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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 as those defined under the Corporate Sustainability Reporting Directive (CSRD) and the European Pollutant Release and Transfer Register (E-PRTR)—but also to monitor progress against internal sustainability targets and ambitions set by the corporate, as well as answer institutional questionnaires such as Carbon Disclosure Project (CDP).
This collection is currently conducted through an annual campaign using the PURE platform, in which sites are asked to complete the Site Environmental Reporting Form (SERF). The process involves submitting data on emissions, waste, water consumption, environmental incidents, and other KPIs relevant to corporate reporting.
However, this corporate reporting process is perceived as disconnected from daily site operations, "on top of", since each site already manages a range of local environmental responsibilities, including:
- Regulatory compliance with site-specific permits and national laws
- Monitoring of emissions and discharges and permits allowances where applicable
- Reporting to local environmental authorities 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. It also risks introducing inconsistencies or delays in data accuracy and completeness, especially as environmental reporting requirements become more rigorous and time-sensitive.
Ultimately, this lack of integration between corporate and site-level environmental data processes undermines the efficiency and credibility of environmental reporting across the group and poses a growing risk as regulations and stakeholder expectations continue to evolve.
Recommendation
Summarise the recommendation being made for the reader, leaving the pro/con evaluation and exact decision-making process to the subsequent sections.
Will be completed after all options have been identified and compared
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 on a system called PURE, based on the UL 360 platform, to conduct an annual environmental reporting campaign known as the SERF (Site Environmental Reporting Form).
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 two dimensions of reporting—Group Reporting and Site Reporting—serve different but interdependent purposes. Both levels may be subject to internal and external audit.
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:
- Emissions to air and water
- Water usage
- Waste generation
- Environmental fines and incidents
To standardize this process, the corporate team has developed the Site Environmental Reporting Form (SERF), which is 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 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 may be done on operational and / or financial perimeter. Past years data and perimeters are retained to allow ad hoc analysis in the past, 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 site-specific permits 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 explore a more automated solution, Syensqo has launched a Proof of Concept (PoC) in mid-2024 at its largest site (Tavaux). 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 (PDF)
The system also included embedded algorithms for KPI computation, plausibility checks, and validation workflows, offering real-time insights and a significantly more efficient reporting mechanism. The initial scope of the PoC focused on a small set of emissions to water indicators but is expected to expand in 2025 to cover additional domains such as air emissions and waste.
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.
Assumptions
- Input data is available from multiple sources, structured (MES) or not (PDF)
- Not all sites have the same digital maturity or IT tools. Amount of KPIs reported also varies
- Integration between tools/platforms (Microsoft Fabric ↔ SAP ↔ SFM ↔ SCT) is feasible
- Although SAP EHS focuses 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 (cf link in "See also))
Constraints
- System and data should be auditable. Users should be able to add the comment if there is any change in value when data is validated
- Regulatory pressure to start using new CSRD reporting from 2025, Interim solutions may have to be put in place
- Need to maintain complex formulas (If and Else)
- 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 and cover both operational and financial reporting parameters
- Sites vary in size, reporting obligations, and data availability readiness. IoT equipment requires investment
- Some needed functionalities only in SAP roadmap: ex plausibility check requirement is present in cloud public version and not in SAP Private cloud version
Impacts
- Potential for improved data quality, reduced manual work, and better regulatory alignment
- Risk of data inconsistency if systems are not well integrated
- Increased IT workload during the transition phase
- Need for training and change management at site and corporate 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 from each relevant site
- Sites must comply with local regulations and monitor environmental performance and permits allowance wherever its applicable
- KPIs must be traceable to source data and auditable
- Any system must support future expansion of KPI scope or update of definition or calculation rule
Options considered
Option A: To continue AS-IS
In this scenario, the company maintains its current environmental reporting setup:
The annual Site Environmental Reporting Form (SERF) campaign is conducted using the PURE platform (step 3)
Sites operate independently using a variety of local tools, spreadsheets, or semi-automated systems to collect and manage environmental data (steps 1 and 2) Some sites may have developed custom integrations or partial automation (e.g., via Microsoft Fabric or IoT), but this is not harmonized across the group.
- Results from PURE campaign and calculations are manually incorporated into other reporting processes and tools (ex for CDP or CSRD)
This approach continues to fulfill basic reporting obligations but offers limited scalability, efficiency, and readiness for growing regulatory and internal sustainability demands.
Pros
- All users (site and corporate) are familiar with the PURE process and interfaces.
- No major system changes or investment required.
Cons:
This option does not align with SAP’s sustainability roadmap or evolving EU regulations. The lack of integration, standardization, and real-time capability poses growing risk:
CSRD & E-PRTR require timelier, more auditable, and comparable data.
Fragmented tools make it harder to adopt emerging SAP sustainability products (e.g., SCT or SFM).
Risk of site fatigue from manual rework and disconnected processes.
Option B: Move full scope (PURE + Microsoft Fabric PoC) to SAP EHS Environment
Under this option, the company consolidates all environmental data management into SAP EHS. PURE is rebuilt natively in SAP, and site-level tools (like Tavaux POC running on Microsoft ) are replaced or phased out over time. This establishes a unified platform, fully integrated with the SAP landscape and aligned with long-term goals for SFM and SCT, covering all steps from 1 to 4.
