Universal Registration Document 2022

Introduction

Climate and health & safety issues better taken into account in the purchasing process

In May 2022, as part of its adaptation of its raison d’être, the Group Purchasing Department decided to take further measures to tackle and focus on climate issues and natural resources in its purchasing process with prescribers and suppliers to reduce carbon emissions and preserve natural resources. Its main goals are to:

  • take account of sustainability issues upstream from the launch of invitations to tender based on lifecycle cost analysis;
  • set up a coal and resources incentive system for our suppliers;
  • get Group Purchasing Department staff engaged with these key issues.

This project particularly includes assisting EDF’s supply chain to “go low-carbon”, helping prescribers to take account of these issues upstream from purchasing, and creating the tools needed to cover the purchasing process from A to Z.

Furthermore, following the EXCOM of 21 March 2022, it was decided that every business must require that a high level of health & safety standards be met when selecting businesses and that these standards must be increased at every stage of the purchasing process. To do so, an approach has been developed for each health & safety issue per purchasing category to identify the most exposed categories (e.g., rotating machine maintenance) in order to take appropriate actions such as including standards in specifications, and suitability and/or admissibility criteria, and criteria in technical ratings.

Supplier assessments

The monitoring of suppliers, which includes a CSR component, begins with an internal evaluation of the services they provide. Supplier monitoring is mainly carried out by the business line or Contract Management, which uses Performance Assessment Sheets and Supplier Assessment Sheets.

Document audits are completed by the supplier and are always (and independently) checked by the AFNOR teams. Questionnaires cover the entire scope of CSR; some are custom-designed to take issues specific to a given category into account. In 2021, it is mainly the suppliers in the risk categories (mobility and service providers working on nuclear sites) that have been questioned. It should be noted that suppliers were also interviewed at the request of Purchasing Category Managers (accommodations).

At the end of 2021, a special human rights questionnaire was developed with AFNOR and sent in 2022 to all suppliers with a contract in force, in the purchasing categories mentioned in international reports on the non-compliance with human rights or expressly mentioned by these reports, in the fields of textiles, computer equipment, control devices, and IT. In terms of solar panel purchases, EDF Renewables also sent out a questionnaire focusing on Human Rights to its suppliers in 2021: all surveyed suppliers provided a Human Rights policy and a purchasing code of conduct.

At the end of 2022, 3,200 suppliers were questioned using the ACESIA platform, and nearly a thousand of them have been controlled. The assessments were “satisfactory” for 34% of the audited questionnaires. The suppliers to be assessed are mainly selected based on the supplier risk mapping and the needs of buyers and business lines, on the contracts in progress.

This tool makes it possible for purchasers and suppliers to share an approach of continuous improvement in Corporate Social and Environmental Responsibility.

These on-site audits cover all CSR aspects: environmental, social and ethical (in particular human rights) policies, commitments and practices. On-site supplier audits are conducted by external, independent providers. CSR audits are conducted based on supplier risk mapping and feedback capitalised by Procurement Category Managers on how contracts are executed, with the help of the business line entities.

These audits are designed to test the CSR commitments adopted and are conducted on site (head office or production site of the supplier or place of work at an EDF site).

In 2022, 37 on-site CSR audits were conducted; 54% of which were outside France. 33.5% had a “satisfactory” result, 58.5% an “acceptable with comments” result and 8% an “insufficient” result: action plans were subsequently set up with suppliers and follow-up audits scheduled as necessary.

A large proportion of CSR audits were carried out as part of a call for tenders for the “workwear” category. Potential suppliers with audited production sites rated “Insufficient” or “Unsatisfactory” overall were ruled out of the supply chain selection process. In 2022, the declared secondary chain sub-contractors of suppliers selected in 2021 were audited. Only sub-contractors with a “Satisfactory” or “Acceptable” result can be included in secondary supply chain. The results of this campaign show that environmental and societal impacts were better taken into account, particularly compared to the similar initial campaign back in 2014. There was only one “Insufficient” result. Several businesses have demonstrated their determination to minimise their environmental impact: OEKO-TEX certification prioritised or obtained, reduced use of chemicals, energy management, etc.

Regarding audits conducted on other purchasing categories:

Upstream from an invitation to tender regarding manufacturing of GRP piping, potential tenderers were audited to confirm the compliance of their practices with minimum expected CSR prerequisites. In case of an unsatisfactory or insufficient result, an action plan must be set up: if necessary, an inspection audit is also required before the contract can be awarded. Across all purchasing categories, as in previous years, overall results for 2022 indicated appropriate management of safety and environment-related operational risks, due mainly to certification providing a framework and a robust safety culture. Environmental impact was also found to have also been better taken into account: carbon offsetting, use of the local economy, presence of CSR indicators/goals. However, several audited businesses did not have a code of ethics or anti-corruption policy. The other area for improvement was once more taking account of CSR criteria in successful bidders’ own supply chains, even if some good practices were identified this year. EDF’s requirements on these matters are still to be promoted in the audited companies.

In terms of organisation, 2022 was marked by audit postponements or cancellations due to geopolitical events (Russia-Ukraine crisis, instability in Burma, pandemic in China at the end of the year).

Awareness Raising and Training

The Purchasing Department and Impact Department organise awareness campaigns and training sessions for purchasers and prescribers focusing on responsible purchasing processes. In 2022, a training day was held along with 2 virtual classes aimed at people working in the CSR field at Group business lines and entities (section  3.3.3.6.6 “Skills development in the area of sustainable development”).

In addition, in late 2022 an e-learning course was created and released Group-wide to raise awareness of the Responsible Purchasing process.

Each of these training courses and awareness campaigns makes clear and explains the connection with the duty of vigilance.

Coal and uranium procurement

In the coal supply chain, EDF no longer has direct contractual relations with mining companies or the market but remains an active supporter of Bettercoal (1) – the initiative for responsible coal purchases of which EDF is a founding member. The operational approach is based on a code that sets out ethical, corporate and environmental principles and provisions relevant to mining companies. It takes into account general performance requirements, including management systems, and also performance requirements concerning: ethics and transparency, human and labour rights (such as the prevention of forced and child labour, the right to a decent wage), social issues, including health and safety, and the environment. JERA Trading, its supplier, is now a member of Bettercoal, thus increasing the initiative’s influence in Asia. In 2022, 24% of the EDF group coal supplies from JERAT were sourced from operators who had adopted the Bettercoal initiative, 28% from