Our Modern Slavery Statement


EDF is one of the UK’s largest energy companies and the largest producer of low-carbon electricity. We produce around one fifth of the nation's electricity from our nuclear power stations, renewables, coal and gas power stations and combined heat and power plants.

This statement is made by and on behalf of EDF Energy Limited, its parent company EDF Energy Holdings Limited, and its subsidiaries, which make up EDF in the UK (referred to collectively in this statement as EDF). Those subsidiaries of EDF Energy Holdings Limited that are required to make their own statement under the Modern Slavery Act 2015, together  with both NNB Holding Company (HPC) Limited and NNB Holding Company (SZC) Limited, have adopted this statement.

EDF has a focus on safe, dependable, energy generation and an ethos of service excellence. We intend to play a leading role in new nuclear build in the UK and secure a bright future for the combined business and its employees.

Our society depends on energy to live, work, develop and grow. Our customers depend on us to produce affordable low-carbon energy, and we depend on our people to help us take on new challenges and fulfil our ambitions. Being a sustainable and responsible energy business is an integral part of EDF’s 2030 strategic business vision – to be an efficient, responsible energy company and a champion of low-carbon growth.

Doing business in an ethical way is one of our most important values. In Helping Britain Achieve Net Zero, we're working to ensure sustainable, ethical practice across our supply chain, and we will not tolerate fraud, corruption or abuse of human rights. At EDF we recognise that Modern Slavery is a growing global concern, and we’re working to ensure that our own operations, and those of our supply chains, are appropriately evaluating the risks of Modern Slavery. We are working to mitigate these risks as far as possible through our commitment to ethical business. We report our sustainability performance annually through our Helping Britain Achieve Net Zero, and are signatories to the United Nations Global Compact (UNGC)

We strive to improve our standards of ethical behaviour continuously, and our commitment to ethical business practice is outlined in our Ethics & Business Conduct Policy. Our commitment to sustainable and responsible business, including steps we plan to take to further address social issues including modern slavery, are outlined in more detail in our purpose of Helping Britain Achieve Net Zero.

Our People

We employ around 12,000 people, alongside a supply chain of around 3,500 suppliers. We also indirectly hire and work with many more people, including contractors.

All our people are expected to work to our guiding principles for ethical behaviour and our business values are communicated through a variety of channels. We have supporting documents in place to guide our employees to work in an honest and ethical manner, as well as giving them the confidence and tools to report any suspected unethical conduct in the organisation.

Our Codes of Conduct remind our people that we are a company that acts honestly and ethically. Employees are reminded that they should report any concerns of potentially illegal activities, unethical conduct or anything that might prejudice the business, using EDF’s Confidential Reporting of Serious Concerns procedure.

EDF is committed to fair employment practices and to ensuring legal and regulatory compliance. This commitment, in addition to the policies and procedures described above, collectively demonstrates our on-going commitment to the elimination of any risk of Modern Slavery practices.

Our Supply Chain

We contract with suppliers to ensure that we have the goods and services needed to generate and supply electricity, gas and energy services to our customers.

Our supply chain due diligence processes include defined and monitored onboarding and qualification processes of all new suppliers. These processes serve to identify any potential risks relating to slavery and human trafficking, and we carry out thorough risk assessments to identify areas of focus in relation to Modern Slavery concerns.


Supplier Standards

At EDF we have a set of Minimum Standards that suppliers are required to abide by. These include a requirement for suppliers to complete a risk-based self-assessment aligned to the 10 Principles of the NGC. This provides us with our first opportunity to assess and mitigate the risks associated with Modern Slavery.

EDF is currently the UK’s largest generator of low-carbon electricity which we support with our Powering Net Zero company ambitions. 

We encourage our supply chain to drive positive social and environmental change. We include Modern Slavery obligations within our standard precedent contracts and assess supplier standards at all parts of the procurement lifecycle from specification through procurement and into contract delivery.

Risk Assessment

We adopt tender specification requirements to set expectations of how goods and services should be delivered. Tender evaluation processes are also designed to establish whether suppliers can meet these expectations. Where appropriate, we award contracts to companies registered in the UK. This means that our suppliers are likely to match EDF’s levels of transparency in relation to UK employment law and the Modern Slavery Act.

Highest Areas of Risk

Power Station Maintenance and Development

Nuclear generation and nuclear new build activities are subject to oversight from the Office for Nuclear Regulation and part of this oversight requires a high level of transparency from our suppliers. This includes ensuring that only duly authorised and other suitably qualified and experienced persons perform duties required by our nuclear generation business. Our parent company, EDF SA, also oversees our ethical performance including alignment to UNGC.

As critical infrastructure projects, the activities at Hinkley Point C and Sizewell C involve complex supply chain structures. At EDF we are continually and actively evaluating our assurance processes and seek to maintain open discussions with suppliers to promote a collaborative approach to ethical and sustainable working practices across the supply chain.


Smart Meter Production and Installation

The known risks around sourcing and installing smart meters are understood and addressed throughout the tendering and contract management processes, including site-visits to smart meter suppliers. Those involved with installing meters are employed through UK-registered companies and have the relevant security and recruitment checks required by English and/or Scottish law (as appropriate).


Fuel Supply

Obligations contained within our contracts for the purchase of nuclear fuel are aligned to the UN Declaration of Human Rights, the EU Charter of Fundamental Rights and the International Labour Organisation conventions. Additionally, EDF engages where possible with suppliers who adhere to the Bettercoal Initiative. Whilst we recognise that the supply chain for commodity market-traded coal lacks transparency, we limit the use of this source of supply as much as possible.

Most of the gas we buy, both for sale to our customers and for use in our power stations, is purchased via our affiliate 
company. Our gas is received via the National Balancing Point (a gas trading facility run independently of EDF) or via Beach Gas at a UK terminal. As it is a fungible product, it is not possible for us to track the supply chain backwards. 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes EDF’s slavery and 
human trafficking statement for the financial year ending 31 December 2021.