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Commitments
Group CSRD reporting & double materiality
The Lenergy Group adopts the ESRS standards for its non-financial CSRD reporting.
Non-financial reporting — CSRD & double materiality
The European CSRD Directive (Corporate Sustainability Reporting Directive, 2023/2775) requires companies to produce sustainability reporting in accordance with ESRS standards. Lenergy is committed to publishing its first compliant CSRD report in 2026.
Our approach to double materiality
- Impact materiality: how our activities affect the environment and society
- Financial materiality: how environmental issues affect our performance
ESRS standards covered
ESRS E1Climate change — 1.5°C pathway, GHG emissions Scopes 1-2-3
ESRS E2Pollution — water, air, soil, hazardous substances
ESRS E4Biodiversity — Kunming-Montreal, TNFD
ESRS S1Workforce — working conditions, diversity, gender equality
ESRS S2Value chain — supplier human rights
ESRS G1Governance — ethics, anti-corruption, tax transparency
Our first full CSRD report will be published in Q1 2026 for the 2025 financial year. View our current ESG indicators →
Documents associated with CSRD reporting
All policies and charters of the Lenergy Group — available online, printable, no PDF download required.
Version 2.1
Updated 15 March 2026
Validated by Ethics Committee
Reference LEN-CHE-2026-01
Lenergy Group ethics charter
« The energy transition will only make sense if it is carried by women and men of integrity. Economic performance can never be built at the expense of human dignity, the environment or the law. This charter commits each of us, from the Board of Directors to the intern, without exception. »
1Preamble & scope
This charter applies to all employees, executives, directors, subcontractors and suppliers of Lenergy Group, in all subsidiaries and countries of operation (France, Senegal, Democratic Republic of Congo, Morocco, Côte d'Ivoire, United Arab Emirates).
2Founding values
Integrity
Each employee acts with honesty, transparency and loyalty. Any form of corruption, fraud, undeclared conflict of interest or manipulation of information is strictly prohibited.
Respect
Lenergy ensures a respectful work environment. No form of harassment, discrimination or violence is tolerated.
Responsibility
Each person is accountable for their actions and their impact on the environment, health, safety and the Group's reputation.
Transparency
Lenergy publishes all ESG impact data in open data and submits its accounts to external audit (PricewaterhouseCoopers).
3Concrete commitments
- Anti-corruption — Sapin II compliance, training 100% of exposed staff, €50 gift threshold with mandatory declaration
- Human rights — Adherence to UN Global Compact, supply chain due diligence
- Environment — Net-zero scopes 1, 2 & 3 by 2035, SBTi-validated at 1.5 °C
- Diversity & inclusion — 52% women on COMEX, Pénicaud Index 86/100, 60% local hiring in African sites
- Data protection — GDPR compliance, DPO appointed, ISO 27001 in progress
4Conflicts of interest
Every employee declares to the Ethics Officer any situation likely to create a conflict of interest. Declarations are confidential. The Ethics Committee decides within 15 days.
5Whistleblowers
In accordance with the French Sapin II law and EU Directive 2019/1937, Lenergy provides a confidential platform.
Guarantees offered to good-faith whistleblowers:
- Possible anonymity · end-to-end encrypted transmission
- Full legal protection against any form of retaliation
- Handling by independent Ethics Officer
- Acknowledgment within 7 business days
6Sanctions
Any breach exposes its author to disciplinary, civil and/or criminal sanctions: warning, suspension, dismissal for gross misconduct, damages, applicable criminal qualifications.
7Distribution & updates
Charter delivered to each employee during onboarding. Mandatory 2-hour annual training. Reviewed annually by the Ethics Committee, ratified by the Board.
« Ethics is not a communication topic. It is a daily commitment measured in deeds, not intentions. »
H.E. Sheikh Adnan Mohamed Ali ALGHAMDI
Chairman of the Board
— Lenergy SAS
Angelo MASI
Founder · Administration & Finance
Lenergy —
Version 3.0
Updated 10 February 2026
Compliant Sapin II
Reference LEN-AC-2026-01
Anti-corruption policy
« Zero tolerance. Corruption in all its forms — passive or active, public or private — is strictly prohibited at Lenergy. This is a non-negotiable condition of our license to operate in 6 countries. »
1Legal framework
This policy complies with the French Sapin II law (9 December 2016), the OECD anti-corruption convention, the UK Bribery Act 2010 and the US FCPA. It applies in all countries where the Group operates.
