Orano - Annual Activity Report 2025 107 RISK CONTROL AND VIGILANCE PLAN 3 Vigilance plan Externally, industrial facilities are regularly checked by the competent administrative authorities. These authorities are the ASNR for regulated nuclear facilities or the DREAL working under the authority of the regional prefect and under the functional authority of the departmental prefect, missions of control and security of industrial operations for installations classified for the protection of the environment. Insurers also carry out industrial safety inspections to assess the risks of property damage and subsequent operating losses at all of the group’s industrial sites. These inspections contribute to the management of the risks of these facilities. Controls of suppliers and subcontractors As previously indicated, suppliers are required to commit to Orano to respect and promote the protection of human rights and the environment. They are also required to implement safety and security mechanisms, with each supplier committing to continuous progress in these areas. The group’s GTC allow Orano, its customers or any third party commissioned by Orano to access the premises of the supplier for the purpose of inspections or audits to ensure compliance. In the same way, Orano reserves the right to verify, at any time, the compliance of its suppliers’ and subcontractors’ practices with the Code of ethics and business conduct, it being understood that non-compliance with the provisions of the GTC may result in the termination of the order. Strategic suppliers may be audited by each of the Business Units concerned. Contracts are reviewed with suppliers, leading, if necessary, to claims and the application of penalties. For example, within Orano NPS (Nuclear Packaging and Services), the transport supervision unit conducts on-site visits and numerous inspections (both scheduled and unannounced), while CAFs (Manufacturing Project Managers) monitor the packaging manufacturing process directly at the supplier’s site. In accordance with the INB decree (regulated nuclear facilities), Orano’s various Business Units oversee their contractors, with this oversight being duly inspected by the authorities in a proportional manner. The group’s Responsible Purchasing policy also provides for the implementation of field surveys by an independent third party, depending on the geographical areas and procurement segments concerned, in order to identify potential risks of harm to health, safety, human rights and the environment and to enable the implementation of dedicated action plans. 3.4.4 Orano trains its employees and suppliers, and operates a process for collecting and processing reports Orano complies with the provisions of the French law on the duty of vigilance and has deployed a training program for its employees (Section 3.4.4.1) and a system for collecting and processing reports (Section 3.4.4.2). 3.4.4.1 Orano trains its employees and participates in the training of its suppliers The Orano Code of ethics and business conduct is distributed to all employees to raise awareness about the group’s values. This Code is available on the group’s website and intranet and can be downloaded in nine languages. All new employees are required to read it and may refer to it in the event of a situation that appears to be contrary to the principles set out in the Code, whether it is a matter of human rights or other values whose protection is promoted by the group. Orano has also set up an e-learning module called “Our Code of Ethics” dedicated to the proper application of the Code of ethics and business conduct and the group’s rules of conduct, including a knowledge validation test. During their annual review with their manager, employees formally confirm their commitment to respecting the rules of the Code of Ethics, as well as the completion of the online training. The group trains its employees and subcontractors working on its facilities on the group’s risks and rules in terms of health and safety at work and radiation protection. In 2023, Orano trained 250 supply chain participants on the challenges of climate change and the importance of reducing scope 3 greenhouse gas emissions. The group also held 30 meetings with its main contributing suppliers to discuss Orano’s objectives and their actions. The sustainable development Declaration applicable to suppliers was updated and sent to 500 of the group’s suppliers. In 2025, a two-day training session was organized to allow buyers to deepen their knowledge of responsible purchasing with a specific focus on decarbonization.
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