Universal Registration Document 2022

In order to prevent racial discrimination, the EDF group addressed the issue of its origins, and more specifically racism in the workplace, in a reference document for its managers and Human Resources (RH) Officers.

The EDF group has been committed to respecting religion in the workplace since 2008, and published a first set of guidelines in 2010 (updated in 2016), setting out guidelines for managers and HR officers to help them understand, analyse and act in compliance with the law.

EDF is also partner of L’Autre Cercle ⁽¹⁾, of the Energay association ⁽²⁾ since 2010, and has been a signatory of the LGBT charter since 2015. EDF’s HR staff and managers have been provided since 2015 with guidelines on “Respect for sexual orientations in the workplace”. EDF has also designed, in partnership with Energay, a process to accompany and support transitioning employees within the Group. “Supporting transitioning employees at EDF – Respect for gender identity” guidelines were published.

To implement these policies of inclusion and equal opportunity, EDF has produced educational and training materials for its entire workforce, whilst still providing managers and HR staff with more targeted materials. The Company trains everyone involved in its recruitment process, using training course on how to “recruit without discrimination”. To raise awareness about diversity among employees and promote the emergence of inclusive practices and organisations, the Group set up a range of digital training courses called “Vivre Ensemble La Diversité” (i.e., diversity and togetherness) in the form of serious games played by 1,708 employees in 2022 (i.e., 16,155 employees overall since they were launched).

A toll-free hotline ⁽³⁾ for all employees of the Company, operating seven days a week, to allow employees to confide in someone and obtain advice on all harassment and discrimination issues; a support team (with internal and external skills) intervenes in investigations carried out when alerts are reported.

Preventing risks related to the Group’s international activities and projects concerning violations of the rights of communities and workers and the use of security forces

The EDF group does not tolerate any infringement of human rights or fundamental freedoms in its operations or in those of its business relationships for operations related to the relationship. All the Group’s commitments relating to human rights are described in section 3.3.2.3 “Human rights”.

These commitments are implemented and based on the principles of action that apply to all Group operations such as:

1. initial and ongoing screening and management of environmental and societal impacts and risks, including those caused by operations as part of its business relationships;
2. organising, worldwide, a transparent, all-inclusive dialogue and consultation process focusing on each new facility-related project involving a budget of over €50 million with a significant impact on the local area or environment;
3. implementation and monitoring of these commitments and requirements is ensured under the Group’s internal policies or agreements, in particular the CSR policy, the ethics and compliance policy, the purchasing policy, the health and safety policy, the global CSR agreement, the Ethics Charter and the roll-out of the Vigilance Plan;
4. implementation of 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 ⁽⁴⁾).

Depending on the context of the project, a Human Rights Impact Assessment (HRIA) is conducted. It is based on the principles defined by the UN Guiding Principles on Business and Human Rights, as developed for example by the Danish Institute for Human Rights. These studies place the identification of impacted human rights at the centre of the analysis. They include an assessment of the state of human rights in the country as well as in the project area, a mapping of human rights-oriented stakeholders (listing “rights-holders” and “duty bearers”), an analysis of the project’s impacts on these rights, and the development of mitigation measures. This type of study identifies the activities at risk according to their importance and sensitivity.

These studies are generally entrusted to national or international consultants specialising in the topic, and managed by EDF’s internal CSR referents.

The conclusions of these studies are intended to be integrated into all development, construction, operation and end-of-life activities of the project, via an ad hoc management system (internal CSR policy, CSR contact and correspondents, contractual tools, audits and performance monitoring, reporting, etc.). They concern both affected communities and workers, the use of security forces, the whistleblowing system and the protection of whistleblowers, etc.

With regard to decent working conditions, external inspection and audit missions carried out on the sites of internationally financed projects (such as the Nachtigal project) enable the Group to detect breaches of the Group’s commitments at each stage of the project’s life.

At the level of the investment decision-making process, a strong focus on human rights, through the Group’s commitments framework, is integrated into each analysis files of projects presented to the Group Executive Committee’s Commitments Committee (CECEG), as well as to the Validation Committee for the Group’s international development projects (CBDI). Efforts are also systematically made to identify project-related risks of violation of human rights relating to both developed activities and relationships with suppliers and sub-contractors being considered for projects. This identification will be facilitated by the construction of a screening grid which will allow for an analysis of projects that are consistent with the Group’s raison d’être, commitments and guidelines, as well as with international standards. This grid takes into account all of the Group’s human rights commitments and requirements, such as compliance with the ILO’s fundamental conventions (on child labour, forced labour, freedom of association, discrimination), the rights of local communities, and health and safety conditions for the populations in question.

In operational terms, several projects are presented in section  3.3.2.3.4 “Implementation of human rights commitments” including some managed by EDF Renewables or by the Group’s International Department:

Wind project in Chili

As part of an onshore wind project in the Antofagasta region, EDF Renewables Chile conducted an anthropological survey of the indigenous Chango community, based on interviews with five organisations from the Chango community, which has begun the process of reconstructing its past. The information collected will be added to the preliminary impact study carried out as part of EDF Renewables’ project.

Solar park in Israel

The Gevim project, on which construction was completed in March 2022, is located near the Gevim Kibbutz – a typical Israeli collectivist village. Representatives of the kibbutz and the district committee’s environmental team identified that the photovoltaic facility would have a visual impact on the kibbutz’s inhabitants and that the unique landscape would be affected as a result. So it was decided that a buffer zone of vegetation would be set up between the facility and the kibbutz, and that the facility must be made to blend into its environment as much as possible. A wide strip made up of trees and local plants requiring only limited watering was planted between the facility and the kibbutz.