EDF has strengthened its oversight of the Vigilance Plan with the appointment, in December 2020, of a Group Duty-of-Care Compliance Officer by two members of the Executive Committee: the Group Corporate Secretary and the Group Executive Director in charge of Innovation, Corporate Responsibility and Strategy. This officer is responsible for the development, deployment and coordination of the plan and its application within the Group.
The Vigilance Plan and the resulting actions are validated by the CSR Strategy Committee chaired by the Group’s Chairman, and submitted to the Corporate Responsibility Committee, a Committee of the Board of Directors dedicated to social and environmental responsibility issues.
The Vigilance Plan is managed in collaboration with the Legal Department and the Sustainable Development Department within a Steering Committee and a Strategic Committee that also includes the Human Resources Department, the Purchasing Department, the Risk Department, the International Department, the Ethics and Compliance Department; the Export Control and International Sanctions Department, and the representative of a subsidiary with particularly exposed activities. The Strategic Committee defines the orientations and objectives of the Vigilance Plan in a collegial manner, based on proposals from the Steering Committee. It ensures that these objectives are achieved and may redefine them according to the operational progress reported by the Steering Committee.
The deployment and coordination of the Vigilance Plan is based on a network of Duty-of-Care Officers appointed in each Group entity concerned.
Dialogue with stakeholders is a major part of EDF’s culture. It forms the basis of our cooperation with our stakeholders.
The Global Framework Agreement on Corporate Social Responsibility signed by EDF in 2018 and extended for two years on 29 November 2021 with the Group’s trade unions and two international trade union federations (IndustriAll and ISP) states that EDF’s Vigilance Plan will be “developed and set up in association with the Company stakeholders, including workers’ representative organisations (see section 3.5.3.1.1 “Global Social Responsibility Agreement”).
Since 2018, the Committee for Dialogue on Social Responsibility (CDRS), made up of representatives of all the signatories of the agreement, has been working on numerous topics related to the Duty of Vigilance (health and safety, exercise of the Group’s responsibility in the context of international projects, impacts of the pandemic, etc.) and on the actions to be implemented to roll out and improve the Group’s Vigilance Plan. For example, in 2021, CDRS members learned from its meetings about the progress of the Vigilance Plan, and also were shared the draft duty-of-care framework (“Human Rights and Fundamental Freedoms, Health and Safety, Environment, Business Ethics: the EDF group’s Commitments and Requirements”), which had been submitted to them for comment. A training day in November 2021 dedicated to the Duty of Vigilance was co-organised by the global trade union federations and the Group’s management, during which participants were able to discuss concrete cases and benefit from a demonstration of the new e-learning training module now accessible to all employees (see section 3.9.5 “Major improvements of the EDF group’s Vigilance Plan in 2021”).
Externally, EDF participated in discussions with other companies, lawyers, NGOs, and trade union federations within the framework of the “Entreprises pour les droits de l’homme” (Businesses for Human Rights, EDH (1)) non-profit organisation, in order to openly exchange on the expectations of all stakeholders, practices and
improve Vigilance Plan preparation processes.
In November 2021, EDF also took part in a peer review organised by Global Compact, bringing together other groups subject to the law, and personalities from the world of non-profits and research.
The EDF group is an integrated energy company engaged in activities involving risks in three fields where the Duty of Vigilance applies. EDF is active in all areas of the electricity industry and some areas of the gas industry: power generation using nuclear, renewable and thermal energies; electricity transmission and distribution; sales; energy services; energy trading (see section 1.4 “Description of the Group’s activities”).
The Group’s activities are mainly located in OECD countries. Countries considered to be “higher-risk countries” receive special care, including in terms of relations with partners.
Within the Group, EDF Renewables is an entity that develops a significant number of projects in a large number of countries (present in more than 20 countries) for operation, but also for Development and Sale of Structured Assets (DSSA). Consequently, several geographical areas are concerned, the main ones being (% of net installed capacity in solar and wind power):
| North America | 42 % |
|---|---|
| Europe | Europe 42 % 27 % |
| South America | South America 42 % 12 % |
| China and India | China and India 42 % 11 % |
| Israel | Israel 42 % 4 % |
| Saudi arabia, Egypt and United Arab Emirates | Saudi arabia, Egypt and United Arab Emirates 42 % 3 % |
| South Africa | South Africa 42 % 1 % |
The scope of suppliers and subcontractors managed by the Group Purchasing Department represents approximately 11,000 suppliers. Over 97% of purchases are made in France and 98.5% in Europe. Suppliers of certain subsidiaries or suppliers involved in international projects are subject to special vigilance measures. Because the Group’s activities are mainly in the industrial field, EDF exercises upstream vigilance, with regard to any risk of violation of persons’ rights or risk to their health (employees, service providers, local residents, local communities and customers) or risk to the environment prior to making investment decisions, particularly to build, operate, maintain or dismantle facilities.
The scope of the Vigilance Plan covers EDF’s activities, the activities of subsidiaries it controls (2), as well as the activities of its suppliers and subcontractors with which the Group has established commercial relations to the extent their activities are related to those relations.
The Organisation of the Group is detailed in section 1.2.1 “Organisation of the Group”.
Dalkia and Framatome subsidiaries with a headcount of over 5,000 employees are integrated in the plan, together with all French and foreign subsidiaries.
RTE and Enedis, respectively the French power transmission and distribution system operators, are independently managed subsidiaries, and therefore publish their own Vigilance Plans.
(1) e-dh.org
(2) Subsidiaries integrated into the scope of consolidation using the full consolidation method pursuant to Article L. 233-16 II of the French Commercial Code (in France and abroad) (see note 3 to the consolidated financial statements).
