Air Liquide
Material Topics
ESRS 2 – General Disclosures
GOV-1The role of the administrative, management and supervisory bodiesReported
Air Liquide identifies its administrative, management and supervisory bodies as the Board of Directors and the Chief Executive Officer. Detailed board information is cross-referenced to Chapter 3 of the Universal Registration Document: composition of the Board (pages 98 and 103), participation of employee representatives on the Board (page 113), and the Environment and Society Committee (page 124). The integration of environmental and societal issues is presented as an integral part of the Group's strategy, supported by strong governance. The Sustainable Development department reports to a Director who is a member of the Executive Committee and contributes to strategy and the Company's strategic plan; it participates in the E-Enrisk Committee (managing energy and emissions risks) and in Resources and Investment Committee meetings. The Group's CO2 trajectory is filtered into local decarbonization plans, with a CO2 budget per entity monitored quarterly. Board gender diversity and percentage of independent members are cross-referenced to Chapter 3, page 103.
GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodiesReported
Air Liquide addresses how sustainability matters are handled by the Board through cross-references to Chapter 3 of the Universal Registration Document, section Governance (Composition, Functioning and Work of the Board of Directors and Committees). Specific references include paragraph 10 The Board of Directors' work in 2024 (page 115), paragraph 10.1 Activity, results and strategy (page 115), paragraph 10.3 Human resources/stakeholders (page 117), and the joint session of the Audit and Accounts Committee and the Environment and Society Committee under paragraph 11.1 The Committees of the Board of Directors (page 120). Elsewhere the statement notes that the results of the double materiality assessment were presented to Executive Management and to the Board's specialized committees, with the Audit and Accounts Committee monitoring the sustainability information preparation process and the double materiality process, and the Environment and Society Committee monitoring material sustainability topics and impacts, risks and opportunities.
GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemesReported
Air Liquide discloses that the elements relating to the incentive mechanisms applied to the Group's governance bodies, including the integration of sustainability-related performance in incentive schemes, are dealt with in Chapter 3 of the Universal Registration Document, in the section Remuneration of L'Air Liquide S.A. Corporate Officers (page 145). The content index also links GOV-3 to the transition plan introduction in paragraph 2.2.1 (page 300). The narrative in the Sustainability Statement itself is limited to this cross-reference rather than reproducing the detail of the ESG criteria embedded in executive remuneration.
GOV-3(was GOV-4)Statement on due diligenceReported
Air Liquide provides a statement on due diligence under the responsibility of the Vice President, Duty of Vigilance and Societal Responsibility. The Group implements a due diligence process covering human rights and fundamental freedoms, the health and safety of persons, and the environment, in accordance with the French law on the Duty of Vigilance. It establishes a Vigilance Plan based on international instruments including the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises and its Due Diligence Guidance on Responsible Business Conduct. The statement notes that Chapter 2, Vigilance Plan section, paragraph 2 (Vigilance Plan cross-reference table, page 92) meets the disclosure requirements relating to the sustainability due diligence process through a cross-reference table referring to the Sustainability Statement. The GOV-4 statement on due diligence is also mapped in the list of data points from other EU legislation (Chapter 5, paragraph 1.3.1, page 283).
GOV-4(was GOV-5)Risk management and internal controls over sustainability reportingReported
Air Liquide describes risk management and internal control over sustainability reporting, covering the thematic ESRS and disclosure requirements deemed material by the double materiality assessment. The objective is reasonable coverage of risks relating to completeness, integrity, suitability of estimates, availability and timeliness of data. Main components are the organization producing the Statement (roles, responsibilities, validation steps), policies and procedures for consistent definitions and calculation methods, control activities (consistency, reconciliation, completeness, gap analysis) and IT systems automating controls. Regular internal audit reviews provide independent control. A data-point-level risk assessment addresses inherent risks (calculation complexity, manual processes, estimates, third-party data dependence) and other data-use risks. In 2024 the Group strengthened training, information systems and used a single integrated tool for writing the Statement, with particular focus on E1 Climate, S1 Own workforce and E3 Water. Given 2024 is the first year under the regulation, attention was paid to data heterogeneity and integrity. Results were presented to the Audit Committee (page 119).
SBM-1Strategy, business model and value chainReported
Air Liquide's business model, business sectors and value chain are cross-referenced to Chapter 1 (Business model, pages 22 and 24). The ADVANCE strategic plan places sustainable development at the heart of the strategy, combining financial and extra-financial performance, with four pillars: strong financial performance, leadership in industry decarbonization, progress through technological innovation, and acting for all. The Group commits to carbon neutrality by 2050 with intermediate steps in 2025 and 2035. For the double materiality assessment, the value chain was scoped upstream to tier-one suppliers and subcontractors (unless an IRO requires going beyond) and downstream to delivery of products and services to customers and patients. Own operations cover Gas and Services, Engineering and Construction, and Global Markets and Technologies. Main inputs are electricity, natural gas and air; almost 85% of large production units are Air Separation Units using air as sole raw material. The Group also depends on water. Key future sectors are Healthcare, Electronics, Industrial Merchant, Hydrogen mobility and High-techs.
SBM-2Interests and views of stakeholdersReported
Air Liquide identifies its main stakeholder groups as employees and their representatives, customers and patients, shareholders, investors and financial partners, suppliers and their employees, local communities and civil society, and the public sphere. Engagement is integrated into operational processes rather than a single channel, with communication described as continuous. Channels include social dialogue mechanisms, the My Voice internal survey, Voice of Customer satisfaction surveys, pharmacovigilance, dedicated Shareholder Services and Investor Relations teams, the Supplier's Code of Conduct and annual assessment of Sustainability-Critical Suppliers, and the European and International Affairs Department for communities and public authorities. The Group has around 80,000 tier-one suppliers and subcontractors. Prior to the double materiality assessment, an external consultant interviewed departments to assess dialogue maturity against four criteria (frequency, mechanisms, analysis, sharing with governance bodies); engagement was deemed sufficiently mature. In 2024 the Group did not identify any need for major adjustments to strategy or business model to meet stakeholder expectations. Processes for informing the Board and the Environment and Society Committee are cross-referenced to Chapter 3.
