Universal Registration Document 2021

3. Non-financial performance

Among the categories of purchases analysed and classified as major residual risks, the most important categories in terms of amount are the following:

  • IT and electronic services and materials concerning human rights risks in relation to the supply chain;
  • work and maintenance services in industrial environments concerning the increased security risk;
  • deconstruction/depollution services concerning the environmental risk (waste production).

Some smaller categories are also included, such as airline ticketing.

In 2021, the human rights risks related to the supply chain have been specified in the areas of textile purchasing, IT equipment, control/command and solar panels concerning the risks of forced labour.

3.9.6.4.2 Main prevention, mitigation and monitoring measures implemented

The Group’s new supplier policy, adopted in October 2021, defines the shared principles that the senior managers of the various entities are responsible for implementing with regard to purchasing and contract management. It emphasises the Group’s CSR requirements and sets out the Group’s raison d’être and its commitments in terms of responsible purchasing, the use of companies employing disabled workers only, local presence, and supplier awareness. The Group’s commitments and obligations to responsible purchasing are integrated into every stage of the purchasing process, including upstream, during the qualification of suppliers, as well as during the preparation of calls for tender.

Even when these mechanisms are not directly applied, the Group major department or subsidiaries use equivalent methods of commitment adapted to their specific industrial or geographic characteristics; they are detailed in section 3.4.2.3.2 “Sustainable and balanced relationships”.

EDF’s Group Purchasing Department takes CSR into account in its relations with its suppliers according to the principles of supplier commitments through:

  • all bidders signing a compliance commitment (mandatory to participate in the tender); this commitment covers the following issues: corruption, money laundering, financing of terrorism, absence of conflicts of interest. Bidders undertake to comply with the requirements of the Duty-of-Care Act: To respect human rights and fundamental freedoms, to guarantee the health and safety of people at work, to protect the environment, and to comply with the social and environmental regulations applicable to its activities;
  • the integration of CSR criteria in contracts, by including specific criteria in the specifications according to the risks identified for each type of contract, or to meet the Group’s CSR ambitions, such as the use of companies employing disabled workers only, local presence, or the integration of SMEs in the supplier panel;
  • the integration of a sustainable development clause covering environmental, human rights and health and safety commitments in the General Purchasing Conditions;
  • always including a Sustainable Development Charter between EDF and its suppliers as an integral part of the contracts;
  • development of Productivity Parternships;
  • monitoring supplier compliance with theses principles (see section 4.2.3.3)
Supplier assessment

The monitoring of suppliers, which includes a CSR component, begins with an internal evaluation of the services they provide. Supplier monitoring is mainly carried out by the Division or Contract Management, which uses Performance Assessment Sheets and Supplier Assessment Sheets.

Document audits are completed by the supplier, and are always (and independently) checked by the AFNOR teams. The questionnaires cover all areas of CSR; some are tailored to take into account category-specific issues. In 2021, it is mainly the suppliers in the risk categories (mobility and service providers working on nuclear sites) that have been questioned. It should be noted that suppliers were also interviewed at the request of Purchasing Category Managers (accommodations).

At the end of 2021, a special human rights questionnaire was developed with AFNOR and sent to all suppliers with a contract in force, in the purchasing categories mentioned in international reports on the non-compliance with human rights or expressly mentioned by these reports, in the fields of textiles, computer equipment, control devices, and IT. Regarding the purchase of solar panels, in 2021 EDF Renewables sent out a human rights questionnaire to its suppliers.

At the end of 2021, 3,000 suppliers were questioned using the Acesia platform, and nearly a thousand of them have been controlled. The assessments were “satisfactory” for 63% of the audited questionnaires. The suppliers to be assessed are mainly selected based on the supplier risk mapping and the needs of buyers and business lines, on the contracts in progress.

This tool makes it possible for purchasers and suppliers to share an approach of continuous improvement in Corporate Social and Environmental Responsibility.

These on-site audits cover all CSR aspects: environmental, social and ethical policies, commitments and practices. on-site supplier audits are conducted by external, independent providers. CSR audits are triggered on the basis of feedback on contract performance conditions, compiled by the Purchasing Category Managers in particular, and on supplier risk mapping.

These audits are designed to test the CSR commitments adopted and are conducted on site (head office or production site of the supplier or place of work at an EDF site).

In 2021, 52 on-site CSR audits were conducted, 67% of which were outside France. 60% had a “Satisfactory” rating, 34% an “Acceptable with Comment” rating and 6% an “Insufficient” rating, requiring supplier action plans. A large proportion of CSR audits were carried out as part of a call for tenders for the “workwear” category. Audited production sites that received “Insufficient” or “Unsatisfactory” overall ratings caused the applicant supplier to be excluded from the supply chain. The results of this specific campaign, carried out on sites mainly outside France, are quite heterogeneous. Best practices have been noted at several sites (voluntary certifications and labels, proactive employment/remuneration policy, good management of chemicals). However, the differences in compensation, working hours, and safety (lack of periodic verification of collective protection, inadequate PPE), including in Europe. Among the 2021 CSR audits, all of the Insufficient results relate to the textile category.

With regard to the audits carried out on other purchasing categories, the overall results show, in line with previous years, good management of operational risks in the area of safety and the environment, based in particular on critical certifications and a strong safety culture. Good practices and opportunities have been identified such as: Internal innovation challenge, improvement research in the fields of eco-design, and greenhouse gas reduction. Areas for improvement still relate to incorporating CSR criteria in the supply chains of the winning bidders themselves. Existing CSR policies and commitments are encountering trouble being adapted to the sites for implementation (training, responsible purchasing, etc.). EDF’s requirements on these matters are still to be promoted in the audited companies.

Coal and uranium procurement

In the coal supply chain, EDF no longer has direct contractual relations with mining companies or the market, but remains an active supporter of Bettercoal (1) – the initiative for responsible coal purchases of which EDF is a founding member. The operational approach is based on a code that sets out ethical, corporate and environmental principles and provisions relevant to mining companies. It takes into account general performance requirements, including management systems, and also performance requirements concerning: ethics and transparency, human and labour rights (such as the prevention of forced and child labour, the right to a decent wage), social issues, including health and safety, and the environment. JERA Trading, its supplier, is now a member of Bettercoal, thus increasing the initiative’s influence in Asia. In 2021, 92% of the coal supplied by JERAT to the EDF group will come from Bettercoal operators, and 8% from North American operators.

(1) bettercoal.org