2Risk mapping
The Group updates its corruption risk mapping quarterly across 8 areas: procurement, sales, sponsorship, political donations, M&A, recruitment, customs, trading.
3Mandatory training
- 100% of exposed staff trained via 90-minute e-learning
- Annual reinforced module for buyers, sales staff and executives
- Country-contextualised case studies
4Gifts & hospitality
- Declaration threshold: €50 incl. tax per interaction
- Business gifts to public officials prohibited
- Gift register kept by Compliance Officer
- Prior hierarchical approval above €100
5Third-party due diligence
Every commercial partner, agent or intermediary is subject to anti-corruption due diligence proportionate to country/sector risk. No facilitation payments authorised.
Alert procedure:
- External secure platform (Whispli) — available 24/7
- Anonymity guaranteed, investigation by independent Compliance Officer
- Maximum investigation period: 90 days
6Internal sanctions
Any proven corruption results in immediate dismissal for gross misconduct and report to authorities (financial prosecutor). No settlement is possible.
Angelo MASI
Group Compliance Officer
— Lenergy SAS
Version 2.0
Updated 20 January 2026
Signatory UN Global Compact
Reference LEN-DH-2026-01
Human rights policy
« No industrial ambition can justify the slightest violation of human rights. Our African deployment will not be at the expense of local communities — it will be with them or not at all. »
1Reference framework
- Universal Declaration of Human Rights (UN 1948)
- UN Ruggie Guiding Principles on business and human rights (2011)
- UN Global Compact — Lenergy signatory since 2024
- 8 ILO fundamental conventions
2Operational commitments
Decent work
Living minimum wage guaranteed in all operating countries (above local legal minimum). No unpaid overtime. Extended health coverage for family.
Freedom of association
Recognition of representative unions in all countries. Active collective bargaining. No sanctions for legitimate union activity.
Non-discrimination
Hiring and promotion based on skills only. Zero discrimination linked to gender, origin, religion, disability, sexual orientation or age.
3Child & forced labour
Absolute prohibition of child labour (under 15, under 18 for hazardous work) and any form of forced labour or modern slavery. Unannounced quarterly audits on African sites.
4Supply chain
Human rights due diligence extended to tier 1 and 2 suppliers (PV panels, batteries, electrical equipment). Supplier code of conduct signed. SMETA audits.
5Local communities
- Free, Prior and Informed Consent (FPIC) before any implementation project
- Systematic social impact study
- Fair land compensation (above local market price)
- Minimum 60% local hiring on all new African projects
6Grievance mechanism
For communities and workers:
- Local hotline in each country (free number)
- Independent mediator per site (partner NGO)
- Acknowledgment within 7 days, resolution targeted within 60 days
H.E. Sheikh Adnan Mohamed Ali ALGHAMDI
Chairman
— Lenergy SAS
Version 1.4
Updated 8 March 2026
Pénicaud Index 86/100
Reference LEN-EHF-2026-01
Gender equality policy
« Real equality is not decreed, it is built into every HR decision, every promotion, every board meeting. Our 2030 target: Pénicaud Index 95/100 and 50% women in top management. »
1Pénicaud Index 2025 — 86/100
- Pay gap: 38/40 (corrected gap 1.8%)
- Raises: 20/20
- Promotions: 15/15
- Raises after maternity leave: 13/15
- Top 10 compensation: 0/10 (4 women needed — 2026 project)
2Parity at COMEX
52% women on Executive Committee (Rixain law target exceeded 2 years early). 4 women on 8 board members. Audit Committee chair held by a woman since 2024.
3Solar Women in Tech Programme
Dedicated programme to attract more women engineers to our R&D centres. 24 mentees in 2025, 12 hired permanent at the end of the programme. Target 50% women engineers by 2030 (29% today).
4Extended parental leave
- Maternity leave 100% salary maintained 16 weeks (above legal)
- Paternity leave 28 days at 100%
- 60% childcare coverage on African sites
- Telework guaranteed on return from maternity leave (3 days/week)
5Anti-harassment
Designated sexual/gender harassment officers on each site.
