Issue

At the group level, Syensqo  is required to collect and consolidate a broad set of environmental indicators from its industrial sites. This is necessary not only to meet external reporting requirements—such requirements—such as those defined under the Corporate Sustainability Reporting Directive (CSRD) and the European Pollutant Release and Transfer Register (E-PRTR regulation)—but also to monitor progress against internal sustainability targets and ambitions set by the corporate leadershipcorporate, as well as answer institutional questionnaires such as Carbon Disclosure Project (CDP).

This data collection is currently conducted through an annual campaign using the PURE platform, in which sites are asked to complete the Site Syensqo Environmental Reporting Form File (SERF - 7 forms in 2024). The process involves submitting data on emissions, waste, water consumptionbalance, environmental incidents, and other KPIs relevant to corporate reporting.

HoweverCurrently, this corporate this corporate reporting process is perceived as disconnected from daily site operations. Each site already manages a range of local environmental responsibilities, including, that include:

• Regulatory compliance with site-specific permits and national laws
• Real-time monitoringMonitoring of emissions and discharges and permit thresholds where applicable
• Reporting to local environmental authorities
  Internal operational tracking of environmental performance
  where applicable

These tasks often require the collection and validation of the same or similar data as that required by the SERF campaign, but through different workflows, tools, or systems. Because the corporate process is not integrated with site-level systems, it creates a sense of duplication, manual rework, and administrative burden for site teams.As a result, the annual data collection exercise is seen by many sites as redundant, resource-intensive, and misaligned with operational realities. It also risks introducing introducing inconsistencies or delays in data accuracy and completeness, especially as environmental reporting requirements become more rigorous and time-sensitive. A certain level of duplication is unavoidable due to the different nature of the reporting and also because local authorities may impose reporting in specific platforms, languages etc., but in some instances there is opportunity to mutualize and leverage on the same input data.

Ultimately, this lack of integration between corporate and site-level environmental data processes undermines the efficiency and credibility of environmental reporting across the group automation undermines the possibility to increase the frequency of reporting and poses a growing risk as regulations and stakeholder expectations continue to evolve.

Site-Level Scope (Local Responsibilities)

• Ensure compliance with site-specific permits and national environmental laws.

• Monitor emissions, discharges, waste, water, and other environmental KPIs.

• Report to local environmental authorities using local tools and workflows.

• Deal with duplication due to disconnected corporate reporting processes.

 This KDD will address the site-level scope, aiming to streamline data collection for each site  and reduce manual effort and the Change request -CR0014 is created for the effort estimated for this KDD. 

Issue for Corporate Reporting will be handle in another KDD : KDD090 - Corporate Environmental Data Reporting

Recommendation

Recommendation: Adopt Option B

• Single, Integrated Solution: SAP EHS Environment becomes the sole platform for all sites to manage waste, emissions and water.

• Pros:

  • A single, integrated solution

  • More standardized site-level processes thanks to single IT solution (same data objects etc)

  • By enabling automation, offers a solution for sites to build more frequent reporting

• Cons :

  • Loss of flexibility and autonomy for each site 

• Best For:

  • Long-term scalability

  • Regulatory compliance

  • Harmonized data and performance management across the organization

Our recommendation: Option B is the most future-proof approach

Background & Context

Syensqo is subject to increasingly stringent environmental reporting requirements, both from external regulations (notably the Corporate Sustainability Reporting Directive - CSRD and E-PRTR) and from internal sustainability goals set by the corporate group. 

To address this, the company has historically relied is relying on a system called PURE, based on the UL 360 platform, to conduct an annual environmental reporting campaign known as the SERF (Site Syensqo Environmental Reporting FormFile).

Syensqo  operates in a regulatory environment where environmental data must be collected, validated, and reported both at the corporate level and at the individual site level. These x GBU combination level( Site Level) These two dimensions of reporting—Group Reporting and Site Reporting—serve different but interdependent purposes. However, until now, they have evolved largely in isolation from one another, creating operational inefficiencies and data fragmentation.. Both levels may be subject to internal and external audit. As site level data is the basis of input to corporate group reporting, its important its accurate, automated and streamlined

1. Group Reporting

On an annual basis, each site within the defined reporting scope is required to submit a comprehensive set of environmental indicators to the corporate HSE team. These indicators include, but are not limited to:

• Emissions to air and water
• Water usagebalance (intake, use, discharge, losses, circularity)
• Waste generationshipment and treatment
• General information (Environmental fines, climate change related information, additional information on water for CDP, summed production volumes....)
  Environmental fines and incidents
  
  

To standardize this process, the corporate team has developed the Site Syensqo Environmental Reporting Form File (SERF), which is are implemented through the PURE application (UL 360 platform). The SERF covers more than 1000 KPIs and is structured to support corporate-level reporting requirements under frameworks such as CSRD and E-PRTR, as well as internal environmental performance monitoring.

