Chemical risk
When it is technically feasible, in order to reduce the pollution risks, the Group’s entities have also implemented a programme to eliminate or substitute certain chemical substances with more environmentally-friendly products. This work focuses as a priority on CMR (carcinogenic, mutagenic, or toxic for reproduction) substances or those considered extremely worrying (see section 3.1.2.4.4).
Radiological risk
Nuclear security is EDF’s top priority and a permanent and major area of concern for the Group. Nuclear security is based on technical and organisational specifications aimed at preventing a nuclear accident, and in the hypothetical case of such an accident, at limiting the consequences thereof (see section 2.2.2). Regarding radioactive waste, in compliance with applicable legislation, EDF has set up an industrial waste management and reduction plan for the waste it produces through operations and dismantling which respects the environment and the health of people and relevant personnel (see section 3.3.2.2.5).
Hydropower risk
Hydropower safety comprises all the measures taken when designing and operating dams and plants to reduce risks and hazards to people and property associated with water and the presence or operation of facilities (see section 2.2.1 -1b). Responsible use and sharing of water are governed by EDF’s sustainable development policy and the EMS (see section 3.3.2.2.1).
To prevent and mitigate risks of serious harm to the health and safety of its employees, suppliers and subcontractors working on its sites, the Group relies on a Health and Safety policy further strengthened by the signed endorsement from the Chief Executive Officer and all of the Executive Committee members. This policy is supported by a roadmap and defines the framework for consistent policy and action plans in the various subsidiaries (see section 3.3.1.4).
The Health and Safety policy sets down as an absolute priority the elimination of fatal accidents (3.3.3.1.), followed by the reduction in the number of accidents, as well as absenteeism. The risks identified are used for information campaigns. The Group entities perform a self-evaluation based on the 10 “Essential Rules” specifically defined by EDF to prevent the occurrence of serious, and particularly, fatal, accidents. High Potential Events (HPE) are shared and analysed to foster experience-based feedback.
EDF promotes the concept of general health and relays public health campaigns. Regarding the health and safety of its customers and the public, the Group’s entities implement customised information campaigns on electricity usage (see section 3.3.1.1.4), including in the areas surrounding EDF sites.
The Group’s Purchasing policy states that respect for contractual commitments and the requirements of sustainable development policy in favour of people and the environment “constitute the foundation of the relationship with suppliers”.
A “responsible purchasing” policy led by the Group Procurement Division makes it possible to identify supplier-related risks (see section 3.3.3.2.2.). This policy includes, among other initiatives, the use of CSR performance requirements in contractual clauses. Serious discrepancies identified amongst our suppliers may compromise the contractual relationship and entail termination of the contract.
Suppliers’ respect for environmental and societal undertakings is mainly ensured by giving priority to supplier evaluations which are defined based on the risk mapping performed by the Procurement Division. In segments falling into the major risks category, the high-priority evaluations are carried out either by way of questionnaire in compliance with ISO 26000, which are completed by the suppliers and their subcontractors or by audits(1) performed by outside service companies.
In the coal supply chain, EDF no longer has direct contractual relations with mining companies or the market, but remains an active supporter of Bettercoal(2) – the initiative for responsible coal purchases of which EDF is a founding member. Concerning uranium supply chain, clauses authorising the completion of audits and setting out EDF’s requirements in terms of enforcement of the fundamental rights and main international standards by suppliers and subcontractors have been included to the contracts. The system implemented by EDF since 2011 to audit uranium mines makes it possible to ensure good environmental, social and societal conditions for ore mining and treatment (see section 3.3.3.2.2.).
Since 2018, the Group’s whistleblowing system has been extended to include third parties in addition to EDF employees and external or occasional employees, who all have the possibility of using the whistleblowing system to report any risk of a serious violation of human rights and fundamental freedoms, serious harm to the environment or the health and safety of people. Whistleblowers are guaranteed protection in accordance with applicable legislation.
The Ethics and Compliance Division examines the admissibility of reports recorded through the system (see section 3.3.1.1.1). The Ethics and Compliance Division assesses the reports received on the basis of the law on the duty of care (see section 3.3.1.1.1).
In order to monitor the measures implemented and evaluate their effectiveness, EDF relies on indicators established for the purposes of its non-financial reporting processes that cover the areas involved in the duty of care (see 3.4.1. “Indicators”), as well as the monitoring system for Group risks and the monitoring system for the six Corporate Responsibility Objectives which are all part of the Group’s strategic loop.
As of 2020, Directors will be appointing a Duty of Care Officer in the entities they manage who may be either the Ethics and Compliance Officer or the Sustainable Development Officer.
Each year, a report on the vigilance plan is presented to the Committee for Dialogue on Social Responsibility (CDSR) as well as to the Committee for Corporate Responsibility of the Board of Directors.
According to the internal control guide, entities and subsidiaries have the obligation to design a self-assessment sheet for the vigilance plan. The purpose of this sheet is to analyse the assessment of the risks identified (analysis of results, facts, causes and consequences), evaluate the entity’s control and performance, and set out the objectives of its yearly action plan. They are asked to focus particularly on the evaluation of suppliers. Regular audits are conducted by the Group Auditing Division.
In addition, within the framework of the Responsible Purchasing plan, the Group Procurement Division, the main divisions and the subsidiaries carry out CSR evaluations on their suppliers and subcontractors using both questionnaires and audits administered directly or by independent firms (see section 3.3.3.2.2). Each year, almost 10,000 evaluations are performed, making it possible to audit roughly 2,000 suppliers. Additionally, CSR evaluations and audits are performed. Examples of this can be found at the Nuclear Power Production Division (DPN), which conducts around one hundred qualification and follow-up audits per year and with the Group Procurement Division, which administers around one-hundred questionnaires and performs roughly fifty audits worldwide.
In 2019, the EDF group continued to implement the requirements of the duty of care in all of its activities and relations with suppliers and subcontractors.
For new investment projects in mainland France, French overseas regions and territories and abroad, the identification of risks, discussed within the various Group Investment Committees, and particularly within the Investment Committees of the Group Executive Committee(3) (CECEG) and the International Business Development
(1) Auditing standards are based in particular on ISO 26000, OHSAS and SA80000.
(2)bettercoal.org/.
(3) This undertaking concerns new projects involving investments of more than €50 million, entailing a significant impact on regions and the environment.
