The Group Purchasing Department has carried out a review to assess the integration of the duty of vigilance in its contracting phases. In late 2021, the compliance commitment for bidders (which is mandatory to participate in the tender), covering the themes of corruption, money laundering, financing of terrorism, no conflicts of interest, and international sanctions, was finalised. Bidders now commit to comply with EDF’s requirements relating to the French Duty-of-Care Act: To respect human rights and fundamental freedoms, to guarantee the health and safety of people in the workplace, to protect the environment, and to comply with the social and environmental regulations applicable to its activities (see section 3.4.2.3.2 “Sustainable and balanced relationships – Responsible purchasing processes”). The rest of this review will take place in 2022 and will contribute to improving the integration of the duty of vigilance at all levels of the contracting process.
In order to raise awareness among Group managers, a programme of internal “roadshows” was organised throughout the year for the Executive and Management Committees of the most exposed subsidiaries and departments. The purpose of these roadshows is to reiterate the foundations and obligations of the law, the Group’s dedicated organisation, as well as a presentation about ongoing litigation based on the duty of vigilance concerning an EDF Renewables project in Mexico (see section 3.9.6.1.2 “Main prevention, mitigation and monitoring measures implemented”). In order to raise awareness among Group managers, a programme of internal “roadshows” was organised throughout the year for the Executive and Management Committees of the most exposed subsidiaries and departments. The purpose e of these roadshows is to reiterate the foundations and obligations of the
law, the Group’s dedicated organisation, as well as a presentation about ongoing
litigation based on the duty of vigilance concerning an EDF Renewables project in
Mexico (see section 3.9.6.1.2 “Main prevention, mitigation and monitoring
measures implemented”).
In addition to the network of Duty-of-Care Officers appointed in the relevant Group entities, closer coordination has been established between the various EDF internal networks relating to Sustainable Development (corporate and international activities), Ethics and Compliance, and Internal Control, in order to promote the duty of vigilance in all areas that may be exposed and/or contribute.
In September 2021, the Group developed an e-learning module dedicated to the duty of vigilance to raise awareness and help deploy the Group’s compliance plan. The module, which aims to reach as many managers and project leaders as possible, is available in French and English. It provides a definition of the duty of vigilance, its scope of application, the actors involved and the associated obligations, and identifies the risks and remedial actions through concrete examples relating to the Group’s activities. Details are also included on how the Group has organised its duty of vigilance and its whistleblowing process. By the end of December 2021, approximately 500 people have registered to take the module.
In response to requests from stakeholders, the Group has redesigned the section of its website dedicated to the duty of vigilance in order to provide a quick overview of the Group’s Vigilance Plan, the associated Standards and the organisation in place.
These actions in 2021 are part of a year-round improvement process based on a regularly reviewed action plan.
Risk prevention and mitigation measures are implemented by each relevant entity by way of applying cross-functional and sectorial policies and using common Group methodology for risk control as a basis. This methodology provides a description of risk treatment action plans and an evaluation of their efficacy. Industrial projects are subject to a risk analysis within the scope of application of the duty of vigilance, taking into account their nature, size, technical features and location. For this purpose, environmental and social impact assessments are based on the most demanding international standards (mostly IFC, WB, ADB(1)).
In addition, issues relating to the environment, personal health and safety and human rights are systematically addressed as part of the assessment process for projects submitted to the Group Executive Committee’s Commitments Committee(CECEG) and to the Committee that validates the Group’s international development projects, the International Business Development Committee (CBDI), in the form of an identification of the risks associated with projects, to ensure that EDF’s commitments in this area are not overlooked.
In addition to these structural mitigation measures, in 2021 the Group reinforced all of these measures based on its Duty-of-Care action plan, which is validated annually.
In the area of human rights and fundamental freedoms, the Group’s ethics and compliance policy, which includes the duty of vigilance, has led the EDF group to implement an approach that results in the identification of key risks and associated mitigation measures, assessed according to the Group’s activities and the countries where the Company and its subsidiaries operate.
Two categories of salient risks related to human rights and fundamental freedoms were identified:
The implementation of human rights commitments is part of the deployment of the EDF’s group Global Social Responsibility Agreement and of the Group’s reference framework.
Executives must take all necessary steps to prevent discrimination, harassment and physical and emotional abuse within their entities by striving to make employees aware of such risks. They must provide regular information about the Group whistleblowing system and take appropriate disciplinary action in the event of proven wrongdoing (see section 3.3.2.2.2 “Prevention of harassment and discrimination”).
The EDF group is committed to developing concrete action to promote equality in the workplace and occupational and social integration for disabled people, combating sexism, violence and all forms of discrimination and developing support for parents. Among the many prevention actions described in section 3.3.3 “Equality, diversity and inclusion”, the following major prevention and mitigation actions are carried out by the Group:
(1) IFC: International Finance Corporation. WB: World Bank. ADB: Asian Development Bank.
