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 the companies it controls as defined in point II of Article L. 233-16 of the French Commercial Code, directly or indirectly, together with 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 can present risks that fall within the scope of the Vigilance Plan.
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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. Although compliance with applicable regulations in each country where the Group operates is most often consistent with the protection of the objectives of the Vigilance Plan, Total, having noted that minimum fundamental principles are necessary for a uniform application of these objectives, notably adhered to the United Nations Global Compact in 2002 and committed to comply with the UN Guiding Principles on Business and Human Rights following their adoption in 2011. Total has also committed to support the United Nations’ recommendations for the implementation of the Sustainable Development Goals (SDGs) and launched in 2017 a project to identify and prioritize the SDGs to which it can make the most significant contribution and to define public commitments.
The "Challenges" pages of this website set out the Group’s social, environmental and societal strategy, actions and performance indicators.
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 (hereafter referred to as the “Subsidiaries”). The companies 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 stated in the Group’s Vigilance Plan.
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 this relationship (hereafter referred to as the “Suppliers”). In accordance with the legal provisions, suppliers with which the Group does not have an established commercial relationship do not fall within the scope of the Plan.
The Plan sets out the rules and measures which, as elements of the risk management systems, enable the Group to identify and prevent actual or potential severe impacts linked to its Activities and to mitigate the effects thereof as the case may be. It does not guarantee that the risks identified will not materialize. It contains the sustainable procurement principles applicable to relationships with Suppliers, but does not aim to replace the measures in place at those Suppliers.
Dialog with stakeholders
Total puts in place procedures for dialog with its stakeholders at every level of its organization. Among the numerous stakeholders with which Total maintains regular dialog, the Group’s employees and their representatives have a privileged position and role, particularly in constructive discussions with management.
The Group societal directive stipulates that “each entity must regularly consult its stakeholders1 regularly to gain a clearer understanding of their expectations and concerns, measure their level of satisfaction regarding the Group and identify avenues of improvement for its societal strategy”.
In this context, Total has deployed since 2006 its internal Stakeholder Relationship Management (SRM+) methodology. The aim is to identify and map out the main stakeholders of each Subsidiary and site (depots, refineries, etc.), schedule consultation meetings and gain a better understanding of their expectations, and then define an action plan for building a long-term trusting relationship. This methodology is used to explain the Group’s Activities to communities and other stakeholders, and to gather information about their expectations and those of local individuals and groups that might be vulnerable or marginalized. It has been deployed at over 100 Subsidiaries since 2006 and the deployment continued in 2017. The system is supplemented by a network of mediators with local communities, deployed in the Exploration & Production segment to maintain a constructive dialog with neighboring communities.
1“Stakeholders” means all of the people and organizations that can have an impact on the Group or be affected by its Activities.
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 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; and 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 and an adequate standard of living 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 ecosystem 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 and third parties, or sensitive natural environments2. This risk can materialize gradually or suddenly.
Total has developed safety, health and environment risk assessment procedures and tools applicable to its Activities. Analyses are performed regularly at various levels (Group, activities and/or industrial sites):
- prior to approving new investment, acquisition and disposal projects, through individual identification of potential risks using methods developed by the relevant business segments within the Group, mainly the HSE (Occupational Health, Safety and Environment) and Security departments;
- during operations (safety studies, security reviews, environmental and societal impact assessments, health impact studies); and
- prior to releasing new substances on the market (toxicological and ecotoxicological studies, life cycle analyses).
These analyses have highlighted the following risks of severe impacts:
- the risks to the safety of people and the environment resulting from a major industrial accident, such as an explosion, fire or leakage of toxic substances, 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 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; and
- the risks to the safety of people and the environment related to the overall life cycle of the products manufactured, as well as the substances and raw materials used. With regard to transportation, 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, environmental considerations).
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.), together with 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.
Total’s Vigilance Plan is based primarily on its Code of Conduct, which is anchored in the Group’s values and sets forth the Action Principles in terms of safety, security, protection of health and environment, integrity and respect for human rights and fundamental freedoms.
