Universal Registration Document 2022

3.9 Vigilance Plan

3.9.1 The EDF group’s CSR commitment and its duty of vigilance framework

EDF has a long track record of running a responsible business, based on the values of respect, solidarity and responsibility, promoting sustainable solutions for individuals and the environment.

EDF’s raison d’être has been modified to read “To build a net zero energy future with electricity and innovative solutions and services, to help save the planet and drive well-being and economic development” and this statement was added to its articles of association at the General Shareholders’ Meeting held on 7 May 2020. The Group’s raison d’être is broken down into 16 CSR commitments ⁽¹⁾, which are ranked and grouped into four key issues: carbon and climate neutrality, preserving the planet’s resources, well-being and solidarity, and responsible development of the EDF group’s activities.

Legal Framework

French Act No. 2017-399 of 27 March 2017 on the Duty of Vigilance of parent companies and ordering companies introduced the obligation, in Article L. 225- 102-4 of the French Commercial Code, to draw up and implement a Vigilance Plan.

This plan must include “reasonable vigilance measures to identify risks and prevent serious violations of human rights and fundamental freedoms, the health and safety of individuals, and the environment” that may result from the activities of the company and its controlled subsidiaries, as well as those of suppliers or subcontractors with whom it has an established business relationship, when these activities are tied to that relationship.

It must also include five measures:

1. risk mapping to identify, analyse and prioritise risks;
2. procedures for regular evaluation of the situation of controlled subsidiaries, subcontractors and suppliers based on risk mapping;
3. appropriate risk mitigation or serious harm prevention actions;
4. a mechanism for reporting and collecting information on the existence or realisation of risks;
5. a system for monitoring the measures implemented and evaluating their effectiveness.

The Group’s Vigilance Plan sets out these five measures as follows:

• 3.9.1 The EDF group’s CSR commitment and its duty of vigilance framework
• 3.9.2 Governance, steering and stakeholder involvement
• 3.9.3 Main characteristics of EDF as regards the “Duty of Vigilance” law
• 3.9.4. Methodology regarding Group risk mapping
• 3.9.5. Major improvements of the EDF group’s vigilance plan in 2022
• 3.9.6. Salient risks and risk prevention and mitigation measures
  • 3.9.6.1 Human Rights and Fundamental Freedoms
  • 3.9.6.2 Environment
  • 3.9.6.3 Health & Safety
  • 3.9.6.4 Suppliers and subcontractors
• 3.9.7. Group whistleblowing system
• 3.9.8. Monitoring procedure

The Group’s framework relating to its commitments and requirements with respect to the environment, human rights, and health and safety

EDF’s Vigilance Plan was determined within the framework of the UN Guiding Principles on Business and Human Rights, OECD Guiding Principles, the fundamental conventions of the International Labour Organisation and UN International Bill of Human Rights.

In this context, the Group has published on its website its Duty of Vigilance standards in a document entitled “Human rights and fundamental freedoms, Health and safety, Environment, and Business ethics: the EDF group’s commitments and requirements”. This set of standards brings together the commitments and requirements of the EDF group (EDF and the companies it controls, see section 3.9.3 “Main characteristics of EDF as regards the Duty of Vigilance law”) and the fundamental requirements with regard to its business relationships in terms of respect for human rights and fundamental freedoms, environmental protection, guaranteeing the health and safety of individuals, and business ethics (see section 3.9.5 “Major improvements of the EDF group’s Vigilance Plan in 2022 – Creation, promotion and publication of a set of Duty of Vigilance standards”).

This set of standards refers to all the Group’s public documents and internal policies, including:

• mandatory Group procedures binding on all controlled entities ⁽²⁾: risk management and internal control, governance of subsidiaries and holdings, project management, ethics and compliance, CSR, health and safety, procurement;
• internal documents made public: Ethics Charter, code of conduct Ethics and Compliance, Sustainable Development Charter for Suppliers, Global Framework Agreement on Corporate Social Responsibility;
• external sources: UN Global Compact, UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises, WBCSD CEO Guide to Human Rights, Conventions of the International Labour Organisation (ILO) guaranteeing fundamental principles and rights at work and combatting for the elimination of discrimination, Declaration on the Rights of the Child, Declaration on the Elimination of All Forms of Discrimination against Women, Global Reporting Initiative (GRI), Supplier Relations and Responsible Procurement Label (RF&AR).