SBM-3Material impacts, risks and opportunities and their interaction with strategy and business modelReported
The double materiality assessment identified 62 material impacts, risks or opportunities out of 122 identified, aggregated by sustainability topic and described in bold within the relevant topical paragraphs. Material topical standards are E1 Climate change (mitigation and adaptation), E3 Water (withdrawals, consumption, discharges), S1 Own workforce, S2 Value-chain workers, S4 Consumers and patients, and G1 Business conduct. Material S1 topics include inclusion and diversity, social dialogue, violence and harassment, adequate wages, work-life balance, secure employment, training and skills, working time and privacy; S2 covers child and forced labor and working conditions; S4 covers health and safety and access to quality information. G1 items material by nature via the Principles of Action include corporate culture, prevention of corruption and bribery, protection of whistleblowers and management of supplier relationships. Not material are E2 Pollution, E4 Biodiversity and ecosystems, and E5 Resource use and circular economy, plus S3 Affected communities. The current financial effects of material risks and opportunities are cross-referenced to Chapter 4, note 31 (page 248).
IRO-1Description of the processes to identify and assess material impacts, risks and opportunitiesReported
Air Liquide conducted its double materiality assessment by building on pre-existing internal processes, notably the duty of vigilance risk mapping (for impact materiality) and the Enterprise Risk Management system (for financial materiality), following a gap analysis against regulatory requirements with an external consultant. The assessment was centralized by a working group coordinated by the Group Risk Management Department with support from the Duty of Vigilance and Societal Responsibility Department, drawing on functions including Sustainable Development, Human Resources, Sustainable Procurement, Safety, Ethics, Digital Security, Public Affairs, Finance and Home Healthcare. It proceeded in two steps: identification of IROs (structured on the ESRS 1 AR 16 list of sustainability matters) then assessment of materiality. Negative impacts were assessed on severity (scale, scope, irremediability) and probability using a four-level matrix (materiality threshold of 3); positive impacts similarly. Risks were mapped on financial magnitude weighted by a maturity coefficient (0.75 to 1.5) times probability, with any rating of 12 or higher out of 24 presumed material, then reviewed by experts. Opportunities were assessed case by case. G1 Principles of Action topics were material by nature. A yearly consistency review is planned.
IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statementReported
Air Liquide presents the disclosure requirements it covers through tables of contents / content indexes in its Sustainability Statement (referenced at pages 278, 294, 326 and 352), mapping each ESRS 2 general disclosure and topical disclosure requirement to the relevant paragraph and page. On the basis of the topics assessed as material, the Group identified the information required by the CSRD, with materiality of each data point assessed by the responsible internal expert according to relevance and usefulness to a user of the Statement. A small amount of information related to material topics was deemed non-material: renewable electricity production, carbon credits and carbon elimination, the percentage of GHG emissions covered by the internal carbon pricing mechanism, stored water, non-guaranteed-hours employees, the annual total remuneration ratio of the highest paid individual to the median, and fines and penalties resulting from work-related incidents. Section 1.6 provides the list of data points deriving from other EU legislation (SFDR, Pillar 3, Benchmark and EU Climate references), indicating where each is located or that it is non-material or phased-in.
E1 – Climate Change
E1-1Transition plan for climate change mitigationReported
Air Liquide first announced its climate strategy in March 2021 and in 2024 adopted and published a consolidated Climate Transition Plan, covering the Gas and Services segment (about 95% of 2024 turnover). The plan was approved by Group Executive Management, reviewed by the Environment and Society Committee, and the Sustainability Statement containing it was adopted by the Board of Directors on February 20, 2025. The Group is committed to carbon neutrality by 2050 across Scopes 1, 2 and 3, understood as a massive reduction of CO2 emissions to the atmosphere. The operational trajectory (Scopes 1 and 2) includes a turning point around 2025 and a -33% reduction in Scope 1 and 2 emissions by 2035 versus the 2020 baseline. Reference 2020 emissions are 39.3 million tonnes of CO2. Three levers each contribute roughly one third of the required decarbonization: renewable or low-carbon electricity supply (about 5 Mt by 2035), asset management including efficiency and electrification (about 5-7 Mt), and CO2 capture (about 3-4 Mt). The 2035 Scope 1 and 2 target was validated by the SBTi as aligned with well below 2 degrees Celsius. No 2030 milestone was formalized and no quantitative Scope 3 reduction target has been set.
E1-4(was E1-2)Policies related to climate change mitigation and adaptationReported
Air Liquide's climate policy is an integral part of the BlueBook and covers the entire Group, with processes and actions supervised by the Executive Committee. It sets out how the Group assesses climate-related risks, impacts and opportunities across its value chain (mitigation and adaptation), how it responds through its processes, monitors performance by measuring its carbon footprint, and communicates to stakeholders including customers, employees, suppliers, public bodies and NGOs. It defines the roles and responsibilities of internal entities and is made available to all employees via the intranet. The climate policy is rolled out through other BlueBook policies, notably by integrating management of new capital expenditure and purchases, and by emphasizing three main levers, including zero- or low-carbon energy supply to reduce the Group's CO2 footprint. The supply of renewable and low-carbon energy, and energy efficiency projects, are governed by the Energy Management policy in the BlueBook. Transition risk is managed through ambitious emission trajectory targets, regulatory watch, technological development, use of an internal carbon price for new investments, and central management of an annual carbon budget allocated to regions and reviewed by the Board's Environment and Society Committee.
E1-5(was E1-3)Actions and resources in relation to climate change policiesReported
Since announcing its climate objectives in March 2021, Air Liquide has implemented actions aligned with the three decarbonization levers of its Climate Transition Plan: renewable or low-carbon electricity supply, asset management (including electrification of industrial assets and energy efficiency), and CO2 capture for geological storage or use. Actions are managed at Group level with local sub-actions. Key 2024 achievements include: signing several contracts for low-carbon electricity (renewable, nuclear, hydroelectric, wind) totalling more than 2,500 GWh per year across Brazil, China, France, Germany and Spain; investing nearly 100 million euros in the development of production units serving Aurubis in Europe, with replaced and modernized plants expected operational in 2027; and investing to install a CCS unit using the Group's proprietary Cryocap technology in the port of Rotterdam, connected to the Porthos infrastructure project in the Netherlands to reduce emissions at an Air Liquide site in Rozenburg. Investments to decarbonize assets are not subject to separate budgets and are fully integrated into the Group's industrial investment policy. In 2024 the Group updated its Sustainable Investment Framework and issued a 500 million euro green bond, adding to a first green bond issued in 2021.
