Orano - Annual Activity Report 2024 103 RISKS, CONTROL AND DUTY OF VIGILANCE PLAN 3 Duty of vigilance plan ● sent them questionnaires to collect their concrete actions in 2024 to reduce their carbon footprint as well as their carbon footprint targets for 2030; and ● set up monitoring of the data collected. An action is also underway within the group to integrate the specific emission factors of the suppliers with the highest impact in the calculation of scope 3 related purchases. Contractual commitments Subcontractors and suppliers of Orano are required to comply with the group’s Code of ethics and business conduct and its General Terms and Conditions of Purchasing (hereinafter the “GTC”) derived therefrom, failing which the contractual relationship may be terminated. The group’s Code of ethics and business conduct sets out the essential values to which the group adheres and shares with its subcontractors and suppliers who 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. Regarding the GTC, they 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 to certain specific contracts, particular attention is given to ensuring that the fundamental principles from which the group does not derogate are included in the special conditions. 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 to adhere to these principles. Orano is committed and also imposes a clear commitment on its suppliers and subcontractors to respect the principles of the UN Global Compact, the OECD guidelines for multinational companies and the Extractive Industries Transparency Initiative (EITI). Orano has also been a signatory since 2010 and again since December 2, 2021, upon its reissue, of the “Charter for Responsible Supplier Relations” (http://www.rfar.fr/). By signing this charter, Orano expresses its commitment to implementing a continuous improvement plan with its partners, within a framework of mutual trust and respect for the rights and responsibilities of all parties involved. The charter outlines ten commitments whose aim is to establish responsible business practices between customer/ supplier partners that are conducive to the development of a sustainable relationship. This commitment is further reinforced by the appointment of an internal mediator within the Company, who can be referred to by the group’s suppliers when a situation has not been resolved through amicable negotiation, reachable at at the following email address : G-ORN-MEDIATEUR@orano.group. Regular discussions Orano maintains regular local discussions with its suppliers on the implementation of its industrial policy. Thus, in 2023, a meeting was organized by Orano ChimieEnrichissement with its main suppliers and operational teams (project managers and representatives of the Supply Chain Department in particular) to raise awareness on the industrial challenges of ongoing and future operations covered by Orano Chimie-Enrihissement. This meeting gave rise to numerous discussions, demonstrating the strong involvement of external service providers. Faced with the major issues of the la Hague site, particularly related to “Back End of the Future” program, the site’s management organized an event in May 2024 with its main suppliers called Partners’ Day to “Share tomorrow” and forge new partnerships in order to meet the three major challenges facing the site: the completion of the group’s projects, the decarbonization of purchases and the skills challenge. Orano NPS subject to conflict minerals regulation Orano NPS, as an occasional importer of tungsten, also published its policy in July 2024 regarding the supply chain of minerals and metals that may originate from conflict-affected or high-risk areas. This policy complies with the guidelines of the OECD and European Regulation 2017/821 on the due diligence requirement for gold, tin, tantalum and tungsten importers (available on the Orano website www.orano.group). Orano NPS commits to the following due diligence principles: ● Implementing a traceability and transparency system in its mineral supply chain, particularly for minerals such as tungsten that are likely to come from areas of conflict or political instability; and ● Carring out independent audits of suppliers whenever necessary to ensure compliance with ethical and environmental standards. Orano has adapted its duty of vigilance plan to the Russia-Ukraine conflict Since February 24, 2022, Orano has adapted its duty of vigilance plan in response to the Russia-Ukraine conflict. Beyond the aforementioned measures that constitute its duty of 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 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
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