Orano - Annual Activity Report 2025 106 3 RISK CONTROL AND VIGILANCE PLAN Vigilance plan Contractual commitments Subcontractors and suppliers of Orano are required to comply with the group’s Code of ethics and business conduct. This Code specifies the essential values to which the group adheres and shares with its suppliers and subcontractors. Under its terms, suppliers commit to respect and promote the protection of human rights, labor law (labor standards, fight against child labor, fight against discrimination), and limit their impact on the environment. The group has also adopted a Sustainable Development Declaration that sets out principles regarding human rights, labor standards, health, occupational safety and nuclear safety, environmental protection, and community involvement. It expects its suppliers to adhere to these principles. Orano’s general terms and conditions (“GTC”) set out the obligations and provisions to be complied with in terms of (i) hygiene, safety and protection of human health, (ii) compliance with the environment and sustainable development and (iii) management of chemical substances regulated by the European REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) regulations. They are incorporated into all contracts entered into with suppliers, it being specified that in the event of negotiations to adapt the GTCs, particular attention is given to ensuring that the fundamental principles from which the group does not derogate are included in the special conditions. Orano has adapted its vigilance plan to the Russia-Ukraine conflict Since February 24, 2022, Orano has adapted its vigilance plan in response to the Russia-Ukraine conflict. Beyond the aforementioned measures that constitute its vigilance plan, Orano has ceased all business activities with Russia, except for those essential to preserve non-Russian energy security. For this exception, Orano has developed and implemented a dedicated validation process to ensure strict compliance with applicable international sanctions and the group’s internal policies and commitments. A dedicated internal governance body has been established to oversee compliance with international sanctions. This body includes the General Counsel responsible for export controls and international sanctions, three Orano executive committee members, the group General Counsel, the Chief Financial Officer, and the Chief Customers and Strategy Officer. This governance body ensures that the group complies with its overall strategy regarding international sanctions, which includes compliance with applicable laws and regulations, as well as additional prudential restrictions. A restricted decision-making body (“MOC restreint”) has also been created to analyze all transactions carried out by the group and involving Russia, in accordance with the policy set out above. The analysis of the files and the preparation of the deliberations of this committee is carried out by the General Counsel in charge of export control and international sanctions. The members with voting rights are the three members of the executive committee mentioned above. This committee ensures that the operation is essential for preserving non-Russian energy security, if necessary, requiring certification from the supplier involved in the operation. The opinions of the restricted MOC are essential. No transaction planned in connection with Russia may take place without first obtaining a favorable opinion. As of the date of this document, Orano continues to closely monitor the evolving war in Ukraine. Orano’s Legal Department regularly provides training sessions to raise awareness among employees about applicable sanctions. Additionally, the Export Control and International Sanctions Department has developed practical guidelines for the group’s commercial teams to support them in their operations. 3.4.3 Regular risk assessment To assess and manage the aforementioned risks, the group relies on various organizational and management procedures aimed at ensuring, among other things: ● compliance with standards and regulations; ● design control; ● industrial risk management; ● health and environmental management; ● management of industrial purchases; ● analysis and processing of incidents and accidents; and ● the distribution of shared technical standards across the group’s entities; the application of which is the responsibility of the group’s various departments. In this context, the group audits its suppliers to verify that the operations they carry out comply with Orano’s requirements. Examples include safety reviews before launching new production units to prevent construction-related accidents, technical audits to ensure operations comply with the group’s rules, as well as inspections of industrial sites. Visits and inspections of nuclear and industrial sites The group’s nuclear and industrial sites are subject to internal and external monitoring. Internally, the General Inspectorate aims to provide Executive Management with insight into the degree of control of operations and activities in terms of safety, workplace and industrial safety, radiation protection and the environment. It also examines the robustness of the processes guaranteeing the quality of operations and products manufactured, by ensuring the proper implementation of all the measures defined. It contributes to the achievement of the group’s objectives in these areas by assessing the processes implemented in risk management, control and corporate governance activities, and the level of compliance with regulations and internal directives. It issues, as necessary, recommendations to improve efficiency in these areas. In this context, approximately 30 inspections are carried out every year on the group’s industrial sites, both in France and abroad.
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