E1-6(was E1-4)Targets related to climate change mitigation and adaptationReported
Air Liquide announced its climate objectives in March 2021: an ambition to achieve carbon neutrality by 2050 by reducing emissions across its value chain (precise quantification not yet provided, with residual emissions to be neutralized using high-quality carbon credits); a clear 2035 milestone of a -33% reduction in Scope 1 and 2 emissions compared to the 2020 baseline; and a turning point by 2025. The 2035 target covers absolute CO2-equivalent Scope 1 and 2 emissions on a market-based basis, matching the reporting scope for direct emissions and indirect emissions from electricity and steam purchased. The 2020 reference year was chosen because it precedes the announcement and is considered representative; it is restated only for significant scope or methodology changes per GHG Protocol guidance. The 15-year 2020-2035 horizon matches a typical contractual investment cycle; no 2030 crossing point was set given the time to scale reduction measures. No quantitative Scope 3 reduction target has been announced, though Scope 3 emissions are reported and reduction levers identified. Performance versus the objectives is monitored by Group Operations Control and communicated annually. At December 31, 2024, Scope 1 and 2 emissions were down about -11% versus comparable 2020 emissions.
E1-7(was E1-5)Energy consumption and mixReported
For 2024, total energy consumption was 65,574,681 MWh. Total fossil energy consumption was 50,013,872 MWh, representing 76% of the total, comprising natural gas fuel of 24,364,468 MWhth, crude oil and petroleum products of 149,421 MWhth, other fossil sources of 2,492,490 MWhth, and purchased electricity, heat and steam from fossil sources of 23,007,494 MWhe. Coal fuel consumption was reported as non-material. Energy from nuclear sources was 6,632,957 MWhe (10% of the total). Total renewable energy consumption was 8,927,851 MWh (14%), of which purchased renewable electricity, heat and steam was 8,927,563 MWhe and renewable fuel including biomass was 288 MWhth; self-generated non-fuel renewable energy was reported as non-material. Consumption of electricity from renewable sources amounted to 8.9 TWh, up 18.6% versus 7.5 TWh in 2023, representing 23% of electricity purchased; renewable plus nuclear electricity consumption reached 15.6 TWh. Energy intensity for 2024 was 2,423.50 MWh per million euros of net revenue, treated as a high climate impact sector with no further disaggregation. Non-renewable energy production was 24,914,015 MWh (thermal and electrical); renewable energy production was deemed non-significant. Reported figures exclude raw material consumption.
E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissionsReported
For fiscal year 2024 (tCO2eq): gross Scope 1 GHG emissions were 14,868,470 (96.1% of restated 2023 of 15,473,000; restated 2020 base year 15,505,000). Emissions from units in regulated emission trading schemes represented 48.4% of Scope 1. Gross location-based Scope 2 was 20,682,800 and gross market-based Scope 2 was 20,064,140 (2020 base 23,784,000). Total gross indirect Scope 3 emissions were 23,243,928, dominated by purchased goods and services (6,526,255, category 1), fuel and energy-related activities (6,211,500, category 3), use of sold products (6,845,518, category 11) and downstream leased assets (2,134,902, category 13); categories 5, 8, 9, 10, 12, 14 and 15 are not applicable or not significant. Total GHG emissions were 58,795,198 location-based and 58,176,538 market-based (2020 base 58,737,700). Combined Scope 1+2 market-based emissions were 34,933 ktCO2, about -11% below comparable 2020, in line with the -33% by 2035 target. GHG intensity was 2,150.08 tCO2eq/m euro market-based and 2,172.95 location-based. Direct biogenic CO2 not in Scope 1 was 202 ktCO2eq; indirect biogenic not in Scope 2 was 587 ktCO2eq; biogenic not in Scope 3 was 566 ktCO2eq.
E1-9(was E1-7)GHG removals and GHG mitigation projects financed through carbon creditsReported
Air Liquide's climate strategy is based above all on a drastic reduction in CO2 emissions from operations, and the Group's intention is to minimize the use of offsetting instruments. To date the Group has not mobilised carbon credits to steer its CO2 trajectory, and does not plan to use carbon credits to achieve its 2035 objective. Carbon credits may nevertheless be used occasionally by operational entities, for example in internal seminars or to comply with regulatory schemes such as quota markets; these uses are described as marginal, are not reported at Group level, and are not included in the carbon footprint communicated in the climate indicators, in line with carbon accounting practice. For the Group, offsetting should not replace emission reductions where possible but only cover non-reducible residual emissions, in particular through negative emissions (removals) whose quality must be guaranteed by recognized standards. Residual emissions from customer decarbonization projects that are recognized in Air Liquide's footprint are anticipated to be offset ultimately by appropriate instruments once accounting methodologies for offsetting instruments and Net Zero definitions are clarified. Carbon credits used were not quantified at Group level and were treated as marginal and non-material.
E1-10(was E1-8)Internal carbon pricingReported
Air Liquide uses an internal carbon price for new investments as one of its transition-risk management tools. All projects must incorporate a sensitivity analysis around the carbon price to assess project viability for the customer, since the CO2 price is contractually transferred to the customer. This sensitivity analysis uses the current local price and a value of 100 euros per tonne or more, chosen according to geography and context. This is a notional price applied for sensitivity analyses when developing new investments; its level was initially set with reference to the work of the Stern-Stiglitz Commission (2017). Where an explicit carbon price exists, that price and dedicated projections are used. Because the price applies to the Group's new industrial investments, it covers most of the Group's Scope 1 and 2 emissions. In 2025 the Group plans to review how the carbon price is incorporated into the investment process to strengthen consistency with the 1.5 degrees Celsius scenario used, drawing on IEA work. Beyond noting that it covers most Scope 1 and 2 emissions, a specific percentage of GHG emissions covered by the internal carbon price was not disclosed as a distinct material datapoint.
