Orano - Annual Activity Report 2024 105 RISKS, CONTROL AND DUTY OF VIGILANCE PLAN 3 Duty of vigilance plan 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. Actions to raise awareness and share feedback on anti-corruption and conflicts of interest are regularly rolled out to all Orano Mining employees, at all its sites worldwide. 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. Orano also raises awareness on climate change issues. For example, since 2021, nearly 800 managers have been trained in the Climate Fresk, including all of the group’s Management Committees. 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. 3.4.4.2 System for collecting and processing ethical reports The group’s whistleblowing system is a secure reporting portal accessible at the following address: https://oranoethic. signalement.net. It is open to all employees, business partners and other stakeholders (internal and external) related to the group who may file a report from within France or abroad. It covers all the topics of the Code of Ethics and in particular the topics of the Sapin II law and the French law on the duty of vigilance. It also guarantees confidentiality in the processing of information and the protection of whistleblowers acting in good faith. Orano was aware of a case of human rights violation in 2024. Details of this case are confidential. To strengthen the relationships of trust established with stakeholders and populations living near its sites, Orano Mining has operated since 2020 a system for the management of claims and complaints on all its sites. It enables any person to express their fears, observations, comments or questions and to obtain a response within a given period. This system, co-developed with the sites, demonstrates Orano Mining’s respect for the concerns of local stakeholders and the group’s desire for transparency. This system is promoted during meetings with stakeholders, via social networks or on the country’s website like in Canada. Each year, Orano Mining reports on the number of complaints recorded in its CSR report. 3.4.5 Monitoring measures and assessing their effectiveness The law on the duty of vigilance requires the publication of a report on the effective implementation of the duty of vigilance plan for the previous financial year. The group has various monitoring systems in place to ensure the effective deployment of the measures set out in the duty of vigilance plan, which cover all of its activities as well as those of the subsidiaries that it controls within the meaning of the law of March 27, 2017. For example, the annual report of the General Inspectorate published on the group’s website lists significant nuclear safety events. The table below shows the group’s main indicators in terms of health and occupational safety; nuclear and industrial safety, and enviromental protection; human rights and fundamental freedoms; and responsible purchasing. The data correspond to the group’s reporting scope.
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