North-American operators and 48% from other global producers. This reduction was particularly due to the suspension of imports from Russia and use of alternative suppliers from producing countries not signed up to the Bettercoal initiative. However, Bettercoal is currently in discussions with several of these producers to sign them up in 2023.
Concerning uranium supply chain, EDF obtains its uranium supplies over the long term under diversified contracts in terms of origin and suppliers, in most of the main producing countries (Australia, United States, Canada, Kazakhstan, etc.). The clauses authorising the completion of audits and setting out EDF’s expectations in terms of enforcement of the fundamental rights and main international standards by suppliers and sub-contractors have progressively been added to contracts. The uranium mine audit system used by EDF since 2011 ensures that the ore is extracted and processed in good environmental, social and societal conditions (see section 3.4.2.3.4 “Responsibility in the fuel supply chain”).
The method and the evaluation grid were developed with WNA (World Nuclear Association). This method is based on international standards, including The World Nuclear Association’s Sustaining Global Best Practices in Uranium Mining and Processing: Principles for Managing Radiation, Health and Safety, and Waste and the Environment, The Global reporting Initiative’s (GRI), Sustainability reporting Guidelines & Mining and Metals Sector Supplement, and The International Council on Mining and Metals’ (ICMM) Sustainable Development Framework. The issue of safety, which is particularly critical in mining (process safety), consists of a standardised framework recognised by all those involved in the sector. These standards take account of the issue of human rights and fundamental liberties (human rights, whistleblowing register, rights of native peoples, radiation protection), personal health & safety, and the environment, including in the broadest sense of the term (greenhouse gases, water, biodiversity, waste post- extraction site rehabilitation). Every year, EDF carries out mine audits through internal means (2 audits per year). The reports present the main strengths, recommendations and suggestions. The most ordinary ones relate to health and safety (wearing personal protective equipment such as gloves or googles), the display of safety instructions, monitoring accidents, performing radiological controls, monitoring environmental footprint (specifically carbon emissions) and proposals relating to well-being in the workplace. Audit recommendations are included in the continuous improvement plans and action plans. There were two uranium mine audits in 2022.
The EDF group whistleblowing system consists of a single reporting system for all wrongdoing reported under the Sapin II Act and the “Duty of Vigilance” Act as well as wrongdoing reported by employees alleging harassment and discrimination. In late 2022, following the transposition into French law of the European directive on the protection of whistleblowers, in the form of the “Waserman Act”, which came into force on 1 September 2022, EDF began working on a new whistleblowing procedure to take account of the broader definition of “whistleblower” status.
This Group system benefits all Group entities, except for Enedis and RTE (1), which have their own whistleblowing system.
Whistleblowers may choose to use the Group whistleblowing system or the other channels available to them (manager, human resources, staff representatives, local ethics and compliance officers, mediators etc.).
The Group whistleblowing system, managed from an independent platform, may be accessed at any time via the EDF group website ( https://www.bkms-system.com/ bkwebanon/report/clientInfo?cin=5edf6&c=-1&language=eng), in French, English, Italian, Portuguese, Dutch and Mandarin, in France or abroad. The whistleblower can report in the language of their choice.
In order to comply with the requirements of the Sapin II and Duty of Vigilance laws, EDF has taken appropriate measures to guarantee the strict confidentiality of the personal data of whistleblowers, of those implicated or cited, and of the facts reported, in particular by setting up a whistleblowing system hosted on a dedicated, secure external platform.
The Group whistleblowing system allows Group employees and external staff (temporary workers, service provider employees, etc.) or occasional employees (fixed-term contracts, apprentices, trainees, etc.), as well as third parties, to report wrongdoing of which the EDF group or its staff are the culprits or victims.
See section 3.3.2.4 “The EDF group whistleblowing procedure” for more details on the functioning of the whistleblowing system.
In 2022, within the Group (via the Group system or any other channel), 305 admissible alerts were recorded (including 63 in the Group alert system). 224 were about incidents occurring in France and 81 abroad. 133 related to EDF and 172 to Group subsidiaries. 52% cases reported relates to harassment/discrimination. In 2022, 68% the alerts handled were sufficiently detailed to result in corrective action or disciplinary sanctions (in particular, 9 dismissals following proven acts of harassment-discrimination). In 31% of the cases where the facts were not proven, action to improve the relevant processes was still taken.
The Group’s vigilance mission is committed to developing the Vigilance Plan’s monitoring system as part of a continuous improvement process. This system is based on the operational action plan, which is monitored by the Steering Committee. This action plan is regularly presented to the CDRS (see section 3.9.2 “Governance, steering and stakeholder involvement”).
The assessment of the system is included in the annual internal control plan, and a dedicated risk sheet on due diligence has been drawn up and implemented. It allows entities to self-assess whether or not they meet duty of vigilance
requirements. Furthermore, internal control in this field was increased with two “essential progress actions” to be implemented at entities in 2022: one involved raising awareness among all relevant managers and project managers, via adedicated e-learning course (see section 3.9.5. “Major improvements to the EDF group’s Vigilance Plan in 2022”); and the other involved analysing salient risks at each entity (see section 3.9.5 “Major improvements to the EDF group’s Vigilance Plan in 2022”).
(1) Distribution network operator Enedis and transmission operator RTE are managed independently.