E3 – Water and Marine Resources
E3-1Policies related to water and marine resourcesReported
In 2021 Air Liquide published an internal water management policy in the BlueBook, accessible to employees, with implementation under the supervision of the Executive Committee. The policy identifies the impacts and dependencies of the Group's activities on water availability and quality and defines water risk management principles based on a specific assessment of each site's situation. It describes the required actions and key principles for appropriate water management, including a set of indicators to be monitored, and details stakeholder commitment, seeking comprehensive management of water uses while complying with the most stringent applicable requirements and regulations. The main water management risk is the potential unavailability of water, which could slow or shut down a production unit; each subsidiary's management is responsible for implementation. The policy aims to guarantee availability of water meeting adequate specifications for safe, reliable and efficient operations, and to protect people and the environment through sustainable water management in operations and supply chains. It covers management of water-unavailability risk in water-stressed areas via a water management plan, and operational excellence using best available techniques for water treatment, withdrawal, consumption and quality of discharged water. Air Liquide respects the human right to water and sanitation and is committed to the ten principles of the UN Global Compact.
E3-2Actions and resources related to water and marine resourcesReported
At this stage the Group does not have consolidated monitoring of the action plans undertaken by operational entities to reduce water use, nor of local value-chain commitments; the related financial resources are not specifically monitored and form part of maintenance and continuous-improvement resources. In the future the Group plans to set up reporting and monitoring of the most significant projects. The Group's continuously improved policy sets key principles of operational excellence for each subsidiary, including: monitoring and reporting impacts and dependencies related to water and installing appropriate meters and treatment equipment; conducting water leak assessments and improvement plans; minimizing freshwater withdrawal and consumption while ensuring safe, efficient production; assessing equipment changes during overhauls or major renovations; minimizing wastewater discharges and maximizing recovered water; measuring and analyzing returned water quality at a frequency set by local regulations; and minimizing contaminants so returned water complies with local standards. In water-stressed areas targeted actions apply, with each facility manager responsible for monitoring water indicators and directing corrective actions, assisted by an appointed water quality manager. Water risk is addressed in the due diligence process for new investments and major renovations in water-stressed areas. The Supplier's Code of Conduct is regularly updated to reflect alignment with the Group's water policy and objectives.
E3-3Targets related to water and marine resourcesReported
Air Liquide has established two water management objectives at Group level. First, for operations in water-stressed areas, a documented water management plan addressing risks related to water withdrawal or use should be put in place. This objective, set voluntarily by the Group at the end of 2021, is monitored annually until the selected date of the end of 2025, targeting completion of 100% of the water management plans for the 75 sites identified in 2021. The Group has not quantified an objective for reducing water needs, but anticipates all significant sites will have such an action plan in future, and is working to set quantitative objectives for the period beyond 2025. Second, for all operations, documented processes and procedures should ensure that the quality parameters of discharged water match those of withdrawn water while meeting or exceeding applicable local standards. Since 2023 the Group's technical standards for water management have been strengthened and apply to all activities, with the ambition to roll them out across all activities, prioritizing water-stressed locations; entities monitor progress annually. These objectives address the prioritization of water-risk areas and the Group's material water impacts, and are aligned with the strictest applicable requirements.
E3-4Water consumptionReported
For 2024, total water consumption was 99,560,000 m3, calculated as the difference between total water withdrawal and total water discharge during the data consolidation phase. Consumption in areas at water risk, including areas of high water stress, was 11,740,000 m3. Total water recycled and reused was 398,940,000 m3. The water intensity ratio was 3,680 m3 per million euros. The share of volumes consumed obtained by direct measurement was 23%. The Group notes that its water consumption represents 11% of water withdrawals, meaning 89% of the water withdrawn is returned to its source. Water is used mainly as a raw material (for example for steam production) or as a cooling system, with Air Separation Units accounting for more than 50% of total consumption, hydrogen production units around 25%, and cogeneration units less than 20%. The Group pays particular attention to the 75 sites withdrawing more than 50,000 m3 per year located in high or very high water stress and arid areas. The source of withdrawal and discharge data (direct measurement, sampling, extrapolation, best estimate) is indicated by each site in the reporting tool. A separate figure for stored water was not disclosed as a material datapoint.
S1 – Own Workforce
S1-1Policies related to own workforceReported
Air Liquide's own-workforce policies are set out in section 3.1.2 (p329) and the topic-specific sections 3.1.3 to 3.1.8. The Group states it respects and promotes human rights across its operations, covering health, safety, non-discrimination, freedom of opinion, expression and association, decent and fair working conditions, and the prohibition of child labor and modern slavery. These commitments are embedded in Air Liquide's Principles of Action and Code of Conduct (detailed in paragraph 4.2.1, p353). The Group references the International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the OECD Guidelines for Multinational Enterprises, and the UN Guiding Principles on Business and Human Rights, and is a signatory of the UN Global Compact. A human rights due diligence process runs under the Vice President, Duty of Vigilance and Societal Responsibility. Topic policies cover diversity, inclusion and harassment prevention (3.1.4), remuneration and benefits (3.1.5), well-being at work (3.1.6), employability (3.1.7) and personal data protection (3.1.8).
S1-2Processes for engaging with own workforce and workers' representatives about impactsReported
Section 3.1.2 (p329) describes engagement with own workers. Air Liquide runs the My Voice engagement measurement program, overseen by the Vice President, Group Human Resources Deputy. Since 2023 it runs on a two-year cycle (a full questionnaire one year, a reduced version the next), covering around 20 topics with anonymized responses analyzed Group-wide. In the 2024 My Voice program, 83% of eligible employees expressed their views, more than 53,000 employees, leaving over 63,000 unsolicited comments. Results feed action plans at team, entity and Group level, whose effectiveness is tracked by indicators or by changes in the associated theme score in the next survey edition. Engagement also runs through employee representative bodies: the European Works Council has 29 representatives from 12 countries (renewed 2021 for four years) and held four plenary meetings in 2024; the France Group committee has 25 representatives (renewed 2024 for two years) and held two plenary meetings. Extra-financial performance topics (safety, employee turnover, training, diversity) are presented to and discussed with the European Works Council.
