The EDF group’s commitment to ethics and compliance
In order to protect its reputation, the EDF group promotes a culture of integrity and, as a matter of principle, promotes a zero tolerance towards fraud and corruption.
An ethical conduct in accordance with the law must therefore be the absolute rule for all Group employees, worldwide, at all levels of the organisation, without exception.
A Group ethics and compliance programme and a dedicated division
In line with this approach, in December 2015, the EDF group’s ethics and compliance plan was strengthened with the creation of a Group Ethics and Compliance Division and the setting up of a group ethics and compliance programme build up to meet the requirements of national and international regulatory authorities as well as market practices. The programme places all EDF executive directors and more generally all employees at the heart of the compliance system. The programme is signed off by the Chairman and CEO of EDF.
The main missions of the Group Ethics and Compliance Division are to consolidate an analysis of the Group’s ethical and compliance risks, to coordinate the network of Heads of Ethics & Compliance in Group entities, to provide support to executive directors and Heads of Ethics & Compliance for the diffusion of appropriate rules, to develop training and awareness-raising of employees, to oversee the handling of any breach that are detected and produce regular reports for the Group’s governance bodies.
A Group ethics and compliance policy in place since 2016
In 2016, the EDF group Executive Committee adopted the EDF group Ethics & Compliance Policy (PECG), which brings together the main rules that executive directors must imperatively know, observe and enforce within their entities, which are strictly aligned with the risks of these entities.
This is a single document forming the overarching reference for the Group’s Code of Ethics (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 Ethics Charter constructed around the Group’s three values
The previous Group code of ethics, dating from 2013, was no longer in line with the Group’s ambition. An update was necessary in order to adapt it to the Group’s strategic developments and to the new regulatory environment with, in particular, the coming into force of the French “Sapin II” law.
The new Group Ethics Charter reaffirms the Group’s three values - Respect, Solidarity and Responsibility - in order to put ethical requirements back at the heart of corporate responsibility. They contribute to the establishment of a relationship of trust with our partners and promote cohesion within the Group.
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 adapted 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.
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.