AFD - Universal Registration Document 2020

STATEMENT OF NON-FINANCIAL PERFORMANCE Fair practices

2.7.4 Counterparty commitments AFD Group’s financing agreements include a certain number of provisions that impose commitments on counterparties in terms of combating corruption, fraud, cartels, money laundering and terrorist financing. These clauses require counterparties to inform the Agency of cases of alleged prohibited practices or proven reprehensible practices, and to take remedial measures to the satisfaction of the AFD Group. In the absence of remediation, the Group reserves the right to trigger an event of breach. The Group can suspend payments, cancel the portion of its financing in relation to which improper or non-compliant practices have been detected and demand early repayment of all or part of a loan or repayment of all or part of a grant paid. 2.7.5 Information reporting systems There are several reporting mechanisms within the AFD Group to report reprehensible practices. Firstly, Group employees have an operating incident declaration system which collects and centralises all shortcomings identified by employees (including AML/CFT/ corruption and fraud issues). Group employees must also report, through a reporting mechanism following management reporting lines, any suspicion of irregular practices within and outside projects. The processing of these reports is managed by the Investigations Function of the Compliance Department in order to have an exhaustive overview of the cases encountered, and to ensure a consistent response or action plan. The AFD Group’s employees also have the right to consult the Director of this department and his/her deputy directly if they believe they have identified a situation where there is a compliance risk. Since January Ǿ 2019, the AFD Group has provided its employees with a whistleblowing system, in accordance with the requirements of the so-called “Sapin Ǿ II” law of 9 Ǿ December 2016. This system constitutes an ancillary, voluntary and optional warning system when an employee believes that current alert channels have not operated properly, or that there is a serious obstacle preventing their use. 2.7.6 Training of Group employees In accordance with applicable French regulations, the AFD Group ensures that all of its employees, including those of its office network, receive regular training and notifications on the risks and procedures to implement in terms of the fight against money laundering, terrorist financing, fraud and corruption. Due to the health crisis, the training format had to be adapted so that it could continue to welcome new employees within the Group, but also to raise awareness among all staff. Thus, in addition to AML/CFT e-learning, remote training courses have been set up ( via Skype or the tools offered by the AFD Training Department).

This year, these training sessions were provided in e-learning format, in the form of a webinar and in a face-to-face mode (before the lockdown period). P Training provided in e-learning format on AML/CFT: this training has been completely redesigned to take into account regulatory changes and their implementation in the AFD Group’s procedural system, but also to offer a new- generation-digital, personalised, flexible and collaborative training course. All Group employees (Headquarters and Network, whether new hires or existing employees) were asked to follow one or two e-learning modules. The number of modules assigned to each employee takes into account the risks identified with regard to the activities carried out by the employee. The results for 2020 are as follows: 77% of employees enrolled in pathway 1 including a module ( i.e. 890 of the 1,154 Ǿ people enrolled) completed their training and 76% of employees enrolled in pathway 2 including two modules ( i.e. 1,310 of the 1,724 Ǿ people enrolled) validated their training. P 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 2020, 207 Ǿ 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. Compliance thus developed two offers: one intended for operational employees, and the other for support employees. 2.7.7 Initiatives undertaken to prevent tax evasion Keen to participate in the French policy to fight against tax fraud and tax evasion as promoted by France within the framework of the G8, the G20, the LOP-DSI or the CICID, the AFD Group has, since 2009, a rigorous and specific policy with regard to transactions carried out and projects financed in Non- Cooperative Jurisdictions (NCJs) in tax or AML/CFT matters or involving one or more NCJs and/or more broadly one or more offshore centres. 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 fiscal NCJ or AML/CFT, the AFD Group policy determines the types of transactions authorised and the types of projects eligible for Group financing: depending on the case, the use of fiscal NCJs is either authorised subject to conditions, or strictly prohibited.

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2020 UNIVERSAL REGISTRATION DOCUMENT