S1-2(was S1-3)Processes to remediate negative impacts and channels for own workforce to raise concernsReported
Section 3.1.2 (p329) and paragraph 4.2.1 (p353) describe channels to raise concerns and remediate negative impacts. The Whistleblowing Policy is the main process through which employees can raise concerns or complaints, with the ethics whistleblowing system and remedial approach detailed in 4.2.1. Since 2023 a question on the whistleblowing system has been included in the My Voice full survey to measure employees' level of trust. The system is not intended for routine HR issues such as remuneration or career development, which go directly to HR Departments. For the two material topics of health and safety and personal data protection, Air Liquide maintains specific alert mechanisms. The Safety and Industrial System Department runs an internal reporting process for safety and security incidents that informs the management chain quickly by severity, with crisis management and incident monitoring. For personal data, a form on the Air Liquide website and an Information Protection Coordinator allow requests and reporting of possible violations, recorded in a dedicated register and systematically analyzed.
S1-3(was S1-4)Taking action on material impacts on own workforceReported
Actions on material impacts are set out across sections 3.1.3 to 3.1.8. On health and safety (3.1.3) the Group operates an Industrial Management System (IMS), Life-Saving Rules translated into at least 10 languages, Job Hazard Analysis, process safety (HAZOP methodology), road safety measures (onboard cameras, master drivers) and security systems. On diversity (3.1.4) actions include an Inclusion & Diversity roadmap on three pillars, a monthly HR Headcount & Diversity dashboard set up in 2024, bias-mitigation nudges, mandatory annual ethics training, a women's leadership pilot program (123 women in 2024), a maternity leave standard (in force October 2024), and a 6th company agreement in France for disability employment (2023-2025, about 6,000 employees). On remuneration (3.1.5) actions include annual salary reviews accounting for pay gaps, HR awareness sessions, and a partnership with the Fair Wage Network established end of 2024. On well-being (3.1.6) actions include BeActEngage, Career Discussions, Care & Perform and Next Normal. Employability (3.1.7) and personal data protection (3.1.8) actions are also described.
S1-4(was S1-5)Targets related to own workforceReported
Targets are disclosed across sections 3.1.3 to 3.1.8. For health and safety (3.1.3), the Group has not formalized quantitative targets but shares the aim of achieving 'zero accidents' and continuously improving safety performance, contributing to UN SDGs 3 and 8. For gender equality (3.1.4, part of the ADVANCE program), 2025 objectives are 35% women among Group Managers and Professionals (2024 result 33.1%, versus a 30% reference in 2020) and 25% women at the highest level of responsibility or senior executives (2024 result 23.7%, versus 21% in 2020); the Executive Committee target is to maintain 30% women by 2026 under the Rixain Law, standing at 30.7% in 2024. In France, the direct disability employment rate target is 6% by end 2025 (4.69% in 2023). For remuneration (3.1.5), Air Liquide committed to offering a common basis of care coverage to 100% of employees by 2025, with a 100% result in 2024 (from 34% in the 2022 reference year). For well-being (3.1.6) no measurable objectives were set.
S1-5(was S1-6)Characteristics of the undertaking's employeesReported
Section 3.1.1 (p328) gives employee characteristics as at December 31, 2024, on a headcount basis. Total Group employees stand at 66,657 (versus 67,778 at end 2023). By geography: Europe, Middle East and Africa 26,843; Americas 26,089; Asia Pacific 13,725. By contract type and gender: permanent employees total 64,124 (18,419 women, 45,658 men, 47 not disclosed/other) and temporary employees total 2,533 (1,056 women, 1,477 men). Total by gender is 19,475 women, 47,135 men and 47 not disclosed/other. In 2024, 8,995 employees left the Group through resignation, dismissal, mutually agreed termination, retirement or death, representing a turnover rate of 13.5%. HR data is sourced mainly from the Workday system, covering 98% of employees at December 31, 2024, with remaining entities aggregated manually. Section 3.1.4 adds an age breakdown: under 30 years 8,100 (12.2%), between 30 and 50 years 38,427 (57.6%), and over 50 years 20,130 (30.2%).
S1-7(was S1-8)Collective bargaining coverage and social dialogueReported
Section 3.1.2 (p329) covers collective bargaining and social dialogue. In 2024, in the European Economic Area where Air Liquide operates in 18 countries, more than 88% of employees were covered by a collective bargaining agreement. France is the only EEA country where the Group operates with employees representing at least 10% of total headcount, and France falls in the 80-100% band both for collective bargaining agreement coverage and for workers' representation. Collective agreements considered are those concluded at entity, site, industry and national level, per ILO Convention No. 154. Social dialogue runs through the European Works Council (29 representatives from 12 countries, four plenary meetings in 2024), the France Group committee (25 representatives, renewed 2024 for two years, two plenary meetings), Social and Economic Committees of French companies, and negotiations with Representative Trade Unions on social policy. Social dialogue sits under the Human Resources function.
S1-8(was S1-9)Diversity metricsReported
Section 3.1.4 (p336) gives diversity metrics as at December 31, 2024. Total employees by gender: 19,475 women, 47,135 men, 24 not disclosed and 23 other, out of 66,657. France holds 11,940 employees (4,831 women, 7,101 men) and the United States 20,043 (3,791 women, 16,222 men). Senior executives break down as 88 women (23.7%) and 283 men (76.3%). Women make up 33.1% of Group Managers and Professionals and 23.7% at the highest level of responsibility. The Executive Committee was 30.7% women in 2024 (4 women among 13 members). By age group: under 30 years 8,100 (12.2%), between 30 and 50 years 38,427 (57.6%), and over 50 years 20,130 (30.2%).
S1-9(was S1-10)Adequate wagesReported
Section 3.1.5 (p338) addresses adequate wages. Air Liquide strives to ensure all employees receive remuneration at least equal to legal minimum wages where they apply. For all employees excluding apprentices in the European Economic Area, Air Liquide compared base salaries (including fixed allowances where applicable) against local legal minimum wages where they exist, and against 50% of the average gross salary in countries with no legal minimum wage. The comparison showed that 100% of the employees concerned received remuneration at least equal to these reference thresholds. The Group notes the adequate wage does not benefit from an established benchmark and wishes to define a consistent, homogeneous calculation methodology comparable with peers, covering employees across 60 countries. To improve this, at the end of 2024 Air Liquide established a partnership with the Fair Wage Network (FWN), a recognized non-governmental organization, which will refine its analysis from 2025. Remuneration data was consolidated in the HR Information System in its first year of operation in 2024.