- Mandatory manager training (8 hours, certified)
- Anonymous reporting procedure via Whispli
- Disciplinary sanctions: warning → dismissal for gross misconduct
- 3 cases investigated in 2025, 100% resolved within 30 days
62030 targets
- Pénicaud Index 95/100
- 50% women top management (vs 38% today)
- 50% women R&D engineers (vs 29% today)
- Zero pay gap at equal skills/experience
Group HR Department
Equality Officer
— Lenergy SAS
Version 2.1
Updated 15 February 2026
42 nationalities
Reference LEN-DI-2026-01
Diversity & inclusion policy
« Our strength is our plurality. 42 nationalities work under our banner. Each culture brings its reading of the energy challenge. This diversity makes Lenergy a credible actor on 3 continents. »
1Inclusion commitment
Lenergy guarantees a work environment where every employee can thrive regardless of origin, gender, religion, sexual orientation, disability or age.
2Current composition (2025)
- 42 nationalities represented (vs 28 in 2022)
- 39% women in workforce (vs 32% in 2022)
- 6.8% employees with disability (legal target 6% met)
- 22% employees > 50 years (intergenerational balance)
3Solar Women in Tech
See Gender Equality Policy for programme details. 24 mentees 2025, 12 permanent hires.
4Disability inclusion
- Dedicated disability mission — officer per site
- Systematic workstation adaptation (unlimited budget)
- ESAT partnership for solidarity subcontracting
- Disability index 4.2/5 (AGEFIPH audit 2025)
5Anti-discrimination
Debiased recruitment process:
- CV anonymised in first stages
- Mixed jury mandatory (at least 1 woman/external person)
- Standardised technical tests (zero subjective questions)
- Annual internal audit of recruitment decisions
6African local hiring
Minimum 60% local hiring on all new African sites. 88% achieved on Dakar plant (2025). Lenergy Academy apprenticeship programme to train local talent in energy professions.
Group Diversity Department
— Lenergy SAS
Version 1.3
Updated 20 March 2026
Law of 27 March 2017
Reference LEN-PV-2026-01
Vigilance plan
« Our duty of vigilance extends far beyond our walls. It covers our suppliers, subcontractors, joint ventures and all communities impacted by our activities. This is a legal obligation as much as a moral one. »
1Legal framework
In accordance with the French law n°2017-399 of 27 March 2017 on duty of vigilance, and anticipating the European CSDDD directive, Lenergy publishes its annual vigilance plan.
2Risk mapping
- Human rights: child labour PV chain (silica/cobalt), forced labour Xinjiang, working conditions African construction sites
- Environment: biodiversity impact ground-mounted PV, panel end-of-life, water consumption
- Health/safety: construction accidents, chemical exposure R&D, road risk
- Corruption: public procurement, customs, commercial agents in risk countries
3Assessment procedures
- Enhanced due diligence on tier 1 suppliers — 100% audited
- Annual EcoVadis evaluation (score 76/100 — Gold 2025)
- SMETA audits on African construction sites (4 audits/year)
- Biodiversity mapping before each new project
4Mitigation actions
- Strengthened supplier charter signed by 88% (target 100% end 2026)
- Mandatory site safety training (CACES certification, panel mounting)
- Systematic flora/fauna studies before deployment
- Closure/restoration plans provisioned (~3% CapEx)
5Alert mechanism
Whispli platform open to all:
- Employees, suppliers, local communities, NGOs
- Available in French, English, Arabic, Wolof, Lingala
- Anonymity guaranteed — independent law firm handling
- 54 alerts received 2025 — 100% handled within 60 days
6Monitoring & reporting
The plan is reviewed annually and its execution monitored by the Board's CSR Committee. Public report published in the Universal Registration Document (URD).
Group CSR Department
Vigilance Officer
— Lenergy SAS
Version 2.0
Updated 15 January 2026
Signatories 88%
Reference LEN-CF-2026-01
Supplier charter
« Our suppliers are our transition partners. We cannot demand ethics internally and turn a blind eye on our supply chains. This charter is not a polite signature — it is an operational commitment. »
1Scope & commitment
The charter applies to all suppliers and subcontractors contracting with a Lenergy Group entity. Its signature conditions inclusion in the purchasing panel.
