In the course of its operations, particularly in the nuclear field, EDF and its subsidiaries carry out a range of operations to meet their own needs or the needs of third parties, requiring the use of goods and technologies including dual-use goods and technologies (“DUG”), i.e. civil and military, that can expose it to certain risks inherent in specific French, European and/or foreign regulations, some of which have extraterritorial scope, and can require the issuing by the competent authorities of a license/authorisation prior to any transfer, export, re-export, brokerage, and/or transit of such goods and technologies. Some regulations, particularly in the United States, have introduced restrictions on access to goods and technologies applicable to foreign entities that may affect both DUGs and any other commercial goods.
The Group, or some of its partners, may be exposed, directly or indirectly, to sanctions programmes, in particular (i) international sanctions adopted by the United Nations Security Council, (ii) sanctions adopted by regional organisations such as the European Union, and (iii) sanctions adopted unilaterally by certain States, some of which have extraterritorial scope.
| Group Export Control and International Sanctions Department | A Group Export Control and International Sanctions Department was set up in August 2019 to strengthen the Group’s ability to comply with these regulations. A memorandum of instructions describing the compliance procedures to be implemented was adopted by the Executive Committee on 4 May 2020. |
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See section 3.9 “Vigilance Plan”
One of the EDF group’s fundamental goals is to endeavour to respect and ensure respect for human rights in all its activities and wherever it operates.
| 2021 Guidelines |
In March 2021, EDF drew up a set of guidelines listing the commitments of the Group (EDF SA and its controlled subsidiaries (1)) 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 and the rights of local communities in particular. |
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The EDF group does not tolerate any infringement of human rights or fundamental freedoms in its operations or in those of its business relationships for operations related to the relationship.
| International Standards | EDF strives to comply at least with the international standards protecting and defending human rights and fundamental freedoms, including the United Nations International Bill of Human Rights and the fundamental conventions of the International Labour Organisation (ILO). |
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| Conflicting standards | If the laws of a country where it operates conflict with these international standards, EDF endeavours to find a solution to allow it to comply with both the spirit of the international standards and national laws. |
| Vigilance approach | To ensure that human rights and fundamental freedoms are respected in its operations, EDF has implemented a vigilance approach to identify, assess and prevent any potential infringement of human rights or fundamental freedoms. The vigilance approach has been designed to comply with the French Duty-of-Care Act and is based on the recommendations of the UN Guiding Principles on Business and Human Rights. |
| Vulnerable persons | The EDF group pays special attention to the impact of its operations on individuals recognised as vulnerable under international human rights law and investigates, in complete transparency, impartiality and good faith, any alleged infringements of human rights or fundamental freedoms connected to the operations of the Group’s entities, providers and subcontractors. |
| Proven cases of injury | If an infringement of human rights or fundamental freedoms is proven in the operations of the Group’s entities or suppliers or subcontractors, EDF has agreed to engage in dialogue with the victims and/or their representatives to address the situation, pursuant to the OECD Principles for Multinational Enterprises applicable to the EDF group. |
(1) With the exception of RTE, transmission network operator, and Enedis, subsidiaries independently managed within the meaning of the Energy Code.
