BPCE - 2018 Registration document

2 NON-FINANCIAL PERFORMANCE REPORT Sustainable and responsible value creation

Tasked with identifying the main risks liable to arise in the course of conducting its activities, the working group selected the following two risk approaches: an approach tailored to the activities and operations of BPCE and ● its subsidiaries; an approach specific to the procurement function, developed ● during the update of procurement processes as a whole. Accordingly, in light of these identified risks, and with an obligation to provide resources, reasonable due diligence measures intended to prevent the risk of a serious violation of human rights and fundamental freedoms, or of health, safety or the environment, were identified and/or enhanced. The overall implementation of the due diligence policy will be coordinated by the divisions involved in the working group and placed under the responsibility of the relevant operating divisions. The due diligence plan will be adapted over time as new issues and risks are identified. Due Diligence policy: review of risks and analysis of systems in place to manage these risks To prepare its due diligence plan, the Group reviewed its existing policies and their suitability in terms of the existing assessment tools and risk management approach, across the scope covered by the law. The following scope was considered in terms of the risks incurred by With regard to the Declaration of Human Rights of 1789, the Environment Charter or, more broadly, international law, a risk review was performed in terms of the following issues: issues involving human rights and fundamental freedoms, in ● particular discrimination, inequality, the right to privacy and family life, right to protest, freedom of association, and freedom of opinion; issues involving personal health and safety: health-related risk, ● failure to observe legal working conditions, forced labor, child labor, violation of worker safety and unequal access to healthcare; issues relating to the environment: risk of pollution (water, sea, ● soil), adverse impacts on the fight against global warming or biodiversity, waste management. As a signatory of the Global Compact (advanced level obtained for the second time in 2018), Groupe BPCE has undertaken to uphold the ten associated principles covering human rights, international labor standards, environmental protection and anti-corruption. For the management of its employees, Groupe BPCE is aware that its first scope of responsibility lies in-house and to this end, it has a responsible staff management policy. For the risks incurred by its members of staff – most of whom work in France – the most relevant areas requiring attention in terms of the activities performed by BPCE and its subsidiaries were deemed to be: preventing discrimination and promoting equal opportunities for ● men and women (see Chapter 2.5.1, “Promoting gender equality and diversity” section, and Chapter 2.2.3, “Public commitments made under exacting standards” section); the Group’s activities: its members of staff; ● its business activities. ●

promoting equal opportunities for visible minorities (see ● Chapter 2.5.1, “Equal opportunities” section); preventing discrimination against persons with disabilities (see ● Chapter 2.5.1, “Promoting gender equality and diversity” section, and Chapter 2.2.3, “Public commitments made under exacting standards” section); facilitating social dialog and the freedom of association (see ● Chapter 2.5.1, “Organization of labor dialog at the Groupe BPCE level”, and “Freedom of association and the right to collective bargaining” sections); health and safety in the workplace (see Chapter 2.5.1, ● “Occupational health and safety”, and “Occupational health and safety conditions” sections); non-compliance with legal working conditions (see Chapter 2.5.1, ● “Workplace accidents” section); equal access to law and healthcare (see Chapter 2.5.1, ● “Occupational health and safety” section and Chapter 2.2.3, “Public commitments made under exacting standards” section). These topics are covered by the risk analysis performed for the non-financial performance report: employability and transformation of jobs; ● diversity among employees; ● working conditions. ● These issues are already strictly monitored under existing legislation in France, in particular the Labor Code. Specific commitments or voluntary measures have been implemented for some of these topics, as described in the chapters referred to. As a responsible company, BPCE ensures it applies ethical business practices by fostering a compliance culture among all members of staff through the Groupe BPCE code of conduct and Ethics. This is rounded out by a responsible compliance approach implemented by Financial Security and Compliance: anti-money laundering, anti-fraud and anti-corruption measures (see Chapter 2.4.3, “Prevention of money laundering and fraud” section). This risk is reported in the non-financial performance report in the chapter entitled “Respecting business ethics in all Group business lines”. Regarding the risks relating to discrimination against its customers arising with the distribution of financial products and services, the following topics were identified: preventing discrimination and promoting equal opportunities for ● men and women (see Chapter 2.3.2, “Promoting the development of personal and professional microloans, in partnership with support networks” section); promoting equal opportunities for visible minorities (see ● Chapter 2.3.1, “Helping households and SMEs transform their way of life” section, Chapter 2.3.2, “Financing for the energy, ecological and social transition: offers tailored to our customers’ needs” section, and Chapter 2.2.3, “Public commitments made under exacting standards” section). These topics are covered by the risk analysis performed for the non-financial performance report: financial inclusion; ● financing the real economy and society’s needs; ● more generally, via the risks relating to sustainable customer ● relations and customer protection and the transparency of the product offer. Customers’ right to privacy, data protection and cybersecurity are also points identified in respect of the due diligence action plan. This matter is covered in the non-financial performance report under

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Registration document 2018