Concerning uranium supply chain, clauses authorising the completion of audits and setting out EDF’s requirements in terms of enforcement of the fundamental rights and main international standards by suppliers and subcontractors have been included in the contracts. The uranium mine audit system used by EDF since 2011 ensures that the ore is extracted and processed in good environmental, social and societal conditions (see section 3.4.2.3.3 “Coal and uranium supply chain”).
This audit system ensures that the ore is extracted and processed in good environmental, social and societal conditions. The method and the evaluation grid were developed with WNA (World Nuclear Association). This method is based on international standards, including “The World Nuclear Association’s Sustaining Global Best Practices in Uranium Mining and Processing: Principles for Managing Radiation, Health and Safety, and Waste and the Environment”, “The Global reporting Initiative’s (GRI)”, “Sustainability reporting Guidelines & Mining and Metals Sector Supplement” and “The International Council on Mining and Metals’ (ICMM) Sustainable Development Framework”. The issue of safety, which is particularly critical in mining (process safety), consists of a standardised framework recognised by all those involved in the sector. It takes into account the issues of human rights and fundamental freedoms (human rights, whistleblowing register, rights of indigenous peoples and radiation protection) and also the environment, in the broadest sense of that term (water, diversity, waste, site clean-up after extraction). Every year, EDF carries out mine audits through internal means (2 audits per year). The reports present the main strengths, recommendations and suggestions. The most common ones relate to health and safety (wearing personal protective equipment such as gloves or googles), the display of safety instructions, monitoring accidents, performing radiological controls, monitoring environmental footprint (specifically carbon emissions) and proposals relating to well-being in the workplace. Audit recommendations are included in the continuous improvement plans and action plans. The 2021 audit programme, after being suspended in 2020 due to the global pandemic, resumed in August 2021 in remote mode and in October 2021 with the implementation of an on-site audit.
The EDF group whistleblowing system consists of a single reporting system for all wrongdoing reported under the Sapin II Act and the “Duty-of-Care” Act as well as wrongdoing reported by employees alleging harassment and discrimination.
This Group system benefits all Group entities, except for Enedis and RTE (1), which have their own whistleblowing system.
Whistleblowers may choose to use the Group whistleblowing system or the other channels available to them (manager, human resources, staff representatives, local ethics and compliance officers, mediators etc.).
The Group whistleblowing system, managed from an independent platform, may be accessed at any time via the EDF group website (https://www.bkms-system.com/ bkwebanon/report/clientInfo?cin=5edf6&c=-1&language=fre), in French, English, Italian, Portuguese, Dutch and Mandarin, in France or abroad. The whistleblower can report in the language of their choice.
In order to comply with the requirements of the Sapin II and Duty-of-Care Acts, EDF has taken appropriate measures to guarantee the strict confidentiality of the personal data of whistleblowers, of those implicated or cited, and of the facts reported, in particular by setting up a whistleblowing system hosted on a dedicated, secure external platform.
The EDF group ethics and compliance whistleblowing system allows Group employees and external staff (temporary workers, service provider employees, etc.) or occasional employees (fixed-term contracts, apprentices, trainees, etc.), as well as third parties, to report wrongdoing of which the EDF group or its staff are the culprits or victims.
See section 3.3.2.4 for details on how the whistleblowing system works.
In 2021, within the Group (via the Group system or any other channel), 247 admissible alerts were recorded (including 39 in the Group alert system). 157 were about incidents occurring in France and 90. 95 related to EDF and 152 to Group subsidiaries. 47% of cases reported relates to harassment/discrimination. In 2021, 71% of the alerts handled were sufficiently detailed to result in corrective action or disciplinary sanctions (in particular, 14 dismissals following proven acts of harassment-discrimination). In 33% of the cases where the facts were not proven, action to improve the relevant processes was still taken.
The Group’s vigilance mission is committed to developing the Vigilance Plan’s monitoring system as part of a continuous improvement process. This system is based on the operational action plan, which is monitored by the Steering Committee. This action plan is regularly presented to the CDRS (see section 3.9.2 “Governance, steering and stakeholder involvement”).
The assessment of the system is included in the annual internal control plan, and a dedicated risk sheet on due diligence has been drawn up and implemented. Annual reports from all Group entities are analysed to identify areas of concern within the Group. Following the analysis in 2021, an essential requirement for progress was decided by COMEX to improve the deployment of the duty of vigilance in the Group, which led to the creation of the dedicated e-learning module (see section 3.9.5 “Major improvements of the EDF group’s Vigilance Plan in 2021”).
The Indicators, which enable the effectiveness of the Group’s prevention and mitigation measures to be assessed, are summarised and available on the Group’s website: https://www.edf.fr/groupe-edf/agir-en-entreprise-responsable/rapports- et-indicateurs/indicateurs-extra-financiers#indicateurs-es.
(1) Distribution network operator Enedis and transmission operator RTE are managed independently.
