Orano - Annual Activity Report 2024 84 3 RISKS, CONTROL AND DUTY OF VIGILANCE PLAN Duty of vigilance plan Human rights and fundamental freedoms The group ensures that its activities in all regions of the world do not seriously violate human rights and fundamental freedoms. In this regard, the group has identified the following risks: ● the risk of forced labor and child labor; ● the risk associated with housing conditions for employees and subcontractors at the group’s mining sites; ● the risk of harassment and sexist behavior; ● the risk of retaliation for trade union activities or denial of the right to collective bargaining; ● the risk of violence on site due to armed conflicts; and ● the risk of infringement of the social and economic rights of local communities living near the sites. 3.4.2 Measures applied in the prevention of duty of vigilance risks In all the regions where Orano operates, increased vigilance is applied to preventing serious violations of health and safety, environmental protection, human rights, and fundamental freedoms. This applies to the activities of the parent company, as well as those of the companies it directly or indirectly controls, within the meaning of Article L. 233-16 of the French Commercial Code. It also extends to the activities of subcontractors and suppliers with whom Orano has an established commercial relationship when these activities arise from that relationship. Once again, this preventive approach is carried out through active and close consultation with its ecosystem and stakeholders with whom the group maintains a constant dialogue. 3.4.2.1 Prevention of risks to human health and occupational safety Orano aims to continuously improve its results with the goal of achieving zero injuries and zero impacts from its activities on the health and safety of its employees, subcontractor personnel and the local communities near its sites. The new HSE 2024-2026 policy outlines the priorities for actions by the group and its operational entities for the period from 2024 to 2026 in terms of health and psychosocial risks, safety, and radiation protection. This policy covers all activities carried out by the group and its operating entities in France and abroad in their capacity as employers, including in particular: ● as operator of nuclear or high-risk mines and facilities; ● as an industrial operator on behalf of other operators; and ● as service and work provider. The HSE policy applies to all employees and external contractors working on Orano’s sites or for group entities. Its key commitments in the areas of health and occupational safety are: ● embedding a solid culture of leadership in nuclear safety, industrial and occupational safety, and radiation protection; and ● moving towards a level of prevention and requirements that is homogeneous for all employees of the group and all contractors. Vigilance regarding the health of the group’s employees and those of an external company During their activities, the employees of the group and of an external company working on the Orano sites are exposed to radiological, chemical and conventional risks that could have consequences on their health. Consequently, Orano has implemented various measures to preserve their physical and mental health. Medical monitoring and prevention of occupational risks The group ensures the application of international standards for medical monitoring of occupational risks. It implements a multiyear health prevention plan for all the group’s employees. Occupational health is coordinated within a group health service with national responsibilities and international activities to enhance its effectiveness. The operation of the group’s occupational health service has reached maturity, and feedback is used to develop employee monitoring schedules drawn up by the service’s health professionals on a scientific and regulatory basis. These changes are made within the framework of the governance of the Prevention and Occupational Health Service (SPST). The monitoring of expatriate employees or employees on long-term assignments is also ensured by the group SPST. The implementation of the Orano group SPST continued in 2024, with the ongoing internalization of employees in the group’s occupational health and safety service in France. This medical monitoring helps detect and prevent occupational diseases. It provides individual prevention information to employees. It is also at the origin of the traceability of occupational exposures throughout their professional career. A prevention plan is implemented on the Orano sites, covering prevention of musculoskeletal disorders (MSDs), cancer prevention with the Santé Attitude program, midwifery consultations, management of radiological events with the GATOME project, promotion of physical activity, and more. The HSE Department and the SPSTs regularly participate in national and international crisis exercises. The management of health evacuations and the actions of health insurance providers are managed in close coordination with the Insurance Department. Health monitoring is carried out by the SPST. Regarding employees of external companies working on Orano sites, the group ensures that the risks and rules are well-known. The group monitors the accidents of contractors working on its facilities and takes necessary feedback into account to adapt practices.
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