EDF SA

France|Electric Utilities & Power Generators|FY2024|Auditor: KPMG SA, PricewaterhouseCoopers Audit|View original report →

ESRS 2General Disclosures

GOV-1The role of the administrative, management and supervisory bodies
Reported

Reference: page 158

Sustainability governance is supervised at the top Group level, respecting the independence of network infrastructure managers. The composition, duties, skills and functioning of EDF's Board of Directors are set out in section 4.2. Within the Board, specialised committees contribute to defining and implementing CSR strategy: the Strategy Committee, the Risk and Audit Committee, the Corporate Responsibility Committee, and a Climate Officer member of the Board. The Risk and Audit Committee and the Corporate Responsibility Committee jointly examine the control, management and monitoring of the Group's sustainability impacts, risks and opportunities. At executive level, governance includes the Executive Committee, the CSR Strategy Committee chaired by the Chairman and CEO, the Sustainable Development Committee, the CSRD Project Governance Committee, the Group Executive Committee Commitments Committee (CECEG), and the Impact Division integrated into the Performance, Impact, Investments and Finance Division. Specific governance covers climate and nature issues, including climate point persons on the Board and the Executive Committee.

GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies
Reported

Reference: page 158

In 2024 the Risk and Audit Committee and the Corporate Responsibility Committee each met three times on sustainability issues. Topics covered included training of directors on sustainability, appointment of the Statutory Auditors certifying sustainability information, the double materiality process, and the process of setting CSR targets. When the double materiality process was presented, the list of significant impacts, risks and opportunities was presented to both committees. These bodies monitor the sustainability reporting process, the effectiveness of internal control, risk management and internal audit systems, the certification of sustainability information, the independence of certification providers, and report regularly to the Board. The Strategy Committee reviewed the Group's climate transition plan in 2024. The sustainability statement and its issues were discussed three times during Board or committee meetings, including the double materiality analysis, the internal control process, and establishment of targets and commitments.

GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemes
Reported

Reference: page 161

In line with EDF's pursuit of integrated performance, the annual variable remuneration of senior executives is based on both financial and CSR criteria. In 2024 EDF strengthened this lever: the weighting of CSR criteria in annual variable remuneration rose to between 9% and 21% depending on entity (versus 9% to 15% in 2023), and in the long-term plan from 20% to 30%. A gender balance criterion was added to the annual bonus, alongside new climate criteria based on Scope 3 and avoided CO2 emissions. Three climate criteria (carbon intensity, Scope 3 emissions, avoided CO2 emissions) represent 30% of the bonus targets within the Group's share of bonuses. Three social criteria cover health and safety (global LTIR), employee commitment, and increasing the number of women among senior executives. A cap of 80% applies to the LTIR criterion in case of a fatal accident. The framework is validated by Executive Management and Remuneration Committees.

GOV-3(was GOV-4)Statement on due diligence
Reported

Reference: page 162

The vigilance plan is included in section 3.6, with cross-references made where relevant. EDF provides a cross-reference table mapping the elements of the due diligence process to the relevant sections of the sustainability statement. Embedding due diligence in governance, strategy and business model is covered by section 3.1.2.1 on the role of governance bodies, section 3.6.2 on governance and stakeholder involvement, section 3.1.3.2 on stakeholder interests, and the whistleblowing system. Engaging with affected stakeholders is addressed through workforce interaction and community dialogue processes. Identifying and assessing negative impacts on people and the environment is covered by section 3.1.4 on the double materiality assessment process and various thematic action sections. Taking action to address negative impacts and tracking the effectiveness of these efforts are mapped to the relevant policies, actions, targets and indicators across the environmental, social and governance sections.

GOV-4(was GOV-5)Risk management and internal controls over sustainability reporting
Reported

Reference: page 163

The Group's risk management and internal control systems are described in section 2.1 of the URD and are deployed and supplemented for sustainability, targeting both double materiality and the security of the information transmitted. The general mapping of the Group's risks, using a multi-criteria methodology, is an input for identifying the impacts, risks and opportunities, and regular iterations ensure consistency between the risk mapping and the IROs. The IRO materiality assessment methodology is consistent with the risk mapping assessment method. For information security, a first-level control system covers data collection and consolidation by entity (collection methods, justification, responsible persons, traceability) and a second-level system led by the Impact Division and Group Human Resources Division ensures data consistency. In 2024 a specific control topic for sustainability information was added to the internal control framework. The voluntary approach implemented in 2024 will be extended in 2025, prioritising the most significant data and entities.

SBM-1Strategy, business model and value chain
Reported

Reference: page 164

As a responsible operator and supplier, the EDF group positions itself as a major player in the ecological transition and energy sovereignty. All Group activities fall under a single major ESRS sector, the Energy sector. The Group employed 191,444 people worldwide in 2024, including 151,135 in France, 32,957 in the rest of Europe and 7,352 in the Americas. Activities range from construction, operation and decommissioning of nuclear, hydro, solar, wind and thermal power plants, to electricity networks, marketing and supporting customers in energy savings, across the whole value chain in France and internationally. The synthetic value chain is based on 11 value chains (nuclear, thermal, wind, solar, hydropower, electrochemical storage, cooling, heat, hydrogen, energy services, and marketing of electricity and gas). The Group is in contact with around 150,000 active suppliers. Strategy is described in section 1.3.2 and the business model in section 1.1.

SBM-2Interests and views of stakeholders
Reported

Reference: page 168

Dialogue with stakeholders is a major part of EDF's culture and the basis of its CSR policy. The Group's stakeholders contributed to identifying and assessing the impacts, risks and opportunities in the double materiality analysis, and their expectations and interests are considered in the Group's strategy and objectives. The raison d'etre, adopted in 2020 by 99.99% of the General Meeting of Shareholders, was developed with more than 4,000 employees and internal stakeholders were systematically consulted when setting targets. The Group has an overall stakeholder map approved by the Executive Committee. The main stakeholders are employees, customers, civil society (local communities, NGOs, press and media), public authorities, financial partners and business partners, with their main expectations and means of dialogue identified. The Group relies on external stakeholder councils, including the Stakeholder Council of 13 civil society figures, which was consulted when the double materiality analysis was prepared.

SBM-3Material impacts, risks and opportunities and their interaction with strategy and business model
Reported

Reference: page 170

The double materiality analysis identified 27 material sustainability issues that already influence the Group's strategy; the analysis revealed no previously unrecognised issues. A sustainability issue is material when at least one related IRO is material, and all issues listed are treated to the same high standards. EDF treats all ESRS topical standards as material: Climate change (E1), Pollution (E2), Water and marine resources (E3), Biodiversity and ecosystems (E4), Resource use and circular economy (E5), Own workforce (S1), Workers in the value chain (S2), Affected communities (S3), Consumers and end-users (S4), and Business conduct (G1). Detailed tables describe each material impact, risk and opportunity and its location in the value chain (upstream, own operations, downstream). Most IROs are material over all three time horizons. The IROs guide the Group's actions under its Ambitions 2035 corporate plan, which rests on four pillars: supporting customers, producing more low-carbon electricity, developing networks, and finding flexibility solutions.

IRO-1Description of the processes to identify and assess material impacts, risks and opportunities
Reported

Reference: page 179

EDF has relied on a materiality analysis since 2014 and launched the review of its double materiality analysis in 2023 per CSRD requirements. The analysis considers both financial materiality (issues generating risks or opportunities affecting the financial position over the short, medium and long term) and impact materiality (actual or potential positive or negative impacts on people and the environment). The process, validated and conducted by the Impact Division, included six phases across three steps: capitalisation on existing assets, identification of IROs, and assessment of IROs. EDF reviewed 78 internal and external documents and held more than 17 interviews and workshops with over 50 participants. IROs were assessed against materiality thresholds defined with the Group Risk Division, rating probability and severity (or magnitude of financial effects) on a scale of 1 to 5; an IRO with absolute severity is material, and others are material if a combined score exceeds the defined threshold. Gross and net levels are distinguished. Stakeholders, including the Stakeholder Council and the CSRD Project Governance Committee, reviewed the ratings.

IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Reported

Reference: page 184

The annexes include a list of disclosure requirements met (section 3.1.5.1), mapping each ESRS 2 and topical disclosure requirement to the section of the report where it is addressed or marking it not applicable. The information to be published was determined according to the methodology in section 3.1.4 on the double materiality assessment process. Additional information on governance, actions, indicators and targets for the IROs is provided at the beginning of each standard. A table of all data points arising from other EU legislation is referenced in section 3.1.5.2, and an ESRS benchmark by sustainability issue (section 3.1.5.3) links material issues to the subtopics and sub-subtopics of the ESRS. EDF also provides a cross-reference table (section 3.1.4.2) between the material IROs and the main risks in section 2.2 of the URD, confirming that each negative impact and each risk in the CSRD sense corresponds to a risk in the risk mapping, although this does not itself meet a CSRD publication requirement.

E1Climate Change

E1-1Transition plan for climate change mitigation
Reported

Reference: page 198

EDF's climate transition plan, approved at the 12 May 2022 General Meeting and updated by the Board of Directors in 2024, structures the Group's climate ambition. It targets Net Zero emissions across all activities by 2050, covering Scopes 1, 2 and 3 and all geographic regions, based on a reduction of at least 90% of direct and indirect emissions and neutralisation of residual emissions through high-integrity carbon sinks. The Group's carbon trajectory, strengthened in 2023, was validated by Moody's as compatible with a 1.5C warming scenario. The plan rests on three pillars: developing the use of low-carbon electricity and energy efficiency, generating more low-carbon electricity (nuclear and renewables), and adapting infrastructure to physical risks. EDF relies on scenarios compatible with the Paris Agreement, including IEA WEO 2024 scenarios (STEPS, APS, NZE) and the French National Low Carbon Strategy (SNBC), and follows the UN HLEG recommendations on net-zero commitments.

E1-4(was E1-2)Policies related to climate change mitigation and adaptation
Reported

Reference: page 199

EDF reports policies covering both climate change mitigation and adaptation. Mitigation policies aim to develop a new energy model emitting less CO2 through three areas supported by the highest governance levels (climate officers on the Board and Executive Committee): a Net Zero Emissions ambition backed by an ambitious carbon trajectory; developing the use of low-carbon electricity, energy efficiency and innovative energy services (target of 150 TWh of additional electricity demand in France by 2035 vs 2023); and generating more low-carbon electricity from nuclear and renewables. The Group also acts as a 'Responsible gas company' to support gas customers toward carbon neutrality. The adaptation policy (section 3.2.2.2) commits the Group to evaluate climate change impacts, adapt existing facilities, incorporate climate scenarios in new installations, and adapt operations. Most-exposed entities must prepare a climate adaptation plan updated every five years, approved by the CSR Strategy Committee.

E1-5(was E1-3)Actions and resources in relation to climate change policies
Reported

Reference: page 209

EDF implements an action plan coordinated with its Carbon Neutrality Strategy project. Actions to reduce direct emissions include strategic disposals of carbon-intensive assets, coal discontinuation (phase-out by 2027 in Europe and 2030 worldwide), greening of heating networks, decarbonisation of islands (replacing fuel oil with liquid biomass), SF6 and HFC emission reductions, and CO2 capture and storage. In 2024 nearly 94% of the Group's investments, i.e. 25 billion euros, went to decarbonised technologies (64% nuclear, 23% networks, 11% renewables, 2% energy services). Resources invested in climate change mitigation amounted to 24 billion euros, including 23 billion euros in low-carbon generation, 176 million euros in fossil-fuel decarbonisation, 170 million euros in greening heating networks, and 199 million euros in energy-efficient uses. In 2024 EDF spent 752 million euros on R&D, 88% on climate mitigation. Over 2025-2027 the Group plans to invest 77 billion euros, at least 95% in decarbonised activities.

E1-6(was E1-4)Targets related to climate change mitigation and adaptation
Reported

Reference: page 213

EDF's targets define a trajectory compatible with 1.5C. Scope 1 (2017 baseline of 51.3 MtCO2e): -60% by 2025 (20.0 MtCO2e), -65% by 2027 (18.0 MtCO2e), -70% by 2030 (15.5 MtCO2e), -80% by 2035 (10.5 MtCO2e). Carbon intensity targets: 30 gCO2/kWh by 2030 and 22 gCO2/kWh by 2035 (37 in 2023, 30 in 2024). Scope 3 (2019 baseline of 119.4 MtCO2e): -30% by 2027, -35% by 2030, -45% by 2035. Overall Net Zero across all three scopes by 2050, implying at least -90% of direct and indirect emissions. On SBTi: in December 2020 SBTi validated the Group's 2030 targets on a Well Below 2C trajectory (50% reduction of Scope 1 and 2 vs 2017; 28% reduction of gas-combustion Scope 3 vs 2019). The Group chose not to submit its new (raised) objectives to SBTi pending a change in SBTi methodology, which it considers penalises already-decarbonised utilities.

E1-7(was E1-5)Energy consumption and mix
Reported

Reference: page 218

Total energy consumption in 2024 was 91,779,630 MWh LCV (sum of Scope 1 and Scope 2 entities). Total fossil fuel consumption was 74,708,138 MWh, giving fossil sources an 81.4% share of total energy consumption (natural gas 60,770,891 MWh, petroleum products 11,904,719 MWh, coal 1,411,310 MWh, other fossil 621,218 MWh). Energy consumption from nuclear sources was 4,422,281 MWh, a 4.8% share. Energy consumption from renewable sources (biomass, biogas and wood meeting sustainability criteria) was 12,649,211 MWh, a 13.8% share. Energy intensity was 786 (total energy consumption per Group sales/turnover excluding trading). EDF notes that the uranium used in its power plants is not counted as final energy, and that these own-consumption indicators are considered less relevant for an integrated energy company whose decarbonisation role extends well beyond its own consumption.

E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissions
Reported

Reference: page 211

In 2024 the EDF group's GHG footprint was: Gross Scope 1 emissions 16.8 MtCO2e (down 11% from 18.9 MtCO2e in 2023). Gross Scope 2 emissions 0.66 MtCO2e on the country/location-based approach (up 136% from 0.28) and 0.65 MtCO2e on the supplier/market-based approach (up 44% from 0.45); Scope 2 represents 0.7% of the footprint. Gross Scope 3 emissions 73.3 MtCO2e (up 1% from 72.5), of which gas sales to end customers (Scope 3.11 combustion) 38.0 MtCO2e. Total GHG emissions were 90.7 MtCO2e under both the country approach (90,736,178 tCO2e) and the supplier approach (90,732,965 tCO2e), down about 1% from 91.6/91.8 MtCO2e in 2023. The value-chain split was Scope 1 18%, Scope 2 0.7%, Scope 3 81%. Of Scope 1, 66% (11.1 MtCO2) resulted from regulated emission trading schemes.

