Ethics and legal conformity


The energy policy choices of a country are strategic: they have an influence on the country’s energy independence, the competitiveness of its companies, the buying power of its consumers, its environment, the wellbeing and health of its people, etc.


These choices create legal, social, technical and environmental obligations, for energy producers and suppliers. Requirements evolve quickly, due to the many changes in the sector and the on-going energy transition, which impact all of the actors.


Compliance with the laws and regulations is thus a specific focus, within the company and for its suppliers.

The framework

The "Ethics and Legal Compliance” policy

In 2016, EDF Luminus reworked its "Legal Compliance" policy, which had been in force since the beginning of the decade, to take into account changes in the constantly evolving ethical standards and new regulations.


In 2016, EDF Luminus reworked its "Legal Compliance" policy, which had been in force since the beginning of the decade, to take into account changes in the constantly evolving ethical standards and new regulations.

The “Corporate Social Responsibility” (CSR) policy

In 2012, a CSR (Corporate Social Responsibility) policy was drafted then published on the EDF Luminus website. .

This policy listed specific commitments in five areas, including ethics and good governance.


In 2017, this policy was updated to include a sixth axis: innovation.

2017-CSR Policy_UK.pdf
Adobe Acrobat Document 3.6 MB

Code of Conduct

Since 2009, EDF Luminus has published a Code of Conduct for its employees, with the rules to follow for their internal and external interactions. From respect for others, to data protection, to reporting of hazardous situations, the Code includes eight chapters. It was updated in 2017. Anyone may access it on the EDF Luminus website.

Gedragscode in het Nederlands
2017_EDFLuminus_CodeofConduct_NL def.pdf
Adobe Acrobat Document 1.9 MB
Code de conduite en français
2017_EDFLuminus_CodeofConduct_FR def.pdf
Adobe Acrobat Document 1.9 MB

Responsible purchasing conditions

The general purchasing terms of EDF Luminus were modified in 2012 to include clauses relating to social responsibility, respect for human rights and the environment, and work conditions.


In May 2017, as part of the update of the Ethics and Legal Compliance policy, a clause was added to the general purchasing conditions, regarding integrity.


Suppliers that wish to report a violation of the rules of law, relating to ongoing or future contracts, can use the email address:

Updated supplier mapping in 2016

The 2013 mapping of key suppliers in terms of social responsibility was updated in 2016. This update was the subject of a specific objective for the Purchasing team in 2016, thereby affecting the variable remuneration of the buyers. Since then, the mapping is updated with each significant change in the supplier database.


2017 update of the Ethics and Legal Compliance policy

The Ethics and Legal Compliance policy was updated in 2017.

A new chapter was added to describe the process to follow to check the integrity of counterparts (suppliers, large customers, etc.)

Addition of a new clause on integrity in the general purchasing conditions

In May 2017, a clause on integrity was added to the company’s general purchasing conditions. This clause has two parts. It can be read on the company’s website.

Update of the Code of Conduct, at the end of 2017

To take into account changes to the ever-more complex regulations, as well as certain ethical guidelines, the EDF Luminus Code of Conduct was updated in 2017.


Several paragraphs were modified to be even more instructive, on conflicts of interest, fraud, corruption and duty of care. The Code now includes a specific alert process if insider trading is suspected. It also provides for more flexibility in the rules for using social media.


A new commitment fostering a balanced work/private life


In this new version of the Code of Conduct, EDF Luminus undertakes to “foster work-life balance, especially for parents or grandparents of young children, by creating the possibility, when the person’s job allows, of flexible hours and telework solutions.”

GDPR direction: preparations for compliance

The European directive GDPR (General Data Protection Regulation), which came into force on 25 May 2018, is the biggest change in 20 years in the area of the private data protection. To prepare for this new regulation, EDF Luminus implemented several preparatory measures, in two phases.


In the first phase, an external company carried out an evaluation of our compliance with the previsions of the upcoming regulation.

In the second phase, a dedicated project team was set up to put in place the necessary measures in all the impacted departments.


This cross-department team will be in charge of the implementation of good practices and procedures to ensure our respect of all private data (of customers, employees, etc.)

A satisfactory "Legal & Compliance" audit

Following the updating of the “Legal Compliance” policy of EDF Luminus in July 2016, an audit was carried out by the company’s “Internal Audit” department, to ensure that this policy, now called “Ethics and Legal Compliance”, is applied correctly. A detailed analysis of, in particular, compliance with the new consumer protection agreement was carried out.


The ” Internal Audit” department of EDF Luminus reports to the Board of Directors through the Audit and Risks Committee. This structure fosters the independence of the department and ensures that the recommendations based on the audits made each year are followed by an action plan.

An "exceptional" EcoVadis score

With a score of 85/100 in 2017, EDF Luminus is amongst the top 1% of the 35,000 companies evaluated each year by EcoVadis. The average for the companies evaluated by this organisation was 42.5/100 in 2017.


0 local alerts regarding Purchasing
0 Alerts recieved from the EDF group

Internal audits completed during the year


Supplier action plan under discussion


Employees who followed the "Code of Conduct" e-learning course by 2017 year end

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