EDF / 2018 Reference document

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ENVIRONMENTAL AND SOCIETAL INFORMATION – HUMAN RESOURCES EDF's commitments in the area of sustainable development

Management of environmental risks 3.1.3.3.2 Conscious of the potential impact of its activities on the environment, the EDF group implements a policy for the management of its risks at the operational, financial and organisational levels in compliance with the regulations in force. Environmental risks, including those associated with climate change, are fully integrated into the Group’s EMS and internal control system in coordination with the Group risk management function. They are subject to action plans resulting from strategic priorities in the Group’s sustainable development policy. The 2018 risk mapping (1) update reconfirmed the risk analysis and did not highlight new environmental risks. At the end of 2018, with the sale of the Dunkirk LNG terminal and the acquisition of Framatome, the Group has nine high-threshold SEVESO sites and 38 low-threshold sites (2) . In 2018, as in previous years, the most significant factors in terms of the economic and financial challenges related to environmental risks pertain to the following subjects: climate change and GHG emissions; the roll-out of energy efficiency initiatives; the impacts of EDF’s activities on the air, water and soil and the production of waste; protection of biodiversity and services provided by ecosystems and the management of water resources. Preventing risks and pollution In order to control risks of industrial incidents or accidents that could harm the natural environment or public health, EDF has implemented: a Group environmental management system that is constantly monitored and ■ improved in the entities and at the sites; an active investment policy and an industrial asset decommissioning programme ■ for assets no longer in operation, which includes decontamination operations where necessary; an employee training and awareness-raising programme for all stakeholders, ■ including feedback from crises experienced and exercises; inspections and audits at the generation sites; ■ a crisis management policy which requires the regular testing of crisis systems ■ through an annual programme of crisis response drills (see section 2.2.2.1.2 “Crisis management and business continuity”). In order to reduce these risks, the Group’s entities have also implemented a programme to eliminate or substitute certain substances (PCBs, chemical products) with more environmentally-friendly products. This work focuses as a priority on CMR (carcinogenic, mutagenic, or toxic for reproduction) substances or those considered extremely worrying. Following on from the studies of previous years, substitutions are now implemented: environmentally acceptable oils for hydraulic production, fluids for thermal and nuclear power plant turbines in France and the United Kingdom, varnishes and paints (Industrial Division, Property Management and Citelum in Italy),

etc. As part of an R & D project, activities aim to identify and evaluate mature and innovative liquid effluent treatment technologies to reduce harmful chemicals (bore, hydrazine, ammonia, C14, H3, nitrates, AOX, CRT, Cu/Zn, etc.). Locally, each of the Group’s operational units and companies identify events that could have an environmental impact, manage emergency situations that could result from them, conduct corresponding crisis response drills, implement monitoring and communicate on environmental events under its responsibility. There were no high-stakes environmental events (3) during 2018. There were a few incidents, without any major environmental or health impacts, which mainly concerned leaks or spillages of hydrocarbons or chemical products. They were controlled according to the emergency procedures in effect which considerably limited their impact on the natural environment. However, some events are to be noted: the presence of yellow dustfall near the combined cycle gas turbine in Bouchain (France) with no certainty on the link with the startup emissions, and the death of some raptors on wind farms in France and Mexico. In addition, the period of heat and drought created unfavourable conditions for fish life and made water management difficult especially in the lower Ain valley and the étang de Berre. Some environmental events may be followed by litigation arising from complaints filed by NGOs or non-profits or formal warnings from national regulatory authorities (the French Nuclear Safety Authority (ASN), the Prefecture, etc.) or by litigation relating to land transactions. In 2018, the total penalty amount imposed on EDF in France stood at approx. €1.94 million. It consists of two types of penalties: a ruling relating to an industrial event on the Bugey site in 2013 (€5,000 in damages), and two disputes that have come to an end and related to land sales transactions accompanied by soil cleaning work. It includes a land sale in Perpignan in 2010 and In order to coordinate all the objectives and actions resulting from its commitments and its sustainable development policy, EDF group has put in place Group-wide coordination managed by a Sustainable Development Committee (SDC) and implemented as regards the environmental component (including aspects associated with climate change) with the aid of an environmental management system (EMS). The EDF group’s EMS is ISO 14001 2015 certified for a scope representing almost all the consolidated revenue of EDF and its subsidiaries (excluding Enedis) and associates (4) . In 2018, new subsidiaries joined the Group's scope of certification (Electricité de Strasbourg, Energy Services, and Electricité de Strasbourg, Networks, IFOPSE). Two subsidiaries are not certified but have environmental management systems (EMS) and participate in EMS coordination. In 2018, and as part of the continuous improvement of the EMS, the AFNOR certifier emphasised on the even stronger integration of sustainable development in the Group's strategy, as well as efforts made to equip and simplify the process (e.g. like the operational implementation of the HSE tool in the regulatory compliance watch). another sale in Saint-Malo in 2007 (land of a former gas plant). The environmental management system (EMS)

See section 2.2.2.1.1 "Risk mapping and the report on the control of activities and risks". (1) Upper and lower threshold: industrial establishments are “Seveso” classified according to their technological risk depending on the quantities and types of hazardous products (2) they handle. There are two different thresholds which classify establishments as “Seveso low-threshold” or “Seveso high-threshold”. There are two different thresholds which classify establishments as “Seveso low-threshold” or “Seveso high-threshold”. The requirements vary significantly between these two types; they are very restrictive for the high-threshold, particularly with regard to the safety management system, informing the public and the prevention plan, etc. High-stake environmental event: an event causing serious environmental damage (areas, resources and natural environments, sites and landscapes, air quality, animal and plant (3) species, biological diversity and balance) combined with extensive media coverage or a financial impact of more than €3 million. An event causing environmental damage and likely to affect human health falls within the scope of a high-stake environmental event for the EDF group. See results of environmental indicators. (4)

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EDF I Reference Document 2018