E1-9(was E1-7)GHG removals and GHG mitigation projects financed through carbon credits
Reported

Reference: page 216

In 2024 EDF financed emission reduction and absorption projects via carbon credits amounting to 1,070 tCO2e (27% reduction projects, 73% sequestration projects; 73% Label Bas Carbone, 27% Gold Standard/Verra VCS; 73% in the EU; 0% subject to a corresponding adjustment). EDF plans to withdraw emission reduction units from the Chambord forestry project totalling 18,075 tCO2e certified, of which about 5,000 tCO2e meet the regulatory obligation under the Carbon Offsetting Fund. No contribution was made to EDF's Carbon Offsetting Fund for 2024 as facility emissions stayed below regulatory thresholds. The Net Zero commitment involves cancelling carbon credits to neutralise residual emissions by 2050, up to a maximum of 10% of the Group's emissions in the reference year, around 16 MtCO2e per year from 2050. EDF favours 'negative emissions' sequestration projects (natural solutions and BECCS) screened against the iC-VCM Core Carbon Principles. The Group also reports avoided emissions of 13.4 MtCO2 in 2024.

E1-10(was E1-8)Internal carbon pricing
Reported

Reference: page 224

EDF uses an internal carbon price to guide investments, corresponding to a shadow price modelling the actual expected price of the EU-ETS allowance, applied to investment decisions in new generation capacities and to strategic reviews via impairment tests of existing assets in geographies with a public carbon policy (EU-ETS, UK-ETS). The carbon price range currently used by EDF in its scenarios is around 40 to 190 euros per tCO2 by 2040, with a median price of 150 euros per tCO2. In 2024, 66% of the Group's Scope 1 emissions were covered by ETS1. The scenarios are built from parameters including GDP growth, raw material prices, technology costs and climate/energy regulations (Fit-for-55, RePower EU, SNBC), drawing on IEA modelling and Potsdam Institute (PIK) studies. For asset-valuation impairment tests at end-December 2024, the prices used were 130 (2023) euros/t for 2030, 170 euros/t for 2040 and 210 euros/t for 2050. EDF anticipates an internal carbon price for gas sales under ETS2, operational in 2027.

E1-11(was E1-9)Anticipated financial effects from material physical and transition risks and potential climate-related opportunities
Omitted

E2Pollution

E2-1Policies related to pollution
Reported

Reference: page 227

EDF's pollution policies are set out under section 3.2.3.1 "Policies related to pollution control". The Group is committed to limiting its environmental footprint across the life cycle of its facilities by minimising use of natural resources, ensuring responsible land management and contributing to sustainable water management. These commitments sit within its CSR policy, implemented by the CSR Strategy Committee. EDF controls discharges to air (NOx, SO2, dust), water and soil through compliance with environmental regulations and its Environmental Management System (EMS). The policy spans the facility design stage (environmental impact analysis shared with authorities, use of best available techniques), normal operation (regulatory compliance, control and environmental monitoring, continuous improvement to eliminate or substitute chemical substances such as CMR products), incident management, and post-operations (decommissioning and soil remediation). The approach applies to the entire Group.

E2-2Actions and resources related to pollution
Reported

Reference: page 229

Actions on air discharges (NOx, SO2, dust) focus on transforming the thermal generation fleet, which represented around 6% of Group electricity generation in 2024. New combined cycle gas facilities adopt best available techniques for energy efficiency above 60%, emitting less NOx, SO2 and dust. The two transformation actions with significant impact are converting island thermal facilities to low-sulphur bioliquids (reducing SO2) and phasing out coal by 2030 (2027 in France). In 2024 bioliquid tests at Vaires showed positive effects on CO2 and SO2; the new Presenzano plant in Italy uses "H" technology with over 60% efficiency. For soil pollution, EDF invests in remediation; Edison in Italy is carrying out corrective actions on 36 sites across 16 areas, and applies a "zero phyto" approach. On research expenditure, the Group identified no significant pollution prevention spending in 2024 but contributed 12 million euros through R&D to pollution control.

E2-3Targets related to pollution
Reported

Reference: page 229

Targets relating to discharges of pollutants into the air (NOx, SO2, dust) are set out in section 3.2.3.2.2. Emissions from EDF's generation sites are governed by local or national regulations, with site-specific emission limit values. The Group considers it not relevant to translate site emission limits into exhaustive generic targets, since combustion facility operation varies greatly year to year with the overall electricity system balance. However, because EDF is among the French energy sector companies emitting sulphur oxides under E-PRTR, the Group set a specific target: reduction of SO2 emissions by 75% in 2035 (reference year 2019, reviewed annually, scope the Group's thermal power and heat production facilities). The 75% SO2 flow reduction is to be achieved in 2035 with no intermediate target and is a voluntary commitment. For NOx and dust, EDF already met its commitment to reduce emissions by 50% between 2005 and 2020, including closure of 700MW oil-fired units.

E2-4Pollution of air, water and soil
Reported

Reference: page 229

Indicators on pollution of air, water and soil are reported in section 3.2.3.2.3 for the three main atmospheric pollutants from the Group's thermal generation fleet (reviewed annually, scope the Group's thermal power and heat production facilities). For 2024: SO2 was 10 kt (down from 11 kt in 2023), NOx was 28 kt (up from 26 kt in 2023), and dust was 3 kt (unchanged from 3 kt in 2023). NOx rose about 6% versus 2023, linked to increased production from certain thermal generation facilities in island systems and internationally. The initiated conversion of island thermal facilities to bioliquids contributes to the SO2 reduction, expected to reach 10 kt in 2024. Assessment methods for these pollutant flows include measurement and calculation, aggregated at Group entity level then at Group level on an annual basis. Other discharges to water and soil were not assessed as material.

E2-5Substances of concern and substances of very high concern
Not Material
E2-6Anticipated financial effects from pollution-related impacts, risks and opportunities
Omitted

E3Water and Marine Resources

E3-1Policies related to water and marine resources
Reported

Reference: page 233

Water policies are described in section 3.2.4.1 "Policies related to water resources". As a responsible user and major player in water resource management, the EDF group is committed to helping preserve water resources to enhance environmental resilience and satisfy uses in a concerted and sustainable manner, in line with its CSR policy implemented by the CSR Strategy Committee. The commitment is reflected in four main areas: optimising water use in quantity and quality across sites and the value chain; ensuring the resilience of territories through transparent and responsible water management and positive contribution to the large water cycle; active involvement in water governance at river basin scale and the search for compromises in water management; and developing the skills, know-how and partnerships needed while raising employee awareness. The policy aligns with the UN Sustainable Development Goals, the EU Water Framework Directive, and the French government's 2023 resilient water management action plan.

E3-2Actions and resources related to water and marine resources
Reported

Reference: page 235

Actions on water withdrawals and consumption are set out in section 3.2.4.2.3. In France the Group defined water management plans for its main freshwater-using entities (nuclear and thermal fleet, Framatome, Dalkia) and launched a Group-wide water sobriety working group in 2024. For cooling circuits, R&D studies water recovery and dry cooling, with an Infinite Cooling experiment underway at the Bugey nuclear site (first results expected 2025); future EPR2 river sites will use dry coolers. For industrial processes, actions include better quantifying uses (Rhone sites to get flow meters by end 2028, Golfech water flow mapping started 2024), avoiding freshwater via seawater desalination (Flamanville, Jarry Sud) and unconventional water (Framatome Montbard used over 14,000 m3 of rainwater in 2024, 74% of needs), and recycling and reuse (Martigues reused 25,000 m3 in 2024; Framatome Jarrie reused 1.4 million m3). The Group contributed 18 million euros of R&D to water protection in 2024.