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 can be consulted on the Group’s website and is aimed at all employees and external stakeholders (Suppliers, host countries, customers, partners, etc.).
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, 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.
The Group takes care to comply with the strictest 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 operates4.
As such, the Group’s Subsidiaries implement5 a normative 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 produced on the basis of feedback and simplified 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. If any of the Golden Rules is not being followed, each individual is also authorized to use his or her “Stop Card” and stop any work under way.
4 The Group’s Safety Health Environment Quality Charter is currently being rolled out at Saft Groupe, which joined the Total Group in the second half of 2016.
5 Saft Groupe and SunPower have developed HSE management systems specific to their activities and organization (for example, the Environmental Health Safety & Quality Management System).
The relationship between the Group and its Suppliers is based on adherence to the principles set forth in the Code of Conduct and the Fundamental Principles of Purchasing (click here for further information about the relationship between the Group and its suppliers).
The Fundamental Principles of Purchasing, introduced in 2010 and formally set out in a Group directive in 2014, 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, conflicts of interest and fraud, respect for competition law, as well as the promotion of economic and social development.
The rules specified by this document, which apply to all the Group’s companies(1), must be communicated to Total's suppliers by including or transposing them into the agreements concluded with the suppliers. These principles are available for consultation by all suppliers in both French and English on Total’s website (under “suppliers”).
Total signed in 2015 a global agreement with the worldwide trade union federation, IndustriALL Global Union, which represents 50 million employees in 140 countries. Under this agreement, the Group is committed to maintaining minimum social standards and guarantees worldwide for all Subsidiaries in which it has more than a 50% stake.
The Group also ensures that the principles of the global agreement on safety, health, human rights and fundamental freedoms are promoted among its Suppliers, particularly through the Fundamental Principles of Purchasing. In the event that a Supplier fails to observe these principles, the Group is committed to taking the necessary measures, which can include termination of the contract.
Furthermore, on December 21th, 2017, the Group adhered to the Global Deal initiative, together with some 60 partners, states, trade unions, companies and international organizations. This international multi-stakeholder partnership aims at fighting against inequalities, encouraging effective social dialogue and promoting more equitable globalization. It promotes social dialogue, collective negotiations and freedom of unionization as essential tools to achieve the United Nations Sustainable Development Goals (SDGs) 8, 10 and 17.
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 framework of Group standards, completed 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 Corporate Technology Group, frameworks for each business segment, and a specific framework for each significant operational entity.
The Group’s organization is structured around three main levels: Holding, business segments and operational entities. 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 made up of members representing all of the Group’s business segments. One of its duties is to ensure that the Code of Conduct is distributed, understood and implemented within the Group. It is assisted in its work by the relevant Departments, as well as by 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 Total S.A.’s 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 the “Whistleblowing mechanisms” section. The members of the Ethics Committee are subject to confidentiality and data protection obligations.
The Human Rights Committee is made up of representatives from different departments (including in particular safety, purchasing and societal commitment) and business segments. It meets several times a year and coordinates actions relating to human rights and fundamental freedoms taken by the various business segments and Subsidiaries, in line with the road map approved by the Executive Committee in this regard.
The Human Rights Committee is made up of representatives from different departments (including in particular safety, purchasing and 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.
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, among others, responsible for supporting the implementation of the Group’s HSE policy. Specific expert units were set up in 2016 in the following areas: major risks, human and organizational factors, environmental and societal issues, transportation and storage, crisis management and pollution prevention.
Since January 1, 2017, Total Global Procurement covers a large proportion of the Group’s goods and services purchasing(1), both for categories specific to one business activity and categories shared between several business activities. In the Subsidiaries, purchasers implement framework agreements and manage local procurement.
A Sustainable Procurement Committee, which regularly 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, monitors the implementation of the Group’s Sustainable Procurement road map. The road map sets out the strategic direction of the Sustainable Procurement working group.
In addition, the Vetting department of Trading & Shipping, known as Total Activités Maritimes (TAM), defines and applies the selection criteria for the tankers used to transport the Group’s petroleum, chemical and gas products, in order to ascertain the technical condition of the vessels, the crews’ experience and the quality of the ship owners’ technical management.