Site representatives are prompted annually to fill out the SERF questionnaire questionnaires within PURE, after which the corporate team validates, consolidates, and extracts the data for use in the group’s sustainability disclosures and internal reporting dashboards.

Group reporting is done on operational and financial perimeter depending on the requirements. The calculation perimeter may be modified based on the properties of the reporting entities (start- and stop-date during their lifetime) and the exact inquiry (e.g. historical perimeter is with inactive sites included, running perimeter is without the past contribution for the past sites). It therefore allows executing ad hoc analysis of past data, for example in the event of a carve-out or spin-off.

2. Site Reporting

Independently of the corporate SERF campaign, each site is also responsible for managing its own local environmental compliance. This includes:

• Meeting local legal requirements
• Respecting Acknowledging  site-specific permits
  Conducting real-time by monitoring of emissions and discharges
• Submitting data to local authorities on a monthly, quarterly, or yearly basis depending on the jurisdiction and regulatory requirements
  

To address this inefficiency and explore a more integrated automated solution, Syensqo has launched a Proof of Concept (PoC) in mid-2024 at its largest site (TavauxTravaux). The objective of this initiative was to automate the capture, processing, and validation of environmental data at the source. Using technologies like Microsoft Fabric and Power Apps, the PoC integrated data streams from:

• IoT sensors data collected in the site MES
• Analytical lab results (digital or PDF)
• Waste disposal records (via PDF parsing and AI tools)
  
  

The system also included embedded algorithms for KPI indicator computation, plausibility checks, and validation workflows, offering real-time daily insights and a significantly more efficient reporting mechanism. The initial scope of the PoC focused on 24 water-related emission indicators a small set of emissions to water indicators from the PVDF production unit but is expected to expand in 2025 to cover additional domains indicators such as air emissions and waste indicators.

The first POC demonstrated technical feasibility based on 21 indicators related to water emissions and the scope was extended to other indicators according to a 2025 project timeline.

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Assumptions

• Input data is available from multiple sources some digital(PDF) , MES sources(Structured)
• SAP EHS Environment has modules that may be extended to match PURE and Microsoft solution functionality
• , structured (from MES) or not ( in the form of PDF)
• Not all sites have the same digital maturity or on IT tools. Amount of KPIs emission, water and waste input indicators reported also varies 
• Integration between tools/platforms (Microsoft Fabric ↔ SAP ↔ SFM) is feasible
• SAP EHScould be Although SAP EHSfocuses on Emissions Management at the moment, it can already be used for tracking, configuring, and reporting water-related data to meet compliance and operational needs supporting water balance and usage reporting 
• Data flow is auditable by auditors and business users
• reporting (cf link in "See also) 
• Some needed functionalities only in SAP roadmap: ex plausibility check requirement is present in 2023 service pack 2. SAP cloud version
• Integration between tools/platforms (Microsoft Fabric ↔ SAP EHS Environment ↔ SFM ↔ SCT) is feasible. SAP proposes a suite of solutions to cater for different needs and audiences.
  • SAP EHS Environment (SAP EHS EM) focusing on site environmental footprint, in particular emissions
  • SAP Sustainability Footprint Management (SFM) computing and / or aggregating the GHG Emissions to provide Group GHG Emissions or Product level Carbon footprint
  • SAP Sustainability Control Tower (SCT) gather all the ESG indicators and narrative to be used for Group reporting and sustainability performance management 
  • additional reporting may be done in reporting platform that will be implemented during the project (such as SAP Datasphere)

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Constraints

• System and data should be auditable. Users should be able to add the comment if there is any change in Value value when Data data is validated as well as when Emission flow is reviewed

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• The system should keep all historical values for the same indicator / reporting entity and period combination; together with the reasons for the corrections, the name of the person who asked for the correction, the date, etc
• Auditors may impose to make some changes in the reporting process at site or group level to better cater for CSRD requirements
• Need to maintain

Constraints

• Regulatory pressure to start using new CSRD reporting from 2025, Interim solutions needs to be maintained
  
• Need to be able to consider both operational and financial reporting parameters
• Need to maintain the complex formulas (If and Else) and the full flexibility for the SERF Manager to modify calculation equations and consolidation settings
• Need to update data collection forms every year to cater for reporting frameworks updates
• Need to have flexible reporting to cater for ad-hoc requests
• Sites vary in size, reporting obligations, and data readiness
• Some environmental KPIs are only meaningful at group level, others only locally
• Plausibility check requirement is present in cloud public version and not in SAP Private cloud version
• and cover both operational and financial reporting parameters
• Need to be able to use time-variable calculation constants and time-variable consolidation rates, the latter is needed for the computation of the financial perimeter
• IoT equipment requires investment. Coverage depends on the site, so we need the flexibility to automate or manually input data at site level