S1-13(was S1-14)Health and safety metricsReported
Section 3.1.3 (p331) gives health and safety metrics for 2024. Fatalities: 1 among Group employees and temporary workers (a driver, an Air Liquide employee in the Dominican Republic, in a road accident), and 2 among subcontractors (one from a fall while working at height in Poland, one from the bursting of a gas cylinder in Brazil). There were 319 recordable work-related accidents among Group employees and temporary workers, at a rate of 2.42. Cases of recordable work-related ill health among Group employees numbered 2. Days lost to work-related injuries, accidents, ill health and fatalities among Group employees and temporary workers totaled 4,001. The lost-time accident frequency rate (accidents with at least one day's absence per million hours worked) for Air Liquide employees including temporary workers improved 32% to 0.7 at end 2024, from 1.0 at end 2023; for subcontractors it dropped to 1.1 at end 2024, from 1.3 at end 2023.
S1-15(was S1-16)Compensation metrics (pay gap and total compensation)Reported
Section 3.1.5 (p338) discloses that in 2024 the gender pay gap was 6.7%. This indicator is based on data not adjusted for characteristics such as seniority, experience, performance or the market. It is calculated for the Group, by country and by entity (for entities deployed under Workday) and for four job categories using the ESRS-defined formula: the difference between the average gross hourly remuneration of male employees and that of female employees, divided by the average gross hourly remuneration of male employees, times 100. Apprentices, expatriates and employees who did not declare their gender or non-binary employees are excluded; gross hourly remuneration comprises basic salary, mandatory indemnities and target variable remuneration. Air Liquide monitors the pay gap through annual salary reviews and HR awareness sessions. The annual total remuneration ratio was assessed non-material in the double materiality assessment and is not reported, and S1-16 is absent from the report's ESRS content index; only the gender pay gap figure is disclosed.
S1-16(was S1-17)Incidents, complaints and severe human rights impactsReported
Section 3.1.2 (p329) and paragraph 4.2.1 (p353) cover incidents, complaints and severe human rights impacts. The figures refer to alerts in the Group's ethics whistleblowing system concerning employees reported in 2024, irrespective of processing status or investigation conclusions. In 2024 there were 310 incidents of discrimination, including harassment; 137 work-related complaints other than those related to discrimination (HR-related alerts excluding discrimination and health and safety); and 0 severe human rights incidents (incidents of forced or child labor). As of December 31, 2024, Air Liquide is not involved in any complaint to the OECD National Contact Points for Responsible Business Conduct. The Whistleblowing Policy and remediation approach are detailed in paragraph 4.2.1, and specific alert mechanisms exist for the material topics of health and safety and personal data protection.
S2 – Workers in the Value Chain
S2-1Policies related to value chain workersReported
Air Liquide states it respects and promotes human rights and shares the principles of the International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights. Its core policy instruments for value-chain workers are the Supplier's Code of Conduct (published on its website and based on the Group's Code of Conduct) and the Sustainable Procurement procedure. Adherence to the Supplier's Code is a prerequisite for any commercial relationship. On health and safety, the Code requires suppliers to enforce protective laws, ensure worker safety and comply with Air Liquide's Life-Saving Rules. On working conditions, it requires compliance with working-time and overtime laws, payment of at least the legal minimum wage and fair compensation, and use of certified recruitment agencies. On forced and child labor, it prohibits all forced and compulsory labor, involuntary prison labor and modern slavery, and sets a minimum working age no lower than the legal minimum or 15 years (whichever is higher), with hazardous work restricted to workers aged 18 or over.
S2-2Processes for engaging with value chain workers about impactsReported
The Group Procurement Department engages with suppliers about their potential impacts on their own workers through several channels. At qualification, suppliers must adhere to the Supplier's Code of Conduct and the Group's Code of Conduct in contracts. During the annual assessment campaign for Sustainability-Critical Suppliers, the Group engages with them to assess performance and, where necessary, to establish and implement corrective action plans. Air Liquide also uses monitoring mechanisms to collect the interests and views of value-chain workers through their legitimate representatives, such as international trade unions, or credible proxies such as civil society organizations or third-party assessment companies. The supplier relationship and risk management procedure requires preliminary checks before qualification, using Dow Jones databases (including international sanction lists) and adverse media, which surfaces workers' claims and grievances; the Sustainability-Critical Supplier assessment also includes a controversy component. The International Trade Union Confederation's Global Rights Index feeds the country-risk assessment. The Procurement Department and the Duty of Vigilance and Societal Responsibility Department continuously monitor countries and topics of interest to civil society.
S2-2(was S2-3)Processes to remediate negative impacts and channels for value chain workers to raise concernsReported
Air Liquide states that the Group whistleblowing system is accessible to all workers in the value chain in order to prevent the occurrence of negative impacts and to implement the necessary remedies. Suppliers are informed of this possibility through the Supplier's Code of Conduct, which includes a section on the ethics whistleblowing system. The Whistleblowing Policy and system to which value-chain workers have access are described in paragraph 4.2.1 of the Sustainability Statement (page 353). In addition, the media watch conducted as part of preliminary supplier checks (using Dow Jones databases, international sanction lists and adverse media articles) makes it possible to report claims and grievances of workers in the value chain, and the Sustainability-Critical Supplier assessment includes a controversy component. Where suppliers are found needing improvement or non-compliant, corrective action plans are required and may be supported by on-site environmental or social audits, providing a means to remedy situations affecting value-chain workers.
