Universal Registration Document 2020

3. Non-financial performance

The Purchasing Department conducted 40 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 on site (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.

Examples of actions implemented by the entities

In 2019, using its environmental and social management system, EDF Renewables organised site visits in India and China to analyse how to manage environmental and societal risks (relations with stakeholders, human rights, subcontractors’ working conditions, biodiversity, waste management, etc.) in connection with the development and construction of wind and solar power projects and to train local teams on EDF group requirements in this area.

In Myanmar(1), a specific study was planned for the Shweli 3 project to assess and manage human rights impacts and launched in 2019. No field studies could be conducted in 2020 due to the health crisis. This study could not therefore be completed as planned but the risk assessment is already available. The main risks involve the rights of future displaced persons (including potential local communities), the safety of project workers and staff and the rights of downstream communities. Further field studies and the corresponding action plans are scheduled for 2021.

In the Ivory Coast, for a biomass project using agricultural waste (for which construction is scheduled to start in 2021), a specific study identified the work performed by children in support of their parents’ work. In particular, the study (i) determined the type of work (mainly support for women collecting fallen fruit), and (ii) identified the reasons for this work (cultural, training and economic purposes). A collaboration with a cooperative already operational in the region will be set up to enhance the “field work-training” sessions on child labour and gender equality.

In Brazil, EDF Norte Fluminense (NF) organised a virtual public consultation to present and discuss the Environmental Impact Assessment (EIA) for a proposed combined cycle gas turbine plant (“UTE NF2”) in accordance with the requirements of theNational Environmental Council (CONAMA). The online event was held on 7 October after being publicised on the EDF NF website and through the local newspaper, radio ads, WhatsApp invitations, emails, a toll-free number and a website. It lasted more than 3 hours with a peak of 123 people connected at the same time and 224 people signed the attendance list. After the live event, lines of communication were opened up for any further questions and other events for 20 days. Additionally, a full recording of the live event was posted online and viewed 543 times.

In Cameroon, as part of the Nachtigal hydroelectric project, a programme to combat Gender-Based Violence (GBV) has been implemented. Since February 2020, victims in local communities have been assisted through a special office and GBV and HIV awareness-raising campaigns have been conducted, targeting 1,339 motor cycle-taxi and truck drivers and sex workers and 3,702 students. Training has also been provided to the employees of the civil engineering companies working on the project.

In China, actions were taken in favour of vulnerable groups by supplying and maintaining radiators for the elderly, granting scholarships to low-income students, assistance to improve quality of life and health of children (clothing, shoes, access to hot water).

In China, the Group decided not to commit to a wind turbine project in are development area. The production capacity was not consistent with the number of families that would have to be displaced.

Risks were identified by EDF Hydro at suppliers’ and subcontractors’ sites which have their components (water wheels and turbines, transformers, alternators) manufactured in plants located in China, India, Brazil, Turkey and Eastern European countries. CSR audits on these suppliers were requested and the majority have been performed. These audits systematically covered respect for Human rights, safety and the environment. The audits are conducted at the headquarters of the relevant companies, in certain plants and are supplemented with audits on the EDF Hydro work sites. In one case in particular, a supplier was given an insufficient score for control of CSR risks at a subcontractor’s site in China, which led it to establish an action plan and enhance vigilance for orders placed with this company.

For the DTEAM (in charge of thermal facilities), the safety of service providers is an absolute priority. When activities involve risks, the level of requirements is based on certification (MASE, OHSAS 18000) of subcontractors. Improvement programmes in the fields of guard services, road transport, maintenance and logistics have been initiated in cooperation with subcontractors.

Citelum, a subsidiary with business in a number of countries, organises risk management to fulfil its duty of care based on social, regulatory and operating conditions at each one of its sites:

  • in Italy, the entity was certified SA 8000 for all of its business lines and those of its subcontractors;
  • in Brazil, the entity published and implemented a code of conduct which focuses particularly on the respect for human rights by suppliers;
  • in Spain, the entity was certified SGE21(RSC) which guarantees that human rights-related risks have been identified, evaluated and treated.

(1) EDF is paying close attention to political developments in the wake of the coup on 1 February 2021, and may review its projects currently under development in Myanmar.