EDF_REGISTRATION_DOCUMENT_2017

ENVIRONMENTAL AND SOCIETAL INFORMATION − HUMAN RESOURCES Defining and implementing corporate responsibility

3.1.6

THE VIGILANCE PLAN

Methodology for developing the plan The preparation of the plan brings involves all the parties in the EDF group concerned by the subject, and in particular: the Corporate departments: Sustainable Development, Legal, Group Risk Control ■ and Group Procurement; Group entities conducting international projects (EDF Énergies Nouvelles, ■ International Division, the Hydraulic Engineering Production Division (DPIH in the French abbreviation, etc.); the business line and Group companies (including their subsidiaries and ■ suppliers). The plan is based on the existing corpus as regards: Group Policies: risk management and internal control, governance of subsidiaries ■ and associates, project management, ethics and compliance, procurement, sustainable development, health and safety, etc.; internal commitments: Ethics Charter, Suppliers’ Sustainable Development ■ Charter, code of conduct; external commitments: UN Global Compact, Bettercoal, Responsible Supplier ■ Relations label, CSR agreement. On a complementary basis the “vigilance plan” theme was added to the Internal Control Guide in the form of a questionnaire addressed in the summer of 2017 to 70 EDF group entities. The law also specifies that the plan must be drawn up with the companies’ stakeholders: a presentation of the law was made to the Dialogue on CSR Committee (“CDRS” ■ in the French abbreviation), and reference will be made to the plan in the new international framework agreement negotiated with the EDF group trade unions and two international trade union federations, IndustriAll and Public Services International. If a new agreement is signed, a progress report on implementation of the vigilance plan will be presented every year to the CDRS; the vigilance plan was also the subject of exchanges with other businesses in the ■ context of EDH (“Entreprises pour les droits de l’homme”, or “Businesses for human rights”, a non-profit association). Content of the EDF group’s vigilance 3.1.6.3 plan The vigilance plan fits into a process of continuous improvement aimed at identifying and minimising the risks that the activities of EDF, its subsidiaries and their suppliers might cause their stakeholders to incur in the area of human rights and fundamental freedoms, the health and safety of people, and the environment. For this first exercise, the content cannot be exhaustive; as a first step we have to make an inventory of, and fill in any gaps in, the policies, mechanisms and actions at every level of the EDF group that allow us to identify the risks associated with its activities or those of its suppliers and to confirm that they are either well under control or that existing arrangements need to be strengthened. Mapping risks in order to identify, 3.1.6.3.1 analyse and prioritise them Risks are mapped by the Group Risk Control Department. This mapping identifies and covers risks in the areas of the environment, human rights and fundamental freedoms and health and safety. Environmental risks are clearly identified and incorporated into the Group’s environmental management system (EMS) and internal control system. They are linked in particular to our industrial activity, and mainly concern GHG emissions, impacts on water, air and soil and the production of conventional and radioactive waste. Particular attention is given to the conservation of biodiversity, the services rendered by the ecosystems and the management of water resources. In this regard the EDF group, with the help of the WCMC (World Conservation Monitoring Centre) has undertaken an inventory of sensitive sites as regards biodiversity in France and in its international subsidiaries and projects, including those still on the drawing board, under construction or being dismantled. The results will be known during the course of 2018.

The materiality matrix identifies the duty of vigilance among its material issues (issue no. 34 Duty of vigilance and responsible procurement). Law no. 2017-399 of 27 March 2017 on parent companies’ and ordering companies’ duty of vigilance requires companies with more than 5,000 employees in France to develop and effectively implement vigilance plans. For EDF, which falls within the scope of application of this law, this involves going through an initial stage aimed at raising awareness throughout the Group, making an inventory of all the policies and mechanisms implemented, and putting in place procedures for constructing the EDF group’s vigilance plan. Next year a dashboard will be drawn up showing progress in implementing the plan, and it will then be possible to complete the risk mapping. This section sets out the main characteristics of EDF as regards the law on the duty of vigilance (1) , defines the scope of the plan and the methodology used to develop it, and provides the initial components of its actual content as defined by the law. Main characteristics of EDF as regards 3.1.6.1 the law The EDF group is present in all electricity business lines and has strong positions in Europe, notably in France, the UK, Belgium and Italy. The EDF group also supplies gas and provides energy related services. As regards fundamental rights and freedoms, the EDF group currently operates essentially in OECD countries. It also has assets and carries out projects in countries that can be considered “at risk”, such as: Egypt, Southeast Asia, Latin America, etc. and which require particular attention. As for the supply chain, although 97% of tier-one suppliers dealt with by the Group Procurement Department are located in France or elsewhere in the European Union, there is room for improving our knowledge of subsidiaries’ suppliers and of suppliers involved in international projects. As far as the health and safety of persons are concerned, the analysis of the risks associated with the EDF group’s activities covers the health and safety of both employees and subcontractors as well as possible effects on residents and local communities. Health issues in the supply chain are the subject of close scrutiny (e.g. in the case of chemical products, etc.) The environmental impacts of the Group’s activities are identified and monitored, notably in the context of the environmental management system. Supplier’s environmental performances are he subject of contractual clauses accompanied by self-assessments and possible audits. Scope of the vigilance plan and 3.1.6.2 methodology for developing it Scope The scope of the vigilance plan covers the parent company EDF SA and its subsidiaries within the meaning of Article L. 233-1 and the companies that it controls within the meaning of Article L. 233-3 of the French Commercial Code. As regards suppliers, the plan covers those with which the Group maintains established commercial relations. This mainly concerns the tier-one suppliers handled by the Group Procurement Department and the fuel suppliers dealt with by the Nuclear Fuels Division or EDF Trading Logistics on behalf of the Upstream/Downstream Optimisation & Trading Division (DOAAT in the French abbreviation). Information on other suppliers (direct suppliers of subsidiaries (2) or projects) is provided by the respective customer companies. The law on the duty of vigilance provides that subsidiaries exceeding certain thresholds are covered by the parent company’s vigilance plan. Such is the case of Dalkia, a subsidiary of EDF). It has nevertheless been decided that Enedis will develop and publish its own vigilance plan, and that EDF may refer to it in the Group’s vigilance plan.

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Without including an exhaustive list of all the items contained in this Registration Document. (1) Except for those managed by the Procurement Department. (2)

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EDF I Reference Document 2017