Universal Registration Document 2020

3.3.2.4.2 Accessibility of the system

The Group whistleblowing system, managed from an independent platform that is not connected to EDF’s IS, may be accessed at any time via the EDF group website. The interface is available in several languages (French, English, Italian, Portuguese, Dutch and Mandarin) in France and abroad, and the whistleblower can report wrong doing in the language of their choosing⁽¹⁾.

3.3.2.4.3 Reporting wrongdoing

The EDF group ethics and compliance whistleblowing system allows Group employees and external staff (temporary workers, service provider employees, etc.) or occasional employees (fixed-term contracts, apprentices, trainees, etc.), as well as third parties, to report wrongdoing of which the EDF group or its employees are the culprits or victims.

3.3.2.4.4 Analysis of the admissibility of reports

Once the report has been submitted, whistleblowers receive confirmation within 72hours informing them that the admissibility assessment has begun. Whistleblower scan submit reports anonymously in countries where this is authorised. Wrong doing can be reported anonymously, as long as the severity of the reported facts is established and the factual elements are provided in precise and sufficient detail, so as to provide evidence for the reality of the reported facts.

The Group Ethics and Compliance Department assesses the admissibility of the report, which depends on the scope of application and the whistleblower’s relationship with the Company. This admissibility is independent of whether the alleged facts are well-founded or not, which can only be determined through are port handling process. Once a ruling has been made on admissibility, the whistleblower is informed of the protective measures from which they benefit (protection under the Sapin II law, French Labour Code, etc.). These vary according to their status (victim or witness, individual or corporation, etc.), their relationship with the Company (employee, external service provider, third party, etc.) and the themes involved (fraud, harassment, serious environmental damage, etc.).

3.3.2.4.5 Processing of admissible reports

Each report that is deemed admissible is processed. The Group Ethics and Compliance Department appoints a case manager and, if necessary, is assisted by Ethics and Compliance Officers and other experts to handle reports. When the investigations have been completed, an investigation report is drawn up by the case manager. If the allegations reported are proven or partially proven, an action plan is implemented. The Group Ethics and Compliance Department monitors the progress of this action plan and ensures it has been fully implemented before the report is closed.

3.3.2.4.6 2020 Results

Whistleblowing results are consolidated and included in the annual ethics & compliance report submitted to the Executive Committee and presented to the EDF Board of Directors’ Governance & Corporate Responsibility Committee. For 2020, the Group Ethics and Compliance Department has consolidated all admissible reports submitted within the Group (via the Group system or any other channel). 184 admissible reports were recorded (including 39 via the Group whistleblowing system). 95 were about incidents occurring in France and 89 abroad; 97 related to EDF and 87 to Group subsidiaries. Most whistleblowing (40%) relates to harassment/discrimination. In 2020, 58% of the whistleblowing reports handled were sufficiently substantiated to result in corrective action or disciplinary action, including the dismissal of a Group executive manager following an established report of harassment. It should be noted that in 43% of the cases where the facts were not proven, action to improve the relevant processes was still taken.

Admissibility of reports in the Group's whistleblowing system