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Vigilance Plan Implementation Report Orange

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Vigilance Plan Implementation Report Orange Vigilance Plan Implementation Report Orange 2019 1 Contents 1. Implementation of the Vigilance Plan related to the cluster of risks associated with the lack of or a faulty Vigilance Plan ...... 3 1.1 Vigilance Plan governance ................................................................................................................................................... 3 1.1.1 At Group level ............................................................................................................................................................. 3 1.1.2 At entity level ..............................................................................................................................................................3 1.1.3 Consultation with stakeholders .................................................................................................................................... 3 1.2 Scope of implementation monitoring .....................................................................................................................................4 1.3 Operational implementation ..................................................................................................................................................4 1.3.1 Methodology for local adaptations of the Vigilance Plan .............................................................................................. 4 1.3.2 Status of implementation of risk mapping and mitigation action plans ......................................................................... 4 1.3.3 Internal audit work on the implementation of the Vigilance Plan .................................................................................. 5 1.4 Whistleblowing system.......................................................................................................................................................... 5 2. Implementation of the Vigilance Plan related to the cluster of risks associated with the effects of our activities in terms of respect of human rights and fundamental freedoms ............................................................................................................................ 5 2.1 Protecting Personal Data ...................................................................................................................................................... 6 2.1.1 Operational organization: ............................................................................................................................................ 6 2.1.2 Awareness and Training.............................................................................................................................................. 6 2.1.3 Controls ...................................................................................................................................................................... 7 2.2 Breaches of human rights and fundamental freedoms .......................................................................................................... 7 2.2.1 Impact study on human rights ..................................................................................................................................... 7 2.2.2 Promotion of human rights and fundamental freedoms ............................................................................................... 7 2.2.3 Freedom of association and right to collective bargaining on working conditions ......................................................... 7 2.2.4 Combating discrimination ............................................................................................................................................ 9 3. Implementation of the Vigilance Plan related to the cluster of risks associated with health and safety................................. 12 3.1 Managing health and safety at work .................................................................................................................................... 12 3.2 Special case of managing psychosocial risks ...................................................................................................................... 14 3.2.1 2019 survey on the prevention of psychosocial risks ................................................................................................. 14 3.2.2 Mitigating the social crisis of 2007/2010 .................................................................................................................... 14 3.3 Special case of managing the Covid-19 epidemic ............................................................................................................... 15 4. Implementation of the Vigilance Plan related to the cluster of risks associated with the environment .................................. 15 4.1 Toward the circular economy .............................................................................................................................................. 15 4.1.1 Waste prevention and management .......................................................................................................................... 16 4.1.2 Use of rare and critical resources .............................................................................................................................. 18 4.2 Toward a lower impact on the environment and the climate ................................................................................................ 18 4.2.1 Network energy consumption .................................................................................................................................... 19 4.2.2 Other energy consumption ........................................................................................................................................ 20 5. Support for suppliers and subcontractors ............................................................................................................................ 21 5.1 New supplier assessment program for the subsidiaries of Orange ...................................................................................... 21 5.2 On-site JAC audits .............................................................................................................................................................. 22 5.3 On-site audits in the MEA region ........................................................................................................................................ 22 6. Result of indicators introduced to monitor and assess measures ........................................................................................ 23 7. Conclusion .......................................................................................................................................................................... 25 2 1. Implementation of the Vigilance Plan related to the cluster of risks associated with the lack of or a faulty Vigilance Plan 1.1 Vigilance Plan governance 1.1.1 At Group level In 2019, Orange enhanced the governance of the Vigilance Plan by building on the review by the specialist committee of the Board of Directors on Governance and Corporate Social Responsibility and its approval, also in February 2020, of Orange's Board of Directors, with a review by the Ethics Committee, comprising in particular the members of the Group's Executive Committee responsible for Group Human Resources, Corporate Social Responsibility, Diversity, Partnerships and Inclusiveness, Group Finance and Performance, the General Secretariat and the Group's Chief Compliance Officer. Indeed, following a decision in July 2019, this committee's remit has been expanded to include Monitoring the Group's Non-Financial Performance. These new responsibilities include preparing the Group's Vigilance Plan, the operational monitoring of its implementation and associated reporting. Risk mapping for the Vigilance Plan was also referred to the Risk Committee in September 2019, then to the Audit Committee (another specialist Committee of the Board of Directors). The Board of Directors' Joint Committee also specifically reviewed climate change risk in October 2019. As part of Orange's 2019 commitments set out in its Purpose and its new strategic plan, Engage 2025, covering the 2020-2025 period, the environmental action plan developed by the Group and Orange's position and outlook in this respect have undergone an extensive review by the Group's Executive Committee and its Board of Directors bringing the relevant issues to the attention of the highest echelons of the Group. 1.1.2 At entity level At the end of 2018, the action plans arising out of the local adaptations of the Group Vigilance Plan, as well as their monitoring by the entity, were approved by all relevant subsidiary Boards of Directors in Europe and by the Executive Committee in the case of divisions of Orange SA, in line with the governance arrangements in place for the implementation of Orange's Vigilance Plan. At the end of 2019, 96% of Entities within the scope of the monitoring of the Vigilance Plan appointed a manager with responsibility for implementing the Vigilance Plan within the subsidiary or entity in question. As such, a network of 26 Vigilance Plan implementation managers has been established. Its members, who are appointed or designated by the entity's CEO, are from a range of backgrounds. The majority (40%) are CSR Managers with 30% Risk Managers and 23% Compliance Officers. Reviews of divisional internal
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