Compliance with other regulations
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
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 terrorism, and those concerning compliance with the European EMIR regulation. A Stock Exchange Ethics Code, updated in February 2017, complements this Policy.
Actions to raise awareness of stock market rules are conducted with Group employees, concerning particularly the precautions and obligations for holders of inside information.
Preventing breaches of competition law
EDF group is making awareness of and adherence to competition law an absolute priority for its employees. With this in mind, the Group has implemented a Competition Compliance Programme since 2010. The programme aims to ensure that all operations of subsidiaries and entities of the Group in France and worldwide comply with competition law. It applies to all Group employees, particularly as regards their relations with customers, competitors, partners and suppliers.
This Competition Compliance Programme covers all aspects of competition law: abuse of dominant position, anti-competitive agreements, concentrations and state aid. The programme entails a number of training sessions, either online or face-to-face. It has given rise to the preparation of numerous training and awareness-raising instruments.
After rolling out an e-learning module between 2010 and 2015 which trained over 5,400 employees, in France and overseas, the Legal Department’s Competition Law Unit devised a new general e-learning competition module with a more interactive format.
This online offering is completed by tailored face-to-face training for some Group subsidiaries and entities.
At the same time, a best practice guide, as well as regular notes and publications on developments in competition law are circulated widely.
Personal data protection
Personal data protection is now governed in France by the “Loi Informatique et Libertés” (Data Protection Act) no. 78-17 of 6 January 1978, as amended. In response, EDF appointed as of 2006 a Personal Data Officer (PDO) responsible for ensuring personal data protection for both customers and employees and for enforcing this law within the Company.
Work has started on preparing the Group for the application from May 2018 of the new provisions of the European General Data Protection Regulation (GDPR).
Compliance with industry regulations
In application of the EDF group’s Ethics & Compliance Policy, the entities concerned must put in place a REMIT compliance system, the purpose of which is to ensure the transparency and integrity of the functioning of the wholesale energy market, notably by prohibiting insider trading based on privileged information and market manipulation.
This Policy also requires entities involved in exporting products on the list of dual-use products appended to EC regulation no. 428/2009 of 5 May 2009 (including exports within the EU) to implement a compliance procedure.
Compliance with international sanctions programmes
The Group Ethics and Compliance Policy requires the directors of Group entities concerned to implement a system to prevent the risk of international sanctions within their entities. The system involves a clause being inserted into each contract entitling EDF to terminate a business relationship with immediate effect in the event of failure to adhere to an international sanctions programme.
EDF has put in place a procedure for checking on the integrity of business relations and in support of this has made tools available for the Heads of Ethics and Compliance to verify that there is no risk of international sanctions. The mapping of these sanctions drawn up by the European Union is posted online on the ethics and compliance intranet.