Universal Registration Document 2021

The EDF group and some of its subsidiaries have decided to apply for an international certification (GEEIS certification, renewable every four years) to assess the quality and relevance of their commitments to gender diversity and equality in the workplace. The certification was renewed in 2019 and, for the very first time, it was extended to all the Group’s other fields of action in terms of diversity and inclusion. signing a GEEIS commitment charter, marking the Group’s commitment to fighting stereotypes by deploying inclusive artificial intelligence without gender stereotypes in all business processes and environments.

The EDF group is committed to preventing and combating all forms of violence against women, in the workplace (sexism, harassment) and also domestic and family violence (support, guidance and job retention). The aim is to train and raise the awareness of managers and Human Resources personnel on the subjects of sexism and both moral and sexual harassment. Thus, with the help of the“ENERGIES mixité!” network, a new “sexism barometer” was set up in 2021, as part of the #StOpE multi-company initiative, of which EDF has been a member since the beginning. Operational implementation of such measures was carried out in partnership with the Company’s medical and social teams and the “FIT, une femme un toit” association in particular. EDF has helped, assisted, supported and guided 102 employees who were victims of domestic violence over 2021.

The EDF group is committed to societal and professional integration of disabled people, with its 11th EDF agreement for equal rights and equal opportunity and the occupational integration of disabled people, entered into for the 2019-2022 period. The challenges change over time, such as digital matters (“digital accessibility at all stages of a project” e-learning course), which has been made a priority in the latest EDF disability agreements.

In order to prevent racial discrimination, the EDF group addressed the issue of its origins, and more specifically racism in the workplace, in a reference document for its managers and Human Resources Officers.

The EDF group has been committed to respecting religion in the workplace since 2008, and published a first set of guidelines in 2010 (updated in 2016), setting out guidelines for managers and HR officers to help them understand, analyse and act in compliance with the law.

EDF is also partner of L’Autre Cercle ⁽¹⁾ and Energay associations ⁽²⁾, and has been a signatory of the LGBT charter since 2015. “Respect for different sexual orientations in the worplace” guidelines were published. EDF has also designed, in partnership with Energay, a process to accompany and support transitioning employees within the Group. “Supporting transitioning employees at EDF – Respect for gender identity” guidelines were published.

A toll-free hotline for all employees of the Company, operating seven days a week, to allow employees to confide in someone and obtain advice on all harassment and discrimination issues; a support team (with internal and external skills) intervenes in investigations carried out when alerts are reported.

Preventing risks related to the Group’s international activities and projects concerning violations of the rights of communities and workers and the use of security forces

The EDF group does not tolerate any infringement of human rights and fundamental freedoms, whether in its own activities or in those of its business relations when their activities are related to this relationship. All of the Group’s commitments relating to human rights are described in section 3.3.2.3 “Human rights”.

These commitments are implemented and based on the principles of action that apply to all Group operations such as:

1. screening, initial and ongoing, and management of environmental and societal impacts and risks, including those caused by operations under its business relationships;
2. organisation, throughout the world, of transparent, debated discussions and consultations for each new;
3. implementation and monitoring of these commitments and requirements is ensured under the Group’s internal policies or agreements, in particular the CSR policy, the ethics and compliance policy, the purchasing policy, the health and safety policy, the global CSR agreement, the Ethics Charter and the roll-out of the Vigilance Plan;
4. implementation of 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).

Depending on the context of the project, a Human Rights Impact Assessment (HRIA) is conducted. It is based on the principles defined by the UN Guiding Principles on Business and Human Rights, as developed for example by the Danish Institute on Human Rights. These studies place the identification of impacted human rights at the centre of the analysis. They include an assessment of the state of human rights in the country as well as in the project area, a mapping of human rights-oriented stakeholders (listing “rights-holders” and “duty bearers”), an analysis of the project’s impacts on these rights, and the development of mitigation measures. This type of study identifies the activities at risk according to their importance and sensitivity.

These studies are generally entrusted to national or international consultants specialising in the topic, and managed by EDF’s internal CSR referents.

The conclusions of these studies are intended to be integrated into all development, construction, operation and end-of-life activities of the project, via an ad hoc management system (internal CSR policy, CSR contact and correspondents, contractual tools, audits and performance monitoring, reporting, etc.). They concern both affected communities and workers, the use of security forces, the whistleblowing system and the protection of whistleblowers, etc.

With regard to decent working conditions, external inspection and audit missions carried out on the sites of internationally financed projects (such as the Nachtigal project) enable the Group to detect breaches of the Group’s commitments at each stage of the project’s life.

At the level of the investment decision-making process, the consideration of human rights, through the Group’s commitments framework, is integrated into each analysis of projects presented to the Group Executive Committee’s Commitments Committee (CECEG), as well as to the Validation Committee for the Group’s international development projects (CBDI). This takes the form of identifying the human rights risks associated with the projects, both for the activities developed and for the supplier relationships envisaged in the framework of the project. This identification will be facilitated by the construction of a grid, to be made available in2021, 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. All of the Group’s human and requirements are addressed, such as compliance with the ILO’s fundamental conventions (on child labour, forced labour, freedom of association, discrimination), the rights of local communities, and health and safety conditions for the populations in question.

In operational terms, several projects are presented in section 3.3.2.3.4 “The implementation of human rights commitments” including:

• solar park development project in India:

  During the development of EDF Renewables’ solar park in Bap Tehsil, India, dialogue with local communities has enabled:

• impact avoidance: A bypass road was built to avoid traffic disruption in the village,
• impact mitigation: The plant was redesigned to preserve trees in accordance with local community requests,
• impact compensation: Community investments have been made, such as the creation of a water basin in the village,
• during the operational phase, dialogue and investment have continued: asocial budget is devoted each year to programmes such as improving the sanitation of school buildings, and providing fans and sporting equipment to students and bicycles to the poorest villagers. The development of the project has also created employment opportunities for the people living in the area;

(1) L’Autre Cercle is an LGBT (Lesbian Gay Bi and Trans) association combatting discrimination in the workplace. www.autrecercle.org

(2) Energay is the LGBT association for the electric and gas industries and their www.energay.org