Universal Registration Document 2021

3. Non-financial performance

On-site audits ordered by the Group Procurement Department

These audits cover all CSR aspects: environmental, social and ethical (in particular human rights) policies, commitments and practices. Eight quality audits were also conducted. On-site supplier audits are conducted by external, independent providers. CSR audits are triggered on the basis of feedback capitalised by Procurement Category Managers on how contracts are executed, in particular with respect to the supplier risk map.

  2021
Number of on-site audits ordered by the Group Procurement Department

Number of on-site audits ordered by the Group Procurement Department

2021

52

Proportion of audits conducted outside France (percent)

Proportion of audits conducted outside France

(percent)

2021

67%

60% of the finalised audits received a “Satisfactory” rating, 34% an “Acceptable with Comment” rating and 6% an “Insufficient” rating, requiring supplier action plans.

“Work clothing” campaign

In 2021, many of the CSR audits related to a call for tenders in the “work clothing” category. “Insufficient” and/or “unsatisfactory” scores for audited production sites led to the bidding supplier in question being excluded from the supply chain. The results of this specific campaign, most of which concerned sites outside France, were quite diverse. Best practice was noted at several facilities (voluntary accreditation and labels, proactive employment/pay policy, proper management of chemicals). However, there were also shortcomings relating to pay, working hours, and safety (lack of periodic inspections, collective protective equipment, and inappropriate PPE), in some cases within Europe. All ‘insufficient’ scores in the 2021 CSR audits related to the textile category.

Audits for other procurement categories

As in previous years, overall results indicated appropriate management of safety and environment-related operational risks, due mainly to certification providing a framework and a robust safety culture. There were several noteworthy best practices and opportunities, including an in-house innovation challenge and seeking improvements in eco-design and in the reduction of greenhouse gases. There is still room for improvement in how CSR criteria are taken into account in the supply chains of successful bidders themselves. CSR policies and commitments are proving difficult to apply on different sites (training, deployment of responsible purchasing, and so on). EDF’s requirements in this respect still need to be promoted in audited companies.

Audits have also been conducted by other companies, e.g. Dalkia (2916 audits in 2021) and Luminus, where a significant shortcoming was noted at a subcontractor for one of its main suppliers. After several alerts, the entity suspended its contract until the relevant company became compliant.

3.4.2.3.4 Responsibility in the fuel supply chain
Coal supply chain
Bettercoal

Since its coal contracts were taken over by JERA Trading (JERAT), EDF has no direct contractual relations with mining companies or the market, but remains an active promoter of the Bettercoal responsible coal purchasing initiative that EDF helped to found. Bettercoal brings together energy companies, port institutions and coal terminals to promote CSR in the coal supply chain, mainly at mining sites, to ensure that fundamental rights are respected.

The operational approach is based on a code that sets out ethical, corporate and environmental principles and provisions relevant to mining companies. It takes into account general performance requirements, including management systems, and also performance requirements concerning: ethics and transparency, human and labour rights (such as the prevention of forced and child labour, the right to a decent wage), social issues, including health and safety, and the environment.

EDF supplier JERA Trading has become a member of Bettercoal, thus raising the profile and influence of this initiative in Asia. In 2021, 92% of JERAT supplies of coal to the EDF group came from operators that have adopted the Bettercoal initiative; 8% came from North American operators.

Uranium supply chain

EDF obtains its uranium supplies over the long term under diversified contracts in terms of origin and suppliers, in most of the main producing countries (Australia, United States, Canada, Kazakhstan and Russia). The clauses authorising the completion of audits and setting out EDF’s expectations in terms of enforcement of the fundamental rights and main international standards by suppliers and sub-contractors have progressively been added to contracts.

Audit reference framework

The uranium mine audit system used by EDF since 2011 ensures that the ore is extracted and processed in good environmental, social and societal conditions. The method and evaluation chart were developed with the World Nuclear Association (WMA). (1) This method is based on international standards, including The World Nuclear Association’s Sustaining Global Best Practices in Uranium Mining and Processing: Principles for Managing Radiation, Health and Safety, and Waste and the Environment, The Global reporting Initiative’s (GRI),

Sustainability reporting Guidelines & Mining and Metals Sector Supplement, and The International Council on Mining and Metals’ (ICMM) Sustainable Development Framework. Safety is an especially critical issue in mining (process safety), and as such is standardised and recognised by all players in the industry. It takes into account the issues of human rights and fundamental freedoms (human rights, whistleblowing register, rights of indigenous peoples and radiation protection) and also the environment, in the broadest sense of that term (water, diversity, waste, site clean-up after extraction).

Audits

Every year, EDF carries out mine audits through internal means (2 audits per year). The reports present the main strengths, recommendations and suggestions. The most common ones relate to health and safety (wearing personal protective equipment such as gloves or googles), the display of safety instructions, monitoring accidents, performing radiological controls, monitoring environmental footprint (specifically carbon emissions) and proposals relating to well-being in the workplace. Audit recommendations are included in the continuous improvement plans and action plans.

2021 Programme

After being suspended in 2020 due to the international health crisis, the audit programme resumed in August 2021 remotely; on-site auditing was resumed in October 2021.

(1) Guidelines for Evaluating Supplier Performance at Uranium Mining and other Processing Sites in the Nuclear Fuel Supply Chain.