Impacts

• Potential for improved data quality, reduced manual work, and better regulatory alignment at site level
  
• Risk of data inconsistency if systems are not well integrated
• Increased IT and business GBUs workload during the transition phase
• Need for training and change management at site and corporate site  level
• Potential impacts on portfolio as some sites may already have digital solution not identified by IT 

Business Rules

• Yearly SERF campaign must collect a fixed set of KPIs indicators from each relevant site
• Sites must comply with local regulations and monitor environmental performance and permits allowance wherever its applicable
  
• KPIs must Indicators must be traceable to source data and auditable
  
• Any system must support future expansion of KPI scope (e.g. air, water, waste)or update of definition or calculation rule

Options considered

To facilitate the understanding of the options, the end to end process is divided as follows, where 1 and 2 are executed at site level and 3 and 4 at corporate level.

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Evaluation

	Option A : Continue As-Is	Option B : Move

full scope (PURE + Microsoft Fabric PoC)

site scope  to SAP EHS Environment

Option C : SAP EHS at Site + PURE at Corporate

System Integration	Con :Fragmented local tools, no standardized integration Con : higher long term cost due to multiple solutions at site level	Pro: Fully embedded in SAP ecosystem (EHS EM + SFM + SCT + SAP reporting) Direct data flows for footprints native integration to seamlessly compute GHG Emissions Possibility to import organizational structure from plant maintenance
Compliance and Performance management	Con : local authority mandated reporting cannot be leveraged for corporate reporting	Pro: versatility of SAP EHS ENV can be used

at all sites, integration needed only between SAP and PURE

to address local regulatory monitoring and reporting activities (eg environmental permit management) as well as the corporate reporting ("killing 2 birds with 1 stone") Pro: opportunity to increase the frequency of KPI generation to better monitor and anticipate the group performance, take early actions to correct course, as well as reducing the effort at year end to review the data
Scalability to Other Sites	Con

Difficult – Varies by local tool maturity; high onboarding effort

; not applicable, site based solutions remain

Pro: Is scalable

Pro: Is scalable 

KPI

. Possibility to automate or manually input the indicator allows to cater for different site size and digitization levels.
IoT Data Integration	Con Not standardized – Sites may have custom solutions, but no group-level integration	Pro :

Possible via middleware  or external connectors, but not natively real-time; requires integration middlewarePro: IoT possible via middleware with SAP EHS; requires investment per site

opportunity to standardize by using the same technology to capture data. However still relying on IOT investment at site level

Computation Flexibility

Pro: PURE has possibility to

enhance

handle Complex KPI computation, controlled by the admin user

Con :

Low to Medium – Mostly,pre-configured; limited flexibility; logic sits at site × substance level in Emissions Mgt

Pro: SAP EHS can support site-specific KPI logic; 

PURE handles group KPIs with complex calculation and data flow can be validated with added comment

not the same flexibility and autonomy for the administrator as some steps have to be pre configured in the background
Regulatory Content (e.g., e-PRTR linkage)	Con:

Must be maintained separately at each site or uploaded manually to PURE

In case of regulation change (eg E PRTR) each site has to update their own process and tools to adapt

Pro : Yes – regulatory lists like e-PRTR and substance classifications can be embedded in SAP EHS content

Pro: SAP EHS includes regulatory content (e.g., e-PRTR substance list, limits)

(provided by external regulatory provider)

Standard Auditability & Traceability of

Regulatory

Data

Con:

Depends

Although PURE is centralized and auditable, the site level inputs depends on local setup

; lacks

and lack centralized traceability

Pro

Strong – full traceability, audit logs, regulatory reporting packagesCon: Do not provide end to end traceability due to fragmented landscape, and it will require governance between two systems

: improved traceability at site level:  audit logs, regulation kept up to date by content provider
Change Management Impact	Pro: No major system change required

, but also no process improvement

Con: Survey fatigue on site. Without automation, not possible to increase the frequency of reporting for selected indicators

Con :

High –

new process for sites, training on SAP UI and logic, complex configuration model (but one time set up) Pro:

Some changes at site level to harmonize SAP usage; PURE processes stay unchanged at corporate level

Sites are trained to use both Waste management and Emissions Management

See also

https://community.sap.com/t5/product-lifecycle-management-blogs-by-sap/water-balance-and-usage-report-step-by-step-configuration-guide/ba-p/14058864#

Change log

Workflow history