3.3.2.4 Whistleblowing system
3.3.2.4.1 Scope
In order to make report-handling more secure and to strengthen the confidentiality and security of personal data, in 2018 the Executive Committee decided to set up a single whistleblowing system for all wrongdoing reported under the Sapin II Act and the Duty-of-Care Act as well as wrongdoing reported by employees alleging harassment and discrimination. The Group Ethics and Compliance Department is the Group point of contact for the system. This Group system benefits all Group entities, except for the subsidiaries in the regulated sector, Enedis and RTE (1), which have their own whistleblowing system to respect their managerial independence. Whistleblowers may choose to use the Group whistleblowing system or the other channels available to them (manager, human resources, staff representatives, local ethics and compliance officers, mediators etc.).
3.3.2.4.2 Accessibility of the system
The Group whistleblowing system, managed from an independent platform that is not connected to EDF’s IS, may be accessed at any time via the EDF group website. The interface is available in several languages (French, English, Italian, Portuguese, Dutch and Mandarin) in France and abroad, and the whistleblower can report wrongdoing in the language of their choosing (2).
3.3.2.4.3 Reporting wrongdoing
The EDF group ethics and compliance whistleblowing system allows Group employees and external staff (temporary workers, service provider employees, etc.) or occasional employees (fixed-term contracts, apprentices, trainees, etc.), as well as third parties, to report wrongdoing of which the EDF group or its staff are the culprits or victims.
3.3.2.4.4 Analysis of the admissibility of reports
Once the report has been submitted, whistleblowers receive confirmation within 72 hours informing them that the admissibility assessment has begun. Whistleblowers can submit reports anonymously in countries where this is authorised. Wrongdoing can be reported anonymously, as long as the severity of the reported facts is established and the factual elements are provided in precise and sufficient detail, so as to provide evidence for the reality of the reported facts.
The Group Ethics and Compliance Department assesses the admissibility of the report, which depends on the scope of application and the whistleblower’s relationship with the Company. This admissibility is independent of whether the alleged facts are well-founded or not, which can only be determined through a report handling process. Once a ruling has been made on admissibility, the whistleblower is informed of the protective measures from which they benefit (protection under the Sapin II Act, French Labour Code, etc.). These vary according to their status (victim or witness, individual or corporation etc.), their relationship with the Company (employee, external service provider, third party, etc.) and the themes involved (fraud, harassment, serious environmental damage, etc.).
3.3.2.4.5 Processing of admissible reports
Each report that is deemed admissible is processed. The Group Ethics and Compliance Department appoints a case manager and, if necessary, is assisted by Ethics and Compliance Officers and other experts to handle reports. When the investigations have been completed, an investigation report is drawn up by the case manager. If the allegations reported are proven or partially proven, an action plan is implemented. The Group Ethics and Compliance Department monitors the progress of this action plan and ensures it has been fully implemented before the report is closed.
Admissibility of reports in the Group's whistleblowing system
Admissible reports : 53%
Non-Admissible reports : 47%
Relationship of whistleblowers with the Group (all channels combined)
Employees : 82%
Other third parties : 5%
External staff : 11%
Occasional staff : 2%
Results of investigations following alerts (all channels combined)
Proven allegations : 51%
Partially proven allegations : 13%
Unproven allegations : 36%
Actions taken following alerts (all channels combined)
Legal + Corrective : 2%
Disciplinary : 40%
Corrective : 50%
Disciplinary + Corrective : 8%
(1) Distribution network operator Enedis and transmission operator RTE are managed independently.