E3-3Targets related to water and marine resources
Reported

Reference: page 237

Water targets are set out in section 3.2.4.2.4. The main target concerns water consumption of cooling circuits of electricity generation sites: keeping water intensity per kWh of electricity generation below the threshold of 0.9 L/kWh (reference year 2016, reviewed annually, Group scope). In 2024 the indicator stood at 0.86 L/kWh, below the threshold; the threshold was reduced by 0.05 L/kWh from the 0.95 L/kWh set in 2016. This is a voluntary target. For water withdrawal for industrial processes, the Group is working on establishing a future voluntary reduction target, consolidating targets already set in certain entities (nuclear and thermal fleets, Dalkia, Framatome). For multi-use water management, the target is meeting demand to support low-water levels at 100% (annual review, EDF Hydro scope); the target was met in 2022, 2023 and 2024, delivering an average of more than 465 Mm3 per year over the last 10 years under the Act4nature commitments.

E3-4Water consumption
Reported

Reference: page 237

Water indicators are reported in section 3.2.4.2.5. The Group withdraws approximately 13 billion m3 of freshwater, of which 97% is returned directly to the original environment. In 2024 the Group consumed 442 million m3 of freshwater for cooling nuclear and thermal generation facilities (445 million m3 including salt and brackish water), 17% more than the 377 million m3 in 2023, in line with increased nuclear power generation in France. Freshwater consumption at sites in high and very high water-stress areas was 32 million m3, i.e. 7% of the Group's freshwater consumption. The Group withdrew 43 million m3 of water for industrial processes in 2024, mostly from surface water or third-party networks. Around 1,100 million m3 of water was reused in 2024 (54% of withdrawals for the main condenser of closed-circuit plants). Water intensity by turnover was 0.004 m3/euro, and water intensity per kWh was 0.86 L/kWh.

E3-5Anticipated financial effects from water and marine resources-related impacts, risks and opportunities
Omitted

E4Biodiversity and Ecosystems

E4-1Transition plan on biodiversity and ecosystems
Reported

Reference: page 240

EDF describes its biodiversity strategy and the resilience of its business model. Its activities interact with terrestrial, aquatic and marine environments, and the Group acts on its most significant impacts and dependencies aligned with the major pressure factors on biodiversity, aiming to reduce its contribution to those pressures, recreate spaces favourable to biodiversity, and strengthen knowledge sharing. It relies on R&D and engineering skills and facility monitoring programmes. The Group is working on the resilience of its strategy in relation to biodiversity as part of its commitment to TNFD Early Adopter 2026, using TNFD tools. Material impacts identified through the 2023/2024 double materiality analysis include degradation of ecosystems, improvement of ecosystems, impact via upstream resources, and biodiversity loss, with a political and regulatory risk. The net zero ambition is treated as inseparable from promoting biodiversity.

E4-2Policies related to biodiversity and ecosystems
Reported

Reference: page 241

The Group's CSR policy outlines commitments within direct and indirect scope on biodiversity and ecosystems. To limit its environmental footprint across the life cycle of facilities, EDF acts responsibly toward land it holds or holds under concession, limiting soil artificialisation and sealing, optimising land value, and promoting multiple land uses. It ensures sustainable biomass supplies, committing to increase wood from PEFC- or FSC-certified forests, and ensures no forest disappears for its energy needs. In 2023 the Group renewed two voluntary schemes: "Entreprises engagees pour la nature" (under the French Biodiversity Office, OFB) and "act4nature international" (under EPE), with objectives to reduce pressure factors, recreate favourable spaces, enhance and share knowledge, and transform processes and skills. Commitments were recognised in October 2024 as meeting "It's Now for Nature" criteria. The ocean and seas policy is not distinct from policies for other ecosystems.

E4-3Actions and resources related to biodiversity and ecosystems
Reported

Reference: page 242

EDF seeks to reduce negative impacts and generate positive ones across direct operations and the value chain. Since 2014 it has been involved in voluntary contributions to the French National Biodiversity Strategy. Actions span improving and sharing knowledge (environmental monitoring of nuclear sites by EDF teams and bodies such as IFREMER and ASNR, hydrobiological monitoring at thermal sites, submarine monitoring of wind farms), R&D involving nearly 200 researchers and around 50 scientific partners across the BIODIV, REES, CACTUS and Environmental Footprint projects, reducing contributions to pressure factors via the mitigation hierarchy and recycling artificial land for new infrastructure, and restoring and preserving natural environments. Examples include over 250 fish migration schemes in France, low-flow drought support, avifauna collision and bat mortality measures, sustainable biomass procurement (Dalkia supplies 2.4 million tonnes of wood in 2024), and the commitment to preserve and restore 12 sites between 2023 and 2025.

E4-4Targets related to biodiversity and ecosystems
Reported

Reference: page 247

As a signatory of Business for Nature campaigns for COP15 and COP16, EDF aims to contribute to a Positive Nature world (2050 ambition of the Kunming-Montreal Global Framework). Following materiality and feasibility analysis, the Group is considering setting up a target for the restoration of natural spaces and will re-examine new targets once the LEAP-inspired analysis and biodiversity tools are concluded. Its current target, linked to the material positive impact of improving ecosystems, is to preserve and restore on a voluntary basis 12 sites between 2023 and 2025 (per act4nature international commitments), with reference year 2023, annual review, scope EDF SA; 6 sites were achieved in 2024. The 2025 target was set without ecological thresholds. The Group is considering a medium-to-long-term target covering more entities, contributing to the Kunming-Montreal framework aim of conserving and restoring 30% of terrestrial, aquatic and marine areas.

E4-5Impact metrics related to biodiversity and ecosystems change
Reported

Reference: page 247

EDF reports impact metrics and resources allocated to biodiversity. The resources invested by the Group in biodiversity and ecosystem actions amounted to 104 million euros in 2024, mainly: 89 million euros on distribution networks (notably burying structures), 4 million euros on hydropower facilities (new dam crossing facilities for fish farming continuity), and 11 million euros on new nuclear site preparation. Avoidance, reduction, offsetting and support actions on major projects (EPR2 Penly, Saut-Mortier, EDF Renewables) amounted to 8 million euros. The annual cost of hydroecological monitoring is around 2.9 million euros and radioecological monitoring around 1.9 million euros. In 2024 the Group contributed at least 9 million euros to improving biodiversity knowledge through R&D. The 2024 progress indicator for the voluntary commitment was 6 sites preserved and restored against the 12-site (2023-2025) target.

E4-6Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunities
Omitted

E5Resource Use and Circular Economy

E5-1Policies related to resource use and circular economy
Reported

Reference: page 248

EDF makes optimal use of natural resources consumed across its value chain a core component of corporate responsibility, with compliance on waste of all kinds an essential element. The Group's CSR policy aims to develop the circular economy approach and improve recycling of waste produced. It seeks to promote a circular economy from the design phase of major projects via eco-design analysis; limit conventional waste production and promote reuse, recycling and recovery of products and equipment throughout the value chain, including for parts during decommissioning; secure sustainable biomass supply using certified forests and forestry by-products; and assume responsibility for radioactive waste, decommissioning French nuclear plants safely while optimising and managing radioactive waste and developing treatment channels to reduce stored volumes. EDF has built assets to secure long-term financing obligations. Measures are applied per principles of subsidiarity and proportionality across business lines and subsidiaries.

E5-2Actions and resources related to resource use and circular economy
Reported

Reference: page 249

The Group has embarked on improving efficiency and optimising incoming resources, including optimising fuel needs and responsible raw material management. For fossil fuels it uses high-efficiency gas combined cycles, renewable and recovered resources (Dalkia supplying heating plants with renewable biomass), and optimises existing facilities (SEI obtained ISO 50001 certification for seven thermal sites). It develops renewables and is phasing out fossil fuels (EDF Energy closed its last coal plant in 2023). For raw materials, the "On Deck" approach led by DCN aims to decarbonise the fuel cycle with suppliers. The circular economy is integrated into responsible purchasing via a carbon and resource questionnaire, life cycle sheets, and a reuse guide. Activities include life cycle analyses, eco-design in the EPR programme (low-carbon concrete and steel, reuse of excavated soil), and Dunkirk industrial ecology (1.3 TWh recovered heat annually, 1.5 Mm3 water saved, 43 kt CO2 avoided).

