Universal Registration Document 2020

3.6.8 Procedure for regular evaluation of the situation of subsidiaries, subcontractors and suppliers based on risk mapping

Under the internal control guide, which in turn refers to the “duty of care” section of the Group’s “Ethics and Compliance” policy, entities and subsidiaries are required to complete a form on the management of their operations for all aspects of the duty of care. The purpose of this form is on the one hand to summarise the specific risk assessment carried out for each entity (evaluation and assessment based on analysis of results, facts, causes and consequences) and on the other hand to self-assess the management of its operations and performance of the entity, and set out the objectives of its yearly action plan. They are asked to focus particularly on the evaluation of suppliers.

In addition, within the framework of the Responsible Purchasing plan, the Group Procurement Division, the main Divisions and the subsidiaries carry out CS Revaluations on their suppliers and subcontractors using both questionnaires and audits administered directly or by independent firms (see section 4.2.3.4 “CorporateResponsibility Committee”).

3.6.9 Report on the EDF group’s vigilance plan

In 2020, the EDF group continued to implement the requirements of the duty of care in all of its activities and relations with suppliers and subcontractors.

Main actions at the Group level

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⁽¹⁾, and particularly within the investment committees of the Group Executive Committee (CECEG) and the International Business DevelopmentCommittee (CBDI) relies on the use of a screening grid that take into account risks related to the duty of care.

Projects financed by Green Bonds or development banks were the subject of reporting to financiers on social and environmental matters (see section 3.1.3.3.2 “Use of Green Bonds”). In 2020, EDF extended the scope of its Green Bonds to cover biodiversity, by including biodiversity indicators in the Green Bond Framework⁽²⁾.

More details on the actions implemented are given below:

Human rights

In March 2021, EDF drew up a set of guidelines listing the commitments of the Group and the fundamental requirements for its business relationships in terms of human rights and fundamental freedoms, environmental protection, protection of personal health and safety and business ethics. In the guidelines, the Group notes and summarises its commitments in terms of compliance with international standards, the rights of its staff, the rights of local communities and the use of security forces (see section 3.3.2.3 “Human rights”).

Human rights commitments are implemented as part of the Group’s CSR commitments⁽³⁾ and requirements, 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 new 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.

When leading international projects, the commitment of stakeholders and seeking of consent have been systematic. When applicable, the use of migrant workers at worksites and on-site security guard forces received particular attention. For example, all hydropower projects included a stakeholders’ commitment plan and a local complaint management mechanism. These plans make it possible for all persons concerned to freely express their complaints or worries and to participate in decision making.

In the field of training, the e-learning programme “Human rights in business”developed with the Businesses for Human Rights organisation (Entreprises pour les droits de l’homme – EDH) was updated with a yearly process which includes the duty of care and is available to all employees. The updated version of this training module was released to employees as part of an internal communications campaign to raise awareness of Human Rights for the Human Rights Day held on 10 December 2020.

In 2018, an NGO referred the planned Gunaa Sicaru wind farm, managed by a subsidiary of EDF Renewables in Mexico, to the OECD’s French national contact point (NCP). During the course of the OECD mediation process, the EDF group took part in two dialogue meetings with the plaintiffs and provided some responses to the concerns raised. The NCP closed the matter in spring 2020. The local consultation process had resumed in early 2020 but has since been suspended due to the health crisis. Likewise, in December 2019, EDF responded to a formal notice for the same project sent pursuant to the French “Duty of Care” Law by that NGO and four individuals. EDF was then summoned on 13 October 2020 to appear before the ParisCourt of Justice (Tribunal judiciaire) under the French “Duty of Care” Law. The applicants have asked the court to order changes to the vigilance plan produced byEDF to better address, in particular, the risks posed to the rights of indigenous communities and to order compensation for the damage caused by its failure to fulfil its duty of care. EDF has challenged these two applications. The investigation is underway.

Environment

Environmental risks were identified and incorporated into the Group’s environmental management system (EMS) and internal control system (see section 3.5.2.5.2 “Environment management system (EMS)”).

Today, the EDF group provides one of the most detailed GHG reports for its entire value chain of any leading European electricity company. EDF improves its performance in this area each year and it now includes, since 2020, all its results in the non-financial performance statement for the year under review (see section 3.1.1.2 “The Group’s GHG report”). In 2020, and for the fourth year, theGroup was on the A List published by CDP Climate Change, uniting companies without standing performance in the areas of transparency and objectives laid down for their carbon approach and their commitment to fighting climate change (see section 3.8 “Non-financial rating”).

The EDF group only had three coal-fired plants left at the end of 2020: the Le Havre plant, scheduled to be shut down in spring 2021, the West Burton A plant, scheduled to be shut down by 2024 and, lastly, the Cordemais plant, scheduled to be shutdown by 2026 at the latest, which may be converted to a biomass plant as early as 2022 (see, also, section 1.4.1.2.2 “Issues relating to thermal generation”).