After having deployed from 2010 to 2015 an e-learning module which trained more than 5,400 employees, then between 2016 and 2021 a more general Serious Game entitled “Cap Antitrust” taken by about 2,300 employees, a new module on competition law awareness has been accessible since October 2021 to all employees on the internal training portal of the Group in two languages (French, English). This e-learning module was attended by 789 participants in 2022 and is integrated into the training programmes for the directors of the Group’s subsidiaries, who also receive additional awareness training in the form of an in- person module. The Group regularly organises simulated investigations by competition authorities in order to raise awareness of the importance of complying with competition law.
EDF, which appointed a Personal Data Officer (PDO) in France as early as 2006, appointed its Data Protection Officer (DPO) in 2018, pursuant to EU regulation 2016/679 of 27 April 2016 known as the General Data Protection Regulation (GDPR). The DPO is the Lead Manager for the Group.
Around twenty DPOs have been appointed in the French and European subsidiaries and Personal Data Contacts (interlocuteurs informatique et libertés (I2L)) are present in all EDF entities. The DPOs are ensuring compliance with regulations relative to the protection of personal data within the Group, whether with regard to the personal data of its customers, employees, service providers or partners.
In the course of its operations, particularly in the nuclear field, EDF and its subsidiaries carry out a range of operations to meet their own needs or the needs of third parties, requiring the use of goods and technologies including dual-use goods and technologies (“DUG”), i.e. civil and military, that can expose it to certain risks inherent in specific French, European and/or foreign regulations, some of which have extraterritorial scope, and can require the issuing by the competent authorities of a license/authorisation prior to any transfer, export, re-export, brokerage, and/or transit of such goods and technologies. Some regulations, particularly in the United States, have introduced restrictions on access to goods and technologies applicable to foreign entities that may affect both DUGs and any other commercial goods.
The Group, or some of its partners, may be exposed, directly or indirectly, to sanctions programmes, in particular (i) international sanctions adopted by the United Nations Security Council, (ii) sanctions adopted by regional organisations such as the European Union, and (iii) sanctions adopted unilaterally by certain States, some of which have extraterritorial scope.
A Group Export Control and International Sanctions Department was set up in August 2019 to strengthen the Group’s ability to comply with these regulations. A memorandum of instructions describing the compliance procedures to be implemented was adopted by the Executive Committee on 4 May 2020. In April 2022, the Export Control and International Sanctions Department implemented to e-learning modules, “export control” and “international sanctions” in French and English, accessible for all Group employees on the e- campus platform. Almost 600 people attended these e-learning modules, in addition to the 300 people trained in-person or via Teams, as part of more closely- targeted deployments (in 2022, this applied to staff concerned in the DTEAM, the Audit Department, the Development Department, the DP2D, the Procurement Department, or for the project teams at Nuward and Sizewell C).
See section 3.9 “Vigilance Plan”.
In 2020, EDF drew up a set of guidelines(1) listing the commitments of the Group and the fundamental requirements for its business relationships in terms of human rights and fundamental freedoms, environmental protection, protection of personal health and safety and business ethics.
The EDF group does not tolerate any infringement of human rights or fundamental freedoms in its operations or in those of its business relationships for operations related to the relationship.
EDF strives to comply, at least, with the international standards protecting and defending human rights and fundamental freedoms, including the United Nations International Bill of Human Rights and the fundamental conventions of the International Labour Organisation (ILO).
If the laws of a country where it operates conflict with these international standards, EDF endeavours to find a solution to render it compliant with both the spirit of the international standards and national laws.
To ensure that human rights and fundamental freedoms are respected in its operations, EDF has implemented a vigilance approach to identify, assess and prevent any potential infringement of human rights or fundamental freedoms. The vigilance approach has been designed to comply with the French Duty-of-Care Act and is based on the recommendations of the UN Guiding Principles on Business and Human Rights.
The EDF group pays special attention to the impact of its operations on individuals recognised as vulnerable under international human rights law and investigates, in complete transparency, impartiality and good faith, any alleged infringements of human rights or fundamental freedoms connected to the operations of the Group’s entities, providers and subcontractors.
If an infringement of human rights or fundamental freedoms is proven in the operations of the Group’s entities, EDF has agreed to engage in dialogue with the victims and/or their representatives to address the situation, pursuant to the OECD Principles for Multinational Enterprises with which the EDF group complies.
The EDF group is committed to the human rights and fundamental freedoms of its staff and complies, as a minimum, with the provisions of the standards published by the International Labour Organisation (ILO).
In terms of the prevention of discrimination, the EDF group guarantees equal treatment for its employees and is against any form of distinction, exclusion or preference, whether based on presumed race, skin colour, sex, age, religion, political beliefs, national origin, social origin, disability, family status, sexual orientation or gender identity. In the countries where it operates and for its own operations, the EDF group actively promotes equality in the workplace and equal treatment for equal work for the women and men working for the Group and strives to achieve balanced work teams at all levels of the Company. Diversity is encouraged at all staffing levels and employees must be protected from all forms of discrimination or retaliation.
(1) Human Rights Impacts Assessment and Management.
