Universal Registration Document 2022

Introduction

Safety of nuclear and hydropower facilities

The operational safety of nuclear facilities is taken into consideration from the initial design stage, and is regularly monitored, together with the implementation of an employee motivation policy and large-scale investment programmes. The Group’s nuclear safety policy is incorporated into training for both EDF employees and subcontractors. Nuclear safety is subject to internal controls (annual reviews, internal control plans and nuclear inspection audits in France) and external controls (peer reviews between corporate members of WANO and OSART audits conducted by experts from the International Atomic Energy Agency (IAEA)). In France, the safety of nuclear facilities is controlled by the ASN (French Nuclear Safety Authority). In the UK, the Office for nuclear regulation (ONR) is the independent safety regulator in the civil nuclear sector. It monitors compliance with safety rules, including for the transport of radioactive materials. The “EDF group Nuclear Safety” policy was redefined in 2021.

Stress corrosion: see in 1.4.1.1.2.1 “Handling of stress corrosion detected on the auxiliary circuits of a number of nuclear reactors”.

Hydropower safety aims to limit risks of structural failure, risks relating to the operation of facilities during times of flooding, as well as watercourse flow variations during operation. The hydropower safety policy aims for a high level of safety and continuous improvement (see section 3.3.1.1 “Nuclear safety”).

Air quality

The Group is fulfilling its commitments by closing coal-fired power plants (see section 3.1.1.3.1 “Coal-fired power generation, currently representing 0.4% of the total power generation, to be reduced to 0 by 2030”). In parallel, the EDF group is continuing its process of modernising and improving the environmental performance of its thermal fleet, until it meets European best available techniques requirements. Regarding island systems, actions are taken to reduce NOx emissions, on a case-by-case basis: optimising exhaust gas processing, or reducing the number of hours of operation for certain turbines. In Brazil, the emission levels of the Combined Gas Cycle power plant in Norte Fluminense are below NOx limit of 25ppm, mainly due to the high level of equipment maintenance. In Italy, the Marghera Levante power plant replaced less efficient facilities, and authorising not only increases in specific greenhouse gas emissions (up to 40%), but also a significant reduction in nitrogen oxide emissions (more than 50%) into the atmosphere (see section 3.3.1.6 “Air quality”).

Noise and light pollution

With regard to noise pollution in particular, acoustic studies are carried out at the design stage and are included in the environmental impact studies. Acoustic measurement campaigns are run in the area surrounding nuclear power plants.

EDF Renewables performs acoustic studies from the initial development phase of the wind turbines and the noise levels of turbines form part of the selection criteria for machinery. The same level of attention is given to noise pollution in the Group’s international and French subsidiaries (see section 3.3.1.4 “Consumer health and safety”).

With regard to the action taken to prevent light pollution, Citelum has implemented a system of sensors to adjust the intensity of lighting on the road network based on traffic density and driving speeds, which also improves car safety.

3.9.6.4 Suppliers and subcontractors
3.9.6.4.1 Identifying salient risks

The salient risks relating to the duty of vigilance concerning suppliers and subcontractors are identified on the basis of a risk map covering all of EDF’s purchasing categories within the scope of purchases covered by the Group

Purchasing Department. The method takes into account all aspects of CSR (environment, working relations and conditions, human rights, ethics and compliance). Its ultimate aim is to determine the degree of residual risk and identify actions for the supplier (see section 3.4.2.3 “Contribution to development through purchasing”).

This risk analysis covers approximately 11,000 suppliers who have a contract with EDF. More than 97% of its purchases are made in France and 99.4% in Europe (1).

Risks are assessed per purchasing categories. The evaluation and prioritisation of risks is based on the activities of suppliers, and their geographical location is also a major factor in the assessment of risk.

Major risks have been identified in the various sectors of purchasing, mainly concerning safety, ethics, waste, the use of rare materials and human rights. 15% of the purchasing segments analysed are classified as having a major residual risk; 50% are classified as having a material residual risk and 35% are classified as having a low residual risk.

The largest procurement categories in financial terms for which major residual risks are deemed to remain include the following:

  • IT and electronic services and materials regarding human rights risks in relation to the supply chain;
  • work and maintenance services in an industrial environment regarding the increased safety risk;
  • decommissioning/depollution services regarding environmental risk (waste production).

Some smaller categories are also included, such as airline ticketing.

Supply chain-related human rights risks featured in the risk map in areas including: textile purchasing, computer hardware, and command control. This also applies to solar panels (forced labour risks).

3.9.6.4.2 Main prevention, mitigation and monitoring measures implemented

The Group’s new supplier policy, adopted in 2021, defines the shared principles that the senior managers of the various entities are responsible for implementing with regard to purchasing and contract management. It emphasises the Group’s CSR requirements and sets out the Group’s raison d’être and its commitments in terms of responsible purchasing, the use of companies employing disabled workers only, local presence, and supplier awareness.

Group commitments and obligations in respect of responsible procurement apply to every stage of the procurement process, including during prior supplier qualification, as well as during preparation of calls for tenders.

Even when these mechanisms are not directly applied, the Group major department or subsidiaries use equivalent methods of commitment adapted to their specific industrial or geographic characteristics; they are detailed in section 3.4.2.3.2.5 “Other practical procedures within the EDF group”.

EDF’s Group Purchasing Department takes CSR into account in its relations with its suppliers according to the principles of supplier commitments through:

  1. validation of a compliance commitment for all bidders (mandatory to respond to the call for tenders) coverings the following areas: corruption, money- laundering, the funding of terrorism, and the absence of any conflict of interest. Bidders also undertake to comply with the requirements of the Duty of Vigilance Act: To respect human rights and fundamental freedoms, to guarantee the health and safety of people at work, to protect the environment, and to comply with the social and environmental regulations applicable to its activities;
  2. incorporation of CSR criteria in tenders, including specific criteria in the specifications on the basis of the risks identified for each type of contract and/ or to address Group CSR aspirations such as the use of sheltered workshops, local engagement, and the inclusion of SMEs in the supplier panel;
  3. development of Productivity Partnerships;
  4. integration of a CSR clause covering environmental, human rights and health and safety commitments in the General Purchasing Conditions;
  5. systematic inclusion of a CSR Charter between EDF and its suppliers as a contract document, updated on December 2022 to add the Group’s raison d’être and CSR commitments made by the Group, as well as to take better account of the duty of vigilance;
  6. ensuring these principles are upheld by suppliers (see section  3.4.2.3.3 “Supplier monitoring”).

(1) European Union, Switzerland and the United Kingdom notably.