Daily Emissions Management at Site Level
SAP EHS offers structured modules for emissions management, including:
Integration with direct measurement sources like IoT or MES is feasible but will require middleware.
Emission calculations can be handled through SAP’s formula management but are generally less flexible than Fabric for rapidly evolving or site-specific logic.
Emissions can be monitored with SAP reporting and alerting, though real-time visualizations are not as advanced or intuitive as Power BI dashboards.
While compliance and auditability are strong with real-time flexibility in SAP EHS
SERF Campaign Management at Corporate Level
This use case would be supported by a combination of SAP solutions (Sustainability Control Tower and associated reporting in SAP Analytics Cloud, Sustainability Footprint Management) and SAP EHS for Site level data collection and calculation
Sites and legal entities can be easily added or modified within SAP’s organizational structure.
KPI updates and form modifications can be managed via configuration (though they may require technical support).
Campaign monitoring, user assignment, data validation workflows, approvals, and historical data restatement are all standard are core feature of SAP EHS EM
Complex KPI logic and simulations can be supported through SCT or by layering custom functionality into SAP EHS. Also EHS has native integration with SAC as well which can be leveraged for complex reporting and visualization
- Plausibility check requirement is present in cloud public version and not in SAP Private cloud version
Annual Site Submission
SAP EHS already supports waste and emissions management. With appropriate configuration:
Sites can submit waste data through the Waste Management module.
Emissions to air and water are managed through the Emissions module.
SAP EHS Management provides tools for tracking, configuring, and reporting water-related data to meet compliance and operational needs supporting water balance and usage reporting
- Users should be able to add the comment if there is any change in Value when Data is validated as well as when Emission flow is reviewed is not supported in SAP EHS which is critical for Business Users
GHG Scope 1 Consolidation
SAP EHS and SFM together provide a strong basis for consolidated Scope 1 reporting:
Emission points can be defined, limits set, and both carbon and non-carbon GHG emissions recorded.
The data flows cleanly into SFM for Scope 1 calculation, ensuring alignment with upcoming CSRD requirements.
Pros:
- Single system of record
- Consistency across sites
- Better integration with SAP core
Cons:
- SAP EHS will not be able to support the final calculation and condition( If and Else) at the group level
- Risk of losing site-level flexibility and innovation
Option C : SAP EHS at Site + PURE at Corporate
In this architecture, all industrial sites use SAP Environment, Health & Safety (SAP EHS Environment) as the standardized platform for site-level environmental data capture and compliance reporting (steps 1 and 2). This includes modules for:
Emissions management
Waste tracking
Water usage reporting
The corporate environmental reporting platform PURE (based on UL 360) remains in place for annual group-level consolidation and reporting, including CSRD and E-PRTR compliance (step 3). Data from SAP EHS is exported and integrated into PURE for the Site Environmental Reporting Form (SERF) campaign.
Sites operate in SAP EHS, entering data on:
Emissions
Waste categories and volumes
Water usage
Data is validated locally using SAP EHS validation rules and audit trails.
On a yearly basis, the data required for SERF is extracted from SAP EHS, transformed as needed, and uploaded or integrated into PURE, where corporate teams run:
Campaign monitoring
Plausibility checks
Final calculations and KPI aggregations
External reporting formats
Optional enrichment can be done in PURE (e.g., for KPIs not captured in SAP or for comments/annotations).
Pros:
- All sites use SAP EHS, ensuring consistency in data structure and validation logic.
- Minimal impact on sites; they stay within SAP. Corporate users continue with PURE.
- SAP EHS serves as a foundation that can later integrate with SAP SCT or SFM.
Cons:
- Corporate and site platforms must stay synchronized; this creates overhead in IT and governance.
- Without tight integration, the same data might be validated twice — once in SAP, again in PURE.
- Lack of integration between step 3 and 4 means the SERF results would have to be re incorporated into SAP SCT
Evaluation
Outline why you selected a position. The best format could be a pro/con table (sample below), but is up to you as the author. You must consider complexity, feasibility, cost/effort to implement, but also ongoing operational impact and cost. You must consider the program principles and explain any deviations in detail. This is probably as important as the decision itself.
Option A : Continue As-Is | Option B : Move full scope (PURE + Microsoft Fabric PoC) to SAP EHS Environment | Option C : SAP EHS at Site + PURE at Corporate | |
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| System Integration | |
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| Scalability to Other Sites |
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| IoT Data Integration |
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|  Pro: IoT possible via middleware with SAP EHS; |
KPI Computation Flexibility |
|  Con :Low to Medium – Mostly,pre-configured; limited flexibility; logic sits at site × substance level in Emissions Management |
PURE handles group KPIs with complex calculation and data flow can be validated with added comment |
| Regulatory Content (e.g., e-PRTR linkage) |
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Yes – regulatory lists like e-PRTR and substance classifications can be embedded in SAP EHS content (provided by external regulatory provider). Thanks to integration with SCT, process is also CSRD compliant by design |
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Standard Auditability & Traceability of Regulatory Data |
| Pro Strong – full traceability, audit logs, regulatory reporting packages |
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Change Management Impact |
| Con : High – new process for sites, training on SAP UI and logic, complex configuration model |
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