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Conflicts of Interest (EDF/NNB) and whistleblowing policies

  • Date released: 1 October 2025
  • Request number: 202509034
  • Release of information under: Freedom of Information Act 2000 (FOIA)

Information requested

I am making a request under the Freedom of Information Act 2000. Please provide the following recorded information.

A) Conflicts of Interest – Board/Executive (EDF/NNB), 1 Jan 2023 – present

  1. The ONR Registers of Interests/Conflicts (and any updates) for the ONR Board and Executive leadership (incl. CEO, Chief Nuclear Inspector and Directors) insofar as they relate to EDF group entities (incl. EDVANCE, Framatome, EDF Energy) and NNB Generation Company (HPC) Ltd, or the Hinkley Point C and Sizewell C projects.
  2. Copies of any conflict declarations filed and any recusal records (e.g., standing or meeting-specific recusals), and relevant extracts of minutes where a conflict was declared and/or a recusal was recorded, limited to the EDF/NNB/HPC/SZC scope above.

B) Whistleblowing confidentiality & sharing with duty holders – policies/procedures (2023–2025)

  1. The current and previous versions (2023–2025) of ONR policies, procedures or internal guidance that govern: Confidentiality assurances to whistleblowers and any exceptions; Whether/when/how information from whistleblowing cases may be shared with dutyholders (e.g., licensees/EDF/NNB/HPC/SZC) or third parties; Any standard templates or internal instructions relevant to such sharing (e.g., redaction protocols, case handling steps).
  2. Where available, the document IDs/version numbers, issue dates, and revision/change logs for the above.

Information released

We confirm that under s.1 of the FOIA, we hold some of the information you have requested.

Part A, Question 1

There have been no declarations of interests/conflicts for neither the ONR Board or Executive leadership (including CEO, Chief Nuclear Inspector and Directors),

relating to EDF group entities (incl. EDVANCE, Framatome, EDF Energy) and NNB Generation Company (HPC) Ltd, or the Hinkley Point C and Sizewell C projects in the timeframe requested.

Part A, Question 2

As there are no conflict declarations, we do not hold any conflict declarations or any recusal records, nor are there any relevant extracts of minutes where a conflict was declared and/or a recusal was recorded.

Part B, Question 1

We have enclosed the current Whistleblowing procedure dated October 2023 to present, and the previous procedure dated January 2021 to October 2023.

Our current procedure details the assurances we provide in section 6, paragraph 4. Paragraph 3 notes when we may share, and section 9, paragraph 3 provides details of how we anonymise cases in external reporting.

Similarly, our previous procedure detailed confidentiality approaches which are referenced in section 4, page 7, and section 6, page 10. Section 9, page 12, provides details of how we anonymised cases in external reporting.

Our procedures do not detail whether/when/how information from whistleblowing cases may be shared with duty holders, nor are there any standard templates or internal instructions relevant to training (e.g. redaction protocols, case handling steps) specific to whistleblowing cases.

Part B, Question 2

Document ID/version numbers, issue dates and revision changes are noted on page 2 of the current procedure, and page 1 of the previous procedure.

Further information

You may wish to view our current Board Members’ Register of Interests which are published on our website .

Exemption(s) applied:

None

Public Interest Test (PIT):

N/A

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