EDF / 2019 Universal registration document

3. Non-financial performance

EDF, a company committed to a just and fair transition

accounting controls: Control procedures have been established for the ■ Company’s different processes. Following a technical analysis, any anomalies likely to be characterised as fraud are, where applicable, forwarded to the entity’s Ethics and Compliance Officer; training schemes: The Group Ethics & Compliance Division is developing ■ prevention measures and training for all employees. It has a dedicated community on the Group intranet that provides a range of training materials. It organises standard in-class training courses, particularly for members of the ethics & compliance network, subsidiary directors, and contract managers. The Group Ethics & Compliance Division has introduced a “Preventing the risk of corruption” e-learning module for executives. As of 31 December 2019, 62% of executives had completed the module. The target is for 100% of executives to have been trained by 31 December 2021. EDF, a company with a responsible attitude to people and communities

international sanctions: The Group Ethics & Compliance Policy requires the ■ executive directors of the relevant Group entities to implement a system to prevent the risks of international sanctions within their entities, particularly providing for integrity checks to be carried out to ensure the absence of risks of exposure to international sanctions as well as the insertion of a clause into each contract entitling EDF to terminate a business relationship with immediate effect in the event of failure to adhere to an international sanctions programme; regulation of interest representatives: EDF is an interest representative ■ within the meaning of the Sapin II law. In this respect, it is registered on the list of interest representatives managed by the HATVP (French High Authority for Transparency in Public Life). The network managers RTE, Enedis, and Dalkia are also registered: they each declare interest representation actions carried out during the year. The list of persons in charge of an interest representation identified in the register will be updated regularly. EDF also files with the HATVP  (1) an annual declaration relating to interest representation actions carried out that mentions actions aimed at influencing a public decision, with national public officials identified by the legislator. At the European level, EDF is listed in the Transparency Register of the European Parliament and the European Commission, and applies the related code of conduct. EDF presents its positions publicly via this transparency register  (2) , and via associations of which it is a member  (3) The estimated annual cost of the activities covered by the European Transparency Register since 2016 is around €2 million, with a downward trend; regulation of 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 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. In 2019, only EDF Renewables made payments in the United States, consisting of US$26,300 in the form of Political Action Committee contributions and US$184,900 in the form of Corporate contributions. Other compliance programmes Prevention of harassment and discrimination Banning all harassment or discrimination, and preventing and dealing with any physical or psychological violence, intolerance or injustice in the workplace is one of the requirements of the Group Ethics Charter. 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 preventive measures. More specifically, directors must take all necessary measures to prevent discrimination, harassment and physical and emotional violence within their entities by striving to make employees aware of the risks of harassment and discrimination, raise awareness among managers on ways of preventing and fighting harassment and discrimination, communicate regularly on the Group whistleblowing system and apply the appropriate sanctions in the event of proven wrongdoings. Two Reference guides to prevent and handle bullying and sexual harassment were released in the first half of 2019. They are intended for management and the HR Department, as well as for Ethics and Compliance Managers of entities. Financial ethics (Prevention of market abuse and the risk of money laundering, plus compliance with the EMIR regulation) The Ethics and Compliance Policy sets out the requirements to be followed to prevent market abuse, the risk of money laundering and the financing of terrorism. An Ethical Code for Trading in Securities, updated in 2019, complements this Policy. The Group Ethics & Compliance Policy also sets out the requirements concerning compliance with the European EMIR regulation. The practical implementation of this EMIR regulation by the EDF group, the implications for entities as well as the related processes and controls are described in the EDF group EMIR Policy Paper support guide.

Proportion of executives who have completed the anti-corruption training programme (%)

100%

100

80

62%

57%

60

42%

40

20

0

Target 2021

2019

2018

2017

Key non-financial performance indicator (see concordance table with the non-financial performance statement in section 8.5.4). For the scope and methodology of this indicator, see section 3.4 “Indicators and methodology”. This indicator refers to key stake no. 8 “Ethics and the duty of care” described in section 3.6.2 “Description of key stakes in the materiality matrix”. In 2019, it also released an interactive training tool, in French and English, to increase and test staff knowledge of the ethics & compliance code of conduct. The Group Legal Affairs Department also provides a “Preventing corruption” e-learning module, for staff to learn about how best to behave in situations relating to business relations, conflicts of interest and gifts. As of 31 December 2019, 8,313 employees had completed this module: internal control and evaluation system: To ensure the appropriateness and ■ effectiveness of measures to prevent and detect misconduct, a system allowing entities to evaluate the level of implementation and meeting of each key requirement has been put in place. It enables identification of improvement actions to be taken; a system to prevent conflicts of interest: The entities have put in place a ■ system designed to prevent conflicts of interest and raise employee awareness of high-risk situations, provide a system for employees to declare their links to organisations in which they have a personal interest, and require managers to resolve conflicts of interest with respect for individual freedoms; fight against fraud: In accordance with the “Fight against fraud” ■ memorandum of instructions, executives are tasked with setting up systems within their entities to raise awareness among their staff, put in place checks to detect potential cases of fraud, investigate incidents, report proven cases and sanction those responsible;

(2) ec.europa.eu/transparencyregister/public/consultation/displaylobbyist.do?id=39966101835-69. (3) avere.org/wp-content/uploads/2019/02/the_electrification_alliance_-_declaration-2017-030-0453-01-e.pdf (The Electrification Alliance Electricity for an Efficient and Decarbonised Europe). (1) hatvp.fr/fiche-organisation/?organisation=552081317.

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EDF | Universal registration document 2019