How does REACH affect Grupo SOS?

Acting in a manner likely to improve the health and wellbeing of our employees, consumers and clients, as well as in the interests of protecting the environment in all those areas in which we conduct our activities, constitutes a strategic objective for Grupo SOS. Grupo SOS is committed to the safety of the products it manufactures and to meeting its obligations under REACH rules.

The main activity of Grupo SOS is in the field of the manufacture of foodstuffs, where in terms of REACH rules it acts as an intermediate user of certain substances used in its production processes. It should be remembered here that substances destined for human or animal consumption, together with all additives and preservatives used therein, fall outside the remit of REACH rules, as stated in Article 2.5 of the Agency’s rules.

As an intermediate user, Grupo SOS must report all information concerning the regulated substances and their movements within the supply chain, whether upstream or downstream.

Another of the activities of Grupo SOS is energy co-generation. Via our subsidiary COANSA Group SOS produces biodiesel from vegetable oils. In doing so the Group–COANSA acts as a manufacturer of substances according to REACH rules. The substances concerned are biodiesel and its by-product, glycerine.

Grupo SOS uses the high value-added by-products obtainable from refining vegetable oils to convert them into vegetable squalene, itself a high value-added product marketable for a number of purposes, chief among them being cosmetics.

Lastly, we wish to report that at the present time all the substances falling under the remit of REACH and manufactured by Grupo SOS are substances in a transitory stage, meaning that they must all be registered.

What steps is Grupo SOS taking to meet its obligations under REACH?

1. Grupo SOS has set up a multidisciplinary team to respond to all its obligations under REACH. The team is headquartered in Madrid and is made up of experts in the areas of: procurement, production, sales, legal, environment, corporate responsibility, security and prevention.
2. In addition an outside consultant has been engaged to identify the substances for which the Group is liable as manufacturer and to work out an action plan. These steps were concluded in July 2008.

At present the Group plans to take the following steps:

1. Contract its clients and suppliers to work out the best means of meeting our obligations under REACH.
2. Pre-register the substances the Group manufactures, in order to benefit from the grace periods awarded for pre-registration under REACH. The Group plans to pre-register as a minimum the following substances: biodiesel, glycerine and vegetable squalene.
3. Following pre-registration, the Group will review all the substances it manufactures or imports in order to draw up a list of substances to be registered in due course.

Novelties

• November 2008: All the substances falling under the remit of REACH and manufactured by Grupo SOS has been pre-registered.
• March 2009: Grupo SOS has developed an internal procedure to report all information concerning the regulated substances (handled as an intermediate user or manufactured by the organization) and their movements within the supply chain.

From time to time we will report to stakeholders here on our website on the progress made.

In the meantime if any of you have any questions relating to SOS products and REACH, please direct them to our REACH team using the following email address: reach@gruposos.com