(1)With the exception of crude oil and petroleum product purchasing by Trading & Shipping, gas and electricity purchasing by TOTAL Gas & Power Ltd, and the purchases made by Hutchinson, Saft Groupe and SunPower. TOTAL Global Procurement made purchases from over 100,000 suppliers worldwide in 2017.
The Group has set up procedures for assessing its Subsidiaries and Suppliers, particularly in conjunction with independent bodies, in order to identify and prevent risks of severe impacts on human rights and fundamental freedoms, human health and safety.
The Audit and Feedback Unit of the HSE division is a key component of HSE governance. It was formed in response to the need for internal control to:
- ensure the quality and effectiveness of risk management processes and the implementation thereof in the entities’ and subsidiaries’ operations to improve their risk management and contribute to operational excellence; and
- ensure compliance with the Group’s HSE requirements.The unit organizes, optimizes and conducts HSE audits within the Group, and is also responsible for analyzing major incidents in the oil and gas sector and managing feedback.
The level of risk analyzed is assessed for each industrial site operated, and an action plan is then produced to supplement the application of technical standards and local regulations. In addition, the Management Committee of each of the Group’s business segments carries out an annual review of the major risk analyses and the progress of the associated action plans.
The Supplier qualification process was harmonized in 2017 by Total Global Procurement and it will be rolled out gradually throughout the Group6 using a consolidated database. The process covers human rights, environment, health and safety.
Depending on the results of a risk analysis carried out by Supplier, a detailed assessment is carried out. It includes questionnaires addressing the aforementioned issues and, if needed, an action plan, a technical inspection of the site by an employee or an audit of working conditions carried out by a specialist service provider with which a framework agreement was signed in 2016.
Regarding petroleum shipping activities, any operation that involves vessels 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 by TAM of ship owners permit the assessment of the quality of the technical management systems implemented by the operators, crew selection and training, and the support provided to vessels. With 1,200 annual inspections performed by inspectors representing the Group, Total is actively involved in sharing inspection reports with other major oil 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.
6 Crude oil and petroleum product purchasing by Trading & Shipping, gas and electricity purchasing by TOTAL Gas & Power Ltd, and the purchases made by Hutchinson, Saft Groupe and SunPower are covered by qualification processes specific to their organization and business, defined by those companies and Group entities.
Since 2002, the Group has engaged GoodCorporation, a company specializing in ethical assessments, to check the 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 is questioned to gain an understanding of how its Activities are perceived locally. Following the assessment, the Subsidiary in question defines and implements an action plan and a monitoring procedure.
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 oil and gas exploration and production activities in sensitive contexts.
The DIHR has also developed a self-assessment tool, the Human Rights Compliance Assessment (HRCA), to help companies evaluate their compliance with international human rights standards. The Group has used the tool several times to raise awareness at the Subsidiaries and incorporate respect for human rights and fundamental freedoms into their everyday operational management.
The Group7 conducts baseline socioeconomic context studies and societal and human rights impact assessments for industrial projects, asset acquisition transactions and shareholding purchases that might have an impact on stakeholders.
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. Similarly, the Group works with International Alert (IA), an NGO based in the United Kingdom specializing in conducting audits in conflict zones. CDA and IA’s reports are published online on their websites.
In addition, an annual self-assessment questionnaire enables each of the Group’s entities and business segments to measure and evaluate the level of implementation of their societal governance on the ground by identifying and analyzing their dialog initiatives, impact management and contribution to socioeconomic and cultural development.
7 Hutchinson, Saft Groupe and SunPower have implemented assessment processes specific to their organization and activities.
Awareness and training actions
The Group has put in place a variety of communication and information channels so that all employees of Total S.A. and its Subsidiaries can access its Action Principles in relation to human rights and fundamental freedoms, health, safety and the environment.
The Code of Conduct is distributed to all employees and can be consulted on the Group’s website. All new employees must confirm that they are familiar with it.
A number of practical guides are available on the Group’s intranet, such as for example the Human Rights Guide and the Guide to dealing with religious questions within the Group, to help Group employees apply the commitments set out in the Code of Conduct to individual cases.
