EDF / 2019 Universal registration document

3. Non-financial performance Appendices, concordance tables and report from Statutory Auditors

Committee (CBDI) relies on the use of a new screening grid that take into account risks related to the duty of care. Projects financed by Green Bonds or development banks were the subject of

a subcontractor of one of its main suppliers was far from the mark and after several warnings, suspended the supplier’s contract until the relevant subcontractor was in compliance. In addition, the Procurement Division has performed 35 on-site audits in Europe, of which 77% in France. 10% led to an “insufficient” score, giving rise to action plans with the suppliers concerned. Examples of actions implemented by the entities For the Myanmar SCHWE LI 3 hydroelectric dam project, the International ■ Division and EDF Hydro identified the main risks: risks related to on-going conflict in the State of Shan where the project is located, risks related to displacement of populations, risks of violation of the rights of indigenous peoples, risks to the safety of workers in areas of insecurity. These risks are assessed in detail in order to design appropriate measures in connection with an environmental and social impact study, as well as a study to evaluate and manage human rights impacts (see section 3.3.1.1.2) In 2019, using its environmental and social management system, EDF ■ Renewables organised site visits in India and China to analyse how to manage environmental and societal risks (relations with stakeholders, human rights, subcontractors’ working conditions, biodiversity, waste management, etc.) in connection with the development and construction of wind and solar power projects and to train local teams on EDF group requirements in this area In Cameroon, training in human rights was rolled out for service companies ■ ensuring the security of the Nachtigal dam In China, actions were taken in favour of vulnerable groups by supplying and ■ maintaining radiators for the elderly, granting scholarships to low-income students, assistance to improve quality of life and health of children (clothing, shoes, access to hot water) In China, the Group decided not to commit to a wind turbine project in a ■ redevelopment area. The production capacity was not consistent with the number of families that would have to be displaced In Côte d’Ivoire, for a biomass electricity generation project, the International ■ Division commissioned an analysis of the risk of forced labour on the plantations by an independent outside consultant (ERM), which assessed the risk as low. Since 2013, audits on child labour on these plantations have been conducted and action programmes implemented (to promote schooling, in particular). Since 2018, no cases of child labour have been detected. However, efforts and due diligence are being maintained (audits, awareness and action programmes) for the subsequent phases of the project (construction and operation) EDF Hydro identified risks at suppliers’ and subcontractors’ sites which have ■ their components (water wheels and turbines, transformers, alternators) manufactured in plants located in China, India, Brazil, Turkey and Eastern European countries. CSR audits on these suppliers were requested and the majority have been performed. These audits systematically covered respect for Human rights, safety and the environment. The audits are conducted at the headquarters of the relevant companies, in certain plants and are supplemented with audits on the EDF Hydro work sites. In one case in particular, a supplier was given an insufficient score for control of CSR risks at a subcontractor’s site in China, which led it to establish an action plan and enhance vigilance for orders placed with this company For the DTEAM (in charge of thermal facilities), the safety of service providers is ■ an absolute priority. When activities involve risks, the level of requirements is based on certification (MASE, OHSAS 18000) of subcontractors. Improvement programmes in the fields of guard services, road transport, maintenance and logistics have been initiated in cooperation with subcontractors Citelum, a subsidiary with business in a number of countries, organises risk ■ management to fulfil its duty of care based on social, regulatory and operating conditions at each one of its sites: - in Italy, the entity was certified SA 8000 for all of its business lines and those of its subcontractors, - in Brazil, the entity published and implemented a code of conduct which focuses particularly on the respect for human rights by suppliers, - in Spain, the entity was certified SGE21(RSC) which guarantees that human rights-related risks have been identified, evaluated and treated.

reporting to financiers on social and environmental matters. More details on the actions implemented are given below. Human rights

In June 2019, the Chairman of the EDF group was one of the co-signatories of the “CEO Guide to Human Rights” published by the WBCSD (World Business Council for Sustainable Development). When leading international projects, the commitment of stakeholders and seeking of consent have been systematic. When applicable, the use of migrant workers at work sites and on-site security guard forces received particular attention. For example, all hydropower projects included a stakeholders’ commitment plan and a local complaint management mechanism. These plans make it possible for all persons to concerned to freely express their complaints or worries and to participate in decision making. In the field of training, the e-learning programme “Human rights in business” developed with the Businesses for Human Rights organisation (Entreprises pour les droits de l’homme – EDH) was updated to include the duty of care and is available to all employees. A second e-learning programme covering “Human rights risks in the supply chain”, more specifically dedicated to buyers, was made available at the end of 2019. Environment Environmental risks were identified and incorporated into the Group’s environmental management system (EMS) and internal control system (see section 3.1.2.4.4.). Concerning biodiversity, a study completed in 2018 with the help of the WCMC (World Conservation Monitoring Centre) prioritises highly sensitive sites (generally bordering a high-profile protected area). In 2019, a full analysis of climate related risks was performed. Among the major European power producers, EDF is currently a player that publishes one of the most detailed annual GHG balances for its entire value chain (see section 3.2.1.1.5). For the year 2019 for the third time, the Group was on the A List published by CDP Climate Change, uniting companies with outstanding performance in the areas of transparency and objectives laid down for their carbon approach and their commitment to fighting climate change. Health/Safety Each Group entity promoted action plans aimed at on-going improvement of safety and health at work. At the Executive Committee’s request, a shutdown was organised on 3 October 2019 for all working teams, involving employees and service providers in order to discuss, in particular, the fatal accidents the Group had been confronted with in 2019 after a reduction over the previous years, and to define actions locally to improve the level of prevention. Group employees were encouraged to use the new e-learning programme designed by the Safety Academy (14,295 EDF employees have completed this training module). The situation of service Company employees was highlighted. As regards this point, a partnership agreement was signed with the MASE association in May 2019 and an event was held during the Preventica trade fair to encourage service companies to establish health and safety management systems. Purchases In 2019, the Group Procurement Division strengthened the performance of its risk analysis methods in accordance with the law on the duty of care. New methodology takes into account all of the CSR topics (environment, working relations and conditions, human rights, ethics and compliance) and makes it possible to determine the level of residual risk and define the priority controls and actions to be taken with suppliers depending on their purchasing segment (see section 3.3.3.2.2). Regular evaluation and follow-up audits are performed. For example, EDF Hydro audited 62 of its suppliers. One of them received an insufficient score for its control of CSR risks at a subcontractor’s site in China and was asked to establish an action plan and step up vigilance over orders placed with them. Luminus determined that

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EDF | Universal registration document 2019