Orano - Annual Activity Report 2024 104 3 RISKS, CONTROL AND DUTY OF VIGILANCE PLAN Duty of vigilance plan 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 mandatory, meaning that no operation related to Russia can proceed without prior approval. 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. This regular assessment of industrial risks that could affect individuals covers all of the group’s activities in all geographical areas. 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, approximatively 30 inspections are carried out every year on the group’s industrial sites, both in France and abroad. Externally, industrial facilities are regularly checked by the competent administrative authorities (e.g., the French nuclear safety authority for regulated nuclear facilities or the prefect for environmentally regulated facilities). 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 indicated earlier, suppliers must commit to respecting and promoting human rights, environmental protection as well as safety and security of individuals. Each supplier is expected to engage in continuous improvement 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. 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 contract. 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 (Basic Nuclear Installations), 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.
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