E5-3Targets related to resource use and circular economy
Reported

Reference: page 250

The Group uses raw materials, with fuels (uranium, gas, fuel oil, bioliquids, biomass) accounting for a significant proportion. In 2024 fossil fuel consumption decreased: coal (-23%), heavy fuel oil (-20%), and natural and industrial gas (-14%), reflecting the Group's commitment to reducing fossil fuel use. To date, EDF has not established a quantitative target for the consumption of strategic fuels and materials. Main risk management actions, described under operational performance risks (risk 1E on operational continuity of supply chains), help maintain an acceptable risk level. Strategic materials are subject to prospective scientific monitoring by the Group's R&D and Strategy Division, covering resource availability, supply chain and medium-term economic dimensions. In France EDF participates in external working groups with public authorities, academic institutions, BRGM and OFREMI to improve understanding of strategic materials at European and global levels.

E5-4Resource inflows
Reported

Reference: page 250

EDF reports materials consumed (resource inflows) for 2024. Nuclear fuel loaded in the reactor was 1,126 tonnes (France scope; 999 in 2023, 779 in 2022), of which 99 tonnes (10%) were components or secondary materials. Liquid and solid biomass excluding wood was 268 kTonnes (112 in 2023). Wood was 2,548 kTonnes (2,396 in 2023). Coal was 189 kTonnes (247 in 2023). Heavy fuel oil was 502 kTonnes (631 in 2023). Domestic fuel oil was 506 kTonnes (465 in 2023). Natural gas was 60,150 TWh LCV (69,675 in 2023). Industrial gas was 355 TWh LCV (372 in 2023). Biogas was 514 TWh LCV (387 in 2023). The Group monitors material consumption across industrial sites via business-line tools, using protocols established with competent authorities and subject to regular checks within the environmental management system.

E5-5Resource outflows
Reported

Reference: page 251

Resource outflows and circular economy practices focus on recycling, reuse and recovery of products and materials. Recycling of used nuclear fuel saves around 10% of natural uranium (via MOX at equilibrium) and up to 25% when reprocessing is fully operational; treatment reduces radioactive waste volume by a factor of four to five and radiotoxicity by a factor of ten. The planned Technocentre at Fessenheim will recycle very-low-level (VLLW) metals, with French recyclable metal sources of about 500,000 tonnes (about 200,000 held by EDF, 200,000 by Orano); commissioning is scheduled for 2031. In 2024, Fessenheim steam generator parts processed in Sweden recovered 600 tonnes of metal. EDF Reutiliz reuse platform avoided 9,003 tonnes of CO2 equivalents in 2024, with 471 tonnes of equipment reused (5,010 tonnes since 2021); Enedis tracked reuse of 488 tonnes. Wind turbine structures are 90% recyclable (95-98% including foundations), and coal ash is recovered for cement and concrete.

E5-6Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities
Omitted
E5-5(was E5-5-Waste)Waste
Reported

Reference: page 254

Waste indicators for 2024. Total conventional waste produced was 1,334,899 tonnes (502,513 tonnes in 2023); the rise was driven by more dam sediment, increased Enedis network activity, first EPR2 Penly earthworks, and the addition of the Hinkley Point C site. Total non-disposed conventional waste was 1,200,902 tonnes. Total waste disposed was 133,997 tonnes. Total non-recycled waste was 389,991 tonnes, equal to 29% of the total. Total hazardous waste was 90,686 tonnes (66,447 in 2023). For radioactive waste (France): VLLW was 6,031 m3 (6,451 in 2023), LILW was 6,603 m3 (5,298 in 2023), and HLW was 284 m3 (261 in 2023); United States Framatome class A waste was 807 m3 and United Kingdom radioactive waste was 589 m3, giving a total radioactive waste of 14,314 m3. The waste recovery target is 90% of conventional waste directed to a recovery industry by 2030 (88.4% in 2022; 90% in 2024).

S1Own Workforce

S1-1Policies related to own workforce
Reported

Reference: page 287

EDF describes its workforce policies anchored in the 2025-2030 global master agreement on Social and Environmental Responsibility, signed on 27 January 2025 with 18 trade unions and two global federations (IndustriAll Global Union and ISP). The agreement covers all employees of companies under EDF control and commits the Group to respect for human rights and ILO standards. Sub-policies include corporate social responsibility, a health and safety prevention policy updated in April 2024, a skills development policy (Groupe France, updated 2022), and a policy combating discrimination and promoting inclusion of disabled people, parents and against sexism and violence. Long-term social welfare follows principles of responsibility, ownership and balance between competitiveness and sustainability.

S1-2Processes for engaging with own workforce and workers' representatives about impacts
Reported

Reference: page 288

EDF engages its workforce through social dialogue and surveys. The MyEDF group survey conducted by IPSOS in November 2024 received 136,318 responses. Employee representative bodies include the consultation and coordination body (ICCE), Social and Economic Committees, the France Group Committee (FGC, set up 2008, 28 employee representatives, met four times in 2024) and the European Works Council (EWC, established 2001, 38 representatives, met twice in 2024). For parent company EDF SA, the 2024 mapping included 48 establishment SECs and a Central SEC. The CDRS serves as the main forum for dialogue with representatives on the duty of vigilance, meeting around three times a year including one plenary session.

S1-2(was S1-3)Processes to remediate negative impacts and channels for own workforce to raise concerns
Reported

Reference: page 290

Employees can use the Group's whistleblowing system, set up under the Sapin II and Duty of Vigilance laws, which guarantees anonymity and is available in the Group's six languages. The system enables the reporting of acts contrary to laws and regulations, crimes or misdemeanours, breaches of the EDF Code of Conduct, breaches of an international commitment, and threats or serious harm to the general interest. Whistleblowers may also use other channels available to them such as managers, human resources, employee representatives, local ethics and compliance officers and mediators. EDF Renewables uses the Group's Grievance Mechanism, and local grievance systems are set up for certain large international projects.

S1-3(was S1-4)Taking action on material impacts on own workforce
Reported

Reference: page 292

EDF takes action on workforce impacts across training, health and safety, and diversity. On skills, the Group invested nearly 664 million euros in 2024, providing nearly 7.9 million hours of training, and launched the Skills project (2023) to plan resources over 10, 5 and 3 years. On health and safety, the Group deploys the 10 life-saving rules, psychosocial risk prevention with a 24/7 Listening and Support platform, exoskeletons for musculoskeletal disorders, and annual Safety STOP events. On diversity, actions include recruiting women in technical professions, the disability agreement, combating sexism and violence (toll-free hotline, STOP sexist violence tool), and support for parenthood and family caregivers. EDF assisted 164 employees who were victims of domestic violence in 2024.

S1-4(was S1-5)Targets related to own workforce
Reported

Reference: page 295

EDF reports a limited number of formal targets. For health and safety, the Group set an overall Lost Time Injury Rate (LTIR, employee plus supplier) target of below 1.7 in 2024 and below 1 in 2030, reviewed annually at Group scope. For gender balance, the Group targets 40% of women among the Group's executives by the end of 2030, alongside a common target of 33% women across all hierarchical levels by 2026 and between 36% and 40% by 2030. EDF notes that for certain material impacts no specific improvement targets have been set, with only disclosure of results planned; the Group training policy planned for 2025 will help establish a future training target.

