EDF_REGISTRATION_DOCUMENT_2017

3.

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

Actions designed to mitigate risks and 3.1.6.3.3 prevent serious damage For environmental risks, the EMS is permanently monitored and continuously improved; personnel training and stakeholder awareness-raising programmes are in place. As well as inspections, audits and crisis drills are conducted regularly at the production sites. For risks attributable to our suppliers, the responsible procurement approach allows action plans to be put in place in the light of the results of the self-assessments and audits, in order to correct the non-conforming issues identified. In the event of a serious breach, the contractual relation may even be terminated. By way of example we may refer to the ICOVET project, which involves working together with all the suppliers of workwear in order to better identify the environmental, social and economic risks, opportunities and stakes using a life-cycle approach. In 2010 EDF signed the Responsible Supplier Relations Charter, and in 2015 it obtained the “Responsible Suppliers and Purchasing” label. One of the objectives set is the improvement of our suppliers’ CSR performance, particularly in sharing our commitments vis-à-vis their subcontractors. The subsidiaries (Dalkia, EDF Energy, etc.) also have mechanisms for integrating social and environmental criteria into their contracts. With regard to coal, EDF is a founding member of Bettercoal, an initiative launched in 2011 that brings together energy providers, port institutions and coal-fired terminals. It is a mechanism that aims to promote CSR in the coal supply chain, particularly at mining sites, and to ensure that the fundamental rights (human rights, working conditions, workers’ and communities lives, protection of the environment, etc.) are respected. EDF Trading’s coal trading and freight business was acquired by JERA Trading (JERAT) in April 2017. With the coal purchasing contracts being taken over by JERAT from 2018, and JERAT joining Bettercoal, EDF decided not to renew its membership in 2018. EDF, which was one of the founder members of Bettercoal, remains an active promoter of Bettercoal and has expressed the wish that its supplies continue to be covered by Bettercoal. As for uranium, EDF mainly obtains its supplies through diversified contracts in terms of sources and suppliers. In order to ensure good environmental, social and societal conditions for the extraction and processing of the mineral, in 2011 EDF initiated a system of mine audits based on a method developed with the WNA (World Nuclear Association) consisting of a standardised framework and recognised by all players in the sector. It takes account of the issues of human rights and fundamental freedoms: human rights, register of warnings, rights of indigenous peoples, freedom of association. The question of safety in the context of mining is given particular emphasis (safety of process, protection from radiation), and the environment is taken widely into account, notably as regards matters relating to water, biodiversity, waste and the rehabilitation of sites after exploitation. EDF carries out at least two audits per year. Following the audits, monitoring is carried out. The clauses listing EDF’s expectations in terms of enforcement of the fundamental rights and main international standards by suppliers and sub-contractors have progressively been inserted in contracts signed by EDF. EDF envisages developing self-assessment tools to round out its arrangements. Lastly we may note that the introduction of the vigilance plan will be the subject of awareness-raising with regard to environmental questions and respect for human rights, the first priority being to address management and the positions most directly concerned, such as buyers and auditors. It will find expression in particular in enhancement of the training programmes on responsible procurement, human rights and the environment, notably by making e-learning modules available to all personnel in France and in the subsidiaries. A mechanism for issuing warnings and 3.1.6.3.4 picking up signals relating to the

Risks associated with human (1) rights and fundamental freedoms are assessed by reference to the countries in which the Company, its subsidiaries and its suppliers operate. Particular attention is paid to projects in countries at risk. EDF Energy has also carried out a risk mapping of the risks of forced labour, which it has reported in its statement as required by the UK Modern Slavery Act 2015. Regarding health and safety risks, this concerns first and foremost the risks affecting our employees and service providers (accidents at work, occupational diseases) and our suppliers’ employees, but also potentially neighbours and local communities. For French and international projects, risks are identified by sifting for projects of more than €50 million examined by the Group Executive Committee’s Commitments Committee (“CECEG” in the French abbreviation). The international management was also involved in analysing the compliance of all its new and most advanced projects with the IFC’s performance standards on environmental and social risk management. Apart from this, EDF Énergies Nouvelles projects financed by green bonds or development banks are the subject of reporting to the financiers on social and environmental matters. The section on responsible procurement (3.5.7 "Responsible purchasing") sets out the details of the system implemented by the Group Procurement Department for identifying and controlling risks in the supply chain. The risks are assessed by means of a system for evaluating the purchasing segments (16 of the 253 are considered major risks and 33 high risk), self-assessment questionnaires (at the end of 2017, 1,500 suppliers had been questioned and 730 assessed and checked) and targeted audits (51 in 2017). The subsidiaries (Dalkia, EDF Energy, etc.) also have mechanisms for integrating social and environmental criteria into their contracts. Among the suppliers at risk not handled by the Procurement Department we also identify the suppliers of fuel (coal, oil, uranium, etc.) For example, for uranium the risks identified concern the environment and the protection of employees from radiation. EDF Energy has also carried out a study of the risks associated with conflict minerals. Procedures for regular evaluation of the 3.1.6.3.2 In 2016 and 2017, the EDF group reviewed and completed all the Group policies (some 40 of them) to which all the controlled entities and subsidiaries are subject. We note in particular the policy on Governance and equity interests, one of the principles of which is strict compliance with applicable regulations as well as with Group policies. It is rounded out by the policy on Control of Integrity in business relations (particularly partners and suppliers), the Ethics and Compliance Policy, the Group Procurement Policy, the Group Sustainable Development Policy (including respect for the environment and human rights) and the Group Health & Safety Policy (which applies to all persons involved in its activities). All the requirements of these policies are currently included in the internal control system and the performance reviews. For environmental issues, the Group has put in place a coordination system overseen by a Sustainable Development Committee and implemented a Group EMS which has been ISO 14001 certified since 2002. The performance of the entities and subsidiaries is assessed annually with the aid of internal control and performance review questionnaires. They are the subject of an action plan (see section 3.1.8.2 "Management and prevention of environmental risks"). Furthermore, the CSR Goals are now integrated into the strategic loop. For checking on suppliers and subcontractors, the responsible procurement approach (see section 3.5.7.3"Assessment of suppliers") also includes self-assessment questionnaires, which are checked, and audits. In the event of non-compliance, an action plan is drawn up with the supplier. Implementation of the required corrections is monitored. situation of subsidiaries, subcontractors and suppliers with whom established commercial relations are maintained, as regards the mapping of risks

existence or materialisation of risks, established in consultation with the representative trade union organisations in said company

In order to respond to the requirements of the Sapin 2 law, EDF has further developed its existing ethics and compliance whistleblowing system: a single mechanism for all signals covered by the Sapin 2 law and wherever possible (2) by the Duty of Vigilance law, should be made available to all Group employees in

By way of example, risks identified included the risk of forced labour in the transport of fuel-oil and the risk of violation of the rights of indigenous peoples in the context of (1) industrial projects. Subject to authorisation by the CNIL (French data protection authority) for opening the system to the outside. (2)

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EDF I Reference Document 2017