Universal Registration Document 2022

EDF presents its positions publicly via this transparency register ⁽¹⁾ and associations of which it is a member ⁽²⁾. Its main messages are also posted on social media (LinkedIn, Twitter). The European Affairs Department has introduced a regular internal control process for these associations to ensure that they match its mission statement, following which decisions may be taken (withdrawal or new membership) where necessary.

The estimated annual cost of the activities covered by the European Transparency Register since 2016 is around €2 million, with a downward trend. In 2022, the main actions were connected with: an ambitious revision of the EU ETS Directive and the implementation of the carbon adjustment at national boundaries; the development of low-carbon electricity generation sources, particularly for accelerating the permitting procedures for renewable energies; accelerating electrification of the economy, particularly in transport with the AFIR Directive promoting low-carbon hydrogen; and discussions around the forthcoming reform of the electricity market architecture.

Regulation for the financing of political parties

The EDF group complies with the laws and regulations in force concerning the financing of political parties. In accordance with the legislation in force in France, EDF makes no payments to political parties. The Group’s Italian and UK subsidiaries have written directly into their codes of conduct the prohibition of financing political parties. In countries where it is allowed (such as the United States), EDF group companies may determine whether they wish to provide financial support. In such case, the financing shall comply with the principle of neutrality. Every year, the Group companies concerned must report any financing to their parent company.

In 2022, EDF Renewables made payments in the United States, consisting of US$44,190 in the form of Political Action Committee contributions and US$348,000 in the form of Corporate Contributions.

Training schemes

The Group Ethics and Compliance Department develops prevention measures and training for all employees of EDF and its subsidiaries, including:

• a dedicated community on the Group Intranet providing a range of training materials;
• the introduction of e-learning training modules, in particular an interactive training course on the code of conduct, in the form of two e-learning courses (“All employees” and “Exposed employees”), in French and English, enabling participants to deepen and test their knowledge (2,861 participants in 2022);
• targeted in-person training courses: generic training for new entrants to the ethics and compliance networks; for directors of subsidiaries or contract managers; and also to training courses, in French and in English, conducted by lawyers and targeting Group employees tasked with assessing third parties and with processing whistleblowing.

Additionally, the Group Legal Affairs Department and Ethics and Compliance Department are also providing a “Preventing corruption and influence peddling” e- learning module, accessible to all employees on the e-campus platform, that teaches about how best to behave in situations relating to business relations, conflicts of interest, and gifts. It became mandatory for all employees moving to a new position exposed to corruption risks to follow an anti-corruption e-learning module (e-learning module added to the standard training given to managers, project managers, buyers and contract managers, etc.).

3.3.2.2.2 Prevention of harassment and discrimination

Banning all harassment or discrimination, preventing and dealing with any physical or psychological violence as well as intolerance or injustice in the workplace are some of the requirements of the Group Ethics Charter. This commitment is part of the regulatory and judicial context which, in many countries, incriminates not only the actions and behaviours themselves, but also employers who fail to implement sufficient preventive measures. The executives must take all necessary steps to prevent discrimination, harassment and physical and emotional abuse within their entities by informing employees of these risks. They must provide regular information about the Group whistleblowing system and take appropriate disciplinary action in the event of proven wrongdoing.

Reference guides and training

Two reference guides designed to prevent and combat bullying and sexual harassment have been distributed, primarily to managers, the HR Department and the Ethics and Compliance Managers of entities. They have been published in a simplified format for all employees.

Several training modules are available for everyone on e-Campus:

• the first module covers identifying and understanding the links between stereotypes and discrimination, through a serious game called “Vivre ensemble la diversité” (Experiencing Diversity Together);
• the second is about understanding and preventing ordinary sexism in the workplace and is entitled “Sexisme, pas notre genre” (Sexism is not for us);
• the third is a training module on preventing and combating sexual harassment. It is also included in the manager training course, among the manager fundamentals on e-Campus Manager.

See also section 3.3.3.2 “Combating sexism”.

3.3.2.2.3 Financial ethics

The Ethics and Compliance Policy sets out the requirements to be followed to prevent market abuse, the risk of money laundering and the financing of terrorism. An Ethical Code for Trading in Securities, recently updated, complements this Policy. The Group Ethics & Compliance Policy also sets out the requirements concerning compliance with the European EMIR regulation.

Support guide

The implementation of this EMIR regulation by the EDF group, the implications for entities as well as the related processes and controls are described in the EDF group EMIR Policy Paper support guide. An e-learning module is available on the e- campus, attended during the year under review by close upon 200 particularly- concerned employees.

3.3.2.2.4 Integrity and transparency of the wholesale energy market (REMIT regulation)

In accordance with the Group Ethics & Compliance Policy, entities concerned must put in place a compliance programme for the European REMIT regulation (on the integrity and transparency of the wholesale energy market). A Group Compliance Officer is tasked with preventing risks of non-compliance, by developing an appropriate control environment. The practical implementation of this REMIT regulation by the EDF group, the implications for entities as well as the related processes and controls are described in a memorandum of instructions.

Training

An online staff training tool has been set up since 2019. It is freely available on VEOL, the EDF group Intranet. Subsidiaries outside France, in particular EDF UK, Edison, Luminus, and EDF Trading, have also set up training and awareness-raising programmes for their employees. As far as EDF employees are concerned, 1,468 people have been trained by the end of 2022 through this scheme.

3.3.2.2.5 Preventing breaches of competition law

The EDF group has made the prevention of anti-competitive practices (cartels and abuse of dominant positions) a major issue for its employees. With this in mind, the Group has implemented a Competition Law Compliance Programme since 2010. The programme, which is binding on all employees, aims to ensure that all operations of subsidiaries and entities of the Group in France and worldwide comply with competition law. Any suspicion of anti-competitive practices may be reported under the whistleblowing system set up by the Group (see section 3.3.2.4).