S1-5(was S1-6)Characteristics of the undertaking's employees
Reported

Reference: page 286

The EDF group's consolidated workforce totalled 191,444 employees as of 31 December 2024, a 6.6% increase versus 2023. By region, 151,135 employees were in France (up 5.9%), 32,957 in Europe excluding France (up 8.7%), and 7,352 in the rest of the world (up 13.2%); 96% of the global workforce is European and 79% based in France. By country, France had 151,135 employees and the United Kingdom 19,165. By gender, there were 140,663 men, 50,625 women, 0 other and 156 not declared. By contract type at 31 December 2024, permanent contracts covered 132,860 men and 46,776 women, and fixed-term contracts covered 7,803 men and 3,849 women; employees on non-guaranteed hours numbered 450 men and 46 women.

S1-6(was S1-7)Characteristics of non-employee workers
Omitted
S1-7(was S1-8)Collective bargaining coverage and social dialogue
Reported

Reference: page 289

EDF reports collective bargaining coverage based on the ratio of employees benefiting from a collective agreement to the physical workforce at 31 December, at Group scope. In 2024, 86.1% of employees were covered by a collective bargaining agreement, rising to 93.9% in the European Economic Area, 94.3% in France, and 38.0% outside the EEA. France is the only EEA country where the Group has more than 10% of its total workforce. Social dialogue is conducted through representative bodies (SECs, Central SEC, FGC, EWC, CDRS) and the global Social and Environmental Responsibility master agreement, with each Group company recording the number of employees benefiting from a collective agreement once a year through its HR department.

S1-8(was S1-9)Diversity metrics
Reported

Reference: page 299

EDF reports diversity metrics covering gender split and women in management. Of the total workforce at the Group, there were 140,663 men and 50,625 women as of 31 December 2024. On women in management, as of 31 December 2024 the EDF group employed 304 women executives, representing 26.7% of the Group's executives, up from 24% at the end of 2023, against a target of 40% women among executives by the end of 2030. At EDF SA, 31.4% of the 10% most senior positions were held by women, up from 30.6% in 2023. By age group, 32,664 employees (17%) were under 30, 105,887 (55%) were 30 to 50, and 52,893 (28%) were 50 and older.

S1-9(was S1-10)Adequate wages
Reported

Reference: page 291

EDF reports on adequate and fair wages through its total remuneration policy, described as an essential lever for performance and attractiveness. The Group is committed to offering employees fair and competitive remuneration, while paying close attention to the level of social welfare it provides, particularly cover against the major risks of life. The overall remuneration policy is guided by four principles: competitiveness with the external market, internal equity and consistency, financial sustainability, and readability for employees and managers. The policy is based on fixed remuneration and individual and/or collective variable remuneration recognising the achievement of objectives connected to the companies' economic results, ensuring consistency of job remuneration with the market.

S1-10(was S1-11)Social protection
Omitted
S1-11(was S1-12)Persons with disabilities
Reported

Reference: page 299

EDF reports on persons with disabilities, describing itself as a pioneer in the professional and social integration of disabled people, committing to go well beyond legal requirements. The 12th EDF agreement for equal rights and the occupational inclusion of disabled people was signed on 11 January 2023 for the 2023-2025 period. By the end of 2024, the Group employed 8,096 individuals with disabilities, a sharp increase compared with 7,054 in 2023 and 6,791 in 2022; this represented 4.2% of the workforce in 2024 (compared with 3.9% in 2023 and 4.0% in 2022). At EDF specifically, 2,997 employees with disabilities were employed in 2024, representing 4.4% of its workforce. The 2023-2025 agreement included a renewed Quality of Life at Work survey covering 2,584 employees with disabilities.

S1-12(was S1-13)Training and skills development metrics
Reported

Reference: page 293

EDF reports on training and skills development. The Group invested nearly 664 million euros in 2024, providing nearly 7.9 million hours of training and professional capacity-building. The average number of training hours per employee at the Group was 41.4 hours in 2024, up from 40.5 hours in 2023 and 38 hours in 2022. The increase is mainly attributed to the training of new hires and increased recruitment in 2024. Nearly a quarter of training hours consumed were delivered digitally (EDF SA figure), through platforms such as Powerskills and EDFLEX (which offers more than 50,000 resources in more than 25 languages). The average training hours per employee is calculated as total annual training hours divided by employees present at year-end.

S1-13(was S1-14)Health and safety metrics
Reported

Reference: page 295

EDF reports health and safety metrics. The overall Lost Time Injury Rate (LTIR, EDF plus service providers) was 1.6 in 2024, against a 2024 target of below 1.7 and a 2030 target of below 1; the LTIR was 1.9 in 2022 and 1.7 in 2023. On fatalities in 2024 at Group level: 1 death from accidents directly related to professional activities (employees), 2 deaths from work-related illnesses (employees), and 2 deaths from accidents directly related to professional activities (service providers). At EDF SA in 2024 there were 410 recordable work-related accidents for employees and 537 for service providers, with work-related accident rates of 4.3 for employees and 5.9 for service providers. The rate of employees covered by the health and safety management system was 34.6%.

S1-14(was S1-15)Work-life balance metrics
Omitted
S1-15(was S1-16)Compensation metrics (pay gap and total compensation)
Reported

Reference: page 301

EDF reports on pay gap and total remuneration. The gender pay gap, defined as the difference in average pay between male and female employees expressed as a percentage of the average pay of male workers, was 1.8% in 2024. The material scope includes all employees of the main EDF group companies in France (EDF SA France, Enedis, Framatome France and Dalkia France) and in the United Kingdom (EDF Energy), approximately 153,670 employees, representing more than 80% of the Group's workforce worldwide. On total remuneration, the pay ratio of the highest-paid person to the median total annual remuneration of all other employees was 26.5 in 2024. The professional gender equality index for EDF reached 95 out of 100 in 2024 (in respect of 2023).

S1-16(was S1-17)Incidents, complaints and severe human rights impacts
Reported

Reference: page 284

EDF reports on serious cases, complaints and human rights impacts. In 2024, 449 admissible alerts were recorded (including 93 in the Group whistleblowing system); 335 related to incidents in France and 114 abroad; 45% related to harassment or discrimination, with 16 dismissals pronounced for proven harassment. There was 1 admissible human rights alert (concerning a worker in the value chain). EDF states there were no serious human rights incidents in 2024 (one alert is still being processed). On harassment and discrimination, compensation paid by EDF in 2024 under final court decisions amounted to 35,000 euros for harassment and 18,000 euros for discrimination. The OECD-defined human rights violations tracked include discrimination, harassment, forced labour, human trafficking, child labour, unsafe working environments and denial of freedom of association.

S2Workers in the Value Chain

S2-1Policies related to value chain workers
Reported

Reference: page 303

EDF's policies for value chain workers rest on the Group's human rights commitments, which apply to all employees and business relationships, including suppliers and subcontractors. Guidelines published in 2021 set out fundamental requirements on human rights, health and safety, and ethics, signed by the Chairman and CEO. A responsible supplier policy systematically includes health and safety, environmental, social and human rights clauses in agreements. EDF was an early signatory of the Responsible Supplier Relations and Purchasing Charter and holds the RFAR label, obtained in 2015 and renewed in 2024 for three years, backed by ISO 20400. The CSR charter between EDF and its suppliers, updated in 2023, commits suppliers to ILO conventions, the UN Global Compact, UNGP and OECD guidelines. A Code of Conduct governs the contracting process. In the United Kingdom EDF maintains a Modern Slavery Statement covering employees and procurement.

