EDF_REGISTRATION_DOCUMENT_2017

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

Number of important cases detected

Geographical distribution 2017

Europe excl. France Africa America Asia

France excl. EDF

Total 2017

Total 2015

Total 2016

Theme

EDF SA

Group ethics Charter - Non-respect of persons - Violations of Human Rights

11

23

3 3

2 2

1 1

- - - - - - - - - - - - - - - - - - -

- - - - - - - - - - - - - - - - - - - -

- - - - - - - -

- - - - - - - - - - - - - -

- - - - - - -

- - - - - - -

- - - - - -

- - - - - -

- - - - - -

- Others

Fight against corruption

3.

- Checks on the integrity of business relations

- Control of gifts and hospitalities

Financial ethics

- Prevention of the risk of money laundering and the financing of terrorism

-

-

-

-

-

-

- Prevention of market abuse - Compliance with EMIR

- -

- - -

- - -

- - -

- - - -

- - -

Competition law Conflicts of interest

1

- -

3 1

3 7

2 6

1

Security of personal data

1 2 6

-

Fight against fraud

29 19

23 25

21 26

12 19

4

1

2 1

Harassment & discrimination

- - - - -

Sector regulations

- - - -

- - - -

- - - -

- - - -

- - - -

- - - -

- REMIT

- Controls on export of dual-use goods

International sanctions

60

75

60

41

10

4

0

2

3

TOTAL

implement the tools, reporting and actions necessary for the continued, ■ optimum, forward-looking management of tax cash flows (1) , as well as attentive and proactive monitoring of the Group’s effective tax rate; ensure the conditions necessary for obtaining constructive relations with the tax ■ and government authorities of all kinds by maintaining a transparent, professional relationship with them. Ethical principles In the context of the distribution between countries of operating margins internal to the Group, EDF strives to apply a transfer price policy in accordance with the principles of the OECD to justify the resulting revenues. EDF has no legal implantation (company, branch or office of representation) in a territory listed as a non-cooperative state or territory as defined by French and international legislation which is not determined by economic activity reasons and under no circumstances purely by tax reasons. Similarly, cash flow via these countries is prohibited where it is for tax reasons only. Presence in Luxembourg and Ireland Like all major French and international groups, EDF relies on captive and mutual insurance companies to supplement the cover provided by traditional insurance markets. The captive and mutual insurance companies enable EDF to reduce the cost of its insurance schemes and the total sum of premiums paid. EDF has two captive insurance companies which are based in Ireland and Luxembourg: Wagram Insurance Company DAC Ltd. (wholly owned by EDF), insurance ■ company founded in 2003 in Dublin which is involved in the majority of the Group’s insurance schemes; Océane Ré (EDF 99.98%), a reinsurance company founded in 2003 in ■ Luxembourg to reinsure EDF’s nuclear civil liability risk.

TAX TRANSPARENCY 3.1.5 EDF has implemented a Group tax policy to define the applicable principles, in terms of taxation, to all of the Group’s relations with its financial or business partners and the government or tax authorities. The tax policy is applied by the Group Executive Director responsible for the Group’s Financial Management. It was validated by the Executive Committee in January 2017 (material issue no. 3, business ethics). Group tax policy 3.1.5.1 A wide scope The policy covers all the Group’s taxes: direct and indirect taxes, duties, contributions, tax or customs deductions which are the ultimate liability of the Company or its customers (when EDF merely acts as a collector on behalf of third parties). It must be applied throughout the Group, by all controlled entities regardless of their nature or geographical location, with the exception of regulated infrastructure managers, for whom it constitutes a guide. All Group staff must comply with this policy which aims to protect the Group’s reputation and to reduce any tax risks to which it may be exposed through its activities. Clear directions strengthen the tax performance of the Group in strict compliance with national ■ and international tax laws and regulations; control tax risks through continued, systematic improvement, in all Group ■ entities, of the identification and management of fiscal risks;

Tax cash: tax actually paid or recovered. (1)

153

EDF I Reference Document 2017