2022 Communication on Progress

Orange

Published date

July 4, 2022

No. of questions

60

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

    1. Does the Board / highest governance body or most senior executive of the company:

    Optional comment
    Orange has incorporated a Purpose in its bylaws in 2020 which act as annual statement on Orange being exemplary on environmental and social matters

    2. Does the company have a publicly stated commitment regarding the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

    No formal structure

    Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)

    Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)

    Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)

    Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Prevention

    6. Does the company have a process or processes to assess risk?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    6.1. During the assessment of risk, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    7.1. During the due diligence process, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Concerns and grievance mechanisms

    8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

    8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    Is the process confidential (e.g., whistleblowing process)?

    Are there processes in place to avoid retaliation?

    Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)

    Other (Please provide additional information)

    Group whistleblowing mecanism is supplemented by local mecanism and is opened to external alerts

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Lessons

    10. How does the company capture lessons regarding each of the following sustainability topics?

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Executive Pay

    11. Is executive pay linked to performance on one or more of the following sustainability topics?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Board Composition

    12. Percentage of individuals within the company’s Board / highest governance body by:

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    14

    Male (%)

    55

    Female (%)

    45

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    21

    Above 50 years old (%)

    79

    From minority or vulnerable groups (%)

    0

    Executive (%)

    1

    Independent (%)

    7

    13. Do you produce sustainability reporting according to:

    Data Assurance

    14. Is the information disclosed in this questionnaire assured by a third-party?

    please refer to the Report

  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    Response

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    Orange was one of the first companies to sign the United Nations Global Compact in 2000. Respect for the fundamental principles set out in the Universal Declaration of Human Rights and the International Labour Organization explicitly features in the Group’s Code of Ethics. Orange thus asserts its commitment to respecting and promoting fundamental human rights in its activities and sphere of influence, in particular in supporting and promoting freedom of expression and respect for privacy worldwide. It also confirms its commitment to ensure that these rights are respected by each of its employees and managers, both internally (employee relations) and in its relationships with its customers, partners, suppliers and subcontractors; In 2017, Orange published its first report dedicated to respect for human rights, drawn up in accordance with a reporting framework aligned with the United Nations Guiding Principles for Business and Human Rights, which was subsequently transcribed in 2021 in its fifth Declaration on Modern Slavery and Human Trafficking (available at gallery.orange.com). Any potential or actual breaches of human rights and fundamental freedoms that Orange may have caused are taken into account in Orange’s 2021 Vigilance Plan.

  • Labour

    Commitment

    1. Does the company have a policy commitment in relation to the following labour rights principles?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    2021

    Forced labour

    2021

    Child labour

    2021

    Non-discrimination in respect of employment and occupation

    2021

    Occupational safety and health

    2021

    Working conditions (wages, working hours)

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving labour rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks /impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    4. Who receives training for the following labour rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Performance

    6. What is the percentage of employees covered under collective bargaining agreements?

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    Optional comment
    56% of the workforce in France is covered under collective bargaining agreements. Unknown situation outside France. Global agreements covering all consolidated companies ensure common rights for employees (OHS, Fundamental Rights...)

    7. What is the percentage of employees in a trade union or other workers' organization?

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

    Employees in a trade union or on a worker committee (%)

    100
    Optional comment
    In regions where representative bodies are not legally required, the Group promotes the creation of employee forums in order to establish formalized dialogues.

    8. In the course of the reporting period, what was the percentage of women in:

    Percent of women (%)

    Unknown

    Senior leadership level position

    31.3

    Non-executive board

    35.9

    9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    Optional comment
    pay gap between women and men in comparable employement situation is 1,5% for Orange SA in 2020 (URD p338)

    10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    2.21
    Optional comment
    the frequency rate of occupational accidents relates to the number of occupational accidents with lost time per million theoritical hours worked

    11. In the course of the reporting period, what was the company’s incident rate?

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    Response and Reporting

    12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    Orange works to promote human rights and fundamental freedoms and defends their values, particularly with regard to the responsibility it intends to assume in respect of its supply chain: Orange actively participates in the respect of human rights in its sphere of influence through the following collective initiatives: − as a signatory to the United Nations Guiding Principles, Orange contributed to discussions as part of a working group on companies and human rights (BHRWG of the United Nations) on the new framework (“UNGPs 10+”) to be put in place after ten years of applying the Guiding Principles. Orange shares the United Nations’ analysis on the effective implementation of the Principle of “protection of human rights” by public authorities and the Principle of “respect for human rights” by companies. Orange proposes to set up an analysis of the sharing of responsibility between public authorities and companies prior to the implementation of a Principle of “remedy” yet to be developed; − Orange also takes part in the ILO platform on child labor, which returned its work in June 2021; − as part of the JAC, a Human Rights working group was created in February 2021. Initial work focused on the subject of forced labor, with questioning of suppliers by the operators, based on the report of the Australia Strategic Policy Institute (ASPI) which described the forced labor allegations and concerns of the Uyghur people and other ethnic minorities in and from Xinjiang. Of the 35 suppliers questioned by the eight members of the JAC (including Orange), 29 provided proof of due diligence, either because they did not use suppliers in or from Xinjiang, or an audit did not provide any proof of forced labor associated with the factories named in the ASPI report, or because corrective measures had been taken (including banning the use of certain providers). The work of the JAC continues on follow‑up of corrective action plans and for suppliers who are yet to respond; the next subject to be tackled by this working group will be child labor; − an initiative to share good practices between companies on these same issues was undertaken with the participation of Orange within the French association EDH (Entreprise pour les Droits de l’Homme). In addition, Orange takes action to increase visibility of issues in the sector and to promote good practices. On several occasions in 2021, Orange presented the context and its policy in terms of respecting freedom of expression and privacy in response to the governmental injunctions for restriction or alteration of access to its services. Finally, Orange took part in the definition of human rights‑related standards with the GRI.

