2024 ESG Report FINAL - Report - Page 24
• External Stakeholder Relationships – Programs, such
as community advisory panels or community advisory
councils, are in place to facilitate meaningful dialogue
with local communities and raise awareness of
potential community issues.
• Assurance & Review – CTEMS is assessed periodically
using a disciplined and systematic approach. The
effectiveness of all policies, programs, processes
and procedures is reviewed to ensure they are
appropriate and address the commitment for continual
improvement.
In early 2024, we completed the 昀椀rst round
of the re昀椀ning EERA program by conducting
environmental excellence and risk assessments
on all 15 re昀椀neries during the last four years.
In addition, progress on the improvement
opportunities identi昀椀ed by each of these
assessments has been monitored by subject
matter experts and members of the
management team.
2. Environmental Excellence and Risk
Assessment (EERA)
EERA elevates the environmental audit and compliance
functions to an environmental excellence vision. Its main goal
is to assess the design and effectiveness of environmental
performance regarding speci昀椀c excellence objectives and to
facilitate continuous improvement across the company. EERA
de昀椀nes more than 100 expectations and involves a proprietary
昀椀ve-step process (generally summarized below) using due
diligence on data and 昀椀eld assessments reviewed by a
combination of external and internal subject matter experts.
• On-Site: Re昀椀nery leadership reviews and self-scores
against EERA expectations.
• Digital Documentation: Third-party and in-house
subject matter experts conduct an extensive deep-dive
review of re昀椀nery environmental data and reports in a
due diligence-style process.
• Technology: Technical 昀椀eld assessment is conducted
using industry standards and advanced technology to
evaluate effectiveness in controlling emissions.
• Inspection: Results from the technology review and due
diligence process are used by a team of experts in a
substantive on-site inspection and cultural assessment.
• Implementation: Final gap assessment report is
produced by experts and leadership team with
mitigation pathway and scoring improvement actions.
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3. Fuels Management System (FMS)
FMS provides operational safeguards, software,
training and protocols for uniformity across our
re昀椀neries, terminals and import locations to
reinforce our compliance with applicable fuels
regulations.
Built on the success of FMS, our Low Carbon
Assurance Program (LCAP) was implemented
to further delineate and strengthen our
internal processes. LCAP de昀椀nes key regulatory
requirements, management expectations
and internal regulatory assurances relating to
transportation fuels regulated by low-carbon fuels
programs. Internal and third-party audits, incident
investigation processes, informal and formal
training programs and consideration of market
changes are just a few of the expectations laid out
in our LCAP. LCAP leadership commits within their
respective areas to:
• Clearly de昀椀ne the responsibilities and
accountabilities of leadership and supporting
staff who are involved with carrying out
compliance with low-carbon fuels regulations
and the LCAP.
• Provide resources to help our facilities and
operations fully comply with applicable
regulations.
• Verify that affected employees receive
training for their speci昀椀c job roles.
• Report, investigate and take corrective action
to minimize, mitigate and prevent recurrence
of violations of low-carbon fuels regulations.
• Execute an internal risk assessment and
assurance program to periodically evaluate
compliance with low-carbon fuels regulations
and the LCAP and take any necessary
corrective actions.
Methane emissions are mainly associated
with the extraction and transportation
of oil and gas, and smaller methane
emissions may also be emitted from
process leaks from valves and connectors
as part of the re昀椀ning process. Although
our re昀椀neries use natural gas, methane
emissions account for less than 1% of our
GHG emissions inventory.
