3. Non-financial performance
3.3 EDF, a company committed to a just and fair transition3.3 EDF, a company committed to a just and fair transition
3.3.1 EDF, a company with a responsible attitude to people and communities
The attention the EDF group pays to people covers the stakeholders identified in its mapping (see section 3.6.6 “Stakeholder mapping”).
3.3.1.1 EDF, a company with a responsible attitude to people
3.3.1.1.1 Ethics and compliance
The EDF group promotes a culture of integrity and applies a zero tolerance policy towards fraud and corruption. Ethical conduct in accordance with the law is the absolute rule for all Group employees, at all levels of the organisation, and without exception.
Organisation of ethics and compliance at the EDF group
Governance
The EDF Executive Committee (Excom) is responsible for determining the orientations and priorities of the ethics and compliance programme, allocating the necessary resources and ensuring the monitoring and control of its implementation. The Board of Directors of EDF, through its Corporate Governance and Social Responsibility Committee, oversees the Company’s incorporation of ethical and compliance considerations into its works. Every year, the Executive Committee and the Governance & Corporate Responsibility Committee also receive an activity report drawn up by the Group Ethics & Compliance Division.
In December 2019, the Group held its first Ethics & Compliance Day. This is a key event for the EDF group in its role as a responsible company.
The Group Ethics & Compliance Division and its ethics & compliance network
Reporting to the General Secretary, the Group Ethics & Compliance Division manages and coordinates, in liaison with the divisions concerned, the implementation of the Group’s ethics & compliance programme. This programme is created to meet the requirements of national and international regulatory authorities and local practices. The programme places all EDF executive directors and, more generally, all employees at the heart of the compliance system.
A network of around 50 Ethics & Compliance Officers within the French entities and internationally share and deploy the Group’s Ethics & Compliance Policy.
The Ethics & Compliance Officers take part in Management Committee meetings and report directly to the directors of the entities on ethics & compliance matters and on the associated action plans. EDF is a member of several anti-corruption groups and non-profits. In 2016, it joined Transparency International France, in which it participates in the Forum of Engaged Companies (Forum des entreprises engagées or FEE) composed of companies looking to adopt the highest standards of transparency and integrity.
EDF group Ethics Charter and values
The Group Ethics Charter sets out the values shared by all EDF staff, places ethical requirements at the heart of corporate responsibility and, in accordance with the Chairman’s commitment, promotes ethical behaviour in all professional activities. Updated in 2019, the Group Ethics Charter now focuses on the Group’s three values “Respect, Solidarity and Responsibility”, each featuring 4 requirements. It is available in French and English on the EDF group website and in eleven other languages in which the Group works.
Group Ethics & Compliance Policy
In 2016, the Executive Committee adopted the Group Ethics & Compliance Policy (PECG), which comprises the Company’s compliance programmes as well as the main rules that executive directors must know, observe and enforce within their entities, which are strictly aligned with the risks of these entities. The PECG was updated in January 2020 and now includes thirteen compliance programmes:
- preventing the risk of corruption and influence peddling;
- preventing conflicts of interest;
- the fight against fraud;
- compliance with international sanctions programmes;
- prevention of harassment and discrimination;
- prevention of market abuse;
- prevention of the risk of money laundering and financing of terrorism;
- compliance with the EMIR regulation;
- compliance with the REMIT regulation;
- preventing breaches of competition law;
- personal data protection;
- export control (dual-use goods);
- and duty of care.
The anti-corruption programme
In accordance with the French law of 9 December 2016 on transparency, the fight against corruption and the modernisation of the economy, known as the “Sapin 2” Law, EDF set up an anti-corruption compliance programme taking account of legal requirements:
- an ethics & compliance code of conduct included with the internal rules of procedure and a disciplinary mechanism. This code of conduct defines and illustrates, through practical cases, the different types of behaviour employees are likely to face as a result of the Company’s business activities and organisation, and which should be prohibited given that they may constitute acts of corruption or influence peddling. It sets rules for all the themes identified during the risk mapping process. It prohibits facilitating payments, and restricts gifts and invitations. Breach of any of its rules may result in disciplinary sanctions. It can be viewed by third parties on EDF’s site in French andEnglish(1) ;
- a whistleblowing system (described below);
- risk mapping: Ethics & compliance risk mapping is part of the Group Risk Division’s annual internal control self-assessment process. Based on this, the entities draw up action plans appropriate to their operational contexts to prevent and mitigate these risks. Since 2018, a specific “corruption” risk map was prepared, which identifies and prioritises, by business sector and country, risks of exposure to corruption;
- accounting controls: Control procedures have been established for the Company’s different processes. Following a technical analysis, any anomalies likely to be characterised as fraud are, where applicable, forwarded to the entity’s Ethics and Compliance Officer;
- training schemes: The Group Ethics & Compliance Division is developing prevention measures and training for all employees. It has a dedicated community on the Group intranet that provides a range of training materials. It organises standard in-class training courses, particularly for members of the ethics & compliance network, subsidiary directors, and contract managers. The Group Ethics & Compliance Division has introduced a “Preventing the risk of corruption” e-learning module for executives. As of 31 December 2019, 62% of executives had completed the module. The target is for 100% of executives to have been trained by 31 December 2021.