Universal Registration Document 2020

The EDF group complies with the ILO standards and all applicable laws and regulations governing working time, based on the following principles, subject to the exceptions approved by the ILO:

• regular working weeks should not exceed 48 hours;
• working weeks are limited to 60 hours, including overtime;
• workers should have at least one day off for every seven days worked, except in emergencies or unusual situations;
• workers should have at least three weeks of paid leave for a full year of service;
• workers are entitled to at least 14 weeks of maternity leave.

The EDF group strives to comply with the ILO standards on pay, working conditions and benefits. The Group is committed to paying a living wage, covering the basic needs of its employees and their families, and to providing adequate social security cover for all its employees. When employee accommodation is provided by theCompany, the EDF group ensures that decent housing or accommodation is provided in compliance with the ILO standards.

In 2018, EDF signed a new global agreement on the Group’s Corporate Social Responsibility with two international trade union federations (IndustriAll and ISP) and all of the EDF group’s own trade unions. This agreement automatically applies to all the Group’s employees and effectively reflects its commitment to “makeup holding human rights a prerequisite to all its business activities, and not to tolerate any violation of these rights whatsoever, whether during the course of its business, or by its suppliers, subcontractors and partners”. It confirms that, in the event of conflicting standards with applicable laws in countries in which it operates, the EDF group undertakes to apply the most protective human rights provisions while complying with the national laws. All controlled subsidiaries of the EDF group have now been informed of the agreement and are developing a social progress action plan.

3.3.2.3.3 Rights of local communities

The EDF group is committed to protecting the rights of the local communities affected by its operations and arranging, systematically and worldwide, transparent, debated discussions and consultations for each new project.

The Group recognises the role of human rights and environmental activists. It is committed to protecting the exercise of their rights and ensures that it identifies the risks to human rights and environmental activists caused by its business operations and allows them to speak freely about its operations.

The EDF group identifies, for each project, the potential impact on the health, living conditions and environment of local communities, with reference to the performance standards of the International Finance Corporation (World Bank Group) and proposes suitable measures.

EDF is committed to respecting the specific characteristics and rights of indigenous peoples as defined in the UN Declaration on the Rights of Indigenous Peoples(UNDRIP) and ILO Convention 169, which provides, in particular, that “indigenous peoples shall not be forcibly removed from their lands or territories. No relocation shall take place without the free, prior and informed consent of the indigenous peoples concerned and after agreement on just and fair compensation”.

Whenever its operations threaten or affect the livelihood of a community, the Group implements compensation and/or restoration measures for their livelihood matching or exceeding the level prior to its operations.

The EDF group is committed to respecting and protecting or safeguarding, in agreement with the populations concerned, any expressions of their culture, religion or heritage present on the land used for its operations.

In terms of the use of security forces, the Group is committed to protecting the safety of its employees and sites in strict compliance with human rights, including those of local communities, and only authorises the use of force for preventive or defensive purposes in a manner proportionate to the nature and severity of the threat.

3.3.2.3.4 Implementation of human rights commitments

Human rights commitments are implemented as part of the Group’s CSR commitments and requirements⁽¹⁾, based on the principles of action that apply to all Group operations, such as:

• screening, initial and ongoing, and management of environmental and societal impacts and risks, including those caused by operations under its business relationships;
• organisation, throughout the world, of transparent, debated discussions and consultations for each project;
• the implementation and monitoring of these commitments and requirements is ensured under the Group’s existing internal policies or agreements, in particular the sustainable development policy, the ethics and compliance policy, the purchasing policy, the health and safety policy, the global CSR agreement, the Ethics Charter and the roll-out of the vigilance plan;
• systems for collecting and processing reports of wrongdoing, that are accessible and notified to anyone who could be impacted by the Company’s operations, guaranteeing the confidentiality of the reports and protecting internal whistleblowers (employees and external staff), have also been set up.

EDF strives to implement its commitments in the early stages of its investment processes, including in its business relationships by requiring its suppliers and subcontractors to comply with CSR requirements for operations related to their joint business relationships.

This ensures that human rights aspects are systematically addressed in the analysis of projects presented to the Commitments Committee of the Group Executive Committee and also to the committee that validates the Group’s international development projects, the International Business Development Committee. It involves identifying human rights risks associated with the projects, such as aspects related to workers’ rights and health and safety conditions for the populations concerned, to ensure that EDF’s commitments in this area are taken into account.

In terms of purchasing, the Group Purchasing Department’s CSR risk mapping has included an analysis of “human rights” risks for each purchasing segment since 2019, to determine the level of residual risk and identify the action to be taken with suppliers (see section 3.4.2.3.2 “Responsible procurement strategy and practices”). For fuels, see section 3.4.2.3.3 “Coal and uranium supply chain”.

The “human rights in business” e-learning module developed with the association Entreprises pour les droits de l’homme (i.e. Businesses for human rights), of which EDF is a founding member, has been updated to include the duty of care and is available to all employees.

Performance indicators are monitored at the Group level, based on Cap 2030, via the Health & Safety Policy (see section 3.3.1.3 “Health and safety of employees and subcontractors”), Let’s Talk Energy programme, employee commitment surveys and supplier relations (evaluations, supplier focus survey).

3.3.2.4 Whistleblowing system

In 2018, the EDF Executive Committee decided to upgrade its system to secure the handling of reported wrongdoing and increase personal data confidentiality and security.

3.3.2.4.1 Scope

The Executive Committee decided to set up a single whistleblowing system for all wrong doing reported under the Sapin II Law and the law on “duty of care” as well as wrongdoing reported by employees alleging harassment and discrimination. The Group Ethics and Compliance Department is the Group point of contact for the system. This Group system benefits all Group entities, except for the subsidiaries in the regulated sector, Enedis and RTE⁽²⁾, which have their own whistle blowing system to respect their managerial independence. Whistleblowers may choose to use the Group whistleblowing system or the other channels available to them (manager, human resources, staff representatives, local ethics and compliance officers, mediators, etc.).