundamental freedoms, human health and safety and environment.
Safety Health Environment Quality Charter
The Group ensures that it complies with strict safety, security, health and environment standards in the performance of its Activities. The Safety Health Environment Quality Charter sets out the principles that apply to the conduct of its operations in all of the countries where it operates.
As such, the Group’s Subsidiaries(4) implement a framework incorporating occupational health and safety, security, societal commitment and environment as well as associated management systems (Management And Expectations Standards Towards Robust Operations, MAESTRO).
With regard to safety at work, the Golden Rules, which were established on the basis of feedback and restructured in 2017 into a set of “dos and don’ts”, apply to all Group entities, employees and Suppliers on site. Each individual must ensure that they are adopted, strictly followed and monitored on the ground. Each individual is also authorized to use his or her “Stop Card” and stop any work under way in particular in the case of non-compliance with any of these rules.
Fundamental Principles of Purchasing
The relationship between the Group and its Suppliers is based on adherence to the principles set forth in the Code of Conduct and in the Fundamental Principles of Purchasing(5).
The Fundamental Principles of Purchasing specify the commitments that Total expects from its suppliers in the following areas: respect for human rights at work, health protection, safety and security, preservation of the environment, prevention of corruption and conflicts of interest and fraud, respect for competition law, as well as the promotion of economic and social development.
The requirements specified by this document must be communicated to Suppliers and be included in or transposed into agreements.
(5) Saft Groupe and SunPower have defined fundamental principles of purchasing specific to their activities (for example, SunPower Supplier Sustainability Guidelines).
Internal control framework
At the Group, business segment and Subsidiary level, internal controls are based on specific procedures for organization, delegation of responsibilities and staff awareness and training, based on the framework of the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Total has a Group reference framework that is supplemented by a series of practical recommendations and feedback. Like the Group’s organization, this framework has a three-level structure: a Group level, with the REFLEX Group framework and the technical framework set out by the Group Technology Committee, frameworks for each business segment, and a specific framework for each significant operational entity.
The Group’s organization is structured around three main levels: Corporate, business segments and operational entities. The Action Principles are driven by the Executive Committee. The People and Social Responsibility Division headed by a member of the Executive Committee coordinates the Group’s action in the area of Human Resources, health – safety – environment (HSE), security and societal commitments. Purchases of goods and services are under the authority of an entity in the Total Global Services Branch which also reports to the Executive Committee member responsible for this division. This organization aims to support operational managers in the implementation of the Action Principles. Each level is involved in and accountable for identifying and implementing the reasonable vigilance measures deemed appropriate.
The Ethics Committee is a central structure representing all of the Group’s business segments. All its members are Group employees who collectively have good knowledge of its activities and have demonstrated the independence and impartiality necessary for carrying out their duties.
The Ethics Committee is the guarantor of compliance with the Code of Conduct and ensures its proper implementation. It is assisted in its work by the relevant departments, as well as by a network of local Ethics Officers. The Chairperson of the Ethics Committee reports to the Chairman and Chief Executive Officer of Total. The Chairperson submits an annual report to the Executive Committee and the Governance and Ethics Committee of the Board of Directors.
Employees and stakeholders can refer any breach of the Code of Conduct to the Ethics Committee at any time, in accordance with the procedure described in point ”Whistleblowing mechanisms”. The members of the Ethics Committee are subject to a confidentiality obligation.
Human Rights Committee and Department
The Human Rights Committee is made up of representatives from different departments (safety, purchasing and societal commitment in particular) and business segments. It meets several times a year and coordinates actions relating to human rights and fundamental freedoms led by the various business segments and Subsidiaries, in line with the Human Rights roadmap approved by the Executive Committee.
The Human Rights Department, within the Civil Society Engagement Division, supports the Group’s operational managers with its expertise in implementing the Action Principles relating to human rights and fundamental freedoms.
Occupational Health, Safety and Environment Division
Since 2016, a single HSE Division combines the Group’s Occupational Health, Safety and Environment functions. Its role is to implement a strong and unified HSE model.