2Legal compliance
The supplier guarantees compliance with all applicable legislation: labour law, environmental law, tax law, international sanctions, anti-corruption.
3Human rights & labour
- Absolute prohibition of child labour and forced labour
- Freedom of association and collective bargaining
- Non-discrimination in hiring and pay
- Decent working conditions: duration, safety, living wage
- No use of conflict minerals (3TG: tin, tantalum, tungsten, gold)
4Environment
- GHG reduction plan aligned with Paris Agreement 1.5 °C
- Responsible water and waste management
- No primary deforestation in supply chain
- Circular economy encouraged (recycled materials)
5Anti-corruption
No payment, gift, hospitality or undue advantage linked to a public official or Lenergy employee. No facilitation payment.
6Audits & sanctions
Lenergy reserves the right to:
- Audit supplier sites (7-day notice)
- Require a corrective action plan within 60 days
- Suspend ongoing orders in case of serious breach
- Terminate the contract without compensation for gross misconduct
Group Procurement Department
— Lenergy SAS
Version 2.0
Updated 15 April 2026
Country-by-country reporting
Reference LEN-TAX-2026-01
Tax transparency
« Pay tax where value is created. A simple but structuring principle. Lenergy publishes country-by-country reporting annually and rejects aggressive tax optimisation schemes. »
1Guiding principle
Lenergy pays profit tax in the country where economic value is created, in accordance with OECD BEPS standards and EU ATAD directive.
2Country-by-Country Reporting 2025
Financial data published by country (in €M):
- France: Revenue 87 · Profit 12 · Corp tax paid 3.1 · Headcount 142
- Senegal: Revenue 24 · Profit 4.2 · Corp tax paid 1.2 · Headcount 68
- DRC: Revenue 8 · Profit 1.1 · Corp tax paid 0.3 · Headcount 32
- Morocco: Revenue 16 · Profit 2.8 · Corp tax paid 0.8 · Headcount 41
- Ivory Coast: Revenue 14 · Profit 2.1 · Corp tax paid 0.6 · Headcount 38
- UAE: Revenue 3 · Profit 0.4 · Corp tax paid 0 · Headcount 7
3Anti-avoidance commitment
- No entity in tax haven on EU/OECD blacklists
- Rejection of aggressive tax optimisation schemes (Mauritius, BVI, Caymans)
- Transfer prices arm's length compliant (full TP documentation)
- Annual external tax audit by PwC
4Effective tax rate
Consolidated effective rate 2025: 25.8% (close to French legal rate 25%). No unexplained gap over the last 5 years.
5Public subsidies received
Public aid 2025 (transparency published):
- CIR (R&D Tax Credit): €2.4M
- France 2030 grant (perovskite): €4.8M
- ADEME subsidy (smart grid): €1.2M
- Total: €8.4M (fully reinvested in R&D and French jobs)
Angelo MASI
Founder · Administration & Finance
— Lenergy SAS
Version 1.2
Updated 28 February 2026
Regulation EU 2017/821
Reference LEN-CM-2026-01
Conflict minerals policy
« Not a single photovoltaic cell, not a single battery should contain minerals funding armed conflict or exploiting child labour. This is a non-negotiable standard, verified smelter by smelter. »
1Legal framework
This policy complies with EU Regulation 2017/821 on conflict minerals, Section 1502 of the US Dodd-Frank Act, and OECD principles on due diligence in mineral supply chains.
23TG + Cobalt scope
- Tin (Sn) — PV cell soldering
- Tantalum (Ta) — inverter capacitors
- Tungsten (W) — smart grid components
- Gold (Au) — electrical contacts
- + Cobalt — Lenergy STORAGE batteries (voluntary extension)
3Exclusion zones
Lenergy refuses any supply coming directly or indirectly from:
- Eastern DRC zone (Kivu, Ituri) — unless ITSCI certified
- South Sudan, Central African Republic, Myanmar
- Mines not compliant with RMI (Responsible Minerals Initiative)
4Supplier due diligence
- Annual smelter mapping
- RMAP certification requirement
- Quarterly CMRT reporting
- Independent audit non-certified smelters (RCS Global)
5Responsible DRC sourcing
Specific position: we operate in DRC but refuse to source 3TG/cobalt there until ITSCI traceability is widespread. We support artisanal mining formalisation programmes (Solidaridad NGO funding).
