Orano - Annual Activity Report 2024 82 3 RISKS, CONTROL AND DUTY OF VIGILANCE PLAN Duty of vigilance plan 3.4 Duty of vigilance plan Orano operates within a dense and restrictive regulatory and normative framework, source of numerous obligations whose control and proper execution are ensured by various bodies and regulatory authorities, among which is the French nuclear safety authority (ASN). Orano ensures the rigorous application of the provisions relating to human rights, fundamental freedoms, health and safety of individuals, as well as environmental protection, in particular those provided for by French law No. 2017-399 of March 27, 2017, on the duty of vigilance of parent companies and ordering companies (hereinafter, the “law on the duty of vigilance”). This vigilance is an integral part of its corporate culture. The current duty of vigilance plan was established in line with the plan of 2023 and demonstrates the application of the said law. It reflects the group’s orientations expressed through its purpose and rolled out in its corporate project integrating societal and environmental commitments. The duty of vigilance plan is available on the group’s website (www.orano.group). It is structured around five sections that reflect the structure of the law on the duty of vigilance: ● the mapping of risks related to the duty of vigilance (Section 3.4.1); ● the deployment of risk preventive measures (Section 3.4.2); ● the assessment of subsidiaries as well as subcontractors and suppliers with whom the group maintains an established commercial relationship (Section 3.4.3); ● the implementation of a system for processing and collecting any reports brought to the attention of the group (Section 3.4.4); ● the control of the effective implementation of the announced vigilance measures (Section 3.4.5). Methodology, governance and deployment of the 2024 duty of vigilance plan In order to define its duty of vigilance plan, the group relies on strong ethical principles that have long underpinned its policy in terms of compliance, social and environmental responsibility, and respect for human rights and fundamental freedoms. The regulated nature of its activities means that the group is subject to strict prior authorization processes and controls by the competent authorities, which take into account their possible impacts on employees as well as service providers, local populations and the environment. The group is also bound by particularly high standards of ethics and corporate responsibility, set out in its Code of ethics and business conduct (hereinafter, the “Code of Ethics”, available on the Orano website www.orano.group). The group’s duty of vigilance plan is part of a continuous improvement process. It sets out identification, alert and monitoring procedures that have been in place within the group for several years. It is the result of close collaboration between various departments at both central and entity level, particularly in the areas of legal, Health, Safety, Environment (HSE), CSR, internal control and compliance, supply chain and human resources, and contains reasonable due diligence measures. It is drawn up with the group’s Business Units, who also participate in its deployment. The relevant departments have participated, each in their areas of expertise and depending on the nature, scope and location of their activities, in the identification and prioritization of risks, followed by their anticipation and the definition of suitable mitigation and preventive measures, as well as their implementation and monitoring of their effectiveness. In 2023, a Vigilance Committee led by the Legal Department was created, composed of representatives of the Safety, Health, and Environment (HSE), Risk, Compliance and Internal Audit (RCAI), and Supply Chain (SC) departments. This Committee’s prerogatives include approving the drafting of the duty of vigilance plan and monitoring the deployment of vigilance measures within the group. This committee also defines annual action plans and helps develop a culture of vigilance within the group. The duty of vigilance plan is also informed by discussions with internal and external stakeholders to which the group is committed. As part of its activities and the implementation of its preventive actions, Orano maintains an ongoing dialogue with its stakeholders in France and abroad. This includes customers and partners, employees and their representatives, administrations and authorities, shareholders and investors, elected officials and State representatives, subcontractors and suppliers, as well as with local residents. These exchanges take place through various forms of dialogue and interaction, including participation in discussion forums, visits to industrial sites, participation in supplier associations, meetings, local sessions and national debates, etc. Since the coup in Niger in July 2023, Orano has been subject to increasing interference by the State of Niger in the governance of its Nigerien Subsidiaries (the “Nigerien Subsidiaries” meaning Somaïr, Imouraren and Cominak). This interference, which is part of a sovereigntist agenda aimed at regaining control of the country’s mining activities, has led the group to confirm the loss of Orano’s operational control over its Nigerien Subsidiaries as of December 2024 (1). Consequently, the Nigerien Subsidiaries have been excluded from the scope of application of the duty of vigilance plan as of that date. Due to the interference of the authorities in Niger, Orano can no longer ensure the deployment of its duty of vigilance plan for its Nigerien Subsidiaries as of December 2024. The measures implemented in Niger during 2024 are nevertheless described in this duty of vigilance plan. (1) The group confirmed the loss of operational control over its subsidiaries in Niger in December 2024. For more information on the situation in Niger, see Section 2.1.2.1.
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