Orano - Annual Activity Report 2024 247 SUSTAINABILITY STATEMENT 4 Governance information To adapt the responses to the risk levels, Orano has divided the markets into three categories using a “hazard analysis”. Suitable risk criteria have also been defined as regards compliance and anticorruption. The level of the activity’s risk determines the list of suppliers invited to bid and the measures to be taken for contract follow-up and operational supervision to ensure the control of subcontractor HSE and sustainable development requirements. Moreover, the Purchasing Manager and the specifier must factor in the economic and ethics aspects, as well as fair competition practices, specifically by: ● promoting competition, plurality of responses, and the emergence of alternative offers; ● allowing all companies matching the bid requirements to respond without discrimination; ● applying the reciprocity principle, i.e., requiring of suppliers what the organization requires of itself; and ● valuing the suppliers and bids that are the best fit with the organization’s activities. When identifying needs, they must factor in the local situation, the impact on jobs and the local economy and social criteria when adapted (such as during calls for proposals for the most risky markets). Specific measures relating to subcontracting at our facilities The Supply Chain Unit helps the group’s Health – Safety – Environment (HSE) Department issue a report on the state of outsourcing in France, which is sent to the French Ministry with oversight. This report is also transmitted to the French nuclear safety authority (ASN) and the French institute of radiation protection and nuclear safety (IRSN). It reports on the inclusion of HSE requirements in the purchasing process, as well as on the monitoring of authorizations, training and awareness programs for outside companies operating on Orano sites. For activities in isolated territories and sites, Orano Mining makes an inventory of the health organization of subcontracting companies (occupational medicine, mandatory vaccinations, first aid training, healthcare, infirmary, equipment, health evacuation plans). In addition, in order to guarantee the same quality of monitoring as that of its employees, dosimetric monitoring of categorized subcontractors can be carried out by the Orano subsidiaries themselves. Sapin II law and duty of vigilance The Orano group’s Supply Chain Management System integrates the duty of vigilance and corruption prevention plan into these processes (RFI (Request for Information)/RFQ (Request for Quotation) and Supplier evaluation and monitoring). The various documents and processes making up the supply chain management system (Code of Ethics, GTC, purchasing policy, sustainable development commitment, etc.) take into account: ● the risk analyses by Purchasing market (“Hazard Table”) and by country (see Orano internal “Country Compliance Classification” procedure); ● the plan for mitigating the associated risks before awarding contracts (through supplier selection criteria and qualification audits, and monitoring programs during contract fulfillment); ● the supplier performance metrics and the required improvement plans; ● the ethics, sustainable development commitment, and corruption prevention aspects in contract clauses, in compliance with the French Sapin II and corporate duty of vigilance laws; and ● the studies carried out by the group’s Economic Intelligence Division and a compliance questionnaire for certain suppliers, in accordance with the third-party compliance evaluation process. In accordance with the procedure for assessing third-party compliance, which was rolled out together with the Compliance 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 with regard to reputation. In order to enable the identification and processing of events that breach the regulations or the Orano Code of Ethics, the Orano ethics alert system portal is also open to the staff of suppliers, service providers, and subcontractors. Being vigilant about economic difficulties for suppliers and subcontractors From 2019, the Supply Chain Department and the Quality Department launched a working group on supplier qualification and support to make this process more robust. In addition, for the fourth consecutive year, it took part in the GIFEN France Outlook Day on June 18-19, 2024 to give suppliers visibility on the Orano strategy and the group’s needs over the next ten years. Since the Covid-19 pandemic and the strengthening of international sanctions, the supply chain has identified a priori sensitive third parties and set up regular reporting points for risks and weak signals identified for rapid processing (advanced payments, payment of down payments, etc.) in conjunction with the Finance Department. An action plan to organize the monitoring and support of sensitive suppliers in 2021 has been defined and approved. It has also helped to strengthen the payment deadline process and internal control to anticipate any delays that could impact the supplier. These actions continued in 2024, particularly concerning the monitoring of sensitive/critical suppliers for the group, also in conjunction with the group’s Economic Intelligence Division and the French ministries (Ministry for Ecological Transition, General Directorate for Energy). Involve the value chain on societal and environmental impacts Orano wishes to engage its suppliers in its efforts toward sustainable development. For several years, Orano has included provisions concerning suppliers’ observance of this commitment in 100% of its contracts and general terms and conditions of purchase.
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