S2-3(was S2-4)Taking action on material impacts on value chain workersReported
On health and safety, contracts with suppliers and subcontractors include safety clauses, new suppliers undergo a technical assessment covering safety and reliability, the Group communicates its safety values and standards to on-site subcontractors, and it assesses their safety performance after task completion. The Safety and Industrial System Department runs an internal incident-reporting process open to suppliers' and subcontractors' workers present on Air Liquide sites. On working conditions, the annual Sustainability-Critical Supplier assessment uses EcoVadis (in 2024) or an internal 10-question questionnaire; suppliers are rated responsible, needing improvement or non-compliant against score thresholds, and non-compliant or needing-improvement suppliers must implement corrective action plans, with possible audits and suspension or termination. In 2024, of 804 Sustainability-Critical Suppliers the campaign addressed 626: 516 were invited to complete a questionnaire and 426 (83%) were assessed (37% via the third-party platform, 63% via Air Liquide's internal questionnaire); 102 suppliers needing improvement were invited to set up plans and 101 did; 8 non-compliant suppliers were invited and all prepared and completed plans. On forced and child labor, the assessment covers human-rights standards and new suppliers face preliminary negative-press checks.
S2-4(was S2-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesReported
For health and safety, the Group has not formalized quantitative targets, but assesses effectiveness through the Sustainability-Critical Supplier assessment and health and safety indicators for value-chain workers on its sites. For working conditions, three key performance indicators are tracked. In 2024, the share of Sustainability-Critical Suppliers addressed by the annual campaign that responded was 83% against an 80% objective; the share of suppliers needing improvement that prepared a corrective action plan was 99% against a 96% objective; and the share of non-compliant suppliers that prepared and implemented a corrective action plan was 100% against a 100% objective (reflecting zero tolerance). The average current score on the external platform was 56/100 for Sustainability-Critical Suppliers, with human rights and working conditions and the environment highest at an average 57/100 and sustainable procurement procedures lowest at 49/100. For forced and child labor, Air Liquide states that, with the exception of the working-conditions objectives described above, it does not have additional human rights due diligence objectives for value-chain workers.
S4 – Consumers and End-Users
S4-1Policies related to consumers and end-usersReported
Air Liquide's consumers and end-users are primarily the patients of its Home Healthcare business, covering 2.1 million patients with chronic diseases. The Group states it respects human rights and shares the International Bill of Human Rights, the OECD Guidelines and the UN Guiding Principles on Business and Human Rights; its Principles of Action set out commitments to patients and to protecting vulnerable lives (described in paragraph 4.2.1). Three material topics have dedicated policies. For personal data protection, robust governance and policies described in paragraph 3.1.8 (including Binding Corporate Rules adopted in May 2018 and a personal data protection policy) apply to patients as well as employees. For patient health and safety, the Group operates an Industrial Management System covering all businesses, plus pharmacovigilance (for drug-status products) and medical device vigilance processes. For access to quality information, subsidiaries provide accurate information through written, verbal and video materials, with central content validated by the Regulatory Affairs Department and a review committee. Air Liquide notes there is no specific policy or channel for patients to report misuse of a product linked to incorrect or inaccurate information.
S4-2Processes for engaging with consumers and end-users about impactsReported
Since 2017 Air Liquide has run a customer-centric transformation supported by a Voice of Customer (VoC) management tool that lets all entities regularly poll customers and patients, analyze comments in real time, identify dissatisfied people and act. VoC is available as an annual survey covering all stages of the experience and a more frequent transactional survey, and has been rolled out across 88% of the Group's sales worldwide. The annual survey feeds a Group-level Net Promoter Score. In 2024, 90% of Air Liquide's customers and patients were satisfied. For patients specifically, interests and views are taken into account in two ways: some Home Healthcare subsidiaries (for example in France) intervene directly in patients' homes and regularly collect opinions that inform how care is adapted, and where data-protection rules allow, subsidiaries send patients satisfaction surveys at least once a year, after which each subsidiary sets up an action plan to address dissatisfaction. Home care providers also report patient needs to prescribers to adapt treatment and improve adherence.
S4-2(was S4-3)Processes to remediate negative impacts and channels for consumers and end-users to raise concernsReported
The Whistleblowing Policy is one of the main processes by which Air Liquide collects complaints. The policy, the ethics whistleblowing system and the approach to finding a remedy are described in paragraph 4.2.1 (page 353), and the system is open to everyone, including patients. Air Liquide states that, for patients, there is currently no specific communication to inform them of the existence of this Whistleblowing Policy, and that this is an area of reflection for the coming years. For the two material topics of personal data protection and patient health and safety, the Group has specific alert mechanisms to identify and report incidents and patient concerns: the tools for collecting requests to exercise rights and alerts regarding personal data breaches described in paragraph 3.1.2 (page 329), and the pharmacovigilance and medical device vigilance processes described in paragraph 3.3.3. A system for reporting adverse effects of medical gases and equipment has been set up in accordance with European and local regulations to take patient feedback into account and implement corrective actions.
S4-3(was S4-4)Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actionsReported
Actions to protect patients' personal data are those described in paragraph 3.1.8 (page 343), including the Data Protection Officer supported by a network of more than 150 Information Protection Coordinators. For patient health and safety, pharmacovigilance is covered by an online training module that all exposed employees of the health activities must complete annually; the module is mandatory and its completion by all employees was added as a profit-sharing criterion in 2024, with a quiz where a score of at least 80% earns an individual certificate. A system for reporting adverse effects of medical gases and distributed equipment has been established in line with European and local regulations, and medical device vigilance teams in subsidiaries analyze incidents and inform suppliers and health authorities. For access to quality information, a Patient Centricity program was set up in 2024 for the European subsidiaries, and a quality-of-information indicator is monitored for all European Home Healthcare subsidiaries to track locally implemented actions.
S4-4(was S4-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesReported
Objectives for the protection of patients' personal data are those described in paragraph 3.1.8 (page 343); the Group measures effectiveness through the assessed data-protection maturity of its entities, which reached 3.48 out of 4 in 2024. For patient health and safety, Air Liquide's objective is to train 100% of eligible employees in the main principles of pharmacovigilance each year; the results of each annual training campaign are documented and managed and may be communicated to health authorities during pharmacovigilance inspections. For access to quality information, under a new internal policy for measuring the patient experience launched in 2024, all subsidiaries must measure several variables related to the service provided, including their ability to understand patients' needs and convey information clearly (monitored annually). Air Liquide states that no objective is currently associated with this or any other metric concerning access to quality information for patients, and that a reflection will be initiated in 2025 on a potential objective depending on first-year results.