Tools have also been developed for employee use, for instance the “Safety +” web application in the field of HSE, which aims to provide a unique forum for sharing and promoting significant individual or collective safety actions (good practice, compliance with rules, initiatives) implemented at the Group’s 750 entities8.
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 focus participants on their mutual commitments.
Information for Suppliers, including the Fundamental Principles of Purchasing, is available on the Group’s website. Events such as the annual Business Ethics Day are used to raise awareness among employees of Total S.A. and its Subsidiaries. The theme of this event in 2016 focused on challenges in terms of human rights and anti-corruption in the supply chain, and an awareness-raising brochure was circulated on the Fundamental Principles of Purchasing.
8 Excluding Hutchinson, Saft Groupe and SunPower.
Training courses, incorporating on-line educational programs and technical training tailored to the various business segments, are available 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. In the field of procurement, training modules explaining the Group’s ethical commitments and the Fundamental Principles of Purchasing have also been developed for Group purchasers.
Similarly, training programs in the fields of health, safety and environment have been rolled out within the Group. For example, since its launch, over 900 directors of Subsidiaries have taken the “HSE for Managers” training, which is aimed at senior operational and functional management. The Group has also introduced an HSE training course for all new recruits, lasting between 5 and 20 days; the program will be rolled out worldwide in 2018.
Training initiatives are also undertaken with the Group’s Suppliers, such as the responsible security training given to safety service providers’ personnel, the celebration of the 2017 World Safety Day on the theme of “our shared safety”, promoting dialog with Suppliers, or the Safety Contract Owners program, which brings together more than 650 Suppliers at the Group level.
All of the chemical products or substances marketed by the Group are covered by a safety data sheet for the information of carriers of dangerous goods, emergency services, poison control centers, plant health product professionals and consumers.
Each safety data sheet provides comprehensive information about a substance or mixture 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, so that they can implement any measures necessary to protect people and the environment.
To support employees on a day-to-day basis, the Group encourages a climate of dialog 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@example.com). 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 (firstname.lastname@example.org). The mediator is available to Suppliers and purchasers, and restores dialog so that solutions can be found 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 affected by its Activities.
Total has human rights, health, safety and environment monitoring procedures and tools in order to ensure that the Vigilance Plan is correctly applied and continuously updated.
The Group has an internal reporting system and indicators for monitoring the implementation of actions undertaken regarding human rights, health, safety and environment that are available to the Subsidiaries.
The system is based:
- for social indicators (including, in particular, health), on a guide entitled “Corporate Social Reporting Protocol and Method”;
- 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 (for example, TRIR, or number of recorded injuries per million hours worked) and reviewed annually. The business segments apply these indicators as appropriate to their area of responsibility, analyze the results and set out a plan.
Each year, Total conducts an internal Worldwide Human Resources Survey. In 2017, it covered 133 companies in 57 countries, representing 87.2% of the consolidated Group's workforce. The survey includes indicators that cover major components of the Group’s Human Resources policy, such as mobility, career management, training, working conditions, social dialog, Code of Conduct application, human rights, health, compensation, retirement and death or disability benefits. The survey covers a representative sample of the consolidated scope.
A survey of Group employees carried out every two years is used to measure the teams’ level of commitment and their understanding of and adherence to the Group’s Action Principles. This survey is followed by action plans implemented by each entity in response to the areas for improvement identified.
A CSR global agreement monitoring committee, known as the “FAIR Committee”, meets every year in the presence of representatives who are members of trade unions affiliated with the IndustriALL Global Union and appointed by this federation to monitor and implement the agreement. It identifies good practice and areas for improvement.
With regard to human rights and fundamental freedoms, the Group publishes a Human Rights report that describes the Group's Activities’ major impacts on human rights and fundamental freedoms and the remedial measures taken. Total is the first company in the oil industry to have published this report in accordance with the UN Guiding Principles Reporting Framework. It is available on the Group’s website and has been 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 (VPSHR). Total is the first company in the oil industry to make this report public. 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.