| Respect, Solidarity and Accountability | The Group Ethics Charter sets out the values shared by all EDF staff, places ethical requirements at the heart of corporate responsibility and, in accordance with the Chairman’s commitment, promotes ethical behaviour in all professional activities. Updated in 2019, the Group Ethics Charter now focuses on the Group’s three values “Respect, Solidarity and Responsibility”, each featuring 4 requirements. It is available in French and English on the EDF group website and in eleven other languages in which the Group works. |
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| 13 compliance programmes | The Group Ethics and Compliance Policy (PECG), which identifies the Company’s compliance programmes as well as the main rules that Executive Directors should know, observe and enforce within their entities, strictly aligned with the risks of these entities, was updated and approved during an Executive Committee in January 2020. The PECG includes thirteen compliance programmes: preventing the risk of corruption and influence peddling; preventing conflicts of interest; fight against fraud; compliance with international sanctions programmes; prevention of harassment and discrimination; prevention of market abuse; prevention of the risk of money laundering and financing of terrorism; compliance with the EMIR regulation; compliance with the REMIT (regulation on Wholesale Energy Market Integrity and Transparency) regulation; preventing breaches of competition law; personal data protection; export control (dual-use goods); and the duty of vigilance (covering environmental, human rights and health and safety issues). |
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In accordance with the French Act of 9 December 2016 on transparency, the fight against corruption and the modernisation of the economy, known as the “Sapin II” Act, EDF set up an anti-corruption compliance programme taking account of legal requirements:
| An ethics & compliance code of conduct included with the internal rules of procedure and a disciplinary mechanism |
This code of conduct, which was reviewed in July 2021, defines and illustrates, through practical cases, the different types of behaviour employees are likely to face as a result of the Company’s business activities and organisation, and which should be prohibited given that they may constitute acts of corruption or influence peddling. It sets rules for all the themes identified during the corruption risk mapping process. It prohibits facilitating payments, and restricts gifts and invitations. Breach of any of its rules may result in disciplinary sanctions. It can be viewed by third parties on EDF’s site in French and English (1). |
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| Whistleblowing system | See section 3.3.2.4 “Whistleblowing system”. |
| Risk mapping | Ethics & compliance risk mapping is part of the Group Risk Department’s annual internal control self-assessment process. Based on this, the entities draw up action plans appropriate to their operational contexts to prevent and mitigate these risks. Since 2018, a specific “corruption” risk map was prepared, which identifies and prioritises, by business sector and country, risks of exposure to corruption. In 2020, the methodology used for the mapping was improved, to enhance its focus on the operational specificities of the Group’s various business lines and geographical locations. |
| Third-party integrity control system | Under the Group Ethics and Compliance Policy, executives of the relevant Group entities are required to implement a system within their entities to control the integrity of any partners with which the Group plans to establish or continue a business relationship, mainly designed to check that there are no risks of exposure to international sanctions and that a clause is inserted in each contract entitling EDF or its subsidiary to terminate a business relationship with immediate effect in the event of a failure to adhere to an international sanctions programme. In 2021, this system was reviewed in line with the Group’s corruption risk map. |
| Accounting controls | Control procedures, containing specific requirements for the detection and prevention of corruption, have been defined for the Company’s various processes. Following a technical analysis, any anomalies likely to be characterised as fraud are, where applicable, forwarded to the entity’s Ethics and Compliance Officer. |
| Training schemes |
The Group Ethics and Compliance Department develops prevention measures and training for all employees of EDF and its subsidiaries, including:
Additionally, the Group Legal Affairs Department and Ethics and Compliance Department are also providing a “Preventing corruption and influence peddling” e-learning module, accessible to all employees on the e-campus platform, that teaches about how best to behave in situations relating to business relations, conflicts of interest, and gifts. Since the end of 2020, it became mandatory for all employees moving to a new position exposed to corruption risks to follow an anti-corruption e-learning module (e-learning module added to the standard training given to managers, project managers, buyers and contract managers, etc.). |
| Internal evaluation system | A system allowing entities to evaluate the level of implementation and meeting of each key requirement has been put in place. It enables identification of improvement actions to be taken. |
