Universal Registration Document 2022

3.4.2.3.2.9 Company mediator and whistleblowing

• The EDF group has used a company mediator since 2010. Suppliers may refer a matter to the mediator directly, free of charge, through its website or by post ⁽¹⁾, as stated in the General Terms and Conditions of Purchase and on the Group’s purchasing platform.
• As is the case for all stakeholders, suppliers can use the Group’s whistleblowing system, set up in accordance with the Sapin 2 and Duty of Vigilance Acts, which guarantees anonymity and is available in the Group’s six languages ⁽²⁾.

3.4.2.3.3 Supplier monitoring ⁽³⁾

3.4.2.3.3.1 Identifying the CSR risks

The assessments designed to ensure suppliers comply with CSR commitments are prioritised based on risk mapping limited to the purchases driven by the Group Procurement Department. This monitoring takes the form of documentary or on-site audits.

Enhancing the supplier risk map

En 2020, the Group Purchasing Department enhanced the performance of its risk analysis, implemented in particular in accordance with the “Duty of Care” Act. This method takes into account all aspects of CSR (environment, working relations and conditions, human rights, ethics and compliance). Its ultimate aim is to determine the degree of residual risk and identify actions for the supplier. The risk analysis encompasses all procurement categories, covering some 11,000 suppliers.

3.4.2.3.3.2 CSR risk level

Inherent risks and residual risks ⁽⁴⁾ are assessed per purchasing categories on a scale of 1 to 4: low, material, major or critical risk. Risk assessment is based on the business of the supplier; their geographical location is also a significant risk assessment component.

Any residual risk in the assessed segments can be secured using countermeasures implemented prior to contracting, the contractual clauses and contract monitoring.

Major residual risks have been identified in the various sectors of purchasing, mainly concerning safety, ethics, waste, the use of rare materials and human rights. 15% of the purchasing segments analysed are classified as having a major residual risk, 50% are classified as having a material residual risk and 35% are classified as having a low residual risk.

The largest procurement categories in financial terms for which major residual risks are deemed to remain include the following:

• IT and electronic services and hardware (supply chain human rights risk);
• industrial environment works and maintenance services (heightened safety risk);
• decommissioning/de-pollution services (environmental risk: waste production).

More than 97% of purchases are made in France, 98.4% in Europe, and 99.4% if European countries outside the European Union are included (particularly Switzerland and the UK). The human rights risks related to the supply chain have been specified in the risk mapping, in the areas of textile purchasing, IT equipment, instrumentation & control and solar panels concerning the risks of forced labour.

3.4.2.3.3.3 Internal service assessments

The monitoring of suppliers, which includes a CSR component, begins with an internal evaluation of the services they provide. Supplier monitoring is mainly carried out by the Division or Contract Management, which uses Performance Assessment Sheets.

Documentary audits (CSR)

These audits are completed and documented by the supplier and then systematically verified by an independent body, French standards agency AFNOR. Questionnaires cover the entire scope of CSR; some are custom-designed to take issues specific to a given category into account. The decision to evaluate a supplier is based in particular on the supplier risk map, business line and purchaser requirements, and contracts in progress.

In 2022, the Group Purchasing Department continued the CSR documentary audit campaign focusing on Human Rights. A questionnaire was sent out to suppliers with a contract belonging to procurement categories listed in international reports on failures to observe human rights and/or specifically named therein in the fields of textiles, electronics, instrumentation & control, and IT.

Once more based on a risk management approach, suppliers in the major residual CSR risk categories were questioned (moving, document management, warehousing in case of third-party services). Since 2020, there have been audit campaigns focusing on 91% of major residual risk categories. In parallel, suppliers were also questioned on request from Purchasing Category Managers (rope access work, valves and fittings, pressure vessels).

At the end of 2022, 3,200 suppliers were questioned using the Acesia platform, and over 1,200 have been controlled. In 2022, the assessments were “satisfactory” for 34% of the audited questionnaires. The majority of questionnaires analysed in 2022 came from two targeted campaigns:

• Human Rights campaign: this issue can be better taken into account by questioned businesses, particularly VSEs/SMEs;
• Housing campaign: most of the panel of businesses surveyed are small-sized establishments, which still do not have the resources to formally put in place and implement the CSR policies adopted by their parent companies.

In 2022, EDF used the results of the Housing campaign to highlight the most virtuous suppliers in the sector. EDF’s user business trip booking tool now highlights hotels with satisfactory CSR scores.

These audit campaigns make it possible for purchasers and suppliers to share an approach of continuous improvement in Corporate Social and Environmental Responsibility.

Audits have also been conducted by other companies, e.g. Dalkia (2,932 audits in 2022).

In 2021, EDF Renewables sent out a supplier questionnaire on human rights in respect of solar panel procurement.

(1) mediateur.edf.fr | by post (Médiateur du groupe EDF – TSA 50026 – 75804 Paris cedex 08).

(2) edf.fr/edf/dispositif-alerte-groupe

(3) This monitoring is performed from supplier qualification onwards. For example, EDF Renewables assesses its suppliers of strategic wind and solar energy equipment in its qualification processes, comprising selection criteria in all CSR fields.

(4) Residual risks are the risks remaining after countermeasures have been adopted.