AFD // 2021 Universal Registration Document

STATEMENT OF NON-FINANCIAL PERFORMANCE 2 Fair practices

As such, any project involving a counterparty registered in a NCJ (whether it is a fiscal NCJ or AML-CFT) is considered to present a very high level of risk under the AML/CFT risk classification of the Group. The level of due diligence expected for its projects is therefore more granular. When a project involves one or more fiscal NCJs or LCB/FTs, the AFD Group’s policy sets out the categories of operations authorised or eligible for Group financing: depending on the case, the presence of fiscal NCJs may be authorised under conditions or strictly prohibited. The AFD Group’s JNC policy is subject to regular updates, both as regards the list of countries concerned, and the content and methods of application of the restrictions. The Group initiated a project to reform this NCJ policy in 2022, looking for greater clarity for the operational teams, and a more detailed understanding of the taxation of projects. 2.7.8 Speci fi c risks of non-compliance related to the Covid-19 crisis Against a backdrop of an upsurge in fraud, a trend specific to each period of crisis, the Compliance Department has endeavoured to prevent the risks of non-compliance linked to the criminal opportunities offered by this pandemic. Thus, Compliance has been attentive to communications from regulatory bodies (ABE, ACPR, AMF) calling for enhanced vigilance in terms of AML/CFT, fraud and corruption or those of financial intelligence units such as Tracfin in France or FinCEN in the United States, which raised awareness in the banking and financial sector about the types of financial crime relating to Covid-19. Unsurprisingly, these entities emphasised that the typologies encountered reflected those that were traditionally observed following natural disasters or crises, and that the scams commonly encountered, such as false transfer orders, had been able to adapt to the increasing number of orders for medical equipment and increased funding for healthcare projects. These players in the fight against money laundering also highlighted the significant risks of misappropriation of State mechanisms put in place in response to the crisis. In this context, the Compliance Department’s “Investigation” function wanted to reinforce the vigilance of the Group’s employees by sending dedicated communication messages describing the most sensitive risk areas and providing tools/ advice aimed at protecting the institution but also its partners against the risks of fraud and embezzlement.

(2,126 trained out of 2,576) and 60% validated module ɸ 2 (881 trained out of 1,458). In addition, in 2021, the completion of module ɸ 1 of the AML/CFT e-learning training was included as an indicator in the calculation of the Group’s profit-sharing and will be the subject of a “point of attention” in 2022 as part of the annual assessment interviews (1) . (ii) Training provided in e-learning format on the fight against corruption and influence peddling and the management of conflicts of interest: in 2021, a set of six online training modules on several risk topics was made available to Group employees under the “Must” label; one of the six modules concerns the fight against corruption and influence peddling and the management and treatment of conflicts of interest. 62% of the Group’s employees validated this module (1,859 trained out of 2,979 ɸ subject to the obligation to follow these modules); among this group, 63% of AFD employees validated this training ( i.e. 1,614 trained out of 2,576 ɸ enrolled). (iii) Training delivered in a face-to-face or webinar format: they complement the self-training system and aim to provide employees with all the regulatory and legislative knowledge required to carry out their activities within the AFD Group. In 2021, 256 ɸ employees were trained (new hires and some employees catching up). These training courses are adapted to the profile of the people trained because they take into consideration the assignments of employees as part of the process of welcoming new hires but also with regard to the professional mobility carried out by AFD group employees. The Compliance Department thus developed two offers: one intended for operational employees, and the other for support employees. 2.7.7 Initiatives undertaken to prevent tax evasion Eager to participate in the French policy to combat fraud and tax evasion, as promoted by France in the framework of the G8, the G20, the 2014 Law on the Orientation and Programming of Development and International Solidarity Policy (LOP-DSI) and the Interministerial Committee for International Co-operation and Development (CICID), the AFD group has had a rigorous policy since 2009. This policy is specific to transactions carried out and projects financed in non-cooperative jurisdictions (NCJs) for tax or AML/CFT matters, or with regard to transactions involving one or more NCJs and/or, more broadly, one or more jurisdiction(s) considered as offshore centre(s).

(1) In 2020, 77% of the employees enrolled in pathway 1, comprising one module (i.e. 890 of the 1,154 people enrolled), completed their training and 76% of the employees enrolled in pathway 2, comprising two modules (i.e. 1,310 of the 1,724 people enrolled), completed their training. The format was reviewed in 2021 to allow a greater number of employees to participate in training.

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2021 UNIVERSAL REGISTRATION DOCUMENT