Human rights commitments are implemented as part of the Group’s CSR commitments and requirements (1), based on the principles of action that apply to all Group operations, such as:
The initial and ongoing evaluation and the management of environmental and societal (E&S) impacts and risks, including those caused by the activities of its business acquaintances.
The organisation, worldwide, of a procedure of transparent, debated discussions and consultations for each new project relating to a facility drawing on a budget of more than €50 million, and having a significant impact on the territories or the environment.
The implementation and monitoring of these commitments and requirements is ensured under the Group’s existing internal policies or agreements, in particular the sustainable development policy, the ethics and compliance policy, the purchasing policy, the health and safety policy, the global CSR agreement, the Ethics Charter and the roll-out of the vigilance plan.
Systems for collecting and processing reports of wrongdoing, that are accessible and notified to anyone who could be impacted by the Company’s operations, guaranteeing the confidentiality of the reports and protecting internal whistleblowers (employees and external staff), have also been set up.
Depending on the context of the project, a Human Rights Impact Assessment (HRIA (2)) is conducted. It is based on the principles defined by the UN Guiding Principles on Business and Human Rights, as developed for example by the Danish Institute on Human Rights. These studies place the identification of impacted human rights at the centre of the analysis. They include an assessment of the state of human rights in the country as well as in the project area, a mapping of human rights-oriented stakeholders (listing “right-holders” and “duty bearers”), an analysis of the project’s impacts on these rights, and the development of mitigation measures. This type of study identifies the activities at risk according to their importance and sensitivity. These studies are generally entrusted to national or international consultants specialising in the topic, and managed by EDF’s internal Human Rights contacts. The conclusions of these studies are intended to be integrated into all development, construction, operation and end-of-life activities of the project, via an ad hoc management system (internal Human Rights policy, Human Rights contact and correspondents, contractual tools, audits and performance monitoring, reporting, etc.). They concern both the affected communities and workers, the use of security forces, the whistleblowing system and the protection of whistleblowers, etc.
A component focusing on human rights, through the Group’s commitments framework, is systematically integrated into each analysis of a project presented to the Group Executive Committee’s Commitments Committee (CECEG), or to the Validation Committee for the Group’s international development projects (CBDI). This consists of systematically identifying the human rights risks associated with the projects, both for the activities developed and for the supplier relationships envisaged. This identification will be facilitated by the construction of a screening grid, which will allow an analysis of projects that are consistent with the Group’s raison d’être, CSR commitments, and guidelines, as well as with international standards. This grid takes into account environmental, health and safety, human rights, and ethical dimensions of a project. All of the Group’s human rights commitments and requirements are addressed, such as compliance with the ILO’s fundamental conventions (on child labour, forced labour, freedom of association, discrimination), the rights of local communities, and health and safety conditions for the populations in question.
The Gevim project, on which construction work was completed in March 2022, is located near the Gevim Kibbutz, a community-oriented village that is typical of Israel. The kibbutz representatives and the district committee environmental team identified a visual impact of the solar-energy plant for the kibbutz inhabitants, thereby affecting the unique landscape. Accordingly, it was decided that of vegetation buffer zone would be established between the facility and the kibbutz, and the facility would be assimilated as far as possible with its environment. A wide swathe of local vegetation and trees was planted between the plant and the kibbutz.
As part of the onshore wind power project in the Antofagasta region, EDF Renewables Chile drew up an anthropological reference document for the Changos indigenous community, based on interviews conducted with five Changos organisations. This community undertook a process for reconstituting its history. The information gathered will supplement the preliminary impact study conducted by EDF Renewables in connection with the project.
Concerning the BIOVEA Energie biomass power plant project in Côte d’Ivoire, a specific study was carried out on child labour in order to understand its nature and causes in the agro-industrial sector of the region in which the power plant will be located. On the basis of this study, BIOVEA Energie has chosen to act, in particular through a collaborative venture with the cooperative of the Toumangué region, which alone covers the vast majority of small planters in this area. The objective is to develop Champs École Paysans (“Farmer Field Schools” or CEPs), which allow the implementation of good agricultural and management practices based on 6 themes, including a specific one on child labour. A budget of €150,000 is planned for the first two years for the launch and development of the CEPs, followed by €24,000 of support per year for 14 years.
In this connection should be noted the operational implementation in 2022 of the committees for follow-up, shortlisting and for the mechanism to settle complaints of communities (11 complaints were recorded mid-year, with 7 settled, and 4 under investigation).
In accordance with international environmental and social standards, the Nachtigal Hydroelectric Project in Cameroon has had a mechanism in place since April 2015 to manage requests and complaints. Anyone can submit them 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 Conciliation 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 Conciliation Committee.
See also section 3.9.6.1.2 “Main prevention, mitigation and monitoring measures implemented”.
The EDF subsidiaries in the United Kingdom are implementing human-rights commitments in consistency with the Group’s CSR commitments and requirements.
In accordance with the Modern Slavery Act, EDF in the United Kingdom is working to ensure that its activities, as well as those of its supply chain, are subject to an assessment of the risks associated with modern slavery, and that means of prevention and mitigation are put in place. EDF in the UK has a Modern Slavery Statement covering all its employees and procurement. This statement, in accordance with the Modern Slavery Act, is published on the subsidiary’s website. EDF in the UK also contributed to the online “Modern Slavery Statement Registry”.
EDF in the UK employs around 12,000 people, with a supply chain of around 3,500 suppliers. All staff are required to adhere to the EDF guiding principles (Staff code of conduct, and the Ethics & Business Conduct Policy) concerning ethics. EDF in the UK has published support guides to make employees aware of these principles and values and to provide the necessary tools to report any behaviour contrary to EDF’s principles.
(1) unglobalcompact.org/what-is-gc/mission/principles
(2) EIDH – Human Rights Impacts Assessment and Management.
