Universal Registration Document 2021

3.3.2.2.2 Prevention of harassment and discrimination

Banning all harassment or discrimination, preventing and dealing with any physical or psychological violence as well as intolerance or injustice in the workplace are some of the requirements of the Group Ethics Charter. This commitment is part of the regulatory and judicial context which, in many countries, incriminates not only the actions and behaviours themselves, but also employers who fail to implement sufficient preventive measures. The executives must take all necessary steps to prevent discrimination, harassment and physical and emotional abuse within their entities by informing employees of these risks. They must provide regular information about the Group whistleblowing system and take appropriate disciplinary action in the event of proven wrongdoing.

Reference guides and training	Two reference guides designed to prevent and combat bullying and sexual harassment have been distributed, primarily to managers, the HR Department and the Ethics and Compliance Managers of entities. They have been published in a simplified format for all employees. Several training modules are available for everyone on e-Campus: the first module covers identifying and understanding the links between stereotypes and discrimination, through a serious game called Vivre ensemble la diversité (experiencing diversity together); the second is about understanding and preventing ordinary sexism in the workplace and is entitled Sexisme, pas notre genre (Sexism, not our thing); the third is a training module on preventing and fighting against sexual It is also included in the manager training course, among the manager fundamentals on e-Campus Manager. See also section 3.3.3.2 Combatting sexism and violence.

Reference guides and training

Two reference guides designed to prevent and combat bullying and sexual harassment have been distributed, primarily to managers, the HR Department and the Ethics and Compliance Managers of entities. They have been published in a simplified format for all employees.

Several training modules are available for everyone on e-Campus:

the first module covers identifying and understanding the links between stereotypes and discrimination, through a serious game called Vivre ensemble la diversité (experiencing diversity together);

the second is about understanding and preventing ordinary sexism in the workplace and is entitled Sexisme, pas notre genre (Sexism, not our thing);
the third is a training module on preventing and fighting against sexual It is also included in the manager training course, among the manager fundamentals on e-Campus Manager.

See also section 3.3.3.2 Combatting sexism and violence.

3.3.2.2.3 Financial ethics

The Ethics and Compliance Policy sets out the requirements to be followed to prevent market abuse, the risk of money laundering and the financing of terrorism. An Ethical Code for Trading in Securities, updated in 2021, complements this Policy.

The Group Ethics & Compliance Policy also sets out the requirements concerning compliance with the European EMIR regulation.

Support guide	The implementation of this EMIR regulation by the EDF group, the implications for entities as well as the related processes and controls are described in the EDF group EMIR Policy Paper support guide. An e-learning module is available on e-campus.

3.3.2.2.4 Integrity and transparency of the wholesale energy market (REMIT regulation)

In accordance with the Group Ethics & Compliance Policy, entities concerned must put in place a compliance programme for the European REMIT regulation (on the integrity and transparency of the wholesale energy market). A Group Compliance Officer, appointed in September 2017, was tasked with preventing risks of non-compliance, by developing an appropriate control environment. The practical implementation of this REMIT regulation by the EDF group, the implications for entities as well as the related processes and controls are described in a memorandum of instructions. An online training system for EDF personnel is available on the EDF group intranet with free access. The subsidiaries outside France, in particular EDF UK, Edison, Luminus, and EDF Trading, have also set up training and awareness-raising programmes for their employees.

Awareness Raising and Training	An online staff training tool has been set up since 2019. It is freely available on VEOL, the EDF group intranet. Subsidiaries outside France, in particular EDF UK, Edison, Luminus, and EDF Trading, have also set up training and awareness-raising programmes for their employees. As far as EDF employees are concerned, 1,335 people have been trained by the end of 2021 through this scheme.

3.3.2.2.5 Preventing breaches of competition law

The EDF group has made the prevention of anti-competitive practices (cartels and abuse of dominant positions) a major issue for its employees. With this in mind, the Group has implemented a Competition Law Compliance Programme since 2010. The programme, which is binding on all employees, aims to ensure that all operations of subsidiaries and entities of the Group in France and worldwide comply with competition law. Any suspicion of anti-competitive practices may be reported under the whistleblowing system set up by the Group (see §3.3.2.4).

Awareness Raising and Training	After having deployed from 2010 to 2015 an e-learning module which trained more than 5,400 employees, then between 2016 and 2021 a more general Serious Game entitled “Cap Antitrust” taken by about 2,300 employees, a new module on competition law awareness has been accessible since October 2021 to all employees on the internal training portal of the Group in two languages (French, English). This e-learning module is integrated into the training programme for the directors of the Group’s subsidiaries, who also receive additional awareness training in the form of an in-person module. The Group regularly organises simulated investigations by competition authorities in order to raise awareness of the importance of complying with competition law.

Awareness Raising and Training

After having deployed from 2010 to 2015 an e-learning module which trained more than 5,400 employees, then between 2016 and 2021 a more general Serious Game entitled “Cap Antitrust” taken by about 2,300 employees, a new module on competition law awareness has been accessible since October 2021 to all employees on the internal training portal of the Group in two languages (French, English). This e-learning module is integrated into the training programme for the directors of the Group’s subsidiaries, who also receive additional awareness training in the form of an in-person module.

The Group regularly organises simulated investigations by competition authorities in order to raise awareness of the importance of complying with competition law.

3.3.2.2.6 Personal data protection

EDF, which appointed a Personal Data Officer (PDO) in France as early as 2006, appointed its Data Protection Officer (DPO), pursuant to EU regulation 2016/679 of 27 April 2016 known as the General Data Protection regulation (GDPR). The DPO is the Lead Manager for the Group.

Data Protection Officer (DPO)	Around twenty DPOs have been appointed in French and European subsidiaries and Personal Data Contacts (Relais Informatique et Libertés (I2L) are present in all EDF entities. The DPOs are ensuring compliance with regulations relative to the protection of personal data within the Group, whether with regard to the personal data of its customers, employees, service providers or partners.