Universal Registration Document 2021

3. Non-financial performance

In operational terms
Solar park in India

During the development of EDF Renewables’ solar park in Bap Tehsil, India, dialogue with local communities has enabled:

  • impact avoidance: a bypass road was built to avoid traffic disruption in the village;
  • impact mitigation: the plant was redesigned to preserve trees in accordance with local community requests;
  • impact compensation: community investments have been made, such as the creation of a water basin in the village.

During the operational phase, dialogue and investment have continued: a social budget is devoted each year to programmes such as improving the sanitation of school buildings, and providing fans and sporting equipment to students and bicycles to low-income villagers. The development of the project has also created employment opportunities for the people living in the area.

Biomass plant in Côte d’Ivoire

Concerning the BIOVEA Energie biomass power plant project in Côte d’Ivoire, a specific study was carried out on child labour in order to understand its nature and causes in the agro-industrial sector of the region in which the power plant will be located. On the basis of this study, BIOVEA Energie has chosen to act, in particular through a collaboration with the cooperative of the Toumangué region, which alone covers the vast majority of small planters in this area. The objective is to develop Champs École Paysans (“Farmer Field Schools”, or CEPs), which allow the implementation of good agricultural and management practices based on 6 themes, including a specific one on child labour. A budget of €150,000 is planned for the first two years for the launch and development of the CEPs, followed €24,000 of support per year for 14 years.

Hydroelectric project in
Cameroon

In addition to the EDF group’s ethics alert system, projects are developing local complaint management systems to ensure that communities directly and indirectly impacted by the projects can raise their concerns and have them addressed. In accordance with international environmental and social standards, the Nachtigal Hydroelectric Project in Cameroon has had a mechanism in place since April 2015 to manage requests and complaints. Anyone can submit them in writing, orally, or by proxy, in all local languages of the project area, as well as in the official languages of the country. Grievances are recorded in the project’s query and complaint log. Once recorded, if the complaint relates to the project’s commitments, activities, accountability or mandate, an investigation is initiated to determine the basis for the complaint. The project then proposes a treatment to the complainant. A mediation Committee can intervene if the complainant is not satisfied with the treatment applied. Finally, an appeals Committee can be called upon if the complainant is not satisfied with the solution proposed by the mediation Committee.

Modern Slavery Act
EDF UK

In accordance with the Modern Slavery Act, EDF in the United Kingdom is working to ensure that its activities, as well as those of its supply chain, are subject to an assessment of the risks associated with modern slavery and that means of mitigation are put in place. EDF in the UK has a Modern Slavery Statement covering all its employees and procurement. This statement, in accordance with the law (Modern Slavery Act), is published on the subsidiary’s website. EDF in the UK employs around 12,000 people, with a supply chain of around 5,000 suppliers. All employees are required to comply with the subsidiary’s code of conduct for Employees and Ethics & Business Conduct Policy. The subsidiary has published support guides to make employees aware of these principles and values and to provide the necessary tools to report any behaviour contrary to EDF’s principles in the UK.

With respect to the supply chain, the potential risks of slavery and human trafficking are assessed to identify areas of focus for procurement. This concerns, for example, the purchase of photovoltaic panels. Suppliers are required to comply with a set of standards, including the obligation to conduct a self-assessment of their risks aligned with the ten principles of the United Nations Global Compact (1). EDF in the UK is encouraging its supply chain to adopt a social and environmental improvement approach. Modern slavery obligations are included in the upstream contracting process and suppliers are evaluated at all stages of the procurement cycle, from qualification to contract execution.

Consideration in Group purchasing
Group Procurement In terms of purchasing, the Group Purchasing Department’s CSR risk mapping has included an analysis of “human rights” risks for each purchasing segment since 2019, to determine the level of residual risk and identify the action to be taken with suppliers (see section 3.4.2.3.2 “Responsible procurement strategy and practices”). For fuels, see section 3.4.2.3.4 “Responsibility regarding the fuel supply chain”.

The “human rights in business” e-learning module developed with the association Entreprises in 2021 pour les droits de l’homme (i.e. businesses for human rights), of which EDF is a founding member, has been updated in 2021 to include the duty of vigilance and is available to all employees.

Performance indicators are monitored at the Group level, based on Cap 2030, via the Health & Safety Policy (see section 3.3.1.3 “Health and safety of employees and subcontractors”), Let’s Talk Energy programme, employee commitment surveys and supplier relations (evaluations, supplier focus survey).

(1) unglobalcompact.org/what-is-gc/mission/principles