EDF has strengthened its oversight of the Vigilance Plan with the appointment, in December 2020, of a Group Duty of Vigilance Compliance Officer by two members of the Executive Committee: the Group Corporate Secretary and the Group Executive Director in charge of Innovation, Corporate Responsibility and Strategy. This officer is responsible for the development, deployment and coordination of the vigilance plan and its application within the Group.
The Vigilance Plan and the resulting actions are validated by the CSR Strategy Committee chaired by the Group’s Chairman, and submitted to the Corporate Responsibility Committee, a Committee of the Board of Directors dedicated to social and environmental responsibility issues.
The Vigilance Plan is designed and managed in collaboration with the Legal Department and the Impact Department within a Steering Committee and a Strategic Committee that also includes the Human Resources Department, the Purchasing Department, the Risk Department, the International Department, the Ethics and Compliance Department, the Export Control and International Sanctions Department, and, when applicable, representatives of subsidiaries with particularly exposed activities. The Strategic Committee defines the orientations and objectives of the Vigilance Plan in a collegial manner, based on proposals from the Steering Committee. It ensures that these objectives are achieved and may redefine them according to the operational progress reported by the Steering Committee that meet on a quarterly basis.
The deployment and coordination of the Vigilance Plan is based on a network of Duty-of-Vigilance Officers appointed in each Group entity concerned (see section 3.9.5 “Main improvements of the EDF group’s Vigilance Plan in 2022”).
Dialogue with stakeholders is a major part of EDF’s culture. It forms the basis of our cooperation with our stakeholders.
The Global Framework Agreement on Corporate Social Responsibility signed by EDF in 2018 and extended for two years on 29 November 2021 with the Group’s trade unions and two international trade union federations (IndustriAll and ISP) states that EDF’s Vigilance Plan will be “developed and set up in association with the Company stakeholders, including workers’ representative organisations” (see section 3.5.3.1.1. “The Global Social Responsibility Agreement”). Since 2018, the Committee for Dialogue on Social Responsibility (CDRS), made up of representatives of all the signatories of the agreement, has been working on numerous topics related to the Duty of Vigilance (health and safety, exercise of the Group’s responsibility in the context of international projects, impacts of the pandemic, etc.) and on the actions to be implemented to roll out and improve the Group’s Vigilance Plan. Thus, in 2022, CDRS members learned from its meetings about the progress of the 2021 Vigilance Plan, and also shared about the vigilance actions in 2022. In terms of legal framework, the proposed European directive on the corporate duty of vigilance in terms of sustainability was also presented to members, along with changes to the EDF group’s whistleblowing system relating to the transposition into French law of the European directive on the legal protection of whistleblowers. These CDRS meetings also feature discussions designed to answer members’ questions or examine key local issues of which members are aware.
Externally, EDF participated in discussions with other companies, lawyers, NGOs, and trade union federations within the framework of the “Entreprises pour les droits de l’homme” (Businesses for Human Rights) (EDH (1)) non-profit organisation, in order to openly exchange on the expectations of all stakeholders, practices and improve Vigilance Plan preparation processes.
In November 2021, EDF also took part in a peer review on the Vigilance plan, organised by Global Compact (2), bringing together other groups subject to the law, and personalities from the world of non-profits and research.
In 2022 a specialist in businesses and human rights was appointed to the Group Stakeholder Council (see section 3.4.1.1.1.1 “EDF: a pioneer in the implementation of stakeholder panels”) to boost the Council’s expertise in this field. In June 2022, EDF submitted its Vigilance Plan and its Group-wide implementation to the Stakeholder Council.
At the same time, the Group is steadfastly pursuing discussions opened with a range of members of civil society (non-profits, leading figures) keen to maintain this dialogue, with the aim of continuously improving its Vigilance Plan.
The EDF group is an integrated energy company engaged in activities involving risks in three fields where the Duty of Vigilance applies. EDF is active in all areas of the electricity industry and some areas of the gas industry: power generation using nuclear, renewable and thermal energies; electricity transmission and distribution (3); sales; energy services; energy trading (see section 1.4 “Description of the Group’s activities”).
The Group’s activities are mainly located in OECD countries (see section 1.4.5 “International activities”). Countries considered to be “higher-risk countries” receive special care, including in terms of relations with partners.
The EDF group is a major energy provider on four key European markets: France, the UK, Italy and Belgium. The Group is seeking to move into new geographical areas, developing low-carbon solutions in growing countries and strengthening its positions in Europe.
The Group most often develops its overseas projects as minority shareholder, mainly in the following countries: Brazil, Chile, the Middle East (Saudi Arabia and the United Arab Emirates), Western and Central Africa (Cameroon, Côte d’Ivoire, Togo), India, the United States, Germany and Spain.
Group-wide, EDF Renewables develops projects on its own or with partners, operates and maintains renewable power generation facilities (mainly wind and solar) in more than 20 countries. The main zones in which it has historically operated are North America (United States, Canada and Mexico) and Europe, starting with France and the United Kingdom. EDF Renewables has also rebalanced its business in geographical terms, increasing its presence in other countries with high potential for the development of renewable energy, including South Africa, Brazil, China, India, UAE, Saudi Arabia, Morocco, and Egypt.
(1) e-dh.org
(2) Pacte mondial réseau France (https://pactemondial.org/).
(3) In accordance with the principle of independent management of regulated infrastructure operators.
