In addition to the EDF group’s ethics alert system, projects are developing local complaint management systems to ensure that communities directly and indirectly impacted by the projects can raise their concerns and have them addressed. In line with international environmental and social standards, the Nachtigal Hydroelectric Project in Cameroon has had a mechanism in place since April 2015 to manage queries and complaints. They may be submitted in writing, orally or by proxy, in all local languages of the project area, as well as in the official languages of the country. Grievances are recorded in the project’s query and complaint log. Once recorded, if the complaint relates to the project’s commitments, activities, accountability or mandate, an investigation is initiated to determine the basis for the complaint. The project then proposes a treatment to the complainant. A mediation Committee can intervene if the complainant is not satisfied with the treatment applied. Finally, an appeals Committee can be called upon if the complainant is not satisfied with the solution proposed by the mediation Committee;
EDF has been involved in projects since the beginning of the country’s democratisation process in order to contribute to the electricity needs of the population, 40% of which cannot access it. The Group took part in a consortium dedicated to the development of the Shweli 3 hydroelectric project, as well as the development of Myanmar’s first microgrid, without any government subsidies. On 1 February 2021, the Shweli 3 consortium decided to suspend the development of the project (including the activities of its subcontractors in the project), as it could no longer ensure respect for human rights;
In 2018, an NGO referred the planned Gunaa Sicaru wind farm, managed by a subsidiary of EDF Renewables in Mexico, to the OECD’s French national contact point (NCP). During the course of the OECD mediation process, the EDF group took part in two dialogue meetings with the plaintiffs and provided some responses to the concerns raised. The NCP closed the matter in spring 2020. The indigenous consultation process conducted by the Mexican authorities was suspended following the earthquake in 2018, and since 2020 due to the Covid-19 pandemic. The process is now about to enter the phase of deliberation by the indigenous community. Likewise, in December 2019, EDF responded to a formal notice for the same project sent pursuant to the French “Duty-of-Care” Act by that NGO and four individuals. EDF was then summoned on 13 October 2020 to appear before the Paris Court of Justice (Tribunal judiciaire) under the French “Duty-of-Care” Act. The applicants have asked the court to order changes to the Vigilance Plan produced by EDF to better address, in particular, the risks posed to the rights of indigenous communities and to order compensation for the damage caused by its failure to fulfil its duty of Vigilance. EDF has challenged these two applications. On 30 November 2021, the pre-trial judge rejected the non-profits’ request for a precautionary suspension of the project as well as their request for an injunction against EDF’s Vigilance Plan, due to the lack of a prior formal notice. The applicants appealed the judgment of the pre-trial judge. The Tribunal proposed mediation, which EDF accepted.
A website dedicated to the project is available in English and Spanish: https://www.gunaa-sicaru.com/.
Group mapping of risks is performed based on the Group’s line of industrial activities. Environmental risks are identified, assessed, and prioritised through the environmental management system (EMS) and the internal control system linked to Group risk management (see section 3.5.4.2 “Environmental management system (EMS)”). The identification of environmental risks is part of the Group’s overall risk management system (see chapter 2 “Risk factors and control framework”). Each company draws up its own risk map, based on the Group’s methodology, and defines action plans to reduce and limit its risks.
The 2021 risk mapping update reconfirmed the 2020 risk analysis and did not highlight new environmental risks. The main change concerns the observation of the effects of climate change with higher temperatures in summer and droughts increasing the pressure on both environments and some of the Group’s business lines such as hydropower and nuclear activities.
The salient environmental risks are as follows:
| Salient risks | Production activities most exposed |
|---|---|
|
Power and heat generation activities from fossil fuel |
|
Power generation activities (nuclear, thermal, hydropower, wind and solar power) |
To prevent and mitigate risks of serious harm to the environment, EDF relies on its Environmental Management System (SME) and its CSR policy to commit its entities to a precautionary approach and acting responsibly. The most significant risks are covered in risk control plans in conjunction with the Group’s CSR policy.
In order to implement the environmental goals and related actions based on its CSR commitments and policy, the EDF group has set up a Group-wide environmental management mechanism using an Environmental Management System (EMS) (see section 3.5.4.2 “The environmental management system (EMS)”). This management system relies on EDF’s governance bodies, which define the environmental guidelines and objectives to be achieved, in line with the expectations of external and internal stakeholders (see chapter 4 “Corporate governance” and section 3.5.2 “CSR governance bodies”).
In accordance with the requirements of the CSR policy, each of the Group’s entities (1) is implementing an environmental management approach adapted to its own issues.
The EMS’ operation is carried out by Group and business processes that allow for certification to stakeholders:
The Group’s EMS is certified by an external body, AFNOR, according to the international standard ISO 14001. All industrial sites are covered by an EMS, 87% of which are certified.
(1) Companies with industrial, operational (installation, operation, maintenance), engineering, distribution and marketing activities relating to goods and services
