BPCE - 2018 Registration document

2 NON-FINANCIAL PERFORMANCE REPORT Sustainable and responsible value creation

Employees who are not sure that what they are about to do complies with the Code of Conduct should ask the following questions:

Is it legal?

No?

WHISTLEBLOWING

Yes Yes Yes Yes

Groupe BPCE employees can use the internal whistle- blowing procedures in place in all Group entities to report breaches of the rules before they become serious risks. The Group protects whistleblowers. Under no circumstances may they be subject to any disciplinary action or legal proceeding, provided they have acted impartially and in good faith.

Does it observe our policies and procedures?

No?

Does it follow our culture, which puts the long-term interests of our customers and cooperative shareholders first?

No?

Would I feel comfortable explaining my decision to a third party (regulatory authority, the courts) or if I read about it in the media?

No?

Have I considered all the risks at stake for my entity or Groupe BPCE?

No?

Rollout of the code of conduct Once published, all employees will receive training on the code, an ethical governance system will be established, ethics will be incorporated in HR processes, and the code will be aligned with internal procedures. RESPONSIBLE COMPLIANCE APPROACH In accordance with internal control measures and the Group’s risk, compliance and permanent control charter, Groupe BPCE’s Risk, Compliance and Permanent Control division has set up several controls under its financial security and ethics and compliance frameworks.

methods for detecting unusual transactions that are specific to their risk classification. These can be used, if needed, to conduct closer analysis and to submit the required reports to Tracfin (French financial intelligence agency) as promptly as possible. The Group’s risk classification system takes into account “high-risk” countries (listed by the FATF, the OECD Global Forum on Transparency and Exchange of Information for tax purposes, Transparency International, the Directorate General of the French Treasury responsible for areas controlled by terrorist organizations, etc.). With respect to compliance with restrictive measures related to international sanctions, Group institutions are kept informed by BPCE’s Group Financial Security division and equipped with screening tools that generate alerts on customers (asset freezes on certain individuals or entities) and international flows (asset freezes and countries subject to European and/or US embargoes).

Prevention of money laundering and fraud

In accordance with regulations on the organization of internal control at credit institutions and investment companies, the banks have

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Registration document 2018

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