Orano - Annual Activity Report 2024 91 RISKS, CONTROL AND DUTY OF VIGILANCE PLAN 3 Duty of vigilance plan These studies help establish a mapping of impacts, better understand the various physical, ecological and socio-economic components of the environment, assess the risks associated with the project and identify mitigation measures to be integrated preventively within the facilities to reduce risks at source. These studies also include the principles for mine rehabilitation at the end of the mine’s life, potential compensation measures, and the principles for environmental monitoring of activities. As an example, detailed impact studies continued in 2024 on the Zuuvch Ovoo and Dulaan Uul sites in Mongolia to assess the impacts of the mining project in ISR and propose mitigation measures as well as environmental monitoring principles. Furthermore, Orano has a strict policy for the responsible management of its sites at the end of their lifecycle, aiming to avoid risks to populations and the environment while enabling the reuse of sites for other purposes. This policy is implemented within Orano Mining, which makes the remediation and post-mining management of its sites a priority. Orano Mining is committed to planning and designing the end-of-life phase of sites in consultation with the authorities and relevant stakeholders, implementing all measures related to environmental protection and social issues, and ensuring the financial provisions to fulfill commitments for site closure and remediation. There are several phases involved in the remediation of a mining site: ● a study phase which consists of defining the remediation strategy best suited to the site by taking into account its specific constraints; ● a mining work phase that is determined depending on the nature of the mine and the facilities concerned; ● a post-works monitoring phase, which consists of checking the ways in which uranium and its decay products as well as various other substances related to mining activities, and the local geological context (metals, minerals, etc.), may be transferred at sites and in the surrounding area. The main objectives of a remediation plan are as follows: ● ensure long-term stability of structures (dams, underground mining works, etc.) in terms of public safety and health; ● minimize the residual impact of former activities; ● limit the land surface subject to usage restrictions; ● successfully integrate the site into the landscape of its environment in order to preserve local biodiversity and allow potential reuse of the site depending on the level of easement; ● enable the site to be managed properly from a social and societal perspective in the mine closure phase; and ● support the reconversion of the site. All Orano Mining’s sites are covered by a specific remediation plan. Since the beginning of its mining activities, Orano Mining has undertaken the dismantling of facilities, as well as the remediation and monitoring of former uranium mining sites in France, Gabon, the United States and Canada. Responsible management of tailings Since August 5, 2020, Orano Mining has committed to implementing the Global Industry Standard on Tailings Management (GISTM) developed by the United Nations Environment Program (UNEP), the Principles for Responsible Investment (an investor network supported by the United Nations) and the International Council on Mining and Metals (ICMM) following the tragic Brumadinho tailings facility collapse in Brazil. Underpinned by an integrated approach to tailings management, this standard aims to prevent catastrophic failure and enhance the safety of mine tailings facilities across the globe. It represents a radical change in terms of transparency, responsibility and the protection of the rights of people affected and involved in projects. The standard has six topic areas: affected communities; integrated knowledge base; design, construction, operation and monitoring of the tailings facility; management and governance; emergency response and long-term recovery; public disclosure and access to information. Orano Mining transparently and regularly discloses and updates information on its tailings facilities classified as having “extreme” or “very high” potential consequences, as well as its policy for managing the storage of ore processing residues and industrial effluents. Orano Mining manages two tailings storage facilities respectively classified as having “extreme” and “very high” potential consequences according to the classification of the standard: the Bois-Noirs Limouzat (“BNL”) site in France, which ceased operations in 1980, and the JEB Tailings Management Facility in Canada, which is currently undergoing expansion. Orano Mining is working to implement the requirements of the standard on its tailings facilities and to disclosure the results in 2025, for all facilities. Orano Mining has also adopted a policy to manage storage of ore processing tailings and industrial effluents. Signed by all members of the Orano Mining Management Committee, the policy has applied to all of its sites since October 2023. Discharge control Liquid and gaseous discharges from Orano facilities are subject to appropriate controls (continuous or deferred measurements) designed to ensure compliance with the applicable values and enable rapid corrective actions when necessary. By measuring the activity released in liquid and gaseous effluents and its dispersion in the environment, the radioactivity in the surrounding environment (seawater, groundwater, rivers, fauna, flora, air, soil, etc.) is assessed, then the dosimetric impact is calculated, taking into account all the various routes by which radioactivity can reach humans. This assessment focuses on population groups identified as being the most exposed locally to the impact of discharges. To verify the absence of real impact from an industrial site, deferred monitoring (based on sampling) is conducted in various ecosystems and along the entire radionuclide transfer chain to humans.
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