Orano - Annual Activity Report 2024 243 SUSTAINABILITY STATEMENT 4 Governance information The purposes of the representation of interests actions carried out in 2024 will specify these elements and will be declared to the HATVP by March 30, 2025. External positions taken in Brussels in favor of the financing of nuclear energy and critical materials Concerning the European regulation for a “Net Zero” industry, Orano requested the inclusion in this regulation of all nuclear technologies, including those of the fuel cycle for current and future reactors (GENII, III, IV) and research, so that they can benefit from all the provisions of the law. Concerning the European Green Taxonomy regulation, the group gave its opinion, according to the EU consultation procedures, on the draft delegated act relating to the four environmental objectives of the taxonomy and on the draft amendment of the delegated act relating to the first two climate objectives. Orano reiterated the importance of including all fuel cycle activities that are essential to the nuclear operations already included (including electricity production) and should therefore be considered as enabling activities or as substantially contributing to a climate or environmental objective, depending on the activity. With regard to the European regulation on critical raw materials, Orano reiterated the importance of strengthening the European Union’s critical raw materials value chain, from mining to recycling, including refining and processing. Orano’s expertise in chemistry, hydrometallurgy and process industrialization can be applied to the recycling of critical raw materials, in particular for electric vehicle batteries. Lastly, Orano is interested in recycling platinum group metals, which are critical materials, recovered from used nuclear fuel. As part of the publication by the European Commission of a communication on the 2040 climate target, Orano gave its opinion. Orano considers that the best option today is a mix including both nuclear and renewable energy to achieve the climate objectives set by the EU. Considering the key role that nuclear energy will play alongside renewable energy in the energy transition by 2040 and beyond, Orano recommends that the European Commission guarantee technological neutrality between all low carbon-emission energy sources. In 2024, the group made no direct or indirect financial political contributions. Indicators ESRS Reference 2019 2022 2023 2024 Financial political contributions made (in million euros) G1-5>29 b i n/a n/a n/a 0 In-kind political contributions made (in million euros) G1-5>29 b i n/a n/a n/a 0 n/a: not applicable. The indicators required by the CSRD Directive are published from the 2024 financial year. Methodological precision: These indicators cover the entire scope of consolidation. 4.4.1.5 A robust anti-corruption and prevention of influence peddling program A robust anti-corruption and influence peddling program is deployed at the level of group-controlled entities and regularly updated. The program promotes a culture of business ethics and transparency through a robust prevention policy based on strict rules of conduct as well as training and awareness-raising actions. Transparency, sincerity, and openness to dialogue accompany this program throughout its implementation, including its supervision by the Board of Directors, the Chief Executive Officer and the Executive Committee. Based on its corruption and influence peddling risk mapping, which is updated each year, and in compliance with the Sapin II law, Orano established a corruption and influence peddling prevention program. The program is overseen and implemented by the Compliance division of the Risk, Compliance, Internal Audit Department, assisted by a network of compliance correspondents. This program is intended for all group employees, managers, and executives and is based on the appropriation and application of rules of conduct, internal policies and procedures, and external laws and regulations. The corruption prevention and detection program is organized around eight pillars: ● the corruption and influence peddling risk mapping, updated annually; ● the Code of ethics and business conduct including the anticorruption rules of conduct and documentation on related policies and procedures; ● awareness-raising among staff in general and targeted training for those exposed; ● the assessment of the compliance of third parties in direct contact with the group; ● the accounting controls and the internal control environment;
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