ESG Report - Report - Page 21
STRATEGY
LOW-CARBON
ENVIRONMENT
Competitive benchmarks are used and evaluated,
and gap closure plans are implemented. A
procurement process supports safe and reliable
plant operations. Our annual strategic planning
drives business competitive improvement.
• External Stakeholder Relationships - Programs,
such as Community Advisory Panels, 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 are reviewed to ensure they are
appropriate and address the commitment for
continual improvement.
Environmental Excellence and Risk Assessment
(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
specific excellence objectives and to facilitate
continuous improvement across the company. EERA
defines more than 100 expectations and involves a
proprietary five-step process (see below) using due
diligence on data and field assessments reviewed by
a combination of external and internal subject matter
experts.
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• On-Site: Refinery leadership reviews and self-scores
against EERA expectations.
• Digital Documentation: Third-party and in-house
subject matter experts conduct an extensive deepdive review of refinery environmental data and
reports in a due diligence-style process.
SAFETY
COMMUNITY
PEOPLE
GOVERNANCE
Fuels Management System (FMS) - provides
operational safeguards, software, training and
protocols for uniformity across our refineries, terminals
and import locations to reinforce our compliance with
applicable fuels regulations.
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Built on the success of FMS, our Low Carbon Assurance
Program (LCAP) was implemented to further delineate
and strengthen our internal processes to assure
compliance. LCAP defines key regulatory requirements,
management expectations and internal regulatory
assurances relating to transportation fuels regulated
by low-carbon fuels programs. Internal and thirdparty 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 define 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 specific 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.
• Technology: Technical field 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.
ENVIRONMENTAL, SOCIAL AND GOVERNANCE REPORT •
21
