EDF / 2018 Reference document

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ENVIRONMENTAL AND SOCIETAL INFORMATION – HUMAN RESOURCES Appendices and correspondence tables

The whistleblowing and alert system In September 2018, the EDF group set up a new whistleblowing system that allows Group employees, external employees and third parties to report serious breaches in relation to human rights and fundamental freedoms, individual health and safety, and the environment. This system is available in six languages and guarantees whistleblower protection. At the end of 2018, no “duty of care” alerts had been recorded. The system for monitoring the measures implemented and evaluating their effectiveness For 2018, the monitoring system was ramped up, by introducing a vigilance plan sheet in the internal control guide applicable to the entities concerned. The purpose of this sheet is to assess and justify the assessment of the risks identified (analysis of results, facts, causes and consequences), evaluate the entity’s control and performance, and set out the objectives of their 2019 action plan. It is asked that specific attention be paid to supplier evaluations (implementation of the responsible purchasing section of the Group procurement policy, including for new suppliers). Although not exhaustive, it is worth noting the measures taken by the Group entities that are most concerned: EDF International Department (ID): in 2018, set up an Environment and Social ■ Department in order to integrate a vigilance approach within all of its major projects (particularly regarding human rights risks). Particular attention will be required of controlled subsidiaries, and consideration is being given to non-controlled subsidiaries; Group Procurement Department (GPD): on the basis of sustainable ■ development/social responsibility risk mapping, the Group Procurement Department implements monitoring systems for Tier 1 suppliers. For certain high-risk sectors (workwear, chemicals, etc.), external audits are carried out throughout the entire supply chain. In 2019, a review of the sustainable development and social responsibility risks was carried out, so as to better integrate the duty of care provisions. The control system questionnaire will be reviewed in order to improve the quality of responses. The sustainable development and social responsibility risk assessment for new calls for tenders will be gradually rolled out in 2019; Nuclear Generation Division (NGD): it qualifies its service providers in the areas ■ of safety and environment. Prevention plans (1992 decree) are prepared and implemented with service providers in order to address safety and radiation protection risks. Checks are carried out at existing suppliers’ factories and qualification audits are carried out for new suppliers. Monitoring programmes and on-site assessment sheets cover the safety and environmental aspects. A toll-free number (2) is made available to report possible non-compliant practices; Nuclear Fuels Division: since 2011, EDF has conducted mine audits (2-3 a year) ■ based on a method drawn up collaboration with the World Nuclear Association (WNA). This constitutes a standardised framework recognised by all stakeholders in the sector. It takes account of issues of human rights and fundamental freedoms: such as human rights, register of warnings, rights of indigenous peoples and freedom of association. The question of safety in the context of mining is given particular emphasis (safety of process, protection from radiation). The environment is taken widely into account, notably as regards matters relating to water, biodiversity, waste and the rehabilitation of sites after exploitation. Recommendations may be made, together with an improvement plan if necessary. The principles defined by the WNA are based on those of the International Council on Mining and Metals, for the extraction and sustainable use of uranium. The clauses listing EDF’s expectations in terms of enforcement of the fundamental rights and main international standards by suppliers and sub-contractors have progressively been inserted in contracts signed by EDF; Upstream/Downstream Optimisation & Trading Division (DOAAT): the coal ■ contract was amended to include a “duty of care” clause when transferring the coal trading activity from EDF Trading to JERA (which has also committed to continue using audits conducted by Bettercoal). The fuel oil contract with EDF Trading Logistics was amended with the same requirements. A similar clause will gradually be included in non-fuel purchases.

Risks associated with human rights and fundamental freedoms are assessed by reference to the countries in which the Company, its subsidiaries and its suppliers operate, with specific focus paid to high-risk countries (1) . For example, the risk of forced labour linked to fuel transport conditions or the risk of infringements of the rights of indigenous peoples during industrial projects in Latin America, have been identified. As part of the Shweli3 project in Myanmar, the International Department identified a risk related to the conflict between the army and separatists. Furthermore, EDF Energy provided a report on forced labour risks in its statement required by the UK Modern Slavery Act of 2015. Personal health and safety risks relate to risks affecting our employees, service providers (industrial accidents, occupational illnesses – asbestos, ionising radiation) and our suppliers' employees, as well as risks relating to our industrial installations that may affect local residents and communities (e.g. water releases into hydraulic dams that may impact walkers. These risks are the subject of information and guidance campaigns). EDF also deploys information systems on electricity use to improve consumer health and safety. Risk prevention and mitigation initiatives The Group’s policies have been completely revised since 2015, and set out the requirements all entities must comply with. Clear and binding objectives have been defined for the areas covered by the vigilance plan (environment, individual health and safety, human rights and fundamental freedoms). The EDF group 2018 Sustainable Development policy states that it “shall not tolerate any human rights violations in any of its activities and among its suppliers”. This statement is also included in the global CSR agreement, which even makes human rights “a prerequisite for all the EDF group’s activities”. With regard to the environment, the EDF group maintains its ISO 14001 certification, first obtained in 2002. The processes implemented as part of this certification help curb environmental risks further. The EDF group’s 2018 Health and Safety Policy states that “the health of employees and service providers is the EDF group’s most valuable asset”, with the number one priority being the elimination of fatal accidents (see section 3.2.2.1). All Group companies perform a self-assessment according to ten vital rules and the BEST requirements, and They implement improvement plans targetting this level of excellence. Executives, managers, employees and service providers are all committed to this initiative. The EDF group also promotes the concept of global health, which includes risk management and prevention measures, (including of addiction) as well and promotes public health campaigns. The Group Procurement policy for 2017 applies to all purchases made within the Group. It states that “compliance with contractual commitments and the rigorous Sustainable Development policy, in terms of respect for people and the environment, is the foundation of the Group’s relationship with its suppliers”. Serious discrepancies identified amongst our suppliers may compromise the contractual relationship, until it is terminated. For new French and international projects of more than €50 million, risks are identified using a screening grid adapted in 2018 to include all “duty of care” risks, and which is discussed by the CECEG (Group Executive Committee’s Commitments Committee). Projects financed by green bonds or development banks are the subject of reporting to financiers on social and environmental matters.

Based on a country risk analysis. (1) There is a monitoring body at each EDF nuclear site which service providers are welcome to contact for verifiable facts relating to difficulties in terms of risk prevention, dosimetry, (2) training, working conditions and conditions of on-site stays. Anonymity is guaranteed, if desired. The monitoring body does not get involved in the employee negotiation process at service provider companies. However, it plays a whistleblowing and information role with regard to EDF’s management.

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EDF I Reference Document 2018