62025 results
Annual audit 2025 status:
- 184 smelters identified in chain
- 171 (93%) RMAP-certified compliant
- 9 (5%) certification in progress — 12-month deadline
- 4 (2%) delisted in 2025 for non-compliance
Group Procurement & CSR Department
— Lenergy SAS
Version 1.0
Year 2025
Method GHG Protocol
Audited by PwC
Carbon footprint 2025
« Transparency is not a reputational risk — it is a credibility prerequisite. Our carbon footprint is audited, published, year-on-year comparable, SBTi-validated. It is our compass. »
1Methodology
Carbon footprint established according to GHG Protocol Corporate Standard and ADEME method. Operational scope: 100% of consolidated Group entities. Annual external audit by PricewaterhouseCoopers.
2Total emissions 2025
- Scope 1 (direct emissions): 1,240 tCO₂e (-42% vs 2022)
- Scope 2 (energy consumed): 380 tCO₂e (-78% vs 2022 — switched to 100% renewable since 2024)
- Scope 3 (value chain): 12,580 tCO₂e (-18% vs 2022)
- TOTAL: 14,200 tCO₂e (-31% scopes 1+2 vs SBTi baseline)
3SBTi 1.5°C pathway
Lenergy committed in March 2025 with Science Based Targets initiative on a 1.5°C compatible pathway:
- Scopes 1+2: -50% by 2030 (vs 2022) — Net-zero 2035
- Scope 3: -42% by 2030 (vs 2022) — Net-zero 2040
- 100% renewable electricity maintained on Lenergy sites
4Main emission sources
- PV panel purchases (scope 3 upstream) — 4,200 tCO₂e (30%)
- Site construction (concrete, steel) — 3,100 tCO₂e (22%)
- International logistics — 2,800 tCO₂e (20%)
- Business travel — 1,100 tCO₂e (8%)
- Panel end-of-life 25 years — 1,200 tCO₂e (8%)
5Avoided emissions
892,000 tCO₂e avoided by our renewable production in 2025 (European conventional mix method). Ratio avoided / total emissions: ×63.
Group CSR Department
Climate Officer
— Lenergy SAS
Version 1.2
Updated 20 February 2026
Framework Kunming-Montreal
Reference LEN-BIO-2026-01
Biodiversity policy
« Decarbonise without destroying ecosystems. That is the dual imperative of the 21st century. Our solar panels must not be deployed at the expense of local species and habitats. No net loss of biodiversity by 2030. »
1Reference framework
- Kunming-Montreal Global Framework (COP15, 2022) — 23 targets 2030
- ESRS E4 Biodiversity (CSRD reporting)
- TNFD (Taskforce on Nature-related Financial Disclosures) — adoption 2026
- SBTN (Science Based Targets for Nature) — commitment 2027
2Mitigation hierarchy
Every Lenergy implementation applies the ARC sequence (Avoid — Reduce — Compensate):
- Avoid: priority deployment on degraded soils, abandoned farmland, industrial brownfields. Zero implementation in Natura 2000 zones, type 1 ZNIEFF or nature reserves.
- Reduce: elevated panel installation (fauna passes underneath), vegetated inter-row corridors, LED warm-white outdoor lighting.
- Compensate: for 1 ha artificialised, 1.5 ha biodiversity restoration in same biogeographic zone.
3Systematic impact studies
- Fauna-flora inventory across 4 seasons before each new project
- Green and Blue Infrastructure evaluation + ecological connectivity
- Ecological monitoring for 10 years after commissioning
- Independent scientific committee (LPO, MNHN) consulted
4Agrivoltaics & co-benefits
Lenergy SOLAR develops agrivoltaics: PV panels + crops or grazing underneath. 3 pilot plants in France (vineyards, sheep, market gardening).
52030 targets
Concrete objectives:
- No net loss of biodiversity on all sites
- Net Biodiversity Gain targeted on 50% of new African projects
- 100% new projects with prior biodiversity assessment
- Active partnership with 3 African conservation NGOs
- Annual TNFD report publication from 2027
Group CSR Department
Biodiversity Officer
— Lenergy SAS
