Universal Registration Document 2022

Introduction

On-site CSR audits ordered by the Group Procurement Department

These audits cover all CSR aspects: environmental, social and ethical (in particular human rights) policies, commitments and practices. A quality audit was also carried out in 2022. On-site supplier audits are conducted by external, independent providers. CSR audits are conducted based on supplier risk mapping and feedback capitalised by Procurement Category Managers on how contracts are performed, with the help of the business line entities.

  2022
Number of on-site CSR audits ordered by the Group Procurement Department

Number of on-site CSR audits ordered by the Group Procurement Department

2022

37

Proportion of audits conducted outside France (in %)

Proportion of audits conducted outside France

(in %)

2022

54

33.5% of finalised audits had a “satisfactory” result, 58.5% an “acceptable with comments” result and 8% an “insufficient” result: action plans were subsequently set up with suppliers and follow-up audits scheduled as necessary.

“Work clothing” Audit campaign

In 2021, many of the CSR audits related to a call for tenders in the “work clothing” category. Audited production sites that received “Insufficient” or “Unsatisfactory” overall ratings caused the applicant supplier to be excluded from the supply chain. In 2022, declared sub-contractors of the secondary chains of successful bidders selected in 2021 were audited. Only sub-contractors with a “Satisfactory” or “Acceptable” result can be included in secondary supply chain. The results of this campaign show that environmental and societal impacts were better taken into account, particularly compared to the similar initial campaign back in 2014. There was only one “Insufficient” result. Several businesses have demonstrated their determination to minimise their environmental impact: OEKO-TEX certification prioritised or obtained, reduced use of chemicals, energy management, etc.

Audits for other procurement categories

Upstream from an invitation to tender regarding manufacturing of GRP piping, potential tenderers were audited to confirm the compliance of their practices with minimum expected CSR prerequisites. In case of an unsatisfactory or insufficient result, an action plan must be set up: if necessary, an inspection audit is also required before the contract can be awarded.

Across all procurement categories, in 2022 as in previous years, overall results indicated appropriate management of safety and environment-related operational risks, due mainly to certification providing a framework and a robust safety culture. Environmental impact was also found to have also been better taken into account: carbon offsetting, use of the local economy, presence of CSR indicators/goals. However, several audited businesses did not have a code of ethics or anti- corruption policy. The other area for improvement was once more taking account of CSR criteria in successful bidders’ own supply chains, even if some good practices were identified this year. EDF’s requirements on these matters are still to be promoted in the audited companies.

In terms of organisation, 2022 was marked by audit postponements or cancellations due to geopolitical events (Russia-Ukraine crisis, instability in Burma, pandemic in China at the end of the year).

3.4.2.3.4 Responsibility in the fuel supply chain
3.4.2.3.4.1 Coal supply chain

Since its coal contracts were taken over by JERA Trading (JERAT), EDF has no direct contractual relations with mining companies or the market, but remains an active promoter of the Bettercoal responsible coal purchasing initiative that EDF helped to found. Bettercoal brings together energy companies, port institutions and coal terminals to promote CSR in the coal supply chain, mainly at mining sites, to ensure that fundamental rights are respected.

The operational approach is based on a code that sets out ethical, corporate and environmental principles and provisions relevant to mining companies. It takes into account general performance requirements, including management systems, and also performance requirements concerning: ethics and transparency, human and labour rights (such as the prevention of forced and child labour, the right to a decent wage), social issues, including health and safety, and the environment.

JERA Trading, its supplier, is now a member of Bettercoal, thus increasing the initiative’s influence in Asia. In 2022, 24% of the coal supplied by JERAT to the EDF group come from Bettercoal operators, 28% from North American operators and 48% from producers in the rest of the world. This reduction was particularly due to suspension of imports from Russia and use of alternative suppliers from producing countries not signed up to the Bettercoal initiative. However, Bettercoal is currently in discussions with several of these producers to sign them up in 2023.

3.4.2.3.4.2 Uranium supply chain

EDF obtains its uranium supplies over the long term under diversified contracts in terms of origin and suppliers, in most of the main producing countries (Australia, United States, Canada, Kazakhstan, etc.). The clauses authorising the completion of audits and setting out EDF’s expectations in terms of enforcement of the fundamental rights and main international standards by suppliers and sub- contractors have progressively been added to contracts.

Audit reference framework

The uranium mine audit system used by EDF since 2011 ensures that the ore is extracted and processed in good environmental, social and societal conditions. The method and evaluation chart were developed with the World Nuclear Association (WNA) (1). This method is based on international standards, including The World Nuclear Association’s Sustaining Global Best Practices in Uranium Mining and Processing: Principles for Managing Radiation, Health and Safety, and Waste and the Environment, The Global Reporting Initiative’s (GRI) Sustainability Reporting Guidelines & Mining and Metals Sector Supplement, and The International Council on Mining and Metals’ (ICMM) Sustainable Development Framework. Safety is an especially critical issue in mining (process safety), and as such is standardised and recognised by all players in the industry. It takes into account the issues of human rights and fundamental freedoms (human rights, whistleblowing register, rights of indigenous peoples and radiation protection), health and safety of people and the environment, in the broadest sense of that term (greenhouse gases, water, diversity, Biodiversity waste, site clean-up after extraction).

Audits

Every year, EDF carries out mine audits through internal means (two audits per year). The reports present the main strengths, recommendations and suggestions. The most ordinary ones relate to health and safety (wearing personal protective equipment such as gloves or googles), the display of safety instructions, monitoring accidents, performing radiological controls, monitoring environmental footprint (specifically carbon emissions) and proposals relating to well-being in the workplace. Audit recommendations are included in the continuous improvement plans and action plans. There were two uranium mine audits in 2022.

“ON DECK” approach

In 2022, with the aim of boosting its CSR commitments, the Nuclear Fuel Department (NFD) focused on decarbonisation via the so called ON DECK approach (“Décarboner ensemble le cycle du combustible”, i.e., decarbonising the fuel cycle together). The aim of this approach is to highlight and showcase to stakeholders the challenges and ways for its activities to achieve carbon neutrality, and encourage the different links in its value chain to change the direction of their own carbon trajectory.

(1) for Evaluating Supplier Performance at Uranium Mining and other Processing Sites in the Nuclear Fuel Supply Chain.