The process for identifying and prioritising risks used to develop the Vigilance Plan is based on two complementary approaches: Group risk mapping, which includes several risks related to the duty of vigilance, and additional risk mapping, specifically focused on the entities most exposed because of their activity and/or their location.
Under the Group approach described in section 2.1 “Risk management and control of activities”, each Group entity conducts a risk mapping exercise, under the responsibility of management, using a risk typology designed to cover all categories of risk, whether internal or external, operational or strategic, to which the Group is exposed.
It is made up of 5 successive steps: Risk identification, risk assessment, prioritisation, control through the definition of an action plan, managing the action plan which includes monitoring the action plan’s deployment, and measuring its effectiveness.
In order to reasonably ensure that the main risks are being identified, a separate approach for each business process and each asset is combined with a separate approach for each major risk type. In addition, feedback, events, incidents, and near-misses are taken into consideration as a source of risk identification, as well as the results of audits. The identification of risks is the result of a discussion between the main actors: Managers, experts and stakeholders.
The identified risks are qualitatively prioritised according to:
The EDF group’s risk map is based on the entities’ risk maps, internal control self-assessments, and cross-analyses of feedback from operational and functional entities.
The Group Risk Management Department identifies and assesses Group-level risks and draws up a Group risk map, which is validated by the Risk Committee chaired by the Group’s Chairman and then presented to the Board of Directors’ Audit Committee.
Through this approach, the main risks presented in section 2.2 “Risks to which the Group is exposed” have been identified, at the level of the EDF group.
Several of these risks are of strategic importance for the Vigilance Plan:
The risks specific to the Duty of Vigilance are detailed by area in section 3.9.6 “Salient risks and risk prevention and mitigation measures”.
Early in 2021, an inventory, review, and diagnosis of the Group’s internal processes was carried out in order to measure the Vigilance Plan’s efficiency and how far its deployment had progressed. Several projects and actions were initiated as part of a continuous improvement process:
In March 2021, EDF drew up a set of guidelines listing the commitments of the Group (EDF and its controlled subsidiaries) and the fundamental requirements for its business relationships in terms of human rights and fundamental freedoms, environmental protection, protection of personal health and safety and business ethics.
The Group has summarised its duty-of-care commitments in these standards, and spells out its requirements for its partners, financiers, suppliers, and subcontractors.
This document, submitted to the members of the CDRS (1) (see section 3.9.2 “Governance, steering and stakeholder involvement”), was signed by the Chairman of the EDF group. It is available in French and English on edf.fr website (https://www.edf.fr/sites/default/files/contrib/groupe-edf/engagements/2021/rse/edfgroup_rse_referentiel-ddv-2021_fr.pdf).
Consideration of the Duty of Vigilance and the associated Group standards is included in each analysis of projects presented to the Commitments Committee of the Group Executive Committee (CECEG). In concrete terms, this takes the form of identifying the risks associated with the projects, both for the activities developed and for the supplier relationships envisaged within the framework of the project (see section 3.9.6 “Salient risks and risk prevention and mitigation measures – Global actions to prevent and mitigate risks relating to the Duty of Vigilance”).
This identification will be facilitated by the construction of a grid, to be made available in 2021, which will allow for an analysis of projects that are consistent with the Group’s raison d’être, CSR commitments, and guidelines, as well as with international standards. This grid takes into account environmental, health and safety, human rights, and ethical dimensions.
The Group has developed an in-house country profiling tool to assess a country’s context in terms of risks related to the duty of vigilance. It gathers the values of eight indicators (such as the Gender Gap Index or the Children’s Rights in the Workplace Index) for more than 180 countries covering the three Duty-of-Carethemes (Human Rights, Environment, Health and Safety) as well as the country’s socio-economic situation.
To complete this tool, the Group has also subscribed to Verisk Maplecroft® to have access to 13 human rights indices in order to refine and specify the human rights risks that the Group could face in the countries where it operates, purchases and develops.
(1) Committee for Dialogue on Social Responsibility (CDRS).