Within the division, the HSE Departments of the Exploration & Production, Gas, Renewables & Power, Refining & Chemicals and Marketing & Services segments are in particular responsible for supporting the implementation of the Group’s HSE policy. Specific expert units set up in 2016 cover the following areas: major risks, human and organizational factors, environmental and societal issues, transportation and storage, crisis management and pollution prevention, standards and legislation, audits and feedback.
Since January 1, 2017, a dedicated subsidiary, Total Global Procurement centralizes management of a large part of the Group’s goods and services purchasing(6), whether for categories of products or services specific to one business activity or categories shared between several business activities. In the Subsidiaries, purchasers implement framework agreements as well as manage local procurement.
A Responsible Purchasing Committee meets at least once a year and brings together the Management Committee of Total Global Procurement and the Civil Society Engagement (including the Human Rights Department), HSE and Legal Divisions as well as the Ethics Committee in order to monitor implementation of the Group’s Responsible Purchasing roadmap. The roadmap sets out the strategic direction of the Responsible Purchasing working group.
Furthermore, the Vetting department of Trading & Shipping defines and applies the selection criteria for the tankers and barges used to transport the Group’s liquid petroleum or chemical products and gas products, in order to ascertain their technical qualities relative to the best international standards, the crews’ experience and the quality of the ship owners’ technical management.
(6) With the exception of purchases made by the Subsidiaries Hutchinson, Saft Groupe and SunPower. Total Global Procurement made purchases from over 100,000 suppliers worldwide in 2018.
The Group has set up procedures for assessing its Subsidiaries and Suppliers, particularly in conjunction with independent bodies, which help identify and prevent risks of severe impacts on human rights and fundamental freedoms, human health and safety.
Procedures for assessing Subsidiaries
The Audit and Feedback Unit within the central HSE Division is a key component of HSE governance. It steers the internal control mechanisms intended to verify compliance with the Group’s HSE requirements.
This mechanism is organized around a self-assessment to be carried out by the Subsidiaries at least every two years and an assessment every three to five years conducted by the Audit unit and feedback based on an audit protocol. The objective is to identify potential gaps in the application of the rules by the Subsidiairies and to enable them to define and implement improvement actions.
This unit is also in charge of analysis of major incidents and management of feedback. Additionally, the Management Committee of each of the Group’s business segments performs monitoring of its major risk analyses and of the progress of the associated action plans.
Lastly, the HSE Division steers the measurement and reporting work relating to greenhouse gas emissions resulting from the Activities. These direct greenhouse gas measurements (Scope 1) are published in the “Report on implementation of the Vigilance Plan”.
Assessments regarding human rights and fundamental freedoms
Since 2002, the Group has engaged GoodCorporation, a company specialized in ethical assessments, to verify the proper application of the principles set out in the Code of Conduct at the Subsidiary level. These assessments include criteria relating to human rights and fundamental freedoms, and corruption. As part of the process, a selection of employees and external stakeholders of the Subsidiary are questioned to understand how their Activities are perceived locally. Following the assessment, the Subsidiary in question defines and implements an action plan and a monitoring procedure.
Furthermore, Total works with the Danish Institute for Human Rights (DIHR), an independent national body for the defense and promotion of human rights and fundamental freedoms, which assesses the impact on human rights and fundamental freedoms of the Group’s activities in sensitive contexts.
In some cases, the Group works with independent experts such as CDA, a company specialized in preventing and managing conflict between businesses and local communities. The reports by CDA are published online on its website.
Lastly, an annual self-assessment questionnaire enables each of the Group’s Subsidiaries and operational entities to measure and evaluate the level of implementation of their societal governance on the field. Actions involving dialogue, impact management and the contribution to socioeconomic and cultural development are recorded and analyzed.
Procedures for assessing Suppliers
The Supplier qualification process was harmonized at Group level in 2017 by Total Global Procurement. A new internal framework was published in 2018. In particular, it was used to set up a new IT qualification tool to be deployed progressively within the Group which also will serve as a consolidated database. The framework covers human rights, environment, health and safety.
