Universal Registration Document 2021

When analysing the technical and DNSH criteria, EDF relies on its Environmental Management System (EMS), its Sustainable Development policy, as well as its Ethics Charter that commits its entities to a precautionary approach, to acting responsibly and to developing technologies which respect the environment. Management of identified risks, including those associated with climate change, is fully integrated into the Group’s global risk management process and internal control system. The most significant risks are covered in risk control plans in conjunction with the Group’s Sustainable Development policy.

The Group’s EMS covers the environmental objectives of the Taxonomy as described in the paragraphs below.

• The Group ensures that its facilities are adapted to climate change. The EDF group developed a climate incident plan in 2004, followed by a climate change adaptation strategy in 2010.

This document lays out the foundations of the Group’s commitments in terms of adaptation, and identifies actions to be implemented across all business lines: evaluating the impacts of climate change on future and existing activities, adapting existing installations to make them less sensitive to climatic conditions and more resilient to extreme weather events, incorporating climate change scenarios in the design of new installations, and adapting the Group’s solutions, internal operations, and expertise to encompass climate change.

All EDF group entities are required to take account of climate risks in mapping their risks, including both physical risks and “transition” risks. The entities most exposed to physical risks have climate change adaptation plans, which must be updated at least every 5 years.

In June 2021, the Executive Committee approved a new adaptation plan that will be deployed in the entities concerned.

• As a manager and major user of water resources, the EDF group is committed to integrated and responsible water management, both in terms of quantity and quality. Consequently, each energy-generating site will provide for, evaluate and report on the sustainability of its water use. The Group also ensures that water is shared within the regions in which it operates by fully taking into account the local water situation (multi-use under climate constraints).
• With regard to waste management and the circular economy, optimising the use of the natural resources consumed by the Group’s value chain is an essential component of the Group’s corporate responsibility.

The Group’s action therefore focuses on three priorities: eco-social design, the functional economy and industrial ecology. The Group prevents and optimises the production of conventional waste by promoting reuse, recycling and recovery initiatives for products/equipment throughout its value chain: a customised “waste plan” is produced for all new construction sites to avoid the production of conventional waste and promote recycling and recovery.

The Group takes full responsibility for radioactive waste and, in France, uses procedures to decommission closed nuclear power plants that are completely safe and protect the environment. It optimises and manages the operating and decommissioning radioactive waste for which it is responsible and develops treatment processes to reduce the volume of stored waste.

• With regard to the prevention and control of pollution, when it is technically feasible, in order to reduce the 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.

Nuclear safety is the Group’s top priority and a major, ongoing concern for the Group throughout the entire cycle, from procurement of fuel to decommissioning and waste management. It is based on technical and organisational specifications aimed at preventing a nuclear accident, and in the hypothetical case of such an accident, at limiting the consequences thereof.

• Protection and restoration of biodiversity and ecosystem is also a major challenge for the EDF group. The action taken by the Group is structured around the following priorities: reducing the contribution of its operations to major biodiversity pressures, recreating spaces and conditions promoting biodiversity, improving and sharing knowledge, strengthening governance and raising awareness of biodiversity-related issues.

In 2020, the Group renewed its commitment to biodiversity through two voluntary schemes supported by the French government: Entreprises engagées pour la biodiversité – act4nature France (Companies committed to biodiversity

– act4nature France), a corporate biodiversity scheme run by the Office français de la biodiversité (French Biodiversity Office) and “Act4nature”.

The DNSH criteria were analysed for each activity.

For example, the following audits were conducted to assess the alignment of the electricity distribution business:

• confirmation of compliance with the technical criterion of interconnection to the European grid or new connections involving more than 67% of installations emitting less than 100gCO₂e/KWh;
• confirmation of facility resiliency to validate the criterion of not harming climate change adaptation;
• verification of the existence of a waste management plan to validate the criterion of not harming the transition to the circular economy;

• confirmation of compliance with international IFC guidelines and electromagnetic pollution regulations to validate the criterion of not harming the prevention of pollution;

• verification of the existence of studies and measures attesting to respect of the criterion of not harming the preservation of biodiversity.

• The Group’s compliance with the minimum safeguards criterion is based on the implementation of human rights commitments and on the deployment of the “Human Rights and Fundamental Freedoms, Health and Safety, Environment and Business Ethics: EDF group commitments and requirements” guidelines ⁽¹⁾. It is based on principles of action that apply to all of the Group’s activities, and which aim, as part of an approach to progress, to carry out in particular:

• initial and ongoing screening and management of environmental and societal impacts and risks, including those caused by operations as part of its business relationships;

• organisation, throughout the world, of transparent dialogue and consultations for each new project. EDF strives to implement its commitments in the early stages of its investment processes, including in its business relationships by requiring its suppliers and subcontractors to comply with CSR requirements for operations related to their joint business relationships, with a specific focus on the rights of local and indigenous communities and vulnerable groups;

• systems for collecting and processing reports of wrongdoing, that are accessible and notified to anyone who could be impacted by the Company’s operations, guaranteeing the confidentiality of the reports and protecting internal whistleblowers (employees and external staff). These reports are evaluated and, if necessary, remedial measures are taken.

  This public document applies to EDF and the companies it controls (2). As far as
  Enedis is concerned, the subsidiary has drawn up its own vigilance plan to meet the requirements of French Act 2017-399 of 27 March 2017.

Following the analysis of the technical criteria, DNSH criteria and minimum guarantees, almost all of the Group’s activities qualified as eligible are also qualified as aligned.

(1) Reference framework available on the EDF website https://www.edf.fr/edf/dispositif-alerte-groupe

(2) Excluding Enedis, the distribution network operator, a subsidiary managed in compliance with the rules of management independence, as defined in the French Energy