EDF_REGISTRATION_DOCUMENT_2017

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

Fighting against fraud Within the priority actions defined by the Group, the fight against fraud is a major concern: a “zero tolerance” policy has been enforced since the end of 2010. Within the framework of the internal control system, managers have drawn up and adopted anti-fraud measures locally. In 2017, a memorandum of instructions and an operational support guide were distributed with the aim of explaining to managers and those immediately responsible, the Heads of Ethic and Compliance, the main checks to be carried out in order to contribute to keeping the risk of fraud under control. This guide will be updated regularly. Prevention of harassment and discrimination As part of its policy of respect for persons, the Group does not tolerate any form of discrimination, harassment or violence in the workplace. This commitment is part of the regulatory and judicial context which, in many countries, incriminates not only the actions and behaviours themselves, but also employers who fail to implement sufficient preventative measures. Respect for people is one of the key commitments of the Group Code of Ethics, and it is upheld by every Group employee, irrespective of his or her position within the Group. More specifically, directors take all necessary measures to prevent discrimination, harassment and physical and emotional violence in their entities by striving to make employees aware of the risks of harassment and discrimination, raise awareness among managers on ways of preventing and fighting harassment and discrimination, communicate regularly on the ethics and compliance whistleblowing system and apply the appropriate sanctions in the event of proven wrongdoings. All cases reported via the whistleblowing system are processed in accordance with the Group’s zero tolerance policy. Preventing the risk of corruption 3.1.4.3 The law of 9 December 2016 on transparency, the fight against corruption and the modernization of the economy, known as the "Sapin II" law, which introduced new measures. Eight pillars are thus prescribed for businesses meeting the criteria of size and annual turnover: a code of conduct, an internal whistleblowing system, a risk mapping, procedures for assessing third parties, accounting controls procedures, a training programme, disciplinary sanctions and internal control procedures to assess the efficiency of the measures. The Code of Conduct Ethics and Compliance The Code of Conduct Ethics and Compliance is the cornerstone of the anti-corruption arrangements required by the law. Integrated with the Company’s internal regulations, it constitutes the reference text for the prevention of corruption, describing the conduct required and setting the rules to be followed by all employees. EDF SA Code of Conduct Ethics and Compliance. Its purpose is to protect employees by clearly setting out what is allowed and what is prohibited, enabling them to identify situations of risk and showing them the proper behaviour to adopt. It aims to ensure the preservation of EDF’s culture of integrity. The Code of Ethical Conduct Ethics and Compliance was delivered to all employees of EDF SA in the second half of 2017. The roll-out of the Code of Conduct Ethics and Compliance was accompanied by a programme of awareness-raising. Whistleblowing system EDF already had a whistleblowing system, but it was reinforced to meet the requirements of the "Sapin II" law (see section 3.1.4.6 "Whistleblowing system"). Risk mapping This instrument allows the Group entities to identify the risks associated with their activities and then to view them on a map of the ethics and compliance risks. Based on this, the entities draw up action plans appropriate to their operational contexts to prevent and mitigate these risks. This work meets the requirements of the regulations applicable to the Group (1) , the recommendations of international (2) organisations, and the best practice identified among groups comparable to EDF.

Integrity checks on business relations Integrity checks on business relations is the subject of a specific memorandum of instructions in application of the Group Ethics & Compliance Policy. Applicable since 1 January 2017, it defines the third party evaluation procedures to be implemented by the Heads of Ethics and Compliance of the entities before any commitment and throughout the course of the relationship. Accounting controls The control procedures defined in EDF are presented in its supporting guide to the fight against fraud accompanying the memorandum of instructions on the fight against fraud of 18 April 2017. The control procedures defined for the various processes (procurement, sales, treasury, personnel, fixed assets-stock, accounting) meet the objective of the "Sapin II" law. Training The Group Ethics and Compliance Division has designed a specific training programme on the prevention of corruption, and provides deployment tools for all employees. (see section 3.1.4.5 "Training and professionalisation of players"). Disciplinary sanctions In the framework of its policy of zero tolerance, any employee of EDF SA breaking the rules laid down by the Code of Conduct Ethics and Compliance is liable to the sanctions provided by Article 6 of the Statutes for Electricity and Gas Industry employees and in the provisions of the French Labour Code. Depending on the circumstances and situations, the penalty may range from a warning to dismissal, including different stages (with or without an entry in the file, with or without suspension, with or without demotion). The internal control and evaluation system In order to make sure of the appropriateness and effectiveness of the measures for preventing and detecting any breach of ethics or failure of compliance, in 2016 the Group Ethics and Compliance Division put in place a dashboard enabling entities to evaluate the degree of deployment of each key requirement. The exercise meets the internal control requirements defined by the Group Ethics and Compliance Policy by allowing the implementation of the measures to be controlled, breaches to be identified and corrective measures established. The Group Ethics and Compliance Policy having established the prevention of the risk of corruption as a priority, the Group Ethics and Compliance Division has defined a specific complementary mechanism for the following two high-risk practices: Guidance on gifts and hospitalities The Ethics & Compliance Policy obliges managers to put in place in their entities a system governing gifts and hospitalities appropriate to their activities. Conflicts of interest The Group Ethics & Compliance Policy obliges Group senior excecutives to implement a system to prevent conflicts of interest and raise employee awareness of hight-risk situations, provide a system for employees to declare their links to bodies in which they have a personal interest (elective mandates, corporate mandates, etc.), and an obligation to withdraw from an activity in the event of a potential conflict of interest. The Group Ethics & Compliance Division has developed internal instruments for raising awareness of all employees to situations of conflict of interest. Compliance with other regulations 3.1.4.4 The EDF group’s Ethics & Compliance Policy covers other compliance subjects or programmes, the operational implementation of which is carried out by expert divisions within the Group. Some of these subjects were completed in 2017 by memoranda of instructions designed to underpin their roll out in the Group’s entities. They relate to financial ethics, the protection of personal data and the fight against fraud. Financial ethics The EDF group’s Ethics and Compliance Policy sets out the requirements to be adhered to prevent market abuse, the risk of money laundering and the financing of

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Federal Corrupt Practice Act in the US, United Kingdom Bribery Act in the UK, Law no. 2016-1691 of 9 December 2016 known as Sapin 2 in France. (1) World Bank, OECD, Organisation for Economic Co-operation and Development, International Chamber of Commerce (ICC), Transparency International. (2)

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EDF I Reference Document 2017