EDF / 2020 Universal Registration Document
3 NON-FINANCIAL PERFORMANCE Vigilance plan
Vigilance plan 3.6 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 its fourth vigilance plan in this Universal Registration Document. This vigilance plan demonstrates that the identification, prevention and mitigation of risks related to serious violations of human rights, the environment and the health and safety of persons are systematically taken into account in all EDF group activities, including in its relations with suppliers and subcontractors and with a continuous progress approach. EDF’s vigilance plan was determined within the framework of the UN Guiding Principles on Business and Human Rights, OECD Guiding Principles, the fundamental conventions of the International Labour Organization and UN International Bill of Human Rights. EDF has a long track record of running a responsible business, based on the values of respect, solidarity and responsibility, promoting sustainable solutions for individuals and the environment. EDF’s raison d’être has been modified to read “To build a net zero energy future with electricity and innovative solutions and services, to help save the planet and drive well-being and economic development” and this statement was added to its articles of association at the General Shareholders’ Meeting held on 7 May 2020. This raison d’être helps us to improve the visibility and consistency of the EDF group’s CSR structure. It is split into 4 key issues and 16 major CSR commitments covering all of the Group’s CSR commitments and policies. regards the “Duty of Care” law The EDF group is an integrated energy company engaged in activities involving risks in three fields where the duty of care applies. EDF is active in all areas of the electricity industry and some areas of the gas industry: power generation using nuclear, renewable and thermal energies; electricity transmission and distribution; sales; energy services; energy trading (see section 1.4 “Description of the Group’s activities”). As a key player on the French market – both in mainland France and overseas regions and territories – EDF holds strong market positions in Europe, particularly in the United Kingdom, Italy and Belgium. EDF is the no. 1 nuclear-based electricity operator worldwide and the Group is also active in the design and production of nuclear equipment and fuels. As the top producer of renewable energies in Europe, EDF operates 80% of the hydroelectric power capacity in mainland France and is developing its skills in other renewable energy sources, including more particularly, land-based and off-shore wind power, photovoltaics and biomass sources. The Group is also an important player on the gas market generating electricity and heat using combined-cycle power plants and sells natural gas in several countries. EDF’s activities are based mainly in OECD countries. EDF’s assets and projects that are managed in many countries worldwide. Countries considered to be “higher-risk countries” receive special care, including in terms of relations with partners. As regards the supply chain, over 95% of Tier-1 suppliers managed by the Group Procurement Division are located in France or the European Union. Suppliers of certain subsidiaries or suppliers involved in international projects are subject to special vigilance measures. Pursuant to law of 27 March 2017, because the Group’s activities are mainly in the industrial field, EDF exercises upstream vigilance, with regard to any risk of violation of persons’ rights or risk to their health (employees, service providers, local residents, local communities and customers) or risk to the environment prior to making investment decisions, particularly to build, operate, maintain or dismantle facilities. Main characteristics of EDF as 3.6.1
Scope and methodology for developing the plan
Scope of the vigilance plan The scope of the vigilance plan covers EDF’s activities, the activities of subsidiaries it controls (1) , as well as the activities of its suppliers and subcontractors with which the Group has established commercial relations to the extent their activities are related to those relations. Dalkia and Framatome subsidiaries with a headcount of over 5,000 employees are integrated in the plan, together with all French and foreign subsidiaries. RTE and Enedis, respectively the French power transmission and distribution system operators, are independently managed subsidiaries, and therefore publish their own vigilance plans. Methodology for developing the plan The preparation of the plan involves all parties in the EDF group: the Group Duty of Care Compliance Officer; ● the EDF Corporate Divisions: Sustainable Development Division, Legal Division, ● Risks Division, Ethics and Compliance Division, Procurement Division, HR Division and International Division; all other EDF Business Divisions and Group subsidiaries heading up projects in ● France or abroad; the trade union organisations within the framework of the global framework ● agreement on the Group’s social responsibility (Global CSR Agreement). The plan is based on the Group reference documents: mandatory Group policies binding on all controlled entities: risk management and ● internal control, governance of subsidiaries and holdings, project management, ethics and compliance, sustainable development, health and safety, procurement; internal documents made public: Ethics Charter, code of conduct Ethics and ● Compliance, Sustainable Development Charter for Suppliers, Global Framework Agreement on Corporate Social Responsibility (CSR); external sources: UN Global Compact, UN Guiding Principles on Business and ● Human Rights, OECD Guidelines for Multinational Enterprises, WBCSD CEO Guide to Human Rights, Conventions of the International Labour Organization (ILO) guaranteeing fundamental principles and rights at work and combatting for the elimination of discrimination, Declaration on the Rights of the Child, Declaration on the Elimination of All Forms of Discrimination against Women, Global Reporting Initiative (GRI), Supplier Relations and Responsible Procurement Label (RF&AR); the EDF group’s reference framework drawn up in March 2021: “Human rights ● and fundamental freedoms, Health and safety, Environment, Business ethics: the EDF group’s commitments and requirements”. In 2020, EDF strengthened the governance of its vigilance plan. A special Group Duty of Care Compliance Officer is in charge of supervising and implementing the plan, using feedback from entities and working in cooperation with a Duty of Care Committee involving the other relevant divisions (legal, risks, ethics and compliance, human resources, purchasing and international). The duty of care is implemented consistently throughout the year.
(1) Subsidiaries integrated into the scope of consolidation using the full consolidation method pursuant to Article L. 233-16 II of the French Commercial Code (in France and abroad) (see note 3 to the consolidated financial statements).
EDF - UNIVERSAL REGISTRATION DOCUMENT 2020
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