EDF / 2018 Reference document

ENVIRONMENTAL AND SOCIETAL INFORMATION – HUMAN RESOURCES Appendices and correspondence tables

3.8

APPENDICES AND CORRESPONDENCE TABLES

3.8.1

VIGILANCE PLAN

Methodology for developing the plan The preparation of the plan involves all parties in the EDF group. The following were involved in preparing the plan: the Corporate departments: Sustainable Development (coordination), Legal, ■ Group Risk Control and Group Procurement; departments or entities with international projects: International, ■ EDF Renewables, etc.; the other business lines and Group companies, including their subsidiaries and ■ suppliers; the trade union organisations within the framework of the global agreement on ■ the EDF group’s social responsibility. The plan is based on the existing corpus as regards: Group Policies: risk management and internal control, governance of subsidiaries ■ and associates, project management, ethics and compliance, sustainable development, health and safety, procurement. These policies apply to all companies controlled by the EDF group; internal commitments: code of conduct, ethical charter, supplier sustainable ■ development charter; external commitments: United Nations Global Compact, OECD Guidelines, Global ■ CSR Agreement, Supplier Relations and Sustainable Procurement Label. Stakeholder association 3.8.1.3 On 19 June 2018, a new corporate social responsibility agreement was entered into with the Group trade unions and two international trade union federations (IndustriAll and ISP). For the first time, an agreement explicitly refers to the implementation of the law on the duty of care (“devoir de vigilance”) throughout the Group. It states that “the vigilance plan shall be drawn up and implemented in conjunction with the Company’s stakeholders, including employee representative organisations”. The annual vigilance plan report will be presented at the next Global Agreement Monitoring Committee meeting. Several meetings were held with the Monitoring Committee in order to share methodologies and involve EDF and subsidiary employee representatives in the detection of risks at their entities. Furthermore, EDF participated in discussions with other companies and NGOs, within the framework of the “Entreprises pour les droits de l'homme” (EDH (2) ) non-profit, in order to compare corporate practices and improve vigilance plan preparation processes. Content of the EDF group’s vigilance 3.8.1.4 plan Salient risk mapping Every year, the entities produce a risk map based on a methodology implemented by the entire Group, with a focus on : management responsibility, the broadest possible identification of internal and external risks, a shared methodology for assessing the impact and control of risks, a description of risk management action plans and an assessment of their effectiveness. The risks covered by the duty of care obligation (although focused on the risks that the Company, its subsidiaries or suppliers may generate amongst their stakeholders) are intended to be assessed and monitored in a similar way.

In accordance with French law no. 2017-399 of 27 March 2017 relating to the duty of care of parent companies and ordering companies, the EDF group published an initial version of its vigilance plan in its 2017 Reference Document. For the sake of continuous improvement, the system in place to prepare the second vigilance plan, aimed to raise awareness among all players concerned and deepen and enhance the steps taken, including monitoring the measures implemented and assessing their effectiveness. This second version of the EDF group vigilance plan states how the plan has been implemented and reports on progress achieved by the entities with regard to different parts of the plan. In 2018, the vigilance plan was presented to the Governance and Corporate Social Responsibility Committee of the Board of Directors. Main characteristics of EDF as regards 3.8.1.1 the law The EDF group is an integrated energy company active in all electricity businesses: nuclear, renewable and traditional thermal generation, transmission, distribution, sales and marketing, efficiency and energy services, and energy trading. It is the primary player on the French market and has a strong foothold in Europe (specifically in the United Kingdom, Italy and Belgium). It is involved in the design and manufacture of equipment and fuels for nuclear reactors, with the integration of Framatome in 2018. As regards human rights and fundamental freedoms, the EDF group primarily operates in OECD countries. However, it has assets and projects in countries that can be qualified, in terms of human rights and fundamental freedoms, as “high-risk countries” (for example in Southeast Asia, and Latin America) thus require specific attention, including in relations with our partners. As for the supply chain, although over 95% of its tier-one suppliers dealt with by the Group Procurement Department are located in France or elsewhere in the European Union, suppliers to certain subsidiaries or those involved in international projects are given greater attention. In the area of personal health and safety, and due to its industrial nature, risk analysis covers both employee health and safety (employees, service providers, etc.) and the potential impacts on nearby residents, local communities and customers. Health issues in the supply chain are the subject of close scrutiny (e.g. the use of chemical products). Environmental impacts relate in particular to the construction and operation of energy generation facilities, and are assessed within the framework of a management system. Suppliers' environmental performances are the subject of contractual clauses and are regularly evaluated. Governance and scope 3.8.1.2 Reporting plan The scope of the vigilance plan covers the EDF Group and its audited subsidiaries (1) . As regards suppliers, the plan covers those with which the Group maintains established commercial relations. This mainly concerns the tier-one suppliers handled by the Group Procurement Department and the fuel suppliers dealt with by the Nuclear Fuels Division or EDF Trading Logistics on behalf of the Upstream/Downstream Optimisation & Trading Division (DOAAT in the French abbreviation). The law on the duty of care provides that French subsidiaries exceeding certain thresholds be covered by the parent company’s vigilance plan. As in 2017, the Dalkia subsidiary has been included in the plan. Framatome was also included for the first time, having joined the Group in 2018. RTE and Enedis, transmission and distribution system operators and independently managed subsidiaries, prepare and publish their own vigilance plans.

3.

Environmental risks are clearly identified and incorporated into the Group’s environmental management system (EMS) and internal control system. More specifically, they relate to the Group’s industrial activities, and mainly concern GHG emissions, impacts on water, air and soil and the production of conventional and radioactive waste. Particular attention is given to the conservation of biodiversity, the services rendered by the ecosystems and the management of water resources. As such, a study was completed in 2018 with the help of the WCMC (World Conservation Monitoring Center), which prioritises sites most sensitive to biodiversity, generally bordering a high-profile protected area. The 2018 risk mapping update did not highlight any new environmental risks. Subsidiaries integrated into the scope of consolidation using the full consolidation method pursuant to Article L. 233-16 of the French Commercial Code (in France and abroad). (1) e-dh.org. (2)

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EDF I Reference Document 2018