In 2020, EDF is strengthening the governance of its vigilance plan. A dedicated compliance officer has been appointed to the Sustainable Development Division. This officer is in charge of supervising the plan and reporting, using feedback from entities and working in cooperation with the Duty of Care Committee together with the other relevant corporate Divisions (legal, risks, ethics and compliance, human resources). Directors appoint a Duty of Care Officer within the entity they manage, who may be either the Ethics and Compliance Officer or the Sustainable Development Officer.
The Global Framework Agreement on Corporate Social Responsibility signed by EDF in 2018 with the Group’s trade unions and two international trade union federations (IndustriAll and ISP) states that EDF’s vigilance plan will be “developed and set up in association with the Company stakeholders, including workers’ representative organisations.”
An annual meeting is organised for all of the signatories of the Agreement who sit on the Committee for Dialogue on Social Responsibility (CDSR) in order to work together on methodology for the vigilance plan. In 2020, work is scheduled with the members of the CDRS to jointly design new tools useful for operational staff and to optimize risk mapping on the duty of care. In 2019, training sessions on human rights and the law on the duty of care were organized at the ILO in Torino for all CDSR members with managers from the Social Dialogue Division (Group HRD).
Externally, EDF participated in discussions with other companies, lawyers, NGOs, and trade union federations within the framework of the “Entreprises pour les droits de l’homme” (Businesses for Human Rights) (EDH(1) non-profit organisation), in order to openly exchange on the expectations of all stakeholders, compare corporate practices and improve vigilance plan preparation processes.
EDF participated in the study commissioned by the ILO, which was presented in December 2019 on the implementation of vigilance plans.
For EDF, the risks covered under the vigilance plan meet the criteria for “salient risks” in accordance with the UN Guiding Principles on Business and Human Rights.
Risk identification relies on the same methodological basis as general (global, comprehensive) risk mapping for the Group, which is of wider scope. Each Group entity maps internal and external risks under the management’s responsibility using common evaluation and risk control criteria (see section 2.1.2.1).
General mapping ranks Group risks based on their degree of criticality, as determined from a comparative analysis of three criteria: impact, probability, level of expertise and control. Using this as an initial basis, the vigilance plan determines three categories of main risks which may be related to:
1. the safety and health of employees and service providers (see section 2.2.1-1C);
2. the impact of the Group’s activities and supply chain on the climate (see section 2.2.4-4C and 3.2.1.1.5. presenting a comprehensive GHG report on Group level, i.e. including scope 1, 2 and 3);
3. industrial activities (outside of nuclear and hydropower) and their impacts on the environment and biodiversity (see section 2.2.1-1H).
Risks related to nuclear security (see section 2.2.2) and hydropower security (see section 2.2.1 -1B) are categorised as among the main risks in the Group’s general risk mapping. Having a “security culture” and maintaining control of these risks constitute absolute priorities for the Group and are the watchwords of its global performance.
In terms of harm that could be caused to individuals and the environment, the Group considers that the most sensitive risks it faces are connected to its international business. These risks are analysed using mapping performed by the relevant entities based on three main criteria: contexts in host country, features of the projects themselves and their impacts, characteristics of the chain of suppliers and services providers involved.
Regarding the supply chain, risk mapping is performed by the Group Procurement Division. EDF’s 253 purchasing segments involving 12,800 suppliers and subcontractors are mapped. The main risks concern:
1. health and safety at work, particularly lifting/handling/maintenance services;
2. the environment, mainly by the production of waste during operating and dismantling phases of facilities; as well as the use of rare materials, in particular with suppliers of IT and telecommunications equipment;
3. human rights, particularly in the textile industry which supplies Personal Protective Equipment for employees.
Analysing this mapping enables EDF to establish priorities for evaluations, controls and audits (see section 3.3.3.2.2).
In the area of human rights and fundamental freedoms, the duty of care has led the EDF group to establish a reasonable diligence plan for all of its entities, which is implemented on the ground by identifying salient risks and the related measures to mitigate such risks. These risks are first assessed based on the country where the entity, its subsidiaries and its suppliers do business with a particular focus on higher risk countries. For EDF’s activities and projects in Latin America, Asia, Africa and the Middle East, due to local practices and legislation which are less demanding than the standards applicable in OECD countries, the Group identifies:
1. risks of harm to communities, indigenous peoples and vulnerable groups (in particular when engaging in dialogue and concertation processes and when there are land issues or displacement of populations);
2. risks due to working conditions, including forced labour and child labour;
3. risks relating to practices of Security Departments or companies.
Mapping of environmental risks is performed based on the Group’s line of industrial activities. These risks are identified, evaluated and ranked using the Group’s environmental management system (EMS). The following points are given priority:
1. impact on the climate;
2. impact on various compartments of environment (water, soil, air, biodiversity);
3. waste management and the natural resources footprint;
In addition, chemical risks, due to their potential consequences, are studied in detail.
On the international level, risks of serious harm are first assessed based on the country where the entity, its subsidiaries and its suppliers do business or have their products manufactured. Points of vigilance given priority concern activities conducted by the chain of suppliers and service providers in Latin America, Asia, Africa and the Middle East and in certain cases, the European continent where local practices and legislation may be less demanding than in France or in the European Union. The main risks concern:
1. respect by the supply chain of the Group’s commitment to the carbon trajectory;
2. protection of biodiversity;
3. waste management (conventional waste, solar panels, batteries, etc.).
Mapping risks of harm to the Health and Safety of workers, customers and the public is performed by the Health and Safety Division within the framework of the EMS;
For Group employees, service providers, suppliers and subcontractors, the risks given priority are:
1. occupational accidents;
2. occupational illnesses (asbestos, ionising radiation);
3. musculoskeletal diseases and anxio-depressive disorders.
(1) e-dh.org.
