Universal Registration Document 2022

• Eligible energy efficiency and performance, research and development services: they were considered as aligned with the Taxonomy.

3.8.4.3.2.2 DNSH criteria analysis

When analysing the DNSH criteria, EDF relies on its Environmental Management System (EMS), its Corporate Social Responsibility (CSR) policy, as well as its Ethics Charter that commits its entities to a precautionary approach, to acting responsibly and to developing technologies which respect the environment. Management of identified risks, including those associated with climate change, is fully integrated into the Group’s global risk management process and internal control system. The most significant risks are covered in risk control plans in conjunction with the CSR.

Pursuant to the policy, the EDF group undertakes to evaluate the impacts of climate change on future and existing activities; adapt existing installations to make them less sensitive to climatic conditions and more resilient to extreme weather events; incorporate climate change scenarios in the design of new installations, adapt the Group’s solutions, internal operations, and expertise to encompass climate change and take into account the eco-systemic dimension of climate change.

All EDF group entities are required to take account of climate risks in mapping their risks, including both physical risks and so called transition risks.

The Group’s EMS covers the environmental objectives of the Taxonomy as described in the paragraphs below.

As a manager of reservoirs and major user of water resources, the EDF group is committed to integrated and responsible water management, both in terms of quantity and quality. The Group also ensures that water is shared within the regions in which it operates by fully taking into account the local water situation (multi-use under climate constraints).

With regard to waste management and the circular economy, optimising the use of the natural resources consumed by the Group’ s value chain is an essential component of the Group’s corporate responsibility (see section 3.2.4). The Group’s action therefore focuses on three priorities: eco-social-design, the functional economy and industrial ecology.

The Group also takes full responsibility for radioactive waste and, in France, uses procedures to decommission closed nuclear power plants that are completely safe and protect the environment. It optimises and manages the operating and decommissioning radioactive waste for which it is responsible and develops treatment processes to reduce the volume of stored waste.

With regard to the prevention and control of pollution, when it is technically feasible, in order to reduce the pollution risks, the Group’s entities have also implemented a programme to eliminate or substitute certain chemical substances with more environmentally-friendly products. This work focuses as a priority on CMR (carcinogenic, mutagenic, or reprotoxic) substances or those considered subject for concern. The application of BAT (best available techniques) in facilities’ pollution management processes ensures optimised management of the waste produced.

Nuclear safety is the Group’s top priority and a major, ongoing concern for the Group throughout the entire cycle, from procurement of fuel to decommissioning and waste management. It is based on technical and organisational specifications aimed at preventing a nuclear accident, and in the hypothetical case of such an accident, at limiting the consequences thereof.

Protection and restoration of biodiversity and ecosystem is also a major challenge for the EDF group. The action taken by the Group is structured around the following priorities: reducing the contribution of its operations to major biodiversity pressures, recreating spaces and conditions promoting biodiversity, improving and sharing knowledge, strengthening governance and raising awareness of biodiversity-related issues.

Furthemore, the Group made commitment towards biodiversity through two voluntary schemes: Entreprises engagées pour la nature and Act4nature international.

The DNSH criteria were analysed for each activity.

3.8.4.3.2.3 Compliance with minimum social guarantees

The Group’s compliance with the minimum guarantees criterion relies on robust processes regarding protection of human rights (see section  3.3.2.3 “Human rights”), combatting corruption (see section 3.3.2.2 “Anti-corruption and other compliance programmes”), taxation (see section 3.4.2.2.1 “Group tax policy”), and combating anti-competitive practices (see section  3.3.2.2.5 “Preventing breaches of competition law”).

These commitments are also published in its “Human rights and fundamental freedoms, Health and safety, Environment, and Business ethics: the EDF group’s commitments and requirements” ⁽¹⁾ standards. It is based on principles of action that apply to all of the Group’s activities, and which aim, as part of an approach to progress, to carry out in particular:

• initial and ongoing screening and management of environmental and societal impacts and risks, including those caused by operations as part of its business relationships;
•  organisation, throughout the world, of transparent dialogue and consultations for each new project. EDF strives to implement its commitments in the early stages of its investment processes, including in its business relationships by requiring its suppliers and subcontractors to comply with CSR requirements for operations related to their joint business relationships, with a specific focus on the rights of local and indigenous communities and vulnerable groups;
• 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). These reports are evaluated and, if necessary, remedial measures are taken;
• in the event that a group entity is warned, sanctioned or convicted by authorities in the field of human rights, taxation, combating corruption or anti- competitive practices, the Group reviews the relevant processes and puts in place remedial actions to ensure continued compliance with the minimum guarantees.

This public document applies to EDF and the companies it controls ⁽²⁾. As far as Enedis is concerned, the subsidiary has drawn up its own vigilance plan to meet the requirements of French Act 2017-399 of 27 March 2017.

3.8.4.3.2.4 Analysis of nuclear activity

Following the publication in the Official Journal of the EU on 15 July 2022 of the Complementary Delegated Act relating to nuclear activities, the Group analysed technical and environmental alignment criteria specific to its nuclear activities in France, both for the existing nuclear fleet and for projects to construct and operate new facilities (Flamanville 3 power plant; studies ongoing for the EPR 2 and SMR).

As a reminder, in terms of eligibility, the Group had already concluded that these activities were eligible based on the draft Complementary Delegated Act adopted by the European Commission on 2 February 2022 and published proforma Taxonomy indicators on this basis in its non-financial performance statement on 31 December 2021.

In summary, evidence of meeting the technical criteria is particularly based on:

• the transposition into French law of the Euratom directives and compliance with the Euratom treaty and European Union legislation on environmental law (criteria 1.a and 1.b);
• the legal and regulatory framework set up in France to secure the financing of long-term expenses relating to decommissioning of basic nuclear facilities as well as long-term storage of radioactive waste, via the obligation for operators of nuclear facilities to create funds (dedicated assets); the entire system is overseen by the administrative authorities (criteria 1.c, 1.d and 4);
• the existence of operational permanent storage facilities in France for all very low-level and short-lived low- and intermediate-level radioactive waste from nuclear facilities in operation or being decommissioned, as well as the French national radioactive substance and waste management plan (PNGMDR - Plan national de gestion des matières et déchets radioactifs) governing the commissioning in France of high-level radioactive waste storage facilities⁽³⁾ (criteria 1.e, 1.f and 7 for activity 4.27, criteria 1.e, 1.f and 7 for activity 4.28);