Supplier compliance with CSR commitments is primarily ensured by a mechanism prioritising assessments based on risk mapping covering all of EDF’s purchasing categories, limited to the purchases covered by the Group Purchasing Department.On this basis, in 2020, the Group Purchasing Department enhanced the performance of its risk analysis, implemented in particular in accordance with the “Duty of Care” law. The new methodology factors in all CSR aspects (environment, working relations and working conditions, human rights, ethics and compliance), and ultimately allows it to determine the level of residual risk and identify the action to be taken with the supplier.
Inherent risks and residual risks(1) are assessed on a scale of 1 to 4: low, material, major or critical risk. Any critical residual risk in the assessed segments can be secured using countermeasures implemented prior to contracting, the contractual clauses and contract monitoring. Major residual risks have been identified in the various sectors of purchasing, mainly concerning safety, ethics, waste, the use of rare materials and human rights. 15% of the purchasing segments analysed are classified as having a major residual risk, 51% are classified as having a material residual risk and 34% are classified as having a low residual risk.
Supplier monitoring is mainly carried out by the Division or Contract Management, which uses Performance Assessment Sheets and Supplier Assessment Sheets. Almost 10,000 assessments are completed each year, on almost 2,000 suppliers.
CSR assessments and audits are also carried out:
At the end of 2020, 2,200 suppliers were questioned using the Acesia platform, and nearly 900 have been controlled. The assessments were “satisfactory” for almost 40% of the audited questionnaires. The suppliers to be assessed or audited are mainly selected based on the new supplier risk mapping and information received from buyers and business lines, on the contracts in progress. Group entities that do not use the Acesia platform use their own specific assessment methods. Suppliers of the Nuclear Division must agree to comply with the Progress Charter for Exemplary and Efficient Nuclear Power and the Social Specifications of the Strategy Committee for the Nuclear Sector. Edison uses a self-assessment platform that focuses on the ten principles of the Global Compact and is shared with other companies. EDF Renewables assesses its suppliers of strategic wind and solar energy equipment in its qualification processes, comprising selection criteria in all CSR fields. A Chinese turbine supplier that qualified for the very first time was only selected for its ISO 14001 certified plants.
All Group entities conduct assessment or follow-up audits in their supply chain. For example, the Dalkia teams conducted 2,225 health and safety audits on its subcontractors in 2020. EDF Hydro audited 62 of its suppliers: one of them obtained an insufficient CSR risk control rating for a subcontractor in China. As a result, it was asked to produce an action plan and the orders placed with it were monitored closely. Luminus noted a major discrepancy with a subcontractor of one of its main suppliers. After several alerts, the entity suspended its contract until the relevant company became compliant.
The Purchasing Department conducted 40 CSR on-site audits worldwide, 48% of which were in France. These audits cover all CSR aspects: environmental, social and ethical policies, commitments and practices. Four quality audits were also conducted.CSR audits are designed to test the CSR commitments adopted and are conducted onsite (head office or production site of the supplier or place of work at an EDF site). A recent example of this is the campaign of audits conducted on tenderers and their main subcontractors for a call for tenders in the “workwear” category. Contracts may only be awarded to suppliers whose audit was deemed “Acceptable with Comment”.In general, the 2020 health crisis led to an unavoidable drop in the number of on-site audits, postponed until 2021. Apart from eight year-end audits whose reports were still pending on the date of review, 41% had a “Satisfactory” rating, 56% an“Acceptable with Comment” rating and 3% an “Insufficient” rating, requiring supplier action plans. A follow-up audit may be scheduled for the year following any audit deemed “Insufficient” or “Unsatisfactory”, based on the proposed action plan and the opinion of those responsible for the contract (purchasing/business line).These campaigns have shown that suppliers still have a relatively low level of CSR risk management in their own supply chain, particularly for the SMEs audited. However, the risk of a pandemic had been properly integrated by all those audited.Additionally, the operational management of safety and environmental issues is increasingly implemented through certification processes such as the MASE or ISO 14001 certification.
Since its coal contracts were taken over by JERA Trading (JERAT), EDF has no direct contractual relations with mining companies or the market, but remains an active promoter of the Bettercoal responsible coal purchasing initiative that EDF helped to found. Bettercoal brings together energy companies, port institutions and coal terminals to promote CSR in the coal supply chain, mainly at mining sites, to ensure that fundamental rights are respected. The operational approach (audits and self-assessments) is based on a code that sets out ethical, corporate and environmental principles and provisions relevant to mining companies. It takes into account general performance requirements, including management systems, and also performance requirements concerning: ethics and transparency, human and labour rights (such as the prevention of forced and child labour, the right to a decent wage), social issues, including health and safety, and the environment. EDF has not renew edits membership but its coal supplies remain covered by Bettercoal as JERA Trading, its supplier, is now a member, thus increasing Bettercoal’s influence in Asia.
EDF obtains its uranium supplies over the long term under diversified contracts in terms of origin and suppliers, in most of the main producing countries (Australia,United States, Canada, Kazakhstan, South Africa and Russia). The clauses authorising the completion of audits and setting out EDF’s expectations in terms of enforcement of the fundamental rights and main international standards by suppliers and sub-contractors have progressively been added to contracts. The uranium mine audit system used by EDF since 2011 ensures that the ore is extracted and processed in good environmental, social and societal conditions. The method was developed with the WNA (World Nuclear Association), consisting of a standardised framework recognised by all those involved in the sector. It takes into account the issues of human rights and fundamental freedoms (human rights, whistleblowing register, rights of indigenous peoples and radiation protection) and also the environment, in the broadest sense of that term (water, diversity, waste, site clean-up after extraction).
Every year, EDF carries out mine audits through internal means (2 audits per year). The reports present the main strengths, recommendations and suggestions. The most common ones relate to health and safety (wearing personal protective equipment such as gloves or googles), the display of safety instructions, monitoring accidents, performing radiological controls, monitoring carbon emissions and proposals relating to well-being in the workplace. Audit recommendations are included in the continuous improvement plans. The 2020 audit programme had to be suspended due to the international health crisis. These audits will be conducted as soon as the health situation improves. The Nuclear Fuel Division (DCN) worked alongside its suppliers to ensure that they were monitoring the effects of the health situation on their facilities and organised regular conference calls with them to share information about the work organisation methods implemented to protect the health and safety of employees.
(1) Residual risks are the risks remaining after countermeasures have been adopted.
