EDF / 2018 Reference document

ENVIRONMENTAL AND SOCIETAL INFORMATION – HUMAN RESOURCES Ethics, compliance, tax transparency

At the end of 2018, 8,556 employees had completed anti-corruption certification training. Disciplinary sanctions In accordance with the Sapin II Law, any breach of the rules set out in chapter 3 of the code of conduct, Ethics and Compliance, may expose employees to disciplinary sanctions. A paragraph has been included in the code of conduct to inform employees of the disciplinary sanctions applied. The sanctions concerned are those set out in Article 6 of the Electricity and Gas Industry agreement (EGI status) and those in the French Labour Code. Depending on the circumstances and situations, the penalty may range from a warning to dismissal, including different stages (with or without an entry in the file, with or without suspension, with or without demotion). To its knowledge, EDF did no face (neither as victim nor culprit) proven acts of corruption in 2018. The internal control and evaluation system In order to make sure of the appropriateness and effectiveness of the measures for preventing and detecting any breach of ethics or failure of compliance, in 2016 the Group Ethics and Compliance Division put in place a dashboard enabling entities to evaluate the degree of deployment of each key requirement. The exercise meets the internal control requirements defined by the Group Ethics and Compliance Policy by allowing the implementation of the measures to be controlled, breaches to be identified and corrective measures established. This assessment of the level of control in terms of ethics and compliance has been carried out since 2017 as part of the annual internal control self-assessment initiative led by the Group Risk Division (DRG). The analysis and consolidation of escalated information is carried out by the Group Ethics and Compliance Division at the beginning of the following year. In 2018, several indicators were added to the self-assessment sheet on corruption risks. The control system is strengthened by regular internal audits at the entities and subsidiaries, ensuring that the system is continuously improved. The Group Ethics and Compliance Division works closely with the Internal Audit Division. Salient points from the audits in the area of ethics and compliance are shared regularly. Conflicts of interest The Group Ethics and Compliance Policy obliges Group senior executives to implement a system to prevent conflicts of interest and raise employee awareness of hight-risk situations, provide a system for employees to declare their links to bodies in which they have a personal interest (elective mandates, corporate mandates, etc.), and an obligation to withdraw from an activity in the event of a potential conflict of interest. The Group Ethics and Compliance Division has developed internal tools to raise awareness amongst all employees about conflicts of interest (educational information document, e-learning modules, video, etc.) and a chapter of the code of conduct, Ethics and Compliance is devoted to the matter, in order to identify high-risk situations, reflexes to adopt and good practices. Interest representatives In a general sense, the EDF group complies with applicable international agreements, does not seek or attempt to obtain information or decisions in a dishonest manner, makes sure that it does not mislead or deceive stakeholders, decision-makers or public authorities, and ensures that the information it provides is honest, up-to-date and comprehensive. In France, EDF is an interest representative within the meaning of Articles 25 et seq. of the Sapin II law (Articles 18 et seq.). In this respect, EDF is registered on the list of interest representatives maintained by the High Authority for transparency in public life - HATVP (1) . The network managers RTE, Enedis and Dalkia are also registered. The list of persons in charge of an interest representation identified in the register will be updated regularly.

Pursuant to this same law, in March 2018 EDF sent HATVP, its first declaration, relating to interest representation actions carried out between 1 July and 31 December 2017. As provided for by law, the declaration covers actions taken by the Company aimed at influencing a public decision, with national public officials identified by the legislator. By 31 March 2019, EDF and the registered subsidiaries will send HATVP their annual declaration on interest representation actions carried out during 2018. At European level, EDF is listed on the Transparency Register of the European Parliament and the European Commission, and applies the related code of conduct. The estimated annual costs for the activities covered by the European Transparency Register in 2016, 2017 and 2018 around €2 million. The main actions taken in 2018 include: legislative discussions on the Clean Energy Package. On this occasion, many ■ meetings and events were held to raise awareness and inform stakeholders of the Group’s priority challenges. Among these, the Group had the opportunity to reaffirm the importance it attaches to improving the coordination of European policies (renewable energy, energy efficiency and combating global warming), to long term solutions for confirming the security of supply in Europe and to raising the profile of its decarbonised investments and to the setting of a fair price for CO 2 ; preparation by the European Commission of its long-term strategy for reducing ■ greenhouse gas emissions. The Group has stated the need to continue a proactive approach to reducing CO 2 emissions. It is also committed to taking advantage of the opportunity presented by the development of electric transport, in order to more efficiently combat air pollution and reduce the transport sector’s carbon footprint, in addition to the actions already undertaken by the energy sector; the work carried out by the European Commission on sustainable finance has led ■ EDF, believing that long-term investors should contribute to achieving the objectives of the Paris Agreement, to promote greater transparency on sustainability criteria in asset managers’ portfolios. Lastly, the foreign direct investment (FDI) screening regulation has been closely monitored in order to uphold legal guarantees, proportionality of screening, complementarity and European added value. Non-financing of political parties The EDF group complies with the laws and regulations in force concerning the financing of political parties. Such financing may take place only in countries that allow it, and only with due regard to the principle of neutrality. In accordance with the legislation in force in France, EDF makes no payments to political parties. The Group’s Italian and UK subsidiaries have written directly into their codes of conduct the prohibition of financing political parties. In Belgium, EDF Luminus has made no contribution to political parties. No payments were made in Latin America or Asia. In countries where it is allowed (such as the United States), EDF group companies may determine whether they wish to provide financial support. Every year, the Group companies concerned must report any financing to their parent company (statement of beneficiaries and relevant amounts). In 2018, the amounts paid by EDF Renewables in the United States amounted to USD 39,000 to a Political Action Committee and USD 26,500 in political contributions. Other compliance programmes 3.5.1.3 The EDF group’s Ethics & Compliance Policy covers other compliance subjects and programmes, the operational implementation of which is carried out by expert divisions within the Group. Some of these subjects were completed in 2017 by memoranda of instructions designed to underpin their roll out in the Group’s entities. Prevention of harassment and discrimination As part of its policy of respect for persons, the Group does not tolerate any form of discrimination, harassment or violence in the workplace. This commitment is part of the regulatory and judicial context which, in many countries, incriminates not only the actions and behaviours themselves, but also employers who fail to implement sufficient preventative measures. Respect for people is one of the key commitments of the Group Ethics Charter. It is upheld by every Group employee, irrespective of his or her position within the Group. More specifically, directors take all necessary measures to prevent discrimination, harassment and physical and emotional violence in their entities by striving to make

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EDF I Reference Document 2018