EDF_REGISTRATION_DOCUMENT_2017

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

The Board of Directors of EDF, through its Corporate Governance and Social Responsibility Committee, oversees the Company’s incorporation of ethical and compliance considerations into its works and management. Checks and controls on the programme The rules of the Group Ethics & Compliance Policy define the requirements covering the areas of ethics and compliance. Their implementation is subjected to the annual risk mapping exercise and to evaluation by the EDF group’s internal controls. It allows the Group Ethics and Compliance Division to evaluate the degree of deployment of each key requirement and to obtain assurance as to the implementation of the actions decided on and their effectiveness. The Group Ethics and Compliance Division works closely together with the Internal Audit Division. Salient points from the audits in the area of ethics and compliance are shared regularly. Respect for the Group’s values 3.1.4.2 Group Code of Ethics The Group Code of Ethics rolled out in the business lines and Group companies between 2013 and 2014. The Group wanted the Code to be championed at the managerial level, so presentations to the Executive Management Committee were held, as well as team meetings and integration training. The Code has been widely circulated by managers or via the Group’s many communication tools (intranets, noticeboards, newsletters, emails, etc.). Non-financing of political parties The EDF group complies with the laws and regulations in force concerning the financing of political parties. The EDF group’s Ethics Code states that the Group “respects the beliefs and opinions of everyone as well as those of political organisations, trade unions and religious organisations without providing support to any in particular”. Thus, such financing may take place only in those countries that authorize it, and then only with due regard to the principle of neutrality. In accordance with the legislation in force in France, EDF SA makes no payments to political parties. The Group’s Italian and UK subsidiaries have written directly into their codes of conduct the prohibition of financing political parties. This is the case of subsidiaries Edison and Fenice in Italy and EDF Energy in the UK. In Belgium, EDF Luminus has made no contribution to political parties. In the United States, certain subsidiaries have made token contributions transparently and publicly to political action Committees in full compliance with US law and within the framework of rigorous managerial validation. Public Affairs In-depth discussions were held with the European Commission, the Parliament and the Council on the Clean Energy Package, the framework for all the major legislative texts for the future of the European electricity sector. On this occasion, numerous meetings and events were held to raise awareness and inform the Brussels public of the priority stakes for the Group. Among these, the Group had the opportunity of reaffirming the importance it attaches to long term solutions for confirming the security of supply in Europe and of raising the profile of its future decarbonised investments (renewables, nuclear and energy efficiency) and of the setting of a fair price for CO 2 . The Group pointed out the need to hold a steadfast course towards the goal of reducing CO 2 emissions and improving coordination among European policies (renewables, energy efficiency and combating global warming); the Group also stressed the opportunity presented by the development of electric vehicles to combat air pollution more effectively and to limit the carbon footprint of the transport sector, complementing the actions undertaken by the energy sector. EDF is listed on the Transparency Register of the European (1) Parliament and the European Commission, and applies the related code of conduct. In France, EDF is listed on the register of lobbyists of the National (2) Assembly and of the Senate, and has undertaken to adhere to their code of conduct. In application of the law known as "Sapin II", Group employees mainly or regularly involved in lobbying are listed on the published register of lobbyists.

This is a single document forming the overarching reference for the Group’s Code of Ethics Charter (launched in 2013) and Code of Conduct (published in 2017), updated as new applicable rules are published and subjected to audit. The Group Ethics & Compliance Policy covers nine subject areas: preventing the risk of corruption (integrity checks on business relations, ■ limitations on gifts and hospitality); financial ethics (prevention of the risk of money laundering and the financing of ■ terrorism, prevention of market abuse, compliance with EMIR rules); preventing breaches of competition law; ■ preventing conflicts of interest; ■ protection of the security of personal data; ■ the fight against fraud; ■ the fight against harassment and discrimination; ■ compliance with sector regulations (REMIT, dual-use goods); ■ and compliance with international sanctions programmes. ■ A Group Code of Ethics constructed around the Group’s three values The Group Code of Ethics, constructed around the Group’s three values (respect, solidarity and responsibility) has been rolled out since the end of 2013. It sets out the rules and principles which must guide the actions and behaviour of Group employees on a daily basis. It is accessible in French and English on EDF’s website. The Code is also available in ten other languages: Chinese, Dutch, German, Hungarian, Italian, Polish, Portuguese, Russian, Spanish and Vietnamese. A Code of Conduct Ethics and Compliance that aims to ensure the safeguarding of our culture of integrity The law of 9 December 2016 on transparency, the fight against corruption and the modernisation of the economy brought France and French businesses up to the level of international standards regarding the fight against corruption. Building on its ethical commitments, EDF fully complies with the law’s requirements thanks to the publication of its Code of conduct in the second half of 2017. Integrated with the Company’s internal regulations, the Code of Conduct Ethics and Compliance is the cornerstone of the Group’s anti-corruption mechanism. It applies to the employees of EDF SA and is adaptated in its subsidiaries. The Code establishes the rules to be followed and enables employees to identify situations of risk and to conduct themselves accordingly. A strengthened governance The structure of the Group ethics and compliance function is approved by the Group’s Executive Committee. The Group Ethics and Compliance director reports to the General Secretary, who is a member of the Group Executive Committee. He proposes, manages and coordinates, in liaison with the other division concerned, the implementation of the Group’s ethics and compliance action plans both within France and abroad. In 2016 the Group Ethics and Compliance Division set up a network of 47 Heads of Ethics and Compliance in the French entities and internationally. The Heads of Ethics and Compliance report directly to the directors of the entities and take part in Management Committee meetings on ethics and compliance matters and the associated action plans. They have the means and powers necessary to implement the Group Ethics and Compliance Policy and to make sure that it is complied with. The Group Executive Committee, led by the EDF Chairman and CEO, is responsible for determining the orientations and priorities of the compliance programme, allocating the necessary energy and resources and ensuring the monitoring and control of its implementation. In 2017, the Group Ethics and Compliance Division took part in two meetings of the Group Executive Committee to validate the action plan, report on progress and validate the code of conduct.

http://ec.europa.eu/transparencyregister/public. (1) http://www2.assemblee-nationale.fr/representant/detail_representant_interet/2177. (2)

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EDF I Reference Document 2017