With respect to the supply chain, the potential slavery and human trafficking risks are assessed to identify procurement areas of focus. Suppliers are required to comply with a set of standards, including the obligation to conduct a self- assessment of their risks aligned with the ten principles of the United Nations Global Compact. EDF in the UK is encouraging its supply chain to adopt a social and environmental improvement approach. Modern slavery obligations are included in the upstream contracting process and suppliers are evaluated at all stages of the procurement cycle, from qualification to contract execution.
In terms of purchasing, the Group Purchasing Department’s CSR risk mapping has included an analysis of “human rights” risks for each purchasing segment since 2019, to determine the level of residual risk and identify the action to be taken with suppliers (see section 3.4.2.3.2 “Sustainable and balanced relationships”). For fuels, see section 3.4.2.3.4 “Responsibility in the fuel supply chain”.
The “humn rights in business” e-learning module developed with the voluntary association Entreprises pour les droits de l’homme (i.e. businesses for human rights – EDH), of which EDF is a founding member, was updated in 2021 to include the duty of vigilance, and is available to all employees.
Performance indicators are monitored at the Group level, based on Cap 2030, via the Health & Safety Policy (see section 3.3.1.3 “Health and safety of employees and subcontractors”), Let’s Talk Energy programme, employee commitment surveys and supplier relations (evaluations, supplier focus survey).
The EDF group whistleblowing procedure is undergoing review in order to incorporate both the Waserman Act of 21 March 2022, transposing into French law the European Directive on whistleblower protection, and its implementing decree of 4 October 2022. After validation by the competent bodies, the revised whistleblowing procedure will enter into force during the first half of 2023.
In order to make report-handling more secure and to strengthen the confidentiality and security of personal data, in 2018 the Executive Committee decided to set up a single whistleblowing system for all wrongdoing reported under the Sapin II Act and the Duty-of-Vigilance Act as well as wrongdoing reported by employees alleging harassment and discrimination. This Group system benefits all Group entities, except for the subsidiaries in the regulated sector, Enedis and RTE, which have their own whistleblowing system to uphold their managerial independence. 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 referee body for the EDF group procedure for collecting and processing reports of wrongdoing, appointed by the Executive Committee, is the Group Ethics and Compliance Department (DECG) (1).
The Group whistleblowing system, managed from an independent server that is not connected to EDF’s IS, can be accessed at any time via the EDF group website. The interface is available in several languages (French, English, Italian, Spanish, German, Portuguese, Dutch and Mandarin) in France and abroad, and the whistleblower can report wrongdoing in the language of their choosing.
The EDF group whistleblowing procedure enables staff and external personnel (2) to report evidence of:
Once the report has been submitted, whistleblowers receive confirmation within seven days from the delivery of such report. Whistleblowers can submit reports anonymously in countries where this is authorised. Wrongdoing can be reported anonymously, as long as the severity of the reported facts is established and the factual elements are provided in precise and sufficient detail, so as to provide evidence for the reality of the reported facts.
Each whistleblowing report is examined for admissibility by the DECG whistleblowing committee in order to determine, before investigating the actions reported, whether it meets the criteria defined in 3.3.2.4.3, and whether the appropriate protective measures can be identified.
During the phase of ascertaining admissibility, the recipient of the whistleblowing report may exchange with the whistleblower and refer to the experts (DECG, Legal- Affairs Department, REC, RDV) in order to obtain any supplementary information required for finalising the admissibility analysis.
Upon confirmation of the whistleblowing report’s admissibility, the investigating officer appointed (3) signs a specific confidentiality undertaking and has a maximum of three months within which to communicate to the whistleblower the information on the measures envisaged or taken in order to remedy the wrongdoing reported, and on the reasons for those measures.
The processing of whistleblowing reports (verification of the facts, interviews with the persons concerned, searching for evidence, etc.) is conducted with the support of line experts (DECG, HRD, DSIE, Legal-Affairs Department, Audit Department, etc.) or, where necessary, with the support of an external consultant. These experts are bound by the same strict confidentiality obligations (was prior signature of a confidentiality undertaking).
Upon completion of the investigation into the matter, if the facts reported are found to be true, an action plan is implemented. The whistleblowing report will be closed only upon complete fulfilment of that action plan.
(1) Decree of 4 October: The referee is tasked with gathering the wrongdoing report and with processing it in compliance with the procedure. This referee is appointed by the Company.
(2) Occasional staff (interns, work-study students, etc.) and also service providers or partners.
(3) The investigating officer is appointed from within the network of Group ethics and compliance officers (Departments and subsidiaries), managed by the DECG. In the event of difficulty (e.g. conflict of interest), the investigation may be conducted by the DECG itself or by the Ethics & Compliance Manager (REC) of another entity.
