Universal Registration Document 2021

2. Risk factors and control framework

b) Information systems failure including cyberattacks
Main risks

The Group operates multiple, interconnected and complex information systems (databases, servers, networks, applications, etc.) that are essential to the conduct of its commercial and industrial activity, the preservation of its human, industrial and commercial assets, and the protection of personal data (of customers and employees) and that must adapt to a rapidly changing context (digital transition, development of teleworking, new ways to share work in extended companies with suppliers, changes in regulations, etc.)

The facilities and assets used by the Group or its employees may be the target of external attacks or malicious acts of any kind. An attack or malicious act committed on these facilities could have consequences such as injury to persons and/or damage to property, the Group being held liable on the grounds of measures judged to be inadequate, and interruptions in operations. The Group would also be forced to make additional investments or incur additional costs if laws and regulations relating to the protection of sensitive sites and critical infrastructures became more stringent.

The frequency and sophistication of information system hacking and data corruption incidents are increasing worldwide. The impact of a malicious attack – or any other failure resulting in the unavailability of information systems – may have a negative impact on the Group’s operating activity, financial, legal and asset situation, or reputation.

Control actions

The EDF group has defined an Asset Security policy for malicious acts and an Information System Security policy to prevent this risk and limit its impact in the event of an attack. These policies are supplemented by guidelines on the protection of personal data.

A charter regarding the use of IT resources is annexed to the Company’s internal regulations. IS security training and awareness-raising courses adapted to different profiles (users, project managers, IS security managers, etc.) are offered on a regular basis to employees. The Executive Committee and the Audit Committee of the Board of Directors receive reports on cybersecurity risk management. Several dozen security audits are carried out each year by external PASSI qualified IS security audit companies (IS security audit providers) by the ANSSI (the National Cybersecurity Agency of France), both on IT infrastructures and on business information systems. In addition, the EDF group SOC (Security Operational Center) reports on IS security incidents on a monthly basis. The Group SOC has moreover carried out a qualification process with the ANSSI, which issued a favourable opinion in August 2021 (https://www.ssi.gouv.fr/uploads/2021_2047_np.pdf).

In 2021, the main actions deployed in the areas of cybersecurity, protection of intangible assets and, more generally, the Company’s resilience to the risks of damage to information systems were:

  • setting cybersecurity targets for Group entities;
  • deploying “Cybersecurity Passport” e-learning accessible to all (including subsidiaries) and which has been made compulsory for all Group executives and managers in France;
  • deploying phishing campaigns within the Group’s entities (more than 60,000 people targeted in 2021);
  • strengthening the operational cybersecurity function: strengthening the CERT (Computer Emergency Response Team), setting up a new SOC (Security Operations Center) model, professionalising the Cyber Support Teams within
    the departments and subsidiaries, who contribute to the CERT’s activities and implement the actions requested;
  • Group monitoring of the remediation of the most critical IT security flaws;
  • continuing the deployment and evaluation within the entities of a security reference framework based on the rules of the Agence nationale de la sécurité des systèmes d’information (the French national cybersecurity agency);
  • periodic publication of a dashboard for the Executive Committee indicating the Group’s level of cybersecurity.

In addition, IS crisis and cybersecurity drills are regularly carried out to test the various measures put in place.

4E – Hydraulic safety violations

Summary The hydroelectric facilities operated by the Group present risks with potentially serious consequences for people, property and the environment that could have a financial and reputational impact on the Group.

Criticality : ●● Intermediate

Hydropower safety comprises all the measures taken when designing and operating plants to reduce risks and hazards to people and property associated with water and the presence or operation of facilities.

a) Main risks

The Group’s hydraulic structures present specific risks with potentially very serious consequences: breakage, overflow during floods, operating manoeuvres.

b) Control actions

Hydropower safety is the major and permanent concern of the producer. It falls under the purview of the Group’s CSR “nuclear safety, health and security” issue (see section 3.3.1 “Health & Safety”). It involves three main activities:

  • measures to address the major risk associated with dam or reservoir failures, through the regular monitoring and maintenance of facilities under the supervision of public authorities, mainly the French regional environment, land use and housing authorities (Directions régionales de l’environnement, de l’aménagement et du logement – DREAL). Of the largest dams, 67 are subject to a special administrative procedure implemented by the competent prefect;
  • the management of facilities during periods of exceptionally high water levels in order to ensure safety at the facilities and for the surrounding communities;
  • control of operational risks: changes in the level of the water bodies or the flow of watercourses downstream of the works.

EDF regularly monitors and maintains its dams, including through continuous monitoring. The real-time readings and analysis at each site of multiple data (settlement, pressure, leakage measurements, combined with the visual inspection of the concrete and an inspection of the mechanical parts, etc.) enable EDF to conduct a regular assessment on the state of its dams. In Grenoble and Toulouse, EDF teams can analyse the largest dams or those dams that are the hardest to access remotely and in real time, using a series of sensors.

Furthermore, for each of the large dams, a danger study, including a complete examination, is conducted every ten or fifteen years (for one class A dam and one class B dam respectively). This examination requires draining or an inspection of the submerged parts with sub-aquatic equipment. These operations are carried out under the strict control of the French State authorities (Service de contrôle et de sécurité des ouvrages hydrauliques (Hydraulic Works Control and Safety Department) within each DREAL (French regional environment, land use and housing authority)).

At the organisational level, the Hydro Safety Inspector prepares an annual report for the Chairman & Chief Executive Officer of EDF, to which he or she reports directly, as well as to those involved in hydropower safety (see section 1.4.1.3.1.3 “Hydropower Safety”). Issued after analyses, inspections and assessments carried out by the Hydro Safety Inspector, this report aims to give an opinion on the level of hydropower safety of the Group’s facilities and provide a basis for reflection and progress to ensure its improvement and consolidation. This report is made public on the Group’s website.