EDF / 2019 Universal registration document

3. Non-financial performance

EDF, a company committed to a just and fair transition

Coal and uranium supply chain Since its coal contracts were taken over by JERA Trading (JERAT), EDF has no direct contractual relations with mining companies or the market, but remains an active promoter of the Bettercoal  (1) responsible coal purchasing initiative that it helped to found. Bettercoal brings together energy companies, port institutions and coal terminals to promote CSR in the coal supply chain, mainly at mining sites, to ensure that fundamental rights are respected. The operational approach (audits and self-assessments) is based on a code that sets out ethical, corporate and environmental principles and provisions relevant to mining companies. It takes into account general performance requirements, including management systems, and also performance requirements concerning: ethics and transparency, human and labour rights (such as the prevention of forced and child labour, the right to a decent wage), social issues, including health and safety, and the environment. EDF has not renewed its membership but its coal supplies remain covered by Bettercoal as JERAT, its supplier, is now a member, thus increasing Bettercoal’s influence in Asia. EDF obtains its uranium supplies over the long term under diversified contracts in terms of origin and suppliers, in most of the main producing countries (Australia, United States, Canada, Kazakhstan, South Africa and Russia). The clauses authorising the completion of audits and setting out EDF’s expectations in terms of enforcement of the fundamental rights and main international standards by suppliers and subcontractors have progressively been added to contracts. The uranium mine audit system used by EDF since 2011 ensures that the ore is extracted and processed in good environmental, social and societal conditions. The method was developed with the WNA (World Nuclear Association), consisting of a standardised framework recognised by all those involved in the sector. It takes into account the issues of human rights and fundamental freedoms (human rights, whistleblowing register, rights of indigenous peoples and radiation protection) and also the environment, in the broadest sense of that term (water, diversity, waste, site clean-up after extraction). Every year, EDF carries out mine audits through internal means (2 audits in 2019). The reports present with the main strengths, recommendations and suggestions. The most common ones relate to health and safety (wearing personal protective equipment such as gloves or googles), the display of safety instructions, monitoring accidents, performing radiological controls, monitoring CO 2 emissions and proposals relating to well-being in the workplace. Audit recommendations are included in the improvement plans.

At the end of 2019, 1,750 suppliers were questioned using the Acesia platform, and 815 have been controlled. The assessments were “satisfactory” for almost 40% of the questionnaires. They were “satisfactory” or “acceptable with comments” in more than 80% of all audits. Group entities that do not use the Acesia platform use their own specific assessment methods. Suppliers of the Nuclear Department must agree to comply with the Progress Charter for Exemplary and Efficient Nuclear Power and the Social Specifications of the Strategy Committee for the Nuclear Sector. Edison uses a self-assessment platform that focuses on the ten principles of the Global Compact and is shared with other companies. EDF Renewables assesses its suppliers of strategic wind and solar energy equipment in its qualification processes, comprising selection criteria in all CSR fields. A Chinese turbine supplier that qualified for the very first time was only selected for its ISO14001-certified plants. All Group entities conduct assessment or follow-up audits in their supply chain. For example, the Dalkia teams conducted 2,718 health and safety audits on its subcontractors at worksites or customer sites operated by Dalkia. EDF Hydro audited 62 of its suppliers: one of them obtained an insufficient CSR risk control rating for a subcontractor in China. As a result, it was asked to produce an action plan and the orders placed with it were monitored closely. Luminus noted a major discrepancy with a subcontractor of one of its main suppliers: after several alerts, the entity suspended its contract until the relevant company became compliant. The Purchasing Department also conducted 35 on-site audits in Europe, 77% of which were in France. Apart from five year-end audits whose reports were still pending on the date of review, 40% had a “Satisfactory” rating, 50% an “Acceptable with Comment” rating and 10% an “Insufficient” rating, requiring supplier action plans. The main areas for improvement identified were: the requirements arising under the duty of care law, which are still insufficiently applied by suppliers in their own supply chain; operational discrepancies in the management of liquid effluent and chemical containment and waste monitoring; the formal recording of CSR commitments, which is not automatic, in particular for waste and energy use reductions; a failure to obtain information on the recycling rate or percentage of recycled materials in incoming products; a low number of GHG assessments; insufficient consideration of biodiversity factors. Non-conformities were found in safety signage and training courses did not include preventive health actions (e.g. on addictions). Moreover, there were not many training courses on ethics or the prevention of bribery and corruption, discrimination and harassment. The development of good societal practices, such as using car-sharing and fleets of electric vehicles when employees travel within urban areas, and partnerships with start-ups, was also highlighted.

(1) bettercoal.org/.

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EDF | Universal registration document 2019

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