Depending on the results of a risk analysis carried out by Suppliers, a detailed assessment is performed. It includes questionnaires addressing the aforementioned issues and, if needed, an action plan, a technical inspection of the site by employees or an audit of working conditions carried out by a specialist service provider with which a framework agreement was signed in 2016. Crude oil and petroleum product purchasing by Trading & Shipping, gas and electricity purchasing by the subsidiary Total Gas & Power Ltd, and the purchases made by the Subsidiaries Hutchinson, Saft Groupe and SunPower are subject to Supplier qualification processes specific to their organizations.
This qualification process may be completed if needed by specific organizations, such as the unit put in place in the Group as from September 2018 for the selection of palm oil suppliers. This unit aims to ensure that palm oil purchases are made on the basis of sustainability certifications such as the ISCC EU certification.
This type of certification incorporates criteria relating to carbon footprint, anti-deforestation, good use of land and respect for human rights. In addition to this mandatory certification, suppliers must have signed the Fundamental Principles of Purchasing and be members of the Roundtable on Sustainable Palm Oil (RSPO).
As regards the chartering of tankers and barges, any operation that involves tankers or barges calling at a terminal operated by a Group Subsidiary, carrying shipments that belong to the Group or chartered by Total must be approved in advance by the Vetting department. Responses are given on the basis of technical data and independently of any commercial considerations. The audits conducted with ship owners also permit the assessment of the quality of the technical management systems implemented by the operators, crew selection and training, as well as the support provided to vessels.
Through the annual inspections performed by inspectors representing the Group, Total is actively involved in sharing inspection reports with other international oil and gas companies through the SIRE (ship inspection report) Program set up by the OCIMF (Oil Companies International Marine Forum), thus contributing to the continuous improvement of petroleum shipping safety.
Awareness and training actions
Awareness and training of Group employees
The Group has put in place a variety of communication and information channels enabling all employees of TOTAL S.A. and its Subsidiaries to have access to the Action Principles defined by the Group in relation to human rights and fundamental freedoms, health, safety and the environment.
The Code of Conduct is distributed to all employees. All new employees must confirm that they are familiar with it.
Events such as the annual Business Ethics Day are used to raise awareness among employees of TOTAL S.A. and its Subsidiaries. Practical guides are available on the Group’s intranet, such as the Human Rights Guide and the Guide to dealing with religious questions within the Group, to help Group employees apply the commitments provided for in the Code of Conduct in each individual cases.
The HSE Division organizes the Group’s World Safety Day, which aims to bring teams on board and raise awareness of ways to put the HSE Action Principles into practice. The Group’s employees implement its safety culture on a day-to-day basis through “Safety Moments” at the beginning of meetings or before hazardous operations, consisting of a short discussion to reiterate the key safety messages and align participants with mutual commitments.
Training courses, incorporating on-line educational programs as well as technical training tailored to the various business segments, are offered to all Group employees.
Dedicated human rights and fundamental freedoms training programs have been set up for senior executives, site directors and the employees most exposed to these issues. Awareness-raising sessions on these subjects are organized regularly for employees, as is the case at the time of ethical assessments of Subsidiaries. In the field of procurement, training modules explaining the Group’s ethical commitments and the Fundamental Principles of Purchasing have also been developed for the Group’s purchasers.
Similarly, training programs in the fields of health, safety and environment have been rolled out within the Group reflecting different perspectives: general, by type of activities or by subject areas. For example, the following general training actions exist depending on the level of responsibility and experience in the Group: HSE Leadership for Group senior executives, HSE training for managers, and Safety Pass training for new recruits.
Awareness and training of Suppliers
The Fundamental Principles of Purchasing are brought to the attention of Suppliers as of their registration in the Supplier database.
Training initiatives are also undertaken with the Group’s Suppliers, such as the responsible security training given to safety service providers’ personnel, and the Safety Contract Owners program, which brings together more than 650 suppliers at the Group level.