G1 – Business Conduct
G1-1Business conduct policies and corporate cultureReported
Air Liquide's corporate culture rests on its Principles of Action and Code of Conduct, which affirm values of safety, transparency, respect, rigorous management and continuous improvement and are published on the Group website. The Code of Conduct, available in 28 languages, is structured around three chapters: Acting with Care, Acting with Integrity and Transparency, and Acting Responsibly. It applies to all employees, officers and Directors, and business partners are expected to comply. The BlueBook translates these principles into policies and procedures. Rollout is led by the Group Ethics Officer and supervised by the Ethics and Compliance Committee, which meets twice a year. A mandatory annual Code of Conduct e-learning covered cybersecurity and digital protection, conflicts of interest and a whistleblowing reminder in 2024, with 97% employee participation. The Whistleblowing Policy defines reporting channels (EthiCall for all entities and stakeholders; EthicsPoint added for Airgas in 2024) and complies with Directive (EU) 2019/1937. In 2024 the system logged 558 alerts (Human Resources 422, health/safety/environment 28, fraud 55, other compliance 53). As of December 31, 2024, 125 alerts were still being processed; of the 433 closed, 38.6% were substantiated or partially substantiated.
G1-2Management of relationships with suppliersReported
Management of relationships with suppliers is based on the supplier risk and relationship management procedure, which defines the supplier qualification process to identify associated risks, and the Sustainable Procurement procedure, which integrates ethical, social and environmental aspects into procurement (described in paragraph 3.2, page 344). The Procurement Function communicates its sustainability requirements through two instruments: the Supplier's Code of Conduct and a sustainability clause included in supplier contract templates, including framework agreements. The Supplier's Code of Conduct promotes respect for human rights, ethics, environmental protection and safety, is based on the Group's Code of Conduct, and supplier adherence is a prerequisite for all commercial relations. Its 2023 revision aligned it with new regulatory expectations, adding articles on conflict minerals and the whistleblowing system. The Procurement Function may require sustainability specifications at local or category level, defined with specialist functions, covering the goods or services, the production and delivery process, or the supplier organization. Air Liquide's Procure-to-Pay (P2P) procedure frames all employees involved in procure-to-pay activities and is jointly owned by the Procurement and Finance Departments together with entity Managing Directors.
G1-2(was G1-3)Prevention and detection of corruption and briberyReported
Air Liquide's commitment to prohibit all forms of corruption, set out in the Principles of Action, is supported by an anti-corruption program relying on: mapping of corruption risks; the Code of Conduct; a full set of training and awareness actions for those exposed to corruption risks; a third-party assessment mechanism; a whistleblowing system; and accounting controls. The Group also has a Supplier's Code of Conduct with a chapter on corruption prevention. The program is coordinated by the Group Ethics Officer, supported by a network of ethics correspondents and the Legal and Human Resources Departments, and is regularly audited. Detection relies on the whistleblowing system and on controls and audits, with an internal fraud management procedure. Progress is monitored by the Ethics and Compliance Committee and presented annually to the Audit and Accounts Committee. Exposed and particularly exposed functions (typically sales, procurement and administration) are identified from job profiles and risk mapping. They must complete an annual e-learning, supplemented by face-to-face training every three years for particularly exposed functions. In 2024, the anti-corruption e-learning covered 20,110 people (95% completion), classroom training 11,578 people (23%, on a three-year rotation), and the Code of Conduct e-learning 64,123 people (97%).
G1-4Incidents of corruption or briberyReported
Air Liquide reports on confirmed incidents of corruption and bribery. In 2024, Air Liquide has not been convicted for violation of anti-corruption and anti-bribery laws. The double materiality assessment concluded that corruption and bribery (prevention, training, incidents) is a material topic, noting that the absence or failure to prevent or detect corruption could constitute a violation of applicable anti-corruption laws or expose the Group to legal proceedings or sanctions damaging its reputation. Detection of possible incidents relies on the whistleblowing system and on controls and audits, with entities applying an internal fraud management procedure to report and process cases. In 2024 the ethics whistleblowing system recorded 55 fraud-related alerts out of 558 total alerts, and of the 433 closed alerts 38.6% were considered substantiated or partially substantiated and led to corrective measures and remedies.
G1-5Political influence and lobbying activitiesReported
Lobbying and political influence were assessed material. Air Liquide drafted and issued a Public Affairs Charter in 2021 governing its interactions with public authorities at national, regional/European and international levels, guided by principles of transparency to avoid practices undermining the Group's values of integrity. The Group's Board of Directors, in particular the Audit and Accounts Committee, regularly reviews engagement with public stakeholders, which is coordinated by the European & International Affairs Department (budget, organization, engagement principles, objectives and actions). The Group General Secretary, an Executive Committee member, oversees the European & International Affairs Department among others. There are no members of the Board of Directors or Executive Committee who have held previous functions in national public administrations. Key public-affairs themes cover energy transition (low-carbon energy sourcing, CO2 emission reduction mechanisms, hydrogen and CO2 networks and mobility), electronics (semiconductor industry, industrial sovereignty) and healthcare. Air Liquide publishes its Public Affairs Charter and key positions on its website and is registered in the transparency registers of the European Union (id 94857385769-70), France (HATVP, organisation 552096281) and the USA (US Senate lobbying disclosure register).
G1-6Payment practicesReported
Supplier payment practices were assessed material, being an essential component of supplier relationships and important for the viability of SMEs. The Procure-to-Pay procedure recommends monitoring Days Payable Outstanding and the percentage of invoices paid on time. Contractual payment terms vary by country and supplier activity and must comply with local laws. Based on payment terms indicated on invoices received in 2024, expenditure broke down as: Immediate 24.9%, Net 20 days 5.2%, Net 30 days 22.4%, Net 45 days 7.3%, Net 60 days 13.1%, and Other 27.1%. Air Liquide does not distinguish between small, medium-sized and large companies in its payment practices. The largest expenditure item is energy (electricity and natural gas); in 2024, 54.6% of these expenses had to be paid immediately, 14.9% at 20 days net and 14.2% at 30 days net. The average Days Payable Outstanding was 63.5 days in 2024. 93.6% of trade payables were aligned with contractual payment terms (a share ranging from 93.0% to 94.3% over the period retained). As at December 31, 2024, the Group had no knowledge of any ongoing legal proceedings concerning late payments.