S2-2Processes for engaging with value chain workers about impacts
Reported

Reference: page 304

Dialogue with value chain workers is structured through the Group's global Social and Environmental Responsibility master agreement, covering all Group employees and subcontractors. A responsible subcontracting policy provides visibility to service providers and develops socially responsible practices, supported by the Global Framework Agreement on CSR signed on 27 January 2025 and the Responsible Subcontracting Agreement signed on 19 October 2006. CSR Agreement commitments are monitored by the global CSR Committee, with a committee of signatory trade unions meeting twice a year. EDF holds continuous discussions with civil society stakeholders specialising in human rights and participates in meetings with companies, lawyers, NGOs and trade unions through the non-profit Entreprises pour les droits de l'homme (EDH). Since 2022, recognised human rights specialists have been members of the Group's Stakeholder Council, co-chaired by EDF's Chairman and Cecile Renouard.

S2-2(was S2-3)Processes to remediate negative impacts and channels for value chain workers to raise concerns
Reported

Reference: page 305

Value chain workers can raise concerns through several channels. Since 2010 EDF has had a company ombudsman who can be contacted directly by suppliers, free of charge, via the mediator's website or by post. Suppliers and their employees can also use the Group's whistleblowing system, set up under the Sapin II and Duty of Vigilance laws, which guarantees anonymity and is available in the Group's six languages. It allows reporting of breaches of laws, the EDF Code of Conduct, international commitments, or serious harm to the general interest. Knowledge of these alert channels by value chain workers can be verified during on-site audits at suppliers' sites, carried out by external independent providers. Remedy procedures involve in-depth joint analysis between EDF and the supplier; external audits may be carried out, with follow-up audits to verify corrective actions. Persistent failure can lead to contract suspension or termination.

S2-3(was S2-4)Taking action on material impacts on value chain workers
Reported

Reference: page 306

EDF manages impacts and risks through its responsible purchasing approach, structured by the Group Purchasing Division, which has managed the function since April 2024. The approach rests on four pillars: identifying purchasing category risks and opportunities, integrating CSR levers at all purchasing stages, supporting suppliers, and monitoring CSR performance. Each purchasing entity maintains a CSR risk mapping that feeds the Group's vigilance plan. Levers include compliance commitments from bidders, the CSR charter, contractual audit and penalty clauses, and CSR selection criteria. Supplier support includes qualification, contractual assessments and on-site audits. The CSR Suppliers Club brought together around 100 companies, with about 60 partners in collective intelligence workshops. Around 350 suppliers were surveyed through the ACESIA platform in 2024. In 2024 almost 32% of audits carried out were outside France, mainly in China and Morocco. Fuel supply chain controls cover uranium, coal, gas and biomass.

S2-4(was S2-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reported

Reference: page 311

In 2025 the purchasing function plans to standardise the criteria for assessing responsible purchasing performance through three pillars: equipping the purchasing functions, onboarding suppliers, and measuring the impact of the value chain. A target on supplier support is being defined in 2025 to integrate the contributions of all entities in the purchasing sector. For 2024, the reported indicator on supplier support covers the number of qualifications, audits and assessments including a CSR or Health and Safety component, reviewed annually, with a Group target being defined. Results for the scope of EDF SA, Dalkia, Edison and Framatome were 31 audits and 3,633 assessments. Other indicators are currently being standardised and instrumented, as the purchasing function adopted performance indicators in 2024 to manage the deployment of responsible purchasing across Group entities.

S3Affected Communities

S3-1Policies related to affected communities
Reported

Reference: page 313

EDF's policies for affected communities commit the Group to respecting the rights of local communities and indigenous populations affected by its activities. These commitments are covered by the Group's human rights commitments (sections on human rights commitments and the rights of affected communities) and by the Group's Corporate Social Responsibility policy through its commitment to territorial responsibility. The Group is committed to protecting the rights of local communities affected by its operations and to arranging transparent, debated discussions and consultations for each new facility project over 60 million euros in funding with a significant impact on territories or the environment. Specific commitments address indigenous populations, respecting their specificities and rights. The Group also commits to contributing to regional development through local jobs, local purchases, economic value creation and tax payments, and in developing countries to access to energy and the development of low-carbon energies.

S3-2Processes for engaging with affected communities about impacts
Reported

Reference: page 314

Dialogue and consultation are core social commitments of the EDF group. The Group organises a transparent, adversarial process of dialogue and consultation around each new project worldwide, involving local and indigenous communities throughout the project life cycle. For all projects worth more than 60 million euros, EDF uses a societal approach based on the Equator Principles for stakeholder identification and participation. Specific informed consultation of indigenous peoples may require Free, Prior and Informed Consent (FPIC). In France, dialogue is structured through EDF organisations and a Department of Territories and Regional Action (DTAR), and major projects may be subject to public debates under the National Commission for Public Debate (CNDP). The Group develops skills for managers, shares experience through an intranet site, and draws on R&D with 30 years of expertise in local acceptability. Internationally each subsidiary rolls out the Group's dialogue principles locally.

S3-2(was S3-3)Processes to remediate negative impacts and channels for affected communities to raise concerns
Reported

Reference: page 315

Systems to collect and handle complaints, alerts, warnings and claims have been set up at Group level and are accessible for each project, alongside the Group's whistleblowing system. These systems are accessible to any person potentially impacted by the Group's activities and guarantee the confidentiality of alerts and callers. At the international level, each project sets up a request and complaints management mechanism (RCMM). In Malawi, the Mpatamanga 361MW hydropower project established a mechanism allowing stakeholders to submit requests in person, by phone, SMS, WhatsApp, post or email, handled through Group Village Grievance Redress Committees; since the project started, 20 complaints have been received, of which 19 were resolved and one was still in process at the end of 2024. In Oman, the Manah I 500MW solar project uses a dedicated WhatsApp number and an HSE-managed register, with complaints handled by a multi-lingual team.

S3-3(was S3-4)Taking action on material impacts on affected communities
Reported

Reference: page 317

Actions to manage risks and opportunities for communities span health and safety, project consultation and local development. The Group develops the highest standards in nuclear and hydropower safety and addresses pollution and biodiversity impacts via ESRS E2 and E4. In France, public debates under the CNDP were held in 2024 for the Gravelines EPR2 reactors and the Fessenheim Technocentre, with EDF committed to responding to questions within 15 days for Gravelines and 8 days for the Technocentre. Other projects include the Vouglans-Saut-Mortier hydropower project and the Ricanto 130MW bioenergy plant in Corsica. Internationally, projects use Stakeholder Engagement Plans, such as Nachtigal in Cameroon (420MW), where more than 140 meetings were held. On local development, more than 95% of purchases are made in France and 97% in the European Union; EDF pays over 1 billion euros annually in local taxes and supports around 374,000 jobs in France, including nearly 65,000 direct jobs.

S3-4(was S3-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reported

Reference: page 318

EDF is currently considering setting a target in relation to the IROs for 2025. For projects over 60 million euros examined by the CECEG with a significant impact on regions or the environment, the Group's key performance indicator is the annual proportion of such projects for which a dialogue and consultation process has been initiated, meaning each project has initiated or implemented a dialogue and consultation strategy taking local and indigenous communities into account. This indicator, with a target of 100% and a 2021 reference, reached 100% in both 2023 and 2024 for the scope of CECEG-examined projects. A second indicator measures the local purchasing rate for EDF SA, calculated for the first level of the subcontracting chain, with a target to be defined in 2025; it was 94.5% in 2023 and 95.4% in 2024. The indicator may change in 2025 to include all the Group's subsidiaries.

