EDF / 2020 Universal Registration Document

3 NON-FINANCIAL PERFORMANCE Vigilance plan

Accessibility of the system The Group whistleblowing system, managed from an independent platform that is not connected to EDF’s IS, may be accessed at any time via the EDF group website. The interface is available in several languages (French, English, Italian, Portuguese, Dutch and Mandarin) in France and abroad, and the whistleblower can report wrongdoing in the language of their choosing (4) . Reporting wrongdoing The EDF group ethics and compliance whistleblowing system allows Group employees and external staff (temporary workers, service provider employees, etc.) or occasional employees (fixed-term contracts, apprentices, trainees, etc.), as well as third parties, to report wrongdoing of which the EDF group or its staff are the culprits or victims. Analysis of the admissibility of reports Once the report has been submitted, whistleblowers receive confirmation within 72 hours informing them that the admissibility assessment has begun. Whistleblowers can submit reports anonymously in countries where this is authorised. Wrongdoing can be reported anonymously, as long as the severity of the reported facts is established and the factual elements are provided in precise and sufficient detail, so as to provide evidence for the reality of the reported facts. The Group Ethics and Compliance Department assesses the admissibility of the report, which depends on the scope of application and the whistleblower’s relationship with the Company. This admissibility is independent of whether the alleged facts are well-founded or not, which can only be determined through a report handling process. Once a ruling has been made on admissibility, the whistleblower is informed of the protective measures from which they benefit (protection under the Sapin II Law, French Labour Code, etc.). These vary according to their status (victim or witness, individual or corporation, etc.), their relationship with the Company (employee, external service provider, third party, etc.) and the themes involved (fraud, harassment, serious environmental damage, etc.). Processing of admissible reports Each report that is deemed admissible is processed. The Group Ethics and Compliance Department appoints a case manager and, if necessary, is assisted by Ethics and Compliance Officers and other experts to handle reports. When the investigations have been completed, an investigation report is drawn up by the case manager. If the allegations reported are proven or partially proven, an action plan is implemented. The Group Ethics and Compliance Department monitors the progress of this action plan and ensures it has been fully implemented before the report is closed. In order to monitor the measures implemented and evaluate their effectiveness, EDF relies on indicators established for the purposes of its non-financial reporting processes that cover the areas involved in the duty of care (see 3.7.2.2 “Further details on performance indicators”), as well as the monitoring system for Group risks. A Group Duty of Care Compliance Officer was appointed on 2 November 2020 and is responsible for producing and monitoring the vigilance plan in liaison with the Sustainable Development Department, the Legal Department, the Group Ethics and Compliance Department and all other departments and subsidiaries affected. Support is provided by a network of “Duty of Care” Officers coordinated jointly with the Sustainable Development Department. Each year, a review of the vigilance plan is presented to the Committee for Dialogue on Social Responsibility (CDRS) and regular briefings on its implementation and any developments are presented to the Corporate Responsibility Committee of the Board of Directors (see section 4.2.3.4 “Corporate Responsibility Committee”). System for monitoring the measures implemented and evaluating their effectiveness 3.6.7

EDF promotes the concept of general health and relays public health campaigns. In November 2020, EDF agreed to partner the “Moi(s) Sans Tabac” anti-smoking campaign run by Santé publique France (French Public Health Agency). Regarding the health and safety of its customers and the public, the Group’s entities implement customised information campaigns on electricity usage (see section 3.3.1.4 “Health and safety of consumers”), including in the areas surrounding EDF sites. Likewise, in its international infrastructure projects, EDF encourages the use of public health impact studies for all stages of its facilities and customised management programmes. Purchases The Group’s Purchasing policy states that respect for contractual commitments and the requirements of sustainable development policy in favour of people and the environment “constitute the foundation of the relationship with suppliers”. A “responsible purchasing” policy led by the Group Procurement Division makes it possible to identify supplier-related risks (see section 3.4.2.3.2 “Responsible procurement strategy and practices”). This policy includes, among other initiatives, the use of CSR requirements in contractual clauses. Serious discrepancies identified amongst our suppliers may compromise the contractual relationship and entail termination of the contract. Suppliers’ respect for environmental and societal undertakings is mainly ensured by giving priority to supplier evaluations which are defined based on the risk mapping performed by the Procurement Division. In segments falling within the major risks category, the high-priority evaluations are carried out either through self-assessment CSR questionnaires completed by suppliers and subcontractors and verified by an independent external provider, based on ISO 26000 compliance, or through audits (1) performed by external specialist firms. In the coal supply chain, EDF no longer has direct contractual relations with mining companies or the market, but remains an active supporter of Bettercoal (2) – the initiative for responsible coal purchases of which EDF is a founding member. Concerning uranium supply chain, clauses authorising the completion of audits and setting out EDF’s requirements in terms of enforcement of the fundamental rights and main international standards by suppliers and subcontractors have been included in the 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 (see section 3.4.2.3.3 “Coal and uranium supply chain”). 3.6.6 In 2018, the EDF Executive Committee decided to upgrade its system to secure the handling of reported wrongdoing and increase personal data confidentiality and security. Scope The Executive Committee decided to set up a single whistleblowing system for all wrongdoing reported under the Sapin II Law and the law on “duty of care” as well as wrongdoing reported by employees alleging harassment and discrimination. The Group Ethics and Compliance Department is the Group point of contact for the system. This Group system benefits all Group entities, except for the subsidiaries in the regulated sector, Enedis and RTE (3) , which have their own whistleblowing system to respect their managerial independence. Whistleblowers may choose to use the Group whistleblowing system or the other channels available to them (manager, human resources, staff representatives, local ethics and compliance officers, mediators, etc.). Whistleblowing system

(1) Auditing standards are based in particular on ISO 26000, OHSAS and SA80000. (2) bettercoal.org/ (3) Distribution network operator Enedis and transmission operator RTE are managed independently. (4) www.edf.fr/edf/alerte-ethique

202

www.edf.fr

EDF - UNIVERSAL REGISTRATION DOCUMENT 2020