Orano - Annual Activity Report 2024 102 3 RISKS, CONTROL AND DUTY OF VIGILANCE PLAN Duty of vigilance plan ● Reducing the environmental impact of the group’s purchases; ● Building balanced and virtuous relationships with the group’s partners, promoting diversity and inclusion and contributing to the development of SMEs; and ● Contributing to the development of the industrial sector as well as the economies of the areas in which the group is active. The Responsible Purchasing policy thus consolidates and reinforces all the measures taken by the group to ensure an informed choice of its suppliers and subcontractors. It is available on the Orano website at the following address www.orano.group Identification and evaluation of potentially at-risk suppliers In order to identify the suppliers that may potentially present risks, the group uses three basic criteria: ● the volume of annual purchases; ● the procurement segment; and ● the geographic location of the activity. Based on an external reference framework, the group has identified four countries and eleven at-risk procurement segments, particularly in terms of human rights. This represents 32 suppliers with which the group has an established commercial relationship and on which additional checks are expected to ensure the absence of risks for workers and the environment. In 2024, Orano Mining launched its duty of vigilance approach in Kazakhstan by relying on the supplier risk analysis defined by the group. Suppliers were selected according to the risk criteria defined by Orano, namely the annual volume of purchases made, the procurement segment and the geographical location. An evaluation questionnaire designed by a panel of experts representing various group’s departments was sent to the main suppliers based at the Katco site. A first series of supplier assessments was held locally with the participation of the Internal Control and Supply Chain teams of the local subsidiary and Orano Mining. The meetings provided an opportunity to discuss changes in European duty of vigilance legislation and its application at the Katco site in Kazakhstan with company executives and their employees. It was emphasized that requests for information about suppliers’ employees are an integral part of the process. The first results do not highlight any major risk. Katco is developing a culture and standards in terms of safety, enviromental protection and respect for human rights to help improve its suppliers and comply with Orano Mining’s requirements. To support Katco in the deployment of this approach, a service provider was selected to carry out a detailed study in order to highlight any gaps between the requirements of French law on duty of vigilance and the legislation of the country. The service provider will supplement this study with an in-depth analysis of the purchasing segments most exposed to risks, taking into account the supplier risk analysis of Orano and Orano Mining in order to highlight the main points needing attention. At the end of this phase, the identified suppliers will, if necessary, implement an action plan jointly defined with the teams of Katco and Orano Mining to increase their skills and comply with the requirements of the law on the duty of vigilance. In accordance with the procedure for assessing third-party compliance, which was rolled out together with the Risk, Compliance and Internal Audit Department, any new supplier or any material change in a supplier relationship must be specifically verified and adapted according to the estimated level of risk. Depending on the results obtained, a questionnaire may be sent to the supplier and, if necessary, a study by the Business Intelligence division is undertaken. These measures may lead to the identification of risks of violations of human rights, health and safety of individuals, as well as the enviromental impact. A study of the economic pole is systematically carried out for suppliers with a medium or high risk level. This process ensures that potential compliance risks have notably been identified and that appropriate mitigation measures are implemented. The regular review of third-party suppliers thus enables better prevention of compliance, non-financial and duty of vigilance risks. Integration of social and environmental criteria in tenders In order to make an informed choice, the Supply Chain Department selects its suppliers and subcontractors according to strict criteria. They are based on the methodology developed by the Risk, Compliance and Internal Audit Department, and takes into account tender criteria (compliance with technical, quality, economic and HSE criteria), the associated risk mitigation plan prior to contract award (through selection criteria and supplier qualification audits, and monitoring programs during contract execution), as well as performance measurements and required improvement plans. These criteria may be adapted according to the specific nature of each activity. In France, the North-West Supply Chain has set up support for its suppliers on these CSR initiatives when responding to tenders. It also participates in events dedicated to the energy transition and decarbonization such as the regional event “Cap décarbonation” which took place at the la Hague site in November 2024. Since 2023, the group has introduced three carbon criteria in its selection grids for tenders (decarbonization pathway of the company by 2030, carbon footprint of the contract in question and existence of a low-carbon alternative with potential impacts). The group continued its approach in 2024 to integrate these three criteria across a range of activities within its Business Units. The group also includes societal criteria in its tenders (gender equality index, share of the company’s revenue dedicated to training, existence of a policy promoting diversity and inclusion). In 2024, the group also: ● established a list of its suppliers with the highest impact in terms of carbon footprint;
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