  • Environment

    Commitment

    1. Does the company have a formal policy on the following environmental topics?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    2021

    Water

    2020

    Oceans

    Forests / Biodiversity / Land Use

    2021

    Air Pollution

    2021

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    2021

    Energy & Resource Use

    2021

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks/ impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

    Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)

    Climate Action

    Orange has made a “Net Zero Carbon in 2040” commitment and has set itself the interim target of reducing its CO2 equivalent emissions by 30% by 2025 compared with 2015.

    Energy & Resource Use

    Orange launched a vast energy efficiency and natural resources savings plan and intends to reach a utilization rate of at least 50% renewable electricity by 2025.

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Oceans

    4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

    Progress is reviewed against goals annually or more frequently

    Progress is reported internally to the most senior level

    Progress is reported externally

    Other (Please provide additional information)

    Climate Action

    Energy & Resource Use

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Oceans

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Climate Action

    6. What were the company’s gross global greenhouse gas emissions for the reporting period?

    Scope 1 Emissions

    Emissions (tCO2e)

    324.023

    Scope 2 Emissions

    Emissions (tCO2e)

    978.642

    Scope 3 Emissions

    Emissions (tCO2e)

    6.475

    7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

    Percent of revenue (%)

    8. Has the organization acted to support climate change adaptation and resilience?

    Energy / Resource Use

    9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

    % of total energy consumption

    36.3

    Technology

    10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

    Percent of total revenue (%)

    Sector-specific Questions

    11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.

    Sector-specific: Forest, biodiversity, and land use

    14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).

    Number

    Unknown

    Not applicable (Please provide additional information)

    Sites

    Hectares

    15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

    Conversion of natural resources (hectares)

    16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

    No

    No, but we plan to in the next 2 years

    Yes

    Forest ecosystem restoration

    Other ecosystem restoration

    Reforestation

    - local projects, like the partnership with Alliance Forêts Bois signed in October 2021 to finance the reforestation of around 175 hectares of forests in mainland France, a partnership in Senegal with Nébéday for the plantation of 100,000 trees in five years, the reforestation of pines in Spain, a partnership project with Planète Urgence in Cameroon, etc; − with a stake in the multi‑investor fund Livelihoods Carbon Fund 3; − with Orange Nature, an innovative single‑investor carbon fund with 50 million euros launched by Orange in December 2021 in partnership with the asset management company Mirova (Natixis Investment Managers) and which exclusively targets a payment in kind in the form of high quality carbon credits.

    Natural regeneration

    Agroforestry

    In December 2021, Orange announced the creation of Orange Nature, an innovative carbon fund intended to finance reforestation projects and the restoration of natural ecosystems. The fund will invest in different carbon sequestration projects worldwide (in the form of either mangroves or agroforestry projects).

    Set-aside land

    Biodiversity offsetting

    commit to digital technology that works to benefit biodiversity

    Other (please specify in text box)

    Overall Environment

    21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

    Please see our Universal Registration Document 2021 or our anwers to CDP 2021

  • Anti-corruption

    Commitment

    1. Does the company have an anti-corruption compliance programme?

    2017

    2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

    Prevention

    3. Who receives training on anti-corruption and integrity?

    Optional comment
    all employees are sensibilized thanks to special events and seminars through the year

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

    4. Does the company monitor its anti-corruption compliance programme?

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    confidential information

    Confirmed during the current year, and related to this year

    Confidential information - in 2021, Orange Group wisthleblowing mecanisms accounted 4,9% of alerts due to unethical behaviour, fraud, corruption (URD p331)

    6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

    7. Does your company engage in Collective Action against corruption?

    Orange participates in various collective, sectoral or thematic initiatives dedicated to the development and sharing of good integrity practices, including the MEDEF International Ethics Committee, the Transparency International Engaged Companies Forum, and the Cercle Éthique des Affaires. Orange's Compliance Director is involved in the Compliance Officer/Compliance Officer training cycle at Panthéon-Assas University.

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

    - the group's anti-corruption policy has been rolled out and / or adapted through out the Group and its subsidiaries - the group's fraud and compliance due dilligence methodology, which was completely updated in 2021, has been rolled out cross all group divisions and countries - the prevention of conflicts of interest continued with obligatory reporting campaigns in certain subsidiaries including Orange Slovensko, Sonatel, Orange DRC - ... see more URD p.330