Orano - Annual Activity Report 2024 67 RISKS, CONTROL AND DUTY OF VIGILANCE PLAN 3 Methodology: risk mapping and risk management Insurance covering the specific risks relating to the activities of nuclear facility operators International nuclear liability law is distinct from general civil liability law in that the operator of the nuclear facility causing any damage has sole liability. Its liability is objective and exclusive (“no fault”), for which there are few exemptions. The operator of a nuclear facility is therefore required to compensate the victims for any physical injury and property damage they may suffer and for this purpose must maintain a financial guarantee (generally, an insurance policy), in order to cover its liability, for a limited amount. This arrangement is defined by international conventions, including the Paris Convention of July 29, 1960, as amended on January 1, 2022, by the 2004 Protocol, supplemented by the Brussels Supplementary Convention of January 31, 1963, of which France is a signatory. Orano’s nuclear facilities are all located in France, where, since February 18, 2016, pursuant to French law No. 2015-992 of August 17, 2015, on the energy transition for green growth in France, known as the TECV law, and ahead of the entry into force of the 2004 protocols, the operator’s liability is capped at 700 million euros per nuclear accident in a nuclear facility, at 70 million euros in a reduced-risk facility and at 80 million euros per nuclear accident during transportation. The protocols entered into force on January 1, 2022. For its regulated nuclear facilities (INB) in France and its other facilities abroad, as well as for its nuclear transportation operations, the group’s companies are covered by Orano’s subscription to the insurance liability program. These insurance policies comply with the international conventions governing nuclear operator liability, as well as the provisions of the French Environmental Code (Articles L. 597-1 et seq.), including in terms of liability limits. To cover these risks, the group uses the insurance and reinsurance markets (pools) and specialized mutual insurance companies. Property damage insurance For property damage and business interruption insurance, Orano has implemented a risk prevention policy. This approach focuses on controlling industrial risks (prevention and protection) that could impact production assets and the overall business continuity of the group’s production plant. It offers recommendations, weighed economically and strategically, so that the sites achieve a sufficient level of control. Property and business interruption insurance for nuclear operations This policy covers material damage (nuclear and conventional) to property owned or leased by Orano at its nuclear facilities, such as buildings, immovable or movable fittings, equipment, tooling, supplies, inventories, as well as operating losses resulting from said material damage incurred by the INB. Due to the nature of the damage likely to be caused to nuclear sites, this insurance coverage (in the same way as the nuclear civil liability policy) is only available from a limited number of insurance companies, from pools or specialized mutual insurance companies able to provide the appropriate guarantees. The limits of coverage for this type of insurance are based on the estimated “as new” replacement value or on an estimate of the maximum possible loss (MPL). Property and business interruption insurance for non-nuclear operations This policy covers material damage (conventional) to property owned or leased by Orano such as buildings, immovable or movable fittings, equipment, tooling, supplies, inventories, as well as operating losses resulting from said material damage to so-called conventional sites. Moreover, mining activities are not covered by property and business interruption guarantees for the nuclear scope, but rather are covered by specific insurance policies controlled by Orano’s Insurance Department, in consultation with the various mining subsidiaries. The risk that the insurance policy terms and conditions for triggering a payout are not met or that the limits for this coverage are reached and thus that the policies are insufficient to fully cover the consequences of a claim cannot, in principle, be ruled out. Participation in mutual insurance companies Orano SA participates in the following mutual insurance companies set up by nuclear operators to offer an alternative to national nuclear insurance pools: ● ELINI (European Liability Insurance for the Nuclear Industry); ● EMANI (European Mutual Association for Nuclear Insurance); ● NIRA (Nuclear Industry Reinsurance Association); and ● Blue Re. This group risk investment scheme limits the cost of the insurance programs taken out by the group. Other insurance coverage In view of Orano’s risk profile, the group takes out all the insurance cover required for its business activities, including cyber, all nuclear and non-nuclear worksite risks, ten-year civil liability, damage to works, environmental liability, transported goods, car fleet, etc. 3.2.2.2 Outlook and trends in 2025 The main insurance programs will be renewed in April 2025 for the Orano group against a backdrop of sustained price pressure in the corporate risk insurance market.
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