Orano - Annual Activity Report 2025 74 3 RISK CONTROL AND VIGILANCE PLAN Risk factors fuels from existing and future nuclear power plants, as well as the decisions of the NPC of March 17, 2025, which confirmed the Aval du Futur program for the renewal of the facilities at the back end of the nuclear fuel cycle at la Hague (1). It is one of the group’s strategic priorities for the coming decades. Notwithstanding the decisions taken at the CPNs, there is currently no legislation enshrining the principles of treatment and recycling, which means there is a risk that regulations that are not in the group’s interests could be adopted at government level, jeopardizing the long-term viability of its treatment and recycling activities. The local and national acceptability of the Aval du Futur program is a key success issue. In this context, Orano plans to organize a national public debate under the aegis of the National Commission for Public Debate (CNDP) at the end of 2027. Two guarantors of the CNDP have been appointed to advise Orano ahead of this public debate. Furthermore, the group remains exposed to the risk related to the financing model of back-end of the cycle activities. The NPC of March 17, 2025 indicates that the Aval du Futur will be financed mainly by EDF. On this basis, a preparatory contract was signed between Orano and EDF to cover the 2025 and 2026 expenses of the Aval du Futur program. Discussions between Orano and EDF are underway for the long-term financing of the program. The outcome of these discussions is a key factor in the continuation of the Aval du Futur program and the timeline for the commissioning of the first facilities in 2038-2040. The articulation between the Aval du Futur program and the Life extension and resilience program is also an issue. For the continuity of the nuclear industry, the Aval du Futur program is necessary to be able to deliver the new facilities before the end of the current plants’ operating period. The results of the studies of the Life extension and resilience program expected in 2026 will help identify the remaining operating lives of the current plants, and thus the risk of discontinuity with the commissioning of the new facilities by the Aval du Futur program. Similarly, the link with the national strategy for the closure of the cycle may represent a risk, in particular in the event that national decisions aimed at accelerating the closure of the cycle could lead to redesigns or result in a plant that is sub-optimal in relation to the needs of the NRR reactors (Fast Neutron Reactors). Lastly, in the context of the development of the nuclear industry and the group in particular, tensions on the supply chain and on key engineering skills could increase and postpone the implementation of this program. Risk management measures The internal governance of the program is now in place, as are the governance bodies with EDF and with the French State. For the sake of efficiency, the decision was made to consolidate project management and project supervision for the ADF program within a single company called Orano-Aval du Futur. The Director of the Aval du Futur program is also a member of the Orano executive committee, in accordance with the recommendations of the Folz (2) report. Regarding financing, discussions between Orano and EDF take place on a weekly basis and a “financing” working group has been created with the French State to report on the progress of the discussions. Periodic meetings are also held with the teams of the Recycling BU, which is in charge of the Life extension and resilience program, as well as with the various stakeholders (EDF, State, CEA) involved in the cycle’s closure strategy. Lastly, the proper allocation of high-level experts between the group’s various projects is a major challenge both for the Aval du Futur and for the proper operation of current facilities. The systems deployed as part of the unified engineering system will address this issue from 2026. An ad hoc, lighter committee must be tested on the project management side. With regard to skills and meeting recruitment targets, various actions have been undertaken, including the signing of several partnerships with companies specializing in nuclear engineering. 3.3.2.3 Risks related to end-of-lifecycle operations Description of the risk As operators of regulated nuclear facilities (installations nucléaires de base, INB) and industrial facilities covered by legislation on environmentally regulated sites (installations classées pour la protection de l’environnement, ICPE), the group’s legal entities have an obligation to ensure the safety and decommissioning of those facilities during their final shutdown, in whole or in part, and/or to restore the sites, and to manage the products resulting from these operations. Future expenses associated with the end-of-lifecycle obligations of nuclear facilities and with the remediation of regulated industrial facilities have been identified, and specific provisions have been constituted by the legal entities which operate those facilities. As of December 31, 2025, these future expenses are provisioned for 8.9 billion euros. The rules related to provisions for end-of-lifecycle operations are described in Note 13 End-oflifecycle operations in Section 6.1 of the Consolidated financial statements. Apart from the financial aspects, the main risks likely to impact the cost of end-of-lifecycle operations relate in particular to: ● identification of discrepancies between the original condition of legacy facilities or legacy waste and their actual condition; ● changes in regulations, particularly with respect to decommissioning, the target final condition of the facilities and soils after decommissioning, the storage solutions used or the requalification as waste of radioactive materials currently (1) Excerpt from the NPC’s press release on the Aval du Futur: “Regarding the processing of spent fuel, the Nuclear Policy Council has confirmed the continuation of investments in the Aval du Futur program led by Orano on the la Hague site. This program includes the storage of spent fuel in a new pool installed in la Hague, which should be commissioned by 2040 in order to meet the needs of the existing nuclear fleet and then the EPR2 units. These facilities will ensure the proper operation of the fleet, as well as the continuation of fuel reprocessing under the best economic and safety conditions, consolidating France’s leadership in the control of all industrial stages of the uranium cycle. The Board also approved the principle of financing this program mainly carried by EDF, as the future customer of these facilities, and of governance led by Orano, involving EDF, the CEA and State services.” (2) Audit entrusted by EDF to Jean-Martin Folz (former CEO of PSA), delivered in October 2019, with the aim of analyzing the causes of cost and time drifts in the construction of the EPR reactor in Flamanville (France).
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