Information on product risks
All of the chemical and petroleum products marketed by the Group are covered by a safety data sheet prepared in accordance with applicable regulations. The packaged products are labelled accordingly.
Each safety data sheet provides comprehensive information on the substances or mixtures usable in the regulatory framework of managing chemicals in the workplace. It enables users to identify the risks linked to handling such products, particularly regarding safety and the environment, in order to implement any measures necessary to protect people and the environment.
Safety data sheets are available to carriers of dangerous goods, emergency services, poison control centers, as well as professional and industrial customers. Consumers are informed of the risks and precautions of use through product labelling.
To support employees on a day-to-day basis, the Group encourages a climate of dialogue and trust that enables individuals to express their opinions and concerns. Employees can thus go to their line manager, an HR or other manager, their Compliance Officer or their Ethics Officer.
The Group’s employees and Suppliers, as well as any other external stakeholder, can contact the Ethics Committee to ask questions or report any incident where there is a risk of non-compliance with the Code of Conduct using the generic email address ([email protected]). The system is supplemented by specific whistleblowing mechanisms implemented at certain subsidiaries (SunPower, Hutchinson).
The Group’s Suppliers can also contact the internal supplier mediator using a generic email address ([email protected]). The mediator is available to Suppliers and purchasers, and restores dialogue to find solutions when measures taken with the usual contact have been unsuccessful.
Grievance handling procedures are also in place within the Group in order to receive and facilitate the resolution of concerns and grievances of local communities that may be affected by its Activities.
As regards HSE, an on-call system has been set up to alert the directors of the business segments and of the Group as quickly as possible in the case of a major incident. Depending on the incident, a crisis management and monitoring process is put in place.(7)
(7) RD 2018 p.88 - .18.104.22.168 Risk assesment and management – general principles
To ensure the continuous updating of the Vigilance Plan, Total relies on existing monitoring procedures and tools relating to human rights, safety, health and environment made available to the Subsidiaries.
Thus, the system of internal reporting and of indicators for monitoring implementation of the actions undertaken in the Group in these areas is based:
- for social indicators (including, in particular, health), on a guide entitled “Corporate Social Reporting Protocol and Methodology”;
- for industrial safety indicators, on a Group rule concerning event and statistical reporting; a feedback analysis process identifies, in particular, events for which a structured analysis report is required in order to learn lessons in terms of design and operation; and
- for environmental indicators, on a Group reporting procedure, together with activity-specific instructions.
Consolidated objectives are defined for each key indicator and reviewed annually. The business segments apply these indicators as appropriate to their area of responsibility, analyze the results and set out a plan.
All of the procedures enable regular monitoring of actions and areas for improvement to be implemented in the area of human rights, safety, health and environment. The Group Performance Management Committee(8) is involved in this approach. In particular, it is responsible for examining, analyzing and steering the Group’s HSE, financial and operational results on a quarterly basis.
In addition, the committee responsible for monitoring the IndustriALL Global Union signed by Total in 2015, known as the “FAIR Committee”, meets every year in the presence of representatives who are members of trade unions affiliated to the IndustriALL Global Union (refer to the “Employment and social inclusion” and “Supply Chain”) and appointed by this federation to monitor and implement the agreement. It identifies good practices and areas for improvement in the fields of safety, health, human rights and fundamental freedoms.
Additionally, the Group publishes a Human Rights information document that describes the Group’s Activities’ major impacts on human rights and fundamental freedoms and the remedial measures taken. In 2016, Total became the first company in the oil industry to have published this document in accordance with the UN Guiding Principles Reporting Framework. It was updated in 2018.
Since 2015, Total also publishes a report to assess the progress made in the implementation of the Voluntary Principles on Security and Human Rights. The information set out in the report is based on annual reporting organized by the Security Division that brings together the results of the risk and compliance analyses for each subsidiary operating in a sensitive context.
Lastly, in September 2018 Total published the third edition of its “Integrating climate in our strategy” brochure dedicated to the consideration of climate issues and detailing the Group’s lines of action in this area.
Report on implementation of the Vigilance Plan