S4Consumers and End-Users

S4-1Policies related to consumers and end-users
Reported

Reference: page 319

EDF maintains policies for its 34.9 million electricity and 6.6 million gas customers worldwide. Material consumer issues are electricity continuity and supply, personal data protection, and social inclusion and energy poverty. EDF's public service commitments, set out in the Public Service Agreement of 24 October 2005 with the French State, focus on ensuring continuity of electricity supply, including for customers on regulated tariffs. EDF renews its commitment to customers facing energy poverty through public solidarity mechanisms and specific initiatives. Privacy and personal data protection commitments are formalised in an instruction note attached to the Group's Ethics and Compliance and Information Systems Governance policies, ensuring compliance with the GDPR (EU Regulation 2016/679).

S4-2Processes for engaging with consumers and end-users about impacts
Reported

Reference: page 321

EDF customers benefit from several methods of dialogue with Group entities. Digital resources broaden access to information; in 2024 EDF consumption monitoring tools, including the EDF & MOI app, recorded 210 million visits from 7.4 million unique users. With 5,000 France-based customer advisors, the Individual Clients Market Department supports customers from subscription through to understanding and managing invoices. Enedis rolled out an information system to alert customers about scheduled load shedding via interactive voice server, website, email or SMS. On energy poverty, EDF engages through some forty Pimms mediation points and works with social services and charities. On personal data, interactions are handled across all communication channels, with customers encouraged to use EDF's digital platforms.

S4-2(was S4-3)Processes to remediate negative impacts and channels for consumers and end-users to raise concerns
Reported

Reference: page 321

Customer complaints are treated as opportunities to restore confidence and improve processes. For contract disputes, customers may submit an oral or written complaint to Customer Service, then escalate to the internal appeal body, and then refer the matter free of charge to EDF's Consumption Mediator (referenced by the CECMC). If the dispute is unresolved within two months, the customer may refer it to the National Energy Mediator. In the 2024 Energy Mediator report, EDF reported a rate of 44 disputes per 100,000 contracts, placing it fourth. For distribution disputes, complaints may be sent to Enedis or Strasbourg Electricite Reseaux. Out-of-court settlement is optional, and customers may refer matters to the competent courts at any time.

S4-3(was S4-4)Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions
Reported

Reference: page 325

EDF takes action to manage energy poverty and protect personal data. On energy poverty, EDF deploys 230 solidarity experts and more than 3,000 partnerships, with 5,000 customer advisors trained to detect hardship. It contributed 224 million euros to the French Housing Solidarity Fund in 2024. Since 1 April 2022, EDF replaced cut-offs for unpaid residential bills with a 1kVA power limitation; in 2024, 427,000 customers were affected by a power limitation. Programmes include Toits d'abord, Territoire zero exclusion energie, Info Watt, and the Agir Plus offers. On data protection, an annual compliance control plan is presented to Group Governance, all customer advisors receive training, and the DPO submits biannual reports to the Executive Committee.

S4-4(was S4-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reported

Reference: page 322

EDF tracks targets and indicators for consumer issues. For electricity continuity, the key indicator is the average annual outage duration (SAIDI, Criterion B). The CRE regulatory target for Enedis in interconnected zones is 62 minutes; in 2024 Enedis recorded 71.6 minutes, exceeding the target, mainly due to climatic hazards. For non-interconnected zones the target is 220.2 minutes; EDF SEI recorded 264.1 minutes in 2024. For combating energy poverty, a new indicator tracks the number of non-payment power limitations avoided versus implemented: in 2024, 426,938 limitations were implemented and 398,612 avoided (mainland France, EDF SA and ES); a target is to be defined in 2026. For personal data protection, a target and indicator are still being considered.

G1Business Conduct

G1-1Business conduct policies and corporate culture
Reported

Reference: page 330

EDF promotes a culture of integrity and applies a zero-tolerance policy towards fraud and corruption. The Executive Committee determines the orientations of the ethics and compliance programme, and the Board's Corporate Responsibility Committee oversees its incorporation. The Group Ethics and Compliance Division, reporting to the General Secretary, coordinates the programme with a network of around 50 Ethics and Compliance Officers. The Group Ethics Charter sets out three values, Respect, Solidarity and Responsibility. There are thirteen compliance programmes, including preventing corruption and influence peddling, conflicts of interest, fraud, and the duty of vigilance. An Ethics and Compliance Code of Conduct sits within the internal rules. Whistleblowers are protected through the Group's whistleblowing system, open to employees and third parties.

G1-2Management of relationships with suppliers
Reported

Reference: page 332

EDF deploys a Responsible Purchasing approach applying the Group's CSR policy to all subcontractors. The purchasing sector includes around 2,100 buyers working with around 150,000 active suppliers and addressing a total purchasing volume of 30 billion euros. The Group Purchasing Department manages the function while respecting the management independence of network operators. Each buyer signs a mandatory ethical undertaking. Strategic managers manage relations with main contractual partners through regular reviews, risk analyses and progress plans. Specific measures help SMEs access EDF markets through the Pacte PME association. The quality of supplier relationships is validated by the RFAR label, which EDF has held since 2015. For nuclear suppliers, EDF relies on ISO 19443 certification, with nearly 200 French suppliers already certified.

G1-2(was G1-3)Prevention and detection of corruption and bribery
Reported

Reference: page 334

Under the 2016 Sapin II Law, EDF runs an anti-corruption compliance programme. It maintains a specific corruption risk map (since 2018, methodology improved in 2020), a third-party integrity control system, accounting controls, an internal evaluation system, and a conflict-of-interest prevention system. The Group Ethics and Compliance Division develops training for all staff and third parties. E-learning includes an interactive Code of Conduct course in two versions (All employees and Exposed employees), with 8,270 participants in 2024, plus a Preventing corruption and influence peddling module. In 2024, 71.6% of employees exposed to corruption risk in the Group's main subsidiaries received training; full Group scope recognition was limited by the 2024 reorganisation and will be covered in 2025.

G1-4Incidents of corruption or bribery
Reported

Reference: page 334

EDF tracks indicators on corruption, namely the number of convictions for acts of passive or active bribery attributable to individuals or legal entities, the amount of fines for breach of anti-corruption legislation, and remediation measures taken for non-compliance and incidents of corruption. In 2024, there were no convictions for corruption offences involving legal entities or individuals. Because no incidents were confirmed, information on remediation measures and the involvement of value-chain players is reported as not applicable. Remediation measures, where relevant, would include awareness-raising actions, amendment of prevention procedures and reinforcement of controls to prevent repetition.

G1-5Political influence and lobbying activities
Reported

Reference: page 336

Lobbying activities are governed by the Group Responsible Lobbying Charter and comply with the Group Ethics Charter, with activities the responsibility of each entity's management. EDF undertakes to align all direct and indirect lobbying with the Paris Agreement's 1.5C objective. Key climate positions are validated by the Public Authorities Relations Management Committee, chaired by the director of public and international affairs, which meets weekly. EDF is registered as an interest representative with the French HATVP and on the EU Transparency Register (no. 39966101835-69). EDF provides no financing to political parties in France. In 2024, only EDF Renewables made payments in the United States: US$87,150 in Political Action Committee contributions and US$270,500 in Corporate Contributions.

G1-6Payment practices
Reported

Reference: page 333

The Group complies with regulatory payment terms in the countries where it operates to prevent deterioration of suppliers' financial health, and offers initiatives such as collaborative invoicing and a reverse factoring system. In France, the target average supplier payment period is based on the LME Law, a maximum of 60 calendar days. In 2024 the average time to settle supplier invoices was 60 days in France, 42 days in the United Kingdom, 38 days in Italy, and 46 days in Belgium. In France, French entities apply a 60-day contractual period for about 79% of annual invoices by value. The Group reported three ongoing legal proceedings concerning late payments, none with a significant impact on the Group's financial position as of 31 December 2024.