Universal Registration Document 2022

3.9.6 Salient risks and risk prevention and mitigation measures

3.9 Vigilance Plan

3.9.6 Salient risks and risk prevention and mitigation measures

With regard to training, in 2021, the Group developed an e-learning module dedicated to the duty of vigilance to raise awareness and help deploy the Group’s compliance plan. It provides a definition of the duty of vigilance, its scope of application, the actors involved and the associated obligations, and identifies the risks and remedial actions through concrete examples relating to the Group’s activities. By the end of December 2022, approximatively 1,500 employees had attended e-learning sessions.

These actions in 2022 are part of a year-round improvement process based on a regularly reviewed action plan.

3.9.6 Salient risks and risk prevention and mitigation measures

Global actions to prevent and mitigate risks related to the duty of vigilance

Risk prevention and mitigation measures are implemented by each relevant entity by way of applying cross-functional and sectorial policies and using ordinary Group methodology for risk control as a basis. This methodology provides a description of risk treatment action plans and an evaluation of their efficacy. Industrial projects are subject to a risk analysis within the scope of application of the duty of vigilance, taking into account their nature, size, technical features and location. For this purpose, environmental and social impact assessments are based on the most demanding international standards (mostly IFC, WB, ADB (1)).

In addition, issues relating to the environment, personal health and safety and human rights are systematically addressed as part of the assessment process for projects submitted to the Group Executive Committee’s Commitments Committee (CECEG) and to the Committee that validates the Group’s international development projects, the International Business Development Committee (CBDI), in the form of an identification of the risks associated with projects, to ensure that EDF’s commitments in this area are not overlooked. Concretely, this takes the form of identifying the risks associated with the projects for the activities developed and for the supplier and subcontractors relationships envisaged in the framework of the project. This identification will be facilitated by the providing of a regularly updated grid screening, which will allow for an analysis of projects that are consistent with the Group’s raison d’être, CSR commitments, and guidelines, as well as with international standards. This grid takes into account environmental, health and safety, human rights, and ethical dimensions.

3.9.6.1 Human Rights and Fundamental Freedoms
3.9.6.1.1 Identifying salient risks

In the area of human rights and fundamental freedoms, the Group’s ethics and compliance policy, which includes the duty of vigilance, has led the EDF group to implement an approach that results in the identification of key risks and associated mitigation measures, assessed according to the Group’s activities and the countries where the Company and its subsidiaries operate.

Two categories of salient risks related to human rights and fundamental freedoms were identified:

  • at the cross-functional/global level: risks related to harassment and discrimination;
  • in the Group’s international activities and projects, and in particular in geographical areas where local practices and situations, as well as legislation, are less demanding than the standards of OECD countries:
    • risks of infringing on the rights of local communities: these risks are linked to land issues and population displacements, or to the consequences of inadequate consultation of local communities, particularly indigenous ones,
    • risk of infringement of workers’ rights including risks related to decent working conditions at the Group’s construction sites,
    • risks related to the use of security forces for projects near conflict zones or security regimes.
3.9.6.1.2 Main prevention mitigation and monitoring measures implemented

The implementation of human rights commitments is part of the deployment of the EDF’s group Global Social Responsibility Agreement and of the Group’s reference framework (see section 3.3.2.3 “Human rights”).

Preventing and dealing with any physical or psychological violence, intolerance or injustice in the workplace

Executives must take all necessary steps to prevent discrimination, harassment and physical and emotional abuse within their entities by striving to make employees aware of such risks. They must provide regular information about the Group whistleblowing system and take appropriate disciplinary action in the event of proven wrongdoing (see section 3.3.2.2.2 “Prevention of harassment and discrimination”).

Combating sexism and all forms of discrimination:

The EDF group is committed to developing concrete action to promote equality in the workplace and occupational and social integration for disabled people, combating sexism, violence and all forms of discrimination and developing support for parents. Among the many prevention actions described in section  3.3.3 “Equality, diversity and inclusion”, the following major prevention and mitigation actions are carried out by the Group:

The EDF group’s professional equality policy is based on principles such as equal treatment of women and men throughout their professional lives; condemning any behaviour or practice that discriminates against employees; and EDF’s contribution to changing attitudes. In 2021, the EDF Executive Committee wanted to further the Group’s diversity aims, particularly adding a new Group-wide goal of increasing the number of women at all levels of the Group: 33% in 2026 and 40% in 2030 (see section 3.3.3.1.1 “Reinforcing the Group’s commitment”).

The EDF group and some of its subsidiaries have decided to apply for an international certification (GEEIS certification) to assess the quality and relevance of their commitments to gender diversity and equality in the workplace. The certification was renewed in 2019 and, for the very first time, it was extended to all the Group’s other fields of action in terms of diversity and inclusion. Signing a GEEIS commitment charter, marking the Group’s commitment to fighting stereotypes by deploying inclusive artificial intelligence without gender stereotypes in all business processes and environments.

The EDF group is committed to preventing and combating all forms of violence against women, in the workplace (sexism, harassment) and also domestic and family violence (support, guidance and job retention). The aim is to train and raise the awareness of managers and Human Resources personnel on the subjects of sexism and both moral and sexual harassment. Thus, with the help of the “ENERGIES mixité!” network, a new “sexism barometer” was set up as part of the #StOpE multi-company initiative, of which EDF has been a member since the beginning. Operational implementation of such measures was carried out in partnership with the Company’s medical and social teams and the “FIT, une femme un toit” association in particular. In 2022, EDF took care of, assisted, supported and advised 122 female employees who were victims of domestic violence. Overall, more than 485 employees (465 women and 20 men) were assisted between 2019 and 2022.

The EDF group is committed to societal and professional integration of disabled people, with its 12th EDF agreement for equal rights and equal opportunity and the occupational integration of disabled people, entered into on 11 January 2023 for the 2023-2025 period. The issues we face change over time, such as digital technologies, which were made a special point of focus in the latest EDF disability agreements, resulting in the signing of a first EDF digital accessibility policy in February 2022. EDF Renewables also renewed its agreement in December 2022 for the same period. Framatome has a valid agreement until the end of 2023.

(1) IFC: International Finance Corporation. WB: World Bank. ADB: Asian Development Bank.