Universal Registration Document 2021

Reduction of chemical risks

When it is technically feasible, in order to reduce pollution risks, the Group’s entities have also implemented a programme to eliminate or substitute certain chemical substances with more environmentally-friendly products. This work focuses as a priority on CMR (carcinogenic, mutagenic, or toxic for reproduction) substances or those considered subject for concern.

Substitution and disposal	Substitute products are often environmentally certified, e.g. cleaning products (regarding our subsidiaries Citelum, Électricité de Strasbourg (ÉS) and data centres). Following on from the R&D studies, substitutions are implemented, such as: environmentally acceptable oils for hydraulic production, fluids for thermal and nuclear power plant turbines in France and the United Kingdom, varnishes and paints (Industrial Division, Property Management and Citelum), and the decision by the Real Estate Department to stop using pesticides.
PCBs and PCTs	EDF, Hydro, Property Management, Enedis and ÉS are continuing with their programmes to decontaminate equipment with concentrations higher than 50 ppm for PCBs ⁽¹⁾ and PCTs ⁽²⁾. These action plans continued in 2021 and are on target. For the “Electrical Equipment Laboratory” Department at the site in Les Renardières, the matter was fully handled. Complete disposal is set for the end of 2025 for EDF IES and Dalkia. Thermal and nuclear generation lines no longer have any equipment exceeding the threshold.

Substitution and disposal

Substitute products are often environmentally certified, e.g. cleaning products (regarding our subsidiaries Citelum, Électricité de Strasbourg (ÉS) and data centres). Following on from the R&D studies, substitutions are implemented, such as: environmentally acceptable oils for hydraulic production, fluids for thermal and nuclear power plant turbines in France and the United Kingdom, varnishes and paints (Industrial Division, Property Management and Citelum), and the decision by the Real Estate Department to stop using pesticides.

PCBs and PCTs

EDF, Hydro, Property Management, Enedis and ÉS are continuing with their programmes to decontaminate equipment with concentrations higher than 50 ppm for PCBs ⁽¹⁾ and PCTs ⁽²⁾. These action plans continued in 2021 and are on target. For the “Electrical Equipment Laboratory” Department at the site in Les Renardières, the matter was fully handled. Complete disposal is set for the end of 2025 for EDF IES and Dalkia. Thermal and nuclear generation lines no longer have any equipment exceeding the threshold.

3.5.4.4 Predictive watch networks

EDF anticipates changes to environmental and energy policies in order to take appropriate measures to guarantee regulatory compliance and manage business integration or reputational risk issues. To this end, the Sustainable Development Division coordinates a predictive watch system that mobilises and coordinates the Group’s experts.

Watch networks: this process is based on the work of thematic groups known as “watch networks”: water, waste and soil, air, biodiversity, industrialists, energy efficiency, energy poverty, health and climate change, sustainable finance.
Sustainable Development Agency: the managers of each network meet every month as a Sustainable Development Agency which monitors the transversality of approaches and ensures that the Group’s challenges are taken into consideration.
Cross-functionality: each network works closely with the Legal, Public Affairs and European Affairs Divisions.
Recognition: EDF was considered by the Influence Map think tank to be one of the 17 companies most actively supporting regulation in accordance with the Paris Agreements⁽³⁾.

3.5.4.5 Controversy management process

The EDF group attaches great importance to identifying, preventing and mitigating the risks of serious human rights, environmental and health and safety risks in all its activities and projects. Accordingly, in order to identify and anticipate the risks of ESG (Environment, Social and Governance) controversies, EDF has set up a dual system for managing controversies:

Prevention: pursuant to its risk anticipation approach, and thanks to monitoring tools ⁽⁴⁾, EDF identifies the risks of ESG controversies in France and internationally to which its operating activities and projects may contribute. EDF classifies these risks in consultation with the relevant entities and countries and decides on appropriate measures and/or communication.
Engagement and responsiveness: when reacting to the occurrence of risks, EDF responds systematically and transparently to rating agencies that ask for explanations on issues they have deemed controversial. This process is applied in particular when screening projects eligible for EDF’s green emissions financing.

3.5.4.6 CSR and remuneration policy for group executives

In line with EDF’s desire to promote integrated performance based on both finance and CSR, the annual variable compensation of the Group’s senior executives is also based on financial and CSR criteria.

The CSR criteria, which can represent up to 15% of the variable compensation of executives, consist of a climate criterion and two social criteria.

A Climate criterion, based on carbon intensit

	Weighting in the Group share of bonuses	2021 result	2021 target	2021 attainment rate
Carbon intensity	Carbon intensity Weighting in the Group share of bonuses 30%	Carbon intensity 2021 result 48g/ KWh	Carbon intensity 2021 target 51g/KWh	Carbon intensity 2021 attainment rate 114 %

Two social criteria

The global LTIR and the leadership index ⁽⁵⁾ together represent up to 30% (17.5% + 12.5%) of the bonus linked to objectives that are specific to the different structures of the Group (Divisions, companies).

(1) PCB: Polychlorobiphenyl.

(2) PCT : Polychloroterphenyl.

(3) How companies really impact progress on climate, 2019, influence map.org/climate-lobbying.

(4) Such as RepRisk.

(5) See sections 3.3.1.3.3 “Occupational accidents” and 3.3 “Well-being and solidarity”